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Memorandum submitted by the Welsh Anti Nuclear Alliance (NPS 58)
The Welsh Anti Nuclear Alliance established in 1980 is comprised of individuals and organisations concerned about the safety, security and economics of nuclear power. It has given evidence at several nuclear public inquiries and House of Commons select committees over the last 26 years. IntroductionThe Energy and Climate Change Committee is "to determine whether the energy National Policy Statements provide a coherent and practical framework within which the Infrastructure Planning Commission can assess future planning applications for energy infrastructure." This paper provides evidence that the draft Nuclear National Policy Statement is not fit for purpose because insufficient information has been put forward.
The Draft National Policy Statement for Nuclear Power Generation states of the Higher Level Wastes including spent fuel that: [1] "Having considered this issue, the Government is satisfied that effective arrangements will exist to manage and dispose of the waste that will be produced from new nuclear power stations. As a result the IPC need not consider this question."
This absurd statement is a result of placing responsibility for managing radioactive waste with the department that is actively promoting nuclear power. Every local planning authority in the land has the right to know from the applicant what is to be done with any hazardous waste created on the site as a result of the development. This is uniquely important when the storage period of 160 years will outlast the developer, the waste is particularly dangerous and there are well-founded doubts about its safety and security. High Burnup Spent FuelThe high burnup fuel proposed for new reactors uses more enriched uranium, and leaves it in the reactor for longer. This gets more output from the fuel, but increases the dangers of radioactive releases as the fuel cladding gets thinner. This increased danger persists throughout its storage and disposal. Burnup is expressed in thousand MegaWatt days per tonne of Uranium. Sizewell B has typically discharged fuel at 30,000MWd/tU compared with the proposed very high burnup spent fuel (60,000MWd/tU).
As high burnup spent fuel will be twice as hot and twice as radioactive as the legacy spent fuel that the government wants to dispose of, it will require twice as long to cool down before disposal. Sites of new nuclear power stations will accumulate and store this hazardous material above ground over very long periods. According to the International Atomic Energy Agency (IAEA) any benefits of lower electricity costs during the operation of reactors in this way will be offset by an increase in the cost of managing the spent fuel.[2] The problem is that the costs will long outlast any benefits, in effect transferring burdens to future generations.
In 2007 the IAEA warned that Britain must not go ahead with a new generation of nuclear power stations until it has a "clear and robust" plan in place for dealing with the twin problems of decommissioning and waste treatment. The agency's executive director said:[3] "The spent-fuel issue is the most critical one for nuclear. It will not develop if there is not a credible and satisfactory answer to the management of spent fuel and one which is convincing for the public."
The draft Nuclear National Policy Statement, and its 'evidence' says nothing about how the public and workers are to be protected from accidents and deliberate attacks, or how the deterioration of high burnup spent fuel is to be addressed over a 100 year cooling period. As this lack of publicly available information on a vital part of the new nuclear programme fails to comply with Britain's duty under Article 6 of the IAEA Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management, the IPC are under no obligation to determine any application made as a result of the draft Nuclear National Policy Statement. Article 6 of the convention states: [4] Each Contracting Party shall take the appropriate steps to ensure that procedures are established and implemented for a proposed spent fuel management facility: (iii) to make information on the safety of such a facility available to members of the public;
The government's 'arrangements' statement also pre-empts the work of its own nuclear regulators whose Generic Design Assessment Step 3 reports on the EPR and AP1000 reactors require further work or additional information on: [5] "the safety of the long term storage of the fuel before final disposal focussing on the role of the levels of burnup".
The government's central claim is that 'based on scientific consensus and international experience' high burnup spent fuel doesn't require different solutions: [6] "...spent fuel from new nuclear build would not raise such different technical issues compared with nuclear waste from legacy programmes as to require a different technical solution. "The disposability assessments that have been conducted by the Nuclear Decommissioning Authority....have concluded that....no new issues arise that challenge the fundamental disposability of the wastes and spent fuel expected to arise from operation of the EPR and AP-1000 reactors."
