FAQs 2018-07-03T08:38:52+00:00

FAQs

What is a consolidated interim storage facility?
A consolidated interim storage facility, or CISF, securely stores used nuclear fuel either above or below ground in one facility until it can be transported to a permanent fuel repository. It provides a near-term interim solution that significantly reduces taxpayer costs and the security requirements for 70+ storage sites that currently exist around the U.S.

When will it open?
Though we included a planned start date in the application, it’s a bit early in the review process to have a definitive date.

Is this CISF legal under current U.S. law?
Private development of the proposed ISP consolidated interim storage facility is not likely to require a change to any existing U.S. laws.

How is this project different from the one in New Mexico?
Details about the proposed New Mexico CISF can be found on the NRC’s website.

Who is Orano?
Orano USA is a subsidiary of the global company Orano, with more than 700 employees located across the U.S. Headquartered in Washington, D.C., the company is an international leader in decommissioning shutdown nuclear energy facilities, used fuel management, federal site cleanup and closure, and the sale of uranium, conversion, and enrichment services to the U.S. commercial and federal markets. Its Orano Med nuclear medicine business is developing targeted radioactive isotopes for removing hard-to-treat cancers. Orano has more than three decades of experience in decontaminating and dismantling nuclear facilities, and more than 50 years’ experience in transporting and storing used nuclear fuel (UNF) and radioactive materials. Orano USA was previously known as AREVA Nuclear Materials.

Who is WCS?
Waste Control Specialists (WCS) has been a vital and trusted member of the Andrews, Texas, community for more than 20 years, providing a one-stop location for the treatment, storage and disposal of low-level radioactive waste (LLRW) and mixed low-level radioactive waste. Its licensed 1,338-acre facility is part of a 14,900-acre site in western Andrews County. Located on a 600-ft. thick nearly impermeable red-bed clay formation, the WCS site ensures safe and permanent disposal of low-level radioactive waste by taking advantage of this unique natural barrier. The company provides vital disposal services at its Compact Waste Facility (CWF) for generators of LLRW in Texas and 34 other states. Such waste generators include nuclear power facilities, hospitals and research centers. WCS provides similar disposal options for the U.S. Department of Energy at its Federal Waste Facility (FWF) and at its Byproduct Waste Facility. In January 2018, WCS was acquired by J.F. Lehman & Co.

Who is NAC/What is NACs role in the proposed storage project?
NAC International has more than 30 years of experience in providing a wide range of services and equipment to the nuclear industry. This experience includes a quarter century in designing, engineering, licensing, operating, and maintaining used fuel management systems for storage and transport.

What are the roles of the participants (Orano USA, WCS and NAC International) in the proposed storage project?
Orano USA and Waste Control Specialists (WCS) have established a Joint Venture to pursue a license from the Nuclear Regulatory Commission (Part 72) for consolidated storage of commercial used nuclear fuel (UNF) at WCS’ site in Andrews, TX, using Orano TN’s and NAC International’s dry fuel storage systems. The Orano TN NUHOMS® used fuel storage system is used at more than 30 sites across the country, including at shutdown nuclear energy facilities in California, Wisconsin, and Connecticut. NAC’s transportable used fuel storage technologies are among the most widely deployed multipurpose canister systems in the United States, with more than 550 canisters in place at commercial operating or decommissioned nuclear energy facilities.

What is the joint venture called?
The joint venture developing the consolidated interim storage facility at WCS is Interim Storage Partners (ISP). This private-sector storage solution combines the necessary technical and proven experience of both companies, leveraged by a local, presence that is actively engaged in the community and in Texas. ISP’s proposed CISF would add additional capabilities to the national UNF management system while mitigating the taxpayer liabilities that occur with used fuel storage at numerous shutdown, decommissioned and operating nuclear energy facilities around the country.

