Waste Confidence Generic 

Environmental Impact 

Statement

Draft Report for Comment

Office of Nuclear Material Safety and Safeguards

NUREG-2157
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Waste Confidence Generic 

Environmental Impact 

Statement

Draft Report for Comment

Manuscript Completed: August 2013

Date Published: September 2013

Waste Confidence Directorate

Office of Nuclear Material Safety and Safeguards

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

NUREG-2157
1 COMMENTS ON DRAFT REPORT

2

3 Any interested party may submit comments on this report for consideration by the NRC. Please 

4 send comments by the end of the comment period specified in the Federal Register notice 

5 announcing the availability of this report. There are many ways to submit comments on the 

6 draft GEIS.

7 Submit comments online at www.regulations.gov using Docket ID No. NRC–2012–0246

8 E-mail comments to Rulemaking.Comments@nrc.gov, citing Docket ID No. NRC–2012–0246

9 Mail comments to Secretary

10 U.S. Nuclear Regulatory Commission

11 Washington, DC 20555-0001

12 ATTN: Rulemakings and Adjudications Staff

13 Fax comments to Secretary

14 U.S. Nuclear Regulatory Commission

15 301-415-1101, citing Docket ID No. NRC–2012–0246

16

17 Hand-deliver comments to 11555 Rockville Pike, Rockville, Maryland 20852, between 

18 7:30 a.m. and 4:15 p.m. (Eastern Time) on Federal workdays; telephone 301-415-1677.

19

20 For any questions about the material in this report, please contact:

21

22 Sarah Lopas

23 Mail Stop: 3WFN-14C64

24 U.S. Nuclear Regulatory Commission

25 Washington, DC 20555-0001

26 Phone: 301-287-0675

27 E-mail: sarah.lopas@nrc.gov

28

29 Please be aware that any comments that you submit to the NRC will be considered a public 

30 record and entered into the Agencywide Documents Access and Management System 

31 (ADAMS). Do not provide information you would not want to be publicly available.
September 2013 iii Draft NUREG‒2157

1 Abstract

2 In 2010, the Commission published an updated Waste Confidence decision and rule that 

3 included an Environmental Assessment and finding of no significant impact. In response to the 

4 2010 update, several groups filed a lawsuit in the U.S. Court of Appeals for the District of 

5 Columbia Circuit challenging the 2010 Rule on grounds primarily relating to aspects of the 

6 National Environmental Policy Act of 1969, as amended, (NEPA) analysis in the Environmental 

7 Assessment. 

8 The objective of this draft Waste Confidence Generic Environmental Impact Statement (draft 

9 GEIS) is to examine the potential environmental impacts that could occur as a result of the 

10 continued storage of spent nuclear fuel (spent fuel) at at-reactor and away-from-reactor sites 

11 until a repository is available. For the resource areas considered, this draft GEIS attempts to 

12 establish generic impact determinations that would be applicable to a wide range of existing and 

13 potential future spent fuel storage sites. While some site-specific information is used in 

14 developing the generic impact determinations, the NRC does not intend for this draft GEIS to 

15 replace the NEPA analysis associated with any individual site licensing action. 

16 The draft GEIS is intended to improve the efficiency of the NRC’s licensing processes by 

17 (1) providing an evaluation of the environmental impacts that may occur as a result of continuing 

18 to store spent fuel at at-reactor or away-from-reactor sites until a repository is available, 

19 (2) identifying the types and assessing the magnitude of environmental impacts where generic 

20 findings can be established, and (3) providing the regulatory basis for the NRC’s proposed 

21 amendments to regulations in Title 10 of the Code of Federal Regulations Part 51, 

22 “Environmental Protection Regulations for Domestic Licensing and Related Regulatory 

23 Functions.” To accomplish these objectives, the draft GEIS makes maximum use of existing 

24 environmental impact determinations, site-specific data, publicly available literature, and public 

25 comments received during the scoping period for the draft GEIS. 

26 The draft GEIS evaluates alternatives to the proposed action, including a no-action alternative

27 (site-specific licensing review), a GEIS-only option, and a policy statement. The proposed 

28 action would have the same potential environmental impacts as any of the alternatives

29 evaluated. However, as shown in the quantitative analysis of costs, the cost for the proposed 

30 action is less than the cost for any of the alternatives.

September 2013 v Draft NUREG‒2157

Contents

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

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

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

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

Abbreviations/Acronyms .........................................................................................................lxv

Units of Measure ......................................................................................................................lxix

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 .......................................1-5

1.4 Proposed Federal Action..........................................................................................1-5

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

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

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

1.6.2 Other Reasonable Alternatives.....................................................................1-7

1.6.2.1 GEIS-Only Alternative....................................................................1-7

1.6.2.2 Policy-Statement Alternative..........................................................1-8

1.6.3 Alternatives Considered but Eliminated........................................................1-8

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

1.6.3.2 Implementing Additional Regulatory Requirements.......................1-9

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

1.7 Public and Agency Involvement .............................................................................1-10

1.7.1 Scoping Process.........................................................................................1-10

1.7.2 Cooperating Agencies ................................................................................1-11

1.8 Analytical Approach................................................................................................1-11

1.8.1 Approach to Impact Assessment................................................................1-11

1.8.2 Timeframes Evaluated................................................................................1-12

1.8.3 Analysis Assumptions.................................................................................1-13

1.8.4 Other Environmental Analyses ...................................................................1-17

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

1.8.6 Issues Eliminated from Review in this GEIS ..............................................1-23
Contents

Draft NUREG‒2157 vi September 2013

1.8.7 Draft GEIS Contents...................................................................................1-24

1.9 Other Applicable Federal Requirements ................................................................1-25

1.10 References.............................................................................................................1-26

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 .........................................2-1

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...............................................................................................2-4

2.1.1.3 Reactor and Fuel Technologies.....................................................2-5

2.1.2 Onsite Spent Fuel Storage and Handling ...................................................2-10

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

2.1.2.2 At-Reactor Independent Spent Fuel Storage Installations...........2-12

2.1.3 Away-from-Reactor ISFSIs.........................................................................2-17

2.1.4 Dry Transfer System...................................................................................2-19

2.2 Generic Activity Descriptions..................................................................................2-22

2.2.1 Short-Term Storage Activities.....................................................................2-22

2.2.1.1 Decommissioning Activities during Short-Term Storage..............2-22

2.2.1.2 Activities in Spent Fuel Pools ......................................................2-25

2.2.1.3 Activities at At-Reactor ISFSIs.....................................................2-26

2.2.1.4 Activities at Away-from-Reactor ISFSIs.......................................2-27

2.2.2 Long-Term Storage Activities .....................................................................2-27

2.2.2.1 Construction and Operation of a DTS..........................................2-28

2.2.2.2 Replacement of Storage and Handling Facilities.........................2-29

2.2.3 Indefinite Storage Activities ........................................................................2-29

2.3 References.............................................................................................................2-29

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

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

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

3.2.1 Employment and Income.............................................................................. 3-5

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

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

3.2.4 Housing ........................................................................................................ 3-7

3.2.5 Public Services ............................................................................................. 3-7

3.2.6 Transportation .............................................................................................. 3-8
Contents

September 2013 vii Draft NUREG‒2157

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

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

3.4.1 Climate ....................................................................................................... 3-12

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

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

3.5 Geology and Soils .................................................................................................. 3-15

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

3.7 Groundwater Quality and Use................................................................................ 3-17

3.8 Terrestrial Resources ............................................................................................. 3-20

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

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

3.8.3 Wildlife........................................................................................................ 3-22

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 ................................................................. 3-25

3.9.1.3 Marine Ecosystems ..................................................................... 3-25

3.9.2 Aquatic Organisms ..................................................................................... 3-25

3.9.2.1 Fish .............................................................................................. 3-25

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

3.9.2.3 Zooplankton ................................................................................. 3-27

3.9.2.4 Phytoplankton and Aquatic Macrophytes..................................... 3-27

3.9.2.5 Other Aquatic Invertebrates and Vertebrates .............................. 3-27

3.9.2.6 Aquatic Vegetation....................................................................... 3-27

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

3.11 Historic and Cultural Resources............................................................................. 3-29

3.12 Noise ...................................................................................................................... 3-32

3.13 Aesthetics............................................................................................................... 3-33

3.14 Waste Management ............................................................................................... 3-33

3.14.1 Low-Level Radioactive Waste .................................................................... 3-33

3.14.2 Mixed Waste............................................................................................... 3-35

3.14.3 Hazardous Waste ....................................................................................... 3-35

3.14.4 Nonradioactive, Nonhazardous Waste ....................................................... 3-36

3.14.5 Pollution Prevention and Waste Minimization ............................................ 3-36

3.15 Transportation ........................................................................................................ 3-37
Contents

Draft NUREG‒2157 viii September 2013

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

3.16.1 Radiological Exposure................................................................................ 3-38

3.16.1.1 Regulatory Requirements for Occupational Exposure................. 3-38

3.16.1.2 Regulatory Requirements for Public Exposure............................ 3-39

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

3.16.3 Occupational Hazards ................................................................................ 3-41

3.17 References............................................................................................................. 3-41

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

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

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

4.1.2 Long-Term Storage ...................................................................................... 4-5

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

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

4.2.1 Short-Term Storage...................................................................................... 4-7

4.2.2 Long-Term Storage ...................................................................................... 4-8

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 ....................................................................................... 4-17

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

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

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

4.5.3 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

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

September 2013 ix Draft NUREG‒2157

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

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

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

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

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

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

4.8 Groundwater Quality and Use................................................................................ 4-25

4.8.1 Short-Term Storage.................................................................................... 4-25

4.8.1.1 Spent Fuel Pools ......................................................................... 4-25

4.8.1.2 ISFSIs .......................................................................................... 4-27

4.8.1.3 Conclusion ................................................................................... 4-27

4.8.2 Long-Term Storage .................................................................................... 4-27

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

4.9 Terrestrial Resources ............................................................................................. 4-28

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

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

4.9.1.2 ISFSIs .......................................................................................... 4-31

4.9.1.3 Conclusion ................................................................................... 4-32

4.9.2 Long-Term Storage .................................................................................... 4-32

4.9.3 Indefinite Storage ....................................................................................... 4-34

4.10 Aquatic Ecology...................................................................................................... 4-35

4.10.1 Short-Term Storage.................................................................................... 4-35

4.10.1.1 Spent Fuel Pools ......................................................................... 4-35

4.10.1.2 ISFSIs .......................................................................................... 4-41

4.10.1.3 Conclusion ................................................................................... 4-41

4.10.2 Long-Term Storage .................................................................................... 4-42

4.10.3 Indefinite Storage ....................................................................................... 4-42

4.11 Special Status Species and Habitat ....................................................................... 4-43

4.11.1 Short-Term Storage.................................................................................... 4-43

4.11.1.1 Spent Fuel Pools ......................................................................... 4-43

4.11.1.2 ISFSIs .......................................................................................... 4-45

4.11.1.3 Conclusion ................................................................................... 4-45

4.11.2 Long-Term Storage .................................................................................... 4-46

4.11.3 Indefinite Storage ....................................................................................... 4-46

4.12 Historic and Cultural Resources............................................................................. 4-47

4.12.1 Short-Term Storage.................................................................................... 4-48
Contents

Draft NUREG‒2157 x September 2013

4.12.2 Long-Term Storage .................................................................................... 4-49

4.12.3 Indefinite Storage ....................................................................................... 4-50

4.13 Noise ...................................................................................................................... 4-50

4.13.1 Short-Term Storage.................................................................................... 4-50

4.13.2 Long-Term Storage .................................................................................... 4-52

4.13.3 Indefinite Storage ....................................................................................... 4-53

4.14 Aesthetics............................................................................................................... 4-53

4.14.1 Short-Term Storage.................................................................................... 4-53

4.14.2 Long-Term Storage .................................................................................... 4-54

4.14.3 Indefinite Storage ....................................................................................... 4-54

4.15 Waste Management ............................................................................................... 4-55

4.15.1 Short-Term Storage.................................................................................... 4-55

4.15.1.1 Low-Level Radioactive Waste...................................................... 4-55

4.15.1.2 Mixed Waste ................................................................................ 4-56

4.15.1.3 Nonradioactive Waste.................................................................. 4-57

4.15.2 Long-Term Storage .................................................................................... 4-57

4.15.2.1 Low-Level Radioactive Waste...................................................... 4-58

4.15.2.2 Mixed Waste ................................................................................ 4-59

4.15.2.3 Nonradioactive Waste.................................................................. 4-59

4.15.3 Indefinite Storage ....................................................................................... 4-60

4.15.3.1 Low-Level Radioactive Waste...................................................... 4-60

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

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

4.16 Transportation ........................................................................................................ 4-61

4.16.1 Short-Term Storage.................................................................................... 4-61

4.16.2 Long-Term Storage .................................................................................... 4-63

4.16.3 Indefinite Storage ....................................................................................... 4-64

4.17 Public and Occupational Health ............................................................................. 4-64

4.17.1 Short-Term Storage.................................................................................... 4-65

4.17.2 Long-Term Storage .................................................................................... 4-66

4.17.3 Indefinite Storage ....................................................................................... 4-67

4.18 Environmental Impacts of Postulated Accidents .................................................... 4-67

4.18.1 Design Basis Events................................................................................... 4-69

4.18.1.1 Design Basis Events in Spent Fuel Pools.................................... 4-69

4.18.1.2 Design Basis Events in Dry Cask Storage Systems .................... 4-76
Contents

September 2013 xi Draft NUREG‒2157

4.18.1.3 Conclusion ................................................................................... 4-79

4.18.2 Severe Accidents........................................................................................ 4-79

4.18.2.1 Severe Accidents in Spent Fuel Pools......................................... 4-79

4.18.2.2 Severe Accidents in Dry Cask Storage Systems ......................... 4-82

4.18.2.3 Conclusion ................................................................................... 4-83

4.19 Potential Acts of Sabotage or Terrorism ................................................................ 4-84

4.19.1 Attacks on Spent Fuel Pools ...................................................................... 4-85

4.19.2 Attacks on ISFSIs ....................................................................................... 4-87

4.19.3 Conclusion.................................................................................................. 4-89

4.20 Summary ................................................................................................................ 4-90

4.21 References............................................................................................................. 4-91

5.0 Environmental Impacts of Away-From-Reactor Storage............................................5-1

5.1 Land Use..................................................................................................................5-5

5.1.1 Short-Term Storage......................................................................................5-5

5.1.2 Long-Term Storage ......................................................................................5-6

5.1.3 Indefinite Storage .........................................................................................5-7

5.2 Socioeconomics .......................................................................................................5-8

5.2.1 Short-Term Storage......................................................................................5-8

5.2.2 Long-Term Storage ......................................................................................5-9

5.2.3 Indefinite Storage .......................................................................................5-10

5.3 Environmental Justice ............................................................................................5-10

5.3.1 Short-Term Storage....................................................................................5-11

5.3.2 Long-Term Storage ....................................................................................5-13

5.3.3 Indefinite Storage .......................................................................................5-14

5.4 Air Quality...............................................................................................................5-14

5.4.1 Short-Term Storage....................................................................................5-14

5.4.2 Long-Term Storage ....................................................................................5-17

5.4.3 Indefinite Storage .......................................................................................5-17

5.5 Climate Change......................................................................................................5-18

5.5.1 Short-Term Storage....................................................................................5-18

5.5.2 Long-Term Storage ....................................................................................5-20

5.5.3 Indefinite Storage .......................................................................................5-20

5.6 Geology and Soils ..................................................................................................5-20
Contents

Draft NUREG‒2157 xii September 2013

5.6.1 Short-Term Storage....................................................................................5-20

5.6.2 Long-Term Storage ....................................................................................5-21

5.6.3 Indefinite Storage .......................................................................................5-22

5.7 Surface-Water Quality and Use..............................................................................5-22

5.7.1 Short-Term Storage....................................................................................5-22

5.7.2 Long-Term Storage ....................................................................................5-23

5.7.3 Indefinite Storage .......................................................................................5-24

5.8 Groundwater Quality and Use................................................................................5-24

5.8.1 Short-Term Storage....................................................................................5-24

5.8.2 Long-Term Storage ....................................................................................5-25

5.8.3 Indefinite Storage .......................................................................................5-25

5.9 Terrestrial Resources .............................................................................................5-26

5.9.1 Short-Term Storage....................................................................................5-26

5.9.2 Long-Term Storage ....................................................................................5-27

5.9.3 Indefinite Storage .......................................................................................5-28

5.10 Aquatic Ecology......................................................................................................5-28

5.10.1 Short-Term Storage....................................................................................5-28

5.10.2 Long-Term Storage ....................................................................................5-29

5.10.3 Indefinite Storage .......................................................................................5-30

5.11 Special Status Species and Habitats .....................................................................5-30

5.11.1 Short-Term Storage....................................................................................5-30

5.11.2 Long-Term Storage ....................................................................................5-31

5.11.3 Indefinite Storage .......................................................................................5-33

5.12 Historic and Cultural Resources.............................................................................5-33

5.12.1 Short-Term Storage....................................................................................5-34

5.12.2 Long-Term Storage ....................................................................................5-36

5.12.3 Indefinite Storage .......................................................................................5-37

5.13 Noise ......................................................................................................................5-37

5.13.1 Short-Term Storage....................................................................................5-37

5.13.2 Long-Term Storage ....................................................................................5-39

5.13.3 Indefinite Storage .......................................................................................5-40

5.14 Aesthetics...............................................................................................................5-40
Contents

September 2013 xiii Draft NUREG‒2157

5.14.1 Short-Term Storage....................................................................................5-40

5.14.2 Long-Term Storage ....................................................................................5-41

5.14.3 Indefinite Storage .......................................................................................5-41

5.15 Waste Management ...............................................................................................5-42

5.15.1 Short-Term Storage....................................................................................5-42

5.15.2 Long-Term Storage ....................................................................................5-43

5.15.3 Indefinite Storage .......................................................................................5-44

5.16 Transportation ........................................................................................................5-45

5.16.1 Short-Term Storage....................................................................................5-45

5.16.2 Long-Term Storage ....................................................................................5-48

5.16.3 Indefinite Storage .......................................................................................5-50

5.17 Public and Occupational Health .............................................................................5-50

5.17.1 Short-Term Storage....................................................................................5-50

5.17.2 Long-Term Storage ....................................................................................5-51

5.17.3 Indefinite Storage .......................................................................................5-52

5.18 Environmental Impacts of Postulated Accidents ....................................................5-52

5.19 Potential Acts of Sabotage or Terrorism ................................................................5-54

5.20 Summary ................................................................................................................5-54

5.21 References.............................................................................................................5-56

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 ....... 6-9

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

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

Draft NUREG‒2157 xiv September 2013

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 ................................................................................... 6-15

6.4.3 Environmental Justice ................................................................................ 6-16

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....................................................... 6-17

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 ................................................................................... 6-21

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

6.4.5.1 Potential Cumulative Impacts from General Trends and 

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

6.4.5.2 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 ................................................................................... 6-25

6.4.7 Surface-Water Quality and Use.................................................................. 6-25

6.4.7.1 Potential Cumulative Impacts from General Trends and 

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

September 2013 xv Draft NUREG‒2157

6.4.7.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities....................................................... 6-27

6.4.7.3 Conclusion ................................................................................... 6-27

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 Ecology.......................................................................................... 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....................................................... 6-35

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

6.4.11 Historic and Cultural Resources ................................................................. 6-37

6.4.11.1 Potential Cumulative Impacts from General Trends and 

Activities....................................................................................... 6-37

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....................................................................................... 6-40

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 ................................................................................. 6-44
Contents

Draft NUREG‒2157 xvi September 2013

6.4.14 Waste Management ................................................................................... 6-45

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....................................................... 6-47

6.4.14.3 Conclusion ................................................................................... 6-49

6.4.15 Transportation ............................................................................................ 6-50

6.4.15.1 Potential Cumulative Impacts from General Trends and 

Activities....................................................................................... 6-50

6.4.15.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities....................................................... 6-51

6.4.15.3 Conclusion ................................................................................... 6-53

6.4.16 Public and Occupational Health ................................................................. 6-53

6.4.16.1 Potential Cumulative Impacts from General Trends and 

Activities....................................................................................... 6-53

6.4.16.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities....................................................... 6-54

6.4.16.3 Conclusion ................................................................................... 6-55

6.4.17 Environmental Impacts of Postulated Accidents ........................................ 6-55

6.4.17.1 Potential Cumulative Impacts from General Trends and 

Activities....................................................................................... 6-55

6.4.17.2 Potential Cumulative Impacts from Other NRC-Regulated or 

Spent Fuel-Related Activities....................................................... 6-56

6.4.17.3 Conclusion ................................................................................... 6-57

6.5 Summary ................................................................................................................ 6-57

6.6 References............................................................................................................. 6-59

7.0 Cost-Benefit Analysis....................................................................................................7-1

7.1 Assumptions.............................................................................................................7-2

7.1.1 New Reactor Applications ............................................................................7-3

7.1.2 Reactor License Renewal.............................................................................7-5

7.1.3 ISFSI Licensing ............................................................................................7-6

7.2 Estimated Costs and Benefits of the No-Action Alternative .....................................7-7

7.3 Estimated Costs and Benefits of the Proposed Action.............................................7-8

7.4 Estimated Costs and Benefits of the GEIS-Only Alternative ....................................7-9

7.5 Estimated Costs and Benefits of the Policy Statement Alternative ........................7-11

7.6 Comparison of Alternatives ....................................................................................7-13

7.7 References.............................................................................................................7-16
Contents

September 2013 xvii Draft NUREG‒2157

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

8.1 Comparison of Environmental Impacts .................................................................... 8-2

8.2 Unavoidable Adverse Environmental Impacts.......................................................... 8-5

8.3 Irreversible and Irretrievable Commitments of Resources ....................................... 8-8

8.4 Relationship between Short-Term Uses of the Environment and the 

Maintenance and Enhancement of Long-Term Productivity .................................... 8-9

8.5 Proposed Action and Alternatives .......................................................................... 8-10

8.6 Cost-Benefit Balance.............................................................................................. 8-11

8.7 Recommendation ................................................................................................... 8-12

8.8 References............................................................................................................. 8-12

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

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

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 Comments 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

September 2013 xix Draft NUREG‒2157

Figures

ES-1 Three Storage Timeframes Addressed in the Waste Confidence Draft GEIS and 

the Major Assumptions for Each Timeframe................................................................. xxviii 

1-1 Continued Storage Timeframes.....................................................................................1-12

1-2 NEPA Analyses for Other NRC Activities ......................................................................1-18

2-1 Dry Storage of Spent Fuel .............................................................................................2-13

2-2 Licensed/Operating ISFSIs by State..............................................................................2-15

2-3 Conceptual Sketches of a Dry Transfer System............................................................2-20

2-4 Continued Storage Timeline ..........................................................................................2-23

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

September 2013 xxi Draft NUREG‒2157

Tables

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

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

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

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

ES-5 Summary of Cumulative Effects for Continued Storage of Spent Fuel.............................. lvi 

1-1 List of NEPA Documents Used in Preparation of this Draft GEIS ................................. 1-19

2-1 U.S. Pressurized Water Reactors with Shared Spent Fuel Pools ...................................2-5

2-2 Stainless-Steel-Clad Fuel at Decommissioning Plants....................................................2-7

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 ........................... 3-39

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

the U.S. Population for 2006.......................................................................................... 3-40

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

4-2 Summary of Environmental Impacts of Continued At-Reactor Storage......................... 4-90

5-1 Summary of Environmental Impacts of Continued Away-from-Reactor Storage...........5-55

6-1 General Trends and Human Activities Occurring at or near Storage Facilities ............... 6-5

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

6-3 Summary of Incremental Impacts from Continued Storage on Waste Management..... 6-45

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

Other Federal and Non-Federal Activities ..................................................................... 6-58

7-1 Constant and Discounted Estimated Costs of the No-Action Alternative ........................7-7

7-2 Constant and Discounted Estimated Costs of the Proposed Action................................7-9

7-3 Constant and Discounted Estimated Costs of the GEIS-Only Alternative .....................7-10

7-4 Constant and Discounted Estimated Costs of the Policy-Statement Alternative ...........7-12

7-5 Summary of Constant and Discounted Estimated Costs for Each Alternative ..............7-13

7-6 Summary of Unquantified Costs and Benefits of Each Alternative................................7-15

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 ISFSI .................................................................................................................. 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 ............................................................................................. 9-4

September 2013 xxiii Draft NUREG‒2157

1 Executive Summary

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

3 draft Waste Confidence Generic Environmental Impact Statement (draft GEIS). It briefly 

4 discusses the proposed action, alternatives to the proposed action, the environmental impacts 

5 of the proposed action and alternatives (including the NRC's analysis of spent fuel pool leaks

6 and fires), and the major conclusions and the NRC’s preliminary recommendation to the 

7 Commission. The summary ends with next steps in the Waste Confidence rulemaking and how 

8 the public can comment on the draft GEIS and proposed Waste Confidence rule.

9 ES.1 What is Waste Confidence? 

10 Historically, Waste Confidence has been the NRC’s generic 

11 determination regarding the safety and environmental 

12 impacts of storing spent nuclear fuel (spent fuel) beyond the 

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

14 Commission has incorporated the generic determination in 

15 its regulations at Title 10 of the Code of Federal Regulations

16 (CFR) 51.23, which satisfied the NRC’s obligations under 

17 the National Environmental Policy Act of 1969, as amended, 

18 (NEPA) with respect to the continued storage of spent fuel 

19 for commercial reactor licenses, license renewals, and spent fuel storage facility licenses and 

20 license renewals.

21 ES.2 Why has the NRC Developed a Draft Generic 

22 Environmental Impact Statement?

23 Since the Waste Confidence rule was 

24 originally developed in 1984, the NRC has 

25 periodically updated the rule, with the last 

26 update completed in 2010. A number of 

27 parties challenged the 2010 Waste 

28 Confidence rule in court, and in June 2012, 

29 the Court of Appeals for the District of 

30 Columbia (D.C.) Circuit ruled that the 

31 2010 Waste Confidence rulemaking did not 

32 satisfy the NRC’s NEPA obligations. The 

33 Court identified deficiencies in the 

34 2010 Waste Confidence rule and supporting 

Waste Confidence 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. 

This timeframe is referred to as 

“continued storage” throughout 

this draft GEIS.

To comply with The National Environmental 

Policy Act of 1969 (NEPA) Federal agencies:

• assess the environmental impacts of major 

Federal actions

• consider the environmental impacts in making 

decisions

• disclose the environmental impacts to the 

public

The Waste Confidence rulemaking is a major 

Federal action that requires a NEPA review.
Executive Summary

Draft NUREG‒2157 xxiv September 2013

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

2 environmental impacts should a repository not become available. 

3 In response to the Court’s ruling, the Commission decided that the NRC would not issue any 

4 final licenses that relied upon the Waste Confidence rule until the NRC addresses the 

5 deficiencies identified by the Court (Commission Order CLI–12–16). The Commission also 

6 directed the staff to develop an updated Waste Confidence decision and rule supported by an 

7 environmental impact statement. The staff has prepared this draft GEIS to satisfy its NEPA

8 obligations regarding the impacts of continued storage of spent fuel. The draft GEIS provides a 

9 regulatory basis for the proposed revision of the Waste Confidence rule. Chapter 1 of the draft 

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

11 ES.3 What is the Proposed Action Being Addressed in this 

12 Draft GEIS? 

13 The proposed action is to issue a rule, 

14 10 CFR 51.23, that generically addresses the 

15 environmental impacts of continued spent fuel 

16 storage by incorporating into rule the conclusions of 

17 the final version of this draft GEIS. If the proposed 

18 Rule is adopted, the site-specific NEPA analyses for 

19 future commercial power reactor and spent fuel 

20 storage facility licensing actions would not need to 

21 consider the environmental impacts of continued 

22 storage.

23 ES.4 What is the Purpose and 

24 Need for the Proposed 

25 Action? 

26 The purpose and need for the proposed action are identified below: 

27 1. to improve the efficiency of the NRC’s licensing process by generically addressing the 

28 environmental impacts of continued storage

29 2. to prepare a single document that reflects the NRC’s current understanding of these 

30 environmental impacts

31 3. to address the deficiencies in the 2010 Waste Confidence rule identified by the U.S. Court of 

32 Appeals for the D.C. Circuit

Why is the NRC evaluating Waste 

Confidence on a generic basis?

The NRC considers the continued storage 

of spent fuel a generic 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‒1437), 

the Decommissioning GEIS

(NUREG‒0586), and the In-Situ Leach 

Uranium Milling Facilities GEIS 

(NUREG‒1910).
Executive Summary

September 2013 xxv Draft NUREG‒2157

1 ES.5 What is Covered in the Draft GEIS?

2 The draft GEIS analyzes the environmental impacts of continued storage of spent fuel. The 

3 NRC has looked at the direct, indirect, and cumulative effects of continued storage for three 

4 spent fuel storage timeframes—short-term, long-term, and indefinite. These timeframes are 

5 defined below and are discussed in more detail in Section 1.8.2 of the draft GEIS. The 

6 analyses contained in this draft GEIS provide a regulatory basis for the proposed revisions to 

7 10 CFR 51.23.

8 ES.6 What is Not Covered in the Draft GEIS?

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

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

11 topics include:

12 • noncommercial spent fuel (e.g., defense waste)

13 • commercial high-level waste generated from reprocessing

14 • Greater-than-Class-C waste

15 • foreign spent fuel stored in the United States

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

17 fuel stored in the United States)

18 • need for nuclear power

19 • reprocessing of commercial spent fuel

20 ES.7 Are There Alternatives to the Waste Confidence

21 Rulemaking? 

22 Alternatives to the proposed action, a revision to the Waste Confidence rule, are discussed in 

23 Section 1.6 of the draft GEIS. The NRC looked at the following three alternatives to revising the 

24 Waste Confidence rule:

25 1. The No-Action Alternative. The NRC would take no action to generically address the 

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

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

28 2. The GEIS-Only Alternative. The NRC would prepare a GEIS to analyze the environmental 

29 impacts of continued storage that would then support site-specific licensing reviews. There 

30 would be no Waste Confidence rule, so site-specific EISs or environmental assessments 

31 would incorporate the GEIS by reference or adopt the conclusions in the GEIS.
Executive Summary

Draft NUREG‒2157 xxvi September 2013

1 3. The Policy Statement Alternative. The Commission would issue a policy statement that 

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

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

4 NRC licensing action.

5 The NRC determined that the environmental impacts of these three alternatives were essentially 

6 the same because, in each alternative, the NRC would analyze the environmental impacts of 

7 continued storage. The NRC’s preliminary conclusion is to revise 10 CFR 51.23 because of the 

8 efficiencies that would be gained in reactor and spent fuel storage facility licensing reviews. 

9 Revising the Waste Confidence rule minimizes expenditures on site-specific reviews, limits the 

10 potential for lengthy project delays, and provides for the same level of environmental protection 

11 as the other alternatives.

12 During the scoping period for the draft GEIS, the NRC 

13 received many suggested alternatives to the Waste 

14 Confidence rulemaking, including calls for halting NRC 

15 licensing activities and shutting down operating reactors 

16 or imposing new requirements on nuclear power plants, 

17 such as storing spent fuel in special hardened onsite 

18 storage, reducing spent fuel pool density, and 

19 accelerating the transfer of spent fuel from pools to dry 

20 casks. The NRC determined that halting NRC licensing 

21 and closing nuclear reactors would not meet the purpose 

22 and need of the proposed rulemaking action. The NRC also determined that additional 

23 requirements on spent fuel storage would not meet the purpose and need. Further, the draft 

24 GEIS is a NEPA review and not a licensing action; therefore, this draft GEIS would not be the 

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

26 ES.8 Did the NRC Involve the Public or Governmental 

27 Organizations? 

28 The NRC announced that it was 

29 planning to develop an EIS and 

30 requested comments on the proposed 

31 scope of the draft GEIS in a Federal 

32 Register Notice that was published on 

33 October 25, 2012 (77 FR 65137). 

34 Publication of this notice began a 

35 70-day public comment period for 

36 scoping. The NRC also issued press 

37 releases, sent scoping letters to Tribal governments and State liaisons, and sent e-mails to 

The Waste Confidence rulemaking is

not a licensing action. 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 site-specific 

licensing process.

At the end of the 70-day scoping period, the NRC 

summarized what it heard and responded to public 

comments in its Scoping Summary Report, which can be 

accessed at 

http://pbadupws.nrc.gov/docs/ML1306/ML13060A128.pdf. 

A separate document at 

http://pbadupws.nrc.gov/docs/ML1306/ML13060A130.pdf

lists the comments the NRC received, organized by 

category.
Executive Summary

September 2013 xxvii Draft NUREG‒2157

1 approximately 1,050 stakeholders who had previously expressed interest in matters related to 

2 high-level waste. The NRC conducted four public scoping meetings that were all accessible via 

3 Internet and telephone, so people from all over the country could participate and give their 

4 comments on the scope of the Waste Confidence draft GEIS. In November 2012, the NRC met 

5 with representatives of the U.S. Environmental Protection Agency (EPA) to discuss the Waste 

6 Confidence rulemaking. The NRC also held a government-to-government meeting with the 

7 Prairie Island Indian Community in June 2013. Future meetings with these groups are also 

8 planned. There are no formal cooperating agencies identified in the Waste Confidence 

9 environmental review.

10 Section 1.7, Appendix A, and Appendix C of the draft GEIS discuss public and agency 

11 involvement in the Waste Confidence environmental review. The Scoping Summary report also 

12 provides information about the NRC’s scoping activities and what the NRC heard during the 

13 scoping process.

14 ES.9 How did the NRC Evaluate the Continued Storage of 

15 Spent Fuel in this Draft GEIS? 

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

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

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

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

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

21 see Section 1.8.2 of the draft GEIS.

22 As discussed above and in the draft GEIS, the NRC has analyzed three timeframes that 

23 represent various scenarios for the length of continued storage that will be needed before spent 

24 fuel is sent to a repository. The first, most likely, timeframe is the short-term timeframe, which 

25 analyzes 60 years of continued storage after the end of a reactor’s licensed life for operation. 

26 The NRC acknowledges, however, that the short-term timeframe, although the most likely, is not 

27 certain. Accordingly, the draft GEIS also analyzed two additional timeframes. The long-term 

28 timeframe considers the environmental impacts of continued storage for a total of 160 years 

29 after the end of a reactor’s licensed life for operation. Finally, although the NRC considers it 

30 highly unlikely, the draft GEIS includes an analysis of an indefinite timeframe, which assumes 

31 that a repository does not become available.
Executive Summary

Draft NUREG‒2157 xxviii September 2013

1

2 Figure ES-1. Three Storage Timeframes Addressed in the Waste Confidence Draft GEIS 

3 (Short-Term, Long-Term, and Indefinite Storage) and the Major Assumptions for 

4 Each Timeframe

5 To guide its analysis, the NRC also relied upon certain 

6 assumptions regarding the storage of spent fuel. A 

7 detailed discussion of these assumptions is contained 

8 in Section 1.8.3 of the draft GEIS. Some of these 

9 assumptions are listed below:

10 • Institutional controls would be in place.

11 • Spent fuel canisters and casks would be replaced 

12 approximately once every 100 years.

13 • Independent spent fuel storage installation (ISFSI) 

14 and dry transfer system (DTS) facilities would also 

15 be replaced approximately once every 100 years.

16 • A DTS would be built at each ISFSI location for 

17 fuel repackaging. 

18 • All spent fuel would be moved from spent fuel 

19 pools to dry storage by the end of the short-term 

20 storage timeframe (60 years).

21 • The analyses in the draft GEIS are based on current technology and regulations.

An ISFSI (independent spent fuel 

storage installation) is a facility designed 

and constructed for the interim storage of 

spent fuel. Typically, spent fuel is stored 

in dry cask storage systems. In 

accordance with NRC requirements, dry 

cask storage shields people and the 

environment from radiation and keeps the 

spent fuel inside dry and nonreactive.

A dry transfer system would be built at 

ISFSI sites (at-reactor or away-fromreactor) 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

September 2013 xxix Draft NUREG‒2157

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

2 impact determinations in this draft GEIS. Chapter 1 of the draft GEIS includes a list of NEPA

3 documents used in the development of the draft GEIS, and the end of each chapter includes a 

4 complete list of references. References are publicly available, and most are available in the 

5 NRC’s Agencywide Documents Access and Management System (ADAMS).

6 The ADAMS electronic public reading room is available at http://www.nrc.gov/reading7 rm/adams.html. If you encounter issues accessing ADAMS, call the NRC at 1-800-397-4209 or 

8 301-415-4737, or send an e-mail to pdr.resource@nrc.gov.

9 ES.10 What Facilities and Activities are Addressed in the 

10 Draft GEIS?

11 Chapter 2 of the draft GEIS describes typical facility 

12 characteristics and activities that the NRC used to assess 

13 the environmental impacts of continued storage of spent 

14 fuel. The draft GEIS looked at spent fuel storage at single15 and multiple-reactor nuclear power plant sites, in spent fuel 

16 pools, at-reactor ISFSIs, and away-from-reactor ISFSIs. In 

17 addition to existing reactor designs and conventional spent 

18 fuel, the NRC also considered reactor and fuel technologies 

19 such as mixed oxide fuel (MOX) and small modular 

20 reactors.

21 Section 2.2 of the draft GEIS describes the activities related 

22 to the storage of spent fuel that are expected to occur 

23 during the three storage timeframes (short-term, long-term, 

24 and indefinite):

25 • The short-term storage timeframe (60 years beyond the 

26 licensed life for operation of the reactor) includes routine 

27 maintenance and monitoring of the spent fuel pool and 

28 ISFSI and transferring spent fuel from pools to dry cask storage. Because decommissioning

29 is normally completed within 60 years after a reactor shuts down, the NRC assumes that all 

30 spent fuel will be moved from spent fuel pools to dry cask storage by the end of the short31 term storage timeframe. For an away-from-reactor ISFSI, this timeframe includes 

32 construction and operation, including routine maintenance and monitoring, at the facility.

33 • The long-term storage timeframe (100 years beyond the initial 60-year (short-term) storage 

34 timeframe) includes activities such as continued facility maintenance, construction and 

35 operation of a DTS, and replacement of ISFSI and DTS facilities, including casks.

MOX (mixed oxide 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 size 

(e.g., 300 MW(e)) than current 

generation baseload plants 

(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 site.
Executive Summary

Draft NUREG‒2157 xxx September 2013

1 • Indefinite storage (i.e., no repository is available) assumes that the activities associated with 

2 long-term storage continue indefinitely, with ISFSI and DTSs facilities being replaced at 

3 least once every 100 years.

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

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

6 2001, terrorist attacks and the March 11, 2011, earthquake and tsunami in Japan. Appendix B 

7 of the draft GEIS discusses a number of ongoing regulatory program reviews that ensure the 

8 safety and security of spent fuel storage and transportation.

9 ES.11 How did the NRC Describe Environmental Impacts? 

10 NRC used terms in other NEPA documents, such as those for license renewal or new reactors, 

11 for defining the standard of significance for assessing environmental issues.

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

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

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

15 destabilize, important attributes of the resource.

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

17 destabilize important attributes of the resource.

18 For risk-based determinations (such as in the NRC’s 

19 analyses of severe accidents such as spent fuel pool 

20 fires), the probability of occurrence as well as the 

21 potential consequences have been factored into the 

22 determination of significance.

23 For some resource areas, the impact determination 

24 language is specific to the authorizing regulation (e.g., 

25 “not likely to adversely impact” for endangered 

26 species).

NRC's concept of risk combines the 

probability of an accident with the 

consequences of that accident. In other 

words, the NRC examines the following 

questions:

• What can go wrong? 

• How likely is it? 

• What would be the consequences? 

More information can be found at 

http://www.nrc.gov/aboutnrc/regulatory/risk-informed.html.
Executive Summary

September 2013 xxxi Draft NUREG‒2157

1 ES.12 What Environmental Resource Areas did the NRC 

2 Consider? 

3 Chapter 3 of the draft GEIS discusses the environment that exists at and around the facilities 

4 where spent fuel is stored in spent fuel pools and at-reactor ISFSIs. The description of 

5 resources in Chapter 3 provides information that is incorporated into the analyses of 

6 environmental impacts of continued storage in Chapter 4 (at-reactor impacts) and Chapter 6 

7 (cumulative impacts). The License Renewal GEIS (NUREG‒1437, Volumes 1 and 2, Revision 

8 1) was the primary source of information in Chapter 3. The NRC also referenced information 

9 from site-specific environmental reviews, such as those for initial and renewal ISFSI licenses, 

10 the renewal of operating licenses, and operating licenses for new reactors.

11 The affected resource areas and attributes discussed in the draft GEIS are listed in Table ES-1.

12 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; the presence of minority and lowincome 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

Description of historic and cultural resources that could occur at nuclear power 

plant sites; compliance with Section 106 of the National Historical Preservation 

Act of 1966

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

13
Executive Summary

Draft NUREG‒2157 xxxii September 2013

1 Table ES-1. Affected Resource Areas for At-Reactor Spent Fuel Storage (cont’d)

Affected 

Resource Area Attributes

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

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.

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

3 ISFSI are discussed in Chapter 5 (away-from-reactor impacts). The analysis of away-from4 reactor spent fuel storage in Chapter 5 is based, in general, on the description of the affected 

5 environment provided in Chapter 3. However, some aspects of those discussions would not be 

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

7 affected resource areas and attributes discussed in Chapter 5 of the draft GEIS are listed in 

8 Table ES-2.

9 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 around locations 

meeting the siting evaluation factors of 10 CFR Part 72, Subpart E, including 

employment, taxes, public services, housing demand, and traffic

Environmental 

Justice

The potential presence of minority and low-income populations; subsistence 

consumption of fish and wildlife around locations meeting the siting evaluation 

factors of 10 CFR Part 72, Subpart E.

Climate and Air 

Quality

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

greenhouse gases

Geology and Soils The physical setting of locations meeting the siting evaluation factors of 

10 CFR Part 72, Subpart E and associated geologic strata and soils; the different 

physiographic provinces in the United States

Water Resources Surface-water and groundwater use and quality around locations meeting the 

siting evaluation factors of 10 CFR Part 72, Subpart E

10
Executive Summary

September 2013 xxxiii Draft NUREG‒2157

1 Table ES-2. Affected Resource Areas for Away-From-Reactor Spent Fuel Storage (cont’d)

Affected 

Resource Area Attributes

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

A description of historic and cultural resources, including traditional cultural 

properties; compliance with the National Historical Preservation Act of 1966, 

Section 106; results of a historic and cultural resources survey for the Private 

Fuel Storage, LLC, application for an away-from-reactor ISFSI

Noise Ambient noise levels around general construction sites and as discussed in the 

Private Fuel Storage, LLC, application for an away-from-reactor ISFSI

Aesthetics The existing scenic quality of locations meeting the siting evaluation factors of 

10 CFR Part 72, Subpart E, 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

Transportation Transportation characteristics of locations meeting the siting evaluation factors of 

10 CFR Part 72, Subpart E; 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.

2 ES.13 What are the Environmental Effects of Continued 

3 Storage? 

4 Chapter 4 of the draft GEIS addresses potential environmental impacts of at-reactor continued 

5 storage in spent fuel pools and at-reactor ISFSIs. Chapter 5 addresses impacts at away-from6 reactor ISFSIs. As applicable for each resource area, impact determinations were made for 

7 each of the three spent fuel storage timeframes: short-term, long-term, and indefinite. The 

8 following pages provide a short synopsis of impacts, followed by summary tables (Tables ES-3 

9 and ES-4). At-reactor impacts of continued storage are addressed first, followed by away-from10 reactor impacts.
Executive Summary

Draft NUREG‒2157 xxxiv September 2013

1 ES.13.1 Environmental Impacts of At-Reactor Spent Fuel Storage

2 ES.13.1.1 Land Use

3 Short-Term Storage. Impacts would be SMALL. Sixty years of continued at-reactor storage in a 

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

5 maintenance activities that would change land use. 

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

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

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

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

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

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

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

13 part of the cyclic replacements.

14 ES.13.1.2 Socioeconomics

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

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

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

18 services.

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

20 1 to 2 years and the size of the construction and ISFSI replacement and operations workforce 

21 would be small. Tax payments would continue and would remain relatively constant at post22 operations levels. Additionally, there would be no increased demand for housing and public 

23 services.

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

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

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

27 onsite.

28 ES.13.1.3 Environmental Justice

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

30 ISFSIs would have minimal human health and environmental effects on minority and low31 income populations. As previously discussed for other resource areas, the overall contributory 

32 human health and environmental effects from continued short-term spent fuel storage would be 
Executive Summary

September 2013 xxxv Draft NUREG‒2157

1 limited in scope and SMALL for all populations. Therefore, minority and low-income populations 

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

3 environmental effects from the continued short-term storage of spent fuel.

4 Long-Term Storage. The continued maintenance and monitoring of spent fuel in at-reactor 

5 ISFSIs would have minimal human health and environmental effects on minority and low6 income populations near these storage facilities. As previously discussed for other resource 

7 areas, the overall contributory human health and environmental effects from continued long8 term spent fuel storage would be limited in scope and SMALL for all populations, except for 

9 historic and cultural resources where impacts could be SMALL, MODERATE, or LARGE. The 

10 magnitude of adverse effect on historic properties and impact on historic and cultural resources 

11 largely depend site-specific conditions. Measures such as implementation of historic and 

12 cultural resource plans and procedures, agreements, and license conditions can be used to 

13 avoid, minimize, or mitigate adverse effects. Therefore, minority and low-income populations 

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

15 environmental effects from the continued long-term storage of spent fuel.

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

17 would have minimal human health and environmental effects on minority and low-income 

18 populations near these storage facilities. As previously discussed for the other resource areas, 

19 the overall contributory human health and environmental effects from the indefinite storage of 

20 spent fuel storage would be limited in scope and SMALL for all populations, except for historic 

21 and cultural resources where impacts could be SMALL, MODERATE, or LARGE. If 

22 replacement activities occur in previously disturbed areas, then impacts to historic and cultural 

23 resources would be SMALL. Therefore, historic properties would not be adversely affected. If 

24 construction activities occur in previously undisturbed areas or avoidance is not possible, then 

25 there could be adverse effects to historic properties, and impacts to historic and cultural 

26 resources could be SMALL, MODERATE, or LARGE depending on site-specific factors. 

27 Minority and low-income populations are not expected to experience disproportionately high and 

28 adverse human health and environmental effects from the indefinite storage of spent fuel.

29 ES.13.1.4 Air Quality

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

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

32 smaller than air emissions during power generation. Heat released to the atmosphere from the 

33 dry casks would not be different than temperature changes that occur naturally.

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

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

36 would result in minor and temporary air emissions. Heat released to the atmosphere from the 

37 dry casks would decrease throughout this period as decay heat diminishes.
Executive Summary

Draft NUREG‒2157 xxxvi September 2013

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

2 storage ISFSI and DTS operation and replacement activities would result in minor and 

3 temporary air emissions. Heat released to the atmosphere from the dry casks would decrease 

4 as the spent fuel cools over time.

5 ES.13.1.5 Climate Change

6 Short-Term Storage. Impacts would be SMALL. The 

7 annual level of greenhouse gases generated during 

8 continued storage is a small percentage of the annual 

9 levels generated in the United States.

10 Long-Term Storage. Impacts would be SMALL. 

11 Impacts would be similar to short-term impacts, and greenhouse gas emissions would be a 

12 small fraction of the overall level in the United States.

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

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

15 United States.

16 ES.13.1.6 Geology and Soils

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

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

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

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

21 of spent fuel pools and ISFSIs.

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

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

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

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

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

27 impacts to geology would be expected.

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

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

30 and would minimize impacts to soils and geology.

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 2013 xxxvii Draft NUREG‒2157

1 ES.13.1.7 Surface-Water Quality and Use

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

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

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

5 pools and ISFSIs would be less than for normal plant operations.

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

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

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

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

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

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

12 ES.13.1.8 Groundwater Quality and Use

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

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

15 nonradiological and radiological impacts to groundwater quality, including tritium contamination. 

16 Appendix E of the draft GEIS contains additional supporting analysis of the environmental 

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

18 a leak of sufficient quantity and duration to affect offsite locations and (2) site hydrologic 

19 characteristics and monitoring programs ensure that impacts from spent fuel pool leaks would 

20 be unlikely. Impacts to groundwater from continued storage in ISFSIs would be minimal 

21 because ISFSI storage requires minimal water and produces minimal, localized, and easy-to22 remediate liquid effluents on or near ground surface.

23 Long-Term Storage. Impacts would be SMALL. Construction of a DTS would require minimal 

24 groundwater use. With regard to storage facility-replacement activities, groundwater 

25 consumptive use and quality impacts would be similar to those for initial construction of the 

26 facilities, and would be minor and temporary.

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

28 storage. Once every 100 years, groundwater would be required for demolishing and replacing 

29 the ISFSI and DTS facilities. Consumptive use of groundwater and water-quality impacts would 

30 be minor and temporary.

31 ES.13.1.9 Terrestrial Resources

32 Short-Term Storage. Impacts would be SMALL. Impacts associated with the operation of spent 

33 fuel pools would likely be bounded by the impacts analyzed in the License Renewal GEIS for 
Executive Summary

Draft NUREG‒2157 xxxviii September 2013

1 those issues that were addressed generically in the License Renewal GEIS. For the issue of 

2 water-use conflicts with terrestrial resources at plants with cooling ponds or cooling towers using 

3 makeup water from a river, the NRC determined that the impacts from operating the spent fuel 

4 pool during the short-term storage timeframe would be minimal, because the water withdrawal 

5 requirements for spent fuel pool cooling are considerably lower than those for a power reactor. 

6 Impacts associated with operating an at-reactor ISFSI would be minimal and similar to those 

7 described in example Environmental Assessments reviewed for the GEIS.

8 Long-Term Storage. Impacts would be SMALL. Construction, repackaging, and replacement 

9 activities for the ISFSI and DTS would have minimal impacts on terrestrial resources. Based on 

10 a review of example Environmental Assessments, normal operations and replacement of DTS 

11 and ISFSI facilities would not generate significant noise, would not significantly affect the area 

12 available for terrestrial wildlife, and would not adversely impact terrestrial environments or their 

13 associated plant and animal species.

14 Indefinite Storage. Impacts would be SMALL. Impacts would be similar to long-term storage 

15 impacts. Replacement of the ISFSI and DTS facilities would likely occur on land near the

16 existing facilities and could be sited on previously disturbed ground and away from terrestrial 

17 species and habitat.

18 ES.13.1.10 Aquatic Ecology

19 Short-Term Storage. Impacts would be SMALL. Impacts associated with the operation of spent 

20 fuel pools would likely be minimal and bounded by the impacts analyzed in the License Renewal

21 GEIS because of the lower withdrawal rates, lower discharge rates, and smaller thermal plume

22 for a spent fuel pool compared to an operating reactor with closed-cycle cooling. Impacts from 

23 operation of onsite ISFSIs would be minimal because ISFSIs do not require water for cooling, 

24 and ground-disturbing activities would have minimal impacts on aquatic ecology.

25 Long-Term Storage. Impacts would be SMALL. Construction, repackaging, and replacement 

26 activities for the ISFSI and DTS would have minimal impacts on aquatic resources. The ISFSI 

27 and DTS would not require water for cooling, would produce minimal gaseous or liquid effluents, 

28 and would have minimal impacts on aquatic resources.

29 Indefinite Storage. Impacts would be SMALL. Activities and impacts to aquatic resources 

30 would be similar those described for long-term storage, although complete repackaging would 

31 occur once every 100 years. Replacement of ISFSI and DTS facilities would occur on land near

32 existing facilities and could likely be sited on previously disturbed ground and away from 

33 sensitive aquatic features.
Executive Summary

September 2013 xxxix Draft NUREG‒2157

1 ES.13.1.11 Special Status Species and Habitat

2 Short-Term Storage. The Endangered Species Act 

3 (ESA) has several requirements that would help ensure 

4 protection of listed species and critical habitat beyond 

5 the licensed term of the reactor during short-term 

6 storage. In complying with the ESA, the NRC would 

7 evaluate the impacts from spent fuel pool construction, 

8 operations, and decommissioning in a site-specific 

9 review before the spent fuel pool is initially constructed 

10 and operated. ESA protection would continue during 

11 the short-term storage timeframe. NRC would be 

12 required to reinitiate consultation with the U.S. Fish and 

13 Wildlife Service (FWS) or the National Marine Fisheries 

14 Service (NMFS) if the cooling system parameters 

15 change, if a “take” occurs for a species not included in 

16 an incidental take permit, or if a new species is listed under the ESA. In addition, the NRC 

17 would either need to continue to require the licensee to abide by the conditions described in the 

18 Biological Opinion or reinitiate consultation.

19 With regard to dry cask storage of spent fuel, given the small size and ability to site ISFSI 

20 facilities away from sensitive ecological resources, the NRC concludes that continued storage of 

21 spent fuel in at-reactor ISFSIs is not likely to adversely affect listed species or critical habitat. In 

22 the unlikely situation that ISFSIs could affect listed species or critical habitat, the NRC would be 

23 required to initiate consultation with the NMFS or the FWS. 

24 Long-Term Storage. In addition to routine maintenance and monitoring of ISFSIs, impacts from 

25 the construction of a DTS and replacement of the DTS and ISFSIs on special status species 

26 and habitat would be minimal because of the small size of the ISFSI and DTS facilities and 

27 because no water is required for cooling. NRC assumes that the ISFSI and DTS facilities could 

28 be sited to avoid listed species and critical habitat because of the small size of the construction 

29 footprint and sufficient amount of previously disturbed areas on most nuclear power plant sites. 

30 Therefore, the NRC concludes that construction of a DTS and replacement of the DTS and 

31 ISFSI that would occur during the long-term storage timeframe are not likely to adversely affect 

32 listed species or critical habitat, or essential fish habitat. In the unlikely situation that the ISFSI 

33 could affect listed species or critical habitat, the NRC would be required to initiate Section 7 

34 ESA consultation with the NMFS or FWS for listed species or critical habitat, and consult with 

35 the NMFS for essential fish habitat.

36 Indefinite Storage. Impacts from indefinite storage on special status species and habitat would 

37 be minimal. The same consultation and any associated mitigation requirements described for 

38 the short-term storage timeframe would apply to the construction of the DTS and replacement of 

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 any 

listed species. Under Section 7, the 

NRC must consult with the U.S. Fish and 

Wildlife Service or National Marine 

Fisheries Service when any action NRC

carries out, funds, or authorizes (such as 

through a permit) may affect a listed 

endangered or threatened species.
Executive Summary

Draft NUREG‒2157 xl September 2013

1 the DTS and ISFSI facilities during indefinite storage. NRC concludes that the replacement of 

2 the DTS and ISFSI that would occur during the indefinite storage timeframe is not likely to 

3 adversely affect listed species or critical habitat, or essential fish habitat. In the unlikely 

4 situation that the ISFSI could affect listed species or critical habitat, NRC would be required to 

5 initiate Section 7 ESA consultation with NMFS or FWS (for listed species or critical habitat), and 

6 consult NMFS (for essential fish habitat).

7 ES.13.1.12 Historic and Cultural Resources

8 Short-Term Storage. Impacts would be SMALL. Because no ground-disturbing activities are 

9 anticipated during the short-term storage timeframe, impacts associated with continued 

10 operations and maintenance would be SMALL. Therefore, there would be no impacts on 

11 historic and cultural resources. 

12 Long-Term Storage. Impacts could be SMALL, MODERATE, or LARGE. Impacts from 

13 continued operations and routine maintenance during the long-term storage timeframe would be 

14 similar to those described in the short-term storage timeframe. The impacts would be SMALL 

15 because no ground-disturbing activities would occur. NRC authorization to construct and 

16 operate a DTS and replace an at-reactor ISFSI and DTS would constitute Federal actions under 

17 NEPA and would be undertakings under the National Historic Preservation Act of 1966 (NHPA). 

18 In accordance with 36 CFR Part 800, a site-specific Section 106 review would be conducted for 

19 each undertaking to determine whether historic properties are present in the area of potential 

20 effect, and if so, whether these actions would result in any adverse effects upon these 

21 properties. Impacts to historic and cultural resources would vary depending on what resources 

22 are present. Resolution of adverse effects, if any, should be concluded prior to the closure of 

23 the Section 106 process. Therefore, the potential impacts to historic and cultural resources 

24 could be SMALL, MODERATE, or LARGE depending on site-specific factors.

25 Indefinite Storage. Impacts could be SMALL, MODERATE, or LARGE. If replacement activities 

26 occur in previously disturbed areas (i.e., in areas that have previously experienced construction 

27 impacts) then impacts to historic and cultural resources would be SMALL. Therefore, historic 

28 properties would not be adversely affected. If construction activities occur in previously 

29 undisturbed areas or avoidance is not possible, then there could be adverse effects to historic 

30 properties, and impacts to historic and cultural resources could be SMALL, MODERATE, or

31 LARGE depending on site-specific factors.

32 ES.13.1.13 Noise

33 Short-Term Storage. Impacts would be SMALL. Spent fuel pool and dry cask storage noise 

34 levels, noise duration, and distance between noise sources and receptors would generally not 

35 be expected to produce noise impacts noticeable to the surrounding community.
Executive Summary

September 2013 xli Draft NUREG‒2157

1 Long-Term Storage. Impacts would be SMALL. Construction of the DTS and replacement of 

2 the DTS and ISFSI, although temporary and representing a small portion of the overall time 

3 period for spent fuel storage, would generate noise levels that exceed EPA-recommended noise 

4 levels. Noise from dry cask storage operations would be infrequent and at lower levels than for 

5 construction or replacement activities. Generally, for spent fuel storage, the noise levels, noise 

6 duration, and distance between the noise sources and receptors would not be expected to 

7 produce noise impacts noticeable to the surrounding community.

8 Indefinite Storage. Impacts would be SMALL. Spent fuel casks resting on concrete pads are 

9 essentially a passive activity that does not generate noise. The most noise would be generated 

10 by construction equipment associated with the replacement of the ISFSI and DTS facilities, and 

11 impacts would be similar to those during the long-term storage timeframe. 

12 ES.13.1.14 Aesthetics

13 Short-Term Storage. Impacts would be SMALL. No changes to the visual profile are likely to 

14 occur as a result of the continued operation and maintenance of the existing spent fuel pool and 

15 at-reactor ISFSI.

16 Long-Term Storage. Impacts would be SMALL. Periodic construction, replacement, and 

17 operation activities would not significantly alter the landscape of an ISFSI.

18 Indefinite Storage. Impacts would be SMALL. Impacts would be similar to long-term storage 

19 and would not significantly alter the landscape of an ISFSI.

20 ES.13.1.15 Waste Management

21 Short-Term Storage. Impacts would be SMALL. 

22 Continued at-reactor storage of spent fuel would 

23 generate much less low-level, mixed, and 

24 nonradioactive waste than an operating facility, and 

25 licensees would continue to implement Federal and 

26 State regulations and requirements regarding proper 

27 management and disposal of wastes.

28 Long-Term Storage. Impacts would be SMALL. 

29 The replacement of the ISFSI, repackaging of spent 

30 fuel canisters, and construction, operation, and 

31 replacement of the DTS is not expected to 

32 significantly increase the low-level waste (LLW) 

33 disposal capacity needed for reactor decommissioning, and LLW would continue to be managed 

34 according to Federal regulations. The quantity of mixed waste generated from long-term 

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

Draft NUREG‒2157 xlii September 2013

1 storage would be a small fraction of that generated during the licensed life of the reactor. 

2 Although large amounts of nonradioactive waste would be generated by replacement of dry 

3 cask storage facilities, it would still be less than the waste generated during decommissioning 

4 and would not likely have a noticeable impact on local or regional landfill capacity and 

5 operations. 

6 Indefinite Storage. Impacts would be SMALL to MODERATE. It is expected that sufficient LLW

7 disposal capacity would be made available when needed. A relatively small quantity of mixed 

8 waste would be generated from indefinite storage and proper management and disposal 

9 regulations would be followed. The amount of nonradioactive waste that would be generated 

10 and impacts to nonradioactive waste landfill capacity is difficult to accurately estimate over an 

11 indefinite storage timeframe. 

12 ES.13.1.16 Transportation

13 Short-Term Storage. Impacts would be SMALL. A low volume of traffic and shipping activities 

14 is expected with the continued storage of spent fuel in spent fuel pools and at-reactor ISFSIs.

15 Long-Term Storage. Impacts would be SMALL. There would be small workforce requirements 

16 for continued storage and aging management activities (relative to the power plant workforce) 

17 and a low frequency of supply shipments and shipments of LLW from DTS activities, continued 

18 dry cask storage operations, and ISFSI and DTS replacement activities.

19 Indefinite Storage. Impacts would be SMALL. There would be no significant changes to the 

20 annual magnitude of traffic or waste shipments that were identified for long-term storage.

21 ES.13.1.17 Public and Occupational Health

22 Short-Term Storage. Impacts would be SMALL. Annual 

23 public and occupational doses would be maintained 

24 below the annual dose limits established by 10 CFR 

25 Part 72 for the public and 10 CFR Part 20 for 

26 occupational personnel. Licensed facilities would also 

27 be required by the above regulations to maintain an 

28 as-low-as-reasonably-achievable (ALARA) program, 

29 which would likely reduce the doses even further. 

30 Appendix E of the draft GEIS provides additional information to support the environmental 

31 impact determination with respect to leaks from spent fuel pools on public health. Public health 

32 regulatory limits could be exceeded in the very unlikely event a spent fuel pool leak remained 

33 undetected for long periods of time. Preventive maintenance activities would be conducted in 

34 accordance with Occupational Safety and Health Agency requirements and risks to 

35 occupational health and safety would be infrequent and minor.

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.
Executive Summary

September 2013 xliii Draft NUREG‒2157

1 Long-Term Storage. Impacts would be SMALL. Public 

2 and occupational doses would be maintained well below 

3 the dose limits established by 10 CFR Part 72 for the 

4 public and 10 CFR Part 20 for occupational personnel. 

5 Licensed facilities would also be required by these

6 regulations to maintain an ALARA program to ensure 

7 radiation doses are maintained as low as is reasonably 

8 achievable. Construction activities for the DTS would be 

9 conducted in accordance with Occupational Safety and 

10 Health Agency requirements, and once in operation, ISFSI preventive maintenance would be 

11 infrequent and minor. 

12 Indefinite Storage. Impacts would be SMALL. Impacts to public and occupation health are 

13 expected to be similar to those from long-term spent fuel storage activities.

14 ES.13.1.18 Environmental Impacts of Postulated Accidents

15 Design Basis Accidents in Spent Fuel Pools. Impacts 

16 would be SMALL. The postulated design basis 

17 accidents considered in this draft GEIS for spent fuel 

18 pools include hazards from natural phenomena, such as 

19 earthquakes, floods, tornadoes, and hurricanes; hazards 

20 from activities in the nearby facilities; and fuel handling21 related accidents. In addition, potential effects of climate 

22 change are also considered. Based on the assessment 

23 in Section 4.18, the environmental impacts of these postulated accidents involving continued 

24 storage of spent fuel in pools are SMALL because all important safety structures, systems, and 

25 components involved with the spent fuel storage are designed to withstand these design basis 

26 accidents without compromising the safety functions.

27 Design Basis Accidents in Dry Cask Storage Systems. Impacts would be SMALL. All NRC28 licensed dry cask storage systems are designed to withstand all postulated design basis 

29 accidents without any loss of safety functions. A DTS or a facility with equivalent capabilities 

30 may potentially be needed to enable retrieval of spent fuel for inspection or repackaging. 

31 Licensees of DTS facilities are required to design the facilities so that all safety-related 

32 structures, systems, and components can withstand the design basis accidents without 

33 compromising any safety functions. Based on the assessment, the environmental impact of the 

34 design basis accidents is SMALL because safety-related structures, systems, and components 

35 are designed to function in case of these accidents.

36 Severe Accidents in Spent Fuel Pools. Probability-weighted impacts would be SMALL. A spent 

37 fuel pool may encounter severe events, such as loss of offsite power or beyond design basis 

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.

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.
Executive Summary

Draft NUREG‒2157 xliv September 2013

1 earthquakes. Although it is theoretically possible that these events may lead to loss of spent 

2 fuel pool cooling function resulting in spent fuel pool fire, the likelihood of such events is 

3 extremely small. Additional discussion about spent fuel pool fires can be found in Appendix F.

4 Severe Accidents in Dry Cask Storage Systems. Probability5 weighted impacts would be SMALL. Although some handling 

6 accidents such as a postulated drop of a canister could 

7 exceed NRC’s public dose standards, the likelihood of the

8 event is very low. Therefore, the environmental impact of 

9 severe accidents in a dry storage facility is SMALL. 

10 ES.13.1.19 Potential Acts of Sabotage or Terrorism

11 The NRC finds that even though the environmental consequences of a successful attack on a 

12 spent fuel pool beyond the licensed life for operation of a reactor are large, the very low 

13 probability of a successful attack ensures that the environmental risk is SMALL. Similarly, for an 

14 operational ISFSI during continued storage, the NRC finds that both the probability and 

15 consequences of a successful attack are low, and therefore, the environmental risk is SMALL. 

16 Therefore, the storage of spent fuel during continued storage will not constitute an unreasonable 

17 risk to the public health and safety from acts of radiological sabotage, theft, or diversion of 

18 special nuclear material. The environmental impacts of terrorism are an area of particular 

19 controversy.

20 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 No disproportionately 

high and adverse 

impacts

No disproportionately 

high and adverse 

impacts

No disproportionately 

high and adverse 

impacts

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

21

A severe accident is a type of 

accident that may challenge 

safety systems at a level much 

higher than expected.
Executive Summary

September 2013 xlv Draft NUREG‒2157

1 Table ES-3. Summary of Environmental Impacts of Continued At-Reactor Storage (cont’d)

Resource Area Short-Term Storage Long-Term Storage

Indefinite

Storage

Terrestrial Resources SMALL SMALL SMALL

Aquatic Ecology SMALL SMALL SMALL

Special Status Species 

and Habitat

Impacts from the spent 

fuel pool would be 

determined as part of 

ESA Section 7 

consultation; ISFSI 

operations are not likely 

to be adversely 

affected

Not likely to be 

adversely affected 

Not likely to be 

adversely affected

Historic and Cultural 

Resources SMALL

SMALL, 

MODERATE, or 

LARGE

SMALL, MODERATE, 

or 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

2 ES.13.2 Environmental Impacts of Away-From-Reactor Spent Fuel Storage

3 No away-from-reactor ISFSIs of the size considered in Chapter 5 of the draft GEIS 

4 (40,000 metric tons uranium) have been constructed in the United States. For the analysis of 

5 environmental impacts in Chapter 5 of this draft GEIS, the NRC assumes that construction and 

6 operation of an away-from-reactor ISFSI would be similar to that proposed for the Private Fuel

7 Storage Facility on the Reservation of the Skull Valley Band of Goshute Indians in Tooele 

8 County, Utah. The NRC analyzed the environmental impacts of constructing and operating 

9 Private Fuel Storage Facility in NUREG‒1714 (Volumes 1 and 2).
Executive Summary

Draft NUREG‒2157 xlvi September 2013

1 ES.13.2.1 Land Use

2 Short-Term Storage. Impacts would be SMALL. Construction of an ISFSI would change the 

3 nature of land use within the site boundary and along access corridors. While this change 

4 would be qualitatively substantial (e.g., from agricultural to industrial), the land parcel is 

5 assumed to be sufficiently remote and small (when compared, for example, to any surrounding 

6 county) that no quantitatively significant impact would occur.

7 Long-Term Storage. Impacts would be SMALL. Construction of a DTS would disturb a small 

8 portion of the land committed for an away-from-reactor storage facility. To minimize land-use 

9 impacts from replacement of the ISFSI and DTS facilities, the replacement facilities would likely 

10 be constructed on land near the existing facilities, and the old facilities would likely be 

11 demolished and the land reclaimed.

12 Indefinite Storage. Impacts would be SMALL. Only a small portion of the total land committed 

13 for development of an away-from-reactor ISFSI is required to support continued operations, 

14 including periodic maintenance or replacement of equipment and repackaging of fuel. As 

15 mentioned previously, replacement of the away-from-reactor ISFSI and DTS every 100 years 

16 would likely occur on land near the existing facilities.

17 ES.13.2.2 Socioeconomics

18 Short-Term Storage. Adverse impacts would be SMALL. Based on the small workforce 

19 required for construction and operations of an away-from-reactor facility, and any associated 

20 indirect impacts to public services, housing, and education, the impacts of construction and 

21 operation of a storage facility on those resources would be minor. Beneficial impacts to the 

22 economy would be LARGE in the local area.

23 Long-Term Storage. Adverse impacts would be SMALL. Construction of a DTS would require a 

24 workforce smaller than the workforce required for construction of an away-from-reactor ISFSI. 

25 The labor force required for maintenance and replacement activities of an ISFSI and DTS would 

26 not be expected to exceed the labor force required for construction of the storage facility as a 

27 whole. Beneficial impacts to the economy would be LARGE in the local area.

28 Indefinite Storage. Adverse impacts would be SMALL. If no repository becomes available, 

29 operational and replacement activities would continue, beneficial impacts to the economy would 

30 be LARGE in the local area.

31 ES.13.2.3 Environmental Justice

32 Short-Term Storage. Although it is possible that an away-from-reactor ISFSI could raise 

33 concerns related to environmental justice, the process of siting and licensing such a project 
Executive Summary

September 2013 xlvii Draft NUREG‒2157

1 would be expected to ensure that these issues are addressed before a facility is licensed and 

2 that there would be no significant environmental justice impacts.

3 Long-Term Storage. Because building a DTS is a much smaller project than building a nuclear 

4 power plant and would occur within the ISFSI protected area, the impacts from construction of 

5 the DTS would be within the envelope of impacts from the construction of the away-from-reactor 

6 ISFSI. Because of the passive nature of operations and the temporary nature of any 

7 construction associated with the DTS and the monitoring and maintenance of ISFSI pads and 

8 dry casks, impacts on minority and low-income populations would not be disproportionately high 

9 and adverse.

10 Indefinite Storage. The environmental impacts on minority and low-income populations if a 

11 repository is not available to accept spent fuel, and away-from-reactor storage continues 

12 indefinitely, are the same as the impacts for long-term storage. Impacts on minority and low13 income populations would not be disproportionately high and adverse.

14 ES.13.2.4 Air Quality

15 Short-Term Storage. Impacts would be SMALL to MODERATE. Construction of an away-from16 reactor ISFSI would result in minimal emissions, but construction of the rail spur could produce 

17 temporary and localized impacts that would be noticeable. ISFSI operations generate minor 

18 levels of air emissions but not enough to be classified as a “major stationary source” of 

19 emissions as defined in Federal air quality regulations. Locomotives transporting spent fuel to 

20 an away-from-reactor ISFSI would emit exhaust pollutants in a distributed manner along the 

21 transport route. 

22 Long-Term Storage. Impacts would be SMALL. Operation activities are expected to be of 

23 relatively short duration and limited in extent. The DTS is a relatively small facility, and the air 

24 quality impacts associated with construction would be less than those associated with the 

25 original construction of the ISFSI. Replacement of the DTS and ISFSI and maintenance of the 

26 rail spur would involve only a fraction of the air emissions associated with initial construction of 

27 an ISFSI. Exhaust from vehicles would not be expected to noticeably affect air quality for the 

28 region.

29 Indefinite Storage. Impacts would be SMALL. Indefinite storage would consist of the same 

30 short-duration and limited-extent activities and would result in the same impact magnitudes as 

31 described for long-term storage except that they would continue indefinitely into the future.

32 ES.13.2.5 Climate Change

33 Short-Term Storage. Impacts would be SMALL. Average annual greenhouse gas

34 emissions associated with building and operating an ISFSI as well as transportation 
Executive Summary

Draft NUREG‒2157 xlviii September 2013

1 (e.g., commuters, supplies, waste materials, and spent fuel) would be equivalent to the 

2 annual emissions from about 1,720 passenger vehicles.

3 Long-Term Storage. Impacts would be SMALL. Construction of a DTS, replacement of dry 

4 casks and pads, and maintenance activities would likely involve only a fraction of the 

5 greenhouse gas emissions associated with the original construction of the ISFSI.

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

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

8 United States.

9 ES.13.2.6 Geology and Soils

10 Short-Term Storage. Impacts would be SMALL. The land required to construct an ISFSI would 

11 be relatively small, and soil erosion controls would minimize impacts.

12 Long-Term Storage. Impacts would be SMALL. Construction of a DTS would have minimal 

13 impacts to geology and soil because of the small size of the facility. Replacement of the ISFSI 

14 pads and supporting facilities would likely occur on land near the existing facilities. The old 

15 facilities would likely be demolished, and the land would likely be reclaimed.

16 Indefinite Storage. Impacts would be similar to long-term storage, SMALL. Replacement of 

17 ISFSI and DTS facilities would likely occur on previously disturbed land and would minimize 

18 impacts to soils and geology.

19 ES.13.2.7 Surface-Water Quality and Use

20 Short-Term Storage. Impacts would be SMALL. Best management practices would be 

21 implemented during construction of an ISFSI to address stormwater flows, soil erosion, and 

22 siltation. Stormwater control measures would be required to comply with State-enforced water23 quality permits. Construction and operation of an ISFSI would require very little consumptive 

24 use of water. 

25 Long-Term Storage. Impacts would be SMALL. Given the relatively smaller size of a DTS as 

26 compared to an ISFSI, much less water would be required to build a DTS. Consumptive use 

27 and surface-water quality impacts would be no greater than those identified for initial 

28 construction of the storage facilities.

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

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

31 temporary and minimal impacts to surface-water quality and use.
Executive Summary

September 2013 xlix Draft NUREG‒2157

1 ES.13.2.8 Groundwater Quality and Use

2 Short-Term Storage. Impacts would be SMALL. Methods necessary to control impacts to 

3 groundwater quality during construction and operation of an ISFSI are well understood and 

4 State-issued permits typically require the implementation of such controls. Construction and 

5 operation of an ISFSI would require very little consumptive use of water.

6 Long-Term Storage. Impacts would be SMALL. Impacts on groundwater from a DTS would be 

7 no larger than those considered for construction of the ISFSI. Likewise, the impacts of replacing 

8 portions of the ISFSI over time would be no more than the impacts of the initial construction of 

9 the facility, and would likely occur over a longer period of time.

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

11 storage. Once every 100 years, groundwater may be required when demolishing and replacing 

12 the ISFSI and DTS facilities. Consumptive use of groundwater and water-quality impacts would 

13 be minor and temporary.

14 ES.13.2.9 Terrestrial Resources

15 Short-Term Storage. Impacts would be SMALL to MODERATE. Land area permanently 

16 disturbed for construction of an away-from-reactor dry cask storage facility would be relatively 

17 small, and any impacts to wetlands would be addressed under the Clean Water Act. However, 

18 construction could have some noticeable impacts to terrestrial resources, such as habitat loss, 

19 displacement of wildlife, and incremental habitat fragmentation. ISFSI operations would have 

20 minimal impacts on terrestrial resources.

21 Long-Term Storage. Impacts would be SMALL. Impacts from construction of a DTS would be 

22 significantly less than those impacts expected from construction and operation of an ISFSI. 

23 Because of its relatively small construction footprint, the DTS could be sited on previously 

24 disturbed ground and away from sensitive terrestrial resources. Impacts from operational 

25 activities would be minor. Replacement activities would occur once about every 100 years, and 

26 would likely occur adjacent to existing facilities.

27 Indefinite Storage. Impacts would be SMALL. Replacement activities are not expected to add 

28 additional impacts beyond those impacts expected for initial construction of the away-from29 reactor ISFSI and DTS. Operation of away-from reactor ISFSIs would not require any additional 

30 land use beyond that set aside for original construction of the facility.

31 ES.13.2.10 Aquatic Ecology

32 Short-Term Storage. Impacts would be SMALL. Construction and operation of an away-from33 reactor ISFSI would require limited water supplies, and effluents, if any, would be limited to 
Executive Summary

Draft NUREG‒2157 l September 2013

1 stormwater and treated wastewater. Impacts to aquatic resources would tend to be limited by 

2 certain factors, including the land area permanently disturbed would be relatively small; water 

3 use for the construction and operation of the site would be limited; and any impacts from 

4 discharges to water bodies would need to be addressed under the Clean Water Act, which 

5 requires licensees to obtain a National Pollutant Discharge Elimination System permit for any 

6 discharges to water bodies.

7 Long-Term Storage. Impacts would be SMALL. Building a DTS, and transferring, handling, and 

8 aging management at an away-from-reactor ISFSI could result in ground-disturbing activities 

9 that would have impacts similar to or less than impacts associated with the original construction 

10 of the ISFSI. Replacement activities would likely occur adjacent to existing facilities, and 

11 aquatic disturbances would result in relatively short-term impacts and aquatic environs would 

12 recover naturally.

13 Indefinite Storage. Impacts would be SMALL. Activities associated with demolishing old 

14 facilities and building replacement facilities once about every 100 years could result in minimal, 

15 short-term impacts to aquatic resources. Impacts associated with ISFSI operation and 

16 maintenance would also be small.

17 ES.13.2.11 Special Status Species and Habitat

18 Short-Term Storage. Impacts from the initial construction and ongoing operation and 

19 maintenance of dry cask storage facilities to special status species and habitat would range 

20 from minimal to noticeable, which would be similar to those described for terrestrial and aquatic 

21 resources, with any noticeable impacts resulting from the construction of the ISFSI. An away22 from-reactor ISFSI could be sited to avoid adversely affecting special status species and 

23 habitat. Assuming the ISFSI can be sited to avoid special status species and habitat, operating 

24 the ISFSI is not likely to adversely affect special status species and habitat. Impacts would be 

25 determined as part of an ESA Section 7 consultation if continued storage would affect Federally

26 listed species or critical habitat. The NRC assumes that consultations would result in avoidance 

27 or mitigation measures that would minimize impacts to protected species and habitat.

28 Long-Term Storage. During the long-term storage timeframe, replacement of the casks, pads, 

29 and the DTS would result in impacts that would be less than initial construction impacts because 

30 replacement activities would occur within the facility’s operation area near existing facilities. 

31 Assuming the ISFSI was sited to avoid special status species and habitat, operating and 

32 replacing components of the ISFSI would not likely adversely affect special status species and 

33 habitat. 

34 Indefinite Storage. Impacts to special status species and habitat from continued operation of 

35 away-from-reactor ISFSIs if a repository never becomes available would be similar to those 
Executive Summary

September 2013 li Draft NUREG‒2157

1 described for the long-term storage timeframe. The same operations and maintenance 

2 activities would occur repeatedly because the spent fuel remains at the facility indefinitely.

3 ES.13.2.12 Historic and Cultural Resources

4 Short-Term Storage. Impacts would be SMALL, 

5 MODERATE, or LARGE. Impacts to historic and cultural 

6 resources would vary depending on what resources are 

7 present, but would be minimized because (1) the land 

8 area disturbed would be relatively small, (2) site 

9 selection and placement of facilities on the site could be 

10 readily adjusted to minimize impacts to historic and 

11 cultural resources because the facility does not depend on significant water supply and has 

12 limited electrical power needs, and (3) potential adverse effects could also be minimized 

13 through development of agreements, license conditions, and implementation of the licensee’s 

14 historic and cultural resource management plans and procedures to protect known historic and 

15 cultural resources and address inadvertent discoveries during construction. 

16 Long-Term Storage. Impacts would be SMALL, MODERATE, or LARGE. Impacts from 

17 continued operations, routine maintenance, replacement of the facilities at an away-from-reactor 

18 ISFSI, and potential construction, operation, and replacement of a DTS would vary depending 

19 on what resources are present, proposed land disturbance, and if the licensee has management 

20 plans and procedures that are protective of historic and cultural resources. Additionally, the 

21 construction of a DTS and replacement of an ISFSI and the DTS would be Federal actions that 

22 would require the NRC to conduct a site-specific assessment of potential impacts to historical 

23 and cultural resources under Section 106 of NHPA. 

24 Indefinite Storage. Impacts would be SMALL, MODERATE, or LARGE. Impacts would be 

25 similar to those described for the long-term storage timeframe. Ground-disturbing activities 

26 would likely occur in areas that have previously experienced construction impacts.

27 ES.13.2.13 Noise

28 Short-Term Storage. Impacts would be SMALL. Noise impacts for an away-from-reactor ISFSI 

29 could exceed EPA-recommended levels during some portions of construction and operation;

30 however, noise impacts would be short in duration and intermittent.

31 Long-Term Storage. Impacts would be SMALL. Noise impacts from continued operation and 

32 routine maintenance of an away-from-reactor ISFSI would be minimal. Impacts from 

33 construction of a DTS and replacement of the DTS and ISFSI would be similar to those for initial 

34 construction of an ISFSI. These construction and replacement activities would be intermittent 

35 and short in duration, and noticeable noise levels would be limited to the nearest receptors.

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

Draft NUREG‒2157 lii September 2013

1 Indefinite Storage. Impacts would be SMALL. Impacts would be similar to those associated 

2 with the long-term storage timeframe. Ongoing operation, maintenance, and replacement 

3 activities would have minimal noise impacts.

4 ES.13.2.14 Aesthetics

5 Short-Term Storage. Impacts would be SMALL to MODERATE. Potential impacts to aesthetic

6 resources would include visibility of facility buildings, dry storage pads and canisters, and the 

7 rail line and trains from across scenic water bodies, roadways, or from higher elevations. 

8 Lighting of the facility would increase visibility. If constructed in an area with no prior industrial 

9 development, the ISFSI probably would be expected to impact the local viewshed, and scenic 

10 appeal of the site would be noticeably changed when viewed from various locations. Impacts 

11 could be minimal if the ISFSI is built in a previously disturbed area.

12 Long-Term Storage. Impacts would be SMALL to MODERATE. Aesthetic impacts from 

13 transferring and handling spent fuel and aging management activities at an away-from-reactor 

14 ISFSI are anticipated to be similar to the impacts for initial construction and short-term operation 

15 of the ISFSI. Periodic construction, demolition, and operation activities required for aging 

16 management would not significantly alter the preexisting impacts on aesthetic resources.

17 Indefinite Storage. Impacts would be SMALL to MODERATE. The same operations and 

18 maintenance activities that are described for the long-term storage timeframe occur repeatedly 

19 because the spent fuel remains at the facility indefinitely.

20 ES.13.2.15 Waste Management

21 Short-Term Storage. Impacts would be SMALL. Construction activities would generate 

22 excavation and construction debris, vegetation debris, and backfill. Operation of an away-from23 reactor ISFSI would involve limited waste generating activities. Small quantities of LLW may be 

24 generated during routine operation and maintenance. Little to no mixed waste generation would 

25 be expected. Small quantities of nonradioactive waste would be generated. All wastes would 

26 be managed and disposed of according to regulatory requirements.

27 Long-Term Storage. Impacts would be SMALL. Routine maintenance would generate minimal 

28 quantities of waste. Construction and operation of a DTS and replacement of casks and ISFSI 

29 and DTS facilities at an away-from-reactor ISFSI would generate LLW and nonradioactive 

30 waste. Although the exact amount of LLW and nonradioactive waste depends on the level of 

31 contamination, the quantity of waste generated from the replacement of the storage casks and 

32 concrete storage pads is expected to be a fraction of the LLW generated during reactor 

33 decommissioning, which was determined to have a SMALL impact in the Decommissioning 

34 GEIS. 
Executive Summary

September 2013 liii Draft NUREG‒2157

1 Indefinite Storage. Impacts would be SMALL to MODERATE. LLW, mixed waste, and 

2 nonradioactive waste would continue to be generated indefinitely, and there could be noticeable 

3 impacts on the local and regional landfill capacity for nonradioactive waste disposal. 

4 ES.13.2.16 Transportation

5 Short-Term Storage. Impacts would be SMALL to MODERATE. The environmental impacts of 

6 transportation include impacts to regional traffic from commuting workers, supply shipments, 

7 shipments of spent fuel to the ISFSI, and shipments of nonradioactive and radiological waste. 

8 Impacts to traffic from workers commuting to and from the 

9 away-from-reactor storage site depend on the size of the 

10 workforce, the capacity of the local road network, traffic 

11 patterns, and the availability of alternative commuting 

12 routes to and from the facility. The majority of impacts 

13 would be associated with the traffic during the initial 

14 construction of the ISFSI. Shipment of spent fuel from 

15 nuclear power plants to the ISFSI would be required to 

16 comply with NRC and the U.S. Department of 

17 Transportation (DOT) regulations. Radiological impacts 

18 to the public and workers from spent fuel shipments from 

19 a reactor have previously been evaluated by the NRC (in 

20 Table S-4 of 10 CFR 51.52) and were found to be small.

21 Long-Term Storage. Impacts would be SMALL to MODERATE. Construction of a DTS would 

22 require a smaller workforce than the initial construction of the ISFSI, so transportation impacts 

23 from workers commuting would be less, but may still be noticeable. Shipments of LLW

24 generated by maintenance and replacement activities would be regulated by NRC and DOT 

25 requirements and impacts to traffic and to public and worker radiological and nonradiological 

26 safety would be minimal.

27 Indefinite Storage. Impacts would be SMALL to MODERATE. Annual transportation activities 

28 and associated environmental impacts would be similar to that analyzed for the long-term 

29 storage timeframe.

30 ES.13.2.17 Public and Occupational Health

31 Short-Term Storage. Impacts would be SMALL. Nonradiological health impacts from the 

32 construction of an away-from-reactor ISFSI include normal hazards associated with construction 

33 such as pollutants (e.g., dust), and fatal and nonfatal occupational injuries (e.g., falls and

34 overexertion). Impacts would be minor and similar to an industrial facility of similar size. Public 

35 and occupation radiological doses would be maintained significantly below the dose limits 

36

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‒1238, 

December 1972, and Supp. 1 

NUREG‒75/038, April 1975.
Executive Summary

Draft NUREG‒2157 liv September 2013

1 established by 10 CFR Part 72 and 10 CFR Part 20. Licensed facilities would also be required 

2 by those regulations to maintain an ALARA program, which would likely reduce the doses even 

3 further.

4 Long-Term Storage. Impacts would be SMALL. Nonradiological health impacts associated with 

5 replacement activities would be similar those for the original construction of the facility, although 

6 replacement activities would take place over a longer period of time. Public and occupational 

7 radiological doses would be maintained significantly below the dose limits established by 

8 10 CFR Part 72 and 10 CFR Part 20. In addition, the dry cask storage facility would be required 

9 to maintain an ALARA program that would further reduce radiological doses. Operation of the 

10 DTS would involve increased doses to works and a very small increase in dose levels at the site 

11 boundary; however, the licensee would still be required to comply with regulations limiting dose.

12 Indefinite Storage. Impacts would be SMALL. For the indefinite storage timeframe, the types of 

13 activities (construction, operation, and decommissioning) and associated health impacts would 

14 remain the same as those for the long-term storage timeframe.

15 ES.13.2.18 Environmental Impacts of Postulated Accidents

16 Impacts would be SMALL. Consideration of accidents at an away-from-reactor ISFSI for all 

17 three storage timeframes are similar to those for at-reactor ISFSIs (described in Chapter 4 of 

18 the draft GEIS). The postulated accidents analysis in the draft GEIS is applicable for all three 

19 timeframes (short-term, long-term, and indefinite). NRC regulations in 10 CFR Part 72 require 

20 that structures, systems, and components important to safety will be designed to withstand the 

21 effects of natural phenomena (such as earthquakes, tornadoes, and hurricanes) and human22 induced events without loss of capability to perform those safety functions. NRC siting 

23 regulations also require applicants to take into consideration, among other things, physical 

24 characteristics of sites that are necessary for the safety analysis or that may have an impact on 

25 plant design (such as the design basis earthquake). All these factors are considered in 

26 determining the acceptability of the site and design criteria of a proposed dry cask storage 

27 facility. The draft GEIS analysis considered an accident scenario in which wind-borne missiles 

28 damage the concrete overpack of a dry cask. This accident would result in only slightly higher 

29 occupational doses and only negligible increases in radiological doses at the boundary of the 

30 site. The analysis also considered an accident resulting in a dry cask leaking, and determined 

31 that radiological doses would still be below the limits in 10 CFR Part 20 and 10 CFR Part 72.

32 ES.13.2.19 Potential Acts of Sabotage or Terrorism

33 The consideration of terrorism at an away-from-reactor ISFSI for all three storage timeframes

34 are similar to those for at-reactor ISFSIs (described in Chapter 4 of the draft GEIS). The 

35 probability and consequences of a successful attack on an away-from-reactor ISFSI are low; 

36 therefore, the environmental risk is SMALL.
Executive Summary

September 2013 lv Draft NUREG‒2157

1 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 No disproportionately 

high and adverse 

impacts

No 

disproportionately 

high and adverse 

impacts

No disproportionately 

high and adverse 

impacts

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 from the construction of the ISFSI would be determined as 

part of an ESA Section 7 consultation. Assuming the ISFSI can be 

sited to avoid special status species and habitat, operation and 

replacement of the ISFSI is not likely to adversely affect special 

status species and habitat. Impacts would be determined as part of 

an ESA Section 7 consultation if continued storage would affect 

listed species or critical habitat.

Historic and Cultural Resources SMALL, MODERATE, 

or LARGE

SMALL, 

MODERATE, or 

LARGE

SMALL, 

MODERATE, or 

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

Draft NUREG‒2157 lvi September 2013

1 ES.14 Did the NRC Look at Cumulative Effects? 

2 In Chapter 6 of the draft GEIS, the NRC examined the 

3 incremental impact of continued storage on each 

4 resource area in combination with other past, present, 

5 and reasonably foreseeable actions. The introductory 

6 sections of Chapter 6 discuss the NRC's methodology 

7 for assessing cumulative effects, including the spatial 

8 and temporal bounds on which the NRC based its analyses, and provide a table that describes 

9 national, regional, and local trends that informed the NRC’s consideration of reasonably 

10 foreseeable future actions. Trends that the NRC examined include increased energy demand, 

11 continued use of radiological materials, increased water demand, population growth and 

12 demographic shifts, increased urbanization, transportation, and other activities and 

13 environmental stressors. The temporal boundary for the cumulative effects analysis includes 

14 activities that could occur through decommissioning of at-reactor or away-from-reactor storage 

15 facilities.

16 Table ES-5 provides a summary of the determinations made in Chapter 6. The second and 

17 third columns list resource impact determinations made in Chapters 4 and 5. These impacts are 

18 combined with the past, present, and reasonably foreseeable actions discussed in Chapter 6. 

19 The last column lists the cumulative impacts to resource areas. Discussions about impact 

20 differences resulting from cumulative effects can be found in Chapter 6 of the draft GEIS.

21 Table ES-5. Summary of Cumulative Effects for Continued Storage of Spent Fuel

Resource Area

Incremental Impact 

from Onsite 

Storage

Incremental Impact 

from Offsite 

Storage

Cumulative Impact from 

Continued Storage and 

Other Federal and NonFederal Activities

Land Use SMALL SMALL SMALL to MODERATE

Socioeconomics SMALL SMALL SMALL to LARGE

Environmental Justice No disproportionately high and adverse impacts

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 to 

MODERATE

SMALL to LARGE

Groundwater Quality and Use SMALL SMALL SMALL to LARGE

Terrestrial Resources SMALL SMALL to 

MODERATE

SMALL to MODERATE

Aquatic Ecology 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 2013 lvii Draft NUREG‒2157

1 Table ES-5. Summary of Cumulative Effects for Continued Storage of Spent Fuel (cont’d)

Resource Area

Incremental 

Impact from

Onsite Storage

Incremental Impact 

from Offsite 

Storage

Cumulative Impact from 

Continued Storage and 

Other Federal and NonFederal Activities

Historic and Cultural Resources SMALL, 

MODERATE, or 

LARGE

SMALL, 

MODERATE, or 

LARGE

SMALL, MODERATE, or 

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

2 ES.15 Does the Draft GEIS Address Costs? 

3 Chapter 7 of the draft GEIS analyzes and compares the benefits and costs associated with the 

4 proposed action (preparing a GEIS and revising 10 CFR 51.23), other action alternatives (the 

5 GEIS-only and policy statement alternatives), and the no-action alternative. The alternatives do 

6 not noticeably alter the environmental impacts from continued storage that the NRC addresses 

7 in Chapters 4, 5, and 6 of the draft GEIS. Instead, the alternatives considered provide different 

8 approaches that the NRC could apply to future licensing activities that can satisfy the agency’s 

9 responsibility to consider the potential environmental impacts of continued storage in deciding 

10 whether to issue certain new and renewed licenses. Section 7.1 of the draft GEIS includes 

11 assumptions about financial costs and current and future licensing reviews that are the bases 

12 for the cost and benefit analysis.

13 Section 7.6 of the draft GEIS summarizes and compares the estimated costs of the alternatives, 

14 including the savings or expense of each action alternative when compared to the no-action 

15 alternative. The cost for the proposed action (preparing a GEIS and revising 10 CFR 51.23) is 

16 significantly lower than the cost for any of the alternatives. This occurs primarily because the 

17 NRC does not undertake site-specific reviews of the continued storage issue in the course of 

18 individual licensing proceedings as part of the proposed action. In general, the no-action 

19 alternative is substantially more costly than the proposed action, but less costly than either the 

20 GEIS-only or policy statement alternatives. While the no-action alternative avoids the costs 

21 associated with a GEIS and rulemaking, site-specific review costs are significantly higher than 

22 the avoided costs of the GEIS and rulemaking. The GEIS-only and policy-statement 
Executive Summary

Draft NUREG‒2157 lviii September 2013

1 alternatives avoid the need for rulemaking, but result in higher costs than the no-action 

2 alternative because of the up-front costs of creating the GEIS and, for the policy-statement 

3 alternative, the policy statement.

4 ES.16 How did the NRC Address Spent Fuel Pool Fires and 

5 Leaks?

6 The NRC assessed the environmental impacts of spent fuel pool fires and leaks as part of the 

7 analysis in the GEIS. Further, in response to the historic interest of the public in this issue, as 

8 evidenced by comments in NRC’s Waste Confidence rulemaking and related litigation, the NRC 

9 prepared separate appendices to provide additional, more detailed discussion of the analyses 

10 supporting the impact determinations for spent fuel pool fires and leaks. Appendix E of the draft 

11 GEIS describes the environmental impacts of spent fuel pool leaks during the short-term 

12 storage timeframe, and Appendix F describes the environmental impacts of a spent fuel pool fire 

13 during the short-term storage timeframe. In the draft GEIS, the NRC assumes that all spent fuel 

14 being stored in spent fuel pools will be transferred to dry casks by the end of the 60-year (short15 term) storage timeframe.

16 ES.16.1 Spent Fuel Pool Leaks

17 A variety of factors work together to make the likelihood of a spent fuel pool leak that leads to 

18 noticeable offsite environmental impacts during continued storage very low, including the 

19 combination of spent fuel pool design and maintenance, operational and regulatory practices 

20 (e.g., leakage monitoring, NRC oversight, and, more recently, groundwater monitoring), site 

21 hydrogeologic characteristics, and radionuclide transport properties.

22 For impacts to groundwater resources, though highly unlikely, it is possible that a leak of 

23 sufficient quantity and duration could occur, resulting in noticeable impacts to groundwater 

24 resources. The factors that could lead to a significant leak are many and varied. These factors

25 include the magnitude and duration of the leak, the radiological constituents of the leak, the 

26 hydrologic conditions of the site, and the distance to the offsite groundwater resource. All these 

27 factors, in addition to the assessment of past leaks and the promulgation of regulations requiring 

28 monitoring and reporting of subsurface contamination, leads NRC to conclude that the 

29 environmental impacts of a spent fuel pool leak during continued storage would be SMALL.

30 Public health concerns would be related to groundwater contamination and would be limited to 

31 private wells nearest the site. In the event of uncontrolled and undetected discharges 

32 associated with long-term spent fuel pool leaks to nearby surface waters, the annual discharge 

33 would be comparable to normal discharges associated with operating reactors, and would likely 

34 remain below limits in 10 CFR Part 50, Appendix I. If, in the very unlikely event that a pool leak 

35 remained undetected for a long period of time, public health regulatory limits (i.e., EPA drinking 
Executive Summary

September 2013 lix Draft NUREG‒2157

1 water standards) could potentially be exceeded. 

2 However, it is unlikely that a leak of sufficient quantity 

3 and duration could occur without detection, or that such 

4 a leak would not be impeded by the inherent hydrologic 

5 characteristics typical at spent fuel pool locations. 

6 Therefore, based on the low probability that a long7 duration leak exceeding effluent limits would go 

8 undetected and affect offsite groundwater sources to the 

9 extent that a public health limit would be exceeded, the 

10 NRC concludes that impacts during the short-term 

11 storage timeframe would be SMALL.

12 For all other resource areas evaluated, the impacts from 

13 a spent fuel pool leak would be SMALL.

14 ES.16.2 Spent Fuel Pool Fires

15 The spent fuel pool fire environmental impacts described 

16 in Appendix F are a summary of spent fuel pool fire risk

17 studies the NRC has completed since 1975. While most 

18 of the earlier studies were concerned with spent fuel pool 

19 fire risk during the operating life of a reactor, the most 

20 recent risk study completed in 2001 examined the risk of 

21 spent fuel pool fires during the reactor decommissioning

22 period, which is the same storage timeframe of continued 

23 storage of spent fuel on which this draft GEIS is focused.

24 The conservative estimates used to assess the impacts of 

25 spent fuel pool fires in NRC’s previous analyses resulted 

26 in frequency-weighted population doses and economic 

27 impacts that were much less than the values calculated for a full power reactor accident

28 estimated in the 1996 and 2013 License Renewal GEIS for the assumptions found in previous 

29 analyses (e.g., spent fuel pool density, site population density, and time after shutdown for the 

30 event to occur). Furthermore, mitigation measures implemented by licensees as a result of 

31 NRC Orders have further lowered the risk of this class of accident. As a result, the NRC finds 

32 that the 1996 and 2013 License Renewal GEIS conclusion that the probability-weighted 

33 consequences of atmospheric releases, fallout onto open bodies of water, releases to 

34 groundwater, and societal and economic impacts of spent fuel pool fires are SMALL is

35 applicable for a spent fuel pool fire during the continued storage timeframe. 

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-radiationfs.html.

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

Draft NUREG‒2157 lx September 2013

1 ES.17 What is the Overall Conclusion of the Waste 

2 Confidence Draft GEIS?

3 Chapter 8 of the draft GEIS provides a summary of the environmental impacts and 

4 consequences of continued at-reactor and away-from-reactor spent fuel storage, a discussion 

5 and cost-benefit analysis of the proposed action, other action alternatives, and the no-action 

6 alternative, and a preliminary recommendation to the Commission regarding the preferred 

7 alternative. 

8 For at-reactor storage, the unavoidable adverse environmental impacts for each resource 

9 area are SMALL, with the exception of waste-management impacts, which are SMALL to 

10 MODERATE, and historic and cultural impacts, which are SMALL, MODERATE, or LARGE. 

11 The moderate waste-management impacts are associated with the volume of nonhazardous 

12 solid waste generated by assumed facility-replacement activities for only the indefinite 

13 timeframe. The SMALL, MODERATE, or LARGE historic and cultural impacts are based on a 

14 combination of the additional land-disturbing activities from DTS-construction and facility15 replacement activities during the long-term and indefinite storage timeframes and a range of 

16 site-specific characteristics that are assumed for the purpose of evaluating a reasonable range 

17 of potential impacts.

18 For away-from-reactor storage, the unavoidable adverse environmental impacts for each 

19 resource area are SMALL except for air quality, terrestrial ecology, aesthetics, waste 

20 management, and transportation for which the impacts would be SMALL to MODERATE. 

21 Socioeconomics impacts would range from SMALL to beneficial and LARGE and historic and 

22 cultural impacts could be SMALL, MODERATE, or LARGE. The potential MODERATE impacts 

23 to air quality, terrestrial wildlife, and transportation are based on construction-related potential 

24 fugitive dust emissions, terrestrial wildlife direct and indirect mortalities, and temporary 

25 construction traffic impacts. The potential MODERATE impacts to aesthetics and waste 

26 management are based on noticeable changes to the viewshed from constructing a new ISFSI, 

27 and the volume of nonhazardous solid waste generated by assumed ISFSI and DTS 

28 replacement activities for only the indefinite timeframe. Potential LARGE impacts to 

29 socioeconomics would be due to local economic tax revenue increases from an away-from30 reactor ISFSI. The potential LARGE impacts to historic and cultural and special status species 

31 apply to assumed site-specific circumstances at an away-from-reactor ISFSI involving the 

32 presence of these resources during construction activities and absence of effective protection 

33 measures. Specifically, these potential historic and cultural impacts vary depending on whether 

34 resources are present, the extent of proposed land disturbance, and if the licensee has 

35 management plans and procedures that are protective of historic and cultural resources. 

36 For both at-reactor and away-from-reactor ISFSIs, there would be no irreversible and 

37 irretrievable commitments of resources during continued storage for most resources. However, 
Executive Summary

September 2013 lxi Draft NUREG‒2157

1 impacts on land use, aesthetics, historic and cultural resources, waste management, and 

2 transportation would result in irreversible and irretrievable commitments. As finite resources, 

3 the loss of historic and cultural resources would constitute irreversible and irretrievable impacts. 

4 For the indefinite storage timeframe, land and visual resources allocated for spent fuel storage 

5 would be committed in perpetuity as continued operations would preempt other productive land 

6 uses and permanently affect the viewshed. Waste-management activities involving waste 

7 treatment, storage, and disposal would result in irreversible commitment of capacity for waste 

8 disposal. Transportation activities would involve irreversible and irretrievable commitment of 

9 resources, including vehicle fuel for commuting workers and shipping activities.

10 Of the alternatives considered, the proposed action (i.e., preparing a GEIS and revising 

11 10 CFR 51.23) is the most efficient regulatory approach for addressing the impacts of continued 

12 storage, and provides for the same level of environmental protection as the other alternatives. 

13 The NRC quantitative analysis of costs shows that the cost for the proposed action is 

14 significantly lower than the cost for any of the alternatives. This occurs primarily because the 

15 NRC does not undertake site-specific reviews of continued storage in the course of individual 

16 licensing proceedings as part of the proposed action.

17

In conclusion, the NRC recommendation is to select the proposed action—revising 

10 CFR 51.23—as the preferred alternative. The NRC recommendation is based on 

(1) NRC independent impact assessments of continued storage summarized in the 

draft GEIS, which would result in substantially the same impact conclusions for any of 

the evaluated alternatives; (2) NRC consideration of public scoping comments in the 

development of the draft GEIS; and (3) NRC analysis of the cost-benefit balance of 

the proposed action and alternatives. In making its preliminary recommendation, the 

NRC determined that none of the alternatives assessed were obviously superior to the 

proposed action.

18

19 ES.18 How is the Draft GEIS Related to the Waste 

20 Confidence Rule?

21 This draft GEIS, if adopted, would provide a regulatory basis for the NRC’s proposed 

22 amendment to 10 CFR 51.23. Appendix B of the draft GEIS contains detailed information about 

23 the previous Waste Confidence rule, and addresses two relevant topics from earlier versions of 

24 the Waste Confidence decisions: the technical feasibility for continued storage and repository

25 availability. NRC’s conclusions regarding these topics, based on the best available information, 

26 continue to undergird the agency’s environmental analysis.
Executive Summary

Draft NUREG‒2157 lxii September 2013

1 ES.19 Are There Any Areas of Controversy in the Draft 

2 GEIS? 

3 There are a number of areas of controversy that should be considered in preparing comments 

4 on the draft GEIS.

5 1. The NRC has included detailed analyses of spent fuel pool leaks and spent fuel pool fires. 

6 Historically, the NRC has devoted considerable attention to these topics, and there has 

7 been intense public interest in these issues, as evidenced by comments received during the 

8 scoping period and during the litigation on the 2010 Waste Confidence update. The NRC 

9 therefore prepared separate appendices to provide additional detail regarding the studies 

10 and analyses that underlie the analyses of spent fuel pool fires and leaks. 

11 2. The NRC has included indefinite storage as one of the three timeframes analyzed in this 

12 draft GEIS. The NRC has devoted considerable attention to this timeframe in response to 

13 the intense public interest in this issue, as evidenced by comments received during the 

14 scoping period and during the litigation on the 2010 Waste Confidence update. Although 

15 the NRC believes it is likely that a repository will be available by 60 years after the end of a 

16 reactor’s licensed life for operation, it does recognize that the availability of a repository is a 

17 controversial issue and has included an analysis of indefinite storage in the draft GEIS. 

18 3. The NRC will update this list to reflect areas of controversy that are identified by public 

19 comments on this draft GEIS. 

20 ES.20 Are There Any Remaining Issues to be Resolved?

21 For the purposes of successfully completing the draft GEIS while meeting NEPA requirements, 

22 the NRC believes there are numerous sources of the requisite technical data and information 

23 available; therefore, there are no remaining issues that require resolution. In the reference 

24 section of each chapter, the NRC has listed technical documents and reports on pertinent 

25 issues that are used to support the analyses in the draft GEIS. Additionally, the NRC will adopt 

26 or incorporate by reference all or part of existing EISs, as appropriate. The NRC will rely on 

27 accurate and high quality information to ensure the Waste Confidence GEIS contains a 

28 thorough and rigorous environmental impact analysis. As new information becomes available, 

29 the NRC will gauge the significance of the new information, and will review its conclusions as 

30 necessary.
Executive Summary

September 2013 lxiii Draft NUREG‒2157

1 ES.21 What are the Next Steps in the NRC's Waste 

2 Confidence Rulemaking? 

3 The NRC is seeking comments on both the draft GEIS and proposed Waste Confidence rule. 

4 A 75-day public comment period from September 13, 2013, through November 26, 2013, will be 

5 scheduled to receive comments on the draft GEIS and the proposed Rule. During that time, the 

6 NRC plans to conduct two nationally webcast meetings and eight regional public meetings. 

7 There will be no need to submit separate comments on the draft GEIS and the proposed Rule, 

8 as comments on the two documents will be treated the same. The 75-day comment period from 

9 September 13, 2013, through November 26, 2013, will be the same for both the draft GEIS and 

10 proposed Rule.

11 Following closure of the comment period, the NRC will evaluate, summarize, and respond to the 

12 comments received. The NRC will revise the draft GEIS and proposed Rule in response to 

13 comments, as necessary, and, if appropriate, will issue a final GEIS and Rule. Comments on 

14 the draft GEIS and proposed Rule will be summarized and responded to in a separate 

15 document that will be issued with and referenced in the final GEIS and Federal Register Notice 

16 for the final rule.

17 ES.22 How Can I Obtain a Copy of and Comment on the 

18 Draft GEIS and Proposed Rule? 

19 Ways of viewing or obtaining a copy of the draft GEIS are described below:

20 • View an electronic copy of the draft GEIS at http://www.nrc.gov/waste/spent-fuel21 storage/wcd.html

22 • View an electronic copy of the draft GEIS at www.regulations.gov using 

23 Docket ID No. NRC–2012–0246

24 • Request a free CD or hard copy of the draft GEIS by submitting a request to 

25 WCOutreach@nrc.gov, or by calling 301-287-0675

26 There are many ways to submit comments on the draft GEIS and proposed Rule. You can 

27 participate in one of the nationally webcast meetings, which will also be accessible by 

28 telephone, or one of the regional public meetings, where you can state your comments and 

29 obtain additional information related to the draft GEIS and proposed Rule. Comments received 

30 during the public meetings will be transcribed and added to the record. Information on how to 

31 participate in the webcast meetings, and the dates, times, and locations of the regional 

32 meetings can be found at http://www.nrc.gov/public-involve/public-meetings/index.cfm. 
Executive Summary

Draft NUREG‒2157 lxiv September 2013

1 The NRC gives all comments equal weight, no matter who submits them or how they are 

2 submitted. If you cannot participate in one of our nationally webcast meetings or regional public 

3 meetings, you can submit written comments through any of the methods below.

4 Submit comments online at www.regulations.gov using Docket ID No. NRC–2012–0246

5 E-mail comments to Rulemaking.Comments@nrc.gov, citing Docket ID No. NRC–2012–0246

6 Mail comments to Secretary

7 U.S. Nuclear Regulatory Commission

8 Washington, DC 20555-0001

9 ATTN: Rulemakings and Adjudications Staff

10 Fax comments to Secretary

11 U.S. Nuclear Regulatory Commission

12 301-415-1101, citing Docket ID No. NRC–2012–0246

13 Hand-deliver comments to 11555 Rockville Pike, Rockville, Maryland 20852, between 

14 7:30 a.m. and 4:15 p.m. (Eastern Time) on Federal workdays; telephone 301-415-1677.

15 ES.23 When Can I Comment? 

16 You can comment via mail, fax, www.regulations.gov, and e-mail any time from September 13, 

17 2013 through November 27, 2013. 

18
September 2013 lxv Draft NUREG‒2157

Abbreviations/Acronyms

ACHP Advisory Council on Historic Preservation

ADAMS Agencywide Documents Access and Management System

AEC U.S. Atomic Energy Commission

ALARA as low as is reasonably achievable

ANS American Nuclear Society

ANSI American National Standards Institute

ASLBP Atomic Safety and Licensing Board Panel

ASME American Society of Mechanical Engineers

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

COL combined license 

dBA decibel(s) (acoustic)

D.C. District of Columbia

DOE U.S. Department of Energy 

DOT U.S. Department of Transportation

DTS dry transfer system

EA Environmental Assessment

EIS environmental impact statement 

EFH essential fish habitat

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
Abbreviations/Acronyms

Draft NUREG‒2157 lxvi September 2013

FTE full-time equivalent

FWS U.S. Fish and Wildlife Service 

GCRP U.S. Global Change Research Program

GEH General Electric-Hitachi

GEIS Generic Environmental Impact Statement

GHG greenhouse gases

HLW high-level waste

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

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 

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

OMB Office of Management and Budget

OSHA Occupational Safety and Health Administration

PFS Private Fuel Storage, LLC

PFSF Private Fuel Storage Facility

PM particulate matter

PM2.5 particulate matter with a diameter of 2.5 microns or less
Abbreviations/Acronyms

September 2013 lxvii Draft NUREG‒2157

PM10 particulate matter with a diameter of 10 microns or less

PWR pressurized water reactors

RCRA Resource Conservation and Recovery Act of 1976, as amended

REMP radiological environmental monitoring program

TEDE total effective dose equivalent

TMI-2 Three Mile Island Unit 2

TN Transnuclear Inc.

TVA Tennessee Valley Authority

USACE U.S. Army Corps of Engineers

USC United States Code

USCB U.S. Census Bureau

September 2013 lxix Draft NUREG‒2157

Units of Measure

1 Metric Prefixes

tera (T-) 1012 2

giga (G-) 109 3 

mega (M-) 106 4 

kilo (k-) 103 5

hecto (h-) 102 6 

deci (d-) 10‒1 7

centi (c-) 10‒2 8 

milli (m-) 10‒3 9 

mirco (μ-) 10‒6 10

nano (n-) 10‒9 11

pico (p-) 10‒12 12

13

14 Radiological Units

15 μCi/ml microcurie(s) per milliliter 

16 Bq becquerel(s)

17 Ci curie(s)

18 Ci/L curies per liter

19 Ci/yr curie(s) per year

20 mrem millirem

21 mSv millisievert(s)

22 pCi picocurie(s)

23 pCi/L picocurie(s) per liter

24 R roentgen

25 rad special unit of absorbed 

26 dose

27 rem roentgen equivalent man 

28 (a special unit of radiation 

29 dose)

30 S siemens

31 Sv sievert

32

33

34 Length/Distance

35 cm centimeter(s)

36 ft foot or feet

37 in. inch(es)

38 km kilometer(s)

39 m meter(s)

40 mi mile(s)

41 mm millimeter(s)

42 yd yard(s)

43

44 Volume

m3 45 cubic meter(s)

yd3 46 cubic yard(s)

ft3 47 cubic foot(feet)

48 L liter(s) 

49 gal gallon(s)

50 gpd gallon(s) per day

51 gpm gallon(s) per minute 

52 oz ounce(s)

53

54 Area 

55 ha hectare(s)

56 ac acre(s) 

ft2 57 square foot(feet)

mi2 58 square mile(s)

m2 59 square meter(s)

60

61 Units of Time

62 hr hour(s)

63 mo month

64 s second(s)

65 yr year(s)

66 min minute

67 Ryr reactor year(s)

68

69
Units of Measure

Draft NUREG‒2157 lxx September 2013

1 Units of Temperature

2 °C degree(s) Celsius

3 °F degree(s) Fahrenheit

 4 

5 Units of Concentration

6 ppm parts per million

7 ppt parts per thousand

 8 

9 Units of Speed

10 mph mile(s) per hour

11

12

13 Units of Weight

14 MT metric ton(s) (or tonne[s]) 

15 MTU metric ton(s) of uranium

16 T ton(s)

17

18 Units of Power

19 Btu British thermal unit(s) 

20 GWd gigawatt-day(s)

21 MW megawatt(s) 

22 MW(e) megawatt(s) electrical 

23 Ci/L curies per liter

24 L/d liter(s) per day

25 L/min liter(s) per minute

26 ml or mL milliliter(s)

27
September 2013 1-1 Draft NUREG‒2157

1 1.0 Introduction

2 Since the inception of commercial nuclear power, the United States has worked to find a 

3 disposal solution for spent nuclear fuel (spent fuel) generated by commercial nuclear power 

4 reactors. In the late 1970s, the U.S. Nuclear Regulatory Commission (NRC) reexamined an 

5 underlying assumption used in licensing reactors to that time—that a repository could be 

6 secured for the ultimate disposal of spent fuel generated by nuclear reactors, and that spent fuel 

7 could be safely stored in the interim. This analysis was called the Waste Confidence

8 proceeding.

9 This draft Waste Confidence Generic Environmental Impact Statement (draft GEIS) addresses 

10 the environmental impacts of continuing to store spent fuel at a reactor site or at an away-from11 reactor storage facility, after the end of a reactor’s licensed life for operation until final 

12 disposition in a geologic repository (“continued storage”). This draft GEIS has been prepared to 

13 fulfill the Commission’s obligations under the National Environmental Policy Act of 1969, as 

14 amended (NEPA) and NRC regulations implementing NEPA in Title 10 of the Code of Federal 

15 Regulations (CFR) Part 51.

16 1.1 History of Waste Confidence

17 The first Waste Confidence rulemaking began in the late 1970s in response to two significant 

18 legal proceedings. In 1977, the Commission denied a petition for rulemaking filed by the 

19 Natural Resources Defense Council (NRDC) that asked the NRC to determine whether 

20 radioactive wastes generated in nuclear power reactors can be disposed of without undue risk

21 to public health and safety and to refrain from granting pending or future requests for reactor 

22 operating licenses until the NRC made a determination regarding disposal. The Commission 

23 stated in its denial that, as a matter of policy, it “... would not continue to license reactors if it did 

24 not have reasonable confidence that the wastes can and will in due course be disposed of 

25 safely” (42 FR 34391). The Commission’s denial of the NRDC petition was affirmed upon 

26 judicial review (NRDC v. NRC). Since that time, the Federal government has adopted deep 

27 geologic disposal as the national solution for spent fuel disposal (Nuclear Waste Policy Act of 

28 1982). Recently, the U.S. Department of Energy (DOE) reaffirmed the Federal government’s 

29 commitment to the ultimate disposal of spent fuel and predicted that a repository would be 

30 available by 2048 (DOE 2013).

31 At about the same time the Commission denied the NRDC petition, the State of Minnesota and 

32 the New England Coalition on Nuclear Pollution challenged license amendments that permitted 

33 expansion of the capacity of spent fuel storage pools at two nuclear power plants, Vermont 
Introduction

Draft NUREG‒2157 1-2 September 2013

1 Yankee and Prairie Island. In 1979, the Court of Appeals for the District of Columbia (D.C.)

2 Circuit, in Minnesota v. NRC, remanded to the Commission the question of whether an offsite 

3 storage or disposal solution would be available for the spent fuel at the two facilities at the 

4 expiration of their licenses—at that time scheduled for 2007 and 2009—and, if not, whether the 

5 spent fuel could be stored safely at those reactor sites until an offsite solution was available.

6 In 1979, the NRC initiated a generic rulemaking that stemmed from these challenges and the 

7 Court’s remand in Minnesota v. NRC. The Waste Confidence rulemaking generically assessed 

8 whether the Commission could have reasonable assurance that spent fuel produced by nuclear 

9 power plants “... can be safely disposed of....when such disposal or offsite storage will be 

10 available, and....whether radioactive wastes can be safely stored onsite past the expiration of 

11 existing facility licenses until offsite disposal or storage is available” (44 FR 61372). On 

12 August 31, 1984, the Commission published the Waste Confidence decision (49 FR 34658) 

13 (Decision) and a final rule (49 FR 34688), codified at 10 CFR 51.23 (Rule). In addition to 

14 addressing the NRC’s assessment of the issues presented by the Court’s remand, the Decision 

15 provided an environmental assessment (EA) and finding of no significant impact (FONSI) to 

16 support the Rule.

17 The analysis in 10 CFR 51.23 found that, for at least 30 years beyond the expiration of a 

18 reactor’s licensed life for operation, no significant environmental impacts would result from

19 storage of spent fuel, and expressed the Commission’s reasonable assurance that a repository

20 was likely to be available in the 2007 to 2009 timeframe. The Rule also stated that, as a result 

21 of this generic determination, the NRC need not prepare any site-specific environmental 

22 analysis in connection with continuing storage when issuing a license or amended license for a 

23 new reactor or independent spent fuel storage facility (ISFSI) (10 CFR 51.23(b)). 

24 The first review of the Decision and the Rule occurred in 1989 and 1990. This review resulted 

25 in revisions to the Decision and the Rule to reflect revised expectations for the availability of the 

26 first repository, and to clarify that the expiration of a reactor’s licensed life for operation referred 

27 to the full 40-year initial license for operation and a 30-year revised or renewed license. On 

28 September 18, 1990, the Commission published the revised Decision (55 FR 38474) and final 

29 Rule (55 FR 38472).

30 The Commission conducted its second review of the Decision and the Rule in 1999 and 

31 concluded that experience and developments after 1990 had confirmed the findings and made a 

32 comprehensive reevaluation of the Decision and Rule unnecessary. The Commission also 

33 stated that it would consider undertaking a comprehensive reevaluation when the pending 

34 repository development and regulatory activities had run their course or if significant and 

35 pertinent unexpected events occurred that raised substantial doubt about the continuing validity 

36 of the Waste Confidence decision (64 FR 68005). 
Introduction

September 2013 1-3 Draft NUREG‒2157

1 In 2008, the Commission decided to conduct its third review of the Decision and the Rule. This 

2 review resulted in revisions to reflect revised expectations for the availability of the first 

3 repository and to encompass at least 60 years of continued storage. In December 2010, the 

4 Commission published its revised Decision (75 FR 81032) and final Rule (75 FR 81037).

5 In response to the 2010 rulemaking, the States of New York, New Jersey, Connecticut, and 

6 Vermont; several public interest groups; and the Prairie Island Indian Community sought review

7 in the U.S. Court of Appeals for the D.C. Circuit challenging the Commission’s NEPA analysis

8 that supported the Rule. On June 8, 2012, the Court ruled that some aspects of the 

9 2010 Waste Confidence rulemaking did not satisfy the NRC’s NEPA obligations. The Court 

10 therefore vacated the Decision and the Rule and remanded the case to the NRC for further 

11 proceedings consistent with the Decision (New York v. NRC).

12 The Court concluded that the Waste Confidence rulemaking proceeding is a major Federal 

13 action necessitating either an environmental impact statement (EIS) or an EA that results in a 

14 FONSI. The Court identified three deficiencies in the NRC’s environmental analysis:

15 1. Related to the Commission’s conclusion that permanent disposal will be available “when 

16 necessary,” the Court held that the Commission needed to evaluate the environmental 

17 effects of failing to secure permanent disposal, given the uncertainty about whether a 

18 repository would be built.

19 2. Related to 60 years of continued storage, the Court concluded that the Commission had not 

20 adequately examined the risk of spent fuel pool leaks in a forward-looking fashion.

21 3. Also related to continued storage, the Court concluded that the Commission had not 

22 adequately examined the consequences of potential spent fuel pool fires. 

23 In response to the Court’s decision, the Commission stated in Commission Order CLI–12–16 

24 that it would not issue reactor or ISFSI licenses dependent upon the Waste Confidence rule 

25 until the Court’s remand is appropriately addressed (NRC 2012a). This decision is not an 

26 indication that the Commission lacks confidence in the availability of an ultimate disposal

27 solution, but rather reflects the Commission’s need to develop an analysis that assesses the 

environmental impacts of continued storage in a manner addressing the Court’s remand.1 28 

29 The Commission stated, however, that this determination extends only to issuance of the 

30 reactor or ISFSI license, and that all licensing reviews and proceedings should continue to move 

 

1 “Waste confidence undergirds certain agency licensing decisions, in particular new reactor licensing and 

reactor license renewal. Because of the recent court ruling striking down our current waste confidence 

provisions, we are now considering all available options for resolving the waste confidence issue, which 

could include generic or site-specific NRC actions, or some combination of both. We have not yet 

determined a course of action. But, in recognition of our duties under the law, we will not issue licenses 

dependent upon the Waste Confidence Decision or the Temporary Storage Rule until the court’s remand 

is appropriately addressed.” (NRC 2012a) at 4 citations omitted. 
Introduction

Draft NUREG‒2157 1-4 September 2013

1 forward. In SRM–COMSECY–12–016, the Commission directed the NRC to develop a GEIS to 

2 support an updated Waste Confidence decision and rule (NRC 2012b).

3 1.2 Scope of the Generic Environmental Impact Statement

4 This draft GEIS analyzes the environmental impacts of continued storage, and also will provide 

5 a regulatory basis for a proposed revision to the NRC’s Waste Confidence rule.

6 The Waste Confidence rule, originally adopted by the Commission in 1984, satisfies part of the 

7 Commission’s NEPA obligation to prepare an environmental analysis prior to licensing a 

8 commercial nuclear power reactor or a facility that will store the spent fuel generated by 

9 these reactors.

10 For both power reactor and storage facilities, NEPA requires that the NRC address direct, 

11 indirect, and cumulative impacts of its licensing actions. Thus, in issuing a power reactor

12 license, the NRC must analyze the environmental impacts resulting from the generation of spent 

13 fuel by the reactor and its continued storage pending ultimate disposal. Likewise, for an ISFSI, 

14 the NRC must analyze the impacts of continued storage at the facility until ultimate disposal for 

15 the spent fuel is available. The environmental impacts addressed in this draft GEIS are limited 

16 to the environmental impacts of continued storage.

17 This draft GEIS considers three possible continued storage timeframes: (1) short-term storage 

18 of no more than 60 years after the end of a reactor’s licensed life for operation; (2) long-term 

19 storage of no more than 160 years after the end of a reactor’s licensed life for operation; and 

20 (3) indefinite storage at a reactor site or at an away-from-reactor ISFSI. The indefinite storage 

21 scenario assumes that disposal in a repository never becomes available.

22 As discussed above, the NRC has analyzed three timeframes that represent various scenarios 

23 for the length of continued storage that will be needed before spent fuel is sent to a repository. 

24 The first, most likely, timeframe is the short-term timeframe, which analyzes 60 years of 

25 continued storage after the end of a reactor’s licensed life for operation. As discussed in more 

26 detail later this draft GEIS and in Appendix B to this draft GEIS, the NRC believes this is the 

27 most likely timeframe because the DOE has expressed its intention to provide repository 

28 capacity by 2048, which is about 10 years before the end of this timeframe for the oldest spent 

29 fuel within the scope of this analysis. Further, international and domestic experience with deep 

30 geologic repository programs supports a timeline of 25–35 years to provide repository capacity 

31 for the disposal of spent fuel. The DOE’s prediction of 2048 is in line with this expectation. The 

32 NRC acknowledges, however, that the short-term timeframe, although the most likely, is not 

33 certain. Accordingly, this draft GEIS also analyzed two additional timeframes. The long-term 

34 timeframe considers the environmental impacts of continued storage for a total of 160 years 

35 after the end of a reactor’s licensed life for operation. Finally, although the NRC considers it 
Introduction

September 2013 1-5 Draft NUREG‒2157

1 highly unlikely, this draft GEIS includes an analysis of an indefinite timeframe, which assumes 

2 that a repository does not become available.

3 1.3 Purpose of the Generic Environmental Impact Statement

4 This draft GEIS assesses the environmental impacts of continued storage and, if adopted, 

5 would provide a regulatory basis for the NRC’s proposed amendment to 10 CFR 51.23.

6 Consistent with principles of efficient use of agency resources and the Council on 

7 Environmental Quality guidance, publication of this draft GEIS will help the Commission 

8 decide whether the environmental impacts associated with continued storage can be considered 

9 on a generic basis and codified in a rule. If so, then site-specific consideration of continued 

10 storage would be unnecessary. As described in the introduction to this chapter, the 

11 Commission has already generically considered continued storage and related impacts 

12 addressed in 10 CFR 51.23 in various proceedings over the past 40 years. The Commission‘s 

13 operating experience from spent fuel storage and licensing dates back to the 1950s and 

14 supports the assessment of continued storage impacts in a draft GEIS for several reasons: 

15 • Continued storage will involve spent fuel storage facilities for which the environmental 

16 impacts of operation are sufficiently well understood as a result of lessons learned and 

17 knowledge gained from operating experience.

18 • Activities associated with continued storage are expected to be within this well-understood 

19 range of operating experience; thus, environmental impacts can be reasonably predicted.

20 • Changes in the environment around spent fuel storage facilities are sufficiently gradual and 

21 predictable to be addressed using a generic approach.

22 This draft GEIS does not authorize issuance of any NRC license, but rather discloses the 

23 environmental impacts associated with the continued storage of spent fuel. In addition, this 

24 draft GEIS considers alternative approaches to assessing the environmental impacts of 

25 continued storage (see Section 1.6).

26 1.4 Proposed Federal Action

27 The Commission proposes to issue a revised Rule, 10 CFR 51.23, that generically addresses 

28 the environmental impacts of continued storage. This revision would adopt into regulation the 

29 environmental impact analyses in this draft GEIS. Further, the revision would state that 

30 because the impacts of continued storage have been generically assessed in this draft GEIS 

31 and codified in a Rule, NEPA analyses for future reactor and spent fuel storage facility licensing 

32 actions would not need to separately consider the environmental impacts of continued storage.
Introduction

Draft NUREG‒2157 1-6 September 2013

1 1.5 Purpose of and Need for the Proposed Action

2 The purpose and need for the proposed action are threefold: (1) to improve the efficiency of the 

3 NRC’s licensing process by generically addressing the environmental impacts of continued 

4 storage; (2) to prepare a single document that reflects the NRC’s current understanding of these 

5 environmental impacts; and (3) to respond to the issues identified in the remand by the Court in 

6 the New York v. NRC decision.

7 The NRC intends to codify the results of its analyses in this draft GEIS at 10 CFR 51.23. 

8 NRC licensing proceedings for nuclear reactors and ISFSIs will continue to rely on the generic 

9 determination in 10 CFR 51.23 to satisfy obligations under NEPA with respect to the 

10 environmental impacts of continued storage.

11 1.6 Alternatives

12 The NRC could pursue several alternatives, other than the proposed action, to address the 

13 environmental impacts of continued storage in its licensing actions. 

14 • First, the NRC could take no action and address the environmental impacts from continued 

15 storage in each of its nuclear power plant and ISFSI initial licensing and license renewal

16 proceedings.

17 • Second, the NRC could develop a GEIS without incorporating the results into a rule. This 

18 approach would allow the NRC to adopt these draft GEIS findings into environmental 

19 reviews for future licensing activities, but without the binding effect of a rule.

20 • Third, the Commission could issue a policy statement. The policy statement would not bind 

21 licensees and applicants like a rule, but it would provide notice of the Commission’s intent to 

22 incorporate the findings of the GEIS into environmental reviews for future licensing activities.

23 1.6.1 No-Action Alternative

24 Under the no-action alternative, the NRC would take no action to generically address the 

25 environmental impacts of continued storage. The NRC would then perform site-specific reviews 

26 of the environmental impacts of continued storage. These reviews would generally take place 

27 within the context of existing environmental review processes for new reactor licensing, reactor 

28 license renewal, and ISFSI licensing and renewals. In some cases, these reviews could involve 

29 time- and resource-intensive considerations of issues that could readily be resolved on a 

30 generic basis. Therefore, this alternative is not consistent with Council on Environmental 

31 Quality guidance for achieving efficiency and timeliness under NEPA. 

32 In the no-action alternative, it is likely that NRC would first construct complete analyses of the 

33 issues previously addressed by earlier Waste Confidence proceedings resulting in the adoption 
Introduction

September 2013 1-7 Draft NUREG‒2157

1 and revision of 10 CFR 51.23 for use in site-specific NEPA reviews, and then incorporate by 

2 reference the applicable findings from the first few published environmental documents that 

3 used the analyses. This approach could ultimately lead the NRC to consider the issue through 

4 a generic and replicable analysis.

5 From a procedural perspective, the main effect of the no-action alternative is that the NRC 

6 would have to address, in site-specific reviews, the environmental impacts of continued storage 

7 for individual licensing proceedings. Requiring the NRC to prepare site-specific discussions of 

8 generic issues, like those associated with continued storage, could result in the considerable 

9 expenditure of public, NRC, and applicant resources. Further, licensing boards could be 

10 required to hear nearly identical contentions in each proceeding on these generic issues. 

11 Preparing and codifying the generic impacts of continued storage allows the NRC and the 

12 parties to its licensing proceedings to focus their limited resources on the site-specific issues 

13 that are unique to each licensing action.

14 1.6.2 Other Reasonable Alternatives

15 In addition to the proposed action and the no-action alternative, this draft GEIS considers two 

16 other alternatives: a GEIS-only alternative and a policy-statement alternative.

17 1.6.2.1 GEIS-Only Alternative

18 Instead of incorporating the results of this draft GEIS into a binding revision of 10 CFR 51.23, 

19 the NRC could develop and issue a GEIS that addresses the generic environmental effects of 

20 continued storage, which would then be used to support site-specific licensing reviews. This 

21 nonbinding, “GEIS-only” alternative would add somewhat to the efficiency of NRC reviews by 

22 addressing issues that are similar at all sites or that otherwise are susceptible to generic 

23 consideration. For particular licensing actions, the EIS or EA could incorporate by reference 

24 any finding or conclusion of the GEIS, but parties to a proceeding could still file contentions on 

25 continued storage. This approach is consistent with Council on Environmental Quality guidance 

26 regarding efficiency and timeliness under NEPA. 

27 While this approach would be beneficial in terms of improved efficiency, the GEIS’s findings and 

28 conclusions would remain open to challenge in site-specific reviews for reactor and ISFSI 

29 licensing proceedings. Although this incorporation-by-reference approach would satisfy NRC’s 

30 NEPA obligations, this alternative could enable parties in licensing proceedings to raise 

31 contentions that challenge the conclusions of the GEIS. Thus, the “GEIS-only” approach would 

32 eliminate some of the efficiency and time-savings that the NRC would gain through a binding 

33 generic analysis of continued storage, although it would provide greater efficiencies than the no34 action (site-specific) alternative.
Introduction

Draft NUREG‒2157 1-8 September 2013

1 Requiring the NRC to prepare multiple site-specific discussions of generic issues, when a 

2 generic analysis would suffice, would result in considerable expenditure of public, NRC, and 

3 applicant resources. Further, licensing boards might be required to hear nearly identical 

4 contentions in individual licensing proceedings. Determining and codifying the generic impacts 

5 of continued storage, on the other hand, would allow the NRC and parties to its licensing 

6 proceedings to focus their limited resources on the site-specific issues that are unique to each 

7 licensing action.

8 1.6.2.2 Policy-Statement Alternative

9 Instead of incorporating a GEIS into a binding rule on the impacts of continued storage, the 

10 Commission could issue a policy statement that expresses its intent to either incorporate the 

11 environmental impacts determined by the GEIS into site-specific NEPA analyses or to prepare 

12 a site-specific evaluation without regard to the GEIS for each NRC licensing action.

13 In general, a policy statement suffers from many of the same shortcomings as the no-action and 

14 nonbinding GEIS alternatives. The NRC would still need to address the impacts of continued 

15 storage in site-specific NEPA analyses either by incorporating the impacts from the GEIS or 

16 through the consideration of the impacts on a site-specific basis if no GEIS is adopted. Like the 

17 no-action and nonbinding GEIS-only alternatives, the policy-statement alternative would reduce 

18 the efficiencies that the NRC would gain through a rule whose incorporation of environmental 

19 impacts of continued storage would be binding in licensing proceedings, although it would at 

20 least provide notice to parties that the Commission might elect to incorporate by reference all or 

21 a portion of the existing GEIS.

22 Preparation of site-specific analyses of continuing storage impacts, either by incorporating a 

23 generic analysis by reference or by ignoring earlier analyses altogether, would result in 

24 considerable expenditure of public, NRC, and applicant resources. Further, licensing boards 

25 could be expected to hear nearly identical contentions in each proceeding on these generic 

26 issues. Determining and codifying the generic impacts of continued storage would allow the 

27 NRC and parties to its licensing proceedings to focus their limited resources on site-specific 

28 issues that are unique to each licensing action.

29 1.6.3 Alternatives Considered but Eliminated

30 Interested parties submitted numerous scoping comments suggesting that this draft GEIS 

31 should consider other actions as alternatives to the proposed update to 10 CFR 51.23. In 

32 this section, this draft GEIS considers and eliminates the most common suggested alternatives 

33 because they fail to address the purpose and need for this draft GEIS.
Introduction

September 2013 1-9 Draft NUREG‒2157

1 1.6.3.1 Cessation of Licensing or Cessation of Reactor Operation

2 Cessation of licensing activities and cessation of reactor operations do not satisfy the stated 

3 purpose and need for this draft GEIS, which is to improve the efficiency of NRC’s licensing 

4 process, to prepare a single source that reflects the NRC’s current understanding of the 

5 environmental impacts of continued storage, and to comply with the remand in the New York v. 

6 NRC decision. Abandonment of reactor licensing and the closure of existing plants is not a 

7 reasonable alternative to the proposed action because these actions would not meet the NRC’s 

8 stated objectives in proposing to revise 10 CFR 51.23.

9 Through the Atomic Energy Act, Congress has mandated that the NRC establish criteria to 

10 allow the licensing of nuclear power plants. Therefore, without Congressional direction to do so, 

11 the NRC may not deny a reactor license unless it determines that a license applicant has not 

12 met the NRC’s regulatory standards for issuance of a license. Further, unless a threat to the 

13 public health and safety or the common defense and security exists, the NRC has no authority 

14 to deprive current licensees of their vested interest in licenses already issued in compliance with 

15 those regulatory standards. In separate rulemaking actions, the Commission has already 

16 established criteria that provide reasonable assurance of public health and safety and due 

17 consideration of environmental impacts in the construction and operation of nuclear power 

18 plants, including facilities for continuing storage of spent fuel.

19 Although cessation of nuclear power plant licensing and operations would halt the future 

20 generation of spent fuel, other environmental impacts could result from the required 

21 development of replacement power sources or demand reductions. Even then, the 

22 environmental impacts of continued storage would not cease until sufficient repository capacity 

23 becomes available.

24 1.6.3.2 Implementing Additional Regulatory Requirements

25 Imposing new regulatory requirements, such as requiring licensees to implement hardened 

26 at-reactor storage systems, reduce the density of spent fuel in pools, or expedite transfer of 

27 spent fuel from pools to ISFSIs, is outside the scope of this proposed action, which includes 

28 alternatives that improve the efficiency of the NRC’s licensing process by generically addressing 

29 the environmental impacts of continued storage. Adoption of a revised 10 CFR 51.23, 

30 supported by this draft GEIS, is not a licensing action, and does not impose new requirements 

31 on licensees or applicants. Therefore, the NRC cannot impose new requirements or regulations 

32 on the duration of spent fuel storage in pools through this proposed action. In separate 

33 proceedings, the NRC is considering implementing revised security requirements as part of the 

34 ongoing ISFSI security rulemaking effort. The rulemaking effort is described in the 

35 December 16, 2009, Federal Register notice (74 FR 66589), “Draft Technical Basis for 

36 Rulemaking Revising Security Requirements for Facilities Storing SNF [spent nuclear fuel] and 

37 HLW [high-level waste]; Notice of Availability and Solicitation of Public Comments.” Also, the 
Introduction

Draft NUREG‒2157 1-10 September 2013

1 NRC is separately considering expedited transfer of spent fuel from pools as part of lessons 

2 learned from the March 11, 2011 earthquake and subsequent tsunami that badly damaged the 

3 Fukushima I Nuclear Power Plant in Japan (NRC 2012c).

4 1.6.4 Comparison of Reasonable Alternatives

5 The reasonable alternatives considered here include the proposed action (revising 

6 10 CFR 51.23), no action (resulting in site-specific analyses in each licensing proceeding), a 

7 generic EIS without a Rule (GEIS-only), and a Commission policy statement (GEIS-only or site8 specific analysis in each licensing proceeding).

9 The environmental impacts of these three alternatives are substantially the same, and the 

10 licensed activities under all three alternatives remain the same. The alternatives merely 

11 propose alternative means of analyzing the environmental impacts of continued storage. In 

12 subsequent chapters of this draft GEIS, the NRC considers the potential environmental impacts 

13 that result from continued storage. Chapter 7 provides a cost-benefit analysis of the 

14 alternatives.

15 1.7 Public and Agency Involvement

16 1.7.1 Scoping Process

17 The NRC began the environmental review process by publishing a Notice of Intent to prepare

18 an EIS and conduct scoping in the Federal Register on October 25, 2012 (77 FR 65137). The 

19 NRC conducted live and webcast public meetings on November 14, 2012 (NRC 2012d), and 

20 conducted public webinars on December 5 and 6, 2012 (NRC 2012e). The NRC transcribed 

21 the discussions that took place during the scoping meetings and webinars. The NRC received 

22 approximately 700 pieces of comment correspondence, primarily through the website at 

23 www.Regulations.gov (using Docket ID NRC–2012–0246) and, to a lesser extent, by fax and 

24 mail. The scoping period formally closed on January 2, 2013, although staff considered 

25 comments received after this date to the extent practical.

26 Scoping participants included private citizens and representatives of Tribes and State 

27 governments, the U.S. Environmental Protection Agency (EPA), multiple environmental and 

28 advocacy groups, industry, and quasi-governmental organizations. In all, the NRC identified 

29 approximately 1,700 comments from the materials submitted.

30 The NRC responded to comments in its “Waste Confidence Generic Environmental Impact 

31 Statement Scoping Process Summary Report” (NRC 2013a), which was published on March 4, 

32 2013. The summary report, in accordance with 10 CFR 51.29(b), contained a summary of 

33 conclusions reached by the NRC and issues identified as a result of the scoping process. 
Introduction

September 2013 1-11 Draft NUREG‒2157

1 Additional information regarding the summary report is provided in Appendix A. A summary of 

2 outreach and correspondence related to the environmental review is provided in Appendix C.

3 Both this draft GEIS and the proposed Rule will have a concurrent 75-day public comment 

4 period. The comment period will begin on the date of publication of EPA’s Notice of Availability 

5 of this draft GEIS in the Federal Register and will allow interested parties to comment on the 

6 results of the environmental review and the proposed Waste Confidence rule. During this 

7 period, the NRC will conduct public meetings to describe the results of the environmental 

8 review, respond to questions, and accept public comments on this draft GEIS and proposed 

9 rule. Comments received on this draft GEIS and the proposed Rule will be addressed in the 

10 final GEIS and the Rule. 

11 1.7.2 Cooperating Agencies

12 The NRC did not identify any cooperating agencies for the Waste Confidence environmental 

13 review, nor did the NRC receive any formal requests for cooperating agency status.

14 1.8 Analytical Approach

15 The NRC’s methodology and approach to evaluating the environmental impacts of continued 

16 storage follows the guidance in NUREG–1748, “Environmental Review Guidance for Licensing 

17 Actions Associated with NMSS Programs: Final Report” (NRC 2003), where applicable.

18 This draft GEIS evaluates the potential environmental impacts of continued storage at reactor 

19 sites in Chapter 4, and at away-from-reactor sites in Chapter 5. The environmental impacts are 

20 evaluated for three timeframes based on when a repository would become available. This 

21 section outlines the approach, timeframes, assumptions, and previous NEPA assessments the 

22 NRC used in its evaluation.

23 1.8.1 Approach to Impact Assessment

24 To evaluate the potential environmental impacts of continued storage at reactor sites 

25 (Chapter 4), the NRC assumes that spent fuel is stored in a pool and in an ISFSI, both of which 

26 have already been constructed and are operating during reactor operations. Therefore, many of 

27 the impacts of at-reactor continued spent fuel storage can be determined by comparing onsite 

28 activities that occur during reactor operations to the reduced activities that occur during 

29 continued storage. Where appropriate, the environmental impacts during reactor operations are 

30 drawn from the License Renewal GEIS (NRC 2013b), which evaluates the impacts of continued 

31 reactor operation. In addition, this draft GEIS uses analyses in EAs prepared for ISFSIs and 

32 renewals of those ISFSI licenses.
Introduction

Draft NUREG‒2157 1-12 September 2013

1 For the impacts of continued storage at an-away-from-reactor ISFSI, the NRC evaluated the 

2 impacts of an ISFSI of the same size as described in the “Final Environmental Impact Statement 

3 for the Construction and Operation of an Independent Spent Nuclear Fuel Storage Installation 

4 on the Reservation of the Skull Valley Band of Goshute Indians and Related Transportation 

5 Facility in Tooele County, Utah” (NRC 2001). Chapter 5 contains a list of the assumptions used 

6 in that analysis. Unlike in Chapter 4, the generic analysis for away-from-reactor storage at an 

7 ISFSI includes a general discussion of the construction of the facility. However, the site-specific 

8 impacts of the construction and operation of any proposed ISFSI would be evaluated by NRC as 

9 part of that ISFSI’s licensing process.

10 For both the at-reactor and away-from-reactor storage sites, the NRC assumes that the 

11 construction, operation, and replacement of a dry transfer system (DTS) facility is necessary at 

12 some point to handle the transfer of fuel. Chapter 2 provides the physical characteristics of the 

13 reference DTS (see Section 2.1.4).

14 1.8.2 Timeframes Evaluated

15 The NRC evaluated the environmental impacts of continued storage in three timeframes that 

16 begin once the licensed life of the reactor ends—short-term storage, long-term storage, and 

17 indefinite storage (see Figure 1-1). 

18

19 Figure 1-1. Continued Storage Timeframes

Reactor

Licensed 

Life

•40 years of reactor operation on original license

•Up to 40 years of additional renewed license (up to 2 license renewals)

•Impacts evaluated within cumulative impacts analysis (See Chapter 6).

Short-Term 

Storage

•Timeframe is 60 years beyond licensed life for reactor operations

•Assumes a repository becomes available by the end of this timeframe.

Long-Term 

Storage

•Timeframe is for 100 years beyond the short-term storage timeframe

•Assumes a repository becomes available by end of this timeframe.

Indefinite 

Storage

•Assumes no repository becomes available

•Indefinite storage and handling of spent fuel. 
Introduction

September 2013 1-13 Draft NUREG‒2157

1 The first timeframe—short-term storage—lasts for 60 years and begins after the end of the 

2 licensed life for a nuclear power plant. The NRC evaluated the environmental impacts resulting 

3 from the following activities that occur during the short-term storage timeframe:

4 • continued storage of spent fuel in spent fuel pools (at-reactor only) and ISFSIs

5 • routine maintenance of at-reactor spent fuel pools and ISFSIs (e.g., maintenance of 

6 concrete pads)

7 • construction and operation of an away-from-reactor ISFSI (including routine maintenance)

8 • handling and transfer of spent fuel from spent fuel pools to ISFSIs 

9 The next timeframe—long-term storage—is 100 years and begins immediately after the short10 term storage timeframe. The NRC evaluated the environmental impacts resulting from the 

11 following activities that occur during long-term storage: 

12 • continued storage of spent fuel in ISFSIs, including routine maintenance

13 • one-time replacement of ISFSIs and spent fuel canisters and casks

14 • construction and operation of a DTS (including replacement)

15 For the long-term storage timeframe, the NRC assumes that all spent fuel has already been 

16 moved from the spent fuel pool to dry cask storage by the end of the short-term storage 

17 timeframe. The spent fuel pool would be decommissioned within 60 years of permanent 

18 cessation of operation, as required by 10 CFR 50.82.

19 The third timeframe—indefinite storage—assumes that a geologic repository does not become 

20 available. In this timeframe, at-reactor and away-from-reactor ISFSIs would continue to store 

21 spent fuel in dry casks indefinitely. For the evaluation of environmental impacts if no repository 

22 becomes available, the following activities are considered:

23 • continued storage of spent fuel in ISFSIs, including routine maintenance

24 • replacement of ISFSIs and spent fuel canisters and casks every 100 years

25 • construction and operation of an away-from-reactor ISFSI (including replacement every 

26 100 years)

27 • construction and operation of a DTS (including replacement every 100 years)

28 These activities are the same as those that would occur for long-term storage, but without a 

29 repository, they would occur repeatedly.

30 1.8.3 Analysis Assumptions

31 To evaluate the potential environmental impacts of continued storage, this draft GEIS makes 

32 several assumptions.
Introduction

Draft NUREG‒2157 1-14 September 2013

1 • Although the NRC recognizes that the precise time spent fuel is stored in pools and dry cask 

2 storage systems will vary from one reactor to another, this draft GEIS makes a number of 

3 reasonable assumptions regarding the length of time the fuel can be stored in a spent fuel 

4 pool and in a dry cask before the fuel needs to be moved or the facility needs to be 

5 replaced. With respect to spent fuel pool storage, the NRC assumes that all spent fuel is 

6 removed from the spent fuel pool and placed in dry cask storage in an ISFSI no later than 

7 60 years after the end of the reactor’s licensed life for operation. With respect to dry cask 

8 storage, the NRC assumes that the licensee uses a DTS during long-term and indefinite 

9 storage timeframes to move the spent fuel to a new dry cask every 100 years. Similarly, the 

10 NRC assumes that the DTS and the ISFSI pad are replaced every 100 years. For an ISFSI 

11 that reaches 100 years of age near the end of the short-term storage timeframe, the NRC 

12 assumes that the replacement would occur during the long-term storage timeframe.

13 • Based on its knowledge of and experience with the structure and operation of the various 

14 facilities that will provide continued storage, including the normal life of those facilities, 

15 the NRC believes that spent fuel pool storage could last for about 60 years beyond the 

16 licensed life for operation of the reactor where it is stored, and that each ISFSI will last about 

17 100 years, for a total of 160 years or less of likely continued storage if a repository becomes 

18 available.

19 • Institutional controls, i.e., the continued regulation of spent nuclear fuel, will continue. This 

20 assumption avoids unreasonable speculation regarding what might happen in the future 

21 regarding Federal actions to provide for the safe storage of spent fuel. Although 

government agencies2 22 and regulatory safety approaches can be expected to change over 

 

2 Institutional controls are relied upon by Federal agencies that regulate hazards to public health and 

property that persist into the future. For example, the Environmental Protection Agency (EPA) relies on 

institutional controls to ensure that future land use at decontaminated sites is consistent with the type and 

level of cleanup at a site, and the Federal Emergency Management Agency and the U.S. Army Corps of 

Engineers use institutional controls to restrict development in floodplains (ELI 1995). Institutional controls 

associated with Federal programs typically include enforcement tools to address potential problems 

involving improper or incomplete implementation, maintenance, and breaches of institutional controls. 

Examples of institutional controls include permits, Federal Facility Agreements, and environmental 

covenants that apply continuously with present and future ownership of the subject property (under either 

state statute or common law) (EPA 2012). Some Federal agencies acknowledge that it may be 

necessary to have permanent institutional controls (USACE 2000). In addition, EPA recognizes that 

“[f]or some response actions, institutional controls may be selected as a permanent measure to prevent 

unacceptable exposures to contamination that remains in place” (EPA 2012). The Department of Energy 

(DOE), at their Savannah River Site facility, asserts that the entire site will remain under federal 

government ownership within its current boundaries in perpetuity (DOE 2000). 

When reviewing site remedies at Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA) sites, EPA does not consider loss of institutional controls. Rather, as required by 

section 121(c) of CERCLA and consistent with 40 CFR 300.430(f)(4)(ii), EPA conducts five-year reviews 

of the IC components of the implemented remedy (EPA 2011). For disposal sites where waste is buried 

in place or disposed in the subsurface, DOE does consider loss of institutional controls in their 
Introduction

September 2013 1-15 Draft NUREG‒2157

1 long periods of time into the future, the history of radiation protection has generally been 

2 towards ensuring increased safety as knowledge of radiation and effectiveness of safety 

3 measures has improved. For the purpose of the analyses in this draft GEIS, the NRC 

4 assumes that regulatory control of radiation safety will remain at the same level of regulatory 

5 control as currently exists today.

6 • The DOE analyzed a no-action alternative in their Final EIS for Yucca Mountain (DOE 2008) 

7 that considered the loss of institutional controls. In particular, the DOE considered a specific 

8 scenario in which spent fuel and high-level radioactive waste would remain in dry storage 

9 at commercial and DOE sites and would be under institutional controls for approximately 

10 100 years, and beyond that time, it was assumed there would be no institutional controls. 

11 The NRC provided comments to the DOE related to their assumption about the loss of 

12 institutional controls (NRC 2000). The NRC stated that it did not consider the loss of 

13 institutional controls a reasonable assumption because the Federal government would 

14 continue to control licensed material under its authority for as long as necessary to protect 

15 the public health and safety. 

16 • A DTS will be built at each ISFSI location during long-term storage timeframe to facilitate 

17 spent fuel transfer and handling.

18 • The NRC assumes a 100-year replacement cycle for spent fuel canisters and casks. This 

19 assumption is consistent with assumptions made in the Yucca Mountain Final EIS (DOE

20 2008). 

21 • The 100-year replacement cycle also assumes replacement of the ISFSI facility and DTS.

 

Environmental Impact Statements (EISs). For example, in their post-closure EIS analysis for the 

Savannah River Site F- and H-Tank Farms, DOE assessed the potential impacts if institutional controls 

were lost after 100 years and residents move into or intruders entered the tank farm areas (DOE 2002). 

However, DOE’s post closure analysis of the F- and H-Tank Farms needed to demonstrate that the tank 

closure meets applicable disposal performance requirements, which is unrelated to the indefinite storage 

of licensed spent nuclear fuel considered in this draft Generic EIS. DOE also took a similar approach in 

their EIS analysis for the Waste Isolation Pilot Plant site where it was assumed that the earliest time that 

penetration of the buried material could occur was 100 years after repository closure (i.e., the end of the 

active institutional control period) (DOE 1997). DOE’s approach to the loss of institutional controls at a 

dry cask storage facility was provided in its Yucca Mountain EIS (DOE 2008). In its analysis, DOE found 

that the loss of institutional controls resulted in catastrophic impacts for several resource areas. These

approaches to institutional controls were related to post-closure buried radioactive waste and are not 

relevant to the indefinite dry cask storage of licensed spent nuclear fuel considered in Waste Confidence. 

A dry cask spent nuclear fuel storage facility is not sited, designed, or built to avoid active maintenance 

like a low-level waste disposal facility. Further, at some period beyond the closure of the disposal facility, 

there is a potential that the knowledge of the intended purpose of the facility could be lost, thereby 

increasing the likelihood that an inadvertent intrusion could occur. In contrast, a dry storage facility is 

typically a visible surface structure requiring active maintenance and security, making loss of institutional 

control so unlikely that it is a remote and speculative occurrence. Given that the National Environmental 

Policy Act does not require consideration of remote and speculative issues, this analysis has not been 

included in this GEIS. 
Introduction

Draft NUREG‒2157 1-16 September 2013

1 • Based on currently available information, the 100-year replacement cycle provides a 

2 reasonably conservative assumption for a storage facility that would require replacement at 

3 a future point in time. However, this assumption does not mean that dry cask storage 

4 systems and facilities need to be replaced every 100 years to maintain safe storage.

5 • The NRC assumes that the land used for the ISFSI pads and DTS would be reclaimed after 

6 the facilities are demolished and, therefore, could be used again in the next 100-year 

7 replacement cycle. The NRC believes this assumption is reasonable because the 

8 characteristics of the previously disturbed land are already known and are suitable for ISFSI 

9 and DTS design and construction.

10 • The NRC assumes that aging management, including routine maintenance activities and 

11 programs occurs between replacements. These “routine” or planned maintenance activities 

12 are distinct from the “replacement” of facilities and equipment.

13 • The spent fuel is moved from the spent fuel pool to dry cask storage within the short-term 

14 storage timeframe.

15 • Under NRC regulations, a nuclear power plant that operates for the term specified in its 

16 license is required to complete decommissioning within 60 years after the licensed life for 

17 operations in accordance with 10 CFR 50.82 or 52.110. Under these regulations, a plant 

18 that terminates its license early is required to complete decommissioning within 60 years 

19 after the permanent cessation of operation. Consistent with this requirement, the NRC 

20 assumes that by the end of the short-term storage timeframe, a licensee will either terminate 

21 its Part 50 or 52 license and receive a specific Part 72 ISFSI license (see 10 CFR Part 72, 

22 Subpart C) or apply to receive Commission approval under 10 CFR 50.82(a)(3) or 52.110(c) 

23 to continue decommissioning under its Part 50 or 52 license. Accordingly, the NRC would 

24 conduct any appropriate site-specific NEPA analysis for either issuance of a Part 72 ISFSI 

25 license upon termination of the licensee’s Part 50 or 52 license or approval to continue 

26 decommissioning beyond 60 years after ceasing operations in accordance with 10 CFR 

27 50.82(a)(3) or 52.110(c). Further, the NRC assumes that replacing an ISFSI and licensing a 

28 DTS are licensing actions that would be subject to separate site-specific NEPA reviews. 

29 The ISFSI and DTS would be decommissioned separately.

30 • Replacement of the entire ISFSI would occur over the course of each 100-year interval, 

31 starting at the beginning of the long-term storage timeframe. 

32 • Construction, operation, and replacement of the DTS are assumed to occur within the long33 term storage timeframe. If the DTS is built at the beginning of the long-term storage 

34 timeframe, it could be near the end of its useful life by the end of that storage timeframe. To 

35 be conservative, the NRC included the impacts of replacing the DTS one time during the 

36 long-term storage timeframe. 

37 • Because an away-from-reactor ISFSI could store fuel from several different reactors, the 

38 earliest an away-from-reactor ISFSI would enter the short-term timeframe is when the first of 

39 these reactors reaches the end of its licensed life for operation.
Introduction

September 2013 1-17 Draft NUREG‒2157

1 • 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). 2 3

3 • A typical spent fuel pool of 700 metric tons of uranium (MTU) storage capacity reaches its 

4 licensed capacity limit about 30 years into the licensed life for operation of a reactor. At 

5 that point, some of the spent fuel would need to be removed from the spent fuel pool and 

6 transferred to a dry cask storage system at either an at-reactor or away-from-reactor ISFSI.

7 • The environmental impacts of constructing a “spent fuel pool island,” which allows the spent 

8 fuel pool to be isolated from other reactor plant systems to facilitate decommissioning, are 

9 considered within the analysis of cumulative effects in Chapter 6. Because a new spent fuel 

10 pool cooling system would be smaller in size and have fewer associated impacts than 

11 existing spent fuel pool cooling systems, the environmental impacts of operating the new 

12 spent fuel pool cooling system in support of continued storage in the spent fuel pool, would 

13 be bound by the impacts of operating the existing cooling system described in Chapter 4.

14 • It is assumed that an ISFSI of sufficient size to hold all spent fuel generated will be 

15 constructed during the licensed life for operation. 

16 • Sufficient low-level waste (LLW) disposal capacity will be made available when needed. 

17 Historically, the demand for LLW disposal capacity has been met by private industry. NRC 

18 expects that this trend will continue in the future. For example, in response to demand for 

19 LLW disposal capacity, Waste Control Specialists, LLC, opened a LLW disposal facility in 

20 Andrews County, Texas on April 27, 2012.

21 The analyses in this draft GEIS are based on current technology and regulations. Appendix B 

22 provides further information supporting the analysis assumptions. These analyses are not 

23 intended to be, and should not be interpreted as, representative of any specific storage facility 

24 or site in the United States where spent fuel is currently stored or could be stored in the future. 

25 1.8.4 Other Environmental Analyses

26 Numerous NRC proceedings, regulations, or NEPA documents address the environmental 

27 impacts of other NRC-regulated activities: the licensed life for operation of a commercial 

28 nuclear power facility, the licensed life of an ISFSI, spent fuel transportation, the nuclear fuel 

29 cycle, license termination, and ultimate spent fuel disposal. This is depicted in Figure 1-2. A 

30 brief description of these other NEPA documents and regulations are presented below. Some 

31 of the NEPA documents used to support the analyses in this draft GEIS are listed in Table 1-1. 

32

 

3 The Commission’s regulations provide that renewed operating licenses may be subsequently renewed, 

although no licensee has yet submitted an application for such a subsequent renewal. This draft GEIS 

included two renewals as a conservative assumption in evaluating potential environmental impacts.
Draft NUREG‒2157 1-18 September 2013

1

Figure 1-2. NEPA Analyses for Other NRC Activities 2

Nuclear Power Plants and ISFSIs Licensed Life for Operations

•Initial Licensing EISs, License Renewals SEISs, and License 

Amendments EAs for nuclear power plants

•Initial Licensing EISs and EAs and License Renewal EAs for ISFSIs

•Transportation Impacts - 10 CFR 51.52

•Uranium Fuel Cycle - 10 CFR 51.51

Nuclear Power Plant Decommissioning

•Decommissioning GEIS

Nuclear Power Plant License Termination

• License Termination EIS

Continued Storage of Spent Fuel

•Activity covered by this draft GEIS.

Ultimate Disposal of Spent Fuel

•Will be evaluated in a future EIS.

•Generic Discussion of Impacts of a Repository - Table S-3
Introduction

September 2013 1-19 Draft NUREG‒2157

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

Document Agency Date Availability

Final EIS for a Geologic Repository for the 

Disposal of Spent Nuclear Fuel and HighLevel Radioactive Waste at Yucca 

Mountain, Nye County, Nevada and its 

supplements

DOE June 2008 Online at www.energy.gov

ML081750212(a)

Generic EISs

Final Generic EIS on Decommissioning of 

Nuclear Facilities Supplement 1 Regarding 

the Decommissioning of Nuclear Power 

Reactors

NRC November 

2002

NUREG–0586(b)

ML023470323

Spent Fuel Transportation Risk

Assessment

NRC May 2012 NUREG–2125(b)

ML12125A218

Final Generic EIS on Handling and 

Storage of Spent Light Water Power 

Reactor Fuel 

NRC August 

1979

NUREG–0575(b)

ML022550127

ISFSI Licensing

EA for 10 CFR Part 72 Licensing 

Requirements for the Independent Storage 

of Spent Fuel and High-Level Radioactive 

Waste 

NRC August 

1984

NUREG–1092(b)

ML091050510

Final EIS 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

NRC December 

2001

NUREG–1714(b)

ML020150217

Environmental Assessment Related to the 

Construction and Operation of the 

H.B. Robinson Independent Spent Fuel 

Storage Installation

NRC March 

1986

ML060200531(a)

Environmental Assessment for the Trojan 

Independent Spent Fuel Storage 

Installation

NRC November 

1996

ML060410416(a)

Environmental Assessment for the License 

Renewal of the General Electric Morris 

Operation Independent Spent Fuel Storage 

Installation in Morris, Illinois

NRC November 

2004

ML043360415(a)

2
Introduction

Draft NUREG‒2157 1-20 September 2013

Table 1-1. List of NEPA Documents Used in Preparation of this Draft GEIS (cont’d)

Document Agency Date Availability

Final Environmental Impact Statement for 

the Construction and Operation of an 

Independent Spent Fuel Storage 

Installation to Store the Three Mile Island 

Unit 2 Spent Fuel at the Idaho National 

Engineering and Environmental Laboratory 

NRC March 

1998

NUREG–1626(b)

ML123480202

Environmental Assessment Related to the 

Construction and Operation of the Oconee 

Nuclear Station Independent Spent Fuel 

Storage Installation - Redacted 

NRC October 

1988

ML123480209(a) (Redacted) 

Environmental Assessment Related to the 

Construction and Operation of the Calvert 

Cliffs Independent Spent Fuel Storage 

Installation – Redacted 

NRC March 

1991

ML123480177(a) (Redacted)

Environmental Assessment for Proposed 

Renewal of Calvert Cliffs Nuclear Power 

Plant Independent Spent Fuel Storage 

Installation

NRC April 2012 ML121220084(a)

Environmental Assessment Related to the 

Construction and Operation of the Fort St. 

Vrain Independent Spent Fuel Storage 

Installation 

NRC February 

1991

ML123480181(a) (Redacted) 

Environmental Assessment Related to the 

Construction and Operation of the 

Humboldt Bay Independent Spent Fuel 

Storage Installation 

NRC October 

2005

ML052430106

Notice of Issuance of Environmental 

Assessment and Finding of No Significant 

Impact for the Diablo Canyon Independent 

Spent Fuel Storage Installation

NRC October 

2003

ML032970369

Environmental Assessment Related to the 

Construction and Operation of the Rancho 

Seco Independent Spent Fuel Storage 

Installation

NRC August 

1994

ML123480187(a) (Redacted) 

Environmental Assessment Related to the 

Construction and Operation of the North 

Anna Independent Spent Fuel Storage 

Installation 

NRC March 

1997

ML123480192(a) (Redacted)
Introduction

September 2013 1-21 Draft NUREG‒2157

Table 1-1. List of NEPA Documents Used in Preparation of this Draft GEIS (cont’d)

Document Agency Date Availability

Reactor License Renewals

Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, 

Rev. 1 

NRC May 2013 NUREG–1437(b)

Vol. 1 ML13106A241

Vol. 2. ML13106A242

Vol. 3. ML13106A244

Supplemental Environmental Impact 

Statement for Wolf Creek Generating 

Station License Renewal 

NRC May 2008 NUREG–1437, Supplement 32(b)

New Reactor Licensing

Environmental Impact Statement for the 

Combined License (COL) for Enrico Fermi 

Unit 3

NRC January 

2013

NUREG–2105(b)

Vol. 1 ML12307A172

Vol. 2 ML12307A176

Vol. 3 ML12307A177

Vol. 4 ML12307A202

Environmental Impact Statement for 

Combined Licenses (COLs) for South 

Texas Project Electric Generating Station 

Units 3 and 4 

NRC February 

2011

NUREG–1937(b)

Vol. 1 ML111290826

Vol. 2 ML11049A001

Environmental Impact Statement for the 

Combined License (COL) for Calvert Cliffs 

Nuclear Power Plant Unit 3 

NRC May 2011 NUREG–1936(b)

ML12026A658

Draft Environmental Impact Statement for 

Combined Licenses (COLs) for William 

States Lee III Nuclear Station Units 1 

and 2 

NRC December 

2011

NUREG–2111

Vol. 1 ML11343A010

Vol. 2 ML11343A011

Previous Waste Confidence Rules and Decisions

Federal Register Notice – “Consideration 

of Environmental Impacts of Temporary 

Storage of Spent Fuel After Cessation of 

Reactor Operation; Waste Confidence

Decision Update; Final Rules”

NRC December 

2010

75 FR 81032

Federal Register Notice – “Waste 

Confidence Decision Review: Status”

NRC December 

1999

64 FR 68005

Federal Register Notice – “Consideration 

of Environmental Impacts of Temporary 

Storage of Spent Fuel After Cessation of 

Reactor Operation; and Waste Confidence

Decision Review; Final Rules”

NRC September 

1990

55 FR 38472
Introduction

Draft NUREG‒2157 1-22 September 2013

Table 1-1. List of NEPA Documents Used in Preparation of this Draft GEIS (cont’d)

Document Agency Date Availability

Federal Register Notice – “Waste 

Confidence Decision and Requirements for 

Licensee Actions Regarding the 

Disposition of Spent Fuel Upon Expiration 

of Reactor Operating Licenses; Final 

Rules”

NRC August 

1984

49 FR 34658

(a) ADAMS can be accessed online. Accession numbers are provided for EAs.

(b) NUREGs can be found online at the NRC’s website.

1 The storage of spent fuel during the initial licensed term for operation of a nuclear reactor is 

2 considered within the site-specific EIS for either a 10 CFR Part 50 or 10 CFR Part 52 licensing 

3 review.