The issues are set out below. There is very little experience of the storage and management of very high burnup spent fuel (60,000MWd/tU) but many scientific and technical uncertainties about its characteristics have been identified which require separate and intense scrutiny. Science and PoliticsWhile decision making is political: [7] "the role of scientific expertise is to identify technical options, specify areas of uncertainty and evaluate the technical component of risk. The government of 1977 accepted a Royal Commission recommendation that the department responsible for the management of radioactive waste "should be independent of the responsibilities of Government Departments for promoting nuclear power." [8] Thus the Department of the Environment would have the responsibility to: [9] "...ensure that waste management problems are dealt with before any large nuclear programme is undertaken."
Radioactive waste remains an issue that is profoundly important and central to the acceptability of nuclear power. A government energy review commented in 2002: [10] "The main focus of public concern about nuclear power is on the unsolved problem of long-term nuclear waste disposal, coupled with perceptions about the vulnerability of nuclear power plants to accidents and attack."
The government now relies on attempting to answer two vague questions: [11] · Do acceptable technologies exist, or are they likely to exist within an appropriate timeframe, for managing and disposing of the waste (given its expected characteristics and quantities)? · Does capacity exist, or is it likely to exist within an appropriate timeframe, to manage and dispose of the waste in a manner which is safe, secure and which ensures environmental and sustainability impacts are manageable?
Despite the 2007 high court judgement that a consultation was "unlawful" because insufficient and "misleading" information had been made available by the government for consultees to make an "intelligent response", the Government has still not put sufficient information into the public domain to enable an effective and informed dialogue on the extremely important issues being consulted on. [12]
The test of acceptability of arrangements for managing high burnup spent fuel is whether they command public confidence. Circular references to the Managing Radioactive Wastes Safely (MRWS) process fail to do this. JustificationThe Secretary of State could yet decide that proposed nuclear power station designs were not justified if he concluded, following the current consultation, that the radiological detriment to health outweighed the benefits, but it has been described as a regulatory 'step' in the construction of new nuclear power stations. [13] "This Justification process is yet another example of the facilitative actions the government is taking to support new nuclear power in the UK."
The danger of allowing a department promoting nuclear power to make regulatory decisions is that in 'reducing regulatory risks for investors' it will pre-empt proper consideration of health detriments. It is for good reason that both the European Union and the IAEA require nuclear regulation to be free from any influence that may affect safety. [14], [15] No practice (activity) involving exposures to radiation should be adopted unless it produces at least sufficient benefit to the exposed individuals or to society to offset the radiation detriment it causes. [16] Waste management and disposal is regarded as an integral part of the one single practice of nuclear power generation so we have to consider all detriments, including that from the waste, before allowing any new nuclear programme. [17] Confidence about 'arrangements' is insufficient to justify the creation of such wastes because of the uncertain, but predictably serious health detriments that will be imposed on future generations. The test is whether the government will fulfil its obligations under article 4. of the IAEA Joint Convention on the Safety of Spent Fuel Management which states that each signatory to the convention [18] "shall take the appropriate steps to ensure that at all stages of spent fuel management, individuals, society and the environment are adequately protected against radiological hazards."
In particular they shall: (vi) strive to avoid actions that impose reasonably predictable impacts on future generations greater than those permitted for the current generation; (vii) aim to avoid imposing undue burdens on future generations. Radiation ExposureThe government acknowledge that high burnup spent fuel from the proposed reactors will be twice as radioactive as that from Sizewell B, [19] but the neutron dose rate (which increases by the power of four with burnup) is stated to be 'not significant for the management of the spent fuel': [20] "....since the total external dose rate from the spent fuel is dominated by the gamma radiation dose and not the neutron dose, which would contribute, at most (for example, for a burn-up of 60 gigawatt days per tonne of uranium (GWd/tU)), only 6% to the total external dose rate with the remainder being gamma.