What is used nuclear fuel and how is it prepared for transport?
Used nuclear fuel is made up of small diameter ceramic pellets contained in long metal-alloy rods bound into rectangular arrays called assemblies that were placed in the reactor to generate energy. To transport these used fuel assemblies, 24 – 61 assemblies are secured inside a metal-alloy “basket” crate sealed within a large canister with 1/2 – 5/8-inch-thick stainless steel walls protected by a robust NRC-certified heavy walled transport cask. The casks are specifically engineered to keep their sealed integrity during extreme circumstances, such as when subjected to hypothetical accident conditions such as a series of drops, sustained thousand-plus-degrees fully engulfing fire and when immersed for long durations under water.

Isn’t this just the first step to reprocessing the fuel?
No, the United States does not currently reprocess used nuclear fuel, even though other countries have operated a complete nuclear fuel cycle for decades and re-use 96% of the used nuclear fuel material as new nuclear fuel.

How will the used nuclear fuel be stored at WCS?
ISP will use currently licensed Orano TN and NAC International Storage Systems. The storage systems consist of large welded stainless steel canisters, which contain the used nuclear fuel, placed inside and protected by robust concrete storage overpacks. The used fuel is contained within the same welded stainless steel canister for both transport and storage. The above-ground, concrete storage overpacks simplify the used fuel canister placement, inspection access for the Aging Management Program (AMP), and eventual retrieval for transport to a permanent federal repository. The AMP is designed to perform inspections and identify potential degradation in the storage system long before the safe operation of the system is affected.

How long will fuel be stored at the proposed consolidated interim storage facility?
Building a consolidated interim storage facility, or CISF, allows the U.S. to better optimize the storage and management of UNF; it does not replace the need for a permanent geologic repository. The Yucca Mountain project – or other national repository that would provide a permanent storage solution – needs to first proceed through licensing and then begin operations, but this may require an extended period of time. The CISF provides a near-term interim solution that significantly reduces taxpayer costs and the security requirements for 70+ storage sites. Until the permanent federal facility is ready, we can safely store the UNF at the CISF for 100 years or more, if necessary, using the NRC-required “learning” Aging Management Program (AMP). This learning AMP continuously evaluates and adjusts the used fuel management process to address any concerns identified during the regular inspections.

Who is going to regulate the new facility?
The Nuclear Regulatory Commission is responsible for reviewing and issuing a Part 72 license to operate a consolidated interim storage facility at the WCS site. The licensing and regulatory process is a thorough and lengthy process evaluating and ensuring the safety of the facility and the environment. During the facility’s design, construction and operations, the NRC will perform regular inspections in their oversite role.
The State of Texas maintains active oversight of the existing WCS site and operations through the Texas Commission on Environmental Quality (TCEQ). TCEQ regulates all current site operations at the WCS facilities in Andrews County and Texas may direct that TCEQ monitor the new CIS facility as well.

You will be storing UNF from all over the United States. Shouldn’t this new CISF be more robust than those constructed at the power plants in order to hold a large quantity?
The design and certification for the existing NRC-licensed storage systems at sites located across the nation must often take into account even more severe weather (i.e. wind/tornado, earthquake, flooding, etc.) than the environmental range of conditions at the west Texas site. Therefore, moving the fuel to the WCS Andrews site reduces the environmental risk to the stored used nuclear fuel. Regarding the quantity of stored fuel: Since each used fuel canister is stored in its own robust overpack, any concern with one canister would not affect the security or containment of fuel stored in other canisters. To be clear, used nuclear fuel in dry storage is not volatile or explosive, and the dry storage components are engineered to securely contain and cool the used fuel sealed within.

WCS is designed to handle low-level waste. How can it handle high-level used nuclear fuel and radioactive waste, and isn’t that a danger to the community?
The proposed CISF is a separate facility next to the existing WCS Operational area, with its own security fences and access control. Interim Storage Partners brings together the combined capabilities of Orano WCS, and NAC International. Orano has more than 50 years’ experience safely transporting and storing used nuclear fuel, and globally transports more than 200 casks every year. Orano has more than 30 years’ experience in the U.S. in safe management and transport of used nuclear fuel. NAC has more than 30 years of experience in providing a wide range of services and equipment to the nuclear industry. This experience includes a quarter century in designing, engineering, licensing, operating, and maintaining used fuel management systems for storage and transport. The WCS Andrews facility is one of a very few number of facilities where there is an existing workforce already experienced in handling radioactive waste.