4 The impacts from renewing the operating licenses for commercial nuclear power plants for up to 

5 an additional 20 years are evaluated in site-specific EISs, which tier off the License Renewal

6 GEIS (NRC 2013b). The License Renewal GEIS addresses spent fuel storage during the

7 license renewal term. The findings from the License Renewal GEIS with respect to 

8 environmental impacts of continued nuclear power plant operations have been codified in 

9 regulation (in 10 CFR Part 51, Table B-1 of Appendix B to Subpart A).

10 The impacts from storage of spent fuel during the initial and renewed licensed terms of an ISFSI 

11 are addressed in site-specific NEPA reviews for licensees that elect to construct ISFSIs with 

12 specific licenses under 10 CFR Part 72. For those licensees that elect to construct an ISFSI 

13 under a general license, the environmental review has already been conducted and 

14 documented in an EA (NRC 1989).

15 The impacts from decommissioning nuclear power plants have previously been evaluated in 

16 Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities 

17 Supplement 1 Regarding the Decommissioning of Nuclear Power Reactors Main Report

18 (Decommissioning GEIS) (NRC 2002), although the Decommissioning GEIS expressly excludes 

19 matters related to the environmental impacts of continued storage.

20 The environmental impacts of portions of the uranium fuel cycle that occur before new fuel is 

21 delivered to the plant and after spent fuel is sent to a disposal site have been evaluated and are 

22 codified in regulation (10 CFR 51.51, Table S–3).

23 Impacts from the transportation of fuel and waste to and from a nuclear power reactor are 

24 codified in regulation (10 CFR 51.52, Table S–4).

25 The environmental impacts of residual radioactivity remaining after license termination are 

26 addressed in the Generic Environmental Impact Statement in Support of Rulemaking on 
Introduction

September 2013 1-23 Draft NUREG‒2157

1 Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities: Final Report

2 (License Termination Rule GEIS) (NRC 1997).

3 The environmental impacts of a specific geologic repository will be addressed in the EIS that the 

4 DOE is required to submit for any geologic repository application that it submits.

5 1.8.5 Significance of Environmental Impacts

6 The NRC has established a standard of significance for assessing environmental issues. In 

7 NRC environmental reviews, significance indicates the importance of likely environmental 

8 impacts and is determined by considering two variables: context and intensity. Context is the 

9 geographic, biophysical, and social setting in which the effects will occur. Intensity refers to the 

10 severity of the impact, in whatever context it occurs. The NRC uses a three-level standard of 

11 significance based upon the President’s Council on Environmental Quality guidelines 

12 (40 CFR 1508.27):

13 SMALL – Environmental effects are not detectable or are so minor that they will neither 

14 destabilize nor noticeably alter any important attribute of the resource. For the purposes 

15 of assessing radiological impacts, the Commission has concluded that radiological

16 impacts that do not exceed permissible levels in the Commission’s regulations are 

17 considered small.

18 MODERATE – Environmental effects are sufficient to alter noticeably, but not to 

19 destabilize, important attributes of the resource.

20 LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize 

21 important attributes of the resource.

22 For issues in which the significance determination is based on risk (i.e., the probability of 

23 occurrence as well as the potential consequences), the probability of occurrence as well as the 

24 potential consequences have been factored into the determination of significance. For some 

25 resource areas, the impact determination language is specific to the authorizing regulation or 

26 statute (e.g., “not likely to adversely impact” for historic and cultural resources).

27 1.8.6 Issues Eliminated from Review in this GEIS

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

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

30 topics include:

31 • noncommercial spent fuel (e.g., defense waste)

32 • commercial high level waste generated from reprocessing
Introduction

Draft NUREG‒2157 1-24 September 2013

1 • greater-than-class-C LLW

2 • advanced reactors (e.g., high-temperature and gas-cooled reactors)

3 • foreign spent fuel

4 • nonpower reactor spent fuel (e.g., test and research reactors)

5 • need for nuclear power

6 • reprocessing of commercial spent fuel

7 The “Waste Confidence Generic Environmental Impact Statement Scoping Process Summary 

8 Report” (NRC 2013a) provides additional details on topics that are considered out of scope for 

9 this draft GEIS.

10 1.8.7 Draft GEIS Contents

11 The subsequent chapters of this draft GEIS are organized as follows. Chapter 2 describes 

12 typical facility characteristics and activities that are used to assess environmental impacts of 

13 continued storage. Chapter 3 describes the affected environment. Chapters 4 and 5 include 

14 analyses of potential environmental impacts of at-reactor storage (Chapter 4) and away-from15 reactor storage (Chapter 5). Chapter 6 evaluates the cumulative impacts of continued storage 

16 with other reasonable past, present, and reasonably foreseeable actions. Chapter 7 provides 

17 cost-benefit analyses of the alternatives. Chapter 8 summarizes the findings of the preceding 

18 chapters and presents the NRC’s recommendation with respect to which alternative should be 

19 chosen. Chapter 9 provides a list of the staff who authored this draft GEIS.

20 Appendices to this draft GEIS provide the following additional information:

21 • Appendix A – Scoping Comments

22 • Appendix B – Technical Feasibility of Continued Storage and Repository Availability

23 • Appendix C – Outreach and Correspondence

24 • Appendix D – Draft GEIS Comments and Responses

25 • Appendix E – Analysis of Spent Fuel Pool Leaks

26 • Appendix F – Spent Fuel Pool Fires

27 • Appendix G –Spent Fuel Storage Facilities

28 • Appendix H – Estimated Costs of Alternatives
Introduction

September 2013 1-25 Draft NUREG‒2157

1 1.9 Other Applicable Federal Requirements

2 Atomic Energy Act of 1954, as amended - The Atomic Energy Act of 1954, as amended, 

3 provides fundamental jurisdictional authority to the DOE and the NRC over governmental and 

4 commercial use of nuclear materials. This Act ensures proper management, production, 

5 possession, and use of radioactive materials. To comply with the Act, NRC has established

6 requirements published in Title 10 of the CFR.

7 This Act gives NRC authority to regulate the possession, transfer, storage, and disposal of 

8 nuclear materials, as well as aspects of transportation packaging design for radioactive 

9 materials that include testing for packaging certification. This Act gives EPA the authority to 

10 develop standards for the protection of the environment and public health from radioactive 

11 material.

12 National Environmental Policy Act of 1969, as amended – The NRC has prepared this draft 

13 GEIS in accordance with the NRC’s implementing regulations for NEPA (10 CFR Part 51).

14 Energy Reorganization Act of 1974, as amended - The Energy Reorganization Act of 1974 

15 (Act of 1974), as amended, established the NRC. Under the Atomic Energy Act of 1954, a 

16 single agency, the Atomic Energy Commission, had responsibility for the development and 

17 production of nuclear weapons and for both the development and the safety regulation of the 

18 civilian uses of nuclear materials. The Act of 1974 split these functions, assigning to one 

19 agency, now the DOE, the responsibility for the development and production of nuclear 

20 weapons, promotion of nuclear power, and other energy-related work, and assigning to the NRC 

21 the regulatory work, which does not include regulation of defense nuclear facilities. The Act of 

22 1974 gave the Commission its collegial structure and established its major offices. The later 

23 amendment to the Act of 1974 also provided protections for employees who identify nuclear 

24 safety concerns.

25 Nuclear Waste Policy Act of 1982, as amended - The Nuclear Waste Policy Act provides for 

26 the research and development of repositories for the disposal of high-level radioactive waste, 

27 spent fuel, and low-level radioactive waste. The Act assigns responsibility for the construction

28 of a deep geologic repository to the DOE. 

29 Administrative Procedure Act of 1946, as amended - The Administrative Procedure Act is 

30 the fundamental law governing the processes of Federal administrative agencies. It requires, 

31 for example, that affected persons be given adequate notice of proposed rules and an 

32 opportunity to comment on the proposed rules. This Act gives interested persons the right to 

33 petition an agency for the issuance, amendment, or repeal of a rule. It also provides standards 

34 for judicial review of agency actions.
Introduction

Draft NUREG‒2157 1-26 September 2013

1 The Administrative Procedure Act has been amended often and now incorporates several other 

2 acts. Three of these incorporated acts deal with access to information: The Freedom of 

3 Information Act, The Government in the Sunshine Act, and The Privacy Act. The Freedom of 

4 Information Act requires that agencies make public their rules, adjudicatory decisions, 

5 statements of policy, instructions to staff that affect a member of the public, and, upon request, 

6 other material that does not fall into one of the act's exceptions for material dealing with national 

7 security, trade secrets, and other sensitive information. The Government in the Sunshine Act

8 requires that collegial bodies such as the Commission hold their meetings in public, with 

9 certain exceptions for meetings on matters such as national security. The Privacy Act limits 

10 release of certain information about individuals.

11 Two other incorporated acts are noteworthy: The Regulatory Flexibility Act and The 

12 Congressional Review Act. The Regulatory Flexibility Act requires that agencies consider the 

13 special needs and concerns of small entities in conducting rulemaking. The Congressional 

14 Review Act requires that every agency rule be submitted to Congress before being made 

15 effective, and that, before being made effective, every "major" rule sit before Congress for 

16 60 days, during which time the rule can be subjected to an accelerated process that can lead 

17 to a statutory modification or disapproval of the rule.

18 1.10 References

19 10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, “Agency Rules of 

20 Practice and Procedure.” Washington, D.C.

21 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

22 Production and Utilization Facilities.” Washington, D.C.

23 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

24 Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

25 Washington, D.C.

26 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

27 Certifications, and Approvals for Nuclear Power Plants.” Washington, D.C.

28 10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing 

29 Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

30 Waste, and Reactor-Related Greater Than Class C Waste.” Washington, D.C.

31 40 CFR Parts 1500 through 1508. Code of Federal Regulations, Title 40, Protection of 

32 Environment, Parts 1500 “Purpose, Policy, and Mandate” through 1508 “Terminology and 

33 Index.” Washington, D.C.
Introduction

September 2013 1-27 Draft NUREG‒2157

1 42 FR 34391. July 5, 1977. “Denial of Petition for Rulemaking.” Federal Register, U.S. Nuclear 

2 Regulatory Commission, Washington, D.C.

3 44 FR 61372. October 25, 1979. “Storage and Disposal of Nuclear Waste.” Federal Register, 

4 U.S. Nuclear Regulatory Commission, Washington, D.C.

5 49 FR 34658. August 31, 1984. “Waste Confidence Decision and Requirements for Licensee 

6 Actions Regarding the Disposition of Spent Fuel Upon Expiration of Reactor Operating 

7 Licenses; Final Rules.” Federal Register, U.S. Nuclear Regulatory Commission, 

8 Washington, D.C.

9 49 FR 34688. August 31, 1984. “Waste Confidence Decision.” Federal Register, U.S. Nuclear 

10 Regulatory Commission, Washington, D.C.

11 55 FR 38472. September 18, 1990. “Consideration of Environmental Impacts of Temporary 

12 Storage of Spent Fuel After Cessation of Reactor Operation; and Waste Confidence Decision 

13 Review; Final Rules.” Federal Register, U.S. Nuclear Regulatory Commission, 

14 Washington, D.C.

15 55 FR 38474. September 18, 1990. “Waste Confidence Decision Review.” Federal Register, 

16 U.S. Nuclear Regulatory Commission, Washington, D.C.

17 64 FR 68005. December 6, 1999. “Waste Confidence Decision Review: Status.” Federal 

18 Register, U.S. Nuclear Regulatory Commission, Washington, D.C.

19 74 FR 66589. December 16, 2009. “10 CFR 72 and 73.” Federal Register, U.S. Nuclear 

20 Regulatory Commission, Washington D.C.

21 75 FR 81032. December 23, 2010. “Consideration of Environmental Impacts of Temporary 

22 Storage of Spent Fuel After Cessation of Reactor Operation; Waste Confidence Decision 

23 Update; Final Rules.” Federal Register, U.S. Nuclear Regulatory Commission, 

24 Washington, D.C.

25 75 FR 81037. December 23, 2010. “Waste Confidence Decision Update.” Federal Register, 

26 U.S. Nuclear Regulatory Commission, Washington, D.C.

27 77 FR 65137. October 25, 2012. “Notice of Intent To Prepare an Environmental Impact 

28 Statement for the Consideration of Environmental Impacts of Temporary Storage of 

29 Spent Fuel After Cessation of Reactor Operation.” Federal Register, U.S. Nuclear Regulatory 

30 Commission, Washington, D.C.

31 Administrative Procedures Act. 5 USC 500, et seq. 

32 Atomic Energy Act of 1954. 42 USC 2011, et seq.
Introduction

Draft NUREG‒2157 1-28 September 2013

1 Congressional Review Act. 5 USC 801–808.

2 DOE (U.S. Department of Energy). 1997. Waste Isolation Pilot Plant Disposal Phase Final 

3 Supplemental Environmental Impact Statement. DOE/EIS-0026-S-2, Carlsbad Area Office, 

4 Carlsbad, New Mexico. Available at http://www.wipp.energy.gov/library/seis/MainMenu.pdf

5 DOE (U.S. Department of Energy). 2000. Savannah River Site Long Range Comprehensive 

6 Plan. PIT-MISC-0041. Accession No. ML111220334. 

7 DOE (U.S. Department of Energy). 2002. Savannah River Site High-Level Waste Tank Closure 

8 Final Environmental Impact Statement. DOE/EIS-0303, Savannah River Operations Office, 

9 Aiken, South Carolina. Available at http://www.doe.gov/sites/prod/files/EIS-0303-FEIS-01-

10 2002.pdf.

11 DOE (U.S. Department of Energy). 2008. Final Supplemental Environmental Impact Statement 

12 for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive 

13 Waste at Yucca Mountain, Nye County, Nevada. DOE EIS–0250F–S1, Office of Civilian 

14 Radioactive Waste Management, Las Vegas, Nevada. Accession No. ML081750212.

15 DOE (U.S. Department of Energy). 2013. Strategy for the Management and Disposal of Used 

16 Nuclear Fuel and High-Level Radioactive Waste. Washington, D.C. Accession 

17 No. ML13011A138.

18 ELI (Environmental Law Institute). 1995. Institutional Controls in Use: A Report by the 

19 Environmental Law Institute to the Environmental Protection Agency. Washington, D.C. 

20 Available at http://www.elistore.org/reports_detail.asp?ID=372. 

21 EPA (U.S. Environmental Protection Agency). 2011. Recommended Evaluation of Institutional 

22 Controls: Supplement to the 'Comprehensive Five-Year Review Guidance. OSWER Directive 

23 9355.7-18. Available at http://www.epa.gov/superfund/policy/ic/guide/641333.pdf. 

24 EPA (U.S. Environmental Protection Agency). 2012. Institutional Controls: A Guide to Preparing 

25 Institutional Control Implementation and Assurance Plans at Contaminated Sites. EPA-540-R26 09-002. Available at 

27 http://www.epa.gov/superfund/policy/ic/guide/ICIAP%20guidance%20(FINAL)%20-

28 %2012.04.2012.pdf. 

29 Energy Reorganization Act of 1974, as amended. 42 USC 5801.

30 Freedom of Information Act. 5 USC 552.

31 Government in the Sunshine Act of 1976. 5 USC 552b.

32 National Environmental Policy Act (NEPA) of 1969. USC 4321–4347.
Introduction

September 2013 1-29 Draft NUREG‒2157

1 Natural Resources Defense Council (NRDC) v. U. S. Nuclear Regulatory Commission (NRC). 

2 1978. 582 F. 2d 166, U.S. Court of Appeals, District of Columbia Circuit.

3 NRC (U.S. Nuclear Regulatory Commission). 1984. Environmental Assessment for 10 CFR 

4 Part 72 “Licensing Requirements for the Independent Spent Fuel and High-Level Radioactive 

5 Waste.” NUREG–1092, Washington, D.C. ML091050510.

6 NRC (U.S. Nuclear Regulatory Commission). 1989. Environmental Assessment and Finding of 

7 No Significant Impact for Proposed Rule Entitled, “Storage of Spent Nuclear Fuel in NRC8 Approved Storage Casks at Nuclear Power Reactor Sites.” Washington, D.C. Accession 

9 No. ML051230231.

10 NRC (U.S. Nuclear Regulatory Commission). 1997. Generic Environmental Impact Statement 

11 in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed 

12 Nuclear Facilities: Final Report. NUREG–1497, Volume 1, Washington, D.C. Accession 

13 No. ML042310492. 

14 NRC (U.S. Nuclear Regulatory Commission). 2000. Letter from William Kane, NRC, to Ivan 

15 Itkin, DOE dated February 22, 2000, regarding “NRC’s Comments on the U.S. DOE’s 

16 Environmental Impact Statement for a Geologic Repository for the Disposal of Spent Nuclear 

17 Fuel and High-Level Radioactive Waste at Yucca Mountain, Nye County, Nevada.” 

18 Washington, D.C. Accession No. ML003684722. 

19 NRC (U.S. Nuclear Regulatory Commission). 2001. Final Environmental Impact Statement for 

20 the Construction and Operation of an Independent Spent Nuclear Fuel Storage Installation on 

21 the Reservation of the Skull Valley Band of Goshute Indians and Related Transportation Facility 

22 in Tooele County, Utah. NUREG–1714, Volume 1, Washington, D.C. Accession 

23 No. ML020150217.

24 NRC (U.S. Nuclear Regulatory Commission). 2002. Final Generic Environmental Impact 

25 Statement on Decommissioning of Nuclear Facilities Supplement 1 Regarding the 

26 Decommissioning of Nuclear Power Reactors Main Report. NUREG–0586, Supplement 1, 

27 Volume 1, Washington, D.C. Accession No. ML023470323. 

28 NRC (U.S. Nuclear Regulatory Commission). 2003. Environmental Review Guidance for 

29 Licensing Actions Associated with NMSS Programs: Final Report. NUREG–1748, 

30 Washington, D.C. Accession No. ML032450279.

31 NRC (U.S. Nuclear Regulatory Commission). 2012a. Memorandum and Order dated August 7, 

32 2012, regarding “Petition to Suspend Final Decision on All Pending Reactor Licensing 

33 Proceedings.” Commission Order CLI–12–16, Washington, D.C. Accession 

34 No. ML12220A094.
Introduction

Draft NUREG‒2157 1-30 September 2013

1 NRC U.S. Nuclear Regulatory Commission). 2012b. Memorandum from R.W. Borchardt to 

2 A.L. Vietti-Cook dated September 6, 2012, regarding “Staff Requirements – COMSECY–

3 12-0016 – Approach for Addressing Policy Issues Resulting from Court Decision to Vacate 

4 Waste Confidence Decision and Rule.” Washington, D.C. Accession No. ML12250A032. 

5 NRC (U.S. Nuclear Regulatory Commission). 2012c. Program Plans for Tier 3 

6 Recommendations. SECY12 0095, Washington, D.C. Accession Nos. ML12208A208 (SECY); 

7 ML12165A092 (Enclosure 1); ML12165A093 (Enclosure 2); and ML12208A210 (Enclosure 3).

8 NRC (U.S. Nuclear Regulatory Commission). 2012d. Summary of Public Scoping Meetings for 

9 Environmental Impact Statement to Support Waste Confidence Rulemaking. Washington, D.C. 

10 Accession No. ML12339A281.

11 NRC (U.S. Nuclear Regulatory Commission). 2012e. Summary of Public Scoping Webinars for 

12 the Environmental Impact Statement to Support the Waste Confidence Rulemaking. 

13 Washington, D.C. Accession No. ML12356A293.

14 NRC (U.S. Nuclear Regulatory Commission). 2013a. Waste Confidence Generic 

15 Environmental Impact Statement Scoping Process Summary Report. Washington, D.C. 

16 Accession No. ML13060A128.

17 NRC (U.S. Nuclear Regulatory Commission). 2013b. Generic Environmental Impact Statement 

18 for License Renewal of Nuclear Plants. NUREG–1437, Revision 1, Washington, D.C. 

19 Accession No. ML13107A023. 

20 Nuclear Waste Policy Act of 1982. 42 USC 10101, et seq.

21 Privacy Act of 1974. 5 USC 552a. 

22 Regulatory Flexibility Act of 1981. 5 USC 601–612. 

23 State of Minnesota v. U.S. Nuclear Regulatory Commission (NRC). 1979. Nos. 78–1269 and 

24 78–2032, U.S. Court of Appeals, District of Columbia Circuit. 

25 State of New York, et al. v. U.S. Nuclear Regulatory Commission (NRC). 2012. No. 11–1045,

26 U.S. Court of Appeals, District of Columbia Circuit.

27 USACE (U.S. Army Corps of Engineers). 2000. Establishing and Maintaining Institutional 

28 Controls for Ordinance and Explosives (OE). EP 1110-1-24. Available at 

29 http://publications.usace.army.mil/publications/eng-pamphlets/EP_1110-1-24/EP_1110-1-

30 24.pdf. 
September 2013 2-1 Draft NUREG‒2157

1 2.0 Generic Facility Descriptions and Activities

2 This chapter describes typical facility characteristics and activities that the U.S. Nuclear 

3 Regulatory Commission (NRC) used to assess environmental impacts that may occur from 

4 continued storage of spent nuclear fuel (spent fuel) beyond the licensed life for operation of a 

5 reactor (continued storage).

6 2.1 Generic Facility Descriptions 

7 Most commercial spent fuel is stored at reactor sites in spent fuel pools and at-reactor 

8 independent spent fuel storage installations (ISFSIs). Some commercial spent fuel is stored 

9 under NRC regulatory oversight at away-from-reactor ISFSIs such as the GE-Hitachi Nuclear 

10 Energy Americas, LLC, Morris wet storage facility in Morris, Illinois (GEH Morris) and the 

11 U.S. Department of Energy’s (DOE) Three Mile Island, Unit 2, Fuel Debris ISFSI at the Idaho 

National Engineering Laboratory.1,2 12 The remainder of the commercial spent fuel has either been 

13 reprocessed at the former Nuclear Fuel Services reprocessing facility in western New York or 

14 removed from reactor sites by the DOE, or its predecessor agencies, and is no longer regulated 

15 by the NRC. The spent fuel addressed by the generic analysis in this draft Waste Confidence

16 Generic Environmental Impact Statement (draft GEIS) is the commercial spent fuel regulated by 

17 the NRC. Spent fuel or commercial high-level waste derived from reprocessing of spent fuel 

18 under the control of other agencies of the Federal government is not included in this generic 

19 analysis. Additional information on the scope of this draft GEIS is presented in Chapter 1.

20 The following sections provide generic descriptions of NRC-licensed facilities that store 

21 commercial spent fuel, with an emphasis on characteristics relevant to continued storage. 

22 These descriptions provide physical context for the generic activities described in Section 2.2.

23 2.1.1 At-Reactor Continued Storage Site Descriptions

24 The following sections describe the general characteristics of at-reactor continued storage sites, 

25 which are identical to nuclear power plant sites.

 

1 DOE holds three ISFSI licenses from 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 did not construct the proposed ISFSI and, on 

December 20, 2012, it submitted a request to the NRC to terminate its license (PFS 2012).
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-2 September 2013

1 2.1.1.1 General Description of Single-Unit Nuclear Power Plant Site

2 This section describes a generic single-unit nuclear power plant site, which is where continued 

3 storage will occur in spent fuel pools and at-reactor ISFSIs. Key differences between a single4 unit site and multiple-unit site, relevant to continued storage, are described in Section 2.1.1.2.

5 A nuclear power plant site, including its associated ISFSI, contains a number of buildings or 

6 structures. Among them are a containment building or reactor building, turbine building, 

7 auxiliary building, vent stacks, meteorological towers, and cooling systems (which may include

8 cooling towers). A nuclear power plant also includes large parking areas, security fencing, 

9 switchyards, water-intake and -discharge facilities, and transmission lines. While reactor, 

10 turbine, and auxiliary buildings are often clad or painted in colors that are intended to reduce or 

11 mitigate their visual presence, the heights of many of the structures, coupled with safety lights, 

12 make power plants visible from many directions and from great distances. Typical heights of 

13 structures found on these facilities are as follows: reactor buildings are 90 m (300 ft), turbine 

14 buildings are 30 m (100 ft), stacks are 90 m (300 ft), meteorological towers are 60 m (200 ft), 

15 natural draft cooling towers are higher than 150 m (500 ft), and mechanical draft cooling towers 

16 are 30 m (100 ft) tall. Transmission-line towers are between 20 and 50 m (70 and 170 ft) in 

17 height, depending on the voltage being carried (NRC 2013a).

18 There are two types of power reactors currently in use in the United States—boiling water 

19 reactors (BWRs) and pressurized water reactors (PWRs). In general, all nuclear power plant 

20 sites, when operating, are similar in terms of the types of onsite structures; however, the layout 

21 of buildings and structures varies considerably among the sites. In addition, while these 

22 buildings and structures are necessary during operations, many of the structures may be 

23 removed, mothballed, or entombed as a result of the decommissioning process, depending on 

24 several factors, including which decommissioning option licensees select and other operational 

25 considerations. Many of these structures will be present at the beginning of continued storage 

26 analyzed in this draft GEIS. As decommissioning of the reactor facility progresses, the number 

27 of onsite structures will decline until only continued storage-related structures are present at the 

28 beginning of the long-term storage timeframe. The following list describes typical structures 

29 located on most sites following the permanent cessation of reactor operations (NRC 2013a):

30 • Containment or reactor building. The containment or reactor building of a PWR is a massive 

31 concrete or steel structure that houses the reactor vessel, reactor coolant piping and pumps, 

32 steam generators, pressurizer, pumps, and associated piping. In general, the reactor 

33 building of a BWR includes a containment structure and a shield building. The reactor 

34 containment building is a massive steel and concrete structure that houses the reactor 

35 vessel, the reactor coolant piping and pumps, and the suppression pool. It is located inside 

36 a shield building.

37 • Fuel building. For PWRs, the fuel building has a fuel pool that is used to store and service 

38 spent fuel and prepare new fuel for insertion into the reactor. This building is connected to 
Generic Facility Descriptions and Activities

September 2013 2-3 Draft NUREG‒2157

1 the reactor containment building by a transfer tube or channel that is used to move new fuel 

2 into the reactor and move spent fuel out of the reactor for storage. For plants with a 

3 BWR/6 reactor, spent fuel is stored in an adjacent Fuel Building or Fuel Handling Building.

4 • Turbine building. The turbine building houses the turbine generators, condenser, feedwater 

5 heaters, condensate and feedwater pumps, waste-heat rejection system, pumps, and 

6 equipment that support those systems.

7 • Auxiliary buildings. Auxiliary buildings house support systems (e.g., the ventilation system, 

8 emergency core cooling system, laundry facilities, water treatment system, and waste

9 treatment system). An auxiliary building may also contain the emergency diesel generators 

10 and, in some PWRs, the diesel fuel storage facility. 

11 • Diesel generator building. Often a separate building houses the emergency diesel 

12 generators if they are not located in the auxiliary building.

13 • Pump houses. Various pump houses for circulating water, standby service water, or 

14 makeup water may be onsite.

15 • Cooling towers. Cooling towers are structures designed to remove excess heat from the 

16 condenser without dumping the heat directly into waterbodies (e.g., lakes or rivers). The 

17 two principal types of cooling towers are mechanical draft towers and natural draft towers. 

18 Most nuclear plants with once-through cooling do not have cooling towers. However, seven

19 facilities with once-through cooling also have cooling towers that are used to reduce the 

20 temperature of the water before it is released to the environment.

21 • Radwaste facilities. Radioactive waste facilities may be contained in an auxiliary building or 

22 located in a separate radwaste building.

23 • Ventilation stack. Many older nuclear power plants, particularly BWRs, have ventilation 

24 stacks to discharge gaseous waste effluents and ventilation air directly to the outside. 

25 These stacks can be 90 m (300 ft) tall or higher and contain monitoring systems to ensure 

26 that radioactive gaseous discharges are below fixed release limits.

27 • Switchyard and transmission lines. Facilities typically contain a large switchyard that

28 connects the site to the regional power distribution system.

29 • Administrative, training, and security buildings. In most cases, administrative, training, and 

30 security buildings are located outside the protected area of the plant.

31 • Independent spent fuel storage installations. An ISFSI is designed and constructed for the 

32 interim storage of spent fuel pending permanent disposal. ISFSIs are used by operating 

33 plants to add spent fuel storage capacity beyond that available in spent fuel pools.

34 Nuclear power plant facilities are large industrial complexes with land-use requirements 

35 generally amounting to 40 to 50 ha (100 to 125 ac) for the reactor containment building, 
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-4 September 2013

1 auxiliary buildings, cooling system structures, administration and training offices, and other 

2 facilities (e.g., switchyards, security facilities, and parking lots). Areas disturbed during 

3 construction of the power plant generally have been returned to prior uses or were ecologically 

4 restored when construction ended. Site areas range from 34 ha (84 ac) for the San Onofre 

5 plant in California to 5,700 ha (14,000 ac) for the Clinton plant in Illinois. Almost 60 percent of

6 plant sites encompass 200 to 800 ha (500 to 2,000 ac), with 28 site areas ranging from 200 to 

7 400 ha (500 to 1,000 ac) and an additional 12 sites encompassing 400 to 800 ha (1,000 to 

8 2,000 ac). Larger land areas are often associated with elaborate man-made closed-cycle 

9 cooling systems that include cooling lagoons, spray canals, reservoirs, artificial lakes, and buffer 

10 areas (NRC 2013a). 

11 Nuclear power plant sites are located in a range of political jurisdictions, including towns, 

12 townships, service districts, counties, parishes, and states. Typically, the nearest resident lives 

13 about 0.4 km (0.25 mi) from a nuclear power plant and ISFSI. At more than 50 percent of the 

sites, the population density within a 80-km (50-mi) radius is fewer than 77 persons/km2 14

(200 persons/mi2 15 ), and at more than 80 percent of the sites, the density within 80 km (50 mi) is 

fewer than 193 persons/km2 (500 persons/mi2 16 ). The largest population density is around the 

17 Indian Point Nuclear Generating Station in upper Westchester County, New York, which has a 

population density within 80 km (50 mi) of more than 825 persons/km2 (2,138 persons/mi2 18 ). 

19 Within the 80-km (50-mi) radius, State, Federal, and Native American lands are present to 

20 various extents (NRC 2013a).

21 The nuclear power plant structures that are used for continued storage of spent fuel, namely 

22 spent fuel pools and at-reactor ISFSIs, are described in more detail in Section 2.1.2 of this draft 

23 GEIS. Power plant-specific data on spent fuel pools and ISFSIs is provided in Appendix G of 

24 this draft GEIS. As shown in Appendix G, spent fuel pool licensed capacities at single-unit 

25 PWR power plants range from 544 assemblies at H.B. Robinson Steam Electric Plant, Unit 2, to 

26 2,363 assemblies at the Callaway Plant and Wolf Creek Generating Station. At BWR plants, 

27 spent fuel pool capacities range from 1,803 assemblies at the Brunswick Steam Electric 

28 Generating plant to 4,608 assemblies at Fermi Unit 2.

29 2.1.1.2 General Description of Multiple-Unit Nuclear Power Plant Sites

30 During continued storage at a multiple-unit site, other onsite reactors may be in different 

31 stages of their life cycles: under construction; operating; or decommissioning. Subject to 

32 NRC regulations that ensure independence of safety systems, multiple reactors may share 

33 systems, structures, and components (e.g., a spent fuel pool). Existing nuclear power 

34 plants with shared spent fuel pools are summarized in Table 2-1. Dresden Units 2 and 3

35 and Comanche Peak Units 1 and 2 do not share a pool, but have two pools in one structure. 

36 Other common structures at multiple-unit sites include cooling system infrastructure, 

37 switchyards, and ISFSIs (Sailor et al. 1987).
Generic Facility Descriptions and Activities

September 2013 2-5 Draft NUREG‒2157

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

Power Plant(a)

Shared Pool Capacity

Assemblies (cores)

Braidwood 2,984 (13.5)

Byron 2,984 (13.5)

Calvert Cliffs 1,830 (8.4)

D.C. Cook 3,613 (18.7)

North Anna 1,737 (11.1)

Oconee(b) 1,312 (7.4)

Point Beach 1,502 (12.4)

Prairie Island 1,582 (13.1)

Surry Units 1,044 (6.6)

Zion(c) 3,012 (15.6)

(a) Source: Individual plant operating licenses www.nrc.gov.

(b) Oconee Units 1 and 2 share a pool. Unit 3 has a separate pool.

(c) Zion Units 1 and 2 were permanently shut down on February 13, 1998.

2 As noted in the Decommissioning GEIS (NRC 2002a), licensees that choose to shut down one 

3 reactor at a multi-reactor site usually choose a decommissioning option that allows the 

4 shutdown reactor to be placed in a safe, stable condition and maintained in that state until other 

reactors shut down, so that all reactors at a site can be decommissioned simultaneously.3 5 In 

6 these cases, a licensee may opt to store spent fuel in the shutdown reactor’s spent fuel pool 

7 until all reactors undergo decommissioning. Alternatively, the licensee may transfer some or all 

8 of the spent fuel in the shutdown reactor’s spent fuel pool to spent fuel pools for the other 

9 operating reactors or to an at-reactor or away-from-reactor ISFSI, and begin some 

10 dismantlement activities in the shutdown reactor’s spent fuel pool. As discussed in Chapter 1, 

11 the NRC assumes that, in compliance with current decommissioning requirements, all of a 

12 reactor’s spent fuel will have been removed from the spent fuel pool within 60 years after the 

13 end of the reactor’s licensed life for operation.

14 2.1.1.3 Reactor and Fuel Technologies

15 Several commercial reactor designs have been built and operated in the United States. As 

16 described below, the generic analysis in this draft GEIS is focused on past, present, and future 

17 spent fuel types that will be subject to a future NRC licensing action. These fuel types include: 

18 fuel types that have been used in the past and continue to be stored under an NRC license; fuel 

19 types that are presently used; and fuel types for which the characteristics are similar to fuel 

20 used today, are well understood, and may be used in the near future.

 

3 See Section 2.2 below for a description of the SAFSTOR option.
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-6 September 2013

1 Light Water Reactors

2 The majority of reactors that have been licensed for commercial operation in the United States, 

3 including the currently operating nuclear power plants and those under construction, are light 

4 water reactors. Light water reactors use ordinary water as coolant and a neutron moderator to 

5 initiate and control the nuclear reaction. The two light water reactor designs in use are PWRs

and BWRs. There are 69 PWRs and 35 BWRs operating in the United States today.4 6 This is 

7 important for the generic analysis of continued storage because these reactors all use similar 

8 fuel, which means that the NRC can generically consider the environmental impacts of 

9 continuing to store spent fuel after a reactor’s licensed life for operation.

10 The nuclear fuel typically used in both types of 

11 reactors is uranium enriched to a concentration of 2 

12 to 5 percent of the uranium-235 isotope. The fuel is 

13 in the form of cylindrical uranium dioxide (UO2) 

14 pellets, approximately 1 cm (0.4 in) in diameter and 

15 1 to 1.5 cm (0.4 to 0.6 in) in height. The fuel pellets 

16 are stacked and sealed inside a hollow cylindrical 

17 fuel rod made of zirconium alloy. As described 

18 further below, a small amount of stainless-steel-clad fuel was used in the past and is still being 

19 stored under NRC licenses. The fuel rods are approximately 4.3 m (14 ft) long. They are 

20 bundled into fuel assemblies that generally consist of 15 × 15 or 17 × 17 rods for PWRs and 

21 8 × 8 or 10 × 10 rods for BWRs. For PWRs, there are typically 150 to 200 fuel assemblies, 

22 containing between 179 and 264 fuel rods per assembly, loaded into the core when operating. 

23 For BWRs, there are typically between 370 and 800 fuel assemblies, containing between 91 

24 and 96 fuel rods per assembly, loaded into the core when operating. The mass of uranium fuel 

25 in a typical light water reactor core is about 90 MTU, regardless of whether the reactor is a PWR 

26 or BWR design.

27 As shown in Table 2-2, fuel with stainless-steel cladding was used at five plants that are all shut 

28 down. LaCrosse was the last decommissioning plant to transfer its stainless-clad fuel from its 

29 pool into an at-reactor dry storage ISFSI in September 2012 (UxC 2013). Some of the Haddam 

30 Neck and San Onofre Unit 1 stainless-clad fuel is stored at the GEH Morris away-from-reactor 

31 ISFSI and the remainder is in at-reactor dry storage. The continued storage of this fuel is 

32 covered by NRC licenses.

 

4 Crystal River Nuclear Generating Plant, Unit 3, and Kewaunee Power Station, both PWRs, have 

announced plans to permanently cease operations.

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

September 2013 2-7 Draft NUREG‒2157

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

Plant

Discharged 

Stainless-Clad 

Assemblies(a)

Stored at GEH 

Morris ISFSI(b)

Haddam Neck 945(c) 82

Indian Point Unit 1 160 ---

LaCrosse 333 ---

San Onofre Unit 1 665 270

Yankee Rowe 76 ---

Total 2,179 352

Sources:

(a) EIA 1994.

(b) NRC 2004a.

(c) S. Cohen & Associates, Inc. 1998.

2 The amount of spent fuel accumulated at a reactor over its licensed life depends on factors such 

3 as how long the reactor operates each year, the duration of outages, spent fuel burnup, and 

4 operating lifetime. For purposes of analysis in this draft GEIS, the NRC assumes reactors 

5 operate with high capacity factors and short outages, which results in the generation of more 

6 spent fuel.

7 Spent fuel burnup describes the extent to which energy has been extracted from nuclear fuel. 

8 Burnup is the actual energy released per mass of initial fuel in GWd/MTU. Spent fuel is 

9 considered to have low burnup if the burnup is less than 45 GWd/MTU. At low burnups, about 

10 one-fourth to one-third of the spent fuel assemblies are removed from the reactor and replaced

11 every 12 to 18 months. Therefore, the amount of spent fuel discharged from a light water 

12 reactor to its spent fuel pool is about 20 MTU per year. After 80 years of reactor operation, this 

13 amounts to about 1,600 MTU of spent fuel. A reactor could operate for 80 years if the licensee 

14 requested, and the NRC granted, two 20-year renewals of its initial 40-year operating license.

15 Currently, the average discharge burnup for PWRs and BWRs is approximately 48 and 

16 43 GWd/MTU, respectively (EPRI 2010). By 2020 it is projected that the maximum discharge 

17 burnups for PWRs and BWRs will be 58 and 48 GWd/MTU, respectively (EPRI 2010). The 

18 current trend toward extended irradiation cycles and higher fuel enrichments of up to 5 weight 

19 percent uranium-235 has led to an increase of the burnup range for discharged nuclear fuel 

20 assemblies in the United States that is expected to exceed 60 GWd/MTU. For plants at which 

21 higher fuel burnups are authorized, the period between outages may be extended to 24 months 

22 and the annual discharge of spent fuel reduced to about 15 MTU per year. Should a nuclear 

23 power plant operate for up to 80 years with high-burnup fuel, it would generate about 

24 1,200 MTU of spent fuel. For purposes of analysis in this draft GEIS, the NRC relies for 

25 impact analysis on the larger reactor lifetime amount of spent fuel discharged at low burnups 

26 (i.e., 1,600 MTU), unless otherwise stated in the description of environmental impacts. This is 

27 because many of the environmental impacts (e.g., land use, geology and soils, and terrestrial 
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-8 September 2013

1 resources) will depend upon the greater amount of space needed to store the larger amounts of 

2 spent fuel that would be generated at low burnups. In cases where high-burnup fuel is a 

3 consideration in the impact determination, which is the case with spent fuel pool fires, this is 

4 explained in the supporting analysis.

5 Mixed Oxide Fuel

6 Mixed oxide (MOX) fuel is a type of nuclear reactor fuel that contains plutonium oxide mixed 

7 with either natural or depleted uranium oxide in ceramic pellet form. Using plutonium reduces 

8 the amount of enriched uranium needed to produce a controlled reaction in commercial light 

9 water reactors. MOX fuel was produced and used in the United States prior to the mid-1970s; 

10 during that time, the United States reprocessed nuclear fuel and recovered plutonium for reuse 

11 as MOX fuel in light water reactors. MOX fuel was used at Quad Cities, San Onofre, Big Rock 

12 Point, Dresden Unit 1 and, as recently as 2005–2008, Catawba Unit 1. Catawba Unit 1 used 

13 four MOX lead test assemblies that were part of a nonproliferation project conducted by the 

14 National Nuclear Security Administration. Because the MOX fuel is substantially similar to 

15 existing uranium oxide light water reactor fuel and was, in fact, used in existing light water

16 reactors in the United States, it is within the scope of this draft GEIS. 

17 MOX fuel is not currently being produced in the United States; however, an application is 

18 pending before the NRC for Shaw AREVA MOX Services (formerly Duke COGEMA Stone & 

19 Webster) to manufacture MOX fuel at the Mixed Oxide Fuel Fabrication Facility at the Savannah 

20 River Site in South Carolina as part of the National Nuclear Security Administration’s ongoing 

21 nonproliferation project. The MOX fuel proposed to be manufactured by Shaw AREVA MOX 

22 Services is a blend of plutonium dioxide, extracted from retired nuclear weapons and other 

23 sources of surplus plutonium, and depleted uranium dioxide, which is a byproduct of the 

24 uranium enrichment process. Because the MOX fuel that would be generated at the Mixed 

25 Oxide Fuel Fabrication Facility is substantially similar to existing light water reactor fuel and is, 

26 in fact, intended for use in existing light water reactors in the United States, MOX fuel from this 

27 project is within the scope of this draft GEIS. 

28 Integral Pressurized Water Reactors

29 The NRC is preparing to review a number of integral pressurized water reactor (iPWR) designs 

30 that are currently under development. An iPWR is a small modular reactor that uses light water 

31 reactor technology. Current iPWR designs employ light water reactor technology with current 

32 design fuel and secondary loop steam generators, but also incorporate a number of advanced 

33 features and characteristics (NRC 2012a). The NRC is currently engaged in preapplication 

34 activities with several applicants for light water small modular reactors.
Generic Facility Descriptions and Activities

September 2013 2-9 Draft NUREG‒2157

1 Because the light water reactor fuel that would be used in iPWR designs is substantially similar 

2 to existing light water reactor fuel (i.e., zirconium-clad, low-enriched uranium oxide pellets in 

3 square fuel rod arrays), it is within the scope of this draft GEIS. 

4 Other Commercial Reactor and Fuel Designs

5 In addition to light water reactors, two other reactor technologies are sufficiently well developed 

6 to be deployed for use as commercial nuclear power plants: the high-temperature gas-cooled 

7 reactor and the liquid metal fast reactor. As described in more detail below, with the exception 

8 of high-temperature gas reactor fuel stored in the Fort Saint Vrain ISFSI, spent fuel generated 

9 by these technologies is not within the scope of the analysis in this draft GEIS because neither

10 technology is in commercial use or under development in the United States at this time.

11 High-Temperature Gas-Cooled Reactors

12 A high-temperature gas-cooled reactor is a type of nuclear fission reactor that typically operates 

13 at a very high temperature, is graphite-moderated, and uses an inert gas such as helium as its 

14 primary coolant. Fuel may be loaded in the core in a prismatic or pebble bed design. In the 

15 United States, there have been two high-temperature gas-cooled reactors built and 

16 commercially operated: Fort Saint Vrain and Peach Bottom Unit 1. Fort Saint Vrain has been 

17 decommissioned, and Peach Bottom Unit 1 is in the process of decommissioning. The 

18 Fort Saint Vrain spent fuel continues to be stored at an NRC-licensed ISFSI in Plattesville, 

Colorado, and is within the scope of this draft GEIS.

5 19 Peach Bottom Unit 1 fuel is under Federal 

20 government control at the Idaho National Laboratory and is not within the scope of this draft 

21 GEIS because it is no longer regulated by the NRC. 

22 The NRC is participating in preapplication reviews of the DOE’s Next Generation Nuclear Plant. 

23 The Next Generation Nuclear Plant would use nuclear fuel comprised of tristructural-isotropic24 coated fuel particles contained in either fuel pebbles or prismatic fuel assemblies. The uranium

25 oxycarbide kernels in each particle would be encapsulated in successive layers of silicon 

26 carbide and pyrolitic carbon. 

27 Because this fuel type has not completed fuel qualification testing, it is not yet a commercially 

28 viable technology. If this technology should become viable and the NRC is asked to review one 

29 or more license applications for a high-temperature gas-cooled reactor facility, then the 

30 environmental impacts of continued storage of spent fuel will be considered in individual 

31 licensing proceedings unless the NRC updates the GEIS and corresponding rule to include the 

32 environmental impacts of storing this type of fuel after a reactor’s licensed life for operation.

 

5 The NRC renewed the operating license for the Fort St. Vrain ISFSI in May 2011, after completing an 

environmental assessment and finding of no significant impact (76 FR 30399).
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-10 September 2013

1 Liquid Metal Fast Reactor

2 Liquid metal fast reactors use a molten metal (e.g., sodium) as their primary coolant. Fuel for a 

3 liquid metal fast reactor varies by concept, but typically consists of a mix of uranium and 

4 zirconium or a mix of uranium, plutonium, and zirconium. In the United States, Enrico Fermi 

5 Unit 1 was a liquid-sodium-cooled fast reactor that operated between 1963 and 1972. Fermi 

6 Unit 1 is in the process of decommissioning and all spent fuel has been removed from the site 

7 and is now the responsibility of the DOE. 

8 The NRC is engaged in preliminary preapplication discussions with the designers of three liquid 

9 metal fast reactors—Toshiba Corporation's Super-Safe, Small and Simple design, General 

10 Electric Hitachi’s Power Reactor Innovative Small Module design, and Gen4 Energy’s Gen4 

11 Module design. The fuel types in these designs range from a mix of uranium-zirconium or 

12 uranium-plutonium-zirconium metal alloys to stainless-steel-clad uranium nitride.

13 These fuel types have not completed fuel qualification testing and are not yet commercially 

14 viable technologies. If these technologies should become viable and the NRC is asked to 

15 review one or more license applications for a liquid metal fast reactor facility, then the 

16 environmental impacts of continued storage of spent fuel will be considered in individual 

17 licensing proceedings unless the NRC updates the GEIS and corresponding rule to include the 

18 environmental impacts of storing this type of fuel after a reactor’s licensed life for operation.

19 2.1.2 Onsite Spent Fuel Storage and Handling

20 As of the end of 2011, the amount of commercial spent fuel in storage at commercial nuclear 

21 power plants is an estimated 67,500 MTU. The amount of spent fuel in storage at commercial 

22 nuclear power plants is expected to increase at a rate of approximately 2,000 MTU per year

23 (NRC 2012a).

24 Licensees have designed spent fuel pools to temporarily store spent fuel in pools of 

25 continuously circulating water that cool the spent fuel assemblies and provide shielding from 

26 radiation. When industry designed the current fleet of operating nuclear power plants, it 

27 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 reprocessing6 28 no 

29 commercial spent fuel reprocessing facilities are currently operating or planned in the 

30 United States (NRC 2012b).

 

6 In furtherance of anti-proliferation policies, the Federal government declared a moratorium on 

reprocessing spent fuel in 1976. This moratorium was lifted in 1981, but in 1993, President Clinton 

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

September 2013 2-11 Draft NUREG‒2157

1 2.1.2.1 Spent Fuel Pools

2 Spent fuel pools are designed to store and cool spent fuel following its removal from a reactor. 

3 Spent fuel pools are massive and durable structures constructed from thick, reinforced-concrete 

4 walls and slabs that vary between 0.7 and 3 m (2 and 10 ft) thick. Typically, spent fuel pools are 

5 at least 12 m (40 ft) deep, allowing the spent fuel to be covered by at least 6 m (20 ft) of water, 

6 which provides adequate shielding from the radiation for anyone near the pool. All spent fuel 

7 pools currently in operation are lined with stainless-steel liners that vary in thickness from 6 to 

8 13 mm (0.25 to 0.5 in.). Further, all spent fuel pools have either a leak-detection system or 

9 administrative controls to monitor the spent fuel pool liner (NRC 2012a). Typically, leak10 detection systems are made up of several individually monitored channels or are designed so 

11 that leaked water empties into monitored drains. Leaked water is directed to a sump, liquid 

12 radioactive waste treatment system, or other cleanup or collection system.

13 Reactor designers originally anticipated that spent fuel would be stored for less than 1 year 

14 before being shipped to a reprocessing plant for separation of the fissile isotopes. For this 

15 reason, currently operating reactors originally had storage capacity for one full core plus one or 

16 two additional discharged batches of spent fuel. When the United States abandoned spent fuel 

17 reprocessing and spent fuel pools began to fill up, licensees expanded fuel storage capacity by 

18 replacing the original storage racks with higher density fuel racks. Licensees achieved the 

19 higher density by taking into account in their safety assessments the neutron-absorbing 

20 characteristics of the stainless-steel structure of the storage racks and incorporating plates or 

21 sheets containing a neutron absorber material for reactivity control (EPRI 1988). As a result, a

22 typical spent fuel pool at a light water reactor now holds the equivalent of about six reactor core 

23 loads, or about 700 MTU (see Appendix G).

24 On this basis, the NRC has adopted as its reference spent fuel pool, one that has 700 MTU 

25 storage capacity that reaches its licensed capacity limit in about 35 years into licensed life for 

26 operation of a reactor. At that point, some of the spent fuel would need to be removed from the 

27 spent fuel pool and transferred to a dry cask storage system at either an at-reactor or away28 from-reactor ISFSI.

29 Two events have resulted in changes to NRC requirements for physical security and the safe 

30 operation of spent fuel pools. The first was the terrorist attacks on September 11, 2001. The 

31 NRC ordered all operating nuclear power plants to immediately implement compensatory 

32 security measures. In addition, the NRC issued orders to decommissioning reactor licensees 

33 that imposed additional security measures associated with access authorization, fitness for duty, 

34 and behavior observation. In 2009, the NRC completed a rulemaking that codified generally 

35 applicable security requirements for operating power plants (74 FR 13926).

36 Second, in response to the March 11, 2011 severe earthquake and subsequent tsunami that 

37 resulted in extensive damage to the six nuclear power reactors at Japan’s Fukushima Dai-ichi 
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-12 September 2013

1 site, the NRC established a task force of senior agency experts (Near-Term Task Force). On 

2 July 12, 2011, the Near-Term Task Force issued its report, which concluded that there was no 

3 imminent risk from continued operation and licensing activities (NRC 2011a). Based on its 

4 analysis, the Near-Term Task Force made 12 overarching recommendations for changes to 

5 ensure the continued safety of U.S. nuclear power plants.

6 Several of these recommendations addressed spent fuel pool integrity and assurance of 

7 adequate makeup water in the event of a serious accident. In response to the Near-Term Task 

8 Force’s recommendations, the NRC issued multiple orders and a request for information to all of 

9 its nuclear power plant licensees on March 12, 2012. The orders addressed: (1) mitigating 

10 strategies for beyond-design basis external events and (2) reliable spent fuel pool 

11 instrumentation. In addition, the NRC issued a formal request for information to all licensees to 

12 assist the agency in reevaluating seismic and flooding hazards at operating reactor sites and 

13 determining whether appropriate staffing and communication can be relied upon to coordinate 

14 event response during a prolonged station blackout event, as was experienced at Fukushima

15 Dai-ichi. The NRC will use the information collected to determine whether to update the design 

16 basis and systems, structures, and components important to safety, including spent fuel pools. 

17 However, because the NRC has not yet received responses to the request for information and 

18 has not decided whether any license needs to be modified, suspended, or revoked, for 

19 purposes of analysis in this draft GEIS, the NRC assumes that the existing regulatory 

20 framework remains unchanged.

21 2.1.2.2 At-Reactor Independent Spent Fuel Storage Installations

22 Spent fuel pools, as discussed above, have limited capacity to store a reactor’s spent fuel. As 

23 noted, the NRC has adopted a reference pool of 700 MTU storage capacity that reaches its 

24 licensed capacity limit about 35 years into licensed life for operation of a reactor. At that point, 

25 the licensee needs a dry cask storage system to store older fuel that has cooled sufficiently and 

26 can be removed safely from the pool. These dry cask storage systems are located in ISFSIs at 

27 reactor sites and are licensed by the NRC. Dry cask storage shields people and the 

28 environment from radiation and keeps the spent fuel dry and nonreactive (NRC 2012a). 

29 There are many different dry cask storage systems, but most fall into two main categories based 

30 on how they are loaded. The first is the bare fuel, or direct-load, casks, in which spent fuel is 

31 loaded directly into a basket that is integrated into the cask. Bare fuel casks, which tend to be 

32 all metal construction, are generally bolted closed. The second is a canister-based system in 

33 which spent fuel is loaded into a basket inside a cylinder called a canister. The canister is 

34 usually loaded while inside a transfer cask, then welded and transferred vertically into either a 

35 concrete or metal storage overpack or horizontally into a concrete storage module 

36 (e.g., NUHOMS) (DOE 2012a). Typical dry cask storage systems are shown in Figure 2-1. 
Generic Facility Descriptions and Activities

September 2013 2-13 Draft NUREG‒2157

1

2 Figure 2-1. Dry Storage of Spent Fuel (Source: NRC 2012a)

 3 
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-14 September 2013

1 Dry cask storage systems are licensed by the NRC for storage only or for storage and 

2 transportation. Storage-only casks are not certified for transportation under 10 CFR Part 71, 

3 “Packaging and Transportation of Radioactive Material.” Casks and canisters licensed for both 

4 storage and transportation are generally referred to as dual-purpose casks and dual-purpose 

5 canisters. Some vendors refer to their dual-purpose casks or canisters as “multipurpose” 

6 canisters, which implies that it would be suitable for storage, transportation, and disposal. 

7 However, in the absence of a repository program, there are no specifications for disposal 

8 canisters and, therefore, no dual-purpose casks or canisters have been certified as 

9 multipurpose (DOE 2012a).

10 There are 69 ISFSIs licensed to operate in 34 states. As of the beginning of 2012, ISFSIs were 

11 storing spent fuel in over 1,700 loaded dry casks. Of the currently licensed ISFSIs, 54 are 

12 operating under general licenses and 15 have specific licenses (NRC 2013b). Figure 2-2 shows 

13 the locations of U.S. ISFSIs. Information on ISFSIs is presented in Appendix G of this draft 

14 GEIS. 

15 NRC authorizes construction and operation of ISFSIs by general and specific licenses. A 

16 general license is created by regulation and confers the right upon the general licensee to 

17 proceed with the licensed activity without further review or approval by the NRC. A specific 

18 license, by contrast, requires an application to perform the licensed activity and NRC review and 

19 approval by granting the license.

20 As these concepts apply to ISFSIs, every nuclear power reactor licensee holds a general 

21 license, by virtue of 10 CFR Part 72, Subpart K, which authorizes storage of spent fuel in casks 

22 whose design has been approved by the NRC. Licensees must evaluate the safety of using the 

23 approved casks at the ISFSI for site-specific conditions, including man-made and natural 

24 hazards, and must conform to all requirements under Subpart K for use of the approved design. 

25 In addition, licensees must review their programs for operating the reactor (e.g., physical 

26 security, radiation protection, or emergency planning) to determine if those programs are 

27 affected by use of the casks and, if so, to seek approval from the NRC for any necessary 

28 changes to those programs.

29 Further, a reactor licensee can seek a specific license to construct and operate an ISFSI, which 

30 requires NRC’s review of the safety, environmental, and physical security aspects of the 

31 proposed facility and the licensee’s financial qualifications. If the NRC concludes the proposed 

32 ISFSI meets licensing criteria, the NRC grants the specific license. This license contains 

33 various conditions (e.g., leak testing and monitoring) and specifies the quantity and type of 

34 material the licensee is authorized to store at the site. A specific license runs for a term of up to

35 40 years and may be renewed in accordance with all applicable requirements. 
Generic Facility Descriptions and Activities

September 2013 2-15 Draft NUREG‒2157 Figure 2-2. Licensed/Operating ISFSIs by State (Source: NRC 2013b)
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-16 September 2013

1 As described in more detail in Section 2.2.1, nuclear power plant licensees will undertake major 

2 decommissioning activities during the 60 years following permanent cessation of reactor 

3 operations. During major decommissioning activities, the licensees will transfer spent fuel from 

4 spent fuel pools to either an at-reactor or away-from-reactor ISFSI. When the at-reactor ISFSI 

5 is the only spent fuel storage structure left onsite, the facility is referred to as an “ISFSI-only 

6 site.” Existing ISFSI-only sites include Big Rock Point, Haddam Neck, Fort St. Vrain, Maine 

7 Yankee, Rancho Seco, Trojan, and Yankee Rowe.

8 The NRC requires licensees to develop spent fuel management plans that include specific 

9 consideration of a plan for removal of spent fuel stored under a general license, and spent fuel 

10 management before decommissioning systems and components needed for moving, unloading, 

and shipping spent fuel (10 CFR 50.54(bb) and 72.218).7 11

12 Following the terrorist attacks on September 11, 2001, the NRC issued Orders to ISFSI 

13 licensees to require certain compensatory measures. For example, on May 23, 2002, the NRC 

14 issued an Order to the GEH Morris wet storage ISFSI (NRC 2002b). On October 16, 2002, the 

15 NRC also issued Orders to specifically licensed and generally-licensed dry storage ISFSIs 

16 (including those with near-term plans to store spent fuel in an ISFSI under a general license). 

17 These Orders apply to prospective licensees. The details of these Orders are withheld from the 

18 public for security reasons.

19 In addition to NRC licensing requirements, licensees may also be subject to individual State 

20 requirements. For example, the State of Minnesota Public Utilities Commission requires an 

21 applicant to receive a “certificate of need” prior to constructing an ISFSI.

22 Example of At-Reactor ISFSIs

23 Dry cask storage systems in use in the United States are summarized in Appendix G. Two 

24 common systems are described below.

25 A common vertical dry cask storage system currently in use in at-reactor ISFSIs is Holtec 

26 International’s HI-STORM 100. The HI-STORM cylindrical overpack is stored on an ISFSI pad 

27 with its longitudinal axis in a vertical orientation. For example, its MPC-32 multipurpose canister 

28 can hold up to 32 PWR fuel assemblies. Canisters are also available for BWR spent fuel. As a 

29 result, dry storage of the entire 1,600 MTU of spent fuel generated by a typical reactor, 

30 assuming all spent fuel is eventually transferred from the spent fuel pool, would require about 

31 100 casks. Each storage cask is about 3.4 m (11 ft) wide and 6.1 m (20 ft) tall. The layout of 

32 casks on an ISFSI pad is guided by operational considerations at each site. However, a 

33 nominal layout involves casks separated by about 4.5 m (15 ft). Therefore, a typical ISFSI pad 

7 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

September 2013 2-17 Draft NUREG‒2157

1 with 100 casks located inside a protected area common to the power plant, and arranged as 

2 10 rows of 10 casks each, would cover about 46 × 46 m (150 × 150 ft). Therefore, the total area 

3 of the ISFSI pad would be about 0.2 ha (0.5 ac) (Holtec 2000). For purposes of analysis in this 

4 draft GEIS, the NRC assumes that an ISFSI of sufficient size to hold all spent fuel generated 

5 during licensed life for operation is constructed during the reactor’s licensed life for operation.

6 A common horizontal dry cask storage system currently in use in at-reactor ISFSIs is available 

7 from Transnuclear, Inc., a wholly-owned subsidiary of AREVA North America. The NUHOMS 

8 horizontal cask system uses dry shielded canisters that are placed in concrete horizontal 

9 storage modules (HSMs). Among the NRC-approved canister designs is the NUHOMS-61BT 

10 dry shielded canister. This canister can hold 61 BWR fuel assemblies. Canisters are also 

11 available for PWR spent fuel. For a BWR, the HSM is about 6.0 m (20 ft) long, 4.6 m (15 ft) 

12 high and 2.9 m (9.7 ft) wide. As a result, dry storage of 1,600 MTU of spent fuel generated by a 

13 generic BWR, assuming all spent fuel is eventually transferred from the spent fuel pool to an 

14 at-reactor ISFSI, would require about 150 HSMs. If HSMs were installed in rows and placed 

15 back-to-back in 2 × 10 arrays, an ISFSI with 150 HSMs would require about 7 double module 

16 rows and a single module row of 10 HSMs. Allowing for a 6-m- (20-ft-) wide concrete approach 

17 slab on the entrance side of each HSM, a 150 HSM ISFSI site would be about 60 m (200 ft) 

18 wide and 220 m (720 ft) long. Therefore, the total area of the horizontal ISFSI, including the 

19 protected area, would be about 1.3 ha (3.6 ac).

20 2.1.3 Away-from-Reactor ISFSIs

21 Existing away-from-reactor ISFSIs include the GEH Morris wet storage facility in Morris, Illinois 

22 and the DOE’s Three Mile Island, Unit 2 Fuel Debris ISFSI at the Idaho National Engineering 

23 Laboratory. Further, the NRC has issued a license to Private Fuel Storage, LLC (PFS) for an 

24 away-from-reactor ISFSI, which would have been located on the reservation of the Skull Valley 

25 Band of Goshute Indians (NRC 2004b).

26 A future away-from-reactor ISFSI could accept spent fuel from one or more nuclear power 

27 plants. For purposes of this draft GEIS, the NRC assumes that the industry could develop an 

28 away-from-reactor ISFSI that would store up to 40,000 MTU of spent fuel from various nuclear 

29 power plant sites using existing technologies. Spent fuel would be moved from operating or 

30 decommissioning reactor sites, or ISFSI-only sites, to an away-from-reactor ISFSI or ISFSIs, 

31 and then from the away-from-reactor ISFSI to one or more permanent repositories. Aside from 

32 the existing GEH Morris wet storage facility, the NRC assumes that, in the future, a portion of 

33 the industry’s spent fuel would be stored in one or more dry cask storage systems at an away34 from-reactor ISFSI.

35 In 2006, the NRC granted a license to PFS, to construct and operate an away-from-reactor 

36 ISFSI in Skull Valley, Utah. PFS, a consortium of eight nuclear power utilities, proposed to 

37 construct the site on the reservation of the Skull Valley Band of Goshute Indians, about 80 km 
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-18 September 2013

1 (50 mi) southwest of Salt Lake City, Utah. The private fuel storage facility was intended for 

2 temporary aboveground storage, using the Holtec HI-STORM dual-purpose canister-based cask 

3 system, of up to 40,000 MTU of spent fuel from U.S. commercial nuclear power plants. PFS 

4 proposed to build the ISFSI on a 330-ha (820-ac) site leased from the Skull Valley Band of 

5 Goshute Indians. The site would be located in the northwest corner of the reservation 

6 approximately 6 km (3.5 mi) from the Skull Valley Band's village. The proposed PFS ISFSI has 

7 not been constructed. On December 20, 2012, PFS submitted a request to the NRC to 

8 terminate its license (PFS 2012). Despite no immediate plans to construct the PFS facility, 

9 issuance of the PFS license supports the assumption in this GEIS that an away-from-reactor 

10 ISFSI is technically feasible and that the NRC can license an away-from-reactor storage facility. 

11 Thus, the NRC’s analysis of construction, operation, and decommissioning activities and 

12 impacts for an away-from-reactor ISFSI in NUREG–1714 are reflected in this draft GEIS 

13 (NRC 2001).

14 Consolidated Storage

15 On January 29, 2010, the President of the United States directed the Secretary of Energy to 

16 establish a “Blue Ribbon Commission on America’s Nuclear Future.” The Blue Ribbon 

17 Commission was tasked with conducting a comprehensive review of policies for managing the 

18 back end of the nuclear fuel cycle and recommending a new strategy. The Blue Ribbon 

19 Commission issued its findings and conclusions in January 2012. Among the findings and 

20 conclusions related to continued storage of spent fuel was a strategy for prompt efforts to 

21 develop one or more consolidated storage facilities.

22 In January 2013, DOE published its response to the Blue Ribbon Commission 

23 recommendations titled, “Strategy for the Management and Disposal of Used Nuclear Fuel and 

24 High-Level Radioactive Waste” (DOE 2013). This strategy implements a program over the next 

25 10 years that, with congressional authorization, will: 

26 • site, design, construct, license, and begin operation of a pilot interim storage facility by 2021

27 with an initial focus on accepting spent fuel from shutdown reactor sites

28 • advance toward the siting and licensing of a larger interim storage facility to be available by

29 2025 with sufficient capacity to provide flexibility in the waste-management system and

30 allow for acceptance of enough spent fuel to reduce expected government liabilities

31 • make demonstrable progress on the siting and characterization of repository sites to

32 facilitate the availability of a geologic repository by 2048

33 The Federal government’s support for interim storage supports the NRC’s decision to consider 

34 this type of facility as one of the reasonably foreseeable interim solutions for spent fuel storage 

35 pending ultimate disposal at a repository. 
Generic Facility Descriptions and Activities

September 2013 2-19 Draft NUREG‒2157

1 2.1.4 Dry Transfer System

2 Although there are no dry transfer systems (DTSs) at U.S. nuclear power plant sites today, the 

3 potential need for a DTS, or facility with equivalent capability, to enable retrieval of spent fuel 

4 from ISFSIs for inspection or repackaging will increase as the duration and quantity of fuel in dry 

5 storage increases. A DTS would enhance management of spent fuel inspection and 

6 repackaging at all ISFSI sites and provide additional flexibility at all dry storage sites by enabling 

7 repackaging without the need to return the spent fuel to a pool. A DTS would also help reduce 

8 risks associated with unplanned events or unforeseen conditions and facilitate storage 

9 reconfiguration to meet future storage, transport, or disposal requirements (Carlsen 2012).

10 Several DTS designs and related concepts have been put forward over the past few decades. 

11 Among these designs is a design developed by Transnuclear, Inc. in the early 1990s under a 

12 cooperative agreement between the DOE and the Electric Power Research Institute (EPRI). 

13 Although the conceptual design was based on transferring spent fuel from a 30-ton 4-assembly 

14 source cask to a 125-ton receiving cask, the DTS could be adapted to be suitable for any two 

15 casks (Carlsen 2012). 

16 On September 30, 1996, the DOE submitted to the NRC for review a topical safety analysis 

17 report on the Transnuclear-EPRI DTS design (DOE 1996). In November 2000, the NRC issued 

18 an assessment report in which it found the DTS concept has merit. The DOE, however, did not 

19 request a license for the DTS (NRC 2000a). 

20 The reference DTS considered in this draft GEIS is a two-level concrete and steel structure with 

21 an attached single-level weather-resistant preengineered steel building. The concrete and steel 

22 structure provides both confinement and shielding during fuel-transfer operations. The DTS 

23 was designed to enable loading of one receiving cask in ten 24-hour days and unloading one 

24 source cask in one 24-hour day.

25 The key facility parameters and characteristics described in the September 30, 1996 topical 

26 safety analysis report are summarized below.

27 The reference DTS is a reinforced-concrete rectangular box structure with internal floor 

28 dimensions of about 8 × 5.5 m (26 × 18 ft) and about 14 m (47 ft) tall. The system also includes 

29 an attached, prefabricated, aluminum Butler-type building referred to as the preparation area 

30 with dimensions of about 11.6 x 7.6 m (38 × 25 ft) wide and 11.6 m (38 ft) tall. The basemat for 

31 the facility measures 14.9 × 21.9 m (49 × 72 ft), and the security zone would be about 

32 76 × 91 m (250 × 300 ft) (i.e., less than 0.7 ha [2 ac]).

33 As shown in Figure 2-3, the preparation area is located at ground level of the DTS. The lower 

34 access area is next to the preparation area and directly below the transfer confinement area. 

35 The lower access area provides shielding, confinement, and positioning for the open source and 
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-20 September 2013

1 receiving casks during spent fuel transfers. An 18- to 23-cm (7- to 9-in.)-thick steel sliding door 

2 separates the lower access area from the preparation area. The transfer confinement area is 

3 the upper level of the DTS, directly above the lower access area. The transfer confinement 

4 area provides the physical confinement boundary and radiation shielding between spent fuel 

5 and the environment.

6 

7 Figure 2-3. Conceptual Sketches of a Dry Transfer System (DOE 1996)
Generic Facility Descriptions and Activities

September 2013 2-21 Draft NUREG‒2157

1 Transnuclear-EPRI found that radioactive waste generation could not be readily quantified, as it 

2 depends strongly on reactor-specific conditions, primarily the crud levels on the fuel assemblies. 

3 Table 6.1-1 of the topical safety analysis report showed the expected waste sources, including 

4 decontamination wastes, spalled material in a crud catcher, and prefilters and high-efficiency 

5 particulate air filters used in the heating ventilation and air conditioning system. Others wastes 

6 considered included mechanical lubricants and precipitation runoff. The DTS does not rely on 

7 water-supply lines. Water is brought to the facility in bottles and used for general purpose 

8 cleaning only.

9 The reference DTS, if licensed, would have operated under the radiological protection 

10 requirements of 10 CFR Part 20, “Standards for Protection Against Radiation.” Occupational 

11 doses for various tasks performed in the DTS are provided in Table 7.4-1 of the topical safety

12 analysis report (DOE 1996). Total estimated occupational doses from loading a single cask are 

13 about 0.5 person-rem.

14 Maximum offsite doses reported in Table 7.6-1 of the topical safety analysis report were 

15 estimated to range from 44 mrem per year at 100 m to 2 mrem per year at 500 m.

16 As with other facilities licensed under 10 CFR Part 72, the design events identified in 

17 ANSI/ANS 57.9 (ANSI/ANS 1992) form the basis for the accident analyses performed for the 

18 DTS. The bounding accident results for a distance of 100 m are a stuck fuel assembly 

19 (47 mrem) and a loss-of-confinement barrier (721 mrem).

20 This draft GEIS considers the environmental impacts of constructing a reference DTS to provide 

21 a complete picture of the environmental impacts of continued storage. This draft GEIS does not 

22 license or approve construction or operation of a DTS. A separate licensing action would be 

23 necessary before a licensee may construct and operate a site-specific DTS.

24 For the purposes of analysis in this draft GEIS, the NRC relies primarily on the facility 

25 description of the Transnuclear-EPRI DTS described above. However, for some impact 

26 assessments in this draft GEIS, the NRC has drawn from the “Environmental Impact Statement 

27 for the Proposed Idaho Spent Fuel Facility at the Idaho National Engineering and Environmental 

28 Laboratory in Butte County, Idaho” (NRC 2004b). The NRC licensed the Idaho Spent Fuel 

29 Facility in November 2004, but DOE has not constructed the facility. However, the proposed 

30 facility has the capability to handle bare spent fuel for the purposes of repackaging and storing 

31 spent fuel from Peach Bottom Unit 1; the Shippingport Atomic Power Station; and various 

32 training, research, and isotope reactors built by General Atomics. Because the Idaho Spent 

33 Fuel Facility, like the DTS, includes design features that allow bare fuel-handling operations to 

34 repackage spent fuel from DOE transfer casks to new storage containers, the NRC has 

35 concluded that some environmental impacts of the facility would be comparable to those of a 

36 DTS.
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-22 September 2013

1 2.2 Generic Activity Descriptions

2 As described in Chapter 1, this draft GEIS analyzes environmental impacts of the continued 

3 storage of spent fuel in terms of three timeframes: short-term, long-term, and indefinite storage. 

4 As described below, the activities at spent fuel storage facilities during the short-term timeframe 

5 coincide with nuclear power plant decommissioning activities. By the beginning of the long-term 

6 timeframe, reactor licensees will have removed all spent fuel from the spent fuel pool and 

7 decommissioned all remaining nuclear power plant structures. At that point, all spent fuel will be 

8 stored in either an at-reactor or away-from-reactor ISFSI. During the long-term storage 

9 timeframe, the NRC has conservatively assumed for the purpose of analysis in this draft GEIS, 

10 that the need will arise for the transfer of spent fuel assemblies from aged dry cask storage 

11 systems to newer systems of the same or newer design. In addition, the NRC assumes that 

12 storage pads and modules would need to be replaced periodically.

13 2.2.1 Short-Term Storage Activities

14 As depicted in the generic timeline in Figure 2-4, after about 35 years of operation at low fuel 

15 burnups, or about 46 years of high-burnup operation, the spent fuel pool at a typical reactor 

16 reaches capacity and spent fuel must be removed from the pool to ensure full core offload 

17 capability. The inventory of spent fuel that exceeds spent fuel pool capacity may be transferred 

18 to dry cask storage at an at-reactor or away-from-reactor ISFSI. This draft GEIS focuses on the 

19 activities and impacts associated with continued storage in a spent fuel pool and dry cask. This 

20 section explains the activities that occur during short-term storage: 

21 • decommissioning of the plant systems, structures, and components not required for 

22 continued storage of spent fuel

23 • routine maintenance of the pool and ISFSI

24 • transfer of spent fuel from the pool to the at-reactor or away-from-reactor ISFSI

25 2.2.1.1 Decommissioning Activities during Short-Term Storage

26 A number of activities occur after a reactor licensee declares permanent cessation of operations. 

27 These activities are divided into three phases: (1) initial activities; (2) major decommissioning

28 and storage activities; and (3) license-termination activities. The initial activities include the 

29 licensee’s certification to the NRC within 30 days of the decision or requirement to permanently 

30 cease operations. This is followed by certification of permanent fuel removal from the reactor. 

31 Within 2 years of permanent shutdown, the licensee is required to submit to the NRC a post32 shutdown decommissioning activities report that includes a description of planned 

33 decommissioning activities along with a schedule, an estimate of expected costs, and a 

34 discussion that provides the reasons for concluding that previously issued environmental impact 

35 statements bound the site-specific decommissioning activities (NRC 2000b).
Generic Facility Descriptions and Activities

September 2013 2-23 Draft NUREG‒2157

1

2 Figure 2-4. Continued Storage Timeline

 3 

4 Licensees may choose from three decommissioning options: DECON, SAFSTOR, and 

5 ENTOMB:

6 DECON: The equipment, structures, and portions of the facility and site that 

7 contain radioactive contaminants are promptly removed or decontaminated to a 

8 level that permits termination of the license shortly after cessation of operations.

9 SAFSTOR: The facility is placed in a safe, stable condition and maintained in 

10 that state (safe storage) until it is subsequently decontaminated and dismantled 

11 to levels that permit license termination. The implementation of SAFSTOR 

12 includes those activities necessary for the final decontamination and 

13 dismantlement of the facility. During SAFSTOR, a facility is left intact, but the 

14 fuel has been removed from the reactor vessel and radioactive liquids have been 

15 drained from systems and components and then processed. Radioactive decay 
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-24 September 2013

1 occurs during the SAFSTOR period, thus reducing the quantity of contaminated 

2 and radioactive material that must be disposed of during decontamination and 

3 dismantlement.

4 ENTOMB: Radioactive structures, systems, and components are encased in a 

5 structurally long-lived substance, such as concrete. The entombed structure is 

6 appropriately maintained, and continued surveillance is carried out until the 

radioactivity decays to a level that permits termination of the license8 7

8 (NRC 2000b).

9 The choice of decommissioning option is left to the licensee, but decommissioning must 

10 conform to the NRC's regulations. This choice is communicated to the NRC and the public in 

11 the post-shutdown decommissioning activities report. In addition, the licensee may choose to 

12 combine the DECON and SAFSTOR options. For example, after power operations cease at a 

13 facility, a licensee could use a short storage period for planning purposes, followed by removal 

14 of large components (such as the steam generators, pressurizer, and reactor vessel internals), 

15 place the facility in storage for 30 years, and eventually finish the decontamination and 

16 dismantlement process (NRC 2000b).

17 Although the selection of the decommissioning option is up to the licensee, the NRC requires 

18 the licensee to reevaluate its selection if the option (1) could not be completed as described, 

19 (2) could not be completed within 60 years of the permanent cessation of plant operations, 

20 (3) included activities that would endanger the health and safety of the public by being outside 

21 of the NRC's health and safety regulations, or (4) would result in a significant impact to the 

22 environment (NRC 2000b).

23 In accordance with the license-termination requirements for power reactors in

24 10 CFR 50.82(a)(3) and 52.110(c), decommissioning will be completed within 60 years of 

25 permanent cessation of operations. Completion of decommissioning beyond 60 years will be 

26 approved by the Commission only when necessary to protect public health and safety. Factors 

27 that will be considered by the Commission include unavailability of waste disposal capacity and 

28 other site-specific factors, including the presence of other nuclear facilities at the site. Given 

29 this regulatory framework, it may be reasonably assumed that each nuclear power plant, 

30 including its onsite spent fuel pool, will be decommissioned within 60 years of permanent 

31 cessation of operations (NRC 2000b).

32 Licensees may begin major decommissioning activities 90 days after the NRC has received the 

33 post-shutdown decommissioning activities report. “Major decommissioning activity” is defined in 

34 10 CFR 50.2 and means, for a nuclear power reactor facility, any activity that results in 

 

8 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 2000b).
Generic Facility Descriptions and Activities

September 2013 2-25 Draft NUREG‒2157

1 permanent removal of major radioactive components, permanently modifies the structure of the 

2 containment, or results in dismantling components for shipment containing greater than class C 

3 waste in accordance with 10 CFR 61.55 (NRC 2000b). Finally, once decommissioning is 

4 completed, and any spent fuel stored by the licensee is removed from the site, a licensee may 

apply to the NRC to terminate its Part 50 license.9 5 A licensee is required to submit to the NRC a 

6 license-termination plan as a supplement to its Final Safety Analysis Report at least 2 years 

7 prior to the expected termination of the license as scheduled in the post-shutdown 

8 decommissioning activities report (NRC 2000b). 

9 2.2.1.2 Activities in Spent Fuel Pools

10 Spent fuel pools are cooled by continuously circulating water that cools the spent fuel 

11 assemblies and provides shielding from radiation. During the short-term storage timeframe, the 

12 pools will be used to store fuel until a licensee decides to remove the spent fuel as part of 

13 implementing either the SAFSTOR or DECON decommissioning option. Beyond the 

14 decommissioning period, the NRC assumes that all of the spent fuel has been transferred to a 

15 dry cask storage system in an at-reactor or away-from-reactor ISFSI, as no other option 

16 currently exists.

17 During the short-term storage timeframe, spent fuel in the pool continues to generate decay 

18 heat from radioactive decay. The rate at which the decay heat is generated decreases the 

19 longer the reactor has been shut down. Storing the spent fuel in a pool of water provides an 

20 adequate heat sink for the removal of heat from the irradiated fuel. In addition, the fuel is 

21 located under water so that the radiation emanating from the fuel is shielded by the water, thus 

22 significantly limiting workers’ exposure to radiation. After the spent fuel has cooled adequately, 

23 it can be removed from the pool and stored in an ISFSI in air-cooled dry casks. At the earliest, 

24 such as for low-burnup spent fuel, transfer of spent fuel to an ISFSI occurs after the fuel has 

25 cooled for 5 years (NRC 2002a). Minimum cooling times for high-burnup fuel vary with burnup 

26 and initial uranium enrichment for different dry cask storage systems, ranging from 5 to 

27 >20 years.

28 Spent fuel pools are cooled by spent fuel pool cooling systems, which typically consist of pumps 

29 to circulate cooling water through the system, a purification system of filters and a 

30 demineralizer, and a heat exchanger (which transfers the heat from the spent fuel pool cooling 

31 system to the service-water system or its equivalent). The operation of the purification system 

32 generates some liquid low-level radioactive waste and some solid low-level radioactive waste in 

33 the form of demineralizer resins. Some licensees opt to modify the existing spent fuel pool 

34 support systems by installing self-contained spent fuel pool cooling and cleanup systems and 

35 monitoring, controls and electrical power. These modifications effectively isolate the spent fuel 

 

9 A licensee may terminate its Part 50 license earlier if the remaining spent fuel is stored under a specific 

license issued under 10 CFR Part 72.
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-26 September 2013

1 pool from the remainder of plant structures, systems and components, thereby creating a “spent 

2 fuel pool island.” This approach allows decommissioning to begin on the remainder of the plant 

3 while the spent fuel is safely stored (EPRI 2005). As described in Chapter 4 of this draft GEIS, 

4 the operation of a new self-contained system would be bounded by the impacts of operating the 

5 existing cooling system, which are also described in Chapter 4. The environmental impacts of 

6 constructing a new spent fuel pool cooling system, which facilitates decommissioning activities, 

7 is addressed in Chapter 6 of this draft GEIS.

8 For plants that enter SAFSTOR, the spent fuel pool will continue to be subject to preventative 

9 and corrective maintenance, including maintenance of the structure, its security systems, 

10 radiation protection and environmental monitoring programs, and processing of radioactive 

11 waste that may be generated.

12 For purposes of analysis in this draft GEIS, the NRC assumes timely decommissioning of the 

13 reactor in accordance with requirements in 10 CFR 50.82 and 52.110(c). As a result, all spent 

14 fuel in storage in the spent fuel pool is assumed to be transported to a repository, if it is 

15 available, or to either an at-reactor or away-from-reactor ISFSI within 60 years beyond the 

16 licensed life for operation of the reactor.

17 2.2.1.3 Activities at At-Reactor ISFSIs

18 Operation and maintenance activities at an at-reactor ISFSI are focused on inspections, 

19 monitoring, and training, and some limited physical and continuous electronic surveillance. The 

20 staff that must be trained for ISFSI operations include staff for operations, maintenance, health 

21 physics, and security personnel. A licensee will also maintain an emergency response plan for 

22 ISFSI-related events.

23 In accordance with 10 CFR 72.42, the initial license term for an ISFSI must not exceed 40 years 

24 and licenses may be renewed upon NRC approval for a period not to exceed 40 years. ISFSI 

25 license renewal applications must include, among other things: (1) time-limited aging analyses 

26 that demonstrate that structures, systems, and components important to safety will continue to 

27 perform their intended safety function for the requested period of extended operation and (2) a 

28 description of the aging management program for management of issues associated with aging 

29 that could adversely affect structures, systems, and components important to safety. The NRC 

30 reviews renewal applications using its recently issued “Standard Review Plan for Renewal of 

31 Spent Fuel Dry Cask Storage System Licenses and Certificates of Compliance” (NRC 2011b).

32 The kinds of aging effects managed under an aging management program include, but are not 

33 limited to: concrete cracking and spalling; loss of confinement; loss of material; and reduction in 

34 heat transfer (e.g., by blocked air duct screens). The application of aging management 

35 programs may include structure monitoring; monitoring of protective coating on carbon steel 
Generic Facility Descriptions and Activities

September 2013 2-27 Draft NUREG‒2157

1 structures; ventilation surveillance; welded canister seal and leakage monitoring programs; and 

2 bolted canister seal and leakage monitoring programs (DOE 2012b).

3 2.2.1.4 Activities at Away-from-Reactor ISFSIs

4 In assessing environmental impacts from construction and operation at an away-from-reactor 

5 ISFSI, the NRC has drawn from the private fuel storage facility environmental impact statement

6 prepared by the NRC (NRC 2001). The proposed PFS facility was designed to store up to 

7 40,000 MTU (44,000 tons of spent fuel) and was licensed to operate for 20 years. The NRC 

8 now allows an initial license term of 40 years with 40-year renewal terms. While this draft GEIS 

9 uses the general attributes of such a facility to assess likely impacts for purposes of this 

10 analysis, it should be recognized that the environmental impacts of constructing and operating

11 an away-from-reactor ISFSI would be evaluated in more details in an environmental review 

12 associated with a site-specific license application.

13 Based on the construction plans for the proposed private fuel storage facility, construction of the 

14 away-from-reactor ISFSI would include construction of major buildings (e.g., administrative, 

15 security, and maintenance) including a canister transfer building and installation of concrete 

16 storage pads, batch plant, access and heavy haul roads, parking areas, and potentially new rail 

17 lines. A peak workforce of approximately 250 workers would be expected (NRC 2001). 

18 Groundwater wells could be installed for potable water use or aboveground storage tanks could 

19 be erected for potable water and water for fires and the batch plant.

20 Should storage at an away-from-reactor ISFSI continue for such a time as bare fuel handling 

21 would be required for inspection or maintenance, then a DTS could be constructed at the 

22 facility.

23 Operation of the away-from-reactor ISFSI would include receiving, transferring, storage, and 

24 repackaging of spent fuel. If a repository becomes available, operations could include the 

25 transfer of spent fuel canisters to shipping casks and transportation to the repository.

26 Approximately 100 to 200 loaded shipping casks would be received at the postulated facility 

27 each year (NRC 2001). The shipping casks would be brought into the canister transfer building 

28 where the spent fuel would be transferred from the shipping cask to a storage cask. The 

29 storage casks would then be placed on the concrete storage pads.

30 2.2.2 Long-Term Storage Activities

31 As described below, the new activities associated with long-term storage include continued 

32 facility maintenance, construction and operation of a DTS, and storage facility replacement. 

33 The maintenance activities during the long-term storage activities are the same as for the 
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-28 September 2013

1 short-term, including any additional monitoring and inspections that may arise as part of 

2 implementation of ongoing aging management programs.

3 2.2.2.1 Construction and Operation of a DTS

4 As described in Section 2.1.4, the NRC assumes a DTS, or its equivalent, would be used to 

5 transfer fuel as needed for inspection or repackaging. For purposes of this draft GEIS, the NRC 

6 assumes the reference DTS would be constructed, operated, and replaced once during the 

7 long-term storage timeframe, and every 100 years thereafter. The reference DTS would occupy 

8 about 0.04 ha (0.1 ac) and would have a total restricted access area of 0.7 ha (2 ac). The NRC 

9 assumes that construction of a reference DTS would take 1 to 2 years.

10 DOE has described the operation of a reference DTS in the “Dry Transfer System Topical 

11 Safety Analysis Report” (DOE 1996). A summary is provided here to illustrate the process of 

12 spent fuel repackaging. 

13 The reference DTS includes three major areas:

14 • preparation area

15 • lower access area

16 • transfer confinement area

17 As shown in Figure 2-3, receiving casks and source casks enter the preparation area and exit 

18 the DTS on rail-mounted trolleys. To begin spent fuel transfer operations, a receiving cask (i.e., 

19 the cask into which fuel will be transferred) is transported to the DTS. The receiving cask is 

20 positioned and loaded on a receiving cask transfer trolley at the DTS and rolled into the 

21 preparation area. Next, the receiving cask lid and outer and inner canister lids are removed. 

22 Finally, the receiving cask is moved into the lower access area and mated to the transfer 

23 confinement area.

24 A source cask (i.e., the cask from which fuel will be transferred) follows a similar path as the 

25 receiving cask into the lower access area and is mated to the transfer confinement area. No 

26 personnel are present in the lower access area for the transfer operations; all transfer 

27 operations are controlled remotely. The lids on both the receiving cask and source cask are 

28 removed to prepare for spent fuel transfer. The fuel-assembly-handling subsystem in the 

29 transfer confinement area is used to grab and lift a spent fuel assembly from the source cask. 

30 The spent fuel assembly is lifted inside a transfer tube and then moved over an empty position 

31 in the receiving cask. The spent fuel assembly is lowered into the receiving cask and detached 

32 from the lifting device. When spent fuel transfers are complete, both casks are closed, 

33 detached from the transfer confinement area, and ultimately removed from the lower access 

34 area back to the preparation area.
Generic Facility Descriptions and Activities

September 2013 2-29 Draft NUREG‒2157

1 Maintenance and monitoring activities at the DTS would include routine inspections and testing 

2 of the spent fuel and cask transfer and handling equipment (e.g., lift platforms and associated 

3 mechanical equipment) and process and effluent radiation monitoring.

4 2.2.2.2 Replacement of Storage and Handling Facilities

5 For purposes of analysis in this draft GEIS, the NRC assumes that storage facilities will require 

6 complete replacement over the 100-year long-term storage timeframe. Replacement activities 

7 are assumed to occur as needed throughout the 100-year long-term storage timeframe, but not 

8 all at once over a relatively short interval (e.g., 2 years). Replacement activities include the 

9 following:

10 • construction of a new ISFSI pads adjacent to, or nearby, the initial pads

11 • construction of replacement storage casks or HSMs

12 • movement of canisters in good condition to new casks or HSMs

13 • use of the initial and replacement DTS to transfer fuel to new canisters and casks, as 

14 necessary

15 • replacement of the DTS

16 2.2.3 Indefinite Storage Activities

17 Should a repository not become available within the long-term storage timeframe, then activities 

18 described for the long-term storage timeframe in Section 2.2.2 are assumed to continue 

19 indefinitely. For purposes of analysis in this draft GEIS, the NRC assumes that storage facilities 

20 (i.e., an ISFSI and its associated DTS) would be replaced once every 100 years.

21 2.3 References

22 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

23 Protection against Radiation.” Washington, D.C.

24 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

25 Production and Utilization Facilities.” Washington, D.C.

26 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

27 Certifications, and Approvals for Nuclear Power Plants.” Washington, D.C.

28 10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, “Licensing

29 Requirements for Land Disposal of Radioactive Waste.” Washington, D.C.
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-30 September 2013

1 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

2 Transportation of Radioactive Material.” Washington, D.C.

3 10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing 

4 Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

5 Waste, and Reactor-Related Greater than Class C Waste.” Washington, D.C.

6 74 FR 13926. March 27, 2009. “Power Reactor Security Requirements.” Federal Register, 

7 U.S. Nuclear Regulatory Commission, Washington, D.C. 

8 76 FR 30399. May 25, 2011. “Duke Energy Carolinas, LLC, Oconee Nuclear Station, Units 1, 

9 2, and 3, Notice of Consideration of Issuance of Amendment to Facility Operating License, 

10 Proposed No Significant Hazards Consideration Determination, and Opportunity for a Hearing 

11 and Order Imposing Procedures for Document Access to Sensitive Unclassified Non12 Safeguards Information.” Federal Register, U.S. Nuclear Regulatory Commission, 

13 Washington, D.C. 

14 ANSI/ANS (American National Standards Institute/American Nuclear Society). 1992. Design 

15 Criteria for an Independent Spent Fuel Storage Installation (Dry Storage Type). 

16 ANSI/ANS 57.9–1992, La Grange Park, Illinois. Available at http://www.techstreet.com/cgi17 bin/detail?doc_no=ans%7C57_9_1992_r2000_;product_id=21087. 

18 Carlsen, B.W. and M.B. Raap. 2012. Dry Transfer Systems for Used Nuclear Fuel. 

19 INL/EXT–12–26218, Idaho National Laboratory, Idaho Falls, Idaho. Available at 

20 http://www.inl.gov/technicalpublications/Documents/5516346.pdf. 

21 DOE (U.S. Department of Energy). 1996. Dry Transfer System Topical Safety Analysis Report. 

22 Volume I, Washington, D.C. Accession No. ML060730035.

23 DOE (U.S. Department of Energy). 2012a. Gap Analysis to Support Extended Storage of Used 

24 Nuclear Fuel. Revision 0, FCRD–USED–2011–000136, PNNL–20509, Washington, D.C. 

25 Available at http://energy.gov/sites/prod/files/Gap%20Analysis%20Rev%200%20Final.pdf. 

26 DOE (U.S. Department of Energy). 2012b. Managing Aging Effects on Dry Cask Storage 

27 Systems for Extended Long-Term Storage and Transportation of Used Fuel. FCRD–USED–

28 2012–000119, ANL–12/29, Washington, D.C. Available at 

29 http://www.ipd.anl.gov/anlpubs/2012/07/73873.pdf. 

30 DOE (U.S. Department of Energy). 2013. Strategy for the Management and Disposal of Used 

31 Nuclear Fuel and High-Level Radioactive Waste. Washington, D.C. Accession 

32 No. ML13011A138.
Generic Facility Descriptions and Activities

September 2013 2-31 Draft NUREG‒2157

1 EIA (Energy Information Administration). 1994. Spent Nuclear Fuel Discharges from 

2 U.S. Reactors 1992. SR/CNEAF/94–01. Washington, D.C. Available at 

3 http://www.ntis.gov/search/product.aspx?ABBR=DE94011195. 

4 EPRI (Electric Power Research Institute). 1988. An Assessment of Boraflex Performance in 

5 Spent-Nuclear-Fuel Storage Racks. NP–6159, Palo Alto, California. Accession 

6 No. ML003736666. 

7 EPRI (Electric Power Research Institute). 2005. Maine Yankee Decommissioning – 

8 Experience Report: Detailed Experiences 1997–2004. Technical Report No. 1011734, 

9 Palo Alto, California. Accession No. ML12338A389. 

10 EPRI (Electric Power Research Institute). 2010. Impacts Associated With Transfer of Spent 

11 Nuclear Fuel from Spent Fuel Storage Pools to Dry Storage After Five Years of Cooling. 

12 TR–1021049, Palo Alto, California. Available at 

13 http://www.epri.com/abstracts/Pages/ProductAbstract.aspx?ProductId=000000000001021049. 

14 Holtec International. 2000. Final Safety Analysis Report for the Holtec International Storage 

15 and Transfer Operation Reinforced Module Cask System (HI-STORM 100 Cask System). 

16 Revision 0. Marlton, New Jersey. Accession No. ML072420254.

17 NRC (U.S. Nuclear Regulatory Commission). 2000a. Letter from E. W. Brach to L. Steward 

18 dated November 13, 2000, regarding “Issuance of Assessment Report for the Dry Transfer 

19 System.” Washington, D.C. Accession Nos. ML003769027 (letter) and ML003769386. 

20 NRC (U.S. Nuclear Regulatory Commission). 2000b. Decommissioning of Nuclear Power 

21 Reactors. Regulatory Guide 1.184, Washington, D.C. Accession No. ML003701137.

22 NRC (U.S. Nuclear Regulatory Commission). 2001. Final Environmental Impact Statement for 

23 the Construction and Operation of an Independent Spent Fuel Storage Installation on the 

24 Reservation of the Skull Valley Band of Goshute Indians and Related Transportation Facility in 

25 Tooele County, Utah. NUREG–1714, Volume 1, Washington, D.C. Accession 

26 No. ML020150217.

27 NRC (U.S. Nuclear Regulatory Commission). 2002a. Generic Environmental Impact Statement 

28 on Decommissioning of Nuclear Facilities: Regarding the Decommissioning of Nuclear Power 

29 Reactors. NUREG–0586, Supplement 1, Volumes 1 and 2, Washington, D.C. Accession 

30 Nos. ML023470327 and ML023500228.

31 NRC (U.S. Nuclear Regulatory Commission). 2002b. Order Modifying License (Effective 

32 Immediately) [General Electric Company – Morris Operation]. Washington, D.C. Accession 

33 No. ML021080507. 
Generic Facility Descriptions and Activities

Draft NUREG‒2157 2-32 September 2013

1 NRC (U.S. Nuclear Regulatory Commission). 2004a. General Electric Company Morris 

2 Operation Technical Specifications for Safety. License SNM–2500, Morris, Illinois. Accession 

3 No. ML043630567.

4 NRC (U.S. Nuclear Regulatory Commission). 2004b. Environmental Impact Statement for the 

5 Proposed Idaho Spent Fuel Facility at the Idaho National Engineering and Environmental 

6 Laboratory in Butte County, Idaho. NUREG–1773, Washington, D.C. Accession 

7 No. ML040490135.

8 NRC (U.S. Nuclear Regulatory Commission). 2011a. Recommendations for Enhancing 

Reactor Safety in the 21 9 st Century: The Near-Term Task Force Review of Insights from the 

10 Fukushima Dai-ichi Accident. SECY–11–0093, Washington, D.C. Accession 

11 No. ML111861807.

12 NRC (U.S. Nuclear Regulatory Commission). 2011b. Standard Review Plan for Renewal of 

13 Spent Fuel Dry Cask Storage System Licenses and Certificates of Compliance. NUREG–1927, 

14 Washington, D.C. Accession No. ML111020115.

15 NRC (U.S. Nuclear Regulatory Commission). 2012a. Information Digest, 2012–2013. 

16 NUREG–1350, Volume 24, Washington, D.C. Accession No. ML12241A166.

17 NRC (U.S. Nuclear Regulatory Commission). 2012b. A Summary of Aging Effects and Their 

18 Management in Reactor Spent Fuel Pools, Refueling Cavities, Tori, and Safety-Related 

19 Concrete Structures. NUREG/CR–7111, Washington, D.C. Accession No. ML12047A184.

20 NRC (U.S. Nuclear Regulatory Commission). 2013a. Generic Environmental Impact Statement 

21 for License Renewal of Nuclear Plants. NUREG–1437, Revision 1, Washington, D.C. 

22 Accession No. ML13107A023.

23 NRC (U.S. Nuclear Regulatory Commission). 2013b. U.S. Independent Spent Fuel Storage 

24 Installations. Washington, D.C. Accession No. ML13197A187.

25 PFS (Private Fuel Storage LLC). 2012. Letter from R. Palmberg to NRC dated December 20, 

26 2012, regarding “Termination of NRC License No. SNM–2513 for Private Fuel Storage LLC.” 

27 La Crosse, Wisconsin. Accession No. ML12356A063.

28 S. Cohen & Associates, Inc. 1998. Effectiveness of Fuel Rod Cladding as an Engineered

29 Barrier in the Yucca Mountain Repository. McLean, VA. Accession No. ML033500112.
Generic Facility Descriptions and Activities

September 2013 2-33 Draft NUREG‒2157

1 Sailor, V. L, K. R. Perkins, J. R. Weeks, and H. R. Connell. 1987. Severe Accidents in Spent 

2 Fuel Pools in Support of Generic Safety Issue 82. NUREG/CR–4982, BNL–NUREG–52093, 

3 Washington, D.C. Available at http://www.osti.gov/bridge/servlets/purl/6135335-

4 5voofL/6135335.pdf. 

5 Ux Consulting (UxC). 2013. StoreFUEL 14(173). Roswell, Georgia. Available at 

6 http://uxc.com/products/rpt_sf_stf.aspx. 

September 2013 3-1 Draft NUREG‒2157

1 3.0 Affected Environment

2 For purposes of the evaluation in this draft Waste Confidence Generic Environmental Impact 

3 Statement (draft GEIS), the affected environment is the environment that exists at and around 

4 the facilities that store spent nuclear fuel (spent fuel) after the end of a reactor’s licensed life for 

5 operation. Spent fuel is stored in at-reactor spent fuel pools and independent spent fuel storage 

6 installations (ISFSIs). Where appropriate, this chapter will discuss the environmental impacts 

7 during reactor operations to establish the baseline affected environment at the beginning of 

8 continued storage.

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

10 ISFSI are discussed in Chapter 5 and are not addressed further in this chapter. Because 

11 conditions at at-reactor ISFSIs are at least partially the result of past construction and 

12 operations at power plants, the impacts of these past and ongoing operations and how 

13 they have shaped the environment help to establish the baseline affected environment. 

14 A comprehensive description of the affected environment during operations is provided in the 

15 Generic Environmental Impact Statement for License Renewal of Nuclear Plants (License 

16 Renewal GEIS) (NRC 2013a) and the analysis in this draft GEIS relies on that description to 

17 help establish the affected environment for continued storage. Sections 3.1 through 3.16

18 provide a general description of the affected at-reactor environment for each resource area. 

19 Descriptions of the typical facilities and activities that occur during continued storage are 

20 described in Chapter 2. The potential environmental impacts of continued storage at reactor 

21 sites are evaluated in Chapter 4.

22 3.1 Land Use

23 This section describes the affected environment in terms of land use associated with continued 

24 storage of spent fuel.

25 The general characteristics of nuclear power plants are described in Section 2.1.1 of this draft 

26 GEIS. Operating commercial nuclear power plant sites range in area from 34 ha (84 ac) to 

27 5,700 ha (14,000 ac) (NRC 2013a). Nuclear power plant sites are zoned for industrial use with 

28 land requirements generally amounting to 40 to 50 ha (100 to 125 ac) for the reactor 

29 containment building, auxiliary buildings, cooling system structures, administration and training 

30 offices, and other facilities (e.g., switchyards, security facilities, and parking lots). Areas 

31 disturbed during construction of the power plant generally were returned to prior uses when 

32 construction was completed. Other land commitments include transmission line right-of-ways 

33 and cooling lakes (if used) (NRC 2013a). 
Affected Environment

Draft NUREG‒2157 3-2 September 2013

1 As described in the License Renewal GEIS (NRC 2013a), areas surrounding nuclear power 

2 plant sites typically consist of flat to rolling countryside in wooded or agricultural areas. 

3 Information on land cover within 8 km (5 mi) of commercial nuclear power plants is summarized 

4 in Table 3.2–1 of the License Renewal GEIS (NRC 2013a). Most of the land cover near plants 

5 is undeveloped land (forest, wetlands, herbaceous cover, and shrub/scrub land), agricultural 

6 land, or open water. U.S. Nuclear Regulatory Commission (NRC) regions and the location of 

7 operating reactors within the United States are shown in Figure 3-1. In Region I (Northeast) and 

8 Region II (Southeast), more than 80 percent of land cover surrounding most plants is open 

9 water, forest, wetlands, and agricultural. Power plants in Region III (northern Midwest) are 

10 mostly surrounded (approximately 80 percent) by agricultural land, open water, and forests. In 

11 Region IV (West and southern Midwest), more than 90 percent of land cover surrounding most 

12 plants is agricultural land, shrub/scrub land, open water, forest, herbaceous cover, and wetlands

13 (NRC 2013a). 

14

15 Figure 3-1. Map of NRC Regions Showing Locations of Operating Reactors (NRC 2012a)

16

17 Nuclear power plants and their at-reactor ISFSIs are located in a range of political jurisdictions 

18 including towns, townships, service districts, counties, parishes, and states. The distances of 

19 plants from metropolitan and residential areas vary among sites. Most sites are not very remote 

20 (i.e., they are not more than about 32 km [20 mi] from a community of 25,000 people or 80 km 
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September 2013 3-3 Draft NUREG‒2157

1 [50 mi] from a community of 100,000 people). State, Federal, and Native American lands are 

2 present to various extents within the 80-km (50-mi) radius of power plants (NRC 2013a). 

3 During the period from 1960 to 1980, with utilities and local government actively encouraging 

4 growth (Metz 1983), commercial and industrial land uses tended to expand within the 16-km 

5 (10-mi) radius around nuclear power plants at the expense of agriculture (NRC 2013a). In some 

6 instances, the roads and water lines built for plant purposes encouraged residential and 

7 industrial growth. As described in Section 2.1, the distance of the nearest resident to a nuclear 

8 power plant and ISFSI is typically about 0.4 km (0.25 mi). Recently, local jurisdictions have 

9 adopted comprehensive land use or master plans to control residential and commercial growth 

10 and preserve agricultural land around nuclear power plants (NRC 2013a). 

11 Commercial nuclear power plant sites are owned and maintained by investor-owned utilities or 

12 merchant generators (i.e., independent power producers) that operate the associated power 

13 plants. While many plant owners use the land solely for generating electricity, some owners 

14 allow other uses for the land. Some plant owners lease land for agricultural (farming) and 

15 forestry production, permit cemetery and historical site access, and designate portions of their 

16 sites for recreation, management of natural areas, and wildlife conservation. As a result of 

17 security concerns after September 11, 2001, licensees have implemented improved site security 

18 measures, such as upgraded fencing, reduced site access, and increased signage detailing site 

19 access and restrictions (NRC 2013a). 

20 Spent fuel pools are housed in shield buildings at nuclear power plants with boiling water 

21 reactors or in fuel buildings at plants with pressurized water reactors (NRC 2013a). Continued 

22 storage in spent fuel pools would require only the building housing the spent fuel pool and any 

23 cooling system infrastructure that keeps the spent fuel cool. Land requirements for spent fuel 

24 pools are small in comparison to the total nuclear power plant site area. 

25 At most operating nuclear power plants, at-reactor ISFSIs have been constructed to provide

26 increased spent fuel storage because the spent fuel pools have reached capacity. The majority 

27 of ISFSIs are located at licensed nuclear power plant sites. Currently, there are 69 ISFSIs 

28 licensed to operate in 34 states. Of these ISFSIs, 54 operate under a general license at reactor 

29 sites and 15 received NRC-issued, site-specific licenses at either reactor sites or at away-from30 reactor sites (NRC 2013b).

31 Land requirements for at-reactor ISFSIs (either at operating or decommissioned power plants) 

32 are small in comparison to the total power plant site area. Spent fuel storage under either a 

33 general license or a site-specific license at an operating reactor consists of the casks, a cask 

34 transfer system (i.e., cranes and mobile equipment necessary to move the casks), and 

35 reinforced concrete pads on which the casks are placed (NRC 1989). Table 3-1 provides 

36 comparisons of land area needed for ISFSIs at various nuclear power plants in contrast to the 

37 total land area of power plant sites.
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Draft NUREG‒2157 3-4 September 2013

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

2 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) 0.2 (0.5)

Diablo Canyon 304 (760) 1.6–2 (4–5) 0.48 (1.2)

Surry 336 (840) 6 (15) 0.2 (0.5)

H.B. Robinson 2,408 (6,020) 0.06 (0.15) 0.06 (0.04)

North Anna 721 (1,803) 4 (10) 0.2 (0.5)

Oconee 204 (510) 1.2 (3) 0.16 (0.4)

Prairie Island 224 (560) 4 (10) 0.16 (0.4)

Sources: NRC 2012b; 2009a; 2008; 2005a,b; 2003; 1992

3 3.2 Socioeconomics 

4 This section describes the general socioeconomic factors that could be directly or indirectly 

5 affected by continued storage. For the draft GEIS, the NRC assumes that all nuclear power 

6 plant sites have constructed at-reactor ISFSIs by the end of a reactor’s licensed life for 

7 operation. Further, by this time, the socioeconomic effects of reactor operations have become 

8 well established because regional socioeconomic conditions will have adjusted to the presence 

9 of the nuclear power plant. During the period of reactor operations, local communities will have 

10 adjusted to fluctuations in workforce caused by regularly scheduled refueling and maintenance 

11 outages. Changes in employment and tax payments caused by the transition from reactor 

12 operations to decommissioning, and the continued storage of spent fuel, can have a direct and 

13 indirect effect on public services and housing demand, as well as traffic volumes in the region 

14 around each nuclear power plant site.

15 In general, nuclear power plant sites in the United States are located in one of two broad 

16 regional economic settings: rural or semi-urban. Rural areas have relatively simple economies 

17 in which agriculture is the primary economic activity (NRC 2013a). Rural economies have 

18 smaller, less diversified labor markets that are often composed of lower-paying occupations 

19 requiring less skill (NRC 2013a). Examples of nuclear power plant sites located in rural 

20 environments include Diablo Canyon, Grand Gulf, Oconee, Peach Bottom, Susquehanna, Three 

21 Mile Island, and Wolf Creek. Semi-urban areas have more complex economic structures, 

22 containing a wider range of industries, with larger and more diverse labor markets (NRC 2013a). 

23 Examples of power plant sites in semi-urban areas include Indian Point, Limerick, Millstone, and 

24 Palo Verde. 

25 For the purposes of this draft GEIS, the socioeconomic region of influence is defined by where 

26 spent fuel storage workers and their families reside, spend their income, and use their benefits, 
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September 2013 3-5 Draft NUREG‒2157

1 thereby directly and indirectly affecting the economic conditions of the region. Local and 

2 regional communities provide the people, goods, and services needed to support spent fuel 

3 storage operations. Spent fuel storage operations, in turn, provide wages and benefits for 

4 people and dollar expenditures for goods and services.

5 Currently, there are 69 ISFSIs licensed to operate in 34 states (NRC 2013b). NRC has 

6 prepared several environmental assessments (EAs) for constructing and operating at-reactor 

7 ISFSIs. A review of these EAs found that the construction workforce for an ISFSI ranged from 

8 approximately 20 to 60 workers for approximately 1 year (NRC 2003; 2005b,c; 1991a). In most 

9 cases, the construction workforce was comprised of locally available construction workers and 

10 existing power plant operations and security personnel. Since most at-reactor ISFSIs were 

11 constructed during the licensed life of the reactor (including renewed license periods), most 

12 reactor licensees added a small number of additional workers (less than three) to support ISFSI 

13 operations (NRC 1988, 1985, 1991b). No additional workers were required to maintain or 

14 monitor continued ISFSI operations for license renewal (NRC 2005a,b; 2009a; 1991a; 2012b).

15 As a nuclear power plant transitions to decommissioning and continued storage, the staffing 

16 requirement decreases. Compared to nuclear power plant operations which requires 600 to 

17 2,400 workers, and decommissioning which requires 100 to 200 workers, continued storage at 

18 spent fuel pool and at-reactor ISFSI requires far fewer workers, which will likely range from 20 to 

19 85 workers, depending on the continued storage activity at any given time. As discussed in 

20 Chapter 1 of this draft GEIS, the environmental impacts of decommissioning are not considered 

21 to be part of continued storage.

22 3.2.1 Employment and Income

23 Regional socioeconomic conditions associated with continued storage can vary depending on 

24 the location of the at-reactor storage site and the size of the storage workforce. Impacts 

25 associated with reactor shutdown and decommissioning are discussed with respect to 

26 cumulative impacts in Chapter 6 of this draft GEIS. Some systems that were used during 

27 reactor operations would remain in operation to ensure spent fuel pool cooling prior to the 

28 transfer of spent fuel from the pool to an at-reactor ISFSI. During continued storage, a reduced 

29 workforce would maintain and monitor the spent fuel pool and ISFSI. Workforce numbers would 

30 vary from site to site. At GEH Morris, an away-from-reactor spent fuel pool storage facility; 

31 fewer than 20 full-time employees monitor and maintain the spent fuel at the site (NRC 2004). 

32 In 2005, the Electric Power Research Institute and Maine Yankee Atomic Power Company 

33 prepared a report that provides detailed information on the decommissioning of Maine Yankee 

34 Atomic Power Station (EPRI and Maine Yankee 2005). At Maine Yankee (EPRI and Maine 

35 Yankee 2005), approximately 85 workers completed fuel transfer from the spent fuel pool to the 

36 at-reactor ISFSI. After fuel transfer was completed, overall staffing at Maine Yankee was 

37 reduced further (EPRI and Maine Yankee 2005). Currently, Maine Yankee maintains a staff of 

38
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Draft NUREG‒2157 3-6 September 2013

1 30 to 35 workers, which consist of operations and security personnel (MYAPC 2013). In 

2 contrast, at Fort St. Vrain, the applicant estimated that a minimal staff of 10 workers was

3 needed for ISFSI operations (NRC 1991a).

4 3.2.2 Taxes

5 Tax payments to local communities vary widely and the magnitude of tax payments depends on

6 a number of factors including the state tax laws and established tax payment agreements with 

7 local tax authorities. These tax payments, whether occurring in rural or semi-urban areas, 

8 provide support for public services at the local level (NRC 2013a). After termination of reactor 

9 operations, property tax payments would continue to provide revenue, albeit at a reduced rate, 

10 for State and local governments to spend on education, public safety, local government 

11 services, and transportation. For example during plant operations, Maine Yankee paid 

12 approximately $12 million a year to the Town of Wiscasset. Following plant shutdown, the town 

13 initially agreed to a reduction in taxes to approximately $6.1 million. Then, subsequent 2-year 

14 agreements were reached, and the annual tax liability was reduced to approximately $1 million 

15 (EPRI and Maine Yankee 2005). For the 2012–2013 tax year, Maine Yankee paid 

16 approximately $1,003,000 in property taxes and fees (MYAPC 2013). Portland General Electric, 

17 the licensee for the decommissioned Trojan site, which stopped electrical generation in 

18 November 1992, has maintained an at-reactor ISFSI and paid $1,075,228.77 in property taxes 

19 for the 2012 tax year (Columbia County 2013). Pacific Gas and Electric, the licensee for 

20 Humboldt Bay, which shutdown in July 1976, and has maintained an at-reactor spent fuel pool

21 paid $1,951,266 in property taxes to Humboldt County for the 2012–2013 tax year (PG&E 

22 2012). Connecticut Yankee Atomic Power Company, the licensee for Haddam Neck that

23 shutdown in December 1996, paid approximately $1,200,000 in property taxes for the 2012 tax 

24 year to the town of Haddam (CYAPC 2012).

25 3.2.3 Demography

26 Nuclear power plants sites and their associated spent fuel pools and at-reactor ISFSIs are 

27 located in a range of political jurisdictions (e.g., towns, townships, service districts, counties, 

28 parishes, Native American lands, and states). More than 50 percent of the sites have a 

population density within an 80-km (50-mi) radius of fewer than 77 people/km2 (200 people/mi2 29 ). 

30 In general, the nearest resident nuclear power plant is typically about 0.4 km (0.25 mi) (NRC 

31 2013a). Demographic characteristics vary in the region around each nuclear power plant site 

32 and may be affected by the remoteness of the nuclear plant to regional population centers 

33 (NRC 2013a).

34 Many communities have transient populations associated with regional tourist and recreational 

35 activities, weekend and summer homes, or populations of students who attend regional colleges 

36 and other educational institutions. For example, nuclear power plant sites located in coastal 

37 regions, such as D.C. Cook and Palisades on Lake Michigan, Oyster Creek on the New Jersey 
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September 2013 3-7 Draft NUREG‒2157

1 shore north of Atlantic City, and Diablo Canyon north of Avila Beach, have summer, weekend, 

2 and retirement populations and a range of recreational and environmental amenities that attract 

3 visitors from nearby metropolitan population centers (NRC 2013a). The regions around 

4 Vermont Yankee and Diablo Canyon power stations attract visitors seeking outdoor recreational 

5 activities for camping, skiing, and hiking in nearby state parks (NRC 2013a, 2003).

6 In addition to transient populations, farms and factories in rural communities often employ 

7 migrant workers on a seasonal basis. For example, berry production near the D.C. Cook and 

8 Palisades Nuclear Plants is a local agricultural activity that employs a sizable migrant labor 

9 force in the summer (NRC 2013a).

10 3.2.4 Housing

11 Housing markets in the vicinities of nuclear power plant sites and the spent fuel pools and 

12 at-reactor ISFSIs associated with the power plants vary considerably, with wide ranges in the 

13 number of housing units, vacancy rates, and the type and quality of housing (NRC 2013a). 

14 Although housing demand may be temporarily affected by the number of workers employed at 

15 a nuclear power plant site (NRC 2013a), actual housing choices are not likely to be affected by 

16 the presence of a nuclear power plant or construction or operation of an at-reactor ISFSI 

17 (NRC 2002). Rather, housing demand and choices are more likely to be in response to housing 

18 prices and commutes to a nearby urban area (NRC 2002). Nuclear power plants located in 

19 rural communities have relatively small housing markets (i.e., low housing availability), stable 

20 housing prices, lower median house values, and moderate and stable vacancy rates. In semi21 urban regions, housing markets are likely to change more rapidly with population growth near 

22 metropolitan areas (NRC 2013a).

23 3.2.5 Public Services

24 Licensees of nuclear power plant sites pay taxes to local and State governments. Revenues 

25 from these tax payments support public services at local levels (NRC 2013a). Changes in 

26 employment and tax payments caused by the transition from reactor operations to 

27 decommissioning and continued storage can have a direct and indirect effect on public services 

28 in the region around each nuclear power plant site. Although the most important source of 

29 revenue for local communities are property taxes, other sources of revenue include levies of 

30 electricity output and direct funding for local educational facilities and programs. As discussed 

31 in Section 3.2.2, after termination of reactor operations, property tax payments would continue 

32 to provide revenue, albeit at a reduced rate, for State and local governments to spend on public 

33 services (e.g., education, public safety, local government services, and transportation).
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Draft NUREG‒2157 3-8 September 2013

1 3.2.6 Transportation

2 Local and regional transportation networks and traffic volumes in the vicinity of nuclear power 

3 plant sites and associated spent fuel pools and at-reactor ISFSIs associated with the power 

4 plants vary considerably depending on the regional population density, location, size of local 

5 communities, and the nature of economic development patterns (NRC 2013a). For continued 

6 storage, it is anticipated that roadways used during plant operations would continue to be used

7 for access to the ISFSI after reactor ceases operation. In both rural and semi-rural locations 

8 most sites have only one access road, which may experience congestion at peak travel times 

9 (NRC 2013a). For further information on transportation networks see Section 3.12.

10 3.3 Environmental Justice

11 This section describes the affected environment in the vicinity of at-reactor spent fuel storage 

12 sites with respect to environmental justice factors that could occur during continued storage. 

13 The environmental justice analysis assesses 

14 the potential for disproportionately high and 

15 adverse human health or environmental effects 

16 on minority and low-income populations that 

17 could result from continued storage.

18 Under Executive Order 12898 (59 FR 7629), 

19 Federal agencies are responsible for 

20 identifying and addressing potential 

21 disproportionately high and adverse human 

22 health and environmental impacts on minority 

23 and low-income populations. Environmental 

24 justice refers to a Federal policy implemented 

25 to ensure that minority, low-income, and tribal

26 communities historically excluded from 

27 environmental decision-making are given 

28 equal opportunities to participate in decision29 making processes. In 2004, the Commission issued a Policy Statement on the Treatment of 

30 Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040), which 

31 states “The Commission is committed to the general goals set forth in Executive Order 12898, 

32 and strives to meet those goals as part of its National Environmental Policy Act (NEPA) review 

33 process” (NRC 2013a). 

Executive Order 12898, Federal Actions to 

Address Environmental Justice in Minority 

Populations and Low-Income Populations 

“Each federal 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”

(59 FR 7629).
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September 2013 3-9 Draft NUREG‒2157

1 The Council of Environmental Quality (CEQ) provides the following definitions to consider when 

2 conducting environmental justice reviews within the framework of NEPA, in “Environmental 

3 Justice: Guidance under the National Environmental Policy Act” (CEQ 1997):

4 • Disproportionately High and Adverse Human Health Effects—Adverse health effects are 

5 measured in risks and rates that could result in latent cancer fatalities, as well as other fatal 

6 or nonfatal adverse impacts on human health. Adverse health effects may include bodily 

7 impairment, infirmity, illness, or death. Disproportionately high and adverse human health 

8 effects occur when the risk or rate of exposure to an environmental hazard for a minority or 

9 low-income population is significant (as employed by NEPA) and appreciably exceeds the 

10 risk or exposure rate for the general population or for another appropriate comparison 

11 group.

12 • Disproportionately High and Adverse Environmental Effects—A disproportionately high 

13 environmental impact that is significant (as employed by NEPA) refers to an impact or risk of 

14 an impact on the natural or physical environment in a low-income or minority community that 

15 appreciably exceeds the environmental impact on the larger community. Such effects may 

16 include ecological, cultural, human health, economic, or social impacts. An adverse 

17 environmental impact is an impact that is determined to be both harmful and significant (as 

18 employed by NEPA). In assessing cultural and aesthetic environmental impacts, impacts 

19 that uniquely affect geographically dislocated or dispersed minority or low-income 

20 populations or American Indian tribes are considered.

21 • Minority individuals—Individuals who identify themselves as members of the following 

22 population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black or 

23 African American, Native Hawaiian or Other Pacific Islander, or two or more races meaning 

24 individuals who identified themselves on a Census form as being a member of two or more 

25 races, for example, Hispanic and Asian.

26 • Minority populations—Minority populations are identified when (1) the minority population 

27 of an affected area exceeds 50 percent or (2) the minority population percentage of the 

28 affected area is meaningfully greater than the minority population percentage in the general 

29 population or other appropriate unit of geographic analysis. Minority populations may be 

30 communities of individuals living in close geographic proximity to one another, or they may 

31 be a geographically dispersed or transient set of individuals, such as migrant workers or 

32 American Indians, who, as a group, experience common conditions with regard to 

33 environmental exposure or environmental effects. The appropriate geographic unit of 

34 analysis may be a political jurisdiction, county, region, or State, or some other similar unit 

35 that is chosen so as not to artificially dilute or inflate the affected minority population.

36 • Low-income population—Low-income population is defined as individuals or families 

37 living below the poverty level as defined by the U.S. Census Bureau’s Current Population 

38 Reports, Series P–60 on Income and Poverty (USCB 2007). Low-income populations may 

39
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Draft NUREG‒2157 3-10 September 2013

1 be communities of individuals living in close geographic proximity to one another, or they 

2 may be a set of individuals, such as migrant workers, who, as a group, experience common 

3 conditions.

4 Consistent with the NRC’s Policy Statement (69 FR 52040), affected populations are defined as 

5 minority and low-income populations who reside within an 80-km (50-mi) radius of a nuclear 

6 power plant site. Data on low-income and minority individuals are usually collected and 

7 analyzed at the census tract or census block group level (NRC 2013a). 

8 For the continued storage of spent fuel, the NRC will comply with Executive Order 12898 

9 through implementation of its NEPA requirements in Title 10 of the Code of Federal Regulations

10 (CFR) Part 51 by considering impacts to minority and low-income populations in this draft GEIS. 

11 It should be noted, however, that the Waste Confidence rulemaking is not a licensing action; it 

12 does not authorize the initial or continued operation of any nuclear power plant, and it does not 

13 authorize storage of spent fuel. Neither this rulemaking nor this draft GEIS identify specific sites 

14 for NRC licensing actions that would trigger a site-specific assessment.

15 This draft GEIS describes the potential impacts to minority and low-income populations

16 associated with continued storage of spent fuel at both at- and away-from-reactor ISFSIs. In 

17 this regard, the NRC has determined that it can provide an assessment of the environmental 

18 justice impacts during continued storage as compared to environmental justice impacts of 

19 storage during reactor operations.

20 For site-specific licensing actions, the NRC addresses environmental justice matters by

21 (1) identifying the location of minority and low-income populations that may be affected by long22 term storage of spent fuel at nuclear power plant sites, (2) determining whether there would be 

23 any potential human health or environmental effects to these populations and special pathway 

24 receptors, and (3) determining if any of the effects may be disproportionately high and adverse. 

25 The NRC has and will continue to prepare a site-specific environmental analysis, including an 

26 assessment of potential impacts to minority and low-income populations prior to any future NRC 

27 licensing action.

28 As discussed in Section 3.2 of this draft GEIS, nuclear power plant sites in the United States are 

29 located in one of two broad regional economic settings: rural or semi-urban. Demographic 

30 characteristics vary in the region around each nuclear power plant site and may be affected by 

31 the remoteness of the nuclear plant to regional population centers (NRC 2013a). Nuclear power 

32 plants located in both rural and semi-urban areas can have varying concentrations of minority 

33 and low-income communities. Prairie Island Nuclear Generating Plant near Red Wing, 

34 Minnesota, is an example of a facility in a rural environment. The Prairie Island Indian 

35 Community is located immediately next to the Prairie Island Nuclear Generating Plant and is the 

36 closest minority population and American Indian community to spent fuel storage pools and an 

37 at-reactor ISFSI.
Affected Environment

September 2013 3-11 Draft NUREG‒2157

1 Subsistence Consumption of Fish and Wildlife

2 Section 4-4 of Executive Order 12898 (59 FR 7629) directs Federal agencies, whenever 

3 practical and appropriate, to collect and analyze information on the consumption patterns of 

4 populations that rely principally on fish or wildlife for subsistence and to communicate the risks

5 of these consumption patterns to the public. In this draft GEIS, NRC considered whether there 

6 were any means for minority or low-income populations to be disproportionately affected by 

7 examining impacts to American Indians, Hispanics, migrant workers, and other traditional 

8 lifestyle special pathway receptors. Special pathways take into account the levels of 

9 radiological and nonradiological contaminants in native vegetation, crops, soils and sediments, 

10 groundwater, surface water, fish, and game animals on or near power plant sites that have 

11 at-reactor spent fuel storage pools and ISFSIs.

12 The special-pathway-receptors analysis is an important part of the environmental justice

13 analysis because consumption patterns may reflect the traditional or cultural practices of 

14 minority and low-income populations in an area, such as migrant workers or Native Americans. 

15 Traditional use of an area can be indicative of properties or resources that are historically 

16 significant for a living community to maintain its cultural heritage. These places—called 

17 traditional cultural properties—are discussed in Section 3.11 of this draft GEIS. For example, in 

18 the Prairie Island Nuclear Generating Plant license renewal review, the Prairie Island Indian 

19 Community provided NRC information about the traditional use of Prairie Island as a summer 

20 encampment for fishing, hunting, gathering medicines and foods, and raising crops. During the 

21 review, the Prairie Island Indian Community also expressed concern about native plants on 

22 Prairie Island being displaced by invasive species and human health impacts associated with 

23 the use of plants that are culturally significant to the Prairie Island Indian Community.

24 Operating nuclear power plants must have a comprehensive radiological environmental 

25 monitoring program to assess the impact of site operations on the environment. During plant 

26 operations, nuclear power plant operators collect samples from aquatic pathways (e.g., fish, 

27 surface water, and sediment) and terrestrial pathways (e.g., airborne particulates, radioiodine, 

28 milk, food products, crops, and direct radiation). Contaminant concentrations found in native 

29 vegetation, crops, soils, sediment, surface water, fish, and game animals in areas surrounding 

30 nuclear power plants are usually quite low (i.e., at or near the threshold of detection) and are 

31 seldom above background levels (NRC 2013a).

32 3.4 Climate and Air Quality

33 This section describes the local and regional climate, air quality, and sources of greenhouse gas

34 emissions during continued storage.
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Draft NUREG‒2157 3-12 September 2013

1 3.4.1 Climate

2 This section describes the climate near spent fuel pools and at-reactor ISFSIs. For this 

3 resource area, the License Renewal GEIS (NRC 2013a) provides the baseline description of the 

4 affected environment at the start of continued storage. As described in the License Renewal

5 GEIS, weather conditions at nuclear power plant sites vary depending on the year, season, time 

6 of day, and site-specific conditions, such as whether the site is located near coastal zones or in 

7 or near terrain with complex features (e.g., steep slopes, ravines, and valleys). These

8 conditions can be generally described by climate zones according to average temperatures. On 

9 the basis of temperature alone, there are three major climate zones: polar, temperate, and 

10 tropical. Within each of the three major climate zones, there are marine and continental 

11 climates. Areas near an ocean or other large body of water have a marine climate. Areas 

12 located within a large landmass have a continental climate. Typically, areas with a marine 

13 climate receive more precipitation and have a more moderate climate. A continental climate 

14 has less precipitation and a greater range in climate. Regional or localized refinements in 

15 climate descriptions and assessments can be made by considering other important climate 

16 variables and climate-influencing geographic variables, such as precipitation, humidity, surface 

17 roughness, proximity to oceans or large lakes, soil moisture, albedo (i.e., the fraction of solar 

18 energy [shortwave radiation] reflected from the Earth back into space), snow cover, and 

19 associated linkages and feedback mechanisms. Localized microclimates can be defined by 

20 considering factors such as urban latent and sensible heat flux and building-generated 

21 turbulence. Both national and regional maximum and minimum average annual temperature 

22 and precipitation climates over the 30 years from 1971 through 2000 are summarized in 

23 Section D.2 in Appendix D of the License Renewal GEIS (NRC 2013a).

24 The frequency and intensity of tornadoes, straight winds, and wind-borne missiles are a 

25 consideration in the design of both spent fuel storage pools and dry cask storage systems. 

26 Natural phenomena hazards, including design bases for high winds and wind-borne missiles are 

27 considered in the design bases of spent fuel storage facilities, as discussed in Section 4.18.

28 3.4.2 Greenhouse Gases

29 Based on assessments by the Global Climate Research Program (GCRP) and the National 

30 Academy of Sciences’ National Research Council, the U.S. Environmental Protection Agency

31 (EPA) determined that potential changes in climate caused by greenhouse gas (GHG) 

32 emissions could endanger public health and welfare (74 FR 66496). The EPA indicated that, 

33 while ambient concentrations of GHGs do not cause direct adverse health effects (such as 

34 respiratory or toxic effects), public health risks and impacts can result indirectly from changes in 

35 climate. Based on EPA’s determination, the NRC recognizes that GHGs contribute to climate 

36 change, climate change can affect health and the environment, and mitigation actions are 

37 necessary to reduce impacts. The NRC considers carbon dioxide and other GHG emissions in 

38 its environmental reviews, and includes consideration of emissions from construction and 
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September 2013 3-13 Draft NUREG‒2157

1 operation of a facility (NRC 2009b). NRC guidance (NRC 2010, 2011a, 2013d) also addresses 

2 consideration of GHGs and carbon dioxide in its environmental reviews for new power reactors. 

3 Historically, long-term carbon dioxide levels extending back 800,000 years have ranged 

4 between 170 and 300 parts per million; the GCRP estimates that present-day carbon dioxide 

5 concentrations are about 385 parts per million (GCRP 2009).

6 According to GCRP estimates, carbon dioxide levels at the end of the century will range 

7 between 500 and 900 parts per million (GCRP 2009). This corresponds with, at worst, a 

8 projected increase in average temperature through the end of the century (around 2090) of 

9 between 4° to 6°C (7° to 11°F) (GCRP 2009). The GCRP also presented the projected change 

10 in precipitation from the “recent past” (1961 to 1979) through the end of the century (around 

11 2090). Further, the GCRP forecasts that future precipitation will increase in northern areas, 

12 while southern areas, particularly in the West, will become drier (GCRP 2009). These estimates 

13 assume that no policies explicitly designed to address climate change are adopted. 

14 3.4.3 Criteria Pollutants

15 The EPA has set National Ambient Air Quality Standards (NAAQS) (40 CFR Part 50) for six 

16 criteria pollutants, including sulfur dioxide, nitrogen dioxide, carbon monoxide, ozone, particulate 

17 matter (PM; PM10, and PM2.5), and lead. Primary NAAQS specify maximum ambient (outdoor 

18 air) concentration levels of the criteria pollutants with the aim of protecting public health with an 

adequate margin of safety.

1 19 Secondary NAAQS specify maximum concentration levels with the 

aim of protecting public welfare.

2 20 States can have their own State Ambient Air Quality

21 Standards. State Ambient Air Quality Standards must be at least as stringent as the NAAQS, 

22 and they can include standards for additional pollutants. If a State has no standard 

23 corresponding to one of the NAAQS, then the NAAQS apply. EPA’s Tribal Authority Rule 

24 (63 FR 7254) also identifies provisions of the Clean Air Act that treat eligible Federally

25 recognized tribes as a state.

 

1 Based on EPA regulations, primary (health-based) standards are requisite to protect public health with 

an “adequate 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 Based on EPA regulations, secondary (welfare-based) standards are requisite to protect the “public 

welfare” from any known or anticipated adverse effects. Welfare effects include “effects on soils, water, 

crops, vegetation, man-made materials, animals, wildlife, weather, visibility and climate...” (Hassett-Sipple 

2011).
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Draft NUREG‒2157 3-14 September 2013

1 The EPA generally designates a nonattainment

2 area based upon air quality monitoring data or 

3 modeling studies that show the area violates, or 

4 contributes to violations of the national standard. 

5 The area also is referred to as an air quality 

6 control region, which the EPA designates for air 

7 quality management purposes and which 

8 typically consists of one or more counties. The 

9 EPA designates the area as attainment/ 

10 unclassifiable if the area meets the standard or 

11 expects to meet the standard despite a lack of 

12 monitoring data or modeling studies. After the 

13 air quality in a nonattainment area improves so 

14 that it no longer violates or contributes to 

15 violations of the standard and the State or Tribe 

16 adopts an EPA-approved plan to maintain the 

17 standard, EPA can re-designate the area as 

18 attainment. These areas are known as maintenance areas. In the License Renewal GEIS

19 (NRC 2013a), the NRC identified operating plants located within or adjacent to counties with 

20 designated nonattainment areas. EPA periodically reviews ambient pollution concentrations 

21 throughout the country and reclassifies the attainment status of areas. Attainment designation 

22 status for areas is presented in 40 CFR Part 81.

23 Each State develops an implementation plan that includes a strategy for attaining or maintaining 

24 the NAAQS, modeling that demonstrates attainment or maintenance, and various rules, 

25 regulations, and programs that provide the necessary air pollutant emissions reductions. On 

26 tribal lands, Federally recognized Indian tribes can develop their own tribal implementation plan, 

27 similar to State implementation plans. If the State or Tribe fails to submit a required plan, EPA

28 can promulgate a plan known as a Federal implementation plan. In accordance with 

29 Section 176(c) of the Clean Air Act and the General Conformity Regulations (40 CFR Part 51 

30 and Part 93), the NRC must analyze its licensing actions to ensure that its Federal action 

31 conforms to any applicable implementation plan. Conformity determinations are required when 

32 a department, agency, or instrumentality of the Federal government engages in, supports in any 

33 way or provides financial assistance for, licenses or permits, or approves any activity to ensure 

34 that the activity conforms to an applicable implementation plan. Currently, the General 

35 Conformity Regulations (40 CFR Part 51 and Part 93) apply to all Federal actions that are taken 

36 in nonattainment or maintenance areas.

37 The NRC will evaluate and document the need for a conformity determination for the activities 

38 within its authority that require an NRC license. These evaluations are completed as part of 

39 licensing actions involving new reactors, reactor license renewal, and any specifically licensed 

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

September 2013 3-15 Draft NUREG‒2157

1 ISFSI. Most NRC licensing actions involve emissions well below de minimis levels established 

2 by EPA in the General Conformity Regulations (e.g., 100 tons per year for nitrogen oxide

3 emissions [a precursor to ozone] in maintenance areas). As described further in Chapter 4, 

4 emissions of criteria pollutants during continued storage are likely to remain below de minimis

5 levels at all sites, and a general conformity determination would not be required.

6 3.5 Geology and Soils

7 This section describes the geology and soils that have the potential to be affected by continued 

8 storage of spent fuel.

9 The geologic environment of a nuclear power plant consists of the regional physiography, 

10 tectonic setting, and composition and physical properties of the bedrock and sedimentary strata 

11 underlying the site. Geologic hazards are also a condition of the geologic environment, 

12 including faulting and seismicity (NRC 2013a). Seismic hazards are the most ubiquitous of the 

13 geologic hazards, and almost all parts in the United States are subject to some potential for 

14 earthquake-induced vibrations. The likelihood and intensity of earthquake-induced vibratory 

15 ground motion at reactors depend on two factors. First, the number, frequency, and location of 

16 earthquakes depend on the site’s tectonic setting, tectonic activity, and nature of the seismic 

17 sources. Second, the physical characteristics of bedrock and soils beneath the site determine 

18 how earthquake energy is attenuated or amplified as it travels from the earthquake sources to 

19 the site. Both factors are integral to the development of the earthquake hazard assessments 

20 that form the bases for the seismic design of spent fuel pools and dry cask storage systems. 

21 Natural phenomena hazards in the design basis of spent fuel storage facilities, including seismic 

22 design, are addressed in Section 4.18, “Environmental Impacts of Postulated Accidents.”

23 The general characteristics of nuclear power plants are discussed in Section 2.1.1 of this draft 

24 GEIS, in the License Renewal GEIS, and in environmental statements and environmental 

25 impact statements prepared for initial construction and operation of nuclear power plants. All 

26 safety-related structures (e.g., seismic category 1 structures) at nuclear power plants are 

27 founded either on competent natural or engineered strata to ensure that no safety-related 

28 facilities are constructed in potentially unstable materials (NRC 2013a).

29 During construction of nuclear power plants, soil is disturbed for buildings, roads, parking 

30 lots, underground utilities (including cooling water system intake and discharge systems), 

31 aboveground utility structures (including transmission lines), cooling towers, and other 

32 structures (NRC 2013a), including at-reactor ISFSIs, which are usually constructed during 

33 nuclear power plant operations. Nuclear power plant sites range in size from 34 ha (84 ac) 

34 at the San Onofre plant in California to 5702 ha (14,090 ac) at the Clinton plant in Illinois. 

35 At-reactor ISFSIs range in size from 0.06 to 6 ha (0.15 to 15 ac). The proportion of land that 

36 remains undisturbed or undeveloped by construction activities varies from site to site.
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Draft NUREG‒2157 3-16 September 2013

1 Soils form over time in response to weathering and erosion of parent materials (underlying

2 bedrock or sediments), and as soils mature, they develop distinct horizons or layers that have

3 varying properties and potential uses. Across the United States, soils have a variety of 

4 compositions and related physical properties, depending on the local geologic conditions and 

5 climate. The degree of infiltration and the relative movement of groundwater or contaminants

6 through the soils depend on these physical properties.

7 The geologic resources in the vicinity of each nuclear plant and at-reactor ISFSI vary with the 

8 location and land-use activities. For example, where mining operations occur (e.g., sand and 

9 gravel pit operations or quarrying for crushed stone), there is little if any interaction between 

10 plant operations and local mining industries. However, some nuclear plants may purchase 

11 materials for landscaping and site construction from local sources. Commercial mining or 

12 quarrying operations are not allowed within nuclear power plant boundaries (NRC 2013a).

13 3.6 Surface-Water Quality and Use

14 This section describes the surface water use and quality that could be affected by the continued 

15 storage of spent fuel in spent fuel pools and at-reactor ISFSIs.

16 Because nuclear reactor operations rely predominantly on water for cooling, most nuclear power 

17 plant sites are located near reliable sources of water. These sources are often surface 

18 waterbodies such as rivers, lakes, oceans, bays, and reservoirs and other man-made

19 impoundments (NRC 2013a). The single exception is the Palo Verde Nuclear Generating 

20 Station in Arizona, which uses treated municipal wastewater for cooling water. Of the 65 sites in 

21 the United States that contain NRC-licensed nuclear power plants, 32 are located near rivers, 

22 22 near lakes and reservoirs, 5 near oceans, and 5 near estuaries and bays. These 

23 waterbodies form part of the affected environment for storage of spent fuel in spent fuel pools 

24 and at-reactor ISFSIs. Local drainage features at and near nuclear power plant sites, such as 

25 creeks and small streams, provide avenues for surface-water movement and interaction with 

26 surface waterbodies. Depending on regional precipitation regimes, local topography, and 

27 drainage patterns, operation of spent fuel pools and at-reactor ISFSIs may affect the availability 

28 and quality of these nearby surface-water resources.

29 Provisions of the Clean Water Act regulate the discharge of pollutants into waters of the 

30 United States. Discharges of cooling water and other plant wastewaters are monitored through 

31 the National Pollution Discharge Elimination System (NPDES) program administered by the 

32 EPA, or, where delegated, individual States. An NPDES permit is developed with two levels of 

33 controls: (1) technology-based limits and (2) water quality-based limits. NPDES permit terms 

34 may not exceed 5 years, and the applicant must reapply at least 180 days prior to the permit 

35 expiration date. The NPDES permit contains requirements that limit the flow rates and pollutant 

36 concentrations that may be discharged at permitted outfalls. Biocides and other contaminants 
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September 2013 3-17 Draft NUREG‒2157

1 in discharged cooling waters are governed by NPDES permit restrictions to reduce the potential 

2 for toxic effects on nontargeted organisms (e.g., native mussels and fish). NPDES permits 

3 impose temperature limits for effluents (which may vary by season) and/or a maximum 

4 temperature increase above the ambient water temperature (referred to as “delta-T,” which also 

5 may vary by season). Other aspects of the permit may include the compliance measuring 

6 location and restrictions against plant shutdowns during winter to avoid drastic temperature 

7 changes in surface waterbodies. The permit also may include biological monitoring parameters 

8 that are primarily associated with the discharge of cooling water.

9 Wastewater discharge is also covered through NPDES permitting, and it includes biochemical 

10 monitoring parameters. Conditions of discharge for each plant are specified in its NPDES 

11 permit issued by the State or EPA. Most plants have a stormwater management plan, with the 

12 parameter limits of the storm water outfalls included in the NPDES permit. Plants also may

13 have a spill prevention, control, and countermeasures plan that provides information on 

14 potential liquid spill hazards and the appropriate absorbent materials to use if a spill occurs.

15 In an effort to minimize or eliminate impacts to the water quality of receiving waterbodies, best 

16 management practices are typically included as conditions within NPDES permits. Best 

17 management practices are measures used to control the adverse stormwater-related effects of 

18 land disturbance and development. They include structural devices designed to remove 

19 pollutants, reduce runoff rates and volumes, and protect aquatic habitats. Best management 

20 practices also include nonstructural or administrative approaches, such as training to educate 

21 staff on the proper handling and disposal of potential pollutants.

22 After cessation of reactor operations at the nuclear power plant sites, water use would be 

23 reduced to spent fuel pool cooling, radiation protection for workers, maintenance, human 

24 consumption, and personal hygiene.

25 3.7 Groundwater Quality and Use

26 This section describes the groundwater use and quality that could be affected by the continued 

27 storage of spent fuel in spent fuel pools and at-reactor ISFSIs.

28 Groundwater, which has been used as a water supply source throughout recorded history, is 

29 found in the voids of unconsolidated geologic materials (e.g., sand and gravel), in fractures of 

30 consolidated rocks (e.g., sedimentary, metamorphic, igneous, and volcanic rocks), and in 

31 conduits/channels of carbonates (e.g., limestone and dolomites). Where groundwater can be 

32 found in the subsurface depends on the geologic history of an area. The quantity and quality of 

33 groundwater for domestic uses depends on site-specific conditions. Anthropogenic impacts 

34 may affect groundwater quality, but those impacts also are site specific. Both unconfined and 

35 confined aquifers that can provide a potential water supply source for domestic use may exist 
Affected Environment

Draft NUREG‒2157 3-18 September 2013

1 beneath a nuclear power plant site. The type of aquifers and their properties at nuclear power 

2 plant sites are site specific and can vary considerably.

3 In the eastern United States, most nuclear power plant sites are located in two large regional 

4 groundwater provinces: (1) the first is composed of the Atlantic and Eastern Gulf coastal plain, 

5 the Southeastern coastal plain, and the Gulf of Mexico coastal plain; and (2) the second is 

6 composed of the Central Glaciated and the Central Nonglaciated plains (Back et al. 1988). The 

7 first groundwater province, which extends from New Jersey south to Florida and west along the 

8 Gulf of Mexico, includes aquifers that have moderate to very high transmissivity values, 

9 moderate to high recharge rates, and moderate- to high-yield wells. In contrast, the second 

10 groundwater province, which includes the Great Lakes and upper Midwest, includes aquifers 

11 that have moderate to high transmissivity values, lower recharge rates, and low- to moderate12 yield wells.

13 In addition, several nuclear power plant sites are located in the Piedmont and Blue Ridge and 

14 the Appalachian Plateau and Valley and Ridge groundwater regions (Back et al. 1988). 

15 Aquifers in the Piedmont and Blue Ridge region have low transmissivity values, and while 

16 recharge rates are moderate to high, typical wells have very low yields. By contrast, aquifers in 

17 the Appalachian Plateau and Valley and Ridge have moderate to high transmissivity values, 

18 moderate to high recharge rates, and low to moderate-yield wells.

19 Two of the four nuclear power plant sites located in the western United States use cooling water 

20 from the Pacific Ocean. These two nuclear power plants are located in the Pacific Coast Range 

21 region of California. The geologic complexity of this region creates diverse hydrogeologic 

22 conditions. Another power plant in the west uses cooling water from the Columbia River, which 

23 dissects the prolific bedded basalt aquifer system of the Columbia Lava Plateau, while the 

24 fourth, located in the Central Alluvial Basins of the arid desert southwest, uses treated municipal 

25 wastewater for cooling (Back et al. 1988).

26 Many of the nuclear power reactor sites in the United States that are adjacent to lakes, rivers, 

27 reservoirs, and engineered cooling ponds are constructed on unconsolidated stream, glacial, 

28 and lake deposits that host shallow, unconfined to semi-confined aquifers (Back et al. 1988). 

29 Where unconsolidated permeable deposits are thin or not inter-bedded with lower permeability 

30 sediments, local groundwater flow systems may be hydraulically connected to deeper, regional 

31 to sub-regional groundwater flow systems in underlying permeable unconsolidated deposits, 

32 coarse-grained sandstone, carbonate units with solution features, and folded or fractured 

33 crystalline rocks. Where shallow aquifers are immediately underlain by thick, impermeable 

34 shale or massive, unjointed carbonate strata, there is likely little or no hydraulic connection with 

35 deeper, regional groundwater flow systems.

36 Contaminants may enter an aquifer system and be transported with the hydraulic gradient. The 

37 direction and rate of contaminant transport will depend on the site-specific properties of the 
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September 2013 3-19 Draft NUREG‒2157

1 aquifer. For relatively permeable aquifers with a substantial hydraulic gradient, contaminants 

2 would be transported down-gradient quickly. For relatively permeable aquifers with a low 

3 hydraulic gradient, contaminants would move very slowly down-gradient. Typically, a 

4 contaminant plume would be elongated in the direction of the hydraulic gradient because 

5 transverse mixing (transverse dispersion) is much less than in the groundwater flow direction 

6 (longitudinal dispersion) (Todd 1960). For relatively low permeable aquifers, contaminants 

7 would move very slowly.

8 As noted in the License Renewal GEIS (NRC 2013a), leaks and spills during the licensed life for 

9 operation at reactors have resulted in groundwater and soil contamination. Industrial practices 

10 involving the use of solvents, heavy metals, or other chemicals and unlined wastewater lagoons 

11 have the potential to contaminate site groundwater, soil, and subsoil. Contamination is subject 

12 to State- and EPA-regulated cleanup and monitoring programs (NRC 2013a). In addition, 

13 radionuclides, particularly tritium, have been released to groundwater at many plants. 

14 Underground system leaks of process water also have been discovered in recent years at 

15 several plants. A description of spent fuel pool leaks at NRC-licensed facilities is included in 

16 Appendix E. 

17 Because tritium travels through groundwater faster than most other radionuclides, tritium is 

18 generally the first radionuclide to be identified in groundwater after a radioactive spill or leak. 

19 There are 65 locations in the United States where commercial nuclear power plants are 

20 operating. Records indicate that, at some time during their operating history, 42 of these sites 

21 have had leaks or spills involving tritium concentrations in excess of the 20,000 pCi/L drinking 

22 water standard established in the Safe Drinking Water Act. Nineteen sites are currently 

23 reporting tritium concentrations, from a leak or spill, in excess of 20,000 pCi/L onsite. However, 

24 no site is currently detecting tritium in excess of 20,000 pCi/L offsite, or in drinking water 

25 (NRC 2012c). 

26 On June 17, 2011, the NRC issued the Decommissioning Planning Rule (76 FR 35512). This 

27 rule, through changes to the regulations at 10 CFR 20.1406 and 20.1501, requires licensees to 

28 “... minimize the introduction of significant residual radioactivity into the site, including the 

29 subsurface, and to perform radiological surveys to identify the extent of significant residual 

30 radioactivity at their sites, including the subsurface” (NRC 2012d). As a result, all currently 

31 operating NRC-licensed nuclear power plants and any nuclear power plant that may be built in 

32 the future are required to perform groundwater monitoring to determine the extent of any 

33 existing contamination and to aid in the timely detection of any future contamination. Timely 

34 detection of leakage will allow licensees to identify and repair leaks and employ mitigation

35 measures, as necessary, to minimize or eliminate any environmental impacts that would result 

36 from leaks.

37 Licensees that have implemented a groundwater monitoring program consistent with the 

38 Nuclear Energy Institute Groundwater Protection Initiative are considered to have an adequate 
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Draft NUREG‒2157 3-20 September 2013

1 program for the purposes of the Decommissioning Planning Rule (NRC 2011b). Additional 

2 discussion pertaining to groundwater monitoring can be found in Appendix E of this draft GEIS.

3 3.8 Terrestrial Resources

4 This section describes the general terrestrial resources that could be affected by continued 

5 storage of spent fuel in spent fuel pools and at-reactor ISFSIs. Terrestrial plant and animal 

6 communities found on land may be subject to potential effects associated with spent fuel 

7 storage facilities (wet storage in spent fuel pools or dry storage in casks).

8 Nuclear power plants (which include spent fuel pools) and associated at-reactor ISFSIs (which 

9 are located on nuclear power plant sites) are sited in a wide variety of terrestrial habitat types 

10 from coastal to intermountain landscapes. Terrestrial habitats vary widely depending on their 

11 ecoregion, or geographic location especially in relation to the climate, landforms, and soil 

12 characteristics. Surrounding land uses and land forms (e.g., deserts and mountains) 

13 significantly influence the local and regional biodiversity and ecosystem. For example, an arid 

14 desert location is likely to have less biodiversity than a temperate rainforest. In addition, 

15 impacts at the local level in the immediate vicinity of nuclear power plants and associated 

16 at-reactor ISFSIs that have relatively intact, functioning ecosystems because of the lack of 

17 extensive development and disturbance would provide higher quality habitat and biodiversity as 

18 opposed to heavily industrialized areas where larger areas of habitat loss and disturbances 

19 decreases habitat quality and biodiversity.

20 For the purposes of this analysis, terrestrial ecological resources are described in terms of 

21 upland vegetation and habitats, lowland and wetland vegetation and habitats, and wildlife.

22 3.8.1 Upland Vegetation and Habitats

23 In general, upland terrestrial vegetation and habitats include habitats such as forests, 

24 grasslands, and shrublands as opposed to lowland areas. These habitats experience changes, 

25 called succession, within the vegetation communities in response to land-disturbing activities. 

26 The level of disturbance varies by land-use management activities (see Section 3.1). Typically, 

27 areas within the security fence at a nuclear power plant and associated at-reactor ISFSI have 

28 been modified by construction and maintenance activities and are maintained as modified 

29 landscapes for operational and security purposes. Some of these areas could contain relatively 

30 undisturbed habitat. Disturbed habitats are characterized mainly by grasses, forbs, and shrubs 

31 that represent the early successional stage. A maintenance activity, such as mowing and 

32 herbicide or pesticide applications, limits the diversity and maturity of plant species that are 

33 present. After construction of nuclear power plants and during maintenance activities, non34 native plant species and weeds often replace the naturally occurring vegetation while natural 

35 forest or shrubland in various degrees of disturbance may be present outside the security fence
Affected Environment

September 2013 3-21 Draft NUREG‒2157

1 (NRC 2013a). The affected habitats for continued storage would be similar to habitats 

2 described in the License Renewal GEIS because spent fuel pools and at-reactor ISFSIs are 

3 located at the nuclear power reactor sites described in the License Renewal GEIS.

4 Several operational activities at nuclear power plants may have effects on upland vegetative 

5 communities and habitats. As described in License Renewal GEIS (NRC 2013a), terrestrial 

6 habitats near nuclear power plants can be subject to small amounts of radionuclides. 

7 Radionuclides, such as tritium, and other constituents in cooling water systems, such as 

8 biocides, that enter shallow groundwater can also be taken up by terrestrial plant species. 

9 Maintenance activities along nuclear power plant transmission line corridors (cutting vegetation 

10 and using herbicides) within the property boundary of a nuclear power plant can contribute to 

11 habitat fragmentation and affect the distribution of plant and animal species in areas near the 

12 corridors. Nuclear power plants with closed-cycle cooling water systems may deposit water 

13 (and salt) droplets on vegetation and increase humidity in the area relatively close to the cooling 

14 towers during the period that the spent fuel pool is operated. In addition, heat dissipated during 

15 power plant operations by a combination of radiation, conduction, and convection can expose 

16 terrestrial habitats to elevated temperatures (NRC 2013a).

17 3.8.2 Lowland and Wetland Vegetation and Habitats

18 Lowlands along rivers, streams, and coastlines may include floodplains and several types of 

19 wetlands (riverine, palustrine, lacustrine, estuarine, and marine) that support fish and wildlife. 

20 As of 2007, wetlands covered an average of 3 percent of the land area near nuclear power 

21 plants and at-reactor ISFSIs, as mapped by the National Wetland Inventory (FWS 2007). 

22 Wetlands exclude permanently flooded areas that occupy, on average, about 10 percent of the 

23 area within 8 km (5 mi) of nuclear power plants (NRC 2013a). Wetland vegetation is 

24 hydrophytic (i.e., able to withstand waterlogged conditions) whether anchored on relatively dry 

25 land or in standing water. Depending on the wetland type, vegetation can vary widely from 

26 flowering plants, grasses, shrubs (reeds, sedges, and rushes), ferns, and trees.

27 During the initial nuclear power plant license periods, wetlands near nuclear power plants were 

28 affected by construction and operation activities (e.g., maintaining power line corridors, dredging 

29 wetland sediments, and sediment disposal) that caused storm water runoff, changes in 

30 vegetative plant community characteristics, altered hydrology, decreased water quality, and 

31 sedimentation. Some wetlands have been affected by nuclear power plant cooling systems that 

32 can increase the salinity of stream segments, increase water temperatures, and introduce 

33 contaminants to wetlands that receive groundwater discharge. However, wetlands have also 

34 been created at some power plants that use cooling ponds (NRC 2013a). 
Affected Environment

Draft NUREG‒2157 3-22 September 2013

1 3.8.3 Wildlife

2 Terrestrial animals (i.e., land mammals, insects, birds, amphibians, and reptiles) in the vicinity of 

3 a nuclear power plant and associated at-reactor ISFSI are typical of species found in a 

4 particular ecoregion and vary widely across the United States. The removal of vegetation 

5 during plant construction and operations have affected the habitat quality and, at some sites, 

6 reduced the available habitat by hundreds of acres. Wildlife biodiversity and ecological function 

7 in disturbed areas of nuclear power plant sites, including at-reactor ISFSIs, is different than in 

8 undisturbed areas, in part because the wildlife communities supported by disturbed areas are 

9 different than those that undisturbed areas support (NRC 2013a). Disruptive human activities 

10 (e.g., noise, ground vibrations, mechanical equipment, vehicles, and physical obstructions) also 

11 repel animals that are less tolerant to such disturbances. At the beginning of continued storage, 

12 these disturbed and undisturbed areas will be identical to the areas that existed during 

13 operations.

14 Maintenance activities along nuclear power plant transmission line corridors within the property 

15 boundary of the plant, which will continue for during continued storage, affects the distribution of 

16 plant and animal species in areas near the corridors and expose wildlife to nonionizing radiation 

17 exposure from transmission line electromagnetic fields (NRC 2013a).

18 Wildlife species that rely on and use the water resources at the reactor site will continue to be 

19 affected by continued storage. For example, the ongoing use of the spent fuel pool cooling 

20 system could introduce hazards to some wildlife and could create water-use conflicts with 

21 wildlife in the area. Wildlife species that occupy onsite habitats are exposed to a variety of 

22 contaminants and factors associated with nuclear power plant and at-reactor ISFSI operations 

23 and maintenance. The maintenance required for landscaped areas generally keeps the 

24 diversity of wildlife at a reduced level compared to unmaintained surrounding habitats. Wildlife 

25 species within the security areas are typically limited by the low quality of the habitat present 

26 and generally include common species adapted to industrial developments (NRC 2013a).

27 3.9 Aquatic Ecology 

28 This section describes the general aquatic resources that could be affected by the continued 

29 storage of spent fuel in spent fuel pools and at-reactor ISFSIs. Aquatic biota found in water, 

30 may be subject to potential effects associated with spent fuel storage facilities (wet storage in 

31 spent fuel pools or dry storage in casks).

32 The information contained in the following sections is a brief summary of aquatic resources 

33 known to exist near nuclear power plant sites which include spent fuel pools and associated 

34 at-reactor ISFSIs. The majority of this information comes from the License Renewal GEIS

35 (NRC 2013a), which describes a range of potentially affected aquatic resources that may be 
Affected Environment

September 2013 3-23 Draft NUREG‒2157

1 found in the vicinity of nuclear power plants. The affected environment for continued storage 

2 would be similar to the affected environment described in the License Renewal GEIS because 

3 spent fuel pools and at-reactor ISFSIs are located within power reactor sites, and the end of 

4 reactor operations would not significantly alter the affected environment for these resources. A 

5 more detailed account of the range of aquatic environments existing at these facilities can be 

6 found in the License Renewal GEIS.

7 Nuclear power plant sites must be located near waterbodies that are large enough to 

8 adequately meet the demands of a plant’s cooling systems. At-reactor ISFSIs are generally 

9 located near power plants. Therefore, nuclear power plant sites are usually placed near marine 

10 and estuarine coastal areas, on the Great Lakes, and along major rivers and reservoirs. A few 

11 power plants are sited near small streams (e.g., the V.C. Summer plant in South Carolina and 

12 the Clinton plant in Illinois), and initial construction activities included impounding the streams to 

13 create cooling ponds or reservoirs.

14 To establish the affected environment for this analysis, aquatic resources are described in terms 

15 of aquatic habitats (freshwater rivers, reservoirs, and lakes and coastal estuarine and marine 

16 systems) and aquatic biota (fish, macroinvertebrates, zooplankton, phytoplankton and 

17 macrophytes, other aquatic vertebrates and invertebrates, and aquatic vegetation).

18 3.9.1 Aquatic Habitats

19 A wide range of aquatic habitats occur in the vicinity of U.S. nuclear power plant sites due to 

20 differences in geographies, physical conditions (e.g., substrate type, temperature, turbidity, and 

21 light penetration), chemical conditions (e.g., dissolved oxygen levels and nutrient 

22 concentrations), biological interactions (e.g., consumption of various algal and invertebrate 

23 species that provide habitats, such as sea grass or shellfish beds), seasonal influences, and 

24 man-made modifications. The interactions of these factors often define the specific type of 

25 aquatic habitats and communities within a particular area. Three main aquatic ecosystem types 

26 occur near nuclear power plant sites: freshwater, estuarine, and marine ecosystems.

27 3.9.1.1 Freshwater Systems

28 Freshwater systems are generally classified into two groups based on the degree of water 

29 movement. Lentic systems are waterbodies with standing or slow-flowing water, such as ponds, 

30 lakes, reservoirs, and some canals. During warmer months, the upper and lower depths will 

31 stratify or become two layers that have different oxygen content and nutrient status. Lotic 

32 habitats, on the other hand, feature moving water and include natural rivers and streams and 

33 some artificial waterways. Most lotic habitats do not stratify (Morrow and Fischenich 2000). 

34 Some freshwater aquatic species may occur in both lentic and lotic habitats. However, many 

35 species are adapted to the physical, chemical, and ecological characteristics of one system or 
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Draft NUREG‒2157 3-24 September 2013

1 the other and the overall ecological communities 

2 present within these aquatic ecosystem types differ 

3 for different regions of the country (NRC 2013a). 

4 A number of major rivers provide cooling water for 

5 nuclear power plant sites. The geographic area, 

6 gradient of the river bed, velocity of the current, and 

7 source of nutrients and organic matter at the base of 

8 the food chain will largely determine species 

9 composition and ecological conditions within riverine 

10 environments. In some instances, nuclear power 

11 plants that use rivers for cooling are located on 

12 sections of rivers that have been impounded, 

13 creating reservoirs. Impoundment of a river can alter 

14 ecological communities occurring in a given 

15 waterbody by blocking movement of aquatic 

16 organisms, changing flow and temperature 

17 characteristics, adding chemical pollutants, and 

18 introducing non-native species. Fish species in 

19 numerous reservoirs are often stocked and managed 

20 to support local recreational fisheries (NRC 2013a). 

21 Littoral, pelagic, and profundal habitat zones are all 

22 found within lentic systems and are classified on the 

23 basis of water depth and light penetration in the 

24 water. Littoral habitats refer to nearshore shallower 

25 waters where sufficient light reaches the bottom to enable rooted plants to grow. Pelagic 

26 habitats include open offshore waters where light intensity is great enough for photosynthesis to 

27 occur. Profundal habitats are found in deep-water areas where light penetration is insufficient to 

28 support photosynthesis (Armantrout 1998). Unique ecological communities inhabit each zone, 

29 reflecting the preferences and tolerances of various aquatic species (NRC 2013a). 

30 In the Great Lakes, species diversity and biomass of fish are greater nearshore than in the 

31 offshore areas since these areas feature habitats and conditions that are favorable for most 

32 species of Great Lakes fish for at least some portion of their life cycle (Edsall and Charlton 

33 1997). Threats to the ecological integrity of the Great Lakes include eutrophication (nutrient 

34 enrichment), land-use changes, overfishing, invasive species, and pollution (Beeton 2002). 

35 Regulations and best management practices have been implemented to reduce nutrient 

36 inputs and control land use changes, such as shoreline alteration and destruction of wetlands. 

37 Invasive species, however, have become a major problem as nonindigenous species gain 

38 access to the Great Lakes. The introduction of invasive species can result in changes to 

39 native ecological communities (NRC 2013a). 

Aquatic Ecosystem Types

• Freshwater: Waters that contain a salt 

concentration or salinity of less than 

0.5 parts per thousand (ppt) or 

0.05 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).

• Marine: Waters that contain a salt 

concentration of about 30 ppt (e.g., 

ocean overlying the continental shelf 

and associated shores).

• 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.
Affected Environment

September 2013 3-25 Draft NUREG‒2157

1 3.9.1.2 Estuarine Ecosystems

2 Brackish to saltwater estuarine ecosystems occur along the coastlines of the United States. 

3 General habitat types found within estuarine ecosystems include the mouths of rivers, tidal 

4 streams, shorelines, salt marshes, mangroves, sea grass communities, soft-sediment habitats 

5 (e.g., mudflats and shellfish beds), and open water. Estuaries can serve as important staging 

6 points during the migration of certain fish species providing a refuge from predation while 

7 physiologically adjusting to the changes in salinity. Numerous marine fish and invertebrate 

8 species spawn in or use estuaries as places for young fish to develop before moving to marine 

9 habitats. Estuarine habitats also support important commercial or recreational finfish and 

10 shellfish species (NRC 2013a).

11 3.9.1.3 Marine Ecosystems

12 Marine ecosystems occur along the coastline and offshore of the United States. General habitat 

13 types within marine ecosystems include the rocky intertidal, rocky subtidal, deep-sea 

14 communities, sea grass communities (e.g., kelp beds), soft-sediment communities (e.g., sandy 

15 bottom or mudflats), and the open water or pelagic habitats. Species often compete for space 

16 within rocky subtidal and intertidal habitats. The area where species eventually settle is often a 

17 tradeoff between accommodating physiological stress and avoiding predation and/or 

18 competition with other species. For example, lower depths may provide a more ideal habitat in 

19 terms of physical requirements (e.g., temperature, pressure, salinity, and avoiding desiccation), 

20 but shallower areas may provide a refuge from predation. As a result, many organisms 

21 (including seaweeds, invertebrates, and some fish) that use rocky subtidal and intertidal habitats 

22 are restricted to a depth zone that balances physiological and biological pressures (Witman 

23 1987). Marine habitats support important commercial or recreational finfish and shellfish 

24 species (NRC 2013a). 

25 3.9.2 Aquatic Organisms

26 Aquatic organisms are known to occur near nuclear power plant sites. The following 

27 discussions provide high-level overviews of aquatic organisms that are known to exist in 

28 habitats near nuclear power plant sites. Additional details regarding aquatic organisms and 

29 species that occur near nuclear power plant sites are provided in the License Renewal GEIS

30 (NRC 2013a).

31 3.9.2.1 Fish

32 Fish can be characterized as freshwater, estuarine, marine, and migratory (e.g., anadromous 

33 and catadromous) species. The first three categories are based on salinity regimes. For 

34 example, freshwater fish usually inhabit waters with a salinity of less than 0.5 parts per 

35 thousand (ppt), although some species can tolerate a salinity as high as 10 ppt; estuarine fish 
Affected Environment

Draft NUREG‒2157 3-26 September 2013

1 inhabit tidal waters with salinities that range between 0 and 30 ppt; and marine fish typically live 

2 and reproduce in coastal and oceanic waters with salinities that are at or more than 30 ppt.

3 Migratory fish are generally categorized by their migratory patterns, or periodic movements that 

4 result in regularly alternating between two or more separate habitats (Northcote 1978). For 

5 example, anadromous species migrate from the ocean waters to freshwater to spawn, while the 

6 opposite situation occurs for catadromous species. Amphidromous species also migrate 

7 between fresh and saltwater, but these migrations are not related to the reproductive cycle. 

8 Potamodromous species migrate entirely within a freshwater system (e.g., some species tend to 

9 move to upstream areas for spawning) whereas oceanodromous species migrate entirely within 

10 the ocean (e.g., some species tend to move northward as waters warm and southward as they 

11 cool). A number of fish species that occur in the vicinity of the power plants are considered 

12 commercially or recreationally important, while others serve as forage for those species

13 (NRC 2013a). 

14 Fish are also categorized by the water depth that they inhabit. For example, pelagic fish live 

15 within the water column. Demersal fish live on or near the bottom of the sea floor (or bottom of 

16 the waterbody) and benthic fish live on the sea floor (or bottom of the waterbody). The 

17 distribution of demersal and benthic fish is usually highly dependent on the type of substrate 

18 that lines the floor of the waterbody. For example, certain fish prefer soft, sandy bottom habitat, 

19 whereas other fish prefer rocky substrates with crevices in which to hide. Other typical bottom 

20 water substrates that provide fish habitat include mud flats, kelp beds, submerged aquatic 

21 vegetation, salt marshes, mangroves, shellfish beds, and coral reefs.

22 3.9.2.2 Aquatic Macroinvertebrates

23 A broad range of aquatic macroinvertebrates may be found near nuclear power plant sites. 

24 Macroinvertebrates are responsible for controlling key ecosystem processes, including primary 

25 production, decomposition, nutrient regeneration, water chemistry, and water clarity. Mussels 

26 consume plankton (i.e., planktivores) and are prey items for some fish and other vertebrates. 