Chart 1This is extremely misleading as Chart 1 illustrates. Neutron radiation becomes very significant over the 100 years storage period and will greatly increase potential exposure in handling accidents. A tonne of legacy spent fuel will emit approximately 33 million neutrons per second 50 years after discharge. [21] Even after 100 years of thermal cooling before emplacement a tonne of new build spent fuel will emit 80 million neutrons per second, [22] exposing the personnel emplacing new build spent fuel of the period 2125 - 2185 to two and a half times that possible for personnel emplacing legacy spent fuel. Confidence in Long Term StorageThe nuclear regulators point out that: [23] "Extremely long time periods into the future increase areas of uncertainty not just associated with the spent fuel itself, but with the long term integrity of containment structures, and introduce inaccuracies associated with quantification of risk." The draft Nuclear National Policy Statement relies on a document setting out the arrangements for the management and disposal of waste from new nuclear power stations. This states that: [24] "PWR spent fuel interim dry storage is an established technology overseas, where cask storage systems have been licensed for the storage of spent fuels from other modern PWRs." Such statements cannot be applied to the very long term storage of high burnup spent fuel. After 18 years in cooling ponds the spent fuel from Westinghouse reactors would be transferred to Holtec Hi Storm dry casks, licensed for 20 years in the US, and assumed to be used for up to 50 years. No one has any idea of how they will stand up to heat and irradiation over a longer period, and the effects of heat build up on the long term integrity of the fuel is unknown. AREVA, the French reactor company have designed dry casks but have decided to store their British EPR spent fuel in ponds until it can be conditioned. In France pond storage for up to 300 years is being considered for high burnup spent fuel.
It is vital to examine the evidence that underpins the governments' confidence: [25] "In the USA spent fuel has been safely and securely managed on arising sites for decades and the US Nuclear Regulatory Commission (NRC) has formally expressed its confidence that spent fuel can be safely and securely stored on-site, without significant environmental impact, for at least 100 years."
The great majority of spent fuel in storage in the US has a burnup of less than 45,000 MWd/tU. A speech by the NRC Chairman in May 2009 [26], while articulating general confidence, conceals NRC concern about high burnup spent fuel which has stated: [27] ".....there is limited data to show that the cladding of spent fuel with burnups greater than 45,000 MWd/MTU will remain undamaged during the licensing period. Limited information suggests increased cladding oxidation, increased hoop stresses and changes to fuel pellet integrity with increasing burnup up to and beyond 60,000 MWd/MTU. These burnup dependent effects could potentially lead to failure of the cladding and dispersal of the fuel during transfer and handling operations.
The IAEA puts worldwide collective experience of spent fuel into context: ".....the use of high burnup and MOX....fuels will lead to higher residual heat and will require long heat decay times, implying longer interim storage period before final disposal. Experience exists in long-term storage of about 30 years without any problems. However, much longer storage periods are expected." [28]
Chart 2Concern about the long term storage of all spent fuel is shared by the industry itself with AREVA stating: [29] "Leaving the spent fuel onsite for extended periods of time was never intended and is not responsible. Independent Spent Fuel Storage Installations [ISFSIs] can safely operate past 100 years by implementing an ageing management program....(but) More responsible options exist, recycling and final disposal need to be pushed forward" Chart 2 is based on official estimates of the amount of radioactivity that would be created by a 10GW new build nuclear programme, and stored on sites. [30] We are now told that the earliest time that disposal of new build wastes would begin is estimated to be around 2130. Any confidence that does exist in long term storage is based on spent fuel with a burnup of less than 45,000 MWd/tU. Only 5% of US spent fuel is in dry casks.[31] The reluctance to use dry storage for high burnup spent fuel is likely to continue, as the US Dept of Energy concluded in 2003:[32] "To minimize operational risks and lower costs, utilities can be expected to send the high-burnup fuel directly from their spent fuel pools to the repository. Under those conditions, (US) Department of Energy will assume responsibility for dry storage until the spent fuel is ready to be disposed."
The long term storage of high burnup spent fuel is expected to result in greater fuel cladding failure, with consequent higher risk of radiation exposure for the generation attempting to retrieve and condition the failed fuel elements. "The three areas where higher burnup has the potential to affect the long-term dry storage of spent fuel are stress driven cladding-failure lifetimes, thermal performance of the rods, and radionuclide inventory of the source term. "Many of the degradation mechanisms for the cladding are stress driven. Extra corrosion of the Zircaloy cladding results in cladding thinning and a higher cladding stress." [33]
In Britain the nuclear regulators expect that: [34] "The waste form and its container should be resistant to degradation, waste packages should be inspectable, retrievable for inspection or reworking. The lifetime of the storage building should be appropriate for storage period prior to disposal. The facility should enable retrieval of wastes for final disposal (or restoring)."