WCS, Orano and NAC International maintain outstanding, well-trained workforces with a strong and effective safety culture and experience in all nuclear protocols. The facility’s design, geographic features, and trained personnel combined with the technical and proven experience of both joint venture companies ensures that Andrews County and the surrounding communities will see the same high quality in ISP’s operations securely managing used nuclear fuel as they currently experience with the handling and storage of low-level waste.

How can you say this is interim storage when there is no current disposal option for used nuclear fuel? What is your definition of interim?
We are not seeking a license for a permanent used nuclear fuel storage facility. When granted, our NRC license is for operating a consolidated interim storage facility for 40 years. After that duration, we must submit a renewal for license extensions in 20-year increments. As we have said before, we expect the ISP CISF to be operational for up to 100 years.

WCS still has waste stored on site from the WIPP that was only supposed to be stored for less than one year. How can you be confident that this waste will ever leave?
According to the regulations governing the operations of our facility, we cannot retain the waste destined for WIPP without the waste owner requesting regulatory approval of additional limited durations. We have been working with the regulatory agencies and the Department of Energy and we have shipped over half of the waste that was being stored to the WIPP facility. We will continue to work with all parties to ensure the remaining waste will be shipped safely and compliantly for final disposal.

What economic benefit is there for Andrews and surrounding communities to store this waste?
Using WCS’ current operations as an example, the economic investment and contributions have been significant for Andrews County. Using the latest fiscal year figures available (as of April, 2018):

  • WCS employs 160 individuals at its Andrews site with an annual payroll of more than $15 million.
  • WCS has invested more than $300 million in the county developing fixed assets , and has paid approximately $235 million in payroll to employees living in Andrews County and the region (Permian Basin, Lea County).
  • The company contributes approximately $50,000 every year in community and charitable programs.
  • Andrews County and the State of Texas each receives a percent of the gross revenue from WCS LLRW disposal activities at the CWF and FWF facilities. WCS makes quarterly payments to the state and county.
  • Andrews County received its first direct payment of disposal revenue fees in June 2012.
    • Andrews County received approximately $8.1 million fee revenues for four years of disposal operations.
    • The State of Texas received approximately $43.5 million in disposal fees since operations began.

How many additional employees will be hired?
At a minimum there will be the addition of a security force during operation and a small number of additional full time positions. During construction there will be a significant temporary workforce required at the site.

Will Orano be manufacturing any of these storage systems locally?
Yes, the massive reinforced concrete storage overpacks will be manufactured onsite.

Why has this part of the state been chosen to store nuclear waste that it seems no one else wants?
The geologic site suitability and informed community support have been and remain the primary criteria for selecting the WCS site as the ISP CISF location. The unique aspects of the WCS site enable the secure handling and storage of nuclear materials in an environmentally safe manner, while also providing economic benefits to the regional community. The WCS Andrews facility is one of a very few number of facilities where there is an existing workforce experienced in handling radioactive materials, with a community that understands and supports these operations. WCS is situated in an arid, less-populated part of Texas atop a thick bed of natural red clay that is 10-times less permeable than concrete and that stretches more than 600 feet below the surface. Even so, WCS operates an extensive monitoring program to ensure the continued safety of the community and environment at all times.