27 Macroinvertebrates require good water quality and physical habitat conditions that will support 

28 populations of their host fish species. Williams et al. (1993) reported that, of the nearly 

29 300 native freshwater mussels in the United States and Canada, nearly 72 percent are 

30 considered endangered, threatened, or of special concern, almost 5 percent are of 

31 undetermined status, and less than 24 percent are considered stable. Mussels occur in the 

32 vicinity of most plants that use freshwater as a cooling water source. Several species of 

33 non-native freshwater mussels and clams have been introduced to the United States and have 

34 reached nuisance levels. These species can alter trophic and nutrient dynamics of aquatic 

35 ecosystems and displace native mussels. Many of the nuclear plants have programs in place to 

36 monitor for these nuisance species and, as appropriate, to control them, usually using biocides 

37 (NRC 2013a). 
Affected Environment

September 2013 3-27 Draft NUREG‒2157

1 3.9.2.3 Zooplankton

2 Zooplankton are small animals that float, drift, or weakly swim in the water column of any 

3 waterbody, and include, among other forms, fish eggs and larvae with limited swimming ability, 

4 larvae of benthic invertebrates, medusoid forms of hydrozoans, copepods, shrimp, and krill 

5 (Euphausiids). Plankton are often categorized by how and where they inhabit the water column, 

6 including holoplankton (plankton that spend their entire lifecycle within the water column), 

7 meroplankton (plankton that spend a portion of their lifecycle in the water column), and 

8 demersal (benthic species that primarily reside on the seafloor but migrate into the water 

9 column on a regular basis). Zooplankton is an important link between phytoplankton and fish or 

10 other secondary consumers (NRC 2013a).

11 3.9.2.4 Phytoplankton and Aquatic Macrophytes

12 Phytoplankton, also referred to as microalgae, contain chlorophyll and require sunlight to live 

13 and grow. Most phytoplankton are buoyant and float in the upper part of the ocean, where 

14 sunlight penetrates the water. Phytoplankton is an important food source for some invertebrate 

15 and fish species and is important for carbon fixation (converting carbon dioxide to organic 

16 materials via photosynthesis). Periphyton (algae attached to solid submerged objects) includes 

17 species of diatoms and other algae that grow on natural or artificial substrates.

18 3.9.2.5 Other Aquatic Invertebrates and Vertebrates

19 Other important aquatic species include cephalopods (e.g., squid and octopus), marine 

20 mammals (e.g., seals and whales), sea turtles, and reptiles. These species may be present 

21 near at-reactor storage facilities; however, because of the significantly reduced water demands

22 for spent fuel pool cooling during continued storage, these larger organisms are more likely to 

23 avoid being impinged or entrained by the cooling system, and are therefore not discussed in 

24 Chapter 4 of this draft GEIS.

25 3.9.2.6 Aquatic Vegetation

26 Aquatic vegetation, including kelp, submerged aquatic vegetation, and sea grasses, provide 

27 important habitat for aquatic organisms and are often referred to as underground meadows or 

28 forests. Aquatic vegetation provides food, structurally complex habitat, areas to hide from 

29 predators, and spawning grounds for many aquatic species.

30
Affected Environment

Draft NUREG‒2157 3-28 September 2013

1 3.10 Special Status Species and Habitats

2 Several Federal and State acts protect aquatic and 

3 terrestrial species and habitats. Federally listed 

4 species, critical habitat, essential fish habitat (EFH), 

5 and other special status species and habitats are 

6 known to occur near nuclear power plant sites 

7 (NRC 2013a). The License Renewal GEIS provides 

8 additional details on the types of special status 

9 species that have occurred near nuclear power 

10 plants, such as sea turtles, fish, birds, and other 

11 protected species.

12 Federally listed threatened and endangered species

13 and critical habitat are protected under the 

14 Endangered Species Act of 1973 (ESA), while State15 listed species and habitats are protected under 

16 provisions of various State regulations. Under the 

17 ESA, the NRC must consult with the U.S. Fish and 

18 Wildlife Service (FWS) and the National Marine 

19 Fisheries Service (NMFS) for actions that could affect 

20 Federally listed species or critical habitat. Prior to 

21 initial licensing, the NRC would be required to consult 

22 with the FWS and/or the NMFS under Section 7 of 

23 the ESA to determine the presence of and potential 

24 impacts to any Federally listed species or critical 

25 habitat at or near the site. Section 7 ESA 

26 consultation could also be required after a license is 

27 granted if operations could impact a listed species or 

28 if a species is newly listed under ESA and that 

29 species occurs near the NRC-licensed facility, as 

30 described in more detail in Section 4.11. The 

31 objective of the consultation is to identify and assess 

32 potential impacts to listed species and critical habitat. 

33 Any ongoing or proposed activity associated with the 

34 operation or maintenance of spent fuel pools or 

35 ISFSIs that has the potential to affect a listed species 

36 requires that the NRC initiate consultation under Section 7 of the Endangered Species Act with 

37 the FWS or the NMFS depending on the species. Additional information on how the 

38 consultation process is used to identify, evaluate, and mitigate potential impacts to Federally 

39 listed species and critical habitat is discussed in Chapter 4.

Terms Related to Threatened, 

Endangered, and Protected Species 

and Habitats

• Endangered Species: Animal or 

plant species in danger of extinction 

throughout all or a significant portion of 

its range.

• Threatened Species: Animal or plant 

species likely to become endangered 

within the foreseeable future 

throughout all or a significant portion of 

its range.

• 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.

• Proposed Species: Animal or plant 

species that is proposed in the Federal

Register to be listed under Section 4 of 

the Endangered Species Act.

• 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. 

• 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 2013 3-29 Draft NUREG‒2157

1 The Magnuson-Stevens Fishery Conservation and Management Act, as amended, calls for the 

2 description, identification, and management of EFH to help conserve and manage Federal 

3 fishery resources. EFH is defined as those waters and substrates that are necessary to fish for 

4 spawning, breeding, feeding, or growth to maturity. Spent fuel pools that withdraw and 

5 discharge water to marine, estuarine, and coastal waters near designated EFH have the 

6 potential to affect EFH because they have a potential to alter, damage, or destroy EFH

7 components, thereby affecting the fishery resources that use them (NRC 2013a).

8 Marine mammals are protected under the Marine Mammal Protection Act of 1972, as amended, 

9 which also assigns responsibility for managing cetaceans (i.e., porpoises and whales), and 

10 pinnipeds (i.e., seals, fur seals, and sea lions) to the NMFS. The Act prohibits, with certain 

11 exceptions, the “take” (i.e., harming) of marine mammals in U.S. waters. Both the Magnuson12 Stevens Act and Marine Mammal Protection Act are administered by the NMFS.

13 The Bald and Golden Eagle Protection Act of 1940, as amended, provides for the protection of 

14 the bald eagle (Haliaeetus leucocephalus) and the golden eagle (Aquila chrysaetos) by 

15 prohibiting the taking, possession, and commerce of these birds, their nests, or their eggs. The

16 Act prescribes criminal and civil penalties for persons violating the conventions identified in 

17 16 USC 668. In addition, the Migratory Bird Treaty Act of 1918, as amended, protects migratory 

18 birds included in the terms of the conventions identified in 16 USC 703. Both acts are 

19 administered by the FWS. 

20 3.11 Historic and Cultural Resources

21 This section describes the historic and cultural 

22 resources that could be affected by continued 

23 storage. For the purposes of this draft GEIS, the 

24 area of potential effect is the area that may be 

25 impacted by land disturbing activities or other 

26 operational activities associated with continued 

27 storage of spent fuel (whether in spent fuel pools or 

28 at an at-reactor ISFSI) including the viewshed. This 

29 determination is made irrespective of land ownership 

30 or control. A description of these sites, including 

31 spent fuel pools and at-reactor ISFSIs, is provided in 

32 Section 2.1 of this draft GEIS.

33 Historic and cultural resources are the remains of 

34 past human activity and include prehistoric era and 

35 historic era archaeological sites, historic districts, buildings, or objects with an associated

36 historical, cultural, archaeological, architectural, community, or aesthetic value. Historic and 

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

Draft NUREG‒2157 3-30 September 2013

1 cultural resources also include traditional cultural properties that are important to a living 

2 community of people for maintaining their culture. “Historic property” is the legal term for a 

3 historic or cultural resource that is eligible for listing on the National Register of Historic Places 

4 (NRHP) (NRC 2013a). 

5 The National Historic Preservation Act of 1966, as amended (NHPA) requires Federal agencies 

6 to take into account the effects of their undertakings on historic properties. Historic properties 

7 are defined as resources that are eligible for listing on the NRHP. The criteria for NRHP 

8 eligibility are listed in 36 CFR 60.4 and include, among other things, (1) association with 

9 significant events that have made a significant contribution to the broad patterns of history, 

10 (2) association with the lives of persons significant in the past, (3) embodiment of distinctive 

11 characteristics of type, period, or method of construction, and (4) sites or places that have 

12 yielded or may be likely to yield important information in history or prehistory (ACHP 2008). The 

13 historic preservation review process (Section 106 of the NHPA) is outlined in regulations issued 

14 by the Advisory Council on Historic Preservation in 36 CFR Part 800.

15 The prehistoric era refers to the period before Europeans arrived in North America in the 1490s. 

16 Some of the most heavily used areas during this period were along rivers, lakes, and the 

17 seashore. These locations provided freshwater and the most abundant food sources, as well as 

18 the most efficient ways to travel. As a result, prehistoric era archaeological sites tend to be 

19 found along these waterways. Prehistoric archaeological resources include small temporary 

20 camps, larger seasonal camps that were revisited year after year, large village sites that were 

21 occupied continuously over several years or potentially for centuries, or specialized-use areas 

22 associated with fishing or hunting or with tool and pottery manufacture (NRC 2013a). 

23 The historic era refers to the period after Europeans arrived in North America. Similar to 

24 prehistoric populations, historic era sites tend to be clustered near waterways because water 

25 provided a means for transportation and trade, and supported agriculture. Historic era 

26 resources include farmsteads, mills, forts, residences, industrial sites (such as mines or canals), 

27 and shipwrecks (NRC 2013a). 

28 Traditional cultural properties are historic and cultural resources that are associated with cultural 

29 practices or beliefs of a living community, and are often associated with Native American

30 cultures. Traditional cultural properties can be considered historic properties and be included 

31 on the NRHP. Examples include traditional gathering areas where particular plants or materials 

32 were harvested, locations where a community has traditionally carried out economic, artistic, or 

33 other cultural practices important to maintaining its identity, or burial locations that connect 

34 individuals or groups with their ancestors. The locations of traditional cultural properties are 

35 often kept private; State Historic Preservation Offices can often be unaware of these locations 

36 (NRC 2013a).
Affected Environment

September 2013 3-31 Draft NUREG‒2157

1 Historic and cultural resources, especially archaeological sites, are sensitive to disturbance and 

2 are nonrenewable. Even a small amount of ground disturbance (e.g., ground clearing and 

3 grading) could affect a small but very significant resource. Much of the information contained in 

4 an archaeological site is derived from the spatial relationships between soil layers and 

5 associated artifacts. Once these spatial relationships are altered, they can never be reclaimed. 

6 (NRC 2013a)

7 Nuclear power plant sites are located in areas of focused past human activities (along 

8 waterways) and, as such, there is a potential for historic and cultural resources to be present 

9 near most nuclear power plants. For example, as part of the recent License Renewal GEIS

10 update, the NRC reviewed historic and cultural resource reviews that were performed for 

11 40 license renewals. For sites that had conducted field investigations, on average, the number 

12 of historic and cultural resources present were 35 per site (NRC 2013a). Sites identified 

13 included a variety of resources, including village and town sites, and cemeteries (NRC 2013a).

14 Most existing nuclear power plants in the United States were constructed in the 1960s, 1970s, 

15 and early 1980s. Although the NHPA was passed in 1966, the process for complying with the 

16 law was developing during the 1970s and early 1980s (NRC 2013a). Many existing nuclear 

17 power plant sites were not investigated for the presence of historic and cultural resources prior 

18 to initial facility construction. Extensive ground-disturbing activities occurred during initial 

19 nuclear power plant construction, and much of the land in and immediately surrounding the 

20 power block was extensively disturbed. It is unlikely that historic and cultural resources are 

21 present within heavily disturbed areas. However, developed and less-developed portions of a 

22 power plant site, including areas that were not extensively disturbed (e.g., construction laydown 

23 areas), could still contain unknown historic and cultural resources. Laydown areas are lands 

24 that were cleared, graded, and used to support fabrication and installation activities during initial 

25 power plant construction.

26 For continued storage, the NRC will consider impacts to historic and cultural resources in this 

27 draft GEIS through its NEPA requirements in 10 CFR Part 51. Neither the Waste Confidence

28 rulemaking nor this draft GEIS identifies specific sites for NRC licensing actions that would 

29 trigger Section 106 consultation requirements that are normally conducted during site-specific 

30 licensing reviews. This rulemaking is not a licensing action; it does not authorize the initial or 

31 continued operation of any nuclear power plant, and it does not authorize storage of spent fuel. 

32 This draft GEIS describes the potential impacts to historic and cultural resources associated 

33 with continued storage of spent fuel at both at-reactor and away-from-reactor ISFSIs.

34 For site-specific licensing actions (i.e., new reactor licensing, reactor license renewal, and site35 specific at-reactor and away-from-reactor ISFSIs), applicants are required to provide historic 

36 and cultural resource information in environmental reports submitted with license applications. 

37 To prepare these assessments, applicants conduct cultural resource surveys. This information 

38 assists NRC in its review of the potential impacts to historic and cultural resources. As part of 
Affected Environment

Draft NUREG‒2157 3-32 September 2013

1 these site-specific licensing actions, the NRC has and will continue to comply with the 

2 consultation requirements in the NHPA regulations in 36 CFR Part 800 and consult with State 

3 Historic Preservation Offices or appropriate Tribal Historic Preservation Officer, Tribal 

4 representatives, and other interested parties to determine the area of potential effect and if the 

5 licensing action would affect historic properties. As identified in 36 CFR 800.2, interested 

6 parties can include representatives of the local government, the license applicant, the Advisory 

7 Council on Historic Preservation, the public, and organizations with a demonstrated interest in 

8 the undertaking. The NRC will consider information provided by these consulting parties when 

9 making determinations under the NHPA. If historic and cultural resources are present within the 

10 area of potential effect, identification of historic properties, adverse effects, and potential 

11 resolution of adverse effects will be done through consultation and application of the NRHP 

12 criteria in 36 CFR 60.4. 

13 3.12 Noise

14 This section describes noise associated with continued storage. The affected environment is 

15 the environment that exists at and around spent fuel pools and at-reactor ISFSIs where 

16 continued storage activities would occur. Noise describes unwanted sound that is undesirable 

17 because it interferes with speech, communication, or hearing; is intense enough to damage 

18 hearing; or is otherwise annoying (NRC 2002). A common sound measurement used to 

19 indicate sound intensity is the A-weighted sound level (designated as decibel-A or dB(A)). The 

20 decibel expresses sound levels on a logarithmic scale and accounts for the response of the 

21 human ear. The noise levels experienced at spent fuel storage locations at a particular point in 

22 time depends on what noise generating activities are occurring in the vicinity.

23 Ambient noise levels depend in part on the amount of development that has occurred in the 

24 area around nuclear power plant sites. In rural or low-population areas, background noise 

25 levels are typically in a range of 35 to 45 dB(A) (NRC 2013a). In areas where more 

26 development has occurred, the surrounding community and highway noise results in baseline 

27 noise levels around 60 to 65 dB(A) (NRC 2013a). Over time, the ambient noise levels at a 

28 particular location can change as the area experiences changes in development. For example, 

29 if new development activities that generate additional noise are initiated, then the ambient noise 

30 levels in the area would increase.

31 Noise can be examined from the perspective of two different receptor groups: workers and the 

32 general public. There are no Federal regulations for public exposure to noise. Impacts are 

33 primarily evaluated in terms of adverse reactions of the public to noise. EPA has developed

34 guideline sound levels below which the general public should be protected from activity 

35 interference and annoyance. For residential areas, EPA identified thresholds over a 24-hour 

36 period of 45 dB(A) for indoor exposures and 55 dB(A) for outdoor exposures (EPA 1974). At 

37 the Federal level, the Occupational Safety and Health Administration regulates noise
Affected Environment

September 2013 3-33 Draft NUREG‒2157

1 exposure for workers. The permissible noise exposure limit varies by duration. The limit 

2 ranges from 90 dB(A) for a duration of 8 hours per day to 115 dB(A) for 15 minutes or less 

3 (29 CFR 1910.95).

4 Baseline noise characteristics would also include noise generated by spent fuel storage 

5 activities. Noise has been assessed in various site-specific at-reactor ISFSI environmental 

6 reviews such as the Calvert Cliffs ISFSI license renewal (NRC 2012b) for dry cask storage and 

7 the GEH Morris ISFSI license renewal (NRC 2004) for pool storage. Activities that involve

8 construction equipment, such as decommissioning, generate the most ongoing noise, with 

9 earthwork and excavation equipment noise levels exceeding 90 dB(A) (NRC 2002). Noise 

10 associated with continued storage is primarily limited to mobile sources associated with the 

11 movement of spent fuel between the spent fuel pool and the dry cask storage pad (see 

12 NRC 2012b).

13 Proximity is a factor when assessing impacts because noise levels decrease as distance from 

14 the source increases. Spent fuel storage facilities typically have large buffer areas between the 

15 facility and the nearest receptor. In addition, other barriers such as buildings, vegetation, and 

16 topography can also reduce noise levels.

17 3.13 Aesthetics

18 Aesthetic resources refer to the visual appeal of a tract of land. The scenic quality of an area 

19 may include natural and man-made landscapes and the ways in which the two are integrated. 

20 Aesthetic resources can include scenic viewsheds with waterbodies, topographic features, or 

21 other visual landscape characteristics. The baseline for evaluation of impacts to aesthetic 

22 resources is the existing visual condition of a site. Assessment of potential impacts to aesthetic 

23 resources requires evaluation of the degree to which a project would contrast adversely with the 

24 existing landscape. Section 2.1 provides a generic description of nuclear power plant sites and 

25 storage facilities.

26 3.14 Waste Management

27 This subsection describes the various types of wastes generated by continued storage of spent 

28 fuel.

29 3.14.1 Low-Level Radioactive Waste

30 Low-level waste (LLW) is radioactive material that (1) is not high-level radioactive waste, spent 

31 fuel, or byproduct material (as defined in Section 11e(2) of the Atomic Energy Act of 1954 and 

32 (2) is classified by the NRC, consistent with existing law, as low-level radioactive waste (as 

33 defined in the Low-Level Radioactive Waste Policy Act, as amended).
Affected Environment

Draft NUREG‒2157 3-34 September 2013

1 Almost all LLW generated from reactor operation, including spent fuel storage in pools and 

2 ISFSIs, is shipped offsite, either directly to a disposal facility or to a processing center before 

3 being sent to a disposal site. The number of shipments leaving each reactor site varies but 

4 generally ranges from a few to about 100 per year. 10 CFR Part 20, Subpart K, discusses the 

5 various means by which the licensees may dispose of their radioactive waste. The 

6 transportation and land disposal of solid radioactive wastes are performed in accordance with 

7 the applicable requirements of 10 CFR Part 71 and 10 CFR Part 61, respectively.

8 There are currently four operating disposal facilities in the United States that are licensed to 

9 accept commercial-origin LLW. They are located in Barnwell, South Carolina; Richland, 

10 Washington; Clive, Utah; and Andrews County, Texas. The facility in Utah, operated by 

11 EnergySolutions, is licensed to accept only Class A LLW, whereas the other three facilities can 

12 accept Class A, B, and C wastes (GAO 2004). In 2001, the South Carolina legislature imposed 

13 restrictions on the Barnwell facility such that after June 2008, the facility can accept waste from 

14 generators in only three States: South Carolina, New Jersey, and Connecticut. The Barnwell 

15 facility is projected to close in 2038 (EnergySolutions 2012). The Richland facility accepts LLW 

16 from only 11 States: Washington, Alaska, Hawaii, Idaho, Montana, Oregon, Utah, Wyoming, 

17 Colorado, Nevada, and New Mexico. It is expected to close in 2056. The EnergySolutions 

18 facility in Utah accepts only Class A waste, but the waste can come from any state. This facility 

19 currently does not have a projected closing date. Waste Control Specialists, LLC, facility in 

20 Texas accepts Class A, B, and C LLW from Texas and Vermont per the Texas Low-Level 

21 Radioactive Waste Disposal Compact. Individual waste generators located outside of Texas 

22 and Vermont may apply for an agreement to import non-Compact generated waste for disposal 

23 at the Waste Control Specialists, LLC site. Currently, there is no projected closing date for this 

24 facility. 

25 Operating nuclear power plants, including activities associated with spent fuel storage, generate 

26 LLW generally consisting of air filters, cleaning rags, protective tape, paper and plastic 

27 coverings, discarded contaminated clothing, tools, equipment parts, and solid laboratory wastes 

28 (all these are collectively known as dry active waste) and wet wastes that result during the 

29 processing and recycling of contaminated liquids at the plants. Wet wastes generally consist of 

30 spent demineralizer or ion exchange resins, and spent filter material from the equipment drain, 

31 floor drain, and water cleanup systems. The wet wastes are generally solidified, dried, or 

32 dewatered to make them acceptable at a disposal site (NRC 2013a).

33 The quantity of LLW generated by reactor operation, including spent fuel storage in spent fuel 

34 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 35 ) and 

1,000 Ci (3.7 × 10 36 13 Bq) of LLW per year (Table 6.6 in NRC 2013a). The annual volume and 

37 activity of LLW generated at a boiling water reactor are approximately twice the values indicated 

38 for a pressurized water reactor. Approximately 95 percent of this waste is Class A (NEI 2013). 
Affected Environment

September 2013 3-35 Draft NUREG‒2157

1 After reactor operations have ceased, the number and types of activities generating LLW will 

2 decrease. Therefore, the annual quantity of LLW generated from storage of spent fuel during 

3 continued storage is expected to be a small fraction of that generated while the nuclear power 

4 plant is operating because there are less waste generating activities occurring.

5 3.14.2 Mixed Waste

6 Wastes that are both radioactive and hazardous 

7 are called mixed waste. These wastes are 

8 regulated by the EPA or an authorized State for the 

9 hazardous component, and by the NRC or an 

10 agreement State for the radioactive component. 

11 The types of mixed wastes generated in the 

12 storage of spent fuel include organics (e.g., waste 

13 oils and halogenated organics), metals (e.g., lead, 

14 mercury, chromium, and cadmium), solvents, 

15 paints, and cutting fluids.

16 The quantity of mixed waste generated by an 

17 operating nuclear power plant is generally relatively 

18 small (NRC 2013a). For example, the EIS for the 

19 Fermi Unit 3 combined license application stated 

that less than 0.5 m3/yr (0.65 yd3 20 /yr) of mixed waste 

21 would be generated during operation (NRC 2013c).

22 Because of the added complexity of dual 

23 regulation, the management and disposal of mixed 

24 waste is more problematic than for the other types 

25 of wastes. Similar to hazardous waste, mixed 

26 waste is generally accumulated onsite in 

27 designated areas as authorized under the 

28 Resource Conservation and Recovery Act (RCRA), and then shipped offsite for treatment as 

29 appropriate and for disposal. The only disposal facilities that are authorized to receive mixed 

30 LLW for disposal at present are the EnergySolutions and the Waste Control Specialists, LLC, 

31 facilities as discussed in Section 3.14.1. 

32 3.14.3 Hazardous Waste

33 Hazardous waste is defined by the EPA in 40 CFR Part 261, “Identification and Listing of 

34 Hazardous Waste,” as solid waste that (1) is listed by the EPA as being hazardous; (2) exhibits 

35 one of the characteristics of ignitability, corrosiveness, reactivity, or toxicity; or (3) is not 

36 excluded by the EPA from regulation as being hazardous. All aspects of hazardous waste 

Other Waste Types Associated with Spent 

Fuel Storage

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, 

as amended, 1976).

Nonradioactive Nonhazardous Waste: 

Waste that is neither radioactive nor 

hazardous.
Affected Environment

Draft NUREG‒2157 3-36 September 2013

1 generation, treatment, transportation, and disposal are strictly regulated by the EPA or by the 

2 States under agreement with the EPA per the regulations promulgated under RCRA. 

3 The types of hazardous waste typically generated by nuclear power plants during storage 

4 operations include waste paints, laboratory packs, and solvents. The quantities of these wastes 

5 generated by an operating nuclear power plant can vary between facilities, but the quantities

6 generally are relatively small when compared with the quantities at most other industrial facilities 

7 that generate hazardous waste (NRC 2013a). Nuclear power plants would likely accumulate 

8 their hazardous waste onsite as authorized under RCRA and transport it to a treatment facility. 

9 Residues remaining after treatment are sent to a permanent disposal facility. There are many 

10 RCRA-permitted treatment and disposal facilities available throughout the United States.

11 3.14.4 Nonradioactive, Nonhazardous Waste

12 Similar to other industrial activity, the continued storage of spent fuel will generate wastes that 

13 are not contaminated with either radionuclides or hazardous chemicals. These wastes include 

14 trash, paper, wood, construction and demolition materials, and sanitary wastes (sewage). Solid 

15 wastes, defined as nonhazardous by 40 CFR Part 261, are collected and disposed of in a local 

16 landfill. Sanitary wastes may be treated onsite and the residues are sent to local landfills, or 

17 discharged directly to a municipal sewage treatment facility. Sanitary waste may also be 

18 collected in onsite septic tanks, which are emptied periodically, and then the waste is shipped to 

19 a local sanitary waste treatment plant. The wastes and sewage are tested for radionuclides 

20 before being sent offsite to ensure that no inadvertent contamination occurs. Offsite releases 

21 from onsite sewage treatment plants are conducted under NPDES permits. As with operating 

22 nuclear power plants, stormwater runoff may be collected and tested before it is discharged 

23 offsite (NRC 2013a).

24 3.14.5 Pollution Prevention and Waste Minimization 

25 Waste minimization and pollution prevention are important elements of operations at all nuclear 

26 power plants and at-reactor ISFSIs. Licensees are required to consider pollution prevention 

27 measures as dictated by the Pollution Prevention Act of 1990 and RCRA. 

28 In addition, as noted in the License Renewal GEIS and in recent EISs for new reactors and 

29 license renewal applications, licensees are likely to have waste minimization programs in place 

30 that are aimed at minimizing the quantities of waste sent offsite for treatment or disposal. 

31 Waste minimization techniques employed by the licensees may include source reduction and 

32 recycling of materials either onsite or offsite. The establishment of a waste minimization 

33 program is also a requirement for managing hazardous wastes under RCRA.
Affected Environment

September 2013 3-37 Draft NUREG‒2157

1 3.15 Transportation 

2 The affected environment for transportation associated with continued storage includes the 

3 characteristics of the reactor site that support transportation activities, workers involved in 

4 transportation activities, and the local, regional, and national transportation networks and 

5 populations that use or live along these networks.

6 All nuclear power plants sites are serviced by controlled access roads. In addition to the access 

7 roads, many of the plants also have railroad connections for moving heavy equipment and other 

8 materials. Some of the plants that are located on navigable waters, such as rivers, Great 

9 Lakes, or oceans, have facilities to receive and ship loads on barges (NRC 2013a). Power plant 

10 sites provide a network of roads and sidewalks for vehicles and pedestrians as well as parking 

11 areas for workers and visitors (NRC 2013a). 

12 Local and regional transportation networks in the vicinity of nuclear power plant sites may vary 

13 considerably depending on the regional population density, location, and size of local 

14 communities, nature of economic development patterns, location of the region relative to 

15 interregional transportation corridors, and land surface features, such as mountains, rivers, and 

16 lakes. The impacts of employee commuting patterns on the transportation network in the 

17 vicinity of nuclear power plants depend on the extent to which these factors limit or facilitate 

18 traffic movements and on the size of the plant workforce that uses the network at any given 

19 time. Impacts at the local level in the immediate vicinity of power plant sites vary depending on 

20 the capacity of the local road network, local traffic patterns, and particularly the availability of 

21 alternate routes for power plant workers. Given the rural locations of most power plant sites, 

22 site traffic has a small impact on the local road system, since often there is not much other 

23 traffic on local roads in the immediate vicinity of the plant. Because most sites have only one 

24 access road, there may be congestion on this road at certain times, such as during shift 

25 changes (NRC 2013a). 

26 For transportation of radioactive material from a nuclear power plant site, the affected 

27 environment includes all rural, suburban, and urban populations living along the transportation 

28 routes within range of exposure to radiation emitted from the packaged material during normal 

29 transportation activities or that could be exposed in the unlikely event of a severe accident

30 involving release of radioactive material. The affected environment also includes those 

31 members of the public that could be exposed to radiation emitted from the packaged material 

32 during normal transportation activities including people in vehicles on the same transportation 

33 route, people living along transportation routes, and people at truck stops and workers that are 

34 involved with the transportation activities. 
Affected Environment

Draft NUREG‒2157 3-38 September 2013

1 3.16 Public and Occupational Health

2 This section describes the affected environment during continued storage with respect to the

3 radiological protection of the public and workers. Public radiation doses from natural and 

4 artificial sources other than spent fuel are also described. This section also describes the 

5 regulatory framework for protection from occupational hazards.

6 3.16.1 Radiological Exposure

7 Nuclear power plants, spent fuel pools, and 

8 at-reactor ISFSIs cause doses to members of the 

9 public and onsite workers. The Atomic Energy Act

10 of 1954 requires the NRC to promulgate, inspect, 

11 and enforce standards that provide an adequate 

12 level of protection for public health and safety and 

13 the environment. The NRC continuously evaluates 

14 the latest radiation protection recommendations from 

15 international and national scientific bodies to 

16 establish the requirements for nuclear power plant 

17 licensees. The NRC has established multiple layers 

18 of radiation protection limits to protect the public 

19 against potential health risks from exposure to 

20 effluent discharges from nuclear power plant 

21 operations. If the licensees exceed a certain fraction 

22 of these dose levels in a calendar quarter, they are 

23 required to notify the NRC, investigate the cause, 

24 and initiate corrective actions within the specified 

25 timeframe (10 CFR 20.2201 and 20.2203). 

26 Nuclear power reactors and their associated spent fuel pools and ISFSIs in the United States 

27 are licensed by the NRC and must comply with NRC regulations and conditions specified in the 

28 license in order to operate. The licensees are required to comply with 10 CFR Part 20,

29 Subpart C, “Occupational Dose Limits for Adults,” and 10 CFR Part 20, Subpart D, “Radiation 

30 Dose Limits for Individual Members of the Public.” Additionally, the EPA provides environmental 

31 radiation protection standards for the uranium fuel cycle in 40 CFR Part 190. 

32 3.16.1.1 Regulatory Requirements for Occupational Exposure

33 A plant licensee must maintain individual doses to workers within the 10 CFR 20.1201 

34 occupational dose limits that are summarized in Table 3-2 and incorporate provisions to 

35 maintain doses as low as is reasonably achievable. Under 10 CFR 20.2206, the NRC requires 

36 licensees to submit an annual report of the results of individual monitoring carried out by the 

Definitions

• 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

September 2013 3-39 Draft NUREG‒2157

1 licensee for each individual for whom monitoring was required by 10 CFR 20.1502 during that 

2 year. Annually, the NRC publishes a volume of the results of annual reporting of all licensees in 

3 the publically available NUREG–0713, Volume 32, “Occupational Radiation Exposure at 

4 Commercial Nuclear Power Reactors and Other Facilities 2010” (NRC 2012e).

5 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

More limiting of 5 rem/yr TEDE to whole body or 50 rem/yr sum of the 

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 15 rem/yr dose equivalent

Skin of the whole body, or 

skin of any extremity

50 rem/yr shallow dose equivalent

(a) See text box for definitions.

Note: To convert rem to sievert, multiply by 0.01.

6 Under 10 CFR 20.2202 and 20.2203, the NRC requires all licensees to submit reports of all 

7 occurrences involving personnel radiation exposures that exceed certain control levels. The 

8 control levels are used to investigate occurrences and to take corrective actions as necessary. 

9 Depending on the magnitude of the exposure, reporting is required immediately, within 

10 24 hours, or within 30 days.

11 3.16.1.2 Regulatory Requirements for Public Exposure

12 During continued storage in spent fuel pools, liquid, gaseous, and solid radioactive waste 

13 management systems would be used to collect and treat the radioactive materials produced as 

14 byproducts. These systems would process radioactive liquid, gaseous, and solid effluents to 

15 maintain releases within regulatory limits and to levels as low as is reasonably achievable 

16 before releasing them to the environment. Waste processing systems are designed to meet the 

17 design objectives of 10 CFR Part 50, Appendix I, “Numerical Guides for Design Objectives and 

18 Limiting Conditions for Operation to Meet the Criterion ‘As Low as is Reasonably Achievable’ for 

19 Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents”.

20 NRC regulations in 10 CFR 72.104 identify criteria for radioactive materials in effluents and 

21 direct radiation from an ISFSI. These criteria include that, for normal operations and anticipated 

22 occurrences, the annual dose equivalent to any real individual located beyond the controlled 

23 area must not exceed 25 mrem (0.25 mSv) to the whole body, 75 mrem (0.75 mSv) to the 

24 thyroid, and 25 mrem (0.25 mSv) to any other critical organ as a result of exposure to planned 

25 discharges of radioactive materials, direct radiation, and any other radiation from uranium fuel 
Affected Environment

Draft NUREG‒2157 3-40 September 2013

1 cycle operations within the region. This regulation also requires that operational restrictions be 

2 established to meet as low as is reasonably achievable objectives.

3 3.16.2 Radiological Exposure from Naturally Occurring and Artificial Sources

4 Table 3-3 identifies background doses to a typical member of the U.S. population. In the table, 

5 the annual values are rounded to the nearest 1 percent. A total average annual effective dose 

6 equivalent to members of the U.S. population (i.e., 620 mrem/yr) comes from two primary 

7 sources: (1) naturally occurring background radiation and (2) medical exposure to patients.

8 Table 3-3. Average Annual Effective Dose Equivalent of Ionizing Radiation to a Member of the 

9 U.S. Population for 2006

Source

Effective Dose Equivalent

mrem

Percent of 

Total

Ubiquitous background

Radon and thoron 228 37

Natural

Cosmic 33 5

Terrestrial 21 3

Internal 29 5

Total ubiquitous background 311 50

Medical

Computed tomography 147 24

Nuclear medicine 77 12

Interventional fluoroscopy 43 7

Conventional radiography and fluoroscopy 33 5

Total medical 300 48

Consumer products 13 2

Industrial, security, medical, educational and 

research

0.3 0.05

Occupational 0.5 0.08

Total 624.8 100

Source: Adapted from NCRP 2009

10 Natural radiation sources other than radon result in 13 percent of the typical radiation dose

11 received. The larger source of radiation dose in ubiquitous background (37 percent) is from 

12 radon, particularly because of homes and other buildings that trap radon and significantly 

13 enhance its dose contribution over open-air living. The remaining 50 percent of the average 
Affected Environment

September 2013 3-41 Draft NUREG‒2157

1 annual effective dose equivalent consists of radiation mostly from medical procedures 

2 (computed tomography, 24 percent; nuclear medicine, 12 percent; interventional fluoroscopy,

3 7 percent; and conventional radiography and fluoroscopy, 5 percent) and a small fraction from 

4 consumer products (2 percent). The consumer product exposure category includes exposure to 

5 members of the public from building materials, commercial air travel, cigarette smoking, mining 

6 and agricultural products, combustion of fossil fuels, highway and road construction materials, 

7 and glass and ceramic products. The industrial, security, medical, education, and research 

8 exposure category includes exposure to the members of the public from nuclear power 

9 generation; U.S. Department of Energy (DOE) installations; decommissioning and radioactive 

10 waste; industrial, medical, education, and research activities; contact with nuclear medicine 

11 patients; and security inspection systems. The occupational exposure category includes 

12 exposure to workers from medical, aviation, commercial nuclear power, industry and commerce, 

13 education and research, government, the DOE, and military installations. Radiation exposures 

14 from occupational activities, industrial, security, medical, educational and research contribute 

15 insignificantly to the total average effective dose equivalent.

16 3.16.3 Occupational Hazards

17 The Occupational Safety and Health Administration (OSHA) is responsible for developing and 

18 enforcing workplace safety regulations. OSHA was created by the Occupational Safety and 

19 Health Act of 1970, which was enacted to safeguard the health of workers. Facility conditions

20 that result in an occupational risk, but do not affect the safety of licensed radioactive materials, 

21 are under the statutory authority of OSHA rather than the NRC as set forth in a Memorandum of 

22 Understanding (53 FR 43950) between the NRC and OSHA. Regardless, occupational hazards 

23 can be minimized when workers adhere to safety standards and use appropriate protective 

24 equipment; however, fatalities and injuries from accidents can still occur.

25 3.17 References

26 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

27 Protection Against Radiation.” Washington, D.C.

28 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

29 Production and Utilization Facilities.” Washington, D.C.

30 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

31 Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

32 Washington, D.C.

33 10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, “Licensing 

34 Requirements for Land Disposal of Radioactive Waste.” Washington, D.C.
Affected Environment

Draft NUREG‒2157 3-42 September 2013

1 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

2 Transportation of Radioactive Material.” Washington, D.C.

3 10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, “Licensing Requirements for 

4 the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor5 Related Greater Than Class C Waste.” Washington, D.C.

6 29 CFR 1910. Code of Federal Regulations, Title 29, Labor, Part 1910, “Occupational Safety

7 and Health Standards.” Washington, D.C.

8 36 CFR Part 60. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

9 Part 60, National Register of Historic Places.” Washington, D.C.

10 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

11 Part 800, “Protection of Historic Properties.” Washington, D.C.

12 40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of the Environment, Part 50, 

13 “National Primary and Secondary Ambient Air Quality Standards.” Washington, D.C.

14 40 CFR 51. Code of Federal Regulations, Title 40, Protection of the Environment, Part 51, 

15 “Requirements for Preparation, Adoption, and Submittal of Implementation Plans.” 

16 Washington, D.C.

17 40 CFR 81. Code of Federal Regulations, Title 40, Protection of the Environment, Part 81, 

18 “Designation of Areas for Air Quality Planning Purposes.” Washington, D.C.

19 40 CFR 93. Code of Federal Regulations, Title 40, Protection of the Environment, Part 93, 

20 “Determining Conformity of Federal Actions to State or Federal Implementation Plans.” 

21 Washington, D.C.

22 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of the Environment, 

23 Part 190, “Environmental Radiation Protection Standards for Nuclear Power Operations.” 

24 Washington, D.C.

25 40 CFR Part 261. Code of Federal Regulations, Title 40, Protection of the Environment, 

26 Part 261, “Identification and Listing of Hazardous Waste.” Washington, D.C.

27 53 FR 43950. October 31, 1988. “Memorandum of Understanding (MOU); Nuclear Regulatory 

28 Commission.” Federal Register. U.S. Nuclear Regulatory Commission, Washington, D.C.

29 59 FR 7629. February 16, 1994. Federal Actions to Address Environmental Justice in Minority 

30 Populations and Low-Income Populations. Federal Register. U.S. Environmental Protection 

31 Agency, Washington, D.C.
Affected Environment

September 2013 3-43 Draft NUREG‒2157

1 63 FR 7254. February 12, 1998. “Indian Tribes: Air Quality Planning and Management.” 

2 Federal Register. U.S. Nuclear Regulatory Commission, Washington, D.C.

3 69 FR 52040. August 24, 2004. “Policy Statement on the Treatment of Environmental Justice

4 Matters in NRC Regulatory and Licensing Actions.” Federal Register. U.S. Nuclear Regulatory 

5 Commission, Washington, D.C.

6 74 FR 66496. December 15, 2009. “Endangerment and Cause or Contribute Findings for 

7 Greenhouse Gases under Section 202(a) of the Clean Air Act.” Federal Register. 

8 U.S. Environmental Protection Agency, Washington, D.C.

9 76 FR 35512. June 17, 2011. “Decommissioning Planning.” Federal Register. U.S. Nuclear 

10 Regulatory Commission, Washington, D.C. 

11 ACHP (Advisory Council on Historic Preservation). 2008. National Register Evaluation Criteria. 

12 Washington, D.C. Accession No. ML082880723.

13 Armantrout, N.B. 1998. Glossary of Aquatic Habitat Inventory Terminology. Western Division 

14 of American Fisheries Society, Bethesda, Maryland.

15 Atomic Energy Act of 1954, as amended. 42 USC 2011 et seq. 

16 Back, W., J.S. Rosenshein, and P.R. Seaber, eds. 1988. The Geology of North America: 

17 Volume O–2: Hydrogeology. The Geological Society of America, Boulder, Colorado. 

18 Bald and Golden Eagle Protection Act of 1940, as amended. 16 USC 668–668d, et seq.

19 Beeton, A.M. 2002. “Large Freshwater Lakes: Present State, Trends, and Future.” 

20 Environmental Conservation 29(1):21–38, New York, New York.

21 CEQ (Council on Environmental Quality). 1997. Environmental Justice: Guidance Under the 

22 National Environmental Policy Act. Executive Office of the President, Washington, D.C. 

23 Available at 

24 http://www.epa.gov/compliance/ej/resources/policy/ej_guidance_nepa_ceq1297.pdf. 

25 Clean Air Act. 42 USC 7401 et seq. 

26 Columbia County. 2013. “Summary of Assessment and Tax Roll 2012–13.” Columbia County, 

27 Mt. St. Helens, Oregon. Accession No. ML13099A042.

28 CYAPC (Connecticut Yankee Atomic Power Company). 2012. Haddam Neck Plant 

29 Independent Spent Fuel Storage Installation Decommissioning Funding Plan. East Hampton, 

30 Connecticut. Package Accession No. ML123630241.
Affected Environment

Draft NUREG‒2157 3-44 September 2013

1 Edsall, T. and M. Charlton. 1997. Nearshore Waters of the Great Lakes. U.S. Environmental 

2 Protection Agency and Environment Canada, Washington, D.C. and Downsview, Ontario. 

3 Available at http://www.on.ec.gc.ca/solec/nearshore-water/paper/part5.html. 

4 Endangered Species Act of 1973. 16 USC 1361, et seq. 

5 EnergySolutions. 2012. FY 2012/2013 Least Cost Operating Plan Barnwell Disposal Facility. 

6 BEDL–12–024. Barnwell, South Carolina. Available at

7 http://dms.psc.sc.gov/pdf/matters/0FC14AB1-155D-2817-10B95B39AB319DC1.pdf. 

8 EPA (U.S. Environmental Protection Agency). 1974. Information on Levels of Environmental 

9 Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. 

10 550/9–74–004, Washington, D.C.

11 EPRI and Maine Yankee. 2005. Maine Yankee Decommissioning Experience Report: Detailed 

12 Experiences 1997–2004. Palo Alto, California and Wiscasset, Maine. Accession 

13 No. ML12088A297.

14 FWS (U.S. Fish and Wildlife Service). 2007. National Wetlands Inventory. U.S. Department of 

15 the Interior, Washington, D.C. Available at http://www.fws.gov/wetlands/index.html. 

16 GAO (General Accounting Office). 2004. Low-Level Radioactive Waste—Disposal Availability 

17 Adequate in Short Term, but Oversight Needed To Identify Any Future Shortfalls. 

18 GAO–04–604, U.S. Nuclear Regulatory Commission, Washington, D.C. Available at 

19 http://www.gao.gov/assets/250/242883.pdf. 

20 GCRP (U.S. Global Change Research Program). 2009. Global Climate Change Impacts in the 

21 United States. T.R. Karl, J.M. Melillo, and T.C. Peterson, eds. Cambridge University Press, 

22 New York, New York. Available at http://downloads.globalchange.gov/usimpacts/pdfs/climate23 impacts-report.pdf. Accession No. ML100580077.

24 Hasseett-Snipple, B.M. 2011. National Ambient Air Quality Standards (NAAQS) for Particulate 

25 Matter (PM): Current Review – Focus on Primary PM2.5 Standards. EPA/WESTAR Residential 

26 Wood Smoke Workshop, Salt Lake City, Utah.

27 Low-Level Radioactive Waste Policy Act. 42 USC 2021, et seq. (1986).

28 Magnuson-Stevens Fishery Conservation and Management Act. 16 USC 1801, et seq.

29 Marine Mammal Protection Act. 16 USC 1361, et seq.

30 Metz, W. 1983. Population and Land Use Change in the Vicinity of Operating Nuclear Power 

31 Station—An Anthology. Brookhaven National Laboratory, Upton, New York.
Affected Environment

September 2013 3-45 Draft NUREG‒2157

1 Migratory Bird Treaty Act of 1918, as amended. 16 USC 703–712.

2 Morrow, J.V. and J.C. Fischenich. 2000. Habitat Requirements for Freshwater Fishes. ERDC 

3 TN–EMRRPSR–06. U.S. Army Engineer Research and Development Center, Vicksburg, 

4 Mississippi. Available at http://el.erdc.usace.army.mil/elpubs/pdf/sr06.pdf. Accessed 

5 November 12, 2007).

6 MYAPC (Maine Yankee Atomic Power Company). 2013. Maine Yankee Independent Spent

7 Fuel Storage Installation Revised Decommissioning Funding Plan. Wiscasset, Maine. Package 

8 Accession No. ML130460347. 

9 NCRP (National Council on Radiation Protection and Measurements). 2009. Ionizing Radiation 

10 Exposure of the Population of the United States. Report 160, Bethesda, Maryland.

11 National Environmental Policy Act of 1969 (NEPA). USC 4321–4347.

12 National Historic Preservation Act of 1966, as amended (NHPA). 16 USC 470, et seq. 

13 NEI (Nuclear Energy Institute). 2013. Low-Level Radioactive Waste. Washington, D.C. 

14 Accession No. ML13100A276.

15 Northcote, T.G. 1978. “Migratory strategies and production in freshwater fishes.” Ecology of 

16 Freshwater Fish Production: 326–359, New York, New York.

17 NRC (U.S. Nuclear Regulatory Commission). 1985. Environmental Assessment Related to the 

18 Construction and Operation of the Surry Dry Cask Independent Spent Fuel Storage Installation. 

19 Washington, D.C.

20 NRC (U.S. Nuclear Regulatory Commission). 1988. Environmental Assessment Related to the 

21 Construction and Operation of the Oconee Nuclear Station Independent Spent Fuel Storage 

22 Installation. Washington, D.C. Accession No. ML123480209.

23 NRC (U.S. Nuclear Regulatory Commission). 1989. Environmental Assessment and Finding of 

24 No Significant Impact for Proposed Rule Entitled, “Storage of Spent Nuclear Fuel in NRC25 Approved Storage Casks at Nuclear Power Reactor Sites.” Washington, D.C. Accession 

26 No. ML051230231.

27 NRC (U.S. Nuclear Regulatory Commission). 1991a. Environmental Assessment Related to 

28 Construction and Operation of the Fort St. Vrain Independent Spent Fuel Storage Installation. 

29 Docket No. 72–009, Public Service Company of Colorado. Washington, D.C. Accession 

30 No. ML062710252.
Affected Environment

Draft NUREG‒2157 3-46 September 2013

1 NRC (U.S. Nuclear Regulatory Commission). 1991b. Environmental Assessment Related to 

2 the Construction and Operation of the Calvert Cliffs Independent Spent Fuel Storage 

3 Installation. Washington, D.C. Accession No. ML022550053.

4 NRC (U.S. Nuclear Regulatory Commission). 1992. Environmental Assessment Related to 

5 Construction and Operation of the Prairie Island Independent Spent Fuel Storage Installation. 

6 Washington, D.C. Accession No. ML090260415.

7 NRC (U.S. Nuclear Regulatory Commission). 2002. Final Generic Environmental Impact 

8 Statement on Decommissioning of Nuclear Facilities: Regarding the Decommissioning of 

9 Nuclear Power Reactors. NUREG–0586, Supplement 1, Volume 1, Washington, D.C. 

10 Accession Nos. ML023470304 and ML023500228.

11 NRC (U.S. Nuclear Regulatory Commission). 2003. Environmental Assessment Related to the 

12 Construction and Operation of the Diablo Canyon Independent Spent Fuel Storage Installation. 

13 Washington, D.C. Accession No. ML032970370.

14 NRC (U.S. Nuclear Regulatory Commission). 2004. Environmental Assessment for the License 

15 Renewal of the General Electric Morris Operation Independent Spent Fuel Storage Installation 

16 in Morris, Illinois. Washington, D.C. Accession No. ML043360415.

17 NRC (U.S. Nuclear Regulatory Commission). 2005a. Environmental Assessment Related to 

18 the Renewal of the H.B. Robinson Steam Electric Plant, Unit No. 2 Independent Spent Fuel 

19 Storage Installation License Special Nuclear Materials License No. SNM–2502. 

20 Washington, D.C. Accession No. ML050700137.

21 NRC (U.S. Nuclear Regulatory Commission). 2005b. Environmental Assessment Related to 

22 the Renewal of the License for the Surry Independent Spent Fuel Storage Installation. 

23 Washington, D.C. Accession No. ML040560238.

24 NRC (U.S. Nuclear Regulatory Commission). 2005c. Environmental Assessment Related to 

25 the Construction and Operation of the Humboldt Bay Independent Spent Fuel Storage 

26 Installation. Washington, D.C. Accession No. ML052430106.

27 NRC (U.S. Nuclear Regulatory Commission). 2008. North Anna Independent Spent Fuel 

28 Storage Installation, Final Safety Analysis Report. Revision 6, Washington, D.C. Accession 

29 No. ML110180557.

30 NRC (U.S. Nuclear Regulatory Commission). 2009a. Environmental Assessment for the 

31 Renewal of U.S. Nuclear Regulatory Commission License No. SNM–2503 for Oconee Nuclear 

32 Power Station Independent Spent Fuel Storage Installation. Washington, D.C. Accession 

33 No. ML091340557.
Affected Environment

September 2013 3-47 Draft NUREG‒2157

1 NRC. (U.S. Nuclear Regulatory Commission). 2009b. Memorandum and Order [Duke Energy 

2 Carolinas, LLC and Tennessee Valley Authority – Greenhouse Gas Emissions]. CLI–09–21, 

3 Washington, D.C. Accession No. ML093070690.

4 NRC (U.S. Nuclear Regulatory Commission). 2010. Memorandum from S.C. Flanders to 

5 B. Clayton dated December 10, 2010, regarding “Addressing Construction and Preconstruction 

6 Activities, Greenhouse Gas Issues, General Conformity Determinations, Environmental Justice, 

7 Need for Power, Cumulative Impact Analysis, and Cultural/Historical Resources Analysis Issues 

8 in Environmental Impact Statements.” Washington, D.C. Accession No. ML100760503.

9 NRC (U.S. Nuclear Regulatory Commission). 2011a. Memorandum from B. Clayton to 

10 S.C. Flanders dated March 4, 2011, regarding “Revision 1—Addressing the Construction and 

11 Preconstruction Activities, Greenhouse Gas Issues, General Conformity Determinations, 

12 Environmental Justice, the Need for Power, Cumulative Impact Analysis, and Cultural/Historical 

13 Resources Analysis Issues In Environmental Impact Statements.” Washington, D.C. Accession 

14 No. ML110380369.

15 NRC (U.S. Nuclear Regulatory Commission). 2011b. Policy Issue (Information) from 

16 R.W. Borchardt to The Commissioners dated February 9, 2011, regarding “Senior Management 

17 Review of Overall Regulatory Approach to Groundwater Protection.” SECY–11–0019, 

18 Washington, D.C. Accession No. ML110050525.

19 NRC (U.S. Nuclear Regulatory Commission). 2012a. Information Digest, 2012–2013. 

20 NUREG–1350, Volume 24, Washington, D.C. Accession No. ML12241A166.

21 NRC (U.S. Nuclear Regulatory Commission). 2012b. Environmental Assessment for the 

22 Proposed Renewal of U.S. Nuclear Regulatory Commission License No. SNM–2505 for Calvert 

23 Cliffs Nuclear Power Plant, LLC’s Independent Spent Fuel Storage Installation. 

24 Washington, D.C. Accession No. ML121220084.

25 NRC (U.S. Nuclear Regulatory Commission). 2012c. List of Historical Leaks and Spills at 

26 U.S. Commercial Nuclear Power Plants. Revision 10, Washington, D.C. Accession 

27 No. ML101270439.

28 NRC (U.S. Nuclear Regulatory Commission). 2012d. Predecisional Draft - Proposed Draft 

29 Guidance Decommissioning Planning During Operations. Washington, D.C. Accession 

30 No. ML12179A246.

31 NRC (U.S. Nuclear Regulatory Commission). 2012e. Occupational Radiation Exposure at 

32 Commercial Nuclear Power Reactors and Other Facilities 2010. NUREG–0713, Volume 32, 

33 Washington, D.C. Accession No. ML120950282.
Affected Environment

Draft NUREG‒2157 3-48 September 2013

1 NRC (U.S. Nuclear Regulatory Commission). 2013a. Generic Environmental Impact Statement 

2 for License Renewal of Nuclear Plants. NUREG–1437, Revision 1, Washington, D.C. Package 

3 Accession No. ML13107A023. 

4 NRC (U.S. Nuclear Regulatory Commission). 2013b. U.S. Independent Spent Fuel Storage 

5 Installations [map]. Washington, D.C. Accession No. ML13057A527.

6 NRC (U.S. Nuclear Regulatory Commission). 2013c. Final Environmental Impact Statement for 

7 Combined Licenses (COL) for Enrico Fermi Unit 3. NUREG–2105, Volumes 1 and 2. 

8 Washington, D.C. Accession Nos. ML12307A172 (Vol 1) and ML12307A176 (Vol 2).

9 NRC (U.S. Nuclear Regulatory Commission). 2013d. Staff Guidance to Support ISG–026 

10 Attachment 1 Regarding Greenhouse Gas and Climate Change Impacts for New Reactor 

11 Environmental Impact Statements. Washington, D.C. Accession No. ML12356A500. 

12 Occupational Safety and Health Act. 29 USC 651, et seq. 

13 PG&E (Pacific Gas and Electric Company). 2012. “PG&E Making $157 Million in Property Tax

14 Payments to 49 California Counties.” News and Perspectives from Pacific Gas and Electric 

15 Company, San Francisco, California. Accession No. ML13099A045.

16 Pollution Prevention Act of 1990. 42 USC 13101, et seq. (1990).

17 Resource Conservation and Recovery Act of 1976. 42 USC 6901 et seq. (1976).

18 Safe Drinking Water Act. 42 USC 300. (1974). 

19 Todd, D.K. 1960. Groundwater Hydrology. Second Edition, New York, New York.

20 USCB (U.S. Census Bureau). 2007. Current Population Reports. Series P60, 

21 Washington, D.C. Available at http://www.census.gov/main/www/cprs.html. 

22 Williams, J.D., M.L. Warren, K.S. Cummings, J.L. Harris, and R.J. Neves. 1993. “Conservation

23 Status of Freshwater Mussels of the United States and Canada.” Fisheries 18:6–22, 

24 Philadelphia, Pennsylvania.

25 Witman, J.D. 1987. “Subtidal Coexistence: Storms, Grazing, Mutualism, and the Zonation of 

26 Kelps and Mussels.” Ecological Monographs 55:421–445, Ithaca, New York.
September 2013 4-1 Draft NUREG‒2157

1 4.0 Environmental Impacts of At-Reactor Continued 

2 Storage of Spent Fuel

3 This chapter evaluates the environmental impacts of continued at-reactor storage of spent 

4 nuclear fuel (spent fuel) in a spent fuel pool or independent spent fuel storage installation 

5 (ISFSI). The U.S. Nuclear Regulatory Commission (NRC) evaluated the environmental impacts 

6 of at-reactor continued storage for three timeframes: short-term storage, long-term storage, and 

7 indefinite storage. Chapter 2 provides descriptions of the various activities that occur during 

8 continued storage. The environmental impacts of away-from-reactor ISFSI storage are 

9 evaluated in Chapter 5.

10 In the short-term storage timeframe, the NRC evaluates the impacts of continued storage of 

11 spent fuel for 60 years beyond the licensed life for operations of a reference reactor. The NRC 

12 assumes that all spent fuel has been transferred from the spent fuel pool to an ISFSI by the end 

13 of this 60-year timeframe. The NRC also assumes that a repository becomes available by the 

14 end of this 60-year timeframe. 

15 Short-term storage of spent fuel for 60 years beyond licensed life for operations includes the 

16 following: 

17 • continued storage of spent fuel in spent fuel pools (at-reactor only) and ISFSIs

18 • routine maintenance of spent fuel pools and ISFSIs (e.g., maintenance of concrete pads)

19 • handling and transfer of spent fuel from spent fuel pools to ISFSIs 

20 The NRC then evaluates the impacts of continued storage for another 100 years after short21 term storage. This 100-year timeframe is referred to as the long-term storage timeframe. In this 

22 timeframe, the draft Waste Confidence Generic Environmental Impact Statement (draft GEIS)

23 assumes that a repository would become available by the end of the 100-year timeframe 

24 (160 years total continued storage after the end of the reactor’s licensed life for operation).

25 Long-term storage activities include the following: 

26 • continued storage of spent fuel in ISFSIs, including routine maintenance

27 • one-time replacement of ISFSIs and spent fuel canisters and casks

28 • construction and operation of a dry transfer system (DTS) (including replacement)

29 The NRC also evaluates the environmental impacts of a third timeframe that assumes a 

30 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

Draft NUREG‒2157 4-2 September 2013

1 end of the short-term storage timeframe and storage in ISFSIs indefinitely. The activities during 

2 the indefinite storage timeframe are the same as those that would occur for long-term storage; 

3 however, without a repository these activities occur repeatedly. Figure 1-1 provides a graphical 

4 representation of the three timeframes.

5 Section 1.8.3 provides a list of the assumptions made in this draft GEIS regarding continued 

6 storage. Impacts from decommissioning the spent fuel pool, ISFSI, and DTS are not evaluated 

7 in this chapter but are considered in the cumulative impacts analysis in Chapter 6, as is spent 

8 fuel transportation to a repository. Construction of a new spent fuel pool cooling system, to 

9 support decommissioning, is also addressed in the cumulative impacts analysis. The 

10 environmental impacts of operating a new cooling system during continued storage are bound 

11 by the impacts of an operating reactor and are therefore not discussed further in this chapter. 

12 The NRC assumes that the initial at-reactor ISFSIs would be constructed under a general or 

13 site-specific license during the term of reactor operations (including license renewal); therefore, 

14 the construction impacts of these initial at-reactor ISFSIs are not specifically analyzed in this 

15 draft GEIS, but are taken into account in establishing the baseline affected environment 

16 described in Chapter 3. These ISFSIs would, however, be subject to periodic relicensing 

17 reviews and accompanying environmental reviews under the National Environmental Policy 

18 Act of 1969 (NEPA). Further, the NRC assumes that the ISFSIs are completely replaced every 

19 100 years. This replacement activity would require separate site-specific authorization from the 

20 NRC before the start of any replacement activities. NRC authorization to relicense or replace 

21 an ISFSI and NRC authorization to construct, operate, and replace a DTS are separate 

22 licensing actions that would require an NRC review. They are considered Federal actions under 

23 NEPA and would be undertakings under the National Historic Preservation Act (NHPA).

24 As discussed in Chapter 2, there are two existing away-from-reactor ISFSIs—the GEH Morris 

25 and Three Mile Island Unit 2 (TMI-2) ISFSIs. However, as explained below, the environmental 

26 impacts described in this chapter for at-reactor ISFSIs are representative of the impacts at both 

27 of these away-from-reactor ISFSIs.

28 • The GEH Morris ISFSI is at the site of a spent fuel reprocessing facility (a production facility) 

29 that was constructed by General Electric, but never operated. Because it was to be a 

30 production facility licensed under siting and safety requirements similar to those for reactors 

31 (e.g., Title 10 of the Code of Federal Regulations Part 50 [10 CFR Part 50], “Domestic 

32 Licensing of Production and Utilization Facilities”), the GEH Morris facility is sited and 

33 constructed in a manner substantially similar to a reactor spent fuel pool. In fact, it is 

34 currently licensed to store 352 pressurized water reactor (PWR) fuel assemblies and 

35 2,865 boiling water reactor (BWR) fuel assemblies, for a total of about 714 MTU, which is no 

36 more than the licensed capacity of many BWR spent fuel pools. Therefore, the 

37 environmental impacts described in the following chapters of this draft GEIS for at-reactor 

38 spent fuel pools are representative of the impacts at the GEH Morris facility.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-3 Draft NUREG‒2157

1 • The TMI‒2 ISFSI is a modified NUHOMS spent fuel storage system (designated 

2 NUHOMS-12T) with 30 horizontal storage modules (DOE 2012). It was licensed by the 

3 NRC in March 1999 and contains spent fuel from the damaged TMI-2 reactor (a single 

4 reactor core). Although the NUHOMS‒12T storage module contents are core debris (not 

5 fuel assemblies) and the debris storage canisters could not be treated like fuel cladding, the 

6 design of the NUHOMS‒12T accounts for these technical differences. Each NUHOMS‒12T 

7 module provides for the horizontal dry storage of up to 12 TMI‒2 stainless-steel canisters 

8 inside a dry shielded canister, which is placed inside a concrete horizontal storage module. 

9 The NUHOMS‒12T modification includes venting of the dry shielded canister through high10 efficiency particulate air grade filters during storage. The vent system allows for release of 

11 hydrogen gas, generated due to radiolysis, and monitoring and/or purging of the system 

12 during operation (DOE 2012). The TMI‒2 ISFSI is actually no larger than a typical at-reactor 

13 ISFSI and meets the same NRC regulatory standards as at-reactor ISFSIs. Therefore, the 

14 environmental impacts described in this chapter for at-reactor ISFSIs are representative of 

15 the impacts at the TMI‒2 ISFSI.

16 In this chapter, the NRC uses the License Renewal GEIS (NRC 2013) to inform some of the 

17 impact determinations regarding continued storage. In many of these cases, the analysis in this 

18 draft GEIS considers how the environmental impacts of continued storage compare to the 

19 impacts considered in the License Renewal GEIS. In the License Renewal GEIS, the NRC 

20 evaluated the potential impacts in each resource area by reviewing previous environmental 

21 analyses for past license renewal reviews, scientific literature, and other available information. 

22 Where appropriate, this draft GEIS also considers analyses and impact determinations made in 

23 previous ISFSI licensing and renewal environmental assessments (EA) and environmental 

24 impact statements (EISs) and in reactor license renewal and new reactor licensing EISs to 

25 inform the impact determinations in this analysis.

26 Sections 4.1 through 4.17 evaluate the potential impacts on various resource areas, such as 

27 land use, air quality, water quality, transportation, and public health. Sections 4.18 and 4.19 

28 discuss accidents and terrorism. Section 4.20 provides a summary of the environmental 

29 impacts and Section 4.21 contains the references. Within each resource area, the NRC has 

30 provided an analysis of the potential impacts for the short-term storage timeframe, the long-term 

31 storage timeframe, and indefinite storage and provided an impact determination—SMALL, 

32 MODERATE, or LARGE—for each timeframe. The definitions of SMALL, MODERATE, and 

33 LARGE are provided in Section 1.8.5. For some resource areas, the impact determination 

34 language is specific to the authorizing regulation (e.g., “not likely to adversely impact” for 

35 endangered species).
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-4 September 2013

1 4.1 Land Use

2 This section describes land-use impacts caused by the continued storage of spent fuel in spent 

3 fuel pools and at-reactor ISFSIs.

4 4.1.1 Short-Term Storage

5 Spent fuel pool operations during the short-term storage timeframe would not require the use of 

6 any land beyond that which was cleared and graded during nuclear power plant construction. 

7 Continued operation of the spent fuel pool during short-term storage is not anticipated to require 

8 new or additional monitoring or maintenance activities that would affect current land use. In 

9 addition, inspection, testing, and surveillance activities that are conducted throughout the life of 

10 spent fuel pools necessary to ensure compliance with Federal, State, and local requirements 

11 regarding the environment and public safety are not expected to affect land-use conditions 

12 (NRC 2013a).

13 As described in Section 3.1, most nuclear power plant sites have constructed at-reactor ISFSIs 

14 for onsite dry cask storage of spent fuel. Dry cask storage at operating nuclear power plant 

15 sites provides supplemental storage for portions of the spent fuel pool inventory. As further 

16 described in Section 3.1, only a small fraction of the land committed for a nuclear power plant is 

17 required to construct and operate an at-reactor ISFSI (see Table 3-1).

18 Operation of an ISFSI involves removing the spent fuel from spent fuel pools, packaging the 

19 spent fuel in dry casks, and placing the dry casks on concrete storage pads. ISFSI operations

20 would not require the use of any land beyond that which was cleared and graded during facility 

21 construction. The ISFSI would be surrounded by security fencing to restrict and control access 

22 in accordance with requirements for the protection of stored spent fuel in 10 CFR 73.51. Only a 

23 small portion of the land committed for a nuclear power plant is required for an at-reactor ISFSI 

24 (see Table 3-1). Therefore, access restrictions associated with operation of an ISFSI during the 

25 short-term storage timeframe would affect only a small amount of land within the larger nuclear 

26 plant site.

27 ISFSIs are designed as passive systems that require no power or regular maintenance other 

28 than routine visual inspections and checks of the cask ventilation system (e.g., for blockages of 

29 ducts). Continued operation of an at-reactor ISFSI is not anticipated to require new or additional 

30 maintenance activities that would affect current land use. The NRC has prepared several EAs 

31 for site-specific licenses for construction and operation of at-reactor ISFSIs (NRC 2012a, 2005a, 

32 2003, and 1992). 

33 Based on the assessment above, 60 years of continued at-reactor storage in a spent fuel pool 

34 or at-reactor ISFSI would not require disturbance of any new land at a nuclear power plant or 

35 result in operational or maintenance activities that would change the current land use. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-5 Draft NUREG‒2157

1 Therefore, the NRC concludes that the potential environmental impact on land use would be 

2 SMALL during the short-term storage timeframe.

3 4.1.2 Long-Term Storage

4 The potential environmental impacts on land use from long-term storage in an ISFSI would be 

5 similar to those described for short-term storage. Only a small fraction of the land committed for 

6 a nuclear power plant is required for an ISFSI (see Table 3-1). Operation and maintenance of 

7 an ISFSI would not require the use of any land beyond that which was already cleared and 

8 graded during facility construction. Access restrictions associated with operation of an ISFSI 

9 during the long-term storage timeframe would affect only a small amount of land within the 

10 larger nuclear plant site.

11 During long-term storage, in addition to routine maintenance and monitoring, the NRC assumes 

12 that a DTS is constructed and operated to facilitate the transfer, handling, and repackaging of 

13 spent fuel after the end of the short-term timeframe. As described in Section 2.1.4, the 

14 reference DTS considered in this draft GEIS consists of two major structures: (1) a two-level 

15 concrete and steel structure that provides confinement and shielding during fuel transfer, 

16 handling, and repackaging operations and (2) an attached, single-level steel building for receipt 

17 and handling of the spent fuel shipping casks. These two major structures would be 

18 constructed on a reinforced-concrete basemat that would occupy about 0.04 ha (0.1 ac). 

19 Maintenance and monitoring activities associated with a DTS would include routine inspections 

20 and testing of the spent fuel and cask transfer and handling equipment (e.g., lift platforms and 

21 associated mechanical equipment) and process and effluent radiation monitoring, which do not 

22 require the use of any land beyond that which would be cleared and graded during DTS 

23 construction. 

24 As described in Section 3.1, the physical area required for operating a commercial nuclear 

25 power plant site ranges from 34 ha (84 ac) to 5,700 ha (14,000 ac) (NRC 2013a). Therefore, 

26 only a small fraction of the land committed for a nuclear power plant would be required to 

27 construct and operate a DTS. Once the DTS is constructed, access to the facility site would be 

28 restricted, in accordance with 10 CFR Part 73, to activities that support facility operations. The 

29 restricted access area for the reference DTS described in Section 2.1.4 is about 0.7 ha (2 ac).

30 The NRC assumes that the at-reactor ISFSI and DTS would be replaced during the long-term 

31 storage timeframe. The number of storage casks that would be replaced and the size of the 

32 replacement concrete storage pad would depend on the remaining inventory of spent fuel to be 

33 transported to a permanent repository after the 100-year timeframe. The replacement facilities 

34 for the at-reactor ISFSI and DTS would likely be constructed on land near the existing facilities.

35 Long-term storage of spent fuel at an at-reactor ISFSI would not result in operational or 

36 maintenance activities that would change land-use conditions. Construction and operation of a 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-6 September 2013

1 DTS and replacement of the ISFSI and DTS would affect a small fraction of the land already 

2 committed for a nuclear power plant. Therefore, the NRC concludes that the environmental 

3 impacts on land use during the long-term storage timeframe would be SMALL.

4 4.1.3 Indefinite Storage

5 This section describes the potential environmental impacts on land use if a repository is not 

6 available to accept spent fuel. For this analysis, the NRC assumes that spent fuel would 

7 continue to be stored in at-reactor ISFSIs indefinitely. The potential environmental impacts on 

8 land use from indefinite storage would be similar to those described for long-term storage.

9 Aging management is assumed to include replacement of the ISFSI and DTS every 100 years 

10 and necessitate repackaging of spent fuel at a DTS. Replacement of the ISFSI and DTS would

11 occur on land near existing facilities. The older ISFSI and DTS would be demolished, and the 

12 land reclaimed by the licensee. 

13 Access to the ISFSI and DTS would be restricted to activities that support facilities operations in 

14 accordance with 10 CFR Part 73. Restricted access under the indefinite storage timeframe 

15 would result in land that would not be available for other productive land uses for an indefinite 

16 amount of time. However, as noted previously, only a small portion of the land already 

17 committed for a nuclear power plant is required for an at-reactor ISFSI and DTS. Therefore, the 

18 amount of land that would not be available for other land uses under the indefinite storage 

19 timeframe would be small.

20 Indefinite storage of spent fuel in at-reactor ISFSI facilities would not result in operational or 

21 maintenance activities that would change land-use conditions. Construction of a DTS and 

22 replacement of the ISFSI and DTS every 100 years would affect a small fraction of the nuclear 

23 plant site. After replacement, the older ISFSI and DTS would be demolished and the land would 

24 be reclaimed. Therefore, the NRC concludes that the environmental impacts on land use from 

25 indefinite storage would be SMALL.

26 4.2 Socioeconomics 

27 This section describes the socioeconomic factors that could be directly or indirectly affected by 

28 continued storage of spent fuel in spent fuel pools and at-reactor ISFSIs. Changes in 

29 employment and tax payments caused by continued storage can have a direct and indirect 

30 effect on public services and housing demand, as well as traffic volumes in the communities in 

31 the region around each nuclear power plant site. As discussed in Chapter 3, the socioeconomic 

32 region of influence is where spent fuel storage workers and their families reside, spend their 

33 income, and use their benefits, thus directly and indirectly affecting the economic conditions of 

34 the region.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-7 Draft NUREG‒2157

1 4.2.1 Short-Term Storage

2 During the short-term storage timeframe, some systems used during reactor operations would 

3 remain in operation to ensure spent fuel pool cooling prior to the transfer of spent fuel from the 

4 pools to an at-reactor ISFSI. A small number of workers—likely between 20 and 85—would 

5 continue to maintain, monitor, and transfer spent fuel from spent fuel pools to at-reactor ISFSIs 

6 after the cessation of reactor operations. A small number of workers (30–35) would also 

7 continue to maintain and monitor the at-reactor ISFSI. Because the existing storage workforce 

8 would continue 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 9 

10 Therefore, during the short-term timeframe, there would be no increase in population or demand 

11 for housing and public services because of continued storage. Activities associated with short12 term storage are also not likely to affect local transportation conditions in the vicinity of the 

13 continued storage site. Transportation activities would continue into the period of continued 

14 storage at a reduced magnitude consistent with diminishing onsite activities and operations.

15 The amount of tax payments during the short-term storage timeframe would depend on a 

16 number of factors, including State tax law and established tax payment agreements with local 

17 tax authorities. Property tax and other payments, including the portion for at-reactor spent fuel 

18 storage, would continue, although the amount of tax payments would likely be reduced after 

19 reactor operations cease. Nevertheless, the amount of tax payments related to continued 

20 storage is not expected to change during the short-term timeframe.

21 The socioeconomic effects of reactor operations have become well established as regional 

22 socioeconomic conditions have adjusted to the presence of the nuclear power plant. During the 

23 period of reactor operations local communities have adjusted to fluctuations in workforce 

24 caused by regularly scheduled refueling and maintenance outages (NRC 2013a). By 

25 comparison, the contributory effect on socioeconomic conditions from continued short-term 

26 spent fuel storage would be SMALL, because of (1) the small number of workers required to 

27 maintain and monitor spent fuel storage in pools or an at-reactor ISFSI,(2) the continuation of 

28 tax payments, and (3) no increased demand for housing and public services. To the extent that 

29 State and local taxes paid by the licensee might drop during the short-term storage timeframe, 

30 the reduction would be attributable to the cessation of reactor operations and the reduced value 

31 of the facility rather than to continued storage. Therefore, the socioeconomic impacts of 

32 continued onsite storage during the short-term timeframe would be SMALL.

 

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

Draft NUREG‒2157 4-8 September 2013

1 4.2.2 Long-Term Storage

2 As discussed in Section 2.1.4, in contrast to short-term storage, long-term storage of spent fuel 

3 would require the construction and operation of a DTS and replacement of the DTS and ISFSI. 

4 The construction of a DTS and replacement at-reactor ISFSI would require a much smaller 

5 workforce than required for nuclear power plant construction or extended maintenance and 

6 refueling outages. As discussed in Section 3.2 of this draft GEIS, the construction workforce for 

7 an at-reactor ISFSI ranged from approximately 20 to 60 workers over approximately 1 year. 

8 The DTS is a two-level concrete and steel structure with an attached single-level, weather9 resistant, pre-engineered steel building on 0.04 ha (0.1 ac). With regard to the workforce 

10 required for the construction of the DTS, the NRC reviewed a proposal to construct and operate 

11 a 3.2-ha (8-ac) spent fuel transfer facility at the Idaho National Laboratory (NRC 2004b). The 

12 proposal estimated 250 construction workers would be employed for 2 years. Given that the 

13 INL facility is an estimated 80 times larger than the Transnuclear Inc.-Electric Power Research 

14 Institute (TN-EPRI) DTS design, the NRC estimates that no more than 60 to 80 short-term 

15 construction workers would be needed for between 1 to 2 years to build the DTS and at-reactor 

16 ISFSI pad. The construction workforce would likely comprise local workers. Given the 

17 availability of housing in the vicinity of all existing nuclear power plant sites and relatively few 

18 construction workers required for the project, the NRC concludes that nonlocal workers would 

19 be able to rely on temporary housing and not increase the demand for permanent housing.

20 Similar to short-term storage, a small number of workers (30–35) would continue to maintain 

21 and monitor the storage of spent fuel in the at-reactor ISFSI. The ISFSI workforce requirements 

22 would remain unchanged from the period of nuclear reactor operations. Because there would 

23 be no need for any additional at-reactor ISFSI operations workers during the long-term 

24 timeframe, there would be no increase in population or demand for housing or public services. 

25 In addition, activities associated with long-term storage are also not likely to affect local 

26 transportation conditions in the vicinity of the continued storage site.

27 Similar to the short-term timeframe, the amount of overall tax payments during long-term 

28 storage would depend on a number of factors, including State tax law and established tax 

29 payment agreements with local tax authorities. Property tax and other payments, including the 

30 portion for continued at-reactor storage, would continue during the long-term storage timeframe. 

31 Similar to short-term storage, the amount of tax payments would be reduced after reactor 

32 operations cease. The replacement of the at-reactor ISFSI and construction, operation, and 

33 subsequent replacement of the DTS could be viewed as property improvements by local tax 

34 assessors causing the property tax payment to be increased. Overall, construction activities are 

35 expected to have a minor effect on the local economy. Nevertheless, the amount of tax 

36 payments related to continued storage is not expected to change during the long-term 

37 timeframe. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-9 Draft NUREG‒2157

1 As previously noted for short-term storage, regional socioeconomic conditions have become 

2 well established during the period of reactor operations for all nuclear power plants (NRC 2013). 

3 By comparison, the contributory effect from long-term storage would be SMALL for all 

4 socioeconomic categories because (1) relatively few workers will be required to maintain and 

5 monitor spent fuel storage, construct and operate a DTS, and replace the at-reactor ISFSI and 

6 DTS; (2) construction activities will be of short duration; (3) continued tax payments will remain 

7 relatively constant at post-reactor operations level; and (4) there will be no increased demand 

8 for housing and public services. Therefore, the NRC concludes that the socioeconomic impacts 

9 of continued storage during the long-term timeframe would be SMALL.

10 4.2.3 Indefinite Storage

11 This section describes the socioeconomic impacts if a repository is not available to accept spent 

12 fuel from an existing nuclear power plant site. With no repository available, the aging 

13 management program would continuously monitor and maintain an at-reactor ISFSI. Impacts 

14 from indefinite storage would be similar to those described for the long-term storage timeframe. 

15 The NRC assumes the ISFSI pads and DTS would be replaced every 100 years and that this 

16 would require a small continuous workforce. Property tax revenue would remain relatively 

17 constant while spent fuel remains stored onsite. Therefore, the socioeconomic impacts from 

18 indefinite onsite storage of spent fuel in at-reactor ISFSIs would be SMALL.

19 4.3 Environmental Justice

20 This section describes the impacts on minority and low-income populations living in the vicinity 

21 of nuclear power plant sites resulting from the continued onsite storage of spent fuel in spent 

22 fuel pools and at-reactor ISFSIs.

23 The NRC strives to identify and consider environmental justice issues in agency licensing and 

24 regulatory actions primarily by fulfilling its NEPA responsibilities for such actions. Under 

25 Executive Order 12898 (59 FR 7629), Federal agencies are responsible for identifying and 

26 addressing potential disproportionately high and adverse human health and environmental 

27 impacts on minority and low-income populations. Environmental justice refers to a Federal 

28 policy that ensures that minority, low-income, and tribal communities that have historically been 

29 excluded from environmental decision-making are given equal opportunities to participate in 

30 decision-making processes.

31 In 2004, the Commission issued a Policy Statement on the Treatment of Environmental 

32 Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040), which states, “The 

33 Commission is committed to the general goals set forth in Executive Order 12898, and strives 

34 to meet those goals as part of its National Environmental Policy Act (NEPA) review process.” 

35 In addition, the Commission stated in its decision on the Private Fuel Storage (PFS) facility 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-10 September 2013

1 application that environmental justice, as applied at the NRC, “means that the agency will make 

2 an effort under NEPA to become aware of the demographic and economic circumstances of 

3 local communities where nuclear facilities are to be sited, and take care to mitigate or avoid 

4 special impacts attributable to the special character of the community” (NRC 2002a, 2004b).

5 Potential impacts on minority and low-income populations as the nuclear power plant transitions 

6 from reactor operations to decommissioning and continued storage would mostly consist of 

7 radiological (human health) and socioeconomic (environmental) effects. During continued 

8 storage, the incremental radiation dose from spent fuel stored in spent fuel pools and at-reactor 

9 ISFSIs is expected to remain unchanged from the period of reactor operations and within 

10 regulatory limits (see Section 4.17). Radiological and environmental monitoring programs,

11 similar to those implemented during nuclear power plant operations, would ensure that the 

12 radiation dose from continued spent fuel storage would remain within regulatory limits. In 

13 addition, socioeconomic conditions affected by the continued storage of spent fuel as they relate 

14 to minority and low-income populations living near nuclear power plant sites would remain 

15 unchanged.

16 As discussed in Section 3.3, the special pathway receptors analysis is an important part of the 

17 environmental justice analysis because consumption patterns may reflect the traditional or 

18 cultural practices of minority and low-income populations in the area of the continued storage 

19 site, such as migrant workers or Native Americans. All NRC licensees have to assess the 

20 impact of facility operations on the environment through their radiological environmental 

21 monitoring programs (REMPs). These programs assess the effects of site operations on the 

22 environment that could affect special pathway receptors. However, once reactor operations 

23 cease, the REMP would be modified to consider only the potential sources of radiation and 

24 radioactivity that may be released from a spent fuel pool or at-reactor ISFSIs. Air monitoring, 

25 thermoluminescent dosimeters, and groundwater monitoring would likely be used to detect 

26 releases from the spent fuel pools and at-reactor ISFSI, but collection of other environmental 

27 sampling data would depend on site-specific conditions (e.g., proximity to surface waterbody).

28 In most cases, NRC environmental justice analyses are limited to evaluating the human health

29 effects of the proposed licensing action and the potential for minority and low-income 

30 populations to be affected. Environmental justice-related issues as well as demographic 

31 conditions (i.e., the presence of potentially affected minority and low-income populations) differ 

32 from site to site, and environmental justice issues and concerns usually cannot be resolved 

33 generically with regard to NRC licensing actions. In its site-specific reviews, the NRC 

34 addresses environmental justice issues and concerns during each environmental review for 

35 licensing actions by identifying potentially affected minority and low-income populations. The 

36 NRC identifies minority and low-income populations by examining any potential human health 

37 or environmental effects on these populations to determine if these effects may be 

38 disproportionately high and adverse. Resource areas that might create human health and other 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-11 Draft NUREG‒2157

1 environmental impacts include, but are not limited to air quality, land use, and water and 

2 ecological resources. Consequently, environmental justice, as well as other socioeconomic

3 issues, are normally considered in site-specific environmental reviews (69 FR 52040).

4 In the present case, however, the NRC has determined that it can provide an assessment of the 

5 environmental justice impacts during continued storage compared to environmental justice 

6 impacts of storage during reactor operations. As previously stated in Chapters 2 and 3, this 

7 draft GEIS and the Waste Confidence rule are not licensing actions and do not authorize the 

8 continued storage of spent fuel. The environmental analysis in this draft GEIS fulfills a small

9 part of the NRC’s NEPA obligation with respect to the licensing or relicensing of a nuclear 

10 reactor or spent fuel storage facility. Further, the site-specific NEPA analysis that is required 

11 prior to an NRC licensing action will include a discussion of the impacts on minority and low12 income populations, and will appropriately focus on the NRC decision directly related to specific 

13 licensing actions. As with all other resource areas, this site-specific analysis will allow the NRC 

14 to make an impact determination with respect to environmental justice for each NRC licensing 

15 action. A generic determination of the human health and environmental effects impacts during 

16 continued storage is possible because the NRC understands how the environmental impacts 

17 change when a nuclear power plant site transitions from reactor operations to continued 

18 storage. Based on this knowledge, the NRC can provide an assessment of the potential human 

19 health and environmental effects during continued storage. As discussed in the following 

20 sections, the NRC has determined that the human health and environmental effects from 

21 continued storage would be small compared to the impacts that are normally experienced 

22 during reactor operations.

23 4.3.1 Short-Term Storage

24 As previously explained in Section 4.2.1 (socioeconomics—short term), the socioeconomic 

25 effects of reactor operations have become well established because regional socioeconomic 

26 conditions will have adjusted to the presence of the nuclear power plant (NRC 2013a). After the 

27 cessation of reactor operations, a small number of workers (15–85) would continue to maintain 

28 and monitor spent fuel pools. These workers would also transfer spent fuel from spent fuel 

29 pools to at-reactor ISFSIs. Once all of the spent fuel is transferred from the spent fuel pools to 

30 dry cask storage, spent fuel pool storage operations worker positions would be eliminated. For 

31 at-reactor ISFSIs, a small number of workers (30–35) would be needed to maintain and monitor 

32 the at-reactor ISFSI. Consequently, socioeconomic impacts due to continued storage would be 

33 unchanged in comparison to the period of reactor operations for minority and low-income 

34 populations. 

35 Generally, the continued maintenance and radiological monitoring associated with spent fuel 

36 storage, either in spent fuel pools or at-reactor ISFSIs, during the short-term timeframe ensures 

37 that any human health and environmental effects would remain within regulatory limits for the 

38 general population. Based on a review of recent REMP reports, human health impacts would 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-12 September 2013

1 not be expected in special pathway receptor populations living near a nuclear power plant site 

2 as a result of subsistence consumption of water, local food, fish, and wildlife during the 

3 short-term timeframe. A modified REMP would remain in effect after the nuclear power plant 

4 ceases operations through the short-term timeframe. Monitoring would ensure that radiological 

5 doses would remain within regulatory limits and minority and low-income populations would 

6 experience no new human health and environmental effects during the short timeframe beyond 

7 what had already been experienced during reactor operations.

8 As previously discussed for the other resource areas in Chapter 4, the overall contributory 

9 human health and environmental effects from continued short-term spent fuel storage would be 

10 limited in scope and SMALL for all populations. Therefore, minority and low-income populations 

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

12 environmental effects from the continued short-term storage of spent fuel. In addition, as 

13 indicated in the NRC policy statement, the potential for environmental justice impacts would also 

14 be considered during the environmental reviews for specific licensing actions associated with 

15 each particular storage facility (69 FR 52040).

16 4.3.2 Long-Term Storage

17 In addition to monitoring and maintenance, long-term storage includes the construction and 

18 operation of a DTS and replacement of the at-reactor ISFSI and DTS. Construction and 

19 operation of a DTS would constitute a federal action under NEPA and site-specific analysis 

20 would include an analysis of the potential effects on minority and low-income populations. 

21 NRC environmental justice analyses are generally limited to evaluating the human health and 

22 environmental effects of the proposed licensing action and the potential for minority and low23 income populations to be disproportionately affected. As stated in the NRC policy statement, 

24 environmental justice assessments would be performed as necessary in the underlying 

25 licensing action for each particular facility (69 FR 52040). DTS license reviews would not rely 

26 on the analysis in this draft GEIS, because the site-specific NEPA analysis would consider the

27 site-specific impacts on minority and low-income populations.

28 Potential impacts on minority and low income populations from the construction, operation, and 

29 replacement of the DTS and at-reactor ISFSI would mostly consist of environmental and 

30 socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and housing 

31 impacts). Noise and dust impacts during construction would be short term and primarily limited 

32 to onsite activities. Minority and low income populations residing along site access roads could 

33 be directly affected by increased commuter vehicle and truck traffic. However, because of the 

34 temporary nature of construction and the relatively low numbers of workers (60–80 short-term 

35 construction workers), these effects are likely to be minimal and limited in duration. Increased 

36 demand for rental housing during construction could cause rental costs to rise temporarily, 

37 disproportionately affecting low-income populations living near the site who rely on inexpensive 

38 housing. However, given the short duration of construction (1–2 years), the relatively small 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-13 Draft NUREG‒2157

1 number of workers needed, and the proximity of some nuclear power plant sites to metropolitan 

2 areas, it is expected that many of the workers would commute to the construction site, thereby 

3 reducing the need for rental housing. Based on this information and the analysis of human 

4 health and environmental impacts presented in this chapter, the construction of the DTS and 

5 replacement of the ISFSI would not have disproportionately high and adverse human health and 

6 environmental effects on minority and low-income populations. Similar to the short-term 

7 storage, a small number of workers (30–35) would be needed to maintain and monitor the 

8 at-reactor ISFSI after cask transfers to the replacement facility. Consequently, employment 

9 opportunities, although reduced from reactor operations, would remain unaffected for minority 

10 and low-income populations. Based on this information, there would be no disproportionately 

11 high and adverse human health and environmental effects on minority and low-income 

12 populations from the construction and operation of the DTS and replacement of the DTS and 

13 at-reactor ISFSI.

14 For long-term spent fuel storage, REMPs, similar to those implemented during nuclear power 

15 plant operations and short-term storage, would ensure that the radiation dose from DTS 

16 operations and continued spent fuel storage would remain within regulatory limits. Similar to 

17 short-term storage, a modified REMP would be in place to ensure that radiological doses remain 

18 within regulatory limits and minority and low-income populations would experience no new 

19 human health and environmental effects during the long-term timeframe beyond those 

20 experienced during reactor operations.

21 The continued maintenance and monitoring of spent fuel in at-reactor ISFSIs would have 

22 minimal human health and environmental effects on minority and low-income populations near 

23 these storage facilities. As previously discussed for the other resource areas in Chapter 4, the 

24 overall contributory human health and environmental effects from continued long-term spent fuel 

25 storage would be limited in scope and SMALL for all populations, except for historic and cultural 

26 resources where impacts could be SMALL, MODERATE, or LARGE. The magnitude of adverse 

27 effect on historic properties and the impact on historic and cultural resources largely depends on 

28 what resources are present, the extent of proposed land disturbance, if the area has been 

29 previously surveyed to identify historic and cultural resources, and if the licensee has 

30 management plans and procedures that are protective of historic and cultural resources. The 

31 site-specific environmental review and compliance with the NHPA process could identify historic 

32 properties, adverse effects, and potentially address adverse effects on historic properties and 

33 impacts on other historic and cultural resources. Thus, the potential impacts on historic and 

34 cultural resources could be SMALL, MODERATE, or LARGE depending on site-specific factors. 

35 However, measures such as implementation of historic and cultural resource plans and 

36 procedures, agreements, and license conditions can be used to avoid, minimize, or mitigate 

37 adverse effects on historic properties and impacts on historic and cultural resources. Minority 

38 and low-income populations are not expected to experience disproportionately high and adverse 

39 human health and environmental effects from the continued long-term storage of spent fuel. In 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-14 September 2013

1 addition, as indicated in the NRC policy statement, the potential for environmental justice

2 impacts would be considered during the environmental reviews for specific licensing actions 

3 associated with each particular storage facility (69 FR 52040).

4 4.3.3 Indefinite Storage

5 This section describes the environmental impacts on minority and low-income populations if a 

6 repository is not available to accept spent fuel. With no repository available, the aging 

7 management program would continuously monitor and maintain an at-reactor ISFSI. Impacts 

8 from indefinite onsite storage would be similar to those described in Section 4.3.2.

9 The indefinite maintenance and monitoring of spent fuel in at-reactor ISFSIs would have 

10 minimal human health and environmental effects on minority and low-income populations near 

11 these storage facilities. As previously discussed for the other resource areas in Chapter 4, the 

12 overall contributory human health and environmental effects from the indefinite storage of spent 

13 fuel storage would be limited in scope and SMALL for all populations, except for historic and 

14 cultural resources where impacts could be SMALL, MODERATE, or LARGE. If replacement 

15 activities occur in previously disturbed areas (i.e., in areas that have previously experienced 

16 construction impacts) then impacts on historic and cultural resources would be SMALL. 

17 Therefore, historic properties would not be adversely affected. If construction activities occur in 

18 previously undisturbed areas or avoidance is not possible, then there could be adverse effects 

19 on historic properties, and impacts on historic and cultural resources could be SMALL, 

20 MODERATE, or LARGE depending on site-specific factors. Minority and low-income 

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

22 and environmental effects from the indefinite storage of spent fuel. In addition, as indicated in 

23 the NRC policy statement, the potential for environmental justice impacts would be considered 

24 during the environmental reviews for specific licensing actions associated with each particular 

25 storage facility (69 FR 52040).

26 4.4 Air Quality

27 This section describes impacts on air quality caused by continued storage in spent fuel pools 

28 and at-reactor ISFSIs. Because there would be no increase in emissions during continued 

29 storage, the requirements for a conformity determination under 40 CFR Part 93 do not apply to 

30 the operation of a spent fuel pool or an at-reactor ISFSI. The requirements for a conformity 

31 determination with respect to the replacement of an ISFSI and the construction, operation, and 

32 replacement of a DTS are considered in the long-term storage section (Section 4.4.1).

33 4.4.1 Short-Term Storage

34 Once reactor operations cease and continued storage begins, most pollutant-generating 

35 activities at the nuclear power plant site would either cease or continue at lower levels. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-15 Draft NUREG‒2157

1 Therefore, as described following, the environmental impacts on air quality during continued 

2 storage would be less than the impacts during reactor operations.

3 The License Renewal GEIS concluded that impacts for continued power-generation operations 

4 in attainment, nonattainment, and maintenance areas are SMALL for all plants, at least in part 

5 because licensees would be required to operate within State permit requirements (NRC 2013). 

6 Specifically, the License Renewal GEIS analyzes a number of specific activities related to 

7 continued power-generation operations that result in emissions of air pollutants. These include

8 testing of emergency diesel generators, use of fossil-fuel boilers (for evaporator heating, plant 

9 space heating, and feed water purification), testing of fossil-fuel-fired fire pumps, cooling-tower 

10 drift, and transmission-line emissions. When the nuclear power plant ceases operations and the 

11 site enters the short-term storage timeframe, many of these activities will also cease. For 

12 example, testing requirements may be reduced or eliminated for emergency diesel generators 

13 once the reactor is permanently shutdown. Also, cooling towers would no longer be rejecting up 

14 to two-thirds of the thermal power of a reactor, which would dramatically reduce cooling-tower 

15 drift. Because emissions of air pollutants resulting from continued storage of spent fuel in either 

16 spent fuel pools or at-reactor ISFSIs would be substantially smaller than air emissions during 

17 power generation, air quality impacts from continued storage would also be minor.

18 Routine maintenance and monitoring activities at the at-reactor ISFSI would occur during short19 term storage. Because dry cask storage systems do not have active systems (e.g., diesel 

20 generators), these activities do not involve significant releases of air pollutants.

21 Thermal releases from the at-reactor ISFSI will cause some local atmospheric heating. 

22 Downwind from an ISFSI, ambient temperatures can increase by 2.1°C (3.8°F) at 1 km (0.6 mi) 

23 to 0.1°C (0.2°F) at 10 km (6.2 mi) from the site (NRC 1984). Temperature changes this small 

24 could not be differentiated from temperature changes that naturally occur, such as from 

25 passage of the sun throughout the day and passing clouds. Over time, the spent fuel in the 

26 casks will cool and less heat will be released resulting in less local atmospheric heating. The 

27 heat released by storing dry casks on the surface should be distinguished from the greenhouse 

28 gas emissions discussed in Section 4.5 of this draft GEIS. Heat released from a dry cask is a 

29 local phenomenon, whereas greenhouse gases released into the atmosphere potentially 

30 contribute to impacts beyond the local environment.

31 Because emissions of air pollutants resulting from short-term continued storage of spent fuel 

32 would be substantially smaller than air emissions during power generation, which was 

33 determined to have SMALL impacts in the License Renewal GEIS, the NRC concludes the 

34 impacts associated with continued spent fuel storage would be SMALL for all location 

35 classifications (i.e., attainment, nonattainment, and maintenance). Further, the impact from heat 

36
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-16 September 2013

1 released to the atmosphere from ISFSIs would be SMALL because the small variations in 

2 downwind temperatures caused by heat released from the ISFSI would not be different from 

3 natural temperature fluctuations.

4 4.4.2 Long-Term Storage

5 As noted in Section 1.8, all the spent fuel would be moved out of the spent fuel pool and into 

6 at-reactor dry cask storage by the beginning of this timeframe. Routine maintenance and 

7 monitoring activities at the at-reactor ISFSI would continue during long-term storage. Because 

8 dry cask storage systems do not have active systems (e.g., diesel generators), these activities 

9 do not involve significant releases of air pollutants. As described in Section 1.8.3, the NRC 

10 assumes that the ISFSI needs to be replaced and the fuel repackaged during this timeframe. 

11 The licensee must construct a DTS to facilitate the transfer of the spent fuel to new casks. The 

12 draft GEIS also assumes that the DTS is replaced once during the long-term storage timeframe.

13 The construction and replacement of a DTS would involve onsite fabrication involving heavy 

14 equipment (earthmoving, concrete batch plant, cranes, etc.), which would cause emissions of 

15 air pollutants. Given the relatively smaller size of the DTS compared to an at-reactor ISFSI, the 

16 time, materials, and equipment required to build the DTS would be no more than those used to 

17 construct an ISFSI. The NRC previously determined that the environmental impact on air 

18 quality from construction of the Diablo Canyon ISFSI, which would hold up to 140 dry storage 

19 casks from two reactors on a 2-ha (5-ac) site and would be larger than the reference DTS, 

20 would be minimal (NRC 2003). Therefore, the air emissions and impacts on air quality for 

21 construction and replacement of the DTS would also be minimal. The DTS relies on electrical 

22 power for operations. As a result, there are no routine emissions of air pollutants from the DTS 

23 during operations, such as might occur from a boiler or diesel generator. A diesel generator 

24 could be used as a source of backup electrical power. Testing and use of a backup diesel 

25 generator would be infrequent and would cause emissions no greater than those caused by 

26 emergency diesel generators at operating nuclear power plants, which are minor.

27 Activities associated with ISFSI replacement and DTS operations, including cask repair, bare 

28 fuel handling as part of repackaging operations, and cask replacement, are expected to be of 

29 relatively short duration and limited extent in any year during long-term continued storage. 

30 These activities are likely to involve only a portion of the ISFSI, and in any year would likely 

31 involve only a fraction of the air emissions that were associated with initial construction of the 

32 at-reactor ISFSI. As a result, there may be temporary increases in levels of suspended 

33 particulate matter from construction and replacement activities. In addition, exhaust from 

34 vehicles would add to levels of hydrocarbons, carbon monoxide, and nitrogen oxides. However, 

35 these emissions of air pollutants are not expected to noticeably affect important attributes of air 

36 quality in the region. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-17 Draft NUREG‒2157

1 Previous NRC NEPA analyses for site-specific licensing actions support this conclusion for 

2 attainment, maintenance, and nonattainment areas. For example, the NRC analyzed the 

3 impacts of constructing and operating an ISFSI at Humboldt Bay (NRC 2005a), which is located 

4 in an attainment area, and determined that the air quality impacts were SMALL. The NRC also 

5 analyzed the impacts of constructing and operating additional reactor units at existing nuclear 

6 power plant sites such as Calvert Cliffs Unit 3 (NRC 2011a) and Fermi Unit 3 (NRC 2013b), 

7 which are located in nonattainment areas. In both examples, the NRC determined that the air 

8 impacts were SMALL, at least in part because licensees would be required to operate within 

9 State permit requirements. The level of activities and associated air emissions from long-term 

10 storage would not be greater than those for the construction and operation of another reactor 

11 unit at an existing power plant site.

12 Emissions of air pollutants during ISFSI replacement and construction, operation, and 

13 replacement of a DTS would be well below de minimis levels in 40 CFR Part 93 and the 

14 requirements for a conformity determination would not apply. For example, the de minimis

15 annual emission rate for all nuclear power plants in nonattainment and maintenance areas is 

16 100 T/yr for all criteria pollutants, except volatile organic compounds for plants within an ozone 

17 transport region, for which the de minimis level is 50 T/yr (NRC 2013a). The NRC estimated the 

18 peak annual emissions for preconstruction and construction of the entire Fermi Unit 3 nuclear 

19 power plant to be 123.2 T/yr nitrogen oxide and 53.4 T/yr volatile organic compounds (NRC 

20 2013b), which is only slightly above de minimis levels. Because the DTS and ISFSI are only a 

21 small fraction of the size of an entire nuclear power plant, the emissions of air pollutants during 

22 ISFSI replacement and DTS construction and replacement would be well below de minimis

23 levels.

24 Thermal releases from storing dry casks on the surface would cause some local atmospheric 

25 heating. As described previously for short-term storage, this effect is not expected to be 

26 noticeable and would decrease during the long-term storage timeframe as decay heat in the 

27 ISFSI decreases over time.

28 Emissions of air pollutants during long-term continued storage of spent fuel would be minimal, 

29 and the NRC concludes the impacts would be SMALL for all location classifications (i.e., 

30 attainment, nonattainment, and maintenance). The impact from heat released to the 

31 atmosphere from ISFSIs would be SMALL because the small variations in downwind 

32 temperatures would not be noticeable and would decrease throughout this period as decay heat 

33 diminishes.

34 4.4.3 Indefinite Storage

35 This section describes the environmental impacts on air quality if a repository never becomes

36 available to accept spent fuel. Indefinite storage would consist of the same activities and result 

37 in the same impacts as those for long-term storage (Section 4.4.2), except that they would 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-18 September 2013

1 continue indefinitely into the future. Thermal releases from storing dry casks on the surface 

2 would cause some local atmospheric heating, which would continue to decrease as decay heat 

3 from spent fuel diminishes. Therefore, the NRC concludes that the environmental impacts on 

4 air quality from indefinite storage due to air emissions and thermal releases would each be 

5 SMALL.

6 4.5 Climate Change

7 In this section, the NRC evaluates the effect of continued storage on climate change. The 

8 NRC’s evaluation of the effects of climate change on the intensity and frequency of natural 

9 phenomena hazards that may cause spent fuel storage accidents is provided in Section 4.18.

10 4.5.1 Short-Term Storage

11 This section describes greenhouse gas emissions related to short-term continued storage of 

12 spent fuel. The activities at a nuclear power plant during short-term continued storage involve 

13 the emission of greenhouse gases, primarily carbon dioxide (CO2). The quantities of 

14 greenhouse gas emissions are often described in terms of a CO2 footprint expressed as metric 

15 tons of CO2 equivalent. The NRC’s previous estimates of a reference reactor’s CO2 footprint 

16 during the decommissioning period include activities in addition to those related to continued 

17 storage of spent fuel. However, these estimates provide a reasonable upper bound on the 

18 CO2 footprint for short-term continued storage because the activities that occur as a direct result 

19 of continued storage would generate less CO2 than decommissioning activities. 

20 The NRC estimated the CO2 footprint for a reference 1,000-MW(e) reactor for a 50-year 

21 decommissioning period, assuming the licensee chooses the SAFSTOR decommissioning 

22 option (NRC 2011h). The greenhouse gas emissions resulting from the SAFSTOR 

23 decommissioning option would include all emissions of greenhouse gases that would be 

24 associated with the immediate decommissioning (or DECON) option, and also include the 

25 greenhouse gases that would be emitted by vehicles used by the caretaker workforce for the 

intervening 40-year period of SAFSTOR.2 26 Therefore, greenhouse gas emissions associated 

27 with the SAFSTOR option bound those associated with the DECON option. The NRC assumed 

28 that SAFSTOR lasts for 40 years and is followed by 10 years of major decommissioning 

29 activities. The predominant sources of greenhouse gas emissions during major 

30 decommissioning activities are fossil-fuel powered demolition equipment and worker 

31 transportation vehicles for the estimated 300 decommissioning workers. Continued storage 

 

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 2013 4-19 Draft NUREG‒2157

1 activities at the spent fuel pool and at-reactor ISFSI do not involve significant sources of fossil2 fuel consuming activities, other than the use of vehicles by the commuting workforce, and the 

3 occasional use of onsite vehicles for inspection and maintenance of spent fuel storage facilities. 

4 Therefore, greenhouse gas emissions from decommissioning activities would be more than the 

5 greenhouse gas emissions associated with the smaller workforce responsible for continued 

6 storage. The CO2 footprint of decommissioning is on the order of 48,000 MT of CO2 equivalent, 

7 or an annual emission rate of about 1,000 MT, averaged over the period of operation, compared 

8 to a total U.S. annual CO2 emissions rate of 6,702,000,000 MT of CO2 equivalent (EPA 2012).

9 Based on its assessment of the relatively small short-term continued storage greenhouse gas

10 footprint compared to the U.S. annual CO2 emissions, the NRC concludes that the atmospheric 

11 impacts of greenhouse gases from short-term continued storage would not be noticeable and 

12 would therefore be SMALL.

13 4.5.2 Long-Term Storage

14 This section describes the greenhouse gas production of continued storage during long-term 

15 continued storage. Over the long-term storage timeframe, sources of greenhouse gas 

16 emissions include vehicles used by the commuting workforce and workers conducting routine 

17 maintenance activities for the at-reactor ISFSI and construction and demolition equipment 

18 required to initially construct, and eventually replace, a DTS and to replace the at-reactor ISFSI. 

19 Given that activities at the site have been reduced to continued storage of spent fuel at the 

20 at-reactor ISFSI, the CO2 footprint for the commuting workforce would be no greater than that 

21 associated with the SAFSTOR workforce described previously. Using the greenhouse gas 

22 emission rate of 13,000 MT of CO2 equivalent over 40 years associated with the SAFSTOR 

23 option, this is approximately 32,500 MT of CO2 equivalent over the 100-year long-term storage 

24 timeframe (NRC 2011h).

25 The NRC’s estimated CO2 footprint for a reference 1,000-MW(e) reactor provides a useful upper 

26 bound for the CO2 footprint that would be associated with construction and replacement of the 

27 ISFSI and DTS, which are much smaller facilities. The CO2 footprint for construction equipment 

28 used to build a 1,000-MW(e) reactor is about 35,000 MT of CO2 equivalent. The CO2 footprint 

29 for decommissioning equipment used on a 1,000-MW(e) reactor is about 18,000 MT of 

30 CO2 equivalent (NRC 2011h).

31 Combining the total CO2 footprints for the commuting workforce, construction and replacement 

32 activities, and averaging over the 100-year long-term storage timeframe, the annual 

33 CO2 footprint is estimated to be no more than 855 MT of CO2 equivalent, compared to a total 

34 U.S. annual CO2 emissions rate of 6,702,000,000 MT of CO2 equivalent (EPA 2012). Based on 

35 its assessment of the relatively small long-term continued storage greenhouse gas footprint 

36
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-20 September 2013

1 compared to the U.S. annual CO2 emissions, the NRC concludes that the atmospheric impacts 

2 of greenhouse gases from long-term continued storage would not be noticeable and would 

3 therefore be SMALL. 

4 4.5.3 Indefinite Storage

5 This section describes the greenhouse gas production of continued storage if a repository never 

6 becomes available to accept spent fuel. The main difference when compared to the impacts 

7 during long-term storage is that without a repository these activities would occur on an ongoing 

8 basis over a longer period of time so the total amount of emissions would be greater. However, 

9 the annual emission levels for the various phases would remain the same.

10 The NRC concludes that the relative contribution from indefinite onsite storage of spent fuel to 

11 greenhouse gas emission levels would be SMALL based on the same considerations as those 

12 cited previously in the long-term storage section.

13 4.6 Geology and Soils

14 This section describes the potential environmental impacts on geology and soils caused by the 

15 continued onsite storage of spent fuel. 

16 4.6.1 Short-Term Storage

17 Continued spent fuel pool operation is not anticipated to increase impacts on the local geology 

18 and soils. However, spent fuel pool leaks could result in radiological contamination of offsite 

19 soils. The degree of contamination of offsite soils would depend on the rate of release from the 

20 spent fuel pool, direction of groundwater flow, the distance to offsite locations, and the velocity 

21 or transport rates of radionuclides through soils and radioactive decay rates. Tritium in 

22 groundwater is likely to be observed as part of a licensee’s radiological environmental 

23 monitoring program, and corrective action would be taken consistent with Federal and State 

24 requirements. In addition, most radionuclides move at a much slower rate and are much more 

25 likely to be absorbed by the concrete structures of the spent fuel building and by the soil 

26 surrounding the leak location. As a result, the NRC expects that most soil contamination from 

27 spent fuel pool leaks would remain onsite and, therefore, offsite soil contamination is unlikely to 

28 occur. Therefore, the NRC concludes that the environmental impact of spent fuel pool leaks to 

29 offsite soils (i.e., outside the power plant’s exclusion area) would be SMALL. Appendix E 

30 contains additional information regarding the analysis of the impacts of spent fuel pool leaks on 

31 soils.

32 Continued ISFSI operation is not expected to affect the underlying geology because ISFSIs 

33 have no moving parts to affect the subsurface (see e.g., NRC 2012a). Although soils may be 

34 affected by spills and leaks of radiological and hazardous materials, ISFSIs are designed to 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-21 Draft NUREG‒2157

1 prevent leakage and licensee employees conduct routine inspections to verify that the ISFSIs 

2 are performing as expected. Leaks could result in spills of oil and hazardous material from 

3 operating equipment and stormwater runoff carrying grease. However, these activities are 

4 monitored and, in the case of stormwater runoff, regulated under National Pollutant Discharge 

5 Elimination System (NPDES) permit requirements (NRC 2002b).

6 Because no new land would be disturbed for the continued operation and maintenance of the 

7 existing pool and ISFSI and the impacts from spent fuel leaks to offsite soils would be SMALL, 

8 the NRC concludes that the continued storage of spent fuel during short-term storage on 

9 geology and soils would be SMALL.

10 4.6.2 Long-Term Storage

11 During the long-term storage timeframe, routine maintenance and monitoring of the ISFSI would 

12 continue. Similar to short-term storage, the operation of any ISFSI is not anticipated to have 

13 any additional impacts on soils beyond those associated with construction.

14 The construction of a DTS is anticipated to have minimal impacts on soils due to the small size 

15 of the DTS, which is about 0.7 ha (2 ac). The types of impacts on soils from construction of a 

16 DTS would be similar to those anticipated for any power plant facility construction and would

17 include soil compaction, soil erosion, and potential surface leaks of oils, greases, and other 

18 construction materials. Due to the relatively small size of the DTS, the impacts would be limited 

19 to the immediate area. Any laydown areas associated with construction would be reclaimed 

20 once the construction phase was complete. The draft GEIS also assumes that the ISFSI and 

21 DTS would require replacement and could occur on land immediately adjacent to existing 

22 facilities. There would be no permanent increase in the overall area of land disturbed because 

23 the old facilities would be demolished and the land could be reclaimed.

24 The construction and operation of the DTS, along with the replacement of the DTS and ISFSI 

25 facilities, would have minimal impacts on soils on the small fraction of the land committed for the 

26 facilities. There are no anticipated impacts on the geology of the area as the result of these 

27 activities. Therefore, the NRC concludes that the environmental impact on geology and soils 

28 would be SMALL during long-term storage.

29 4.6.3 Indefinite Storage

30 In this section, impacts are evaluated assuming a repository does not become available. As 

31 previously noted, the ISFSI would require continued maintenance and monitoring. In addition, 

32 the ISFSI, storage casks, and DTS are assumed to be replaced every 100 years using a staged 

33 approach. As described above, no additional land would be required for these activities. At the 

34 end of the next 100-year cycle it is anticipated that the replacement of the ISFSI and DTS would 

35 occur on previously disturbed land, thereby minimizing impacts on soils. Given the temporary 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-22 September 2013

1 nature of the impacts on geology and soils, and the occurrence of the impacts within previously

2 disturbed areas, the NRC concludes that the environmental impacts on geology and soils from 

3 the indefinite onsite storage of spent fuel would be SMALL.

4 4.7 Surface-Water Quality and Use

5 This section describes potential environmental impacts on the quality and consumptive use of 

6 surface water caused by continued storage of spent fuel in spent fuel pools and ISFSIs. 

7 4.7.1 Short-Term Storage

8 During the short-term timeframe, most environmental impacts on surface-water resources 

9 will cease due to the end of reactor operations. For example, consumptive water loss per 

10 1,000 MW(e) for different cooling systems used at operating power plants ranges from 

11 8,100 gpm for plants that use once-through cooling system to 14,000 gpm at plants with 

12 mechanical draft cooling towers (NRC 2013a). After permanent cessation of operations, 

13 the amount of heat rejected by these cooling systems would drop from over 10,000 BTU/hr to 

14 approximately the initial 40-BTU/hr decay heat load associated with cooling a spent fuel pool 

15 shortly after fuel is discharged from a reactor (EPRI 2002). Other potential impacts on surface16 water resources would result from use of water to shield workers from radiation in the reactor 

17 area, continued stormwater management, and minor chemical spills. With more than 

18 99 percent reduction in the amount of heat to be discharged, and a corresponding reduction in 

19 cooling-water demand, potential impacts from these activities would be significantly less severe 

20 than those associated with normal plant operation. The same activities described above also 

21 may affect surface-water quality. Surface waters are most likely to be affected by stormwater 

22 runoff, erosion, and by discharge of hazardous substances. However, these activities are 

23 monitored and regulated under NPDES permit requirements (NRC 2002b).

24 4.7.1.1 Spent Fuel Pools

25 As described above, because cooling-water demand would be significantly reduced after reactor 

26 operations have ceased, the NRC has determined that impacts on surface-water consumptive 

27 use from the continued storage of spent fuel in spent fuel pools will not be detectable or be so 

28 minor that they would not be destabilizing.

29 Surface-water quality may be affected by groundwater contamination. The NRC has completed 

30 a review of its overall regulatory approach to groundwater protection (NRC 2011b). The NRC 

31 started this review in response to recent incidents of radioactive contamination of groundwater 

32 and soils at nuclear power plants. Contaminated groundwater at some sites may discharge to 

33 nearby surface waters, resulting in indirect effects on surface-water quality. The concentrations 

34 of radionuclides in offsite surface waters would depend on the rate of release from the spent 

35 fuel pool, direction and rate of groundwater flow, the distance to nearby offsite surface waters 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-23 Draft NUREG‒2157

1 toward which groundwater flows, the velocity or transport rates of radionuclides through the 

2 subsurface and radioactive decay rates. However, because surface waters in the vicinity of 

3 nuclear power plants are usually large to meet reactor cooling requirements, a large volume of 

4 surface water is usually available to dilute groundwater contaminants that flow into the surface 

5 waterbody. This dilution ensures that contaminants that may have been present above 

6 applicable groundwater-quality standards are diluted well below limits considered safe.

7 The NRC estimated an annual discharge rate for leakage from the spent fuel pool of 380 L/d 

8 (100 gpd) with contaminants at certain concentrations assumed to be present at the start of 

9 short-term storage. These concentrations were compared to annual effluent ranges for BWRs

10 and PWRs. Even in the unlikely event that spent fuel pool leakage flowed continuously 

11 (24 hours per day, 365 days per year) undetected and unimpeded to local surface waters, the 

12 quantities of radioactive material discharged to nearby surface waters would be comparable to 

13 values associated with permitted, treated effluent discharges from operating nuclear power 

14 plants (see Table E–4). Based on the above considerations, the NRC concludes that the impact 

15 of spent fuel pool leaks on surface water would be SMALL. More information about the NRC’s 

16 analysis of the environmental surface-water-quality impacts of continued storage of spent fuel 

17 on nearby surface waters from groundwater contamination can be found in Appendix E of this 

18 draft GEIS.

19 4.7.1.2 ISFSIs

20 As passive, air-cooled storage systems, ISFSIs do not consume water and they generate 

21 minimal liquid effluents that may be discharged to surface waterbodies during normal operation. 

22 For example, in its consideration of water-use impacts for the renewal of the Calvert Cliffs 

23 ISFSI, the NRC determined that both direct and indirect impacts would be SMALL (NRC 2012a). 

24 This includes consideration of cask-loading operations and stormwater runoff carrying grease, 

25 oil, and spills from operating equipment that support the ISFSI.

26 4.7.1.3 Conclusion

27 Because short-term storage of spent fuel would use less surface water and have fewer activities 

28 that could affect surface-water quality than an operating reactor, which was previously 

29 determined to have a SMALL impact, and because leaks from spent fuel pools would have a 

30 SMALL impact on surface-water quality, the NRC concludes that impacts on surface-water

31 quality and consumptive use during the short-term storage timeframe would each be SMALL.

32 4.7.2 Long-Term Storage

33 During long-term storage, there is no demand for surface water for routine maintenance and 

34 monitoring of an at-reactor ISFSI. In addition, as during short-term continued storage described 

35 above, water-quality impacts from ISFSI operations would be minimal. However, during 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-24 September 2013

1 long-term continued storage, there could be temporary consumptive use of surface water for 

2 demolishing and replacing the ISFSI and constructing and eventually replacing a DTS. 

3 During ISFSI demolition, a small amount of water could be sprayed from water trucks to 

4 minimize dust clouds. Additional water may be required to make concrete to replace facilities. 

5 For example, it would require about 100,000 gal of water to make the concrete to replace an 

6 entire 46 × 46 m (150 ×150 ft) ISFSI pad that is 1 m (3 ft) thick. A comparable amount could be 

7 required to replace dry cask storage system components, such as storage casks. If the activity 

8 were to take several months to complete, the average daily consumptive water use would be a 

9 few thousand gallons, which is less than the consumptive water loss estimated for an operating 

10 reactor for 1 minute (NRC 2013a). Therefore, the consumptive water-use impacts for 

11 demolishing and replacing the ISFSI would be minimal.

12 The NRC assumes that a DTS would need to be constructed and replaced during the long-term 

13 storage timeframe. The construction and operation of a DTS involves very little temporary 

14 consumptive use of water. Some water would be required for construction of its concrete 

15 basemat and shell. Given the relatively small size of the DTS compared to an ISFSI, less water 

16 would be required to build the DTS than would be used to construct the ISFSI. During 

17 operations, water would be brought to the facility by tanker truck or temporary connection to 

18 public water supply for general purpose cleaning and canister decontamination. Additional 

19 water might be consumed by activities such as drinking, conducting personal hygiene, and 

20 disposing of sewage.

21 The NRC concludes that the potential consumptive use and surface-water quality impacts from 

22 continued ISFSI operations would be minimal. Consumptive use of surface water for ISFSI 

23 replacement and DTS construction, operation, and replacement would involve amounts of water 

24 that are a small fraction of water use during reactor operations. Therefore, the NRC concludes 

25 that the potential impacts on surface-water use and quality for the long-term storage timeframe 

26 would be SMALL.

27 4.7.3 Indefinite Storage

28 If no repository becomes available, storage of spent fuel would continue indefinitely. As a 

29 result, the potential impacts on surface-water resources would be similar to those described for 

30 long-term storage (Section 4.7.2) because the same activities would occur. Every 100 years, 

31 surface water would be required for demolishing and replacing the ISFSI and DTS. This 

32 additional consumptive use would be temporary. Therefore, the NRC concludes that the 

33 potential impacts on surface-water use and quality for the indefinite storage of spent fuel would 

34 each be SMALL.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-25 Draft NUREG‒2157

1 4.8 Groundwater Quality and Use

2 This section describes the potential environmental impacts on groundwater water quality and

3 consumptive use caused by continued storage of spent fuel in spent fuel pools and at-reactor 

4 ISFSIs. 

5 4.8.1 Short-Term Storage

6 During short-term storage, most groundwater consumptive use and quality impacts that had 

7 been caused by reactor operations would cease. Groundwater dewatering may occur during 

8 short-term storage because groundwater may be pumped for potable water, sanitary uses, and 

9 maintenance of spent fuel pools. However, surface-water resources may be used for these 

10 activities.

11 The NRC determined in the License Renewal GEIS that consumptive use of groundwater during 

12 reactor operation would be SMALL because groundwater supplies are commonly not used or 

13 are used as a backup water source. During normal reactor operations, at most reactors, the 

14 withdrawal rate from production aquifers is kept below 378 L/min (100 gpm) to avoid 

15 groundwater-use conflicts (NRC 2013a). When reactor operations cease, the use of 

16 groundwater is greatly reduced, especially at sites where reactor operations use groundwater as 

17 a backup water source (e.g., H.B. Robinson Steam electric plant [NRC 2005b]). The potential 

18 use of groundwater is greatly reduced when reactor operation ceases, because cooling-water 

19 system demands are substantially lower after the facility is shut down and spent fuel is removed 

20 from the reactor vessel (NRC 2002b).

21 4.8.1.1 Spent Fuel Pools

22 Because consumptive water-use impacts on groundwater resources during short-term storage 

23 of spent fuel in spent fuel pools would be significantly less than during normal reactor operation, 

24 the resultant impacts on groundwater at offsite wells would be nondetectable or so minor that 

25 they would not destabilize groundwater resources. As a result, the NRC has made a generic 

26 conclusion that the consumptive water-use impacts on groundwater resources during short-term 

27 storage of spent fuel in spent fuel pools would be minor or minimal.

28 Continued short-term storage of spent fuel in spent fuel pools could result in radiological 

29 impacts on groundwater quality. As discussed in Appendix E, in the very unlikely event that a 

30 leak from a spent fuel pool goes undetected and the resulting groundwater plume reaches the 

31 offsite environment, it is possible that the leak could be of sufficient magnitude and duration to 

32 contaminate a groundwater source above a regulatory limit (i.e., a maximum contaminant level 

33 [MCL] for one or more radionuclides). 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-26 September 2013

1 But the impacts of a spent fuel pool leak on offsite groundwater depend on many factors, 

2 including the volume and rate of water released from the spent fuel pool, the radionuclide

3 content and concentration and water chemistry of the spent fuel pool water, the direction of 

4 groundwater flow, the distance to an offsite groundwater receptor, the velocity or transport rates 

5 of radionuclides through the subsurface, and radioactive decay rates. Further, as discussed in 

6 Appendix E, spent fuel pool design (e.g., stainless-steel liners and leakage-collection systems) 

7 and operational controls (e.g., monitoring and surveillance of spent fuel pool water levels) make 

8 it unlikely that a leak will remain undetected long enough to exceed any regulatory requirement 

9 (e.g., the NRC dose limit or EPA-mandated Maximum Contaminant Level) in the offsite 

10 environment. Although a small number of spent fuel pool leaks have caused radioactive liquid 

11 releases to the environment, based on the available data, none of these releases have affected 

12 the health of the public (NRC 2006a). In addition, onsite groundwater monitoring required to 

13 comply with 10 CFR 20.1501 provides added protection with respect to identifying a spent fuel 

14 pool leak and, if necessary, isolating and remediating contaminated groundwater onsite. A 

15 recent revision to the NRC’s regulations that explicitly requires monitoring of subsurface areas 

16 will further ensure leaks are detected. Besides these measures, the hydrologic characteristics 

17 associated with typical nuclear power plant settings (see Section E.2.1.3)—such as their 

18 location near large waterbodies (due to cooling requirements), shallow water table flow direction 

19 toward these waterbodies, flat hydraulic gradients in the shallow water tables, large distance to 

20 local groundwater users, and the likelihood that local groundwater usage is in deeper confined 

21 aquifers—will act to impede the offsite migration of future spent fuel pool leakage. Finally, 

22 current and future spent fuel pool sites are required to have routine environmental monitoring 

23 programs in place that should take samples at offsite groundwater sources (e.g., potable or 

24 irrigation) in areas where the hydraulic gradient or recharge properties are suitable for 

25 contamination (NRC 1991c,d). Further, any detection of onsite contamination would likely result 

26 in additional monitoring, including additional sampling of any nearby private wells, as part of an 

27 expanded environmental monitoring program. With these measures and characteristics in 

28 place, it is unlikely that offsite migration of spent fuel pool leaks will occur or go undetected. 

29 Based on these factors, the NRC concludes that the radiological impacts on groundwater quality 

30 resulting from a spent fuel pool leak during the short-term timeframe would be SMALL.

31 The NRC is aware that unintentional releases of nonradiological hazardous substances have 

32 infrequently occurred after reactors shut down. Except for a few substances (e.g., diesel fuel), 

33 these hazardous spills are often localized, quickly detected, and relatively easy to remediate 

34 (NRC 2002b). During the short-term storage timeframe, the licensee will decommission the site, 

35 which will result in the ultimate cleanup of the portions of the reactor facility that are not needed 

36 for continued short-term storage in a spent fuel pool. In addition, permit requirements (e.g., 

37 NPDES permit) and the requirements for compliance with the Resource Conservation and 

38 Recovery Act (RCRA) and the Safe Drinking Water Act would minimize potential risks for 

39 nonradiological contamination entering groundwater during short-term spent fuel storage in 

40 spent fuel pools.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-27 Draft NUREG‒2157

1 Therefore, the NRC concludes that during short-term storage, the nonradiological impacts on

2 groundwater quality would be minimal.

3 4.8.1.2 ISFSIs

4 ISFSIs, which are passive systems, consume minimal water and generate minimal 

5 nonradiological liquid effluents during normal operation (see e.g., NRC 2012a). The only 

6 potential impact on groundwater quality from operating an ISFSI consists of the infiltration of 

7 stormwater runoff carrying grease and oil, and spills from operating equipment that supports the 

8 ISFSI. Because ISFSI storage requires minimal water and produces minimal, localized, and 

9 easy-to-remediate liquid effluents on or near the ground surface, ISFSI storage impacts on 

10 groundwater quality and use would not be detectable or would be so minor that they would not 

11 be destabilizing to groundwater resources. As a result, the NRC concludes that the potential 

12 consumptive water-use and quality impacts on groundwater during ISFSI storage of nuclear 

13 fuels would be minimal.

14 4.8.1.3 Conclusion

15 Based on the discussion above, the NRC concludes that consumptive water-use impacts on 

16 groundwater resources during short-term storage of spent fuel in spent fuel pools and at-reactor 

17 ISFSIs would be SMALL. For groundwater quality, the NRC concludes that radiological and 

18 nonradiological impacts during the short-term storage of spent fuel in pools and ISFSIs would 

19 be SMALL.

20 4.8.2 Long-Term Storage

21 The consumptive water use associated with routine maintenance and monitoring of the ISFSI 

22 discussed for short-term storage would continue during long-term storage. In addition, the NRC 

23 assumes that a DTS would need to be constructed and operated during long-term storage. The 

24 construction and operation of a DTS involves very little consumptive use of groundwater. 

25 Concrete used for construction of the basemat and shell would likely arrive ready mixed and 

26 would not require additional water. For example, the NRC previously identified that little or no 

27 water would be consumed by the construction of the Calvert Cliffs and Prairie Island ISFSIs 

28 (NRC 1991a and 1992). Because the size of the DTS would be small compared to an ISFSI, 

29 less water would be required to construct the DTS than would be used to construct the ISFSI. 

30 During DTS operations, water would be brought to the facility by tanker truck or temporary 

31 connection to public water supply for general purpose cleaning and canister decontamination. 

32 Additional water might be consumed by activities such as drinking, conducting personal 

33 hygiene, and disposing of sewage.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-28 September 2013

1 The impacts on groundwater quality from the operation of the ISFSI during long-term storage 

2 would be similar to the impacts discussed previously for short-term storage (Section 4.1.1). 

3 While operation of the DTS does consume water, no groundwater quality affecting discharges 

4 are expected. Therefore, the consumptive groundwater use and quality impacts from 

5 construction of the DTS and operation of the ISFSI, including the DTS would be minimal during 

6 long-term storage.

7 With regard to ISFSI and DTS replacement activities, the consumptive use and groundwater8 quality impacts would be similar to those associated with initial construction of the ISFSI. For 

9 example, NRC staff determined that construction of the Calvert Cliffs and Prairie Island ISFSIs 

10 (NRC 1991a, 1992) would have negligible to no impacts on water resources. Similarly, the 

11 groundwater-quality and consumptive-use impacts associated with ISFSI and DTS replacement 

12 activities during long-term storage would be minor.

13 Because the potential impacts on groundwater water quality and consumptive water uses during 

14 long-term storage would be similar to the impacts during short-term dry storage, the NRC 

15 concludes that the impacts on groundwater quality and consumptive use associated with the 

16 long-term storage of spent fuel in an at-reactor ISFSI would be SMALL.

17 4.8.3 Indefinite Storage

18 If no repository becomes available, storage of spent fuel in an ISFSI would continue indefinitely. 

19 As a result, the potential impacts on groundwater resources would be similar to those described 

20 for long-term storage (Section 4.8.2) because the same activities would be happening at the 

21 storage site. Every 100 years, groundwater may be required for demolishing and replacing the 

22 ISFSI and DTS. This additional consumptive use would be temporary. Therefore, the NRC 

23 concludes that the potential impacts on groundwater use and quality if a repository is not 

24 available would each be SMALL.

25 4.9 Terrestrial Resources

26 This section describes potential environmental impacts on terrestrial resources caused by the 

27 continued storage of spent fuel in spent fuel pools and at-reactor ISFSIs.

28 As explained in Section 3.8, a wide variety of terrestrial habitats are present at nuclear power 

29 plant sites, which include spent fuel pools and at-reactor ISFSIs. The generic environmental 

30 impact analyses in this section considers both existing generic analyses and site-specific 

31 analyses that the NRC completed for licensing and relicensing of nuclear power plants and 

32 ISFSIs. The significance of potential impacts on plants and animals and their habitats depends 

33 on the importance or role of the plant or animal within the ecological community that is affected.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-29 Draft NUREG‒2157

1 4.9.1 Short-Term Storage

2 During the short-term storage timeframe, many activities that occurred during the operation of 

3 the reactor that could affect terrestrial resources would cease. However, terrestrial resources 

4 will likely continue to be affected during this timeframe by the continued operation of the spent 

5 fuel pool cooling system, and by the operation and maintenance of systems and structures at 

6 the nuclear power plant site and the at-reactor ISFSI.

7 4.9.1.1 Spent Fuel Pools 

8 The following discussion describes the impacts of spent fuel pool operations during short-term 

9 storage, using the impact analyses from the License Renewal GEIS to inform the NRC’s 

10 analysis of these impacts during short-term storage. Operation of a spent fuel pool and its 

11 associated cooling system during short-term storage would require the withdrawal of water and 

12 discharge of effluents into a nearby waterbody. The NRC evaluated the effects of the continued 

13 operation of nuclear power plants, which included the operation of associated spent fuel pools, 

14 on terrestrial resources in the License Renewal GEIS (NRC 2013a). The NRC then looked at 

15 the systems that would be needed to cool the spent fuel pool during short-term storage, and 

16 compared the impacts associated with water use during operations and water use after the end 

17 of operations.

18 Water-Use Conflicts with Terrestrial Resources at Plants with Cooling Ponds or Cooling 

19 Towers Using Makeup Water from a River

20 Water from nearby lakes, rivers, and oceans is needed for both closed and once-through 

21 cooling systems. Water-use conflicts with terrestrial resources could occur if water from a single 

22 waterbody is required to simultaneously cool a spent fuel pool and support other water users 

23 such as agricultural, municipal, or industrial users. A conflict could arise if the surface-water

24 resource is diminished because of decreased water availability due to low flow or drought

25 conditions; increased demand for agricultural, municipal, or industrial usage; or a combination of 

26 factors (NRC 2013a).

27 The License Renewal GEIS evaluated the potential impacts on terrestrial biota and concluded 

28 that the impacts from water-use conflicts with terrestrial resources could, in certain situations, 

29 result in noticeable impacts on terrestrial resources (NRC 2013a). For example, Wolf Creek 

30 Generating Station in Kansas, which operates a cooling pond to cool plant systems, withdraws 

31 makeup water for the pond from the Neosho River located downstream of the John Redmond 

32 reservoir. The riparian communities downstream of the reservoir may be temporarily affected 

33 by the plant’s water use during periods when the reservoir level is low and makeup water is 

34 obtained from the Neosho River (NRC 2013a). Water-use conflicts during reactor operations, 

35 such as those described previously, could result in SMALL to MODERATE impacts due to the 

36 uncertainty associated with water availability to a plant for future water use (see, e.g., 

37 NRC 2008a).
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-30 September 2013

1 However, the water-withdrawal requirements for a spent fuel pool are considerably lower than 

2 those for a power reactor (see Table 4-1). In addition, a State agency or the EPA would require 

3 the licensee to obtain and comply with an NPDES permit, which would limit the amount of water 

4 the facility could withdraw. As part of the NPDES review, the State agency or EPA would 

5 assess the local water availability to help prevent water-use conflicts. In addition, the State 

6 agency or EPA would review and, if necessary, update the NPDES permitevery 5 years. 

7 Therefore, the NRC concludes that water-use conflicts during short-term storage would have 

8 minimal impacts on terrestrial resources.

9 Table 4-1. Reference Plant Withdrawal Rates and Heat Loads

Reactor

Once-Through Cooling Closed-Cycle Cooling Spent Fuel Pool

Withdrawal Rate (gpm)(a) 800,000(b) 12,000(c) 2,800(d)

Heat Load (106 BTU/hr) 10,000(b) 10,000(b) 35(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-MW(e) nuclear power plant.

(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 draft GEIS, and would decrease as time after 

shutdown increases.

(e) Design heat load for a spent fuel pool.

10 Other Potential Impacts from the Spent Fuel Pool Cooling System

11 The License Renewal GEIS determined that all other potential impacts on terrestrial ecology 

12 from the operation of the cooling system would be SMALL at all nuclear power plant sites. 

13 These additional impacts include the following:

14 • exposure of terrestrial organisms to radionuclides

15 • cooling-system impacts on terrestrial resources (plants with once-through cooling systems

16 or cooling ponds)

17 • cooling-tower impacts on vegetation

18 The License Renewal GEIS determined that these impacts on terrestrial ecology would be 

19 SMALL at all power plants based on review of literature, operational monitoring reports, 

20 consultations with utilities and regulatory agencies, and license renewal supplemental EISs 

21 (SEISs) published to date. The License Renewal GEIS indicated that exceptions have been 

22 observed at some nuclear plants; however, licensees have addressed the impacts by changing

23 plant operations to prevent impacts. During short-term storage, because reactor operations 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-31 Draft NUREG‒2157

1 have ceased, these impacts will be less than during operations. Specifically, the frequency and 

2 quantity of radionuclides released will decrease after reactor shutdown, resulting in less impact 

3 on terrestrial organisms than considered in the License Renewal GEIS. Also, because the 

4 cooling system requirements for the spent fuel pool (e.g., intake and discharge water volume 

5 and heat load rejected) are much less than for an operating reactor, the impacts of the operation 

6 of the cooling system will be much less than those considered in the License Renewal GEIS. 

7 Therefore, the NRC has determined that the impacts of the spent fuel pool cooling system on 

8 terrestrial ecology will be minimal during short-term storage.

9 Impacts from the Operation and Maintenance of Systems and Structures at the Nuclear 

10 Power Plant Site

11 The License Renewal GEIS evaluated other potential impacts on terrestrial resources from 

12 sources other than the operation of the spent fuel pool cooling system. These additional 

13 impacts include the following:

14 • electromagnetic fields on flora and fauna

15 • bird collisions with plant structures and transmission lines

16 • transmission-line right-of-way management impacts on terrestrial resources

17 NRC determined in the License Renewal GEIS that these impacts on terrestrial ecology would 

18 be SMALL. During the short-term timeframe, electrical power will still be required to operate the 

19 spent fuel pool cooling system and to provide power to the system associated with the operation 

20 of ISFSIs (e.g., lighting). Licensees may choose to power these systems by maintaining the 

21 existing transmission-line infrastructure or replacing this infrastructure with a smaller capacity 

22 distribution system. This new distribution system would have smaller impacts than the existing 

23 transmission lines because of the smaller profile, reduced electromagnetic field, and reduced 

24 vegetative maintenance required around the distribution lines. In addition, fewer structures will 

25 be required to be maintained during the short-term timeframe, which would reduce the likelihood 

26 of bird collisions with nuclear power plant structures. As a result, the NRC has determined that 

27 the impacts from the operation and maintenance of systems and structures at the nuclear power 

28 plant site on terrestrial ecology will be minimal during short-term storage.

29 4.9.1.2 ISFSIs

30 Normal operation of an ISFSI does not require water for cooling and the facility would produce 

31 minimal gaseous or liquid effluents. Therefore, no water withdrawal and minimal discharges 

32 would be associated with the operation of ISFSIs. Some radiological exposure and 

33 maintenance activities would occur during operation. Maintenance may include some ground34 disturbing or rights-of-way management activities. However, impacts on terrestrial resources 

35 from short-term storage, including routine maintenance activities, would be temporary.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-32 September 2013

1 After they are constructed, at-reactor ISFSIs have similar impacts on terrestrial resources, 

2 regardless of their location, due to the passive nature and small size of an at-reactor ISFSI and 

3 because minimal liquid or gaseous effluents are generated during normal operations. This is 

4 supported by a number of site-specific EAs performed in support of licensing actions that have 

5 looked at the environmental impacts on terrestrial resources during ISFSI operations. For 

6 example, a number of these reviews found that the ISFSIs would not contribute any significant 

7 impacts on terrestrial resources during normal operations (see, e.g., NRC 2012a, 2005a, 2003). 

8 Normal operation of an ISFSI would not generate any significant noise, would not significantly 

9 affect the area available for terrestrial wildlife, and would not adversely affect terrestrial 

10 environments or their associated plant and animal species (see, e.g., NRC 2012a, 2005a, 

11 2003). In addition, while the air temperature in the immediate vicinity of the casks will be higher 

12 than ambient temperature, the affected area is limited by the distance from the casks to 

13 receptors and is not expected to affect terrestrial resources (see, e.g., NRC 2009a). To the 

14 extent that animals and birds are affected by ISFSI operations, they would likely either 

15 accustom themselves to regular operations or would relocate themselves away from the facility 

16 (see, e.g., NRC 2012a). Further, licensees are required to adhere to the protection of eagles 

17 and migratory birds under the Federal Bald and Golden Eagle Protection Act and Migratory Bird 

18 Treaty Act. In addition, coordination with State natural resource agencies may further ensure 

19 that power plant operators take appropriate steps to avoid or mitigate impacts on State species 

20 of special concern that may not be protected under other Federal statutes.

21 4.9.1.3 Conclusion

22 Impacts associated with the operation of spent fuel pools and at-reactor ISFSIs would be 

23 bounded by the impacts analyzed in the License Renewal GEIS and example ISFSI EAs 

24 previously discussed. For operation of the spent fuel pool cooling system, impacts would be 

25 bounded by those discussed in the License Renewal GEIS, primarily due to the reduced cooling 

26 system requirements for the spent fuel pool (e.g., intake and discharge water volume and heat 

27 load rejected). For ISFSI operations, impacts would be similar to those described in example 

28 ISFSI EAs because of the passive nature and small size of ISFSIs, and because minimal liquid 

29 or gaseous effluents are generated during normal operations. Therefore, the NRC concludes 

30 that impacts on terrestrial resources from the operation of spent fuel pools and ISFSIs during 

31 the short-term storage timeframe would be SMALL.

32 4.9.2 Long-Term Storage

33 During the long-term timeframe, routine maintenance and monitoring of the ISFSIs continues, 

34 and the NRC assumes that a DTS is constructed, the fuel is moved from existing dry storage 

35 casks to new dry storage casks, and a new ISFSI is constructed.

36 Impacts from the ongoing maintenance and monitoring of ISFSIs on terrestrial resources during 

37 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

September 2013 4-33 Draft NUREG‒2157

1 storage, described in Section 4.9.1. These impacts would be minimal due to the small size of 

2 the ISFSIs, because water is not used for cooling, and because minimal liquid or gaseous 

3 effluents are generated during normal operations.

4 ISFSIs are designed as passive systems that require no new or additional long-term 

5 maintenance; however, an at-reactor ISFSI is assumed, for this draft GEIS, to require 

6 replacement within the long-term storage timeframe, which would require repackaging of 

7 spent fuel at a DTS. Replacement of the ISFSI would occur within the plant’s operational 

8 area adjacent to existing facilities. The older ISFSI would be demolished and the land 

9 reclaimed and maintained for the next 100 years.

10 Impacts on terrestrial resources from ISFSI replacement activities would be similar to those 

11 impacts evaluated for the decommissioning of an existing at-reactor ISFSI and the construction 

12 of a new at-reactor ISFSI.

13 During the removal of an existing at-reactor ISFSI, increases in noise levels and changes in 

14 localized air quality as a result of fugitive dust and equipment exhaust emissions would likely 

15 result in animals and birds temporarily avoiding the activity area. Expected ground-disturbing, 

16 re-grading, and reseeding activities associated with removal of the ISFSI are not expected to 

17 substantially affect local vegetation. Unless the reclaimed area will be used for another 

18 purpose, wildlife would likely re-inhabit the area as vegetation begins to reestablish itself (see, 

19 e.g., NRC 2012a).

20 The impacts of the replacement and management of an ISFSI would be minimal because the 

21 construction footprint of an ISFSI is relatively small, the ISFSI could be sited in a previously 

22 disturbed area, and the licensees would likely be required to implement best management 

23 practices as part of their NPDES permits to address issues such as stormwater runoff. This is 

24 supported by a number of site-specific EAs performed in support of licensing actions that have 

25 looked at the environmental impacts of the construction of an ISFSI on terrestrial resources. 

26 For example, the NRC concluded in the EA for the Calvert Cliffs ISFSI renewal that the impact 

27 on ecological resources from decommissioning would be SMALL and would not be significant in 

28 part because the 2-ha (6-ac) ISFSI area was previously disturbed by ISFSI construction (NRC 

29 2012a). Also, the NRC did not identify any significant impacts on aquatic resources from 

30 construction of the Humboldt Bay ISFSI in part due to the fact that ground-disturbing activities 

31 would be limited to 0.4 ha (1 ac) and the ISFSI would not be located near any aquatic features 

32 (NRC 2005a). Similarly, the construction footprint for the Diablo Canyon ISFSI was limited to 

33 2 ha (4.9 ac) and was sited in a previously disturbed area (NRC 2003). In addition, the NRC 

34 indicated that controls would be in place to minimize any site runoff, spillage, and leaks

35 (NRC 2003, 2005a). Stormwater control measures, which would be required to comply with 

36 NPDES permitting, would also minimize the impacts of site runoff, spillage, and leaks on nearby 

37 wetlands.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-34 September 2013

1 Like an ISFSI, a DTS would be located within the operational area adjacent to existing facilities 

2 and, like ISFSI replacement and maintenance activities, a DTS would require construction and 

3 maintenance activities. Impacts on terrestrial resources from repackaging and operation of the 

4 DTS would be limited. Like ISFSIs, a DTS could likely be sited on previously disturbed ground 

5 or away from sensitive terrestrial features because of the relatively small construction footprint 

6 for a DTS (about 0.7 ha [2 ac]) compared to the entire power plant site and because there is a 

7 sufficient amount of previously disturbed area on most nuclear power plant sites. The NRC 

8 assumes that construction of a DTS would be temporary (1 to 2 years) and would require a 

9 small fraction of the land (about 0.7 ha [2 ac]) committed for a nuclear power plant. The 

10 construction laydown area would be reclaimed and revegetated after construction is completed. 

11 There may be temporary increases in traffic, soil erosion, noise, fugitive dust, and habitat 

12 reduction from construction and refurbishment activities that could affect terrestrial resources. 

13 The plant operator could implement best management practices to minimize land disturbances, 

14 vegetation removal, erosion, noise, and dust. DTSs and ISFSIs do not require water for cooling. 

15 Minimal liquid or gaseous effluents are generated during normal operation. Thus construction, 

16 repackaging, and replacement activities would have minimal impacts on terrestrial resources for 

17 reasons previously explained. In addition, based on review of example EAs, the NRC expects 

18 that normal operations of DTSs and ISFSIs would not generate any significant noise, would not 

19 significantly affect the area available for terrestrial wildlife, and would not adversely affect 

20 terrestrial environments or their associated plant and animal species. Therefore, the NRC 

21 concludes that impacts on terrestrial resources during the long-term storage timeframe would be 

22 SMALL.

23 4.9.3 Indefinite Storage

24 Activities and impacts from the operation of ISFSIs to terrestrial resources would be similar to 

25 those described in Section 4.9.2, although replacement of the DTS and complete repackaging

26 would occur every 100 years. The NRC concluded in Section 4.9.2 that impacts on terrestrial 

27 resources during long-term storage would be SMALL because continued operations, 

28 repackaging, DTS construction, and DTS and ISFSI replacement would not adversely affect 

29 terrestrial environments or their associated plant and animal species. In addition, replacement 

30 of the ISFSI and DTS would likely occur on land near existing facilities and could be sited on 

31 previously disturbed ground away from terrestrial species and habitats. By alternating the ISFSI 

32 between two adjacent onsite locations, the NRC expects the upper limit of land disturbances to 

33 be bounded by doubling the land area developed for existing ISFSIs presented in Table 3-1. 

34 The older ISFSIs and DTSs would be demolished and the land likely reclaimed. Therefore, the 

35 NRC concludes that the impacts on terrestrial resources from indefinite storage of spent fuel at 

36 at-reactor ISFSIs would be SMALL.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-35 Draft NUREG‒2157

1 4.10 Aquatic Ecology 

2 This section describes potential aquatic ecology impacts caused by the continued storage of 

3 spent fuel in spent fuel pools and at-reactor ISFSIs. Impacts on aquatic resources include 

4 impingement and entrainment; thermal impacts; effects of cooling-water discharge on dissolved 

5 oxygen, gas supersaturation, and eutrophication (the over-enrichment of water by nutrients such 

6 as nitrogen phosphorus); effects of nonradiological contaminants on aquatic organisms; 

7 exposure of aquatic organisms to radionuclides; water-use conflicts with aquatic organisms; and 

8 losses from predation, parasitism, and disease among organisms exposed to sublethal 

9 stresses.

10 4.10.1 Short-Term Storage

11 During the short-term storage timeframe, many activities that occurred during the operation of 

12 the reactor that could affect aquatic resources would cease. However, aquatic resources will 

13 likely continue to be affected during this timeframe by the continued operation of the spent fuel 

14 pool cooling system and the at-reactor ISFSI.

15 4.10.1.1 Spent Fuel Pools

16 The following discussion describes the impacts of spent fuel pools during short-term storage, 

17 using the impact determinations from the License Renewal GEIS to inform the NRC’s analysis 

18 of these impacts during short-term storage.

19 Operation of a spent fuel pool and its associated cooling system during the short-term storage 

20 timeframe would require the withdrawal of water and discharge of effluents into a nearby 

21 waterbody. To make this comparison, the NRC evaluated the effects of the continued operation 

22 of nuclear power plants, which included the operation of associated spent fuel pools, on aquatic 

23 ecology in the License Renewal GEIS (NRC 2013a). The NRC then looked at the systems that 

24 would be needed to cool the spent fuel pool during short-term storage, and compared the 

25 impacts associated with water use during operations and water use after the end of operations.

26 Impingement and Entrainment of Aquatic Organisms

27 Aquatic organisms can be impinged or entrained when cooling-water intakes for spent fuel pools 

28 withdraw water that provides habitat to fish, shellfish, plankton, or other aquatic resources. 

29 Impingement, which mostly involves fish and shellfish, occurs when organisms are held against 

30 the intake screen or netting placed within intake canals. Exhaustion, starvation, asphyxiation, 

31 descaling, and physical stresses may kill or injure impinged organisms. The License Renewal

32 GEIS describes some of the fish species commonly impinged at operating power plants as well 

33 as other vertebrate species that may also be impinged on the traveling screens or on intake 

34
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-36 September 2013

1 netting placed within intake canals 

2 (NRC 2013a). These species would 

3 likely continue to be impinged as a 

4 result of operation of the spent fuel 

5 pool cooling system during the short6 term storage timeframe. 

7 Entrainment occurs when organisms 

8 pass through the intake screens and 

9 travel through the spent fuel pool 

10 condenser cooling system. Heat, 

11 physical stress, or chemicals used to 

12 clean the cooling system may kill or 

13 injure the entrained organisms. Due to these physical stresses, the NRC assumes 100 percent 

14 mortality for all entrained organisms. Typically entrained aquatic organisms include 

15 ichthyoplankton (fish eggs and larvae), larval stages of shellfish and other macroinvertebrates, 

16 zooplankton, and phytoplankton. Juveniles and adults of some species may also be entrained if 

17 they are small enough to pass through the intake screen openings, which are commonly 1 cm

18 (0.4 in) at the widest point. The License Renewal GEIS describes some of the fish species 

19 commonly entrained at operating power plants (NRC 2013a). These species would likely 

20 continue to be entrained as a result of operation of the spent fuel pool cooling system during the 

21 short-term storage timeframe. 

22 The severity of impacts associated with impingement and entrainment is dependent upon 

23 several factors including the amount of water withdrawn relative to the size of the cooling-water 

24 source, location and configuration of intake structures, type of waterbody from which water is 

25 withdrawn, conditions within that waterbody, proximity of withdrawal structures to sensitive 

26 biological habitats (e.g., spawning and nursery habitats), sensitivity of populations of impinged 

27 and entrained organisms to potential losses of individuals, and mitigation measures in place to 

28 reduce impingement and entrainment (NRC 2013a). Among these factors, the volume of water 

29 withdrawn relative to the size of the water source can be a good predictor of the number of 

30 organisms that would be impinged or entrained within a given aquatic system (EPA 2002). 

31 Impingement monitoring at the Palisades Nuclear Plant in Michigan demonstrates this 

32 difference: In 1972, when the plant used once-through cooling with a water-withdrawal rate of 

33 400,000 gpm, 654,000 fish were impinged yearly. In 1976, cooling towers were added to the 

34 plant, and it began operating as a closed-cycle plant. The intake withdrawal rate was reduced 

35 to 78,000 gpm, and impingement dropped to 7,200 fish per year (Consumers Energy Company 

36 and Nuclear Management Company 2001). These results showed that an approximate 

37 80 percent decrease in water withdrawal resulted in an approximate 98 percent decrease in 

38 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 CFR 125.83).

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 coolingwater system (40 CFR 125.83).
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-37 Draft NUREG‒2157

1 The License Renewal GEIS concluded that the impacts from impingement and entrainment

2 would be SMALL, MODERATE, or LARGE at operating plants with once-through cooling, 

3 cooling ponds, or hybrid cooling (NRC 2013a). The magnitude of the impact would depend on 

4 plant-specific characteristics of the cooling system (including location, intake velocities, 

5 screening technologies, and withdrawal rates) and characteristics of the aquatic resource 

6 (including population distribution, status, management objectives, and life history). However, for 

7 operating plants with closed-cycle cooling, the License Renewal GEIS generically concluded 

8 that impingement and entrainment is SMALL (NRC 2013a). The main reason the License 

9 Renewal GEIS could generically conclude that the impacts would be SMALL at all closed-cycle 

10 cooling plants is because power plants with closed-cycle cooling require much less water than 

11 those with once-through cooling. For example, EPRI estimated that the average flow rate for a 

12 reference 1,000-MW(e) nuclear plant with closed-cycle would be 12,000 gpm, which is 

13 approximately 1 to 3 percent of the flow rate for a reference 1,000-MW(e) plant with once14 through cooling 416,700 to 1,000,000 gpm (EPRI 2002). Reactors are typically cooled either by 

15 transferring excess heat directly to a water source (referred to as open-cycle cooling) or to the 

16 atmosphere through a cooling tower (referred to as closed-cycle cooling). For nuclear power 

17 plants with closed-cycle cooling systems installed, cooling water for the service-water system 

18 (which cools the spent fuel pool) is usually withdrawn from a surface waterbody, circulated 

19 through the service-water system, and sent to the cooling tower as a source of makeup water 

20 for the main cooling system. While it is typically used as a source of makeup water, the 

21 discharge from the service-water system can also be returned to the surface waterbody, 

22 functioning, in essence, like an open-cycle cooling system. Because the heat load associated 

23 with the spent fuel pool during continued storage is significantly smaller than a reactor at full 

24 power and because of the costs associated with operating the cooling towers, the NRC 

25 assumes that, for nuclear power plants with closed-cycle cooling systems, those systems will be 

26 operated in a manner similar to an open-cycle cooling system to cool the spent fuel pool during 

27 the short-term timeframe. As discussed below, the NRC expects that the flow rate associated 

28 with the water needed to cool the spent fuel pool after operations will be significantly less than 

29 the overall water needed during operation of the reactors, regardless of the cooling technology 

30 used to cool the reactors. When compared to a once-through cooling system, the water needed 

31 to cool the spent fuel pool is orders of magnitude less than the water needed during reactor 

32 operations.

33 To operate spent fuel pools during short-term storage, the service-water system would likely 

34 continue to operate to cool the spent fuel pools. Cooling systems associated with spent fuel

35 pools require substantially less water volume and carry a lower heat load than operating nuclear 

36 power plants, as indicated in Table 4-1. For example, based on the current operation of spent 

37 fuel pools, the NRC estimates that approximately 2,800 gpm would be withdrawn at each spent 

38 fuel pool. Operating reactors with closed-cycle cooling systems, on the other hand, withdraw 

39 approximately 12,000 gpm and operating plants with once-through cooling require 416,700 to 

40 1,000,000 gpm (EPRI 2002). In addition, the amount of water withdrawn to cool spent fuel 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-38 September 2013

1 pools is likely to decrease over the short-term storage timeframe because the spent fuel pool 

2 would require less cooling as the spent fuel cools. Based on the reduced operational 

3 requirements for spent fuel pool cooling systems (e.g., reduced water-withdrawal and discharge 

4 rates), the impingement and entrainment impacts from an operating nuclear plant bounds the 

5 potential impacts from operating spent fuel pools during short-term storage.

6 Because operating the spent fuel pool cooling system during the short-term timeframe will use 

7 less water than operating the cooling system for an operating plant with a closed-cycle cooling 

8 system, which was considered in the License Renewal GEIS, the NRC concludes that 

9 impingement and entrainment impacts from operating spent fuel pools during continued storage 

10 would have minor impacts on aquatic resources.

11 Heat Shock

12 Water-based cooling systems for spent fuel pools generally discharge heated effluent into 

13 nearby waterbodies. Heat shock can occur if the water temperature meets or exceeds the 

14 thermal tolerance of a species for some duration (NRC 2007a). In most situations, fish are 

15 capable of moving out of an area that exceeds their thermal tolerance limits, although many 

16 aquatic resource species lack such mobility. Heat shock is typically observable only for fish 

17 species, particularly those that float when dead. The License Renewal GEIS provides additional 

18 details on observed fish kills and other potential environmental impacts from heat shock.

19 The severity of impacts for heat shock depends on the characteristics of the cooling system

20 (including location and type of discharge structure, discharge velocity and volume, and 

21 three-dimensional characteristics of the thermal plume) and characteristics of the affected 

22 aquatic resources (including the species present and their physiology, habitat, population

23 distribution, status, management objectives, and life history). Site-specific design features, such 

24 as locating the discharge structures in areas where warmer water would be rapidly diluted, may 

25 mitigate adverse thermal effects (Beitinger et al. 2000). Hall et al. (1978) determined that the 

26 potential for thermal discharge impacts is greatest in shallow, enclosed, and poorly mixed 

27 waterbodies. 

28 The License Renewal GEIS concluded that for operating plants with a once-through cooling 

29 system or cooling ponds, the level of impact for thermal discharge on aquatic biota (primarily 

30 due to heat shock) was SMALL at many plants and MODERATE or LARGE at some plants. For 

31 example, some nuclear plants have reported occasional fish kills from heat shock (see, e.g., 

32 NRC 2006b, 2007a; Exelon 2001, 2005). For operating plants with closed-cycle cooling, the 

33 NRC conducted a review of the literature and license renewal SEISs published to date and 

34 determined that reduced populations of aquatic biota attributable to occurrences of heat shock 

35 have not been reported for any existing nuclear power plants with cooling towers operated in 

36 closed-cycle mode. Based on this review and because of the smaller thermal plumes at plants 

37 with closed-cycle cooling compared to plants with once-through cooling systems, the License 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-39 Draft NUREG‒2157

1 Renewal GEIS concluded that impacts from heat shock would be SMALL at all plants with 

2 closed-cycle cooling. The thermal plume is generally smaller at plants with closed-cycle cooling 

3 because less water is being discharged (NRC 2013a).

4 As described above, cooling systems associated with spent fuel pools operating during the 

5 short-term storage timeframe would require substantially less water volume and carry a lower 

6 heat load compared to operating nuclear power plants with closed-cycle cooling systems (see 

7 Table 4-1). In addition, the heat load in the spent fuel pool would decrease over time as the fuel 

8 continues to decay. Because the amount of water discharged from a spent fuel pool, regardless 

9 of the type of cooling system, would still be significantly less than the amount of water 

10 discharged from an operating plant with closed-cycle cooling, the extent of the thermal plume

11 would likely be smaller. In addition, the licensee would be required to obtain an NPDES permit 

12 for thermal discharges, and the permit would limit the amount and temperature of thermal 

13 effluent to be discharged. The NPDES permit would also require the licensee to monitor and 

14 ensure the effluent is within the set thermal limit. Based on this information, the thermal impacts 

15 from an operating nuclear plant with closed-cycle cooling (which was determined to be SMALL 

16 in the License Renewal GEIS) likely bounds the potential thermal impacts from operating spent 

17 fuel pools beyond the licensed term of the nuclear plant.

18 The NRC has determined that thermal impacts from operating spent fuel pools beyond the 

19 licensed term of the plant would have a minor impact on aquatic resources because operating 

20 the spent fuel pool cooling system during the short-term storage timeframe will use less water 

21 than operating a closed-cycle cooling system for an operating reactor and a spent fuel pool 

22 considered in the License Renewal GEIS. 

23 Water-Use Conflicts with Aquatic Resources at Plants with Cooling Ponds or Cooling 

24 Towers Using Makeup Water from a River

25 Water-use conflicts with aquatic resources could occur if water from a single waterbody is 

26 required to simultaneously cool a spent fuel pool to support aquatic resources, and support 

27 other water users such as agricultural, municipal, or industrial users. A conflict could arise if the 

28 surface-water resource is diminished either because of decreased water availability due to 

29 droughts; increased demand for agricultural, municipal, or industrial usage; or a combination of 

30 factors. The License Renewal GEIS determined that water-use conflicts during plant operation 

31 are a concern for streams or rivers because of the duration of license renewal and potentially 

32 increasing demands on surface water. However, the water-withdrawal requirements for a spent 

33 fuel pool during short-term storage are considerably lower than for an operating plant (see 

34 Table 4-1). In addition, the spent fuel pool operator would be required to obtain and comply with 

35 an NPDES permit, which would limit the amount of water that could be withdrawn. As part of 

36 the NPDES review, the State agency or EPA would assess the local water availability to help 

37 prevent water-use conflicts. In addition, the NPDES permit would be reviewed, and updated if 

38 necessary, every 5 years. Because operating the spent fuel pool cooling system during 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-40 September 2013

1 short-term storage will use significantly less water than operating the cooling system for an 

2 operating plant considered in the License Renewal GEIS, the NRC has determined that water3 use conflicts from operating spent fuel pools during short-term storage would have minimal 

4 impacts on aquatic resources.

5 Other Potential Impacts from the Cooling System

6 The License Renewal GEIS determined that all other potential impacts on aquatic ecology from 

7 the operation of the cooling system would be SMALL at all nuclear power plants. These 

8 additional impacts include the following:

9 • cold shock, which can occur when organisms acclimated to the elevated temperatures of a 

10 thermal plume are abruptly exposed to temperature decreases when the artificial source of 

11 heating stops

12 • the creation of thermal plume migration barriers, which would occur if the mixing zone of the 

13 thermal plume covers an extensive cross-sectional area of a river and exceeds the fish 

14 avoidance temperature (NRC 2013a)

15 • changes in the distribution of aquatic organisms

16 • accelerated development of aquatic insect maturation due to warmer temperatures

17 • stimulation of the growth of aquatic nuisance species

18 • effects of cooling-water discharge on dissolved oxygen, gas supersaturation, and 

19 eutrophication

20 • effects of nonradiological contaminants on aquatic organisms

21 • exposure of aquatic organisms to radionuclides

22 • losses from predation, parasitism, and disease among organisms exposed to sublethal 

23 stresses

24 In the License Renewal GEIS, the NRC determined that these impacts would be SMALL at all 

25 nuclear power plants. The NRC based its conclusion on the following:

26 • Any fill kills or other events related to the impacts described previously were relatively rare 

27 and did not result in population level impacts.

28 • The heat from the thermal plume usually dissipated rapidly.

29 • Heated plumes are often small relative to the size of the receiving waterbody. The License 

30 Renewal GEIS provides additional details regarding these potential impacts and the studies 

31 reviewed to support the SMALL conclusion.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-41 Draft NUREG‒2157

1 As described above, the water-withdrawal rate, discharge rates, and extent of the thermal plume

2 would be greater for an operating plant than a spent fuel pool during short-term storage (see 

3 Table 4-1). Based on this information, the other potential impacts from an operating a nuclear 

4 plant with closed-cycle cooling (which was determined to be SMALL in the License Renewal

5 GEIS) likely bound the potential impacts from operating spent fuel pools during short-term 

6 storage. Because operating the spent fuel pool cooling system during short-term storage will 

7 use less water than operating the cooling system for an operating plant considered in the 

8 License Renewal GEIS, the NRC has determined that other potential impacts from operating 

9 spent fuel pools during the short-term storage timeframe would have minimal impacts on 

10 aquatic resources.

11 4.10.1.2 ISFSIs

12 The NRC reviewed example ISFSI EAs to inform its analysis of the environmental impacts of 

13 ISFSIs on aquatic resources during short-term storage.

14 During normal operations, ISFSIs do not require water for cooling and the facility would produce 

15 minimal gaseous or liquid effluents. Therefore, no water withdrawal or discharges would be 

16 associated with the operation of ISFSIs. Some maintenance activities could occur during ISFSI 

17 operation, which may include ground-disturbing activities. However, impacts on any aquatic 

18 features would be minimal. Stormwater control measures, which would be required to comply 

19 with NPDES permitting, would also minimize the flow of disturbed soils or other contaminants 

20 into aquatic features. In addition, the plant operator would likely implement best management 

21 practices to minimize erosion and sedimentation and control any runoff, spills, or leaks (NRC 

22 2005a, 2003). For example, the EAs for the Calvert Cliffs, Humboldt Bay, and Diablo Canyon 

23 ISFSIs did not identify any significant impacts on aquatic resources during normal operations of 

24 an onsite dry cask storage facility (NRC 2003, 2005a, 2012a). Consequently, given that ISFSIs 

25 do not require water for cooling and the facility would produce minimal gaseous or liquid 

26 effluents, impacts on aquatic resources from the operation of ISFSIs during short-term storage 

27 would not have noticeable impacts on aquatic resources.

28 4.10.1.3 Conclusion

29 Given that the impacts associated with the operation of spent fuel pools would likely be bounded 

30 by the impacts analyzed in the License Renewal GEIS due to the lower withdrawal rates, lower 

31 discharge rate, smaller thermal plume, and lower heat content for a spent fuel pool compared to 

32 an operating reactor with closed-cycle cooling, the NRC concludes that impacts on aquatic 

33 resources from the operation of spent fuel pools during short-term storage would be minimal. In 

34 addition, the impacts from operation of at-reactor ISFSIs would be minimal because ISFSIs do 

35 not require water for cooling, produce minimal gaseous or liquid effluents, and ground-disturbing 

36 activities for ISFSI maintenance would have minimal impacts on aquatic ecology. Therefore the 

37 NRC concludes that the potential environmental impacts on aquatic resources would be SMALL 

38 during the short-term storage timeframe. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-42 September 2013

1 4.10.2 Long-Term Storage

2 Routine maintenance and monitoring of the ISFSIs would continue during long-term storage. 

3 Likewise, the impacts from routine maintenance and monitoring of ISFSIs during the short-term 

4 storage timeframe would continue during the long-term storage timeframe and would remain the 

5 same.

6 Due to the relatively small construction footprint of a DTS, a DTS could likely be sited and 

7 constructed on land near existing facilities, on previously disturbed ground, and away from 

8 sensitive aquatic features. In addition, the replacement DTS and ISFSI facilities could likely be 

9 sited on previously disturbed ground away from sensitive aquatic features. For example, the 

10 NRC did not identify any significant impacts on aquatic resources from construction of the 

11 Humboldt Bay ISFSI in part due to the fact that ground-disturbing activities would be limited to 

12 0.4 ha) and the ISFSI was not located near any aquatic features (NRC 2005a). Similarly, the 

13 construction footprint for the Diablo Canyon ISFSI was limited to 2 ha and was sited in a 

14 previously disturbed area that did not contain any sensitive aquatic features (NRC 2003). In 

15 addition, the NRC (2003, 2005a) indicated that controls would be in place to minimize the flow 

16 of any site runoff, spillage, and leaks into sensitive aquatic features. For example, stormwater

17 control measures, which would be required to comply with NPDES permitting, would minimize 

18 the flow of disturbed soils or other contaminates into aquatic features. The plant operator could 

19 also implement best management practices to minimize erosion and sedimentation.

20 ISFSIs and DTSs do not require water for cooling and produce minimal gaseous or liquid 

21 effluents. In addition, replacement ISFSIs and DTSs could likely be sited on previously 

22 disturbed ground away from sensitive aquatic features. The older ISFSIs and DTSs would be 

23 demolished and the land reclaimed. Therefore, the NRC concludes that impacts on aquatic 

24 resources during long-term storage would be SMALL.

25 4.10.3 Indefinite Storage

26 During indefinite storage, the activities that occur during long-term storage would continue and 

27 the ISFSIs and DTSs would be replaced every 100 years. Therefore the impacts that occurred 

28 during long-term storage would continue. The NRC concluded in Section 4.10.2 that impacts on

29 aquatic resources would be SMALL because ISFSIs do not require water for cooling and would 

30 have minimal impacts on aquatic resources. In addition, replacement of the ISFSIs and DTSs 

31 would occur near existing facilities and could likely be sited on previously disturbed ground 

32 away from sensitive aquatic features. The older ISFSIs and DTSs would be demolished and the 

33 land reclaimed. Therefore, the NRC concludes that the impacts on aquatic resources from 

34 indefinite storage of spent fuel in at-reactor ISFSIs would be SMALL.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-43 Draft NUREG‒2157

1 4.11 Special Status Species and Habitat

2 This section describes potential environmental impacts on special status species and their 

3 habitats caused by the continued storage of spent fuel in spent fuel pools and at-reactor ISFSIs. 