The designers of facilities for the very long term storage of high burnup spent fuel face multiple challenges, as acknowledged in 2003 in an IAEA conference: [35] "...cask designers currently face a number of new challenges including storage of high burnup fuel with correspondingly higher enrichments.." [36]
"The NRC has been focusing on the storage and transportation of high burnup fuel over the last few years because high burnup fuel is thought to have degraded mechanical properties as compared to lower burnup fuel. The staff has also become more aware of the various types of fuel assembly damage that may exist." [37] The NRC confirmed the additional problems that accompany the use of high burnup fuel: [38] "...beyond 45 GW·d/tU, the oxide layer thickness on the exterior of Zircaloy cladding increases at a faster rate than at lower burnup levels....Additionally, as burnup levels increase, the cladding absorbs more hydrogen which affects the mechanical properties of the cladding and, depending on the environmental conditions of the cladding, can affect the mode of cladding failure."
There are internationally accepted consequences associated with the long-term dry storage of spent fuel above 45,000MWd/tU. These include stress driven cladding-failure, through higher internal hydrogen gas pressure, and higher cladding corrosion. [39] Encapsulation - the unanswered questionsBefore anyone accepts new reactors that discharge high burnup spent fuel, they should be aware of the prevailing attitude within the nuclear industry - that they may evade the responsibilities of creating high burnup spent fuel, storing it for 100 years and conditioning it for disposal. Prospective operators of new nuclear power stations have been open about wanting the taxpayer to take title to and responsibility for their high burnup spent fuel 'as soon as practicable'. [40]
From the perspective of corporate entities planning investments and returns, a twenty year horizon is perfectly sufficient for shareholders. If long term risks associated with spent fuel storage and disposal can be offset by effectively transferring burdens to future generations, it is a helpful inducement for investors.
NII guidance to inspectors makes it clear that spent fuel should be stored dry: [41] "For spent fuel, the options are to reprocess or to dry store, prior to the availability of a final disposal route, and this choice is largely a commercial judgement by the operators, subject to satisfying planning and regulatory requirements."
The EPR reactor developers are still unsure whether to store their spent fuel wet or dry. [42] Both have serious problems. The problem with maintaining 'wet storage' over 160 years is that pumps have to be kept going continuously and safety could be compromised by a terrorist attack that partially or completely drains the spent fuel pool. This could lead to the rapid heat-up of spent fuel to temperatures at which the zirconium alloy cladding would catch fire and release radiation.
However, handling dry 100 year old fuel will be a hazardous operation. In Finland where spent fuel below 45,000MWd/tU is to be encapsulated after about 40 years: [43] "In case of accidents or mishandling, possible damages to the fuel assemblies would be more severe in air than in water."
The cladding of spent nuclear fuel above 45,000MWd/tU is vulnerable to failure, especially during a handling accident in which it is dropped. [44] Quenching embrittled 100 year old dry spent fuel in water, in order to provide shielding at the encapsulation plant, could cause fuel elements to fail, leading to their being rejected for disposal. In Finland these (lower burnup) failed spent fuel elements will be put in 'special storage'. [45]
EDF think that encapsulation will take place just before emplacement underground (from 2130 presumably, which makes it rather unlikely that they will be doing it): [46] "It is anticipated that conditioning (encapsulation) of spent fuel will not take place until the fuel is due for emplacement in the repository." The New Build Repository FootprintA series of unrealistic and misleading assumptions have lead the Nuclear Decommissioning Authority to conclude that ILW and spent fuel from the operation and decommissioning of the Westinghouse AP1000 and the AREVA EPR: [47] "should be compatible with plans for transport and geological disposal of higher activity wastes and spent fuel."
A central conclusion of the NDA's disposability assessments for spent fuel from the reactors proposed for England and Wales is that, after 100 years cooling, the spent fuel may be disposed of in the same repository as 'legacy' spent fuel because its additional footprint will be small relative to that of the legacy waste repository. "A fleet of nine such reactors (AP1000) would require an additional area of approximately 1 km2, excluding associated service facilities. This represents approximately 6% of the area required for legacy HLW and spent fuel per AP1000 reactor, and approximately 55% for the illustrative fleet of nine AP1000 reactors. This is in line with previous estimates for potential new build reactor designs."