There are no nuclear power plants in the West Texas / Eastern New Mexico area. Why should we have to deal with the storage of UNF?
WCS is one of the best geologic sites in the country for the interim storage of used nuclear fuel. Both Texas and New Mexico receive power from nuclear power plants. The storage of used nuclear fuel scattered around the country today, including in Texas, is a growing national concern and a significant expense to all taxpayers. By consolidating storage at WCS, we will provide a secure location using proven technology, and manage the stored fuel much more efficiently. Each of us, as federal taxpayers, also benefits from this approach. Since the Department of Energy is unable to fulfill its legal obligation to remove the used fuel from the many current storage sites, the utility owners have had to litigate against the DOE to recover their costs for continuing to store the used fuel onsite. This taxpayer liability is expected to total $27.1 billion by 2021 if the DOE does not take ownership of the material.
WCS facilities are situated in an arid, isolated part of the state atop natural red clay that is 10x less permeable than concrete and that stretches more than 600 feet below the surface. The WCS site operates an extensive monitoring program to ensure the safety of the community and environment at all times. The facility also has an experienced workforce and safety record, and the local communities have seen firsthand the safe handling and storage of nuclear waste.

Texas and New Mexico don’t want these storage sites.
WCS has been a strong corporate citizen of the Andrews, Texas, community for more than 20 years. The partnership between WCS and the region built on education, open communication and trust has enabled residents to understand and appreciate the nuclear waste storage process and the economic benefits of securely managing this material. As Interim Storage Partners begins to develop the interim storage site, ISP will continue WCS’ tradition of transparency while bringing increased opportunities and benefits to the region.

How will the UNF be transported?
The Department of Energy is still evaluating a number of different methods, but we expect the primary mode of transport will be by rail and include access to the WCS site’s existing railroad infrastructure.

How many shipments are expected each year?
During the first year of operations, we expect to receive less than five shipments. After the first year, shipments will eventually grow to approximately 50 per year.

Is it safe to move this fuel?
Yes, it is safe. The movement of used nuclear fuel has an exemplary track record of safety, and far exceeds the standards for quality and protection required for other hazardous materials using the same rail infrastructure. Since 1965, more than 2,700 shipments of used fuel have been safely transported nearly 2 million miles across the United States – and there has never been a radiological release caused by a transportation accident. Most used nuclear fuel is shipped by rail and requires prior NRC approval and notifications to local officials. The NRC and Department of Transportation determine the most direct route, taking into consideration large cities and any geographic transport concerns. We will use dedicated trains to move the used nuclear fuel. To move the used fuel from an existing nuclear energy facility’s onsite storage to the CISF, the canisters are placed inside an NRC-certified transport cask for shipment primarily by rail. Once the transport cask arrives at the Cask Handling Building at the CISF, the internal canister is transferred to a concrete overpack on the storage site.

Globally, more than 200 casks are transported every year, with a total of nearly 10,000 used fuel casks having been delivered. With the ISP CISF concept, we are effectively transferring a canister from a concrete storage module at a reactor site to a concrete storage module at the ISP site.

What are the expected transportation routes?
ISP will work with the railroad operators, route states, the Department of Transportation, and other stakeholders to identify, designate, and prepare the rail routes for shipments.

What if there is an accident during transport?
Regardless of transportation method, there has never been an accident in which these NRC-certified transport casks containing radioactive materials have been breached. Worldwide, there are more than 200 shipments of used fuel every year. In France, alone, more than 9,400 used fuel transport casks have been delivered to the La Hague recycling facility. Even with the greater frequency of transport in Europe, there have only been two incidents involving used fuel transport casks. In one case, there was a derailment and, in the second case, a used fuel transport rolled off the tracks. In both cases, the robust used fuel transport casks maintained their sealed integrity and operational capability: the casks were lifted back onto the rails and the shipments completed.

Everything about the transport of used nuclear fuel is designed to significantly reduce the likelihood of an accidental radioactive release from the robust transport cask. Since used nuclear fuel is a solid – not a liquid – it is also very unlikely to leak or come out of the numerous defense-in-depth barriers. The 2014 NRC study determined that there is less than a one in a billion chance that radioactive materials would be released in an accident.

The casks are too heavy for our nation’s infrastructure! Even some railroad workers have admitted that.
This claim is simply not true. Though some rail infrastructure may not be able to handle heavy loads, the rail routes for transporting the used fuel casks to the CISF will be certified for handling the weight. WCS has already received 400-ton steam generators via rail shipment. The NRC-licensed transportation casks with the loaded canisters are significantly lighter than the steam generators.