4 Special status species and habitats may include those identified in Section 4.9 for terrestrial 

5 resources and Section 4.10 for aquatic resources.

6 4.11.1 Short-Term Storage

7 Impacts on Federally listed species, critical habitat, and essential fish habitat during short-term 

8 storage may occur from spent fuel pool or ISFSI operations.

9 4.11.1.1 Spent Fuel Pools

10 Given that Federally listed species, critical habitat, and essential fish habitat may be affected by 

11 operation of cooling systems for nuclear power plants, special status species and habitats could 

12 also be affected by the operation of cooling systems for spent fuel pools during the short-term 

13 storage timeframe. Possible impacts on Federally listed species, critical habitat, and essential 

14 fish habitat would be similar to those described in Sections 4.9.1 and 4.10.1 for terrestrial and 

15 aquatic resources.

16 Prior to entering the short-term storage timeframe, if listed species or critical habitat may occur 

17 near the nuclear power plant site and the operation of the cooling system (which includes the 

18 spent fuel pool cooling system) may affect those species, the NRC would evaluate those 

19 impacts by preparing a Biological Assessment. The U.S. Fish and Wildlife Service (FWS) or 

20 National Marine Fisheries Service (NMFS) would provide its evaluation of the impacts in a 

21 Biological Opinion. The Biological Opinion may also require monitoring programs or mitigation

22 measures to minimize impacts on listed species and their habitats. If the evaluation indicates 

23 that listed species would result in a “take,” or would “harass, harm, pursue, hunt, shoot, wound, 

24 kill, trap, capture, or collect, or attempt to engage in any such conduct,” the biological opinion

25 could include an incidental take statement. The incidental take statement would specify the 

26 allowable number of “takes” that could occur during a specified period. If the number of takes 

27 exceeds the incidental take statement, the NRC would be required to reinitiate consultation with 

28 the FWS or NMFS. For example, the Oyster Creek nuclear plant exceeded its incidental take 

29 limit established by the NMFS for Kemp’s ridley sea turtles. The NRC, therefore, was required 

30 to reinitiate Endangered Species Act (ESA) Section 7 consultation with NMFS, which included 

31 the reevaluation of the impacts on the Kemp’s ridley sea turtles and potential mitigation 

32 measures (NRC 2013a). Thus, the ESA Section 7 consultation process would help identify any 

33 impacts on listed species, potentially require monitoring and mitigation to minimize impacts on

34 listed species, and ensure that any takes that occur as a result of cooling-system operations are 

35 within the bounds of the incidental take statement. Additional details and guidance regarding 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-44 September 2013

1 the ESA Section 7 consultation process are provided 50 CFR Part 402 and in the Endangered 

2 Species Consultation Handbook (FWS/NMFS 1998).

3 Identified species and critical habitats would continue to be protected under the ESA during the 

4 short-term storage timeframe. For example, for nuclear power plants with a Biological Opinion, 

5 the NRC would either need to continue to require the licensee to abide by the conditions 

6 described in the Biological Opinion or reinitiate consultation with the FWS and NMFS if there is 

7 a significant change in the plant parameters listed in the Biological Opinion, which would include 

8 parameters associated with the spent fuel pool cooling system, that could affect listed species 

9 or critical habitats in a manner or to an extent no previously considered. The most likely change 

10 in a plant parameter during short-term storage would be a decrease in water-withdrawal and 

11 discharge rates due to the lower water demands to operate a spent fuel pool than to operate a 

12 nuclear power reactor. Impacts on special status species and habitats would likely decrease 

13 due to less impingement, entrainment, and thermal impacts associated with lower withdrawal 

14 and discharge rates.

15 Listed species that are not included in a Biological Opinion would continue to be protected 

16 under the ESA. If operation of the spent fuel pool cooling system resulted in a “take” of a listed

17 species not covered under a Biological Opinion, the NRC would be required to initiate ESA 

18 consultation with the FWS or NMFS. The official lists of ESA-listed species are regulary

19 updated by the FWS and NMFS. Species may be added to the list or delisted. If new species 

20 were listed under the ESA, the NRC would evaluate any potential impacts on those species at 

21 all NRC-licensed facilities at the time of listing. Therefore, if a new species was listed after the 

22 licensed life of the associated nuclear reactor, the NRC would coordinate with the FWS and 

23 NMFS to determine if the newly listed species could occur near a spent fuel pool. Further, NRC 

24 would initiate ESA Section 7 consultation if operation of a spent fuel pool could adversely affect 

25 the newly listed species. 

26 The NRC is required under the Magnuson-Stevens Fishery Conservation and Management Act, 

27 as amended, to consult with NMFS if operation of the cooling system could adversely impact 

28 essential fish habitat. As part of this consultation, NRC would assess the occurrence of and 

29 adverse impacts to essential fish habitat in an Essential Fish Habitat Assessment. The 

30 implementing regulations for the Magnuson-Stevens Fishery Conservation and Management 

31 Act (50 CFR 600) describe additional details regarding the steps involved in Essential Fish 

32 Habitat consultation.

33 In addition, coordination with other Federal and State natural resource agencies would further 

34 ensure that licensees take appropriate steps to avoid or mitigate impacts on special status 

35 species, habitats of conservation concern, and other protected species and habitats, such as 

36 those protected under the Marine Mammal Protection Act, the Migratory Bird Treaty Act, and the 

37 Bald and Golden Eagle Protection Act. These consultations would likely result in avoidance or 

38 mitigation measures that would minimize impacts on protected species and habitats.
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September 2013 4-45 Draft NUREG‒2157

1 4.11.1.2 ISFSIs

2 Impacts from the operation of ISFSIs on special status species and habitats would be similar to 

3 those described above for terrestrial and aquatic resources, which would be minimal due to the 

4 small size of the ISFSIs and because no water is required for cooling. For example, the NRC’s 

5 EAs for the Humboldt Bay and Diablo Canyon ISFSIs did not identify any impacts on special 

6 status species during normal operations of at-reactor ISFSIs (NRC 2003, 2005a).

7 As described in Section 4.11.1.1, the NRC is required to consult with NMFS for actions that may 

8 affect essential fish habitat or marine mammals. The NRC assumes that these consultations 

9 would result in avoidance or mitigation measures that would minimize impacts on protected 

10 aquatic species and habitats. However, it is unlikely that ISFSIs would affect essential fish 

11 habitat or marine mammals because they are built on land and do not require water for cooling. 

12 In the unlikely event that an ISFSI could affect essential fish habitat, the NRC would consult with 

13 NMFS. In addition, coordination with State natural resource agencies would further ensure that 

14 plant operators take appropriate steps to avoid or mitigate impacts on State-listed species, 

15 habitats of conservation concern, and other protected species and habitats. 

16 4.11.1.3 Conclusion

17 As described above, the ESA has several requirements that would help ensure protection of 

18 listed species and critical habitat during short-term storage. For spent fuel pools, the impacts 

19 would be determined as part of ESA Section 7 consultation. In complying with the ESA, the 

20 NRC would evaluate the impacts from spent fuel pool construction, operations, and 

21 decommissioning in a site-specific review before the spent fuel pool is initially constructed, if the 

22 cooling-system parameters change, or if a “take” occurs for a species not included in an 

23 incidental take statement, as described in Section 4.11.1.1. The NRC would characterize the 

24 effects of spent fuel pools to listed species in terms of its ESA findings of (1) no effect, (2) not 

25 likely to adversely affect, (3) likely to adversely affect, or (4) is likely to jeopardize the listed 

26 species or adversely modify the designated critical habitat of Federally listed species 

27 populations or their critical habitats. Similarly, in complying with the Magnuson-Stevens Act 

28 Fishery Conservation and Management Act, the NRC would report the effects of spent fuel 

29 pools in terms of the Act’s required findings of (1) no adverse impact, (2) minimal adverse 

30 impact, or (3) substantial adverse impact on the essential habitat of Federally managed fish 

31 populations. Impacts to non-listed special status species, such as State-listed species, would 

32 be less than that experienced during the licensed life for operation of the reactor due to the 

33 smaller size of the spent fuel pool and lower water demands. 

34 For ISFSIs, given the minimal size and ability to site ISFSIs away from sensitive ecological 

35 resources, the NRC concludes that ISFSIs are not likely to adversely affect listed species, 

36 critical habitat, State-listed species, marine mammals, migratory birds, and bald and golden 

37 eagles, and would have no adverse impact on essential fish habitat. In the unlikely situation 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-46 September 2013

1 that the continued operation of an ISFSI could affect listed species, critical habitat, or essential 

2 fish habitat, the NRC would be required to initiate ESA Section 7 consultation with the NMFS or 

3 FWS (for listed species or critical habitat) and initiate EFH consultation with NMFS (for essential 

4 fish habitat).

5 4.11.2 Long-Term Storage

6 In addition to routine maintenance and monitoring of ISFSIs, impacts from the construction of a 

7 DTS and replacement of the DTS and ISFSIs on special status species and habitats would be 

8 similar to those described in Sections 4.9.2 and 4.10.2, which would be minimal due to the small 

9 size of the ISFSIs and DTSs and because no water is required for cooling. The same 

10 consultations and any associated mitigation requirements described in Section 4.11.1, would

11 apply to construction of a DTS and replacement of the DTS and ISFSI during long-term storage. 

12 The NRC assumes that the ISFSIs and DTSs could be sited to avoid listed species and critical 

13 habitat due to the small size of the construction footprint and sufficient amount of previously 

14 disturbed areas on most nuclear power plant sites (NRC 2003, 2005a). For example, the EAs 

15 for the Humboldt Bay and Diablo Canyon ISFSIs did not identify any significant impacts on

16 special status species from construction and normal operations of the at-reactor ISFSIs (NRC 

17 2003, 2005a). In addition, coordination with Federal and State natural resource agencies would 

18 further ensure that plant operators take appropriate steps to avoid or mitigate impacts on State19 listed species, habitats of conservation concern, and other protected species and habitats. 

20 Therefore, the NRC concludes that construction of a DTS and the replacement of the DTS and 

21 ISFSI that would occur during the long-term storage timeframe are not likely to adversely affect 

22 listed species, critical habitat, State-listed species, marine mammals, migratory birds, and bald 

23 and golden eagles and would have no adverse impact on essential fish habitat. In the unlikely 

24 situation that the ISFSI could affect listed species or critical habitat, the NRC would be required 

25 to initiate ESA Section 7 consultation with the NMFS or FWS (for listed species or critical 

26 habitat) and initiate EFH consultation with NMFS (for essential fish habitat).

27 4.11.3 Indefinite Storage

28 The impacts of indefinite storage on special status species and habitats would be minimal and 

29 similar to those described in Sections 4.9.3 and 4.10.3. The same consultations and any 

30 associated mitigation requirements described in Section 4.11.1 would apply to the construction 

31 of the DTS and replacement of the DTS and ISFSI facilities during indefinite storage. For the 

32 reasons described in Section 4.11.2, the NRC concludes that the replacement of the DTS and 

33 ISFSI that would occur during the indefinite storage timeframe are not likely to adversely affect 

34 listed species, critical habitat, State-listed species, marine mammals, migratory birds, and bald 

35 and golden eagles and would have no adverse impact on essential fish habitat. In the unlikely 

36 situation that the ISFSI could affect listed species or critical habitat, the NRC would be required 

37 to initiate Section 7 ESA consultation with the NMFS or FWS (for listed species or critical 

38 habitat) and initiate EFH consultation with NMFS (for essential fish habitat).
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-47 Draft NUREG‒2157

1 4.12 Historic and Cultural Resources

2 This section describes potential impacts on historic and cultural resources caused by the 

3 continued storage of spent fuel in spent fuel pools and at-reactor ISFSIs.

4 The NRC is considering impacts on historic and cultural resources in this draft GEIS through 

5 implementation of its NEPA requirements in 10 CFR Part 51. This rulemaking is not a licensing 

6 action; it does not authorize the initial or continued operation of any nuclear power plant, and it 

7 does not authorize storage of spent fuel. Because the Waste Confidence GEIS does not 

8 identify specific sites for NRC licensing actions, a NHPA Section 106 review has not been 

9 performed. However, the NRC complies with NHPA Section 106 and the implementing 

10 provisions in 36 CFR Part 800 in site-specific licensing actions. As discussed in Section 3.11, 

11 identification of historic properties, adverse effects, and potential resolution of adverse effects 

12 would be conducted through consultation and application of the National Register of Historic 

13 Places criteria in 36 CFR 60.4. This information would also be evaluated to determine the 

14 significance of potential impacts on historic and cultural resources in the NRC’s environmental 

15 review documents.

16 As discussed in Section 3.11, most nuclear power plant sites are located in areas along 

17 waterways that people tended to settle near or travel along, so there is a potential for historic 

18 and cultural resources to be present. Waterways provided freshwater, the most abundant food 

19 sources, transportation, and trade routes. As a result, prehistoric era archaeological sites and 

20 historic-era sites tend to be found along these waterways (NRC 2013a). As part of the recent 

21 License Renewal GEIS update, the NRC reviewed historic and cultural resource reviews that 

22 were performed for 40 license renewals. For sites that had conducted field investigations, on 

23 average, the number of historic and cultural resources present were 35 per site (NRC 2013a). 

24 Many applicants conducted surveys to identify historic and cultural resources for their site25 specific reactor license renewal and new reactor license applications, and they have developed 

26 and implemented historic and cultural resource management plans and procedures that protect 

27 known historic and cultural resources and address inadvertent discoveries. However, some 

28 licensees do not have management plans or procedures.

29 As discussed in Section 1.8, the NRC assumes that at-reactor ISFSIs are constructed onsite 

30 under a general or site-specific license during the term of reactor operations (including license 

31 renewal). A general license authorizes a power reactor licensee to build an at-reactor ISFSI 

32 and store spent fuel onsite in dry storage casks that have received a certificate of compliance. 

33 Under the general license, the authority to use a storage cask is tied to the cask’s certificate of 

34 compliance term, which is issued to the cask vendor through an NRC rulemaking process (NRC 

35 1996). The NRC rulemaking for certification of the cask design involves both safety and 

36 environmental reviews. The EA supporting the certification of the cask design rulemaking 

37 generally assesses the environmental impacts associated with the use of this cask design at 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-48 September 2013

1 any power reactor site. However, the general license provisions do not require a site-specific 

2 environmental analysis before constructing the ISFSI; therefore, there is no Section 106 review.

3 For site-specific licensing actions that are not under the general license described previously,

4 (new reactor licensing, reactor license renewal, away-from-reactor ISFSIs, and specifically 

5 licensed at-reactor ISFSIs), the NRC complies with Section 106 requirements to consider the 

6 effects of its undertaking on historic properties. If adverse effects on historic properties are 

7 identified, appropriate mitigation can be developed through consultation with the State Historic 

8 Preservation Officer, tribal representatives, and other interested parties. This information is also 

9 used to determine the potential impact on historic and cultural resources for the proposed 

10 specific licensing action. Issuance of a site-specific license could be granted at the conclusion 

11 of the NRC’s safety review, environmental review, and compliance with NHPA Section 106 

12 requirements.

13 4.12.1 Short-Term Storage

14 During the short-term storage timeframe, the spent fuel pool would remain in operation until the 

15 transfer of the spent fuel from the pool to an at-reactor ISFSI. As discussed in Section 3.11, 

16 ground-disturbing activities occurred during initial nuclear power plant construction, and much of 

17 the land within and immediately surrounding the power block was extensively disturbed. This 

18 activity would have eliminated any potential for historic and cultural resources to be present in 

19 these portions of the power plant site. Continued operations and maintenance activities 

20 associated with spent fuel pools would not affect historic and cultural resources because spent 

21 fuel pools are located in the fuel building within the power block and most resources would have 

22 been removed during initial plant construction.

23 As discussed in Section 3.11, less-developed or disturbed portions of a power plant site, 

24 including the areas that were used to support construction of the at-reactor ISFSI, could contain 

25 historic and cultural resources. For purposes of evaluating the impacts of continued storage in 

26 this draft GEIS, the NRC assumes that at-reactor ISFSIs are constructed during the period of 

27 reactor operations. Impacts associated with construction of an at-reactor ISFSI have already 

28 occurred and are not considered in the short-term storage timeframe. Routine maintenance and 

29 continued operations of an at-reactor ISFSI are not expected to affect historic and cultural 

30 resources because no ground-disturbing activities are anticipated. If ground-disturbing activities 

31 occur as a result of continued operations or maintenance, impacts could be mitigated if the 

32 licensee has previously identified historic and cultural resources and has management plans 

33 and protective procedures in place.

34 Because no ground-disturbing activities are anticipated during the short-term storage timeframe, 

35 the impacts associated with continued operations and maintenance of the at-reactor ISFSI 

36 would be SMALL. Therefore, there would be no impacts on historic and cultural resources. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-49 Draft NUREG‒2157

1 4.12.2 Long-Term Storage

2 In addition to routine maintenance and monitoring, the NRC assumes that an at-reactor ISFSI 

3 would be replaced, which will require the construction and operation of a DTS. Further, the 

4 NRC assumes that the DTS is replaced once during the long-term storage timeframe. As 

5 discussed in Section 1.8.3 of this draft GEIS, the NRC assumes that by the end of the short6 term storage timeframe a licensee with a general at-reactor ISFSI license will either terminate its 

7 10 CFR Part 50 or 52 license and receive a site-specific license under 10 CFR Part 72 or 

8 receive Commission approval under 10 CFR 50.82(a)(3) or 52.110(c) to continue 

9 decommissioning under its 10 CFR Part 50 or 52 license.

10 NRC authorization to construct and operate a DTS and replace an at-reactor ISFSI and DTS 

11 would constitute Federal actions under NEPA and would be undertakings under the NHPA. In

12 accordance with 36 CFR Part 800, a Section 106 review would be conducted for each 

13 undertaking to determine whether historic properties are present in the area of potential effect, 

14 and if so, whether these actions would result in any adverse effects on these properties. 

15 License applicants are required to provide historic and cultural resource information in their 

16 Environmental Reports. To prepare these assessments, applicants conduct cultural resource 

17 surveys of any areas of proposed development to identify and record historic and cultural 

18 resources. Impacts on historic and cultural resources would vary depending on what resources 

19 are present. Resolution of adverse effects, if any, should be concluded prior to the closure of 

20 the Section 106 process.

21 Impacts from continued operations and routine maintenance of the at-reactor ISFSI and DTS 

22 during long-term storage would be similar to those described in the short-term storage 

23 timeframe. The impacts would be SMALL because there would be no ground-disturbing 

24 activities as a result of the continued operations and routine maintenance.

25 The replacement of the at-reactor ISFSI and initial and replacement DTS would require a site26 specific environmental review and compliance with NHPA requirements before making a 

27 decision on the licensing action. The NRC assumes that the replacement of the at-reactor 

28 ISFSI and initial and replacement DTS will be constructed on land near the existing facilities. As 

29 discussed in Section 3.11, ground-disturbing activities occurred during initial nuclear power 

30 plant construction, and much of the land within and immediately surrounding the power block 

31 was extensively disturbed. This activity would have eliminated any potential for historic and 

32 cultural resources to be present in these portions of the power plant site. However, less33 developed or disturbed portions of a power plant site, including areas that were used to support 

34 construction of the at-reactor ISFSI, could contain historic and cultural resources. Given the 

35 minimal size of the replacement ISFSI and initial and replacement DTS, and the large land 

36 areas at nuclear power plant sites, licensees should be able to locate these facilities away from 

37 historic and cultural resources. Potential adverse effects on historic properties or impacts on

38 historic and cultural resources could also be minimized through development of agreements, 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-50 September 2013

1 license conditions, and implementation of the licensee’s historic and cultural resource 

2 management plans and procedures to protect known historic and cultural resources and 

3 address inadvertent discoveries during construction of the replacement at-reactor ISFSI and 

4 initial and replacement DTS.

5 However, it may not be possible to avoid adverse effects on historic properties or impacts on

6 historic and cultural resources. The magnitude of adverse effect on historic properties and 

7 impact on historic and cultural resources largely depends on what resources are present, the 

8 extent of proposed land disturbance, whether the area has been previously surveyed to identify 

9 historic and cultural resources, and whether the licensee has management plans and 

10 procedures that are protective of historic and cultural resources. The site-specific 

11 environmental review and compliance with the NHPA process could identify historic properties, 

12 adverse effects and potentially resolve adverse effects on historic properties and impacts on

13 other historic and cultural resources. Therefore, the potential impacts on historic and cultural 

14 resources could be SMALL, MODERATE, or LARGE depending on site-specific factors.

15 4.12.3 Indefinite Storage

16 This section describes the potential environmental impacts on historic and cultural resources if a 

17 repository is not available to accept spent fuel. For this analysis, the NRC assumes that spent 

18 fuel would continue to be stored onsite indefinitely. During this timeframe, maintenance and 

19 monitoring would continue and the at-reactor ISFSI and DTS would be replaced every 

20 100 years. If replacement activities occur in previously disturbed areas (i.e., in areas that have 

21 previously experienced construction impacts) then impacts on historic and cultural resources 

22 would be SMALL. Therefore, historic properties would not be adversely affected. If 

23 construction activities occur in previously undisturbed areas or avoidance is not possible, then 

24 there could be adverse effects on historic properties, and impacts on historic and cultural 

25 resources could be SMALL, MODERATE, or LARGE depending on site-specific factors.

26 4.13 Noise

27 This section describes potential noise impacts caused by the continued storage of spent fuel in 

28 spent fuel pools and at-reactor ISFSIs.

29 4.13.1 Short-Term Storage

30 During short-term storage, spent fuel pool systems would remain in operation to ensure 

31 adequate cooling prior to the transfer of spent fuel from the pools to an at-reactor ISFSI. Most 

32 noise would be generated when spent fuel is transferred from the spent fuel pool to the ISFSI. 

33 Once reactor operations cease, there would be less noise generated because some of the 

34 noise-generating equipment and activities would either cease or operate at lower levels. 

35 Therefore, short-term storage noise levels would be less than reactor operation noise levels. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-51 Draft NUREG‒2157

1 The License Renewal GEIS (NRC 2013a) analyzed the environmental impacts associated with 

2 continued reactor operations during the license term of a nuclear power plant. Facility noise 

3 levels at operating reactor sites may sometimes exceed 55 dB(A) over a 24-hour period, which 

4 is the threshold EPA identified to protect residential areas against excess noise during outdoor 

5 activities (NRC 2013a; EPA 1974). As discussed in Section 3.12, primary factors that influence 

6 impact magnitude are the noise level of the source and the proximity of the source to the 

7 receptor. Proximity matters because noise levels decrease as distance from the source 

8 increases. For point sources like stationary equipment, noise is reduced by about 6 dB(A) for 

9 each doubling of distance from the source, and for a line source, like a road, noise is reduced by 

10 3 dB(A) per doubling of the distance (Washington State Department of Transportation 2013). 

11 As stated in the License Renewal GEIS (NRC 2013a), in most cases, the sources of noise are 

12 far enough away from sensitive receptors that the noise is attenuated to nearly ambient levels 

13 and is scarcely noticeable. However, in some cases noise from reactor operations can be 

14 detected relatively close to the site boundary and create a minor nuisance.

15 As described earlier in this section, noise levels would be lower once reactor operations cease. 

16 Noise sources associated with spent fuel pool storage include water cooling-system equipment, 

17 spent fuel handling equipment, and in some cases vehicles to transport spent fuel from pools to 

18 dry cask storage pads. Some of the noise from equipment associated with spent fuel pool 

19 storage is attenuated because the activities occur inside a building, which functions as a noise 

20 barrier. Spent fuel handling and transfer would be infrequent, so the noise generated from 

21 these activities would also occur infrequently. Typically, pool storage sites produce no noise 

22 impacts on the local environment (NRC 2004b).

23 As described in Section 3.12, spent fuel casks resting on concrete pads are essentially passive, 

24 without any sources generating noise. Noise from routine maintenance and monitoring as well 

25 as from ancillary activities such as operation of the administration buildings would be minimal.

26 Even in rare cases where an independently operating spent fuel pool causes noise impacts that 

27 exceed the EPA-recommended threshold for outdoor noise, licensees are usually able to make 

28 engineering changes to address the problem. For example, at the Maine Yankee nuclear power 

29 plant the licensee set up the pool storage operations to operate independently from the reactor, 

30 which was being decommissioned. The fans used as part of the spent pool cooling-system 

31 generated noise levels up to 107 dB, which attenuated to 50 dB less than 1.6 km (1 mi) away 

32 (NRC 2002b). This noise level exceeded the 55 dB(A) threshold recommended by the EPA for 

33 protection against outdoor activity interference and annoyance. Nearby residents complained to 

34 the plant staff about the noise level, and the licensee made engineering changes to the fans that 

35 were causing the noise and the issue was resolved.

36 In conclusion, the operation noise levels, duration, and distance between the noise sources and 

37 receptors generally do not produce noise impacts noticeable to the surrounding community. In 

38 certain cases, such as Maine Yankee spent fuel pool island, potential noise impacts on 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-52 September 2013

1 receptors closest to the site property line can experience unmitigated noise levels that exceed 

2 EPA-recommended noise levels. However, noticeable noise levels are generally not expected 

3 and would be limited to the nearest receptors. Therefore, the NRC concludes that the overall 

4 impact from noise during short-term storage would be SMALL.

5 4.13.2 Long-Term Storage

6 In addition to routine maintenance and monitoring, the NRC assumes that long-term storage 

7 would include the construction, operation, and replacement of a DTS and the replacement of the 

8 ISFSI. Construction of a DTS would generate higher noise levels than DTS operations. The 

9 NRC assumes that DTS construction would take 1–2 years. Construction equipment would be 

10 used to grade and level the site, excavate the facility foundation, handle building materials, and 

11 build the facility. Construction equipment generates noise levels over 90 dB(A) (at a reference 

12 distance of 15 m [50 ft] from the source) (NRC 2002b). At distances greater than about 1.6 km 

13 (1 mi), expected maximum noise levels from construction equipment would be reduced to about 

14 55 dB(A), which is the EPA-recommended level for protection in residential areas against 

15 outdoor activity interference and annoyance (NRC 2002b).

16 During operation of the DTS, some activities would be conducted inside the building, which 

17 functions as a noise barrier. Spent fuel transfer between the storage pad and the DTS would be 

18 infrequent. The NRC expects noise levels from this transfer of spent fuel to be no more than the 

19 noise level generated transferring spent fuel from the pool to the dry pad, as described in 

20 Section 4.13.1. In addition, some of the reactor and spent fuel pool storage noise sources 

21 present during short-term storage (such as the cooling towers and associated equipment) would 

22 not be present during long-term storage.

23 The NRC assumes that the at-reactor ISFSI (i.e., concrete storage casks and pads) and the 

24 DTS would be replaced within the 100-year timeframe. Similar to the DTS construction, ISFSI 

25 and DTS replacement uses construction equipment, which can generate noise levels over 

26 90 dB(A). The noise levels exceed the EPA-recommended level for protection against outdoor 

27 activity interference and annoyance (NRC 2002b). However, distance from the source will 

28 eventually reduce the noise level to below the EPA-recommended level for protection against 

29 outdoor activity interference and annoyance.

30 Construction and replacement of the DTS, although temporary and representing a small portion 

31 of the overall long-term storage timeframe, would generate noise levels that exceed EPA32 recommended noise levels. Operational noise levels would not produce noise impacts 

33 noticeable to the surrounding community. For some activities (e.g., replacement of the DTS 

34 and ISFSI facilities), potential noise impacts on receptors closest to the site property line can 

35 experience unmitigated noise levels that exceed EPA-recommended noise levels. However, 

36 these activities are temporary and noticeable noise levels would be limited to the nearest 

37 receptors. Therefore, the NRC concludes that the overall impact from noise during long-term 

38 storage would be SMALL.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-53 Draft NUREG‒2157

1 4.13.3 Indefinite Storage

2 This section describes the noise impacts in the event a repository is not available to accept 

3 spent fuel and the spent fuel must be stored indefinitely in ISFSIs. Impacts from indefinite 

4 storage would be similar to those described for the long-term storage timeframe. NRC does not 

5 anticipate that indefinite storage in an ISFSI would generate any new or additional noise in 

6 comparison with the noise impacts described for the long-term storage timeframe. Therefore, 

7 the NRC concludes that the overall impact from noise during indefinite storage would be 

8 SMALL.

9 4.14 Aesthetics

10 This section describes potential impacts on aesthetic resources caused by continued storage of 

11 spent fuel in spent fuel pools and at-reactor ISFSIs.

12 4.14.1 Short-Term Storage

13 No changes to nuclear power plant structures will be required for continued operation of the 

14 spent fuel pool during continued storage, including routine maintenance and monitoring. 

15 In the License Renewal GEIS, the NRC determined that the aesthetic impacts associated with 

16 continued operation of a nuclear power plant, which included the continued operation of the 

17 spent fuel pool, were SMALL because the existing visual profiles of nuclear power plants were 

18 not expected to change during the license renewal term (NRC 2013a). Therefore, the NRC 

19 concludes that the potential impacts from the short-term continued operation of the spent fuel 

20 pool would be of minor significance to aesthetic resources.

21 For at-reactor ISFSIs, NRC evaluations of existing ISFSIs have found the aesthetic impacts to 

22 be SMALL. For example, the NRC found that continued operation of the Calvert Cliffs ISFSI

23 would have a SMALL impact on aesthetic resources in part because there would be no new 

24 construction at the facility (NRC 2012a). Similarly for Humboldt Bay, the NRC determined that 

25 the aesthetic impact would be minimal (NRC 2005a), because the Humboldt Bay ISFSI is an 

26 in-ground vault with a low visual profile. Given that the NRC assumes that all ISFSIs are 

27 constructed during the nuclear power reactor’s licensed life for operation, the visual profile of 

28 at-reactor ISFSIs during short-term storage is expected to be the same after the permanent 

29 cessation of reactor operations. The NRC therefore believes that potential impacts from short30 term continued storage in at-reactor ISFSIs would be of minor significance to aesthetic 

31 resources.

32 This assessment of visual impacts depends in part on the degree of public interest and concern 

33 about potential changes to the existing scenic quality. However, because no changes to the 

34 visual profile are likely to occur as a result of the continued operation and maintenance of the 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-54 September 2013

1 existing spent fuel pool and ISFSI, the NRC concludes that the impacts from short-term storage 

2 of spent fuel on aesthetics would be SMALL.

3 4.14.2 Long-Term Storage

4 As discussed in the previous section, routine maintenance is not expected to have an impact on 

5 aesthetic resources. The NRC assumes that a DTS would need to be constructed during the 

6 long-term storage timeframe. Construction and operation of a DTS would have limited impacts 

7 on aesthetic resources. A DTS (approximately 26 ft × 18 ft and about 47 ft tall) is likely to have 

8 a larger visual profile than other ISFSI structures; however, it would not be expected to provide 

9 a significant visual contrast to the surrounding landscape. There would be temporarily adverse 

10 impacts on aesthetic resources during construction of the DTS, resulting from the presence and 

11 operation of the construction equipment used to build the facility. However, because a DTS is a 

12 relatively small facility (e.g., compared to a nuclear power plant) and many of the internal 

13 components of the facility would be prefabricated, the construction of a DTS would take less 

14 time and equipment to build, and it would have a minimal impact on aesthetic resources.

15 Replacement of the ISFSIs and DTSs within the 100-year timeframe would occur on land 

16 immediately adjacent to existing facilities. The NRC assumes that the overall land disturbed, 

17 and hence the visual profile of the facility, would not increase because the old ISFSIs and DTSs 

18 would be demolished and the land reclaimed. Impacts on aesthetic resources would likely 

19 temporarily increase during the period of construction of the new facilities and demolition of the 

20 old, when the most visible features are likely to be equipment associated with cask handling. 

21 Aesthetic impacts from such equipment and its operation would be minimal.

22 Because continued operation of the ISFSI, construction and operation of the DTS, and 

23 replacement of the ISFSIs and DTSs would not significantly alter the landscape of an at-reactor 

24 ISFSI, the NRC concludes that the potential environmental impacts on aesthetic resources 

25 during long-term storage would be SMALL.

26 4.14.3 Indefinite Storage

27 If a repository is not available, current practices of using at-reactor ISFSIs are expected to 

28 continue indefinitely. At the end of each 100-year cycle, the previously reclaimed land would be 

29 used to construct the replacement ISFSIs and DTSs. The potential activities and their impacts 

30 would be the same as those described in Section 4.14.2 for long-term storage, but would 

31 continue to occur repeatedly. Therefore, the NRC concludes that the indefinite onsite storage of 

32 spent fuel would result in SMALL impacts on aesthetic resources.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-55 Draft NUREG‒2157

1 4.15 Waste Management

2 This section describes potential environmental impacts from low-level radioactive waste (LLW), 

3 mixed waste, and nonradioactive waste management and disposal caused by the continued 

4 storage of spent fuel in spent fuel pools and at-reactor ISFSIs.

5 Section 3.14 identified the types of waste generated by continued storage of spent fuel, 

6 including LLW, mixed waste, hazardous waste, and nonradioactive, nonhazardous waste. 

7 Because the NRC expects hazardous and nonradioactive, nonhazardous waste to be generated 

8 in small amounts, these waste types are discussed together in this section as nonradioactive 

9 waste.

10 After reactor operations cease, most waste-generating activities would also cease, except for 

11 those associated with continued storage. Because there would be fewer waste-generating 

12 activities during continued storage, the amount of waste generated would be less than that 

13 estimated for reactor license renewal, and consequently the impacts in the License Renewal 

14 GEIS would bound the impacts for waste during continued storage.

15 Impacts from the transportation of waste are discussed in Section 4.16. The public and 

16 occupational health impacts associated with at-reactor radioactive waste-management activities 

17 at nuclear plants are addressed in Section 4.17.

18 4.15.1 Short-Term Storage

19 The impacts associated with the management and disposal of LLW, mixed waste, and 

20 nonradioactive waste during short-term continued storage are discussed in the following 

21 sections.

22 4.15.1.1 Low-Level Radioactive Waste

23 The continued operation of a spent fuel pool would continue to generate minimal amounts of 

24 LLW such as wet wastes from processing and recycling contaminated liquids. In the License 

25 Renewal GEIS, the environmental impacts associated with the management and disposal of 

26 LLW during normal reactor operation were determined to be SMALL (NRC 2013a). The NRC 

27 concluded impacts from LLW would be SMALL because of the regulatory controls in place, low 

28 public dose being achieved, and reasonable assurance that sufficient LLW disposal capacity will 

29 be made available when needed for facilities to be decommissioned.

30 The amount of LLW generated from the operation and maintenance of an at-reactor ISFSI 

31 during short-term storage is expected to be minimal. For example, in the Calvert Cliffs ISFSI 

32 renewal EA (NRC 2012a), the NRC determined that the impacts from waste management would 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-56 September 2013

1 be SMALL, mainly because of the small quantities of LLW being generated and the fact that 

2 those wastes would be handled and disposed of according to regulatory requirements.

3 Comprehensive regulatory controls, facilities, and procedures are in place at operating reactors 

4 to ensure that the LLW is properly handled and stored and that doses and exposure to the 

5 public and the environment are negligible at all plants (NRC 2013a). These same regulatory 

6 controls are expected to remain in effect during short-term continued storage of spent fuel.

7 Because short-term continued storage of spent fuel would generate much less LLW than an 

8 operating reactor and licensees would continue to implement Federal and State regulations and 

9 requirements for proper management and disposal of LLW, the NRC concludes that the 

10 environmental impact from the management and disposal of LLW would be SMALL for all 

11 waste-management facilities.

12 4.15.1.2 Mixed Waste

13 The amount of mixed waste generated from the operation and maintenance of the spent fuel 

14 pool and the ISFSI is expected to be minimal compared to that of an operating reactor. After 

15 reactor operations cease, most waste-generating activities, as described in Section 3.14, would 

16 also cease, except for those associated with continued storage.

17 In the License Renewal GEIS, the NRC determined that the radiological and nonradiological 

18 environmental impacts from the storage and disposal of mixed waste would be SMALL for all 

19 operating reactor sites (NRC 2013a) because of the small quantities generated and 

20 comprehensive regulatory controls in place to ensure that this waste is properly managed and 

21 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/yr (0.544 yd3 22 /yr)of mixed waste would 

23 be generated during operation. Because the amount of mixed waste generated during short24 term continued storage would be comparable to the relatively small amount estimated for 

25 reactor license renewal, the impacts in the License Renewal GEIS would bound the impacts for 

26 mixed waste during continued storage.

27 Comprehensive regulatory controls, facilities, and procedures are expected to remain in place 

28 during short-term continued storage of spent fuel, which will ensure that mixed waste is properly 

29 managed so that exposure to the public and environmental are negligible at all storage sites.

30 Because short-term storage of spent fuel would generate much less mixed waste than an 

31 operating reactor and licensees would continue to implement Federal and State regulations 

32 regarding proper management and disposal of mixed waste, the NRC concludes that the 

33 environmental impact from the management and disposal of mixed waste would be SMALL.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-57 Draft NUREG‒2157

1 4.15.1.3 Nonradioactive Waste

2 The amount of nonradioactive waste generated from the operation and maintenance of an 

3 at-reactor ISFSI is expected to be minimal compared to that of an operating reactor. After 

4 reactor operations cease, most waste-generating activities would also cease, except for those 

5 associated with short-term storage.

6 The impacts associated with the storage and disposal of nonradioactive wastes at operating 

7 nuclear power plants were determined to be SMALL in the License Renewal GEIS

8 (NRC 2013a), because although the quantities of waste generated are highly variable, they are 

9 generally less than amounts generated at other industrial facilities. After reactor operations 

10 ceased, most waste-generating activities would also cease, except for those associated with 

11 continued storage. Because the amount of waste generated during short-term storage would be 

12 less than that estimated for reactor license renewal, the impacts in the License Renewal GEIS 

13 would bound the impacts for nonradioactive waste during short-term continued storage.

14 For example, in EISs for the licensing of new reactors (e.g., Fermi 3 and Lee), the impacts 

15 associated with the storage and disposal of nonradioactive waste, including hazardous waste, 

16 were determined to be SMALL, primarily because the wastes would be handled and disposed of 

17 according to County and State regulations (NRC 2013b, NRC 2011c).

18 The handling and disposal of hazardous wastes are regulated by the EPA or the responsible 

19 State agencies in accordance with the requirements of RCRA. Nonhazardous wastes are 

20 managed onsite and are generally disposed of in landfills permitted locally under RCRA 

21 Subtitle D regulations. Similar to LLW and mixed waste, nonradioactive waste would continue 

22 to be managed according to local, State, and Federal regulatory requirements.

23 Because short-term storage of spent fuel would generate less nonradioactive waste than an 

24 operating reactor, which was previously determined to have a SMALL impact, and licensees 

25 would continue to implement Federal and State regulations regarding proper management and 

26 disposal of nonradioactive waste, the NRC concludes that the environmental impact from the 

27 management and disposal of nonradioactive waste would be SMALL.

28 4.15.2 Long-Term Storage

29 Ongoing routine maintenance would continue to generate minimal amounts of waste. The NRC 

30 assumes that, during this long-term storage timeframe, a DTS would need to be constructed 

31 and operated. In addition, the DTS and ISFSI facilities (including casks and concrete pads) 

32 would need to be replaced.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-58 September 2013

1 4.15.2.1 Low-Level Radioactive Waste

2 Routine maintenance and monitoring of the ISFSI would continue to occur, which would 

3 generate minimal amounts of LLW. The NRC anticipates no LLW would be generated by onsite 

4 construction activities associated with the DTS.

5 During long-term storage, storage canisters will reach the end of their design life and require 

6 replacement. The replacement process will involve the transfer of spent fuel assemblies to new 

7 canisters and decontamination and disposal of the old canisters. The repackaging process is 

8 expected to generate types of dry wastes similar to those described for normal operations (e.g., 

9 clothing and tools) and radioactively contaminated storage canisters that would be handled and 

10 disposed of as LLW. Because storage canisters come into direct contact with spent fuel, it is 

11 possible that the metal components could become contaminated or activated and require 

12 disposal as LLW (EPRI 2010). In the Calvert Cliffs ISFSI renewal EA (NRC 2012a), the NRC 

estimated that less than 0.06 m3 (2 ft3 13 ) per canister of LLW would be generated during cask 

14 loading and decontamination. The LLW would be processed by compaction.

15 All spent fuel repackaging would be performed in the DTS. The repackaging process consists 

16 of removal of the spent fuel assemblies from the old canister and their placement into a new 

17 canister. For example, in the Calvert Cliffs ISFSI renewal EA (NRC 2012a), the NRC estimated 

that less than 0.06 m3 (2 ft3 18 ) per canister of LLW would be generated during cask loading and 

19 decontamination, based on a horizontal storage module design such as that described in 

20 Section 2.1.2.2. This LLW would consist of garments, tapes, and cloths, and would be 

21 processed by compaction. In addition, the old canister would require disposal. Because 

22 storage canisters come into direct contact with spent fuel for an extended period of time, it is 

23 assumed that the dry storage canister and any internal components have become activated or 

24 radioactively contaminated and require disposal as LLW (EPRI 2010). For example the 

25 NUHOMS 32P–S100 dry storage canister licensed for use at the Calvert Cliffs ISFSI has a 

compacted nominal volume of 1.3 m3 (46 ft3 26 ) (Transnuclear 2004) that must be managed and 

27 disposed of as LLW. Repackaging and replacement of the 120 canisters at the Calvert Cliffs 

ISFSI would generate approximately 163 m3 (5,800 ft3 28 )of compacted LLW.

29 In addition to repackaging the spent fuel during long-term storage, the ISFSI and DTS would 

30 need to be replaced. For purposes of this analysis, because the activities associated with the 

31 replacement and demolition of the ISFSI are similar to decommissioning activities, the impacts 

32 from the replacement of casks and concrete pads are based on the decommissioning impacts 

33 considered in the Calvert Cliffs ISFSI renewal EA, which are used as an example. A small 

34 portion of the horizontal storage module could be expected to be contaminated, and it would 

35 require disposal at a LLW facility. Affected soils would potentially have to be disposed of as 

36 LLW. In the Calvert Cliffs ISFSI EA, the NRC determined that the impacts from waste 

37 management during decommissioning would be SMALL (NRC 2012a). These impacts would be 

38 similar for vertical storage designs, as described in Section 2.1.2.2. NRC previously determined 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-59 Draft NUREG‒2157

1 that waste generated during reactor decommissioning would have a SMALL impact (NRC 

2 2013a) and waste generated during ISFSI license renewal would also have a SMALL impact 

3 (NRC 2012a). Because waste generated during the long-term storage timeframe would be less 

4 than that generated during decommissioning, NRC expects that LLW generated during 

5 replacement of an ISFSI and DTS would be minimal. 

6 Because LLW would continue to be managed according to Federal regulations and the disposal

7 capacity for LLW is expected to be available when needed (see Section 1.8.3.), the NRC 

8 determines the impacts from LLW management and disposal would be SMALL during long-term 

9 storage.

10 4.15.2.2 Mixed Waste

11 Routine maintenance and monitoring of the ISFSI would continue during long-term storage, and 

12 would generate minimal amounts of mixed waste. The repackaging of spent fuel, construction 

13 and operation of a DTS, and the replacement of the ISFSIs and DTSs are not expected to 

14 generate mixed waste. However, if mixed waste is generated, it would be a small fraction of 

15 that generated by an operating nuclear power plant and it would be managed according to 

16 regulatory requirements.

17 Due to the type of activities occurring during long-term storage that are expected to generate 

18 minimal to no mixed waste and because the quantity of mixed waste generated from the 

19 operation and replacement of the ISFSIs and DTSs is expected to be a small fraction of that 

20 generated during the licensed life of the reactor, the radiological and nonradiological 

21 environmental impacts associated with the management and disposal of mixed waste are 

22 expected to be SMALL during long-term storage.

23 4.15.2.3 Nonradioactive Waste

24 Routine maintenance and monitoring of the ISFSI would continue to generate minimal amounts 

25 of nonradioactive waste. The construction and operation of a DTS would be expected to 

26 generate nonradioactive waste like construction debris, packaging material, and worker trash.

27 Repackaging of the canisters could generate some amount of nonradioactive waste if the waste 

28 were never contaminated. Replacing the DTS and ISFSI facilities (including casks and storage 

29 pads), would generate nonradioactive waste. The noncontaminated portions of the storage 

30 modules, concrete pads, and DTS building would be demolished and disposed of as 

31 construction debris in a landfill.

32 Similar to LLW estimates, the amount of nonradioactive waste generated from cask and facility 

33 replacement is based on decommissioning estimates. However, specific quantities of 

34 nonradioactive waste are difficult to estimate because the amount of waste will depend on 

35 whether the materials were contaminated during storage.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-60 September 2013

1 Based on the NUHOMS cask design described in Section 2.1.2.2, a single storage module 

volume is 82.4 m3 (2910 ft3 2 ) of concrete and steel. The amount of material would be similar for 

3 vertical storage cask designs, as described in Section 2.1.2.2. Some portion of this volume 

4 would likely be disposed of as LLW due to contamination, but the majority of the waste would be 

5 disposed of as nonradioactive waste. A 1-m (3.3-ft) thick ISFSI pad capable of supporting 

6 108 NUHOMS horizontal storage modules, based on the example facility described in 

Section 2.1.2.2, would contain about 9,270 m3 (327,370 ft3 7 ) of concrete that would need to be 

8 demolished and disposed of as demolition debris. The amount of concrete would be similar for 

9 vertical storage cask designs, as described in Section 2.1.2.2.

10 Routine maintenance, fuel repackaging, and construction and operation of the DTS and 

11 replacement of the DTS and ISFSI are expected to generate nonradioactive waste that would 

12 be handled in accordance with regulatory requirements and disposed of at an appropriately 

13 permitted disposal facility. Although a large amount of nonradioactive waste would be 

generated by the removal of the storage modules and storage pads (approximately 18,200 m3 14

[642,700 ft3 15 ]), it would still be less than the amount of waste generated during decommissioning

16 (which NRC already determined would have a SMALL impact), and it would not likely have a 

17 noticeable impact on local or regional landfill capacity and operations. Therefore, the NRC 

18 determines that the environmental impact from the management and disposal of nonradioactive 

19 waste would also be SMALL during long-term storage.

20 4.15.3 Indefinite Storage

21 This section evaluates the potential environmental impacts from the management and disposal

22 of LLW, mixed waste, and nonradioactive waste from the indefinite at-reactor storage of spent 

23 fuel. The waste-generating activities during this timeframe include the same activities discussed 

24 in for long-term storage but with the activities occurring every 100 years.

25 4.15.3.1 Low-Level Radioactive Waste

26 The activities associated with the management and disposal of LLW from indefinite at-reactor 

27 storage of spent fuel would be similar to those described for long-term storage. As stated in 

28 Section 1.8.3, it is expected that sufficient LLW disposal capacity will be made available when 

29 needed. Similar to long-term storage, the NRC concludes the management and disposal of 

30 LLW could result in SMALL environmental impacts during indefinite storage of spent fuel.

31 4.15.3.2 Mixed Waste

32 The activities associated with managing and disposing of mixed waste from the indefinite 

33 at-reactor storage of spent fuel after the licensed life for operations will be similar to those 

34 discussed for long-term storage. Because of the relatively small quantity of mixed waste 

35 generated from indefinite storage and licensee adherence to proper management and disposal
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-61 Draft NUREG‒2157

1 regulations, the NRC concludes that the indefinite management of mixed wastes resulting from 

2 at-reactor storage of spent fuel would result in SMALL impacts.

3 4.15.3.3 Nonradioactive Waste

4 Although the activities associated with managing and disposing of nonradioactive waste from 

5 indefinite at-reactor storage will be similar to those discussed for long-term storage, the amount 

6 of nonradioactive waste being generated is difficult to accurately estimate over an indefinite 

7 timeframe. Therefore, the NRC concludes the management and disposal of nonradioactive 

8 waste could result in SMALL to MODERATE impacts on nonradioactive waste landfill capacity.

9 4.16 Transportation 

10 This section describes potential transportation impacts caused by the continued at-reactor

11 storage of spent fuel in spent fuel pools and ISFSIs.

12 The potential impacts from transportation activities include fugitive dust emissions, increased 

13 traffic on local roads, worker and public exposure to radiation, and accident risks. The potential 

14 impacts from transportation of spent fuel to a repository or to an away-from-reactor storage 

15 facility are not evaluated in this section. Activities and impacts associated with transportation of 

16 spent fuel to a repository would occur after continued storage and are addressed as cumulative 

17 impacts in Chapter 6. The transportation activities to move spent fuel to an away-from-reactor 

18 ISFSI during continued storage are addressed in Chapter 5. Air emissions are evaluated in 

19 Section 4.4. This transportation analysis provides a generic analyses that is further supported 

20 by a survey of recent site-specific analyses that were completed by the NRC for new reactors. 

21 This transportation analysis considers the impacts of transportation activities during continued

22 storage on the affected environment beyond the site boundary. The environmental impacts 

23 evaluated include the nonradiological impacts on regional traffic and accidents from worker 

24 commuting, supply shipments, and waste shipments and the public and worker radiological 

25 safety impacts from shipments of LLW generated by continued storage activities. 

26 4.16.1 Short-Term Storage

27 Impacts on traffic from workers commuting to and from the power plant site during the short28 term storage timeframe depend on the size of the workforce, the capacity of the local road 

29 network, traffic patterns, and the availability of alternate commuting routes to and from the 

30 facility. While workforce levels are expected to vary among continued storage facilities 

31 (including ISFSIs and spent fuel pools), the limited nature of storage operations relative to 

32 power plant operations and the low reported and estimated storage workforce size indicate that 

33 the workforce needed to support short-term storage would be much smaller than the power 

34 plant workforce. For example, an operational full-time workforce of fewer than 20 workers has 

35 been documented for wet storage (safe storage mode) at the GEH Morris ISFSI (NRC 2004b)
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-62 September 2013

1 and a 200-person workforce has been estimated for dry cask ISFSI fuel transfer and loading 

2 operations at the Fort St. Vrain facility (NRC 1991b). For comparison, the operational workforce 

3 at nuclear power plants ranges from 800 to 2,400 permanent personnel (NRC 2002b) with an 

4 additional 1,000 or more temporary workers needed to support refueling operations (NRC 

5 2011d). The environmental impact on traffic from renewal of operations of nuclear reactors was 

6 evaluated generically in the License Renewal GEIS (NRC 2013a), which concluded the impacts 

7 on traffic from commuting workers would be SMALL. Because at-reactor ISFSI and spent fuel 

8 pool operations represent a small proportion of the operations at any reactor site, the NRC 

9 concludes the traffic impacts of continuing the storage activities during the short-term timeframe 

10 would continue to be a fraction of the small traffic impacts realized during the period of reactor 

11 operations.

12 The operation of the at-reactor ISFSI and spent fuel pool would generate a small amount of 

13 LLW (e.g., used personal protection equipment and wastes related to pool–to-cask transfer 

14 activities) relative to power plant operations that would result in infrequent waste shipments to a 

15 licensed disposal facility. The Atomic Energy Commission (AEC 1972) estimated the annual 

amount of LLW generated from a typical 1,100-MW(e) operating light water reactor was 108 m3 16

(3,800 ft3), resulting in as many as 70 shipments of waste per year, assuming 0.05 m3 (1.8 ft3 17 ) 

18 per drum and 30 drums per truck. More recent estimates of annual LLW generated by power 

19 plants with higher power ratings are comparable (NRC 2011e) or as much as four times higher 

(NRC 2011f) than the previously reported 108 m3 (3,800 ft3 20 ) value but would represent, on 

21 average, less than one shipment per day. The small and infrequent number of shipments 

22 and compliance with NRC and U.S. Department of Transportation (DOT) packaging and 

23 transportation regulations would limit potential worker and public radiological and 

24 nonradiological impacts from these waste shipments. The radiological impacts on the public 

25 and workers of LLW shipments from a reactor have been previously evaluated by the NRC. 

26 A generic impact determination in Table S–4 in 10 CFR 51.52 and supporting analysis (AEC 

27 1972) conclude that the environmental impacts of the transportation of fuel and waste to and 

28 from a light water reactor under normal operations of transport and from accidents during

29 transport would be SMALL. Subsequent analysis of LLW transportation impacts in Final 

30 Environmental Statement on Transportation of Radioactive Material by Air and Other Modes

31 (NRC 1977) concluded transportation impacts are small. Additional site-specific analyses of 

32 transportation impacts for power plants that did not meet the conditions of 10 CFR 51.52 also 

33 concluded the transportation radiological impacts would be SMALL (NRC 2006b, c; 2008b; 

34 2011a,d–f; 2013a). Because LLW waste-generating activities for storage would be a fraction of 

35 total power plant LLW-generating activities, the short-term storage LLW waste shipments would 

36 also result in a small fraction of the low level of impacts realized for waste shipment during the 

37 period of reactor operations.

38 Based on the preceding analysis that describes the low volume of traffic and shipping activities 

39 associated with the continued storage of spent fuel in at-reactor ISFSIs and spent fuel pools, the 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-63 Draft NUREG‒2157

1 NRC concludes the impacts on traffic and public and worker radiological and nonradiological 

2 safety from transportation activities would be SMALL during the short-term storage timeframe.

3 4.16.2 Long-Term Storage

4 As discussed in Section 1.8, the NRC assumes that the spent fuel would need to be repackaged 

5 during this timeframe, and that the ISFSI would be replaced. To facilitate the repackaging of the 

6 spent fuel, the NRC assumes that a DTS would be constructed.

7 The construction of a DTS would require a small temporary workforce relative to the power plant 

8 workforce. Because a DTS has not been constructed at any power plant site and construction

9 information is limited, the NRC considered a previously reviewed proposal to construct a spent 

10 fuel transfer facility at the Idaho National Laboratory (NRC 2004a) that estimated a construction 

11 workforce of 250 workers for 2 years. Because the proposed Idaho transfer facility is larger 

12 (3.2 ha [8.0 ac] (NRC 2004a) than the assumed DTS (0.04 ha [0.1 ac], Section 2.2.2.1), the 

13 Idaho facility bounds the impacts of constructing a DTS. For comparison, the operational 

14 workforce at nuclear power plants ranges from 800 to 2,400 permanent personnel (NRC 2002b) 

15 with an additional 1,000 or more temporary workers needed to support refueling operations 

16 (NRC 2011d). Based on this information, the NRC concludes that worker commuting traffic 

17 impacts associated with construction of a DTS during the long-term storage timeframe would be 

18 a small fraction of the power plant operations traffic impacts (described in Section 4.16.1 as 

19 small) and therefore the DTS construction traffic would also be small. Operation of the DTS 

20 would involve fewer workers than the construction workforce and therefore the commuting traffic 

21 impacts during the DTS operations period would also be minor. The remainder of activities 

22 during the long-term storage timeframe would be similar to activities and impacts, as evaluated 

23 in Section 4.16.1 (i.e., workers commuting and a small number of LLW shipments), and 

24 therefore transportation impacts would continue to be small.

25 The operation of the DTS would involve shipment of materials and generate a small amount of 

26 LLW (e.g., used canisters, decontamination swabs, air filters, and used personal protection 

27 equipment) (DOE 1996) that would result in infrequent waste shipments to a licensed disposal

28 facility. Supply and waste shipments would be infrequent because transfer activities would 

29 occur over a long period of time. The small and infrequent number of LLW shipments and 

30 compliance with NRC and DOT packaging and transportation regulations would limit potential 

31 worker and public radiological and nonradiological impacts from waste shipments.

32 Continued repackaging activities and the replacement of the ISFSIs and DTSs would generate 

33 additional LLW and nonradiological waste that would need to be shipped offsite for disposal. 

Section 4.15.2.1 provides an example estimate of 163 m3 (5,800 ft3 34 ) of compacted LLW from the 

35 repackaging of all 120 canisters at a proposed ISFSI. Because repackaging would occur as 

36 needed during the long-term storage timeframe, the LLW shipments would occur infrequently. 

Repackaging and replacement would generate about 18,200 m3 (642,000 ft3 37 ) of nonhazardous 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-64 September 2013

1 waste (Section 4.15.3). Assuming the nonhazardous waste from replacement is shipped in rolloff containers with a capacity of 15 m3 (20 yd3 2 ), the total number of truck shipments estimated is 

3 1189. If replacement were phased over a 5-year period, and shipping occurred 5 days per 

4 week, less than one shipment per day would be needed. The activities would not significantly 

5 increase the magnitude of traffic generated by continued storage occurring each year.

6 The remainder of activities during the long-term storage timeframe would be similar to the 

7 activities and impacts evaluated in Section 4.16.1 (i.e., workers commuting and a small number 

8 of LLW shipments).

9 Due to the small workforce requirements for continued storage and aging management activities 

10 (relative to the power plant workforce) and the low frequency of supply shipments and 

11 shipments of LLW from DTS and ISFSI operations and replacement activities, the NRC 

12 concludes that impacts on traffic and public and worker radiological and nonradiological safety

13 during the long-term storage timeframe would each be SMALL.

14 4.16.3 Indefinite Storage

15 Assuming no repository becomes available, spent fuel would be stored indefinitely in at-reactor 

16 ISFSIs. Annual transportation activities and associated environmental impacts would be similar 

17 to those analyzed for long-term storage operations and DTS construction and operations in 

18 Section 4.16.2, including continued aging management, repackaging, and replacement 

19 activities. In addition, because the impact analysis pertains to continued storage, the maximum 

20 inventory of spent fuel in storage at any reactor site would be the same as that evaluated in 

21 Section 4.16.1.

22 Because the NRC concluded in Section 4.16.2 that transportation impacts for continued storage 

23 and aging management activities would be SMALL, and no significant changes to the annual 

24 magnitude of traffic or waste shipments were identified in the preceding analysis of 

25 transportation activities assuming indefinite at-reactor storage, the NRC concludes that the 

26 transportation impacts during the indefinite storage timeframe would continue to be SMALL.

27 4.17 Public and Occupational Health

28 This section describes potential impacts on public and occupational health caused by the 

29 continued storage of spent fuel in spent fuel pools and at-reactor ISFSIs.

30 For the purposes of assessing radiological impacts, impacts are considered to be SMALL if 

31 releases and doses do not exceed dose standards in the NRC’s regulations. This definition of 

32 SMALL applies to occupational doses as well as to doses to individual members of the public.

33 Transportation-related public and occupational health impacts are addressed in Section 4.16. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-65 Draft NUREG‒2157

1 4.17.1 Short-Term Storage

2 Continued storage of spent fuel in spent fuel pools and ISFSIs is expected to continue in the 

3 same manner as during the licensed life for operation of a reactor. The License Renewal GEIS

4 (NRC 2013a) describes a number of specific activities related to continued normal plant 

5 operations that result in impacts on public and occupational health. These include normal plant 

6 operation for power generation, the storage of spent fuel in fuel pools and ISFSIs, normal 

7 refueling, and other outages that include steam generator replacements. Overall, data and 

8 analyses presented in the License Renewal GEIS (NRC 2013a) provide ample evidence that 

9 public and occupational doses at all commercial power plants are far below the dose limits in 

10 10 CFR Part 20 and that the continuing efforts to maintain doses at as low as reasonably 

11 achievable levels have been successful. Therefore, because continued storage represents a 

12 fraction of the activities occurring during reactor operations, NRC expects that the public and 

13 occupational doses would continue to remain below the regulatory dose limits.

14 Spent fuel pool leaks can result in environmental impacts. As discussed in Appendix E, in the

15 event that a leak from a spent fuel pool goes undetected and the resulting groundwater plume 

16 reaches the offsite environment, it is possible that the leak could be of sufficient magnitude and 

17 duration to contaminate a groundwater source above a regulatory limit (i.e., a maximum 

18 contaminant level [MCL] for one or more radionuclides). As discussed in Appendix E, factors 

19 such as spent fuel pool design (stainless-steel liners and leakage-collection systems) and 

20 operational controls (monitoring and surveillance of spent fuel pool water levels), onsite and 

21 offsite ground water monitoring, make it unlikely that a leak of sufficient quantity and duration 

22 could occur without detection. Additionally, should a spent fuel pool leak occur, the hydrologic 

23 characteristics typical at spent fuel pool locations make it improbable that water leaked from the 

24 spent fuel pool would migrate offsite. Therefore, based on the low probability of a leak affecting 

25 offsite groundwater sources, NRC concludes that impacts on public health resulting from a 

26 spent fuel pool leak during short-term timeframe would be SMALL.

27 The data presented in NUREG–0713, “Occupational Radiation Exposure at Commercial Nuclear 

28 Power Reactors and Other Facilities 2010” (NRC 2012b), as well as a number of ISFSI license 

29 renewal EAs (e.g., the Surry ISFSI [NRC 2005c] and Calvert Cliffs ISFSI [NRC 2012a]), provide 

30 ample evidence that the public and occupational radiological health impacts from the continued 

31 storage of spent fuel are a small fraction of the doses and impacts presented in the License 

32 Renewal GEIS (NRC 2013a) that include reactor operations. For example, NUREG–0713 

33 (NRC 2012b) provides occupational exposure reporting from facilities that no longer have 

34 operating reactors, such as the Big Rock Point and Trojan ISFSIs. Both of these facilities had 

35 no measurable occupational exposure in the 2010 reporting period. The GEH Morris facility is a 

36 spent-fuel-pool-only ISFSI and has never had an operating reactor onsite. Its 2010 annual 

37 report indicates an average measured total effective dose equivalent of 0.34 mSv (34 mrem) in 

38 relation to the 10 CFR Part 20 occupational dose limit of 50 mSv (5,000 mrem).
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-66 September 2013

1 The analyses presented in the License Renewal GEIS (NRC 2013a) and a number of ISFSI 

2 license renewal EAs (e.g., the Surry ISFSI [NRC 2005c] and Calvert Cliffs ISFSI [NRC 2012a]) 

3 provide evidence that annual public and occupational doses would be maintained below the 

4 annual dose limits established by 10 CFR Part 72 for the public and 10 CFR Part 20 for 

5 occupational personnel. In addition, a licensed storage facility would be required to maintain an 

6 as low as reasonably achievable program, which would likely result in doses lower than those 

7 described in the License Renewal GEIS (NRC 2013a). 

8 Nonradiological risks to occupational health and safety would include exposure to industrial 

9 hazards and hazardous materials. Industrial hazards are those typical of other industrial facility 

10 construction and operating hazards and include exposure to chemicals and accidents ranging 

11 from minor cuts to industrial machinery accidents. Preventative maintenance activities are 

12 conducted in accordance with Occupational Safety and Health Administration requirements and 

13 are infrequent and minor. Therefore, nonradiological occupational health impacts are 

14 considered to be minimal.

15 The NRC concludes that the impacts on public and occupational health due to continued 

16 storage of spent fuel would be SMALL during the short-term storage timeframe. 

17 4.17.2 Long-Term Storage

18 In addition to the impacts considered above for short-term continued storage in an ISFSI, the 

19 NRC assumes that a DTS is constructed during the long-term storage timeframe. Risks to 

20 occupational health and safety during construction of the DTS would include exposure to 

21 industrial hazards, hazardous materials, and radioactive materials. Industrial hazards are those 

22 typical of other industrial facility construction and operating hazards and include exposure to 

23 chemicals and accidents ranging from minor cuts to industrial machinery accidents. Because 

24 construction activities are conducted in accordance with Occupational Safety and Health 

25 Administration requirements, nonradiological occupational health impacts are considered to be 

26 minor.

27 Once constructed, operation of the DTS would be very similar to the operations conducted at 

28 current reactor plant sites with licensed ISFSIs where spent fuel is loaded into dry storage cask 

29 systems and placed on an ISFSI pad. Analyses of ISFSI operations have been conducted in 

30 numerous EAs such as the Calvert Cliffs (NRC 2012a) and Oconee Nuclear Station (NRC 

31 2009b) ISFSI renewals. These analyses and REMP reports provide ample evidence that public 

32 and occupational doses are being maintained well below the dose limits established by 10 CFR 

33 Part 72 for the public and 10 CFR Part 20 for occupational personnel. In addition, all NRC34 licensed facilities are also required to operate using an as low as reasonably achievable 

35 program to ensure radiation doses are maintained as low as is reasonably achievable. 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-67 Draft NUREG‒2157

1 Based on the reasons provided above, the NRC 

2 concludes that the impacts on public and occupational 

3 health during long-term storage would be SMALL.

4 4.17.3 Indefinite Storage

5 The public and occupational health impacts of 

6 continuing to store spent fuel without a repository would 

7 be similar to those described for long-term storage. The 

8 activities and associated human health impacts would 

9 remain the same. The main difference is that these 

10 activities would occur repeatedly. 

11 The no repository scenario was analyzed in detail in the 

12 Yucca Mountain final EIS (FEIS) (DOE 2002) as the 

13 no-action alternative. The Yucca Mountain FEIS 

14 analyses looked at the short- and long-term impacts of 

15 continued storage of spent fuel and high-level 

16 radioactive waste at 72 commercial and 

17 5 U.S. Department of Energy (DOE) sites for 

18 10,000 years. The Yucca Mountain FEIS, in the 

19 analysis of the no-action alternative, assumes all commercial spent nuclear fuel would 

20 eventually be stored in dry configurations in ISFSIs at the existing locations. Detailed analyses 

21 were provided to demonstrate the expectation that maintenance, repairs, repackaging, 

22 operation, and construction at the storage facilities would be conducted in accordance with the 

23 requirements of the Occupational Safety and Health Administration and 10 CFR Parts 20 and 

24 72, as discussed in the sections above. In addition, administrative controls and design features 

25 would minimize worker nonradioactive and radioactive exposures. The Yucca Mountain FEIS 

26 analyses and the discussion provided in Section 4.17.2 support the conclusion that public and 

27 occupational radiological health impacts could be maintained within the public and occupational 

28 dose limits of 10 CFR Parts 72 and 20. Therefore, the NRC concludes that the impacts on

29 public and occupational health due to the indefinite storage of spent fuel in at-reactor ISFSIs 

30 would be SMALL.

31 4.18 Environmental Impacts of Postulated Accidents

32 This section describes the environmental impacts of postulated accidents involving the 

33 continued storage of spent fuel.

34 During continued storage, numerous features combine to reduce the risk associated with 

35 accidents involving spent fuel storage in spent fuel pools and ISFSIs. Safety features in the 

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 exposures (NRC 

2007b).

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 (NRC 2007b).

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

Draft NUREG‒2157 4-68 September 2013

1 design, construction, and operation of nuclear power plants and ISFSIs, which are the first line 

2 of defense, are intended to prevent the release of radioactive materials. Additional measures 

3 are designed to mitigate the consequences of failures in the first line of defense. These include 

4 the NRC’s reactor site criteria in 10 CFR Part 100, “Reactor Site Criteria,” that require the site to 

5 have certain characteristics that reduce the risk to the public and the potential impacts of an 

6 accident, and emergency preparedness plans and protective action measures for the site and 

7 environs. All these safety features, measures, and plans make up the defense-in-depth 

8 philosophy used by the NRC to protect the health and safety of the public and the environment 

9 (NRC 2011c).

10 Consistent with the defense-in-depth philosophy, this section describes design basis events for 

11 which the strategy is to prevent or mitigate the consequences of accidents that could result in 

12 potential offsite doses. For some design basis events, such as tornadoes, this section 

13 describes how the storage facility is designed and built to withstand the event without loss of 

14 systems, structures, and components necessary to ensure public health and safety. In these 

15 cases, the environmental impacts are small because no release of radioactive material would 

16 occur. Other design basis events, such as spent fuel handling accidents, are design basis 

17 accidents that licensees must assume could occur. In these cases, licensees must show how 

18 engineered safety features in the facility mitigate a postulated release of radioactive material. 

19 The environmental impacts of design basis accidents are small because all licensees must 

20 maintain engineered safety features that ensure that the NRC dose limits for these accidents 

21 are met. The basis for impact determinations for design basis events (i.e., whether the accident 

22 is prevented or mitigated) is described for each type of design basis event presented in this 

23 section.

24 Regulations governing accidents that must be addressed by nuclear power facilities, both 

25 operating and shutdown, are found in 10 CFR Parts 50, 52, and 100. The environmental 

26 impacts of design basis events, including those associated with the spent fuel pool, are 

27 evaluated during the initial licensing process. The ability of the plant to withstand these 

28 accidents is demonstrated to be acceptable before issuance of the operating license. The 

29 results of these evaluations are found in license documentation, such as the NRC’s safety

30 evaluation report, the final environmental impact statement, and in the licensee’s Final Safety 

31 Analysis Report (FSAR) or equivalent. The licensee is required to maintain the acceptable 

32 design and performance criteria throughout the life of the plant, including continued storage 

33 (NRC 2002b).

34 The consequences of a severe (or beyond-design-basis) accident, if one occurs, could be 

35 significant and destabilizing. The impact determinations for these accidents, however, are 

36 made with consideration of the low probability of these events. The environmental impact 

37 determination with respect to severe accidents, therefore, is based on the risk, which the NRC 

38 defines as the product of the probability and the consequences of an accident. This means that 
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September 2013 4-69 Draft NUREG‒2157

1 a high-consequence low-probability event, like a severe accident, could still result in a small 

2 impact determination, if the risk is sufficiently low.

3 This section of the draft GEIS follows a different format than the rest of the document. Because 

4 the accident risks for spent fuel pool storage only apply during the short-term timeframe and the 

5 accident risks for dry cask storage are substantially the same across the three timeframes, the 

6 draft GEIS presents the various accident types only once. The three storage timeframes (short7 term, long-term, and indefinite, as described in Chapter 1) apply as follows:

8 • During short-term storage, both design basis and severe accidents are postulated for spent 

9 fuel stored in the onsite spent fuel pool and at-reactor ISFSI. 

10 • For long-term and indefinite storage, the NRC assumes that the spent fuel is moved from 

11 the spent fuel pool to an at-reactor ISFSI. Therefore, only accidents involving an at-reactor 

12 ISFSI are possible during the long-term and indefinite storage timeframes.

13 4.18.1 Design Basis Events

14 During the continued storage of spent fuel, licensees maintain systems, structures, and 

15 components that ensure public health and safety. The hazards that are considered in the 

16 design and operation of storage facilities include failure of facility systems, structures, and 

17 components; man-made hazards, such as nearby military, industrial, and transportation 

18 facilities; and natural phenomena, such as earthquakes and floods. 

19 4.18.1.1 Design Basis Events in Spent Fuel Pools

20 A number of postulated design basis events are considered in the design of spent fuel pools. 

21 Design features of spent fuel pools ensure prevention of inadvertent criticality and also ensure 

22 that the pool is designed to withstand hazards that could result in a significant loss of water. 

23 This section provides brief summaries of accidents involving spent fuel storage operations 

24 during the short-term storage timeframe.

25 Criticality Accidents

26 The presence of fissile nuclides in spent fuel means that controls must be in place to prevent 

27 inadvertent nuclear chain reaction, or criticality, while spent fuel is in storage. NRC regulations 

28 in 10 CFR 50.68, “Criticality Accident Requirements,” and General Design Criterion 62, 

29 “Prevention of Criticality in Fuel Storage and Handling,” of Appendix A, “General Design Criteria 

30 for Nuclear Power Plants,” to 10 CFR Part 50 require that subcriticality in spent fuel pools be 

31 maintained. To comply with these requirements, licensees design and implement controls 

32 based on spent fuel pool nuclear criticality safety analyses. These controls include the use of 

33 neutron-absorbing material in spent fuel pool storage racks. The neutron-absorbing material’s 

34 physical properties, including its dimensions and boron-10 areal density, help maintain 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-70 September 2013

1 subcriticality. The nuclear criticality safety analyses are usually documented in the licensee’s 

2 FSAR and are the basis for demonstrating compliance with plant technical specifications, NRC 

3 regulations, and demonstrating adequate subcriticality for both normal operating conditions and 

4 design basis accidents. 

5 Many licensees use integrated defense-in-depth design features to reduce the chance of a 

6 criticality accident if the neutron-absorbing material degrades. For example, some PWRs have 

7 received approval to take credit for the soluble boron in the spent fuel pool.

8 Licensees are required to demonstrate that some margin to criticality is maintained for a variety 

9 of abnormal conditions, including fuel-handling accidents involving a dropped fuel assembly. 

10 The environmental impacts are small, therefore, because criticality accidents in spent fuel pools 

11 are prevented. 

12 Nearby Military, Industrial, and Transportation Facilities

13 Nuclear power plant licensees are required to assess hazards from nearby military, industrial, 

14 and transportation facilities to ensure that potential hazards in the site vicinity have been 

15 considered in the plant’s design bases. If hazards are identified, such as overpressure from 

16 explosions from nearby industrial facilities, licensees are required to show that the probability is 

sufficiently low (an order of magnitude of 10‒7 17 /yr or less) or that radiological dose criteria in 

18 10 CFR 50.34(a)(1) are met. Since either the probability or the consequences must be 

19 acceptably small, the environmental risk of spent fuel pool releases caused by hazards from 

20 nearby military, industrial, and transportation facilities is small.

21 Postulated Fuel Assembly or Cask Drop

22 In accordance with NRC regulations in 10 CFR 50.34 and 52.79, a licensee must show that a 

23 plant site and mitigating engineered safety features are acceptable with respect to the 

24 consequences of postulated spent fuel cask drop accidents. Improper operation of the handling 

25 equipment (e.g., cranes), poor rigging practices, and equipment failures can lead to a drop of a 

26 cask or a fuel assembly into a spent fuel pool. Generally, the handling equipment is designed 

27 and constructed in accordance with the ASME NOG–1 Standard (ASME 2010) to be certified as 

28 single-failure-proof (any single failure will not drop the load).

29 A heavy load (e.g., cask) drop into the pool or onto the pool wall can affect the structural 

30 integrity of the fuel pool. An unlikely drop of a fuel assembly may cause mechanical damage to 

31 the fuel. Because a relatively small amount of mechanical damage to the fuel could cause 

32 significant radiation doses to facility personnel and releases to the environment, the spent fuel 

33 pool facility has radiation monitors and also provides confinement of radioactive material 

34 released from damaged fuel. The spent fuel pool facility is a controlled leakage building with a 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-71 Draft NUREG‒2157

1 safety-grade filtration system in its ventilation system. This filtration system provides the 

2 necessary confinement to limit offsite dose consequences (NRC 2001). 

3 The licensee provides the necessary plant description and analyses in its FSAR to demonstrate 

4 the safety of the spent fuel pool during the initial license application of the reactor to the NRC. 

5 The licensee also revises the plant description and accident analyses in the FSAR, as needed. 

6 As part of its continuing regulatory oversight of the plant, the NRC reviews the plant description 

7 and accident analyses during the initial licensing proceedings, as well as any subsequent

8 revision to the FSAR.

9 In general, the NRC’s accident dose review criterion for fuel-handling accidents at most plants, 

10 including cask drops, is 6.25 rem total effective dose equivalent (NRC 2000). This dose 

11 criterion must be met regardless of the probability of the event.

12 Since the postulated fuel assembly or cask drop is among the design basis accidents analyzed 

13 by licensees, and licensees must show that radiation dose limits in 10 CFR 50.34(a)(1) will be 

14 met, the environmental consequences associated with this type of design basis accident during 

15 continued storage would be small.

16 Natural Phenomena Hazards

17 Appendix A, “General Design Criteria for Nuclear Power Plants,” to 10 CFR Part 50 requires 

18 that structures, systems, and components that are important to safety be designed to withstand 

19 the effects of natural phenomena, such as earthquakes, tornadoes, hurricanes, floods, tsunamis 

20 and seiches, without loss of capability to perform their safety functions. General Design 

21 Criterion 2 (of Appendix A, “General Design Criteria for Nuclear Power Plants,” to 10 CFR 

22 Part 50) also requires that the design bases for these structures, systems, and components 

23 reflect (1) appropriate consideration of the most severe of the natural phenomena that have 

24 been historically reported for the site and surrounding area, with sufficient margin for the limited 

25 accuracy, quantity, and period of time in which the historical data have been accumulated; 

26 (2) appropriate combinations of the effects of normal and accident conditions with the effects of 

27 the natural phenomena; and (3) the importance of the safety functions to be performed.

28 General Design Criterion 4, “Environmental and Dynamic Effects Design Bases," also applies to 

29 spent fuel pool design as it relates to information on tornadoes that could generate missiles.

30 NRC siting regulations in 10 CFR Part 100, “Reactor Site Criteria,” also require applicants to 

31 consider, among other things, physical characteristics of sites that are necessary for safety

32 analysis or that may have an impact upon plant design (such as maximum probable wind speed 

33 and precipitation). Licensees and applicants are required to identify and characterize the 

34 physical characteristics of the site, so that they may be taken into consideration when 

35 determining the acceptability of the site. Appendix A of 10 CFR Part 100, “Seismic and 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-72 September 2013

1 Geologic Siting Criteria for Nuclear Power Plants,” describes the nature of investigations 

2 required to obtain the geologic and seismic data necessary to determine site suitability and to 

3 provide reasonable assurance that a nuclear power plant can be constructed and operated at a 

4 proposed site without undue risk to the health and safety of the public. Appendix A describes 

5 the procedures for determining the quantitative vibratory ground motion design basis at a site 

6 due to earthquakes and describes information needed to determine whether and to what extent 

7 a nuclear power plant needs to be designed to withstand the effects of surface faulting.

8 Each applicant for a construction permit for a power plant is required to investigate the site for 

9 all seismic and geological factors that may affect the design and operation of the plant to 

10 provide reasonable assurance that the plant can be constructed and operated without undue 

11 risk to health and safety of the public. These siting criteria also provide reasonable assurance 

12 that the spent fuel pool can be operated safely during the short-term storage timeframe. 

13 Earthquakes

14 The NRC requires licensees to design, operate, and maintain safety-significant structures, 

15 systems, and components, including spent fuel pools, to withstand the effects of earthquakes

16 and to maintain the capability to perform their intended safety functions. The agency ensures 

17 these requirements are satisfied through the licensing, reactor oversight, and enforcement 

18 processes (NRC 2011g). In 2005, the NRC began to assess the safety implications of 

19 increased nuclear power plant earthquake hazards identified for the central and eastern 

20 United States. The NRC identified the issue as Generic Issue 199 (GI–199) and completed a 

21 limited scope screening analysis in December 2007, which culminated in the issuance of a 

22 safety/risk assessment in August 2010 (NRC 2010). In the 2010 assessment, the NRC chose 

23 seismic core damage frequency as the appropriate risk metric to changes in the seismic hazard. 

24 For each power plant, the NRC estimated the change in seismic core damage frequency as a 

25 result of the updated seismic hazard. This analysis confirmed that operating nuclear power 

26 plants remain safe with no need for immediate action. The NRC took regulatory action after the 

27 March 2011 earthquake and tsunami in Japan. In March 2012, the NRC issued a request for 

28 information to all U.S. nuclear power plants asking licensees to (1) conduct walkdowns of their 

29 plants, including the spent fuel pools, to identify and address plant-specific vulnerabilities 

30 (through their corrective action programs) and verify the adequacies of monitoring and 

31 maintenance procedures; and (2) re-evaluate the seismic hazards at the plants against present32 day NRC requirements and guidance. These assessments may make use of new consensus 

33 seismic hazard estimates for the power plants in the central and eastern United States

34 developed by the DOE, EPRI, and NRC (NRC 2012c). The NRC has issued guidance to 

35 complete these walkdowns and reevaluations and will take additional regulatory action, as 

36 necessary, in response to the findings. 
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September 2013 4-73 Draft NUREG‒2157

1 Floods

2 As with earthquakes and other natural phenomena, the NRC requires licensees to design, 

3 operate, and maintain safety-significant structures, systems, and components, including the 

4 spent fuel pool, to withstand the effects of floods and to maintain the capability to perform their 

5 intended safety functions. The analysis to meet this requirement involves estimating a design

6 basis flood, which is defined as a flood caused by one or an appropriate combination of several 

7 hydrometeorological, geoseimic, or structural-failure phenomena, which results in the most 

8 severe hazards to safety-significant structures, systems, and components (NRC 1977; Prasad 

9 et al. 2011). Based in part on the plant physical siting location and characteristics, the design 

10 basis flood can include flooding on the site caused by local intense precipitation or local 

11 probable maximum precipitation, stream flooding, storm surges, seiches, tsunamis, seismically 

12 induced dam failures or breaches, flooding caused by landslides, the effects of ice formation in 

13 waterbodies, or some combination of these phenomena (NRC 2013a).

14 All safety-significant structures, systems, and components are required to be protected against 

15 the design basis flood by siting them above the highest flood water-surface elevation or 

16 providing adequate flooding protection. The NRC requires that this protection be achieved by 

17 using a dry site concept, external barriers, or incorporated barriers (NRC 1976). The dry site 

18 concept involves constructing the nuclear power plant above the design basis flood water19 surface elevation using either the natural terrain or engineered fill. External barriers are 

20 engineered solutions that can include levees, seawalls or floodwalls, bulkheads, revetments, or 

21 breakwaters. Incorporated barriers are also engineered solutions that involve specially 

22 designed walls or penetration closures.

23 Given these physical siting and engineered factors, the environmental risk of spent fuel pool 

24 releases caused by design basis floods is small.

25 The NRC also took regulatory action after the March 2011 earthquake and tsunami at the 

26 Fukushima Dai-ichi nuclear power plant. In March 2012, the NRC (NRC 2012d) issued a 

27 request for information to all U.S. nuclear power plants asking licensees to (1) conduct plant 

28 walkdowns (visual inspections) to identify and address plant-specific vulnerabilities (through 

29 their corrective action programs) and verify the adequacies of monitoring and maintenance 

30 procedures; and (2) reevaluate the flooding hazards at the plants against present-day NRC 

31 requirements and guidance to ensure that the plant is designed, operated, and maintained in 

32 such a manner that safety-significant structures, systems, and components, including the spent 

33 fuel pool, are able to withstand the effects of floods. The NRC has issued guidance to complete 

34 these walkdowns and reevaluations and will take additional regulatory action, as necessary, in 

35 response to the findings. The information collected in response to the request for information 

36 will also be applicable to resolution of GI–204, “Flooding of Nuclear Power Plant Sites Following 

37 Upstream Dam Failures” (NRC 2013c).
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Draft NUREG‒2157 4-74 September 2013

1 High Winds (Tornadoes and Hurricanes)

2 The NRC requires licensees to consider both sustained straight winds, such as those caused 

3 by hurricanes, and brief high rotational and translational winds that are caused by tornadoes

4 in the design of safety-related structures. Because tornado wind speeds are generally higher 

5 than hurricane wind speeds, tornado winds tend to be the limiting consideration in design. 

6 The NRC’s definition of a design basis tornado, originally published in 1974 in Regulatory 

7 Guide 1.76, describes design basis tornado characteristics in each of three regions of the 

8 United States (NRC 1974). The design basis tornado characteristics east of the eastern 

9 foothills of the Rocky Mountains included a maximum wind speed of 580 km/hr (360 mph). The 

10 Pacific coastal region and Rocky Mountain region had design basis tornado characteristics that 

11 include a maximum wind speed of 480 km/hr (300 mph) and 390 km/hr (240 mph), respectively. 

12 Operating nuclear power plants in these regions that meet this guidance are designed to 

13 withstand these wind speeds. By comparison, few hurricanes have achieved wind speeds of 

14 310 km/hr (190 mph) (Bender et al. 2010).

15 In 2007, the NRC updated its design basis tornado definition such that a maximum wind speed 

16 of 370 km/hr (230 mph) is appropriate for tornadoes for the central portion of the United States; 

17 a maximum wind speed of 320 km/hr (200 mph) is appropriate for a large region of the United 

18 States along the east coast, the northern border, and western Great Plains; and a maximum 

19 wind speed of 260 km/hr (160 mph) is appropriate for the western United States (NRC 2007c). 

20 Because design basis tornado windspeeds were decreased as a result of the analysis 

21 performed to update Regulatory Guide 1.76, it was no longer clear that the revised tornado 

22 design-basis windspeeds would bound design basis hurricane windspeeds in all areas of the 

23 United States. As a result, in 2011 the NRC published new guidance for design basis hurricane 

24 and hurricane missiles for nuclear power plants (NRC 2011h). This guidance describes 

25 windspeeds and other hurricane characteristics acceptable to the staff for defining a design 

26 basis hurricane for new nuclear power plants. For example, under this new guidance, which 

27 would apply to new reactors, design basis 3-second gust windspeeds along the eastern Florida 

28 coast range from 370 km/hr (230 mph) to 470 km/hr (290 mph).

29 Given the required design bases for nuclear power plants, including spent fuel pool structures, 

30 severe winds are necessary to cause damage to a PWR or a BWR spent fuel pool. Generally, 

31 the safety-related structures of spent fuel pool facility (e.g., pool wall) are designed to withstand 

32 the design basis wind and missiles; however, the facility superstructure and other systems may 

33 not be classified as safety-related and may sustain some damage from wind and wind34 generated missiles. In 2001, the NRC estimated the annual frequency of catastrophic pool 

35 failure from an impact of a tornado-generated missile given a strike of a tornado having at least 

F4 intensity to be less than 10−9 36 (NRC 2001). The extremely low probability of tornado-induced 

37 accidents ensures that the environmental risk of spent fuel pool releases caused by design 

38 basis high winds is small.
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September 2013 4-75 Draft NUREG‒2157

1 Climate Change

2 As described above, NRC regulations in 10 CFR Parts 50, 52, and 100 require that spent fuel 

3 pools be designed to withstand the effects of natural phenomena. Climate change can 

4 influence the frequency and intensity of some natural phenomena. This section of the draft 

5 GEIS addresses the environmental impacts from climate change on the continued storage of 

6 spent fuel in spent fuel pools. The NRC acknowledges that climate change may have impacts 

7 across a wide variety of resource areas including air, water, ecological, and human health. The 

8 U.S. Global Change Research Program describes these potential impacts in the report Global 

9 Climate Change Impacts in the United States (GCRP 2009). However, in this draft GEIS, the 

10 discussion of impacts from climate change on the environment will focus on those affecting the 

11 continued storage of spent fuel. The contribution of continued storage to greenhouse gas

12 emissions and climate change are addressed in Sections 4.5 and 5.5.

13 The consideration of climate change impacts for pool storage only needs to address the short14 term timeframe. Climate change can lead to an increased intensity and frequency of severe 

15 weather events, such as flooding and hurricanes. As described previously in this section, the 

16 NRC requires licensees to design, operate, and maintain safety-significant structures, systems, 

17 and components to withstand the effects of floods and other natural phenomena and to maintain 

18 the capability to perform their intended safety functions. The agency ensures these 

19 requirements are satisfied through the licensing, oversight, and enforcement processes. The 

20 NRC’s oversight authority over the licensed facilities will ensure that minimal impacts of natural 

21 hazards would be associated with climate change during short-term continued storage in spent 

22 fuel pools. Potential effects associated with climate change on the safety of spent fuel storage 

23 are flooding from storm surges and high winds caused by extreme weather events like 

24 hurricanes. Rise in sea level is controlled by complex processes, and it is estimated to rise less 

25 than 1 m by 2100 (75 FR 81037). Based on this projected change, none of the U.S. nuclear 

26 power plants (operational or decommissioned) will be under water or threatened by water levels 

27 by 2050 (75 FR 81037). In addition to sea-level rise, spent fuel facilities may be affected by 

28 increased storm surges, erosion, shoreline retreat, and inland flooding. Coastal area impacts

29 may be exacerbated by land subsidence. NRC-licensed spent fuel storage facilities are 

30 designed to be robust. They are evaluated to ensure that the performance of their safety 

31 systems, structures, and components is maintained during flooding events, and they are 

32 monitored when in use. The lowest grade above the sea level of concern for an NRC-licensed 

33 facility is currently about 4.3 m (14 ft) (75 FR 81037). In the event of climate change-induced 

34 sea-level rise, the NRC (see, e.g., 10 CFR Part 50, Appendix B, Section XVI, “Corrective 

35 Action”) requires licensees to implement corrective actions to identify and correct or mitigate 

36 conditions adverse to safety.

37 Climate change can also lead to an increase in the frequency of droughts. Increasing 

38 temperatures have made droughts more severe and widespread. Trends in droughts vary 

39 regionally. The frequency of droughts in the Southeast and West has increased. However 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-76 September 2013

1 areas in the Midwest and Great Plains have experienced a reduction in drought frequency

2 (GCRP 2009).Droughts can cause increased competition for limited water resources. Although 

3 some aspects of spent fuel storage require water, the amount of water needed is minimal and 

4 water use for spent fuel storage is not expected to cause water-use conflicts, even under the 

5 changed conditions that could be caused by climate change (see Sections 4.7, 4.8, 5.7, and 

5.8). 6 

7 Summary

8 In summary, the postulated design basis accidents considered in this draft GEIS for spent fuel 

9 pools include hazards from natural phenomena, such as earthquakes, flood, tornadoes, and 

10 hurricanes; hazards from activities in the nearby facilities; and fuel handling-related accidents. 

11 In addition, the potential effects of climate change are also considered. Based on the above

12 analysis, the environmental risk of these postulated accidents involving continued storage of 

13 spent fuel in pools are SMALL, because all important to safety structures, systems, and 

14 components involved with the fuel storage are designed to withstand these design basis 

15 accidents without compromising the safety functions.

16 4.18.1.2 Design Basis Events in Dry Cask Storage Systems

17 Design basis events are considered in the design of dry cask storage systems in accordance 

18 with NRC regulations in 10 CFR Part 72, “Licensing Requirements for the Independent Storage 

19 of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than 

20 Class C Waste.” These requirements are applicable for use of dry cask storage systems for 

21 continued storage of spent fuel at all times, including during reactor operations, and all three 

22 continued storage timeframes (i.e., short-term, long-term, and indefinite storage).

23 In the safety analysis reports for specifically licensed dry cask storage facilities, each facility 

24 licensee examines four categories of design events as defined in American National Standards 

25 Institute (ANSI) standard ANSI/ANS–57.9 (1992), which include normal, off-normal, and 

26 accidental events. Design Events I represent those associated with normal operations of an 

27 ISFSI. These events are expected to occur regularly or frequently. Examples of normal events 

28 include receipt, inspection, unloading, maintenance, and loading of a transportation cask; 

29 transfer of loaded storage casks to the storage pads; and handling of radioactive waste 

30 generated as part of the operation. The impacts from these events are similar to those of

31 normal operations at the ISFSI.

32 Design Events II represent those associated with off-normal operations that can be expected to 

33 occur with moderate frequency, approximately once per year. These events could result in 

34 members of the general public being exposed to additional levels of radiation beyond those 

35 associated with normal operations. Examples of these events include loss of external electrical 

36 power for a limited duration, off-normal ambient temperatures, a cask drop from less than the 
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September 2013 4-77 Draft NUREG‒2157

1 design allowable lift height, and off-normal transporter operation. Credible off-normal events or 

2 Design Events II rarely result in any occupational or offsite radiological consequences. During 

3 normal operations and off-normal conditions, the requirements of 10 CFR Part 20 must be met. 

4 In addition, the annual dose equivalent to any individual located beyond the controlled area 

5 must not exceed 0.25 mSv (25 mrem) to the whole body, 0.75 mSv (75 mrem) to the thyroid, 

6 and 0.25 mSv (25 mrem) to any other organ.

7 Design Events III represent infrequent events that could be reasonably expected to occur over 

8 the lifetime of the dry cask storage facility, while Design Events IV represent extremely unlikely 

9 events or design basis accidents that are postulated to occur because they establish the 

10 conservative design basis for systems, structures, and components important to safety. Design 

11 Events III and IV include more severe events, such as earthquakes, tornadoes and missiles 

12 generated by natural phenomena, floods, fire (including wildfires) and explosions, lightning,

13 accidents at nearby sites (facilities), aircraft crashes, canister leakage under hypothetical 

14 accident conditions, storage cask drop or tip-over, and loss of shielding. The dose from any 

15 credible design basis accident to any individual located at or beyond the nearest boundary of 

16 the controlled area may not exceed that specified in 10 CFR 72.106; specifically, the more 

17 limiting total effective dose equivalent of 0.05 Sv (5 rem) or the sum of deep dose equivalent to 

18 and the committed dose equivalent to any individual organ or tissue (other than eye lens) of 

19 0.05 Sv (50 rem); a lens dose equivalent of 0.15 Sv (15 rem); and a shallow dose equivalent to 

20 skin or any extremity of 0.5 Sv (50 rem).

21 The NRC assumes a DTS, or a facility with equivalent capabilities, will be needed to enable 

22 retrieval of spent fuel for inspection or repackaging as the duration and quantity of fuel in dry 

23 storage increases. A DTS would provide repackaging capability at all dry storage sites without 

24 the need to return to a pool and contingency by enabling repackaging at ISFSI-only sites. A 

25 DTS would allow onsite transfer of bare fuel assemblies from a source cask to a receiving cask 

26 (Christensen et al. 2000). The source cask can be a storage cask or a transfer cask. 

27 Confinement and shielding during fuel-transfer operations are provided by the concrete and 

28 steel structure. The facility has several subsystems including a one used to transfer the fuel 

29 assemblies.

30 Two accidents considered in the Topical Safety Analysis Report for the reference DTS are 

31 representative of the types of accidents that could result in environmental impacts. These 

32 accidents involve a stuck fuel assembly and a loss-of-confinement event.

33 A fuel assembly in a reference DTS can become stuck while being retrieved from a cask or 

34 while being inserted into a cask for repackaging. Both of these scenarios can increase the dose

35 at the site boundary because of increased time of operation, and they represent the bounding 

36 accidents. The design of the fuel-handling machine would have several safety features to make 

37 these scenarios unlikely.
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Draft NUREG‒2157 4-78 September 2013

1 Licensees of a reference DTS would be required to incorporate special recovery procedures in 

2 the facilities operational plan to free the stuck assembly, including use of special equipment 

3 through the penetrations in the wall with full viewing capabilities provided by closed-circuit 

4 television cameras. A fuel assembly may be stuck part-way out because a foreign object is 

5 between the assembly and the fuel cell or because of protrusions inside the cask. The situation 

6 could be detected because loads recorded by the fuel-assembly load cell would be abnormal

7 and appropriate actions could be taken. There would not be any time limit to complete the 

8 recovery operations because the assembly would be shielded. A special “recovery” cask may 

9 be needed if the assembly is significantly distorted. The dose from these bounding scenarios 

10 was estimated to be 0.47 mSv (47 mrem) at a distance of 100 m (330 ft) from the DTS, 

11 assuming it would take 2 weeks to free the stuck fuel assembly.

12 In a loss-of-confinement event, TN-EPRI considered a scenario in which high-efficiency 

13 particulate air filters are inoperable while the receiving cask is open and filled with 21 fuel 

14 assemblies. The accident impact analysis is based on assuming that volatile radionuclides are 

15 released from damaged fuel, including up to 10 percent of the noble gases (except that up to 

16 30 percent of the krypton-85 is released), tritium, and iodine-129. The total dose at 100 m 

17 (330 ft) is calculated to be 7.2 mSv (721 mrem).

18 Because the accident consequences would not exceed the NRC accident dose standard 

19 contained in 10 CFR 72.106, the environmental impact of the potential accidents would be 

20 SMALL.

21 Climate Change

22 Potential impacts on storing spent fuel in dry casks from variations in natural hazards resulting 

23 from climate change are the same as those for spent fuel pool storage, which include increased 

24 risk of potential flooding, submergence of structures by rising ocean levels, and competition for 

25 limited water supply caused by droughts. As described in Section 2.2, dry cask storage occurs 

26 during the short-term, long-term, and indefinite storage timeframes. Therefore, the analysis for 

27 dry cask storage would extend beyond the 60-year short-term timeframe considered in the 

28 spent fuel pool analysis. Projected future conditions include uncertainty.

29 The amount and rate of future climate change depends on current and future human-caused 

30 emissions (GCRP 2009). Quantitative expressions, such as the amount of sea-level rise 

31 identified in Section 4.18.1.1, may only extend to the end of the century, which reaches into the 

32 long-term storage timeframe. To whatever extent climate change alters the magnitude and 

33 frequency of natural phenomena during and beyond the short-term storage timeframe, the

34 NRC’s oversight authority over the licensed facilities is the mechanism that addresses the 

35 impact of natural hazards. Under current NRC regulations applicable to dry cask storage 

36 facilities, the NRC requires that the vendor or licensee include design parameters on the ability 

37 of the storage casks and spent fuel storage facilities to withstand severe weather conditions 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-79 Draft NUREG‒2157

1 such as hurricanes, tornadoes, and floods. NRC-licensed spent fuel storage facilities are 

2 designed to be robust. They are evaluated to ensure that performance of their safety systems, 

3 structures, and components is maintained in response to natural phenomena hazards. In the 

4 event of impacts induced by climate change, such as sea-level rise, the NRC regulations (e.g., 

5 10 CFR 72.172, “Corrective action”) require licensees to implement corrective actions to identify 

6 and correct or mitigate conditions adverse to safety.

7 Summary

8 In summary, the dry storage cask systems and any DTSs are designed to withstand the design

9 basis accidents without losing the safety functions. In addition, the DTSs will have special 

10 recovery procedures in the operation plan to recover from these design basis accidents if they 

11 occur.

12 4.18.1.3 Conclusion

13 All NRC-licensed dry cask storage systems are designed to withstand all postulated design

14 basis accidents (Design Events III and IV) with no loss of the safety functions. Licensees of 

15 DTSs are required to design the facilities so that all safety-related structures, systems, and 

16 components can withstand the design basis accidents without compromising safety functions. 

17 In addition, the potential effects of climate changes are considered. Based on the assessment, 

18 the environmental impact of the design basis accidents is SMALL because safety-related 

19 structures, systems, and components are designed to function during and after these accidents.

20 4.18.2 Severe Accidents

21 This section describes severe accidents, or beyond-design-basis accidents, which are accidents

22 that may challenge safety systems at a level much higher than expected, and it assesses the 

23 environmental impact of severe accidents during continued storage. The probability and 

24 consequences of severe accidents are usually considered by the NRC in probabilistic risk

25 assessments. The results of past studies for spent fuel pools and dry cask storage systems are 

26 summarized in the following sections. 

27 4.18.2.1 Severe Accidents in Spent Fuel Pools

28 The NRC examined the risk of severe accidents in spent fuel storage pools in WASH–1400 

29 (NRC 1975). WASH–1400 states that spent fuel pool accidents can arise from either loss of 

30 pool cooling, drainage of the pool, or drop of heavy objects into the pool. Subsequently, NRC 

31 developed NUREG–1353 (NRC 1989), which examined several severe accidents that can affect 

32 a spent fuel storage pool, namely loss of cooling or makeup water, inadvertent draining of the 

33 pool, and structural failure of the pool due to missiles, aircraft crashes, heavy load (shipping 

34 cask) drop, and beyond-design-basis earthquakes. NUREG–1738 (NRC 2001) examined spent

35 fuel pool accidents at decommissioning nuclear power plants. In addition to scenarios leading 
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Draft NUREG‒2157 4-80 September 2013

1 to fuel uncovery in a pool (fuel being uncovered, e.g., because of loss of cooling, loss of offsite 

2 power, heavy load drops, and fire), NUREG–1738 also examined the risk from design basis 

3 seismic events, aircraft crashes, and tornadoes to a spent fuel pool. Assessments made in 

4 these studies are briefly discussed in the following sections. 

5 Internal Events

6 In previous studies, the NRC considered a number of different types of equipment failure, or 

7 internal events, that could lead to a severe accident in a spent fuel pool. For example, all spent 

8 fuel pools have a spent fuel pool cooling and cleanup system. This safety function of this 

9 system is intended to ensure that spent fuel remains cool and covered with water during all 

10 storage conditions. In addition to General Design Criterion 2, which was summarized above, 

pools are required to meet General Design Criterion 61 or equivalent principal design criteria;

3 11

12 General Design Criterion 61 states, among other things, that systems for fuel storage and 

13 handling shall be designed with residual heat removal capability to provide reliability and 

14 testability that reflects the importance to safety of decay heat, other residual heat removal, and 

15 prevention of significant reduction in fuel storage coolant inventory under accident conditions.

16 In general, this means that spent fuel pool cooling and cleanup systems are designed to satisfy 

17 either of two bases: (1) the cooling portion of the system is designed to seismic Category I 

18 (Regulatory Guide 1.29) (NRC 2007d), Quality Group C (Regulatory Guide 1.26) guidelines 

19 (NRC 2007e); or (2) the following systems are designed to seismic Category I, Quality Group C 

20 guidelines and are protected against tornadoes: the fuel pool makeup water system and its 

21 source; and the fuel pool building and its ventilation and filtration system. Licensees prevent a 

22 significant reduction in spent fuel pool coolant inventory by providing adequate makeup water 

23 capability and designing the spent fuel pool cooling and cleanup system so that the coolant can 

24 neither be drained nor siphoned below a specified level.

25 In a 2001 study (NRC 2001), the NRC concluded that the frequency of fuel uncovery resulting 

from loss of offsite power ranges from 1.1 × 10–7 26 /yr for power losses caused by severe weather 

to 2.9 × 10–8 27 /yr for plant-related and grid-related events. Lack of external power would cause 

28 cooling systems to fail, resulting in elevated pool water temperatures and accelerated 

29 evaporation of the pool water. In the event of even a long-term loss of normal pool makeup 

30 water capability at U.S. power plants, measures that were installed in response to the 

31 September 11, 2001 terrorist attacks, plus additional measures that are required as a result of 

32 the post-Fukushima March 12, 2012, mitigating strategies order, would ensure additional 

33 defense-in-depth protection for cooling of the spent fuel. Therefore, the environmental risk of 

34 spent fuel pool releases caused by loss of offsite power is considered to be small.

 

3 U.S. facilities for which construction permits were issued before 1971 have plant-specific principal 

design criteria, because the Atomic Energy Commission (NRC predecessor) had yet to develop generic 

requirements for facility design criteria at that time.
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September 2013 4-81 Draft NUREG‒2157

1 A discussion of a postulated spent fuel pool fire resulting from loss of pool water, a limiting 

2 severe accident in a spent fuel pool, is provided in Appendix F. Appendix F describes the 

3 NRC’s finding that the License Renewal GEIS conclusion that the probability-weighted 

4 consequences of atmospheric releases, fallout onto open bodies of water, releases to 

5 groundwater, and societal and economic impacts of spent fuel pool fires are SMALL are 

6 applicable for a spent fuel pool fire during the period of continued storage.

7 External Events

8 In previous studies, the NRC considered how different types of external events, such as 

9 tornadoes, aircraft crashes, and seismic events, could lead to a severe accident in a spent fuel 

10 pool. Each of these external events was evaluated to determine the frequency of fuel uncovery 

11 associated with the event. In its 2001 study (NRC 2001), the NRC determined that seismic 

12 events had higher fuel uncovery frequencies than aircraft crashes and tornadoes. For this 

13 reason, the seismic event is summarized in this draft GEIS as a representative external event 

14 causing a severe accident. 

15 As discussed in Appendix F, numerous NRC studies have concluded that spent fuel pool 

16 structures are seismically robust and can withstand loads substantially beyond those for which 

17 they are designed (NRC 2001). During an earthquake, the walls and floor of the pool would 

18 carry the seismically induced hydrodynamic pressure from the pool water. Structural (floor, 

19 liner, or walls) failure could occur in a beyond-design-basis earthquake, if the magnitude of the 

20 event is significantly larger than that used in the design. If this occurred, water would rapidly 

21 drain out of the pool. Only a small amount of water would remain and the spent fuel would be 

22 uncovered and exposed to the air. A beyond-design-basis earthquake would also likely result in 

23 the loss of electrical power, which, in addition to any damage to pool superstructure, would 

24 cause a rise in fuel temperature due to loss of cooling. As discussed in Appendix F of this draft 

25 GEIS, if the spent fuel heats to a temperature on the order of 1,000°C (1,832°F), zirconium 

26 cladding on the spent fuel could ignite (“spent fuel pool zirconium fire”). Further, the spent fuel 

27 rod could burst due to high temperature, which could cause the collapse of the spent fuel itself. 

28 Radioactive aerosols and vapors released from the damaged spent fuel could be carried into 

29 the surrounding environment. Based on the discussion in Appendix F, the frequency of fuel 

being uncovered is very small and is between 5.8 × 10−7 and 2.4 × 10−6 30 /yr depending upon the 

31 seismic hazard assessment.

32 Climate Change

33 In its 2001 study, the NRC determined that the overall frequency of catastrophic failure caused 

34 by a tornado is extremely low (i.e., the calculated frequency of such as event is less than 

10–9 35 /yr). The Global Change Research Program (GCRP 2009) determined that there has been 

36 no clear trend in the frequency or strength of tornadoes since the 1950s for the United States as 

37 a whole. Further, although climate models project future increases in the frequency of 
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Draft NUREG‒2157 4-82 September 2013

1 environmental conditions favorable to severe thunderstorms, the inability to adequately model 

2 the small-scale conditions involved in thunderstorm development remains a limiting factor in 

3 projecting the future character of severe thunderstorms (GCRP 2009). Therefore, the NRC 

4 concludes that the risk posed by tornadoes will be comparable to the risk determined in the 

5 2001 study through the short-term storage timeframe.

6 In its 2001 study, the NRC determined that the frequency of significant damage to spent fuel 

7 pool support systems from straight-line winds, such as those from hurricanes, is very low. The 

8 NRC also estimated that the fuel uncovery frequency for loss of offsite power caused by severe 

weather events was 1.1 × 10–7 9 /yr (NRC 2001). The Global Change Research Program 

10 determined that the United States and surrounding coastal waters may experience more intense 

11 hurricanes, but not necessarily an increase in the number of these storms that make landfall 

12 (GCRP 2009). An increase in the intensity of storms that make landfall as a result of climate 

13 change may increase the likelihood of both structural failures in buildings housing spent fuel 

14 pools and loss-of-offsite-power events. While the magnitude of the change in damage likelihood 

15 cannot be quantitatively predicted at this time, an increase in storm intensity is not expected to 

16 change the NRC’s determination that the overall risk of external events on continued storage in 

17 spent fuel pools is small.

18 Summary

19 The NRC has examined the risk of severe accidents in spent fuel pools in several studies over 

20 the years. Based on these assessments, which include consideration of internal and external 

21 event initiators, the NRC concludes that the risk of severe accidents in spent fuel pools is small. 

22 4.18.2.2 Severe Accidents in Dry Cask Storage Systems

23 In March 2007, the NRC published a pilot probabilistic risk assessment of a dry cask storage 

24 system at a nuclear power plant (NRC 2007f). The study covers various phases of the dry cask 

25 storage process from loading fuel from the spent fuel pool, preparing the cask for storage and 

26 transferring it outside the reactor building, moving the cask from the reactor building to the 

27 storage pad, and storing the cask for 20 years on the storage pad. The study develops and 

28 assesses a comprehensive list of initiating events, including dropping the cask during handling 

29 and external events during onsite storage (such as earthquakes, floods, high winds, lightning 

30 strikes, accidental aircraft crashes, and pipeline explosions). Potential cask failures from 

31 mechanical and thermal loads are modeled. As shown in Table 18 of NUREG–1864, the largest 

32 conditional consequences to an individual person of postulated accidents are expected to range 

33 from 280 mrem, at a distance of less than 1 mi, up to 185 rem. One accident that results in 

34 these consequences is a postulated 5.8-m (19-ft) drop of a multipurpose canister while being 

35 lowered from the transfer cask to the storage cask. This drop can happen due to a design basis 

36 earthquake during canister handling operation and has the most severe consequence of 

37 potential drops. However, the probability of a release causing this dose consequence, which 
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September 2013 4-83 Draft NUREG‒2157

1 includes consideration of the initiating event frequency and conditional probability of release, 

given the event occurs, is about 3 × 10−5 2 /yr. Therefore, although the consequence would 

3 exceed NRC public dose standards contained in 10 CFR Part 20 (e.g., 100-mrem/yr dose limits 

4 for members of the public), the likelihood of the event is very low. Therefore, the environmental 

5 risk of an accident is SMALL.

6 Climate Change

7 In its 2007 pilot probabilistic risk assessment, described above, the NRC evaluated high winds 

8 as an initiating event for accidents. The dry cask storage system that was evaluated 

9 was the Holtec HI–STORM 100 system. This vertical cask system is in common use (see 

10 Appendix G). The 2007 study concluded that winds in excess of 644 km/hr (400 mph) would be 

11 required to cause storage cask tip-over, and winds in excess of 1,448 km/hr (900 mph) would 

12 be required to propel a heavy object into a storage cask with enough force to cause significant 

13 damage. There is no recorded evidence of tornado wind speeds in excess of 483 km/hr 

14 (300 mph) (NRC 2007f). Very few hurricanes have achieved wind speeds of 310 km/hr 

15 (190 mph) (Bender et al. 2010). Further, although climate models project future increases in the 

16 frequency of environmental conditions favorable to severe thunderstorms, the inability to 

17 adequately model the small-scale conditions involved in thunderstorm development remains a 

18 limiting factor in projecting the future character of severe thunderstorms (GCRP 2009). 

19 Therefore, the NRC concludes that the risk posed by high winds remains very low.

20 In the 2007 pilot probabilistic risk assessment, floods were considered, but deemed not able to 

21 affect the plant that was the subject of the study. In general, the effects of floods on dry cask 

22 storage systems can include cask sliding, tip-over, and blockage of ventilation ports by water 

23 and silting of air passages. Other effects include water scouring below ISFSI foundations, burial 

24 under debris, and severe temperature gradients resulting from rapid cooling from immersion in 

25 water. However, based on the relatively slow rate of changes in flood risk over time, the NRC is 

26 confident that any regulatory action that may be necessary will be taken in a timely manner to 

27 ensure the safety of dry cask storage systems.

28 Summary

29 The NRC has examined the risk of severe accidents in dry cask storage systems. Based on 

30 this assessment, which includes consideration of internal and external event initiators, the NRC 

31 concludes that the risk of severe accidents in dry cask storage systems is small. 

32 4.18.2.3 Conclusion

33 The NRC has examined the risk of severe accidents in spent fuel pools and dry cask storage 

34 systems in several studies over the years. Based on these assessments, the NRC concludes 

35 that the risk of severe accidents in spent fuel pools and dry cask storage systems is SMALL.
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Draft NUREG‒2157 4-84 September 2013

1 4.19 Potential Acts of Sabotage or Terrorism 

2 This section describes the environmental impacts of potential acts of sabotage or terrorism 

3 involving the continued storage of spent fuel. The NRC regulates the security of radioactive 

material as part of its domestic safeguards program.4 4 This program provides for regulatory 

5 requirements; licensing and NRC oversight of facility access control; fitness for duty; material 

6 control and accounting; and physical protection of spent fuel storage in onsite spent fuel pools, 

7 at-reactor and away-from-reactor ISFSIs, and monitored retrievable storage installations. 

8 This draft GEIS considers the potential risks of accidents and acts of sabotage or terrorism at 

9 spent fuel storage facilities. In 1984 and 1990, the NRC provided some discussion of the 

10 reasons why it believed that the possibility of a major accident or sabotage with offsite 

11 radiological impacts at a spent fuel storage facility is extremely remote. In the 2010 final update 

12 to the Waste Confidence Decision, the Commission gave considerable attention to the issue of 

13 terrorism and spent fuel management (75 FR 81037). The Commission concluded that 

14 [t]oday spent fuel is better protected than ever. The results of security 

15 assessments, existing security regulations, and the additional protective and 

16 mitigative measures imposed since September 11, 2001, provide high assurance 

17 that the spent fuel in both spent fuel pools and in dry storage casks will be 

18 adequately protected (75 FR 81037).

19 There is dispute among the United States Courts of Appeals as to whether NEPA analyses 

20 require consideration of terrorist attacks. In San Luis Obispo Mothers for Peace v. NRC, the 

21 Court of Appeals for the Ninth Circuit held that the NRC needed to consider the environmental 

22 impacts of terrorism in its NEPA reviews. Whereas, in 2009, the Third Circuit Court of Appeals 

23 upheld the NRC's position that terrorist attacks are too far removed from the natural or expected 

24 consequences of agency action to require environmental analysis. Nonetheless, because some 

25 continuing storage will occur within the Ninth Circuit, this draft GEIS discusses the 

26 environmental impacts of a successful terrorist attack to comply with San Luis Obispo Mothers 

27 for Peace v. NRC. The Ninth Circuit left to agency discretion the precise manner in which the 

28 NRC undertakes a NEPA-terrorism review (NRC 2008c).

29 The environmental impact for a successful terrorist attack, if one occurs, could be significant 

30 and destabilizing. The impact determinations for these attacks, however, are made with 

31 consideration of the low probability of successful attack. The environmental impact 

32 determination with respect to successful terrorist attacks, therefore, is based on risk, which 

33 the NRC defines as the product of the probability, even if only a qualitative assessment of 

 

4 The regulations in 10 CFR that are most applicable to the domestic safeguards program for spent 

nuclear fuel storage beyond the licensed life for operation are contained in Parts 11, 25, 26, 70, 72, 73, 

and 74. 
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September 2013 4-85 Draft NUREG‒2157

1 probability is available, and the consequences of a successful attack. This means that a high2 consequence, low-probability event could result in a small impact determination if the risk is 

3 sufficiently low.

4 Impacts from terrorist acts for spent fuel pool storage only apply during the short-term 

5 timeframe, and the impacts for dry cask storage are substantially the same across the three 

6 timeframes. Therefore, this section of the GEIS follows a different format from other sections by 

7 presenting the various accident types only once. The three storage timeframes (short-term, 

8 long-term, and indefinite, as described in Chapter 1) apply as follows:

9 • During short-term storage, the probability and consequences of attacks on both the onsite 

10 spent fuel pool and at-reactor ISFSI are considered. 

11 • Beyond short-term storage, spent fuel is assumed to have been moved from the spent fuel 

12 pool to an at-reactor ISFSI. Therefore, during long-term and indefinite storage timeframes, 

13 only the probability and consequences of attacks on the at-reactor ISFSI are applicable.

14 4.19.1 Attacks on Spent Fuel Pools

15 The NRC has determined that the probability of a successful terrorist attack on a spent fuel 

16 pool, although numerically indeterminable, is very low (73 FR 46204). To support this 

17 conclusion, the NRC reviewed the characteristics of spent fuel pools discussed in Chapter 2 and 

18 assessed how those features would deter terrorist attacks. Spent fuel pool structural features, 

19 complemented by the deployment of effective and visible physical security protection measures, 

20 described further below, are deterrents to terrorist attack. In addition, the emergency 

21 procedures and Severe Accident Mitigation Alternatives guidelines developed for reactor 

22 accidents provide a means for mitigating the potential consequences of terrorist attacks 

23 (73 FR 46204).

24 Further, after the terrorist attacks of September 11, 2001, the NRC issued a series of Security 

25 Orders to require licensees to implement additional interim security measures. Through these 

Orders, the NRC supplemented the Design Basis Threat rule for radiological sabotage5 26 and 

27 mandated specific licensee enhancement of security force training, access authorization, and 

28 defensive strategies, plus additional mitigative measures. In addition, through generic 

29 communications, the NRC specified expectations for enhanced notifications to the NRC for 

30 certain security events or suspicious activities.

 

5 The definition for design basis threat for radiological sabotage is contained in 10 CFR 73.1(a)(1), which 

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.
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Draft NUREG‒2157 4-86 September 2013

1 In response to the Security Orders, facility licensees revised their physical security plans, 

2 access authorization programs, training and qualification plans, and safeguards contingency 

3 plans. These revisions enhanced physical security with increased patrols, augmented security 

4 forces and capabilities, added additional security posts, added additional physical barriers, and 

5 required vehicle checks at greater standoff distances. Procedural enhancements resulted in 

6 greater coordination with law enforcement authorities, augmented security and emergency 

7 response training, equipment, and communication, and more restrictive site access controls for 

8 personnel, including expanded, expedited, and more thorough employee background 

9 investigations (NRC 2008c).

10 In 2007, the NRC amended its regulations in 10 CFR Part 73 governing licensee capability to 

11 defend against design basis threats of radiological sabotage to capture experience and insights 

12 gained by the NRC in implementing those requirements and to redefine the level of security 

13 requirements necessary to ensure adequate protection of the public health and safety and 

14 common defense and security (72 FR 12705). In 2008, the NRC amended its regulations in 

15 10 CFR Parts 50, 52, 72, and 73 to codify the appropriate requirements from the Security 

16 Orders and update those requirements with new insights gained from implementation of the 

17 Security Orders, review of site security plans, implementation of the enhanced baseline 

18 inspection program, and NRC evaluation of force-on-force exercises. This rulemaking also 

19 updated the NRC's security regulatory framework for the licensing of new nuclear power plants 

20 (74 FR 13926).

21 As discussed in more detail in the NRC’s response to a draft U.S. Government Accountability 

22 Office report on material control and accounting of spent fuel, with regard to theft and diversion 

23 of spent fuel, the NRC believes that the likelihood that an adversary could steal spent fuel from 

24 a spent fuel pool is extremely low, given the security and radiation protection measures in place, 

25 the ease of detectability, and the physically disabling radiation from the spent fuel. Further, the 

26 NRC also does not consider the threat of a knowledgeable, active insider stealing a spent fuel 

27 rod, or portion thereof, to be credible (NRC 2005d). 

28 The NRC has determined that these measures and national anti-terrorist measures to prevent, 

29 for example, aircraft hijackings, coupled with the robust nature of spent fuel pools, make the 

30 probability of a successful terrorist attack, although numerically indeterminable, very low 

31 (73 FR 46204).

32 Although a successful act of sabotage or terrorism by an armed attack is low in probability, the 

33 consequences such an act could be severe. A discussion of a postulated spent fuel pool fire

34 resulting from loss of pool water, which could result from a successful attack, is provided in 

35 Appendix F. The conditional consequences described in Appendix F include downwind 

36 collective radiation doses above one million person-rem, up to 192 early fatalities, and economic 

37 damages exceeding $70 billion. However, given the very low probability of successful attack 

38 with these consequences, the NRC determined that the risk of successful attack is small.
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September 2013 4-87 Draft NUREG‒2157

1 4.19.2 Attacks on ISFSIs 

2 Before September 11, 2001, the NRC required ISFSI licensees to comply with the security 

3 requirements specified in 10 CFR Part 72, “Licensing Requirements for the Independent 

4 Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater 

5 than Class C Waste,” and 10 CFR Part 73, “Physical Protection of Plants and Materials.” After

6 the attacks of September 11, 2001, the NRC continued to achieve this requisite assurance for 

7 all facilities licensed to store spent fuel through a combination of the existing security regulations 

8 and the issuance of Security Orders to individual ISFSI licensees. These orders ensured that a 

9 consistent, comprehensive protective strategy was in place for all ISFSIs.

10 As discussed in Chapter 2, two types of ISFSI licenses (general and specific) are available for 

11 the storage of spent fuel. Physical security requirements for these licensees appear in various 

12 sections of 10 CFR Part 73, depending on the type of licensee. The regulations in 

13 10 CFR 72.212(b)(9), "Conditions of General License Issued under §72.210," require general 

14 ISFSI licensees to establish a physical protection program that protects the spent fuel against 

15 the design basis threat for radiological sabotage in accordance with applicable security 

16 requirements imposed on nuclear power reactor licensees under 10 CFR 73.55, “Requirements 

17 for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological 

18 Sabotage.” For general-license ISFSIs, neither 10 CFR 72.212(b)(9) nor 10 CFR 73.55 imposes 

19 a dose limit for security events (i.e., acts of radiological sabotage). For specifically-licensed 

20 ISFSIs, NRC regulations at 10 CFR 73.51, “Requirements for the Physical Protection of Stored 

21 Spent Nuclear Fuel and High-Level Radioactive Waste,” require licensees to establish and 

22 maintain a physical protection system that provides high assurance that licensed activities do 

23 not constitute an unreasonable risk to public health and safety. The physical protection system 

24 must protect against the loss of control of the ISFSI that could be sufficient to cause a radiation 

25 exposure exceeding the dose described in 10 CFR 72.106 (NRC 2007i).

26 In general, the potential for theft or diversion of light water reactor spent fuel from the ISFSI with 

27 the intent of using the contained special nuclear material for nuclear explosives is not 

28 considered credible because of (1) the inherent protection afforded by the massive reinforced29 concrete storage module and the steel storage canister; (2) the unattractive form of the 

30 contained special nuclear material, which is not readily separable from the radioactive fission 

31 products; and (3) the immediate hazard posed by the high radiation levels of the spent fuel to 

32 persons not provided radiation protection (NRC 1991a, 1992). 

33 The immediate hazard posed by the high radiation levels of the spent fuel will, however, 

34 diminish over time, depending on burnup and the level of radiation deemed to provide adequate 

35 self-protection. Self-protection refers to the incapacitation inflicted upon a recipient from 

36 inherent radiation emissions in a timeframe that prevents the recipient from completing an 

37 intended task (Coates et al. 2005). This means that spent fuel could become more susceptible 

38 to possible theft or diversion over long periods of time. This susceptibility depends on the 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-88 September 2013

1 burnup; higher burnup spent fuel provides adequate self-protection for longer time periods. The 

2 Blue Ribbon Commission on America’s Nuclear Future: Report to the Secretary of Energy 

3 (2012) concluded:

4 As the duration of storage is extended, the amount of penetrating radiation 

5 emitted by spent fuel will diminish. In the process, the fuel loses a degree of 

6 “self-protection” against theft or diversion: in other words, unshielded exposure to 

7 the fuel becomes less immediately debilitating and hence creates less of a 

8 deterrent to handling by unauthorized persons. This means that over long time 

9 periods (perhaps a century or more, depending on burnup and the level of 

10 radiation that is deemed to provide adequate self-protection), the fuel could 

11 become more susceptible to possible theft or diversion (although other 

12 safeguards would remain in place). This in turn could change the security 

13 requirements for older spent fuel. Extending storage to timeframes of more than 

14 a century could thus require increasingly demanding and expensive security 

15 protections at storage sites.

16 Furthermore, for nonlight water reactor spent fuel, the period of self-protection may be lower 

17 than that of light water reactor spent fuel, depending on the burnup of the spent fuel and the 

18 isotopic composition of the special nuclear material (i.e., the attractiveness of the material).

19 Thus, additional security requirements may be necessary in the future, if spent fuel remains in 

20 storage for a substantial period of time. Therefore, it is reasonable to assume that, if necessary, 

21 the NRC will issue orders or enhance its regulatory requirements for ISFSI security, as 

22 appropriate, to ensure adequate protection of public health and safety and the common defense 

23 and security.

24 The NRC has determined that the measures described above, coupled with the robust nature of 

25 dry cask storage systems, make the probability of a successful terrorist attack, although 

26 numerically indeterminable, very low.

27 After the NRC issued the license for the Diablo Canyon ISFSI in March 2004, the Ninth Circuit

28 reviewed the licensing action and, as discussed, required the NRC to consider terrorist acts in 

29 its environmental review associated with this licensing action. In response to the Ninth Circuit 

30 decision, the NRC supplemented its EA and finding of no significant impact for the Diablo 

31 Canyon ISFSI to address the likelihood and the potential consequences of a terrorist attack 

32 directed at the ISFSI (NRC 2007i):

33 The NRC staff reviewed the analyses performed for generic ISFSI security 

34 assessments, and compared their assumptions to the relevant features of the 

35 Diablo Canyon ISFSI. Based on this comparison, the staff determined that the 

36 assumptions used in these generic security assessments regarding storage cask 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-89 Draft NUREG‒2157

1 design, source term (amount of radioactive material released), and atmospheric 

2 dispersion, were representative, and in some cases, conservative, relative to the 

3 actual conditions at the Diablo Canyon ISFSI. In fact, because of the specific 

4 characteristics of the spent fuel authorized for storage at the Diablo Canyon 

5 ISFSI (lower burnup fuel), and the greater degree of dispersion of airborne 

6 radioactive material likely to occur at the site, any dose to affected residents 

7 nearest to the Diablo Canyon site will tend to be much lower than the doses 

8 calculated for the generic assessments. Based on these considerations, the 

9 dose to the nearest affected resident, from even the most severe plausible threat 

10 scenarios – the ground assault and aircraft impact scenarios – would likely be 

11 below 5 rem. In many scenarios, the hypothetical dose to an individual in the 

12 affected population could be substantially less than 5 rem, or none at all. In 

13 some situations, emergency planning actions could provide an additional 

14 measure of protection to mitigate the consequences, in the unlikely event that a

15 successful attack were carried out at the Diablo Canyon ISFSI.

16 The specific dose results from the 2007 Diablo Canyon ISFSI EA Supplement were derived 

17 from the generic analysis performed as part of ISFSI security assessments (NRC 2003). The 

18 site-specific assumption in the EA Supplement was the distance to the nearest resident from the

19 Diablo Canyon ISFSI, which is about 2.4 km (1.5 mi). By comparison, this is more than the 

20 average distance to nearby residences for other specifically-licensed ISFSIs, which is about 

21 1.6 km (1 mi). Doses at closer residences could be larger, but are likely to remain well below 

22 levels that could cause immediate health effects. The NRC took both the estimated dose and 

23 the likelihood into consideration in making a finding of no significant impact. Thus, the NRC 

24 determines that the environmental risk is SMALL. In addition, the environmental risk of impacts 

25 on property and land resulting from downwind settling of airborne radioactive material would be 

26 SMALL.

27 In February 2011, after a challenge to the Supplemental Environmental Assessment, the Ninth 

28 Circuit issued a decision affirming its sufficiency (San Luis Obispo Mothers for Peace v. Nuclear 

29 Regulatory Commission 2011). Among other things, the Court rejected an assertion that the 

30 NRC had screened out from further review attacks that would not cause “early fatalities,” 

31 thereby excluding scenarios that would cause land degradation or nonfatal illness. The Court 

32 also concluded that the NRC had considered the relevant factors and reasonably concluded that 

33 an EIS was not necessary. 

34 4.19.3 Conclusion

35 The NRC finds that even though the environmental consequences of a successful attack on a 

36 spent fuel pool during continued storage are large, the very low probability of a successful 

37 attack ensures that the environmental risk is SMALL. Similarly, for operational ISFSIs during 

38 continued storage, the NRC finds that the environmental risk is SMALL. Therefore, the 
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-90 September 2013

1 continued storage of spent fuel will not constitute an unreasonable risk to the public health and 

2 safety from acts of radiological sabotage theft or diversion of special nuclear material.

3 4.20 Summary 

4 The impact determinations for at-reactor storage for each resource area for each timeframe are 

5 summarized in Table 4-2. For most of the resource areas, the impact determinations for all 

6 three timeframes are SMALL. Continued storage is not expected to adversely affect special 

7 species and habitats. For accidents (design basis and severe) and terrorism considerations, the 

8 environmental risks of continued storage are SMALL.

9 However, for a few resource areas, impact determinations are greater than SMALL and varied 

10 for the three timeframes. For the long-term storage and indefinite storage timeframes, during 

11 which ground disturbing activities may occur, impacts on historic and cultural resources range 

12 from SMALL to LARGE, primarily because generally licensed facilities do not require site13 specific licensing reviews. The impacts from management and disposal of nonradioactive waste 

14 would be SMALL for both the short-term and long-term timeframes but SMALL to MODERATE 

15 for indefinite storage, because of the indefinite generation of these wastes potentially affecting 

16 local and national disposal capacity.

17 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 No disproportionately 

high and adverse 

impacts

No disproportionately 

high and adverse 

impacts

No disproportionately 

high and adverse 

impacts

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

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
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-91 Draft NUREG‒2157

1 Table 4-2. Summary of Environmental Impacts of Continued At-Reactor Storage (cont’d)

Resource Area Short-Term Storage Long-Term Storage Indefinite Storage

Aquatic Ecology SMALL SMALL SMALL

Special Status Species and 

Habitats

Impacts from the 

spent fuel pool would 

be determined as part 

of ESA Section 7 

consultation; ISFSI 

operations are not 

likely to adversely 

affect

Not likely to adversely 

affect

Not likely to adversely 

affect

Historic and Cultural 

Resources

SMALL SMALL, 

MODERATE, or 

LARGE

SMALL, 

MODERATE, or 

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

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

2 4.21 References

3 10 CFR Part 11. Code of Federal Regulations, Title 10, Energy, Part 11, “Criteria and 

4 Procedures for Determining Eligibility for Access to or Control Over Special Nuclear Material.” 

5 Washington, D.C.

6 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

7 Protection Against Radiation.” Washington, D.C.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-92 September 2013

1 10 CFR Part 25. Code of Federal Regulations, Title 10, Energy, Part 25, “Access 

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3 10 CFR Part 26. Code of Federal Regulations, Title 10, Energy, Part 26, “Fitness for Duty 

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5 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

6 Production and Utilization Facilities.” Washington, D.C.

7 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

8 Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

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10 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

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17 10 CFR Part 73. Code of Federal Regulations, Title 10, Energy, Part 73, “Physical Protection of 

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19 10 CFR Part 74. Code of Federal Regulations, Title 10, Energy, Part 74, “Material Control and 

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21 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor Site 

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23 36 CFR 60. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

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25 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

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27 40 CFR Part 93. Code of Federal Regulations, Title 40, Protection of the Environment, Part 93,

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29 Washington, D.C.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-93 Draft NUREG‒2157

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16 Station Independent Spent Fuel Storage Installation. Washington, D.C. Accession 

17 No. ML091340557.

18 NRC (U.S. Nuclear Regulatory Commission). 2010. Memo from P. Hiland to B.W. Sheron 

19 dated September 2, 2010, regarding Safety/Risk Assessment Results for Generic Issue 199,

20 “Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern 

21 United States on Existing Plants.” Washington, D.C. Package Accession No. ML100270582.

22 NRC (U.S. Nuclear Regulatory Commission). 2011a. Environmental Impact Statement for the 

23 Combined License (COL) for Calvert Cliffs Nuclear Power Plant Unit 3. NUREG–1936, 

24 Volumes 1 and 2, Washington, D.C. Accession Nos. ML11129A167, ML11129A179.

25 NRC (U.S. Nuclear Regulatory Commission). 2011b. Senior Management Review of Overall 

26 Regulatory Approach to Groundwater Protection. SECY–11–0019, Washington, D.C. 

27 Accession No. ML110050525. 

28 NRC (U.S. Nuclear Regulatory Commission). 2011c. Draft Environmental Impact Statement for 

29 Combined Licenses (COLs) for William States Lee III Nuclear Station Units 1 and 2. 

30 NUREG–2111, Volumes 1 and 2, Washington, D.C. Accession Nos. ML11343A010, 

31 ML11343A011.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

September 2013 4-101 Draft NUREG‒2157

1 NRC (U.S. Nuclear Regulatory Commission). 2011d. Final Environmental Statement for the 

2 Combined Licenses (COLs) for Virgil C. Summer Nuclear Station, Units 2 and 3. 

3 NUREG–1939, Volumes 1 and 2, Washington, D.C. Accession Nos. ML11098A044, 

4 ML11098A057.

5 NRC (U.S. Nuclear Regulatory Commission). 2011e. Final Environmental Statement for the 

6 Combined Licenses (COLs) for South Texas Project Electric Generating Station Units 3 and 4. 

7 NUREG–1937, Washington, D.C. Accession No. ML11049A000. 

8 NRC (U.S. Nuclear Regulatory Commission). 2011f. Final Environmental Impact Statement for 

9 Combined Licenses (COLs) for Comanche Peak Nuclear Power Plant, Units 3 and 4. 

10 NUREG–1943, Volumes 1 and 2. Washington, D.C. Accession Nos. ML11131A001, 

11 ML11131A002.

12 NRC (U.S. Nuclear Regulatory Commission). 2011g. Fact Sheet on Seismic Issues for Nuclear 

13 Power Plants. Washington, D.C. Accession No. ML081620327.

14 NRC (U.S. Nuclear Regulatory Commission). 2011h. Revision 1 – Addressing the Construction 

15 and Preconstruction Activities, Greenhouse Gas Issues, General Conformity Determinations, 

16 Environmental Justice, the Need for Power, Cumulative Impact Analysis and Cultural/Historical 

17 Resources Analysis Issues in Environmental Impact Statements. Washington, D.C. Accession 

18 No. ML110380369.

19 NRC (U.S. Nuclear Regulatory Commission). 2012a. Environmental Assessment for the 

20 Proposed Renewal of U.S. Nuclear Regulatory Commission License No. SNM–2505 for 

21 Calvert Cliffs Nuclear Power Plant, LLC’s Independent Spent Fuel Storage Installation. 

22 Washington, D.C. Accession No. ML121220084.

23 NRC (U.S. Nuclear Regulatory Commission). 2012b. Occupational Radiation Exposure at 

24 Commercial Nuclear Power Reactors and Other Facilities 2010: Forty-Third Annual Report. 

25 NUREG–0713, Volume 32, Washington, D.C. Available at http://www.nrc.gov/reading-rm/doc26 collections/nuregs/staff/sr0713/v32/. 

27 NRC (U.S. Nuclear Regulatory Commission). 2012c. Central and Eastern United States 

28 Seismic Source Characteristics for Nuclear Facilities. NUREG–2115, Washington, D.C. 

29 Package Accession No. ML12048A776.

30 NRC (U.S. Nuclear Regulatory Commission). 2012d. Request for Information Pursuant to 

31 Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 

32 9.3 of the Near-Term Task Force Review of Insights From the Fukushima Dai-Ichi Accident. 

33 Washington, D.C. Accession No. ML12053A340.
Environmental Impacts of At-Reactor Continued Storage of Spent Fuel

Draft NUREG‒2157 4-102 September 2013

1 NRC (U.S. Nuclear Regulatory Commission). 2013a. Generic Environmental Impact Statement 

2 for License Renewal of Nuclear Plants. NUREG–1437, Revision 1, Washington, D.C. Package 

3 Accession No. ML13107A023.

4 NRC (U.S. Nuclear Regulatory Commission). 2013b. Environmental Impact Statement for the 

5 Combined License (COL) for Enrico Fermi Unit 3 Final Report. NUREG–2105, Volumes 1 and 

6 2. Washington, D.C. Accession Nos. ML12307A172, ML12307A176. 

7 NRC (U.S. Nuclear Regulatory Commission). 2013c. Generic Issue Management Control 

System Report for Fiscal Year 2013 1 8 st Quarter. GI–204 Flooding of Nuclear Power Plant Sites 

9 Following Upstream Dam Failure, Washington, D.C. Accession No. ML13007A492.

10 Prasad, R., L. Hibler, A. Coleman, and D. Ward. 2011. Design-Basis Flood Estimation for Site 

11 Characterization at Nuclear Power Plants in the United States of America. NUREG/CR–7046. 

12 U.S. Nuclear Regulatory Commission, Washington, D.C. Accession No. ML11321A195.

13 Resource Conservation and Recovery Act (RCRA) of 1976. 42 USC 6901, et seq. (1976)

14 Safe Drinking Water Act. 1974. 42 USC 300.

15 San Luis Obispo Mothers for Peace v. Nuclear Regulatory Commission (NRC). 2011. 

16 No. 08-75058, 635 F.3d 1109, U.S. Court of Appeals, Ninth Circuit.

17 Transnuclear, Inc. 2004. Final Safety Analysis Report. Volume 3 of 4, Appendix M, 

18 Standardized NUHOMS® Horizontal Modular Storage System for Irradiated Nuclear Fuel

19 Hawthorne, New York. Accession No. ML051040570.

20 Washington State Department of Transportation. 2013. Biological Assessment Preparation for 

21 Transportation Projects – Advanced Training Manual – Version 2013. Olympia, Washington. 

22 Available at http://www.wsdot.wa.gov/Environment/Biology/BA/BAguidance.htm#manual. 
September 2013 5-1 Draft NUREG‒2157

1 5.0 Environmental Impacts of Away-From2 Reactor Storage

3 This chapter evaluates the environmental impacts of continued away-from-reactor storage of 

4 spent nuclear fuel (spent fuel) in an independent spent fuel storage installation (ISFSI) beyond 

5 the licensed life for operation of a reactor during the timeframes considered in this draft “Waste 

6 Confidence Generic Environmental Impact Statement” (draft GEIS). 

7 No away-from-reactor ISFSIs of the size considered in this chapter have been constructed in 

8 the United States; however, the U.S. Nuclear Regulatory Commission (NRC) has issued a 

9 license to Private Fuel Storage, LLC (PFS) to construct and operate the Private Fuel Storage 

10 Facility (PFSF) on the Reservation of the Skull Valley Band of Goshute Indians in Tooele 

County, Utah (NRC 2006a).1 11

12 For the purposes of evaluating the environmental impacts of continued storage of spent nuclear 

13 fuel at an away-from-reactor ISFSI, the NRC evaluates the impacts of a facility of the same size 

14 as the proposed PFS ISFSI. To perform this evaluation, the NRC makes the following 

15 assumptions:

16 • The ISFSI would have the same capacity as that analyzed for the PFSF, which was 

17 designed to store up to 40,000 MTU of spent fuel. This amount of spent fuel is more than 

18 half of the amount generated to date by commercial reactors in the United States, and more 

19 than twice as much as the amount in dry storage based on the most recent data (NRC 

20 2013a). The amount of fuel storage (40,000 MTU) evaluated for the away-from-reactor 

21 ISFSI would represent all of the spent fuel from multiple reactor sites.

22 • The ISFSI would be of approximately the same physical size as that analyzed for the PFSF, 

23 which would have been built on a fenced 300-ha (820-ac) site; the actual storage facilities 

24 would have been built on a 40-ha (99-ac) portion of the site. The onsite facilities (e.g., 

25 buildings and storage pads) for the ISFSI would be similar to those for the PFSF. This 

26 aligns with the preceding assumption.

 

1 Although a license was issued, the PFSF was never constructed, and by letter dated December 20, 

2012, PFS requested that the NRC terminate the license for its proposed away-from-reactor ISFSI (PFS 

2012). Although the facility was not constructed, the NRC determined that there was reasonable 

assurance that (1) the activities authorized by the PFSF license could be conducted without endangering 

the health and safety of the public, and (2) these activities would be conducted in compliance with the 

applicable regulations of 10 CFR Part 72 (NRC 2006a). See also Appendix B, Section B.3.2.2, of this 

draft 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

Draft NUREG‒2157 5-2 September 2013

1 • The ISFSI would require a dry transfer system (DTS) similar to that described in 

2 Section 2.1.4 of this draft GEIS for the long-term storage and indefinite storage timeframes. 

3 The DTS is assumed to be built sometime after the ISFSI is built because it would not be 

4 needed immediately.

5 • Construction and operation of the ISFSI would be similar to that analyzed for the PFSF and 

6 would require workforces similar in size to those described for the PFSF, consistent with the 

7 first assumption above.

8 • No specific location is used by the NRC in the evaluation of an away-from-reactor ISFSI. 

9 However, the location of the ISFSI would be chosen to meet the siting evaluation factors in

10 Title 10 of the Code of Federal Regulations Part 72, Subpart E (10 CFR Part 72, Subpart E). 

11 For example, a site would be deemed unsuitable if adequate protection cannot be provided 

12 for design basis external events. The NRC would also consider characteristics such as 

13 population density, seismicity, and flooding potential as part of its evaluation of a proposed 

14 ISFSI site.

15 • The location of the ISFSI would likely be chosen to minimize the environmental impacts. 

16 Consultation, permitting, and other interactions with water-management agencies, 

17 ecological resource management agencies, State or Tribal Historic Preservation Officers, 

18 and others would ensure that significant impacts are avoided. The NRC assumes that an 

19 applicant would consider these factors in selecting a site.

20 The NRC believes that these assumptions are reasonable and provide an acceptable basis for 

21 developing a generic evaluation of away-from-reactor storage of spent fuel. The NRC makes no 

22 assumptions about when the ISFSI might be built. While the NRC assumes that any proposed 

23 away-from-reactor ISFSI would likely be similar to the assumed generic facility described above 

24 from the standpoint of the size, operational characteristics, and location of the facility, the NRC 

25 would evaluate the site-specific impacts of the construction and operation of any proposed 

26 facility as part of that facility’s licensing process. In this chapter, the term ISFSI refers to all of 

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

28 and the DTS is addressed separately because the NRC assumes that it would be added after 

29 the ISFSI would be placed into operation.

30 In addition to the assumptions discussed above, the analysis of the environmental impacts of an

31 away-from-reactor ISFSI are based, in general, on the description of the affected environment 

32 provided and discussed in Sections 3.1 through 3.16 for at-reactor spent fuel storage. However, 

33 some aspects of the discussions are not applicable, or are not applicable in the same way, for 

34 an away-from-reactor ISFSI. The NRC analysis will be based on the following differences:

35 • Portions of the discussion of at-reactor spent fuel storage address facilities that are in semi36 urban areas. However, the NRC assumes that an away-from-reactor ISFSI will be built in an 

37 area of low population density.
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-3 Draft NUREG‒2157

1 • Portions of the discussion of at-reactor spent fuel storage start from an assumption that 

2 socioeconomic conditions and infrastructure (e.g., access roads) have been established 

3 prior to the short-term storage timeframe due to the presence of an existing nuclear power 

4 plant. For an away-from-reactor ISFSI, the NRC assumes conditions typical in remote areas 

5 (e.g., limited pre-existing road infrastructure).

6 • Portions of the discussion of at-reactor spent fuel storage start from an assumption that 

7 certain site conditions (e.g., proximity to major waterbodies and associated historic and 

8 cultural resources) are related to the way nuclear power plants are sited. Those conditions 

9 likely would not be applicable to an away-from-reactor ISFSI. For an away-from-reactor 

10 ISFSI, NRC assumes that the site selection would be adjusted to minimize impacts on local 

11 resources, including historic and cultural resources and special status species and habitats, 

12 while acknowledging that in some cases avoiding impacts may not be possible.

13 • Portions of the discussion of at-reactor spent fuel storage assume pre-existing programs 

14 associated with operating reactors (e.g., radiological environmental monitoring program and 

15 monitoring for decommissioning) that would exist in a somewhat different form for an away16 from-reactor ISFSI. For an away-from-reactor facility, NRC bases its evaluation of the 

17 impacts of public and occupational doses on the limits and radiological monitoring 

18 requirements in 10 CFR Part 72 and 10 CFR Part 20 that are applicable to an away-from19 reactor ISFSI. 

20 • Portions of the discussion of at-reactor spent fuel storage focus on issues related to reactor 

21 plant systems (e.g., cooling-water systems, liquid and gaseous radioactive waste, and 

22 transmission lines), which would not be applicable for an away-from-reactor ISFSI. For an 

23 away-from-reactor facility, NRC bases its evaluation of impacts on the systems and 

24 supporting facilities that are expected at such an installation.

25 With these exceptions, the NRC used the descriptions of the affected environment in 

26 Sections 3.1 through 3.16 in its evaluation of the environmental impacts of an away-from-reactor 

27 ISFSI.

28 Major features of the away-from-reactor ISFSI include the canister transfer building, the DTS, 

29 the storage casks, and the storage pads. The canister transfer building is used to receive 

30 shipping casks and to move spent fuel canisters from the shipping casks to storage casks for 

31 movement to the pads. The building would also be used to move spent fuel canisters from the 

32 storage casks into shipping casks for the shipment of the spent fuel to the repository. The 

33 canister transfer building would be used in the early years and toward the end of the ISFSI’s 

34 operational period, recognizing that the shipment of the fuel from the reactors to the ISFSI might 

35 occur over a period of 20 or more years. Shipment of the fuel from the ISFSI to the repository 

36 would occur over a similar timeframe. The DTS is designed to handle spent fuel outside the 

37 storage canister, i.e., to move the fuel into a new canister if monitoring identifies the need to 
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-4 September 2013

1 replace the old canister. The DTS is used on an as-needed basis and would likely be built 

2 sometime after the ISFSI begins operations and would be used over the life of the ISFSI.

3 The potential impacts from transportation of spent fuel from an away-from-reactor ISFSI to a 

4 repository are evaluated in Chapter 6 as part of cumulative impacts. Transportation of spent 

5 fuel to an away-from-reactor storage facility is evaluated in Section 5.16.

6 The NRC does not evaluate the impacts of decommissioning of the away-from-reactor ISFSI 

7 and DTS in this chapter. The impacts of these activities are considered in the cumulative 

8 impacts analysis in Chapter 6.

9 For the short-term storage timeframe (see Section 1.8.2), the NRC evaluates the impacts of

10 continued storage of spent fuel 60 years beyond the licensed life for operations of a reference 

11 reactor. The NRC assumes that a repository would become available by the end of this 60-year 

12 timeframe. 

13 Short-term storage of spent fuel for 60 years beyond licensed life for operations at an away14 from-reactor ISFSI includes the following: 

15 • construction and continued operation of the ISFSI

16 • routine maintenance and monitoring of the ISFSI 

17 • cask handling and transfers

18 For the long-term storage timeframe, the NRC evaluates the impacts of continued storage for 

19 another 100 years after short-term storage. The NRC assumes that a repository would become 

20 available by the end of this 100-year timeframe and that the oldest fuel would be transferred to 

21 the repository first.

22 Long-term storage activities include the following: 

23 • continued operation and routine maintenance and monitoring of the away-from-reactor 

24 ISFSI

• construction and operation of a DTS2 25

26 • one-time replacement of the ISFSI (i.e., replacement of casks and canisters, concrete pads, 

27 and canister transfer building) and the DTS (see Section 1.8.2)

 

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 pursuant to 10 CFR Part 51. 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-5 Draft NUREG‒2157

1 For the indefinite storage timeframe, the NRC has also evaluated the environmental 

2 consequences within each resource area for a scenario assuming a repository does not become 

3 available, thus requiring indefinite onsite storage. Although the NRC does not believe this 

4 scenario is reasonably foreseeable (see Section 1.2 of this draft GEIS), impact determinations 

5 for indefinite storage and fuel handling at an away-from-reactor ISFSI have been made for each 

6 resource area. The activities associated with indefinite storage are the same as those for the 

7 long-term storage timeframe, except that they would occur repeatedly due to the lack of a 

8 repository. As discussed in Chapter 1, the ISFSI (i.e., casks and canisters, concrete pads, and 

9 canister transfer building) and the DTS would be replaced on a 100-year cycle.

10 Sections 5.1 through 5.19 evaluate potential impacts on various resource areas, such as land 

11 use, air quality, and water quality. Within each resource area, the NRC provides an analysis of 

12 the potential impacts and an impact determination − SMALL, MODERATE, LARGE − for each 

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

14 authorizing regulation or statute (e.g., “not likely to adversely affect” for endangered species). 

15 Section 5.20 provides a summary of the environmental impacts.

16 5.1 Land Use

17 This section describes land-use impacts caused by the continued storage of spent fuel at an 

18 away-from-reactor ISFSI.

19 5.1.1 Short-Term Storage

20 The environmental impacts on land use from the construction and operation of an away-from21 reactor storage facility are based on a facility similar to the PFSF (NRC 2001), built at a location 

22 selected based on the assumptions presented above. The ISFSI would be designed to store up 

23 to 40,000 MTU of spent fuel on a fenced 300-ha (820-ac) site. Storage pads for the canisters 

24 and some support facilities would be located on a 40-ha (99-ac) restricted access area within

25 the site.

26 Construction activities associated with the ISFSI would be limited to the immediate area of the 

27 ISFSI site and would primarily consist of clearing, excavation, and grading of the 40-ha [99-ac]

28 restricted access area where the storage pads and major buildings would be located. In 

29 addition, one or more access roads and a rail spur would likely have to be either built or 

30 improved. Based on its past experience and judgment, the NRC assumes that (1) disturbed 

31 areas around the ISFSI site and associated corridors would be graded and reseeded after 

construction is completed, (2) permits 32 3 would require best management practices (BMPs) such 

33 as construction of flood diversion berms to control erosion and the installation of silt fencing and 

 

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

Draft NUREG‒2157 5-6 September 2013

1 sediments traps to stabilize disturbed soils to reduce land-use impacts, and (3) the 40-ha 

2 (99-ac) restricted access area would be enclosed with chain-link security fencing. For the 

3 PFSF, the total amount of land disturbed for construction, including the access road and rail 

4 line, was 408 ha (1,008 ac) and the rail line represented more than three-quarters of the land 

5 disturbed. Of the land disturbed, 288 ha (713 ac) was to be revegetated after construction and 

6 120 ha (295 ac) was expected to remain cleared; the rail line represented more than half of that 

7 value (NRC 2001). Although these numbers are specific to the PFSF analysis, based on the 

8 assumptions presented in the introduction to this chapter, they provide a reasonable 

9 representation of the amount of land disturbance that could be expected at another location 

10 because the rail line was fairly long at 51 km (32 mi).

11 Construction of the proposed ISFSI would change the nature of land use within the site 

12 boundary and along the access corridors. While this change would be qualitatively substantial 

13 (e.g., from agricultural to industrial), the land parcel is assumed to be sufficiently remote and 

14 relatively small (compared, for example, to any surrounding county) so that no quantitatively 

15 significant impact would occur. By way of comparison, for the Levy Nuclear Plant, the NRC 

16 concluded that the land-use impacts for the plant (not including transmission lines) “would not 

17 noticeably alter the existing land uses within the vicinity and region.” The Levy project (not 

18 including transmission lines) would have affected just over 405 ha (1,000 ac) (NRC 2012b).

19 Operation of the proposed ISFSI would involve transportation of spent fuel from reactors to the 

20 ISFSI and receiving, transferring, and storing the spent fuel. Impacts on land use during ISFSI

21 operations would create no additional impacts on land use beyond those for the construction of 

22 the facility. This generic analysis and associated findings are consistent with the findings for the 

23 PFSF (NRC 2001).

24 Based on its review, the NRC concludes that the impacts on land use from the construction and 

25 operation of an away-from-reactor ISFSI would be SMALL. This is because the land parcel for 

26 the ISFSI is assumed to be remote and relatively small. 

27 5.1.2 Long-Term Storage

28 As discussed in the introduction to this chapter, the NRC assumes that a DTS is constructed as 

29 part of an away-from-reactor ISFSI. The NRC also assumes that the DTS will be built inside the 

30 confines of the ISFSI’s 40-ha (99-ac) restricted area – a reasonable assumption considering the 

31 small area (0.04 ha [0.1 ac]) required for the DTS basemat and 0.7 ha (2 ac) for the DTS 

32 security zone. The DTS would be used to facilitate transfer of the spent fuel canister from one 

33 cask to another, retrieve and repackage spent fuel, or replace damaged canisters or packages 

34 identified during visual inspections. Construction and operation of a DTS at an away-from35 reactor ISFSI would be based on Section 2.1.4 of this draft GEIS.
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-7 Draft NUREG‒2157

1 By comparison, the canister transfer building at the PFSF would have been a fully enclosed 

2 high-bay building equipped with cask transfer and handling equipment (e.g., overhead and 

3 gantry cranes) and radiation-shielded transfer cells for transferring the spent fuel canisters from 

4 shipping casks to the storage casks (NRC 2001). The building would have occupied about 

5 0.5 ha (1.2 ac) within the 40-ha (99-ac) restricted access area where the storage pads, major 

6 buildings, and access roads would have been located (NRC 2001). It is possible such a 

7 building would be equipped or could be retrofitted with the necessary equipment for retrieval 

8 and repackaging of spent fuel. However, for the purposes of the analysis in this draft GEIS, the 

9 NRC assumes that a separate DTS will be constructed.

10 The NRC assumes that construction of a DTS would take 1 to 2 years based on a construction 

11 schedule similar to that for the canister transfer building at the PFSF, which was estimated to 

12 take approximately 18 months (NRC 2001). Construction equipment would be used to grade 

13 and level the DTS site and excavate the facility foundation. Construction of the DTS structures 

14 would disturb about 0.04 ha (0.1 ac) of land. In addition, the NRC expects that land adjacent to 

15 a DTS would be disturbed for a construction laydown area. Based on its past experience and 

16 judgment, the NRC assumes that after the construction of the DTS is completed (i.e., about 1 to 

17 2 years), the construction laydown area would be reclaimed and revegetated. The DTS would 

18 be built within an area for which access is already restricted, and it would represent a small 

19 increase in the amount of land that is disturbed within that restricted area.

20 The NRC assumes that aging management would require the replacement of an away-from21 reactor ISFSI (i.e., the concrete storage casks and concrete storage pads, and canister transfer 

22 building) and the DTS during long-term storage. The replacement facilities would likely be 

23 constructed on land near the existing facilities. The old facilities would most likely be 

24 demolished and the land reclaimed. Regardless, this land would be inside the 40-ha (99-ac) 

25 restricted area and it would be unavailable for other uses for as long as the ISFSI exists.

26 In conclusion, construction of a DTS would disturb a small portion of the land committed for an 

27 away-from-reactor ISFSI. Operational impacts would include continuing to restrict access to the 

28 facility site and use of the site for spent fuel transfer, handling, repackaging, and aging 

29 management. To minimize land-use impacts from replacing storage casks, storage pads, the 

30 canister transfer building, and the DTS, replacement facilities would likely be constructed on 

31 land near the existing facilities. Therefore, the NRC concludes that the impact on land use from 

32 long-term storage of spent fuel at an away-from-reactor ISFSI would be SMALL.

33 5.1.3 Indefinite Storage

34 This section describes the potential environmental impacts on land use if a repository is not 

35 available to accept spent fuel. For this analysis, the NRC assumes that spent fuel would 

36 continue to be stored at an away-from-reactor ISFSI indefinitely.
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-8 September 2013

1 The environmental impacts on land use from continued operation of dry cask storage of spent 

2 fuel at an away-from-reactor ISFSI if a repository is not available would be similar to those 

3 described in Section 5.1.2. All operations and maintenance activities would occur inside the 

4 40-ha (99-ac) restricted area, which would remain unavailable for other uses for as long as the 

5 ISFSI exists. These activities would occur repeatedly because the spent fuel would remain at 

6 the facility indefinitely.

7 In conclusion, continued storage of spent fuel in an away-from-reactor ISFSI indefinitely (i.e., if a 

8 repository is not available) would affect only a small portion of the total land area developed for 

9 the storage facility and would not change land-use conditions. Therefore, NRC concludes that 

10 the environmental impacts on land use from indefinite storage of spent fuel at an away-from11 reactor ISFSI would be SMALL.

12 5.2 Socioeconomics 

13 This section describes socioeconomic impacts caused by the continued storage of spent fuel at 

14 an away-from-reactor ISFSI. Several types of impacts could occur, including impacts on 

15 population, economy, housing, education, and public services.

16 5.2.1 Short-Term Storage

17 Construction activities would be temporary and would occur mainly within the boundaries of the 

18 ISFSI site. As discussed in the introduction to this chapter, the NRC used the characteristics of 

19 the PFSF (e.g., land area affected and size of workforce) in its analyses. There would be 

20 incremental changes to offsite services to support construction activities, such as the 

21 transportation of construction materials. Most of the construction workforce (255 workers at its 

22 peak) is expected to come from within the region, and those workers who might relocate to the 

23 region would represent a small percentage of the surrounding area’s population base. Because 

24 of the relatively short duration of the construction project, few, if any, of the workers who migrate 

25 to work at the site would be accompanied by their families. As a result, the impacts on housing, 

26 education, and public services are expected to be minor. Aside from the direct impacts 

27 associated with the project, there would also be indirect impacts from jobs created in the area. 

28 For example, the purchase of goods by workers onsite and in the local community could create 

29 additional jobs. However, unlike jobs associated directly with the construction of the ISFSI, 

30 indirect jobs are more likely to be filled by local residents. Because the number of workers is 

31 small, the impacts on the local and regional economy and services would be minor.

32 During ISFSI operation, employees would continue to maintain, monitor, and inspect the facility. 

33 The NRC estimates that the number of operations workers would be around 43 based on the 

34 PFSF environmental impact statement (EIS) (NRC 2001). In contrast to construction, for which 

35 workers may or may not relocate, workers employed for the operation of the storage facility, if 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-9 Draft NUREG‒2157

1 they were not from the local area, would be expected to move into the area with their families. 

2 Again, because the number of workers is small, the impacts on the population and services 

3 would be minor.

4 Local and State governmental agencies would receive tax payments from the ISFSI licensee. 

5 The impact of the payments would depend on a number of factors, including the pre-existing 

6 economic conditions. If the local jurisdiction(s) already have a significant tax base, then the 

7 addition of taxes from the ISFSI would have a minor beneficial impact. But if the pre-existing 

8 local tax base was small, then the NRC would conclude that the new tax revenue would have a 

9 significant beneficial impact. For the PFSF, the NRC concluded that there would be a large 

10 impact on the Skull Valley Band and on Tooele County from the payments made by PFS (NRC 

11 2001). Based on the assumption that any away-from-reactor ISFSI would be built in an area 

12 with low population density, the NRC concludes that local impacts on the economy would be 

13 significant and beneficial, but that the beneficial impacts beyond the host jurisdiction would be 

14 minor.

15 In the PFSF EIS, the NRC concluded that construction and operation of away-from-reactor 

16 storage would have SMALL impacts on the local population, housing, education, and public 

17 services (NRC 2001). Considering the very sparse population around the PFS site (30 persons 

18 on the Reservation and a total of about 150 persons in all of Skull Valley), the NRC concludes 

19 that the impacts at any site would be similar to those described for the PFSF. Based on the 

20 small workforce required for construction and operations of an away-from-reactor facility, and 

21 any associated indirect impacts on public services, housing, and education, the NRC concludes 

22 that the impacts of construction and operation of a storage facility on those resources would be 

23 SMALL. Beneficial impacts on the economy would be LARGE in the local area.

24 5.2.2 Long-Term Storage

25 A DTS constructed as part of an away-from-reactor ISFSI would be used to facilitate the 

26 replacement of spent fuel canisters as part of aging management practices. The construction of 

27 the facility would require a workforce smaller than that required for construction of an away28 from-reactor ISFSI. Similar to the construction of the ISFSI, the workers would come from a 

29 combination of the already-existing workforce or commute into the area from surrounding 

30 communities, but workers would be unlikely to move into the area for DTS construction because 

31 of the short duration of the project. Therefore, the impacts from the construction of the DTS are 

32 bounded by those associated with the construction of the ISFSI discussed in Section 5.2.1.

33 A staged approach to aging management would require the replacement of an away-from34 reactor ISFSI (e.g., the concrete storage casks, concrete storage pads, and canister transfer 

35 building) and replacement of the DTS during the long-term storage timeframe. The workforce 

36 related to the replacement of these structures and components would be similar to or less than 

37 the workforce required for the original construction of the ISFSI, depending on how the work is 
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-10 September 2013

1 spread out over time. Therefore, the socioeconomic impacts of these workers would be similar 

2 to or less than the impacts of the original construction of the ISFSI. In addition, the operational 

3 and maintenance activities begun during the short-term timeframe would continue, as would the 

4 tax payments to local jurisdictions.

5 As discussed above, the impacts from long-term operation and maintenance of the ISFSI are 

6 bounded by those described in Section 5.2.1. Therefore, the NRC concludes the 

7 socioeconomic impacts on public services, housing, and education from the transfer, handling, 

8 and aging management of an away-from-reactor storage facility would be SMALL. Beneficial 

9 impacts on the economy would be LARGE in the local area.

10 5.2.3 Indefinite Storage

11 This section evaluates the socioeconomic impacts of away-from-reactor storage assuming a 

12 repository does not become available. The same operations and maintenance activities 

13 described in Section 5.2.2 occur repeatedly because the spent fuel remains at the facility 

14 indefinitely. Therefore, the NRC concludes that the socioeconomic impacts on public services, 

15 housing, and education from indefinite storage would be SMALL. Beneficial impacts on the 

16 economy would be LARGE in the local area.

17 5.3 Environmental Justice

18 This section describes impacts on minority and low-income populations caused by the 

19 continued storage of spent fuel at an away-from-reactor ISFSI.

20 See Sections 3.3 and 4.3 for discussion of the approach the NRC uses to evaluate issues 

21 related to environmental justice. The discussion in both sections is also applicable to the 

22 consideration of environmental justice for an away-from-reactor ISFSI.

23 In most cases, NRC environmental justice analyses are limited to evaluating the human health

24 effects of the proposed licensing action and the potential for minority and low-income 

25 populations to be affected. Issues related to environmental justice and demographic conditions 

26 (i.e., the presence of potentially affected minority and low-income populations) differ from site to 

27 site, and environmental justice issues and concerns usually cannot be resolved generically. In 

28 each site-specific review, the NRC addresses environmental justice issues and concerns during 

29 the environmental review by identifying potentially affected minority and low-income 

30 populations. The NRC identifies minority and low-income populations by examining any 

31 potential human health or environmental effects on these populations to determine if these 

32 effects may be disproportionately high and adverse. Resource areas that might create human 

33 health and other environmental impacts include, but are not limited to, air quality, land use, 

34
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September 2013 5-11 Draft NUREG‒2157

1 water, and ecological resources. Consequently, environmental justice, as well as other 

2 socioeconomic issues, is normally considered in site-specific environmental reviews 

3 (69 FR 52040).

4 In the present case, however, the NRC has determined that it can provide an assessment of the 

5 environmental justice impacts for the construction and operation of an away-from-reactor ISFSI. 

6 As previously stated in Chapters 2 and 3, this draft GEIS and the Waste Confidence rule are not 

7 licensing actions and do not authorize the continued storage of spent fuel. The environmental 

8 analysis in this draft GEIS fulfills a small part of the NRC’s National Environmental Policy Act of 

9 1969, as amended (NEPA) obligation with respect to the licensing or relicensing of an away10 from-reactor ISFSI. Further, the site-specific NEPA analysis that is required prior to an NRC 

11 licensing action will include a discussion of the impacts on minority and low-income populations, 

12 and will appropriately focus on the NRC decision directly related to specific licensing actions. 

13 As with all other resource areas, this site-specific analysis will allow the NRC to make an impact 

14 determination with respect to environmental justice for each NRC licensing action. For the 

15 purposes of this draft GEIS, a generic assessment of the environmental justice impacts during 

16 continued storage at an away-from-reactor ISFSI is possible because the NRC understands 

17 how such a facility will be sited.

18 5.3.1 Short-Term Storage

19 The construction and short-term operation of an away-from-reactor ISFSI could raise concerns 

20 related to environmental justice. 

21 As previously explained in Section 5.2.1, the small workforce is expected to have minimal 

22 effects on the local economy and services. There may be some beneficial impacts from 

23 increased job opportunities, and there would be beneficial impacts from the taxes paid to local 

24 jurisdictions. But the NRC does not expect there to be any disproportionately high and adverse 

25 impacts on any minority or low-income populations in the area.

26 Radiation doses to surrounding populations would be maintained within regulatory limits (e.g., 

27 10 CFR Part 20), ensuring minor impacts. In addition, the licensee is required by 10 CFR 

28 72.44(d)(2) to implement an environmental monitoring program to ensure compliance with 

29 effluent limitations. Based on a review of recent radiological environmental monitoring program 

30 (REMP) reports, human health impacts would not be expected in special pathway receptor 

31 populations living near a nuclear power plant as a result of subsistence consumption of water, 

32 local food, fish, and wildlife during continued storage of spent fuel. Unlike the operation of 

33 nuclear reactors, the operation of the ISFSI is not expected to have any routine radiological 

34 effluents. Therefore, the results for reactors bound the results for the away-from-reactor ISFSI. 

35 The NRC concludes that there would not be any disproportionately high and adverse

36 radiological human health or environmental impacts on any minority or low-income populations 

37 in the area during short-term storage.
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Draft NUREG‒2157 5-12 September 2013

1 Regarding visual impacts, the NRC expects the canister transfer building to be the largest 

2 building on the site. For the PFSF, this building would have been approximately 60 m (200 ft) 

3 wide, 80 m (260 ft) long, and 27 m (90 ft) high (NRC 2001). Using the 300-ha (820-ac) site area 

4 for the PFSF as a guide, the site boundary would be approximately 0.8 km (0.5 mi) from the 

5 facility. At this distance the NRC concludes that visual impacts on nearby residents would be 

6 minimal. Depending on the location of minority or low-income populations, such populations 

7 could experience an adverse impact. However, it would be a minor impact, so it would not meet 

8 the criterion of a disproportionately high and adverse impact.

9 Regarding noise, in Section 5.13 the NRC concludes that impacts near the site could be 

10 MODERATE at times during construction and operations. If minority or low-income populations

11 are concentrated near the site boundary or transportation routes, they could experience 

12 noticeable impacts to a greater degree than populations living farther away. But the NRC does

13 not expect that these impacts would be disproportionately high and adverse. However, based 

14 on the NRC’s experience with the Louisiana Energy Services Claiborne Enrichment Center, if 

15 impacts appeared to be disproportionately high and adverse, it is likely that the facility would be 

16 relocated or plans modified to mitigate the impacts. The Louisiana Energy Services facility was 

17 originally proposed for a location in Louisiana. However, the applicant eventually decided to 

18 withdraw its application (LES 1998; NRC 1998). A key outstanding issue for this project was an 

19 environmental justice concern identified during the licensing review.