This one square kilometre assumes a uniform strong crystalline geology, and tunnels spaced at 25 metre centres. The NDA believes that UK geology will require only 8% of deposition holes to be rejected as unusable. It is now concluded that 23% of deposition holes are likely to be unusable at the Forsmark repository in Sweden.[48] This combined with a tunnel spacing of 40 metre centres is necessary for the dispersion of heat from the (normal) spent fuel to be disposed of in Sweden. The 25 metre tunnel spacing used by the NDA and 6.5 metre canister spacing means that temperature limits in the repository are likely to be exceeded, [49] defeating the object of the 100 year cooling period: [50]
Chart 3Chart 3 allows a better judgement to be made of the likely footprint of spent fuel from new build. On all realistic and reasonable assumptions the spent fuel repository footprint necessary for 10 GW of new build would exceed the 3 sq km required for legacy HLW and spent fuel. Doubling the footprint of the repository is not tenable for geological reasons. Operating it for over a century after the legacy repository is folly
Simply in order to reduce costs for those considering investing in new nuclear stations the government is prepared to give us (and future generations) the worst of all worlds, keeping one facility open and disposing of both new and legacy radioactive waste in the same repository. ConclusionWe have a fundamental choice before us. The IAEA have recognized that limits will be reached in the increase in fuel burnup because of the environmental, safety and licensing implications: [51] ".....the general burnup trend is heading up to still higher level, even though there should be a plateau level in confrontation with regulatory constraints."
Investment in new nuclear power stations depends on getting the most energy from each tonne of uranium. The very long storage period that is required is commercially driven, a direct result of using high burnup fuel. High burnup spent fuel is more difficult and intractable to manage and dispose of, and will transfer greater burdens to future generations, exposing them to greater hazards than those that we are prepared to accept.
The assertion that very high burnup spent fuel is not much different from 'legacy' spent fuel is confounded by international consensus. As such fuel would be far more hazardous but doesn't yet exist, its creation requires a quite separate and more rigorous process to test and validate proposals for its management and disposal. The IPC's framework is neither practical nor coherent, and will fail to command public respect unless a public inquiry with wide terms of reference is held to permit such scrutiny.
References[1] Draft National Policy Statement for Nuclear Power para 3.8.20 [2] IAEA-TECDOC-1299 Technical and economic limits to fuel burnup extension. Proceedings of a Technical Committee meeting held in San Carlos de Bariloche, Argentina, 15-19 November 1999 IAEA July 2002 http://www-pub.iaea.org/MTCD/publications/PDF/te_1299_web.pdf [3] Britain gets nuclear waste warning from energy chiefs Independent 02 March 2007 [4] IAEA Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management Vienna 2006 CHAPTER 2. SAFETY OF SPENT FUEL MANAGEMENT Article 6 http://www.iaea.org/Publications/Documents/Conventions/jointconv.html [5] NUCLEAR DIRECTORATE GENERIC DESIGN ASSESSMENT - NEW CIVIL REACTOR BUILD STEP 3 FUEL DESIGN ASSESSMENT OF THE EDF AND AREVA UK EPR. DIVISION 6 ASSESSMENT REPORT NO. AR 09/041-P [6] The draft Nuclear National Policy Statement Para 3.8.10 [7] Royal Society Submission to the House of Lords Select Committee on Science and Technology inquiry into The Management of Nuclear Waste, Feb 1998 Page 3 [8] Nuclear Power and the Environment, The Government's response to the Sixth Report of the Royal Commission on Environmental Pollution (Cmnd. 6618) May 1977 Management of Radioactive Wastes (page 6) Para 13 [9] 'Nuclear Power and