Why move the fuel at all?
The Department of Energy (DOE) has a legal obligation to remove used nuclear fuel from the original reactor sites where it was generated. Every year that the fuel remains at sites scattered throughout the U.S., it costs taxpayers more money. Utilities litigate against the Department of Energy to recover damages resulting from DOE’s failure to meet contractual obligations and begin removal. The DOE’s liabilities due to ongoing partial breach of contract are estimated to total $27.1 billion if the DOE cannot take custody of the material by 2021. The communities where these storage sites are located would benefit from removing the fuel and restoring what are often prime industrial sites for new economic development and revenues. The proposed ISP consolidated storage site also reduces the security costs of monitoring fuel stored at 70+ sites nationwide.

Isn’t the HOSS system a far less risky solution?
Some have proposed leaving the scattered fuel in storage where it is and converting the existing used fuel storage sites into what’s been termed Hardened OnSite Storage, or HOSS. This approach would only spend unnecessary effort and resources to add redundant features to a site already designed and certified as secure and protected – and it adds no economic potential to the dormant industrial site. The suggested benefit of not having to move the used fuel misses the fact that we move used fuel like this safely and securely all over the world. There is not a compelling safety or economic reason to leave stranded fuel sitting in these communities on industrial property, where it requires dedicated security and monitoring infrastructure at each site that is then replicated at multiple additional sites across the United States.

Why not use the money to pay communities that inherited waste from shutdown plants that have to store and secure it anyway, instead of using it to build a consolidated facility and then proceed with risky cross-country transport?
There are several issues with keeping the used fuel where it currently resides in more than 70 communities around our country; for one thing, the expenses to maintain and secure the storage site would continue until a federal repository eventually opens. In the same way, scattered storage would continue the need for high-level security at multiple sites throughout the country.

The facts do also not bear out a claim of risky transport. Regardless of transportation method, there has never been an accident in which these NRC-certified transport casks containing radioactive materials have been breached. Everything about the transport of used nuclear fuel has been designed to significantly reduce the likelihood of an accidental radioactive release, including the railcar, the robust transport cask, and even the selected transport railway.

And finally, not creating the consolidated interim storage site allows the unmitigated growth of taxpayer liabilities and prevents economic development in a community that welcomes the facility and its mission.

Is there a radiation risk to people and surrounding communities from the additional storage at WCS of used nuclear fuel canisters?
No. Currently at WCS, the average potential man-made exposure for employees working onsite is less than 5 mrem/yr. Even with the addition of the interim used fuel storage site, a person’s exposure leaning against a storage module containing a used fuel canister is less than the regulatory limit of 25 mrems/yr. Radiation exposure at the WCS site boundaries is indistinguishable from the region’s natural background radiation level.

How can you guarantee that the storage systems will not leak?
Everything about the transport and storage of used nuclear fuel has been designed to significantly reduce the likelihood of an accidental radioactive release. Since used nuclear fuel is a solid – not a liquid – it is also very unlikely to leak or come out of the numerous defense-in-depth barriers. To securely store the used fuel, the canisters are placed and sealed inside individual massive concrete modules. The above-ground, storage overpacks simplify the used fuel canister placement, inspection access for the Aging Management Program (AMP), and eventual retrieval for transport to a permanent federal repository.

We have heard that this used fuel is the most radioactive and harmful waste there is. How do I know that my family and I are protected?
We are regularly handling and transferring these canisters full of used nuclear fuel for utilities all over the country, and we have a personal interest in making sure the men and women working for us are protected, along with the surrounding communities. Ensuring radioactive material is isolated inside the canisters is accomplished through advanced materials science, precision engineering, and layered protection, not just thickness. Beginning inside, the first layer important to isolation is the canister’s basket with fixed neutron absorbers to maintain the used fuel in a known geometry. The canister’s stainless steel shell provides the main isolation barrier with carbon steel shield plugs at the ends and is sealed at the top end by two welded stainless steel lids providing redundant barriers to prevent leakage. Also, the used fuel canisters are always inside the additional barrier of another overpack, adding more layers of protection. During transportation, the transport cask surrounding the canister is specifically engineered with multiple barriers, including containment boundary, structural shell, gamma shielding material, and solid neutron shield. When the canister arrives at the ISP facility, the canister is transferred to its massive concrete storage overpack. The concrete storage overpack provides both physical protection and shielding for the canister inside to ensure any doses on and around the storage pads are well within exposure regulations.