20 The adverse impacts on air quality, land use, and socioeconomics are discussed elsewhere in 

21 this chapter and the NRC concluded that these impacts would be SMALL. However, to reach a 

22 conclusion regarding environmental justice, the NRC must consider whether minority or low23 income populations would be subjected to disproportionately high and adverse impacts.

24 During the environmental review for a specific ISFSI, the NRC would collect information about 

25 nearby minority or low-income populations and any special characteristics (e.g., subsistence 

26 fishing) of those populations. The NRC would use this information to evaluate the potential for 

27 disproportionately high and adverse impacts on those populations. Such a review was 

28 performed for the PFSF and the NRC concluded that “no disproportionately high and adverse

29 impacts will occur to the Skull Valley Band or to minority and low income populations living near 

30 the proposed rail routes from the proposed action” (NRC 2001). The NRC notes that this 

31 conclusion was reached in a case in which the nearest population was a minority and low32 income population.

33 For this generic analysis, it is not possible to define the characteristics of minority or low-income 

34 populations around the ISFSI and the transportation corridor. However, environmental justice

35 would be one of the factors considered in the siting and licensing of any ISFSI. Using past 

36 licensing experience as an indicator, disproportionately high impacts on minority or low-income 

37 populations would likely be avoided. Other than the PFS EIS, other examples include the 

38 licensing for new reactors (projects on a much larger scale in terms of most impact areas), 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-13 Draft NUREG‒2157

1 license renewal for operating reactors, and the licensing review for the Louisiana Energy 

2 Services Claiborne Enrichment Center, as discussed above.

3 Based on this experience, the NRC concludes that, while it is possible that an away-from4 reactor ISFSI could raise environmental justice concerns, the process of siting and licensing 

5 such a project would be expected to ensure that any such issues are addressed before a facility 

6 is licensed and that there would be no significant environmental justice impacts. Therefore, 

7 impacts associated with the construction and operation of an away-from-reactor ISFSI could be 

8 disproportionate, but are not expected to be disproportionately high and adverse. 

9 5.3.2 Long-Term Storage

10 The construction of a DTS would occur within the facility boundaries. NRC authorization to 

11 construct and operate a DTS would constitute a Federal action under the NEPA and would be 

12 addressed through a site-specific analysis that would include an analysis of the potential effect 

13 on minority and low-income populations. The environmental review for the DTS would not rely 

14 on the analysis in this draft GEIS, because the site-specific NEPA analysis would consider the 

15 site-specific impacts on minority and low-income populations.

16 Impacts from construction of the DTS would include the potential for an increase in labor 

17 demand similar to that described under the initial construction of the away-from-reactor facility, 

18 although on a somewhat smaller scale (60 to 80 workers, see Sections 4.2.2 and 4.3.2). The 

19 activities associated with building an away-from-reactor ISFSI are described in the PFSF EIS 

20 (NRC 2001). Because building the DTS is a much smaller project and would occur within the 

21 ISFSI protected area, the description from the PFSF EIS activities bound the activities 

22 necessary to build the DTS. Therefore, the NRC concludes that the impacts from construction 

23 of the DTS would be bounded by the impacts from the construction of the away-from-reactor 

24 ISFSI, as discussed in Section 5.3.1. 

25 Aging management would include continued monitoring, maintenance, and a staged approach 

26 to replacement of ISFSI facilities and components (e.g., casks, pads, and canister transfer 

27 building) and the DTS. Activities associated with aging management are described in 

28 Sections 4.1.2, 4.15.2, and 5.1.2. The activities would occur over the duration of operation and 

29 be contained within the restricted area of the ISFSI. In addition, the dose at the site boundary 

30 would decrease over time because of the decay of the radioactive materials in storage.

31 Due to the passive nature of operations, and the temporary nature of any construction 

32 associated with the DTS and replacement of the ISFSI and the DTS, and based on the analysis 

33 in Section 5.3.1, the NRC concludes the impacts on minority and low-income populations would 

34 not be disproportionately high and adverse.
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Draft NUREG‒2157 5-14 September 2013

1 5.3.3 Indefinite Storage

2 The environmental impacts on minority and low-income populations if a repository is not 

3 available to accept spent fuel and away-from-reactor storage continues indefinitely are the same 

4 as the impacts for long-term storage, as described in Section 5.3.2. The only difference is that 

5 the activities required for maintenance and replacement of the ISFSI and the DTS would be 

6 repeated indefinitely. Therefore, NRC concludes that the impacts on minority and low-income 

7 populations for indefinite storage would not be disproportionately high and adverse.

8 5.4 Air Quality

9 This section describes air quality impacts caused by the continued storage of spent fuel at an 

10 away-from-reactor ISFSI. See Section 3.4.3 for additional information regarding air quality 

11 standards.

12 5.4.1 Short-Term Storage

13 For the purposes of its analysis of air quality impacts in this draft GEIS, the NRC will use the 

14 information regarding the emissions from construction and operations activities at the PFSF

15 (e.g., construction vehicles, land disturbance, fuel receipt, and routine maintenance and 

16 monitoring), because they would be representative of the activities and air emission levels of a 

17 similar away-from-reactor ISFSI, regardless of location. In the PFSF EIS (NRC 2001), the NRC 

18 examined air quality impacts related to construction and operation of a consolidated ISFSI with 

19 a capacity of 40,000 MTU, as well as the construction of a rail spur to transport spent fuel to and 

20 from the ISFSI, located in a National Ambient Air Quality Standards attainment area. Fugitive 

21 dust would have the greatest influence on air quality during construction. As stated in the PFSF 

22 EIS, the magnitude of the impact depends in part on the proximity to receptors. For the 

23 construction analysis for the onsite facilities the PFSF EIS concluded that the impacts were 

24 SMALL. Atmospheric concentrations of particulate matter with an aerodynamic diameter of 

10 microns or less (PM−10 25 ) were modeled between 1.13 km (0.7 mi) from the center of the 

26 proposed facility (i.e., the distance to the nearest publicly owned land) and 3.5 km (2.2 mi) from 

27 the center of the proposed facility (i.e., the distance to the nearest residence). Emissions from 

28 vehicles were also considered. A maximum of 10 equipment operators were expected to be 

29 onsite at any one time, and emissions from construction-related equipment were expected to be 

30 small. However, due to the large extent of the disturbed area, fugitive dust emitted from 

31 excavation and earthwork could lead to local increases in particulate matter concentrations. In 

32 its analysis for the PFSF, the NRC made conservative assumptions including the following:

33 • The entire site area of 30 ha (75 ac) would undergo heavy construction at the same time.

34 • Construction was assumed to occur continuously during a 9-hour shift (8 a.m. to 5 p.m. each 

35 day).
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-15 Draft NUREG‒2157

1 • Background sources of dust from within a 50-km (32-mi) radius of the site were added to the 

2 construction-related dust.

3 • No mitigation was assumed as a result of natural obstructions (e.g., mountains) that exist 

4 between background sources and the PFSF site.

5 Even when the construction was assumed to be as intensive as that assumed for the PFSF, the 

6 modeled concentrations of particulate matter from PFSF construction activities were below the 

7 regulatory standards associated with the allowable increases in emission levels for individual 

8 projects (i.e., Prevention of Significant Deterioration Class II limits under the Clean Air Act).

9 For the rail-spur construction analysis, the PFSF EIS concluded that the temporary and 

10 localized effects of fugitive dust could produce MODERATE impacts in the immediate vicinity 

11 where the rail spur and Interstate 80 were near each other and SMALL impacts elsewhere. 

12 Atmospheric concentrations of PM−10 were modeled for a total area of 5 ha (12.4 ac) where the 

13 rail line ran approximately parallel to Interstate 80 and the rail spur was as close as 50 m 

14 (164 ft) to the highway. Dust levels were noticeable, and dust control mitigation measures 

15 (e.g., surface wetting) were included to ensure compliance with National Ambient Air Quality 

16 Standards. 

17 For an away-from-reactor ISFSI, the NRC assumes that, if necessary, any site-specific permits

18 would include appropriate mitigation to ensure that impacts would not be destabilizing to local 

19 air quality. An applicant would also have to comply with the requirements of the General 

20 Conformity Rule (Section 176 of the Clean Air Act) if the area in which the ISFSI is to be built 

21 has not met the National Ambient Air Quality Standards. Thus, the Clean Air Act permitting 

22 process provides a regulatory mechanism to ensure that particulate concentrations created by 

23 ISFSI construction would be held below regulatory standards and mitigated as appropriate to 

24 protect ambient air quality.

25 The construction of an away-from-reactor ISFSI of the size assumed by the NRC in the 

26 introduction to this chapter of the draft GEIS would generate emissions similar to those 

27 evaluated in the PFSF EIS because similar activities would have to be carried out at the generic 

28 facility. Based on the emission levels associated with continued storage, construction impacts 

29 would depend on the proximity of the receptor to the emission-generating activities. The NRC 

30 expects that noticeable impacts resulting from the proximity between emission sources and 

31 receptors would more likely be associated with rail-spur construction rather than ISFSI facility 

32 construction because of the distance between the ISFSI construction activities and the site 

33 boundary. Therefore, the NRC concludes that for an area that is in attainment for the National 

34 Ambient Air Quality Standards, the construction impacts could range from not noticeable to 

35 noticeable but not destabilizing.
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-16 September 2013

1 The NRC also considered how construction-related emissions might affect areas designated by 

2 the U.S. Environmental Protection Agency (EPA) as “maintenance” or “nonattainment” for 

criteria pollutants.

4 3 Estimated annual emissions of criteria pollutants at the PFSF were much 

4 lower than de minimis levels described in 40 CFR 93.153, “Applicability.” For example, the 

5 applicant for the PFSF estimated that emissions of nitrogen oxides, a precursor to ozone, would

6 have been less than 10 T/yr (PFS 2001). The de minimis level of emissions in even an extreme 

7 nonattainment area for ozone is 10 T/yr.

8 Based on the emission levels discussed above, the NRC concludes that the air quality impacts 

9 related to construction of a consolidated ISFSI could range from not noticeable to noticeable but 

10 not destabilizing in any air quality region. Noticeable but not destabilizing impacts, if they occur, 

11 would be due to fugitive dust emissions in the areas immediately adjacent to the rail-spur

12 construction activities.

13 As stated in the PFSF EIS (NRC 2001), during operations the PFSF would not have been a 

14 “major stationary source” of air emissions as defined in 40 CFR 52.21(b). The PFSF analyses 

15 considered emissions from sources such as space heaters, emergency generators, and a 

16 concrete batch plant, as well as vehicle emissions, and stated that if the emissions from these 

17 sources were combined, the total would not be expected to exceed the significance levels for 

18 Prevention of Significant Deterioration analysis specified in 40 CFR 51.166(b)(23)(i). The PFSF 

19 EIS concluded that the operations impacts on air quality would be SMALL. The NRC 

20 determined that the results of this PFSF EIS would be applicable to any away-from-reactor 

21 ISFSI with a similar 40,000-MTU capacity because the types of emission-generating activities 

22 and associated emission levels would be similar. Therefore, the NRC concludes that the air 

23 quality impacts from the operation of the ISFSI would be minor.

24 Transportation of spent fuel from reactor sites to the away-from-reactor ISFSI could also 

25 contribute to air quality impacts. In the PFSF EIS, the NRC stated that the locomotives using 

26 the rail line would have emitted pollutants in any one area for a very short period before moving 

27 on. The NRC concluded that the associated air quality impacts would be small (NRC 2001). 

28 For the analysis of an away-from-reactor ISFSI in this draft GEIS, the NRC concludes that the 

29 basis for the PFSF conclusion would be applicable to any ISFSI because the same amount of 

30 fuel would have to be transported over similar distances. Therefore, the air quality impacts 

31 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

September 2013 5-17 Draft NUREG‒2157

1 Overall, the NRC concludes that the air quality impacts from the construction and short-term 

2 operation of an away-from-reactor ISFSI would be SMALL to MODERATE. MODERATE 

3 impacts, if they occur, would be due to fugitive dust emissions in the areas immediately adjacent 

4 to the rail-spur construction activities.

5 5.4.2 Long-Term Storage

6 Activities associated with aging management of spent nuclear fuel in dry casks (e.g., cask 

7 repair, bare fuel handling as part of repackaging operations, and replacement of the ISFSI and 

8 the DTS) are expected to be of relatively short duration and limited extent. These activities are 

9 likely to involve only a portion of the ISFSI and would likely involve, in any year, only a fraction 

10 of the air emissions that were associated with initial construction of the ISFSI. Maintenance of 

11 the rail spur would also occur during long-term storage. As a result, there may be temporary 

12 increases in levels of fugitive dust from construction and refurbishment activities. But the 

13 impacts on air quality would be less than those of initial construction because the work would be 

14 performed in stages over an extended period of time, as needed.

15 The NRC assumes that a DTS would have to be constructed during the long-term storage 

16 timeframe. However, as discussed in Section 5.1, the DTS is a relatively small facility and the 

17 air quality impacts associated with its construction would be a fraction of the impacts associated 

18 with the original construction of the ISFSI. In addition, exhaust from vehicles for commuting 

19 workers and material transportation would add to levels of hydrocarbons, carbon monoxide, and 

20 nitrogen oxides. However, these emissions would be less than those during the construction 

21 period and are not expected to noticeably affect air quality in the region. 

22 Overall, the NRC concludes that the impacts on air quality would be SMALL for all location 

23 classifications (i.e., attainment, nonattainment, and maintenance).

24 5.4.3 Indefinite Storage

25 This section evaluates the air quality impacts of away-from-reactor storage, assuming a 

26 repository does not become available. The same activities described in Section 5.4.2 would 

27 occur repeatedly because the spent fuel would remain at the facility indefinitely. Therefore, the 

28 NRC concludes that the impacts on air quality associated with continuing spent fuel storage for 

29 an indefinite period would be SMALL for all location classifications (i.e., attainment, 

30 nonattainment, and maintenance).
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-18 September 2013

1 5.5 Climate Change

2 In this section, the NRC evaluates the effect of continued storage at an away-from-reactor ISFSI 

3 on climate change. The NRC’s evaluation of the effects of climate change on the intensity and 

4 frequency of natural phenomena hazards that may cause spent fuel storage accidents is 

5 provided in Sections 4.18. 

6 5.5.1 Short-Term Storage

7 The issue of climate change was not specifically addressed in the PFSF EIS. Therefore, for the 

8 purposes of this draft GEIS, the NRC assumes that the greenhouse gas emission levels 

9 released from the construction and operation of a 1,000-MW(e) reference reactor would bound 

10 those associated with a 40,000-MTU ISFSI (NRC 2011e). Construction and operation of light 

11 water reactors involves, among other things, substantial earthwork and soil dewatering, 

12 concrete batch plant operations, making and emplacing many thousands of metric tons of 

13 concrete, ironworks, lifting and rigging construction materials and equipment, material 

14 transportation, equipment maintenance, demolition, and workforce transportation. Because 

15 these activities are of a far greater scale than that for an away-from-reactor ISFSI, the 

16 greenhouse gas emission levels from the construction and operation of a 1,000-MW(e) 

17 reference reactor bound the emissions from the construction and operation of an away-from18 reactor ISFSI.

19 In its Carbon Dioxide Footprint Estimates for new reactors (NRC 2011e), the NRC categorized 

20 emission levels by project phases. The NRC assumed a 7-year construction period, which 

21 would generate a total of 185,000 MT of carbon dioxide (CO2) or about 26,500 MT/yr. The 

22 analysis assumed an average workforce of 2,500 workers, or roughly 10 times the number of 

23 workers expected to build the ISFSI. Although the new reactor analysis did not include 

24 transport of supplies and waste materials, which would also generate greenhouse gases during 

25 construction, the number of vehicles transporting workers to a new reactor construction site 

26 vastly exceeds the number of vehicles transporting supplies and materials. Therefore, the 

27 10:1 ratio between workers at a new reactor construction site compared to an ISFSI 

28 construction site still provides a very conservative, bounding calculation of 26,500 MT/yr in 

29 greenhouse gas emissions, even including the emissions from the transport of supplies and 

30 waste materials for the ISFSI. For the PFSF, Phase 1 of the construction, which encompassed 

31 the bulk of construction, was scheduled for 18 months. Using a conservative estimate of 

32 2 years, construction of the ISFSI would lead to greenhouse gas emissions of about 53,000 MT.

33 For a reactor during the operations period, the NRC estimated a workforce of 400 and total 

34 CO2 emissions (including emissions from support equipment) of 320,000 MT over 40 years. 

35 This equates to 8,000 MT/yr (NRC 2011e). Similar to the construction estimate, the new reactor 

36 analysis did not include transport of supplies and waste materials that would also generate 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-19 Draft NUREG‒2157

1 greenhouse gases during operations. However, the workforce assumed for the reactor is about 

2 10 times the workforce that would be needed for the ISFSI and there is more support equipment 

3 (e.g., emergency diesel generators) at the reactor as well. Therefore, for the purposes of 

4 estimating the impacts for the ISFSI, the 8,000 MT/yr produced by an operating reference 

5 reactor is a conservatively high number.

6 Transportation of spent fuel from the reactor sites to the away-from-reactor ISFSI would also 

involve emissions of CO2.

5 7 A similar issue was considered in the U.S. Department of Energy

8 (DOE) EIS for Yucca Mountain (DOE 2002) and DOE’s 2008 Final Supplemental EIS for 

9 Yucca Mountain (DOE 2008a). These EISs considered the transportation of 70,000 MTU of 

10 spent fuel from reactor sites over a 50-year operational period, as opposed to the 40,000 MTU 

11 assumed by the NRC for the away-from-reactor ISFSI over a 20-year operational period. In its 

12 2008 Final Supplemental EIS, DOE determined that the movement of the fuel would add less 

13 than 0.0006 percent to overall national CO2 emissions in 2005. The NRC reviewed the analysis 

14 performed by DOE and determined that it was generally consistent with NRC and Council on 

15 Environmental Quality regulations and NRC guidance for completeness and adequacy 

16 (NRC 2008). Because the annual amount of spent fuel going to an away-from-reactor ISFSI 

17 (2,000 MTU/yr based on shipping 40,000 MTU in 20 years) is a factor of 1.4 greater than the 

18 annual amount considered in the Yucca Mountain EIS (1,400 MTU/yr based on shipping 

19 70,000 MTU in 50 years) and emissions are proportionate to the amount of fuel shipped, the 

20 emissions from the transportation of spent fuel from reactors to the away-from-reactor ISFSI 

21 would be less than double the low proportion (less than 0.0006 percent) of national 

22 CO2 emissions calculated in the Yucca Mountain Final Supplemental EIS. Because this 

23 transportation adds only slightly to existing traffic, and because emissions would be dispersed 

24 over a wide area between the reactor sites and the ISFSI, the NRC concludes that the 

25 greenhouse gas emissions impacts from the transportation of that spent fuel would be minor.

26 The total emissions associated with constructing (2 years at 26,500 MT/yr) and operating the 

27 facility over the short-term timeframe of 60 years (60 years at 8,000 MT/yr) would be 

28 533,000 MT; the average emissions rate would be about 8,600 MT/yr. The annual emission 

29 values for the various phases represent a small percentage of the 6,821,800,000 MT generated 

30 annually in the United States (EPA 2012). To put the annual emissions in context, 8,600 MT is 

31 equivalent to the annual emissions from 1,720 passenger vehicles (NRC 2011a, Table 7-2). 

32 During the construction period, when emissions are higher than the average, the 26,500 MT 

33 would be equivalent to the annual emissions from 5,300 passenger vehicles.

34 The NRC concludes that the relative contribution of an away-from-reactor ISFSI to greenhouse 

35 gas emission levels would be SMALL.

 

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

Draft NUREG‒2157 5-20 September 2013

1 5.5.2 Long-Term Storage

2 Activities associated with aging management of spent nuclear fuel in dry casks (e.g., cask 

3 repair, construction of the DTS, bare fuel handling as part of repackaging operations, and ISFSI 

4 and DTS replacement) are expected to be of relatively short duration and limited extent. These 

5 activities are likely to involve only a portion of the ISFSI, and would likely involve, in any year, 

6 only a fraction of the greenhouse gas emissions associated with initial construction of the 

7 storage facilities (see Sections 5.1.2 and 5.4.2). Therefore, the NRC concludes that the relative 

8 contribution of spent nuclear fuel transfer, handling, and aging management activities beyond 

9 the licensed life for operation of a reactor to greenhouse gas emission levels would be SMALL, 

10 for the same reasons stated in Section 5.5.1.

11 5.5.3 Indefinite Storage

12 This section describes the environmental impacts on climate change if spent fuel must be stored 

13 indefinitely. Ongoing transfer, handling, and aging management activities would continue 

14 indefinitely, the ISFSI and DTS would be replaced, and the spent fuel would be repackaged

15 every 100 years. The main difference when compared to the impacts described in 

16 Sections 5.5.1 and 5.5.2 is that without a repository these activities would occur on an ongoing 

17 basis over a longer period of time. However, the annual emission levels for the various phases 

18 would remain the same.

19 The NRC concludes that the relative contribution of an away-from-reactor ISFSI to annual 

20 greenhouse gas emission levels would be SMALL, the same as the emissions discussed in 

21 Section 5.5.2.

22 5.6 Geology and Soils

23 This section describes geology and soils impacts caused by the continued storage of spent fuel 

24 at an away-from-reactor ISFSI.

25 5.6.1 Short-Term Storage

26 Construction impacts associated with away-from-reactor storage include earth clearing and 

27 foundation laying for the ISFSI, both of which may contribute to soil erosion. As discussed in 

28 the introduction to this chapter, these activities would be similar to those described in the PFSF

29 EIS, regardless of the location of the ISFSI. As described in the PFSF EIS, the environmental 

30 impacts on soils would have included the loss of soils as a result of physical alterations to the

31 existing soil profile. These alterations would have led to a reduced availability to support plant 

32 and animal life and could have led to changes in erosion patterns and characteristics that affect 

33 how water infiltrates into the soil (NRC 2001). However, in the PFSF EIS, the NRC concluded 

34 that these losses are a small percentage of the similar available soils in the valley. The NRC 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-21 Draft NUREG‒2157

1 also noted that soils used in project construction are recoverable upon facility decommissioning, 

2 and that no excess soils would be generated that require shipment or disposal offsite. Similarly, 

3 economic geologic resources (such as minerals, oil, and gas, if any) that would be unavailable 

4 for exploitation during facility construction and operation are widely available elsewhere in the 

5 region.

6 As discussed in Section 5.1, the amount of land committed to the away-from-reactor ISFSI is 

7 relatively small compared, for example, to the land available in a typical county. The methods 

8 necessary to control soil erosion are well understood and local permits typically require the 

9 implementation of erosion controls. Because of the relatively small size of the facility,

10 restrictions on access to geologic resources under the ISFSI site would also be minimal. For 

11 these reasons, the NRC concludes that the impacts on soils and geologic resources from the 

12 building and short-term operation of an away-from-reactor ISFSI would be SMALL.

13 5.6.2 Long-Term Storage

14 The NRC expects that the construction of a DTS (see Chapter 2 for further details) will have 

15 minimal impacts on geology and soils due to the small size of the facility (about 0.7 ha [2 ac] for 

16 the DTS security zone). The types of impacts on soils would be similar to those anticipated for 

17 any power plant facility construction. Due to the relatively small size of the DTS, the impacts 

18 would be limited to the immediate area. Also, any laydown areas associated with construction 

19 would be reclaimed once the construction phase was complete.

20 It is assumed that ISFSI pads and supporting facilities (e.g., canister transfer building) would 

21 require replacement during the long-term storage timeframe and would occur on land 

22 immediately adjacent to existing facilities. It is not anticipated that the overall land disturbed 

23 would increase because the old facility location would be demolished and the land would likely 

24 be reclaimed. Even if the land is not reclaimed, it has no further impact on soils and geologic 

25 resources because all of the activities would occur inside the 40-ha (99-ac) restricted area. The 

26 operations phase of any ISFSI is not anticipated to have any additional impacts on soils above 

27 those associated with construction.

28 In general, while the geological characteristics of the site and vicinity are essential to the safe 

29 design and operation of the ISFSI, continued storage of spent fuel does not have a significant 

30 environmental impact on geological resources (such as, damage to unstable slopes, adjacent 

31 utilities, or nearby structures).

32 The construction, operation, and replacement of a DTS would have minimal impacts on soils on 

33 the small fraction of the land committed for the facility. There are no anticipated impacts on the 

34 geology of an area as the result of either the construction or operation of a DTS. Therefore, the 

35 NRC concludes that the environmental impact on geology and soils due to transfer, handling, 

36 and aging management of fuel during the long-term storage timeframe would be SMALL.
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-22 September 2013

1 5.6.3 Indefinite Storage

2 In this section, the impacts on geology and soils are evaluated for away-from-reactor storage 

3 assuming a repository does not become available. The same operations and maintenance 

4 activities described in Section 5.6.2 would occur repeatedly because the spent fuel would 

5 remain at the facility indefinitely.

6 An away-from-reactor storage facility would have no additional impact if a repository is not 

7 available; therefore, the NRC concludes that the impacts on geology and soils from indefinite 

8 storage would be SMALL. 

9 5.7 Surface-Water Quality and Use

10 This section describes surface-water quality and use impacts caused by the continued storage 

11 of spent fuel at an away-from-reactor ISFSI.

12 5.7.1 Short-Term Storage

13 Construction of an away-from-reactor ISFSI would require modification of the surface drainage 

14 to accommodate increased locally generated stormwater resulting from land cleared of 

15 vegetation and the increased area of impervious cover resulting from paved roads, buildings, 

16 and thick concrete pads on which spent fuel casks would be placed (NRC 2001). The types of 

17 activities carried out at the ISFSI that could affect surface water would be similar to those 

18 activities described for the PFSF based on the assumptions presented in the introduction to this 

19 chapter.

20 For the PFSF site, the NRC noted that BMPs would have been used to address stormwater

21 flows, soil erosion, and siltation throughout the construction period. The NRC determined that, 

22 during construction, implementation of BMPs would have resulted in impacts on surface-water

23 quality that would have been SMALL. The NRC also determined that, in the unlikely event that 

24 severe flooding occurred during the construction period (when the ground-disturbing activities 

25 would have made the soil more mobile), impacts on the surface-water hydrological system

26 would have been SMALL to MODERATE.

27 The methods necessary to control impacts on surface-water quality during the construction of 

28 the ISFSI are well understood and local permits typically require the implementation of these 

29 controls. Stormwater control measures, which would be required to comply with National 

30 Pollutant Discharge Elimination System (NPDES) permitting, would minimize the flow of 

31 disturbed soils or other contaminants into surface waterbodies. The licensee could also 

32 implement BMPs to minimize erosion and sedimentation. The NRC concludes that under 

33 normal circumstances, the impacts on surface-water quality would be minor. Depending on the 

34 characteristics of the specific location, unforeseen storm events could cause periods during 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-23 Draft NUREG‒2157

1 which surface water could be noticeably affected by runoff, erosion, and sediment loads. 

2 However, these events would be of short duration, after which water quality would return to 

3 normal.

During construction, the PFSF would have used from about 102 m3 4 /d (19 gpm) to more than

520 m3 5 /d (96 gpm) of water (NRC 2001). The water requirements for an away-from-reactor 

6 ISFSI would be similar because of its similar size. These water requirements could be met by a 

7 combination of groundwater, surface water, or water delivered to the site (by truck or from a 

8 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 9 /d (10,000 gpm). 

10 During the operational period, the away-from-reactor ISFSI would be in a passive state and 

11 water use would be much lower than during the construction period. The PFSF would have 

used about 6.8 m3 12 /d during operations (1.3 gpm). Activities would be limited to cask 

13 emplacement and site maintenance with very little water use. Transportation of the spent fuel to 

14 the ISFSI would not have any impacts on surface-water use or quality. For these reasons, the 

15 potential impacts on the surface-water flow system, water availability, and water quality during 

16 ISFSI operation are generally expected to be minor. 

17 For construction and operation of the away-from-reactor ISFSI, the NRC concludes that the 

18 overall impacts on surface-water use and quality would be SMALL. Although there is a 

19 possibility of noticeable impacts during unusual storm events during construction, such impacts 

20 would be short-lived before the surface waterbody would return to normal conditions. 

21 Therefore, even taking into consideration the impact of such unusual storm events, the overall 

22 impact would be SMALL.

23 5.7.2 Long-Term Storage

24 The construction and operation of a DTS (see Chapter 2 for further details) is anticipated to 

25 have minimal impacts on surface-water resources due to the small size of the facility (about 

26 0.7 ha [2 ac] for the DTS security zone) compared to the ISFSI restricted area (40 ha [99 ac]).

27 The construction and operation of a DTS involves very little consumptive use of water, and this 

28 use would be intermittent. Given the relatively smaller size of the DTS compared to a 

29 40,000-MTU away-from-reactor ISFSI, much less water would be required to build the DTS than 

30 would be used to construct the ISFSI. Therefore, the consumptive water use for construction 

31 and operation of the DTS would be minor.

32 With regard to storage facility replacement activities, the consumptive water use would be no 

33 greater than that identified for initial construction of the facilities, which would have only a minor 

34 impact on water availability.
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-24 September 2013

1 The NRC assumes that ISFSI and DTS would require replacement during the long-term storage 

2 timeframe and that replacement structures would likely be constructed on land immediately 

3 adjacent to existing facilities. It is not anticipated that the overall land disturbed would increase 

4 because the old facility location would be demolished and the land would likely be reclaimed. 

5 This alternating location pattern minimizes the total land disturbed, which would limit the flow of 

6 disturbed soils or other contaminants into surface waterbodies. Based on the preceding 

7 analysis, expected impacts on surface-water resources would be similar to those in Section 

8 5.7.1, SMALL.

9 5.7.3 Indefinite Storage

10 If no repository becomes available, away-from-reactor dry cask storage of spent fuel would 

11 continue indefinitely. As a result, the potential impacts on surface-water resources would be 

12 similar to those described in Section 5.7.2 because the same operational activities would be 

13 happening at the storage site. Every 100 years, surface water would be needed for demolishing 

14 and replacing concrete pads and other possibly degraded facilities. This additional consumptive 

15 use would be temporary. Therefore, the NRC concludes that the potential impacts on surface16 water use and quality if a repository is not available would be SMALL.

17 5.8 Groundwater Quality and Use

18 This section describes groundwater-quality and -use impacts caused by the continued storage 

19 of spent fuel at an away-from-reactor ISFSI.

20 5.8.1 Short-Term Storage

21 Construction of an away-from-reactor ISFSI would require only shallow excavations for the 

22 concrete pad foundation and all structures for ISFSI facilities would be at or near the ground 

23 surface. 

24 The water-use requirements for the away-from-reactor ISFSI would be similar to those for the 

25 PFSF because of its similar size. This water could be obtained from groundwater sources. For 

26 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 m3 27 /d (96 gpm) (NRC 2001). For an away-from-reactor 

28 ISFSI, these water requirements could be met by a combination of groundwater, surface water, 

29 or water delivered to the site (by truck or from a local municipal water system). The amount of 

30 water required is relatively small. For example, a large power plant with cooling towers might 

consume approximately 54,500 m3 31 /d (10,000 gpm). In the PFSF EIS (NRC 2001), the NRC 

32 determined that environmental impacts from consumptive use of groundwater during 

33 construction of the proposed facility would have been SMALL. Because of the relatively small 

34
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-25 Draft NUREG‒2157

1 amount of consumptive water use and the ability to obtain water from multiple sources, the NRC 

2 concludes that the impacts of consumptive use of groundwater for an away-from-reactor ISFSI 

3 would be minor.

4 Potential impacts on groundwater quality would be expected to originate through seepage from 

5 ground-surface features, such as contaminants in runoff from the concrete pad surfaces and 

6 overlying surface waterbodies. The potential impacts on groundwater quality from an away7 from-reactor ISFSI would depend on local conditions. The methods to control impacts on 

8 groundwater quality are well understood and local permits typically require the implementation 

9 of these controls. Under these permits, licensees would be required to implement BMPs to 

10 mitigate any potential impacts on groundwater from fuels and other ground-surface 

11 contaminants. For this reason, the NRC concludes that the impacts on groundwater quality 

12 would be minor. By way of comparison, the impacts on groundwater quality from the PFSF

13 construction were determined by the NRC to be SMALL, given the depth to groundwater (about 

14 38 m [125 ft]) and mitigation afforded by the PFS BMP plan. Groundwater-quality impacts 

15 during PFSF operation were also deemed to be SMALL. This finding included consideration of 

16 operation of a surface-water detention basin, two planned septic systems with leach fields, and 

17 storage of onsite vehicle fuel.

18 Transportation of the spent fuel to the ISFSI would not have any impacts on groundwater use or 

19 quality.

20 Based on the considerations discussed above, the NRC concludes that the impacts on 

21 groundwater use and quality from construction and short-term operation of the away-from22 reactor ISFSI would be SMALL.

23 5.8.2 Long-Term Storage

24 To accomplish spent fuel repackaging into new canisters, the NRC assumes that a DTS would

25 be required, as described in Chapter 2. The environmental impacts on groundwater of 

26 constructing a DTS at an away-from-reactor facility would be smaller than those considered for 

27 construction of the away-from-reactor ISFSI (Section 5.8.1) because of the small area of land 

28 affected. Likewise, the impacts of replacing the ISFSI and the DTS over time would be no more 

29 than the impacts of the initial construction of the facility because they involve similar activities 

30 and would likely occur over a longer period of time. As a result, the NRC concludes that the

31 impacts on groundwater use and quality of long-term storage of spent fuel would be SMALL.

32 5.8.3 Indefinite Storage

33 If a repository does not become available, then activities described in Section 5.8.2 would 

34 continue indefinitely, including replacement of ISFSI and DTS every 100 years. The potential 

35 environmental impacts on groundwater would be similar to those discussed in Section 5.8.2. 
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-26 September 2013

1 Therefore, the NRC concludes that the potential environmental impacts on groundwater use and 

2 quality due to indefinite storage of spent fuel at an away-from-reactor ISFSI would be SMALL.

3 5.9 Terrestrial Resources

4 This section describes terrestrial resource impacts caused by the continued storage of spent 

5 fuel at an away-from-reactor ISFSI.

6 5.9.1 Short-Term Storage

7 Construction activities of an away-from-reactor dry cask storage facility that would affect

8 terrestrial ecology involve land clearing, grading, and building facilities, including access roads 

9 and a rail spur. During construction of an away-from-reactor dry cask storage facility, vegetation 

10 would be most affected by the direct removal of trees, plants, shrubs, and grasses and by 

11 replacing some of the cleared land with structures and ancillary facilities, including access 

12 roads. These removal activities could result, to varying degrees, in reduction of available 

13 wildlife habitat and food; modification of existing vegetative communities; and potential 

14 establishment or spread of invasive plant species. Parts of the disturbed areas would be 

15 replanted with some mixture of native and non-native plant species. Terrestrial wildlife would be 

16 most affected by habitat loss or alteration, displacement of wildlife, and incremental habitat 

17 fragmentation, all of which can lead to direct and indirect mortalities. However, in general, most 

18 wildlife would disperse from the project area when construction activities begin nearby, and may 

19 recolonize in adjacent, undisturbed areas. In addition, wildlife could be disturbed by noise from 

20 construction equipment and vehicle traffic. Collisions with vehicles could be responsible for 

21 direct mortality of both large and small animals.

22 The NRC evaluated site-specific construction impacts on terrestrial ecological resources from 

23 an away-from-reactor dry storage facility as part of the PFSF EIS (NRC 2001). Based on the 

24 assumptions presented in the introduction to this chapter, land-disturbing activities for an away25 from-reactor ISFSI would be of a similar magnitude. For the PFSF, the NRC evaluated the 

26 clearing of 94 ha (232 ac) for the main facility and access road, of which 37 ha (92 ac) were to 

27 be revegetated after construction and 57 ha (140 ac) were to remain cleared for the life of the 

28 project. The PFSF also required the addition of a 51-km (32-mi) rail line that involved the 

29 clearing of 314 ha (776 ac), of which 251 ha (621 ac) were to be revegetated after construction

30 and 63 ha (155 ac) were to remain cleared for the life of the project (NRC 2001). The proposed 

31 PFSF, located in an arid, shrub-saltbush vegetation community, was expected to store as many 

32 as 4,000 canisters in individual storage casks to store a maximum of 40,000 MTU of spent fuel. 

33 The PFSF had drainages in the area that were ephemeral. However, no wetlands were on or 

34 near the proposed PFSF, and there would have been no direct impacts on wetlands from 

35 construction (NRC 2001). It is likely that an away-from-reactor storage facility would also be 

36 located in an area away from sensitive perennial and wetland habitats to satisfy laws such as 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-27 Draft NUREG‒2157

1 the Endangered Species Act (ESA) and the Clean Water Act (for wetlands). However, in some 

2 locations sensitive terrestrial features may be unavoidably affected.

3 The NRC concluded that the direct impact on vegetation from clearing vegetation and disrupting 

4 the ground surface from the proposed PFSF would have been SMALL because no unique 

5 habitats occur in the proposed project area (NRC 2001). The NRC further concluded that 

6 vegetation removal impacts that reduce habitat, alter prey-predator relationships, and force 

7 animals to leave the area would have been SMALL. The NRC also concluded that indirect 

8 impacts from the proposed PFSF, including surface-water runoff from impermeable surfaces, 

9 restricting large animal movement, construction noise, introduction on non-native plant species, 

10 groundwater withdrawal effects on vegetation, and ground and vegetation disturbances from 

11 trucks and associated fugitive dust, would also have been SMALL (NRC 2001).

12 For an away-from-reactor ISFSI at a different location, the impacts on terrestrial resources could 

13 be different from those at the PFSF. However, certain factors tend to limit the impacts, including 

14 the following:

15 • The land area permanently disturbed is relatively small.

16 • Any impacts on wetlands must be addressed under the Clean Water Act and, if wetlands are 

17 present, the applicant must demonstrate that the proposed action is the least 

18 environmentally damaging practicable alternative. 

19 Even considering these factors, it is possible that the construction of the project could have 

20 some noticeable, but not destabilizing, impacts on terrestrial resources, depending on what 

21 resources are affected, as demonstrated by other environmental reviews the NRC has 

22 performed (e.g., reviews for new reactors). Given the passive nature of ISFSI operations, 

23 impacts on terrestrial resources from such operations (e.g., reduced available habitat, reduced 

24 mobility of terrestrial animals, and increased noise, light, and traffic) would be much less than 

25 the impacts of construction and would be minimal. Transportation of the spent fuel to the ISFSI 

26 would have little or no impacts on terrestrial resources. Therefore, the NRC concludes that, 

27 depending on the characteristics of the particular site, the impacts on terrestrial resources could 

28 range from SMALL to MODERATE, based primarily on the potential impacts of construction 

29 activities.

30 5.9.2 Long-Term Storage

31 As described previously in Section 5.1.2, the NRC assumes that a DTS would be constructed as 

32 part of an away-from-reactor ISFSI. This facility would be used to facilitate repackaging of spent 

33 fuel or replacement of damaged canisters or packages identified during visual inspections or 

34 aging management activities. Construction of a DTS is anticipated to last about 2 years (see

35 Section 5.1.2), and only a small portion of the land committed for an away-from-reactor ISFSI is

36 required to construct and operate a DTS.
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-28 September 2013

1 The NRC assumes that because only a small portion of the land committed for an away-from2 reactor ISFSI is required to construct and operate a DTS, the impacts from construction and 

3 operation of a DTS on terrestrial resources would be significantly less than those from 

4 construction and operation of an away-from-reactor ISFSI. The DTS could be sited on 

5 previously disturbed ground, probably away from sensitive terrestrial features, due to the 

6 relatively small land area affected for a DTS security zone (about 2 ac).

7 Operational impacts would include reduced available habitat and mobility of terrestrial animals 

8 and increased noise, light, and traffic. Maintenance activities would include inspections and

9 testing of the spent fuel and cask transfer and handling equipment and process and effluent

10 radiation monitoring, which do not increase erosion, fugitive dust, traffic, noise, light, or release 

11 of contaminants or require any change to land use. As the ISFSI and the DTS are replaced 

12 during the long-term storage timeframe, it is anticipated that there would be no new or additional 

13 activities from those described above. The potential impacts would be less than the impacts the 

14 NRC evaluated in Section 5.9.1 because replacement activities would occur within the plant’s 

15 operational area adjacent to existing facilities. For these reasons, the NRC concludes that the 

16 impact on terrestrial resources due to transfer, handling, and aging management of spent fuel at 

17 an away-from-reactor ISFSI during the long-term storage timeframe would be SMALL.

18 5.9.3 Indefinite Storage

19 Impacts on terrestrial resources from continued operation of an away-from-reactor ISFSI if a 

20 repository is not available would be similar to those described in Section 5.9.2. The same 

21 operations and maintenance activities described in Section 5.9.2 would occur repeatedly 

22 because the spent fuel would remain at the facility indefinitely.

23 Based on the NRC’s evaluation of the impacts from operations of an away-from-reactor ISFSI in 

24 Section 5.9.2, the NRC concludes that the environmental impacts on terrestrial resources from 

25 dry cask storage of spent fuel at an away-from-reactor ISFSI indefinitely would be SMALL.

26 5.10 Aquatic Ecology

27 This section describes aquatic ecology impacts caused by the continued storage of spent fuel at 

28 an away-from-reactor ISFSI.

29 5.10.1 Short-Term Storage

30 Construction and operation of an away-from-reactor ISFSI would require limited water supplies 

31 (see Sections 5.7 and 5.8). Liquid effluents, if any, would be limited to stormwater and treated 

32 wastewater. The dry cask storage facility could likely be sited away from sensitive aquatic 

33 features to comply with the ESA and other environmental laws. Ground-disturbing activities 

34 could increase runoff and surface erosion into aquatic habitats. In most cases, aquatic 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-29 Draft NUREG‒2157

1 disturbances would result in relatively short-term impacts and the aquatic environs would 

2 recover naturally. In addition, stormwater control measures, which would be required to comply 

3 with NPDES permitting, would minimize the flow of disturbed soils or other contaminates into 

4 aquatic features. The plant operator could also implement BMPs to minimize erosion and 

5 sedimentation.

6 For the PFSF, given the minimal impacts on aquatic biota and minimal aquatic features near the 

7 site, the NRC concluded that construction and operational activities at the PFSF would have 

8 had negligible direct and indirect impacts on aquatic biota (NRC 2001). This conclusion 

9 resulted from the facility’s limited water use and the passive nature of facility operations. For an 

10 away-from-reactor ISFSI at a different location, the impacts on aquatic resources could be 

11 different from those at the PFSF. However, certain factors would tend to limit the impacts, 

12 including the following:

13 • The land area permanently disturbed is relatively small.

14 • Water use for the construction and operation of the site is limited.

15 • Any impacts from discharges to waterbodies must be addressed under the Clean Water Act 

16 and an associated NPDES permit must be obtained for such discharges, including 

17 stormwater runoff.

18 Considering all of these factors, the NRC concludes that the impacts on aquatic resources 

19 would be SMALL.

20 5.10.2 Long-Term Storage

21 Building a DTS and activities related to the transfer and handling of spent fuel and aging 

22 management at away-from-reactor ISFSIs could result in ground-disturbing activities that would 

23 have similar impacts to those analyzed in Section 5.10.1. For example, ground-disturbing 

24 activities could increase runoff and surface erosion into aquatic habitats. The ISFSI and the 

25 DTS would be replaced during the long-term storage timeframe. The NRC anticipates that 

26 aquatic impacts from these activities would be within the bounds of those described in 

27 Section 5.10.1. The potential impacts may be less than the impacts the NRC evaluated in 

28 Section 5.10.1 because replacement activities would occur within the facility’s operational area 

29 adjacent to existing facilities over an extended period of time. In most cases, aquatic 

30 disturbances, if any, would result in relatively short-term impacts and the aquatic environs would 

31 recover naturally. Required mitigation related to NPDES or other permits would also reduce 

32 impacts. Therefore, the NRC concludes that impacts on aquatic resources from long-term 

33 storage at away-from-reactor ISFSIs would be SMALL. 
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-30 September 2013

1 5.10.3 Indefinite Storage

2 Impacts on aquatic resources from maintenance and operation of an away-from-reactor ISFSI if 

3 no repository becomes available would be similar to those described in Section 5.10.2. The 

4 same operations and maintenance activities described in Section 5.10.2 would occur repeatedly 

5 because the spent fuel would remain at the facility indefinitely. As described in Section 5.10.2,

6 these activities could result in minimal, short-term impacts on aquatic resources. Therefore, the 

7 NRC concludes that impacts on aquatic resources for indefinite storage of spent fuel at an 

8 away-from-reactor ISFSI would be SMALL. 

9 5.11 Special Status Species and Habitats

10 This section describes special status species and habitat impacts caused by the continued 

11 storage of spent fuel at an away-from-reactor ISFSI.

12 5.11.1 Short-Term Storage

13 Impacts from the construction and operation of dry cask storage facilities on special status 

14 species and habitats would be similar to those described above for terrestrial and aquatic 

15 resources, which would range from minimal to noticeable; any noticeable impacts would result 

16 from the construction of the ISFSI. The NRC assumes that the dry cask storage facility could be 

17 sited to avoid adversely affecting special status species and habitat because of the facility’s 

18 relatively small construction footprint and limited use of water. However, if an away-from19 reactor ISFSI was located in area that could affect Federally listed species or critical habitat, 

20 consultation under Section 7 of the ESA would ensure that any adverse impacts are mitigated or 

21 avoided.

22 Prior to initial licensing of the facility, the NRC would coordinate with the U.S. Fish and Wildlife 

23 Service (FWS), the National Marine Fisheries Service (NMFS), or both, to determine the 

24 presence of any Federally listed species or critical habitat at or near the site. If Federally listed 

25 species or critical habitat occur near the site and could be affected by the facility, the NRC 

26 would be required to initiate ESA Section 7 consultation. As part of the ESA Section 7 

27 consultation process, NRC would evaluate the potential impacts from construction and 

28 operation of the facility in a Biological Assessment. If necessary, the FWS, NMFS, or both 

29 would provide evaluations of the impacts in a Biological Opinion. The Biological Opinion could 

30 require monitoring programs or mitigation measures to minimize impacts on listed species and 

31 their habitats. If the evaluation indicates that facility activities would result in a “take,” or 

32 “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in 

33 any such conduct” of a listed species, the biological opinion could include an incidental take 

34 statement. The incidental take statement would specify the allowable number of “takes” that 

35 could occur during a specified period. If the number of takes exceeds the incidental take 

36 statement, the NRC would be required to reinitiate consultation with the FWS or NMFS.
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-31 Draft NUREG‒2157

1 Thus, the ESA consultation process would identify potential impacts on listed species and 

2 potentially require monitoring and mitigation to minimize impacts on listed species, thus 

3 ensuring that any takes during ISFSI operations do not exceed incidental take statement 

4 allowances. In addition, the official lists of special status species and habitats are regularly

5 updated by the FWS and NMFS. Species may be added to the list or delisted. If new species 

6 were listed under the ESA, the NRC would evaluate any potential impacts on those species at 

7 the away-from-reactor ISFSI at the time of listing. Therefore, if a new species were listed after 

8 the ISFSI receives its license, the NRC would initiate ESA Section 7 consultation with the FWS 

9 and NMFS if the newly listed species may be affected by the ISFSI. Additional details and 

10 guidance regarding the consultation process are provided at 50 CFR Part 402 and in the 

11 “Endangered Species Consultation Handbook” (FWS/NMFS 1998).

12 In addition, coordination with other Federal and State natural resource agencies would further 

13 ensure that licensees take appropriate steps to avoid or mitigate impacts on special status 

14 species, habitats of conservation concern, and other protected species and habitats, such as 

15 those protected under the Marine Mammal Protection Act, the Migratory Bird Treaty Act, and the 

16 Bald and Golden Eagle Protection Act. These consultations would likely result in avoidance or 

17 mitigation measures that would minimize impacts on protected species and habitats.

18 For construction of the ISFSI, the impacts on listed species would be determined as part of ESA 

19 Section 7 consultation. In complying with the ESA, the NRC would evaluate the impacts of

20 ISFSI construction, operations, and decommissioning in a site-specific review before the ISFSI

21 is initially constructed, if the operating parameters change, or if a “take” occurs for a species not 

22 included in an incidental take permit, as described above. The ESA provides four categories by 

23 which the NRC would characterize the effects of ISFSI construction: (1) no effect, (2) not likely 

24 to adversely affect, (3) likely to adversely affect, or (4) is likely to jeopardize the listed species or 

25 adversely modify the designated critical habitat of Federally listed species populations or their 

26 critical habitat. 

27 For operation of the ISFSI, given flexibility in site selection and the limited size of an ISFSI, the 

28 ISFSI can likely be sited to minimize adverse effects on special status species and habitats. 

29 Accordingly, the NRC concludes that operation of the ISFSI is not likely to adversely affect listed 

30 species, critical habitat, State-listed species, marine mammals, migratory birds, and bald and 

31 golden eagles, and would have no adverse impact on essential fish habitat (EFH). In the 

32 unlikely situation that the operation of an ISFSI could affect listed species, critical habitat, or 

33 EFH, the NRC would be required to initiate ESA Section 7 consultation with the NMFS or FWS

34 (for listed species or critical habitat) and initiate EFH consultation with NMFS (for EFH).

35 5.11.2 Long-Term Storage

36 As described above, the NRC would evaluate the impacts on listed species and critical habitat

37 from construction and operation of the ISFSI in a site-specific review as required under the ESA. 
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Draft NUREG‒2157 5-32 September 2013

1 This evaluation would include the potential impacts from transfer, handling, and aging 

2 management activities, including ISFSI and DTS replacement. If transferring, handling, or aging 

3 management resulted in a take of a species not included in a facility’s Incidental Take 

4 Statement, the NRC would be required to reinitiate ESA Section 7 consultation. During 

5 transferring, handling, and aging management activities, facilities with a Biological Opinion 

6 would either need to continue to abide by the conditions described in the Biological Opinion or 

7 reinitiate consultation if activities occurring at the facility are not covered by the Biological 

8 Opinion.

9 During long-term storage, the NRC assumes that the licensee would have to build a DTS. The 

10 NRC authorization to construct and operate a DTS would constitute a Federal action under 

11 NEPA and would be addressed pursuant to 10 CFR Part 51. Prior to authorization, the NRC 

12 would coordinate with FWS and NMFS, or both, to determine the presence of any Federally

13 listed species or critical habitat at or near the site. If Federally listed species or critical habitat 

14 occur near the site and could be affected by the facility, the NRC would be required to initiate 

15 ESA Section 7 consultation, as described in Section 5.11.1. Because the ISFSI and the DTS 

16 would be replaced during the long-term storage timeframe, the NRC anticipates that the impacts 

17 on special status species and habitats would be within the bounds of those described above. 

18 The potential impacts would most likely be less than the impacts the NRC evaluated in 

19 Section 5.11.1 because replacement activities would occur within the plant’s operational area 

20 adjacent to existing facilities over an extended period of time.

21 As described above, in complying with the ESA, the NRC would evaluate the impacts from an 

22 away-from-reactor ISFSI in a site-specific review before the facility is initially constructed and 

23 reinitiate consultation if necessary. The NRC would characterize the effects of construction and 

24 operations in terms of its ESA findings of (1) no effect, (2) not likely to adversely affect, (3) likely 

25 to adversely affect, or (4) is likely to jeopardize the listed species or adversely modify the 

26 designated critical habitat of Federally listed species populations or their critical habitat.

27 In addition, coordination with other Federal and State natural resource agencies would further 

28 ensure that ISFSI operators take appropriate steps to avoid or mitigate impacts on State-listed 

29 species, habitats of concern, and other protected species and habitats. The NRC assumes that 

30 these consultations would result in avoidance or mitigation measures that would minimize 

31 impacts on protected species and habitats, such as those protected under the Marine Mammal 

32 Protection Act, the Migratory Bird Treaty Act, and the Bald and Golden Eagle Protection Act. 

33 For example, the NRC would be required to consult with the NMFS if replacement activities for 

34 the ISFSI may affect EFH or marine mammals. However, impacts on EFH from long-term 

35 storage are not expected because away-from-reactor ISFSIs are built on land and ground36 disturbing impacts would have minimal impacts on aquatic habitats, as described in 

37 Section 5.10.2.
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September 2013 5-33 Draft NUREG‒2157

1 Given flexibility in site selection and the limited size of an ISFSI, the ISFSI can likely be sited to 

2 minimize adverse effects on special status species and habitats. Accordingly, the NRC 

3 concludes that operating and replacing components of the ISFSI are not likely to adversely 

4 affect listed species, critical habitat, State-listed species, marine mammals, migratory birds, and 

5 bald and golden eagles and would have no adverse impact on EFH. In the unlikely situation 

6 that operating and replacing components of an ISFSI could affect listed species, critical habitat, 

7 or EFH, the NRC would be required to initiate ESA Section 7 consultation with the NMFS or 

8 FWS (for listed species or critical habitat) and initiate EFH consultation with NMFS (for EFH).

9 5.11.3 Indefinite Storage

10 Impacts on special status species and habitats from continued operation of an away-from11 reactor ISFSIs if a repository never becomes available would be similar to those described in 

12 Section 5.11.2. The same operations and maintenance activities described in Section 5.11.2 

13 would occur repeatedly because the spent fuel would remain at the facility indefinitely.

14 As described above, in complying with the ESA, the NRC would evaluate the impacts from an 

15 away-from-reactor ISFSI in a site-specific review before the facility is initially constructed and 

16 reinitiate consultation if necessary. The NRC would report the effects of construction and 

17 operations in terms of its ESA findings of (1) no effect, (2) not likely to adversely affect, (3) likely 

18 to adversely affect, or (4) is likely to jeopardize the listed species or adversely modify the 

19 designated critical habitat of Federally listed species populations or their critical habitat.

20 Given flexibility in site selection and the limited size of an ISFSI, the ISFSI can likely be sited to 

21 minimize adverse effects on special status species and habitats. Accordingly, the NRC 

22 concludes that operating and replacing components of the ISFSI are not likely to adversely 

23 affect listed species, critical habitat, State-listed species, marine mammals, migratory birds, and 

24 bald and golden eagles and would have no adverse impact on EFH. In the unlikely situation 

25 that operating and replacing components of an ISFSI could affect listed species, critical habitat, 

26 or EFH, the NRC would be required to initiate ESA Section 7 consultation with the NMFS or 

27 FWS (for listed species or critical habitat) and initiate EFH consultation with NMFS (for EFH).

28 5.12 Historic and Cultural Resources

29 This section describes historic and cultural resource impacts caused by the continued storage of 

30 spent fuel at an away-from-reactor ISFSI.

31 The NRC is considering impacts on historic and cultural resources in this draft GEIS through 

32 implementation of its NEPA requirements in 10 CFR Part 51. This rulemaking is not a licensing 

33 action; it does not authorize the construction or operation of an away-from-reactor ISFSI, and it 

34 does not authorize storage of spent fuel. Because this draft GEIS does not identify specific 

35 sites for NRC licensing actions, a National Historic Preservation Act (NHPA) Section 106 review 
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-34 September 2013

1 has not been performed. However, the NRC complies with NHPA Section 106 and the 

2 implementing provisions in 36 CFR Part 800 in site-specific licensing actions. As discussed in 

3 Section 3.8, identification of historic properties, adverse effects, and potential resolution of 

4 adverse effects would be conducted through consultation and application of the National 

5 Register of Historic Places criteria in 36 CFR 60.4. This information would also be evaluated to 

6 determine the significance of potential impacts on historic and cultural resources in the NRC’s 

7 environmental review documents.

8 For site-specific licensing actions (new reactor licensing, reactor license renewal, and site9 specific at-reactor and away-from-reactor ISFSIs), the NRC complies with Section 106 

10 requirements to consider the effects of its undertaking on historic properties. If any historic 

11 properties are present, their significance would be determined through application of the 

12 National Register of Historic Places criteria. If adverse effects to historic properties are 

13 identified, appropriate mitigation can be developed through consultation with the State Historic 

14 Preservation Officer, tribal representatives, and other interested parties. Issuance of a site15 specific license could be granted at the conclusion of the NRC’s safety review and 

16 environmental review and compliance with NHPA Section 106 requirements. 

17 5.12.1 Short-Term Storage

18 NRC authorization to construct and operate an away-from-reactor ISFSI would constitute a 

19 Federal action under NEPA and would be an undertaking under the NHPA. In accordance with 

20 36 CFR Part 800, the NRC would conduct an NHPA Section 106 review to determine whether 

21 historic properties are present in the area of potential effect, and if so, whether construction and 

22 operation of the ISFSI would result in any adverse effects on such properties. Prior to 

23 submitting an application to construct and operate the ISFSI, the ISFSI applicant would conduct 

24 a survey of any areas of proposed development to identify and record historic and cultural 

25 resources. Impacts on historic and cultural resources would vary depending on the location of 

26 the ISFSI and what resources are present. Resolution of adverse effects, if any, should be 

27 concluded prior to the closure of the Section 106 process. After construction is completed, 

28 disturbed areas not occupied by ISFSI structures and supporting infrastructure (e.g., access 

29 roads, parking areas, and laydown areas) would be reclaimed and revegetated.

30 The environmental impacts on historic and cultural resources from the construction and 

31 operation of an away-from-reactor storage facility are informed by the evaluation as described in 

32 the PFSF EIS (NRC 2001). The proposed PFSF would have been located on the Reservation 

33 of the Skull Valley Band of Goshute Indians, which encompasses 7,200 ha (18,000 ac) in 

34 Tooele County, Utah. Storage pads for the canisters and some support facilities would have 

35 been located on a 99-ac (40-ha) restricted access area within the PFSF site (NRC 2001). 

36 Additional land would have been disturbed for the access road and the new rail line. The NRC 

37
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September 2013 5-35 Draft NUREG‒2157

1 assumes that the amount of land disturbance for an away-from-reactor ISFSI would be similar to 

2 the land disturbance for the PFSF, as discussed in the introduction to this chapter and 

3 Section 5.1.

4 Extensive work was performed at the PFSF to identify historic and cultural resources on or near 

5 the facilities and to evaluate the potential impacts of the project on those resources (NRC 2001). 

6 As a result, the NRC concluded that the construction of the rail line would have adversely 

7 affected portions of eight historic properties evaluated as eligible for inclusion in the National 

8 Register of Historic Places. The NRC included in the PFS license a condition that required the 

9 implementation of seven specific requirements for the treatment of historic properties. 

10 Operation of the proposed PFSF was not expected to adversely affect historic and cultural 

11 resources because no additional ground disturbance would occur.

12 For an away-from-reactor ISFSI, the impacts on historic and cultural resources would be 

13 different from those at the PFSF, given the difference in sites. However, several factors could 

14 avoid, minimize, or mitigate impacts. These include the following:

15 • Any impacts on historic and cultural resources must be addressed under the NHPA in 

16 consultation with any affected State or Tribal Historic Preservation Officers, and other 

17 interested parties.

18 • The land area disturbed is relatively small and any one of a number of alternative sites can 

19 be selected.

20 • Placement of facilities on the site can be readily adjusted to minimize impacts on any historic 

21 and cultural resources in the area, because the facility does not depend on a significant 

22 water supply and has limited electrical power needs.

23 • Potential adverse effects could also be minimized through development of agreements, 

24 license conditions, and implementation of the licensee’s historic and cultural resource

25 management plans and procedures to protect known historic and cultural resources and 

26 address inadvertent discoveries during construction.

27 However, it may not be possible to avoid adverse effects on historic properties or impacts on 

28 historic and cultural resources. The magnitude of adverse effects on historic properties and 

29 impacts on historic and cultural resources largely depends on what resources are present, the 

30 extent of proposed land disturbance, and if the licensee has management plans and procedures 

31 that are protective of historic and cultural resources. The NRC’s site-specific environmental 

32 review and compliance with the NHPA process could identify historic properties, adverse 

33 effects, and potentially resolve adverse effects on historic properties and impacts on other 

34 historic and cultural resources. Therefore, the NRC concludes that the potential impacts on

35 historic and cultural resources could range from SMALL, MODERATE, or LARGE, depending 

36 on site-specific factors.
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Draft NUREG‒2157 5-36 September 2013

1 5.12.2 Long-Term Storage

2 The NRC assumes that systems, structures, and components of an away-from-reactor ISFSI 

3 would be replaced during the long-term storage timeframe. In addition to routine maintenance, 

4 the NRC also assumes that a DTS is constructed, operated, and replaced as part of an away5 from-reactor ISFSI during the long-term storage timeframe. As discussed in Section 5.1.2 of 

6 this draft GEIS, a DTS would be used to transfer the spent fuel canister from its shipping cask 

7 into the storage cask, retrieve and repackage spent fuel for aging management activities, or to 

8 replace damaged canisters or packages identified during visual inspections. Construction and 

9 operation of a DTS at an away-from-reactor ISFSI is described in Section 2.1.4 of this draft 

10 GEIS. 

11 NRC authorization to construct and operate a DTS and replace the ISFSI and DTS would 

12 constitute Federal actions under NEPA and would be undertakings under the NHPA. In 

13 accordance with 36 CFR Part 800, a Section 106 review would be conducted for each 

14 undertaking to determine whether historic properties are present in the area of potential effect, 

15 and if so, whether these actions would result in any adverse effects upon these properties. 

16 Impacts on historic and cultural resources can vary greatly depending on the location of the 

17 original DTS and the replacement ISFSI and DTS and what resources are present. For site18 specific licensing actions (new reactor licensing, reactor license renewal, and site-specific 

19 at-reactor and away-from-reactor ISFSIs), applicants are required to provide historic and cultural 

20 resource information in their environmental reports. To prepare these assessments, applicants 

21 conduct cultural resource surveys. This information assists NRC in its review of the potential 

22 impacts on historic and cultural resources. Section 106 of the NHPA requires the NRC to 

23 conduct a site-specific assessment to determine whether historic properties are present in the 

24 area of potential effect, and if so, whether construction and operation of a DTS would result in 

25 any adverse effect upon these properties. Resolution of adverse effects, if any, should be 

26 concluded prior to the closure of the Section 106 process. 

27 Impacts from continued operations and routine maintenance during long-term storage would be 

28 similar to those described for the short-term storage timeframe. The impacts would be SMALL 

29 because there would be no ground-disturbing activities as a result of the continued operations 

30 and routine maintenance at the ISFSI. 

31 The replacement of the ISFSI and construction and replacement of the DTS would require a 

32 site-specific environmental review and compliance with NHPA requirements before making a 

33 decision on the licensing action. The NRC assumes that the replacement ISFSI and initial and 

34 replacement DTS will be constructed on land near the existing facilities. Ground-disturbing 

35 activities occurred during initial ISFSI construction, and much of the land within and immediately 

36 surrounding the replacement ISFSI would have already been disturbed. This activity would 

37 have eliminated any potential for historic and cultural resources to be present in these portions 

38 of the ISFSI site. However, less-developed or disturbed portions of the ISFSI site could contain 
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September 2013 5-37 Draft NUREG‒2157

1 historic and cultural resources. Given the large land area available around the ISFSI restricted 

2 area, the licensee should be able to locate the replacement facilities away from historic and 

3 cultural resources. Potential adverse effects on historic properties or impacts on historic and 

4 cultural resources could also be minimized through development of agreements, license 

5 conditions, and implementation of the licensee’s historic and cultural resource management 

6 plans and procedures to protect known historic and cultural resources and address inadvertent 

7 discoveries during construction of the replacement ISFSI and initial and replacement DTS.

8 However, it may not be possible to avoid adverse effects to historic properties or impacts on 

9 historic and cultural resources. The magnitude of an adverse effect on historic properties and 

10 an impact on historic and cultural resources largely depends on what resources are present, the 

11 extent of proposed land disturbance, and whether the licensee has management plans and 

12 procedures that are protective of historic and cultural resources. The site-specific 

13 environmental review and compliance with the NHPA process could identify historic properties, 

14 adverse effects, and potentially resolve adverse effects on historic properties and impacts on

15 other historic and cultural resources. Therefore, the potential impacts on historic and cultural 

16 resources could range from SMALL, MODERATE, or LARGE, depending on site-specific 

17 factors.

18 5.12.3 Indefinite Storage

19 The environmental impacts of indefinite spent fuel storage would be similar to those described 

20 in Section 5.12.2. The same operations and maintenance activities described in Section 5.12.2 

21 would occur repeatedly because the spent fuel would remain at the facility indefinitely. As 

22 discussed in Section 5.12.2, if replacement activities occur in previously disturbed areas (i.e., in 

23 areas that have previously experienced construction impacts), then impacts on historic and 

24 cultural resources would be SMALL. Therefore, historic properties would not be adversely 

25 affected. If construction activities occur in previously undisturbed areas or it is not possible to 

26 avoid affecting historic and cultural resources, then there could be adverse effects on historic 

27 properties, and impacts on historic and cultural resources could range from SMALL, 

28 MODERATE, or LARGE, depending on site-specific factors.

29 5.13 Noise

30 This section describes noise impacts caused by the continued storage of spent fuel at an away31 from-reactor ISFSI.

32 5.13.1 Short-Term Storage

33 The assessment of the environmental impacts of noise from the construction and operation of 

34 an away-from-reactor ISFSI is informed by those described in the PFSF EIS (NRC 2001). 

35 Background noise levels within the vicinity of the PFSF (Skull Valley) are low, as would be 
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-38 September 2013

1 expected for any remote location. The EPA (1974) has provided guideline sound levels below 

2 which the general public would be protected from activity interference and annoyance; 55 dBA 

3 applies to outdoor locations “in which quiet is a basis for use” and 45 dBA applies to indoor 

4 residential areas (NRC 2001).

5 Construction of the ISFSI facility occurs during a small portion of the short-term timeframe. The 

6 schedule for the proposed PFSF called for the first stage of construction, which included the 

7 major buildings and one-fourth of the total number of proposed storage pads, to last 18 months 

8 (NRC 2001). Noise impacts would result from construction equipment used to grade and level 

9 the site, excavate the facility foundation, handle building materials, build the ISFSI facilities 

10 (e.g., buildings, storage pads, access road, new rail siding, and new rail spur), and from 

11 additional construction traffic. Construction equipment associated with these activities can 

12 generate noise levels up to 95 dBA (NRC 2001). This noise level applies at a reference 

13 distance of 15 m (50 ft) from the source. Noise levels decrease by about 6 dBA for each 

14 doubling of distance from the source. At distances greater than about 1.9 km (1.2 mi), expected 

15 maximum noise levels would be less than the 55 dBA recommended by the EPA for protection 

16 against outdoor activity interference and annoyance (NRC 2001). For the PFSF, construction17 related noise levels were expected to be less than 48 dBA in the ambient air at the nearest 

18 residences (at a distance of roughly 3 km [2 mi]). Therefore, noise from construction activity 

19 was not expected to be annoying for residents located in the nearest houses (NRC 2001). 

20 However, for an away-from-reactor ISFSI at a different location, the nearest resident could be 

21 closer and noise levels during construction could exceed the EPA recommendation. Whether 

22 associated noise impacts could or would be mitigated could only be determined during a site23 specific review.

24 Construction would also result in increased vehicle traffic (e.g., commuting workforce, 

25 construction vehicles, and material transport) and an associated increase in noise. For the 

26 PFSF this would have increased noise levels by 5 dBA (NRC 2001). The impacts of the 

27 increase in noise around the ISFSI will depend considerably on the nature of the area through 

28 which the traffic is passing. Because the NRC expects that the ISFSI will be built in a remote 

29 location with little pre-existing traffic, the noise from the additional traffic is likely to be noticeable 

30 and could exceed the EPA recommendation. However, the duration of the most intense portion 

31 of the construction period would be limited (roughly 18 months for the PFSF).

32 Operation of the ISFSI would involve transporting, receiving, handling, and storing spent fuel, as 

33 well as routine maintenance and monitoring of the ISFSI. Cask transportation, receiving, and 

34 handling would be the primary noise sources during operations; the loudest onsite noise source 

35 would most likely be the onsite locomotive diesel switch engine. The train whistle from this 

36 locomotive could be audible at nearby residences. Momentary noise from routine operation 

37 could exceed 100 dBA. However, this locomotive would only operate a few hours per week 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-39 Draft NUREG‒2157

1 (NRC 2001). Because the locomotive would be expected to operate only a few hours per week, 

2 indoor and outdoor noise impacts are expected to be minimal. 

3 Noise impacts could also be associated with the transportation of spent fuel to the site. In the 

4 PFSF EIS (NRC 2001), the NRC estimated that an average of 150 loaded shipping casks would 

5 be received at the facility each year, carried by 1 or 2 trains per week, and a similar frequency is 

6 assumed for the ISFSI. While the train’s whistle would be loud, trains would be passing only 

7 infrequently. Therefore, the NRC concludes that the noise impacts resulting from transportation 

8 of spent fuel to the ISFSI would be minor.

9 In conclusion, the NRC determined that the construction and operation noise impacts for the 

10 away-from-reactor ISFSI could exceed the EPA-recommended levels during some portions of 

11 construction and occasionally during operations. However, because of the limited duration of 

12 the construction period and the intermittent nature of the noise, the NRC concludes that the 

13 overall impacts associated with noise for the construction and short-term operation of the away14 from-reactor ISFSI would be SMALL.

15 5.13.2 Long-Term Storage

16 The NRC assumes that a DTS is constructed as the duration and quantity of spent fuel in dry 

17 cask storage at an onsite storage facility increases. This facility would be used to retrieve and 

18 repackage spent fuel for aging management activities or to replace damaged canisters or 

19 packages identified during visual inspections. Section 2.1.4 provides a detailed description of 

20 the DTS.

21 Construction of a DTS would take approximately 1 to 2 years to complete. Noise levels 

22 generated during construction would be similar to those associated with initial construction of 

23 the ISFSI. Noise levels during construction could exceed the EPA recommendation at the 

24 nearest residence. Whether associated noise impacts could or would be mitigated could only 

25 be determined during a site-specific review. There would also be some additional traffic 

26 associated with the construction of the DTS but less than the traffic that would have occurred 

27 during initial construction.

28 Noise impacts generated during operation of the ISFSI (e.g., cask handling, movements to and 

29 from pads, and routine maintenance and monitoring of the ISFSI) would be the same as during 

30 operations for the short-term timeframe, which were minimal.

31 Aging management would require the replacement of the ISFSI (e.g., casks, storage pads, and 

32 canister transfer building) and the DTS during the long-term storage timeframe. Storage facility 

33 and DTS replacement uses construction equipment that can generate noise levels similar to the 

34 original construction of the ISFSI. These noise levels could exceed the EPA recommendation 
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-40 September 2013

1 during replacement activities. Whether associated noise impacts could or would be mitigated 

2 could only be determined during a site-specific review.

3 In conclusion, construction of the DTS, although temporary and representing a small portion of 

4 the overall timeframe for the spent fuel storage, does generate noise levels that could exceed 

5 EPA-recommended noise levels, as would activities to replace storage pads and other 

6 structures. However, these activities are temporary and noticeable noise levels would be limited 

7 to the nearest receptors. Generally for continued spent fuel storage, the operation noise levels, 

8 noise duration, and distance between the noise sources and receptors do not produce impacts 

9 noticeable to the surrounding community. Therefore, the NRC concludes that the overall noise 

10 impacts during the long-term storage timeframe at an away-from-reactor ISFSI would be 

11 SMALL.

12 5.13.3 Indefinite Storage

13 The environmental impacts of indefinite spent fuel storage would be similar to those described 

14 in Section 5.13.2. The same operations and maintenance activities described in Section 5.13.2 

15 would occur repeatedly because the spent fuel would remain at the facility indefinitely. Based 

16 on this information, the NRC concludes that the overall noise impacts during indefinite storage 

17 at an away-from-reactor ISFSI would be SMALL.

18 5.14 Aesthetics

19 This section describes aesthetic resource impacts caused by the continued storage of spent fuel 

20 at an away-from-reactor ISFSI.

21 5.14.1 Short-Term Storage

22 Development of an away-from-reactor ISFSI would use a larger land area than any at-reactor

23 ISFSI. The ISFSI would likely be sited and constructed in an area remote from population

24 centers and areas sensitive to aesthetic concerns. On the other hand, the ISFSI could be sited 

25 and constructed in an area with no existing industrial facilities or similar land disturbance. 

26 Therefore, a site-specific analysis of the aesthetic impacts will be required for the proposed 

27 facility. The ISFSI could affect local aesthetics to the extent its facility structures and operations 

28 (e.g., buildings, dry storage pads and canisters, the rail line, and trains) are visible across any 

29 scenic waterbodies or from higher topographic elevations. Lighting that illuminates the storage 

30 facilities may increase their visibility. If constructed in an area with no existing industrial 

31 development, the ISFSI would be expected to affect the local viewshed. Potential mitigation

32 measures include use of shielded lights to minimize light diffusion at night, planting native 

33 vegetation or constructing earthen berms to screen the facility, and using paint colors that blend 

34 facility structures with the surrounding landscape, as discussed in the PFSF EIS (NRC 2001).
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September 2013 5-41 Draft NUREG‒2157

1 Further, the NRC considered the aesthetic impacts of spent fuel storage at a consolidated site 

2 as part of the PFSF EIS. This evaluation represents the result for an ISFSI built in an area with 

3 no previous industrial development. For the PFSF, the NRC found that the visual character of 

4 the area surrounding the site would have been negatively affected by development and 

5 operation of an industrial facility in an otherwise largely undeveloped rural landscape. The NRC 

6 determined that the scenic appeal of the site would have been noticeably changed when viewed 

7 from various locations. Because of these anticipated changes to the affected viewshed, the 

8 NRC found the aesthetic impacts from the construction and operation of the PFSF to be SMALL 

9 to MODERATE (NRC 2001). 

10 For an away-from-reactor ISFSI at a different location, the impacts on aesthetic resources would 

11 be similar to those for the PFSF if it is built in a location with no previous industrial development. 

12 But the impacts could be SMALL if the ISFSI is built in a previously disturbed location (i.e., a 

13 brownfield site). Overall, the NRC concludes that the impacts on aesthetic resources would be 

14 SMALL to MODERATE.

15 5.14.2 Long-Term Storage

16 Aesthetic impacts from transferring and handling spent fuel and aging management activities at 

17 an away-from-reactor ISFSI are anticipated to be similar to the impacts described for the 

18 construction and short-term operation of the ISFSI described in Section 5.14.1. More 

19 specifically, periodic construction and demolition of facilities (including a DTS), although 

20 temporary, could cause an increase in aesthetic impacts compared to normal operation of the 

21 facility. However, because the replacement of the facilities would occur at an existing site and 

22 the activities and structures involved in the replacement are not expected to provide a significant 

23 change to what would exist prior to replacement, there would be no noticeable change to the 

24 impacts on aesthetic resources.

25 Because the periodic construction, demolition, and operation activities required for aging 

26 management would not significantly alter the pre-existing impacts of an away-from-reactor 

27 ISFSI, the NRC concludes that the environmental impacts on aesthetic resources due to long28 term storage would be SMALL to MODERATE. 

29 5.14.3 Indefinite Storage

30 If a repository is not available and away-from-reactor ISFSIs are developed, the activities that 

31 would be conducted at an away-from-reactor ISFSI would be the same as those described in 

32 Section 5.14.2. The same operations and maintenance activities described in Section 5.14.2 

33 would occur repeatedly because the spent fuel would remain at the facility indefinitely. Based 

34 on this information, the NRC concludes that the aesthetic impacts during long-term storage at 

35 an away-from-reactor ISFSI would be SMALL to MODERATE.
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Draft NUREG‒2157 5-42 September 2013

1 5.15 Waste Management

2 This section describes impacts from low-level radioactive waste (LLW), mixed waste, and 

3 nonradioactive waste management and disposal resulting from the continued storage of spent 

4 fuel at an away-from-reactor ISFSI. See Section 3.11 for a description of the different types of 

5 waste and typical disposal methods for the wastes. See Section 4.15 for a description of the 

6 types of waste generated from the operation, maintenance, and replacement of an at-reactor 

7 ISFSI; they are the same types of waste produced by the operation, maintenance, and 

8 replacement of an away-from-reactor ISFSI. However, the away-from-reactor ISFSI is a much 

9 larger facility than an at-reactor ISFSI and therefore would generate a higher volume of waste.

10 5.15.1 Short-Term Storage

11 Assessment of the environmental impacts from the handling and disposal of LLW, mixed waste, 

12 and nonradioactive waste from an away-from-reactor ISFSI is informed by those described in 

13 the PFSF EIS (NRC 2001). The PFSF was designed with a capacity of 40,000 MTU and the 

14 NRC has assumed a facility of similar size and characteristics for the away-from-reactor ISFSI. 

15 Because a similar facility is assumed, the quantities of the various wastes generated at the 

16 ISFSI would also be similar to those identified for the PFSF.

17 The construction of the PFSF would have included construction of major buildings (e.g., 

18 administration and laboratory) and 500 concrete storage pads. Construction activities would 

19 have generated excavation and construction debris, vegetation debris, and backfill (NRC 2001). 

20 For an away-from-reactor ISFSI, the construction debris would typically be disposed of at a local 

21 landfill. The excavation and backfill material could likely be reused for other purposes (e.g., 

22 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 23 ). All of this material was expected to 

24 remain onsite for other uses. This is consistent with NRC experience with other applications 

25 (e.g., new reactors), for which excavation materials are used or disposed of on the site.

26 Operation of an away-from-reactor ISFSI, like the PFSF, would involve limited waste-generating 

27 activities. The types of wastes generated would be similar to those for an onsite ISFSI, as 

28 described in Section 4.15.1, but on a larger scale. Small quantities of LLW would be generated 

29 during routine operation, including maintenance and environmental monitoring. This waste 

30 would be managed according to 10 CFR Part 20. Because (1) LLW would continue to be 

31 managed according to Federal regulations and (2) the disposal capacity for LLW is expected to 

32 be available when needed (see Section 1.8.3), the NRC determines the impacts from LLW 

33 management and disposal would be minor during short-term storage.

34 Operation and maintenance of the ISFSI would be expected to generate minimal to no mixed 

35 waste. Like other industrial facilities, small quantities of nonradioactive waste would be 
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September 2013 5-43 Draft NUREG‒2157

1 generated from routine operations and maintenance, including municipal waste and hazardous 

2 wastes, such as paint waste, pesticides, cleaning supplies (NRC 2001). Sanitary wastes would 

3 be handled in accordance with regulatory requirements and disposed of at an appropriately 

4 permitted disposal facility. The wastes would be managed and disposed of according to 

5 regulatory requirements.

6 The NRC considered the impacts of solid and sanitary wastes due to spent fuel storage at a 

7 consolidated site as part of the PFSF EIS. This evaluation found that impacts from managing 

8 solid and sanitary wastes during construction and operation of the PFSF would have been 

9 SMALL (NRC 2001). Because of the small quantities of waste involved, the NRC concludes 

10 that the impacts of managing and disposing of LLW, mixed waste, and nonradioactive waste

11 generated at an away-from-reactor ISFSI would be SMALL.

12 5.15.2 Long-Term Storage

13 Routine maintenance would continue to occur in the same manner as described in 

14 Section 5.15.1, generating minimal amounts of waste. Waste management and disposal

15 activities related to the construction and operation of a DTS, and the replacement of casks, 

16 pads, the canister transfer building, and DTS facilities at an away-from-reactor ISFSI, are 

17 discussed below. The repackaging of spent fuel, construction and operation of a DTS, and 

18 ISFSI and DTS replacement are not expected to generate mixed waste. However, if mixed 

19 waste is generated, it would be a small fraction of that generated by an operating nuclear power 

20 plant and it would be managed according to regulatory requirements.

21 As described in Section 4.15.2.1, the construction of a DTS would not be expected to generate 

22 LLW but would generate nonradioactive wastes similar to, but on a much smaller scale than, the 

23 original construction of the ISFSI. The NRC expects that the material that is excavated for the 

24 DTS would be disposed of onsite.

25 For this analysis, because the activities associated with the replacement of the casks and ISFSI

26 facilities are similar to decommissioning activities, the waste impacts from the replacement of 

27 casks and concrete pads are based on the decommissioning impacts considered in the PFSF

28 EIS. Replacing the ISFSI would entail removing about 500 concrete storage pads. Each 

29 storage pad has the dimensions of 20 m × 9 m × 0.9 m. In its license application, PFS assumed 

30 at least 10 percent of the total storage pad surface area would need to be decontaminated. The 

31 decontamination of the 500 concrete storage pads at the PFSF would have generated an 

additional 8.5 m3 (11 yd3 32 ) of LLW. If the storage pads are removed in their entirety, 

approximately 85,500 m3 (112,000 yd3 33 ) of material would need to be disposed of, either as LLW 

34 or nonradioactive waste (NRC 2001). These activities would occur over an extended period of 

35 time.
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-44 September 2013

1 The repackaging process consists of removal of the spent fuel assemblies from the old canister 

2 and placement into a new one. Once the canister has been removed from the cask, the cask is 

3 surveyed for residual radioactivity. If levels are below NRC limits, the casks can be disposed of 

4 as nonradioactive solid waste. If levels are above NRC limits, the cask material would be 

5 disposed of as LLW. The PFSF was expected to hold 4,000 storage casks that would need to 

6 be replaced approximately every 100 years. Donnell (1998) estimated that the 

decommissioning of one storage cask at the PFSF would generate 0.34 m3 (0.45 yd3 7 ) of 

8 compacted LLW. Using this volume, the dismantling of 4,000 storage casks as part of ISFSI 

replacement would generate 1,360 m3 (1,779 yd3 9 ) of compacted LLW over an extended period 

of time. In addition, replacement of the 4,000 casks would generate 162,000 m3 (212,000 yd3 10 ) 

11 of nonradioactive waste.

12 Although the exact amount of LLW and nonradioactive waste depends on the level of 

13 contamination, the quantity of waste generated from the replacement of the storage casks and 

14 concrete storage pads is still expected to be a fraction of the LLW generated during reactor 

15 decommissioning, which was previously determined to have a SMALL impact in the “Generic 

16 Environmental Impact Statement for License Renewal of Nuclear Plants” (NRC 2013a). 

17 Because (1) LLW would continue to be managed according to Federal regulations and (2) the 

18 disposal capacity for LLW is expected to be available when needed (see Section 1.8.3), the 

19 NRC determines the impacts from LLW management and disposal would be minor during long20 term storage. Therefore, the NRC determines that the potential environmental impacts from 

21 LLW, mixed waste, and nonradioactive waste for long-term storage at an away-from-reactor 

22 ISFSI would be SMALL for each waste stream.

23 5.15.3 Indefinite Storage

24 This section describes the potential environmental impacts from the management and disposal

25 of LLW, mixed waste, and nonradioactive waste if a repository is not available to accept spent 

26 fuel. For this analysis, the NRC assumes that spent fuel would continue to be stored at an 

27 away-from-reactor ISFSI indefinitely. The waste-generating activities during this timeframe 

28 include the same activities discussed in Section 5.15.2 but with the activities occurring 

29 repeatedly. Those impacts were determined to be SMALL based on previous analyses that 

30 assumed a repository would be available.

31 The activities associated with the management and disposal of LLW from indefinite away-from32 reactor storage of spent fuel would be similar to those described for long-term storage. As 

33 stated in Section 1.8.3, it is expected that sufficient LLW disposal capacity will be made 

34 available when needed. Similar to long-term storage, the NRC concludes the management and 

35 disposal of LLW could result in SMALL environmental impacts during indefinite storage of spent 

36 fuel. However, in this timeframe, because nonradioactive waste would continue to be generated 

37 indefinitely, even with continued implementation of and adherence to regulatory requirements, 

38 there could be noticeable impacts on the local and regional landfill capacity. Therefore, the 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-45 Draft NUREG‒2157

1 NRC determines that the environmental impacts from the indefinite management and disposal 

2 of nonradioactive waste would be SMALL to MODERATE.

3 5.16 Transportation 

4 This section describes transportation impacts caused by the continued storage of spent fuel at 

5 an away-from-reactor ISFSI. Noise impacts from transportation activities are evaluated in 

6 Section 5.13 and air emissions are evaluated in Section 5.4. The transportation activities to 

7 move spent fuel to an away-from-reactor ISFSI are included in this section. In considering 

8 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 9 (10 CFR 51.52) and the analysis of spent 

10 fuel transportation provided in the PFSF EIS (NRC 2001). Activities and impacts associated 

11 with moving spent fuel from the away-from-reactor ISFSI to a repository are addressed as 

12 cumulative impacts in Chapter 6.

13 5.16.1 Short-Term Storage

14 This analysis considers the impacts of transportation activities associated with construction and 

15 short-term operation of an away-from-reactor ISFSI on the affected environment beyond the site 

16 boundary. The environmental impacts evaluated include impacts on regional traffic from worker 

17 commuting, supply shipments, shipment of spent fuel to the ISFSI, and nonradiological and 

18 radiological waste shipments. Impacts on traffic from workers commuting to and from the away19 from-reactor storage site depend on the size of the workforce, the capacity of the local road 

20 network, traffic patterns, and the availability of alternate commuting routes to and from the 

21 facility.

22 Construction transportation activities involve workers commuting to and from the site and 

23 shipping construction equipment, supplies, and waste materials. In the prior analysis of impacts 

24 from constructing the PFSF, the NRC concluded the initial construction phase (e.g., major 

25 buildings, approximately 25 percent of the proposed storage pads, the access road, a new rail 

26 siding, and new rail line) would have the largest transportation impacts during construction 

27 based on a total workforce of 255, split almost evenly between work on the site and work on the 

28 rail line (NRC 2001). The NRC considers the amount of transportation (additional number of 

29 vehicles on the road) from the PFSF EIS to be representative of the transportation for the away30 from-reactor ISFSI because the facilities are the same size. For the first phase of construction 

31 for the PFSF, lasting about 18 months, the NRC concluded that the impacts on local 

 

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

Draft NUREG‒2157 5-46 September 2013

1 transportation would have been SMALL to MODERATE. That analysis also found the 

2 transportation impacts of completing remaining facility construction would diminish along with a 

3 concurrent decline in the need for equipment, materials, and construction workers. The prior 

4 analysis concluded traffic impacts and increased wear and maintenance requirements would be 

5 highest (moderate impact) on local roads with low average daily traffic and less pronounced 

6 (small) for major transportation routes that have higher capacities. Specifically, peak 

7 construction traffic involving supply shipments and commuting workers was estimated at 

8 450 vehicle trips per day (NRC 2001). This traffic was being added to local roads with annual 

9 average daily traffic counts between 325 and 565 vehicles per day (an increase in traffic ranging 

10 from 79 to 130 percent). This change in local traffic previously evaluated for the PFSF changed 

11 the level of service resulting in a conclusion of moderate impacts on traffic. Transportation of 

12 cask materials to construct 200 casks per year (an additional 6 truck trips per day) was also 

13 previously evaluated for the PFSF as not significantly adding to the daily traffic or projected 

14 impacts.

15 The impacts on traffic from construction of an away-from-reactor ISFSI at a different location are 

16 likely to be similar. The amount of additional traffic is not very large but because the ISFSI will 

17 likely be built in a remote location with limited existing roads, the impacts on local traffic may still 

18 be noticeable but not destabilizing. If the location of the ISFSI has an extensive existing road 

19 network, then the impacts may not be noticeable.

20 Construction of a rail line and siding to the PFSF would have required the movement of large 

21 quantities of excavated soils, ballast, and sub-ballast as well as the transportation of workers to 

22 construction areas and the same would be true for the away-from-reactor ISFSI, for which a 

23 similar rail line is assumed. The previous NRC impact analysis indicated that most materials 

24 and workers would be expected to travel to the site of the proposed rail siding by the interstate

25 highways. Construction of the proposed rail line and siding would have required approximately

245,000 m3 (320,000 yd3 26 ) of ballast and sub-ballast (composed of crushed gravel or rock) 

27 obtained from existing commercial gravel pits in the area. Assuming a per-truck capacity of 

approximately 15.3 m3 (20 yd3 28 ) for movement of the ballast and sub-ballast, a total of 

29 approximately 32,000 two-way truck trips would have been required to transport the ballast and 

30 sub-ballast or 134 truck trips per day or approximately 13 vehicles per hour. The rail line 

31 construction workforce was estimated to be 125 workers contributing 250 vehicle trips per day 

32 for a total of 384 vehicle trips per day for rail line construction. This level of traffic was 

33 4.5 percent of the interstate traffic; therefore, the NRC concluded impacts on transportation by 

34 construction of the rail line would have been small although temporarily adverse to feeder road 

35 traffic (e.g., noticeable but not destabilizing). 

36 The impacts on traffic of building a rail line to an away-from-reactor ISFSI at a different location 

37 are likely to be similar. The amount of additional traffic is not very large, but because the ISFSI 

38 will likely be built in a remote location with limited existing roads, the impacts on local traffic may 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-47 Draft NUREG‒2157

1 still be noticeable but not destabilizing. If the location of the ISFSI has an extensive existing 

2 road network, then the impacts may not be noticeable.

3 Operation of an away-from-reactor ISFSI would result in small impacts on the local 

4 transportation system due to daily commuting of workers and shipment of fabricated steel liners 

5 for the storage casks and spent fuel shipping casks. The NRC previously estimated for the 

6 PFSF that an operations workforce of 43 workers would commute each day using individual 

7 private vehicles or light trucks. These workers would account for an increase of 86 vehicle trips 

8 per day on local roads during operations. The previous NRC analysis of impacts of the PFSF 

9 concluded this decrease in the volume of traffic generated by the storage facility relative to 

10 construction activities would not result in any degradation of the level of service on local roads 

11 (NRC 2001). Because of the small number of trips involved, the NRC concludes that the traffic 

12 impacts for an away-from-reactor ISFSI at a different location would also not be noticeable.

13 During the operation of the away-from-reactor ISFSI, spent fuel would be shipped from power 

14 plants to the facility. These shipments would be required to comply with applicable NRC and 

15 U.S. Department of Transportation (DOT) regulations for the transportation of radioactive 

16 materials in 10 CFR Part 71 and 49 CFR Parts 171−189. The radiological impacts on the public 

17 and workers of spent fuel shipments from a reactor have been previously evaluated by the NRC 

18 and found to be SMALL in several evaluations. A generic impact determination in 

19 10 CFR 51.52, Table S–4, and the supporting analysis (AEC 1972) concluded that the 

20 environmental impacts of transportation of fuel and waste to and from a light water reactor 

21 under normal operations of transport and accidents in transport would be small.

22 The results of subsequent analyses of transportation impacts in “Final Environmental Statement 

23 on Transportation of Radioactive Material by Air and Other Modes” (NRC 1977) and 

24 “Reexamination of Spent Fuel Shipment Risk Estimates” (Sprung et al. 2000) confirmed that 

25 spent fuel transportation impacts are small. Additional site-specific analyses of transportation 

26 impacts for power plants that did not meet the conditions of 10 CFR 51.52 also concluded that 

27 the transportation radiological impacts would be small (NRC 2006b, 2008b, 2011a−d, 2013b). 

28 The NRC recently calculated spent fuel transportation risks for individual shipments under 

29 incident-free and accident conditions in “Spent Fuel Transportation Risk Assessment Draft 

30 Report for Comment” (NRC 2012a) based on current models, data, and assumptions. The 

31 analysis modeled shipping cask response to accident conditions, such as impact force and fire, 

32 and calculated risks considering a range of truck and rail accidents of different severities, 

33 including those involving no release or loss of shielding, loss of shielding only, or loss of 

34 shielding and release. That analysis reconfirmed that the radiological impacts from spent fuel 

35 transportation conducted in compliance with NRC regulations are low. The NRC concluded that 

36 the regulations for transportation of radioactive material are adequate to protect the public 

37 against unreasonable risk of exposure to radiation from spent fuel casks in transport (NRC 

38 2012a).
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-48 September 2013

1 Considering that an away-from-reactor ISFSI would also receive shipments of spent fuel from 

2 more than one power plant, the radiological and nonradiological impacts from a comparable 

3 transportation scenario were previously evaluated for the PFSF (NRC 2001). That analysis 

4 calculated incident-free and accident risks from the shipment of 4,000 spent fuel casks,

5 transported over a representative route from Maine to Utah over a 20-year period, and 

6 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).7 7 

8 The maximally exposed individual is an individual that is assumed for the purpose of bounding 

9 to be exposed to the radiation from all shipments. By comparison, NRC regulations at 

10 10 CFR 20.1301 limit the annual radiation dose to any member of the public resulting from any 

11 licensed activity to 1 mSv (100 mrem). The PFSF incident-free and accident risk results were 

12 bounded by or comparable to results in 10 CFR 51.52, Table S–4, or the “Final Environmental 

13 Statement on Transportation of Radioactive Material by Air and Other Modes” (NRC 1977). 

14 Based on the PFSF analysis, the NRC concludes in the present analysis that the additional 

15 accumulated impacts from transportation of the entire inventory of spent fuel from multiple 

16 reactors to an away-from-reactor ISFSI would also be minor.

17 The operation of the away-from-reactor ISFSI would generate a small amount of LLW (e.g., 

18 used personal protection equipment) that would result in infrequent waste shipments to a 

19 licensed disposal facility. The small and infrequent number of shipments and compliance with 

20 NRC and the DOT packaging and transportation regulations would also limit potential worker 

21 and public radiological and nonradiological impacts from these waste shipments. Based on this 

22 analysis, the NRC concludes the impacts on traffic and to public and worker radiological and 

23 nonradiological safety from LLW shipments resulting from spent fuel storage activities beyond 

24 the licensed life of reactor operation would be small.

25 Based on the factors discussed above, the NRC concludes the impacts on traffic and public and 

26 worker radiological and nonradiological safety from construction and operation activities for an 

27 away-from-reactor ISFSI during short-term storage would be SMALL to MODERATE. The 

28 potential for a MODERATE impact is related to traffic and would depend on the characteristics 

29 at a particular site.

30 5.16.2 Long-Term Storage

31 During the long-term storage timeframe, the NRC assumes aging management activities would 

32 begin to identify stored spent fuel canisters requiring replacement. To evaluate the potential 

33 impacts, the NRC assumes a spent fuel DTS would be constructed to execute the replacement 

34 of canisters and casks. This facility would provide the capability to repackage spent fuel to 

35 replace damaged canisters or packages identified during regular inspections or aging 

 

7 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) (NRC 2011a).
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-49 Draft NUREG‒2157

1 management activities. The longer duration of storage is assumed to require eventual 

2 replacement of the away-from-reactor ISFSI and DTS facilities during the long-term storage 

3 timeframe. These replacement activities would generate additional waste material shipments.

4 The construction of a DTS would likely involve a smaller temporary workforce than the original 

5 construction workforce. A previously reviewed proposal to construct a spent fuel transfer facility 

6 at the Idaho National Engineering Laboratory (NRC 2004) estimated a construction workforce of 

7 250 workers that would be employed for 2 years. Because the proposed Idaho transfer facility 

8 was designed to transfer a larger variety wastes than would be handled at an away-from-reactor 

9 storage facility, the NRC assumes the Idaho facility bounds the impacts of constructing a DTS at 

10 an away-from-reactor ISFSI. The resulting daily two-way traffic trips from this workforce 

11 (500 trips) would be comparable to the construction workforce traffic evaluated in Section 5.16.1 

12 for initial storage facility construction and therefore traffic impacts would range from not 

13 noticeable to noticeable but not destabilizing. Operation of the dry spent fuel transfer facility 

14 would involve fewer workers than the construction workforce (60 workers were previously 

15 projected for operation of the Idaho transfer facility [NRC 2004]), and therefore the commuting 

16 traffic impacts during the operational period would be minor.

17 The operation of the DTS would involve shipment of materials including new canisters and 

18 would generate a small amount of LLW (e.g., used canisters and used personal protection 

19 equipment) that would result in infrequent waste shipments to a licensed disposal facility. The 

20 small and infrequent number of shipments and compliance with NRC and DOT packaging and 

21 transportation regulations would also limit potential worker and public radiological and 

22 nonradiological impacts from these waste shipments. Based on this analysis, the NRC 

23 concludes the impacts on traffic and to public and worker radiological and nonradiological safety

24 from LLW shipments resulting from spent fuel storage activities during the long-term storage 

25 timeframe would be minimal.

26 The replacement of the storage facility and increase in repackaging would generate additional 

27 nonradiological and LLW that would need to be shipped offsite for disposal. As described in 

28 Section 5.15.2, the estimated quantity of waste from the replacement of storage casks and 

storage pads would be about 249,000 m3 (326,000 yd3 29 ) of nonhazardous waste or LLW. 

Assuming this waste is shipped in roll-off containers with a capacity of 15 m3 (20 yd3 30 ), the total 

31 number of truck shipments estimated is 16,300. If replacement were phased over a 5-year 

32 period and shipping occurred 5 days per week, 12.5 shipments per day would be needed. The 

33 activities would not significantly increase the magnitude of traffic generated by storage 

34 operations occurring each year, and operational transportation impacts would continue to be 

35 minor.
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-50 September 2013

1 Based on the preceding analysis, the overall transportation impacts of continued operations of 

2 the away-from-reactor ISFSI during the long-term storage timeframe would be SMALL to 

3 MODERATE. The potential for a MODERATE impact is related to traffic and would depend on 

4 the characteristics at a particular site.

5 5.16.3 Indefinite Storage

6 Assuming no repository becomes available, spent fuel would be stored indefinitely in the away7 from-reactor ISFSI. Annual transportation activities and associated environmental impacts 

8 would be similar to that analyzed for storage facility operations and DTS construction and 

9 operations evaluated in Section 5.16.2. The same operations and maintenance activities 

10 described in Section 5.16.2 would occur repeatedly because the spent fuel would remain at the 

11 facility indefinitely. Based on this information, the NRC concludes that the transportation 

12 impacts during indefinite storage at an away-from-reactor ISFSI would be SMALL to 

13 MODERATE. The potential for a MODERATE impact is related to traffic and would depend 

14 on the characteristics at a particular site.

15 5.17 Public and Occupational Health

16 This section describes public and occupational health impacts caused by the continued storage 

17 of spent fuel at an away-from-reactor ISFSI. For the purposes of assessing radiological 

18 impacts, impacts are considered to be SMALL if releases and doses do not exceed dose limits 

19 prescribed by NRC regulations. This definition of SMALL applies to occupational doses as well 

20 as to doses to individual members of the public.

21 Transportation-related public and occupational health impacts are addressed in Section 5.16. 

22 5.17.1 Short-Term Storage

23 In the PFSF EIS (NRC 2001), the NRC examined human health impacts related to construction 

24 and operation of a consolidated dry cask storage facility. The analysis addressed in detail the 

25 human health impacts resulting from construction, operation, and potential accidents at the 

26 proposed PFSF site. This included nonradiological impacts from construction and operation of 

27 the proposed PFSF, as well as analysis of the radiological impacts from the spent nuclear fuel 

28 stored at the facility, including potential radiological accidents and their consequences. The 

29 type and frequency of nonradiological injuries and the types of pollutant emissions at an away30 from-reactor ISFSI would be similar to those for the PFSF because of the similarities between 

31 the facilities. The types of radiological releases from the two facilities would also be similar for 

32 the same reason.

33 The nonradiological health impacts from the construction of a facility of this size include the 

34 normal hazards associated with construction, such as pollutants (e.g., dust), and fatal and 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-51 Draft NUREG‒2157

1 nonfatal occupational injuries, such as falls or overexertion. The detailed analysis in the PFSF

2 EIS used extensive data from the Bureau of Labor Statistics and the Occupational Safety and 

3 Health Administration, as well as discussion of the requirements of the Occupational Safety and 

4 Health Administration’s General Industry Standards (29 CFR Part 1910) and Construction 

5 Industry Standards (29 CFR 1926) to conclude that the nonradiological health impacts would 

6 have been SMALL. The results were typical for an industrial facility of this size and would be 

7 just as applicable to a similarly sized away-from-reactor ISFSI at any location. Impacts of 

8 nonradiological accidents during operations would be even less because of the smaller 

9 workforce and because activities carried out during operations will generally be lower risk

10 activities (e.g., monitoring). Therefore, the NRC concludes that human health impacts from 

11 construction and operation of the ISFSI would be minor.

12 Radiological impacts at an away-from-reactor ISFSI would not occur until operation commenced 

13 and spent nuclear fuel storage casks were brought on site. The detailed analyses in the PFSF

14 EIS used the review and evaluation of the PFSF Safety Analysis Report to assess the 

15 radiological impacts on the general public (i.e., potential dose to a hypothetical maximally 

16 exposed individual located at the boundary of the proposed facility as well as known nearby 

17 residents) and estimated dose to occupational personnel.

18 The analyses presented in the PFSF EIS (NRC 2001) provide evidence that public and 

19 occupational doses would have been maintained significantly below the dose limits established 

20 by 10 CFR Part 72 and 10 CFR Part 20. The NRC assumes that an away-from-reactor ISFSI at 

21 any site has the same spent fuel capacity and a similar physical size; therefore, doses to 

22 workers and to the public would be similar to those calculated for the PFSF. The NRC 

23 concludes that public and occupational health impacts would be SMALL.

24 5.17.2 Long-Term Storage

25 As discussed in the previous section, in the PFSF EIS (NRC 2001) the NRC examined human 

26 health impacts related to construction and operation of a consolidated ISFSI. The analysis 

27 addressed in detail the public and occupational human health impacts resulting from 

28 construction, operation, and potential accidents at the proposed PFSF site. The occupational 

29 tasks were grouped into four categories consisting of (1) handling (i.e., receiving, transferring, 

30 and moving) of the spent fuel canisters and casks; (2) security, inspection, and maintenance 

31 activities; (3) administration and management; and (4) facility construction. The analyses for 

32 categories 1, 2, and 3 provide a similar analysis for the transferring, handling, and aging 

33 management activities that would be required for long-term storage of spent fuel being 

34 addressed by this draft GEIS. The analyses presented in the PFSF EIS (NRC 2001) provide 

35 evidence that public and occupational doses would be maintained significantly below the dose 

36 limits established by 10 CFR Part 72 and 10 CFR Part 20. In addition, these regulations would 

37 also require a licensed away-from-reactor ISFSI to maintain an ALARA (as low as reasonably 

38 achievable) program, which would likely reduce the doses described in the PFSF EIS (NRC 
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-52 September 2013

1 2001). The NRC assumes that an away-from-reactor ISFSI at any site has the same spent fuel 

2 capacity and a similar physical size; therefore, doses to workers and to the public would be 

3 similar to those calculated for the PFSF. The NRC concludes that public and occupational 

4 health impacts from operations during the long-term storage timeframe would be minor. 

5 During the long-term storage timeframe, the NRC expects that the licensee would have to build 

6 a DTS for repackaging of spent fuel canisters. The operation of the DTS would involve 

7 increased doses to workers and a very small increase in dose levels at the site boundary 

8 (estimated at roughly 0.8 km [0.5 mi] based on the size of the site). However, the licensee 

9 would still be required to comply with the dose limits established by 10 CFR Part 72 and 10 CFR 

10 Part 20. In addition, the NRC assumes that the casks, pads, canister transfer building, and DTS 

11 would require replacement during the long-term storage timeframe. The health impacts related 

12 to these activities would be similar to those for the original construction of the facility, although 

13 replacement activities would take place over a longer period of time.

14 Based on the information above, the NRC concludes that the public and occupational health 

15 impacts of ISFSI operations and construction and demolition activities during the long-term 

16 timeframe of storage would be SMALL.

17 5.17.3 Indefinite Storage

18 The public and occupational impacts of continuing to store spent fuel without a repository would 

19 be similar to those described in Section 5.17.2. The types of activities (operation, maintenance,

20 and replacement) and associated human health impacts would remain the same. The main 

21 difference is that these activities would be repeated over a longer period of time. Based on this 

22 information, the NRC concludes that the impacts on human health during long-term storage at 

23 an away-from-reactor ISFSI would be SMALL.

24 5.18 Environmental Impacts of Postulated Accidents

25 In this section, the NRC considers the environmental impacts of postulated accidents involving 

26 continued storage of spent fuel at an away-from-reactor ISFSI. The fuel will be stored in dry 

27 storage casks licensed by the NRC. As discussed in Chapter 1, the NRC assumes that a DTS 

28 would be constructed to facilitate canister and cask replacement for long-term and indefinite 

29 storage. The consequences of accidents for a dry cask storage facility are summarized in 

30 Sections 4.18.1.2 and 4.18.2.2. The types and consequences of accidents for the away-from31 reactor ISFSI are represented by the dry cask storage facility results because of the similarities 

32 between the at-reactor ISFSIs and any away-from-reactor ISFSI (i.e., because the types of 

33 casks used to store the fuel and the process for licensing those casks are the same).
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-53 Draft NUREG‒2157

1 This section of the draft GEIS follows a different format than the rest of the document. Because 

2 the impacts from accidents are substantially the same across the three timeframes – short-term, 

3 long-term, and indefinite – the draft GEIS presents the various accident types only once.

4 NRC regulations at 10 CFR Part 72, “Licensing Requirements for the Independent Storage of 

5 Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C 

6 Waste,” require that structures, systems, and components important to safety shall be designed 

7 to withstand the effects of natural phenomena (such as, earthquakes, tornadoes, hurricanes) 

8 and human-induced events without loss of capability to perform their safety functions. NRC 

9 siting regulations at 10 CFR Part 72, Subpart E, “Siting Evaluation Factors,” also require 

10 applicants to consider, among other things, physical characteristics of sites that are necessary 

11 for safety analysis or that may have an impact on plant design (e.g., the design earthquake). 

12 These characteristics are to be identified and characterized so that they may be taken into 

13 consideration when determining the acceptability of the site and design criteria of the facility.

14 In the PFSF EIS, the NRC examined environmental impacts from accidents at the proposed 

15 PFSF. This included two events (i.e., extreme winds and 100 percent air duct blockage) that 

16 could cause higher-than-normal radiation exposures to workers. In that analysis, the NRC 

17 postulated that the high-wind event resulted in wind-borne missiles that damaged the concrete 

18 overpack, which resulted in reduced shielding. The reduced shielding would cause slightly 

19 higher occupational doses and only negligible increases in radiation doses to a member of the 

20 public at the boundary of the owner-controlled area. The NRC considered the occupational 

21 doses that would be received upon transfer of the undamaged canister to a replacement cask. 

22 The NRC estimated that the dose from transfer operations would result in a collective 

23 occupational dose of 2.47 person-mSv (247 person-mrem). In the second event involving 

24 blocked vents, the NRC estimated that the dose to a worker that removes the blockage from the 

25 vents would be 0.586 mSv (58.6 mrem) to the hands and forearms, and 0.386 mSv (38.6 mrem) 

26 to the chest, which is below regulatory limits for workers (NRC 2001). Because of the 

27 similarities between the PFSF and any away-from-reactor ISFSI (i.e., because the types of 

28 casks used to store the fuel and the process for licensing those casks are the same), the results 

29 would be similar to those for the PFSF. Therefore, the impacts of these accidents would be 

30 minor.

31 In addition to the credible events described above, for the PFSF the NRC also considered an 

32 accident, not considered credible, in which a canister leaks. The NRC estimated that the 

33 resulting total effective dose equivalent resulting from a 30-day leak to an individual at the 

34 owner-controlled area boundary was 0.76 mSv (76 mrem). Radiation doses after the first 

35 30 days that result from radioactive material deposited on the ground were 0.027 mSv/yr 

36 (2.7 mrem/yr) (NRC 2001). These values are below dose limits in 10 CFR Part 20 and 

37 10 CFR 72.106. As a result, NRC determined that these impacts would have been SMALL 
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-54 September 2013

1 (NRC 2001). Because of the similarities between the facilities, the results would be similar for 

2 any away-from-reactor ISFSI and the impacts would be minor.

3 While the results described from the PFSF EIS are specific to that facility, the PFSF and away4 from-reactor ISFSI are similar and subject to the same regulations for casks and operations. 

5 The NRC therefore concludes that these results are representative of the impacts for an away6 from-reactor ISFSI at a different location. Therefore, the NRC concludes that the impacts of 

7 postulated accidents would be SMALL during the three storage timeframes. 

8 5.19 Potential Acts of Sabotage or Terrorism 

9 Section 4.19 provides background regarding the NRC approach to addressing acts of terrorism

10 in relation to dry cask storage. That information is also applicable to an away-from-reactor 

11 ISFSI. As with the accident impacts analysis in Section 5.18, the impacts from terrorist acts are 

12 substantially the same across the three timeframes – short-term, long-term, and indefinite – and 

13 are therefore discussed only once.

14 The same safeguards regulations (10 CFR Part 72, Subpart H) apply to both an at-reactor ISFSI 

15 under a site-specific license and an away-from-reactor ISFSI. Safeguard requirements at at16 reactor specifically licensed ISFSIs are described in Sections 4.19.3 and 4.19.4 of this draft 

17 GEIS. In those sections, the NRC concluded that both the probability and consequences of a 

18 successful attack on an at-reactor ISFSI are low and, therefore, the environmental risk is 

19 SMALL. Based on this, the NRC concludes that the results from Sections 4.19.3 and 4.19.4

20 would also be applicable to an away-from-reactor ISFSI, and the associated impacts would be 

21 SMALL during the three storage timeframes.

22 5.20 Summary 

23 The impact levels determined by the NRC in the previous sections for away-from-reactor dry 

24 cask storage of spent fuel are summarized in Table 5-1. For most impact areas, the impact 

25 levels are denoted as SMALL, MODERATE, and LARGE as a measure of their expected 

26 adverse environmental impacts. In other impact areas, the impact levels are denoted according 

27 to the types of findings required under applicable regulatory or statutory schemes (e.g., 

28 “disproportionately high and adverse” for environmental justice impacts).

29 For a number of the resource areas, the impact determinations for all three timeframes are 

30 SMALL. For air quality and terrestrial ecology, there is the potential for a MODERATE impact 

31 during the construction of the ISFSI. For environmental justice, special status species and 

32 habitats, and historic and cultural resources, the results are highly site-specific. While it is 

33 possible the ISFSI could be built and operated with no noticeable impacts on these resources, a 

34 definitive conclusion cannot be drawn in this draft GEIS. For socioeconomics (taxes), 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-55 Draft NUREG‒2157

1 aesthetics, and traffic, there are impacts that could be greater than SMALL that will continue 

2 throughout the existence of the ISFSI. The tax impacts are beneficial in nature. Finally, there is 

3 the potential for a MODERATE impact from the disposal of nonradioactive waste in the 

4 indefinite timeframe if that waste exceeds the capacity of nearby landfills.

5 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 No 

disproportionately 

high and adverse 

impacts

No 

disproportionately 

high and adverse 

impacts

No 

disproportionately 

high and adverse 

impacts

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 from the construction of the ISFSI would be determined 

as part of ESA Section 7 consultation. Assuming the ISFSI can 

be sited to avoid special status species and habitats, operation, 

and replacement of the ISFSI is not likely to adversely affect 

special status species and habitats. Impacts would be 

determined as part of ESA Section 7 consultation if continued 

storage would affect listed species or critical habitat.

Historic and Cultural 

Resources

SMALL, 

MODERATE, or 

LARGE

SMALL, 

MODERATE, or 

LARGE

SMALL, 

MODERATE, or 

LARGE

Noise SMALL SMALL SMALL

Aesthetics SMALL to 

MODERATE

SMALL to 

MODERATE

SMALL to 

MODERATE 6 
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-56 September 2013

Table 5-1. Summary of Environmental Impacts of Continued Away-from-Reactor Storage 

(cont’d)

Resource Area

Short-Term 

Storage

Long-Term 

Storage Indefinite Storage

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

1 5.21 References

2 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

3 Protection Against Radiation.” Washington, D.C.

4 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

5 Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

6 Washington, D.C.

7 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

8 Transportation of Radioactive Material.” Washington, D.C.

9 10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing 

10 Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

11 Waste, and Reactor-Related Greater Than Class C Waste.” Washington, D.C.

12 29 CFR Part 1910. Code of Federal Regulations, Title 29, Labor, Part 1910, “Occupational 

13 Safety and Health Standards.” Washington, D.C.

14 29 CFR Part 1926. Code of Federal Regulations, Title 29, Labor, Part 1926, “Safety and Health 

15 Regulations for Construction.” Washington, D.C.
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September 2013 5-57 Draft NUREG‒2157

1 36 CFR Part 60. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

2 Part 60, “National Register of Historic Places.” Washington, D.C.

3 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 

4 Part 800, “Protection of Historic Properties.” Washington, D.C. 

5 40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of the Environment, Part 51, 

6 “Requirements for Preparation, Adoptions, and Submittal of Implementation Plans.” 

7 Washington, D.C.

8 40 CFR Part 52. Code of Federal Regulations, Title 40, Protection of the Environment, Part 52, 

9 “Approval and Promulgation of Implementation Plans.” Washington, D.C.

10 40 CFR Part 93. Code of Federal Regulations, Title 40, Protection of the Environment, Part 93, 

11 “Determining Conformity of Federal Actions to State or Federal Implementation Plans.” 

12 Washington, D.C.

13 49 CFR Parts 171 - 189. Code of Federal Regulations, Title 49, Transportation, Parts 171−177, 

14 “Hazardous Materials Regulations,” Parts 178−180, “Pipeline and Hazardous Materials Safety

15 Administration Department of Transportation,” and Parts 181−189, “Reserved.” 

16 Washington, D.C.

17 50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries. “Interagency 

18 Cooperation—Endangered Species Act of 1973, as Amended.” Washington, D.C.

19 69 FR 52040. August 24, 2004. “Policy Statement on the Treatment of Environmental Justice

20 Matters in NRC Regulatory and Licensing Actions.” Federal Register, U.S. Nuclear Regulatory 

21 Commission, Washington, D.C.

22 AEC (U.S. Atomic Energy Commission). 1972. Environmental Survey of Transportation of 

23 Radioactive Materials to and From Nuclear Power Plants. WASH–1238, Washington, D.C. 

24 Available at http://www.osti.gov/energycitations/product.biblio.jsp?osti_id=4569134

25 Clean Air Act. 42 USC 7401 et seq.

26 Clean Water Act. 33 USC 1251 et seq. (also referred to as the Federal Water Pollution Control 

27 Act [FWPCA]).

28 DOE (U.S. Department of Energy). 2002. Final Environmental Impact Statement for a Geologic 

29 Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca 

30 Mountain, Nye County, Nevada. DOE/EIS–0250, Washington, D.C. Package Accession 

31 No. ML032690321.
Environmental Impacts of Away-From-Reactor Storage

Draft NUREG‒2157 5-58 September 2013

1 DOE (U.S. Department of Energy). 2008. Final Supplemental Environmental Impact Statement 

2 for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive 

3 Waste at Yucca Mountain, Nye County, Nevada. DOE/EIS–0250F–S1, Washington, D.C. 

4 Package Accession No. ML081750191.

5 DOE (U.S. Department of Energy). 2013. Strategy for the Management and Disposal of Used 

6 Nuclear Fuel and High-Level Radioactive Waste. Washington, D.C. Accession 

7 No. ML13011A138.

8 Donnell, J. 1998. Response to RAI LA 1-6 Private Fuel Storage Facility Docket No. 72-22/TAC 

9 No. L22462 Private Fuel Storage LLC. Private Fuel Storage LLC, La Crosse, Wisconsin. 

10 Accession No. ML010260218. 

11 Endangered Species Act. 16 USC 1531 et seq. 

12 EPA (U.S. Environmental Protection Agency). 1974. Information on Levels of Environmental

13 Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety, 

14 EPA550/9–74–004, Research Triangle Park, North Carolina. Accession No. ML101790269.

15 EPA (U.S. Environmental Protection Agency). 2012. Inventory of U.S. Greenhouse Gas

16 Emissions and Sinks: 1990–2010. EPA 430–R–12–001, Washington, D.C. Accession 

17 No. ML12212A060.

18 FWS/NMFS (Fish and Wildlife Service/National Marine Fisheries Service). 1998. Endangered 

19 Species Act Consultation Handbook. Washington, D.C. Accession No. ML12325A215

20 LES (Louisiana Energy Services, LLC). 1998. Letter from Roland J. Jensen to Chairman 

21 Shirley Ann Jackson dated April 22, 1998, “In the Matter of Louisiana Energy Services, Docket 

22 No. 70–3070–ML.” ADAMS Legacy Library Accession No. 9804240190.

23 National Environmental Policy Act (NEPA) of 1969. USC 4321−4347.

24 National Historic Preservation Act (NHPA). 16 USC 470 et seq. 

25 NRC (U.S. Nuclear Regulatory Commission). 1977. Final Environmental Statement on 

26 Transportation of Radioactive Material by Air and Other Modes. NUREG–0170, Volumes 1

27 and 2, Washington, D.C. Package Accession No. ML022590355.

28 NRC (U.S. Nuclear Regulatory Commission). 1998. In the Matter of Louisiana Energy

29 Services, L.P. (Louisiana Energy Services Claiborne Enrichment Center). CLI–98–3, 47 NRC 

30 77, Washington, D.C. Available at http://www.nrc.gov/reading-rm/doc31 collections/nuregs/staff/sr0750/. 
Environmental Impacts of Away-From-Reactor Storage

September 2013 5-59 Draft NUREG‒2157

1 NRC (U.S. Nuclear Regulatory Commission). 2001. Final Environmental Impact Statement for 

2 the Construction and Operation of an Independent Spent Fuel Storage Installation on the 

3 Reservation of the Skull Valley Band of Goshute Indians and the Related Transportation Facility 

4 in Tooele County, Utah. NUREG–1714, Volume 1, Washington, D.C. Package Accession 

5 No. ML020150170.

6 NRC (U.S. Nuclear Regulatory Commission). 2004. Environmental Impact Statement for the 

7 Proposed Idaho Spent Fuel Facility at the Idaho National Engineering and Environmental 

8 Laboratory in Butte County, Idaho. NUREG–1773, Washington, D.C. Accession 

9 No. ML040490135.

10 NRC (U.S. Nuclear Regulatory Commission). 2006a. Letter from W.H. Ruland to J.D. Parkyn 

11 dated February 21, 2006, regarding “Issuance of Materials License No. SNM–2513 for the 

12 Private Fuel Storage Facility (TAC NO. L23821).” Washington, D.C. Accession 

13 No. ML060450412.

14 NRC (U.S. Nuclear Regulatory Commission). 2006b. Final Environmental Statement for an 

15 Early Site Permit (ESP) at the North Anna ESP Site. NUREG–1811, Volume 1, 

16 Washington, D.C. Accession No. ML063480261.

17 NRC (U.S. Nuclear Regulatory Commission). 2008a. U.S. Nuclear Regulatory Commission 

18 Staff’s Adoption Determination Report for the U.S. Department of Energy’s Environmental 

19 Impact Statements for the Proposed Geologic Repository at Yucca Mountain. Washington, D.C. 

20 Accession No. ML082420342. 

21 NRC (U.S. Nuclear Regulatory Commission). 2008b. Final Environmental Statement for an 

22 Early Site Permit (ESP) at the Vogtle Electric Generating Plant Site. NUREG–1872, Volume 1, 

23 Washington, D.C. Accession No. ML082240145.

24 NRC (U.S. Nuclear Regulatory Commission). 2011a. Final Environmental Impact Statement for 

25 the Combined License (COL) for Calvert Cliffs Nuclear Power Plant Unit 3. Final Report, 

26 NUREG–1936, Volume 1 and 2, Washington, D.C. Accession Nos. ML11129A167, 

27 ML11129A179.

28 NRC (U.S. Nuclear Regulatory Commission). 2011b. Final Environmental Statement for the 

29 Combined Licenses (COLs) for South Texas Project Electric Generating Station Units 3 and 4. 

30 NUREG–1937, Washington, D.C. Accession No. ML11049A000.

31 NRC (U.S. Nuclear Regulatory Commission). 2011c. Final Environmental Statement for the 

32 Combined Licenses (COLs) for Virgil C. Summer Nuclear Station, Units 2 and 3. 

33 NUREG–1939, Volumes 1 and 2, Washington, D.C. Accession Nos. ML11098A044, 

34 ML11098A057.
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Draft NUREG‒2157 5-60 September 2013

1 NRC (U.S. Nuclear Regulatory Commission). 2011d. Final Environmental Impact Statement for 

2 Combined Licenses (COLs) for Comanche Peak Nuclear Power Plant Units 3 and 4. 

3 NUREG–1943, Volumes 1 and 2, Washington, D.C. Accession Nos. ML11131A001, 

4 ML11131A002.

5 NRC (U.S. Nuclear Regulatory Commission). 2011e. Revision 1 – Addressing the Construction 

6 and Preconstruction Activities, Greenhouse Gas Issues, General Conformity Determinations, 

7 Environmental Justice, the Need for Power, Cumulative Impact Analysis and Cultural/Historical 

8 Resources Analysis Issues in Environmental Impact Statements. Washington, D.C. Accession 

9 No. ML110380369.

10 NRC (U.S. Nuclear Regulatory Commission). 2012a. Spent Fuel Transportation Risk

11 Assessment: Draft Report for Comment. NUREG–2125, Washington D.C. Accession 

12 No. ML12125A218.

13 NRC (U.S. Nuclear Regulatory Commission). 2012b. Final Environmental Impact Statement for 

14 Combined Licenses (COLs) for Levy Nuclear Plant Units 1 and 2. NUREG–1941, Voume 1, 

15 Washington, D.C. Accession No. ML12100A063.

16 NRC (U.S. Nuclear Regulatory Commission). 2013a. Generic Environmental Impact Statement 

17 for License Renewal of Nuclear Plants. NUREG–1437, Revision 1, Washington, D.C. 

18 Accession No. ML13107A023.

19 NRC (U.S. Nuclear Regulatory Commission). 2013b. Final Environmental Statement for the 

20 Combined License (COL) for Enrico Fermi Unit 3. NUREG–2105, Volume 1, Washington, D.C. 

21 Accession No. ML12307A172.

22 Private Fuel Storage, LLC. (PFS). 2001. Environmental Report, Private Fuel Storage Facility, 

23 Skull Valley Indian Reservation, Tooele County, Utah (Revision 14). La Crosse, Wisconsin. 

24 Private Fuel Storage, LLC. (PFS). 2012. Letter from R.M. Palmberg to NRC dated 

25 December 20, 2012, regarding “Termination of NRC License No. SNM–25 13 for Private Fuel 

26 Storage LLC.” La Crosse, Wisconsin. Accession No. ML12356A063.

27 Sprung, J.L., D.J. Ammerman, N.L. Breivik, R.J. Dukart, F.L. Kanipe, J.A. Koski, G.S. Mills, 

28 K.S. Neuhauser, H.D. Radloff, R.F. Weiner, and H.R. Yoshimura. 2000. Reexamination of 

29 Spent Fuel Shipment Risk Estimates. NUREG/CR–6672, Sandia National Laboratory, 

30 Albuquerque, New Mexico. Accession No. ML003698324.
September 2013 6-1 Draft NUREG‒2157

1 6.0 Cumulative Impacts

2 The Council on Environmental Quality’s (CEQ’s) regulations implementing the National 

3 Environmental Policy Act of 1969, as amended (NEPA), define a cumulative impact as “... the 

4 impact on the environment that results from the incremental impact of [an] action when added to 

5 other past, present, and reasonably foreseeable future actions, regardless of what agency 

6 (Federal or non-federal) or person undertakes such other actions” (Title 40 of the Code of 

7 Federal Regulations 1508.7 [10 CFR 1508.7]). Cumulative impacts can result from individually 

8 minor, but collectively significant, actions taking place over a period of time. It is possible that 

9 an impact that may be SMALL by itself could result in a MODERATE or LARGE cumulative 

10 impact when considered in combination with the impacts of other actions on the affected 

11 resource. For example, if a resource is regionally declining or imperiled, even a SMALL 

12 individual impact could be substantial if it contributes to or accelerates the overall resource 

13 decline.

14 6.1 Methodology for Assessing Cumulative Impacts

15 The cumulative impacts assessment in this draft “Waste Confidence Generic Environmental 

16 Impact Statement” (draft GEIS) examines the incremental impact of continued storage on each 

17 resource area in combination with other past, present, and reasonably foreseeable actions. The 

18 general approach for assessing cumulative impacts is based on principles and guidance 

19 described in the CEQ’s “Considering Cumulative Effects under the National Environmental 

20 Policy Act” (CEQ 1997). In addition, the U.S. Nuclear Regulatory Commission (NRC) reviewed 

21 the relevant portions of the U.S. Environmental Protection Agency’s (EPA’s) “Consideration of 

22 Cumulative Impacts in EPA Review of NEPA Documents” (EPA 1999) and “The NEPA Task 

23 Force Report to the Council on Environmental Quality on Modernizing NEPA Implementation”

24 (CEQ 2003). Based on the review of these documents, and NRC’s regulations implementing 

25 NEPA in 10 CFR Part 51, the NRC developed the following methodology for assessing 

26 cumulative impacts in this draft GEIS:

27 1. During the scoping and consultation phases of the environmental review, the NRC identified 

28 potential cumulative impact issues associated with the continued storage of spent nuclear 

29 fuel (spent fuel). The NRC included other actions and issues later as they were identified.

30 2. The individual resources, ecosystems, and human communities identified in the affected 

31 environment sections of Chapter 3 become the resource parameters analyzed in this 

32 analysis. Similarly, direct and indirect impacts identified in Chapters 4 and 5 form the basis 

33 for the analysis in this chapter.
Cumulative Impacts

Draft NUREG‒2157 6-2 September 2013

1 3. The spatial boundaries for this analysis are based on resource-specific criteria and defined 

2 within each resource-specific analysis in Section 6.4. Each spatial boundary encompasses 

3 the geographic area where the affected resources, ecosystems, and human communities 

4 and the distances at which impacts associated with other past, present, and reasonably 

5 foreseeable future actions may occur.

6 4. The temporal boundary (i.e., the timeframe) for this analysis is defined in Section 6.2. The 

7 timeframe of the cumulative impacts analysis extends from the past history of impacts on 

8 each resource through decommissioning of the spent fuel pool, at-reactor independent 

9 spent fuel storage installation (ISFSI), and away-from-reactor ISFSI (referred to as storage 

10 facilities). The temporal boundary is the same for all resource-specific analyses below 

11 (Section 6.4).

12 5. The NRC evaluated cumulative impacts by considering the incremental impacts from 

13 continued storage in combination with other past, present, and reasonably foreseeable 

14 future actions. The description of the affected environment in Chapter 3 for at-reactor 

15 storage facilities and Chapter 5 for away-from-reactor ISFSIs serves as the baseline for the 

16 cumulative impacts analysis, including the effects of past actions. The incremental impacts

17 related to continued storage are described and characterized in Chapter 4 for at-reactor 

18 storage facilities and Chapter 5 for away-from-reactor storage facilities. The NRC identified 

19 past, present, and reasonably foreseeable future actions. These actions include projects 

20 and activities that could impact resources, ecosystems, or human communities within the 

21 defined spatial and temporal bounds. Section 6.3.1 describes the general national, regional, 

22 and local trends and activities (general trends) that occur near at-reactor and away-from23 reactor storage facilities, such as urbanization or energy production. These general trends 

24 are the trends in general types of activities that occur near storage facilities and the likely 

25 future trends in these activities. Section 6.3.2 describes other NRC-regulated or spent fuel 

26 related activities that may occur during the period of continued storage, such as 

27 decommissioning of the nuclear power plant.

28 6. Cumulative impacts for each resource area are assessed in Section 6.4. Overlapping or 

29 cumulative impacts could occur if the action or general trend affects the same resource, 

30 ecosystem, or human community as those affected by the continued storage of spent fuel 

31 within the defined temporal and spatial bounds. Because of the various resource 

32 parameters (e.g., an ecosystem versus a human community) and the different spatial 

33 boundaries (e.g., a river versus a county) for each resource area, some activities or general 

34 trends affect a subset of the resource areas discussed below. The level of detail describing 

35 the various cumulative impacts is commensurate with the impact significance. 

36 7. Conclusions for resource and systems analyses in these sections use the same three-level 

37 classification scheme—SMALL, MODERATE, or LARGE—that was used for the at-reactor 

38 and away-from-reactor storage facility analyses, as defined in Chapter 1. For resource 

39 areas in which the cumulative impact could range based on the site-specific conditions, the 
Cumulative Impacts

September 2013 6-3 Draft NUREG‒2157

1 below analyses describes the general conditions for which a SMALL, MODERATE, or 

2 LARGE impact would occur. A conclusion is provided for at-reactor and away-from-reactor 

3 sites and for all three timeframes (short-term, long-term, and indefinite storage) discussed in 

4 Chapters 4 and 5.

5 8. The analysis in this chapter, as in the rest of this draft GEIS, provides a generic analysis that 

6 will ultimately be used to support NRC’s decision regarding a request to license or relicense 

7 a reactor or site-specific ISFSI. A site-specific review is required before the NRC provides a 

8 license for any reactor or ISFSI. Therefore, the analysis in this chapter would be considered 

9 along with the site-specific analysis for a specific license.

10 6.2 Spatial and Temporal Bounds of the Cumulative Impacts 

11 Assessment

12 The spatial boundaries for the cumulative impact assessment are resource-specific and 

13 identified within each resource-specific analysis below in Section 6.4. The NRC set the spatial 

14 boundaries to encompass the geographic area of the affected resources and the distances at 

15 which impacts associated with past, present, and reasonably foreseeable actions may occur.

16 In addition to impacts accumulating over a geographic area, impacts can also accumulate or 

17 develop over time. Therefore, the cumulative impacts assessment looks across a specific 

18 timeline that includes the past, present, and reasonably foreseeable future (CEQ 1997). The 

19 temporal boundary for this analysis includes activities that could occur through 

20 decommissioning of at-reactor or away-from-reactor storage facilities.

21 The spatial and temporal boundaries describes the maximum distance or time considered in the 

22 analysis. However, even if a project falls within these overall temporal and spatial bounds, the 

23 effects many not overlap in space and time with the effects of continued storage, especially for 

24 projects with short-term impacts. For example, constructing a small dock along a shoreline 

25 would have a temporary impacts on aquatic resources. Unless the dock was constructed during 

26 the period of continued storage, the impacts would not likely overlap with potential impacts from 

27 continued storage. On the other hand, construction and operation of a dam could have long28 term impacts that last several decades. Therefore, the impacts could be overlapping with 

29 continued storage, even if dam operations ceased several years before continued storage. 

30 Resource-specific analysis in Section 6.4 only describe activities that would overlap in both 

31 space and time with potential impacts from continued storage.

32 6.3 Past, Present, and Reasonably Foreseeable Actions

33 This section describes the NRC’s methodology for identifying past, present, and reasonably 

34 foreseeable actions. As described in CEQ guidance (CEQ 1997), identifying reasonably 
Cumulative Impacts

Draft NUREG‒2157 6-4 September 2013

1 foreseeable future actions is a critical component of a cumulative impacts analysis. However, 

2 the CEQ also recognizes that agencies should not engage in speculation in an effort to identify 

3 all actions that could contribute to overall potential cumulative effects. Given the national scope 

4 of the U.S. nuclear industry and the long timeframes that are under consideration in this draft 

5 GEIS as described in Chapter 1, it is not practical to consider all potential public and private 

6 projects. For this reason, reasonably foreseeable future actions that will be considered in the 

7 cumulative effects analysis include the following:

8 • general trends or activities that the NRC has previously determined to occur near at-reactor 

9 and away-from-reactor storage facilities

10 • programmatic actions for which Federal agencies have prepared and published NEPA

11 documents

12 • programs and policies enabled by legislation

13 • NRC activities or connected actions that could occur at or beyond the storage site during 

14 continued storage

15 The following sections summarize the past, present, and reasonably foreseeable actions 

16 considered in this cumulative analysis, including both general trends in Section 6.3.1 and other 

17 NRC-regulated or spent fuel-related activities in Section 6.3.2.

18 6.3.1 General Trends and Activities

19 Because of the uncertainty of specific activities that may occur over very long time periods in the 

20 future, the NRC considered the general types of activities that occur near at-reactor and away21 from-reactor storage facilities and the likely future trends of these activities. This approach 

22 follows CEQ (1997) guidance that recommends looking at the trends of various actions to 

23 analyze the potential activities that could occur through the reasonably foreseeable future, 

24 especially in situations with high uncertainty.

25 To determine typical activities that occur near at-reactor and away-from-reactor storage 

26 facilities, the NRC reviewed the cumulative impacts evaluations in NUREG−1437, “Generic 

27 Environmental Impact Statement for License Renewal of Nuclear Plants, Revision 1” (License 

28 Renewal GEIS) (NRC 2013a), site-specific EISs for new and operating reactors (e.g., NRC 

29 2011a–f, 2012a, 2013b), and site-specific at-reactor and away-from-reactor ISFSI 

30 environmental assessments (EAs) or environmental impact statements (EISs) (e.g., NRC 

31 2001a). The NRC also reviewed licensing documents for power reactors because at-reactor 

32 storage facilities are located at the reactor site, and therefore, at-reactor storage facilities are 

33 surrounded by the same activities as those identified in site-specific EISs for new reactors, 

34 supplemental EISs for license renewal of operating reactors, and in the License Renewal GEIS 

35 for operating reactors. Table 6-1 describes the types of activities that the NRC identified.
Cumulative Impacts

September 2013 6-5 Draft NUREG‒2157

1 The NRC also evaluated the reasonably foreseeable trend for each activity, primarily using 

2 projections prepared by Federal, State, and local agencies. In some cases, the NRC 

3 considered projections estimated by industry-based policy organizations, especially for activities 

4 with limited Federal, State, and local oversight. Trends in activities, facilities, or processes are 

5 based on projections as far into the future as reasonably foreseeable for the particular industry 

6 or activity. For many activities, the available projections cover shorter time periods, on the order 

7 of 25 to 40 years. The NRC qualitatively used these projections to estimate reasonable trends 

8 during continued storage. While the NRC considers this a reasonable assumption based on the 

9 best available data, the NRC also notes that applying the trends beyond the time period 

10 specified for each activity introduces additional uncertainty. In addition, the NRC assumed that 

11 local, State, and Federal authorities would continue to have oversight over the construction and 

12 operation of many of the activities described in Table 6-1. 

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

Activity or Stressor Reasonably Foreseeable Future Trend

Increased Energy Demand

Overall energy demand Total energy use will increase by 10% from 2011 to 2040 

(EIA 2012a). For at-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 

operator (NRC 2013a).

Overall electricity consumption Increased electricity consumption at an average annual rate 

of 0.9% (EIA 2012a).

New and continued construction 

and operation of gas-fired plants

About 0.8% annual increase from 2011 to 2040 (EIA 2012a). 

New and continued construction 

and operation of coal-fired plants

About 0.1% annual increase from 2011 to 2040 (EIA 2012a).

New and continued construction 

and operation of nuclear plants

About 0.5% annual increase from 2011 to 2040 (EIA 2012a).

Continued operation of oil-fired 

plants

About 0.9% annual increase from 2011 to 2040 (EIA 2012a).

New and continued construction 

and operation of wind farms

About 2.8% annual increase from 2010 to 2035 (EIA 2012b).

New and continued construction 

and operation of conventional 

hydropower plants

About 0.8% annual increase from 2010 to 2035 (EIA 2012b).

New and continued construction 

and operation of solar plants

About 5.1% to 16.4% annual increase from 2010 to 2035 (EIA 

2012b).

14
Cumulative Impacts

Draft NUREG‒2157 6-6 September 2013

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

(cont’d)

Activity or Stressor Reasonably Foreseeable Future Trend

Construction and operation of 

transmission lines

About 29,000 additional circuit miles of high-voltage 

transmission capacity from 2011 to 2017 (EIA 2011).

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 

2035 (INGAA 2011).

New and continued construction 

and operation of petroleum and 

liquefied natural gas facilities and 

terminals

Domestic production of liquefied natural gas is projected to 

increase from about 1.7% of the natural gas supply in 2010 to 

about 2.5% in 2035 (INGAA 2011; NPC 2011).

New and continued operation of oil 

refineries

Increase in oil refinery capacity from about 1.3 to 4.3 million 

barrels of oil per day from 2010 to 2030, depending on 

economic grown and price assumptions (EIA 2012c). 

Additional capacity will most likely be from expansions, 

updates, and modifications to existing refinery fleet, rather 

than construction of new facilities (NPC 2007).

New and continued oil and gas 

exploration and extraction activities

Domestic production of crude oil increases, mostly due to 

onshore production of shales and tight formations. Natural 

gas is expected to increase from 24% to 30% of electric 

power generation from 2011 to 2040 (EIA 2012a).

New and continued uranium ore 

exploration and extraction activities

New and continued uranium ore exploration and extraction 

activities expected based on the 0.5% annual increase from 

2011 to 2040 for nuclear power generation.

Continued Use of Radiological Materials

Construction and operation of new 

and existing at-reactor ISFSIs

Increase in total commercial spent fuel by about 2000 to 

2400 MT/yr (NRC 2013c). About 9,500 dry storage systems 

would be loaded by 2050, with an additional 1,000 systems 

(10,500 total) loaded by 2075 (Blue Ribbon Commission 

2012).

New and continued activities at 

hospitals and industrial facilities 

that produce and use radioactive 

materials, such as medical or 

industrial isotopes

Increase likely given the prevalence of nuclear medicine in 

current treatment technologies (112 million nuclear 

medicine/radiation therapy procedures annually [NRC 2000]), 

current demand (e.g., SHINE 2013), and increasing 

population and aging demographics. 

Continued operation of research 

and test reactors

As of August 2012, 31 NRC-licensed research reactors 

operate in the United States of which 17 have been granted a 

renewed license and 13 are currently under review for license 

renewal (NRC 2012b). Similar levels are expected in future. 

Continued operation of fuel 

fabrication facilities

Slight decrease based on an estimate of 15.4 million 

separative work units in 2015 to 14.2 million separative work 

units in 2025 (EIA 2012d). 
Cumulative Impacts

September 2013 6-7 Draft NUREG‒2157

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

(cont’d)

Activity or Stressor Reasonably Foreseeable Future Trend

Increased Water Demand

Continued transfer of water within 

and across water basins

Increase likely to establish reliable water supplies to support 

population growth (e.g., Texas Water Development Board 

2012). 

New and continued operation of 

drinking water-treatment plants 

and water-supply facilities

Total withdrawals of water for consumption to increase by 

about 50% from 2010 to 2040 (USACE 2006). 

Population Growth and Demographic Shifts

Overall Population Growth (in the 

U.S.)

Total U.S. population expected to increase from 321 million 

(2015) to 420 million (2060) (USCB 2012).

Increased Urbanization

River, shoreline, canal, or channel 

modifications including dredging 

and erosion-prevention programs

Activities expected to continue based on statutory authority 

for U.S. Army Corps of Engineers (USACE), population

growth, and urbanization.

Construction of housing units An increase in total housing units is expected from 

105.2 million units in 2010, to 143 to 153 million units in 2030, 

to 153 to 192 million units in 2050 (Pitkin and Myers 2008).

Construction of commercial 

buildings

Similar to housing construction, commercial construction 

would be expected to increase with population growth and 

continued urbanization. 

Waterfront development Coastal populations likely to increase, particularly in warmer 

coastal regions in the south based on population growth and 

housing trends.

Transportation

Construction of transportation 

infrastructure (e.g., roads, bridges, 

and rail)

Additional infrastructure likely based on population growth. In 

addition, increased reliance on mass transit would reduce the 

need for new long-distance highway infrastructure (National 

Research Council 2009). 

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 

national population (USDA 2012).

Continued industrial and 

manufacturing activities 

Industrial and manufacturing activities (e.g., mines, quarries, 

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 

increasing national population.
Cumulative Impacts

Draft NUREG‒2157 6-8 September 2013

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

(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 

accordance with their statutory authority. Legislation in 

Congress or in State legislatures may revise (either expand 

or reduce) agency authority (e.g., NPSCC 2009).

Continued operation and closure 

of various military facilities

Military facilities will continue to support combat readiness 

and national security, but projections indicate that future 

overall military budgets will be reduced, accompanied by a 

reduction in active-duty strength (76 FR 4134). 

Climate change Increased temperature, sea-level rise, decreased 

precipitation in the southern states and increased 

precipitation in northern tier states, and other changed in 

climate as described in the U.S. Global Climate Research 

Project (GCRP) (2009) and the Intergovernmental Panel on 

Climate Change (2007). Depending on the assumed 

scenario, global temperatures in 2100 are predicted to 

increase by 1°C (most aggressive carbon emissions control) 

to 6.5°C (least aggressive carbon emissions control). Sea 

level is predicted to increase from 0.5 to 1.2 m by 2100. 

Reduced snowpack in western mountains is predicted 

(USAC 2007).

1 6.3.2 Other NRC-Regulated or Spent Fuel-Related Activities during Continued 

2 Storage

3 In addition to the incremental impacts from continued storage described in Chapters 4 and 5, 

4 other NRC-regulated or spent fuel-related activities could affect the same resources as those 

5 affected by continued storage. These activities include other NRC-regulated actions that would 

6 occur at the storage site or connected actions that could occur at or beyond the storage site. A 

7 summary of these activities considered in this cumulative analysis is provided below. Note that 

8 some of the activities apply only to a subset of the timeframes described in Chapters 4 and 5. 

9 For example, dry transfer system (DTS) construction and decommissioning would occur only 

10 during long-term storage or indefinite storage, but would not occur during short-term storage.
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September 2013 6-9 Draft NUREG‒2157

1 6.3.2.1 Final Reactor Shutdown Activities Prior to Decommissioning

2 These activities could involve an initial increase in staff to execute shutdown, a decrease and 

3 ultimately; a cessation of reactor power output to grid; an increase in power demand to support 

4 onsite activities; a decrease in demand for power plant operational cooling; and the potential for 

5 removal of some structures and equipment.

6 Also see the description of shutdown activities in Section 2.2.

7 6.3.2.2 Decommissioning of the Reactor Power Block (including the spent fuel pool), 

8 DTS, and ISFSI

9 Decommissioning includes activities to remove radioactive materials from structures, systems, 

10 and components to demonstrate compliance with NRC release limits in 10 CFR Part 20, 

11 Subpart E. Reactor decommissioning of facilities not related to spent fuel storage could occur 

12 from the time that the licensee certifies that it has permanently ceased power operations until 

13 the license is terminated. To facilitate decommissioning at some sites, the operator may 

14 construct a new spent fuel pool cooling system to allow spent fuel pool to be isolated from other 

15 reactor plant systems.

16 Decommissioning of the spent fuel pool could begin after stored spent fuel has been transferred 

17 to dry storage. The NRC generically evaluated the environmental impacts from reactor 

18 decommissioning including the spent fuel pool (but not ISFSIs) in NUREG−0586, “Final Generic 

19 Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1”

20 (Decommissioning GEIS) (NRC 2002). The NRC previously evaluated the environmental 

21 impacts of decommissioning an away-from-reactor ISFSI in NUREG−1714, “Final 

22 Environmental Impact Statement for the Construction and Operation of an Independent Spent 

23 Fuel Storage Installation on the Reservation of the Skull Valley Band of Goshute Indians and 

24 the Related Transportation Facility in Tooele County, Utah” (PFSF EIS) (NRC 2001a) and in 

25 site-specific at-reactor ISFSIs in the Calvert Cliffs, Humboldt Bay, H.B. Robinson, Surry, 

26 Oconee, and Diablo Canyon EAs (NRC 2001a, 2003a, 2005a–c, 2009, 2012b). 

27 Decommissioning of the DTS is only applicable for long-term and indefinite storage. Also see 

28 the description of decommissioning activities in Section 2.2.

29 6.3.2.3 Activities to Prepare the Spent Fuel for Transportation to a Repository for Final 

30 Disposal

31 These activities would include transferring spent fuel that was stored in dual-purpose canisters 

32 from the storage casks to transportation casks and then loading the transportation casks on 

33 conveyances before transportation to a repository. Spent fuel stored in storage-only casks or 

34 that would otherwise require bare fuel handling (as described in Chapter 2) would be transferred 

35 to transportation-certified casks using the spent fuel pool for short-term storage and the DTS 
Cumulative Impacts

Draft NUREG‒2157 6-10 September 2013

1 long-term storage timeframe. These transportation-related activities could begin when a 

2 repository begins accepting shipments of spent fuel from power reactors. This activity would 

3 only occur for short-term and long-term storage, because indefinite storage assumes that a 

4 repository is never built.

5 6.3.2.4 Transportation of Spent Fuel from an At-Reactor or Away-From-Reactor 

6 Storage Facility to a Repository for Disposal

7 As described in Section 1.1, the Federal government has adopted deep geologic disposal as 

8 the national solution for spent fuel disposal (Nuclear Waste Policy Act of 1982) and the 

9 U.S. Department of Energy (DOE) has reaffirmed the Federal government’s commitment to the 

10 ultimate disposal of spent fuel (DOE 2013). When a repository is available to accept shipments 

11 of spent fuel, facility operators would ship spent fuel in NRC-approved transportation casks from 

12 facility locations across the United States to a repository site. Shipments would be required to 

13 comply with applicable NRC and U.S. Department of Transportation regulations for the 

14 transportation of radioactive materials in 10 CFR Part 71 and 49 CFR Parts 171 through 180. 

15 Transportation of spent fuel to a repository would only occur during short-term and long-term 

16 storage because indefinite storage assumes a repository is never built.

17 6.4 Resource-Specific Analyses

18 6.4.1 Land Use

19 This section evaluates the effects of continued storage on land use when added to the 

20 aggregate effects of other past, present, and reasonably foreseeable future actions. As 

21 described in Sections 4.1 and 5.1, the incremental impacts from continued storage on land use 

22 would be SMALL for all timeframes at both at-reactor and away-from-reactor storage facilities.

23 The geographic area considered in the cumulative land use analysis includes all affected land 

24 surrounding the at-reactor and away-from-reactor storage facilities. Residential, commercial, 

25 industrial, agricultural, forested, and recreational lands typically surround spent fuel storage 

26 facilities. Depending on the site, the land surrounding a spent fuel storage facility could include 

27 private and public lands in a range of political jurisdictions including towns, townships, service 

28 districts, counties, and parishes. In addition, State, Federal, and Native American lands are 

29 present within the area considered for this analysis.

30 6.4.1.1 Potential Cumulative Impacts from General Trends and Activities

31 Cumulative impacts on land use include (1) changing and disturbing existing land-use 

32 conditions, (2) restricting access or establishing right-of-way access, (3) restricting agricultural 

33 or recreational activities; and (4) altering ecological or historic and cultural resources (e.g., NRC 

34 2011a–f, 2012a, 2013a,b). Cumulative impacts could occur from the activities described in 
Cumulative Impacts

September 2013 6-11 Draft NUREG‒2157

1 Section 6.3.1, such as constructing and operating new and existing energy projects and 

2 infrastructure (e.g., replacement power), water development projects, and constructing housing 

3 units, commercial buildings, roads, bridges, and rail lines (e.g., NRC 2011a–f, 2012a, 2013a,b). 

4 In addition, climate change can impact agricultural and ranching land uses because of reduced 

5 crop yields and livestock productivity (GCRP 2009). Climate change can also lead to higher sea 

6 levels (GCRP 2009), thereby changing land use through inundation and loss of coastal wetlands

7 and other low-lying areas.

8 The magnitude of cumulative land-use impacts resulting from general trends taking place near a 

9 storage facility would depend on current land-use patterns and proposed land-use changes, the 

10 number (and density) of actions, and the extent to which these actions (facilities or projects) 

11 employ mitigation measures to reduce impacts. The cumulative impacts from general trends 

12 and activities would range from minimal (e.g., minor changes in land use from limited 

13 development in the area, see NRC 2011d) to noticeable (e.g., construction and operation of a 

14 new coal-fired power plant, new transmission lines, and climate change in the area, see NRC 

15 2011a). Growth control measures, such as zoning restrictions and implementation of local land 

16 use or master plans, are expected to limit development near a storage facility. Therefore, the 

17 cumulative impacts are not expected to be destabilizing (e.g., major changes in land use from 

18 uncontrolled development in the area).

19 6.4.1.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

20 Activities

21 Cumulative impacts on land-use conditions could result from other NRC-regulated or spent fuel22 related activities, such as decommissioning of the reactor power block (including the spent fuel 

23 pool), ISFSIs, and DTS. 

24 Activities associated with decommissioning of the reactor power block (including the spent fuel 

25 pool) that could impact land use include (1) addition and expansion of staging and laydown 

26 areas for equipment, (2) construction of temporary buildings and parking areas, (3) removal of 

27 large reactor components, (4) structure dismantlement, and (5) low-level waste (LLW) storage 

28 and packaging (NRC 2002). To facilitate decommissioning at some sites, the operator may 

29 construct a new spent fuel pool cooling system to allow the spent fuel pool to be isolated from 

30 other reactor plant systems in order. In the Decommissioning GEIS for power reactors, the 

31 NRC (2002) determined that changes to land use from these activities would be temporary and 

32 would not be detectable. Most reactor sites have sufficient area within the previously disturbed 

33 area (whether during construction or operation of the site); therefore, no additional land 

34 disturbance would be anticipated. The impacts from decommissioning spent fuel pools were 

35 considered in the Decommissioning GEIS. Given that the impacts from decommissioning 

36 reactors and spent fuel pools would be similar to that described in the Decommissioning GEIS 

37 for reactors, impacts on onsite land use during decommissioning are expected to be minimal.
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Draft NUREG‒2157 6-12 September 2013

1 Activities associated with decommissioning ISFSIs that could impact land use include 

2 (1) decontaminating the concrete storage casks; (2) dismantling and removing the concrete 

3 storage casks, concrete pads, and support facilities, including the DTS; and (3) removing any 

4 contaminated soil identified during the final radiological site survey. In most cases, land 

5 disturbance impacts associated with decommissioning ISFSIs would be similar to or less than 

6 land disturbance impacts associated with constructing ISFSIs (NRC 2003a, 2005a−c, 2009, 

7 2012b). After decommissioning activities are complete, the area previously occupied by the 

8 at-reactor or away-from-reactor ISFSI would typically be covered with topsoil, contoured, and 

9 replanted with native vegetation (NRC 2005c). The goal of decommissioning is to release the 

10 site for unrestricted use. Because the land disturbance impacts from decommissioning 

11 at-reactor and away-from-reactor ISFSIs would be similar to or less than those associated with 

12 constructing ISFSIs, impacts on land use during decommissioning are expected to be minimal.

13 6.4.1.3 Conclusion

14 Cumulative impacts on land use include the incremental effects from continued storage when 

15 added to the aggregate effects of other past, present, and reasonably foreseeable future 

16 actions. As described in Sections 4.1 and 5.1, the incremental impacts from continued storage 

17 on land use is SMALL for all timeframes at both at-reactor and away-from-reactor storage 

18 facilities. In addition, past, present, and reasonably foreseeable activities take place in the 

19 geographic area of interest that could contribute to cumulative effects to land use. The 

20 cumulative impacts on land use from continued storage when added to other past, present, and 

21 reasonably foreseeable Federal and non-federal activities are SMALL to MODERATE 

22 depending on land-use patterns and activities surrounding the site. A SMALL impact would 

23 occur if no other actions occur that have overlapping, noticeable effects on land use. A 

24 MODERATE impact would occur if NRC or other Federal or non-federal actions, such as 

25 construction and operation of other nearby nuclear, coal-fired, or gas-fired power plants or 

26 future urbanization, have overlapping impacts with the continued storage of waste that 

27 noticeably altered land use. At storage facilities where the cumulative impacts would be 

28 MODERATE from other Federal or non-federal activities, the NRC determined the cumulative 

29 impacts would likely remain MODERATE whether or not continued storage occurred because 

30 the incremental impacts from continued storage would be minor, especially in comparison to 

31 other general trends, such as urbanization.

32 6.4.2 Socioeconomics

33 This section evaluates the socioeconomic effects of continued storage when added to the 

34 aggregate effects of other past, present, and reasonably foreseeable future actions. As 

35 described in Sections 4.2 and 5.2, the adverse effects of continued storage are SMALL for all 

36 at-reactor and away-from-reactor spent fuel storage facilities because of the small number of 

37 workers required to maintain and monitor the storage of spent fuel. In addition, there could also 
Cumulative Impacts

September 2013 6-13 Draft NUREG‒2157

1 be LARGE beneficial impacts on the local economy and SMALL impacts elsewhere as the result 

2 of construction and operation of an away-from-reactor storage facility.

3 The geographic area considered in the cumulative socioeconomic resources analysis is the 

4 socioeconomic region of influence, which includes the areas where spent fuel storage workers 

5 and their families reside, spend their income, and use their benefits. Thus, in these areas, 

6 workers affect both directly and indirectly the economic conditions of the region.

7 6.4.2.1 Potential Cumulative Impacts from General Trends and Activities

8 Cumulative socioeconomic impacts in local communities could affect (1) employment and 

9 income, (2) tax revenues, (3) population and housing demand, and (4) the availability and 

10 demand for public services (NRC 2008, 2011d, 2012a, 2013a). New industries, such as energy

11 projects (e.g., replacement power); industrial, commercial, and agricultural development; and 

12 regional tourism and recreation, could cause an increase in population, demand for housing and 

13 services, traffic volume, and tax revenue paid to local jurisdictions. In addition, an at-reactor 

14 ISFSI located at or near an operating reactor would experience cumulative impacts associated 

15 with reactor operations, such as traffic and tax revenue paid to local jurisdictions.

16 The magnitude of the socioeconomic impact resulting from general trends within close proximity 

17 of a spent fuel storage facility would depend on the intensity of development. Cumulative 

18 impacts would be specific to the region in which the storage facility is located and would range 

19 from minimal (e.g., minor increase in demand for public services caused by construction and 

20 operation of a new power plant, see NRC 2011d) to noticeable (e.g., noticeable increase in 

21 housing and rental prices because of increased demand caused by the construction and 

22 operation of a new power plant, see NRC 2008). In some situations, the cumulative impacts 

23 could be substantially beneficial (e.g., increase in property tax revenue paid to the local area 

24 resulting from operation of new power plant, see NRC 2012a).

25 6.4.2.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

26 Activities

27 Cumulative impacts could result from other NRC-regulated or spent fuel-related activities, such 

28 as decommissioning the power block (including the spent fuel pool), ISFSI, and DTS. The 

29 extent to which impacts would be cumulative would depend on the timing of decommissioning in 

30 relation to other activities (e.g., plant shutdown).

31 The immediate socioeconomic impact caused by terminating reactor operations and power plant 

32 shutdown would be greater than the impact from decommissioning the power block. The 

33 socioeconomic impacts from terminating reactor operations and power plant shutdown are 

34 described in both the Decommissioning GEIS (NRC 2002) and the License Renewal GEIS

35 (NRC 2013a), as described below.
Cumulative Impacts

Draft NUREG‒2157 6-14 September 2013

1 As discussed in Section 3.2, the size of the nuclear power plant operations workforce varies 

2 considerably among operating U.S. nuclear power facilities and ranges from 600 to 

3 2,400 workers. Operating nuclear power plants generally provide a significant amount of tax

4 revenue to local communities and public school districts. Impacts associated with power plant 

5 shutdown include the loss of jobs at the nuclear plant and in surrounding communities; and a 

6 corresponding reduction in tax payments, demand for housing and public services, and traffic 

7 volume. As stated in Section 3.2, property tax payments would continue as long as spent fuel is 

8 stored onsite. Publicly owned tax-exempt nuclear power plants, fully depreciated plants, or 

9 plants located in urban or an urbanizing area with a large or growing tax base would not 

10 experience many changes in overall socioeconomic conditions (NRC 2002). In rare 

11 circumstances in which a large nuclear power plant located in a rural area permanently ceases 

12 operations early and delays decommissioning, the affected area could experience greater 

13 impacts (NRC 2002). Impacts from the loss or reduction of tax revenue because of the 

14 termination of reactor operations and power plant shutdown on community services could range 

15 from SMALL to LARGE (NRC 2013a). Considering all variables, such as plant size and 

16 community size as equivalent, plants that begin decommissioning immediately would have 

17 less immediate negative impacts because the workforce reduction would occur gradually 

18 (NRC 2002).

19 Impacts associated with decommissioning a power block (including the spent fuel pool) were 

20 described in the Decommissioning GEIS (NRC 2002). While there would be an overall 

21 reduction in the number of workers at the nuclear plant during decommissioning, the size of the 

22 workforce would have already been substantially reduced after the termination of reactor 

23 operations and power plant shutdown. The Decommissioning GEIS estimated that between 

24 100 and 200 workers would be needed to support decommissioning (NRC 2002). The 

25 socioeconomic impact from decommissioning the power block and spent fuel pool would 

26 depend on the size and location of the facility and would eventually result in the loss of jobs 

27 upon completion, including reduced housing demand, tax revenues, and demand for public 

28 services. However, the NRC concluded that the overall socioeconomic impact from 

29 decommissioning the power block would be SMALL (NRC 2002).

30 Because of the smaller workforce involved, the socioeconomic impact from decommissioning

31 any ISFSI and associated DTS would be less than experienced from the decommissioning the

32 power block. Decommissioning activities would commence after spent fuel has been 

33 transported offsite to either a repository or away-from-reactor storage facility. Funding plans for 

34 decommissioning ISFSIs (MYAPC 2013; CYAPC 2012; YAEC 2012) estimate that 

35 approximately 50 workers would be needed to decommission an at-reactor storage facility over 

36 a 1- to 1.5-year period. Decommissioning the DTS could occur in parallel with decommissioning 

37 the at-reactor ISFSI and would represent a minor increase to the workforce. Based on DOE’s 

38 Topical Safety Analysis Report (DOE 1996), it was estimated that a 5-person workforce could 

39 decommission the DTS within 60 days. Workforce numbers and duration of decommissioning 
Cumulative Impacts

September 2013 6-15 Draft NUREG‒2157

1 activities would vary from site to site. A review of NRC EAs and EISs for construction, 

2 operation, and renewal of site specifically licensed at-reactor and away-from-reactor ISFSIs 

3 (NRC 2001a, 2003a, 2005a−c, 2009, 2012b) did not identify any significant socioeconomic 

4 impacts during decommissioning of ISFSIs. The magnitude of impacts from decommissioning 

5 an ISFSI at other sites would be similar to that described in the Calvert Cliffs, Humboldt Bay, 

6 H.B. Robinson, Surry, Oconee, and Diablo Canyon EAs and the PFSF EIS because of 

7 considerations of workforce, housing demand, traffic networks, and public services. Because 

8 the impacts from decommissioning at-reactor and away-from reactor ISFSIs would be similar to 

9 that described in site-specific ISFSI EAs and the PFSF EIS, socioeconomic impacts during 

10 decommissioning are expected to be minimal.

11 6.4.2.3 Conclusion

12 Cumulative impacts include the incremental effects from continued storage when added to the 

13 aggregate effects of other past, present, and reasonably foreseeable future actions. As 

14 described in Sections 4.2 and 5.2, the adverse effects of continued storage are SMALL for 

15 at-reactor and away-from-reactor storage facilities because of the small number of workers 

16 required to maintain and monitor the storage of spent fuel. However, there could also be 

17 LARGE beneficial impacts on the local economy and SMALL impacts elsewhere as a result of 

18 construction and operation of an away-from-reactor storage facility. In addition, past, present, 

19 and reasonably foreseeable activities take place in the geographic area of interest that could 

20 contribute to cumulative socioeconomic impacts. The cumulative socioeconomic impacts from 

21 continued storage when added to other past, present, and reasonably foreseeable Federal and 

22 non-federal activities, such as the termination of reactor operations, decommissioning, 

23 construction of replacement power energy projects, urbanization, and transportation projects, 

24 are SMALL to LARGE depending on the activity and location of the action relative to the local 

25 community. A SMALL impact would occur if there are no other actions that have overlapping, 

26 noticeable socioeconomic effects. A MODERATE impact would occur if other Federal or non27 federal actions, such as construction and operation of a new power plant, have overlapping 

28 impacts with the continued storage of waste that would noticeably alter socioeconomic 

29 conditions (e.g., increased tax revenue). LARGE impacts would be unlikely because local 

30 planning and zoning authorities would ensure that new projects do not destabilize 

31 socioeconomic attributes in the local area. At storage facilities for which the adverse cumulative 

32 impacts would range from MODERATE to LARGE because of other Federal and non-federal 

33 activities, the adverse cumulative impacts would be MODERATE to LARGE whether or not 

34 continued storage occurred because the incremental impacts from continued storage would be 

35 minor, especially in comparison to other general trends, such as urbanization or construction 

36 and operation of new power plants.
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Draft NUREG‒2157 6-16 September 2013

1 6.4.3 Environmental Justice

2 This section describes the impacts on minority and low-income populations resulting from 

3 continued storage when added to the aggregate effects of other past, present, and reasonably 

4 foreseeable future actions. As described in Sections 4.3 and 5.3, minority and low-income 

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

6 and environmental effects from the incremental impacts associated with continued storage.

7 The environmental justice cumulative impact analysis assesses the potential for minority and 

8 low-income populations to experience disproportionately high and adverse human health and 

9 environmental effects from the continued storage of spent fuel combined with past, present, and 

10 reasonably foreseeable future actions. Adverse health effects are measured in terms of the risk

11 and rate of fatal or nonfatal adverse impacts on human health. An adverse environmental 

12 impact is an impact that is determined to be both harmful and significant (as employed by 

13 NEPA).

14 Disproportionately high and adverse human health effects occur when the risk or rate of 

15 exposure to an environmental hazard for a minority or low-income population is significant and 

16 exceeds the risk or exposure rate for the general population or for another appropriate 

17 comparison group. Disproportionately high environmental effects refer to impacts, or risk of 

18 impacts, on the natural or physical environment in a minority or low-income community that are 

19 significant and appreciably exceed the environmental impact on the larger community. Such 

20 effects may include biological, cultural, economic, or social impacts (NRC 2013a).

21 Additionally, the cumulative impact assessment considers the potential radiological risk to 

22 minority and low-income population groups residing within the 80 km (50 mi) region from the 

23 spent fuel storage facility as well as the potential exposure from other sources of radiation from 

24 other actions. As stated in Section 3.3, special population groups include populations that rely 

25 principally on fish or wildlife for subsistence.

26 6.4.3.1 Potential Cumulative Impacts from General Trends and Activities

27 Potentially adverse human health and environmental effects from activities associated with 

28 industrial, commercial, agricultural, and transportation developments can affect the resources 

29 on which minority and low-income populations depend (e.g., fish, game animals, and native 

30 vegetation) (NRC 2013a). For example, potential impacts on minority and low-income 

31 populations from the construction and operation of replacement power and other industrial 

32 projects in the vicinity of storage facilities would mostly consist of environmental (e.g., noise, 

33 dust, and traffic) and socioeconomic (e.g., employment and housing) effects during 

34 construction. Noise and dust impacts during construction would be short term and primarily 

35 limited to onsite activities. Minority and low-income populations residing along site access 

36 roads could be directly affected by increased commuter vehicle and truck traffic. However, 
Cumulative Impacts

September 2013 6-17 Draft NUREG‒2157

1 these effects could be limited to certain hours of the day. Increased demand for rental housing 

2 during construction could cause rental costs to temporarily rise, disproportionately affecting low3 income populations living near the site that rely on inexpensive housing. However, given the 

4 proximity of most industrial sites to urban areas, many workers could commute to the 

5 construction site, thereby reducing the need for rental housing.

6 The magnitude of human health and environmental effects resulting from all actions associated 

7 with general trends on minority and low-income populations living within close proximity of a 

8 spent fuel storage facility would depend on the intensity of the effects. Some of these potential 

9 effects have been identified in resource areas presented in Chapters 4 and 5 of this draft GEIS. 

10 Minority and low-income populations are subsets of the general population residing in the area 

11 and all would be exposed to the same hazards generated from activities associated with 

12 continued storage.

13 6.4.3.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

14 Activities

15 Cumulative impacts could result from other NRC-regulated or spent fuel-related activities, such 

16 as terminating reactor operations, shutting down the power plant, decommissioning the reactor 

17 power block (including the spent fuel pool) and ISFSIs, and constructing and operating the DTS. 

18 The NRC also considers the potential for minority and low-income populations to experience 

19 disproportionately high and adverse human health effects and (1) whether the health effects 

20 would be significant, at or above generally accepted norms; (2) whether the risk or rate of 

21 environmental hazard exposure would be significant, exceed, or likely exceed the risk or rate to 

22 an appropriate comparison group (e.g., the general population); and (3) whether health effects 

23 would occur in a minority or low-income population already affected by cumulative or multiple 

24 adverse exposures from environmental hazards (NRC 2002).