the Environment' The Government's Response to the sixth report of the Royal Commission on Environmental Pollution (Cmnd 6618) (para 14) [10] 'The Energy Review' A Performance and Innovation Unit Report -February 2002, page 12 http://www.cabinetoffice.gov.uk/media/cabinetoffice/strategy/assets/theenergyreview.pdf [11] The arrangements for the management and disposal of waste from new nuclear power stations. DECC November 2009 [12] The Queen on the application of Greenpeace Limited -v- Secretary of State for Trade and Industry. [13] Minister of State for Energy and Climate Change Mike O'Brien, December 17th 2008 [14] Article 5. 2 states that Member States shall ensure that the competent regulatory authority is functionally separate from any other body or organisation concerned with the promotion, or utilisation of nuclear energy, including electricity production, in order to ensure effective independence from undue influence in its regulatory decision making. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32009L0071:EN:HTML:NOT . [15] IAEA Convention on Nuclear Safety adopted on 17 June 1994 ARTICLE 8. states: Each Contracting Party shall take the appropriate steps to ensure an effective separation between the functions of the regulatory body and those of any other body or organization concerned with the promotion or utilization of nuclear energy. http://www.iaea.org/Publications/Documents/Infcircs/Others/inf449.shtml [16] ICRP Publication 103, Annals of the ICRP, Volume 37 Nos. 2-4, 2007. These latest regulations largely affirm the justification principle set out in the 1990 Recommendations of the International Commission on Radiological Protection, ICRP Publication 60. [17] The Justification of Practices Involving Ionising Radiation Regulations 2004 (SI 2004 No 1769) Guidance on their application and administration Version May 2008, Para 8 page 6 [18] IAEA Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management Vienna 2006 CHAPTER 2. SAFETY OF SPENT FUEL MANAGEMENT Article 4. http://www.iaea.org/Publications/Documents/Conventions/jointconv.html [19] NDA Technical Note no. 11339711 Geological Disposal - Generic Design Assessment: Summary of Disposability Assessment for Wastes and Spent Fuel arising from Operation of the Westinghouse AP1000 October 2009. Page 25 http://www.nda.gov.uk/documents/upload/TN-17548-Generic-Design-Assessment-Summary-of-DA-for-Wastes-and-SF-arising-from-Operation-of-APPWR-October-2009.pdf [20] Regulatory Justification of the AP1000 and the EPR. Vol 2 - Secretary of State's Proposed Decision para 4.36 [21] "Nuclide Importance to Criticality Safety, Decay Heating, and Source Terms Related to Transport and Interim Storage of High-Burnup LWR Fuel" I. C. Gauld and J. C. Ryman, ORNL for Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission. NRC Job Code W6479 December 2000, Fig 18 Neutron source from 1 metric tonne (t) of PWR fuel; 27.5 GWd/t page 39 http://www.ornl.gov/sci/scale/pubs/cr6700.pdf [22] "Nuclide Importance to Criticality Safety, Decay Heating, and Source Terms Related to Transport and Interim Storage of High-Burnup LWR Fuel" I. C. Gauld and J. C. Ryman, ORNL for Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission. NRC Job Code W6479 December 2000, Fig 19 Neutron source from 1 metric tonne (t) of PWR fuel; 60 GWd/t page 40 http://www.ornl.gov/sci/scale/pubs/cr6700.pdf [23] Guidance For Inspectors on the Management of Radioactive Materials and Radioactive Waste on Nuclear Licensed Sites HSE/NII March 2001, Appendix 3, para 3.6.3 http://www.hse.gov.uk/foi/internalops/nsd/tech_asst_guides/tast024.pdf [24] The arrangements for the management and disposal of waste from new nuclear power stations: a summary of evidence DECC November 2009. page 15, para 59 [25] The arrangements for the management and disposal of waste from new nuclear power stations: a summary of evidence DECC November 2009, para 41. [26] NRC Chairman Dale E. Klein to the Dry Storage