What about fuel that is damaged or high burn-up fuel?
The storage and transportation systems are designed and licensed to safely handle high burn-up and damaged fuel. In France alone, more than 21,000 High Burn-up used fuel assemblies have been safely delivered to the La Hague reprocessing facility without incident.

Is there a radiation risk to people and communities during the transport of casks containing used nuclear fuel?
No, there is very little risk from the transport casks to people or communities. We take our transportation responsibilities seriously and have extensively researched and tested for risks during the transport of used nuclear fuel, and implemented best practices to ensure secure and safe transport. We also comply with all regulations and oversight by the Nuclear Regulatory Commission and the US Department of Transportation among others. The NRC published a study in 2014, Spent Fuel Transportation Risk Assessment, which modeled any radiation doses people might receive from used nuclear fuel during transport. The results from this research determined that “doses from routine transport would be less than 1/1000 the amount of radiation people receive from background sources each year” (NRC).

Radiation is a natural part of our environment, and our bodies automatically manage our normal exposure. The normal exposure we all receive every day from “background sources” includes naturally occurring radon in our air, cosmic rays, radioactive rocks (granite) and soil, and even plants and food that are naturally high in potassium or other radioactive elements (bananas, carrots, avocados, Brazil nuts). The other normal background sources of radiation exposure are man-made, such as basic medical procedures and consumer products. Background radiation is measured in millirems per year (mrem/yr). The average person receives a background radiation dose of 620 mrem/yr: 310 mrem from natural exposure and 310 from man-made exposure. As stated by the Nuclear Regulatory Commission, “In general, a yearly dose of 620 mrem/yr from all radiation sources has not been shown to cause humans any harm.”

What about people who get stuck next to a stopped train that’s transporting fuel? What if it’s a pregnant woman or someone who shouldn’t be exposed to radiation?
Being stopped next to a transport cask of used nuclear fuel, even for hours, would not expose anyone to a harmful amount of radiation – and likely not any more exposure than the normal background radiation amount for that area.

We take our transportation responsibilities seriously. The transport cask is specifically engineered to comply with strict regulations to securely and safely transport this type of used nuclear fuel without harming the public or the transport employees. Radiation exposure is measured in millirem (mrem), and radiation levels are easily measured to the most miniscule amount. Our monitoring procedures during transport ensure we meet all of our safety and security requirements.

Every day, we all receive radiation exposure from normal, natural sources in the world around us, including radon in the air, cosmic rays, and the naturally radioactive food we eat, like bananas, carrots, avocados and potatoes – and our bodies automatically deal with it without suffering harm. The average person receives a dose of 620 mrem per year from naturally occurring and manmade sources.

Though the containers are shielded, the Nuclear Regulatory Commission acknowledges that the penetrating gamma rays can be detected over a half mile from the containers (900 meters or 0.56 miles).

Background sources of naturally occurring radiation is significantly higher contributors to the dose an individual would receive from one of the containers. NRC regulations maintain strict limits for CISF workers and any visiting members of the public. The onsite doses and dose rates on site and around the Storage Overpacks are well within these limits.

What will the security be like?
As with the existing multiple storage sites at operating and shutdown U.S. nuclear energy facilities, security will be very strict, comprehensive, and proactive with training and armaments. The massive reinforced concrete storage modules with bolted shut enclosures are themselves a substantial security barrier, and can withstand an aircraft impact without compromising the internal canisters’ sealed integrity and isolation of the radioactive material from the environment. The canister with welded stainless steel double lids cannot be easily extracted without specialized equipment, and even that process requires a few hours.