25 The impacts associated with plant shutdown are described in both the Decommissioning GEIS

26 (NRC 2002) and the License Renewal GEIS (NRC 2013a). Plant shutdown and the resulting 

27 loss of jobs, income, and tax revenue could have a disproportionate effect on minority and low28 income populations (NRC 2013a). The loss of tax revenue, for example, could reduce the 

29 availability or eliminate some of the community services on which low-income and minority 

30 populations may depend (NRC 2013a).

31 Environmental impacts associated with decommissioning activities at a nuclear power plant site 

32 and the extent to which minority and low-income populations could be affected are discussed in 

33 the Decommissioning GEIS (NRC 2002). Decommissioning the power block and spent fuel 

34 pool would eventually result in the loss of jobs upon completion. Other impacts would include 

35 reduced housing demand, tax revenues, and the availability and demand for public services 

36 (NRC 2002). Decommissioning activities could affect air and water quality in the area around 

37 each nuclear plant site, which could cause health and other environmental impacts in minority 
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Draft NUREG‒2157 6-18 September 2013

1 and low-income populations that might be present in the area (NRC 2002). Population groups 

2 with particular resource dependencies or practices (e.g., subsistence agriculture, hunting, and 

3 fishing) could also be disproportionately affected (NRC 2002). The Decommissioning GEIS 

4 concluded that disproportionately high and adverse impacts and associated significance would 

5 be based on site-specific environmental reviews because prior to the start of decommissioning 

6 activities, a final decommissioning plan must be submitted to the NRC for review and approval. 

7 NRC authorization of a final decommissioning plan would constitute a federal action under 

8 NEPA and environmental resources (e.g., geology and soils, environmental justice, 

9 socioeconomics, and ecology) would be analyzed on a site-specific basis (NRC 2002).

10 Because a smaller workforce would be needed, impacts from decommissioning an at-reactor 

11 ISFSI are anticipated to be less than impacts resulting from decommissioning the reactor power 

12 block. As discussed in Section 6.4.2, approximately 50 workers would be needed to 

13 decommission an at-reactor ISFSI over a 1- to 1.5-year period. Decommissioning of the DTS 

14 could occur in parallel and would represent a minor increase to the workforce. Workforce 

15 numbers and duration of decommissioning activities would vary from site to site. For away16 from-reactor ISFSIs, the impacts of decommissioning would be similar to those associated with 

17 decommissioning the power block because the number of workers required to decommission 

18 both facilities are similar (NRC 2001b, 2002).

19 6.4.3.3 Conclusion

20 Cumulative impacts on minority and low-income populations include the incremental effects 

21 from continued storage when added to the aggregate effects of other past, present, and 

22 reasonably foreseeable future actions. As discussed in Section 4.3 and 5.3 of this draft GEIS, 

23 minority and low-income populations are not expected to experience disproportionately high and 

24 adverse effects from the incremental impacts associated with the continued storage of spent 

25 fuel. In addition, the NRC determined that no disproportionately high and adverse human health

26 effects are expected in special pathway receptor populations in the region as a result of 

27 subsistence consumption of water, local food, fish, and wildlife. Similarly, there would be no 

28 contributory effects to human health beyond what is currently being experienced for the duration 

29 that spent fuel remains onsite. Potential effects occurring from other reasonably foreseeable 

30 offsite projects would be considered during NRC site-specific licensing reviews (e.g., 

31 construction of an away-from-reactor ISFSI, replacement of ISFSI and construction, operation, 

32 and replacement of a DTS). In addition, as indicated in the NRC policy statement, the potential 

33 for environmental justice impacts would be considered during the environmental reviews for 

34 specific NRC licensing actions associated with each particular storage facility (69 FR 52040).

35 6.4.4 Air Quality

36 This section evaluates the effects of continued storage on air quality resources when added to 

37 the aggregate effects of other past, present, and reasonably foreseeable future actions. As 
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September 2013 6-19 Draft NUREG‒2157

1 described in Sections 4.4 and 5.4, the incremental impacts from continued storage on air quality 

2 is SMALL for all timeframes at both at-reactor and away-from-reactor storage facilities, except 

3 during short-term storage at away-from-reactor ISFSIs where the impacts would range from 

4 SMALL to MODERATE because construction of a rail spur could result in noticeable impacts on

5 air quality.

6 The geographic area considered in the cumulative air quality analysis includes the air quality 

7 control region in which an at-reactor or away-from-reactor storage facility is located. This area 

8 could include one or more counties that comprise the air quality control region surrounding the 

9 site, as described in Section 3.4.

10 6.4.4.1 Potential Cumulative Impacts from General Trends and Activities

11 Cumulative impacts on air quality could include degradation of air quality in air quality control 

12 regions that are already in or near nonattainment or maintenance for one or more national 

13 ambient air quality standards. For at-reactor and away-from-reactor storage facilities, 

14 cumulative impacts could occur due to multiple activities that affect the air quality control region 

15 near the storage facility (e.g., electric power generation; ground, water, and air transportation; 

16 and nearby heavy industries) associated with urbanization and industrial, commercial, 

17 agricultural, and transportation development (e.g., NRC 2011a–f, 2012a, 2013a,b). In addition, 

18 climate change can impact air quality because of higher or lower ambient air temperatures and 

19 changes in precipitation rates (GCRP 2009). For air resources near at-reactor storage facilities, 

20 additional cumulative impacts may include the following: (1) cumulative impacts due to the 

21 various impacts from an individual power plant over time (e.g., employee vehicles and 

22 emergency diesel generator testing) and (2) cumulative impacts due to closely sited power 

23 plants (e.g., air pollutant emissions from nearby coal-fired power plants) (NRC 2013a).

24 The magnitude of cumulative impacts resulting from all general trends within the air quality

25 control region in which a storage facility is located would depend on the nature and location of 

26 the actions, the number (and density) of actions, and the extent to which these actions (facilities 

27 or projects) employ mitigation measures to minimize such impacts. The cumulative impacts 

28 from general trends and activities would range from minimal (e.g., minor air emissions 

29 associated with localized development in the area, see NRC 2011f) to noticeable (e.g., 

30 emissions from the construction and operation of a nearby coal-fired plant, see NRC 2011a).

31 6.4.4.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

32 Activities

33 Cumulative impacts on air quality resources could result from other NRC-regulated or spent 

34 fuel-related activities, such as (1) decommissioning of the reactor power block (including the 

35 spent fuel pool), ISFSIs, and DTS; (2) loading of casks for transportation to a repository; and 

36 (3) long-range transport of spent fuel to a repository.
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Draft NUREG‒2157 6-20 September 2013

1 Reactor power block decommissioning activities involve the use of large diesel-powered 

2 equipment for equipment removal, demolition of structures, worker transportation to and from 

3 the site, and transportation of demolition debris to waste disposal facilities. In most cases, air 

4 quality effects would be relatively minor and short term in duration. Air quality control measures, 

5 which may be required to comply with air quality permits, would also minimize air quality 

6 impacts. The Decommissioning GEIS (NRC 2002) analyzed the air quality impacts for 

7 decommissioning a reactor, including the spent fuel pools. In the Decommissioning GEIS for 

8 power reactors (including spent fuel pools), the NRC determined that there would be minimal 

9 impact on air quality and concluded that the impacts of decommissioning on air quality are not 

10 detectable (NRC 2002). The NRC’s EAs for the Calvert Cliffs and Diablo Canyon at-reactor 

11 ISFSIs and the PFSF away-from-reactor ISFSI EIS did not identify any significant impacts on air 

12 quality resources during decommissioning of the ISFSI (NRC 2001a, 2003a, 2012a). The NRC 

13 assumes that the types and magnitude of impacts described in the Calvert Cliffs and Diablo 

14 Canyon EAs and the PFSF EIS are representative of impacts from decommissioning an 

15 at-reactor or away-from-reactor ISFSI at other sites because these facilities are typical sizes of 

16 at-reactor and away-from-reactor ISFSIs and used typical decommissioning methods. Given 

17 that the impacts from decommissioning reactors, spent fuel pools, and ISFSIs would be similar 

18 to that described in the Decommissioning GEIS for reactors and site-specific ISFSI EAs and the 

19 PFSF EIS, impacts on air quality resources from decommissioning are expected to be minimal.

20 Because the same transporters, trucks, and other fossil-fuel-powered equipment are used to 

21 transfer dual-purpose canisters from transportation casks to storage casks as are used to 

22 transfer them from storage casks to transportation casks, the loading of casks for transportation 

23 to a repository would have similar air emission sources, levels, and impact magnitude as the 

24 receiving of spent fuel at an away-from-reactor facility from at-reactor locations. As described in 

25 Section 5.4.1, the NRC concluded that the operation of an away-from-reactor ISFSI, including 

26 the activity of loading casks, would be SMALL. Therefore the impact magnitude for the loading 

27 of casks for transportation to a repository would be similar.

28 Disposal of spent fuel requires the long-range transportation from the storage site to a 

29 repository. The at-reactor storage operation examines the impacts of a facility with a 

30 1,600-MTU capacity whereas the away-from-reactor operation examines the impacts of a facility 

31 with a 40,000-MTU capacity. The “Final Supplemental Environmental Impact Statement for a 

32 Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste 

33 at Yucca Mountain, Nye County, Nevada” (Yucca Mountain EIS) (DOE 2008) assesses the air 

34 quality impacts for the transportation of 70,000 MTU of spent fuel within Nevada. The 

35 Yucca Mountain EIS concluded that the emissions from spent fuel transportation during 

36 operations would be distributed over the entire length of the route, and no air quality standards 

37 would be exceeded. Because the amount of spent fuel considered in the transportation 

38 analyses in this draft GEIS is less than the amount considered in the Yucca Mountain analyses, 

39 the NRC concludes that the transportation of spent fuel to a repository would not be greater 

40 than the impact magnitude documented in the Yucca Mountain EIS.
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September 2013 6-21 Draft NUREG‒2157

1 6.4.4.3 Conclusion

2 Cumulative impacts on air quality include the incremental effects from continued storage when 

3 added to the aggregate effects of other past, present, and reasonably foreseeable future 

4 actions. As described in Sections 4.4 and 5.4, the incremental impacts from continued storage 

5 on air quality are SMALL for all timeframes for both at-reactor and away-from-reactor storage 

6 facilities, except during short-term storage at away-from-reactor ISFSIs where the impacts 

7 would range from SMALL to MODERATE. In addition, past, present, and reasonably 

8 foreseeable activities take place in the geographic area of interest that could contribute to 

9 cumulative effects to air quality resources. The cumulative impacts from continued storage 

10 when added to other past, present, and reasonably foreseeable Federal and non-federal 

11 activities, such as urbanization, energy development, or other industrial or commercial activities, 

12 are SMALL to MODERATE. A SMALL impact would occur at sites where storage facilities have 

13 minimal impacts on air quality and no other actions occur that had overlapping, noticeable 

14 effects on air quality. A MODERATE impact would occur if other actions occur that did have 

15 overlapping and noticeable effects on air quality, such as a nearby fossil-fuel-fired electricity 

16 generating station. At storage facilities where the incremental impacts would be SMALL and the 

17 cumulative impacts would be MODERATE from other Federal or non-federal activities, the NRC 

18 determined the cumulative impacts would likely remain MODERATE whether or not continued 

19 storage occurred because the incremental impacts from continued storage would be minor, 

20 especially in comparison to other general trends, such as operation of fossil-fuel-fired power 

21 plant.

22 6.4.5 Climate Change

23 As described in Sections 4.5 and 5.5, the incremental impacts from continued storage on 

24 climate change, in terms of emissions of greenhouse gases (GHGs), are SMALL for all 

25 timeframes at both at-reactor and away-from-reactor storage facilities. The geographic area 

26 considered in the cumulative climate change analysis is worldwide.

27 6.4.5.1 Potential Cumulative Impacts from General Trends and Activities and from 

28 Other NRC-Regulated or Spent Fuel-Related Activities

29 The magnitude of cumulative impacts resulting from all general trends taking place within the 

30 region in which a storage facility is located must be placed in geographic context for the 

31 following reasons:

32 • The environmental impact is global rather than local or regional.

33 • The effect is not particularly sensitive to location of the release point.

34 • The magnitudes of individual GHG sources related to human activity, no matter how large 

35 compared to other sources, are small when compared to the total mass of GHGs in the 

36 atmosphere.
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Draft NUREG‒2157 6-22 September 2013

1 • The total number and variety of GHG sources is extremely large and the sources are 

2 ubiquitous.

3 These points are illustrated by the following comparison of annual carbon dioxide emission rates 

4 (Table 6-2).

5 Table 6-2. Comparison of Annual Carbon Dioxide Emission Rates

Source MT/yr(a)

Global emissions from fossil-fuel combustion (2010)

(b) 31,780,000,000

U.S. emissions from fossil-fuel combustion (2011)

(c) 5,745,000,000

1,000-MW(e) nuclear power plant (including fuel cycle, 80 percent capacity factor)(d) 450,000

1,000-MW(e) nuclear power plant (during SAFSTOR)(d) 325

Average U.S. home(e) 12

Average U.S. passenger vehicle(e) 5

Source: (EPA 2012b); expressed in metric tons per year of carbon dioxide.

(a) Nuclear power emissions estimates are in units of metric tons of carbon dioxide-equivalent whereas the other 

energy alternatives emissions estimates are in units of metric tons of carbon dioxide. If nuclear power emissions 

were represented in metric tons of carbon dioxide, the value would be slightly less, as other GHG emissions 

would not be included.

(b) Source: (EPA 2012a), Chapter 3; expressed in metric tons per year of carbon dioxide.

(c) Source: (EPA 2012a), Table 3-1; expressed in metric tons per year of carbon dioxide.

(d) Source: (NRC 2011i); expressed in metric tons per year of carbon dioxide-equivalent.

(e) (EPA 2012b); expressed in metric tons per year of CO2

6 Evaluation of cumulative impacts of GHG emissions requires the use of a global climate model. 

7 The GCRP report (GCRP 2009) provides a synthesis of the results of numerous climate 

8 modeling studies. The NRC concludes that the cumulative impacts of GHG emissions around 

9 the world as presented in the report are the appropriate basis for its evaluation of cumulative 

10 impacts. Based primarily on the scientific assessments of the GCRP and National Research 

11 Council, the EPA Administrator issued a determination in 2009 (74 FR 66496) that GHGs in the 

12 atmosphere may reasonably be anticipated to endanger public health and welfare, based on 

13 observed and projected effects of GHGs, their impact on climate change, and the public health 

14 and welfare risks and impacts associated with such climate change. Based on the impacts set 

15 forth in the GCRP report, and the carbon dioxide emissions criteria in the final EPA “Prevention 

16 of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule” (75 FR 31514), the 

17 NRC concludes that the national and worldwide cumulative impacts of GHG emissions are 

18 noticeable but not destabilizing. The review team bases this conclusion that the environment 

19 may be noticeably affected by GHG emissions but not destabilized on the tailored approach to 

20 addressing carbon dioxide emissions in the EPA rule and the EPA Administrator’s 

21 determination, neither of which call for immediate action such as closure of GHG-emitting 

22 facilities. Therefore, national and worldwide cumulative impacts of GHG emissions reflect 

23 conditions that are noticeable but not destabilizing. The NRC further concludes that the 
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September 2013 6-23 Draft NUREG‒2157

1 cumulative impacts would be noticeable but not destabilizing, with or without the GHG 

2 emissions from continued storage.

3 6.4.5.2 Conclusion

4 Cumulative impacts include the incremental effects from continued storage when added to the 

5 aggregate effects of other past, present, and reasonably foreseeable future actions. As 

6 described in Sections 4.5 and 5.5, the incremental impacts from continued storage on climate 

7 change is SMALL for all timeframes at both at-reactor and away-from-reactor storage facilities. 

8 In addition, past, present, and reasonably foreseeable activities take place worldwide that could 

9 contribute to climate change. The cumulative impacts from continued storage when added to 

10 other past, present, and reasonably foreseeable Federal and non-federal activities, such as 

11 operation of fossil-fuel-fired power plants, would be MODERATE.

12 At storage facilities where the cumulative impacts would be MODERATE from other Federal or 

13 non-federal activities, the NRC determined the cumulative impacts would likely remain 

14 MODERATE whether or not continued storage occurred because the incremental impacts from 

15 continued storage would be minor, especially in comparison to other GHG emitters, such as 

16 operation of fossil-fuel-fired power plant.

17 6.4.6 Geology and Soils

18 This section evaluates the effects of continued storage on geology and soils when added to the 

19 aggregate effects of other past, present, and reasonably foreseeable future actions. As 

20 described in Sections 4.6 and 5.6, the incremental impacts from continued storage on geology 

21 and soils is SMALL for all timeframes at both at-reactor and away-from-reactor storage facilities.

22 The geographic area considered in this cumulative analysis with regard to soils is the area 

23 within the site boundaries, and for geology is the area in the immediate vicinity of the at-reactor 

24 or away-from-reactor storage facility. Depending on the site, the area could include rural and 

25 semi-urban regions and the associated environmental conditions.

26 6.4.6.1 Potential Cumulative Impacts from General Trends and Activities

27 Cumulative impacts on the geology and soils of an area include (1) access to mineral or energy 

28 resources, (2) destruction of unique geologic features, (3) soil loss and increased erosion 

29 potential induced by construction activities, (4) soil compaction and changes to surface drainage 

30 as a result of utilities and structures, and (5) potential soil contamination (both radiological and 

31 nonradiological) through inadvertent spills during normal operations (e.g., NRC 2011a–f, 2012a, 

32 2013a,b). These impacts typically result from land-disturbing activities, including earthmoving, 

33 grading, and excavation from constructing, operating, and decommissioning new and existing 
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Draft NUREG‒2157 6-24 September 2013

1 energy producing plant facilities and associated infrastructures. Land usage in the vicinity of a 

2 storage facility may also affect the access to mineral or energy resources.

3 The magnitude of geology and soils cumulative impacts resulting from general trends taking 

4 place within the region in which a storage facility is located would depend on current land 

5 utilization patterns, any proposed land-use changes, the density of impacting activities, and the 

6 extent to which these activities (facilities or projects) employ mitigation measures to reduce such 

7 impacts. The cumulative impacts from general trends and activities would range from minimal 

8 (e.g., minor ground-disturbing activities associated with localized development in the area, see 

9 NRC 2011d) to noticeable (e.g., sufficient development to noticeably disturb soil near the 

10 storage facility, see NRC 2012a).

11 6.4.6.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

12 Activities

13 Cumulative impacts on geologic resources and soils could result from other NRC-regulated or 

14 spent fuel-related activities, such as decommissioning of the reactor power block (including the 

15 spent fuel pool), ISFSI, and DTS.

16 Activities associated with decommissioning of the reactor that have a potential to affect soils 

17 include (1) addition and expansion of staging and laydown areas for equipment and 

18 (2) construction of temporary buildings, roads, and parking areas. In the Decommissioning 

19 GEIS for power reactors (including spent fuel pools) (NRC 2002), the NRC determined that 

20 impacts on the soils from these activities would be temporary and would not be detectable or 

21 destabilizing. For example, in the case of most reactor sites, sufficient previously disturbed 

22 areas are available for staging, laydown, and construction sites. Therefore, in the 

23 Decommissioning GEIS, it was not anticipated that additional land would need to be disturbed, 

24 thereby reducing the potential for increased soils impacts (NRC 2002). In addition, 

25 implementing best management practices (BMPs) would reduce soil erosion and compaction. 

26 These practices include, but are not limited to, minimizing the amount of disturbed land, 

27 stockpiling topsoil on laydown areas prior to use, mulching and seeding in disturbed areas, 

28 covering loose materials with geotextiles, using silt fences to reduce sediment loading to surface 

29 water, and installing proper culvert outlets to direct flows in streams or drainages. Given that 

30 the impacts from decommissioning reactors and spent fuel pools would be similar to that 

31 described in the Decommissioning GEIS for reactors, impacts on onsite soils during 

32 decommissioning of reactors and spent fuel pools are expected to be SMALL.

33 Activities associated with decommissioning of ISFSIs that could affect geology and soils include 

34 (1) construction of roads and parking areas used during the demolition of the storage pads, 

35 casks, and support facilities and (2) removing any contaminated soils identified (from both 

36 radiological and nonradiological inadvertent spills during the final radiological site survey under 

37 10 CFR Part 20, Subpart E, “Radiological Criteria for License Termination.” In most cases, 
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September 2013 6-25 Draft NUREG‒2157

1 impacts associated with decommissioning of ISFSIs would be similar to or less than those 

2 impacts associated with construction of ISFSIs. After decommissioning activities are complete, 

3 the area previously occupied by the ISFSIs would typically be covered with topsoil, contoured, 

4 and replanted with native vegetation (NRC 2005c). For example, the NRC assumed that the 

5 types and magnitude of impacts from decommissioning an ISFSI would be similar to that 

6 described in the Calvert Cliffs ISFSI License Renewal EA (NRC 2012c) because the facility is a 

7 typical size expected for an ISFSI and the analysis assumed typical decommissioning practices. 

8 Specifically, impacts on soils are related to the temporary disturbance of soil horizons as the 

9 ISFSI foundation is removed and leveling and regrading of the ISFSI area following 

10 decommissioning (NRC 2012b). The NRC expects that subsurface geology would not be 

11 impacted by ISFSI decommissioning because decommissioning activities typically do not extend 

12 to a depth that affects the geology (NRC 2002). Because the impacts from decommissioning 

13 at-reactor and away-from-reactors ISFSIs would be similar to that described in site-specific 

14 ISFSI EAs and EISs, impacts on geology and soils during decommissioning are expected to be 

15 SMALL.

16 6.4.6.3 Conclusion

17 Cumulative impacts on geologic resources and soils include the incremental effects from 

18 continued storage when added to the aggregate effects of other past, present, and reasonably 

19 foreseeable future actions. As described in Sections 4.6 and 5.6, the incremental impacts from 

20 continued storage on geologic resources and soils is SMALL for all scenarios at both at-reactor 

21 and away-from-reactor storage facilities. In addition, past, present, and reasonably foreseeable 

22 activities take place in the geographic area of interest that could contribute to cumulative effects 

23 to geology and soils. The cumulative impacts on geology and soils from continued storage 

24 when added to other past, present, and reasonably foreseeable Federal and non-federal 

25 activities, such as power plant construction or urbanization, would range from SMALL to 

26 MODERATE. A SMALL impact would occur if no other actions occur that had overlapping, 

27 noticeable effects on geological resources. A MODERATE impact would occur if other Federal 

28 or non-federal actions, such as construction of new energy facilities, had overlapping impacts 

29 with the continued storage of waste that noticeably alter soil and geological resources. At 

30 storage facilities where the cumulative impacts would be MODERATE as a result of other 

31 Federal and non-federal activities, the NRC determined that the cumulative impacts would likely 

32 remain MODERATE whether or not continued storage occurred because the incremental 

33 impacts from continued storage would be minor, especially in comparison to other trends, such 

34 as widespread urbanization. 

35 6.4.7 Surface-Water Quality and Use

36 This section evaluates the effects of continued storage on surface-water resources when added 

37 to the aggregate effects of other past, present, and reasonably foreseeable future actions. As 

38
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Draft NUREG‒2157 6-26 September 2013

1 described in Sections 4.7 and 5.7, the incremental impacts from continued storage on surface2 water resources is SMALL for all timeframes at at-reactor and away-from-reactor storage 

3 facilities.

4 The geographic area considered in the cumulative surface-water resources analysis includes 

5 the portion of waterbodies (e.g., streams, rivers, ponds, estuaries, and marine waters) 

6 potentially affected by the at-reactor or away-from-reactor storage facility. 

7 6.4.7.1 Potential Cumulative Impacts from General Trends and Activities

8 Potential cumulative impacts on surface-waterbodies would include conflicts in consumptive 

9 water use and changes to flow patterns and chemical compositions in waterbodies receiving 

10 discharges from the reactor plant or storage facility (e.g., NRC 2011a–f, 2012a, 2013a,b). For 

11 at-reactor and away-from-reactor storage sites, cumulative impacts could occur because of 

12 multiple activities that affect the same waterbody (e.g., conflicting water demands to support 

13 urban, agricultural, commercial, and industrial developments). In addition, climate change can 

14 affect surface-water resources near at-reactor and away-from-reactor storage sites because of 

15 runoff from more intense storms, drought, flooding, and sea-level rise (USGCRP 2009). For 

16 at-reactor storage facilities, additional cumulative impacts on surface-water resources would 

17 include (1) cumulative impacts due to the various impacts from an individual power plant over 

18 time (e.g., consumptive water use, altered current patterns at intake and discharge structures, 

19 altered chemical gradients) and (2) cumulative impacts due to closely sited power plants 

20 (e.g., consumptive water-use conflicts, additive effects of cooling-tower discharges on water 

21 temperature, and chemical composition) (NRC 2013a).

22 The magnitude of cumulative impacts resulting from all general trends taking place within the 

23 region in which a storage facility is located would depend on the nature and location of the 

24 actions relative to important waterbodies, the number and density of actions, and the extent to 

25 which these actions (i.e., facilities or projects) employ mitigation measures to minimize such 

26 impacts. The cumulative impacts from general trends and activities would range from minimal 

27 (e.g., consumptive water use from all water users in the watershed would have minor alterations 

28 to overall volume of water in the watershed, see NRC 2011d) to noticeable (e.g., the discharge 

29 and runoff of increased levels of dissolved solids, particularly during low-flow conditions, could 

30 noticeably alter water quality, see NRC 2011d). In rare situations, the cumulative impacts from 

31 general trends and activities could be destabilizing (e.g., increased water demand from power 

32 plants and the effects of climate change, especially under extreme drought conditions, could 

33 potentially destabilize a river system, see NRC 2011e).
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September 2013 6-27 Draft NUREG‒2157

1 6.4.7.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

2 Activities

3 Cumulative impacts on surface-water resources could result from other NRC-regulated or spent 

4 fuel-related activities, such as ground-disturbing activities that could occur during shutdown, 

5 preparation activities for transportation of waste to a repository, and decommissioning of the 

6 reactor, spent fuel pool, and ISFSI. Impacts could result from activities such as removal of 

7 shoreline or in-water structures, dredging or filling a stream or bay, runoff, and surface soil 

8 erosion. In most cases, such surface-water disturbances and water use for dust abatement 

9 would be relatively minor and short-term in duration. Stormwater control measures, which 

10 would be required to comply with National Pollutant Discharge Elimination System (NPDES) 

11 permits, also would minimize migration of sediments or other contaminants into surface12 waterbodies. Dredging or filling of waterbodies would require permits from the U.S. Army Corps 

13 of Engineers (USACE), which could require additional mitigation or BMPs to minimize impacts 

14 on surface-water quality. In addition, other Federal, State, or local permits may require or 

15 suggest BMPs, and the licensee would likely implement BMPs to minimize erosion and 

16 sedimentation and control any runoff, spills, or leaks (NRC 2003a, 2005).

17 In the Decommissioning GEIS for power reactors (including spent fuel pools), the NRC (2002) 

18 determined that there would be minimal impact on surface-water resources and concluded that 

19 decommissioning nuclear power plants would result in SMALL impacts on surface-water 

20 resources. NRC’s EAs for the Calvert Cliffs, Humboldt Bay, and Diablo Canyon ISFSIs, and the 

21 PFSF ISFSI EIS did not identify any significant impacts on surface-water resources during 

22 decommissioning of an at-reactor, or away-from-reactor ISFSI (NRC 2003b, 2005, 2001a, 

23 2012c). The NRC assumes that the types and magnitude of impacts from decommissioning an 

24 ISFSI at other sites would be similar to those described in the Calvert Cliffs, Humboldt Bay, and 

25 Diablo Canyon EAs and the PFSF EIS due to the limited amount of water required for 

26 decommissioning and minimal impacts from ground-disturbing activities. Given that the impacts 

27 from decommissioning reactors, spent fuel pools, and ISFSIs would be similar to those 

28 described in the Decommissioning GEIS for reactors and site-specific ISFSI EAs and EIS, 

29 impacts on surface-water resources from decommissioning are not expected to be noticeable.

30 6.4.7.3 Conclusion

31 Cumulative impacts on surface-water resources include the incremental effects from continued 

32 storage when added to the aggregate effects of other past, present, and reasonably foreseeable 

33 future actions. As described in Sections 4.7 and 5.7, the incremental impacts from continued 

34 storage on surface-water resources is SMALL for all timeframes at at-reactor and away-from35 reactor storage facilities. In addition, past, present, and reasonably foreseeable activities take 

36 place in the geographic area of interest that could contribute to cumulative effects on surface37 water resources. The cumulative impacts from continued storage when added to other past, 

38 present, and reasonably foreseeable Federal and non-federal activities, such as urbanization, 
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Draft NUREG‒2157 6-28 September 2013

1 energy development, operation of other nearby power plants, or other water uses, would be 

2 SMALL to LARGE depending on the conditions and activities surrounding the site. A SMALL 

3 impact would occur if no other actions occur that have overlapping, noticeable effects on 

4 surface water. A MODERATE impact would occur if other Federal or non-federal actions, such 

5 as operation of other nearby power plants or future urbanization, had overlapping impacts with 

6 the continued storage of waste that noticeably altered availability, flow patterns, and quality of 

7 surface water. A LARGE impact would occur if other Federal or non-federal actions had 

8 overlapping impacts with the continued storage of waste that destabilized surface-water 

9 resources by permanently diminishing water quantity and water quality, or adversely altering 

10 flow patterns in surface-waterbodies. At storage facilities where the cumulative impacts would 

11 be MODERATE or LARGE from other Federal or non-federal activities, the NRC determined 

12 that the cumulative impacts would likely remain MODERATE or LARGE whether or not 

13 continued storage occurred because the incremental impacts from continued storage would be 

14 minor, especially in comparison to other general trends, such as climate change.

15 6.4.8 Groundwater Quality and Use

16 This section evaluates the effects of continued storage on groundwater when added to the 

17 aggregate effects of other past, present, and reasonably foreseeable future actions. As 

18 described in Sections 4.8 and 5.8, the incremental impacts from continued storage on 

19 groundwater resources is SMALL for all timeframes at both at-reactor and away-from-reactor 

20 storage facilities.

21 The geographic area considered in the cumulative groundwater resources analysis includes the 

22 portion of the uppermost aquifer and offsite public groundwater wells potentially affected by the 

23 at-reactor or away-from-reactor storage facility.

24 6.4.8.1 Potential Cumulative Impacts from General Trends and Activities

25 For at-reactor storage facilities, two types of cumulative impacts on groundwater include: 

26 (1) consumptive water use at an individual power plant over time (e.g., groundwater use for the 

27 power plant’s potable and reactor water makeup needs) and (2) groundwater quality 

28 degradation beneath the individual power plant due to spills and leaks (NRC 2013a). For both 

29 at-reactor and away-from-reactor storage facilities, cumulative impacts on groundwater could 

30 occur from groundwater demands associated with current and planned urban, commercial, and 

31 agricultural developments outside the storage facility site and groundwater quality degradation 

32 at the site due to past and present offsite activities. In addition, climate change and alterations 

33 in surface topography and watershed use due to new developments can affect groundwater 

34 levels and water levels in nearby surface-waterbodies (e.g., lakes and rivers). These 

35 modifications could lead to changes in groundwater flow rates and reversal in groundwater flow 

36 directions at or near the site. For example, groundwater withdrawals at coastal sites could lead 

37 to saltwater intrusion. Moreover, intense use of groundwater outside the site for residential, 
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September 2013 6-29 Draft NUREG‒2157

1 industrial, or agricultural uses may cause land subsidence with temporary or permanent 

2 changes in local or regional groundwater hydrology.

3 The magnitude of cumulative impacts resulting from all actions taking place within the affected 

4 groundwater beneath and surrounding the storage facility would depend on the number of 

5 actions (facilities or projects) that draw water from the aquifer, the overall demand on the 

6 aquifer, the hydrogeologic characteristics of the aquifer, and whether facilities follow BMPs to 

7 protect groundwater resources from degradation and overpumping. The cumulative impacts 

8 from general trends and activities would range from minimal (e.g., past and ongoing onsite and 

9 offsite activities do not cause noticeable impacts on the quality and quantity of groundwater 

10 resources, see NRC 2005d) to noticeable (e.g., past and ongoing onsite and offsite activities do 

11 not destabilize, but noticeably alter the quality or quantity of groundwater resources, see NRC 

12 2011g). In rare situations, the cumulative impacts from general trends and activities could be 

13 destabilizing (e.g., groundwater beneath the site and adjacent areas has been adversely 

14 affected and noticeably destabilized by past and ongoing onsite and offsite activities, see NRC 

15 2012d).

16 6.4.8.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

17 Activities

18 Cumulative impacts on groundwater resources could result from other NRC-regulated or spent 

19 fuel-related activities, such as ground-disturbing activities that could occur during shut down 

20 activities; preparation activities for transportation of waste to a repository; as well as during 

21 decommissioning of the reactor, spent fuel pool, and ISFSI. Direct impacts could result from 

22 activities such as removal of shoreline, active dredging, or filling of a stream or bay. Indirect 

23 impacts may result from effects such as downward infiltration or seepage of contaminated 

24 surface water, oil, or other fluids from disturbed ground surface or streams into underlying 

25 groundwater; or from inadvertent changes in horizontal hydraulic gradients from the site to the 

26 nearest surface waterbody. These types of impacts could alter groundwater quality and flow 

27 rates, reverse groundwater flow directions, and induce saltwater intrusion at sites near the 

28 ocean. In most cases, however, groundwater disturbances would result in relatively minor 

29 impacts (NRC 2002). Water demand for power plant operational cooling would decrease during 

30 final power reactor shutdown activities and decommissioning. NPDES permitting for surface 

31 discharges would minimize potential indirect contamination of underlying groundwater systems. 

32 Dredging or filling of waterbodies would require permits from the USACE, which could require 

33 additional mitigation or BMPs to minimize inadvertent changes in site hydrogeology and the 

34 potential for seawater intrusion at a site near the ocean.

35 In the Decommissioning GEIS for nuclear power reactors (including spent fuel pools), the NRC 

36 (2002) determined that there would be minimal impact on groundwater use and quality and 

37 concluded that decommissioning nuclear power plants would result in SMALL impacts on 

38 groundwater. NRC’s EAs and EISs for the Calvert Cliffs, Humboldt Bay, and Diablo Canyon 
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Draft NUREG‒2157 6-30 September 2013

1 ISFSIs, and the PFSF ISFSI EIS did not identify any significant impacts on groundwater 

2 resources during decommissioning of an at-reactor, or away-from-reactor ISFSI (NRC 2001a, 

3 2003a, 2005c, 2012c). The NRC assumes that the types and magnitude of impacts from 

4 decommissioning an ISFSI at other sites would be similar to those described in the Calvert 

5 Cliffs, Humboldt Bay, and Diablo Canyon EAs and the PFSF EIS because a similar amount of 

6 water use is expected. Given that the impacts from decommissioning reactors, spent fuel pools, 

7 and ISFSIs would be similar to those described in the Decommissioning GEIS for reactors and 

8 site-specific ISFSI EAs and EIS, impacts on groundwater from decommissioning are expected 

9 to be SMALL.

10 6.4.8.3 Conclusion

11 Cumulative impacts on groundwater resources include the incremental effects from continued 

12 storage when added to the aggregate effects of other past, present, and reasonably foreseeable 

13 future actions. As described in Sections 4.8 and 5.8, the incremental impacts from continued 

14 storage on groundwater resources is SMALL for all timeframes at both at-reactor and away15 from-reactor storage facilities. In addition, past, present, and reasonably foreseeable activities 

16 take place in the geographic area of interest that could contribute to cumulative effects to 

17 groundwater. The cumulative impacts from continued storage when added to other past, 

18 present, and reasonably foreseeable Federal and non-federal activities; such as urbanization, 

19 energy development, landfills, agricultural, industrial, or other water users; range from SMALL to 

20 LARGE depending on the conditions and activities surrounding the site. A SMALL impact would 

21 occur if continued storage and no other actions occur that have overlapping, noticeable effects 

22 on groundwater. A MODERATE impact would occur if other Federal or non-federal actions, 

23 such as operation of other nearby power plants or future urbanization, had overlapping impacts 

24 with the continued storage of waste that noticeably altered groundwater quality and/or with the 

25 continued withdrawals of groundwater that may adversely impact site groundwater hydrology. 

26 A LARGE impact would occur if elevated radionuclide concentrations in groundwater from past 

27 and ongoing onsite and offsite activities or significant changes in groundwater hydrology at or 

28 near the site (e.g., altered hydraulic interactions between underlying shallow and confined 

29 aquifers; groundwater flow reversal, which may lead to saltwater intrusion at a site near the 

30 ocean) occur that would destabilize quality and quantity of groundwater resources. At storage 

31 facilities where the cumulative impacts would be MODERATE or LARGE from other Federal or 

32 non-federal activities, the NRC determined that the cumulative impacts would likely remain 

33 MODERATE or LARGE whether or not continued storage occurred because the incremental 

34 impacts from continued storage would be minor, especially in comparison to other general 

35 trends, such as climate change.

36 6.4.9 Terrestrial Resources

37 This section evaluates the effects of continued storage on terrestrial resources, including 

38 terrestrial special status species and habitats, when added to the aggregate effects of other 
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September 2013 6-31 Draft NUREG‒2157

1 past, present, and reasonably foreseeable future actions. As described in Section 4.9, the 

2 incremental impacts from continued storage on terrestrial resources is SMALL for at-reactor 

3 storage facilities during all timeframes. As described in Section 5.9, the incremental impacts at 

4 away-from-reactor storage facilities during the short-term timeframe would be SMALL to 

5 MODERATE, depending on whether construction activities noticeably alter suitable habitat for 

6 local terrestrial species. During the long-term and indefinite storage timeframes, the impacts at 

7 away-from-reactor storage facilities would be SMALL.

8 The geographic area considered includes terrestrial habitats on or adjacent to the at-reactor or 

9 away-from-reactor storage facility site affected by continued storage as well as other terrestrial 

10 habitats in the surrounding landscape closely interconnected by movement or migration of 

11 species. In addition, terrestrial ecology evaluations focus on the habitats and species, both 

12 plants and animals, within an ecosystem.

13 6.4.9.1 Potential Cumulative Impacts from General Trends and Activities

14 Cumulative impacts on terrestrial habitats and wildlife may occur because of habitat loss and 

15 degradation, disturbance and displacement, injury and mortality, and obstruction of movement 

16 (e.g., NRC 2011a–f, 2012a, 2013a,b). Factors that could influence impacts on terrestrial 

17 resources include exposure to elevated noise levels and contaminants, altered surface-water

18 and groundwater quality and flow patterns, and hazards associated with direct contact with 

19 physical structures (e.g., bird collisions with buildings and other structures). Adverse impacts 

20 typically result from activities (e.g., construction) associated with urbanization, industrial and 

21 commercial development, agricultural development, transportation development, water projects, 

22 and regional tourism and recreation. Migratory and mobile species may be affected by activities 

23 carried out in locations remote from the storage facility site. Vegetative communities (including 

24 floodplain and wetland communities) also may be affected by activities (e.g., clearing and 

25 grading) associated with these actions, thus creating conditions favorable for invasive species to 

26 establish in the area.

27 Climate change may add to the cumulative impact on terrestrial species and habitats (e.g., NRC 

28 2011a–f, 2012a, 2013a,b). Climate models project that there will tend to be less rainfall in some 

29 areas in the United States and that the precipitation could possibly alter the character of 

30 terrestrial habitats (GCRP 2009). This could further stress terrestrial resources affected by the 

31 activities described above. For example, reduced precipitation could contribute to drawdowns in 

32 some cooling-water sources and contribute to impacts on shoreline habitats of those systems. 

33 Certain areas might experience increased, instead of decreased, precipitation. In these areas, 

34 increased precipitation and sea-level rise could inundate low-lying areas at coastal facilities 

35 (e.g., NRC 2011d). Storm frequency and intensity also could increase, and temperatures could 

36 vary. The position of ecoregions can be expected to shift in response to these changes, and 

37 terrestrial ecosystems can be expected to experience gradual transitions that will stress species 

38 and habitats (GCRP 2009). Similarly, species ranges may shift in accordance with the changing 
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Draft NUREG‒2157 6-32 September 2013

1 environmental conditions and habitats (GCRP 2009). During continued storage, a shift in 

2 species ranges could result in a storage facility affecting certain species that were not present 

3 prior to continued operation. If the species is protected under the Endangered Species Act of 

4 1973, as amended (ESA), the NRC would be required to initiate a ESA Section 7 consultation 

5 with the U.S. Fish and Wildlife Service (FWS) or National Marine Fisheries Service (NMFS). As 

6 described in Section 4.11, the NRC would evaluate any potential impacts on those species and 

7 FWS or NMFS may require mitigation to minimize impacts on those species.

8 The magnitude of cumulative impacts resulting from all general trends taking place within the 

9 region in which a storage facility is located would depend on the nature and location of the 

10 actions relative to important terrestrial resources, the number (and density) of actions, and the 

11 extent to which these actions (facilities or projects) employ mitigation measures to minimize 

12 such impacts. The cumulative impacts from general trends and activities would range from 

13 minimal (e.g., temporary and minor changes to terrestrial habitat from limited development in 

14 the area, see NRC 2011b) to noticeable (e.g., noticeable wetland loss and fragmentation of 

15 wetland and upland forest habitats, see NRC 2012a).

16 6.4.9.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

17 Activities

18 Cumulative impacts on terrestrial resources could result from other NRC-regulated or spent fuel19 related activities, such as ground-disturbing activities that could occur during shutdown 

20 activities; preparation activities to transportation waste to a repository; and decommissioning of 

21 the reactor, spent fuel pool, and ISFSI. For example, incremental impacts could result from 

22 shoreline activities (dredging or filling of wetlands), operation of the cooling system on shoreline 

23 vegetation (water withdrawal and discharge water temperature increases), and habitat 

24 disturbance and fragmentation from development or removal of infrastructure and power 

25 transmission-line and cooling-water pipeline rights-of-ways to support future projects.

26 Incremental impacts from continued storage may result from effects such as runoff because of 

27 ground-disturbing activities and surface erosion. To help protect terrestrial habitats, stormwater

28 control measures, which would be required to comply with NPDES permitting, would minimize 

29 erosion and the flow of disturbed soils or other contaminants into terrestrial habitats. Some 

30 activities would require permits from the USACE, which would require mitigation for impacts on

31 jurisdictional wetlands. Consultation with the FWS and other Federal, State, or local groups 

32 could result in the identification of additional mitigation or BMPs to minimize impacts on

33 terrestrial resources from noise, dust, migratory bird collisions with crane booms or other 

34 construction equipment, and habitat alteration from introduction of invasive plant species. In 

35 most cases, terrestrial disturbances would result in relatively minor, short-term impacts (e.g., 

36 NRC 2006, 2011e).
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September 2013 6-33 Draft NUREG‒2157

1 In the Decommissioning GEIS for power reactors (including spent fuel pools), NRC (2002) 

2 determined that terrestrial resources resulting from activities occurring within the facility’s 

3 operational areas would be SMALL. The NRC’s EAs for the Calvert Cliffs (NRC 2012c), 

4 Humboldt Bay (NRC 2005c), and Diablo Canyon ISFSIs (NRC 2003a), and the PFSF ISFSI EIS 

5 (NRC 2001a) did not identify any significant impacts on terrestrial resources during 

6 decommissioning of an at-reactor or away-from-reactor ISFSI. The NRC assumes that the 

7 types and magnitude of impacts from decommissioning an ISFSI at other sites would be similar 

8 to that described in the Calvert Cliffs, Humboldt Bay, and Diablo Canyon EAs and the PFSF EIS 

9 because of the limited size and minimal impacts from ground-disturbing activities. Therefore, 

10 impacts from decommissioning would likely result in relatively short-term impacts and, most of 

11 the time, within previously disturbed areas. Given that the impacts from decommissioning 

12 reactors, spent fuel pools, and ISFSIs would be similar to impacts described in the 

13 Decommissioning GEIS for reactors and site-specific ISFSI EAs and EIS, impacts on terrestrial 

14 resources from decommissioning is expected to be minimal.

15 6.4.9.3 Conclusion

16 Cumulative impacts on terrestrial resources include the incremental effects from continued 

17 storage when added to the aggregate effects of other past, present, and reasonably foreseeable 

18 future actions. As described in Section 4.9, the incremental impacts from continued storage on 

19 terrestrial resources is SMALL for at-reactor storage facilities during all timeframes. As 

20 described in Section 5.9, the incremental impacts at away-from-reactor storage facilities during 

21 the short-term timeframe would be SMALL to MODERATE, depending on whether construction 

22 activities noticeably alter suitable habitat for local terrestrial species. During the long-term and 

23 indefinite storage timeframes, the impacts at away-from-reactor storage facilities would be 

24 SMALL. In addition, past, present, and reasonably foreseeable activities that take place in the 

25 geographic area of interest could contribute to cumulative effects to terrestrial resources. The 

26 cumulative impacts from continued storage when added to other past, present, and reasonably 

27 foreseeable Federal and non-federal activities, such as urbanization and energy development,

28 range from SMALL to MODERATE depending on the conditions and activities surrounding the 

29 site. At sites where continued storage has minimal impacts on terrestrial resources and no 

30 other actions occur that have overlapping, noticeable effects on terrestrial resources, the 

31 cumulative impacts can be expected to be SMALL. At sites where construction of an away32 from-reactor storage facility has noticeably altered terrestrial resources, or other actions have 

33 overlapping, noticeable effects on terrestrial resources, the cumulative impacts can be expected 

34 to be MODERATE. For example, in more urbanized areas where certain habitats are limited, 

35 MODERATE cumulative impacts may be possible if other Federal or non-federal actions, such 

36 as operation of other nearby power plants or future urbanization, had overlapping impacts with 

37 the continued storage of waste that noticeably altered terrestrial resources. For at-reactor 

38 storage facilities where the cumulative impacts would be MODERATE from other Federal or 

39 non-federal activities, the NRC determined that the cumulative impacts would likely remain 
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Draft NUREG‒2157 6-34 September 2013

1 MODERATE whether or not continued storage occurred because the incremental impacts from 

2 an at-reactor continued storage facility would be minor, especially in comparison to other 

3 general trends, such as climate change or urbanization.

4 6.4.10 Aquatic Ecology

5 This section evaluates the effects of continued storage on aquatic resources, including aquatic 

6 special status species, when added to the aggregate effects of other past, present, and 

7 reasonably foreseeable future actions. As described in Sections 4.10 and 5.10, the incremental 

8 impacts from continued storage on aquatic resources is SMALL for all timeframes at both 

9 at-reactor and away-from-reactor storage facilities.

10 The geographic area considered in this analysis includes affected aquatic habitats on or 

11 adjacent to the at-reactor or away-from-reactor storage facility site as well as other aquatic 

12 habitats in the surrounding landscape closely interconnected by movement or migration of 

13 species using affected habitats. Depending on the site, this could include the potentially 

14 affected portion of streams, rivers, ponds, lakes, estuaries, or nearshore habitats of marine 

15 waters.

16 6.4.10.1 Potential Cumulative Impacts from General Trends and Activities 

17 Cumulative impacts on aquatic habitats and species can include (1) loss and degradation of 

18 habitat; (2) species disturbance, displacement, injury, and mortality; (3) obstruction of 

19 movement; and (4) introduction and spread of invasive species (e.g., NRC 2011a–f, 2012a, 

20 2013a,b). These impacts result from many general trends identified in Table 6-1, such as 

21 industrial, commercial, agricultural, and transportation development; increased water use and 

22 discharges to natural waterbodies from power plant operations (including potential replacement 

23 power); habitat modification associated with urbanization and water development projects; 

24 commercial and recreational fishing; and regional tourism and recreation. For aquatic resources 

25 near at-reactor storage facilities, additional cumulative impacts may include impacts from an 

26 individual power plant over time (e.g., entrainment, impingement, thermal discharges, and 

27 chemical discharges from the power plant), (2) the cumulative impacts due to closely sited 

28 power plants (e.g., the additive effects of entrainment, impingement, thermal discharges, and 

29 chemical discharges from all nearby power plants), and (3) cumulative impacts due to multiple 

30 general trends that affect the same waterbody at the reactor (e.g., dams, agriculture, urban, and 

31 industrial development) (NRC 2013a).

32 Climate change may add to the cumulative impact on aquatic species and habitats (e.g., NRC 

33 2011a–f, 2012a, 2013a,b). Changes to aquatic habitats could result from increased runoff, 

34 increased surface-water temperature, increased storm intensity and frequency, sea-level rise, 

35 ocean acidification, and other biological stressors (GCRP 2009). The position of ecoregions 

36 can be expected to shift in response to these changes, and marine ecosystems can be 
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September 2013 6-35 Draft NUREG‒2157

1 expected to experience gradual transitions stressing species and habitats. Similarly, species 

2 ranges may shift in correspondence to the changing environmental conditions and habitats 

3 (GCRP 2009). During continued storage, a shift in species ranges could result in a storage 

4 facility affecting certain species that were not present prior to continued operation. If the 

5 species is protected under the ESA, the NRC would be required to initiate an ESA Section 7 

6 consultation with the FWS or NMFS. As described in Section 4.11, the NRC would evaluate 

7 any potential impacts on those species, and the FWS or NMFS may require mitigation to 

8 minimize impacts on those species.

9 The magnitude of cumulative impacts resulting from all general trends taking place within the 

10 region in which a storage facility is located would depend on the nature and location of the 

11 actions relative to important waterbodies, the number (and density) of actions, and the extent to 

12 which these actions (facilities or projects) employ mitigation measures to minimize such 

13 impacts. The cumulative impacts from general trends and activities would range from minimal 

14 (e.g., temporary and minor changes to aquatic habitat from limited development in the area, see 

15 NRC 2011c) to noticeable (e.g., past power plant operations resulting in a noticeable decline for 

16 certain fish species, see NRC 2012a). In rare situations, the cumulative impacts from general 

17 trends and activities could be destabilizing (e.g., if cold-water fish species significantly decline in 

18 population as a result of simultaneously being subjected to impingement and entrainment, 

19 intense commercial fishing efforts, and warmer waters from climate change, see NRC 2011h).

20 6.4.10.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

21 Activities

22 Cumulative impacts on aquatic resources could result from other NRC-regulated or spent fuel23 related activities, such as shutdown activities; preparing waste for transportation to a repository; 

24 and decommissioning of the reactor power block (including the spent fuel pool), ISFSIs, and 

25 DTS. Ground-disturbing activities could include the removal of shoreline or in-water structures

26 or the active dredging or filling of a stream or bay, which could result in increased runoff and 

27 surface erosion. In most cases, impacts on aquatic resources would be minor and short-term. 

28 Aquatic habitats would be protected by stormwater control measures, which would minimize the 

29 flow of disturbed soils or other contaminants into aquatic features. These measures would be 

30 required to comply the NPDES permits. Dredging or filling of waterbodies would require permits 

31 from the USACE, which could require additional mitigation or BMPs to minimize impacts on

32 aquatic resources. In addition, other Federal, State, or local permits may require or suggest 

33 BMPs that the licensee would likely implement to minimize erosion and sedimentation and 

34 control any runoff, spills, or leaks (e.g., NRC 2003a, 2005c).

35 Shutdown activities could alter aquatic habitats as the amount of thermal discharge decreases 

36 or ceases entirely. For example, some aquatic organisms, such as manatees, congregate and 

37 overwinter in waters that are warmer than the surrounding water because of thermal discharge 

38 from the plant. Other organisms, such as sea turtles or fish, could experience cold shock 
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Draft NUREG‒2157 6-36 September 2013

1 because of the change in temperature. Some of these species are protected under the ESA. 

2 As described in Section 4.11, if the FWS or NMFS writes a biological opinion for a power plant, 

3 the NRC would be required to consult with the FWS or NMFS if there was a change in plant 

4 parameters, such as reduced thermal discharge. Consultation under the ESA would include an 

5 assessment and potential mitigation factors to offset cold shock or other potential impacts on

6 listed species. In addition, operation of the spent fuel pool would reduce this impact because 

7 some thermal discharge would be expected during spent fuel pool operations, as described in 

8 Section 4.10.

9 In the Decommissioning GEIS for power reactors (including spent fuel pools), the NRC (2002) 

10 determined that there would be minimal impact on aquatic resources and concluded that 

11 decommissioning nuclear power plants would result in SMALL impacts on aquatic resources. 

12 The NRC’s EAs for the Calvert Cliffs, Humboldt Bay, and Diablo Canyon ISFSIs, and the PFSF

13 ISFSI EIS did not identify any significant impacts on aquatic resources during decommissioning 

14 of an at-reactor or away-from-reactor ISFSI (NRC 2001a, 2003a, 2005c, 2012c). The NRC 

15 assumes that the types and magnitude of impacts from decommissioning an ISFSI at other sites 

16 would be similar to that described in the previous EAs and EIS because of the limited amount of 

17 water required for decommissioning and minimal impacts from ground-disturbing activities. 

18 Given that the impacts from decommissioning reactors, spent fuel pools, and ISFSIs would be 

19 similar to that described in the Decommissioning GEIS for reactors and site-specific ISFSI EAs 

20 and EISs, impacts on aquatic resources from decommissioning is expected to be minimal.

21 6.4.10.3 Conclusion

22 Cumulative impacts on aquatic resources include the incremental effects from continued 

23 storage when added to the aggregate effects of other past, present, and reasonably foreseeable 

24 future actions. As described in Sections 4.7 and 5.7, the incremental impacts from continued 

25 storage on aquatic resource is SMALL for all timeframes at both at-reactor and away-from26 reactor storage facilities. In addition, past, present, and reasonably foreseeable activities take 

27 place in the geographic area of interest that could contribute to cumulative effects on aquatic 

28 resources. The cumulative impacts from past, present, and reasonably foreseeable Federal 

29 and non-federal activities; such as urbanization, energy development, or other water users; 

30 would range from SMALL to LARGE depending on the conditions and activities surrounding the 

31 site. At sites where the surrounding development has been limited and no other actions occur 

32 that have overlapping, noticeable effects on aquatic resources, the cumulative impacts can be 

33 expected to be SMALL. MODERATE cumulative impacts could occur if other Federal or non34 federal actions, such as operation of other nearby power plants or future urbanization, had 

35 overlapping impacts with the continued storage of waste that noticeably altered aquatic 

36 resources. LARGE impacts are not as likely but could occur under exceptional circumstances 

37 such as if other Federal or non-federal actions, such as intense fishing pressure or changes in 

38 aquatic habitats from climate change, had overlapping impacts with the continued storage of 
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September 2013 6-37 Draft NUREG‒2157

1 waste that destabilized aquatic resources. At storage facilities where the cumulative impacts 

2 would be MODERATE or LARGE from other Federal or non-federal activities, the NRC 

3 determined that the cumulative impacts would likely remain MODERATE or LARGE whether or 

4 not continued storage occurred because the incremental impacts from continued storage would 

5 be minor, especially in comparison to other general trends, such as climate change or fishing.

6 6.4.11 Historic and Cultural Resources

7 This section evaluates the effects of continued storage on historic and cultural resources when 

8 added to the aggregate effects of other past, present, and reasonably foreseeable future 

9 actions. As described in Sections 4.12 and 5.12, the incremental impacts from continued 

10 storage on historic and cultural resources would be SMALL (no impacts on historic and cultural 

11 resources) during short-term storage for at-reactor ISFSIs. During short-term for away-from 

12 reactor ISFSIs and during long-term and indefinite storage timeframes at away-from-reactor and 

13 at-reactor ISFSIs, the impacts could range from SMALL, MODERATE, or LARGE (impacts 

14 could range from no adverse effects to historic properties/no impacts on historic and cultural 

15 resources to adverse effects to historic properties/impacts on historic and cultural resources). 

16 The actual incremental impacts from continued storage depend on site-specific conditions, as 

17 described in Sections 4.12 and 5.12.

18 The geographic area considered in the cumulative historic and cultural resources analysis 

19 includes the area of potential effect that may be affected by land-disturbing or other operational 

20 activities associated with continued storage of spent fuel, including the viewshed. This 

21 determination is made irrespective of land ownership or control. Cumulative impacts on historic 

22 and cultural resources relate to the damage or destruction of these resources (i.e., 

23 archaeological sites, historic structures, and traditional cultural properties, or their context). 

24 Adverse effects to historic properties or historic and cultural resources (e.g., archaeological sites 

25 or historic structures) would occur if these resources in the area of potential effect are physically 

26 removed or disturbed. In this regard, potential cumulative impacts for this resource area are 

27 localized and limited to the area of physical disturbance. Adverse visual effects could occur if 

28 an undertaking results in the introduction of significant visual intrusions within the viewshed. 

29 Historic and cultural resources are nonrenewable resources that are affected by natural and 

30 man-made actions. Once these resources are removed or destroyed, they cannot be restored, 

31 rebuilt, or repaired; therefore, the impact of destruction of historic and cultural resources is a 

32 cumulative impact.

33 6.4.11.1 Potential Cumulative Impacts from General Trends and Activities

34 Cumulative impacts on historic and cultural resources typically result from ground-disturbing 

35 activities (e.g., earthmoving, blasting, grading, and excavation) within the area of potential effect 

36 and are site-specific. Impacts could occur from activities associated with new energy projects 

37 (e.g., replacement power facilities) or potential industrial, commercial, agricultural, and 
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Draft NUREG‒2157 6-38 September 2013

1 transportation if development occurs within the area of potential effect (NRC 2013). For 

2 example, if a new energy project is co-located with the existing at-reactor or away-from-reactor 

3 ISFSI, there could be adverse impacts on historic properties or historic and cultural resources 

4 associated with the construction and operation of the new facility. Such activities may directly 

5 damage or destroy cultural artifacts or increase the potential for their exposure by accelerating 

6 erosion, leaving them vulnerable to theft and vandalism.

7 The magnitude of cumulative impacts resulting from general trends taking place within and 

8 surrounding the area of potential effect would depend on the nature and location of the actions 

9 (facilities or projects), what resources are present, the extent of land disturbance, whether 

10 cultural resource surveys are conducted, and the extent to which these actions employ 

11 mitigation measures. Additionally, only Federal undertakings require compliance with the 

12 National Historic Preservation Act (NHPA) Section 106 procedural requirements. However, 

13 some States have similar Section 106 procedural or environmental review requirements. 

14 Cumulative impacts would range from minimal (e.g., no impacts on historic and cultural 

15 resources/no historic properties affected, see NRC 2011h) to noticeable (e.g., construction and 

16 operation of a new coal-fired power plant or new transmission lines would result in a noticeable 

17 impact on historic and cultural resources/adverse effects to historic properties, see NRC 2011c), 

18 to destabilizing (e.g., impacts on historic and cultural resources/adverse effects to three National 

19 Register listed/eligible historic properties including two historic buildings/structures—Baltimore & 

20 Drum Point Railroad [CT–1259]—and Camp Conoy [CT–1312] and one archaeological site 

21 [18CV474] that may be the remnants of a residence associated with the lives of slaves and/or 

22 tenants, sharecroppers, or freed African Americans, see NRC 2011d).

23 6.4.11.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

24 Activities

25 Cumulative impacts on historic and cultural resources could result from other NRC-regulated or 

26 spent fuel-related activities, such as decommissioning of the reactor power block (including the 

27 spent fuel pool), ISFSI, and DTS.

28 The environmental impacts associated with reactor decommissioning were assessed in the 

29 Decommissioning GEIS (NRC 2002). Activities associated with decommissioning of the reactor 

30 power block (including the spent fuel pool) that could affect historic and cultural resources

31 include (1) addition and expansion of staging and laydown areas for equipment, (2) construction 

32 of temporary buildings and parking areas, (3) stabilization, (4) decontamination and 

33 dismantlement, and (5) removal of large reactor components (NRC 2002, 2013a). These 

34 activities could affect cultural resources primarily via land disturbance, which could damage or 

35 destroy the resource, or alter the contextual setting of historic and cultural resources (NRC 

36 2002). Decommissioning activities conducted within the operational areas (i.e., the power 

37 block) are not expected to affect historic and cultural resources because much of the land within 

38 and immediately surrounding the power block was extensively disturbed during initial nuclear 
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September 2013 6-39 Draft NUREG‒2157

1 power plant construction. Therefore, if ground-disturbing activities are limited to operational 

2 areas, impacts on historic and cultural resources would be SMALL (NRC 2002). Should 

3 ground-disturbing activities occur outside of power block, some impacts could be noticeable or 

4 destabilizing; there could be adverse effects to historic properties and impacts on other historic 

5 and cultural resources (NRC 2002). Prior to ground-disturbing activities commencing in areas 

6 outside the power block area, cultural resource surveys should be conducted to identify and 

7 protect any historic properties and other historic and cultural resources (i.e., adherence to 

8 management plans and procedures).

9 Activities associated with decommissioning of ISFSIs include dismantling and removing the 

10 concrete storage casks, concrete pads, and support facilities, including the DTS, and removing 

11 any contaminated soils identified during the final radiological site survey. A review of NRC EAs 

12 and EISs for specifically licensed at-reactor and away-from-reactor ISFSIs did not identify any 

13 significant impacts on historic and cultural resources during decommissioning (e.g., NRC 2001a, 

14 2003a, 2005a−c, 2009, 2012c). However, prior to decommissioning activities commencing, a 

15 final decommissioning plan must be submitted to the NRC for review and approval in 

16 accordance with 10 CFR 72.54(g)(1)−(6), 72.54(d), and 72.54(i). NRC authorization of a final 

17 decommissioning plan would constitute a Federal action under NEPA and would be an 

18 undertaking under the NHPA. The site-specific environmental review and compliance with the 

19 NHPA process could identify historic properties, adverse effects and potentially resolve adverse 

20 effects to historic properties and impacts on other historic and cultural resources. After 

21 decommissioning is completed, the area previously occupied by the at-reactor or away-from22 reactor ISFSI would typically be covered with topsoil, contoured, and replanted with native 

23 vegetation (NRC 2005a). Should ground-disturbing activities occur outside of ISFSI footprint, 

24 some impacts could be noticeable or destabilizing. The magnitude of impact largely depends 

25 on what resources are present, the extent of proposed land disturbance, if the area has been 

26 previously surveyed, and if the licensee has management plans and procedures that are 

27 protective of historic and cultural resources.

28 6.4.11.3 Conclusion

29 Cumulative impacts on historic and cultural resources include the incremental effects from 

30 continued storage when added to the aggregate effects of other past, present, and reasonably 

31 foreseeable future actions. As described in Sections 4.12 and 5.12, the incremental impacts 

32 from continued storage on historic and cultural resources would be SMALL (no impacts on 

33 historic and cultural resources) for the short-term timeframe for an at-reactor ISFSI. During the 

34 short-term for away-from-reactor ISFSIs and during long-term and indefinite storage timeframes 

35 at away-from-reactor and at-reactor ISFSIs, the impacts could range from SMALL, MODERATE, 

36 or LARGE (impacts could range from no adverse effects on historic properties/no impacts on

37 historic and cultural resources to adverse effects on historic properties/impacts on historic and 

38 cultural resources) depending on site-specific factors. In addition, past, present, and reasonably 
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Draft NUREG‒2157 6-40 September 2013

1 foreseeable activities take place in the area of potential effect that could also contribute to 

2 cumulative effects to historic and cultural resources. The cumulative impacts on historic and 

3 cultural resources from continued storage when added to other past, present, and reasonably 

4 foreseeable Federal and non-federal activities are SMALL, MODERATE, or LARGE (impacts 

5 could range from no adverse effects on historic properties/no impacts on historic and cultural 

6 resources to adverse effects on historic properties/impacts on historic and cultural resources) 

7 depending on site-specific factors, which could include resources that are present, the extent of 

8 proposed land disturbance, previous surveys, and management plans and procedures that are 

9 protective of historic and cultural resources. The effect of the actions would be a SMALL impact 

10 (no impacts on historic and cultural resources or no adverse impact on historic properties) at 

11 sites where continued storage and no other actions occur that have overlapping, noticeable 

12 effects on historic and cultural resources within the area of potential effect. MODERATE to 

13 LARGE impacts (impacts on historic and cultural resources or adverse impacts on historic 

14 properties) could occur at sites where NRC, or other Federal or non-federal actions (such as 

15 new energy projects and other forms of potential development within and surrounding the area 

16 of potential effect), have overlapping impacts with the continued storage of waste that noticeably 

17 affect or destabilize historic and cultural resources.

18 6.4.12 Noise

19 This section evaluates the effects of continued storage on noise when added to the aggregate 

20 effects of other past, present, and reasonably foreseeable future actions. As described in 

21 Sections 4.13 and 5.13, the incremental impacts from continued storage on noise is SMALL

22 overall for all timeframes for both at-reactor and away-from-reactor storage facilities.

23 The geographic area considered in the cumulative noise analysis extends in a radius of about 

24 7.8 km (4.8 mi) from the noise sources originating from an at-reactor or away-from-reactor 

25 storage facility site. At a distance of about 3.9 km (2.4 mi) from a noise source, most sound 

26 levels would be reduced to less than the 55-dB(A) EPA-recommended threshold for protection 

27 against outdoor activity interference and annoyance. A receptor can be affected by noise 

28 sources from the at-reactor and away-from-reactor ISFSIs up to about 3.9 km (2.4 mi) away. 

29 Therefore, the NRC considered other noise sources within a 3.9 km (2.4 mi) radius of the 

30 receptor for potential cumulative effects. This effectively creates a cumulative geographic area 

31 of interest within a 7.8 km (4.8 mi) radius from the spent fuel noise sources.

32 6.4.12.1 Potential Cumulative Impacts from General Trends and Activities

33 Noise levels in the vicinity of a storage facility could be the result of activities (e.g., traffic) 

34 associated with urban, industrial, and commercial development (including transportation 

35 development) and water projects (e.g., NRC 2011a–f, 2012a, 2013a,b). The magnitude 

36 of cumulative impacts resulting from all general trends would depend on the plant’s 

37 proximity to these activities. Because noise impacts cease once an activity stops, the 
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September 2013 6-41 Draft NUREG‒2157

1 noise would need to occur at the same time as continued storage in order for the 

2 impacts to be overlapping or cumulative.

3 The magnitude of cumulative impacts resulting from all general trends taking place within the 

4 cumulative geographic area of interest would (1) be dominated by the loudest audible source 

5 because noise does not add linearly and (2) depend on the sound level generated by the noise 

6 sources and the proximity of the receptor to the noise sources. The cumulative impacts from 

7 general trends and activities would range from minimal (e.g., the sound levels generated by the 

8 noise sources and proximity of these sources to receptors only produce minor impacts, see 

9 NRC 2011d), to noticeable (e.g., potential noise levels from cooling-water system pumps 

10 associated with the operation of co-located nuclear reactor units, see NRC 2011e). The NRC 

11 also acknowledges that the noise impacts from operation of a fossil-fuel power plant near a 

12 storage facility could result in noticeable impacts (e.g., delivery of coal and limestone by train, 

13 see NRC 2011e).

14 6.4.12.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

15 Activities

16 Cumulative noise impacts could result from other NRC-regulated or spent fuel-related activities, 

17 such as (1) decommissioning of the reactor power block (including the spent fuel pool), ISFSI, 

18 and DTS; (2) loading of casks for transportation to a repository; and (3) long-range 

19 transportation of spent fuel.

20 The primary noise source associated with decommissioning of the power reactor block is the 

21 use of construction equipment to dismantle and remove buildings and structures. The 

22 Decommissioning GEIS (NRC 2002) analyzed noise impacts for decommissioning a reactor 

23 (including the spent fuel pools) and determined that the noise impacts would not be noticeable 

24 enough to routinely disrupt human activity. However, this analysis was based on the 

25 implementation of some mitigation measures (e.g., restrictions on when noise producing

26 activities could be conducted). Unmitigated impacts, however, could be disruptive to human 

27 activity. Such mitigation measures may not be required by Federal regulations, but may be 

28 required by local ordinances. Given that the impacts from decommissioning reactors and spent 

29 fuel pools considered in this draft GEIS would be similar to that described in the 

30 Decommissioning GEIS, the impacts on at-reactor facilities during decommissioning are 

31 expected to be minimal.

32 The primary noise source associated with decommissioning of an ISFSI and DTS is the use of 

33 construction equipment to dismantle and remove concrete storage casks, concrete pads, and 

34 support facilities. Although ISFSI decommissioning was not addressed in the Decommissioning

35 GEIS, it was addressed in the PFSF EIS (NRC 2001a). The PFSF EIS concluded that the 

36 impacts overall were SMALL. However, the conclusion was based on the fact that the distance 

37 between the noise source and nearest resident was 3 km (2 mi) and the 95 dB(A) sound levels 
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Draft NUREG‒2157 6-42 September 2013

1 at the source would be reduced to ambient conditions at those distances. In a broader 

2 application for other locations, the distance between noise source and receptor is important 

3 when assessing whether the sound levels alter noticeably important attributes of the source.

4 The loading of cask for transportation to a repository would have similar noise sources, noise 

5 levels, and impact magnitude as the receiving of spent fuel at an away-from-reactor facility from 

6 at-reactor locations as described in Section 5.1.2. Therefore, close to the source, noise levels 

7 would exceed the 55 dB(A) EPA-recommended level for protection against outdoor activity and 

8 interference and annoyance. At distances greater than about 3.9 km (2.4 mi), the noise level of 

9 100 dB(A) at the source would be reduced to below this EPA-recommended protection level.

10 Disposal of spent fuel requires long-range transportation from the storage site to a repository. 

11 The at-reactor storage operation examines the impacts of a facility with a 1,600-MTU capacity, 

12 whereas the away-from-reactor storage operation examines the impacts of a facility with a 

13 40,000-MTU capacity. The Yucca Mountain EIS (DOE 2008) assessed the noise impacts at the 

14 national and state levels for long-range transport of 70,000 MTHM of spent fuel to the 

15 repository. The Yucca Mountain EIS concluded that the noise impacts would be small at the 

16 national level in comparison with the impacts of other nationwide transportation activities. At the 

17 state level, noise could be noticeable in situations where receptors were near transportation 

18 routes. Because the amount of spent fuel and the associated number of shipments (i.e., the 

19 frequency at which the source generates noise) considered in the transportation analyses for an 

20 at-reactor or away-from-reactor storage site is less than that considered in the Yucca Mountain 

21 analyses, the NRC concludes that the transportation noise impacts for an at-reactor or away22 from-reactor site would not be greater than the impact magnitude in the Yucca Mountain EIS.

23 6.4.12.3 Conclusion

24 Cumulative noise impacts include the incremental effects from continued storage when added to 

25 the aggregate effects of other past, present, and reasonably foreseeable future actions. As 

26 described in Sections 4.13 and 5.13, the incremental impacts from continued storage on noise 

27 is overall SMALL for all timeframes at both at-reactor and away-from-reactor storage facilities. 

28 In addition, past, present, and reasonably foreseeable activities take place in the geographic 

29 area of interest that that could contribute to cumulative effects to noise. The cumulative impacts 

30 from continued storage when added to other past, present, and reasonably foreseeable Federal 

31 and non-federal activities, such as activities from industrial and commercial development, are 

32 SMALL to MODERATE depending on the noise sources and proximity to receptors. In most 

33 cases, a SMALL cumulative impact would be expected and would occur if no other actions had 

34 overlapping, noticeable effects that altered important attributes of the noise. A MODERATE 

35 impact could occur if other actions occur that did have overlapping and noticeable impacts that 

36 altered important noise attributes such as operation of a nearby fossil-fuel-fired power plant. At 

37 storage facilities where the cumulative impacts would be MODERATE from other Federal or 

38 non-federal activities, the NRC determined that the cumulative impacts would likely remain 
Cumulative Impacts

September 2013 6-43 Draft NUREG‒2157

1 MODERATE whether or not continued storage occurred because the incremental impacts from 

2 continued storage would be minor, especially in comparison to other general trends, such as 

3 operation of a fossil-fuel-fired power plant.

4 6.4.13 Aesthetics

5 This section evaluates the effects of continued storage on aesthetic resources when added to 

6 the aggregate effects of other past, present, and reasonably foreseeable future actions. As 

7 described in Sections 4.14 and 5.14, the incremental impacts from continued storage on 

8 aesthetics is SMALL for all timeframes for an at-reactor storage facility, and SMALL to 

9 MODERATE for an away-from-reactor storage facility. The geographic area considered in the 

10 cumulative aesthetic resources analysis includes the area from which the at-reactor or away11 from-reactor storage facility is visible.

12 6.4.13.1 Potential Cumulative Impacts from General Trends and Activities

13 Cumulative impacts on aesthetic resources come from changes to the visual appeal of a tract of 

14 land. The magnitude of cumulative impacts on aesthetic resources depends on the degree to 

15 which the facility contrasts adversely with the existing landscape and is a function of the visibility 

16 of dry storage pads, canisters, and handling facilities from neighborhoods or roads, across 

17 waterbodies, or from higher topographic elevations. The visibility of at-reactor ISFSIs is 

18 generally lower than the nuclear power plant because of the lower profile of the storage facility. 

19 Cumulative impacts also depends in part on the degree of public interest and concern over 

20 potential changes to the existing scenic quality.

21 The continuation of general trends occurring at or near nuclear power plants and storage 

22 facilities could result in overlapping aesthetic impacts during continued storage. For example, 

23 the construction and operation of energy and infrastructure projects, such as transmission lines

24 and liquefied natural gas terminals, could result in noticeably adverse impacts on the area. 

25 Also, increased population growth in the surrounding area could lead to an increase in the 

26 number of viewers, the frequency and duration of views, and in the perceived impact level.

27 The magnitude of cumulative impacts resulting from all general trends taking place within the 

28 region in which a storage facility is located would depend on the number of structures affecting 

29 the landscape, the degree of contrast, the degree of visibility (which, in turn, depends on the 

30 distance and angle from which the landscape is viewed), the value of the landscape, the 

31 number of viewers, the frequency and duration of views, and viewer perception of the impact 

32 level. The cumulative impacts from general trends and activities would range from minimal 

33 (e.g., limited development resulted in minor changes within the viewshed, [NRC 2011c]) to 

34 noticeable (e.g., construction of a new power plant or storage would noticeably alter the scenic 

35 quality of the area by introducing an industrial presence into a largely undeveloped landscape, 

36 see NRC 2011a and 2001a).
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Draft NUREG‒2157 6-44 September 2013

1 6.4.13.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

2 Activities

3 Cumulative impacts on aesthetic resources could result from other NRC-regulated or spent fuel4 related activities, such as changes to operational characteristics of the facility (e.g., the 

5 condensation plume from a cooling tower) during shutdown and dismantlement, demolition, and 

6 removal of structures during decommissioning could have direct aesthetic impacts. Aesthetic 

7 impacts from the removal of structures would be a long-term change, and are generally 

8 considered beneficial to the visual appeal of a site.

9 In the Decommissioning GEIS for power reactors (including spent fuel pools), the NRC (2002) 

10 determined that the impacts on aesthetic resources during decommissioning would be SMALL

11 and that any impact would be temporary and would serve to reduce the aesthetic impact of the 

12 site. The impacts from decommissioning ISFSIs were not considered in the Decommissioning 

13 GEIS. Aesthetic impacts from decommissioning the smaller structure of an ISFSI would be no 

14 greater than that for decommissioning a nuclear power plant because of the smaller size of the 

15 ISFSI. NRC’s EAs for the Calvert Cliffs, Surry, and Diablo Canyon ISFSIs, and the PFSF ISFSI 

16 EIS did not identify any significant impacts on aesthetic resources during decommissioning of 

17 an at-reactor or away-from-reactor ISFSI (NRC 2001a, 2003a, 2005a, 2012c). The NRC 

18 assumes that the types and magnitude of impacts from decommissioning an ISFSI at other sites 

19 would be similar to that described in the Calvert Cliffs, Surry, and Diablo Canyon EAs and the 

20 PFSF EIS because the activities that take place during decommissioning and the change in 

21 visual characteristics that would occur at other sites would be similar to those evaluated in the 

22 Calvert Cliffs, Surry, and Diablo Canyon EAs and the PFSF EIS.

23 Given that the impacts from decommissioning reactors, spent fuel pools, and ISFSIs would be 

24 similar to the impacts described in the Decommissioning GEIS for reactors and site-specific 

25 ISFSI EAs and EISs, impacts on aesthetic resources from decommissioning are expected to be 

26 minimal and that any impact would be temporary.

27 6.4.13.3 Conclusions

28 Cumulative impacts on aesthetic resources include the incremental effects from continued 

29 storage when added to the aggregate effects of other past, present, and reasonably foreseeable 

30 future actions. As described in Sections 4.14 and 5.14, the incremental impacts from continued 

31 storage on aesthetic resources is SMALL for all timeframes for at-reactor storage facilities and 

32 SMALL to MODERATE for away-from-reactor storage facilities. In addition, past, present, and 

33 reasonably foreseeable activities take place in the geographic area of interest that could 

34 contribute to cumulative effects to aesthetic resources. The cumulative impacts from continued 

35 storage and other past, present, and reasonably foreseeable Federal and non-federal activities 

36 range from SMALL to MODERATE depending on the incremental impact from the storage 

37 facility and the conditions and activities surrounding the site. A SMALL impact would occur at 
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September 2013 6-45 Draft NUREG‒2157

1 sites where storage facilities have minimal impacts on the viewshed and no other actions occur 

2 that had overlapping, noticeable effects on aesthetic resources. A MODERATE impact would 

3 occur if the storage facility has a noticeable impact on the viewshed, or if other Federal or non4 federal actions, such as the construction and operation of other nearby power plants or future 

5 urbanization, had overlapping impacts with the continued storage of waste that noticeably 

6 altered aesthetic resources. At storage facilities where the incremental impacts are SMALL and 

7 cumulative impacts are MODERATE from other Federal or non-federal activities, the NRC 

8 determined that the cumulative impacts would likely remain MODERATE whether or not 

9 continued storage occurred because the incremental impacts from continued storage would be 

10 minor, especially in comparison to other general trends, such as constructing new power plants.

11 6.4.14 Waste Management

12 This section evaluates the effects of continued storage on the capacity and operating lifespan of 

13 waste-management facilities when added to the aggregate effects of other past, present, and 

14 reasonably foreseeable future actions. The incremental impacts from continued storage on 

15 waste management are described in Sections 4.15 and 5.15 and summarized in Table 6-3. In 

16 addition to the incremental impacts from continued storage, this cumulative impacts analysis 

17 also considers other past, present, and reasonably foreseeable projects that could affect waste 

18 management. The geographic area considered in the cumulative LLW and mixed-waste19 management resources analysis includes the continental United States because LLW disposal

20 facilities handle waste generated on a national scale. The geographic area considered in the 

21 cumulative nonradioactive waste (i.e., hazardous and nonhazardous wastes) management 

22 resources analysis includes the area where the continued storage of spent fuel occurs and 

23 nonradioactive waste is sent for disposal.

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

Storage

Timeframe

At-Reactor Storage 

(Section 4.15)

Away-From-Reactor Storage

(Section 5.15)

Short-Term LLW

Mixed Waste 

Nonradioactive(a)

SMALL

SMALL

SMALL

LLW

Mixed Waste 

Nonradioactive(a)

SMALL

SMALL 

SMALL

Long-Term LLW

Mixed Waste

Nonradioactive(a)

SMALL

SMALL

SMALL

LLW

Mixed Waste

Nonradioactive(a)

SMALL 

SMALL

SMALL

Indefinite LLW

Mixed Waste

Nonradioactive(a)

SMALL 

SMALL 

SMALL to 

MODERATE

LLW

Mixed Waste

Nonradioactive(a)

SMALL 

SMALL 

SMALL to 

MODERATE

(a) Nonradioactive waste includes hazardous and nonhazardous wastes.
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Draft NUREG‒2157 6-46 September 2013

1 6.4.14.1 Potential Cumulative Impacts from General Trends and Activities

2 Cumulative impacts on waste management could include reduction in landfill capacity needed 

3 for the proper disposal of the total amount of LLW, mixed waste, and nonradioactive waste

4 resulting from all reasonably foreseeable Federal and non-federal activities. These impacts 

5 result from waste-generating activities associated with residential, commercial, industrial, and 

6 military development. The potential cumulative impacts associated with the management of 

7 each waste type are discussed below.

8 Low-Level Waste and Mixed Waste

9 In addition to LLW generated at operating reactors and other uranium fuel cycle facilities, other 

10 radioactive waste-generating activities that can occur in the same regions as operating reactors 

11 including activities at DOE and U.S. Department of Defense installations as well as industrial 

12 facilities and hospitals where radioisotopes are used for industrial or medical purposes (NRC 

13 2013a). These same activities are potential generators of both LLW and mixed waste. 

14 The magnitude of cumulative waste-management impacts resulting from general trends would 

15 depend on current radioactive waste-generating activities, generation rates, potential changes in 

16 waste-generating activities and rates, and the extent to which these waste generators employ 

17 mitigation measures to reduce such impacts. LLW and mixed waste can only be disposed of in 

18 a limited number of disposal facilities, as described in Section 3.14. Depending on the locations 

19 of the radioactive waste generators and the locations of available treatment and disposal 

20 facilities, there could be cumulative impacts resulting from the transportation, treatment, and 

21 disposal of radioactive waste (NRC 2013a). The cumulative impacts from general trends and 

22 activities would range from minimal (e.g., minor changes in available disposal capacity and 

23 limited development of new governmental, industrial, and medical radioactive waste-generating 

24 activities, see NRC 2013a,b) to noticeable (e.g., loss in available disposal capacity and 

25 expanded or new governmental, industrial, and medical radioactive waste-generating activities).

26 Nonradioactive Waste

27 In addition to nuclear reactor operations, residential, commercial, and industrial activities also 

28 generate nonradioactive waste. Nonradioactive waste includes hazardous and nonhazardous 

29 wastes and is typically disposed of in local or regional treatment facilities and landfills. 

30 Hazardous waste treatment, storage, and disposal facilities or nonhazardous waste landfills are 

31 constructed and operated by local or regional units of government or private companies. The 

32 facility size or landfill capacity is based on the projected waste disposal needs for the 

33 geographic area or region that the facility or landfill serves. Municipal solid waste landfills in the 

United States typically have capacities ranging from 1,200,000 m3 (1,600,000 yd3 34 ) to more than 

45,000,000 m3 (59,000,000 yd3 35 ) of compacted solid waste (EREF 1999).
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September 2013 6-47 Draft NUREG‒2157

1 The magnitude of cumulative impacts from the management of nonradioactive wastes resulting 

2 from all waste-generating actions taking place in the area in which a storage facility is located 

3 would likely be minimal (e.g., minor changes in available facility or landfill capacity and limited 

4 increase of waste generation by new residential, commercial, and industrial development, see

5 NRC 2013a,b) to noticeable (e.g., minor changes or decrease in available capacity and major 

6 increase in waste generation by new residential, commercial, and industrial development).

7 6.4.14.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

8 Activities

9 Cumulative impacts on waste-management resources could result from other NRC-regulated or 

10 spent fuel-related activities, such as decommissioning of a nuclear power plant (including the 

11 spent fuel pool), ISFSI, and DTS. These activities would generate LLW, mixed waste, and 

12 nonradioactive waste. Although it would not affect nonradioactive waste disposal on a regional 

13 level because of the local availability of nonradiological disposal facilities, construction and 

14 operation of a repository for spent fuel disposal would contribute additional LLW and mixed 

15 waste, adding to the cumulative impacts from LLW and mixed waste disposal on the limited 

16 number of treatment and disposal facilities available throughout the United States.

17 Low-Level Waste and Mixed Waste

18 The LLW and mixed-waste-management impacts from reactor decommissioning, including a 

19 spent fuel pool, would depend on the size of the reactor and pool. The estimated volume of 

LLW generated by reactor decommissioning ranges from 580 m3 (760 yd3) to 32,800 m3 20

(42,900 yd3 21 ) (NRC 2002). This quantity of LLW would be generated over a period ranging from 

22 about 5 to 14 years depending on the decommissioning option undertaken (NRC 2002). A 

23 conservative estimate of the LLW generated annually, using the maximum volume of LLW of 

32,800 m3 (42,900 yd3), is 6,560 m3 (8,580 yd3 24 ) for a reactor decommissioning lasting 5 years to 

2,340 m3 (3,060 yd3 25 ) for a reactor decommissioning lasting 14 years. This range of annual 

26 quantities of LLW is much larger than the average annual quantity of LLW produced during 

reactor operation, which is about 300 m3 (392 yd3 27 ) for a pressurized water reactor and about 

600 m3 (785 yd3 28 ) for a boiling water reactor (NRC 1996). In the License Renewal GEIS, the 

29 NRC considered the LLW that would be generated by decommissioning and concluded that 

30 there is reasonable assurance that sufficient LLW disposal capacity will be made available when 

31 needed for facilities to be decommissioned consistent with NRC requirements (NRC 2013a).

32 Mixed waste would also be generated at an increased rate during reactor decommissioning

33 relative to reactor operation. The quantity of mixed waste generated during reactor operation is 

34 a small fraction of the quantity of LLW (NRC 2013a). Because of similarities in waste35 generating activities during reactor operation and decommissioning, the quantity of mixed waste 

36 generated during reactor decommissioning is expected to continue to be a small fraction of the 

37
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Draft NUREG‒2157 6-48 September 2013

1 quantity of LLW. Despite an increase in the generation rate of mixed waste during 

2 decommissioning, the quantity of mixed waste produced is expected to remain small relative to 

3 available disposal capacity.

4 The decommissioning of dry spent fuel storage facilities would also generate LLW and mixed 

5 waste. The types and quantities of LLW and mixed waste generated during decommissioning 

6 would be similar to facility replacement, as described in Sections 4.15 and 5.15. The NRC has 

7 determined, as described in Sections 4.15 and 5.15, that the incremental impacts from the 

8 management and disposal of LLW and mixed waste associated with facility replacement would 

9 be SMALL for LLW and mixed waste.

10 The construction and operation of a repository for spent fuel disposal would also generate LLW. 

The final EIS for the proposed repository at Yucca Mountain, Nevada, projected that 74,000 m3 11

(97,000 yd3 12 ) of LLW would be generated from the construction and operation of that facility 

13 (DOE 2008). The period of construction and operation of the proposed repository was 

14 estimated to be greater than 100 years. The DOE determined that the environmental impacts 

15 from management and disposal of LLW would be SMALL, because the treatment and disposal 

16 capacity exceeds the demand created by the quantities of LLW generated. The DOE indicated 

17 that no mixed waste would be generated during the construction and operation of the repository 

18 (DOE 2008).

19 The magnitude of cumulative waste-management impacts resulting from management and 

20 disposal of LLW and mixed waste generated from continued storage of spent fuel, 

21 decommissioning of nuclear facilities, and construction and operation of a repository for spent 

22 fuel disposal would depend on current radioactive waste-generating activities and generation 

23 rates and potential changes in waste-generating activities and rates. It would also depend on 

24 the extent to which these waste generators employ mitigation measures to reduce such 

25 impacts. The cumulative impacts from general trends and activities would range from minimal

26 (e.g., minor changes in available disposal capacity and limited or no increases in other NRC27 regulated or spent fuel-related radioactive waste-generating activities,) to noticeable (e.g., loss 

28 in available disposal capacity and increases in other NRC-regulated or spent fuel-related 

29 activities that produce radioactive waste). Large cumulative waste-management impacts could 

30 occur in the unlikely event that available disposal capacity decreases and radioactive waste 

31 generation increases as a result of multiple other NRC-regulated or spent fuel-related activities 

32 occurring concurrently.

33 Nonradioactive Waste

34 The nonradioactive waste-management impacts from reactor decommissioning, including a 

35 spent fuel pool, would depend on the size of the reactor and pool. Similar to LLW and mixed 

36 waste, reactor decommissioning generates nonradioactive waste at an increased rate relative to 

37 operation over a period ranging from about 5 to 14 years, depending on the decommissioning 
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September 2013 6-49 Draft NUREG‒2157

1 option undertaken. Because the increased waste generation during decommissioning occurs 

2 for a relatively short period of time and decommissioned reactors must continue to comply with 

3 Federal and State regulations in terms of storage, treatment, and disposal of waste, the NRC 

4 determined in the License Renewal GEIS (NRC 2013a) that the cumulative impacts resulting 

5 from the management of nonradioactive wastes resulting from all waste-generating actions 

6 taking place within the region in which an operating reactor is located would be SMALL.

7 The decommissioning of dry spent fuel storage facilities would also generate nonradioactive 

8 waste. The types and quantities of nonradioactive waste generated during decommissioning 

9 would be similar to facility replacement, as described in Sections 4.15 and 5.15. The NRC has 

10 determined, as described in Sections 4.15 and 5.15, that the incremental impacts from 

11 management and disposal of nonradioactive waste associated with dry storage facility 

12 replacement would be SMALL for short-term and long-term storage and SMALL to MODERATE 

13 for indefinite storage.

14 The magnitude of cumulative waste-management impacts resulting from management and 

15 disposal of nonradioactive waste generated from continued storage of spent fuel and 

16 decommissioning of nuclear facilities would depend on current nonradioactive waste-generating 

17 activities and generation rates, potential changes in waste-generating activities and rates in an 

18 area, and the extent to which waste generators in an area employ mitigation measures to 

19 reduce such impacts. The cumulative impacts from general trends and activities would range 

20 from minimal (e.g., minor changes in available landfill capacity and limited or no increases in 

21 other NRC-regulated or spent fuel-related radioactive waste-generating activities,) to noticeable 

22 (e.g., loss in available landfill capacity and increases in other NRC-regulated or spent fuel23 related activities that produce nonradioactive waste). Large cumulative waste-management 

24 impacts could occur in the unlikely event that available landfill capacity decreases and 

25 nonradioactive waste generation increases as a result of multiple other NRC-regulated or spent 

26 fuel-related activities occurring concurrently.

27 6.4.14.3 Conclusion

28 Cumulative impacts on waste-management resources include the incremental effects from 

29 continued storage when added to the aggregate effects of other past, present, and reasonably 

30 foreseeable future actions. The incremental impacts from continued storage on waste31 management resources are described in Sections 4.15 and 5.15 and summarized in Table 6-3. 

32 In addition, past, present, and reasonably foreseeable Federal and non-federal activities 

33 described in Sections 6.3.1 and 6.3.2.2, spread across the geographic area of interest (national 

34 scale) are SMALL to LARGE for LLW and mixed waste because local, regional, or national 

35 waste-management resources might experience minor to destabilizing decreases in their 

36 capacity. For nonradioactive waste, the cumulative impacts from other past, present, and 

37 reasonably foreseeable Federal and non-federal activities spread across the geographic area of 

38 interest (area surrounding an at-reactor or away-from-reactor spent fuel storage facility) would 
Cumulative Impacts

Draft NUREG‒2157 6-50 September 2013

1 be SMALL to LARGE. A SMALL impact would occur if local, regional, or national waste2 management facilities experience no noticeable decreases in their capacity or operating lifespan 

3 from continued storage or other Federal or non-federal activities. A MODERATE impact would 

4 occur if local, regional, or national waste-management facilities experience noticeable 

5 decreases in their capacity or operating lifespan. A LARGE impact would occur in the unlikely 

6 event that available LLW or nonradioactive waste disposal capacity decreases and LLW or 

7 nonradioactive waste generation increases as a result of multiple other NRC-regulated or spent 

8 fuel-related activities occurring concurrently. The NRC determined that these cumulative 

9 impacts (ranging from SMALL to LARGE) could increase as a result of continued storage of 

10 spent fuel because the incremental impacts from continued storage would range from minor to 

11 noticeable, which could increase a SMALL cumulative impact to a MODERATE cumulative 

12 impact or a MODERATE cumulative impact to a LARGE cumulative impact.

13 6.4.15 Transportation

14 This section evaluates the effects of continued storage on transportation when added to the 

15 aggregate effects of other past, present, and reasonably foreseeable future actions. As 

16 described in Sections 4.16 and 5.16, the incremental impacts from continued storage on 

17 nonradiological transportation are SMALL for all timeframes at at-reactor facilities and SMALL to 

18 MODERATE at away-from-reactor ISFSIs. The radiological transportation impacts for at-reactor 

19 and away-from-reactor continued storage activities are SMALL.

20 The geographic area considered in the cumulative transportation analysis includes the site of 

21 the power plant and at-reactor ISFSI, the site of an away-from-reactor ISFSI, and the local, 

22 regional, and national transportation networks and populations that use or live along these 

23 networks.

24 6.4.15.1 Potential Cumulative Impacts from General Trends and Activities

25 Cumulative transportation impacts involve (1) nonradiological impacts, such as increased traffic 

26 (e.g., commuting workers and construction materials) and associated increases in accident

27 risks, injuries, and fatalities and (2) radiological impacts, such as radiation doses from the 

28 shipment of radioactive materials including unirradiated fuel, spent fuel, and waste materials 

29 (NRC 2011a–e, 2012a, 2013a,b). Traffic impacts can accumulate from multiple actions 

30 occurring during the same time period (e.g., overlapping construction projects). Principal 

31 contributors to localized traffic that could overlap with storage facility construction and 

32 operations include the construction of other energy, water, military, or urbanization projects. 

33 Radiation dose impacts can accumulate from multiple shipping activities that overlap during the 

34 same time period or from single or multiple shipping actions that occur over time on the same 

35 routes. Actions involving shipment of radioactive materials for medical, industrial, research, or 

36 other energy projects could also overlap with reactor radioactive material shipment impacts

37 (NRC 2011a,c,d).
Cumulative Impacts

September 2013 6-51 Draft NUREG‒2157

1 The magnitude of cumulative impacts resulting from general trends taking place within the 

2 region in which a storage facility is located would depend on the nature and location of the 

3 actions relative to the storage facility transportation activities. For nonradiological transportation

4 impacts, the cumulative impacts from general trends and activities would range from minimal 

5 (e.g., no overlap in traffic with any other development project, see cumulative operational traffic 

6 impacts in NRC 2011d) to noticeable (e.g., traffic congestion at specific sites and on roads with 

7 limited available capacity to accommodate the increased demand from proposed power plant 

8 activities, see NRC 2012a). For radiological transportation impacts, the cumulative impacts 

9 would likely be minimal based on low dose, prior generic impact assessment in 10 CFR 51.52 

10 (spent fuel, LLW), updated supplemental analyses addressing unique site-specific plant 

11 characteristics, and the low volume of other regional radioactive materials transportation 

12 activities that could overlap with continued storage (NRC 2011a–e, 2013c).

13 6.4.15.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

14 Activities

15 Cumulative impacts on transportation could result from other NRC-regulated or spent fuel16 related activities, such as increases in traffic from workers during final reactor shutdown 

17 activities; decommissioning of the reactor power block (including the spent fuel pool), ISFSIs, 

18 and DTS; and transportation of spent fuel from an at-reactor or away-from-reactor ISFSI to a 

19 repository for disposal. 

20 Nonradiological traffic impacts from reactor shutdown activities would result from a temporary 

21 increase in the reactor workforce; however, the number of workers would not be expected to 

22 exceed the temporary workforce used for refueling outages. Therefore, the traffic impacts 

23 during shutdown would be similar to the traffic impacts during reactor operations. Traffic 

24 impacts during shutdown were evaluated in the License Renewal GEIS in which the NRC 

25 (2013a) determined traffic impacts to be SMALL for operating plants. Combined nonradiological 

26 and radiological traffic impacts from reactor decommissioning were previously evaluated by the 

27 NRC in the Decommissioning GEIS for nuclear reactors (NRC 2002). In that analysis, the NRC 

28 evaluated the number of shipments of dismantled equipment, material, and debris from 

29 decommissioning. Although the number of shipments can be relatively large, the 

30 decommissioning period extends over several years. As a result, the number of LLW shipments 

31 per day is low, with an average of less than one shipment per day from the plant (NRC 2002). 

32 The materials transported offsite would include all wastes generated onsite. Nonradiological 

33 impacts would include increased traffic volume, additional wear and tear on roadways, and 

34 potential traffic accidents (NRC 2002). This information supported a conclusion that the 

35 transportation impacts from nuclear power plant decommissioning would not be detectable 

36 (NRC 2002).

37 Additional radiological impacts would occur from transportation of (1) spent fuel to a repository

38 for disposal and (2) LLW from decommissioning the reactor, spent fuel pool, and ISFSI. 
Cumulative Impacts

Draft NUREG‒2157 6-52 September 2013

1 Radiological impacts would include exposure of transportation workers and the general public 

2 along the transportation routes. The NRC previously determined that radiological impacts on

3 the public and workers of spent fuel and waste shipments from a reactor are SMALL in several 

4 evaluations. For example, the NRC made a generic impact determination in Table S–4 in 

5 10 CFR 51.52 and the supporting analysis (AEC 1972) that the environmental impacts of 

6 transportation of fuel and waste to and from a 1,000- to 1,500-MW(e) light water reactor would 

7 be SMALL under incident-free and accident conditions. Additional site-specific analyses of 

8 transportation impacts for power plants that did not meet the conditions of 10 CFR 51.52 also 

9 concluded the transportation radiological impacts would be SMALL (NRC 2006, 2008, 2011a–f). 

10 In the License Renewal GEIS (NRC 2013a), the NRC also concluded that impacts from uranium

11 fuel cycle transportation, including transportation of spent fuel to a repository for disposal, are 

12 SMALL for all nuclear plants. The results of subsequent analyses of transportation impacts in 

13 “Final Environmental Statement on Transportation of Radioactive Material by Air and Other 

14 Modes (NRC 1977) and Reexamination of Spent Fuel Shipment Risk Estimates” (Sprung et al. 

15 2000) confirmed spent fuel transportation impacts are small. More recently, the NRC calculated 

16 spent fuel transportation risks for individual shipments in “Spent Fuel Transportation Risk 

17 Assessment: Draft Report for Comment” (NRC 2012e) based on current models, data, and 

18 assumptions. The analysis modeled responses of shipping casks to accident conditions such 

19 as impact force and fire, and calculated risks considering a range of truck and rail accidents of 

20 different severities including those involving no release or loss of shielding, loss of shielding 

21 only, or loss of shielding and release. That analysis reconfirmed that the radiological impacts 

22 from spent fuel transportation conducted in compliance with NRC regulations are low. The NRC 

23 also concluded that the regulations for transportation of radioactive material were adequate to 

24 protect the public against unreasonable risk (NRC 2012e). Based on the generic determination 

25 in Table S–4 of 10 CFR 51.52 and the subsequent spent fuel transportation impact analyses 

26 and risk assessments cited above, the NRC concludes the radiological impacts for incident-free 

27 and accident transportation of spent fuel from a single at-reactor storage facility to a repository 

28 would be small.

29 Radiological impacts may accumulate along the transportation route for an away-from-reactor 

30 ISFSI because the same overall transportation route would be used to transfer the entire

31 inventory of spent fuel from an away-from-reactor ISFSI to a repository. To evaluate these 

32 impacts from an away-from-reactor ISFSI, the NRC reviewed other past evaluations of 

33 transportation of spent fuel from an away-from-reactor ISFSI to a repository. For example, the 

34 NRC previously evaluated the radiological and nonradiological impacts from a comparable (full 

35 inventory) transportation scenario for an away-from-reactor ISFSI (PFSF) and concluded that 

36 the impacts would be SMALL (NRC 2001a). That analysis calculated incident-free and accident

37 risks from 4,000 shipments of spent fuel from Maine to Utah over a 20-year period. The 

38 resulting cumulative dose to the maximally exposed individual (an individual that is assumed for 

39 the purpose of bounding analysis for incident-free transportation to be exposed to the radiation 

40 from all shipments) at the end of the 20-year period was 0.022 mSv (2.2 mrem). For 
Cumulative Impacts

September 2013 6-53 Draft NUREG‒2157

1 comparison, the annual NRC public dose limit in 10 CFR Part 20 is 1 mSv (100 mrem). The 

2 NRC (2001a) also concluded that the radiological impacts from transportation of a single 

3 reactor’s spent fuel from an away-from-reactor ISFSI to a repository would be bounded by, or 

4 comparable to, impacts evaluated in Table S–4 in 10 CFR 51.52. Based on these analyses, 

5 the NRC concludes that the additional accumulated impacts from transportation of the entire 

6 inventory of spent fuel from an away-from-reactor ISFSI to a repository would be minor.

7 6.4.15.3 Conclusion

8 Cumulative impacts on transportation include the incremental effects from continued storage 

9 when added to the aggregate effects of other past, present, and reasonably foreseeable future 

10 actions. As described in Sections 4.16 and 5.16, the incremental impacts from continued 

11 storage on transportation is SMALL for all timeframes at an at-reactor ISFSI and SMALL to 

12 MODERATE for all timeframes at an away-from-reactor ISFSI. In addition, past, present, and 

13 reasonably foreseeable activities take place in the geographic area of interest that could 

14 contribute to cumulative effects to transportation. The cumulative impacts from continued 

15 storage when added to other past, present, and reasonably foreseeable Federal and non16 federal activities (such as construction of energy, water, military, or urbanization projects) would 

17 range from SMALL to MODERATE for nonradiological transportation and SMALL for 

18 radiological transportation.

19 6.4.16 Public and Occupational Health

20 This section evaluates the effects of continued storage on public and occupational health when 

21 added to the aggregate effects of other past, present, and reasonably foreseeable future 

22 actions. As described in Sections 4.17 and 5.17, the incremental impacts from continued

23 storage on public and occupational health is SMALL for all timeframes at both at-reactor and 

24 away-from-reactor storage facilities.

25 For this analysis, the geographic area considered in the cumulative public and occupational 

26 health resources analysis is the area within a 80-km (50-mi) radius of the at-reactor or away27 from-reactor storage facility site. Historically, the NRC has used the 80-km (50-mi) radius as a 

28 standard geographic area to evaluate population doses from routine releases from nuclear 

29 power plants. The 80-km (50-mi) radius was selected to encompass potential impact overlaps 

30 from two or more nuclear facilities. This concept is discussed in detail in the site-specific EISs 

31 for new reactors and ISFSI EAs or EISs reviewed for this draft GEIS analysis (see e.g., NRC 

32 2011d, Section 6.8).

33 6.4.16.1 Potential Cumulative Impacts from General Trends and Activities

34 Cumulative human health impacts relate to public exposure to radiological, chemical, and 

35 microbiological hazards and the potentially chronic effects of electromagnetic field (EMF) 
Cumulative Impacts

Draft NUREG‒2157 6-54 September 2013

1 exposure. Public exposures may occur as a result of environmental accumulations of harmful 

2 constituents released from various facilities associated with urban, agricultural, industrial, and 

3 commercial development. The potential cumulative impacts of EMF exposure, while uncertain, 

4 would relate to activities (e.g., transmission lines and substations) associated with urban, 

5 industrial, and commercial development. The NRC acknowledges that there is no conclusive 

6 link between EMF exposure and human health impacts (NRC 2013a).

7 The magnitude of cumulative impacts resulting from general trends taking place within the 

8 region in which a storage facility is located would depend on the nature and location of the 

9 actions, the number of actions (facilities or projects), the level of the public’s exposure, and 

10 whether facilities comply with regulating agency requirements (e.g., permitted discharge limits). 

11 For public and occupational health, the cumulative impact would be minimal (e.g. NRC 2011a–f, 

12 2012a, 2013a,b) because reactors and other industrial buildings would be required to meet 

13 regulations such as the Occupational Safety and Health Administration’s General Industry 

14 Standards (29 CFR Part 1910) and Construction Industry Standards (29 CFR Part 1926) and, 

15 as applicable, operated under NRC regulations such as 10 CFR Part 72 and 10 CFR Part 20. 

16 For example, even though increased urbanization might suggest an increased public exposure 

17 because of a larger receptor group, the NRC would still require the regulated nuclear facilities in 

18 the area of interest to prove through monitoring and as low as reasonably achievable (ALARA) 

19 programs that they were meeting the public and occupational health regulations.

20 6.4.16.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

21 Activities

22 Cumulative impacts on public and occupational health could result from other NRC-regulated or 

23 spent fuel-related activities, such as reactor plant shutdown activities prior to decommissioning, 

24 decommissioning activities, construction of infrastructure to support away-from-reactor ISFSIs, 

25 and preparation activities to enable transportation of waste to a repository. Decommissioning 

26 and preparation for decommissioning are regulated activities that are conducted through the 

27 NRC-approved decommissioning plans. The NRC has evaluated environmental impacts from 

28 these activities in the Decommissioning GEIS (NRC 2002) for reactor decommissioning and the 

29 PFSF EIS (NRC 2001a) for ISFSI decommissioning and found the public and occupational 

30 health impacts to be SMALL. The NRC also evaluated environmental impacts from 

31 infrastructure to support away-from-reactor ISFSIs in the PFSF EIS (NRC 2001a) and found the 

32 public and occupational health impacts to be SMALL. For activities related to spent fuel 

33 transportation to a repository, such as spent fuel storage maintenance activities that involve 

34 bare fuel handling in a postulated dry transfer facility at nearby facilities, as noted in 

35 Sections 4.17 and 5.17, the public and occupational health impacts would be SMALL and would 

36 not aggregate to more significant impacts, given the limited number of facilities within 80 km 

37 (50 mi) expected to be in the decommissioning phase of their lifecycle.
Cumulative Impacts

September 2013 6-55 Draft NUREG‒2157

1 6.4.16.3 Conclusion

2 Cumulative impacts on public and occupational health include the incremental effects from 

3 continued storage when added to the aggregate effects of other past, present, and reasonably 

4 foreseeable future actions. As described in Sections 4.17 and 5.17, the incremental impacts 

5 from continued storage on public and occupational health is SMALL for all timeframes at both 

6 at-reactor and away-from-reactor storage facilities. The cumulative impacts from continued 

7 storage when added to other past, present, and reasonably foreseeable Federal and non8 federal activities are expected to be SMALL because storage facilities, reactors, and other 

9 proposed industrial buildings would be required to meet regulations such as the Occupational 

10 Safety and Health Administration’s General Industry Standards (29 CFR Part 1910) and 

11 Construction Industry Standards (29 CFR Part 1926) and, as applicable, operated under NRC 

12 regulations such as 10 CFR Part 72 and 10 CFR Part 20.

13 6.4.17 Environmental Impacts of Postulated Accidents

14 This section evaluates the effects of continued storage on accident risk when added to the 

15 aggregate effects of other past, present, and reasonably foreseeable future actions. As 

16 described in Sections 4.18 and 5.18, the incremental impacts from continued storage on 

17 environmental impacts of postulated accidents is SMALL for all timeframes at both at-reactor 

18 and away-from-reactor storage facilities.

19 The geographic area considered in the cumulative accident risk assessment is a 80-km (50-mi) 

20 radius from an at-reactor or away-from-reactor storage facility. The cumulative analysis 

21 considers risk from potential accidents from other nuclear plants or storage facilities that have 

22 the potential to increase risks at any location within 80 km (50 mi) of the shutdown reactor or 

23 storage facility. It is possible that one or more other types of nuclear facilities that support the 

24 nuclear fuel cycle may be located within a 80-km (50-mi) radius, but these facilities generally 

25 involve very low accident risk (51 FR 30028). Therefore, the analysis below focuses on the 

26 cumulative risk from reactors and storage facilities.

27 6.4.17.1 Potential Cumulative Impacts from General Trends and Activities

28 Based on a review of the other activities that can occur near proposed new at-reactor storage 

29 facilities, there are two scales of cumulative impacts on accident risk, including (1) cumulative 

30 impacts due to the various impacts from an individual power plant and storage facility over time 

31 (e.g., annual design basis and severe accident risks at a reactor), and (2) cumulative impacts 

32 due to closely sited operating or decommissioning reactors (e.g., design basis and severe 

33 accident risks at other reactors located within 80 km [50-mi]) or other radioactive facilities. In 

34 addition, climate change can impact accident risk due to higher or lower intensity or frequency 

35 of natural phenomena hazards (e.g., precipitation, tornadoes, hurricanes) that result in 

36 radiological accidents.
Cumulative Impacts

Draft NUREG‒2157 6-56 September 2013

1 The magnitude of cumulative accident impacts resulting from all general trends taking place 

2 within the 80-km (50-mi) region of a power plant and storage facility would likely be limited 

3 because:

4 1. Estimates of average individual early fatality and latent cancer fatality risks are well below 

5 the Commission’s safety goals at all plants (51 FR 30028).

6 2. The Commission has determined that the probability-weighted consequences of severe 

7 accidents of a nuclear power plant are SMALL (10 CFR Part 51, Appendix B, Table B-1).

8 3. The severe accident risk due to any particular nuclear power plant gets smaller as the 

9 distance from that plant increases. However, the combined risk at any location within 80 km 

10 (50 mi) of a reactor site would be bounded by the sum of risks for all of these operating and 

11 proposed nuclear power plants. Even though several plants and other nuclear facilities 

12 could potentially be included in the combination, this combined risk would still be low.

13 Because design basis accidents at nearby power plants and storage facilities are individually 

14 unlikely to occur more than once over the life of a facility, and licensees must show that accident

15 consequences of design basis accidents are mitigated to acceptable levels of dose offsite, the 

16 cumulative impact of design basis accidents is very small. Based on the above discussion, the 

17 NRC concluded that, in all new reactor EISs published through February 2013 (e.g., NRC 

18 2011a–f), the cumulative risks from design basis and severe accidents at any location 

19 within 80 km (50 mi) of a reactor would be SMALL.

20 Potential cumulative impacts from an ISFSI or an away-from-reactor storage facility would be 

21 minimal because of passive nature of the ISFSI; no gaseous or liquid effluents are released 

22 during operation. In addition, because licensees are required to maintain doses as low as is 

23 reasonably achievable in accordance with NRC radiation protection regulations, both an ISFSI 

24 and an away-from-reactor facility are designed to minimize radiological doses to workers and 

25 public. Additionally, the severe accident risk from a spent fuel storage facility also decreases as 

26 the distance from that facility increases. On this basis, the NRC concluded that the cumulative 

27 risk of continued storage from design basis and severe accidents at an ISFSI or an away-from28 reactor storage facility would be SMALL. 

29 6.4.17.2 Potential Cumulative Impacts from Other NRC-Regulated or Spent Fuel-Related 

30 Activities

31 Cumulative impacts of postulated accidents could result from other NRC-regulated or spent fuel32 related activities, such as spent fuel storage maintenance activities. Activities that involve bare 

33 fuel handling in a postulated dry transfer facility at nearby facilities could involve additional 

34 accident risk. However, as noted in Sections 4.18 and 5.18, these impacts would be SMALL, 

35 and would not aggregate to more significant impacts, given the limited number of facilities within 

36 80 km (50 mi) expected to be in this part of their life cycle.
Cumulative Impacts

September 2013 6-57 Draft NUREG‒2157

1 Before spent fuel storage facilities can begin final decommissioning and license termination, the 

2 spent fuel must be removed from the site and stored or disposed of offsite. Once the spent fuel 

3 is removed from the site, the residual radioactive material at a reactor poses very little accident

4 risk. Therefore, impacts on accident risk from decommissioning are expected to be SMALL 

5 (NRC 2002).

6 6.4.17.3 Conclusion

7 Cumulative impacts of postulated accidents include the incremental effects from continued 

8 storage when added to the aggregate effects of other past, present, and reasonably foreseeable 

9 future actions. As described in Sections 4.18 and 5.18, the incremental impacts from continued 

10 storage on environmental impacts of postulated accidents is SMALL for all timeframes at both 

11 at-reactor and away-from-reactor storage facilities. In addition, past, present, and reasonably 

12 foreseeable activities take place in the geographic area of interest that could contribute to 

13 cumulative effects to accident risk. 

14 The NRC determined that the cumulative impacts from a reactor, a spent fuel pool, and an 

15 ISFSI would be minimal because accident risk remains SMALL. The cumulative impacts from 

16 other past, present, and reasonably foreseeable Federal and non-federal activities described in 

17 Sections 6.3.1 and 6.3.2 are SMALL. Given that estimates of average individual early fatality 

18 and latent cancer fatality risks are well below the Commission’s safety goals at all nuclear power 

19 plants (51 FR 30028), the Commission determination that the probability-weighted 

20 consequences of severe accidents of a nuclear power plant are SMALL (10 CFR Part 51, 

21 Appendix B, Table B-1), and that the combined risk from several plants and other nuclear 

22 facilities would be low, the NRC concludes that the cumulative impacts at all storage sites would 

23 be SMALL.

24 6.5 Summary 

25 The impact levels determined by the NRC in the previous chapters from at-reactor storage 

26 (Chapter 4), away-from-reactor storage (Chapter 5), and cumulative impacts from continued 

27 storage when added to other past, present, and reasonably foreseeable activities (Chapter 6) 

28 are summarized in Table 6-4. The impact levels are denoted as SMALL, MODERATE, and 

29 LARGE as a measure of their expected adverse environmental impacts.
Cumulative Impacts

Draft NUREG‒2157 6-58 September 2013

1 Table 6-4. Summary of the Cumulative Impacts from Continued Storage When Added to Other 

2 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 No disproportionately high and adverse impacts

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 SMALL SMALL to 

MODERATE

SMALL to 

MODERATE

Aquatic Ecology SMALL SMALL SMALL to LARGE

Historic and Cultural Resources SMALL, 

MODERATE, or 

LARGE

SMALL, 

MODERATE, or 

LARGE

SMALL, 

MODERATE, or 

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
Cumulative Impacts

September 2013 6-59 Draft NUREG‒2157

1 6.6 References

2 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

3 Protection Against Radiation.”

4 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

5 Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

6 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

7 Transportation of Radioactive Material.”

8 10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing 

9 Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

10 Waste, and Reactor-Related Greater Than Class C Waste.”

11 29 CFR Part 1910. Code of Federal Regulations, Title 29, Standards, Part 1910, “Occupational 

12 Safety and Health Standards.”

13 29 CFR Part 1926. Code of Federal Regulations, Title 29, Standards, Part 1926, “Safety and 

14 Health Regulations for Construction.”

15 40 CFR Part 1508. Code of Federal Regulations, Title 40, Protection of Environment, 

16 Part 1508, “Terminology and Index.”

17 49 CFR Parts 171–180. Code of Federal Regulations, Title 49, Transportation, Parts 171−177, 

18 “Hazardous Materials Regulations” and Parts 178−180, “Pipeline and Hazardous Materials 

19 Safety Administration Department of Transportation.”

20 51 FR 30028. August 21, 1986. “Safety Goals for the Operations of Nuclear Power Plants; 

21 Policy Statement; Republication.” Federal Register. U.S. Nuclear Regulatory Commission.

22 69 FR 52040. August 24, 2004. “Policy Statement on the Treatment of Environmental Justice

23 Matters in NRC Regulatory and Licensing Actions.” Federal Register. U.S. Nuclear Regulatory 

24 Commission.

25 74 FR 66496. December 15, 2009. “Endangerment and Cause or Contribute Findings for 

26 Greenhouse Gases Under Section 202(a) of the Clean Air Act.” Federal Register. 

27 U.S. Environmental Protection Agency. 

28 75 FR 31514 June 3, 2010. “Prevention of Significant Deterioration and Title V Greenhouse 

29 Gas Tailoring Rule.” Federal Register. U.S. Environmental Protection Agency. 
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Draft NUREG‒2157 6-60 September 2013

1 76 FR 4134. January 18, 2013. “Availability of the Draft Finding of No Significant Impact and 

2 Final Programmatic Environmental Assessment for Army 2020 Force Structure Realignment.” 

3 Federal Register. U.S. Army Environmental Command.

4 Blue Ribbon Commission (Blue Ribbon Commission on America’s Nuclear Future). 2012. 

5 “Report to the Secretary of Energy.” U.S. Department of Energy, Washington, D.C. Accession 

6 No. ML120970375.

7 CEQ (Council on Environmental Quality). 1997. Considering Cumulative Effects under the 

8 National Environmental Policy Act. Washington, D.C. Accession No. ML12243A349.

9 CEQ (Council on Environmental Quality). 2003. The NEPA Task Force Report to the Council 

10 on Environmental Quality – Modernizing NEPA Implementation. Washington, D.C. Accession 

11 No. ML100840639.

12 CYAPC (Connecticut Yankee Atomic Power Company). 2012. Haddam Neck Plant 

13 Independent Spent Fuel Storage Installation Decommissioning Study. ML123630241.

14 DOE (U.S. Department of Energy). 1996. Dry Transfer System Topical Safety Analysis Report. 

15 Volume 1, Washington, D.C. Accession No. ML052220472.

16 DOE (U.S. Department of Energy). 2008. Final Supplemental Environmental Impact Statement 

17 for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive 

18 Waste at Yucca Mountain, Nye County, Nevada. DOE EIS–0250F–S1, Office of Civilian 

19 Radioactive Waste Management, Las Vegas, Nevada. Accession No. ML081750212.

20 DOE (U.S. Department of Energy). 2013. Strategy for the Management and Disposal of Used 

21 Nuclear Fuel and High-Level Radioactive Waste. Washington, D.C. Accession 

22 No. ML13011A138.

23 EIA (Energy Information Administration). 2011. Electric Power Annual 2010 Data Tables. 

24 Washington, D.C. Available at http://www.eia.gov/electricity/annual/. 

25 EIA (Energy Information Administration). 2012a. Annual Energy Outlook 2013 Early Release 

26 Overview. Washington, D.C. Available at http://www.eia.gov/forecasts/aeo/er/. 

27 EIA (Energy Information Administration). 2012b. Annual Energy Outlook 2012. 

28 DOE/EIA-0383(2012), Washington, D.C. Available at 

29 http://www.eia.gov/forecasts/aeo/pdf/0383(2012).pdf. 

30 EIA (Energy Information Administration). 2012c. Number and Capacity of Petroleum 

31 Refineries. Washington, D.C. Available at 

32 http://www.eia.gov/dnav/pet/pet_pnp_cap1_dcu_nus_a.htm.
Cumulative Impacts

September 2013 6-61 Draft NUREG‒2157

1 EIA (Energy Information Administration). 2012d. 2011 Uranium Marketing Annual Report. 

2 (released May 2012). Available at http://www.eia.gov/uranium/marketing/pdf/2011umar.pdf.

3 EPA (U.S. Environmental Protection Agency). 1999. Consideration of Cumulative Impacts in 

4 EPA Review of NEPA Documents. EPA 315–R–99–002, Washington, D.C. Accession

5 No. ML040081036.

6 EPA (U.S. Environmental Protection Agency). 2012a. Inventory of U.S. Greenhouse Gas

7 Emissions and Sinks: 1900–2010. EPA 430–R12–001, Washington, D.C. Available at 

8 http://www.ntis.gov/search/product.aspx?ABBR=PB2012109114. 

9 EPA (U.S. Environmental Protection Agency). 2012b. Clean Energy. Calculations and 

10 Reference, Washington, D.C. Accession No. ML12292A648.

11 EREF (Environmental Research and Education Foundation). 1999. Lifecycle Inventory of a 

12 Modern Municipal Solid Waste Landfill. Washington, D.C. Available at 

13 http://erefdn.org/publications/uploads/LifeCycleInvRep.pdf. 

14 GCRP (U.S. Global Change Research Program). 2009. Global Climate Change Impacts in the 

15 U.S. T.R. Karl, J.M. Melillo, and T.C. Peterson (eds.). Cambridge University Press, New York. 

16 Accession No. ML100580077.

17 INGAA (Interstate Natural Gas Association of America). 2011. North American Midstream 

18 Infrastructure Through 2035 - A Secure Energy Future.” Washington, D.C. Available at 

19 http://www.ingaa.org/File.aspx?id=14900.

20 IPCC (Intergovernmental Panel on Climate Change). 2007. Climate Change 2007: The 

21 Physical Science Basis. Contribution of Working Group I to the Fourth Assessment, New York, 

22 New York. Available at 

23 http://www.ipcc.ch/publications_and_data/publications_ipcc_fourth_assessment_report_wg1_re

24 port_the_physical_science_basis.htm. 

25 MYAPC (Maine Yankee Atomic Power Company). 2013. Maine Yankee Independent Spent 

26 Fuel Storage Installation Decommissioning Funding Plan. Wiscasset, Maine. Accession 

27 No. ML130460347.

28 National Environmental Policy Act of 1969. USC 4321−4347.

29 NPC (National Petroleum Council). 2007. Topic Paper #16: Refining and Manufacturing. 

30 Washington, D.C. Available at http://www.npc.org/Study_Topic_Papers/16-STG31 RefiningManu.pdf.
Cumulative Impacts

Draft NUREG‒2157 6-62 September 2013

1 NPC (National Petroleum Council). 2011. Paper #1.9. Natural Gas Infrastructure. 

2 Washington, D.C.

3 NPSCC (National Parks Second Century Commission). 2009. Advancing the National Park 

4 Idea: National Parks Second Century Commission Report. Washington, D.C. Available at 

5 http://www.nps.gov/civic/resources/Commission)Report.pdf.

6 National Research Council. 2009. Driving and the Built Environment: The Effects of Compact 

7 Development on Motorized Travel, Energy Use, and CO2 Emissions. Special Report 298, 

8 Washington, D.C. Available at http://onlinepubs.trb.org/Onlinepubs/sr/sr298.pdf.

9 NRC (U.S. Nuclear Regulatory Commission). 1977. Final Environmental Statement on 

10 Transportation of Radioactive Material by Air and Other Modes. NUREG−0170, Volume 1, 

11 Washington, D.C. Accession Nos. ML022590265, ML022590348.

12 NRC (U.S. Nuclear Regulatory Commission). 2000. Consolidated Guidance About Materials 

13 Licenses: Guidance About Administrative Licensing Procedures. NUREG−1556, Vol. 20, 

14 Washington, D.C. Accession No. ML022830863.

15 NRC (U.S. Nuclear Regulatory Commission). 2001a. Final Environmental Impact Statement for 

16 the Construction and Operation of an Independent Spent Fuel Storage Installation on the 

17 Reservation of the Skull Valley Band of Goshute Indians and the Related Transportation Facility 

18 in Tooele County, Utah. NUREG−1714, Volume 1, Washington, D.C. Accession

19 No. ML020150170.

20 NRC (U.S. Nuclear Regulatory Commission). 2001b. Technical Study of Spent Nuclear Fuel 

21 Pool Accident Risk at Decommissioning Nuclear Power Plants. NUREG−1738, 

22 Washington, D.C. Accession No. ML010430066.

23 NRC (U.S. Nuclear Regulatory Commission). 2002. Generic Environmental Impact Statement 

24 on Decommissioning of Nuclear Facilities Supplement 1 Regarding the Decommissioning of 

25 Nuclear Power Reactors. NUREG−0586, Supplement 1, Volume 1, Washington D.C. 

26 Accession No. ML023470327.

27 NRC (U.S. Nuclear Regulatory Commission). 2003. Environmental Assessment Related to the 

28 Construction and Operation of the Diablo Canyon Independent Spent Fuel Storage Installation. 

29 Washington, D.C. Accession No. ML032970370.

30 NRC (U.S. Nuclear Regulatory Commission). 2005a. Environmental Assessment Related to 

31 the Renewal of the License for the Surry Independent Spent Fuel Storage Installation. 

32 Washington, D.C. Accession No. ML040560238.
Cumulative Impacts

September 2013 6-63 Draft NUREG‒2157

1 NRC (U.S. Nuclear Regulatory Commission). 2005b. Environmental Assessment Related to 

2 the Renewal of the H.B. Robinson Steam Electric Plant, Unit No. 2 Independent Spent Fuel 

3 Storage Installation License Special Nuclear Materials License No. SNM–2502. 

4 Washington, D.C. Accession No. ML050700137.

5 NRC (U.S. Nuclear Regulatory Commission). 2005c. Environmental Assessment Related to 

6 the Construction and Operation of the Humboldt Bay Independent Spent Fuel Storage 

7 Installation. Washington, D.C. Accession No. ML052430106.

8 NRC (U.S. Nuclear Regulatory Commission). 2005d. Generic Environmental Impact Statement 

9 for License Renewal of Nuclear Plants Supplement 23 Regarding Point Beach Nuclear Plant 

10 Units 1 and 2. Washington, D.C. Accession No. ML052230490.

11 NRC (U.S. Nuclear Regulatory Commission). 2006. Final Environmental Statement for an 

12 Early Site Permit (ESP) at the North Anna ESP Site. NUREG−1811, Volume 1,

13 Washington, D.C. Accession No. ML063470330.

14 NRC (U.S. Nuclear Regulatory Commission). 2008. Final Environmental Statement for an 

15 Early Site Permit (ESP) at the Vogtle Electric Generating Plant Site. NUREG−1872, Volume 1, 

16 Washington, D.C. Accession No. ML082240145.

17 NRC (U.S. Nuclear Regulatory Commission). 2009. Environmental Assessment for the 

18 Renewal of U.S. Nuclear Regulatory Commission License No. SNM–2503 for Oconee Nuclear 

19 Power Station Independent Spent Fuel Storage Installation. Washington, D.C. Accession 

20 No. ML091340557.

21 NRC (U.S. Nuclear Regulatory Commission). 2011a. Final Environmental Impact Statement for 

22 Combined Licenses (COLs) for South Texas Project Electric Generating Station Units 3 and 4. 

23 NUREG−1937, Washington, D.C. Accession No. ML11049A000.

24 NRC (U.S. Nuclear Regulatory Commission). 2011b. Final Supplemental Environmental 

25 Impact Statement for Combined Licenses (COLs) for Vogtle Electric Generating Plant Units 3 

26 and 4. NUREG−1947, Washington, D.C. Accession No. ML11270A216.

27 NRC (U.S. Nuclear Regulatory Commission). 2011c. Final Environmental Impact Statement for 

28 Combined Licenses (COLs) for Virgil C. Summer Nuclear Station, Units 2 and 3. 

29 NUREG−1939, Volumes 1 and 2, Washington, D.C. Accession Nos., ML11098A044, 

30 ML11098A057.

31 NRC (U.S. Nuclear Regulatory Commission). 2011d. Final Environmental Impact Statement for 

32 Combined Licenses for Calvert Cliffs Nuclear Power Plant Unit 3. NUREG−1936, Volumes 1 

33 and 2, Washington, D.C. Accession Nos. ML11129A167, ML11129A179.
Cumulative Impacts

Draft NUREG‒2157 6-64 September 2013

1 NRC (U.S. Nuclear Regulatory Commission). 2011e. Final Environmental Impact Statement for 

2 Combined Licenses for Comanche Peak Nuclear Power Plant Units 3 and 4. NUREG−1943, 

3 Volumes 1 and 2, Washington, D.C. Accession Nos. ML11131A001, ML11131A002.

4 NRC (U.S. Nuclear Regulatory Commission). 2011f. Draft Environmental Impact Statement for 

5 Combined Licenses for William States Lee III Nuclear Station Units 1 and 2. NUREG−2111, 

6 Volumes 1 and 2, Washington, D.C. Accession Nos. ML11343A010, ML11343A011.

7 NRC (U.S. Nuclear Regulatory Commission). 2011g. Generic Environmental Impact Statement 

8 for License Renewal of Nuclear Plants Supplement 44 Regarding Crystal River Unit 3 Nuclear 

9 Generating Plant—Draft Report for Comment. NUREG−1437, Washington, D.C. Accession

10 No. ML11139A153.

11 NRC (U.S. Nuclear Regulatory Commission). 2011h. Generic Environmental Impact Statement 

12 for License Renewal of Nuclear Plants, Supplement 46 Regarding Seabrook Station—Draft 

13 Report for Comment. NUREG–1437, Washington, D.C. Accession No. ML11213A080.

14 NRC (U.S. Nuclear Regulatory Commission). 2011i. Revision 1 – Addressing the Construction 

15 and Preconstruction Activities, Greenhouse Gas Issues, General Conformity Determinations, 

16 Environmental Justice, the Need for Power, Cumulative Impact Analysis and Cultural/Historical 

17 Resources Analysis Issues in Environmental Impact Statements. Washington, D.C. Accession 

18 No. ML110380369.

19 NRC (U.S. Nuclear Regulatory Commission). 2012a. Final Environmental Impact Statement for 

20 Combined Licenses for Levy Nuclear Plant Units 1 and 2. NUREG−1941, Volumes 1 and 2, 

21 Washington, D.C. Accession Nos. ML12100A063, ML12320A105.

22 NRC (U.S. Nuclear Regulatory Commission). 2012b. 2012–2013 Information Digest. 

23 NUREG–1350, Volume 24, Washington, D.C. Available at http://www.nrc.gov/reading-rm/doc24 collections/nuregs/staff/sr1350/v24/sr1350v24.pdf. 

25 NRC (U.S. Nuclear Regulatory Commission). 2012c. Environmental Assessment for the 

26 Proposed Renewal of U.S. Nuclear Regulatory Commission License No. SNM–2505 for 

27 Calvert Cliffs Nuclear Power Plant, LLC’s Independent Spent Fuel Storage Installation. 

28 Washington, D.C. Accession No. ML121220084.

29 NRC (U.S. Nuclear Regulatory Commission). 2012d. Generic Environmental Impact Statement 

30 for License Renewal of Nuclear Plants Supplement 47 Regarding Columbia Generating Station. 

31 NUREG–1437, Washington, D.C. Accession No. ML12096A334.
Cumulative Impacts

September 2013 6-65 Draft NUREG‒2157

1 NRC (U.S. Nuclear Regulatory Commission). 2012e. Spent Fuel Transportation Risk

2 Assessment Draft Report for Comment. NUREG−2125, Washington D.C. Accession 

3 No. ML12125A218.

4 NRC (U.S. Nuclear Regulatory Commission). 2013a. Generic Environmental Impact Statement 

5 for License Renewal of Nuclear Plants. NUREG−1437, Revision 1, Washington, D.C. 

6 Accession No. ML13107A023. 

7 NRC (U.S. Nuclear Regulatory Commission). 2013b. Environmental Impact Statement for the 

8 Combined License (COL) for Enrico Fermi Unit. NUREG−2105, Volumes 1 and 2, 

9 Washington, D.C. Accession Nos. ML12307A172, ML12307A176.

10 U.S. Nuclear Regulatory Commission (NRC). 2013c. Spent Fuel Storage in Pools and Dry 

11 Casks Key Points and Questions and Answers. Washington, D.C. Accession

12 No. ML120970230.

13 Nuclear Waste Policy Act of 1982. 42 USC 10101, et seq. 

14 Pitkin, J. and D. Myers. 2008. U.S. Housing Trends: Generational Changes and the Outlook to 

15 2050. Special Report 298, National Research Council, Washington, D.C. Available at 

16 http://onlinepubs.trb.org/Onlinepubs/sr/sr298pitkin-myers.pdf.

17 Sprung, J.L., D.J. Ammerman, N.L. Breivik, R.J. Dukart, F.L. Kanipe, J.A. Koski, G.S. Mills, 

18 K.S. Neuhauser, H.D. Radloff, R.F. Weiner, and H.R. Yoshimura. 2000. Reexamination of 

19 Spent Fuel Shipment Risk Estimates. NUREG/CR−6672, Washington, D.C. Accession 

20 No. ML003698324.

21 Texas Water Development Board. 2012. Water for Texas: 2012 State Water Plan. Austin, 

22 Texas. Available at 

23 http://www.twdb.state.tx.us/publications/state_water_plan/2012/2012_SWP.pdf.

24 USACE (U.S. Army Corps of Engineers). 2006. U.S. Water Demand, Supply, and Allocation: 

25 Trends and Outlook. Report 2007–R–3, Washington, D.C. Available at 

26 http://www.iwr.usace.army.mil/Portals/70/docs/iwrreports/2007-R-03.pdf. 

27 USCB (U.S. Census Bureau). 2012. Population Projections. Washington, D.C. Available at 

28 http://www.census.gov/population/projections/. 

29 USDA (U.S. Department of Agriculture). 2012. USDA Agricultural Projections to 2021. Long30 Term Projections Report OCE–2012–1, Washington, D.C. Available at 

31 http://www.usda.gov/oce/commodity/archive_projections/USDAAgriculturalProjections2021.pdf.

32 Yankee Atomic Electric Company (YAEC). 2012. Yankee Rowe Decommissioning Study Plan. 

33 Rowe, Massachusetts.

September 2013 7-1 Draft NUREG‒2157

1 7.0 Cost-Benefit Analysis

2 In this chapter, the U.S. Nuclear Regulatory Commission (NRC) analyzes and compares the 

3 benefits and costs associated with the proposed action, other action alternatives, and the 

4 no-action alternative. This chapter, along with the rest of this “Waste Confidence Generic 

5 Environmental Impact Statement” (draft GEIS), informs the NRC’s decision regarding which 

6 alternative to implement. Each of the action alternatives satisfies the purpose and need for this 

7 draft GEIS, which is to (1) improve the efficiency of the NRC’s licensing process by generically 

8 addressing the environmental impacts of continued storage, (2) prepare a single document that 

9 reflects the NRC’s current understanding of these environmental impacts, and (3) respond to 

10 the issues identified in the remand by the Court in the New York v. NRC decision (State of 

11 New York et al. v. NRC 2012). 

12 Each alternative provides a means for the NRC to address, in its environmental review 

13 documents, the environmental impacts of continued spent fuel storage (continued storage) at a 

14 reactor site or at an away-from-reactor storage facility. In Chapters 4 and 5 of this draft GEIS, 

15 the NRC discusses the potential impacts of continued at-reactor and away-from-reactor storage, 

16 respectively, that may occur under three different continued-storage timeframes. In Chapter 6, 

17 the NRC addresses the potential cumulative impacts of continued storage.

18 The alternatives considered in this chapter do not noticeably alter the environmental impacts 

19 from continued storage that the NRC addressed in Chapters 4, 5, and 6. The alternatives 

20 considered in this chapter instead provide different approaches that the NRC could apply to 

21 future licensing activities that can satisfy the agency’s responsibility to consider the potential 

22 environmental impacts of continued storage in deciding whether to issue certain licenses. As a 

23 result, the costs and benefits shown in this chapter include the specific costs and benefits of the 

24 several alternatives. The costs and benefits do not include the environmental impacts of 

25 continued storage, an activity that will occur regardless of the alternative that the NRC selects to 

26 consider its impacts.

27 Section 7.1 of this chapter contains the assumptions underlying the NRC’s cost-benefit analysis. 

28 Section 7.2 contains the costs and benefits of the no-action alternative, while Section 7.3 

29 contains the costs and benefits of the proposed action. Section 7.4 contains the costs and 

30 benefits of the GEIS-only alternative, and Section 7.5 contains the costs and benefits of the 

31 policy-statement alternative. Finally, Section 7.6 contains a summary and comparison of the 

32 costs and benefits of all alternatives. Additional details about the NRC’s estimated cost 

33 calculations are available in Appendix H, Estimated Cost of Alternatives.
Cost-Benefit Analysis

Draft NUREG‒2157 7-2 September 2013

1 7.1 Assumptions 

2 Throughout this chapter, the NRC projects the estimated costs and benefits of alternative ways 

3 the agency can consider the environmental impacts of continued storage. To the extent that the 

4 NRC considers cost information, the NRC presents figures in constant 2013 dollars and by 

5 applying 3 percent and 7 percent discount rates, as provided in Office of Management and 

6 Budget (OMB) Circular A–4 (OMB 2003) and NUREG/BR−0058, Revision 4, “Regulatory 

7 Analysis Guidelines for the U.S. Nuclear Regulatory Commission” (NRC 2004).

8 In this analysis, the NRC projects the costs of each alternative from fiscal year 2015 (October 

9 2014 through September 2015) through fiscal year 2044 (October 2043 through September 

10 2044). The NRC adopted this 30-year time period based on the example provided in OMB 

11 Circular A–4 and based on the approximate cumulative time period for which previous versions 

12 of the Waste Confidence rule (Title 10 of the Code of Federal Regulations Section 51.23 

13 [10 CFR 51.23]) have existed. The 30-year time period allows for meaningful comparisons 

14 among alternatives. The 30-year time period begins in the month after the Waste Confidence 

15 rulemaking is currently scheduled for completion.

16 The NRC made reasonable assumptions for current and future licensing reviews that inform the 

17 NRC’s cost estimates. This analysis considers site-specific licensing reviews over 30 years that 

18 would rely on 10 CFR 51.23 to address the environmental impacts of continued storage. All 

19 assumptions related to NRC costs for continued storage include costs associated with the 

20 additional NRC efforts on National Environmental Policy Act of 1969, as amended (NEPA) 

21 reviews as well as NRC participation in adjudicatory hearings, as appropriate.

22 The draft GEIS assumptions are based in part on NRC projections of current and likely licensing 

23 reviews (see, for example, SECY–12–0132 for a list of applications currently under review or 

24 projected through the end of 2014 [NRC 2012a]). The assumptions address three important 

25 licensing actions: new reactor applications (pursuant to 10 CFR Part 50 or Part 52), reactor 

26 license renewal applications (pursuant to 10 CFR Part 54), and site-specific independent spent 

27 fuel storage installations (ISFSI) applications (pursuant to 10 CFR Part 72).

28 The NRC assumes that applicants for new or renewed licenses affected by the Waste 

29 Confidence rule would incur costs in the absence of a Waste Confidence rule equal to those the 

30 NRC incurs in addressing the impacts of continued storage. As a result, the total costs for site31 specific reviews are double the NRC’s costs discussed in this chapter. Quantified totals in the 

32 tables in this chapter include industry costs. The NRC assumes that applicants will incur 

33 additional costs by developing applications that address the environmental impacts of continued 

34 storage, responding to the NRC’s requests for additional information related to continued 

35 storage, and participating in any adjudicatory proceedings related to continued storage.
Cost-Benefit Analysis

September 2013 7-3 Draft NUREG‒2157

1 The NRC calculated its estimated costs based on anticipated staff time—measured in full-time 

2 equivalents, or FTEs—and anticipated contractor effort, where applicable, measured in contract 

3 dollars. The average cost for one NRC staff FTE is $173,000 per year, which is based on the 

4 methodology provided in NUREG/CR−4627, “Generic Cost Estimates” (Sciacca 1992). The 

5 NRC’s estimates of potential licensing actions and associated cost calculations are available in 

6 Appendix H, Estimated Costs of Alternatives. 

7 7.1.1 New Reactor Applications

8 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).1 9 In reviewing 

10 each COL and ESP application, the NRC develops a site-specific environmental impact 

11 statement (EIS) that addresses the potential environmental impacts of the proposed facility. 

12 The NRC assumes that the first site-specific review of the environmental impacts of continued 

13 storage would require more time and effort than subsequent reviews because the first 

14 application would be developed with a general approach that could then be used in subsequent 

15 application reviews.

16 In general, COL and ESP application reviews take longer and require more staff effort to 

17 complete than other NRC reviews that rely on the Waste Confidence rule. Among other factors, 

18 COL and ESP applications frequently include cooperating agencies, while COL proceedings 

19 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 supplement2 20

21 would require approximately 3.9 FTEs, or $675,000, and $1 million in contractor support (total of 

22 $1.67 million), based on staff experience supplementing COL EISs. The NRC estimates that 

 

1 One of the COL applications currently under review, Calvert Cliffs Unit 3, is subject to substantial 

uncertainty. An NRC Atomic Safety and Licensing Board (ASLB) found that the plant’s applicants are 

ineligible to receive a COL because the applicants are wholly owned by a foreign company, in violation of 

Commission policy based on Section 103d of the Atomic Energy Act (LBP-12-19). On March 11, 2013, 

the Commission denied the applicants’ appeal of the ASLB’s decision (CLI–13–04) (NRC 2013a). 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 retained the Calvert Cliffs Unit 3 COL application. 2 Under 10 CFR 51.92(a), the NRC 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

Draft NUREG‒2157 7-4 September 2013

1 the next two reviews will require supplementation of existing EISs at a cost of approximately 

2 2.9 FTEs, or $502,000, and $500,000 in contract support (a total of $1.00 million) each. The 

3 NRC estimates that the remaining new reactor reviews, which do not require supplementation, 

will require 0.3 FTE, or $51,900.3 4 See Appendix H, Table H-1, in for new reactor cost 

5 calculations.

6 As noted in Chapter 2 of this draft GEIS, the NRC is currently engaged in preapplication 

7 activities with several applicants for light water small modular reactors. Because the light water 

8 reactor fuel that would be used in iPWR (integral pressurized water reactors; a type of small 

9 modular reactor) designs is substantially similar to existing light water reactor fuel (i.e., zircaloy 

10 clad, low-enriched uranium oxide pellets in square cross-section fuel rod arrays), iPWR fuel is 

11 within the scope of the draft GEIS analysis. The NRC expects to receive applications for NRC

12 review and approval of small modular designs pursuant to 10 CFR Part 52 as early as 2013 

13 (NRC 2013b), but there is no current plan for the NRC to receive or begin review of applications 

14 for specific small modular reactor power plants.

15 Design certification reviews for iPWRs would not require assessments of the impacts of 

16 continued storage, but licensing reviews for specific sites would require such assessments. At 

17 the time of this draft GEIS publication, only one licensee, the Tennessee Valley Authority (TVA), 

18 has expressed an interest in pursuing construction permits pursuant to 10 CFR Part 50 for two 

19 to six small modular reactors, with potential subsequent units licensed pursuant to 10 CFR 

20 Part 52 (NRC 2013c). In 2011, TVA informed the NRC of its intent to submit a construction 

21 permit application in 2012 (TVA 2011), but TVA has not submitted such an application as of the 

22 draft GEIS publication date.

23 As a result of the substantial uncertainties associated with future small modular reactor licensing 

24 reviews, the NRC has not included any small modular reactors in its cost projections. Beyond 

25 the uncertainty related to applications, there is some uncertainty about review costs for small 

26 modular reactor applications. It is reasonable to assume, however, that the effort necessary to 

27 address the environmental impacts of continued storage for small modular reactors will be similar 

28 to the effort necessary to address the environmental impacts of continued storage for other new 

29 reactor applications. If applicants develop and submit applications for small modular reactors to 

30 the NRC, then each additional review activity would require an estimated 0.3 FTE, or $51,900.

 

3 An additional facility, Watts Bar Nuclear Plant, Unit 2, is a proposed new reactor currently undergoing an 

operating license review under 10 CFR Part 50. The NRC projects that Watts 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 $242,000. 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

September 2013 7-5 Draft NUREG‒2157

1 7.1.2 Reactor License Renewal

2 The NRC currently has 10 reactor license renewals under review (see Appendix H, Table H-2, 

3 for a list of applications). An approved license renewal may add up to 20 years of additional 

4 operation to an existing commercial power reactor license (10 CFR 54.31(b)).

5 In the course of reviewing a license renewal application, the NRC prepares a site-specific 

6 supplement to the GEIS for License Renewal of Nuclear Plants (License Renewal GEIS, or 

7 NUREG−1437). A supplemental EIS for license renewal requires less time and effort than a 

8 COL or ESP EIS because the License Renewal GEIS has already addressed many 

9 environmental issues, the plant under review has typically been operating at the site for at least 

10 20 years (avoiding the need for a review of alternative sites for the proposed renewal) and its 

11 effects on the environment tend to be well understood, and because license renewal typically 

12 involves no new construction. In addition, license renewal EISs typically do not include 

13 cooperating agencies and do not require mandatory hearings.

14 The NRC projects that the first site-specific review of continued storage in a supplemental EIS 

15 for license renewal would require more time and effort than subsequent reviews in order to 

16 develop a general approach that subsequent reviews would then use. The first review would 

17 require an estimated 2.5 FTEs, or $433,000 based on NRC experience supplementing license 

18 renewal EISs. The NRC further projects that some reviews would require supplementation of 

19 existing EISs, and these reviews would require approximately 1.4 FTEs, or $242,000. Reviews 

20 that have already begun but that do not require supplementation would require approximately 

21 1.1 FTEs, or $190,000. Reviews of applications that have not yet been submitted would require 

22 approximately 0.3 FTE, or $51,900, or the same amount of effort as new reactor reviews that do 

23 not require supplementation. In addition to reviews already received, the NRC projects that all 

24 plants that have yet to apply for license renewal would apply for renewal by 2020 for purposes 

of this analysis (NRC 2013d).4 25 See Appendix H, Table H-2, for license renewal cost 

26 calculations.

27 Further, the NRC assumes that approximately half of the existing reactor fleet will apply for 

28 subsequent license renewal (which could allow plants to operate for up to 80 years) beginning in 

29 2017. The NRC estimates that it will review a total of 28 applications—or one application per 

30

 

4 Watts Bar Nuclear Plant, Unit 1 is the only unit licensed under 10 CFR Part 50 that does not have a 

renewed license because it is not yet eligible to request renewal. The NRC assumes that this facility will 

undergo a license renewal review for purposes of this analysis. 
Cost-Benefit Analysis

Draft NUREG‒2157 7-6 September 2013

year—from 2017 through the end of 2044.5 1 The NRC assumes that the continued storage 

2 portion of these NEPA reviews will be substantially similar to the reviews performed during the 

3 initial license renewal review. The NRC estimates that subsequent license renewal reviews will 

4 require an estimated 0.3 FTE, or $51,900. 

5 7.1.3 ISFSI Licensing

6 Currently, 15 sites possess site-specific ISFSI licenses (NRC 2013e), and one potential 

applicant has expressed an interest in licensing a new away-from-reactor ISFSI (ELEA 2013).6 7 

8 The majority of existing ISFSIs, however, are generally licensed. The NRC does not perform a 

9 site-specific renewal review for generally licensed ISFSIs; rather, historically, the NRC has 

10 performed an environmental assessment (EA) (with a finding of no significant impact [FONSI]) 

11 for each available cask design, and the facilities’ ability to possess nuclear materials is subject 

12 to its 10 CFR Part 50 (or 10 CFR Part 52) license. As a result, the NRC assumes, for purposes 

13 of this analysis, that there are no costs associated with general ISFSI licensing related to 

14 considering the environmental impacts of continued storage during the 30-year analysis period.

15 The licensed term for a site-specific licensed ISFSI must not exceed 40 years 

16 (10 CFR 72.42(a)). During site-specific ISFSI licensing (new licenses and license renewals), 

17 the NRC typically develops an EA that concludes with a FONSI. To date, every site-specific 

18 ISFSI EA has reached a FONSI.

19 The NRC estimates that approximately 0.5 FTE, or $86,500, is necessary to support site20 specific considerations of Waste Confidence matters in the first two ISFSI EAs, both of which 

21 are currently under review. The NRC estimates that later ISFSI EAs will require 0.25 FTE, or 

22 $43,300. See Appendix H, Table H-3, for ISFSI-related cost calculations and a list of affected 

23 actions.

 

5 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 that host commercial power reactors with 10 CFR Part 50 

operating licenses or both 10 CFR Part 50 operating licenses and 10 CFR Part 52 combined licenses. Of 

these sites, licensees have indicated that they will cease nuclear operations at three of them (Kewaunee, 

Crystal River, and Oyster Creek). Of the remaining 58 sites, licensees at three sites could apply for 

license renewal after 2044 and still submit timely renewal applications (Comanche Peak Units 1 and 2, 

Seabrook, and Watts Bar Nuclear Plant, Unit 1). Because the NRC assumes that approximately half of 

the licensees will apply for initial or subsequent license renewal, the NRC includes 28 initial or 

subsequent-renewal reviews in this analysis. The 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.

6 Private Fuel Storage (PFS)—an away-from-reactor facility—holds a site-specific license, but has not 

taken delivery of spent fuel, and has recently requested that the NRC terminate its license (PFS 2012). 

The NRC has retained PFS in this analysis, to represent a future away-from-reactor facility.
Cost-Benefit Analysis

September 2013 7-7 Draft NUREG‒2157

1 7.2 Estimated Costs and Benefits of the No-Action 

2 Alternative 

3 Under the no-action alternative, the NRC would neither implement a new Waste Confidence rule 

4 supported by a GEIS nor would it implement any other alternative considered in this draft GEIS. 

5 The NRC would review the generic environmental impacts from continued storage in licensing6 specific NEPA reviews that the NRC performs for new reactor licensing, reactor license renewal, 

7 ISFSI licensing, and ISFSI license renewal (see Appendix H, Table H-1, Table H-2, and 

8 Table H-3 for affected actions and their respective estimated costs). The NRC and license 

9 applicants incur the majority of the costs from the no-action alternative. Costs also accrue 

10 through NRC adjudicatory activities, which affect the NRC, license applicants, and petitioners or 

11 interveners. In general, expenses to petitioners are case-specific and difficult to quantify, so the 

12 NRC has not quantified them here. Table 7-1 contains cost estimates for the no-action 

13 alternative based on the detailed information presented in Appendix H.

14 Table 7-1. Constant and Discounted Estimated Costs of the No-Action Alternative

Components(a)

Estimated Costs (millions of dollars)

Constant Dollars 3% Discount Case 7% Discount Case

Site-Specific Review Costs $24.3 $21.4 $18.6

GEIS Costs - - -

Rulemaking Costs - - -

Policy Statement Costs - - -

Estimated Total Cost $24.3 $21.4 $18.6

(a) Table 7-1, Table 7-2, Table 7-3, and Table 7-4 contain line items for site-specific review costs, GEIS costs, 

rulemaking costs, and policy statement costs. Here, the no-action alternative does not include a GEIS, 

rulemaking, or a policy statement, so the NRC includes no costs for those components in Table 7-1. The NRC 

populates subsequent tables according to the components included in each subsequent alternative.

15 The primary quantifiable benefit of the no-action alternative is that the NRC would not need to 

16 prepare a GEIS and rule or a policy statement. In addition, there is a public-perception benefit 

17 from the NRC’s reviewing the environmental impacts of continued storage in site-specific 

18 licensing actions. In a site-specific NEPA analysis, the NRC would describe location-specific 

19 conditions, address the site-specific impacts of a potential licensing action, and address the 

20 impacts of continued storage. The value of reviewing continued storage in site-specific NEPA 

21 analyses is difficult to quantify; however, a site-specific analysis of the environmental impacts of 

22 continued storage would likely not reveal any new information that cannot be addressed in a 

23 generic analysis.

24 Another cost of the no-action alternative relates to increased scheduling uncertainties in 

25 licensing due to additional environmental reviews and potential increased litigation associated 
Cost-Benefit Analysis

Draft NUREG‒2157 7-8 September 2013

1 with continued storage. The effects of schedule uncertainties are likely to be most significant for 

2 new reactor or new site-specific ISFSI applicants. Delays can be more costly for new reactor 

3 applicants, which could incur billions of dollars of additional expenses if a project is delayed. 

4 These costs can include increased financing costs, longer-term accumulation of interest on 

5 debt, replacement-power costs, and contractual penalties. Because these costs are highly 

6 case-specific, the NRC has not attempted to quantify them.

7 Applicants for renewed reactor and site-specific ISFSI licenses that submit timely and sufficient 

8 renewal applications are protected from schedule uncertainty, at least insofar as continued 

9 operations are concerned, by 10 CFR 2.109. Specifically, 10 CFR 2.109 allows for operations

10 of reactors and ISFSIs until such applications have been finally determined, even if final 

11 determination takes place after the license expiration date. Nonetheless, delays may affect 

12 applicants’ plans to commence activities that may depend upon renewed licenses. Because

13 these types of expenses vary significantly and are case-specific, the NRC has not attempted to 

14 quantify them.

15 7.3 Estimated Costs and Benefits of the Proposed Action

16 In the proposed action, the NRC implements a regulatory approach that includes an update to 

17 the Waste Confidence rule, 10 CFR 51.23, that codifies the results of this draft GEIS. The 

18 update would clarify that, because the impacts of continued storage have been generically 

19 assessed in a GEIS and codified in a rule, the NEPA analyses for future reactor and spent fuel 

20 storage facility licensing actions would not need to independently consider the environmental 

21 impacts of continued storage. The Rule also serves to preclude any challenge to the NRC’s 

22 assessment of the environmental impacts of continued storage in a site-specific licensing action, 

23 unless a petitioner can show that sufficient “special circumstances” exist to justify waiving 

24 10 CFR 51.23 in a particular proceeding (10 CFR 2.335).

25 The primary benefit of the proposed action is that it eliminates the costs associated with sitespecific licensing reviews of issues related to the environmental impacts of continued storage.7 26 

27 In addition, this approach is generally consistent with Council on Environmental Quality (CEQ) 

28 guidance regarding efficiency and timeliness under NEPA (77 FR 14473).

29 As shown in Table 7-2, preparation of the GEIS and Rule incurs costs not incurred under the 

30 no-action alternative. The NRC estimates that the proposed action will require approximately 

31 23 FTEs, or $3.98 million, in each of 2013 and 2014, or $8 million total (undiscounted). In 

32 addition, the proposed action will require an estimated $6 million (undiscounted) of contract 

 

7 While there may be some costs associated with developing a generic statement on continued storage 

within a site-specific NEPA document, as well as responding to potential adjudicatory issues related to 

continued storage, these costs are assumed to be negligible. Therefore, the site-specific review costs are 

assumed to be $0 for this analysis.
Cost-Benefit Analysis

September 2013 7-9 Draft NUREG‒2157

1 support spread across the 2 years. Most of the expenditures associated with the proposed 

2 action will occur as a result of the GEIS development. The NRC estimates that approximately 

3 6 FTE, or $1.04 million, of the total expenditure is a result of the rulemaking portion of the 

4 proposed action. See Appendix H, Table H-4, for more information regarding GEIS and 

5 rulemaking costs.

6 Table 7-2. Constant and Discounted Estimated Costs of the Proposed Action

Components

Estimated Costs (millions of dollars)

Constant Dollars 3% Discount Case 7% Discount Case

Site-Specific Review Costs - - -

GEIS Costs $12.9 $12.7 $12.5

Rulemaking Costs $1.04 $1.02 $1.00

Policy Statement Costs - - -

Estimated Total Cost(a) $14.0 $13.8 $13.5

(a) Due to rounding, some costs may not appear to sum correctly.

7 7.4 Estimated Costs and Benefits of the GEIS-Only 

8 Alternative 

9 The GEIS-only alternative is similar to the proposed action insofar as the NRC develops and 

10 relies upon a GEIS. It differs because the Commission does not incorporate the GEIS findings

11 into a rule. Because the Commission does not codify the GEIS findings in this alternative, the 

12 environmental impacts of continued storage remain open to site-specific consideration by the 

13 NRC. Petitioners may also challenge an applicant’s or the NRC’s consideration of the impacts 

14 of continued storage without a waiver petition pursuant to 10 CFR 2.335. Reliance on a GEIS to 

15 address generic issues is consistent with CEQ guidance regarding efficiency and timeliness 

16 under NEPA (77 FR 14473).

17 The primary benefit of the GEIS-only alternative relative to the no-action alternative is that it 

18 reduces NRC and applicant costs in conducting site-specific NEPA reviews. The NRC assumes 

19 that applicants will refer to GEIS findings in environmental reports and the NRC will incorporate 

20 GEIS findings and analyses by reference into NEPA documents for new reactor licensing, 

21 reactor license renewals, ISFSI licensing, and ISFSI license renewals. The NRC assumes that 

22 reliance on the GEIS in site-specific reviews may resolve concerns for some issues related to 

23 continued storage, while other issues may require additional effort to resolve comments, 

24 address site-specific litigation, or to establish that the GEIS findings are applicable to a specific 

25 licensing proceeding. As a result, the NRC assumes that the GEIS-only alternative will 

26 decrease the cost to the NRC and applicants by 50 percent compared to the no-action 

27 alternative at best, and at worst will not reduce the NRC and applicant effort compared to the 
Cost-Benefit Analysis

Draft NUREG‒2157 7-10 September 2013

1 no-action alternative. Therefore, the NRC presents the costs of the GEIS-only alternative for 

2 site-specific reviews as a range in Table 7-3. 

3 Table 7-3. Constant and Discounted Estimated Costs of the GEIS-Only Alternative

Components

Estimated Costs (millions of dollars)

Constant Dollars 3% Discount Case 7% Discount Case

Site-Specific Review Costs $12.2 to $24.3 $10.7 to $21.4 $9.31 to $18.6

GEIS Costs $12.9 $12.7 $12.5

Rulemaking Costs - - -

Policy Statement Costs - - -

Estimated Total Cost(a) $25.1 to $37.3 $23.4 to $34.1 $21.8 to $31.1

(a) Due to rounding, costs may appear not to sum correctly.

4 As was the case in the no-action alternative, there is a public-perception benefit from the NRC’s 

5 reviewing the environmental impacts of continued storage in site-specific licensing actions as 

6 part of the GEIS-only alternative. In a site-specific NEPA analysis, the NRC would describe 

7 location-specific conditions, address the site-specific impacts of a potential licensing action, and 

8 address the impacts of continued storage. The value of reviewing continued storage in site9 specific NEPA analyses is difficult to quantify; however, a site-specific analysis of the 

10 environmental impacts of continued storage would likely not reveal any new information that 

11 cannot be addressed in a generic analysis.

12 Preparation of the GEIS, however, requires costs not incurred under the no-action alternative, 

13 as shown in Table 7-3. GEIS preparation requires an estimated 20 FTEs, or $3.46 million, in 

14 each of 2013 and 2014, or $7.92 million total (undiscounted). In addition, GEIS preparation will 

15 require an estimated $6 million of contract support spread across the 2 years. See Appendix H, 

16 Table H-4, for more information regarding GEIS costs.

17 Similar to the no-action alternative, another cost of the GEIS-only alternative relates to 

18 increased scheduling uncertainties in licensing due to additional environmental reviews and 

19 potential increased litigation associated with continued storage. The effects of schedule 

20 uncertainties are likely to be most significant for new reactor or new site-specific ISFSI 

21 applicants. Delays can be more costly for new reactor applicants, which could incur billions of 

22 dollars of additional expenses if a project is delayed. These costs can include increased 

23 financing costs, longer-term accumulation of interest on debt, replacement-power costs, and 

24 contractual penalties. Because these costs vary significantly and are case-specific, the NRC

25 has not attempted to quantify them.

26 Applicants for renewed reactor and site-specific ISFSI licenses that submit timely and sufficient 

27 renewal applications are protected from schedule uncertainty, at least insofar as continued 
Cost-Benefit Analysis

September 2013 7-11 Draft NUREG‒2157

1 operations are concerned, by provisions of 10 CFR 2.109. Specifically, 10 CFR 2.109 allows for 

2 operations of reactors and ISFSIs until such applications have been finally determined, even if 

3 final determination takes place after the license expiration date. Nonetheless, delays may affect 

4 applicants’ plans to commence activities that may depend upon renewed licenses. Because

5 these types of expenses are case-specific, the NRC has not attempted to quantify them.

6 7.5 Estimated Costs and Benefits of the Policy Statement 

7 Alternative 

8 The policy-statement alternative is similar to the GEIS-only alternative. As in the GEIS-only 

9 alternative, the policy-statement alternative would rely on a GEIS to address the environmental 

10 impacts of continued storage. In addition, the Commission would develop a policy statement to 

11 address specific issues and to bind the NRC in its approach to addressing the environmental 

12 impacts of continued storage in site-specific environmental reviews.

13 As in the GEIS-only alternative, the Commission does not incorporate the GEIS findings into a 

14 rule. Because the Commission does not codify the GEIS findings in this alternative, the 

15 environmental impacts of continued storage remain open to site-specific consideration by the 

16 NRC, within the constraints imposed by the Commission’s policy statement. Petitioners may 

17 challenge an applicant’s or the NRC’s consideration of the impacts of continued storage without 

18 a waiver petition pursuant to 10 CFR 2.335 and would not be constrained by the Commission’s 

19 policy statement on continued storage. Reliance on a GEIS, however, to address generic 

20 issues is consistent with CEQ guidance regarding efficiency and timeliness under NEPA

21 (77 FR 14473).

22 In application, the policy-statement alternative is substantially similar to the GEIS-only 

23 alternative. The primary benefit is that it reduces NRC and applicant effort in conducting 

24 reviews, thereby increasing efficiency and thus decreasing cost. The NRC assumes that 

25 applicants will refer to GEIS findings in environmental reports, and the NRC will incorporate 

26 GEIS findings and analyses by reference into site-specific EISs for new reactors, reactor license 

27 renewals, and ISFSI licensing. As in the GEIS-only alternative, the NRC assumes that reliance 

28 on the GEIS in site-specific reviews may resolve concerns for some issues related to continued 

29 storage, while other issues may require additional effort to resolve comments, address site30 specific litigation, or to establish that the GEIS findings are applicable to a specific licensing 

31 proceeding. The NRC assumes that the decreased cost in conducting site-specific reviews 

32 under the policy-statement alternative relative to the no-action alternative is likely to be similar to 

33 the decreased effort from the GEIS-only approach relative to the no-action alternative. The 

34 NRC assumes that the policy-statement alternative will decrease the cost to the NRC and 

35 applicants by an estimated 50 percent relative to the no-action alternative at best, and at worst 

36 will not reduce the NRC and applicant effort compared to the no-action alternative. The NRC 

37 therefore presents the cost of the policy-statement alternative as a range in Table 7-4. 
Cost-Benefit Analysis

Draft NUREG‒2157 7-12 September 2013

1 Table 7-4. Constant and Discounted Estimated Costs of the Policy-Statement Alternative

Components

Estimated Costs (millions of dollars)

Constant Dollars 3% Discount Case 7% Discount Case

Site-Specific Review Costs $12.2 to $24.3 $10.7 to $21.4 $9.31 to $18.6

GEIS Costs $12.9 $12.7 $12.5

Rulemaking Costs - - -

Policy Statement Costs $0.519 $0.511 $0.502

Estimated Total Cost(a) $25.6 to $37.8 $23.9 to $34.6 $22.3 to $31.6

(a) Due to rounding, costs may appear not to sum correctly.

2 Preparation of the GEIS and policy statement add to the costs of this alternative. The NRC 

3 estimates that a policy statement adds 3 FTEs, or $519,000 (undiscounted), to the cost estimate 

4 for the policy-statement alternative. GEIS preparation requires an estimated 20 FTEs, or 

5 $3.46 million, in each of 2013 and 2014, or $7.92 million total (undiscounted). In addition, GEIS 

6 preparation will require an estimated $6 million (undiscounted) of contract support spread 

7 across the 2 years. As a result of the effort expended in creating the GEIS and policy statement 

8 in addition to the effort expended in performing site-specific reviews, the GEIS-only alternative 

9 provides a negative net benefit when compared to the no-action alternative. See Appendix H, 

10 Table H-4, for more information regarding GEIS and policy-statement costs.

11 Similar to the no-action and GEIS-only alternative, another cost of the policy-statement 

12 alternative relates to increased scheduling uncertainties in licensing due to additional 

13 environmental reviews and potential increased litigation associated with continued storage. The 

14 effects of schedule uncertainties are likely to be most significant for new reactor or new site15 specific ISFSI applicants. Delays can be more costly for new reactor applicants, which could 

16 incur billions of dollars of additional expenses if a project is delayed. These costs can include 

17 increased financing costs, longer-term accumulation of interest on debt, replacement-power 

18 costs, and contractual penalties. Because these costs vary significantly and are case-specific, 

19 the NRC has not attempted to quantify them.

20 As was the case in the no-action alternative and the GEIS-only alternative, there is a public21 perception benefit from the NRC’s reviewing the environmental impacts of continued storage in 

22 site-specific licensing actions as part of the policy-statement alternative. In a site-specific NEPA

23 analysis, the NRC would describe location-specific conditions, address the site-specific impacts 

24 of a potential licensing action, and address the impacts of continued storage. The value of 

25 reviewing continued storage in site-specific NEPA analyses is difficult to quantify; however, a

26 site-specific analysis of the environmental impacts of continued storage would likely not reveal 

27 any new information that cannot be addressed in a generic analysis.
Cost-Benefit Analysis

September 2013 7-13 Draft NUREG‒2157

1 Applicants for renewed reactor and site-specific ISFSI licenses that submit timely and sufficient 

2 renewal applications are protected from schedule uncertainty, where continued operations are 

3 concerned, by provisions of 10 CFR 2.109. Specifically, 10 CFR 2.109 allows for operations of 

4 reactors and ISFSIs until such applications have been finally determined, even if final 

5 determination takes place after the license expiration date. Nonetheless, delays may affect 

6 applicants’ plans to commence activities that may depend upon renewed licenses. Because

7 these types of expenses vary significantly and are case-specific, the NRC has not attempted to 

8 quantify them.

9 7.6 Comparison of Alternatives

10 Table 7-5 summarizes the estimated quantified costs for all alternatives. It also presents the 

11 cost savings (or costs) of each action alternative relative to the no-action alternative. The 

12 analysis indicates that the quantified cost for the proposed action is significantly lower than the 

13 cost for any of the alternatives (see Table 7−5). This occurs primarily because the NRC does 

14 not undertake site-specific reviews of continued storage in the course of individual licensing 

15 proceedings as part of the proposed action. In general, the no-action alternative is substantially 

16 more costly than the proposed action, but less costly (cost savings) than either the GEIS-only or 

17 policy-statement alternatives (see Appendix H, Table H-5, for additional detail).