Information Forum Bonita Springs, FL May 12, 2009. The first NRC waste confidence decision was issued in 1984. In this initial note, the Commission found: · reasonable assurance that safe disposal of high-level waste and spent fuel in a geologic repository is technically feasible, · that repository capacity will eventually be available, · that high-level waste and spent fuel will be safely managed until repository capacity is available, · that spent fuel generated in any reactor can be stored safely and without significant environmental impacts for extended periods, and · that spent fuel storage will be available as needed. [27] NUREG-1567 Standard Review Plan for Spent Fuel Dry Storage Facilities, Final Report March 2000 page 6-15 http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1567/sr1567.pdf [28] IAEA-TECDOC-1089 Storage of spent fuel from power reactors. Proceedings of a symposium held in Vienna, 9-13 November 1998. Conclusions, page19 http://www-pub.iaea.org/MTCD/publications/PDF/te_1089_prn.pdf [29] Research and Data Needs for Very Long-Term Dry Storage - AREVA Perspective Tara Neider, President & CEO, Transnuclear Inc. June 11, 2009 http://www.nwtrb.gov/meetings/2009/june/neider.pdf [30] NIREX The Gate Process: Preliminary analysis of radioactive waste implications associated with new build reactors February 2007 Number: 528386 page 19 [31] The arrangements for the management and disposal of waste from new nuclear power stations: a summary of evidence DECC November 2009, page 14, para 62 [32] Dry Storage Demonstration for High-Burnup Spent Nuclear Fuel- Feasibility Study EPRI, Palo Alto, CA, and U.S. Department of Energy, Washington, DC: 2003. 1007872 August 2003 Conclusions Page 5-2 http://www.pnl.gov/main/publications/external/technical_reports/PNNL-14390.pdf [33] IAEA-TECDOC-1089 Storage of spent fuel from power reactors. Proceedings of a symposium held in Vienna, 9-13 November 1998. 'EXTENDING DRY STORAGE OF SPENT LWR FUEL FOR UP TO 100 YEARS' R.E. EINZIGER, Argonne National Laboratory, Argonne, IL. M.A. MCKINNON, Battelle,Pacific Northwest Laboratories, Richland, Washington A.J. MACHlELS, EPRI, Palo Alto, CA. para 3.7 page 346 http://www-pub.iaea.org/MTCD/publications/PDF/te_1089_prn.pdf [34] TECHNICAL ASSESSMENT GUIDE- MANAGEMENT OF RADIOACTIVE MATERIALS AND RADIOACTIVE WASTE ON NUCLEAR LICENSED SITES T/AST/024 13/03/01 http://www.hse.gov.uk/foi/internalops/nsd/tech_asst_guides/tast024.pdf [35] Storage of Spent Fuel from Power Reactors. Proceedings of an International Conference held in Vienna, 2-6 June 2003 organized by the International Atomic Energy Agency in co-operation with the OECD Nuclear Energy Agency. Foreword. http://www-pub.iaea.org/MTCD/publications/PDF/csp_020c/Start.pdf [36] 'Optimization of cask capacity for long term spent fuel storage' W. Dankera, K. Schneider page 195, in Storage of Spent Fuel from Power Reactors. Proceedings of an International Conference held in Vienna, 2-6 June 2003 organized by the International Atomic Energy Agency in co-operation with the OECD Nuclear Energy Agency http://www-pub.iaea.org/MTCD/publications/PDF/csp_020c/Start.pdf [37] 'U.S. Nuclear Regulatory Commission acceptance criteria and cladding considerations for the storage and transportation of high burnup and damaged spent fuel' K.A. Gruss, G. Hornseth, M.W. Hodges in Proceedings of an International Conference held in Vienna, 2-6 June 2003 organized by the International Atomic Energy Agency in co-operation with the OECD Nuclear Energy Agency. Page 229 http://www-pub.iaea.org/MTCD/publications/PDF/csp_020c/Start.pdf [38] 'U.S. Nuclear Regulatory Commission acceptance criteria and cladding considerations for the storage and transportation of high burnup and damaged spent fuel' K.A. Gruss, G. Hornseth, M.W. Hodges in Proceedings of an International Conference held in Vienna, 2-6 June 2003 organized by the International Atomic Energy Agency in co-operation with the OECD Nuclear Energy