With a large portion of the U.S. used nuclear fuel stored in one location, wouldn’t this become a prime target for terrorism?
The proposed CISF will implement security programs to detect and respond to intrusions, and promptly engage offsite assistance when necessary – something WCS currently has in place. As with the existing multiple storage sites at operating and shutdown U.S. nuclear energy facilities, site security is integrated with local, state and federal law enforcement.

Following the terrorist attacks on September 11, 2001, the NRC began working closely with the country’s security experts to review the capabilities of any potential adversaries and any possible threats to U.S. used nuclear fuel during transport or storage, such as sabotage, diversion and theft. Over the nearly two decades since, no known or suspected sabotage against used nuclear fuel casks or storage facilities has been detected or suspected.

How do you plan to protect against a cyberattack?
The Storage Systems are designed to be completely passive systems that do not require any electronic parts and are not connected to computers or the internet. Therefore, they are immune to a cyberattack.

The containers are too thin! How can they possibly offer enough protection?
We are regularly handling and transferring these canisters full of used nuclear fuel for utilities all over the country, and we have a personal interest in making sure we’re protected. Ensuring radioactive material is isolated inside the canister is accomplished through advanced materials science, precision engineering, and layered protection, not just thickness. Beginning inside, the first layer important to isolation is the canister’s basket with fixed neutron absorbers to maintain the used fuel in a known geometry. The canister’s stainless steel shell provides the main isolation barrier with carbon steel shield plugs at the ends and is sealed at the top end by two welded stainless steel lids providing redundant barriers to prevent leakage. Also, the used fuel canisters are always inside the additional barrier of another overpack, adding more layers of protection. During transportation, the transport cask surrounding the canister is specifically engineered with multiple barriers, including containment boundary, structural shell, gamma shielding material, and solid neutron shield. When the canister arrives at the ISP facility, the canister is transferred to its massive concrete storage overpack. The concrete storage overpack provides both physical protection and shielding for the canister inside to ensure the doses on and around the storage pads are well within exposure regulations.

Your casks are only designed to store fuel for 20-30 years, so how can you say you can safely store it for 40, 60 or even 120 years?
This will be – and is required by NRC regulations to be – an actively managed and monitored storage site. This means conducting regularly scheduled inspections of the external storage modules and the stored canisters. The above-ground, storage overpacks simplify the used fuel canister placement, inspection access for the learning Aging Management Program (AMP) for each system deployed at the CISF. During each license renewal the data gathered from the learning AMPs will be evaluated and additional AMPs will be defined as necessary to endure the continued safe storage at the CISF, and eventual retrieval for transport to a permanent federal repository. Any concerns will be analyzed and, if needed, the existing canister could be inserted and sealed inside a new larger canister, and placed back in the storage module. The above-ground modules also make external and internal inspections a simplified process. The AMP and license renewal process ensures there will be no abandoned used nuclear fuel on this site.

The testing is inadequate. As some recent fires have shown, they can burn hotter than 1475 degrees Fahrenheit and can definitely burn longer than 30 minutes. Also your submersion and impact tests don’t account for other scenarios, such as deeper and longer submersions and impacts from different angles.”
Used nuclear fuel transportation package designs are very robust and compliant with all scenario regulations to ensure public health and safety are always protected. If a possible transport route has the potential for an extreme event beyond the transport package’s design certification, then that route cannot be used. Package testing for extreme events and impacts focuses on the comparably least protected parts of the container to certify that these areas will withstand the strain and ensure that the materials sealed in the package will remain securely contained.