18 Table 7-5. Summary of Constant and Discounted Estimated Costs for Each Alternative (in 

19 millions of dollars)

Proposed Action GEIS-Only Policy Statement No Action

Constant 2013 Dollars

Estimated Cost $14.0 $25.1 to $37.3 $25.6 to $37.8 $24.3

Savings (costs) 

versus no action(a)

$10.4 ($12.9) to ($0.753) ($13.4) to ($1.27) -

3% Discount Case

Estimated Cost $13.8 $23.4 to $34.1 $23.9 to $34.6 $21.4

Savings (costs) 

versus no action(a)

$7.65 ($12.7) to ($2.03) ($13.2) to ($2.54) -

7% Discount Case

Estimated Cost $13.5 $21.8 to $31.1 $22.3 to $31.6 $18.6

Savings (costs) 

versus no action(a)

$5.11 ($12.5) to ($3.19) ($13.0) to ($3.69) -

(a) Due to rounding, some costs may appear not to sum correctly.
Cost-Benefit Analysis

Draft NUREG‒2157 7-14 September 2013

1 While the no-action alternative avoids the costs associated with a GEIS and rulemaking, site2 specific review costs are significantly higher than the avoided costs of the GEIS and rulemaking. 

3 The GEIS-only and policy-statement alternatives avoid the costs of rulemaking, but result in 

4 higher costs than the no-action alternative because of their respective up-front costs.

5 In addition to quantified financial differences among the alternatives, unquantified (qualified) 

6 differences also exist. Table 7-6 contains a summary of unquantified costs and benefits of the 

7 alternatives. First, all alternatives other than the proposed action create schedule uncertainties 

8 that result from site-specific litigation of generic continued storage issues. While costs that 

9 result from these uncertainties may be large, they are difficult to quantify because they vary 

10 significantly, and they are case- and fact-dependent. The ability to litigate site-specific issues 

11 without a waiver petition pursuant to 10 CFR 2.335 carries both costs and benefits. In addition, 

12 there is a public-perception benefit from NRC’s reviewing continued storage in site-specific 

13 licensing actions. 

14 As noted in the introduction to this chapter, each of the alternatives here provides a means of 

15 addressing the environmental impacts of continued storage. The alternatives do not noticeably 

16 alter the NRC’s assessment of environmental impacts presented in Chapters 4, 5, and 6, so the 

17 environmental impacts identified in those chapters are applicable regardless of which alternative 

18 NRC chooses to pursue. 

19 The NRC considers the results of this analysis in the cost-benefit balance discussion contained 

20 in Section 8.6, and this analysis informs the NRC’s recommendation in Section 8.7.
Cost-Benefit Analysis

September 2013 7-15 Draft NUREG‒2157

1 Table 7-6. Summary of Unquantified Costs and Benefits of Each Alternative

No-Action Alternative

Benefits Costs

• Public-perception benefit from site-specific 

reviews

• Public-perception benefit from the ability to 

challenge NRC findings without a waiver petition

• Potential for additional delays due to sitespecific litigation, which may incur 

substantial additional costs

• Repetitive consideration of a generic issue

• Not consistent with CEQ guidance on 

efficiency and timeliness

• Potential additional costs from small 

modular reactor applications

Proposed Action

Benefits Costs

• Generically resolves a generic issue; avoids 

unnecessary, repetitive reviews

• Removes potential for lengthy, site-specific 

litigation and resulting delays, except in cases 

with special circumstances

• Consistent with CEQ guidance on efficiency and 

timeliness

• Avoids potential additional costs from small 

modular reactor applications

• Public-perception cost from precluding 

continued storage from site-specific review

• Public-perception cost from being unable to 

challenge NRC findings without a waiver 

petition

GEIS-Only

Benefits Costs

• Public-perception benefit from site-specific 

reviews

• Public-perception benefit from the ability to 

challenge NRC findings without a waiver petition

• Consistent with CEQ guidance on efficiency and 

timeliness

• Potential for additional delays due to sitespecific litigation, which may incur 

substantial additional costs

• Repetitive consideration of a generic issue

• Potential additional costs from small 

modular reactor applications

Policy Statement

Benefits Costs

• Public-perception benefit from site-specific 

reviews

• Public-perception benefit from the ability to 

challenge NRC findings without a waiver petition

• Consistent with CEQ guidance on efficiency and 

timeliness

• Potential for additional delays due to sitespecific litigation, which may incur 

substantial additional costs

• Repetitive consideration of a generic issue

• Potential additional costs from small 

modular reactor applications
Cost-Benefit Analysis

Draft NUREG‒2157 7-16 September 2013

1 7.7 References

2 10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, “Agency Rules of 

3 Practice and Procedure.” Washington, D.C.

4 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of

5 Production and Utilization Facilities.” Washington, D.C.

6 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

7 Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

8 Washington, D.C.

9 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

10 Certifications, and Approvals for Nuclear Power Plants.” Washington, D.C.

11 10 CFR Part 54. Code of Federal Regulations. Title 10. Energy, Part 54. “Requirements For 

12 Renewal Of Operating Licenses For Nuclear Power Plants.” Washington, D.C.

13 10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing 

14 Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

15 Waste, and Reactor-Related Greater than Class C Waste.” Washington, D.C.

16 77 FR 14473. March 12, 2012. “Final Guidance on Improving the Process for Preparing 

17 Efficient and Timely Environmental Reviews Under the National Environmental Policy Act.” 

18 Federal Register, Council on Environmental Quality, Washington, D.C.

19 Atomic Energy Act of 1954, as amended. 42 USC 2011, et seq. 

20 Eddy-Lea Energy Alliance (ELEA). 2013. Letter from J.M. Maddox to C. Haney dated February 

21 26, 2013, regarding “Notice of Intent to Submit a License Application for Consolidate Used 

22 Nuclear Fuel Facility.” Hobbs, New Mexico. Accession No. ML13067A278.

23 National Environmental Policy Act of 1969, as amended (NEPA). USC 4321, et seq.

24 NRC (U.S. Nuclear Regulatory Commission). 2004. Regulatory Analysis Guidelines of the 

25 U.S. Nuclear Regulatory Commission. NUREG/BR–0058, Revision 4. Washington, D.C. 

26 Accession No. ML042820192.

27 NRC (U.S. Nuclear Regulatory Commission). 2011. Draft Supplemental Environmental Impact 

28 Statement Related to the Operation of Watts Bar Nuclear Plant, Unit 2. NUREG−0498 

29 Supplement 2, Washington, D.C. Accession Nos. ML11298A094, ML11298A095.
Cost-Benefit Analysis

September 2013 7-17 Draft NUREG‒2157

1 NRC (U.S. Nuclear Regulatory Commission). 2012a. Memorandum from C. Haney to The 

2 Commissioners dated October 3, 2012, regarding “Implementation of Commission 

3 Memorandum and Order CLI–12–16 Regarding Waste Confidence Decision and Rule with 

4 Enclosure: Licensing Actions Affected by Waste Confidence Remand.” Washington, D.C. 

5 Package Accession No. ML12276A054.

6 NRC (U.S. Nuclear Regulatory Commission). 2012b. Order (Granting Summary Disposition of 

7 Contention I, LBP–12–19, UniStar and Calvert Cliffs). Atomic Safety and Licensing Board 

8 Panel, LBP–12–19, Washington, D.C. Accession No. ML12243A425.

9 NRC (U.S. Nuclear Regulatory Commission). 2013a. Memorandum and Order [Decision 

10 LBP–12–19, UniStar and Calvert Cliffs]. CLI–13–04, Washington, D.C. Accession 

11 No. ML1307A117.

12 NRC (U.S. Nuclear Regulatory Commission). 2013b. “Advanced Reactors.” Available at 

13 http://www.nrc.gov/reactors/advanced.html. Washington, D.C.

14 NRC (U.S. Nuclear Regulatory Commission). 2013c. “Tennessee Valley Authority (TVA) Clinch 

15 River Site.” Available at http://www.nrc.gov/reactors/advanced/clinch-river.html. 

16 Washington, D.C.

17 NRC (U.S. Nuclear Regulatory Commission). 2013d. “Status of License Renewal Applications 

18 and Industry Activities.” Available at 

19 http://www.nrc.gov/reactors/operating/licensing/renewal/applications.html. Washington, D.C.

20 NRC (U.S. Nuclear Regulatory Commission). 2013e. Information Digest. NUREG−1350, 

21 Volume 24, Appendix O: Dry Spent Fuel Storage Licensees. Washington, D.C. Accession 

22 No. ML12230A174.

23 Office of Management and Budget (OMB). 2003. Circular A–4: Regulatory Analysis. 

24 NRC000060, Washington, D.C. Accession No. ML11231A834.

25 Private Fuel Storage (PFS). 2012. Letter from R.M. Palmberg to NRC dated December 20, 

26 2012, regarding “Termination of NRC License No. SNM–2513 for Private Fuel Storage LLC.” 

27 La Crosse, Wisconsin. Accession No. ML12356A063.

28 Sciacca, F. 1992. Generic Cost Estimates. NUREG/CR−4627 (Rev. 2). Science and

29 Engineering Associates, Inc., Albuquerque, New Mexico.

30 Tennessee Valley Authority (TVA). 2011. TVA Voluntary Response to RIS 2011–02. 

31 Chattanooga, Tennessee. Accession No. ML110840713.

September 2013 8-1 Draft NUREG‒2157

1 8.0 Summary of Environmental Impacts

2 This chapter summarizes the potential environmental impacts and consequences of continued 

3 at-reactor and away-from-reactor spent nuclear fuel (spent fuel) storage after a reactor’s 

4 licensed life for operation (continued storage). In summarizing, the potential impacts and 

5 consequences of these activities are discussed in terms of (1) the unavoidable adverse 

6 environmental impacts, (2) the irreversible and irretrievable commitment of resources, and 

7 (3) the relationship between local short-term uses of the environment and the maintenance of 

8 long-term productivity.

9 The U.S. Nuclear Regulatory Commission’s (NRC) regulations under Title 10 of the Code of 

10 Federal Regulations Part 51(10 CFR Part 51) implement the requirements of the National 

11 Environmental Policy Act of 1969, as amended (NEPA). Section 102(2)(C) of NEPA requires 

12 that an environmental impact statement (EIS) include information about the following:

13 • any adverse environmental effects that cannot be avoided, should the proposal be 

14 implemented

15 • any irreversible and irretrievable commitments of resources that would be involved in the 

16 proposed action should it be implemented

17 • the relationship between local short-term uses of the environment and the maintenance and 

18 enhancement of long-term productivity

19 As discussed in Chapter 1, the significance of potential environmental impacts is categorized 

20 as follows:

21 SMALL—The environmental effects are not detectable or are so minor that they 

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

23 MODERATE—The environmental effects are sufficient to alter noticeably, but not 

24 to destabilize, important attributes of the resource.

25 LARGE—The environmental effects are clearly noticeable and are sufficient to 

26 destabilize important attributes of the resource.

27 For some resource areas, the impact determination language is specific to the authorizing 

28 regulation, executive order, or guidance. Specifically, the Endangered Species Act of 1973, as 

29 amended (ESA) includes findings of (1) no effect, (2) not likely to adversely affect, (3) likely to 

30 adversely affect, or (4) is likely to jeopardize the listed species or adversely modify the 

31 designated critical habitat of Federally listed species populations or their critical habitats. In 
Summary of Environmental Impacts

Draft NUREG‒2157 8-2 September 2013

1 addition, regarding the NRC analyses of environmental justice impacts in the draft “Waste 

2 Confidence Generic Environmental Impact Statement” (draft GEIS), under Executive 

3 Order 12898 (59 FR 7629), Federal agencies are responsible for identifying and addressing 

4 potential disproportionately high and adverse human health and environmental impacts on 

5 minority and low-income populations.

6 8.1 Comparison of Environmental Impacts

7 The environmental impacts related to at-reactor storage of spent fuel are described in Chapter 4 

8 and are summarized by timeframe in Table 8-1. Impacts associated with away-from-reactor 

9 storage of spent fuel are described in Chapter 5 and are summarized by timeframe in Table 8-2. 

10 Cumulative impacts associated with spent fuel storage when considered along with the impacts 

11 of other past, present, and reasonably foreseeable future projects are described in Chapter 6 

12 and summarized with the incremental impacts from Chapters 4 and 5 in Table 8-3. 

13 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 No disproportionately 

high and adverse 

impacts

No disproportionately 

high and adverse 

impacts

No disproportionately 

high and adverse 

impacts

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 from the spent 

fuel pool would be 

determined as part of 

the ESA Section 7 

consultation. 

Independent spent fuel 

storage installation 

(ISFSI) operations are 

not likely to adversely 

affect special status 

species and habitats.

Not likely to adversely affect special status 

species and habitats.

14
Summary of Environmental Impacts

September 2013 8-3 Draft NUREG‒2157

1 Table 8-1. 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, MODERATE, 

or LARGE

SMALL, MODERATE, 

or 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

Transportation SMALL SMALL SMALL

Public and Occupational 

Health

SMALL SMALL SMALL

Accidents SMALL SMALL SMALL

Sabotage or Terrorism SMALL SMALL SMALL

2 Table 8-2. Summary of Environmental Impacts of Continued Storage at an Away-from-Reactor 

3 ISFSI

Resource Area

Construction and 

Operation 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 No disproportionately 

high and adverse 

impacts

No disproportionately 

high and adverse 

impacts

No disproportionately 

high and adverse 

impacts

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

 4 
Summary of Environmental Impacts

Draft NUREG‒2157 8-4 September 2013

1 Table 8-2. Summary of Environmental Impacts of Continued Storage at an Away-from-Reactor 

2 ISFSI (cont’d)

Resource Area

Construction and 

Operation Long-Term Storage Indefinite Storage

Special Status Species 

and Habitat

Impacts from the construction of the ISFSI would be determined as part of 

the ESA Section 7 consultation. Assuming the ISFSI can be sited to avoid 

special status species and habitats, operation and replacement of the ISFSI 

is not likely to adversely affect special status species and habitats. Impacts 

would be determined as part of ESA Section 7 consultation if continued 

storage would affect listed species or critical habitat.

Historic and Cultural 

Resources

SMALL, MODERATE, or 

LARGE

SMALL, MODERATE, 

or LARGE

SMALL, MODERATE, 

or 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

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

4 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 No disproportionately 

high and adverse 

impacts

No disproportionately 

high and adverse 

impacts

No disproportionately 

high and adverse 

impacts

5
Summary of Environmental Impacts

September 2013 8-5 Draft NUREG‒2157

1 Table 8-3. Summary of the Cumulative Impacts from Continued Storage When Added to Other 

2 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

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 SMALL SMALL to 

MODERATE

SMALL to 

MODERATE

Aquatic Ecology SMALL SMALL SMALL to LARGE

Historic and Cultural 

Resources

SMALL, MODERATE, or 

LARGE

SMALL, MODERATE, 

or LARGE

SMALL, MODERATE, 

or 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

3 8.2 Unavoidable Adverse Environmental Impacts

4 Section 102(2)(C)(ii) of NEPA requires that an EIS include information about any adverse 

5 environmental effects that cannot be avoided if the proposal is implemented. This draft GEIS 

6 provides a regulatory basis for a rule that generically addresses the small portion of reactor and 

7 ISFSI NEPA analyses that would discuss the likely impacts of spent fuel storage during 

8 continued storage. Other aspects of spent fuel storage will either be addressed in site-specific 

9 analyses or are addressed generically elsewhere. Thus, for the purposes of this draft GEIS, 
Summary of Environmental Impacts

Draft NUREG‒2157 8-6 September 2013

1 unavoidable adverse environmental impacts are those potential impacts of the NRC action that 

2 cannot be avoided due to constraints inherent in using at-reactor and away-from-reactor spent 

3 fuel storage facilities to store spent fuel beyond the licensed life of operation of a reactor until a 

4 repository is available.

5 The unavoidable adverse environmental impacts associated with continued storage of spent 

6 fuel would include impacts of (1) short-term storage in a spent fuel pool, (2) short-term storage, 

7 (3) long-term storage, and (4) indefinite storage in at-reactor and away-from-reactor ISFSIs. 

8 The short-term storage timeframe assumes that a repository becomes available by 60 years 

9 after the end of the reactor’s licensed life for operation. The long-term storage timeframe 

10 assumes that a repository becomes available by 160 years after the end of the reactor’s 

11 licensed life for operation. As discussed in Chapter 1 of this draft GEIS, the NRC believes that 

12 the most likely outcome is that a repository will become available to accept the spent fuel 

13 generated by a reactor by the end of the short-term timeframe, or 60 years after the end of the 

14 reactor’s licensed life for operation.

15 The short-term storage timeframe involves continued operation of at-reactor spent fuel pool 

16 storage and an at-reactor or away-from-reactor ISFSI until a repository is available. The long17 term storage timeframe involves construction and operation of a dry cask transfer facility (DTS), 

18 continued operation of an at-reactor or away-from-reactor ISFSI, and replacement of these 

19 facilities within the 100-year period. The NRC assumes a repository becomes available at the 

20 end of the long-term timeframe. Indefinite storage continues at an at-reactor or away-from21 reactor ISFSI in perpetuity with continued aging management activities and the assumed 

22 replacement of the ISFSI and DTS every 100 years.

23 The potential impacts from the activities occurring within the three aforementioned storage 

24 timeframes on each resource area are described in Chapter 4 for at-reactor storage and in 

25 Chapter 5 for away-from-reactor storage. Table 8-1 and Table 8-2 summarize the unavoidable 

26 adverse environmental impacts for each resource area. For at-reactor storage, the unavoidable 

27 adverse environmental impacts for each resource area are SMALL with the exception of waste 

28 management impacts, which are SMALL to MODERATE, and historic and cultural impacts, 

29 which are SMALL, MODERATE, or LARGE. These elevated impact conclusions are influenced, 

30 in part, by the uncertainties regarding the specific circumstances of continued storage over long 

31 timeframes, including site-specific characteristics that could affect the intensity of potential 

32 environmental impacts, and the resulting analysis assumptions that have been made by the 

33 NRC as documented in detail in Chapter 4. The moderate waste-management impacts are 

34 associated with the volume of nonhazardous solid waste generated by assumed facility 

35 replacement activities for only the indefinite timeframe. The SMALL, MODERATE, or LARGE 

36 historic and cultural impacts are based on a combination of the additional surface-disturbing 

37 activities from DTS construction and facility replacement activities during long-term and 

38 indefinite timeframes and a range of site-specific characteristics that are assumed for the 
Summary of Environmental Impacts

September 2013 8-7 Draft NUREG‒2157

1 purpose of evaluating a reasonable range of potential impacts. More specifically, these 

2 potential historic and cultural impacts vary depending on whether resources are present, the 

3 extent of proposed land disturbance, if the area has been previously surveyed to identify historic 

4 and cultural resources, and if the licensee has management plans and procedures that are 

5 protective of historic and cultural resources. 

6 Resource areas where the impact determination language is specific to the authorizing 

7 regulation, executive order, or guidance include special status species and environmental 

8 justice. For special status species, at-reactor ISFSI storage would be not likely to adversely 

9 affect special status species and habitats, whereas spent fuel pool continued storage impacts 

10 would be based on site-specific conditions and determined as part of an ESA Section 7 

11 consultation. The NRC environmental justice impact analysis concluded there would be no

12 disproportionately high and adverse human health and environmental impacts on minority and 

13 low-income populations. 

14 For away-from-reactor storage, the unavoidable adverse environmental impacts for each 

15 resource area would be SMALL except for air quality, terrestrial ecology, aesthetics, waste 

16 management, and transportation where the impacts would be SMALL to MODERATE. 

17 Socioeconomics impacts would range from SMALL to LARGE and historic and cultural impacts 

18 could be SMALL, MODERATE, or LARGE. The potential MODERATE impacts on air, terrestrial 

19 wildlife, and transportation are based on construction-related potential fugitive dust emissions,

20 terrestrial wildlife direct and indirect mortalities, and temporary construction traffic impacts. The 

21 potential MODERATE impacts on aesthetics and waste management are based on noticeable 

22 changes to the viewshed from constructing a new ISFSI and the volume of nonhazardous solid 

23 waste generated by assumed ISFSI and DTS replacement activities for only the indefinite 

24 timeframe. Potential LARGE impacts on socioeconomics would be due to local economic tax

25 revenue increases from an away-from-reactor ISFSI. The LARGE impacts on historic and 

26 cultural apply to assumed site-specific circumstances at an away-from-reactor ISFSI involving 

27 the presence of these resources during construction activities and absence of effective

28 protection measures. Specifically, these potential historic and cultural impacts vary depending 

29 on whether resources are present, the extent of proposed land disturbance, and whether the 

30 licensee has management plans and procedures that are protective of historic and cultural

31 resources. 

32 Resource areas where the impact determination language is specific to the authorizing 

33 regulation, executive order, or guidance include special status species and environmental 

34 justice. For special status species, away-from-reactor ISFSI storage would be not likely to 

35 adversely affect special status species and habitats based on the assumption an ISFSI can be 

36 sited to avoid special status species and habitats. Impacts on special status species and 

37 habitats would be based on site-specific conditions and determined as part of an ESA Section 7 

38 consultation. The NRC environmental justice impact analysis for an away-from-reactor ISFSI 
Summary of Environmental Impacts

Draft NUREG‒2157 8-8 September 2013

1 concluded there would be no disproportionately high and adverse human health and 

2 environmental impacts on minority and low-income populations. 

3 8.3 Irreversible and Irretrievable Commitments of 

4 Resources

5 Section 102(2)(C)(v) of NEPA requires that an EIS include information about irreversible and 

6 irretrievable commitments of resources that would occur if the proposed actions are 

7 implemented. The NRC guidance in NUREG−1748, “Environmental Review Guidance for 

8 Licensing Actions Associated with NMSS Programs” (NRC 2003), defines an irreversible 

9 commitment as the commitment of environmental resources that cannot be restored. In 

10 addition, an irretrievable commitment refers to the commitment of material resources that once 

11 used cannot be recycled or restored for other uses by practical means. This draft GEIS 

12 provides a regulatory basis for a rule that generically addresses the small portion of reactor and 

13 ISFSI NEPA analyses that would discuss the likely impacts of spent fuel storage during 

14 continued storage. Other aspects of spent fuel storage will either be addressed in site-specific 

15 analyses or are addressed generically elsewhere. Thus, for the purposes of this draft GEIS, the 

16 NRC is analyzing the irreversible commitments of resources that would occur if continued 

17 storage were to occur. As stated throughout this draft GEIS, this draft GEIS is not a licensing 

18 decision and does not authorize a licensee to store spent fuel.

19 For both at-reactor and away-from-reactor ISFSIs, there would be no irreversible and 

20 irretrievable commitments of resources during continued storage for most resources. However, 

21 impacts on land use, aesthetics, historic and cultural resources, waste management, and 

22 transportation would result in irreversible and irretrievable commitments. As finite resources, 

23 the loss of historic and cultural resources would constitute irreversible and irretrievable impacts. 

24 For the indefinite storage timeframe, land and visual resources allocated for spent fuel storage 

25 would be committed in perpetuity because continued operations would preempt other productive 

26 land uses and permanently affect the viewshed. The area of land that would be occupied by an 

27 at-reactor ISFSI is assumed to be 2.4 ha (6 ac) for both ISFSI and DTS facilities 

28 (Section 2.1.2.2) or 330 ha (820 ac) for an away-from-reactor ISFSI (Section 2.1.3). Waste29 management activities involving waste treatment, storage, and disposal would result in 

30 irreversible commitment of capacity for waste disposal. The largest volume of waste requiring 

31 disposal during continued storage was nonradiological demolition waste from replacement of an 

away-from-reactor ISFSI (247,500 m3 [324,000 yd3 32 ]), as described in Section 5.15.2. 

33 Repackaging of spent fuel into transportation casks would require new canisters and would 

34 generate canister waste that would have to be disposed at an approved facility (approximately 

35 100 to 150 canisters per typical reactor, as described in Section 2.1.2.2). Transportation 

36 activities would involve irreversible and irretrievable commitment of resources including vehicle 

37 fuel for commuting workers and shipping activities.
Summary of Environmental Impacts

September 2013 8-9 Draft NUREG‒2157

1 8.4 Relationship between Short-Term Uses of the 

2 Environment and the Maintenance and Enhancement of 

3 Long-Term Productivity

4 Section 102(2)(C)(iv) of NEPA requires that an EIS include information about the relationship 

5 between local short-term uses of the environment and the maintenance and enhancement of 

6 long-term productivity. The NRC guidance in NUREG−1748 (NRC 2003) further clarifies that 

7 the short-term use period represents the period of the action under review and long-term 

8 productivity period represents the period extending beyond the end of the action under review. 

9 This draft GEIS provides a regulatory basis for a rule that generically addresses the small 

10 portion of reactor and ISFSI NEPA analyses that would discuss the likely impacts of spent fuel 

11 storage during continued storage. Other aspects of spent fuel storage will either be addressed 

12 in site-specific analyses or are addressed generically elsewhere. Thus, for the purposes of this 

13 draft GEIS, the short-term use period evaluated in this chapter is the period of time 

14 encompassing all continued storage activities defined in Chapter 1 (i.e., the period of analysis of 

15 environmental impacts evaluated by the three timeframes in Chapters 4 and 5 of this draft 

16 GEIS). In addition, the long-term productivity period evaluated in this chapter is the time period 

17 beyond continued storage (i.e., based on the NRC guidance in NUREG−1748, the period 

18 beyond the action under review). As discussed in Chapter 1 of this draft GEIS, the NRC 

19 believes that the most likely outcome is that a repository will become available to accept the 

20 spent fuel generated by a reactor by the end of the short-term timeframe, or 60 years after the 

21 end of the reactor’s licensed life for operation. With respect to the indefinite storage timeframe, 

22 there is no time period beyond the storage action under review, for the purpose of the analysis 

23 in this subsection, and because the short-term timeframe is the most likely timeframe, the long24 term productivity period considered in this chapter for the indefinite storage timeframe is 

25 assumed to begin at the end of the long-term storage timeframe evaluated in Chapters 4 and 5.

26 The local short-term use of the human environment is summarized in terms of the unavoidable 

27 adverse environmental impacts and irreversible and irretrievable commitments of resources 

28 summarized in Sections 8.2 and 8.3 and Table 8-1 and Table 8-2. With the exception of the 

29 consumption of depletable resources resulting from the evaluated construction and operations 

30 activities, these uses may be classified as short-term.

31 The maximum long-term impact on productivity would result when an at-reactor or away-from32 reactor ISFSI is not immediately dismantled at the end of storage operations, or, as with the 

33 indefinite storage timeframe, it remains in operation indefinitely. Consequently, the land 

34 occupied by an ISFSI would not be available for any other uses. Most long-term impacts 

35 resulting from land-use preemption by ISFSI structures can be eliminated by removing these 

36 structures or by converting them to productive uses. Once continue storage ends, the facilities 

37 and associated land areas would be decommissioned according to NRC regulations. Once 
Summary of Environmental Impacts

Draft NUREG‒2157 8-10 September 2013

1 decommissioning is complete and the NRC license is terminated, the site would be available for 

2 other uses. Other potential long-term impacts on productivity include the commitment of land 

3 and consumption of disposal capacity necessary to meet waste disposal needs. This 

4 commitment of land for disposal would remove land from productive use. In addition, because 

5 loss of historic and cultural resources would constitute irreversible and irretrievable impacts, any 

6 loss of historic and cultural resources during continued storage would persist as long-term 

7 impacts. A small contribution to greenhouse gas emissions would add to the atmospheric 

8 burden of emissions that could contribute to potential long-term impacts.

9 8.5 Proposed Action and Alternatives

10 As described in Section 1.4 of this draft GEIS, the proposed action is for the Commission to 

11 issue a revised rule, 10 CFR 51.23, that generically addresses the environmental impacts of 

12 continued storage. This revision would adopt into regulation the environmental impact analyses 

13 in this draft GEIS. Further, the revision would state that because the impacts of continued 

14 storage have been generically assessed in this draft GEIS and codified in a rule, the NEPA

15 analyses for future reactor and ISFSI licensing actions would not need to separately consider 

16 the environmental impacts of continued storage.

17 Section 1.6 describes the alternatives to the proposed action as (1) the no-action alternative, 

18 (2) the GEIS-only alternative, and (3) the policy-statement alternative. These alternatives do not 

19 noticeably alter the environmental impacts from continued storage that the NRC addressed in 

20 Chapters 4, 5, and 6. The alternatives instead provide different approaches that the NRC could 

21 apply to future licensing activities that can satisfy the agency’s responsibility to consider the 

22 potential environmental impacts of continued storage in deciding whether to issue certain new 

23 and renewed licenses.

24 Under the no-action alternative, the NRC would take no action to generically address the 

25 environmental impacts of continued storage. The NRC would then perform site-specific reviews 

26 of the environmental impacts of continued storage. In some cases, these reviews could involve 

27 a time- and resource-intensive consideration of issues that could readily be resolved on a 

28 generic basis. Therefore, this alternative is not consistent with Council on Environmental 

29 Quality guidance for achieving efficiency and timeliness under NEPA. 

30 Under the GEIS-only alternative, the NRC could develop and issue a GEIS that addresses the 

31 generic environmental effects of continued storage and then would use the GEIS to support 

32 site-specific licensing reviews. This nonbinding, GEIS-only alternative would add somewhat to 

33 the efficiency of NRC reviews by addressing issues that are similar at all sites or otherwise 

34 susceptible to generic consideration. This alternative could enable parties in licensing 

35 proceedings to raise contentions challenging the GEIS conclusions. Thus, the GEIS-only 

36 approach would eliminate some of the efficiency and time-savings that the NRC would 
Summary of Environmental Impacts

September 2013 8-11 Draft NUREG‒2157

1 gain through a binding generic analysis of continued storage, but it would provide greater 

2 efficiencies than the no-action (site-specific) alternative.

3 Under the policy-statement alternative, the NRC could issue a policy statement that expresses 

4 its intent either to incorporate the environmental impacts determined by the GEIS into site5 specific NEPA analyses or to prepare a site-specific evaluation without regard to the GEIS for 

6 each NRC licensing action. Like the no-action and nonbinding GEIS-only alternatives, the 

7 policy-statement alternative would reduce the efficiencies that the NRC would gain through a 

8 rule whose incorporation of environmental impacts of continued storage would be binding in 

9 licensing proceedings, but it would at least provide notice to parties that the Commission might 

10 elect to incorporate by reference all or a portion of the existing GEIS.

11 8.6 Cost-Benefit Balance

12 This section summarizes benefits and costs associated with the proposed action, other action 

13 alternatives, and the no-action alternative. A detailed accounting of costs and benefits of these 

14 actions is provided in Chapter 7, which includes a cost-benefit comparison of the proposed 

15 action and alternatives (Section 7.6). The alternatives considered in this chapter do not 

16 noticeably alter the environmental impacts from continued storage that the NRC addressed in 

17 Chapters 4, 5, and 6. The alternatives considered in this chapter instead provide different 

18 approaches that the NRC could apply to future licensing activities that can satisfy the agency’s 

19 responsibility to consider the potential environmental impacts of continued storage in deciding 

20 whether to issue certain licenses. As a result, the costs and benefits shown in this chapter 

21 include the specific costs and benefits of the several alternatives. The costs and benefits do not 

22 include the environmental impacts of continued storage, an activity that will occur regardless of 

23 the alternative that the NRC selects to consider its impacts.

24 The NRC quantitative analysis of costs in Chapter 7 (Table 7-5) shows that the quantified cost 

25 for the proposed action is significantly lower than the cost for any of the alternatives. This 

26 occurs primarily because the NRC does not undertake site-specific reviews of continued storage 

27 in the course of individual licensing proceedings as part of the proposed action. In general, the 

28 no-action alternative is substantially more costly than the proposed action, but less costly (cost 

29 savings) than either the GEIS-only or policy-statement alternatives (see Appendix H, Table H-5, 

30 for additional detail).

31 While the no-action alternative avoids the costs associated with a GEIS and rulemaking, site32 specific review costs are significantly higher than the avoided costs of the GEIS and rulemaking. 

33 The GEIS-only and policy-statement alternatives avoid the costs of rulemaking, but result in 

34 higher costs than the no-action alternative because of their respective up-front costs of creating 

35 the GEIS and the policy statement.
Summary of Environmental Impacts

Draft NUREG‒2157 8-12 September 2013

1 Unquantified costs and benefits of the alternatives (Chapter 7, Table 7-6) pertain to schedule 

2 uncertainties, the ability to litigate site-specific issues, and site-specific continued storage 

3 analyses. First, all alternatives other than the proposed action create schedule uncertainties 

4 that result from site-specific litigation of generic continued storage issues. While costs that 

5 result from these uncertainties may be large, they are difficult to quantify—they vary significantly 

6 because they are case- and fact-dependent. Second, perceptions vary among stakeholders 

7 regarding whether unquantified benefits are costs or benefits. The ability to litigate site-specific 

8 issues without a waiver petition pursuant to 10 CFR 2.335 carries both costs and benefits. In 

9 addition, there is a benefit from NRC’s reviewing continued storage in site-specific licensing 

10 actions.

11 8.7 Recommendation 

12 The NRC recommendation is to select the proposed action—revising 10 CFR 51.23—as the

13 preferred alternative. The NRC recommendation is based on (1) the NRC’s independent impact

14 assessments of continued storage summarized in the draft GEIS, which would result in 

15 substantially the same impact conclusions for any of the evaluated alternatives; (2) the NRC’s 

16 consideration of public scoping comments in the development of the draft GEIS; and (3) the 

17 NRC’s analysis of the cost-benefit balance of the proposed action and alternatives. In making 

18 its preliminary recommendation, the NRC determined that none of the alternatives assessed 

19 were obviously superior to the proposed action.

20 8.8 References

21 10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, “Agency Rules of 

22 Practice and Procedure.” Washington, D.C.

23 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

24 Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

25 Washington, D.C.

26 59 FR 7629. February 16, 1994. “Federal Actions to Address Environmental Justice in Minority 

27 Populations and Low-Income Populations.” Federal Register, U.S. Environmental Protection 

28 Agency, Washington, D.C.

29 National Environmental Policy Act (NEPA) of 1969, as amended. USC 4321-4347.

30 NRC (U.S. Nuclear Regulatory Commission). 2003. Environmental Review Guidance for 

31 Licensing Actions Associated with NMSS Programs. NUREG−1748, Washington, D.C. 

32 Accession No. ML032540811.
Summary of Environmental Impacts

September 2013 8-13 Draft NUREG‒2157

1 NRC (U.S. Nuclear Regulatory Commission). 2013a. Waste Confidence Generic 

2 Environmental Impact Statement Scoping Process Summary Report. Washington D.C. 

3 Accession No. ML13030A128.

4 NRC (U.S. Nuclear Regulatory Commission). 2013b. Scoping Comments on the Waste 

5 Confidence Generic Environmental Impact Statement. Washington, D.C. Accession 

6 No. ML13060A130.

September 2013 9-1 Draft NUREG‒2157

1 9.0 List of Preparers

2 The overall responsibility for the preparation of this draft Waste Confidence Generic 

3 Environmental Impact Statement (draft GEIS) was assigned to the Office of Nuclear Material 

4 Safety and Safeguards (NMSS), U.S. Nuclear Regulatory Commission (NRC). NMSS had 

5 assistance from other NRC organizations as well as the Center for Nuclear Waste Regulatory 

6 Analyses (CNWRA). Tables 9-1 and 9-2 provide a listing of the NRC and CNWRA staff 

7 involved, their experience, and their role in preparing this draft GEIS.

 8 
Draft NUREG‒2157

9-2 September 2013

Table 9-1. List of Preparers—NRC 1

Name NRC Office Experience Function o

David Brown NMSS B.S., Physics, Muhlenberg College, 1990

M.S., Environmental Health Physics, Clemson University, 1993

Years of Relevant Experience: 20

Air quality, climate 

water, groundwate

public and occupat

accidents and safe

Ralph Cady RES B.S., Geology, University of Connecticut, 1974

M.A., Geology, University of Connecticut, 1976

Ph.D., Hydrology, University of Arizona, 1989

Years of Relevant Experience: 24

Spent fuel pool lea

Jennifer Davis NMSS B.A, Historic Preservation and Classical Civilization (Archaeology); 

Mary Washington College, 1996.

2 years of fieldwork; 11 years of experience in NEPA compliance, project

management, historic and cultural resource impact analysis and 

regulatory compliance

Historic and cultura

socioeconomics, e

justice, land use, n

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: 10

Spent fuel pool fire

Merri Horn NMSS B.S., Physics, Eastern Illinois University, 1980

M.S., Environmental Systems Engineering, Clemson University, 1987

Years of Relevant Experience: 29

Waste Confidence 

Andrew Kugler NRO B.S., Mechanical Engineering, Cooper Union, 1978

M.S., Technical Management, Johns Hopkins, 1998

Years of Relevant Experience: 34

Away-from-reactor 

Emily Larson NRR B.A., Anthropology (major, emphasis archaeology) and History (minor), 

University of Minnesota, 2004;

M.A., Archaeology, Bangor University, 2006

Years of Relevant Experience: 1 year of fieldwork; 1.5 years of 

experience in NEPA compliance; historic and cultural resource impact 

analysis and regulatory compliance

Historic and cultura

Sarah Lopas NMSS B.A., Molecular Biology, Lehigh University, 2001

MPA, Environmental Science and Policy, Columbia University, 2006

Years of Relevant Experience: 11

Executive summar

Timothy McCartin NMSS B.S., Physics, Xavier University, 1973

M.S., Physics, Wayne State University, 1976

Over 30 years’ experience evaluating safety and regulatory compliance 

of geological disposal facilities

Public and occupa

accidents and safe

Confidence rule an

2
September 2013

9-3 Draft NUREG‒2157

Table 9-1. List of Preparers—NRC (cont’d)

Name NRC Office Experience Function o

Paul Michalak NMSS B.S., Education, Temple University, 1978

M.S., Hydrology, New Mexico Institute of Mining and Technology, 1989

Years of Relevant Experience: 25 

Spent fuel pool lea

Michelle Moser NRR B.S., Environmental Sciences, Brown University, 2002

M.S., Biological Sciences, Stanford University, 2005

10 years of experience in ecological research and aquatic ecology, 

7 years of experience in cumulative impact assessment and NEPA

compliance

Aquatic ecology, cu

Jessie Muir 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, 

6 years in NEPA compliance and project management 

Solid waste manag

Tom Nicholson RES B.S., Geological Sciences, Pennsylvania State University, 1972

M.S., Geology, Stanford University, 1976

Professional Geologist, Indiana

Certified Professional Hydrogeologist, AIH

Years of Relevant Experience: 38

Senior technical ad

radionuclide transp

environment

Jeffrey Rikhoff NRR M.R.P., Regional Planning, University of Pennsylvania, 1988

M.S., Economic Development and Appropriate Technology, University of 

Pennsylvania, 1987

B.A., English (Composition), DePauw University, 1980

Years of Relevant Experience: 25 years of experience in NEPA

compliance, socioeconomics and environmental justice impact analysis, 

cultural resource impacts, and comprehensive land-use and 

development planning

Socioeconomics, e

justice

Andrew 

Stuyvenberg

NMSS B.S., Biochemistry/Molecular Biology and Political Science, Marquette 

University, 2002

M.E.M., Environmental Economics and Policy, Duke University, 2005

J.D., Georgetown University Law Center, In Progress

Years of Relevant Experience: 8

NEPA alternatives

cost-benefit analys

Michael Wentzel NMSS B.S., Microbiology, University of Texas, 1997

Years of Relevant Experience: 15

Ecological resourc

spent fuel pool leak

NRO = Office of New Reactor.

NRR = Office of Nuclear Reactor Regulation.

NSIR = Office of Nuclear Security and Incident Response.

RES = Office of Nuclear Regulatory Research. 1
Draft NUREG‒2157

9-4 September 2013

Table 9-2. List of Preparers—CNWRA 1

Name Experience Function or 

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: 2

Groundwater

Amitava Ghosh B.Tech., Mining Engineering, Indian Institute of Technology, 1978

M.S., Mining Engineering, University of Arizona, 1983

Ph.D., Mining Engineering, University of Arizona, 1990

Years of Relevant Experience: 12

Natural events and a

Amy Hester B.A., Environmental Studies, University of Kansas, 1998

Years of Relevant Experience: 13

Terrestrial resources

Lane Howard B.S., Civil Engineering, Texas A&M University, 1988

M.S., Nuclear Engineering, Texas A&M University, 1995

Years of Relevant Experience: 22

Public and occupatio

Miriam Juckett B.A., Chemistry, University of Texas San Antonio, 2003

M.S., Environmental Sciences, University of Texas San Antonio, 2006

Years of Relevant Experience: 10

Communications, sco

outreach

Patrick LaPlante B.S., Environmental Studies, Western Washington University, 1988

M.S., Biostatistics and Epidemiology, Georgetown University, 1994

Years of Relevant Experience: 24

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: 1

Spent fuel pool fires

Marla Morales B.A., Geology, Vanderbilt University, 2001

M.S., Geology, University of Texas San Antonio, 2007

Years of Relevant Experience: 12

Socioeconomics, env

justice, geology, and 

James Myers B.S., Geology, Michigan State University, 1985

M.S., Geophysical Sciences, Georgia Institute of Technology, 1990

Ph.D., Environmental Science and Engineering, Clemson University, 2004

Years of Relevant Experience: 20

Solid waste managem

2
September 2013

9-5 Draft NUREG‒2157

Table 9-2. List of Preparers—CNWRA (cont’d)

Name Experience Function or 

Olufemi Osidele B.Sc., Civil Engineering, University of Ife, Nigeria, 1987

M.Sc., Hydrology for Environmental Management, University of London, 

England, 1992

Ph.D., Environmental Systems Analysis, University of Georgia, 2001

Years of Relevant Experience: 18

Surface water

Roberto Pabalan B.S., Geology, University of the Philippines, 1976

Ph.D., Geochemistry and Mineralogy, Pennsylvania State University, 1986

Years of Relevant Experience: 1 5

Spent fuel pool leaks

Robert Pauline B.S., Biology, Bates College, 1989

M.S., Biology, George Mason University, 1999

Years of Relevant Experience: 7

Scoping

English Pearcy B.S., Geology, Furman University, 1983

M.S., Geology, Harvard University, 1985

Ph.D., Geology, Harvard University, 1989

Years of Relevant Experience: 23

Aesthetics

James Prikryl B.S., Geology, University of Texas, 1984

M.S., Geology, University of Texas, 1989

Years of Relevant Experience: 23

Land use

David Turner B.A. in Music/Geology, College of William and Mary, 1981

M.S. in Geology, University of Utah, 1985

Ph.D. in Geology, University of Utah, 1990

Years of Relevant Experience: 23

Cumulative impacts

Bradley Werling B.A., Engineering Physics, Westmont College, 1985

B.S., Chemistry, Southwest Texas State University, 1999

M.S., Environmental Science, University of Texas San Antonio, 2000

Years of Relevant Experience: 18

Noise, air quality, clim

1

September 2013 10-1 Draft NUREG‒2157

1 10.0 Index

A

Accident, xxviii, xli, xlii, xliii, lii, liii, lv, lvii, 2-12, 

2-21, 2-32, 3-41, 4-3, 4-18, 4-61, 4-62, 4-

66, 4-67, 4-68, 4-69, 4-70, 4-71, 4-74, 4-76, 

4-77, 4-78, 4-79, 4-80, 4-81, 4-82, 4-83, 4-

84, 4-85, 4-90, 4-91, 4-96, 4-97, 4-101, 5-

18, 5-47, 5-48, 5-50, 5-51, 5-52, 5-53, 5-54, 

5-56, 6-50, 6-51, 6-52, 6-55, 6-56, 6-57, 6-

58, 6-62, 8-3, 8-4, 8-5, 9-2, 9-4, B-7, B-9, B10, B-11, B-13, B-15, B-16, B-20, B-24, B25, E-1, E-4, E-8, F-1, F-2, F-3, F-4, F-5, F6, F-7, F-8, F-9, F-10, F-11, F-12, F-13, F14, F-15

Aesthetics, vii, x, xii, xv, xxix, xxxi, xxxix, xliii, 

l, liii, lv, lviii, lix, 3-9, 3-29, 3-33, 4-53, 4-54, 

4-91, 5-40, 5-41, 5-55, 6-43, 6-44, 6-58, 8-

3, 8-4, 8-5, 8-7, 8-8, 9-3, 9-5

Aging management, xl, xlviii, l, 1-16, 2-26, 2-

28, 4-6, 4-9, 4-14, 4-64, 5-7, 5-9, 5-10, 5-

13, 5-17, 5-20, 5-21, 5-27, 5-28, 5-29, 5-32, 

5-36, 5-39, 5-41, 5-48, 5-51, 8-6, B-12, B13, B-14, B-15, B-17, B-19, B-20, E-5

Air quality, vi, viii, xi, xiv, xxix, xxx, xxxiii, xlii, 

xlv, liii, liv, lviii, lxiv, 3-11, 3-13, 3-14, 3-42, 

3-43, 4-3, 4-11, 4-14, 4-15, 4-16, 4-17, 4-

33, 4-90, 5-5, 5-10, 5-12, 5-14, 5-15, 5-16, 

5-17, 5-54, 5-55, 6-18, 6-19, 6-20, 6-21, 6-

58, 8-2, 8-3, 8-5, 8-7, 9-2, 9-5

Alternative, iii, v, xvi, xvii, xix, xxi, xxiii, xxiv, li, 

lv, lviii, lix, 1-5, 1-6, 1-7, 1-8, 1-9, 1-10, 1-

24, 4-67, 4-85, 4-97, 5-27, 5-35, 6-22, 7-1, 

7-2, 7-3, 7-5, 7-7, 7-9, 7-10, 7-11, 7-12, 7-

13, 7-14, 7-15, 8-10, 8-11, 8-12, 9-3, B-5, 

B-18, E-16, F-12, H-1, H-6, H-7, H-8 

Aquifer, 3-17, 3-18, 4-25, 4-26, 6-28, 6-29, 6-

30, E-12, E-13, E-14, E-16, E-19

Archaeological resource, 3-30

Attainment, 3-14, 4-15, 4-17, 5-14, 5-15, 5-16, 

5-17

B

Bare fuel, 2-12, 2-21, 2-27, 4-16, 4-77, 5-17, 

5-20, 6-9, 6-54, 6-56

Biota, 3-22, 3-23, 4-29, 4-38, 5-29

Boiling water reactor, lxiii, 2-2, 2-3, 2-4, 2-6, 

2-7, 2-16, 2-17, 3-3, 3-34, 4-2, 4-23, 4-74, 

4-97, 6-47, B-9, B-10, B-14, B-26, E-1, E-2, 

E-3, E-17, E-19, E-24, F-11, F-13, F-16, G1, G-3, G-4, G-5, G-6, G-7, G-8, G-9, G-10, 

G-11, G-12

Burnup, 2-7, 2-22, 2-25, 4-87, 4-88, 4-89, B-6, 

B-12, B-13, B-14, B-16, B-21, B-23, B-26, 

F-14

C

Cladding, 2-2, 2-6, 2-9, 2-10, 2-32, 4-3, 4-81, 

7-4, B-7, B-8, B-9, B-11, B-12, B-13, B-23, 

F-2, F-7, F-10

Clean Air Act, 3-13, 3-14, 3-43, 5-15, 5-57, 6-

59

Climate change, viii, xi, xiv, xxxiv, xlii, xlv, liii, 

liv, 3-44, 3-48, 4-18, 4-75, 4-78, 4-79, 4-81, 

4-83, 4-90, 4-96, 5-18, 5-55, 6-8, 6-11, 6-

21, 6-31, 6-34, 6-58, 6-61, 8-2, 8-3, 8-5

Coastal, 3-6, 3-12, 3-18, 3-20, 3-23, 3-24, 3-

26, 3-29, 4-74, 4-75, 4-82, 4-96, 6-7, 6-11, 

6-28, 6-31, F-12

Consolidated storage, 2-18
Index

Draft NUREG‒2157 10-2 September 2013

Cooling system, xxxvii, 1-17, 2-2, 2-3, 2-4, 2-

25, 3-1, 3-3, 3-21, 3-22, 3-23, 3-27, 4-2, 4-

22, 4-29, 4-30, 4-31, 4-32, 4-35, 4-36, 4-37, 

4-38, 4-39, 4-40, 4-41, 4-43, 4-44, 4-80, 6-

9, 6-11, 6-32

Core damage frequency, 4-72

Council on Environmental Quality, lxiii, 1-5, 1-

6, 1-7, 1-23, 3-9, 3-43, 5-19, 6-1, 6-3, 6-4,

6-60, 7-8, 7-9, 7-11, 7-15, 7-16, 8-10

Critical habitat, xxxvii, xxxviii, xlviii, liii, 3-28, 4-

43, 4-44, 4-45, 4-46, 5-30, 5-31, 5-32, 5-33, 

5-55, 8-1, 8-4 

Criticality, 4-69, 4-70

Cultural resource, vii, ix, xii, xv, xxix, xxxi, 

xxxiii, xxxviii, xliii, xlix, liii, lv, lviii, lix, 1-23, 

3-29, 3-30, 3-31, 4-13, 4-14, 4-47, 4-48, 4-

49, 4-50, 4-90, 4-91, 5-3, 5-33, 5-34, 5-35, 

5-36, 5-37, 5-54, 5-55, 6-10, 6-37, 6-38, 6-

39, 6-58, 8-3, 8-4, 8-5, 8-7, 8-8, 8-10, 9-2, 

9-3 

D

Decommissioning, vi, xiii, xix, xxii, xxvii, xxxvii, 

xxxix, l, lii, liv, lvii, 1-16, 1-17, 1-19, 1-22, 1-

29, 2-2, 2-4, 2-5, 2-6, 2-7, 2-9, 2-10, 2-11, 

2-16, 2-17, 2-18, 2-22, 2-23, 2-24, 2-25, 2-

26, 2-31, 3-4, 3-5, 3-7, 3-19, 3-20, 3-33, 3-

41, 3-43, 3-44, 3-45, 3-46, 3-47, 4-2, 4-10, 

4-18, 4-19, 4-26, 4-33, 4-45, 4-49, 4-58, 4-

59, 4-60, 4-79, 4-97, 5-3, 5-4, 5-21, 5-31, 5-

43, 5-44, 6-2, 6-3, 6-8, 6-9, 6-11, 6-12, 6-

13, 6-14, 6-15, 6-17, 6-18, 6-19, 6-20, 6-23, 

6-24, 6-27, 6-29, 6-32, 6-33, 6-35, 6-36, 6-

38, 6-39, 6-41, 6-44, 6-47, 6-48, 6-49, 6-51, 

6-54, 6-55, 6-57, 6-60, 6-61, 6-62, 6-65, 8-

10, B-9, B-10, B-11, B-16, B-18, B-19, B22, B-25, B-26, E-5, E-7, E-8, E-20, E-22, 

E-23, E-24, E-25, F-1, F-2, F-8, F-13, F-14, 

F-15, G-1, G-8, G-15

Decommissioning GEIS, xxii, l, 1-22, 2-5, 6-9, 

6-11, 6-13, 6-14, 6-17, 6-20, 6-24, 6-27, 6-

29, 6-33, 6-36, 6-38, 6-41, 6-44, 6-51, 6-54

Department of Energy, lxiii, 1-1, 1-4, 1-15, 1-

19, 1-23, 1-25, 1-28, 1-29, 2-1, 2-9, 2-10, 2-

12, 2-14, 2-17, 2-18, 2-19, 2-20, 2-21, 2-27, 

2-28, 2-30, 3-41, 4-3, 4-63, 4-67, 4-72, 4-

94, 5-1, 5-19, 5-57, 5-58, 5-59, 6-10, 6-14, 

6-20, 6-42, 6-46, 6-48, 6-60, B-3, B-4, B-5, 

B-22, B-23, B-25, B-26, E-4, E-23, E-24, G12, G-13, G-14

Design-basis accidents, xli, 4-67, 4-68, 4-70, 

4-71, 4-76, 4-77, 4-79, 6-56

Disposal (permanent), xiii, xxi, xxxix, xl, li, lix, 

1-1, 1-2, 1-3, 1-4, 1-17, 1-19, 1-22, 1-25, 1-

27, 1-28, 1-29, 2-3, 2-14, 2-18, 2-19, 2-24, 

2-29, 2-30, 3-17, 3-21, 3-34, 3-35, 3-36, 3-

41, 3-44, 4-55, 4-56, 4-57, 4-58, 4-59, 4-60, 

4-61, 4-62, 4-63, 4-90, 4-94, 5-21, 5-42, 5-

43, 5-44, 5-48, 5-49, 5-55, 5-57, 5-58, 6-9, 

6-10, 6-20, 6-42, 6-45, 6-46, 6-47, 6-48, 6-

49, 6-50, 6-51, 6-60, 8-8, 8-10, 9-2, B-1, B2, B-3, B-4, B-5, B-7, B-20, B-22, B-23, B26, F-9 

Dose, xix, xxx, xxxi, xl, xli, xlii, li, lii, lvii, lxiii, 

lxv, lxvi, 2-21, 3-38, 3-39, 3-40, 4-10, 4-12, 

4-13, 4-26, 4-55, 4-56, 4-64, 4-65, 4-66, 4-

67, 4-68, 4-70, 4-71, 4-77, 4-78, 4-82, 4-86, 

4-87, 4-89, 4-94, 4-97, 5-3, 5-11, 5-13, 5-

48, 5-50, 5-51, 5-52, 5-53, 6-50, 6-51, 6-52, 

6-53, 6-56, B-11, B-13, B-17, B-21, E-16, E18, E-21, E-24, F-1, F-2, F-3, F-5, F-6, F-8, 

F-12

E

Earthquake, xxviii, xli, xlii, lii, 1-10, 2-11, 3-15, 

4-69, 4-71, 4-72, 4-73, 4-76, 4-77, 4-79, 4-

81, 4-82, 5-53, B-9, B-10, B-14, B-15, B-16, 

B-26, E-1, F-12, F-13, G-1
Index

September 2013 10-3 Draft NUREG‒2157

Effluent, xxxv, xxxvi, xlvii, lvii, 2-3, 2-29, 3-17, 

3-38, 3-39, 4-5, 4-23, 4-27, 4-29, 4-31, 4-

32, 4-33, 4-34, 4-35, 4-38, 4-39, 4-41, 4-42, 

4-97, 5-11, 5-28, 6-56, B-17, B-18, E-6, E7, E-13, E-17, E-18, E-23, E-24, E-25

Electromagnetic field, lxiii, 3-22, 4-31, 6-53

Endangered species, xxviii, 3-28, 4-3, 5-5

Entrainment, 4-35, 4-36, 4-37, 4-38, 4-44, 6-

34, 6-35

Environmental justice, vi, viii, xi, xiv, xxix, xxx, 

xxxii, xlii, xliv, liii, liv, 3-8, 3-9, 3-10, 3-11, 3-

42, 3-43, 3-47, 4-9, 4-10, 4-11, 4-12, 4-14, 

4-90, 4-93, 4-97, 4-98, 4-101, 5-10, 5-11, 5-

12, 5-13, 5-54, 5-55, 5-57, 5-60, 6-16, 6-18, 

6-58, 6-59, 6-64, 8-2, 8-3, 8-4, 8-7, 8-12, 9-

2, 9-3, 9-4 

Environmental Protection Agency, xxv, xxxix, 

xlix, lvi, lxiii, 1-10, 1-11, 1-25, 1-28, 3-8, 3-

12, 3-13, 3-14, 3-15, 3-16, 3-17, 3-19, 3-32, 

3-35, 3-38, 3-42, 3-43, 3-44, 4-9, 4-19, 4-

26, 4-30, 4-36, 4-39, 4-51, 4-52, 4-57, 4-93, 

4-95, 5-16, 5-19, 5-38, 5-39, 5-40, 5-58, 6-

1, 6-22, 6-40, 6-42, 6-59, 6-61, 8-12, C-2, 

E-7, E-8, E-15, E-16, E-17, E-18, E-23

Essential Fish Habitat, xxxvii, xxxviii, lxiii, 3-

28, 3-29, 4-43, 4-44, 4-45, 4-46, 5-31, 5-32, 

5-33

Evacuation, B-11, F-3, F-4, F-5, F-6, F-7, F-8 

F

Findings, iii, lxiii, 1-2, 1-6, 1-7, 1-20, 1-22, 1-

24, 1-29, 2-9, 2-18, 3-43, 3-45, 4-45, 4-72, 

4-73, 4-81, 4-88, 4-89, 4-99, 5-6, 5-25, 5-

32, 5-33, 5-54, 6-59, 6-60, 7-6, 7-9, 7-11, 7-

15, 8-1, B-1, B-8, H-8 

Fish and Wildlife Service, xxxvii, xxxviii, lxiv, 

3-21, 3-28, 3-29, 3-44, 4-43, 4-44, 4-46, 4-

95, 5-30, 5-31, 5-32, 5-33, 5-58, 6-32, 6-35, 

6-36

Flood, xli, 4-69, 4-71, 4-73, 4-75, 4-76, 4-77, 

4-79, 4-82, 4-83, 4-96, 4-102, 5-5, B-14, E13

Frequency-weighted consequence, F-9 

Fuel cycle, 1-17, 1-22, 2-18, 3-38, 3-40, 6-22, 

6-46, 6-52, 6-55

Fukushima, 1-10, 2-11, 2-12, 2-32, 4-73, 4-

80, 4-101, B-10, B-15, B-16, B-20, B-24, F11, F-12, F-14, F-15

G

Greenhouse gases, vii, xxix, xxx, xxxiv, xlv, 

xlvi, lxiv, 3-11, 3-12, 3-43, 3-47, 3-48, 4-15, 

4-18, 4-19, 4-20, 4-75, 4-95, 4-101, 5-18, 5-

19, 5-20, 5-58, 5-60, 6-21, 6-22, 6-59, 6-61, 

6-64, 8-10

Groundwater, vii, ix, xii, xv, xxix, xxx, xxxv, 

xlii, xlvii, liii, liv, lvi, lvii, 2-27, 3-11, 3-16, 3-

17, 3-18, 3-19, 3-21, 3-47, 3-48, 4-10, 4-20, 

4-22, 4-23, 4-25, 4-26, 4-27, 4-28, 4-65, 4-

81, 4-90, 4-100, 5-23, 5-24, 5-25, 5-27, 5-

55, 6-28, 6-29, 6-30, 6-31, 6-58, 8-2, 8-3, 8-

5, 9-2, 9-4, B-17, B-25, B-26, E-1, E-5, E-6, 

E-7, E-8, E-9, E-10, E-11, E-12, E-13, E-14, 

E-15, E-16, E-17, E-18, E-19, E-20, E-21, 

E-22, E-23, E-24, E-25

H

Hardened onsite storage, xxiv

Hazardous waste, vii, xxx, xxxi, xxxix, 3-35, 3-

36, 3-42, 4-55, 4-57, 5-43, 6-46

High-level waste, lxiv, 1-9, 1-28, B-25

Human health, xxix, xxxii, xxxiii, 3-8, 3-9, 3-

10, 3-11, 3-35, 4-9, 4-10, 4-11, 4-12, 4-13, 

4-14, 4-67, 4-75, 5-10, 5-11, 5-50, 5-51, 5-

52, 6-16, 6-17, 6-18, 6-53, 8-2, 8-7, 8-8, F-3 
Index

Draft NUREG‒2157 10-4 September 2013

I

Impingement, 4-35, 4-36, 4-37, 4-38, 4-44, 6-

34, 6-35

Institutional control, xxvi, 1-14, 1-15, 1-28, 1-

30

Interim storage, xxvi, 2-3, 2-18, B-4 

L

Land use, vi, viii, xi, xiii, xxix, xxx, xxxii, xlii, 

xliv, xlvii, liii, liv, lix, 1-16, 2-7, 3-1, 3-3, 3-

20, 3-24, 3-44, 4-3, 4-4, 4-5, 4-6, 4-11, 4-

90, 5-5, 5-6, 5-7, 5-8, 5-10, 5-12, 5-28, 5-

55, 6-10, 6-11, 6-12, 6-58, 8-2, 8-3, 8-4, 8-

8, 9-2, 9-5, F-7

License renewal, xvi, xxi, xxii, xxviii, xxix, 

xxxv, xxxvi, lvii, 1-3, 1-6, 1-11, 1-19, 1-21, 

1-22, 1-30, 2-26, 2-32, 3-1, 3-2, 3-5, 3-11, 

3-12, 3-14, 3-15, 3-19, 3-21, 3-22, 3-25, 3-

28, 3-31, 3-33, 3-36, 3-46, 3-48, 4-2, 4-3, 4-

15, 4-25, 4-29, 4-30, 4-31, 4-32, 4-35, 4-36, 

4-37, 4-38, 4-39, 4-40, 4-41, 4-47, 4-48, 4-

51, 4-53, 4-55, 4-56, 4-57, 4-59, 4-62, 4-65, 

4-66, 4-81, 4-98, 4-99, 4-100, 4-102, 5-13, 

5-34, 5-36, 5-44, 5-60, 6-4, 6-6, 6-13, 6-17, 

6-25, 6-47, 6-49, 6-51, 6-52, 6-63, 6-64, 6-

65, 7-2, 7-4, 7-5, 7-6, 7-7, 7-9, 7-11, 7-17, 

B-7, B-12, B-14, B-19, C-1, C-2, E-5, E-22, 

E-26, F-10, F-12, F-15, F-16, H-1, H-3, H-4, 

H-5, H-7, H-8 

License Renewal GEIS, xxii, xxix, xxxv, xxxvi, 

lvii, 1-11, 1-22, 3-1, 3-2, 3-12, 3-14, 3-15, 3-

19, 3-21, 3-22, 3-25, 3-28, 3-31, 3-36, 4-3, 

4-15, 4-25, 4-29, 4-30, 4-31, 4-32, 4-35, 4-

36, 4-37, 4-38, 4-39, 4-40, 4-41, 4-47, 4-51, 

4-53, 4-55, 4-56, 4-57, 4-62, 4-65, 4-66, 4-

81, 6-4, 6-13, 6-17, 6-47, 6-49, 6-51, 6-52, 

7-5, F-10, F-12

License termination, 1-23, 1-29, 6-24, E-8, E24

Low-level waste, xxxix, xl, xliii, l, li, liii, lxiv, 1-

17, 1-24, 3-33, 3-34, 3-35, 4-55, 4-56, 4-57, 

4-58, 4-59, 4-60, 4-61, 4-62, 4-63, 4-64, 4-

91, 5-42, 5-43, 5-44, 5-48, 5-49, 5-56, 6-11, 

6-45, 6-46, 6-47, 6-48, 6-49, 6-51, 8-3, 8-4 

M

Mitigation, xxxvii, xlviii, lvii, 3-12, 3-19, 4-36, 

4-43, 4-44, 4-45, 4-46, 4-48, 4-85, 5-15, 5-

25, 5-29, 5-30, 5-31, 5-32, 5-34, 5-40, 6-11, 

6-19, 6-24, 6-26, 6-27, 6-29, 6-32, 6-35, 6-

36, 6-38, 6-41, 6-46, 6-48, 6-49, E-9, E-24, 

F-11, F-12, F-16

Mixed oxide fuel, xxvii, lxiv, 2-8 

Mixed waste, vii, x, xxx, xxxi, xxxix, xl, xliii, l, 

li, liii, 3-35, 4-55, 4-56, 4-57, 4-59, 4-60, 4-

91, 5-42, 5-43, 5-44, 5-56, 6-45, 6-46, 6-47, 

6-48, 6-49, 8-3, 8-4 

Monitoring, xxvii, xxxii, xxxiii, xxxiv, xxxv, 

xxxvii, xlv, lvi, lxv, 2-3, 2-14, 2-25, 2-26, 2-

28, 2-29, 3-11, 3-14, 3-17, 3-19, 3-38, 4-3, 

4-4, 4-5, 4-7, 4-10, 4-11, 4-12, 4-13, 4-14, 

4-15, 4-16, 4-20, 4-21, 4-23, 4-26, 4-27, 4-

30, 4-32, 4-36, 4-42, 4-43, 4-46, 4-49, 4-50, 

4-51, 4-52, 4-53, 4-58, 4-59, 4-65, 4-72, 4-

73, 5-3, 5-4, 5-11, 5-13, 5-14, 5-16, 5-28, 5-

30, 5-31, 5-38, 5-39, 5-42, 5-51, 6-54, B-7, 

B-17, B-18, B-20, B-25, E-4, E-5, E-6, E-7, 

E-9, E-10, E-15, E-16, E-18, E-20, E-21

N

National Ambient Air Quality Standards, lxiv, 

3-13, 3-14, 3-44, 5-14, 5-15

National Environmental Policy Act, iii, xviii, 

xix, xxi, xxii, xxiv, xxvii, xxviii, xxxviii, lx, lxiv, 

1-1, 1-3, 1-4, 1-5, 1-6, 1-7, 1-8, 1-11, 1-16, 

1-17, 1-18, 1-19, 1-20, 1-22, 1-25, 1-28, 3-

8, 3-9, 3-10, 3-31, 3-43, 3-45, 4-2, 4-9, 4-

11, 4-12, 4-17, 4-47, 4-49, 4-84, 4-96, 5-11, 

5-13, 5-32, 5-33, 5-34, 5-36, 5-58, 6-1, 6-4, 
Index

September 2013 10-5 Draft NUREG‒2157

6-16, 6-18, 6-39, 6-60, 6-61, 7-2, 7-6, 7-7, 

7-8, 7-9, 7-10, 7-11, 7-12, 7-16, 8-1, 8-5, 8-

8, 8-9, 8-10, 8-11, 8-12, 9-2, 9-3, G-2

National Historical Preservation Act, xxix, 

xxxi, xxxviii, xlix, lxiv, 3-30, 3-31, 3-32, 3-45, 

4-2, 4-13, 4-47, 4-48, 4-49, 4-50, 4-96, 5-

33, 5-34, 5-35, 5-36, 5-37, 5-58, 6-38, 6-39

National Marine Fisheries Service, xxxvii, 

xxxviii, lxiv, 3-28, 3-29, 4-43, 4-44, 4-45, 4-

46, 4-95, 5-30, 5-31, 5-32, 5-33, 5-58, 6-32, 

6-35, 6-36

National Pollution Discharge Elimination 

System, lxiv, 3-16, 3-17, 3-36, 4-21, 4-22, 

4-26, 4-30, 4-33, 4-39, 4-41, 4-42, 5-22, 5-

29, 6-27, 6-29, 6-32, 6-35

Native American, 2-4, 3-3, 3-6, 3-11, 3-30, 4-

10, 6-10, C-2

Natural phenomena, xli, lii, 3-12, 3-15, 4-18, 

4-67, 4-69, 4-71, 4-73, 4-75, 4-76, 4-77, 4-

78, 5-18, 5-53, 6-55

No-action alternative, iii, v, xvi, xix, xxiii, lv, 

lviii, 1-6, 1-7, 1-15, 4-67, 7-1, 7-7, 7-8, 7-9, 

7-10, 7-11, 7-12, 7-13, 7-14, 7-15, 8-10, 8-

11

O

Occupational Safety and Health 

Administration, lxiv, 3-32, 3-41, 4-66, 4-67, 

5-51, 6-54, 6-55

P

Population (population density), xix, xxix, xxx, 

xxxi, xxxii, xxxiii, xlv, liv, lvii, 2-4, 3-6, 3-7, 3-

8, 3-9, 3-10, 3-11, 3-26, 3-30, 3-32, 3-37, 3-

40, 3-42, 3-44, 3-45, 3-48, 4-7, 4-8, 4-9, 4-

10, 4-11, 4-12, 4-13, 4-14, 4-36, 4-37, 4-38, 

4-40, 4-45, 4-89, 4-93, 5-2, 5-8, 5-9, 5-10, 

5-11, 5-12, 5-13, 5-14, 5-31, 5-32, 5-33, 5-

40, 6-6, 6-7, 6-13, 6-16, 6-17, 6-18, 6-35, 6-

43, 6-50, 6-53, 6-65, 8-1, 8-7, 8-8, 8-12, E13, F-2, F-3, F-4, F-6, F-7, F-8, F-9, F-10, 

F-12

Postulated accident, x, xiii, xvi, xli, lii, 3-15, 4-

67, 4-76, 4-82, 5-52, 5-54, 6-55, 6-56, 6-57, 

B-11

Pressurized water reactor, xix, lxiv, lxv, 2-2, 2-

3, 2-4, 2-5, 2-6, 2-7, 2-8, 2-16, 2-17, 3-3, 3-

34, 4-2, 4-23, 4-70, 4-74, 4-97, 6-47, 7-4, 

B-9, B-10, B-23, B-26, E-1, E-2, E-3, E-17, 

E-19, E-24, F-10, F-11, F-13, F-16, G-1, G3, G-4, G-5, G-6, G-7, G-8, G-9, G-10, G11, G-12, G-13

Private Fuel Storage Facility, xliii, lxiv, 2-1, 2-

17, 2-27, 2-32, 4-9, 5-1, 5-2, 5-5, 5-6, 5-7, 

5-8, 5-9, 5-12, 5-13, 5-14, 5-15, 5-16, 5-18, 

5-20, 5-22, 5-23, 5-24, 5-25, 5-26, 5-27, 5-

29, 5-34, 5-35, 5-37, 5-38, 5-39, 5-40, 5-41, 

5-42, 5-43, 5-44, 5-45, 5-46, 5-47, 5-48, 5-

50, 5-51, 5-53, 5-54, 5-58, 5-59, 5-60, 6-9, 

6-15, 6-20, 6-27, 6-30, 6-33, 6-36, 6-41, 6-

44, 6-52, 6-54, 7-6, 7-17, B-14, B-26, G-12, 

G-13, G-15

R

Radionuclide, lvi, 2-24, 3-19, 3-21, 3-36, 4-20, 

4-22, 4-25, 4-26, 4-30, 4-31, 4-35, 4-40, 4-

65, 4-78, 6-30, 9-3, B-15, B-18, E-6, E-7, E8, E-9, E-10, E-11, E-12, E-15, E-16, E-17, 

E-18, E-20, E-22, E-23, F-3, F-9 

Remediation, E-6, E-7, E-8, E-15, E-16, E-21, 

E-23, E-24

Repackaging, xxvi, xxxvi, xxxix, xli, xliv, 2-19, 

2-21, 2-27, 2-28, 4-5, 4-6, 4-16, 4-33, 4-34, 

4-58, 4-59, 4-60, 4-63, 4-64, 4-67, 4-77, 5-

7, 5-17, 5-20, 5-25, 5-27, 5-43, 5-44, 5-49, 

5-52, 8-8, B-13, B-15, B-20

Repository (geologic), iii, xiii, xvii, xxi, xxii, 

xxv, xxviii, xliv, xlv, xlviii, lix, lx, 1-1, 1-2, 1-

3, 1-4, 1-9, 1-11, 1-13, 1-14, 1-19, 1-23, 1-

24, 1-25, 1-28, 1-29, 2-14, 2-18, 2-26, 2-27, 
Index

Draft NUREG‒2157 10-6 September 2013

2-29, 2-32, 4-1, 4-2, 4-5, 4-6, 4-9, 4-14, 4-

17, 4-20, 4-21, 4-24, 4-28, 4-50, 4-53, 4-54, 

4-61, 4-64, 4-67, 4-94, 5-3, 5-4, 5-5, 5-7, 5-

8, 5-10, 5-14, 5-17, 5-19, 5-20, 5-22, 5-24, 

5-25, 5-28, 5-30, 5-33, 5-41, 5-44, 5-45, 5-

50, 5-52, 5-57, 5-58, 5-59, 6-9, 6-10, 6-14, 

6-19, 6-20, 6-27, 6-29, 6-32, 6-35, 6-41, 6-

42, 6-47, 6-48, 6-51, 6-52, 6-54, 6-60, 8-6, 

8-9, B-1, B-2, B-3, B-4, B-5, B-6, B-7, B-20, 

B-22, B-23, B-25, B-26, E-1

Reprocessing, xxiii, 1-23, 1-24, 2-1, 2-10, 2-

11, 4-2, 5-45, E-4 

Risk, xxviii, xl, xlii, lii, lvii, 1-1, 1-3, 1-19, 1-23, 

2-12, 2-19, 3-8, 3-9, 3-11, 3-12, 3-38, 3-41, 

4-26, 4-61, 4-66, 4-67, 4-68, 4-69, 4-70, 4-

72, 4-73, 4-74, 4-76, 4-78, 4-79, 4-80, 4-82, 

4-83, 4-84, 4-86, 4-87, 4-89, 4-90, 4-96, 4-

97, 4-99, 4-100, 5-47, 5-48, 5-51, 5-54, 5-

60, 6-16, 6-17, 6-22, 6-50, 6-52, 6-55, 6-56, 

6-57, 6-62, 6-65, B-7, B-9, B-10, B-11, B14, B-15, B-25, F-1, F-2, F-3, F-4, F-6, F-7, 

F-8, F-9, F-10, F-11, F-12, F-13, F-14, F-15

Rulemaking, 1-iv, xxi, xxii, xxiii, xxiv, xxv, lv, 

lvi, lxi, lxii, 1-1, 1-2, 1-3, 1-9, 1-22, 1-26, 1-

27, 1-29, 1-30, 2-11, 3-10, 3-31, 4-47, 4-86, 

4-93, 5-33, 7-2, 7-7, 7-9, 7-10, 7-12, 7-14, 

8-11, B-5, B-6, B-8, C-2, C-4, C-5, C-6, C-7, 

C-8, E-1, E-8, E-24, F-1, F-10, F-14, H-1, 

H-6, H-7

S

Safety, xxi, xxviii, xl, xli, xlii, li, lii, lvii, lxiii, lxiv, 

1-1, 1-9, 1-14, 1-15, 1-25, 2-2, 2-4, 2-11, 2-

12, 2-14, 2-19, 2-21, 2-24, 2-25, 2-26, 2-28, 

2-30, 2-31, 2-32, 2-33, 3-6, 3-7, 3-13, 3-15, 

3-38, 3-41, 3-42, 3-44, 3-46, 3-48, 4-2, 4-4, 

4-47, 4-48, 4-61, 4-63, 4-64, 4-66, 4-67, 4-

68, 4-69, 4-70, 4-71, 4-72, 4-73, 4-74, 4-75, 

4-76, 4-77, 4-79, 4-80, 4-83, 4-86, 4-87, 4-

88, 4-90, 4-94, 4-95, 4-96, 4-99, 4-100, 4-

102, 5-1, 5-34, 5-48, 5-49, 5-51, 5-53, 5-56, 

5-57, 5-58, 6-14, 6-56, 6-57, 6-59, 6-60, 7-

3, 7-17, 9-1, 9-2, B-2, B-3, B-4, B-6, B-7, B9, B-10, B-11, B-12, B-13, B-14, B-15, B16, B-17, B-19, B-20, B-21, B-23, B-25, B26, E-4, E-12, E-15, E-22, E-23, E-24, F-6, 

F-10, F-13, F-14, F-15, F-16, G-1, G-2, G14

Scoping, iii, v, xvii, xxiv, xxv, lix, lx, 1-8, 1-10, 

1-24, 1-30, 6-1, 8-12, 8-13, 9-4, 9-5, A-1, A2, C-1, C-2, C-3, C-4, C-5, C-7, C-8 

Seismic, 2-12, 3-15, 4-71, 4-72, 4-80, 4-81, 4-

99, 4-100, 4-101, B-9, B-11, B-16, E-20, E21, F-3, F-5, F-7, F-9, F-13, F-15

Severe accidents, xi, xxviii, xli, xlii, 2-33, 3-37, 

4-67, 4-68, 4-69, 4-79, 4-80, 4-81, 4-82, 4-

83, 4-85, 6-55, 6-56, 6-57, B-11, F-3, F-6, 

F-7, F-8, F-9, F-13, F-15

Socioeconomic, vi, viii, xi, xiv, xxix, xxx, xxxii, 

xlii, xliv, liii, liv, lviii, 3-4, 3-5, 4-6, 4-7, 4-9, 

4-10, 4-11, 4-12, 4-90, 5-3, 5-8, 5-10, 5-11, 

5-12, 5-54, 5-55, 6-12, 6-13, 6-14, 6-15, 6-

16, 6-18, 6-58, 8-2, 8-3, 8-4, 8-7, 9-2, 9-3, 

9-4 

Solid waste, lviii, 3-35, 3-36, 5-44, 6-46, 6-61, 

8-6, 8-7, 9-3, 9-4, E-7, E-25

Spent fuel pool fires, xvii, xxii, xxviii, xlii, lvi, 

lvii, lx, 1-3, 1-24, 2-8, 4-81, 4-86, 9-2, 9-4, 

B-11, F-1, F-2, F-3, F-4, F-5, F-6, F-7, F-8, 

F-9, F-10, F-11, F-12, F-13, F-14

Spent fuel pool leaks, xvii, xxi, xxxv, xl, lvi, lvii, 

lx, 1-3, 1-24, 3-19, 4-20, 4-23, 4-26, 4-65, 

9-2, 9-3, 9-5, B-17, B-18, B-20, E-1, E-7, E8, E-9, E-10, E-11, E-12, E-13, E-14, E-15, 

E-16, E-17, E-18, E-19, E-20, E-21, E-23, 

E-24, E-25

Stormwater, xlvi, xlviii, 3-17, 3-36, 4-21, 4-22, 

4-23, 4-27, 4-33, 4-41, 4-42, 5-5, 5-22, 5-

28, 5-29, 6-27, 6-32, 6-35

Surface water, vii, viii, xii, xiv, xxix, xxx, xxxv, 

xlii, xlvi, liii, liv, lvi, 3-11, 3-16, 3-17, 4-10, 4-
Index

September 2013 10-7 Draft NUREG‒2157

22, 4-23, 4-24, 4-25, 4-29, 4-30, 4-37, 4-39, 

4-90, 5-22, 5-23, 5-24, 5-25, 5-27, 5-55, 6-

24, 6-25, 6-26, 6-27, 6-28, 6-29, 6-31, 6-34, 

6-58, 8-2, 8-3, 8-5, 9-2, 9-5, E-1, E-13, E15, E-17, E-18, E-19

T

Tax, vi, xxix, xxx, xxxii, lviii, 3-4, 3-6, 3-7, 3-

43, 3-48, 4-6, 4-7, 4-8, 4-9, 5-9, 5-10, 5-11, 

5-54, 6-13, 6-14, 6-15, 6-17, 8-7

Terrorism, xi, xiii, xlii, xliii, lii, liii, 4-3, 4-84, 4-

86, 4-90, 4-91, 5-54, 5-56, 8-3, 8-4, B-16, 

B-21

Thermal impacts, xxxvi, 4-35, 4-38, 4-39, 4-

40, 4-41, 4-44

Threatened species, xxxvii, 3-28

Tornado, xli, lii, 3-12, 4-68, 4-71, 4-74, 4-76, 

4-77, 4-79, 4-80, 4-81, 4-83, 4-96, 4-99, 5-

53, 6-55, F-7, G-2

Transmission lines, 2-2, 2-3, 3-1, 3-15, 3-21, 

3-22, 4-15, 4-31, 5-3, 5-6, 6-6, 6-11, 6-32, 

6-38, 6-43, 6-54

Tribal, xxiv, 3-8, 3-13, 3-14, 3-32, 4-9, 4-48, 5-

2, 5-34, 5-35, A-1, C-1, C-2, C-4 

Tritium, xxix, xxxv, lvii, 3-19, 3-21, 4-20, 4-78, 

E-8, E-12, E-18, E-20, E-21, E-22, E-24

U

Uranium, xxii, xxvii, xliii, lxiv, lxvii, 1-17, 1-22, 

2-6, 2-7, 2-8, 2-9, 2-10, 2-25, 3-38, 3-39, 6-

6, 6-46, 6-52, 6-61, 7-4, B-8, B-12, F-14

W

Waste Confidence, iii, v, xviii, xxi, xxii, xxiii,

xxiv, xxv, xxvi, lvi, lviii, lix, lx, lxi, 1-1, 1-2, 1-

3, 1-4, 1-6, 1-10, 1-11, 1-21, 1-22, 1-24, 1-

27, 1-30, 2-1, 3-1, 3-10, 3-31, 4-1, 4-11, 4-

47, 4-84, 4-93, 5-1, 5-11, 6-1, 7-1, 7-2, 7-3, 

7-6, 7-7, 7-8, 7-17, 8-2, 8-13, 9-1, 9-2, A-1, 

A-2, B-1, B-2, B-5, B-6, B-8, B-10, B-22, C1, C-2, C-3, C-4, C-5, C-6, C-7, C-8, E-1, E8, F-1, H-1, H-5

Wetlands, vii, xxix, xxxi, xlvii, 3-2, 3-20, 3-21, 

3-24, 3-44, 4-33, 5-26, 5-27, 6-11, 6-31, 6-

32

Y

Yucca Mountain, 1-15, 1-19, 1-28, 1-29, 2-32, 

4-67, 4-94, 5-19, 5-57, 5-58, 5-59, 6-20, 6-

42, 6-48, 6-60, B-3, B-22, B-23, B-25, B-26, 

C-2

Yucca Mountain EIS, 5-19, 6-20, 6-42

Appendix A 

–

Scoping Comments

September 2013 A-1 Draft NUREG‒2157

Appendix A

Scoping Comments

1 In this appendix, the U.S. Nuclear Regulatory Commission (NRC) incorporates, by reference, 

2 the “Waste Confidence Generic Environmental Impact Statement Scoping Process Summary 

3 Report” (Scoping Summary Report), which was prepared by the NRC in response to comments 

4 received on the scope of the environmental review. The NRC issued the Scoping Summary 

5 Report on March 4, 2013. 

6 The Scoping Summary Report is available for public inspection in the NRC Public Document 

7 Room, located at One White Flint North, 11555 Rockville Pike, Rockville, Maryland, 20852 or 

8 from the NRC’s Agencywide Documents Access and Management System (ADAMS). The 

9 ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading 

10 rm/adams/web-based.html. The Scoping Summary Report is listed under Accession No. 

11 ML13060A128. Persons who do not have access to ADAMS or who encounter problems in 

12 accessing the documents located in ADAMS should contact the NRC’s Public Document Room 

13 reference staff by telephone at 1-800-397-4209 or 301-415-4737 or by e-mail at pdr@nrc.gov. 

14 On October 25, 2012, the NRC published in the Federal Register a Notice of Intent to prepare 

15 an environmental impact statement and conduct scoping, “Consideration of Environmental 

16 Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation” 

17 (77 FR 65137). The notice described the NRC’s intent to prepare a Waste Confidence Generic

18 Environmental Impact Statement (GEIS) and conduct webcast public scoping meetings and 

19 webinars and requested comments on the scope of the Waste Confidence GEIS. Through the 

20 notice, the NRC invited Federal, Tribal, State, and local governments; organizations; and 

21 members of the public to provide comments on the scope of the GEIS no later than 

22 January 2, 2013.

23 During the 70-day scoping period, the NRC held two public webcast scoping meetings and two 

24 scoping webinars. The meetings and webinars each began with a slide presentation by NRC, 

25 which was followed by a question-and-answer period and a block of time dedicated to listening 

26 to and transcribing public scoping comments. The NRC considered all comments received 

27 during the scoping meetings and webinars and all written comments submitted in-person at the 

28 November 14, 2012 afternoon meeting. Appendix C provides the ADAMS accession numbers 

29 for the meeting summaries and transcripts.

30 In addition, the NRC received hundreds of written comment letters through mail, fax, and 

31 www.Regulations.gov (Docket ID NRC–2012–0246) during the comment period. Comments 
Appendix A

Draft NUREG‒2157 A-2 September 2013

1 received after the January 2, 2013 closing date were considered where practicable. The NRC 

2 reviewed and considered written comments together with the comments received during the 

3 public meetings and webinars. Individual comments each received a unique comment 

4 identification code, to ensure that each comment could be tracked, and received a response. 

5 Comments were consolidated and categorized according to subject matter or topic. The 

6 Scoping Summary Report contains the NRC responses to these grouped comments. 

7 Separately, the NRC published a document containing the text of the comments, “Scoping 

8 Comments on the Waste Confidence Generic Environmental Impact Statement,” which is 

9 located in ADAMS under Accession No. ML13060A130. This document contains a table that 

10 identifies comments made in each category and provides those comment excerpts organized by 

11 comment category. 

12 As a result of the scoping process, the NRC identified and eliminated peripheral issues that will 

13 not be covered in the Waste Confidence GEIS. The Scoping Summary Report provides 

14 responses that either discuss why particular topics or concerns are outside the scope of the 

15 GEIS or indicates concerns or topics that are in scope and will be evaluated in the GEIS.

16 Further detail regarding scoping, public comments received, and the NRC’s responses can be 

17 found in the full text of the Scoping Summary Report. Comments received on the draft GEIS 

18 will be included in Appendix D of the final GEIS.
Appendix B

–

Technical Feasibility of Continued Storage and 

Repository Availability

September 2013 B-1 Draft NUREG‒2157

Appendix B 

Technical Feasibility of Continued Storage and 

Repository Availability

1 B.1 Introduction 

2 In this Waste Confidence Generic Environmental Impact Statement (draft GEIS), the NRC

3 addresses the environmental impacts of continuing to store spent nuclear fuel (spent fuel) at a 

4 reactor site or at an away-from-reactor storage facility, after the end of a reactor’s licensed life 

5 for operation until final disposition in a geologic repository (“continued storage”). This draft 

6 GEIS, if adopted, would provide a regulatory basis for the U.S. Nuclear Regulatory 

7 Commission’s (NRC’s) proposed amendment to Part 10 of the Code of Federal Regulations

8 (CFR) 51.23. Historically, the Waste Confidence decision contained five “findings” that 

9 addressed technical feasibility of a mined geologic repository, the degree of assurance that 

10 disposal would be available by a certain time, and the degree of assurance that spent fuel and 

11 high-level waste could be managed safely without significant environmental impacts for a 

12 certain period beyond the expiration of plants’ operating licenses. Preparation of and reliance 

13 upon a GEIS is a fundamental departure from the approach used in past Waste Confidence 

14 proceedings. This draft GEIS acknowledges the uncertainties in the Commission’s prediction of 

15 repository availability and provides an environmental analysis of any reasonably foreseeable 

16 timeframes. To this end the draft GEIS considers a number of possible timeframes for 

17 repository availability, including the impacts from never having a repository.

18 The NRC’s underlying conclusions regarding the technical feasibility for continued storage and 

19 repository availability, based on the best available information, continue to undergird its 

20 environmental analyses. These underlying conclusions, which are relevant to an analysis of the 

21 potential environmental impacts assessed in this draft GEIS, are discussed as two broad issues 

22 in this appendix: the NRC’s technical information as to the availability of a repository for 

23 disposal of spent fuel generated in a power reactor (Section B.2) and the technical feasibility of 

24 safe storage of spent fuel in an at-reactor or away-from-reactor storage facility until sufficient 

25 repository capacity becomes available (Section B.3). These two broad issues were addressed 

26 in the five findings contained in earlier versions of the Waste Confidence decision. The same 

27 issues will be addressed in this appendix, but the information is presented under these two 

28 broad topic areas rather than “five findings.”
Appendix B

Draft NUREG‒2157 B-2 September 2013

1 B.2 Repository Capacity will be Available to Dispose of Spent 

2 Fuel 

3 The NRC must answer two questions to determine whether sufficient repository capacity will be 

4 available to dispose of spent fuel at the end of the short-term storage timeframe: whether a 

5 repository is technically feasible and, if so, how long will it take to site, license, construct, and 

6 open a repository. “Technical feasibility” simply means whether a geologic repository is 

7 technically possible using existing technology (i.e., without any fundamental breakthroughs in 

8 science and technology). If technically feasible, then the question becomes what is a 

9 reasonable timeframe for the siting, licensing, construction, and opening of a geologic 

10 repository. Both of these questions are discussed in detail below in Sections B.2.1 (Technical 

11 Feasibility of a Repository) and B.2.2 (Availability of Repository Capacity).

12 B.2.1 Technical Feasibility of a Repository

13 Historically, the Commission has consistently determined that current knowledge and 

14 technology support the technical feasibility of deep geologic disposal. In its original 1984 Waste 

15 Confidence decision, the NRC stated that “[t]he Commission finds that safe disposal of [high16 level radioactive waste and spent nuclear fuel] is technically possible and that it is achievable 

17 using existing technology” (49 FR 34658) (emphasis added). The Commission then stated: 

18 “Although a repository has not yet been constructed and its safety and environmental 

19 acceptability demonstrated, no fundamental breakthrough in science or technology is needed to 

20 implement a successful waste disposal program.” Though the Commission has revisited its 

21 Waste Confidence decision since 1984, this focal point – whether a fundamental breakthrough 

22 in science or technology is needed – continues to guide the Commission’s consideration of the 

23 feasibility of commercial nuclear waste disposal. Since 1984, the technical feasibility of a 

24 geological repository has moved significantly beyond a theoretical concept.

25 Today, the consensus within the scientific and technical community engaged in nuclear waste 

26 management is that safe geologic disposal is achievable with currently available technology

27 (see, e.g., Blue Ribbon Commission on America’s Nuclear Future 2012, Section 4.3). Currently, 

28 25 countries, including the United States, are considering disposal of spent or reprocessed 

29 nuclear fuel in deep geologic repositories. Repository programs in other countries, which 

30 continue to provide additional information useful to the U.S. program, are actively considering 

31 crystalline rock, clay, and salt formations as repository host media (IAEA 2005). Many of these 

32 programs have researched these geologic media for several decades.

33 Ongoing research in both the United States and other countries supports a conclusion that 

34 geological disposal remains viable and that acceptable sites can be identified. Despite decades 

35 of research into various geological media, no insurmountable technical or scientific problem has 

36 emerged to challenge the idea that safe disposal of spent fuel and high-level radioactive waste

37 can be achieved in a mined geologic repository. Over the past two decades, significant 
Appendix B

September 2013 B-3 Draft NUREG‒2157

1 progress has been made in the scientific understanding and technological development needed 

2 for geologic disposal. A number of reports, including the following examples, document the 

3 experience gained at an international level on geological disposal:

4 • “Geological Repository Systems for Safe Disposal of Spent Nuclear Fuels and Radioactive 

5 Wastes” (Ahn and Apted 2010)

6 • “Scientific and Technical Basis for the Geologic Disposal of Radioactive Wastes, Technical 

7 Reports Series No. 413” (IAEA 2003a)

8 • “Lessons Learned from Ten Performance Assessment Studies” (Nuclear Energy Agency 

9 1997)

10 • “Radioactive Waste Management Studies and Trends, IAEA/WMDB/ST/4” (IAEA 2005)

11 • “The Use of Scientific and Technical Results from Underground Research Laboratory 

12 Investigations for the Geologic Disposal of Radioactive Waste” (IAEA 2001)

13 • “Joint Convention on Safety of Spent Fuel Management and on Safety of Radioactive Waste 

14 Management, INFCIRC/546” (IAEA 1997)

15 In the United States, the recent report by the Blue Ribbon Commission on America’s Nuclear 

16 Future (Blue Ribbon Commission 2012) supported geologic disposal by concluding that:

17 “geologic disposal in a mined repository is the most promising and technically 

18 accepted option available for safely isolating high-level nuclear wastes for very 

19 long periods of time. This view is supported by decades of expert judgment and 

20 by a broad international consensus. All other countries with spent fuel and high21 level waste disposal programs are pursuing geologic disposal. The United 

22 States has many geologic media that are technically suitable for a repository.”

23 In addition, support for the feasibility of geologic disposal can be drawn from experience gained 

24 from the review of the U.S. Department of Energy’s (DOE’s) Yucca Mountain, Nevada, license 

25 application (DOE 2008). On June 3, 2008, the DOE submitted an application for a construction 

26 authorization to the NRC, and on September 8, 2008, the NRC notified DOE that it found the 

27 application acceptable for docketing (73 FR 53284) and began its review. Although DOE 

28 subsequently filed a motion with an NRC Atomic Safety and Licensing Board seeking 

29 permission to withdraw the license application for a high-level nuclear waste repository at Yucca 

30 Mountain (NRC 2010a), the NRC’s review continued until September 2011. The NRC’s review 

31 did not identify any issues that would challenge the feasibility of geological disposal. This 

32 conclusion is reflected in two technical review documents: NUREG–2108, “Technical 

33 Evaluation Report on the Content of the U.S. Department of Energy Yucca Mountain Repository 

34 License Application - Preclosure Volume: Repository Safety Before Permanent Closure” (NRC

35 2011a) and NUREG–2107, “Technical Evaluation Report on the Content of the U.S. Department 

36 of Energy’s (DOE’s) Yucca Mountain Repository License Application” (NRC 2011b). These 

37 documents contain the NRC technical reviews of the DOE license application for Yucca 

38 Mountain in the areas of safety before and after permanent closure.
Appendix B

Draft NUREG‒2157 B-4 September 2013

1 The technical feasibility of a deep geologic repository is further supported by current DOE

2 defense-related activities. The DOE sited and constructed, and since March 1999 has been 

3 operating a deep geologic repository for defense-related transuranic radioactive wastes near 

4 Carlsbad, New Mexico. This Waste Isolation Pilot Plant is located in the Chihuahauan Desert of 

5 southeastern New Mexico, approximately 42 km (26 mi) east of Carlsbad. The facility is used to 

6 store transuranic waste from nuclear weapons research and testing operations from past 

7 defense activities. Project facilities include mined disposal rooms 655 m (2,150 ft) underground.

8 Recently, in January 2013, the DOE released “Strategy for the Management and Disposal of 

9 Used Nuclear Fuel and High-Level Radioactive Waste,” a response to the Blue Ribbon 

10 Commission on America’s Nuclear Future’s report (DOE 2013). In this strategy document, DOE 

11 presents a framework for “moving toward a sustainable program to deploy an integrated system 

12 capable of transporting, storing, and disposing of used nuclear fuel and high-level radioactive 

13 waste from civilian nuclear power generation...” (DOE 2013). This new DOE strategy includes 

14 a nuclear waste-management system consisting of a pilot interim storage facility, a larger full15 scale interim storage facility, and a geologic repository. U.S. policy remains that geologic 

16 disposal is the appropriate long-term solution for disposition of spent fuel and high-level 

17 radioactive waste.

18 Finally, the activities of European countries support the technical feasibility of a deep geologic 

19 repository. In late 2012, a Finish nuclear-waste-management company (Posiva) submitted a 

20 construction licence application for a geological repository for spent fuel to Finland’s Radiation 

21 and Nuclear Safety Authority, and in spring 2011, Swedish nuclear authorities accepted an 

22 application from the Swedish Nuclear Fuel and Waste Management Company for permission to 

23 build a repository for spent fuel. Based on the national and international information and 

24 experience with geological disposal, the NRC concludes that a geologic repository continues to 

25 be technically feasible.

26 B.2.2 Availability of Repository Capacity

27 Given the international consensus that geologic repositories are technically feasible, 

28 international experience is also relevant in determining the timeframe to successfully site, 

29 license, construct, and open a repository. Of the 24 countries, other than the United States,

30 considering disposal of spent or reprocessed nuclear fuel in deep geologic repositories, 10 have 

established target dates for the availability of a repository.1 31 The majority of the 14 countries with 

32 no established target date for repository availability rely on centralized interim storage, which 

33 may include a protracted period of at-reactor storage before shipment to a centralized facility.

 

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

September 2013 B-5 Draft NUREG‒2157

1 The process of consensus building, by which time is taken to build support from potential host 

2 communities, is most evident from repository-development programs in Finland and Sweden. In 

3 Finland, preliminary site investigations started in 1986 and detailed characterizations of four 

4 locations were performed between 1993 and 2000. In 2001, the Finnish Parliament ratified the 

5 Government’s decision to proceed with a repository project at a chosen site only after the 

6 1999 approval by the municipal council of the host community. In December 2012, Posiva 

7 submitted a construction license application for a final repository that will hold spent fuel from 

8 Finland’s nuclear reactors (Posiva 2011). Finland expects this facility to begin receipt of spent 

9 fuel for disposal in 2020, 34 years after the start of preliminary site investigations.

10 Between 1993 and 2000, Sweden conducted feasibility studies in eight municipalities. One site 

11 was found technically unsuitable and two sites were eliminated by municipal referenda. Three of 

12 the remaining five sites were selected for detailed site investigations. Municipalities adjacent to 

13 two of these sites agreed to be potential hosts and one refused. Since 2007, detailed site 

14 investigations have been conducted for the sites located in the Oesthammer and Oskarshamn

15 municipalities, both of which already host nuclear power stations. On June 3, 2009, the Swedish 

16 Nuclear Fuel and Waste Management Company selected the Forsmark Site located in the 

17 Oesthammer municipality for the Swedish spent fuel repository. The Swedish Nuclear Fuel and 

18 Waste Management Company submitted a license application in spring 2011. A government 

19 decision is expected in 2015. If Swedish authorities authorize construction, the repository could 

20 be available for disposal around 2025, about 30 years after feasibility studies began. 

21 In the United States, the Blue Ribbon Commission on America’s Nuclear Future recommended

22 “prompt efforts to develop one or more geologic disposal facilities” (Blue Ribbon Commission

23 2012). In response, the DOE (2013) stated that the “goal is to have a repository sited by 2026; 

24 the site characterized, and the repository designed and licensed by 2042; and the repository 

25 constructed and its operations started by 2048.” Consistent with the discussion in the 2010 

26 Waste Confidence rulemaking (75 FR 81037) and subsequent events, the NRC continues to 

27 believe that 25 to 35 years is a reasonable period for repository development (e.g., candidate 

28 site selection and characterization, final site selection, licensing review, and initial construction 

29 for acceptance of waste).

30 Another important consideration is that broader institutional issues affect the time it will take to 

31 implement geologic disposal. International and domestic experience have made it clear that 

32 technical knowledge and experience alone are not sufficient to bring about the broad social and 

33 political acceptance needed to construct a repository. The time needed to develop a societal 

34 and political consensus for a repository could add to the time to site and license a repository or 

35 overlap it to some degree. 

36 Inasmuch as the availability of a repository can be substantially affected by whatever process is 

37 employed to achieve a national consensus on repository site selection, this draft GEIS offers 

38 three alternative timeframes for continued storage that reflect significant differences in the 
Appendix B

Draft NUREG‒2157 B-6 September 2013

1 availability of the repository. The short-term timeframe considered in this draft GEIS assumes a 

2 repository is available 60 years after the end of a reactor’s licensed life for operation. The long3 term storage timeframe assumes a repository is not available for an additional 100 years 

4 beyond the short-term storage timeframe, which means a repository would be available 

5 160 years after the end of a reactor’s licensed life for operation. In recognition of the uncertainty 

6 in reaching a national consensus on repository site selection, the third timeframe assumes that 

7 a repository never becomes available and the spent fuel needs to be stored indefinitely.

8 In the 2010 Waste Confidence decision, the Commission assessed the length of time that would 

9 be needed to site, license, construct, and open a repository. This analysis moved away from 

10 the Commission’s historical practice of specifying a “target date” and instead concluded that a 

11 repository would be available “when necessary.” The Commission’s reluctance to select a 

12 target date was not indicative of an inability to predict the length of the process for siting, 

13 constructing, licensing, and opening a repository, but rather that identification of a specific year 

14 as a starting point was uncertain. Based on experience in licensing similarly complex facilities 

15 in the United States and national and international experience with repositories already in 

16 progress, the NRC concludes the time period needed to develop a repository is approximately 

17 25 to 35 years.

18 B.3 Technical Feasibility of Safe Storage

19 Spent fuel removed from a reactor is initially placed in a spent fuel pool for cooling. After 

20 several years (about 5 years for low-burnup fuel and up to 20 years for high-burnup fuel), the 

21 spent fuel is sufficiently cooled that it can be placed in dry cask storage assuming current 

22 storage configurations and heat loads. After the end of a reactor’s licensed life for operations, 

23 spent fuel is stored in onsite spent fuel pools or in an at-reactor or away-from-reactor dry cask 

24 storage systems.

25 In its initial Waste Confidence decision in 1984, the Commission found that spent fuel can be 

26 stored safely and without significant environmental impacts for at least 30 years beyond the 

27 expiration of a reactor’s licensed life for operation (49 FR 34658). This conclusion focuses on 

28 whether reactor licensees can safely store their spent fuel in the period between the cessation 

29 of reactor operations and the availability of repository capacity for their fuel. In 1990, the 

30 Commission reaffirmed its conclusion and further determined that if a reactor’s operating license 

31 were renewed, storage would be safe and without significant environmental impacts for at least 

32 30 years beyond a reactor’s licensed life for operations for a total of at least 100 years 

33 (55 FR 38474). In both its 1984 and 1990 rulemaking, the Commission looked at four broad 

34 issues in assessing the technical feasibility of storage: 

35 1. the long-term integrity of spent fuel under water pool storage conditions

36 2. the structure and component safety for extended facility operation for storage of spent fuel in 

37 water pools
Appendix B

September 2013 B-7 Draft NUREG‒2157

1 3. the safety of dry storage

2 4. the potential risks of accidents and acts of sabotage at spent fuel storage facilities 

3 (49 FR 34658; 55 FR 38472; 75 FR 81037)

4 The Commission found that spent fuel would be managed safely because, under either a 

5 possession-only 10 CFR Part 50 license or a 10 CFR Part 72 license, the utility would remain 

6 under the NRC’s regulatory control and, thus, NRC inspections and oversight of storage 

7 facilities would continue (49 FR 34658; 55 FR 38472). In 1990, when extended storage at the 

8 reactor site seemed more probable, the Commission noted that 10 CFR Part 72 allowed for 

9 license renewals and that the NRC was considering issuance of a general 10 CFR Part 72 

10 license under which spent fuel could be stored in NRC-certified casks (55 FR 38472). The 

11 Commission reasoned that these regulations would provide additional NRC supervision of spent 

12 fuel management. 

13 Continued storage of spent fuel at at-reactor or away-from-reactor sites will be necessary until a 

14 repository is available for permanent disposal. The storage of spent fuel in any combination of 

15 storage (spent fuel pools or dry casks) will continue as a licensed activity under regulatory 

16 controls and oversight. Nonetheless, the conclusions reached by the NRC in the draft GEIS 

17 regarding the technical feasibility of continued storage do not rely solely on NRC’s regulatory 

18 framework governing these activities. Rather, these conclusions are also based on NRC’s 

19 experience with the actual storage of spent fuel under this regulatory framework and the 

20 continued application of proven fuel-storage methodologies. Continued safe storage of spent 

21 fuel requires both the technical feasibility of storage methods and a regulatory framework that 

22 provides for monitoring and oversight to address the potential for evolving issues. The technical 

23 feasibility of wet storage in spent fuel pools and dry casks are discussed separately in 

24 Sections B.3.1 and B.3.2. The regulatory framework applicable to both wet and dry storage is 

25 discussed in Section B.3.3. 

26 B.3.1 Technical Feasibility of Wet Storage

27 The technical feasibility of continued storage in spent fuel pools is supported by a number of 

28 technical considerations. First, the integrity of spent fuel and cladding (e.g., structurally sound 

29 such that the spent fuel can be handled by normal means) within the benign environment of the 

30 spent fuel pool’s controlled water chemistry is supported by operational experience and a 

31 number of scientific studies, some of which are summarized below. Further, the spent fuel 

32 pool’s robust structural design protects against a range of natural and human-induced 

33 challenges, which are discussed in detail in the following sections and in the body of the draft 

34 GEIS. 
Appendix B

Draft NUREG‒2157 B-8 September 2013

1 B.3.1.1 Integrity of Spent Fuel and Cladding in Spent Fuel Pools

2 In 1984, the NRC provided information supporting the low degradation rates of spent fuel in 

3 spent fuel pools based on national and international storage experience, which at that time 

totaled 18 years of experience with zirconium-clad fuel2 4 and 12 years of experience with 

5 stainless-steel-clad fuel (49 FR 34658). Examples of the cited information are: 

6 1. In “Behavior of Spent Nuclear Fuel in Water Pool Storage,” Johnson (1977) reported on 

7 corrosion studies of irradiated fuel at 20 reactor pools in the United States, finding no 

8 detectable degradation of zirconium cladding. 

9 2. At the American Nuclear Society’s Executive Conference on Spent Fuel Policy and its 

10 Implications, presented in Buford, Georgia, April 2 to 5, 1978, Johnson, Jr. (1978) presented 

11 “Utility Spent Fuel Storage Experience,” which reported that no degradation has been 

12 observed in commercial power reactor fuel stored in onsite pools in the United States and 

13 that extrapolation of corrosion data suggests that less than a tenth of a percent of the 

14 thickness of the zirconium clad would be corroded after 100 years. 

15 3. In “The Long-Term Storage of Irradiated CANDU Fuel Under Water,” Walker (1979)

16 concluded that “50 to 100 years under water should not significantly affect their [spent fuel 

17 bundles] integrity.”

18 Almost 30 years of additional experience has been gained since the publication of the first 

19 Waste Confidence rulemaking in 1984, during which time the technical basis for very slow 

20 degradation rates of spent fuel in spent fuel pools has continued to grow. Examples of this 

21 additional experience include the following:

22 1. In “Durability of Spent Nuclear Fuels and Facility Components in Wet Storage,” the IAEA 

23 (1998) summarized the durability of materials in wet storage, stating: “The zirconium alloys 

24 represent a class of materials that is highly resistant to degradation in wet storage, including 

25 some experience in aggressive waters. The only adverse experience involves Zircaloy clad

26 metallic uranium where mechanical damage to the cladding was a prominent factor during 

27 reactor discharge, exposing the uranium metal fuel to aqueous corrosion. Otherwise, the 

28 database for the zirconium alloys supports a judgment of satisfactory wet storage in the time 

29 frame of 50 to 100 years or more.” 

30 2. In “Spent Fuel Performance Assessment and Research: Final Report of a Co-Ordinated 

31 Research Project on Spent Fuel Performance Assessment and Research (SPAR) 

32 1997–2001,” the IAEA (2003b), while discussing spent fuel storage experience reported on 

33 a detailed review of the degradation mechanisms of spent fuel cladding under wet storage 

34 and stated that “wet storage of spent fuel only appears to be limited by adverse pool 

35 chemistry or the deterioration of the fuel storage pool structure.”

 

2 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 2013 B-9 Draft NUREG‒2157

1 3. In “Understanding and Managing Ageing of Materials in Spent Fuel Storage Facilities,” the 

2 IAEA (2006) reported that “[O]ver more than 40 years of experience with several million 

3 LWR rods, power reactor fuel with zirconium alloy cladding has had an excellent durability in 

4 wet storage” (IAEA 2006). The IAEA went on to state that “[D]estructive and non-destructive 

5 examinations of fuel rods, visual evidence and coupon studies [IAEA 2006; pp. 11, 13, 54–

6 58] all support resistance to aqueous corrosion. There have been no reports of fission gas 

7 evolution, indicative of cladding failure in wet storage. Rod consolidation campaigns have 

8 been conducted without any indication of storage induced degradation. There is a sufficient 

9 database to indicate that wet storage of fuel with zirconium alloy cladding can be extended 

10 for at least several decades.”

11 Based on available information and operational experience, degradation of the fuel cladding

12 occurs very slowly over time in the spent fuel pool environment. Degradation of the spent fuel 

13 should be minimal over the short-term storage timeframe. Thus, it is expected that only routine 

14 maintenance will be needed over the short-term storage timeframe. In the draft GEIS, the NRC 

15 assumes that the spent fuel pool will be decommissioned before the end of the short-term 

16 storage timeframe; however, the NRC is not aware of any information that would call into 

17 question the technical feasibility of continued safe storage of spent fuel in spent fuel pools 

18 beyond the short-term storage timeframe.

19 B.3.1.2 Robust Structural Design of Spent Fuel Pools

20 As described in Section 2.1.2.1 of the draft GEIS, spent fuel pools are massive, seismically21 designed structures that are constructed from thick, reinforced concrete walls and slabs that 

22 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.).3 23 Per 

24 NUREG–1738 (NRC 2001), “Technical Study of Spent Fuel Pool Accident Risk at 

25 Decommissioning Nuclear Power Plants,” spent fuel pool structures are designed to be 

26 seismically robust (i.e., it is expected that a seismic event with peak spectral acceleration 

27 several times larger than the safe shutdown earthquake would be required to produce 

28 catastrophic failure of the structure). Further, the NRC (2001) in evaluating the seismic risk to 

29 spent fuel pools states that “In boiling-water reactor (BWR) plants, the pool structures are 

30 located in the reactor building at an elevation several stories above the ground. In pressurized31 water reactor (PWR) plants, the [spent fuel pool] structures are outside the containment 

32 structure and supported on the ground or partially embedded in the ground. The location and 

33 supporting arrangement of the pool structures affect their capacity to withstand seismic ground 

34 motion beyond their design basis. The dimensions of the pool structure are generally derived 

 

3 The sole exceptions are Dresden Unit 1 and Indian Point Unit 1, which have no liner plates. 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

Draft NUREG‒2157 B-10 September 2013

1 from radiation shielding considerations rather than seismic demand needs. Spent fuel 

2 structures at nuclear power plants are able to withstand loads substantially beyond those for 

3 which they were designed.”

4 In its initial Waste Confidence decision, the Commission found that the risks of major accidents

5 at spent fuel pools resulting in offsite consequences were remote because of the secure and 

6 stable character of the spent fuel in the storage pool environment and the absence of reactive 

7 phenomena that might result in dispersal of radioactive material. The Commission noted that 

8 storage pools and independent spent fuel storage installations (ISFSIs) are designed to safely 

9 withstand accidents caused by either natural or man-made phenomena (49 FR 34658). By 

10 1990, the NRC had spent several years studying the potential for a catastrophic loss of reactor 

11 spent fuel pool water, which could cause a fuel fire in a dry pool. The NRC concluded that, 

12 because of the large inherent safety margins in the design and construction of a spent fuel pool, 

13 no action was needed to further reduce the risk (55 FR 38472). On March 11, 2011, an 

14 earthquake and subsequent tsunami resulted in significant damage to the nuclear facilities at 

15 Fukushima Dai-ichi. Subsequent analysis and inspections performed by Tokyo Electric Power 

16 Company personnel determined that the spent fuel pool water levels did not drop below the top 

17 of fuel in any spent fuel pool and that no significant fuel damage occurred (INPO 2011). 

18 Appendix F contains further discussion of the Fukushima event with respect to spent fuel pools.

19 The NRC has continued its examination of spent fuel pool storage to ensure that adequate 

20 safety is maintained and that there are no adverse environmental effects from the storage of 

21 spent fuel in spent fuel pools. The Office of Nuclear Reactor Regulation and the former Office 

22 for Analysis and Evaluation of Operational Data independently evaluated the safety of spent fuel 

23 pool storage, and the results of these evaluations were documented in a pair of memoranda to 

24 the Commission. The first memorandum “Resolution of Spent Fuel Storage Pool Action Plan 

25 Issues,” (NRC 1996a) was dated July 26, 1996. The second memorandum “Assessment of 

26 Spent Fuel Pool Cooling,” (NRC 1996b) was dated October 3, 1996 and later published as 

27 NUREG–1275, Vol. 12, “Operating Experience Feedback Report: Assessment of Spent Fuel 

28 Cooling” (NRC 1997a). As a result of these studies, the NRC and industry identified a number 

29 of follow-up activities, which are described by the NRC in a memorandum to the Commission 

30 dated September 30, 1997, “Follow-up Activities on the Spent Fuel Pool Action Plan,” (NRC 

31 1997b). These evaluations subsequently became part of the investigation of Generic Safety 

32 Issue 173, “Spent Fuel Pool Storage Safety,” which found that the relative risk posed by loss of 

33 spent fuel cooling is low compared with the risk of events not involving the spent fuel pool.

34 The safety and environmental effects of spent fuel pool storage were also addressed in 

35 conjunction with regulatory assessments of permanently shutdown nuclear plants and 

36 decommissioning nuclear power plants. NUREG/CR–6451, “A Safety and Regulatory 

37 Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants” (Travis 

38 et al. 1997), addressed the appropriateness of regulations (e.g., requirements for emergency 
Appendix B

September 2013 B-11 Draft NUREG‒2157

1 planning and insurance) associated with spent fuel pool storage. The study also provided 

2 reasonably bounding estimates for offsite consequences for the most severe accidents, which 

3 would involve draining of the spent fuel pool (e.g., complete draining of the spent fuel pool 

4 occurs 12 days after shutdown of the reactor). 

5 In 2001, the NRC issued NUREG–1738 (NRC 2001), “Technical Study of Spent Fuel Pool 

6 Accident Risk at Decommissioning Nuclear Power Plants,” which found that a postulated 

7 accident causing zirconium cladding fires could result in unacceptable offsite doses. 

8 Appendix F of this draft GEIS presents some results from the NRC (2001), including the largest 

9 number of early fatalities calculated (i.e., 191). The large number of calculated fatalities was 

10 due, in part, to conservative assumptions for the ruthenium release (i.e., the release fraction is 

11 for a volatile fission product in an oxidic [rather than metallic] form), time of the accident (i.e., 

12 30 days after shutdown of the reactor), and late evacuation of the public. More realistic 

13 assumptions (e.g., low ruthenium release, event occurs one year after shutdown), reduce the 

14 largest number of early fatalities to approximately two (NRC 2001). Although early fatalities are 

15 unacceptable, the likelihood for such an accident to occur was estimated to be less than three

16 chances in one million (NRC 2001). The NRC (2001) further states that “[T]he risk at 

17 decommissioning plants is low and well within the Commission's safety goals. The risk is low 

18 because of the very low likelihood of a zirconium fire even though the consequences from a 

19 zirconium fire could be serious.” In arriving at this conclusion, the NRC (2001) considered a 

20 wide range of initiating events, including but not limited to, events that might lead to rapid loss of 

21 pool water (e.g., seismic events, cask drop, aircraft impact, and missiles generated by 

22 tornados). The low probability for these varied events to initiate a rapid loss of water from the 

23 pool is a direct result of the robustness of the structural design of the spent fuel pool.

24 Spent fuel pools are massive structures constructed from thick, reinforced concrete walls and 

25 slabs designed to be seismically robust. Thus, the likelihood of major accidents at spent fuel 

26 pools resulting in offsite consequences is very remote. In particular, Appendix F determined 

27 that the environmental impacts from spent fuel pool fires are SMALL during the short-term 

28 storage timeframe based on the low risk of a spent fuel pool fire. The NRC is not aware of any 

29 additional studies that would cause it to question the low risk of spent fuel pool accidents and 

30 thereby question the technical feasibility of continued safe storage of spent fuel in spent fuel 

31 pools for the short-term timeframe considered in the draft GEIS. 

32 B.3.2 Technical Feasibility of Dry Cask Storage

33 The technical feasibility of dry cask storage is supported by years of experience and technical 

34 studies and NRC reviews that examined and confirmed the integrity of spent fuel and cladding

35 under the controlled and benign environment within dry cask storage systems. The technical 

36 feasibility of these systems is further supported by the robustness of the structural design of the 

37 dry cask storage system against a variety of challenges both natural and human-induced. 

38 Those features are discussed in more detail below.
Appendix B

Draft NUREG‒2157 B-12 September 2013

1 B.3.2.1 Low Degradation Rates of Spent Fuel in Dry Cask Storage 

2 In the United States, spent fuel has been safely stored in dry casks for more than 25 years. In 

3 1986, Virginia Power received a license for an at-reactor dry storage facility located at Surry 

4 Nuclear Power Plant. Today, 69 independent spent fuel storage installations (ISFSIs) are 

5 licensed to operate in the United States, which represents, at the beginning of 2012, 

6 1,700 loaded dry casks in 34 states (see Section 2.1.2 in the draft GEIS for further details). As 

7 with wet storage, the overall experience with dry cask storage of similar fuel types, including the 

8 cladding, has been similar─slow degradation. In addition, spent fuel is cooled for a lengthy 

9 period in a spent fuel pool before being transferred into dry cask storage. NRC guidance 

10 regarding dry cask storage recommends a maximum cladding temperature of 400°C and a dry, 

11 inert atmosphere to reduce the potential for significant degradation (NRC 2010b). Recent 

12 studies, including the following, have confirmed dry cask storage reliability:

13 1. A dry cask storage characterization project (Bare et al. 2001) examined and tested a dry 

14 cask storage system, the CASTOR V/21, and found “there was no evidence of cask, 

15 shielding, or fuel rod degradation during long-term (14 years) storage that would affect cask 

16 performance or fuel integrity.” The project examined zirconium-clad fuel applicable for spent 

17 fuel with a burnup of 35 GWd/MTU. A subsequent study (Einziger et al. 2003), which 

18 examined spent fuel from the Bare et al. 2001 project, suggests that the spent fuel cladding 

19 could remain a viable barrier to fission product release during extended storage up to 

20 100 years in a dry cask environment. 

21 2. The International Atomic Energy Agency (IAEA 2006) status report entitled ‘Understanding 

22 and Managing Ageing of Materials in Spent fuel Storage Facilities’ stated “[P]ower reactor 

23 fuel with zirconium alloy cladding has been placed into dry storage in approximately a dozen 

24 countries. The technical basis for satisfactory dry storage of fuel clad with zirconium alloys 

25 includes hot cell tests on single rods, whole assembly tests, demonstrations using casks 

26 loaded with irradiated fuel assemblies and theoretical analysis.”

27 3. The Electric Power Research Institute (EPRI 1998) evaluated the data needs for long-term 

28 storage and reported that during normal storage of low burnup spent fuel, “the lower 

29 radiation fields and estimated temperatures of 100–125°C after 20 years favor acceptable 

30 fuel behavior for extended storage.”

31 Current-design of low-burnup light water reactor uranium-oxide-based fuel and fuel from a high32 temperature gas-cooled reactor have been successfully stored in dry storage facilities for over 

33 20 years. The NRC allows for a license renewal for up to a 40-year term, subject to certain 

34 requirements (e.g., an aging management program for management of issues associated with 

35 aging that could adversely affect structures, systems, and components important to safety 

36 [10 CFR 72.42]). Although the current record for dry cask storage supports the technical 

37 feasibility of continued safe storage, the NRC constantly works to investigate and monitor the 
Appendix B

September 2013 B-13 Draft NUREG‒2157

1 behavior of spent fuel storage systems to identify any unexpected and deleterious safety 

2 conditions before there are adverse impacts (NRC 2013).

3 For example, the NRC is aware of concerns regarding potential detrimental effects of hydride 

4 reorientation on cladding behavior (e.g., reduced ductility). Reduced ductility, which makes the 

5 cladding more brittle, increases the difficulty of keeping spent fuel assemblies intact during 

6 handling and transportation. Research performed in Japan and the United States (Billone et al. 

7 2013) indicated that: (1) hydrides could reorient at a significantly lower stress than previously 

8 believed and (2) high-burnup fuel could exhibit a higher ductile-to-brittle transition temperature

9 due to the presence of radial hydrides. This phenomenon could influence the approach used for 

10 repackaging spent fuel but the NRC is not aware of information that would require it to conclude 

11 that high-burnup fuel would need to be repackaged during the short-term timeframe defined in 

12 the draft GEIS. Should spent fuel cladding be more brittle, greater care could be required 

13 during handling operations, regardless of when repackaging would occur, to limit the potential 

14 for damage to spent fuel assemblies that could affect easy retrievability of the spent fuel and 

15 complicate repackaging operations.

16 Based on available information and operational experience, degradation of the spent fuel 

17 should be minimal over the short-term storage timeframe if conditions inside the canister are 

18 appropriately maintained (e.g., consistent with the technical specifications for storage). Thus, it 

19 is expected that only routine maintenance will be needed over the short-term storage timeframe. 

20 Repackaging of spent fuel may be needed if storage continues beyond the short-term storage 

21 timeframe. In the draft GEIS, the NRC conservatively assumes that the dry casks 

22 would need to be replaced if storage continues beyond the short-term storage timeframe. 

23 The NRC assumes replacement of dry casks after 100 years of service life, even though studies 

24 and experience to date do not preclude a longer service life. Accidents associated with 

25 repackaging spent fuel are evaluated in Section 4.18 and the environmental impacts are SMALL 

26 because the accident consequences would not exceed the NRC accident dose standard 

27 contained in 10 CFR 72.106. The NRC is not aware of any additional studies that would cause 

28 it to question the technical feasibility of continued safe storage of spent fuel in dry casks for the 

29 timeframes considered in the draft GEIS. The NRC continues to evaluate aging management

30 programs and to monitor dry cask storage so that it can update its service life assumptions as 

31 necessary and consider any circumstances that might require repackaging spent fuel earlier 

32 than anticipated.

33 B.3.2.2 Robust Design of Dry Cask Storage Systems

34 Dry cask storage systems are passive systems (i.e., relying on natural air circulation for cooling)

35 that are inherently robust, massive, and highly resistant to damage. To date, the NRC and 

36 licensee experience with ISFSIs and cask certification indicates that spent fuel can be safely 

37 and effectively stored using passive dry cask storage technology. There have not been any 

38 safety issues with dry cask storage.
Appendix B

Draft NUREG‒2157 B-14 September 2013

1 In addition, the NRC’s technical review supporting issuance of Materials License 

2 No. SNM–2513 for the Private Fuel Storage, LLC (PFS) facility has confirmed the technical 

3 feasibility of continuing storage at an away-from-reactor ISFSI under 10 CFR Part 72. While 

4 issues extraneous to safety and protection of the environment prevented the licensee from 

going forward with the project,

4 5 the NRC’s extensive review of safety and environmental issues 

6 associated with construction and operation of the PFS facility provides further information 

7 supporting the technical feasibility that spent fuel can be safely stored at an away-from-reactor 

8 ISFSI for long periods following storage at a reactor site (i.e., in a spent fuel pool or at-reactor 

9 ISFSI). 

10 The NRC has renewed three specific ISFSI licenses for an extended 40-year period under 

11 exemptions granted from 10 CFR Part 72, which originally provided for 20-year renewals. 

12 The NRC published a final rule on February 16, 2011, to clarify the processes for the renewal 

13 of ISFSIs operated under the general license provisions of 10 CFR Part 72, for renewal of the 

14 Certificate of Compliance for dry cask storage systems, and for extending the license and 

15 renewal terms to 40 years (76 FR 8872). In these cases, the NRC’s technical review has 

16 encompassed the applicant’s evaluation of aging effects on the structures, systems, and 

17 components important to safety, supplemented by a licensee’s aging management program. 

18 These comprehensive reviews support the technical feasibility of continued safe storage of 

19 spent fuel in these ISFSIs and thus reaffirm the technical feasibility of safe, interim dry storage 

20 for an extended period. While these license renewal cases address storage at an ISFSI for a 

21 period of up to 80 years (i.e., up to 40-year initial license, plus 40-year renewal), studies 

22 performed to date (e.g., Einziger 2003; EPRI 2002; 55 FR 38472) have not identified any issues 

23 that would call into question the technical feasibility of long-term use of dry storage for low24 burnup spent fuel. 

25 In 2007, the NRC published a pilot probabilistic risk assessment methodology (NRC 2007) that 

26 identified the dominant contributors to risk associated with a welded-canister dry-spent-fuel27 storage system at a specific boiling water reactor site. The NRC study developed and assessed 

28 a comprehensive list of initiating events, including dropping the cask during handling and 

29 external events during onsite storage (e.g., earthquakes, floods, high winds, lightning strikes, 

30 accidental aircraft crashes, and pipeline explosions) and reported that the analysis indicates that 

31 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 1.8×10−12 32

during the period encompassing the initial cask loading and first year of service and 3.2×10−14 33

34 per year during subsequent years of storage [NRC 2007]).

 

4 As a result of legal challenges involving issues outside of the NRC’s jurisdiction, the proposed PFS

ISFSI has not been constructed. On December 20, 2012, PFS submitted a request to the NRC to 

terminate its license (Private Fuel Storage 2012).
Appendix B

September 2013 B-15 Draft NUREG‒2157

1 Several characteristics of dry cask storage contribute to the low risk determined by the NRC 

2 study. First, these systems are passive. Second, they rely on natural air circulation for cooling. 

3 Third, they are made up of inherently robust, massive concrete and steel structures that are 

4 highly resistant to damage. The robustness of these dry cask storage systems have been 

5 tested by significant challenges (e.g., the August 23, 2011 Mineral, Virginia earthquake that 

6 affected the North Anna Nuclear power plant and the March 11, 2011 earthquake and 

7 subsequent tsunami that damaged the Fukushima Dai-ichi nuclear power plant). Neither event 

8 resulted in significant damage to or the release of radionuclides from the dry cask storage 

containers5 9 (VEPCO 2011; INPO 2011).

10 Thus, technical studies and practical operating experience to date confirm the physical integrity 

11 of dry cask storage structures and thereby demonstrate the technical feasibility of continued 

12 safe storage of spent fuel in dry cask storage systems for the time periods considered in the 

13 draft GEIS. Further, it is expected that only routine maintenance will be needed over the 

14 short-term storage timeframe. Repackaging of spent fuel may be needed if storage continues 

15 beyond the short-term storage timeframe. In the draft GEIS, the NRC conservatively assumes 

16 that the dry casks would need to be replaced if storage continues beyond the short-term storage 

17 timeframe. The NRC assumes replacement of dry casks after 100 years of service life, even 

18 though studies and experience to date do not preclude a longer service life. Environmental 

19 impacts of accidents associated with repackaging spent fuel are evaluated in Section 4.18 and 

20 found to be SMALL. The NRC is not aware of any additional studies that would cause it to 

21 question the technical feasibility of continued safe storage of spent fuel in dry casks for the 

22 timeframes considered in the draft GEIS. The NRC continues to evaluate aging management

23 programs and monitor dry cask storage so that it can update its service life assumptions as 

24 necessary and consider any circumstances that might require repackaging of spent fuel earlier 

25 than anticipated.

26 B.3.3 Regulatory Oversight of Wet and Dry Spent Fuel Storage

27 A strong regulatory framework that includes both regulatory oversight and licensee compliance 

28 is important to the continued safe storage of spent fuel. As part of its oversight, the NRC can 

29 issue orders and new or amended regulations to address emerging issues that could impact the 

30 safe storage of spent fuel. This section provides a discussion of how the NRC’s regulatory 

31 program has addressed potential safety and security concerns and routine operations. 

32 Significantly, the draft GEIS relies strictly upon the current regulatory regime to support its 

33 environmental impact conclusions. Nonetheless, the NRC’s upgrade of safety, environmental, 

34 and security requirements following historic events such as the September 11, 2001 terrorist 

35 attacks, and the more recent March 11, 2011 earthquake and subsequent tsunami that crippled 

36 the Fukushima Dai-ichi nuclear power plant demonstrate the NRC’s capability for prompt and 

 

5 Dry casks at the Fukushima Dai-ichi nuclear power plant are stored in a shared dry cask storage 

building.
Appendix B

Draft NUREG‒2157 B-16 September 2013

1 vigorous response to new developments that warrant increased regulatory attention. Thus, the 

2 vitality and evolution of the NRC’s regulatory requirements support a reasonable conclusion that 

3 continued storage, even over extended periods of time beyond those regarded as most likely, 

4 will continue to be safe with the same or fewer environmental impacts.

5 B.3.3.1 Regulatory Actions for Routine Operations, Accidents, and Terrorist Activity

6 As part of its oversight, the NRC can issue orders and new or amended regulations to address 

7 emerging issues that could impact the safe storage of spent fuel. For example, following the 

8 terrorist attacks of September 11, 2001, the NRC undertook an extensive reexamination of 

9 spent fuel safety and security issues. In 2002, the NRC issued orders to licensees that required 

10 power reactors in decommissioning, spent fuel pools, and ISFSIs to enhance security and 

11 improve their capabilities to respond to, and mitigate the consequences of, a terrorist attack. 

12 For example, these orders required additional security measures, including increased patrols, 

13 augmented security forces and capabilities, and more restrictive site-access controls to reduce 

14 the likelihood of a successful terrorist attack. In 2007, the NRC issued a final rule revising the 

15 Design Basis Threat (a design basis threat provides a general description of the attributes of 

16 potential adversaries who might attempt to commit radiological sabotage or theft or diversion

17 against which licensee's physical protection systems must defend with high assurance), which 

18 also increased the security requirements for power reactors and their spent fuel pools 

19 (72 FR 12705). More recently, in 2009, the NRC issued a final rule to further improve security 

20 measures at nuclear power reactors, including at spent fuel pools (74 FR 13926). This rule 

21 includes improvements to security measures, such as enhancements to the cyber security plan, 

22 facilitation of consistent application of preparatory actions with respect to air attacks, integration 

23 of the access authorization and security program requirements, and additional requirements for 

24 unarmed security personnel to ensure these personnel meet the minimum physical 

25 requirements commensurate with their duties. 

26 Section 4.19 of the draft GEIS describes the environmental impacts of potential acts of 

27 sabotage or terrorism involving the continued storage of spent fuel. This section acknowledges 

28 that as the immediate hazard posed by the high radiation levels of spent fuel diminishes over 

29 time, depending on burnup, so does the deterrent to handling by unauthorized persons. The 

30 NRC will consider this type of information in evaluating whether additional security requirements 

31 are warranted in the future. 

32 Other examples of the NRC’s oversight are the additional requirements that the NRC has 

33 already imposed or is considering in response to the March 11, 2011 earthquake and 

34 subsequent tsunami that resulted in extensive damage to the six-unit Fukushima Dai-ichi 

35 nuclear power plant in Japan. On March 12, 2012, the NRC issued multiple orders and a 

36 request for information to all of its nuclear power plant licensees. A request for information was 

37 also issued to all licensees to determine whether nuclear plant licenses should be modified, 

38 suspended, or revoked. The purpose of the request for information was to re-evaluate seismic
Appendix B

September 2013 B-17 Draft NUREG‒2157

1 and flooding hazards at operating reactor sites and to determine whether appropriate staffing 

2 and communication can be relied upon to coordinate event response during a prolonged station 

3 blackout event, as was experienced at Fukushima Dai-ichi. Section 4.18 and Appendix F 

4 provide further details regarding the NRC’s orders and requests for information in response to 

5 the Fukushima event.

6 Another aspect of the NRC’s regulatory program for continuing storage, at reactors and other 

7 licensed facilities involves generic communications. Generic communications include, but are 

8 not limited to, generic letters, bulletins, information notices, safeguards advisories, and 

9 regulatory issue summaries. Generic letters request licensee actions or information to address 

10 issues regarding emergent or routine matters of safety, security, safeguards, or environmental 

11 significance. Bulletins request licensee actions or information to address significant issues 

12 regarding matters of safety, security, safeguards, or environmental significance that have great 

13 urgency. Information notices are used to communicate operating or analytical experience to the 

14 nuclear industry. The industry is expected to review the information for applicability and 

15 consider appropriate actions to avoid similar problems. Regulatory issue summaries are used 

16 to communicate and clarify the NRC’s technical or policy positions on regulatory matters. 

17 For example, Information Notice 2012–20 (NRC 2012b) informed licensees about the potential 

18 for chloride-induced stress corrosion cracking of austenitic stainless steel and maintenance of 

19 dry cask storage system canisters. Although an immediate safety concern did not exist, the 

20 NRC alerted its licensees and certificate holders that the monitoring program needs to address 

21 this concern as part of an aging management program so that appropriate actions (e.g., 

22 maintenance) would be taken before there were any impacts.

23 B.3.3.2 Regulatory Oversight of Spent Fuel Pool Leaks

24 Spent fuel pool design and operational control requirements contained in NRC regulations make 

25 it unlikely that a leak will remain undetected long enough to result in public health and safety or 

26 environmental concerns. Long-standing and bedrock design requirements include but are not 

27 limited to general design criteria in 10 CFR Part 50, Appendix A that focus on fuel storage and 

28 handling and radioactivity control (e.g., General Design Criterion 61). Operational controls 

29 include requirements for control of effluents and release of radioactive materials such as dose

30 limits found in 10 CFR 20.1301 and design objectives found in 10 CFR Part 50, Appendix I.

31 There are also requirements that are new or have been recently updated in response to recent 

32 operational experience and related studies by NRC task forces. For example, a 2006 report by 

33 NRC’s Liquid Radioactive Release Lessons Learned Task Force made 26 specific 

34 recommendations for improvements to NRC regulatory programs (NRC 2006). In 2010, the 

35 NRC Groundwater Task Force reevaluated the recommendations of the 2006 task force 

36 (NRC 2010c). A review of the Groundwater Task Force recommendations by NRC senior 
Appendix B

Draft NUREG‒2157 B-18 September 2013

1 management concluded that further action was warranted (NRC 2011c). These studies have 

2 influenced specific changes to NRC requirements and guidance. For example:

3 • In June 2008, the NRC issued Regulatory Guide 4.21, “Minimization of Contamination and 

4 Radioactive Waste Generation: Life-Cycle Planning” (NRC 2008). The purpose of this 

5 regulatory guide is to present guidance that will assist applicants covered by 10 CFR 

6 20.1406, “Minimization of contamination,” in effectively implementing this licensing 

7 requirement.

8 • A 2009 revision to Regulatory Guide 4.1 (NRC 2009) provides guidance to licensees for 

9 detecting, evaluating, and monitoring releases from operating facilities via unmonitored 

10 pathways; to ensure consistency with current industry standards and commercially available 

11 radiation detection methodology; to clarify when a licensee’s radiological effluent and 

12 environmental monitoring programs should be expanded based on data or environmental 

13 conditions; and to ensure that leaks and spills are detected before radionuclides

14 migrate offsite via an unmonitored pathway. 

15 • On July 17, 2011, the NRC promulgated its Decommissioning Planning Rule, which added 

16 10 CFR 20.1406(c) and modified 10 CFR 20.1501(a) and (b) (76 FR 35512). This rule 

17 requires all licensees to establish operational practices to minimize site contamination and 

18 perform reasonable subsurface radiological surveys and sets forth new financial assurance 

19 requirements. 

20 • In December 2012, the NRC published Regulatory Guide 4.22, “Decommissioning Planning 

21 During Operations,” which provides methods acceptable to the NRC to use in implementing 

22 portions of the Decommissioning Planning Rule (NRC 2012c).

23 Appendix E provides additional details on spent fuel pool operations, including monitoring. 

24 The draft GEIS provides a detailed description and evaluation of the historical data on spent fuel 

25 pool leakage of water and the offsite environmental impacts that may occur during the period of 

26 continued storage (Appendix E). In particular, Appendix E determined the impact to public 

27 health from spent fuel pool leakage would be SMALL.

28 B.3.3.3 Dry Cask Storage

29 While the NRC has established the necessary regulatory framework for continued safe spent 

30 fuel management, reactor and ISFSI licensees have acted prudently to safely manage their 

31 spent fuel. In the late 1970s and early 1980s, the need for alternative storage began to grow as

32 spent fuel pools at many nuclear reactors began to fill up. Spent fuel pool re-racking, fuel-pin 

33 consolidation, and onsite dry cask storage have been successfully employed to increase onsite 

34 storage capacity. In addition, licensees considered dry cask storage as an option to increase 

35 spent fuel storage capacity. As discussed above, there are currently 69 licensed ISFSIs. The 

36 NRC is successfully regulating six fully decommissioned reactor sites that contain ISFSIs 
Appendix B

September 2013 B-19 Draft NUREG‒2157

1 licensed under either the general or specific license provisions of 10 CFR Part 72. Four of the 

2 decommissioned reactor sites continue to hold 10 CFR Part 50 licenses and consist only of an 

ISFSI under the 10 CFR Part 72 general license provisions.6 3 The other two fully 

4 decommissioned reactor sites (Trojan and Ft. St. Vrain) have a specific license under 10 CFR 

Part 72.7 5

6 After the end of the reactor’s licensed life for operation, the licensee would continue to store 

7 spent fuel onsite under either a possession-only 10 CFR Part 50 or Part 52 license or a 10 CFR 

8 Part 72 license. During this time, the licensee would remain under the NRC’s regulatory control 

9 and NRC inspections and oversight of storage facilities would continue. The NRC monitors the 

10 performance of ISFSIs (at both decommissioned and shutdown reactor sites and operating 

11 reactor sites) by conducting periodic inspections. When conducting inspections at these ISFSIs, 

12 NRC inspectors follow the guidance in NRC Inspection Manual Chapter 2690 (NRC 2012a), 

13 “Inspection Program for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage

14 Installations and for 10 CFR Part 71 Transportation Packages.”

15 The current regulatory framework for storage of spent fuel allows for multiple license renewals, 

16 subject to aging management analysis and planning. In early 2011, the Commission published 

17 a final rule that amended 10 CFR Part 72 to increase the initial and renewal terms for specific 

18 ISFSI licenses from “not to exceed 20 years” to “not to exceed 40 years” (76 FR 8872). The 

19 Commission concluded that, with appropriate aging management and maintenance programs, 

20 license terms not to exceed 40 years are reasonable and adequately protect public health and 

21 safety. An applicant for a storage license renewal must provide appropriate technical bases for 

22 identifying and addressing aging-related effects and develop specific aging management plans 

23 to justify extended operations of ISFSIs. The regulatory framework for storage is supported by 

24 well-developed regulatory guidance; voluntary domestic and international consensus standards; 

25 research and analytical studies; and processes for implementing licensing reviews, inspection 

26 programs, and enforcement oversight.

27 B.3.3.4 Summary of Information on Regulatory Oversight

28 The NRC will continue its regulatory control and oversight of spent fuel storage at both 

29 operating and decommissioned reactor sites through both specific and general 10 CFR Part 72 

30 licenses. Decades of operating experience and ongoing NRC inspections demonstrate that 

31 these reactor and ISFSI licensees continue to meet their obligation to safely store spent fuel in 

32 accordance with the requirements of 10 CFR Part 50 and Part 72. If the NRC were to find

 

6 These reactor sites include Maine Yankee, Yankee Rowe, Connecticut Yankee (also known as Haddam 

Neck), and Big Rock Point.

7 There are several additional sites with specific Part 72 ISFSI licenses that are in the process of 

decommissioning (e.g., Humbolt Bay and Rancho Seco). In addition, several shutdown reactors that are 

not yet decommissioned have ISFSIs under a general license (e.g., La Crosse and San Onofre 1).
Appendix B

Draft NUREG‒2157 B-20 September 2013

1 noncompliance with these requirements or otherwise identify a concern with the safe storage of 

2 the spent fuel, the NRC would evaluate the issue and take whatever action or change in its 

3 regulatory program is necessary to protect the public health and safety and the environment.

4 As noted in the preceding paragraphs, licensees have continued to develop and successfully 

5 use onsite spent fuel-storage capacity in the form of spent fuel pool and dry cask storage in a 

6 safe and environmentally sound fashion. Based on the preceding discussion, the NRC believes 

7 that for the storage timeframes considered in the draft GEIS, regulatory oversight will continue 

8 in a manner consistent with NRC’s regulatory actions and oversight in place today to provide for 

9 continued storage of spent fuel in a safe manner until sufficient repository capacity is available 

10 for the safe disposal of all spent fuel.

11 B.3.4 Summary of Technical Feasibility of Continued Storage

12 Storage of spent fuel will be necessary until a repository is available for permanent disposal. It 

13 is reasonable to assume that the storage of spent fuel in any combination of storage in spent 

14 fuel pools or dry casks will continue as a licensed activity under regulatory controls and 

15 oversight. Licensees have continued to develop and successfully use onsite spent nuclear fuel 

16 storage capacity in the form of spent fuel pool and dry cask storage in a safe and 

17 environmentally sound fashion. As discussed above, technical understanding and operational 

18 experience continues to support the technical feasibility of safe storage of spent fuel in spent 

19 fuel pools and in dry casks over long periods of time (e.g., slow degradation of spent fuel during 

20 storage in spent fuel pools and dry casks; engineered features of storage pools and dry casks to 

21 safely withstand accidents caused by either natural or man-made phenomena). In addition, 

22 regulatory oversight has been shown to enhance safety designs and operations as concerns 

23 and information evolve over time (e.g., safety enhancements made after the September 11, 

24 2001 terrorist attacks and the March 11, 2011 Fukushima Dai-ichi disaster and actions to 

25 address spent fuel pool leaks as discussed in Appendix E of this draft GEIS).

26 Based on the technical information and the national and international experience with wet and 

27 dry storage of spent fuel, the NRC concludes it is technically feasible to safely store spent fuel in 

28 either wet or dry storage for the short-term storage timeframe with only routine maintenance 

29 (i.e., no large-scale replacement of spent fuel pools or dry cask storage systems).

30 In the draft GEIS, the NRC assumes that after the short-term storage timeframe, spent nuclear 

31 fuel is stored in dry casks. If necessary, there is no technical reason that spent fuel cannot be 

32 safely stored in dry casks beyond the short-term storage timeframe. As discussed in this 

33 appendix, the degradation rates of spent fuel are low under dry storage conditions and the 

34 probability of accidents with large consequences are very low. Storage of spent fuel beyond the 

35 short-term storage timeframe would continue under an approved aging management program to 

36 ensure that monitoring and maintenance are adequately performed. Repackaging of spent fuel 

37 may be needed if storage continues beyond the short-term storage timeframe. In the draft 
Appendix B

September 2013 B-21 Draft NUREG‒2157

1 GEIS, the NRC conservatively assumes that the dry casks would need to be replaced if storage 

2 continues beyond the short-term storage timeframe. The NRC assumes replacement of dry 

3 casks after 100 years of service life, even though studies and experience to date do not 

4 preclude a longer service life. Accidents associated with repackaging spent fuel are evaluated 

5 in Section 4.18 and the environmental impacts are SMALL because the accident consequences 

6 would not exceed the NRC accident dose standard contained in 10 CFR 72.106. The NRC 

7 concludes it is technically feasible to continue to store spent fuel beyond the short-term storage 

8 timeframe, which may include activities to repackage spent fuel. The NRC continues to 

9 evaluate aging management programs and monitor dry cask storage and will update its service 

10 life assumptions as necessary and consider any circumstances that might require repackaging 

11 of spent fuel earlier than anticipated.

12 Section 4.19 of the draft GEIS describes the environmental impacts of potential acts of 

13 sabotage or terrorism involving the continued storage of spent fuel. This section acknowledges 

14 that as the immediate hazard posed by the high radiation levels of spent fuel diminishes over 

15 time so does the deterrent to handling by unauthorized persons. The BRC report noted that 

16 “over long time periods (perhaps a century or more, depending on burnup and the level of 

17 radiation that is deemed to provide adequate self-protection), the fuel could become more 

18 susceptible to possible theft or diversion (although other safeguards would remain in place). 

19 This in turn could change the security requirements for older spent fuel. Extending storage to 

20 timeframes of more than a century could thus require increasingly demanding and expensive 

21 security protections at storage sites.” Therefore, additional security requirements may be 

22 necessary in the future, should spent nuclear fuel remain in storage for a substantial period of 

23 time. If necessary, the NRC will issue orders or enhance its regulatory requirements for ISFSI 

24 security, as appropriate, to provide adequate protection of public health and safety and the 

25 common defense and security.

26 B.4 References

27 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

28 Protection against Radiation.” Washington, D.C.

29 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

30 Production and Utilization Facilities.” Washington, D.C.

31 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

32 Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

33 Washington, D.C.

34 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

35 Certifications, and Approvals for Nuclear Power Plants.” Washington, D.C.
Appendix B

Draft NUREG‒2157 B-22 September 2013

1 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

2 Transportation of Radioactive Material.” Washington, D.C.

3 10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing 

4 Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

5 Waste, and Reactor-Related Greater than Class C Waste.” Washington, D.C.

6 49 FR 34658. August 31, 1984. “10 CFR Parts 50 and 51.” Federal Register, U.S. Nuclear 

7 Regulatory Commission, Washington, D.C.

8 55 FR 38472. September 18, 1990. “10 CFR 51, Waste Confidence Decision Review.” 

9 Federal Register, U.S. Nuclear Regulatory Commission, Washington, D.C.

10 72 FR 12705. March 19, 2007. “Design Basis Threat.” Federal Register, U.S. Nuclear 

11 Regulatory Commission, Washington, D.C.73 FR 53284. September 15, 2008. “Department of 

12 Energy; Notice of Acceptance for Docketing of a License Application for Authority To Construct 

13 a Geologic Repository at a Geologic Repository Operations Area at Yucca Mountain, NV.” 

14 Federal Register. U.S. Nuclear Regulatory Commission, Washington, D.C.

15 74 FR 13926. March 27, 2009. “Power Reactor Security Requirements; Supplemental 

16 Proposed Rule.” Federal Register, U.S. Nuclear Regulatory Commission, Washington, D.C. 

17 Accession No. ML080570264.

18 75 FR 81037. December 23, 2010. “Waste Confidence Decision Update.” Federal Register. 

19 U.S. Nuclear Regulatory Commission, Washington, D.C. Accession No. ML12088A302. 

20 76 FR 8872. February 16, 2011. “License and Certificate of Compliance Terms.” Federal 

21 Register. U.S. Nuclear Regulatory Commission, Washington, D.C.

22 76 FR 35512. June 17, 2011. “Decommissioning Planning,” Federal Register, U.S. Nuclear 

23 Regulatory Commission, Washington, D.C.

24 Ahn, J. and M.J. Apted (eds.). 2010. Geological Repository Systems for Safe Disposal of 

25 Spent Nuclear Fuels and Radioactive Wastes. Woodhead Publishing Series in Energy. 

26 Number 9, Oxford, England.

27 Bare, W.C. and L.D. Torgerson. 2001. Dry Cask Storage Characterization Project-Phase 1: 

28 CASTOR V/21 Cask Opening and Examination. NUREG/CR–6745. Idaho National Engineering 

29 and Environmental Laboratory, Idaho Falls, Idaho. Accession No. ML013020363.
Appendix B

September 2013 B-23 Draft NUREG‒2157

1 Billone, M.C., T.A. Burtseva, and R.E. Einziger. 2013. “Ductile-to-Brittle Transition 

2 Temperature for High-Burnup Cladding Alloys Exposed to Simulated Drying-Storage 

3 Conditions.” Journal of Nuclear Materials 433(1–3):431–448. Available at 

4 http://www.sciencedirect.com/science/article/pii/S0022311512005181. 

5 Blue Ribbon Commission (Blue Ribbon Commission on America’s Nuclear Future). 2012. 

6 “Report to the Secretary of Energy.” U.S. Department of Energy, Washington, D.C. Accession

7 No. ML120970375. 

8 DOE (U.S. Department of Energy). 2008. Yucca Mountain Repository License Application 

9 Rev. 0. DOE/RW–0573. Washington, D.C. Accession No. ML081560400.

10 DOE (U.S. Department of Energy). 2013. Strategy for the Management and Disposal of Used 

11 Nuclear Fuel and High-Level Radioactive Waste. Washington, D.C. Accession

12 No. ML13011A138.

13 Einziger, R.E., H. Tsai, M.C. Billone, and B.A. Hilton. 2003. Examination of Spent PWR Fuel 

14 Rods after 15 Years in Dry Storage. NUREG/CR–6831. Argonne National Laboratory-West, 

15 Argonne, Illinois. Accession No. ML032731021. 

16 EPRI (Electric Power Research Institute). 1998. Data Needs for Long-Term Dry Storage of 

17 LWR Fuel. Report TR–108757, Palo Alto, California. 

18 EPRI (Electric Power Research Institute). 2002. Technical Bases for Extended Dry Storage of 

19 Spent Nuclear Fuel. Report 1003416, Palo Alto, California. 

20 IAEA (International Atomic Energy Agency). 1997. Joint Convention on Safety of Spent Fuel 

21 Management and on Safety of Radioactive Waste Management. INFCIRC/546, Vienna, 

22 Austria. Available at http://www.iaea.org/Publications/Documents/Infcircs/1997/infcirc546.pdf. 

23 IAEA (International Atomic Energy Agency). 1998. Durability of Spent Nuclear Fuels and 

24 Facility Components in Wet Storage. IAEA–TECDOC–1012, Vienna, Austria. Available at 

25 http://www-pub.iaea.org/MTCD/publications/PDF/te_1012_prn.pdf. 

26 IAEA (International Atomic Energy Agency). 2001. The Use of Scientific and Technical Results 

27 from Underground Research Laboratory Investigations for the Geologic Disposal of Radioactive 

28 Waste. IAEA–TECDOC–1243, Vienna, Austria. Available at http://www29 pub.iaea.org/MTCD/Publications/PDF/te_1243_prn.pdf. 

30 IAEA (International Atomic Energy Agency). 2003a. Scientific and Technical Basis for the 

31 Geologic Disposal of Radioactive Wastes. Technical Reports Series No. 413, Vienna, Austria. 

32 Available at http://www-pub.iaea.org/MTCD/publications/PDF/TRS413_web.pdf. 
Appendix B

Draft NUREG‒2157 B-24 September 2013

1 IAEA (International Atomic Energy Agency). 2003b. Spent Fuel Performance Assessment and 

2 Research: Final Report of a Co-Ordinated Research Project on Spent Fuel Performance 

3 Assessment and Research (SPAR) 1997–2001. IAEA–TECDOC–1343, Vienna, Austria. 

4 Available at http://www-pub.iaea.org/MTCD/Publications/PDF/TE_1343_web.pdf. 

5 IAEA (International Atomic Energy Agency). 2005. Radioactive Waste Management Studies 

6 and Trends. IAEA/WMDB/ST/4, Vienna, Austria. Available at http://www7 pub.iaea.org/MTCD/publications/PDF/WMDB-ST-4.pdf. 

8 IAEA (International Atomic Energy Agency). 2006. Understanding and Managing Ageing of 

9 Materials in Spent Fuel Storage Facilities. Technical Reports Series No. 443, Vienna Austria. 

10 Available at http://www-pub.iaea.org/MTCD/Publications/PDF/TRS443_web.pdf. 

11 INPO (Institute of Nuclear Power Operations). November 2011. Special Report on the Nuclear 

12 Accident at the Fukushima Dai-ichi Nuclear Power Station. INPO 11–005, Revision 0, Atlanta, 

13 Georgia.

14 Johnson, A.B. 1977. “Behavior of Spent Nuclear Fuel in Water Pool Storage.” BNWL–2256, 

15 Battelle–Pacific Northwest Laboratories, Richland, Washington. Available at 

16 http://www.ntis.gov/search/product.aspx?ABBR=BNWL2256. 

17 Johnson Jr., A.B. 1978. “Utility Spent Fuel Storage Experience.” PNL–SA–6863, presented at 

18 the American Nuclear Society’s Executive Conference on Spent Fuel Policy and its Implications;

19 Buford, Georgia; April 2–5, 1978. Executive Conference Proceedings. 

20 NEA (Nuclear Energy Agency). 1997. Lessons Learnt from Ten Performance Assessment 

21 Studies. Organization for Economic Cooperation and Development, Paris, France. Available at 

22 http://www.oecd-nea.org/rwm/reports/1997/ipag.pdf. 

23 NRC (U.S. Nuclear Regulatory Commission). 1996a. Memorandum from J.M. Taylor to NRC 

24 dated July 26, 1996, regarding “Resolution of Spent Fuel Storage Pool Action Plan Issues.” 

25 Washington, D.C. Accession No. ML003706364. 

26 NRC (U.S. Nuclear Regulatory Commission). 1996b. Memorandum from J.M. Taylor to NRC 

27 dated October 3, 1996, regarding “Assessment of Spent Fuel Cooling.” Washington, D.C. 

28 Accession No. ML003706381.

29 NRC (U.S. Nuclear Regulatory Commission). 1997a. Operating Experience Feedback Report: 

30 Assessment of Spent Fuel Cooling. NUREG–1275, Volume 12, Washington, D.C. Accession 

31 No. ML010670175.
Appendix B

September 2013 B-25 Draft NUREG‒2157

1 NRC (U.S. Nuclear Regulatory Commission). 1997b. Memorandum from L.J. Callan to NRC 

2 dated September 30, 1997, regarding “Followup Activities on the Spent Fuel Pool Action Plan.” 

3 Washington, D.C. Accession No. ML003706412. 

4 NRC (U.S. Nuclear Regulatory Commission). 2001. Technical Study of Spent Fuel Pool 

5 Accident Risk at Decommissioning Nuclear Power Plants. NUREG–1738, Washington, D.C. 

6 Accession No. ML010430066.

7 NRC (U.S. Nuclear Regulatory Commission). 2006. Liquid Radioactive Release Lessons 

8 Learned Task Force Final Report. Washington, D.C. Accession No. ML062650312.

9 NRC (U.S. Nuclear Regulatory Commission). 2007. A Pilot Probabilistic Risk Assessment of a 

10 Dry Cask Storage System at a Nuclear Power Plant. NUREG–1864, Washington, D.C. 

11 Accession No. ML071340012.

12 NRC (U.S. Nuclear Regulatory Commission). 2008. Minimization of Contamination and 

13 Radioactive Waste Generation: Life-Cycle Planning. Regulatory Guide 4.21, Washington, D.C. 

14 Accession No. ML080500187.

15 NRC (U.S. Nuclear Regulatory Commission). 2009. “Radiological Environmental Monitoring

16 For Nuclear Power Plants.” Revision 2, Regulatory Guide 4.1, Washington, D.C. Accession 

17 No. ML091310141.

18 NRC (U.S. Nuclear Regulatory Commission). 2010a. U.S. Department of Energy’s Motion to 

19 Withdraw [Yucca Mountain]. ASLBP No. 09–892–HLW–CAB04., Washington, D.C. Accession 

20 No. ML100621397.

21 NRC (U.S. Nuclear Regulatory Commission). 2010b. Standard Review Plan for Spent Fuel Dry 

22 Storage Systems at a General License Facility. NUREG–1536, Revision 1, Washington, D.C. 

23 Accession No. ML101040620. 

24 NRC (U.S. Nuclear Regulatory Commission). 2010c. Groundwater Task Force Final Report. 

25 Washington, D.C. Accession No. ML101740509.

26 NRC (U.S. Nuclear Regulatory Commission). 2011a. Technical Evaluation Report on the 

27 Content of the U.S. Department of Energy’s Yucca Mountain Repository License Application—

28 Preclosure Volume: Repository Safety Before Permanent Closure. NUREG–2108,

29 Washington, D.C. Accession No. ML11250A093. 
Appendix B

Draft NUREG‒2157 B-26 September 2013

1 NRC (U.S. Nuclear Regulatory Commission). 2011b. Technical Evaluation Report on the 

2 Content of the U.S. Department of Energy’s Yucca Mountain Repository License Application—

3 Postclosure Volume: Repository Safety After Permanent Closure. NUREG–2107, 

4 Washington, D.C. Accession No. ML11223A273.

5 NRC (U.S. Nuclear Regulatory Commission). 2011c. Senior Management Review of Overall 

6 Regulatory Approach to Groundwater Protection. Washington, D.C. SECY–11–0019, 

7 Washington, D.C. Accession No. ML12338A692.

8 NRC (U.S. Nuclear Regulatory Commission). 2012a. Potential Chloride-Induced Stress 

9 Corrosion Cracking of Austenitic Stainless Steel and Maintenance of Dry Cask Storage System 

10 Canisters. IN 2012–20, Washington, D.C. Accession No. ML12319A440. 

11 NRC (U.S. Nuclear Regulatory Commission). 2012b. Decommissioning Planning During 

12 Operations. Regulatory Guide 4.22, Washington, D.C. Accession No. ML12158A361. 

13 PFS (Private Fuel Storage LLC). 2012. Letter from R.M. Palmberg to NRC dated December 

14 20, 2012, regarding “Termination of NRC License No. SNM–2513 for Private Fuel Storage LLC.” 

15 La Crosse, Wisconsin. Accession No. ML12356A063.

16 NRC (U.S. Nuclear Regulatory Commission). 2012c. “Inspection Program for Dry Storage of 

17 Spent Reactor Fuel at Independent Spent Fuel Storage Installations and for 10 CFR Part 71 

18 Transportation Packages.” Chapter 2690 in NRC Inspection Manual. Washington, D.C. 

19 Accession No. ML120390415.

20 NRC (U.S. Nuclear Regulatory Commission). 2013. Use of a Demonstration Program as 

21 Confirmation of Integrity for Continued Storage of High Burnup Fuel Beyond 20 Years. Interim 

22 Staff Guidance-24, Revision 0, Washington, D.C. Accession No. ML13056A516. 

23 Posiva. 2011. Final Disposal of Spent Nuclear Fuel in Olkiluoto. Olkiluoto, Finland. Available 

24 at http://www.posiva.fi/files/1960/Posiva_yleisesite_2011_EN.pdf. 

25 Travis, R.J., R.E. Davis, E.J. Grove, and M.A. Azarm. 1997. Safety and Regulatory 

26 Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants. 

27 NUREG/CR–6451 Brookhaven National Laboratory, Washington, D.C. Available at 

28 http://www.osti.gov/bridge/servlets/purl/510336-qmwPBP/webviewable/510336.pdf. 

29 VEPCO (Virginia Electric and Power Company). 2011. Virginia Electric and Power Company 

30 (Dominion) North Anna Power Station Units 1 and 2 North Anna Independent Spent Fuel 

31 Storage Installation Summary Report of August 23, 2011 Earthquake Response and Restart 

32 Readiness Determination Plan. Richmond, Virginia. Accession No. ML11262A151.
Appendix B

September 2013 B-27 Draft NUREG‒2157

1 Walker, J.F. 1979. Long-Term Storage of Irradiated CANDU Fuel Under Water. Whiteshell 

2 Nuclear Research Establishment, Pinawa, Manitoba. Available at 

3 http://www.ntis.gov/search/product.aspx?ABBR=N7932999. 

Appendix C 

–

Outreach and Correspondence

September 2013 C-1 Draft NUREG‒2157

Appendix C

Outreach and Correspondence

1 This appendix provides a description of outreach activities and agencies and groups that the 

2 U.S. Nuclear Regulatory Commission (NRC) contacted during the preparation of this draft 

3 Waste Confidence Generic Environmental Impact Statement (draft GEIS), and a listing of 

4 correspondence related to the NRC’s environmental review. The NRC did not identify any 

5 cooperating agencies for the Waste Confidence environmental review or receive any formal

6 requests for cooperating agency status.

7 C.1 Outreach

8 The NRC staff has conducted extensive outreach efforts during the preparation of this draft 

9 GEIS. 

10 WCOUTREACH E-mail: The NRC staff uses an e-mail account, WCOutreach@nrc.gov, to 

11 distribute information to subscribers regarding Waste Confidence. Through this e-mail account, 

12 the NRC staff provides periodic updates on activities, links to new information published in the 

13 NRC's Agencywide Document Access and Management Systems (ADAMS), and links to 

14 information on the NRC website. On October 25, 2012, when the NRC staff e-mailed the 

15 scoping notice to subscribers, the NRC’s WCOutreach@nrc.gov e-mail distribution list consisted 

16 of approximately 1,050 individuals, including individuals who expressed interest in previous 

17 spent nuclear fuel (spent fuel) studies and efforts; members of the public on mailing lists for new 

18 reactor and license renewal environmental reviews; representatives from Federal, Tribal, State, 

19 and local governments; and representatives from industry and public advocacy groups and 

20 environmental organizations. In the months following publication of the draft GEIS scoping 

21 notice, the e-mail distribution list has grown to approximately 3,200 subscribers.

22 Public Meetings and Webinars: During the 70-day scoping comment period, the NRC 

23 conducted two webcast public scoping meetings and two webinars. The meetings and webinars 

24 each began with a slide presentation by NRC staff, which was followed by a question-and25 answer period and a block of time dedicated to listening to and transcribing public scoping 

26 comments. Notices for the public meetings were e-mailed, posted on the NRC website, and 

27 advertised by the NRC’s Office of Public Affairs.
Appendix C

Draft NUREG‒2157 C-2 September 2013

1 NRC Website: The NRC maintains a Waste Confidence Directorate webpage at 

2 www.nrc.gov/waste/spent-fuel-storage/wcd.html. The NRC regularly updates the website, 

3 which contains a specific section titled “Public Involvement in Waste Confidence,” with related 

4 documents, new information, and frequently asked questions.

5 Monthly Status Update Public Teleconferences: In the months following closure of the 

6 scoping period and leading up to publication of the draft GEIS, the NRC staff held monthly 

7 public status teleconferences to provide an update on activities related to the Waste Confidence

8 rulemaking and draft GEIS. These were Category 3 meetings where the public was invited to 

9 attend via telephone and ask questions of the NRC staff. Transcripts and summaries of the 

10 teleconferences are posted to the Waste Confidence Directorate “Public Involvement in Waste 

11 Confidence” webpage.

12 Tribal Contact: With assistance from the NRC’s Office of Federal and State Materials and 

13 Environmental Management Programs, the scoping notice was mailed and e-mailed, when 

14 possible, to all Federally recognized Native American Tribes (1) located within 50 mi of a 

15 nuclear power plant, (2) registered with the NRC for advance notification of shipments of 

16 irradiated reactor fuel and nuclear waste under Title 10 of the Code of Federal Regulations

17 (CFR) Parts 71 and 73; or (3) previously expressing interest in the NRC’s Yucca Mountain

18 application activities (see ADAMS Accession No. ML12311A464 for an example of the tribal 

19 outreach letter that transmitted the scoping notice and the tribal distribution list). Approximately 

20 100 Tribes were mailed a copy of the Waste Confidence scoping notice. In addition, the NRC 

21 corresponded with the Northern Chumash Tribal Council (recognized by the state of California) 

22 and the Santa Ynez Band of Chumash Indians (Federally recognized), which are both located 

23 near the Diablo Canyon Nuclear Plant. 

24 The NRC also initiated government-to-government consultation with the Prairie Island Indian 

25 Community. The Prairie Island Indian reservation is located adjacent to the Prairie Island 

26 Nuclear Generating Plant in Welch, Minnesota. A government-to-government meeting was held 

27 between the NRC and Tribal representatives on June 13, 2013, on the Prairie Island 

28 Reservation. The NRC continues government-to-governmental consultation with the Prairie 

29 Island Indian Community Tribal Council as the Waste Confidence review proceeds.

30 State Contact: NRC’s Office of Federal and State Materials and Environmental Management 

31 Programs provided the scoping notice to state liaison officers in all agreement and 

32 nonagreement states and provided monthly notification of the public status teleconferences.

33 U.S. Environmental Protection Agency (EPA) Contact: The NRC met with representatives of 

34 the EPA on November 5, 2012. The purpose of the meeting was to provide historical 

35 information on the Waste Confidence rule, to discuss the status of the Waste Confidence 

36 environmental review and rulemaking, to discuss how the NRC was conducting new reactor and 

37 license renewal reviews in the interim while Waste Confidence was addressed, and to receive 
Appendix C

September 2013 C-3 Draft NUREG‒2157

1 advice on the NRC’s approach. The EPA provided comments on the scope of the Waste 

2 Confidence GEIS (Accession No. ML13028A469) and the NRC continues to consult with the 

3 EPA as the Waste Confidence review proceeds.

4 C.2 Correspondence 

5 This section contains a chronological listing of correspondence related to the NRC’s 

6 environmental review in preparation of this draft GEIS. The documents listed below can be 

7 found online through ADAMS at http://www.nrc.gov/reading-rm/adams.html. The ADAMS 

8 accession numbers for each document are included below. 

9 October 24, 2012 NRC to Hold Public Scoping Meetings for Waste Confidence

10 Environmental Study Nov. 14 in Rockville, MD. Press Release 

11 No. 12-119. Accession No. ML12298A295.

12 October 25, 2012 Federal Register Notice of Intent to Prepare an Environmental Impact 

13 Statement and Notice of Public Meetings. 77 FR 65137. Accession 

14 No. ML12312A178.

15 October 25, 2012 E-mail from WCOutreach@nrc.gov, Federal Register notice 

16 (77 FRN 65137) for Waste Confidence EIS and Scoping. Accession 

17 No. ML13120A477.

18 October 31, 2012 Forthcoming Waste Confidence Scoping Meetings for the Environmental 

19 Impact Statement (November 14, 2012). Accession No. ML12306A224.

20 October 31, 2012 Notification of the Scoping Process for the Environmental Impact 

21 Statement for the Waste Confidence Decision and Rule Update and 

22 Notice of Public Meetings and Webinars (FSME–12–085). Accession 

23 No. ML12293A107.

24 November 6, 2012 E-mail from WCOutreach@nrc.gov, Link to Meeting Notice for Nov. 14 

25 Waste Confidence Scoping Meetings. Accession No. ML13120A483. 

26 November 8, 2012 E-mail from WCOutreach@nrc.gov, Federal Register notice 

27 (77 FRN 65137) for Waste Confidence EIS and Scoping - - and Nov. 14 

28 Public Meeting Notice. Accession No. ML13120A481. 

29 November 8, 2012 Letter to NRC Commissioners, from G. Fettus, M. Goldstein, and 

30 D. Curran, Notice of Intent to Prepare Waste Confidence EIS. 

31 Accession No. ML12314A345.
Appendix C

Draft NUREG‒2157 C-4 September 2013

1 November 13, 2012 Letter to NRC Commissioners, from D. Brancato, Riverkeeper, Waste 

2 Confidence Scoping Meetings and Opportunity to Comment. Accession 

3 No. ML13184A154. 

4 November 13, 2012 E-mail from WCOutreach@nrc.gov, Direct Comment Link and Waste 

5 Confidence Scoping Meeting Slides. Accession No. ML13120A478.

6 November 21, 2012 Forthcoming Webinars for the Environmental Impact Statement to 

7 Support an Updated Waste Confidence Decision and Rule (December 5 

8 and 6, 2012). Accession No. ML12326A911.