Agency. Page 231 http://www-pub.iaea.org/MTCD/publications/PDF/csp_020c/Start.pdf [39] 'Examination of the creep rupture phenomenon and the development of an acceptance criterion for spent fuel dry storage' J.Y.R. Rashid,ANATECH,and A.J. Machiels EPRI,Palo Alto, California. in Proceedings of an International Conference held in Vienna, 2-6 June 2003 organized by the International Atomic Energy Agency in co-operation with the OECD Nuclear Energy Agency. Page 431 http://www-pub.iaea.org/MTCD/publications/PDF/csp_020c/Start.pdf [40] EDF submission to the Consultation on Funded Decommissioning Programme Guidance for New Nuclear Power Stations. May 2008, Para 4.1.9, 6th bullet (spent fuel): [41] TECHNICAL ASSESSMENT GUIDE- MANAGEMENT OF RADIOACTIVE MATERIALS AND RADIOACTIVE WASTE ON NUCLEAR LICENSED SITES T/AST/024 13/03/01 [42] ibid. http://www.hse.gov.uk/foi/internalops/nsd/tech_asst_guides/tast024.pdf [43] STUK-YTO-TR177 March 2001. SPENT FUEL ENCAPSULATION AND VERIFICATION Safeguards workshop in Helsinki, Finland, 19-20 December 2000 Phase II interim report on Task FIN C1184 of the Finnish Support Programme to IAEA Safeguards Tapani Honkamaa (ed.) App 6 page 5 para 4.1 http://www.stuk.fi/julkaisut/tr/stuk-yto-tr177.pdf [44] R. S. Daum, S. Majumdar, Y. Liu, and M. C. Billone, Radial-hydride Embrittlement of High-burnup Zircaloy-4 Fuel Cladding, Journal of Nuclear Sci. and Tech., Vol. 43, pp. 1054-1067, April 2006 http://www.jstage.jst.go.jp/article/jnst/43/9/1054/_pdf [45] STUK-YTO-TR177 March 2001. SPENT FUEL ENCAPSULATION AND VERIFICATION Safeguards workshop in Helsinki, Finland, 19-20 December 2000 Phase II interim report on Task FIN C1184 of the Finnish Support Programme to IAEA Safeguards Tapani Honkamaa (ed.) App 6 page 5 para 4.2 http://www.stuk.fi/julkaisut/tr/stuk-yto-tr177.pdf [46] EDF submission to the Consultation on Funded Decommissioning Programme Guidance for New Nuclear Power Stations. May 2008, Para 4.5.13 (unit pricing): [47] Geological Disposal Generic Design Assessment: Summary of Disposability Assessment for Wastes and Spent Fuel arising from Operation of the Westinghouse AP1000. October 2009; Geological Disposal Generic Design Assessment: Summary of Disposability Assessment for Wastes and Spent Fuel arising from Operation of the UK EPR. October 2009 http://www.nda.gov.uk/documents/upload/TN-17548-Generic-Design-Assessment-Summary-of-DA-for-Wastes-and-SF-arising-from-Operation-of-APPWR-October-2009.pdf. [48] The layout for these underground excavations requires an area of 3.6 km2 The proposed layout (Figure 4-13) represents the area for a gross capacity of 7,818 canisters (i.e. allowing for a possible loss of 23% due to discarded deposition positions). Underground design Forsmark Layout D2 Svensk Kärnbränslehantering AB July 2009. http://www.skb.se/upload/publications/pdf/R-08-116webb.pdf [49] SKB Technical Report TR-07-12 RD&D Programme 2007. Programme for research, development and demonstration of methods for the management and disposal of nuclear waste September 2007, (page 337) Figure 26-1 Isolines for 90 deg C maximum bentonite temperature - Indicates that canisters spaced at 6.5m centres in tunnels at 25 metre centres exceed the 90 deg C limit, (to accommodate 10 deg C uncertainty) with rock initial temperature of 10.6 deg C http://www.skb.se/upload/publications/pdf/TR-07-12%20FUD%202007%20eng%20webb.pdf [50] NDA Technical Note no. 11339711 Geological Disposal - Generic Design Assessment: Summary of Disposability Assessment for Wastes and Spent Fuel arising from Operation of the Westinghouse AP1000 October 2009. Page 5 http://www.nda.gov.uk/documents/upload/TN-17548-Generic-Design-Assessment-Summary-of-DA-for-Wastes-and-SF-arising-from-Operation-of-APPWR-October-2009.pdf. [51] IAEA-TECDOC-1433 Remote technology applications in spent fuel management. March 2005 page 49 http://www-pub.iaea.org/MTCD/publications/PDF/TE_1433_web.pdf
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