  • Transportation Package designs are very robust and provide reasonable assurance that public health and safety are always protected.
  • There have been thousands of used nuclear fuel transports throughout the world with an impeccable safety record.
  • The Part 71 regulations contain a series of tests that the transportation package needs to withstand before NRC will award a Transportation License to that used fuel package.
  • The test sequence and test parameters and conditions are selected such that it includes all the possible normal and hypothetical accident conditions the package is supposed to experience during transportation.
  • Tests were carried out on scaled transportation packages simulating missile impacts and even aircraft crashes to demonstrated that the regulatory exposure limits are not exceeded.
  • The analysis codes and models and methodology used for the package safety analysis are benchmarked against scaled model testing applicable to the package design under consideration.
  • The transportation routes are evaluated for conditions that would be covered by the package certification tests used at the time of initial license. If a given route has the potential to subject the package to parameters more severe than the initial licensing evaluation, that route is forbidden from use.
  • The impact from different angles is bounded by the condition of the impact surface (unyielding surface) and the series of impact angles chosen during the initial certification tests.
  • What if” analyses are carried out to subject packages to beyond design basis events like the Baltimore Tunnel Fire to demonstrate that Transport Package designs are very robust and there will not be any release of radioactive material that would exceed the dose rate limits specified in 10 CFR 71.51 for accident condition and the environment. The health and safety of the public is protected. See the NRC evaluation documented in NUREG/CR-6886, Rev 1—PNNL-15313 report “Spent Fuel Transportation Package Response to the Baltimore Tunnel Fire Scenario.” November 2006.

Even if the location of the proposed CISF at WCS isn’t directly over the aquifer, it is just too close. How can you guarantee the safety of the drinking water in the future?
NRC regulations require an actively managed and monitored storage site. This means conducting regularly scheduled inspections of the external storage modules and the stored canisters. The above-ground, storage overpacks simplify the used fuel canister placement, inspection access for the learning Aging Management Program (AMP) for each system deployed at the CISF. During each license renewal the data gathered from the learning AMPs will be evaluated and additional AMPs will be defined as necessary to endure the continued safe storage at the CISF, and eventual retrieval for transport to a permanent federal repository. Any concerns will be analyzed and, if needed, the existing canister could be inserted and sealed inside a new larger canister, and placed back in the storage module. The above-ground modules also make external and internal inspections a simplified process.

WCS has an extensive monitoring program with more than 400 monitoring wells to ensure the safety of the community and environment at all times, and files both monthly and quarterly reports to the TCEQ.

Potential impacts on the Ogallala Aquifer were thoroughly assessed within the licensing process for the low-level radioactive waste disposal facility licenses for the WCS site issued in 2009. TCEQ extended a two-year licensing period to five years. During this process, more than 600 borings were drilled at a variety of depths. WCS site characterization unequivocally demonstrates that the Ogallala Aquifer is ten miles away from the site and that there is no drinking water beneath the WCS site. The Texas Water Development Board map confirms these site characteristics.

  • Hydraulic conductivity of clay is 1×10-9 cm/sec..
  • Horizontal groundwater travel is approximately 1 foot per 1,000 years.

The proposed CISF at WCS meets all of these criteria. (Source: Nuclear Waste Management Organization)

There is already too much fuel for Yucca Mountain, if it does eventually proceed. That means much of the fuel will have to stay at the so-called “interim” sites.
A number of decades will have passed before Yucca Mountain or another repository comes near to being full, during which time our government and the states can develop the next strategy for used fuel management – which may include tapping the used fuel as an energy resource for some of the next-generation nuclear energy reactors in development.

You can’t predict the future; what is or isn’t at the proposed site now may change drastically in 120 years and create a risk for future generations.
The above-ground, storage overpacks simplify the used fuel canister placement, inspection access for the learning Aging Management Program (AMP) for each system deployed at the CISF. During each license renewal the data gathered from the learning AMPs will be evaluated and additional AMPs will be defined as necessary to endure the continued safe storage at the CISF, and eventual retrieval for transport to a permanent federal repository. We will be using an NRC-approved aging management program and technology to microscopically inspect 100% of the stored canisters’ surfaces. Any concerns will be analyzed and, if needed, the existing canister could be inserted and sealed inside a new larger canister, and placed back in the storage module. The above-ground modules also make external and internal inspections a simplified process.