9 November 27, 2012 E-mail from WCOutreach@nrc.gov, Upcoming December 5 and 6 Waste 

10 Confidence Webinars. Accession No. ML13120A479.

11 November 28, 2012 Letter to NRC Commissioners, from F. Collins, Tribal Administrator, 

12 Northern Chumash Tribal Council, Notice of Intent to Prepare Waste 

13 Confidence EIS. Accession No. ML13184A149.

14 December 5, 2012 Letter to D. Curran, Harmon, Curran, Spielberg & Eisenberg, L.L.P., 

15 from A. Macfarlane, Chairman, NRC, regarding the Waste Confidence

16 Scoping Process. Accession No. ML12319A309. (Identical letters sent 

17 to G. Fettus and M. Goldstein.) 

18 December 6, 2012 Summary of Public Scoping Meetings for Environmental Impact 

19 Statement to Support Waste Confidence Rulemaking (November 14, 

20 2012). Accession No. ML12339A281. 

21 December 26, 2012 Summary of Public Scoping Webinars for the Environmental Impact 

22 Statement to Support the Waste Confidence Rulemaking (December 5 

23 and 6, 2012). Accession No. ML12356A293. 

24 December 31, 2012 E-mail from WCOutreach@nrc.gov, Waste Confidence Scoping Meeting 

25 Summaries and Transcripts. Accession No. ML13120A480.

26 December 31, 2012 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

27 Confidence Environmental Impact Statement and Rulemaking

28 (January 16, 2013). Accession No. ML12366A201.

29 January 2, 2013 Letter to F. Collins, Tribal Administrator, Northern Chumash Tribal 

30 Council, from K. McConnell, Director, Waste Confidence Directorate, 

31 NRC, regarding the Waste Confidence Scoping Process. Accession 

32 No. ML13002A221.
Appendix C

September 2013 C-5 Draft NUREG‒2157

1 January 6, 2013 Letter to NRC Commissioners, from S. Cohen, Government and Legal 

2 Specialist, Santa Ynez Band of Chumash Indians, Notice of Intent to 

3 Prepare Waste Confidence EIS. Accession No. ML130500419. 

4 January 9, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence Monthly Public 

5 Teleconferences. Accession No. ML13120A484.

6 January 11, 2013 Letter to S. Cohen, Government and Legal Specialist, Santa Ynez Band 

7 of Chumash Indians, from K. McConnell, Director, Waste Confidence

8 Directorate, NRC, regarding the Waste Confidence Scoping Process. 

9 Accession No. ML13011A015.

10 January 11, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

11 Confidence Environmental Impact Statement and Rulemaking 

12 (FSME–13–003). Accession No. ML13011A150.

13 January 31, 2013 Summary of Public Teleconference to Discuss Status of Waste 

14 Confidence Environmental Impact Statement and Rulemaking

15 (January 16, 2013). Accession No. ML13032A100.

16 January 31, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

17 Confidence Environmental Impact Statement and Rulemaking

18 (February 20, 2013). Accession No. ML13031A063.

19 February 5, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

20 Confidence Environmental Impact Statement and Rulemaking

21 (FSME-13–016). Accession No. ML13032A152.

22 February 5, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence teleconference 

23 meeting summary, transcript and upcoming meeting. Accession 

24 No. ML13120A475.

25 March 1, 2013 Summary of Public Teleconference to Discuss Status of Waste 

26 Confidence Environmental Impact Statement and Rulemaking

27 (February 20, 2013). Accession No. ML13060A105.

28 March 4, 2013 Summary Report for the Waste Confidence Generic Environmental 

29 Impact Statement Scoping Process. Accession No. ML13060A136.

30 March 5, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence scoping

31 summary report and upcoming teleconference information. Accession 

32 No. ML13120A476.
Appendix C

Draft NUREG‒2157 C-6 September 2013

1 March 5, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

2 Confidence Generic Environmental Impact Statement and Rulemaking

3 (March 20, 2013). Accession No. ML13063A465.

4 March 8, 2013 Letter to K. McConnell and A. Imboden, Waste Confidence Directorate, 

5 NRC, from D. Brancato, Riverkeeper, NRC Waste Confidence Update – 

6 Request for Public Meeting. Accession No. ML13102A054. 

7 March 8, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

8 Confidence Environmental Impact Statement and Rulemaking 

9 (FSME–13–024). Accession No. ML13063A491.

10 March 28, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

11 Confidence Generic Environmental Impact Statement and Rulemaking

12 (April 17, 2013). Accession No. ML13087A363.

13 April 5, 2013 Summary of Public Teleconference to Discuss Status of Waste 

14 Confidence Environmental Impact Statement and Rulemaking

15 (March 20, 2013). Accession No. ML13095A362.

16 April 5, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

17 Confidence Environmental Impact Statement and Rulemaking

18 (FSME-13–034). Accession No. ML13091A344.

19 April 11, 2013 E-mail from WCOutreach@nrc.gov, Upcoming April public 

20 teleconference and March meeting summary and transcript. 

21 Accession No. ML13120A482.

22 May 2, 2013 Summary of Public Teleconference to Discuss Status of Waste 

23 Confidence Environmental Impact Statement and Rulemaking (April 17, 

24 2013). Accession No. ML13122A097.

25 May 6, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

26 Confidence Generic Environmental Impact Statement and Rulemaking

27 (May 29, 2013). Accession No. ML13127A380.

28 May 8, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence April 17 meeting 

29 summary and transcript, and May 29 meeting notice. Accession 

30 No. ML13128A508.
Appendix C

September 2013 C-7 Draft NUREG‒2157

1 May 14, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

2 Confidence Generic Environmental Impact Statement and Rulemaking

3 (FSME-13-044). Accession No. ML13133A072.

4 May 14, 2013 Letter to D. Brancato, Riverkeeper, from K. McConnell, NRC, regarding 

5 NRC Waste Confidence Update – Request for Public Meeting. 

6 Accession No. ML13126A214.

7 May 23, 2013 Letter to NRC Commissioners, from K. Landis-Marinello, Assistant 

8 Attorney General, State of Vermont, States’ Petition for Review of NRC 

9 Staff Scoping Decision, Spent Fuel Storage EIS (RIN 3150-AJ20; 

10 NRC-2012-0246). Accession No. ML13149A446.

11 May 24, 2013 Letter to A. Vietti-Cook, Secretary of the Commission, NRC, from 

12 K. Landis-Marinello, Assistant Attorney General, State of Vermont, 

13 Distributing States’ Petition for Review of NRC Staff Scoping Decision; 

14 Spent Fuel Storage EIS (RIN 3150-AJ20; NRC-2012-0246). Accession 

15 No. ML13149A446.

16 May 30, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

17 Confidence Generic Environmental Impact Statement and Rulemaking

18 (June 19, 2013). Accession No. ML13150A263.

19 June 4, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

20 Confidence Generic Environmental Impact Statement and Rulemaking

21 (FSME-13-053). Accession No. ML13154A434.

22 June 6, 2013 Summary of Public Teleconference to Discuss Status of Waste 

23 Confidence Generic Environmental Impact Statement and Rulemaking

24 (May 29, 2013). Accession No. ML13158A024.

June 13, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence June 19th 25 status 

teleconferencing notice, and May 29 26 th meeting summary and transcript. 

27 Accession No. ML13171A353.

28 June 24, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence Commission 

29 review draft documents now available. Accession No. ML13175A390. 

July 17, 2013 E-mail from WCOutreach@nrc.gov, Waste Confidence June 19 30 th Status 

31 Teleconference Meeting Summary and Transcript. Accession 

32 No. ML13219A201. 
Appendix C

Draft NUREG‒2157 C-8 September 2013

1 July 23, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

2 Confidence Generic Environmental Impact Statement and Rulemaking

3 (August 14, 2013). Accession No. ML13205A393.

4 July 23, 2013 Letter to W. Sorrell, Attorney General, State of Vermont, from Allison M. 

5 Macfarlane, Chairman, NRC, regarding the Petition for Review of Staff 

6 Scoping Decision. Accession No. ML13204A315. (Identical letters sent 

7 to D. Springer, G. Jepsen, M. Coakley, and E. Schneiderman.)

8 July 31, 2013 Notice of Forthcoming Public Teleconference to Discuss Status of Waste 

9 Confidence Generic Environmental Impact Statement and Rulemaking

10 (FSME-13-075). Accession No. ML13211A429.

11 August 5, 2013 E-mail from WCOutreach@nrc.gov, Commission Approves Publication of 

12 Proposed Waste Confidence Rule and Draft Generic EIS. Accession 

13 No. ML13219A211. 
Appendix D 

–

Draft GEIS Comments and Responses

September 2013 D-1 Draft NUREG‒2157

Appendix D

Draft GEIS Comments and Responses

1 This appendix is intentionally left blank. This appendix will summarize the comments and 

2 responses received on the draft Generic Environmental Impact Statement (GEIS) and proposed 

rule. 3 

4 Comments and responses on the draft GEIS and proposed rule will be contained in a separate 

5 document that will be issued with and referenced in the final GEIS and Federal Register notice 

6 for the final rule.

Appendix E

–

Analysis of Spent Fuel Pool Leaks

September 2013 E-1 Draft NUREG‒2157

Appendix E 

Analysis of Spent Fuel Pool Leaks

1 This appendix describes the environmental impacts of spent fuel pool leaks that may occur 

2 during the short-term storage timeframe (defined in Chapter 1 as the first 60 years after the end 

of a reactor’s licensed life for operation).1 3 For the analysis presented in this appendix, the 

4 U.S. Nuclear Regulatory Commission (NRC) assumes that spent nuclear fuel (spent fuel) is 

5 removed from the pool within 60 years of the end of the reactor’s licensed life for operation. 

6 Once removed from the spent fuel pool, the spent fuel will be transferred to dry casks for 

7 storage in an independent spent fuel storage installation or shipment to a repository. 

8 As described in Section E.2, this appendix evaluates the potential offsite (i.e., outside the 

9 owner-controlled area) environmental impacts of spent fuel pool leaks. The environmental 

10 consequences of accidents, (e.g., cask drops) and natural events (e.g., earthquakes) that 

11 damage the spent fuel pool structure and result in a catastrophic loss of water volume in the 

12 spent fuel pool are discussed in Section 4.18.

13 Section E.1 provides a historical overview of information pertaining to spent fuel pool leaks, 

14 including information on spent fuel pool designs, operation, and the history of spent fuel pool 

15 leaks at commercial nuclear power plants. Section E.2 describes the potential offsite 

16 environmental impacts of spent fuel pool leaks to groundwater, surface water, soils, and public 

17 health. Section E.3 presents historical data on spent fuel pool leaks.

18 E.1 Background 

19 As of March 2013, there are 104 commercial nuclear reactors licensed to operate in the 

20 United States. These reactors are located at 65 sites in 31 states (Figure E-1). Of these 

21 104 reactors, 69 are pressurized water reactors and 35 are boiling water reactors. Because 

22 some of these reactors share spent fuel pools, there are 59 pressurized water reactor and 

23 35 boiling water reactor spent fuel pools.

 

1 Historically, the NRC has devoted considerable attention to the topic of this appendix, reflected in the 

detailed analyses and studies discussed in the appendix. In light of the historic interest of the public in 

this issue, as evidenced by comments in NRC’s Waste Confidence rulemaking, as well as related 

litigation, this appendix provides a more detailed discussion of referenced materials and studies that 

underlie the analysis of spent fuel pool leaks in the body of this draft generic environmental impact 

statement (draft GEIS). 
Appendix E

Draft NUREG‒2157 E-2 September 2013

1

2 Figure E-1. Locations of U.S. Nuclear Power Plants. Symbols indicate the years of operation 

3 as of the end of 2010 (NRC 2012a).

4 E.1.1 Spent Fuel Pools

5 Figure E-2 shows diagrams of generic pressurized water reactor and boiling water reactor spent 

6 fuel pools. In general, spent fuel pools for boiling water reactor plants are elevated structures 

7 within the containment building and are filled with demineralized water. Spent fuel pools at 

8 pressurized water reactors are generally located in an auxiliary building adjacent to the reactor 

9 building and contain borated water (e.g., 2,200 to 2,400 ppm boron, pH ~4.8). A typical spent 

10 fuel pool for a pressurized water reactor is about 12 m [40 ft] deep and 12 m [40 ft] or more in 

11 each horizontal direction (Copinger et al. 2012). Water is maintained at a minimum depth of at

12 least 6 m [20 ft] above the spent fuel bundles to ensure sufficient shielding of the spent fuel 

13 bundles. Water levels are maintained by periodically adding water to the pool to compensate 

14 for evaporation. Typically, the reinforced concrete walls are between 0.7 and 3 m [2 and 10 ft]

15 thick and the inside surfaces are lined by welded stainless-steel plates to form a leak-tight 

16 barrier. These plates are generally about 6 to 13 mm [0.25 to 0.5 in.] thick and joined by full17 penetration seam welds. The liner plates may also be plug welded between the seams to studs 

18 embedded in the concrete. In addition, all licensees actively monitor spent fuel pools for 

19 leakage, either directly though leak-detection systems or through various procedural controls. 

20 Leak-detection systems typically consist of several channels installed over the seams formed 

21 when spent fuel pool liner plates are welded together. These channels often can be monitored 

22 individually and are designed so leaked water empties into drains where it can be monitored 

23 and returned to either sumps or other cleanup or collection systems (NRC 1997a).
Appendix E

September 2013 E-3 Draft NUREG‒2157

1

2 (a)

3 

4 (b) 

5 Figure E-2. Generic Layouts of Spent Fuel Pools and Transfer Systems for (a) Pressurized 

6 Water Reactors and (b) Boiling Water Reactors (NRC 1997a)
Appendix E

Draft NUREG‒2157 E-4 September 2013

1 In addition, spent fuel pools are serviced by spent fuel pool cooling and purification systems. 

2 These systems provide cooling to the spent fuel in the pool, provide makeup water to the pool, 

3 maintain water chemistry, and remove fission products from the spent fuel pool water.

4 There is also one standalone spent fuel pool facility in the United States, the GE-Hitachi Nuclear 

5 Energy Americas, LLC, Morris wet storage facility (GEH Morris) in Morris, Illinois (DOE 2003). 

6 Though GEH Morris was originally designed as a commercial reprocessing facility, only the 

7 storage facility was completed and remains in operation. GEH Morris currently holds 

8 3217 spent fuel assemblies from commercial nuclear power plants. These spent fuel 

9 assemblies are stored in two pools. As with spent fuel pools at nuclear power plants, the GEH 

10 Morris spent fuel pools are stainless-steel-lined reinforced concrete structures with leak11 detection systems (GE 2004). 

12 Spent Fuel Pool Maintenance

13 Even though the reactor is no longer operating during the short-term storage timeframe, a 

14 licensee is still bound by the terms and conditions of its operating license until the license is 

15 terminated. As a result, the NRC assumes that spent fuel pool maintenance requirements that 

16 are in place during the operating period of the reactor will remain in place during the short-term 

17 timeframe and will stay in place even if the license is modified during the short-term timeframe.

18 The safety of spent fuel storage is established for each facility through a safety analysis report

19 prepared by the licensee to support its application for an operating license and reviewed by the 

20 NRC. Each safety analysis report includes a number of operational conditions and limitations 

21 important to safe spent fuel storage. These conditions and limitations are subject to regulations 

22 that restrict the changes that can be implemented without prior NRC approval. Among these 

23 regulations are requirements to implement managerial and administrative controls to ensure

24 safe operation through implementation of the facility’s quality assurance program (Title 10 of the 

25 Code of Federal Regulations [CFR] 50.54(a)) and requirements for licensees to obtain a license 

26 amendment prior to implementing changes to the facility or facility procedures that do not meet 

27 certain criteria (10 CFR 50.59). In addition to these regulations, administrative technical 

28 specifications for nuclear power plants typically include a requirement to establish, implement, 

29 and maintain a broad range of procedures for safe operation of the facility. The design basis of 

30 the various facility structures, systems, and components and the licensee’s NRC-approved 

31 quality assurance program, change control processes, and plant procedures ensure that the 

32 facility structures, systems, and components will operate and be maintained within established 

33 safety parameters to accomplish their functions during normal operating as well as accident

34 conditions.

35 Licensees are required to monitor the performance and condition of structures, systems, and 

36 components important to safety (10 CFR 50.65). Monitoring the structures, systems, and 

37 components provides reasonable assurance that the structures, systems, and components are 
Appendix E

September 2013 E-5 Draft NUREG‒2157

1 capable of fulfilling their intended functions. Often referred to as the “Maintenance Rule,”

2 10 CFR 50.65 further requires the licensee to take appropriate corrective action when the 

3 performance or condition of a structure, system, or component important to safety does not 

4 conform to established performance criteria. The main objective of the Maintenance Rule is to 

5 monitor the overall continuing effectiveness of maintenance programs used by the licensees to 

6 ensure that safety-related (and certain nonsafety-related) structures, systems, and components

7 are capable of performing their intended functions. All nuclear power plants have specific aging 

8 management programs to inspect, monitor, detect, and trend the aging of spent fuel structure 

9 concrete, liner plate and structural steel that support different commodities. The aging 

10 management program also include an acceptance criteria that can be used to evaluate the 

11 inspection results and determine if the spent fuel pool structure can perform its intended 

12 function or if corrective action is needed. The inspections are performed periodically at a 

13 frequency of 5 to 10 years.

14 For nuclear power plants that have undergone license renewal, the existing aging management

15 program for the spent fuel pool concrete structure and liner plate is enhanced to monitor 

16 leakage from the spent fuel pool. The enhancement requires monitoring to ensure that leak 

17 chase channels embedded in the concrete as a part of the liner plate are open, unclogged, and 

18 allow free flow of water from the spent fuel pool liner plate. This leaked water is then collected, 

19 analyzed, treated, and disposed of properly. This approach ensures that the water from the 

20 spent fuel pool does not leak to the environment through cracks in the concrete. These 

21 inspections and monitoring activities help ensure that issues associated with aging of spent fuel 

22 pools will be identified and addressed in a timely manner, decreasing the likelihood that a spent 

23 fuel pool would develop a long-term, undetected leak due to aging-related degradation 

24 mechanisms.

25 E.1.2 Groundwater Monitoring and Licensee Response to Leaks at Nuclear 

26 Power Plants

27 This section describes the NRC’s requirements for groundwater monitoring and the nuclear 

28 industry’s implementation of groundwater monitoring at nuclear power plant sites.

29 On June 17, 2011, the NRC issued its Decommissioning Planning Rule (76 FR 35512). The 

30 purpose of this rule, which amended regulations at 10 CFR Parts 20, 30, 40, 50, 70, and 72, is 

31 to “improve decommissioning planning and thereby reduce the likelihood that facilities under its 

32 jurisdiction will become legacy sites” (76 FR 35512). A legacy site is one with complex issues 

33 that is in a decommissioning status and whose owner cannot complete the decommissioning 

34 work for technical or financial reasons (76 FR 35512). The Decommissioning Planning Rule, 

35 through amended regulations at 10 CFR 20.1406 and 20.1501, requires licensees of operating 

36 facilities to “minimize the introduction of significant residual radioactivity into the site, including 

37 the subsurface, and to perform radiological surveys to identify the extent of significant residual 

38 radioactivity at their sites, including the subsurface” (NRC 2012b). For nuclear power plants 
Appendix E

Draft NUREG‒2157 E-6 September 2013

1 licensed before August 20, 1997, which includes all currently operating reactors, the NRC has 

2 found that, in general, groundwater monitoring conducted in accordance with the Groundwater 

3 Protection Initiative developed by the Nuclear Energy Institute, a nuclear industry consortium, is 

4 adequate to comply with these regulations (NRC 2012b). However, licensees may choose to 

5 develop groundwater-monitoring programs with additional elements than those recommended 

6 by the Groundwater Protection Initiative. For nuclear power plants licensed after August 20, 

7 1997, licensees are subject to the additional requirements of 10 CFR 20.1406(a)-(b), of which 

8 “monitoring and routine surveillance programs are an important part of minimizing potential 

9 contamination” (NRC 2008).

10 The Nuclear Energy Institute developed its Groundwater Protection Initiative in 2006 in 

11 response to leaks containing radioactive material at several plants. The Initiative is described in 

12 NEI 07–07, “Industry Ground Water Protection Initiative - Final Guidance Document” (NEI 

13 2007). All power reactor licensees have committed to follow the initiative, which identifies 

14 actions to improve licensee response to inadvertent releases, including releases from spent fuel 

15 pools that may result in low, but detectible, levels of plant-related radioactive materials in 

16 subsurface soils and water. The Initiative identifies the actions licensees are expected to take, 

17 including the development of written groundwater protection programs, improved stakeholder 

18 communications, and program oversight. An important objective of the initiative is to detect 

19 leaks well before radionuclide concentrations approach regulatory limits for radioactive releases. 

20 The Initiative also addresses detection and remediation of leaks. The Electric Power Research 

21 Institute, another industry organization, has published guidance to licensees on the design and 

22 implementation of a groundwater-monitoring program (EPRI 2008).

23 As part of these efforts, the nuclear power industry has committed to improving communication 

24 with external stakeholders, including members of the public as well as local, State, and Federal 

25 government officials. This includes: (i) periodic briefings on their site-specific groundwater

26 protection programs; (ii) prompt notice to the cognizable authorities whenever significant onsite 

27 spills or leaks into groundwater occur or onsite or offsite monitoring results exceed monitoring 

28 standards; (iii) a written 30-day report to the NRC for any monitoring result for onsite 

29 groundwater that is, or may be used as, a source of drinking water that exceeds monitoring

30 criteria; and (iv) an annual radiological environmental operating report or the annual radioactive 

31 effluent release report that documents onsite groundwater sample results and a description of 

32 any significant onsite leaks or spills into groundwater (NEI 2007).

33 Licensees might perform additional site-specific monitoring and reporting, based on State or 

34 local requirements, or agreements between the licensee and other interested parties. For 

35 example, as part of its settlement of spent fuel pool issues raised by parties to the Indian Point 

36 Units 2 and 3 relicensing proceeding, the licensee committed to publish the results of 

37 groundwater monitoring at Indian Point on a quarterly basis to a publicly available website and 

38 to conduct additional fish sampling in accordance with its monitoring plan (Entergy 2012).
Appendix E

September 2013 E-7 Draft NUREG‒2157

1 In April 2011, the NRC evaluated industry performance in “Summary of Results from 

2 Completion of NRC’s Temporary Instruction on Groundwater Protection, TI–2515/173 Industry 

3 Groundwater Protection Initiative” (NRC 2011b). This report was based on inspections 

4 conducted between August 2008 and August 2010 at all nuclear power plant sites. The report 

5 found that groundwater-monitoring programs had been implemented at virtually all nuclear 

6 power plant sites, and that licensees achieved an aggregate 95 percent completion of the 

7 NEI 07–07 Hydrology and Geology, and Site Assessment objectives. For the onsite 

8 groundwater monitoring objective, the completion rate was 92 percent (NRC 2011b). The NRC 

9 continues to monitor the implementation and maintenance of licensees’ groundwater monitoring 

10 programs through the reactor oversight process.

11 Licensee responses to leaks are dictated by the requirements of various NRC regulations. In 

12 Regulatory Guide (RG) 1.21, “Measuring, Evaluating, and Reporting Radioactive Material in 

13 Liquid and Gaseous Effluents and Solid Waste,” the NRC provides guidance to licensees on 

14 actions that could be taken to respond to, among other things, unplanned, abnormal releases 

15 (e.g., leaks). When an unplanned release occurs at a nuclear power plant, the licensee should 

16 identify the area as an “impacted area” for decommissioning planning purposes (NRC 2009). 

17 Further, the licensee should assess the release for reporting it in its annual radioactive effluent 

18 release report. Specifically, the location and estimated volume of the release should be 

19 recorded to identify the extent of the impacted area and predicted size or extent of the 

20 contaminant plume (NRC 2009). For leaks to groundwater, licensees should develop a site 

21 conceptual model, using standards such as American National Standards Institute/American 

22 Nuclear Society (ANSI/ANS) report 2.17–2010, “Evaluation of Subsurface Radionuclide

23 Transport at Commercial Nuclear Power Plants” to characterize, model, and monitor 

24 groundwater flow and radionuclide transport (NRC 2009). This conceptual and subsequent 

25 numerical model would be used as the basis for estimating the dispersion of radionuclide 

26 releases to groundwater. The monitoring program would confirm whether remediation programs 

27 are effective in precluding offsite impacts to groundwater resources.

28 E.1.3 Remediation Techniques

29 While the NRC does not require a specific approach to remediate radioactive contamination of 

30 groundwater that may result from spent fuel pool leakage, various technologies are currently 

31 available to remediate the contaminated groundwater. Licensees decide whether and how to 

32 remediate a radioactive release to groundwater based on a variety of circumstances, including 

33 the source and magnitude of the contamination events; the local and regional groundwater 

34 systems (as reflected in the site conceptual model); the NRC’s regulatory requirements (e.g.,

35 the radiological criteria for license termination in 10 CFR Part 20, Subpart E); and other Federal, 

36 State and local requirements (e.g., U.S. Environmental Protection Agency (EPA) drinking-water 

37 standards).
Appendix E

Draft NUREG‒2157 E-8 September 2013

1 As described in Ferry et al. (1999) groundwater contamination can be limited and mitigated 

2 through hydraulic isolation and capture, using groundwater extraction methods such as low3 discharge pumping wells and interceptor trenches or a funnel and gate system for near-surface 

4 plumes. The extracted groundwater can be treated to remove highly absorptive radionuclides

5 (e.g., strontium-90 and cesium-137) using appropriate separation technologies (e.g., ion6 exchange systems). However, tritium cannot be absorbed in those systems.

7 Various separation technologies can be applied to remove contaminants from the extracted 

8 groundwater. For radioisotopes of elements such as barium, cesium, cobalt, iodide, 

9 manganese, plutonium, and strontium, various treatment technologies are commonly used in 

10 the chemical- and wastewater-treatment industries. Most of these technologies can be broadly 

11 classified into two groups, depending on the reaction mechanism involved (i.e., precipitation or 

12 sorption [including ion exchange]) (IAEA 1999).

13 Using remediation techniques to reduce tritium concentrations to levels below concentrations 

14 exceeding EPA drinking-water standards is more difficult than for other groundwater

15 contaminants because tritium cannot be chemically absorbed. In general, the method used to 

16 remediate tritium is monitored natural attenuation with selective groundwater extraction for high17 concentration areas. Nevertheless, treatment technologies that have potential application for 

18 reducing very high tritium levels in groundwater include water distillation, combined electrolysis 

19 and catalytic exchange, bithermal hydrogen-water process, girdler sulfide process, palladium 

20 membrane reactor, and the GE-Hitachi Nuclear Energy integrated systems (Geniesse and 

21 Stegen 2009).

22 E.2 Environmental Impacts of Spent Fuel Pool Leaks

23 This section addresses the environmental impacts of spent fuel pool leaks that might occur 

24 during the short-term storage timeframe. The NRC’s Decommissioning Planning Rule, 

25 discussed in Section E.1.2, requires licensees to identify the extent of significant residual 

26 radioactivity at their sites, including the subsurface (NRC 2012b). Any significant radioactivity 

27 identified by licensees must be addressed during the decommissioning process to meet the 

28 license-termination requirements of 10 CFR Part 20, Subpart E. As a result, spent fuel pool 

29 leaks that result in contamination that remains onsite are addressed as part of the 

30 decommissioning and license-termination processes, and are outside the scope of this draft 

31 Waste Confidence Generic Environmental Impact Statement (draft GEIS). The environmental 

32 impacts resulting from both normal operations and accidents during decommissioning activities 

33 and all onsite or offsite residual radioactive material that may remain after license termination 

34 are addressed in “Generic Environmental Impact Statement on Decommissioning of Nuclear 

35 Facilities” (NRC 2002) and “Generic Environmental Impact Statement in Support of Rulemaking

36 on Radiological Criteria for License Termination of NRC-Licensed Nuclear Facilities” (NRC 

37 1997b), respectively.
Appendix E

September 2013 E-9 Draft NUREG‒2157

1 E.2.1 Factors that Influence the Impacts of Spent Fuel Pool Leaks

2 A combination of factors minimize the likelihood that a spent fuel pool leak occurring during the 

3 short-term storage timeframe will result in noticeable offsite environmental impacts. The 

4 combination of spent fuel pool design and maintenance; operational practices (e.g., spent fuel 

5 pool leakage monitoring and groundwater monitoring), site hydrogeological characteristics; and 

6 radionuclide-transport properties together make the likelihood very low that an undetected leak 

7 from the spent fuel pool will migrate offsite. Some of these factors, plus NRC oversight and 

8 regulatory controls, will ensure that licensees act to identify and diminish potential 

9 consequences, should a leak that results in an offsite release occur. 

10 E.2.1.1 Spent Fuel Pool Design, Operation and Monitoring

11 As noted below in Section E.3, spent fuel pool leaks have been detected at 13 nuclear power 

12 plant sites. Spent fuel pool leaks, while unpredictable, seldom occur due to stringent design 

13 features and operational controls. As discussed, all operating spent fuel pools are lined with 

14 stainless-steel liners that form a leak-tight barrier between the water in the pool and the 

15 concrete walls of the pool. In addition, all licensees actively monitor for leaks from spent fuel 

16 pools and will continue to do so throughout the short-term storage timeframe. In most cases, 

17 the combination of the spent fuel pool liner and leakage monitoring prevent spent fuel pool 

18 water from leaking, undetected, into the environment. Further, as described in Section E.1.1, 

19 the licensee is required to continuously ensure the integrity of the spent fuel pool liner and 

20 structure by maintaining a low-corrosive environment in the spent fuel pool water through proper 

21 water chemistry control.

22 Nonetheless, relatively small cracks can occur in the stainless-steel liner due to intergranular 

23 stress-corrosion cracking and crevice corrosion of the stainless-steel liner, seam or plug weld 

24 defects, or damage to the liner, resulting in leakage from the spent fuel pool (Copinger et al. 

25 2012). For spent fuel pools with leakage-collection systems installed, these systems could 

26 become clogged or obstructed, which could cause the water to back up in the space between 

27 the liner and concrete. Spent fuel pool water that bypasses the collection system can migrate 

28 through construction joints and cracks in the concrete due to shrinkage, creep, or alkali silica 

29 reaction, resulting in release of contaminated water outside the pool. Whether resulting from 

30 leakage through the liner or clogging in the leakage-collection system, spent fuel pool leaks are 

31 uncommon and unpredictable. However, knowledge and techniques gained from earlier 

32 industry and NRC studies of spent fuel pool leaks should result in heightened awareness of 

33 leaks and earlier detection and mitigation. 

34 Significant short-term water loss from a spent fuel pool is likely to be identified due to licensee 

35 monitoring of spent fuel pool water levels. Furthermore, because of NRC requirements to 

36 identify and minimize contamination (see Section E.1.2), licensees would likely identify and 

37 mitigate, if necessary, the impacts from any significant short-term water loss before noticeable 
Appendix E

Draft NUREG‒2157 E-10 September 2013

1 offsite environmental impacts would occur. As a result, this evaluation considers a long-term, 

2 low-volume undetected leak from a spent fuel pool as the most probable scenario where spent 

3 fuel pool leakage would lead to an offsite environmental impact. To go undetected, a leak 

4 would need to be less than the fluctuations in water level of a spent fuel pool lost to evaporation. 

5 This is so because the spent fuel pool water level is constantly measured by instrumentation 

6 and monitored routinely by the reactor operators. Also, licensees must perform routine 

7 inspections of leak-detection systems and physically inspect the spent fuel pool area for 

8 leakage. 

9 Based on operational experience, the model leak used for analysis here is assumed to 

10 correspond to a leak rate of approximately 380 L/day [100 gpd] (NRC 2004). In analyzing the 

11 impacts of a spent fuel pool leak, the NRC assumed a leak rate similar to the rate of water lost 

12 due to evaporation, which would effectively double the makeup rate to the spent fuel pool. A 

13 leak of this magnitude would likely be identified in an expeditious manner because of licensee 

14 monitoring and surveillance.

15 In addition to spent fuel pool design and operational controls, licensees are required, as 

16 described in Section E.1.2, to perform groundwater monitoring at nuclear power plant sites, 

17 which makes it unlikely that leakage from the spent fuel pool would remain undetected long 

18 enough for any contamination to migrate offsite. In addition, a groundwater-monitoring program 

19 based on a site characterization that conforms to standards (e.g., ANSI/ANS 2.17–2010) and a 

20 configuration of monitoring wells that takes into account the most likely leakage pathway (i.e., 

21 the spent fuel pool) would further reduce the likelihood that a leak would remain undetected long 

22 enough for contamination to migrate offsite.

23 E.2.1.2 Radionuclides in Spent Fuel Pools and Radionuclide Transport

24 Impacts from spent fuel pool leakage occur from radionuclide contaminants present in spent fuel 

25 pool water. The sources of radionuclide contaminants in spent fuel pool water are activation 

26 products and fission products. Activation products are elements formed from the neutron 

27 bombardment of a stable element and fission products are elements formed as a byproduct of a 

28 nuclear reaction and radioactive decay of other fission products. The sources of activation 

29 products are corrosion and wear deposits (including corrosion films on the fuel bundle surfaces). 

30 Fission products come from bundles with rods that failed in-reactor or from intact bundles that 

31 adsorbed circulating fission products (Johnson 1977).

32 Table E-1 lists radionuclides of concern expected to be present in the spent fuel pool water. 

33 The initial concentration column represents the concentration of radionuclides assumed to be 

34 present at the start of the short-term storage timeframe. The final concentration column 

35 represents those radionuclides at the end of the short-term storage timeframe, assuming only 

36 radioactive decay. Actual concentrations would vary based on the efficiency of the spent fuel 

37 pool purification system and the integrity of the spent fuel assemblies stored in the pool. 
Appendix E

September 2013 E-11 Draft NUREG‒2157

1 Because of radioactive decay and the spent fuel pool purification system, spent fuel pool leaks

2 that occur later in the short-term storage timeframe will likely have less impact on onsite soil and 

3 groundwater quality due to the lower concentration of radionuclides present in the leaked spent 

4 fuel pool water.

5 Table E-1. Spent Fuel Pool Radionuclides of Concern

Nuclide Half-Life(a)

Initial Concentration

(micro Curies per 

milliliter)(b)

Final Concentration

(micro Curies per 

milliliter)

Co-58 72 days 3.5 × 10−4 –

Co-60 5.3 years 8.0 × 10−4 3.1× 10−7

Cs-134 2.1 years 8.6 × 10−4 –

Cs-137 30 years 1.3 × 10−3 3.3 × 10−4

H-3 12.3 years 2.9 × 10−2 1.0 × 10−3

Sr-90 28.8 years 5.9 × 10−6 1.4 × 10−6

(a) Johnson (1977).

(b) NRC (2006b).

6 As discussed in the preceding section, spent fuel pool water with radioactive contaminants 

7 could leak through small, intergranular stress-corrosion or crevice-corrosion cracks in the 

8 stainless-steel liner into the space between the liner and the concrete. Because concrete has a 

9 very low permeability, it serves as an additional barrier between leaked spent fuel pool water 

10 and the environment. However, contaminated water could migrate to the environment through 

11 construction joints and cracks in the concrete if the water backs up in the space between the 

12 liner and concrete and a sufficient hydraulic head is developed. As radionuclides migrate 

13 through the concrete structure, their concentrations in the leaked water and the volume released

14 to the environment could be reduced by sorption onto the concrete material. Sorption, a 

15 process by which a substance in solution attaches onto a solid material, can retard the 

16 movement of radionuclides and thus reduce radionuclide concentrations in the leaked water.

17 Spent fuel pool water will likely leave the concrete structure at or near the ground surface and 

18 above the local unconfined water table. The initial migration of radionuclides from the spent fuel 

19 pool leak is usually vertically downward through the vadose zone, i.e., the surrounding and 

20 underlying unsaturated soil, backfill, or other near-surface, disturbed materials. However, the 

21 direction, rate, and volume of the leaked spent fuel pool water migration in the vadose zone is 

22 influenced by the zone’s ambient water content, the moisture and pressure gradients within the 

23 material, and the associated volume of the liquid released that may cause local saturation (or 

24 perching of the released fluid) due to the material’s inability to transmit water at the rate 

25 released (i.e., insufficient permeability).
Appendix E

Draft NUREG‒2157 E-12 September 2013

1 If a sufficient leak volume is released or the unsaturated material underlying the pool has 

2 hydrologic conditions to transmit the leaked water, the soil “wetting event” associated with the 

3 spent fuel pool leak can cause vertical radionuclide migration to reach an underlying shallow 

4 water table or unconfined aquifer (i.e., a saturated hydrogeological unit) and thus contaminate 

5 the aquifer. The rate of water movement would depend on the existing water content of the 

6 porous media and the permeability (an intrinsic property of the porous media related to pore 

7 sizes). For low water contents, the rate of water movement downwards would be slow. 

8 Consequently, it is possible that the water would initially be contained within the site area, but if 

9 the leak continues to be undetected, it will flow downwards in the direction of the aquifer. Once 

10 in the aquifer, the travel time to the environment outside the controlled boundary would depend 

11 upon the hydraulic gradient, the hydraulic properties of the aquifer, and the distance to the site 

12 boundary.

13 Various hydrologic and chemical processes could reduce the environmental impacts of 

14 radionuclides associated with leaked spent fuel pool water. As the contaminant plume evolves, 

15 the radionuclide concentrations may continue to decrease due to mixing, dilution, and 

16 radioactive decay. Different radioisotopes decay at different rates depending on their half-lives 

17 (see Table E-1). In addition, adsorption of radionuclides onto the aquifer matrix material may 

18 significantly delay the transport of radionuclides in the subsurface environment and keep 

19 radionuclide concentrations at low levels in groundwater. Further, adsorption may retard the 

20 movement of radionuclides because radionuclide mass is adsorbed on solid surfaces and 

21 becomes unavailable for transport by water. Although desorption of radionuclides from the 

22 aquifer matrix material back into the groundwater may eventually occur, concentrations will be 

23 much less than if no sorption occurred. Different radionuclides have different degrees of 

24 adsorptive interaction with geologic media due to the geologic materials and water chemistry. 

25 Some radionuclides (e.g., tritium) do not adsorb onto soil and bedrock and, therefore, move

26 generally at the same rate and direction as groundwater. Other radionuclides (e.g., 

27 strontium-90 and cesium-137) strongly adsorb onto geologic media and, thus, move much 

28 slower than the groundwater velocity and at reduced concentrations compared to the source of 

29 a leak. The degree of radionuclide adsorption and retardation depends on the properties of the 

30 geologic media (e.g., mineralogy, reactive surface area, and presence of organic matter) and 

31 groundwater chemistry (e.g., pH, oxidation-reduction potential, and complexing ion 

32 concentration).

33 E.2.1.3 Influence of Site Hydrological Conditions

34 Although it is unlikely that a leak from a spent fuel pool of sufficient magnitude and duration 

35 would go undetected long enough to result in offsite consequences, other factors act to mitigate 

36 any potential impacts should the unexpected occur. In particular, characteristics of ground 

37 water flow and transport of radionuclides in ground water would limit the amount of radioactivity 

38 that would travel offsite and reduce its concentration. A review of Final Safety Analysis Reports 
Appendix E

September 2013 E-13 Draft NUREG‒2157

1 for existing and proposed nuclear power plants, licensee Radioactive Effluent and 

2 Environmental Reports, and other relevant reports indicates that nuclear power plants have 

3 certain common hydrologic characteristics such as being located near large bodies of water and 

4 being sited in areas where the presence of a vadose zone would tend to reduce the amount of 

5 radioactive material leaving the site and lessen the concentration. Because of the siting criteria 

6 of 10 CFR Part 100 spent fuel pools are often located, and will continue to be located in areas 

7 with certain similar hydrologic characteristics.

8 By their nature, nuclear power plants require large volumes of water to provide cooling to plant 

9 systems. As a result, nuclear power plants, which include spent fuel pools, are typically located

10 adjacent to, or near, large surface waterbodies (e.g., rivers, lakes, and oceans). Regional 

11 groundwater flow in the vicinity of most spent fuel pools, particularly shallow water table or 

12 unconfined aquifer flow, is toward these large surface waterbodies. Localized water table flow 

13 around spent fuel pools can be influenced by a variety of physical features and hydrological 

14 conditions. Subsurface features (e.g., basements) or surface features (e.g., buildings and 

15 paved areas) can result in localized disturbances to shallow groundwater flow directions and 

16 velocities. In addition, short-term (transient) factors (e.g., droughts, floods, and daily tidal 

17 influences) can induce a temporary change in shallow groundwater flow directions and rates. 

18 Nevertheless, despite these localized or short-term effects, the NRC’s assessment of hydrologic 

19 conditions at existing nuclear power plant sites indicates that the water table aquifers at these 

20 sites typically have a predominantly horizontal flow component with ultimate discharge into an 

21 adjacent or nearby large waterbody.

22 Because most nuclear power plants are located at sites where the shallow unconfined 

23 groundwater at the site flows into the nearby surface waterbody, leaked water from the spent 

24 fuel pool at these sites would travel towards, and ultimately discharge into, the nearby surface 

25 waterbody. This travel time is often significant due to the fact that the typical spent fuel pool 

26 location adjacent to or in the vicinity of a large surface waterbody coincides with a relatively flat 

27 (i.e., small) hydraulic gradient in the shallow water table. The long travel times produced from a 

28 flat hydraulic gradient allow significant radiological decay of spent fuel pool leak-related 

29 radiological constituents resulting in reduced concentrations in the shallow water table. 

30 Nevertheless, even if one ignores the reduction in leak-related radiological constituent 

31 concentrations due to radiological decay, by volume, the largest undetectable spent fuel pool 

32 leak (approximately 380 L/day [100 gal/day]) is orders-of-magnitude less than flow rates or 

33 volumes of surface waterbodies typically located near nuclear power plant sites.

34 Given the need to locate nuclear power plants near large surface waterbodies, the fact that 

35 reactors are typically sited in areas of lower population density, and the often large size of the 

36 licensee-controlled area surrounding the spent fuel pool and entire facility, it is unlikely to have 

37 groundwater users located between the spent fuel pool and the nearest receiving surface 

38 waterbody (i.e., it is unlikely to have groundwater users downgradient of the spent fuel pool, but 
Appendix E

Draft NUREG‒2157 E-14 September 2013

1 upgradient of the surface waterbody). As a result, it is unlikely that local groundwater users 

2 would be situated in the downgradient path of a spent fuel pool related groundwater plume. 

3 Moreover, due to the large size of the licensee-controlled area and the typical upgradient 

4 location of local groundwater users with respect to the spent fuel pool, it is not expected that 

5 local groundwater pumping will have a significant influence on shallow groundwater flow 

6 conditions near the spent fuel pools (i.e., capture the spent fuel pool related plume due to 

7 pumping). Consequently, for nuclear power plant sites with typical hydrological conditions, it is 

8 unlikely that any shallow water table aquifer users in the vicinity of the nuclear power plant 

9 would be affected by water leaked from a spent fuel pool. Rather, for spent fuel pools located at 

10 sites with these typical characteristics, the environmental impacts of spent fuel pool leakage 

11 would result from the discharge of contamination to the surface waterbody.

12 In many cases, groundwater users located outside the licensee-controlled area surrounding 

13 spent fuel pool locations use deeper confined aquifers (i.e., deeper aquifers separated from the 

14 shallow water table by one or more horizontally continuous low-permeability layers). Potable 

15 water supply wells are often intentionally placed in deeper aquifer units because of the 

16 sensitivity of shallow water table aquifers to surficial sources of contamination (e.g., septic 

17 systems) and the impacts to shallow water supplies from climate variability. In addition, as with 

18 the shallow groundwater users discussed above, the fact that licensees typically maintain 

19 control of large areas of land surrounding the plant (i.e., large distance between spent fuel pool 

20 and local groundwater users) makes it highly unlikely that local groundwater pumping in the 

21 deeper confined aquifer would significantly influence shallow aquifer horizontal or vertical 

22 gradients at the spent fuel pool location. Moreover, it would be improbable for local deep 

23 aquifer potable wells to capture spent fuel pool affected groundwater from a shallow unconfined 

24 aquifer separated from the deeper system by a low-permeability confining layer.

25 Consequently, for nuclear power plant sites that exhibit the hydrologic conditions discussed 

26 above, the offsite environmental impacts would be minimal because groundwater contamination 

27 would likely stay onsite where the licensees would be required to address any residual 

28 contamination as part of the license-termination process. Alternatively, if discharged to a large 

29 waterbody, as discussed in Section E.2.2.2, dilution would reduce concentrations below 

30 analytical detection limits.

31 For spent fuel pools located at sites with hydrological conditions different from those described 

32 above, a leak from a spent fuel pool has the potential to affect nearby groundwater users. 

33 These potential impacts are discussed in Section E.2.2.1. 

34 E.2.2 Analysis of the Impacts of Spent Fuel Pool Leaks

35 Systems or structures can experience undetected radioactive leaks over a prolonged period and 

36 those that are buried or in contact with soil (e.g., spent fuel pools) are particularly susceptible to 

37 undetected leakage (NRC 2006b). An important conclusion of the NRC Lessons Learned Task 
Appendix E

September 2013 E-15 Draft NUREG‒2157

1 Force report (see Section E.3.1) is that the near-term health of the offsite public was not 

2 impacted by inadvertent liquid releases to the environment that have occurred due to previous 

3 spent fuel pool leaks at U.S. nuclear facilities (NRC 2006b). As a result, environmental impacts 

4 from past leaks to groundwater have been minimal. Further, a senior management review of 

5 the NRC Groundwater Task Force (see Section E.3.1) concurred with the Groundwater Task 

6 Force’s conclusion that the NRC is accomplishing its stated mission of protecting public health, 

7 safety, and the environment through its response to groundwater leaks and spills, consistent 

8 with its regulatory framework (NRC 2011a). This protection will continue through the short-term 

9 timeframe and will likely continue to be strengthened based on operating experience.

10 In the unlikely event of offsite migration, offsite physical resources that might be adversely 

11 affected by spent fuel pool leaks are groundwater, surface water, and soils. Potential public 

12 health impacts through these affected resources must also be considered. As described in 

13 Sections E.2.1.1–E.2.1.3, a variety of factors work together to make it unlikely that a leak from a 

14 spent fuel pool would result in offsite consequences. These include design and operational 

15 controls for the spent fuel pool, which should result in the detection and resolution of a leak 

16 before it develops sufficient volume to migrate offsite; radionuclide-transport properties, which 

17 would result in lower contaminant concentrations in the leak volume; and site hydrological 

18 characteristics, which lessen the likelihood that a leak would migrate offsite. As discussed in 

19 Section E.1.3, various remediation strategies can be employed in the event of a leak; however, 

20 the decision about whether and how to remediate a radioactive release to groundwater is based 

21 on a variety of circumstances including, but not limited to, the magnitude of the contamination, 

22 the NRC’s regulatory requirements (e.g., the radiological criteria for license termination 

23 described in 10 CFR Part 20, Subpart E), and other Federal, State and local requirements (e.g., 

24 EPA drinking-water requirements).

25 E.2.2.1 Groundwater

26 Historically, radiological contamination from spent fuel pool leaks has remained onsite within 

27 each licensee’s owner-controlled area or travelled to a nearby surface waterbody (see 

28 Section E.3). Because these leaks have remained onsite or were discharged to large surface 

29 waterbodies, where significant dilution occurred, there have been no impacts to any offsite 

30 groundwater wells used as a potable resource. As described in Section E.2.1.3, this is mainly

31 because the duration or volume of water leaked from the spent fuel pool was insufficient to 

32 result in elevated radionuclide concentrations away from the source or that the spent fuel pools 

33 are sited in areas where the hydrologic conditions impede the flow of leaked water away from 

34 the source (e.g., flat hydraulic gradient) or direct flow to the nearby surface waterbody where 

35 dilution occurs.

36 In the short-term timeframe, spent fuel pool design (stainless-steel liners and leakage-collection 

37 systems) and operational controls (monitoring and surveillance of spent fuel pool water levels) 

38 make it unlikely that a leak will remain undetected long enough to exceed any regulatory 
Appendix E

Draft NUREG‒2157 E-16 September 2013

1 requirement (e.g., the NRC dose limit or EPA-mandated Maximum Contaminant Level) in the 

2 offsite environment. In addition, onsite groundwater monitoring required to comply with 

3 10 CFR 20.1501 provides added protection with respect to identifying a spent fuel pool leak

4 and, if necessary, isolating and remediating contaminated groundwater onsite. Besides these 

5 measures, the hydrologic characteristics associated with typical nuclear power plant settings 

6 (see Section E.2.1.3)—such as their location near large waterbodies (due to cooling 

7 requirements), shallow water table flow direction toward these waterbodies, flat hydraulic 

8 gradients in the shallow water tables, large distance to local groundwater users, and the 

9 likelihood that local groundwater usage is in deeper confined aquifers—would act to impede the 

10 offsite migration of future spent fuel pool leakage. Finally, current and future spent fuel pool 

11 sites are required to have routine environmental monitoring programs in place that should take 

12 samples at offsite groundwater sources (e.g., potable or irrigation) in areas where the hydraulic 

13 gradient or recharge properties are suitable for contamination (NRC 1991a,b). Further, any 

14 detection of onsite contamination would likely result in additional monitoring, including additional 

15 sampling of any nearby private wells, as part of an expanded environmental monitoring 

16 program. With these measures and characteristics in place, it is improbable that offsite 

17 migration of spent fuel pool leaks will occur or go undetected.

18 In the very unlikely event that a leak goes undetected and the resulting groundwater plume 

19 reaches the offsite environment, it is possible that the leak could be of a sufficient enough 

20 magnitude and duration that contamination of a groundwater source above a regulatory limit

21 (i.e., a Maximum Contaminant Level for one or more radionuclide) could occur. But, because of 

22 the relatively small size of the maximum assumed leak rate, the impacts to groundwater would 

23 be highly localized and would not be expected to impact regional groundwater resources. If 

24 contamination from a spent fuel pool leak were to exceed a Maximum Contaminant Level for 

25 one or more radionuclides at a groundwater source that currently supplies water to public water 

26 supplies or that has the potential to supply a public water supply (including private wells), the 

27 EPA could take emergency action under the Safe Drinking Water Act (EPA 1991). Emergency 

28 actions include, but are not limited to, providing alternative water supplies, public notification of 

29 potentially affected users, and remediation of the contamination (EPA 1991).

30 The impacts of a spent fuel pool leak on offsite groundwater depend on many factors, including 

31 the volume and rate of water released from the spent fuel pool, the radionuclide content and 

32 concentration and water chemistry of the spent fuel pool water, the direction of groundwater 

33 flow, the distance to an offsite groundwater receptor, the velocity or transport rates of 

34 radionuclides through the subsurface, and radioactive decay rates. However, as discussed 

35 previously, it is unlikely that a leak of sufficient quantity and duration could occur without 

36 detection, or that such a leak would not be impeded by the hydrologic characteristics typical at 

37 spent fuel pool locations. Therefore, based on the low probability of a leak with sufficient 

38 quantity and duration to reach offsite locations, the detection and monitoring mechanisms 

39 available to licensees and the NRC, and the hydrologic characteristics at typical spent fuel pool 
Appendix E

September 2013 E-17 Draft NUREG‒2157

1 sites, the NRC concludes that the radiological impacts to groundwater quality resulting from a 

2 spent fuel pool leak during short-term timeframe would be SMALL.

3 E.2.2.2 Surface Water

4 Spent fuel pool leaks can result in discharges of radionuclides to offsite surface waters. The

5 concentrations of radionuclides in offsite surface waters will depend on the rate of release from 

6 the spent fuel pool, the direction and rate of groundwater flow, the distance to nearby offsite 

7 surface waters toward which groundwater flows, the velocity or transport rates of radionuclides 

8 through the subsurface, and radioactive decay rates. For a given rate of release, the 

9 concentrations of radionuclides and, consequently, the presence of radionuclides in surface 

10 water would be dependent on the duration of the spent fuel pool leak. 

11 However, because surface waterbodies in the vicinity of nuclear power plants (e.g., oceans, 

12 lakes, rivers, or large man-made cooling-water impoundments) are large enough to meet 

13 reactor cooling requirements, a large volume of surface water is usually available, which would 

14 dilute any groundwater contaminants that flow into them. This dilution ensures that 

15 radionuclides present in groundwater with concentrations exceeding the Maximum Contaminant 

16 Level for that radionuclide are diluted well below EPA safe drinking-water limits.

17 To illustrate the low releases that would be associated with leaked spent fuel pool water, the 

18 NRC estimated the annual discharge rate associated with a leakage of 380 L/day [100 gpd] of 

19 radionuclides in spent fuel pool water at concentrations shown in Table E-1. These values can 

20 be compared in Table E-2 below to the annual liquid effluent discharges in 2008 for boiling 

21 water reactors and pressurized water reactors (NRC 2010b). Values for strontium-90 are not 

22 reported in the NRC annual effluent discharge report.

23 Table E-2. Comparison of Radionuclides Released From a Spent Fuel Pool Leak to 

24 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

Co-58 4.8 × 10−4 1.50 × 10−5 to 6.97 × 10−3 6.51 × 10−5 to 8.29 × 10−3

Co-60 1.1 × 10−3 3.35 × 10−5 to 7.66 × 10−2 1.11 × 10−4 to 4.84 × 10−3

Cs-134 1.2 × 10−3 2.19 × 10−5 to 3.37 × 10−4 7.00 × 10−8 to 4.48 × 10−4

Cs-137 1.8 × 10−3 1.91 × 10−6 to 1.95 × 10−3 1.13 × 10−6 to 1.37 × 10−3

H-3 4.0 × 10−2 1.13 × 10−3 to 1.27 × 102 1.59 × 102 to 1.66 × 103
Appendix E

Draft NUREG‒2157 E-18 September 2013

1 As shown in Table E-2, even in the highly unlikely event that undetected spent fuel pool leakage 

2 flowed continuously (24 hours per day, 365 days per year) and unimpeded to local surface 

3 waters, the quantities of radioactive material discharged to nearby surface waters would be 

4 comparable to values associated with permitted, treated effluent discharges from operating 

5 nuclear power plants.

6 Based on these considerations, the NRC concludes that the impact of spent fuel pool leaks on 

7 surface water would be SMALL.

8 E.2.2.3 Soils

9 Spent fuel pool leaks could result in radiological contamination of offsite soils. The degree of 

10 offsite soil contamination will depend on the rate of release from the spent fuel pool, direction of 

11 groundwater flow, the distance to offsite locations, the velocity or transport rates of 

12 radionuclides through soils, and radioactive decay rates. For a given rate of release, the soil 

13 radionuclide concentrations and mass of soil contaminated would be dependent on the duration 

14 of the spent fuel pool leak.

15 As noted in Section E.2.1.2, the degree to which offsite surface soils could become 

16 contaminated as a result of spent fuel pool leaks depends on the mobility of radionuclides in the 

17 onsite soil. Most radionuclides, other than tritium, that are present in detectable concentrations 

18 in spent fuel pools (e.g., isotopes of cesium and strontium) are absorbed to soil and thus move 

19 at a fraction of local groundwater velocities toward offsite locations. As a result, the presence of 

20 tritium in onsite groundwater-monitoring wells is usually the first indication that a spent fuel pool 

21 is leaking.

22 As stated above in Section E.2.2.1, tritium in groundwater is likely to be observed as part of a 

23 licensee’s radiological environmental monitoring program and corrective action would be taken 

24 consistent with Federal and State requirements. In addition, most radionuclides move at a 

25 much slower rate and are much more likely to be absorbed to the concrete structures of the 

26 spent fuel building and the soil surrounding the leak location. As a result, most soil 

27 contamination from spent fuel pool leaks would be expected to remain onsite and, therefore, 

28 offsite soil contamination is unlikely to occur. Therefore, the NRC concludes that the 

29 environmental impact of spent fuel pool leaks to offsite soils would be SMALL.

30 E.2.2.4 Public Health

31 For the purposes of assessing radiological impacts, environmental impacts are considered to be 

32 SMALL if releases and doses do not exceed permissible levels set by the NRC and the EPA. 

33 Therefore, the impact to public health would be SMALL if the spent fuel pool leakage was 

34 detected and remediated before regulatory limits for drinking water (e.g., EPA Maximum 

35 Contaminant Level) or effluent discharges (NRC dose limits in 10 CFR Part 50, Appendix I) 
Appendix E

September 2013 E-19 Draft NUREG‒2157

1 were exceeded. As described above, should a pool leak continue undetected for a long period, 

2 a highly localized exceedance of groundwater protection limits could occur. Public health 

3 concerns related to groundwater contamination would be limited to private wells nearest the 

4 site. Surface water and aquifers will not be significantly affected for the reasons discussed in 

5 Sections E.2.2.1 and E.2.2.2. In the event of uncontrolled and undetected discharges 

6 associated with long-term spent fuel pool leaks to nearby surface waters, the annual discharge 

7 would be comparable to normal discharges associated with operating reactors, and would likely 

8 remain below limits in 10 CFR Part 50, Appendix I. In the very unlikely event that a pool leak 

9 remained undetected for a long period, public health regulatory limits (i.e., EPA drinking-water 

10 standards) could be exceeded, and, therefore, the NRC has determined that public health 

11 impacts could be SMALL to MODERATE in such circumstances. However, as discussed in 

12 Section E.2.2.1, it is unlikely that a leak of sufficient quantity and duration could occur without 

13 detection or that such a leak would not be impeded by the hydrologic characteristics typical of 

14 spent fuel pool locations. Therefore, based on the low probability of a leak affecting offsite 

15 groundwater sources, the NRC concludes that impacts to public health resulting from a spent 

16 fuel pool leak during short-term timeframe would be SMALL.

17 E.2.2.5 Summary

18 Table E-3 summarizes the NRC impact determinations for the resource areas discussed in 

19 Sections E.2.2.1 through E.2.2.4.

20 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

21 E.3 Historical Data on Spent Fuel Pool Leakage

22 Although the evaluation of spent fuel pool leaks in Section E.2 focuses on the potential impacts 

23 of leaks during short-term storage timeframe, it is helpful to review the historical occurrences of 

24 spent fuel pool leaks. A review of past spent fuel pool leakage events helps to establish a 

25 baseline for the analysis of future impacts and provide context to those impacts. Available data 

26 and information indicate that spent fuel pool leakage has occurred at the 13 sites listed in 

27 Table E-4 (NRC 2006b, 2010c; NRC 2010d; Copinger et al. 2012). Spent fuel pool leakage at 

28 boiling water reactor plants has been identified primarily through leak-detection systems. Spent 

29 fuel pool leakage at pressurized water reactor plants has been detected in the leak-chase 

30 system (channels installed behind spent fuel pool liner welds); as seepage associated with 

31 concrete cracks; by the presence of white deposits on structures (boric acid precipitate); by the 
Appendix E

Draft NUREG‒2157 E-20 September 2013

1 presence of moisture in the seismic gap between the fuel-handling building and auxiliary 

2 building; by the presence of abnormally high levels of tritium in groundwater (i.e., above normal 

3 background levels of approximately 200 pCi/L and by contamination of protective clothing)

4 (Copinger et al. 2012).

5 Table E-4. Occurrence of Spent Fuel Pool Leakage at U.S. Nuclear Power Plants

Site

Date(s) of Leak 

Discovery

Radioactive 

Liquid Released 

to Environment? Radionuclides Detected

Hatch December 1986 Yes Tritium

Indian Point (Units 1 

and 2)

August 2005;

Unit 1 leakage predates

August 2005

Yes Tritium, nickel-63, cesium137, strontium-90, and 

cobalt-60

Palo Verde (Unit 1) July 2005 Yes Tritium, cobalt-60, antimony125, and cesium-137

Salem (Units 1 and 2) September 2002 (Unit 1)

2010 (Unit 2)

Yes Tritium

San Onofre (Unit 1) 1986 Yes(a) Tritium, cesium-137

Seabrook June 1999 Yes Tritium

Watts Bar (Unit 1) August 2002 Yes Tritium and mixed fission 

products

Crystal River (Unit 3) 2009 No(b) —

Davis-Besse (Unit 1) 2000 No(b) —

Diablo Canyon (Units 

1 and 2)

2010 No(b) —

Duane Arnold 1994 No(b) —

Hope Creek 2009 No(b) —

Kewaunee 2007 No(c) —

Sources: NRC 2006b; NRC 2010c; NRC 2010d; Copinger et al. 2012

(a) 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 2010d). 

Environmental monitoring performed by the licensee subsequent to the leak did not identify radionuclides in the 

environment attributable to San Onofre (SCE 1995).

(b) Leaked spent fuel pool water was contained within spent fuel pool leakage-collection system.

(c) White boric acid deposits, possibly boric acid, observed on the wall and ceiling of the waste drumming room 

adjacent to the spent fuel pool.

6 At several of the sites listed in Table E-4, namely Indian Point (Units 1 and 2), Palo Verde 

7 (Unit 1), Salem (Units 1 and 2), Seabrook, and Watts Bar, spent fuel pool leakage has resulted 

8 in inadvertent liquid radioactive releases to the environment. Releases that were known to have 

9 occurred to the environment from spent fuel pool leakage prior to 2006 were examined by the 

10 NRC Liquid Radioactive Release Lessons Learned Task Force as part of its review of historical 

11 information on abnormal, unplanned, unmonitored releases of radioactive liquids into the 
Appendix E

September 2013 E-21 Draft NUREG‒2157

1 environment from nuclear power plants (NRC 2006b). The NRC Groundwater Task Force 

2 (NRC 2010c) reviewed data on releases to groundwater that occurred subsequent to the 

3 publication of the Lessons Learned Task Force report. A more recent study identified other 

4 nuclear power facilities that have experienced spent fuel pool leakage, including Crystal River 

5 Unit 3, Davis-Besse Unit 1, Diablo Canyon Units 1 and 2, Duane Arnold, Hope Creek, and 

6 Kewaunee (Copinger et al. 2012). For those facilities, with the exception of Kewaunee, the 

7 leakage was contained within the spent fuel pool leakage-collection system.

8 Table E-5 lists the maximum tritium contamination detected onsite and at offsite locations from 

9 the spent fuel pool leakage events. None of the spent fuel pool leakage events listed in 

10 Table E-5 are known to have resulted in contamination of drinking water.

11 Table E-5. Dose from Inadvertent Releases of Radioactive Liquids from Nuclear Power Plant 

12 Spent Fuel Pools

Site

Maximum Tritium

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(b)

200,000 for tritium

(100 for nickel-63

50 for strontium-90)

Approximation made in 

dose calculations

MEI(c) 0.0021(d)

Salem 15,000,000(e) None detected NA NA

Seabrook 750,000 Groundwater plume has 

not migrated offsite

NA NA

Watts Bar 30,000 Groundwater plume has 

not migrated offsite

NA NA

Source: NRC 2013

(a) Approximately 124,000 gallons of liquid containing 0.2 Ci of tritium and 0.373 Ci of mixed fission products were 

released to a swamp which is located in the owner-controlled area. No public dose is calculated for releases to 

owner-controlled area.

(b) Source: Entergy 2006 

(c) 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.

(d) 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. 

(e) Maximum tritium level in sample of groundwater near the seismic gap; extensive groundwater remediation

program in place.

NA = Not applicable because water contamination was not detected at offsite locations.
Appendix E

Draft NUREG‒2157 E-22 September 2013

1 NRC Groundwater Task Forces

2 In 2006, the NRC chartered an in-house Lessons Learned Task Force to conduct a systematic 

3 lessons-learned review of unplanned, unmonitored releases of radioactive liquids into the 

4 environment from nuclear plants, which included inadvertent releases from spent fuel pools as 

5 well as other plant systems. The Lessons Learned Task Force reviewed industry experience, 

6 associated public health impacts (if any) of the radioactive liquid releases into the environment, 

7 the NRC regulatory framework, related NRC inspection and enforcement programs, industry 

8 reporting requirements, past industry actions following significant inadvertent releases, 

9 international perspectives (principally from the Canadian experiences with tritium releases), and 

10 NRC communications with members of the public. In its final report (NRC 2006b), the Lessons 

11 Learned Task Force made 26 recommendations that generally addressed enhanced regulations 

12 or regulatory guidance for unplanned, unmonitored releases; additional reviews in the areas of 

13 decommissioning funding and license renewal; and enhanced public communications.

14 The most significant conclusion of the Lessons Learned Task Force was with respect to public 

15 health impacts. Although a number of industry events have caused radioactive liquid releases 

16 to the environment in an unplanned and unmonitored manner, based on the available data, the 

17 task force did not find any instance where the radioactive liquid releases affected the health of 

18 the public (NRC 2006b).

19 In 2010, following further inadvertent, abnormal releases of radionuclides to the environment 

20 from nuclear power plant operations, the NRC established a second task force, referred to as 

21 the NRC Groundwater Task Force. The job of the Groundwater Task Force was to reevaluate 

22 the recommendations in the Lessons Learned Task Force final report; review NRC staff actions 

23 to address the issue of leaks from buried piping at nuclear power plants; and review the actions 

24 taken in response to more recent releases of tritium from systems other than those associated 

25 with spent fuel pools into groundwater at nuclear facilities. The scope of the Groundwater Task 

26 Force work included industry experience; health impacts; the regulatory framework; NRC 

27 inspections and analyses; enforcement and reporting aspects; industry actions; international 

28 perspectives; and communications with external stakeholders. After completing its review, the 

29 Groundwater Task Force determined that the NRC is accomplishing its stated mission of 

30 protecting public health, safety, and the environment through its response to groundwater leaks 

31 and spills. The Groundwater Task Force concluded that within the current regulatory structure, 

32 NRC is correctly applying requirements and properly characterizing the relevant issues (NRC 

33 2010c).

34 E.4 References

35 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

36 Protection Against Radiation.” Washington, D.C.
Appendix E

September 2013 E-23 Draft NUREG‒2157

1 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

2 Production and Utilization Facilities.” Washington, D.C.

3 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor Site 

4 Criteria.” Washington, D.C.

5 76 FR 35512. June 17, 2011. “Decommissioning Planning,” Federal Register, U.S. Nuclear 

6 Regulatory Commission, Washington, D.C.

7 ANSI/ANS (American National Standards Institute/American Nuclear Society). 2010. Draft 

8 Evaluation of Subsurface Radionuclide Transport at Commercial Nuclear Power Plants. 

9 ANSI/ANS–2.17–2010, La Grange Park, Illinois. Accession No. ML101310455.

10 Copinger, D.A., C.B. Oland, and D.J. Naus. 2012. Summary of Aging Effects and Their 

11 Management in Reactor Spent Fuel Pools, Refueling Cavities, Tori, and Safety-Related 

12 Concrete Structures. NUREG/CR–7111, Oak Ridge National Laboratory, Oak Ridge, 

13 Tennessee. Accession No. ML12047A184.

14 DOE (U.S. Department of Energy). 2003. National Report Joint Convention on the Safety of 

15 Spent Fuel Management and on the Safety of Radioactive Waste Management. 

16 DOE/EM–0654, Washington, D.C. Available at 

17 http://energy.gov/sites/prod/files/1st%20US%20JC%20report.pdf. 

18 Entergy Nuclear Operations, Inc. (Entergy). 2006. 2005 Annual Radioactive Effluent Release 

19 Report. Buchanan, NY. Accession No. ML061240373.

20 Entergy Nuclear Operations, Inc. (Entergy). 2012. Joint Motion for Approval of Settlement 

21 Agreement and Dismissal of Consolidated Contention Riverkeeper EC-3 and Clearwater EC-1 

22 (Spent Fuel Pool Leaks). Washington, D.C. Accession No. ML12286A178.

23 EPA (U.S. Environmental Protection Agency). 1991. Final Guidance on Emergency Authority 

24 Under Section 1431 of the Safe Drinking Water Act. WSG 68, Washington, D.C. Available at 

25 http://www.epa.gov/safewater/wsg/wsg_68.pdf.

26 EPRI (Electric Power Research Institute). 2008. Groundwater Protection Guidelines for 

27 Nuclear Power Plants. 1016099, Palo Alto, California. Accession No. ML091170595.

28 EPRI (Electric Power Research Institute). 2011. Groundwater and Soil Remediation Guidelines 

29 for Nuclear Power Plants. 1023464, Palo Alto, California. 

30 Ferry, L., R. Ferry, W. Isherwood, R. Woodward, T. Carlsen, Z. Demir, R. Qadir, and M. Dresen. 

31 1999. Final Site-Wide Feasibility Study for Lawrence Livermore National Laboratory Site 300. 

32 UCRL–AR–132609, Lawrence Livermore National Laboratory, Livermore, California. 
Appendix E

Draft NUREG‒2157 E-24 September 2013

1 GE (General Electric Company). 2004. Morris Operation Consolidated Safety Analysis Report. 

2 NEDO–21326D11, Morris, Illinois. Accession No. ML080220416.

3 Geniesse, D.J. and G.E. Stegen. 2009. 2009 Evaluation of Tritium Removal and Mitigation

4 Technologies for Wastewater Treatment. DOE/RL–2009–18, Richland, Washington.

5 IAEA (International Atomic Energy Agency). 1999. Technical Options for the Remediation of 

6 Contaminated Groundwater. IAEA–TECDOC–1088, Vienna, Austria. 

7 Johnson, A., Jr. 1977. Behavior of Spent Nuclear Fuel in Water Pool Storage. BNWL–2256, 

8 Battelle–Pacific Northwest Laboratories, Richland, Washington.

9 NEI (Nuclear Energy Institute). 2007. Industry Ground Water Protection Initiative—Final 

10 Guidance Document. NEI 07–07, Washington, D.C. Accession No. ML072600295.

11 NRC (U.S. Nuclear Regulatory Commission). 1991a. Offsite Dose Calculation Manual 

12 Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors. Generic 

13 Letter 89–01, Supplement No. 1, NUREG–1301, Washington, D.C. Accession No. 

14 ML091050061.

15 NRC (U.S. Nuclear Regulatory Commission). 1991b. Offsite Dose Calculation Manual 

16 Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors. Generic 

17 Letter 89–01, Supplement No. 1, NUREG–1302, Washington, D.C. Accession 

18 No. ML031290469.

19 NRC (U.S. Nuclear Regulatory Commission). 1997a. Operating Experience Feedback Report: 

20 Assessment of Spent Fuel Cooling. NUREG–1275, Volume 12, Washington, D.C. Accession 

21 No. ML010670175.

22 NRC (U.S. Nuclear Regulatory Commission). 1997b. Generic Environmental Impact Statement 

23 in Support of Rulemaking on Radiological Criteria for License Termination of NRC-Licensed 

24 Nuclear Facilities. NUREG–1496, Washington, D.C. Accession Nos. ML042310492, 

25 ML042320379, and ML042330385.

26 NRC (U.S. Nuclear Regulatory Commission). 2002. Generic Environmental Impact Statement 

27 on Decommissioning of Nuclear Facilities. NUREG–0586, Supplement 1, Nuclear Regulatory 

28 Commission, Washington, D.C. Accession Nos. ML023500395, ML023500310, and 

29 ML023500322.

30 NRC (U.S. Nuclear Regulatory Commission). 2004. Spent Fuel Pool Leakage to Onsite 

31 Groundwater. Information Notice 2004–05. Washington, D.C. Accession No. ML040580454. 
Appendix E

September 2013 E-25 Draft NUREG‒2157

1 NRC (U.S. Nuclear Regulatory Commission). 2006a. Indian Point Nuclear Generating Unit 2 - 

2 NRC Special Inspection Report No. 05000247/2005011. Washington D.C. Accession 

3 No. ML060750842.

4 NRC (U.S. Nuclear Regulatory Commission). 2006b. Liquid Radioactive Release Lessons 

5 Learned Task Force Final Report. Washington, D.C. Accession No. ML062650312.

6 NRC (U.S. Nuclear Regulatory Commission). 2008. Minimization of Contamination and 

7 Radioactive Waste Generation: Life-Cycle Planning. Regulatory Guide 4.21, Washington, D.C. 

8 Accession No. ML080500187.

9 NRC (U.S. Nuclear Regulatory Commission). 2009. Measuring, Evaluating, and Reporting 

10 Radioactive Material in Liquid and Gaseous Effluents and Solid Waste. Regulatory Guide 1.21, 

11 Revision 2, Washington, D.C. Accession No. ML091170109.

12 NRC (U.S. Nuclear Regulatory Commission). 2010a. Generic Aging Lessons Learned (GALL) 

13 Report. NUREG–1801, Revision 2, Washington, D.C. Accession No. ML103490041.

14 NRC (U.S. Nuclear Regulatory Commission). 2010b. Radioactive Effluents from Nuclear 

15 Power Plants, Annual Report 2008. Washington, D.C. Accession No. ML103620452.

16 NRC (U.S. Nuclear Regulatory Commission). 2010c. Groundwater Task Force Final Report. 

17 Washington, D.C. Accession No. ML101740509.

18 NRC (U.S. Nuclear Regulatory Commission). 2010d. Response to Questions Concerning 

19 Spent Fuel Pool Leakage at the San Onofre Nuclear Generating Station, Unit 1. Arlington, 

20 Texas. Accession No. ML101400386.

21 NRC (U.S. Nuclear Regulatory Commission). 2011a. Memorandum from R.L. Conaster to 

22 U.S. Shoop dated April 1, 2011, regarding “Summary of Results from Completion of NRC’s

23 Temporary Instruction on Groundwater Protection, TI–2515/173, “Industry Groundwater 

24 Protection Initiative.” Washington, D.C. Accession No. ML11088A047. 

25 NRC (U.S. Nuclear Regulatory Commission). 2011b. Senior Management Review of Overall 

26 Regulatory Approach to Groundwater Protection. Washington, D.C. SECY–11–0019, 

27 Washington, D.C. Accession No. ML12338A692.

28 NRC (U.S. Nuclear Regulatory Commission), 2012a. “Map of Power Reactors Sites.” 

29 Washington, D.C. Available at http://www.nrc.gov/reactors/operating/map-power-reactors.html.

30 NRC (U.S. Nuclear Regulatory Commission). 2012b. Decommissioning Planning During 

31 Operations. Regulatory Guide 4.22, Washington, D.C. Accession No. ML12158A361. 
Appendix E

Draft NUREG‒2157 E-26 September 2013

1 NRC (U.S. Nuclear Regulatory Commission). 2013. Generic Environmental Impact Statement 

2 for License Renewal of Nuclear Plants. NUREG–1437, Volume 1, Revision 1, 

3 Washington, D.C. Accession No. ML13107A023. 

4 SCE (Southern California Edison Company). 1995. SONGS Unit 1 Spent Fuel Pool Liner Plate 

5 Evaluation. San Clemente, California. Accession No. 9503200118.
Appendix F

–

Spent Fuel Pool Fires

September 2013 F-1 Draft NUREG‒2157

Appendix F

Spent Fuel Pool Fires

1 This appendix examines the environmental impacts of a spent fuel pool fire during the shortterm storage timeframe.1 2 The environmental impacts of spent fuel pool fires described in this 

3 appendix support the U.S. Nuclear Regulatory Commission’s (NRC’s) generic determination of 

4 the environmental impacts of spent fuel pool fires and their risk, as described in Section 4.18.2.1 

of this draft Waste Confidence Generic Environmental Impact Statement (draft GEIS).2 5 The 

6 NRC has conducted extensive evaluations of the risk and impacts of spent fuel pool fires. While 

7 initial studies were concerned with spent fuel pool fire risk during the operating life of a reactor, 

8 a risk study completed in 2001 examined the risk of a spent fuel pool fire during the reactor 

9 decommissioning period (NRC 2001). The analysis in this appendix shows that the probability10 weighted impacts, or risk, from a spent fuel pool fire for the short-term storage timeframe are 

11 SMALL because, while the consequences from a spent fuel pool fire could be significant and 

12 destabilizing, the probability of such an event is extremely remote. The NRC’s probability13 weighted impact analysis is presented in the following sections.

14 F.1 Introduction 

15 The probability of spent fuel pool accidents is the sum of initiating event frequencies that can 

16 lead to a spent fuel pool fire, and represents the NRC’s best forward-looking judgment 

17 concerning spent fuel pool fire risk during the short-term storage timeframe. The potential 

18 consequences are considered in light of these probabilities and expressed in several different 

19 measures of impacts (e.g., collective radioactive dose to the public and economic 

20 consequences).

21 As detailed in the following sections, the impacts from a spent fuel pool fire are expressed in 

22 terms of both the consequence that would occur if the accident occurred and as a probability23 weighted consequence. The probability-weighted consequence, also known as risk, is a 

 

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.

2 Historically, the NRC has devoted considerable attention to the topic of this appendix, reflected in the 

detailed analyses and studies discussed in the appendix. In light of the historic interest of the public in 

this issue, as evidenced by comments in NRC’s Waste Confidence rulemaking, as well as related 

litigation, this appendix provides a more detailed discussion of referenced materials and studies that 

underlie the analyses of spent fuel pool fires in the body of this draft GEIS.
Appendix F

Draft NUREG‒2157 F-2 September 2013

1 quantitative measure of the severity of the accident that accounts for the likelihood of its 

2 occurrence. The probability-weighted consequence is computed by multiplying a consequence, 

3 such as cumulative dose, cost to the local economy, or area of land contamination, by the 

4 probability of the accident’s occurrence. In the following analyses, the NRC first provides a

5 discussion of the consequences of a spent fuel pool fire. The NRC then determines the risk of a 

6 spent fuel pool fire by looking at the probability of this type of event during the short-term 

7 storage timeframe and multiplying the probability by the consequences. The probability8 weighted consequences provide the expected environmental impacts of the continued storage 

9 of spent fuel during the short-term storage timeframe.

10 A significant portion of the NRC’s analysis for spent fuel pool fires during the short-term storage 

11 timeframe is derived from NUREG–1738, “Technical Study of Spent Nuclear Fuel Pool Accident

12 Risk at Decommissioning Nuclear Power Plants” (NRC 2001). This study represents the NRC’s 

13 current judgment as to the expected impacts from a spent fuel pool fire during the short-term 

14 storage timeframe.

15 F.2 Environmental Impacts of Spent Fuel Pool Fires

16 In the event of an accident that leads to a loss of water in a spent fuel pool (via rapid drainage 

17 or extended boiling), without successful efforts to replenish the lost water, spent fuel 

18 temperatures could increase significantly. If cooling of the spent fuel were not reestablished, 

19 the fuel could heat up to temperatures on the order of 1,000°C (1,832°F). At this temperature, 

20 the spent fuel’s zirconium cladding would begin to react with steam or air in a highly exothermic 

21 chemical reaction called a runaway zirconium oxidation reaction or autocatalytic ignition. This 

22 accident scenario is often referred to as a “spent fuel pool zirconium fire.” Radioactive aerosols 

23 and vapors released from the damaged spent fuel could be carried throughout the spent fuel 

24 pool building and into the surrounding environment. This release could lead to exposures of the 

25 surrounding population and contamination of property (e.g., land or structures) in the vicinity of 

26 the site.

27 Under certain conditions, the high temperature runaway zirconium oxidation reaction occurring 

28 in one part of the pool could also spread to other spent fuel in the pool. The proximity of fuel 

29 assemblies to one another, combined with the effects of radioactive heat transfer when these 

30 assemblies are at very high temperatures, could allow the runaway oxidation reaction to spread 

31 from spent fuel with high decay heat to spent fuel with lower decay heat that would otherwise 

32 not have begun burning.

33 A spent fuel pool accident could develop into a spent fuel pool fire in a number of ways. As the 

34 NRC first determined in 1975, spent fuel pool accidents can arise from either the loss of spent 

35 fuel pool cooling, drainage of the spent fuel pool, or the dropping of heavy items into the spent 

36 fuel pool (NRC 1975). Since that time, the NRC has refined its analysis and has looked at 

37 various ways that these events could occur. For example, in 1989 the NRC conducted a study 
Appendix F

September 2013 F-3 Draft NUREG‒2157

1 that assessed various accident sequences including spent fuel pool failure due to wind-driven 

2 missiles, aircraft crashes, heavy-load drop, seal failure, inadvertent draining, loss-of-cooling, 

3 and seismic events (NRC 1989).

4 The NRC has also assessed the probability that these various events could occur. For 

5 example, in its earliest study, the NRC determined that the probability of the drainage of the 

6 spent fuel pool was much less than a loss-of-cooling event for the reactor because accidental 

7 drainage of the spent fuel pool requires multiple simultaneous failures (NRC 1975). Further, in 

8 1989 the NRC quantified the probabilities of various accident initiating events and assessed the 

9 health and economic consequences of a spent fuel pool accident (NRC 1989).

10 Finally, as discussed in more detail below, the NRC confirmed that the overall risks associated 

11 with these types of accidents remain low because the spent fuel pool loss-of-cooling event 

12 probability is low (NRC 2001). As discussed in more detail below, since the NRC completed 

13 this study in 2001, the NRC has continued to implement regulations and orders that further 

14 reduce the likelihood of a spent fuel pool fire. These additional reductions in the likelihood of a 

15 spent fuel pool fire mean that the risks are lower now than those NRC reported in its 2001 

16 study. Further, no new information has emerged that would cause the NRC to question the 

17 results of this study.

18 F.2.1 Consequences of a Spent Fuel Pool Fire

19 The release of radionuclides into the environment resulting from a spent fuel pool fire can lead 

20 to severe consequences, both in terms of direct human health impacts (e.g., early fatalities or 

21 latent cancer fatalities) and economic damages arising from the actions taken to avoid human 

22 exposures (e.g., evacuation and relocation costs, costs for cleanup of contaminated land, and 

23 the loss of economic value associated with land that cannot be used following a severe 

24 accident). These consequences do not consider the probability that an accident will occur. 

25 Possible initiating events and the probability that these events could occur are discussed in 

26 Section F.2.2. The following discussion and Table F-1 examine the consequences of a spent 

27 fuel pool fire.

28 In NUREG–1738 and Table F-1, source terms for high ruthenium (Ru) and low Ru are 

29 expressed as ranges. For example, the total collective dose for the high Ru source term ranges 

from 1.34 × 105 to 2.37 × 105 person-Sv.3 30 The ranges in Table F-1 are mean values of 

31 consequences of a spent fuel pool fire in which the NRC assumed a late evacuation of 

32

 

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

Draft NUREG‒2157 F-4 September 2013

1 95 percent of the population inside the 16-km (10-mi) emergency planning zone around Surry 

2 Power Station (Surry). The late evacuation assumption means that evacuation is started, but 

3 not completed before the release begins. The low value corresponds to a fire that occurs 

4 10 years after shutdown, at which time radioactive decay has reduced the amount of radioactive 

5 material that could be released. The high value corresponds to a fire that occurs within 30 days 

6 after shutdown.

Table F-1. Spent Fuel Pool Accident Probability and Consequences(a) 7

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–1738 

(high Ru)

5.8 × 10−7(e) to 

2.4 × 10−6(f)

4.68 × 10−3 to 

4.43 × 10−2

6.39 × 10−2 to 

8.49 × 10−2

1.34 × 105 to 

2.37 × 105

(50 mi)(c)

<1 (0.360) to 

191

- -

NUREG–1738 

(low Ru)

5.8 × 10−7(e) to 

2.4 × 10−6(f)

1.63 × 10−3 to 

1.27 × 10−2

1.29 × 10−2 to 

1.88 × 10−2

4.72 × 104 to 

5.58 × 104

(50 mi)(c)

<1 to 2 20,000–

27,000

-

NUREG–1353 2.0 × 10−6 - - 2.6 × 105

(50 mi)(g)

- 55,700(h,i)

NUREG/

BR–0184

- - - 2.6 × 105

(50 mi)(j)

- 57,800(h,k)

(a) All values are approximate.

(b) A value of 5.8 x 10-7 is scientific notation for a value that can also be expressed as 0.00000058. This value means that the 

probability of the accident occurring in any year is one chance in 1,700,000 (or one chance in 1/0.00000058).

(c) Consequence values were obtained from NUREG–1738 (NRC 2001, Tables 2 and 3 of Appendix 4B). [Note: Similar 

values appear in NUREG–1738 (NRC 2001, Tables 3.7-1 and 3.7-2), but were incorrectly reporting values from 

Appendix 4B.]

(d) Consequence values were obtained from NUREG–1738 (NRC 2001, Appendix 4) and reflect a range of results from the 

seven cases evaluated.

(e) Electric Power Research Institute data from NUREG–1738 (NRC 2001).

(f) Lawrence Livermore National Laboratory data in NUREG–1738 (NRC 2001).

(g) Case 2 values were obtained from NUREG–1353 (NRC 1989, Table 4.8.3). Case 2 assumed the entire spent fuel pool 

inventory was released.

(h) Values adjusted to 2010 dollars using the Consumer Price Index Inflation Calculator.

(i) Values were obtained from NUREG–1353 (30,200 Million $ in 1988 dollars; excludes replacement power costs) 

(NRC 1989, Tables 5.1.1 and 5.1.2).

(j) Values were obtained from NUREG/BR–0184 (NRC 1997, Table C.101).

(k) Values were obtained from NUREG/BR–0184 (26,400 Million $ in 1983 dollars; excludes replacement power costs) 

(NRC 1997, Table C.95 and C.101).

8 As discussed below, the assumptions described above are conservative assumptions of the 

9 consequences of the spent fuel pool fire. These conservative assumptions further reduce the 

10 likelihood that the actual consequences would be as high as indicated in Table F-1. For

11 example, the low Ru results from the 2001 study more realistically represent the anticipated 

12 consequences of even a high-volatility Ru spent fuel pool fire sequence. The 95 percent 
Appendix F

September 2013 F-5 Draft NUREG‒2157

1 evacuation estimate is less than the NRC’s best estimate of actual evacuation of 99.5 percent, 

2 of the populace from the 16-km (10-mi) emergency planning zone, which was used by the NRC 

3 in its “2012 NRC State-of-the-Art Reactor Consequence Analyses Report for Surry” (NRC 1990, 

4 2012). However, in 

5 NUREG–1738 the NRC used a value of 95 percent in sensitivity studies to address concerns 

6 that the fraction of the public that does not evacuate could be higher. “Late evacuation” is a 

7 reasonable assumption for decay times of less than about 2 years, for which the time-to-release 

8 could be less than 10 hours. However, the time-to-release (following the initiating event) will be 

9 longer than 10 hours after the spent fuel has cooled at least 2 years, and early evacuation, in 

10 which evacuation is completed before the release begins, would be increasingly more likely as 

11 the decay time increases. Early evacuation results in lower public doses because more people 

12 will evacuate before release occurs. Finally, the main contributors to the likelihood of 

13 uncovering the spent fuel are seismic events and cask drop. These events are no more or less 

14 likely to occur in any particular time interval during continued storage. Therefore, the probability 

15 of these initiating events occurring within the first 30 days after shutdown, is an order of 

16 magnitude less, as compared to the per year probability during the 60-year short-term storage 

17 timeframe.

18 The low Ru and high Ru values shown in Table F-1 refer to two different source terms used in 

19 NUREG–1738. The low Ru source term is based on release fractions for chemical element 

20 groups that are discussed in NUREG–1465, “Accident Source Terms for Light-Water Nuclear 

21 Power Plants” (NRC 1995). In NUREG–1738, NRC considered whether the Ru group and fuel 

22 fines component of the NUREG–1465 release fractions were too low. The fuel fines component 

23 of the source term, comprised of small particles of spent fuel, is represented by the element 

24 groups for cerium and lanthanum. In NUREG–1738, the NRC also analyzed a high Ru source 

25 term. The high Ru source term uses the same NUREG–1465 release fractions for all chemical 

26 element groups except those for Ru, lanthanum, and cerium. The higher release fraction for Ru 

27 in the high Ru source term is the same fraction as those used for volatile fission products like 

28 isotopes of iodine and cesium. As stated in NUREG–1738, the higher release fractions for 

29 lanthanum and cerium in the high Ru source term are based on a 1995 study of the Chernobyl 

30 accident.

31 As described in NUREG–1738, Ru in a steam environment has a very low vapor pressure that 

32 tends to limit its release (NRC 2001). For spent fuel pool accidents involving rapid drain-down 

33 of the pool, and thus primarily an air environment during fuel heat up, the volatility of Ru might 

34 be much higher. Recent modeling suggests that Ru release in an air environment would in fact 

35 be much higher than in a steam environment, but still several orders of magnitude below the 

36 release fractions used for the high Ru release in the 2001 study (Gauntt 2010). For this reason, 

37 the low Ru results from the 2001 study are more representative of the anticipated 

38 consequences of even a high-volatility Ru spent fuel pool fire sequence.
Appendix F

Draft NUREG‒2157 F-6 September 2013

1 The NRC assesses the consequences of a spent fuel pool fire and other severe accidents in 

2 terms of health impacts and economic damages. The health impacts from spent fuel pool fires 

3 are measured through both individual impacts at select locations, and overall population

4 consequences. Health impacts include the early fatality risk to an individual within 1.6 km (1 mi) 

5 of the plant and the latent fatality risk to an individual within 16 km (10 mi) of the plant. These 

6 health impacts represent possible exposures and consequences to the population near a 

7 nuclear facility. Early fatalities are the number of fatalities expected to occur within a few weeks 

8 or months of the accident for the individuals exposed to large doses of radiation. Latent 

fatalities are the number of fatalities that occur over the lifetime of the exposed individuals.4 9 

10 Other health impacts that the NRC considers include collective dose to the public within 80 km 

11 (50 mi) of the plant, and the collective latent fatalities within 800 km (500 mi) of the plant (NRC 

12 2001). The collective dose is the dose received by the total population living within a specific 

13 distance from the facility, including return dose and the dose to workers during decontamination 

14 of contaminated land; this value depends upon the site-specific population within a specific 

15 distance of the plant. In Table F-1, health effects taken from NUREG–1738 are based on a 

16 postulated spent fuel pool fire at Surry. A similar case reported in NUREG–1353 and 

17 NUREG/BR–0184 involved 3.5 cores of spent fuel from the R.E. Ginna nuclear power plant and 

a 80-km (50-mi) average population density of 330 people/km2 (860 people/mi2 18 ), (based on the 

19 population around the Zion nuclear power plant in Illinois) (NRC 1989, 1997). In general, health 

20 impacts could be higher than the values reported in these studies if the amount of spent fuel 

21 involved in a fire (and, thus, the amount of radioactive material that could be released) was 

22 higher than assumed in these studies or the total population and population density were higher. 

23 Health impacts can also be affected by protective action guidelines, or the radiation dose levels 

24 above which emergency response officials will recommend protective actions like evacuation or 

25 sheltering. Higher protective action guidelines could increase public doses by allowing people 

26 to remain in affected locations longer. Different types of radioactive material can also change 

27 health impacts. For example, early fatalities would likely be caused by short-lived radioactive 

28 material that is present in operating reactors. Once spent fuel has been removed from a reactor 

29 and stored in the spent fuel pool, short-lived radioactive material will decay to such low levels 

30 that accidents would result in fewer early fatalities in the surrounding population.

31 The NRC also analyzes consequences in terms of the economic consequences arising from the 

32 actions taken to avoid human exposure. The economic consequences identified in Table F-1

33 take into account various costs, including offsite and onsite property damage resulting from the 

34 release of radioactive material and the resulting land contamination. Offsite property damage 

 

4 As discussed in the NUREG–1738, 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–1738 

for comparisons to the Commission’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 be relatively insensitive to the site-specific 

population around a plant (NRC 2001).
Appendix F

September 2013 F-7 Draft NUREG‒2157

1 includes evacuation costs, relocation costs for displaced persons, property decontamination 

2 costs, loss of use of contaminated property through interdiction, crop, and milk losses. The 

3 onsite property damage costs include onsite cleanup and decontamination, repair of the spent 

4 fuel pool, and removal of fuel. The total onsite and offsite economic damage values were 

5 estimated to be between 55.7 and 57.8 billion dollars per event (NRC 1989, 1997), when 

6 adjusted to 2010 dollars. As with health impacts, the economic impacts would vary for different 

7 facilities. For example, higher total population or population density could result in higher 

8 relocation costs, and land use (e.g., whether land is used as farmland or not) could also 

9 impact decontamination and condemnation costs.

10 Although discussed in more detail in the next section, Table F-1 also includes probability and 

11 consequence values for a spent fuel pool fire (NRC 1989, 1997, 2001). As shown in Table F-1, 

12 the zirconium cladding fire probability in the 1989 regulatory analysis was calculated as 

2 × 10−6/yr, which is almost identical to the 2.4 × 10−6 13 /yr probability from the 2001 study (NRC 

14 2001) that the NRC is using for this appendix.

15 F.2.2 Probability-Weighted Consequences of a Spent Fuel Pool Fire

16 As discussed in Section 4.18.2.1, with respect to severe (or, beyond-design-basis) accidents, 

17 the consequences of a severe accident, should one occur, would be significant and 

18 destabilizing. The impact determinations for these accidents, however, are made with 

19 consideration of the low probability of these events. The environmental impact determination 

20 with respect to severe accidents, therefore, is based on the risk, which the NRC defines as the 

21 product of the probability and the consequences of an accident. This means that a high22 consequence, low-probability event, like a severe accident, could still result in a small impact 

23 determination, if the risk is sufficiently low.

24 The NRC has considered a number of initiating events that could lead to a spent fuel pool fire. 

25 These events include loss of offsite power, internal fires, loss of pool cooling, loss-of-coolant 

26 inventory, seismic event, cask drop, aircraft crash, and a tornado missile (NRC 2001). These 

27 initiating events are discussed in more detail below and, as supplemented by the overall 

28 discussion of accidents in Section 4.18 of this draft GEIS, provide the range of credible initiating 

29 events for spent fuel pool fires.

30 The main contributors to the frequency of loss-of-coolant in the pool and exposure of the spent 

31 fuel to air are seismic events and cask drop (NRC 2001). As shown in Table F-1, for the 

32 credible initiating events considered, the NRC has determined that the frequency of fuel being 

uncovered could be between 5.8 ×10−7 and 2.4 × 10−6 33 per year depending upon the seismic

34 hazard assessment (NRC 2001). Seismic risk, in general, is discussed in more detail in 

35 Section 4.18.
Appendix F

Draft NUREG‒2157 F-8 September 2013

1 The source term used in this draft GEIS is derived from the source term used in NUREG–1738. 

2 It includes both the final core off-load and the previous 10 refueling outage off-loads (NRC 

3 2001). The NRC estimated this to be roughly 3.5 core loads in the spent fuel pool, based on an 

4 adjusted inventory for the Millstone 1 nuclear power plant that accounted for larger reactors and 

5 the fact that NUREG–1738 was limited to spent fuel pool accidents during decommissioning

6 (NRC 2001). In addition, the NRC considered a range of times in which the event could occur 

7 after shutdown, including 30 days, 90 days, 2 years, 5 years, and 10 years after final shutdown 

8 (NRC 2001).

9 As shown in Table F-1, the most severe spent fuel pool fire consequences would occur within 

10 30 days after a final reactor shutdown in conjunction with a late or delayed evacuation of the 

11 affected area. The late evacuation impacts results in more severe consequences than those for 

12 an early evacuation because a late evacuation means that even fewer people will have 

13 evacuated when the release of radioactive material begins. Further, the values shown in 

14 Table F-1 are conditional consequences, based on an assumption that a severe accident occurs 

15 without consideration of the remote probability of an accident. Probability-weighted 

16 consequences are shown in Table F-2 and discussed in Section F.2.2.

17 Table F-2. Comparison of Frequency-Weighted Consequences from Reactor Accidents and 

18 Spent Fuel Pool Fires

Accident 

Type

Individual Risk Population Risk

Early 

Fatalities

(within 1 mi)

(Ryr−1)

Latent 

Fatalities

(within 10 mi)

(Ryr−1)

Collective 

Dose 

(person-Sv 

Ryr−1)

Early 

Fatalities 

(Ryr−1)

Latent 

Fatalities 

(Ryr−1)

Economic 

Damage

($ Ryr−1)

(a)

Severe 

Reactor 

Accident(b)

1.5 × 10−8 1.5 × 10−9 0.06 2.0 × 10−6 5.2 × 10−3 1.1 × 105(c)

Spent Fuel 

Pool Fire(d)

3.3 × 10−9 to 

2.5 × 10−8

2.6 × 10−8 to 

3.8 × 10−8

0.09 to 0.11 1.6 × 10−7 to 

4.4 × 10−6

4.4 × 10−3 to 

4.9 × 10−3(e)

1.0 × 105(f) to 

1.1 × 105(g)

(a) Values adjusted to 2010 dollars using the Consumer Price Index Inflation Calculator.

(b) From NUREG–1150 for Surry Power Station (NRC 1990), except for economic damage (see Note (c)).

(c) From NUREG–1437, Supplement 6, Surry Power Station Units 1 and 2 (NRC 2002), without public exposure 

costs. 

(d) From NUREG–1738 (NRC 2001, Figures 3.7-3, 3.7-4, 3.7-7, and 3.7-8), except population latent fatality and 

economic damage risks. 

(e) From NUREG–1738, (NRC 2001, Tables A4-7 through A4-9), which reflect a range of the 3 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 × 10−6 Ryr−1 (NRC 2001).

(f) NUREG/BR–0184 (NRC 1997, Tables C.95 and C.101), without replacement power costs.

(g) From NUREG–1353 (NRC 1989, Tables 4.8.3, 5.1.1, and 5.1.2), without replacement power costs.
Appendix F

September 2013 F-9 Draft NUREG‒2157

1 As the fuel continues to age after reactor shutdown, it will become less hazardous due to 

2 radioactive decay and the reduction of the heat generated by the spent fuel. Thus, both the 

3 consequences and risk predicted by the analysis will continue to decrease in comparison to the 

4 values in Table F-1 through the short-term storage timeframe because the fuel would have been 

5 cooling in the spent fuel pool for a longer period of time and would have a smaller source term 

6 (less radionuclide inventory) due to decay.

7 In NUREG–1738, the NRC determined that the probability-weighted consequences of a spent 

8 fuel pool accident, including a spent fuel pool fire, could be comparable to the probabilityweighted consequences of a severe reactor accident (NRC 2001).5 9 Therefore, the NRC has 

10 decided to include a comparison of the frequency-weighted consequences of a severe reactor 

11 accident to the frequency-weighted consequences of a spent fuel pool fire to provide a more 

12 complete picture of the overall risks of a spent fuel pool fire. As discussed above, the 

13 frequency-weighted consequences, or the risk, of a spent fuel pool fire represent the NRC’s 

14 determination of the environmental impacts of this event.

15 Table F-2 provides the probability-weighted consequences (risk) resulting from a spent fuel pool 

16 fire. This table demonstrates that the probability-weighted consequences of a spent fuel pool 

17 fire are comparable to those for severe reactor accidents. 

18 With the exception of the economic damage risk figures for spent fuel pool fire, all of the risk 

19 values in Table F-2 are for Surry. Economic damage risk figures for spent fuel pool fires are not 

20 available for Surry; thus, this draft GEIS uses available economic damage risk figures that are 

21 as similar as possible. A similar case studied previously by NRC involved 3.5 cores of spent 

22 fuel from the R.E. Ginna nuclear power plant and a 80-km (50-mi) average population density of 

330 people/km2 (860 people/mi2 23 ), which is based on the population around the Zion plant in 

24 Illinois (NRC 1989). Given that the analysis in this draft GEIS is concerned with spent fuel pool 

25 fires at nuclear power plants that have permanently ceased operations, the economic damage 

26 risk figures for spent fuel pool fires presented in Table F-2 do not include replacement power 

27 costs. The costs considered include those for onsite cleanup, repair and disposal of wastes, 

28 and offsite economic damage (e.g., relocation of people and property decontamination).

29 The NRC is using the results for Surry because there are few stations for which quantitative risk

30 values are available for both an onsite reactor accident and a spent fuel pool fire. The NRC 

 

5 The seismic risk analysis performed in NUREG–1738 was based on site-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, such as Diablo 

Canyon, San Onofre, and Columbia, were not specifically considered in this study. Nothing in 

NUREG–1738, or the NRC’s reliance on it here, undermines the NRC’s determination that the impacts of 

a severe accident in a spent fuel pool will be comparable to severe reactor accidents for all facilities.
Appendix F

Draft NUREG‒2157 F-10 September 2013

1 believes that a comparison of severe reactor accidents and spent fuel pool fires for Surry is 

2 appropriate for this generic analysis because of the following:

3 • Each of the two pressurized water reactor units at Surry generate approximately the same 

4 levels of thermal and electric power as the reference facility described elsewhere in this draft 

5 GEIS (838 MW(e) versus the reference value of 1,000 MW(e)), and the shared Surry spent 

6 fuel pool is licensed to store 1,044 spent fuel assemblies—the equivalent of about 4.6 full 

7 reactor cores, or about 520 MTU—which is approximately the pool capacity used elsewhere 

8 in this draft GEIS (520 MTU versus the reference value of 700 MTU). The NRC has 

9 determined that the differences between the Surry and the reference facility values are not 

10 significant for this impact analysis and, as noted above, the impacts can be scaled 

11 appropriately for any particular facility’s surrounding population and source term 

12 characteristics.

13 • The consequences of a severe reactor accident will change in direct proportion to the 

14 reactor’s power level. Likewise, the consequences of a spent fuel pool fire will change in 

15 direct proportion to the amount of spent fuel stored in the pool. In the case of Surry, both

16 the reactor power level and the spent fuel pool licensed capacity are both about the same 

17 proportion lower than the reference facility described in Chapter 2 of the GEIS. As a result, 

18 the ratio of severe reactor accident risk to spent fuel pool fire risk is likely to be similar for the 

19 reference reactor described in Chapter 2.

20 The risk values in Table F-2 include individual risks and population risks. The individual risk 

21 values for both severe reactor accidents and spent fuel pool fires are comparable to each other 

22 and both lower than the NRC’s Quantitative Health Objectives contained in its Safety Goal 

Policy Statement (51 FR 30028) for both individual early fatality risk (5 × 10−7 Ryr−1 23 ) and 

individual latent fatality risk (2 × 10−6 Ryr−1 24 ) (NRC 2001). As stated above, the population risk 

25 values for the two accident types are comparable. The public exposure costs are not included 

26 in the severe reactor accident economic cost-risk figures because the spent fuel pool fire 

27 economic damage risk from the reports cited did not include public exposure costs.

28 This analysis shows that the probability-weighted consequences for a spent fuel pool fire, as 

29 analyzed in NUREG–1738, are comparable to the probability-weighted consequences for 

30 severe power reactor accidents analyzed in the 1996 and 2013 License Renewal GEIS (NRC 

31 1996, 2013). Not only are spent fuel pool probability-weighted consequences comparable, but 

32 NUREG–1738 contains several built-in conservative assumptions. For example, NUREG–1738 

33 assumed that the zirconium fuel cladding would start to burn and was nonrecoverable as soon 

34 as the water level in the spent fuel pool fell to within 0.9 m (3 ft) of the top of the fuel assemblies 

35 (NRC 2001). However, a 2008 Denial of Petition for Rulemaking (73 FR 46204) analysis shows 

36 that there would be significant time between the initiating event and the spent fuel assemblies 

37
Appendix F

September 2013 F-11 Draft NUREG‒2157

1 becoming partially or completely uncovered. Thus, more time would be available for operator 

2 intervention, which would lower the probability of a drain-down event leading to a spent fuel 

3 pool fire. 

4 In addition, NUREG–1738 concluded that it would take more than 4 days for a pressurized 

5 water reactor and more than 6 days for a boiling water reactor (assuming a 60 day decay time 

6 for the fuel) for the water to reach within 0.9 m (3 ft) of the top of the fuel assemblies due to 

7 heating, boiling, and evaporation of the spent fuel pool water. However, if a 2 year decay time 

8 for the spent nuclear fuel were assumed, then the time for the water to reach within 0.9 m (3 ft) 

9 of the top of the fuel assemblies would be more than 11 days for a pressurized water reactor 

10 and more than 14 days for a boiling water reactor. Based on significant time between the 

11 initiating event and the spent fuel assemblies becoming partially or completely uncovered the 

12 licensees and State and Federal authorities would have time to take mitigating action to prevent 

13 a spent fuel pool fire. In addition, air-cooling of spent fuel would be sufficient to prevent spent 

14 fuel pool zirconium fires at a point much earlier following fuel offload from the reactor than was 

15 considered in the 2001 study (73 FR 46204).

16 Since the publication of NUREG–1738, the NRC has required licensees to undertake additional 

17 actions to further reduce the probability of a spent fuel pool fire. These additional actions 

18 resulted from insights following the September 11, 2001 terrorist attack and the March 11, 2011 

19 Fukushima Dai-ichi accident. 

20 Following the September 11, 2001 attack, the NRC took several actions to further reduce the 

21 probability of a spent fuel pool fire. In the wake of the attacks, the NRC issued orders to 

22 licensees that implemented additional security measures, including increased patrols, 

23 augmented security forces and capabilities, and more restrictive site-access controls to reduce 

24 the likelihood of an accident, including a spent fuel pool accident, resulting from a terrorist25 initiated event. In addition, the NRC amended Title 10 of the Code of Federal Regulations

26 50.54(hh)(2) to require licensees to implement other mitigating measures to maintain or restore 

27 spent fuel pool cooling capability in the event of loss of large areas of the plant due to fires or 

28 explosions, which further decreases the probability of a spent fuel pool fire (58 FR 13926). 

29 Further, other organizations, such as Sandia National Laboratory, have confirmed the 

30 effectiveness of the additional mitigation strategies to maintain spent fuel cooling in the event 

31 the pool is drained and its initial water inventory is reduced or lost entirely (73 FR 46204). 

32 Generic strategies for spent fuel pool cooling are further discussed in a publication prepared by 

33 the Nuclear Energy Institute, a nuclear industry policy group, in NEI–06–12, Revision 2 (NEI 

34 2006), which has been endorsed by the NRC. As a result of these additional actions, NRC has 

35 concluded that the probability of an initiating event leading to a spent fuel pool fire is less likely 

36 than analyzed in the NUREG–1738 and previous studies (73 FR 46204). As a result, the 

37 analysis provided in Table F-2, based upon NUREG–1738, is a conservative estimate of spent 

38 fuel pool risk. 
Appendix F

Draft NUREG‒2157 F-12 September 2013

1 The NRC conducted additional evaluations to assess its regulatory framework in response to 

2 the March 2011 Fukushima Dai-ichi events. On March 11, 2011, a massive earthquake off the 

3 east coast of Honshu, Japan, produced a devastating tsunami that struck the coastal town of 

4 Fukushima. The six-unit Fukushima Dai-ichi nuclear power plant was most directly affected by 

5 these events. Damage to the systems and structures of the reactor building resulted in the 

6 release of radioactive material to the surrounding environment. While this accident led to a 

7 substantial release of radioactive material, the fuel stored in the spent fuel pools was not 

8 uncovered and the event did not lead to a spent fuel pool fire. Information on the event 

9 indicates that spent fuel pool cooling was lost for all spent fuel pools following the loss of offsite 

10 power (INPO 2011). But subsequent analyses and inspections confirmed that the spent fuel 

11 pool water levels did not drop below the top of the fuel in any of the spent fuel pools and no 

12 significant damage occurred to the fuel in the pools. These events demonstrate that, even 

13 without spent fuel cooling for multiple days, the pools were able to maintain cooling 

14 (INPO 2012).

15 In response to the earthquake, tsunami, and resulting reactor accidents at Fukushima Dai-ichi, 

16 the Commission directed the staff to convene an agency task force of senior leaders and 

17 experts to conduct a methodical and systematic review of the relevant NRC regulatory 

18 requirements, programs, and processes, including their implementation, and to recommend 

19 whether the agency should make near-term improvements to its regulatory system. As part of 

20 the short-term review, this Near-Term Task Force concluded that some additional improvements 

21 to spent fuel pool storage and other structures, systems, and components would be beneficial. 

22 In NRC Order EA–12–049, the NRC required licensees to implement mitigating strategies to 

23 ensure that spent fuel pool cooling can be accomplished through alternative means to prevent 

24 fuel damage (NRC 2012a). In addition, in NRC Order EA–12–051, the NRC determined that 

25 commercial power reactor licensees must have a reliable means to remotely monitor a wide26 range of spent fuel pool levels to support effective prioritization of event mitigation and recovery 

27 actions in the event of a beyond-design-basis external event (NRC 2012b). These measures 

28 further reduce the probability of a spent fuel pool fire, and thus further increase the 

29 conservatism of NUREG–1738.

30 F.2.3 Conclusion

31 In summary, the conservative estimates that the NRC is using to assess spent fuel pool fire

32 accidents, based upon NUREG–1738 and other analyses, results in probability-weighted 

33 population doses and economic consequences that are comparable to the values calculated for 

34 a reactor accident, as estimated in the 1996 and 2013 License Renewal GEIS (NRC 1996, 

35 2013). Further, mitigation measures implemented by licensees as a result of NRC orders and 

36 regulations adopted since NUREG–1738 have further lowered the probability and risk of a spent 

37 fuel pool fire. As a result, the NRC finds that the environmental impacts from spent fuel pool 

38 fires are SMALL during the short-term storage timeframe.
Appendix F

September 2013 F-13 Draft NUREG‒2157

1 F.3 References

2 F.3.1 Summary of Major Studies Considered in this Appendix

3 One of the earlier spent fuel pool accident studies considered by the NRC was “Reactor Safety

4 Study: An Assessment of Accident Risks in U.S. Commercial Nuclear Power Plants” (NRC 

5 1975). The Reactor Safety Study provides a systematic quantification of commercial nuclear 

6 reactor accident probabilities. Appendix I of the Reactor Safety Study covers various accidents, 

7 including spent fuel storage pool accidents. The Reactor Safety Study states that spent fuel 

8 pool accidents can arise from either loss of spent fuel pool cooling, drainage of the spent fuel 

9 pool, or dropping of heavy items into the spent fuel pool. The Reactor Safety Study also 

10 indicates that the probability of spent fuel damage from a spent fuel pool loss-of-cooling event is 

11 small at less than 0.1 events per year. The Reactor Safety Study used this information to 

12 estimate the probability of fuel damage due to loss of pool cooling. This study examined 

13 drainage of the spent fuel pool and concluded that the probability of drainage is much lower 

14 than for a loss-of-cooling event because drainage would require multiple failures to occur 

15 simultaneously. In addition to loss-of-cooling accidents, the Reactor Safety Study examined 

16 mechanical failure, both for dropping a cask into the spent fuel pool or due to an earthquake. 

17 This study concluded that the risks for a spent fuel pool accident were orders of magnitude 

18 below those involving the reactor core because of the robust design of the spent fuel pool.

19 In 1989, NRC completed a generic analysis of potential accidents in spent fuel pools, 

20 “Regulatory Analysis for the Resolution of Generic Issue 82, ‘Beyond Design Basis Accidents in 

21 Spent Fuel Pools’” (NRC 1989). This analysis reexamined spent fuel pool fires because 

22 1) spent fuel pool storage had been expanded, including use of high-density storage racks and 

23 2) new research had provided evidence of the possibility of fire propagation between 

24 assemblies in an air-cooled environment. This generic analysis examined the various spent fuel 

25 pool and spent fuel storage rack designs. NRC used this information to assess various accident 

26 sequences, including failure due to missiles, aircraft crashes, heavy-load drop, seal failure, 

27 inadvertent draining, loss-of-cooling, and seismic events. NRC quantified the probabilities of 

28 these initiation events and assessed both the health and economic consequences. 

29 The safety and environmental effects of spent fuel pool storage were further addressed in 

30 conjunction with regulatory assessments of permanently shutdown nuclear plants and 

31 decommissioning nuclear power plants. NUREG/CR–6451, “A Safety and Regulatory 

32 Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants” (Travis 

33 et al. 1997), addressed the appropriateness of regulations (e.g., requirements for emergency 

34 planning and insurance) associated with spent fuel pool storage. The study also provided 

35 bounding estimates for offsite consequences for the most severe accidents, which would involve 

36 draining of the spent fuel pool (e.g., complete draining of the spent fuel pool occurs 12 days 

37 after shutdown of the reactor). 
Appendix F

Draft NUREG‒2157 F-14 September 2013

1 In 2001, NRC published the results of its technical study on spent fuel pool accident risk at 

2 decommissioning nuclear power plants. This study, NUREG–1738, “Technical Study of Spent 

3 Nuclear Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants,” also examined 

4 spent fuel pool zirconium fires (NRC 2001). The NRC’s analyses showed that, although the 

5 consequences for a spent fuel pool fire could be high, the risk (probability-weighted 

6 consequence) would be low because the loss-of-coolant event frequency is low. The NRC’s 

7 analysis was based on a spent fuel pool at a decommissioning nuclear power plant but included 

8 times shortly after plant shutdown. Therefore, the study included analysis of accident conditions 

9 for spent fuel that had various amounts of decay heat. The risk analyses included sensitivity 

10 studies to evaluate scenarios in which members of the public residing near the plant did not 

11 evacuate as promptly as expected, given emergency preparedness requirements. This analysis 

12 assumed a spent fuel pool inventory equivalent to 3.5 reactor cores, a much more densely 

13 packed pool than assumed by the 1975 Reactor Safety Study. Further, NUREG–1738 included 

14 core loads with an average fuel burnup of 60 gigawatt-days/metric ton uranium, which is 

15 consistent with high-burnup fuel. This study represents the NRC’s current judgment as to the 

16 expected impacts from a spent fuel pool fire during the short-term storage timeframe.

17 F.3.2 List of References

18 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

19 Production and Utilization Facilities.” Washington, D.C.

20 51 FR 30028. August 4, 1986. “Safety Goals for the Operations of Nuclear Power Plants; 

21 Policy Statement, Republication.” Federal Register. U.S. Nuclear Regulatory Commission, 

22 Washington, D.C.

23 58 FR 13926. March 27, 2009. “Power Reactor Security Requirements.” Federal Register. 

24 U.S. Nuclear Regulatory Commission, Washington, D.C.

25 73 FR 46204. August 8, 2008. “The Attorney General of Commonwealth of Massachusetts, 

26 The Attorney General of California; Denial of Petitions for Rulemaking.” Federal Register. 

27 U.S. Nuclear Regulatory Commission, Washington, D.C.

28 Gauntt, R.O. 2010. MELCOR 1.8.5 Modeling Aspects of Fission Product Release, Transport 

29 and Deposition. Sandia Report, SAND2010–1635. Available at 

30 http://prod.sandia.gov/techlib/access-control.cgi/2010/101635.pdf.

31 INPO (Institute of Nuclear Power Operations). 2011. Special Report on the Nuclear Accident at 

32 the Fukushima Dai-ichi Nuclear Power Station. INPO–11–005, Revision 0, Atlanta, Georgia. 
Appendix F

September 2013 F-15 Draft NUREG‒2157

1 INPO (Institute of Nuclear Power Operations). 2012. Lessons Learned from the Nuclear 

2 Accident at the Fukushima Dai-ichi Nuclear Power Station. INPO–11–005 Addendum, 

3 Revision 0, Atlanta, Georgia. 

4 NEI (Nuclear Energy Institute). 2006. B.5.b Phase 2 & 3 Submittal Guideline. NEI–06–12, 

5 Revision 2, Walnut Creek, California. Accession No. ML070090060.

6 NRC (U.S. Nuclear Regulatory Commission). 1975. Reactor Safety Study: An Assessment of 

7 Accident Risks in U.S. Commercial Nuclear Power Plants. NUREG–75/014 (WASH–1400), 

8 Washington, D.C. Accession No. ML083570090.

9 NRC (U.S. Nuclear Regulatory Commission). 1989. Regulatory Analysis for the Resolution of 

10 Generic Issue 82, “Beyond Design Basis Accidents in Spent Fuel Pools.” NUREG–1353, 

11 Washington, D.C. Accession No. ML082330232.

12 NRC (U.S. Nuclear Regulatory Commission). 1990. Severe Accident Risks: An Assessment 

13 for Five U.S. Nuclear Power Plants. NUREG–1150, Volume 1, Washington, D.C. Accession 

14 No. ML120960691.

15 NRC (U.S. Nuclear Regulatory Commission). 1994. Revised Livermore Seismic Hazard 

16 Estimates for Sixty-Nine Nuclear Power Plant Sites East of the Rocky Mountains. 

17 NUREG–1488, Washington, D.C. Accession No. ML052640591.

18 NRC (U.S. Nuclear Regulatory Commission). 1995. Accident Source Terms for Light-Water 

19 Nuclear Power Plants. NUREG–1465, Washington, D.C. Accession No. ML041040063.

20 NRC (U.S. Nuclear Regulatory Commission). 1996. Generic Environmental Impact Statement 

21 for License Renewal of Nuclear Plants. NUREG–1437, Washington, D.C. Available at 

22 http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/. 

23 NRC (U.S. Nuclear Regulatory Commission). 1997. Regulatory Analysis Technical Evaluation 

24 Handbook. NUREG/BR–0184, Washington, D.C. Accession No. ML050190193.

25 NRC (U.S. Nuclear Regulatory Commission). 2001. Technical Study of Spent Nuclear Fuel 

26 Pool Accident Risk at Decommissioning Nuclear Power Plants. NUREG–1738, Washington, 

27 D.C. Accession No. ML010430066.

28 NRC (U.S. Nuclear Regulatory Commission). 2002. Generic Environmental Impact Statement 

29 for License Renewal of Nuclear Plants, Supplement 6. Regarding Surry Power Station, Units 1 

30 and 2. NUREG–1437, Supplement 6, Washington, D.C. Accession No. ML023380748.
Appendix F

Draft NUREG‒2157 F-16 September 2013

1 NRC (U.S. Nuclear Regulatory Commission). 2012a. Issuance of Order to Modify Licenses 

2 with Regard to Requirement for Mitigation Strategies for Beyond-Design-Basis External Events. 

3 EA–12–049, Washington, D.C. Accession No. ML12054A735.

4 NRC (U.S. Nuclear Regulatory Commission). 2012b. Issuance of Order to Modify Licenses 

5 with Regard to Reliable Spent Fuel Pool Instrumentation. EA–12–051, NRC–2012–051, 

6 Washington, D.C. Accession No. ML12056A044.

7 NRC (U.S. Nuclear Regulatory Commission). 2013. Generic Environmental Impact Statement 

8 for License Renewal of Nuclear Plants. NUREG–1437, Revision 1, Washington, D.C. 

9 Accession No. ML13107A023.

10 Travis, R.J., R.E. Davis, E.J. Grove, and M.A. Azarm. 1997. Safety and Regulatory 

11 Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants. 

12 NUREG/CR–6451 Brookhaven National Laboratory, Washington, D.C. Available at 

13 http://www.osti.gov/bridge/servlets/purl/510336-qmwPBP/webviewable/510336.pdf. 
Appendix G 

–

Spent Fuel Storage Facilities

September 2013 G-1 Draft NUREG‒2157

Appendix G

Spent Fuel Storage Facilities

1 This appendix provides summary information concerning spent nuclear fuel (spent fuel) pools

2 and independent spent fuel storage installations (ISFSIs) located at operating commercial 

3 power reactors and decommissioned reactor sites.

4 Table G-1 through Table G-3 provide information about spent fuel pools. Specifically, Table G-1

5 lists operating reactors and the capacities of their spent fuel pools. Capacities at single-unit 

6 pressurized water reactor (PWR) power plants range from 544 assemblies at the H.B. Robinson 

7 Steam Electric Plant, Unit 2 to 2,363 assemblies at the Callaway Plant and the Wolf Creek 

8 Generating Station. At boiling water reactor (BWR) power plants, spent fuel pool capacities 

9 range from 1,803 assemblies at the Brunswick Steam Electric Generating plant to 4,608 

10 assemblies at Fermi, Unit 2. 

11 Table G-2 indicates the capacity of spent fuel pools for newly licensed power reactors, namely 

12 Vogtle Units 3 and 4 and Virgil C. Summer Units 2 and 3. The capacity of each of the four pools 

13 is 889 assemblies. Table G-3 provides the capacity of spent fuel pools for decommissioning

14 reactors. Presently, only three decommissioning reactors at two sites have spent fuel stored in 

15 pools. These are Millstone Unit 1 (pool capacity of 2,959 assemblies) and Zion Station Units 2 

16 and 3 (shared pool capacity of 3,012 assemblies).

17 Table G-4 and Table G-5 provide information about the ISFSIs with general and specific 

18 licenses under Title 10 of the Code of Federal Regulations (CFR) Part 72, respectively. The 

19 ISFSIs are located at operating and decommissioning reactor sites. There are 54 generally 

20 licensed ISFSIs and 15 specifically licensed ISFSIs. Two of the specifically licensed ISFSIs 

21 (i.e., Private Fuel Storage and the Idaho Spent Fuel Facility) were never constructed. All ISFSIs 

22 are dry storage facilities except for the facility at the General Electric-Hitachi Morris Operation 

23 Facility (GEH Morris) site, which is a wet storage facility. 

24

25 A general license authorizes a nuclear power plant licensee to store spent fuel in the 

26 U.S. Nuclear Regulatory Commission- (NRC)-approved casks at a site licensed to operate a 

27 power reactor under 10 CFR Part 50. An NRC-approved cask is one that has undergone a 

28 technical review of its safety aspects and has been found to be adequate to store spent fuel at a 

29 site that meets all of the NRC's requirements in 10 CFR Part 72. A licensee is required to 

30 perform an evaluation of its site to demonstrate that the site is adequate for storing spent fuel in 

31 dry casks. This evaluation must show that the cask Certificate of Compliance conditions and 

32 technical specifications can be met and must include an analysis of earthquake events and 
Appendix G

Draft NUREG‒2157 G-2 September 2013

1 tornado missiles. In addition, the licensee must review its security program, emergency plan, 

2 quality assurance program, training program, and radiation protection program, and make any 

3 changes necessary to incorporate the ISFSI at the reactor site. Requirements for the general 

4 license are described in Subpart K of 10 CFR Part 72.

5 Under a site-specific license, an applicant submits a license application to NRC. The NRC 

6 performs a technical review of all the safety aspects of the proposed ISFSI and an 

7 environmental review in compliance with the National Environmental Policy Act. If the 

8 application is approved, the NRC issues a license that is valid for up to 40 years. A spent fuel 

9 storage license contains technical requirements and operating conditions (i.e., fuel 

10 specifications, cask leak testing, surveillance, and other requirements) for the ISFSI and 

11 specifies what the licensee is authorized to store at the site. Requirements for the site-specific 

12 license are described in Subparts A through I of 10 CFR Part 72.
September 2013

G-3 Draft NUREG‒2157

Table G-1. Capacity of Spent Fuel Pools for Operating Nuclear Power Reactors 1

Operating Reactors

Reactor 

Type

Core Size

(assemblies)

Commercial 

Operation

Start Date

Pool 

Capacity 

(assemblies)

Pool 

Capacity

(cores)

Arkansas Nuclear One, Unit 1 PWR 177 12/19/1974 968 4.5 

Arkansas Nuclear One, Unit 2 PWR 177 3/26/1980 988 4.6 

Beaver Valley Power Station, Unit 1 PWR 157 10/1/1976 1,627 9.4 

Beaver Valley Power Station, Unit 2 PWR 157 11/17/1987 1,690 9.8 

Braidwood Station, Unit 1 PWR 193 7/29/1988 2,984 13.5 

Braidwood Station, Unit 2 PWR 193 10/17/1988 See above (pool share

Browns Ferry Nuclear Plant, Unit 1 BWR 764 8/1/1974 3,471 3.5 

Browns Ferry Nuclear Plant, Unit 2 BWR 764 3/1/1975 3,471 3.5 

Browns Ferry Nuclear Plant, Unit 3 BWR 764 3/1/1977 3,471 3.5 

Brunswick Steam Electric Plant, Unit 1(c,f) BWR 560 3/18/1977 1,803 2.2 

Brunswick Steam Electric Plant, Unit 2(d,f) BWR 560 11/3/1975 1,839 2.3 

Byron Station, Unit 1 PWR 193 9/16/1985 2,984 13.5 

Byron Station, Unit 2 PWR 193 8/2/1987 See above (pool share

Callaway Plant PWR 193 12/19/1984 2,363 11.2 

Calvert Cliffs Nuclear Power Plant, Unit 1 PWR 217 5/8/1975 1,830 6.4 

Calvert Cliffs Nuclear Power Plant, Unit 2 PWR 217 4/1/1977 See above (pool share

Catawba Nuclear Station, Unit 1 PWR 193 6/29/1985 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 11/24/1987 3,796 5.1 

Columbia Generating Station, Unit 2 BWR 764 12/13/1984 2,658 2.5 

Comanche Peak Steam Electric Station, Unit 1 PWR 193 8/13/1990 3,373 15.5 

Comanche Peak Steam Electric Station, Unit 2 PWR 193 8/3/1993 See above (pool share

2
Draft NUREG‒2157

G-4 September 2013

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

(cores)

Cooper Nuclear Station BWR 548 7/1/1974 2,651 3.8 

Crystal River Nuclear Generating Plant, Unit 3(e) PWR 177 3/13/1977 1,474 7.3 

Davis-Besse Nuclear Power Station, Unit 1 PWR 177 7/31/1978 1,624 8.2 

Diablo Canyon Nuclear Power Plant, Unit 1 PWR 193 5/7/1985 1,324 5.9 

Diablo Canyon Nuclear Power Plant, Unit 2 PWR 193 3/13/1986 1,324 5.9 

Donald C. Cook Nuclear Power Plant, Unit 1 PWR 193 8/28/1975 3,613 16.7 

Donald C. Cook Nuclear Power Plant, Unit 2 PWR 193 7/1/1978 See above (pool share

Dresden Nuclear Power Station, Unit 2 BWR 724 6/9/1970 3,537 3.9 

Dresden Nuclear Power Station, Unit 3 BWR 724 11/16/1971 3,537 3.9 

Duane Arnold Energy Center BWR 368 2/1/1975 3,152 7.6 

Edwin I. Hatch Nuclear Plant, Unit 1 BWR 560 12/31/1975 3,349 5.0 

Edwin I. Hatch Nuclear Plant, Unit 2 BWR 560 9/5/1979 2,933 4.2 

Fermi, Unit 2 BWR 764 1/23/1988 4,608 5.0 

Fort Calhoun Station, Unit 1 PWR 133 9/26/1973 1,083 7.1 

Grand Gulf Nuclear Station, Unit 1 BWR 800 7/1/1985 4,348 4.4 

H. B. Robinson Steam Electric Plant, Unit 2(f) PWR 157 3/7/1971 544 2.5 

Hope Creek Generating Station, Unit 1 BWR 764 12/20/1986 4,006 4.2 

Indian Point Nuclear Generating, Unit 2 PWR 193 8/1/1974 1,374 6.1 

Indian Point Nuclear Generating, Unit 3 PWR 193 8/30/1976 1,345 6.0 

James A. FitzPatrick Nuclear Power Plant BWR 560 7/28/1975 3,239 4.8 

Joseph M. Farley Nuclear Plant, Unit 1 PWR 157 12/1/1977 1,407 8.0 

Joseph M. Farley Nuclear Plant, Unit 2 PWR 157 7/30/1981 1,407 8.0 

Kewaunee Power Station(g) PWR 121 6/16/1974 1,205 9.0 

LaSalle County Station, Unit 1 BWR 764 1/1/1984 3,986 4.2 

LaSalle County Station, Unit 2 BWR 764 10/19/1984 4,078 4.3 

Limerick Generating Station, Unit 1w BWR 764 2/1/1986 4,117 4.4 
September 2013

G-5 Draft NUREG‒2157

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

(cores)

Limerick Generating Station, Unit 2 BWR 764 1/8/1990 4,117 4.4 

McGuire Nuclear Station, Unit 1 PWR 193 12/1/1981 1,463 6.6 

McGuire Nuclear Station, Unit 2 PWR 193 3/1/1984 1,463 6.6 

Millstone Power Station, Unit 2 PWR 217 12/26/1975 1,346 5.2 

Millstone Power Station, Unit 3 PWR 193 4/23/1986 1,860 8.6 

Monticello Nuclear Generating Plant, Unit 1 BWR 484 6/30/1971 2,301 3.8 

Nine Mile Point Nuclear Station, Unit 1 BWR 532 12/1/1969 4,086 6.7 

Nine Mile Point Nuclear Station, Unit 2 BWR 764 3/11/1988 4,049 4.3 

North Anna Power Station, Unit 1 PWR 157 6/6/1978 1,737 9.1 

North Anna Power Station, Unit 2 PWR 157 12/14/1980 See above (pool share

Oconee Nuclear Station, Unit 1 PWR 177 7/15/1973 1,312 5.4 

Oconee Nuclear Station, Unit 2 PWR 177 9/9/1974 See above (pool share

Oconee Nuclear Station, Unit 3 PWR 177 12/16/1974 825 3.7 

Oyster Creek Nuclear Generating Station, Unit 1 BWR 560 12/1/1969 3,035 4.4 

Palisades Nuclear Plant PWR 204 12/31/1971 892 3.4 

Palo Verde Nuclear Generating Station, Unit 1 PWR 241 1/28/1986 1,329 4.5 

Palo Verde Nuclear Generating Station, Unit 2 PWR 241 9/19/1986 1,329 4.5 

Palo Verde Nuclear Generating Station, Unit 3 PWR 241 1/8/1988 1,329 4.5 

Peach Bottom Atomic Power Station, Unit 2 BWR 764 7/5/1974 3,819 4.0 

Peach Bottom Atomic Power Station, Unit 3 BWR 764 12/23/1974 3,819 4.0 

Perry Nuclear Power Plant, Unit 1 BWR 748 11/18/1987 4,020 4.4 

Pilgrim Nuclear Power Station BWR 580 12/1/1972 3,859 5.7 

Point Beach Nuclear Plant, Unit 1 PWR 121 12/21/1970 1,502 10.4 

Point Beach Nuclear Plant, Unit 2 PWR 121 10/1/1972 See above (pool share

Prairie Island Nuclear Generating Plant, Unit 1 PWR 121 12/16/1973 1,386 9.5 

Prairie Island Nuclear Generating Plant, Unit 2 PWR 121 12/21/1974 See above (pool share

Quad Cities Nuclear Power Station, Unit 1 BWR 724 2/18/1973 3,657 4.1 
Draft NUREG‒2157

G-6 September 2013

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

(cores)

Quad Cities Nuclear Power Station, Unit 2 BWR 724 3/10/1973 3,897 4.4 

River Bend Station, Unit 1 BWR 624 6/16/1986 3,104 4.0 

R.E. Ginna Nuclear Power Plant PWR 121 7/1/1970 1,321 9.9 

St. Lucie Plant, Unit 1 PWR 217 12/21/1976 1,706 6.9 

St. Lucie Plant, Unit 2 PWR 217 8/8/1983 1,716 6.9 

Salem Nuclear Generating Station, Unit 1 PWR 193 6/30/1977 1,632 7.5 

Salem Nuclear Generating Station, Unit 2 PWR 193 10/13/1981 1,632 7.5 

San Onofre Nuclear Generating Station, Unit 2 PWR 217 8/8/1983 1,542 6.1 

San Onofre Nuclear Generating Station, Unit 3 PWR 217 4/1/1984 1,542 6.1 

Seabrook Station, Unit 1 PWR 193 8/19/1990 1,236 5.4 

Sequoyah Nuclear Plant, Unit 1 PWR 193 7/1/1981 2,091 9.8 

Sequoyah Nuclear Plant, Unit 2 PWR 193 6/1/1982 2,091 9.8 

Shearon Harris Nuclear Power Plant, Unit 1(h) PWR 157 5/2/1987 1,128 6.2 

South Texas Project, Unit 1 PWR 193 8/25/1988 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 157 12/22/1972 1,044 4.6 

Surry Nuclear Power Station, Unit 2 PWR 157 5/1/1973 See above (pool share

Susquehanna Steam Electric Station, Unit 1 BWR 764 6/8/1983 2,840 2.7 

Susquehanna Steam Electric Station, Unit 2 BWR 764 2/12/1985 2,840 2.7 

Three Mile Island Nuclear Station, Unit 1 PWR 177 9/2/1974 1,062 5.0 

Turkey Point Nuclear Generating, Unit 3 PWR 157 12/14/1972 1,535 8.8 

Turkey Point Nuclear Generating, Unit 4 PWR 157 9/7/1973 1,535 8.8 

Vermont Yankee Nuclear Power Plant, Unit 1 BWR 368 11/30/1972 3,353 8.1 

Virgil C. Summer Nuclear Station, Unit 1 PWR 157 1/1/1984 1,712 9.9 

Vogtle Electric Generating Plant, Unit 1 PWR 193 6/1/1987 1,476 6.6 

Vogtle Electric Generating Plant, Unit 2 PWR 193 5/20/1989 2,098 9.9 
September 2013

G-7 Draft NUREG‒2157

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

(cores)

Waterford Steam Electric Station, Unit 3 PWR 217 9/24/1985 1,849 7.5 

Watts Bar Nuclear Plant, Unit 1 PWR 193 5/27/1996 1,386 6.2 

Wolf Creek Generating Station, Unit 1 PWR 193 9/3/1985 2,363 11.2 

Sources: Reactor operating licenses, available through the NRC’s website at http://www.nrc.gov/reactors/operating/list-power-r

(NRC 2013a).

(a) Represents capacity with full core offload maintained; pool capacity (cores) is derived by subtracting one core’s worth of as

Pool capacity (assemblies) and then dividing that number by core size (assemblies).

(b) Pool capacity (MTU) is derived by multiplying 500 kg (or 0.5 metric ton) per assembly for a PWR or 186 kg (0.186 metric to

for a BWR by the number of assemblies in pool capacity.

(c) Plus 160 PWR assemblies. 

(d) Plus 144 PWR assemblies. 

(e) Duke Energy has certified that Crystal River Unit 3 power operations have ceased and the fuel has been removed from the 

2013).

(f) Brunswick and Robinson shipped to Shearon Harris.

(g) Dominion Energy Kewaunee has certified that power operations will permanently cease on May 7, 2013 (Dominion 2013).

(h) Plus 363 + 2178 BWR assemblies from Brunswick.

1

2
Draft NUREG‒2157

G-8 September 2013

Table G-2. Capacity of Spent Fuel Pools for Newly Licensed Power Reactors 1

Operating Reactors

Reactor 

Type

Core Size

(assemblies)

Commercial

Operation 

Start Date

Pool

Capacity

(assemblies)

Pool

Capacity(a

(cores)

Vogtle Electric Generating Plant, Unit 3 PWR 157 future 889 4.7 

Vogtle Electric Generating Plant, Unit 4 PWR 157 future 889 4.7 

Virgil C. Summer Nuclear Station, Unit 2 PWR 157 future 889 4.7 

Virgil C. Summer Nuclear Station, Unit 3 PWR 157 future 889 4.7 

Sources: Combined operating licenses, available through the NRC’s website at http://www.nrc.gov/reactors/new-reactors/col/v

and http://www.nrc.gov/reactors/new-reactors/col/summer.html (Summer) (NRC 2013b).

(a) Represents capacity with full core offload maintained; pool capacity (cores) is derived by subtracting one core’s worth of as

capacity (assemblies) and then dividing that number by core size (assemblies).

(b) Pool capacity (MTU) is derived by multiplying 500 kg (or 0.5 metric ton) per assembly (assumed for PWR) by the number o

capacity (889).

Table G-3. Capacity of In-Use Spent Fuel Pools for Decommissioning Facilities 2

Operating Reactors

Reactor

Type

Core

Size

(assemblies)

Commercial

Operation

Start Date

Pool

Capacity

(assemblies)

Pool

Capacity(a)

(cores)

Millstone 1 BWR 580 12/28/1970 2959 4.1 

Zion 1 PWR 193 10/19/1973 3012 14.6 

Zion 2 PWR 193 11/14/1973 See above (pool shared wi

Sources: http://www.nrc.gov/info-finder/decommissioning/power-reactor/millstone-unit-1.html (NRC 2013c); Dominion 2011 (f

Commonwealth Edison 1993, 1998 (for Zion).

(a) Represents capacity with full core offload maintained; pool capacity (cores) is derived by subtracting one core’s worth of a

pool capacity (assemblies) and then dividing that number by core size (assemblies).

(b) Pool capacity (MTU) is derived by multiplying 500 kg (or 0.5 metric ton) per assembly for a PWR or 186 kg (0.186 metric 

assembly for a BWR by the number of assemblies in pool capacity.

3 
September 2013

G-9 Draft NUREG‒2157

Table G-4. ISFSIs with General Licenses under Part 72 1

Reactor Site Reactor Type Initial Storage Date Vendor Syst

Arkansas Nuclear One PWR 12/17/1996 BNG Fuel Solutions VSC-24

Arkansas Nuclear One PWR 12/17/1996 Holtec International HI-STOR

Big Rock Point BWR 11/18/2002 BNG Fuel Solutions W-150

Braidwood PWR 11/23/2011 Holtec International HI-STOR

Brunswick(a) BWR 10/28/2010 Transnuclear, Inc. NUHOMS

Browns Ferry BWR 8/21/2005 Holtec International HI-STOR

Byron PWR 9/9/2010 Holtec International HI-STOR

Catawba PWR 7/30/2007 NAC International, Inc. NAC-UM

Columbia Generating Station BWR 9/2/2002 Holtec International HI-STOR

Comanche Peak PWR 2/28/2012 Holtec International HI-STOR

Cook PWR 8/1/2012 Holtec International HI-STOR

Cooper BWR 10/21/2010 Transnuclear, Inc. NUHOMS

Davis-Besse PWR 1/1/1996 Transnuclear, Inc. NUHOMS

Dresden BWR 7/10/2000 Holtec International HI-STAR 

Dresden BWR 7/10/2000 Holtec International HI-STOR

Duane Arnold BWR 9/1/2003 Transnuclear, Inc. NUHOMS

Fort Calhoun PWR 7/29/2006 Transnuclear, Inc. NUHOMS

Ginna(a) PWR 8/23/2010 Transnuclear, Inc. NUHOMS

Grand Gulf BWR 11/18/2006 Holtec International HI-STOR

Haddam Neck 5/21/2004 NAC International, Inc. NAC-MP

Hatch BWR 7/6/2000 Holtec International HI-STAR 

Hatch BWR 7/6/2000 Holtec International HI-STOR

H.B. Robinson PWR 9/6/2005 Transnuclear, Inc. NUHOMS

Hope Creek BWR 11/10/2006 Holtec International HI-STOR

Indian Point PWR 1/11/2008 Holtec International HI-STOR

James A. FitzPatrick BWR 4/25/2002 Holtec International HI-STOR

Joseph M. Farley PWR 8/25/2005 Holtec International. HI-STOR

Kewaunee PWR 9/11/2009 Transnuclear, Inc. NUHOMS

La Crosse(a) BWR 7/12/2012 NAC International, Inc. NAC-MP

2
Draft NUREG‒2157

G-10 September 2013

Table G-4. ISFSIs with General Licenses under Part 72 (cont’d)

Reactor Site Reactor Type Initial Storage Date Vendor Syst

LaSalle BWR 11/1/2010 Holtec International HI-STOR

Limerick BWR 8/1/2008 Transnuclear, Inc. NUHOMS

Maine Yankee PWR 8/24/2002 NAC International, Inc. NAC-UM

McGuire PWR 2/1/2001 Transnuclear, Inc. NAC-UM

McGuire PWR 2/1/2001 Transnuclear, Inc. TN Metal 

Millstone PWR 2/15/2005 Transnuclear, Inc. NUHOMS

Monticello BWR 9/17/2008 Transnuclear, Inc. NUHOMS

Nine Mile Point BWR 9/8/2012 Transnuclear, Inc. NUHOMS

North Anna PWR 3/10/2008 Transnuclear, Inc. TN Metal 

Oconee PWR 3/5/1999 Transnuclear, Inc. NUHOMS

Oyster Creek BWR 4/11/2002 Transnuclear, Inc. NUHOMS

Palisades PWR 5/11/1993 BNG Fuel Solutions VSC-24

Palisades PWR 5/11/1993 Transnuclear, Inc. NUHOMS

Palo Verde PWR 3/15/2003 NAC International, Inc. NAC-UM

Peach Bottom BWR 6/12/2000 Transnuclear, Inc. TN Metal 

Perry(a) BWR 9/29/2012 Holtec International HI-STOR

Point Beach PWR 5/26/1996 BNG Fuel Solutions VSC-24

Point Beach PWR 5/26/1996 Transnuclear, Inc. NUHOMS

Quad Cities BWR 12/2/2005 Holtec International HI-STOR

River Bend BWR 12/29/2005 Holtec International HI-STOR

St. Lucie PWR 3/14/2008 Transnuclear, Inc. NUHOMS

Salem PWR 11/10/2006 Holtec International HI-STOR

San Onofre PWR 10/3/2003 Transnuclear, Inc. NUHOMS

Seabrook PWR 8/7/2008 Transnuclear, Inc. NUHOMS

Sequoyah PWR 7/13/2004 Holtec International HI-STOR

Surry PWR 8/6/2007 Transnuclear, Inc. NUHOMS

Susquehanna BWR 10/18/1999 Transnuclear, Inc. NUHOMS

Susquehanna BWR 10/18/1999 Transnuclear, Inc. NUHOMS

Turkey Point ISFSI PWR 7/29/2010 Transnuclear, Inc. NUHOMS
September 2013

G-11 Draft NUREG‒2157

Table G-4. ISFSIs with General Licenses under Part 72 (cont’d)

Reactor Site Reactor Type Initial Storage Date Vendor Syst

Vermont Yankee BWR 5/25/2008 Transnuclear, Inc. HI-STOR

Waterford Steam Electric Station PWR 11/8/2011 Holtec International HI-STOR

Yankee Rowe PWR 6/26/2002 NAC International, Inc. NAC-MP

Sources: NRC 2012; Ux Consulting 2013

(a) Initial storage dates for Brunswick, Ginna, La Crosse, and Perry obtained from licensee letters: see FirstEnergy 2012 (for P

2010 (for Ginna); Dairyland 2012 (for La Crosse); and Progress Energy 2010 (for Brunswick).

1
Draft NUREG‒2157

G-12 September 2013

Table G-5. ISFSIs with Specific Licenses under Part 72 1

Reactor

Reactor 

Type

Specific 

License 

No.

Initial 

License 

Start Date

Initial 

License 

Expiration 

Date

Renewed 

License 

Expiration 

Date Vendor

Calvert Cliffs PWR SNM–2505 11/25/1992 2012 2052 Transnuclear, Inc. 

Diablo Canyon PWR SNM–2511 3/22/2004 2024 NA Holtec International 

Fort St. Vrain HTGR SNM–2504 11/4/1991 2011 2031 FW Energy 

Applications, Inc. or 

DOE

H.B. Robinson 2 SNM–2502 8/13/1986 2006 2046 Transnuclear, Inc. 

Humboldt Bay BWR SNM–2514 11/30/2005 2025 NA Holtec International 

Idaho National 

Laboratory TMI-2 

Fuel Debris

NA SNM–2508 3/19/1999 2019 NA Transnuclear, Inc. 

Idaho Spent Fuel 

Facility(a)

NA SNM–2512 11/30/2004 2024 NA Foster Wheeler 

Environmental Corp.

Morris Operation 

(GE Hitachi)

NA SNM–2500 5/4/1982 2002 2022 NA 

North Anna 1,2 PWR SNM–2507 6/30/1998 2018 NA Transnuclear, Inc. 

Oconee 1,2,3 PWR 1/29/1990 2010 2050 Transnuclear, Inc. 

Prairie Island PWR SNM–2506 10/19/1993 2013 2053 Transnuclear, Inc. 

Private Fuel 

Storage Facility(a)

NA SNM–2513 2/21/2006 2026 NA Holtec International 

Rancho Seco PWR SNM–2510 6/30/2000 2020 NA Transnuclear, Inc. 

Surry PWR SNM–2501 7/2/1986 2006 2046 General Nuclear 

Surry PWR SNM–2501 7/2/1986 2006 2046 NAC International, 

Inc.

2
September 2013

G-13 Draft NUREG‒2157

Table G-5. ISFSIs with Specific Licenses under Part 72 (cont’d) 1

Reactor

Reactor 

Type

Specific 

License 

No.

Initial 

License 

Start Date

Initial

License 

Expiration 

Date

Renewed 

License 

Expiration 

Date Vendor 

Surry PWR SNM–2501 7/2/1986 2006 2046 Transnuclear, Inc. 

Surry PWR SNM–2501 7/2/1986 2006 2046 Westinghouse, Inc. 

Trojan PWR SNM–2509 3/31/1999 2019 NA Holtec International 

Sources: NRC 2012; Ux Consulting 2013; some information for Idaho National Laboratory TMI-2, the Private Fuel Storage faci

Operation obtained from additional sources: see DOE 2007 (for Idaho TMI-2 facility), NRC 2006 (for Private Fuel Storage), and 

Morris).

(a) Facility was licensed but never constructed. In December, 2012, Private Fuel Storage requested termination of its license 

HTGR = high-temperature gas-cooled reactor.

NA = Not applicable.

2

 3 
Appendix G

Draft NUREG‒2157 G-14 September 2013

1 References

2 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

3 Production and Utilization Facilities.” Washington, D.C.

4 10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing 

5 Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

6 Waste, and Reactor-Related Greater than Class C Waste.” Washington, D.C.

7 CENG. 2010. Letter from T.L. Harding to NRC dated September 16, 2010, regarding “General 

8 License 30-day Cask Registration Notification.” Ontario, New York. Accession 

9 No. ML102670066.

10 Commonwealth Edison. 1993. Zion Station Updated Final Safety Analysis Report, Volume 3, 

11 Chicago, Illinois. Accession No. ML081370016.

12 Commonwealth Edison. 1998. Letter from R.S. Starkey to NRC dated November 10, 1998, 

13 regarding “Submittal of Defueled Safety Analysis Report.” Chicago, Illinois. Accession 

14 No. ML12300A258.

15 Dairyland (Dairyland Power Cooperative). 2012. Letter from J.B. McRill to NRC dated July 12, 

16 2012, regarding “Registration of Spent Fuel Dry Storage Cask in Use.” LAC–14245, Genoa, 

17 Wisconsin. Accession No. ML12199A069.

18 DOE (U.S. Department of Energy). 2007. Letter from B.J. Davis to NRC dated March 15, 2007, 

19 regarding “Submittal of Three Mile Island Unit 2 Independent Spent Fuel Storage Installation 

20 (TMI–2 ISFSI) Update Reports (Docket 72–20).” EM–FMDP–07–008, Idaho Falls, Idaho. 

21 Accession No. ML070820547.

22 Dominion (Dominion Energy Kewaunee, Inc.). 2013. Letter from D.G. Stoddard to NRC dated 

23 February 25, 2013, regarding “Certification of Permanent Cessation of Power Operations.” 

24 Serial No. 13–107, Glen Allen, Virginia. Accession No.ML13058A065.

25 Dominion (Dominion Nuclear Connecticut, Inc.). 2011. Millstone Power Station Unit 1 Defueled 

26 Safety Analysis Report. Revision 8.0, Waterford, Connecticut. Accession No.ML11231A618.

27 Duke (Duke Energy). 2013. Letter from J.A. Franke to NRC dated February 20, 2013, 

28 regarding “Crystal River Unit 3 - Certification of Permanent Cessation of Power Operations and 

29 that Fuel Has Been Permanently Removed from the Reactor.” 3F0213–07, Crystal River, 

30 Florida. Accession No. ML13056A005.
Appendix G

September 2013 G-15 Draft NUREG‒2157

1 FirstEnergy (First Energy Nuclear Operating Company). 2012. Letter from H.D. Hanson, Jr. to 

2 NRC dated October 23, 2012, regarding “Spent Fuel Storage Cask Registration.” L–12–383, 

3 Perry, Ohio. Accession No. ML12310A088.

4 NRC (U.S. Nuclear Regulatory Commission). 2004. Letter from J. Monninger to J.E. Ellis dated 

5 December 21, 2004, regarding “Issuance of Renewed Materials License No. SNM–2500, Morris 

6 Operation Independent Spent Fuel Storage Operation.” TAC No. L23091, Washington, D.C. 

7 Accession No. ML043630433 (package).

8 NRC (U.S. Nuclear Regulatory Commission). 2006. Letter from W.H. Ruland to J.D. Parkyn 

9 dated February 21, 2006, regarding “Issuance of Materials License No. SNM–2513 for the 

10 Private Fuel Storage Facility (TAC No. L23821).” Washington, D.C. Accession 

11 No. ML060450350 (package).

12 NRC (U.S. Nuclear Regulatory Commission). 2012. Information Digest, 2012–2013. 

13 NUREG–1350, Volume 24, Washington, D.C. Available at http://www.nrc.gov/reading-rm/doc14 collections/nuregs/staff/sr1350/. 

15 NRC (U.S. Nuclear Regulatory Commission). 2013a. “Operating Reactors.” Washington, D.C. 

16 Available at http://www.nrc.gov/reactors/operating.html. 

17 NRC (U.S. Nuclear Regulatory Commission). 2013b. “Combined License Applications for New 

18 Reactors.” Washington, D.C. Available at http://www.nrc.gov/reactors/new-reactors/col.html. 

19 NRC (U.S. Nuclear Regulatory Commission). 2013c. “Power Reactor Sites Undergoing 

20 Decommissioning.” Washington, D.C. Available at http://www.nrc.gov/info21 finder/decommissioning/. 

22 PFS (Private Fuel Storage, LLC). 2012. Letter from R.M. Palmberg to NRC dated December 

23 20, 2012, regarding “Termination of NRC License No. SNM–2513 for Private Fuel Storage 

24 LLC.” La Crosse, Wisconsin. Accession No. ML12356A063.

25 Progress Energy. 2010. Letter from P.N. Mentel to NRC dated November 18, 2010, regarding 

26 “Registration and Use of Casks to Store Spent Fuel and System Thermal Performance 

27 Assessment.” BSEP 10–0135, Southport, North Carolina. Accession No. ML103330167.

28 Ux Consulting Company, LLC (UXC). 2013. “Over 1700 Dry Storage Systems Deployed in the 

29 US.” StoreFUEL 14(173):14–173. Bethesda, Maryland. 

Appendix H

–

Estimated Costs of Alternatives

September 2013 H-1 Draft NUREG‒2157

Appendix H

Estimated Costs of Alternatives

1 This appendix provides the cost information upon which the U.S. Nuclear Regulatory 

2 Commission bases the cost portion of its costs and benefits analysis in Chapter 7 of this 

3 draft Waste Confidence Generic Environmental Impact Statement (draft GEIS). Tables H-1 

4 through H-3 provide the estimated costs of site-specific licensing reviews for new reactors, 

5 reactor license renewals, and independent spent fuel storage installations (ISFSI), respectively. 

6 Table H-4 provides estimated costs for generic elements of the alternatives, including costs for 

7 development of the draft GEIS, rulemaking, and a policy statement, as applicable. Finally, 

8 Table H-5 provides the total estimated costs for all alternatives.

 9 
Draft NUREG‒2157

H-2 September 2013

Table H-1. Estimated Site-Specific Costs for New Reactor Reviews 1

Cost per Activity(a) NRC Cost Licensee Cost(b) Total Cost(c)

First review $1,670,000 $1,670,000 $3,350,000

Existing review with supplement $1,000,000 $1,000,000 $2,000,000

Existing review without supplement $51,900 $51,900 $104,000

New review $51,900 $51,900 $104,000

Title 10 of the Code of Federal Regulations

(CFR) Part 50 review with supplement

$242,000 $242,000 $484,000

Year Activity(d) Number Constant 2013 3% Discount 

2015 First review 1 $3,350,000 $3,160,000 

2015 Existing review with supplement 2 $4,010,000 $3,780,000 

2015 10 CFR Part 50 review with supplement 1 $484,000 $457,000 

2016 Existing review with supplement 3 $6,010,000 $5,500,000 

2017 Existing review without supplement 2 $208,000 $184,000 

2018 New review 2 $208,000 $179,000 

Sum(c) $14,300,000 $13,300,000 

(a) As described in Chapter 7, the NRC estimates that the first site-specific review of continued storage in a new reactor environm

statement (EIS) would require approximately 3.9 full-time equivalents (FTE) for NRC and $1 million in contractor support. Th

that subsequent site-specific reviews that require supplementation of existing EISs require approximate 2.9 FTE for NRC and 

contract support. The NRC estimates that new-reactor reviews that do not require supplementation will require 0.3 FTE, or $5

estimates that a review of the environmental impacts of continued storage for a new operating license under 10 CFR Part 50 

(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

(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 (Un

all will require supplementation. One of these reviews will be the first review, and the others are labeled as existing reviews w

Watts Bar 2 is the 10 CFR Part 50 review with supplementation. The NRC assumes that North Anna and Turkey Point will no

supplementation as the NRC will not publish a final EIS by the end of fiscal year 2014; these two reviews are the existing revi

supplements. Bell Bend and the PSE&G Power, LLC/PSE&G Nuclear, LLC Early Site Permit are treated as new reviews bec

not likely to issue a draft EIS by the end of fiscal year 2014; the NRC assumes that the environmental impacts of continued st

addressed within a normal review schedule for those projects.

2
September 2013

H-3 Draft NUREG‒2157

Table H-2. Estimated Site-Specific Costs for Reactor License Renewals 1

Cost per Activity(a) NRC Cost Licensee Cost(b) Total Cost(c)

First review $433,000 $433,000 $865,000

Existing review with supplement $242,000 $242,000 $484,000

Existing review without supplement $190,000 $190,000 $381,000

New or subsequent renewal review $51,900 $51,900 $104,000

Year Activity(d) Number Constant 2013 3% Discount 

2015 First review 1 $865,000 $815,000 

2015 Existing review with supplement 2 $969,000 $913,000 

2016 Existing review with supplement 4 $1,940,000 $1,770,000 

2017 Existing review without supplement 3 $1,140,000 $1,010,000 

2017 Renewal review 1 $104,000 $92,200 

2017 Subsequent renewal 1 $104,000 $92,200 

2018 Renewal review 4 $415,000 $358,000 

2018 Subsequent renewal 1 $104,000 $89,500 

2019 Renewal review 3 $311,000 $261,000 

2019 Subsequent renewal 1 $104,000 $86,900 

2020 Renewal review 2 $208,000 $169,000 

2020 Subsequent renewal 1 $104,000 $84,400 

2021 Subsequent renewal 1 $104,000 $81,900 

2022 Subsequent renewal 1 $104,000 $79,600 

2023 Subsequent renewal 1 $104,000 $77,200 

2024 Subsequent renewal 1 $104,000 $75,000 

2025 Subsequent renewal 1 $104,000 $72,800 

2026 Subsequent renewal 1 $104,000 $70,700 

2027 Subsequent renewal 1 $104,000 $68,600 

2028 Subsequent renewal 1 $104,000 $66,600 

2
Draft NUREG‒2157

H-4 September 2013

Table H-2. Estimated Site-Specific Costs for Reactor License Renewals (cont’d) 1

Year Activity(d) Number Constant 2013 3% Discount 

2029 Subsequent renewal 1 $104,000 $64,700 

2030 Subsequent renewal 1 $104,000 $62,800 

2031 Subsequent renewal 1 $104,000 $61,000 

2032 Subsequent renewal 1 $104,000 $59,200 

2033 Subsequent renewal 1 $104,000 $57,500 

2034 Subsequent renewal 1 $104,000 $55,800 

2035 Subsequent renewal 1 $104,000 $54,200 

2036 Subsequent renewal 1 $104,000 $52,600 

2037 Initial or subsequent renewal 1 $104,000 $51,000 

2038 Initial or subsequent renewal 1 $104,000 $49,600 

2039 Initial or subsequent renewal 1 $104,000 $48,100 

2040 Initial or subsequent renewal 1 $104,000 $46,700 

2041 Initial or subsequent renewal 1 $104,000 $45,400 

2042 Initial or subsequent renewal 1 $104,000 $44,000 

2043 Initial or subsequent renewal 1 $104,000 $42,800 

2044 Initial or subsequent renewal 1 $104,000 $41,500 

Sum(c) $8,860,000 $7,180,000 

(a) As described in Chapter 7, the NRC assumes that the first review would require an estimated 2.5 FTE, or $433,000. The NR

that some reviews would require supplementation of existing EISs, and these reviews would require approximately 1.4 FTE, 

Reviews that do not require supplementation would require approximately 1.1 FTE, or $190,000. Reviews of future applicatio

have not yet been submitted) would require approximately 0.3 FTE, or $51,900.

(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

(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 In

require supplementation given current project schedules. One of these reviews would be the first review. The NRC assumes 

Byron, and Braidwood will be existing reviews that do not require supplements by the end of fiscal year 2014. Diablo Canyon

(Unit 2), Riverbend, La Salle, Perry, Clinton, two facilities in the STARS (Strategic Teaming and Resource Sharing) Alliance, 

are labeled as new license renewal reviews because the NRC will be able to address the environmental impacts of continued 

normal review schedule for those projects. The NRC has not identified specific plants that will seek subsequent license rene

that half of the existing reactor fleet will do so.

2
September 2013

H-5 Draft NUREG‒2157

Table H-3. Estimated Site-Specific Costs for ISFSI Licensing 1

Cost per Activity(a) NRC Cost Licensee Cost(b) Total Cost(c)

First renewal review $86,500 $86,500 $173,000

Renewal review $43,300 $43,300 $86,500

Year Activity(d) Number Constant 2013 3% Discount 

2015 First renewal review 2 $346,000 $326,000 

2018 Renewal review 1 $86,500 $74,600 

2019 Renewal review 2 $173,000 $145,000 

2020 Renewal review 1 $86,500 $70,300 

2022 Renewal review 1 $86,500 $66,300 

2024 Renewal review 1 $86,500 $62,500 

2025 Renewal review 1 $86,500 $60,700 

2026 Renewal review 2 $173,000 $118,000 

2032 Renewal review 1 $86,500 $49,300 

Sum(c) $1,210,000 $973,000 

(a) As discussed in Chapter 7, the NRC estimates that approximately 0.5 FTE, or $86,500, would be necessary to support site-

consideration of Waste Confidence matters in the first two ISFSI Environmental Assessments, both of which are currently u

NRC estimates that later ISFSI Environmental Assessments will require 0.25 FTE, or $43,300.

(b) The NRC assumes that licensees incur costs that are equal to those incurred by the NRC, so the total cost is double the NR

(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 

Island, are docketed at the NRC. Therefore, the NRC assumes that these reviews will be the first reviews. Other site-spec

that will expire during the 30-year analysis period are North Anna (2018), Three Mile Island Unit 2 (2019), Trojan (2019), Ra

(2020), GE Morris (2022), Diablo Canyon (2024), Idaho Spent Fuel Facility (calendar year 2024, but fiscal year 2025), Hum

(calendar year 2025, but fiscal year 2026), Private Fuel Storage (2026), and Fort St. Vrain (calendar 2031, but fiscal 2032). 

with site-specific ISFSIs do not require renewal by 2044. See Appendix G for more information on ISFSIs.

2
Appendix H

Draft NUREG‒2157 H-6 September 2013

Table H-4. Estimated Costs of Generic Elements(a) 1

GEIS Development (applies to all alternatives except No Action)

FTE(b) Contractor Total

Annual Cost 20 $3,000,000 $6,460,000

Year(c) Constant 2013 3% Discount 7% Discount

2013 $6,460,000 $6,460,000 $6,460,000

2014 $6,460,000 $6,270,000 $6,040,000

Sum(d) $12,900,000 $12,700,000 $12,500,000

Rulemaking (applies to the Proposed Action)

FTE(b) Contractor Total

Annual Cost 3 $0 $519,000

Year(c) Constant 3% Discount 7% Discount

2013 $519,000 $519,000 $519,000

2014 $519,000 $504,000 $485,000

Sum(d) $1,040,000 $1,020,000 $1,000,000

Policy Statement (Applies to the Policy Statement alternative)

FTE(b) Contractor Total

Annual Cost 2 $0 $260,000

Year(c) Constant 3% Discount 7% Discount

2013 $260,000 $260,000 $260,000

2014 $260,000 $252,000 $243,000

Sum(d) $519,000 $511,000 $502,000

(a) Generic elements are those portions of the alternatives that are not directly attributable to any 

site-specific review.

(b) One FTE costs $173,000.

(c) The NRC assumes that the effort necessary to develop generic elements occurs during fiscal years 

2013 and 2014.

(d) Due to rounding, some costs may not appear to sum correctly.

2
Appendix H

September 2013 H-7 Draft NUREG‒2157

1 Table H-5. Total Estimated Costs of Alternatives

No Action Alternative (site-specific reviews)

Constant 2013 3% Discount 7% Discount

New reactor reviews $14,300,000 $13,300,000 $12,100,000

Reactor license renewal $8,860,000 $7,180,000 $5,790,000

ISFSI licensing $1,210,000 $973,000 $755,000

Total Cost(a) $24,300,000 $21,400,000 $18,600,000

Proposed Action (no site-specific reviews)

Constant 2013 3% Discount 7% Discount

GEIS $12,900,000 $12,700,000 $12,500,000

Rulemaking $1,040,000 $1,020,000 $1,000,000

Total Cost(a) $14,000,000 $13,800,000 $13,500,000

GEIS-Only Alternative (site-specific reviews; possible cost savings)

With No Cost Savings(b) Constant 2013 3% Discount 7% Discount

New reactor reviews $14,300,000 $13,300,000 $12,100,000

Reactor license renewal $8,860,000 $7,180,000 $5,790,000

ISFSI licensing $1,210,000 $973,000 $755,000

GEIS development $12,900,000 $12,700,000 $12,500,000

Total Cost(a) $37,300,000 $34,100,000 $31,100,000

With 50% Cost Savings(b) Constant 2013 3% Discount 7% Discount

New reactor reviews $7,180,000 $6,670,000 $6,070,000

Reactor license renewal $4,430,000 $3,590,000 $2,900,000

ISFSI licensing $606,000 $486,000 $378,000

GEIS development $12,900,000 $12,700,000 $12,500,000

Total Cost(a) $25,100,000 $23,400,000 $21,800,000

Policy Statement Alternative (site-specific reviews; possible cost savings)

With No Cost Savings(b) Constant 2013 3% Discount 7% Discount

New reactor reviews $14,300,000 $13,300,000 $12,100,000

Reactor license renewal $8,860,000 $7,180,000 $5,790,000

ISFSI licensing $1,210,000 $973,000 $755,000

GEIS development $12,900,000 $12,700,000 $12,500,000

Policy statement $519,000 $511,000 $502,000

Total Cost(a) $37,800,000 $34,600,000 $31,600,000

2
Appendix H

Draft NUREG‒2157 H-8 September 2013

1 Table H-5. Total Estimated Costs of Alternatives (cont’d)

Policy Statement Alternative, cont’d

50% Cost Savings(b) Constant 2013 3% Discount 7% Discount

New reactor reviews $7,130,000 $6,630,000 $6,030,000

Reactor license renewal $4,430,000 $3,590,000 $2,900,000

ISFSI licensing $606,000 $486,000 $378,000

GEIS development $12,900,000 $12,700,000 $12,500,000

Policy statement $519,000 $511,000 $502,000

Total Cost(a) $25,100,000 $23,400,000 $21,800,000

(a) Due to rounding, some costs may not appear to sum correctly.

(b) The NRC estimates that staff and applicants may reduce their efforts by as much as 50% 

compared to the No-Action alternative in both the GEIS-only and Policy Statement alternatives. 

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.

2 References

3 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

4 Production and Utilization Facilities.”

5 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

6 Certifications, and Approvals for Nuclear Power Plants.”

7 10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing 

8 Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 

9 Waste, and Reactor-Related Greater than Class C Waste.”

10 Office of Management and Budget (OMB). 2003. Circular A-4: Regulatory Analysis. 

11 NRC000060, Washington, D.C. Accession No. ML11231A834.

12



UNITED STATES 

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

--------------------

OFFICIAL BUSINESS
NUREG

-2157

Draft

Waste Confidence Generic Environmental Impact Statement