diablo canyon decommissioning engagement panel spent fuel … · 2019-03-06 · years of discharge....

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Diablo Canyon Decommissioning Engagement Panel Spent Fuel Workshop Date/Time: Friday - February 22, 2019 (8:00 AM – 6:15 PM) Facilitator: Chuck Anders Meeting Location: Embassy Suites Hotel, 333 Madonna Road, San Luis Obispo (Workshop – SLO North and Central, Exhibit Room – Los Osos Room) Recorder: TBD Live Streaming: AGP live stream Purpose: Understand current storage methods and path forw ard for future storage methods for nuclear materials at DCPP Desired Outcomes: By the end of the meeting, the Panel will: Understand current strategy for storage of spent nuclear fuel (SNF) at the DCPP ISFSI Understand cask storage technologies currently available to DCPP Understand requirements for storage of SNF after decommissioning Solicit the public’s input regarding the storage of SNF at the DCPP ISFSI Make PG&E aware of the Panel and public’s input AGENDA Item # What – Content Organization - Presentation Topic Presenter Start Time 1. Safety Overview PG&E 8:00 AM (5) 2. Review workshop agenda and presentation schedule Anders 8:05 AM (5) 3. Opening Comments Panel Members 8:10 AM (20) 4. Storage of SNF at DCPP ISFSI Overview of DCPP ISFSI Fuel transfer strategies and path forward Questions / Discussion PG&E 8:30 AM – Presentation (50) 9:20 AM – Discussion (30) 5. Break 9:50 AM (10) 6. Nuclear Regulatory Commission - ISFSI Requirements and Oversight Michael Layton 10:00 AM – Presentation (35) 10:35 AM – Discussion (30) 7. California Energy Commission Drew Bohan 11:05 AM – Setup (10) 11:15 AM – Presentation (35) 11:50 AM – Discussion (30) 8. Lunch Break 12:20 PM (70) 9. Presentation / Discussion – ORANO (Cask Vendor) Chris Miller 1:30 PM – Presentation (35) 1:55 PM – Discussion (30) 10. Presentation / Discussion – GNS (Cask Vendor) Dirk Becher 2:25 PM – Setup (10) 2:35 PM – Presentation (35) 3:10 PM – Discussion (30) 11. Break 3:40 PM (10) 12. Presentation / Discussion – Holtec (Cask Vendor) Jearl Strickland 3:50 PM – Presentation (35) 4:25 PM – Discussion (30) 13. Presentation / Discussion – Kevin Kamps Kevin Kamps 4:55 PM – Setup (10) 5:05 PM – Presentation (35) 5:40 PM – Discussion (30) 14. Wrap-Up Days Activities Anders 6:10 PM (5 min) 15. Adjourn Anders 6:15 PM Rev.021919

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Page 1: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Diablo Canyon Decommissioning Engagement Panel Spent Fuel Workshop

Date/Time: Friday - February 22, 2019 (8:00 AM – 6:15 PM) Facilitator: Chuck Anders

Meeting Location:

Embassy Suites Hotel, 333 Madonna Road, San Luis Obispo (Workshop – SLO North and Central, Exhibit Room – Los Osos Room)

Recorder:

TBD

Live Streaming: AGP live stream

Purpose: Understand current storage methods and path forw ard for future storage methods for nuclear materials at DCPP

Desired Outcomes:

By the end of the meeting, the Panel will: • Understand current strategy for storage of spent nuclear fuel (SNF) at the DCPP ISFSI • Understand cask storage technologies currently available to DCPP • Understand requirements for storage of SNF after decommissioning • Solicit the public’s input regarding the storage of SNF at the DCPP ISFSI • Make PG&E aware of the Panel and public’s input

AGENDA

Item # What – Content Organization - Presentation Topic

Presenter

Start Time

1. Safety Overview PG&E 8:00 AM (5)

2. Review workshop agenda and presentation schedule Anders 8:05 AM (5)

3. Opening Comments Panel Members 8:10 AM (20)

4.

Storage of SNF at DCPP ISFSI • Overview of DCPP ISFSI • Fuel transfer strategies and path forward • Questions / Discussion

PG&E

8:30 AM – Presentation (50) 9:20 AM – Discussion (30)

5. Break 9:50 AM (10)

6.

Nuclear Regulatory Commission - ISFSI Requirements and Oversight

Michael Layton 10:00 AM – Presentation (35) 10:35 AM – Discussion (30)

7.

California Energy Commission

Drew Bohan

11:05 AM – Setup (10) 11:15 AM – Presentation (35) 11:50 AM – Discussion (30)

8. Lunch Break 12:20 PM (70)

9. Presentation / Discussion – ORANO (Cask Vendor) Chris Miller 1:30 PM – Presentation (35) 1:55 PM – Discussion (30)

10.

Presentation / Discussion – GNS (Cask Vendor)

Dirk Becher 2:25 PM – Setup (10) 2:35 PM – Presentation (35) 3:10 PM – Discussion (30)

11. Break 3:40 PM (10)

12. Presentation / Discussion – Holtec (Cask Vendor) Jearl Strickland 3:50 PM – Presentation (35) 4:25 PM – Discussion (30)

13. Presentation / Discussion – Kevin Kamps Kevin Kamps 4:55 PM – Setup (10) 5:05 PM – Presentation (35) 5:40 PM – Discussion (30)

14. Wrap-Up Days Activities Anders 6:10 PM (5 min)

15. Adjourn Anders 6:15 PM

Rev.021919

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Spent Nuclear Fuel Transfer to the Diablo Canyon Independent Spent Fuel Storage Installation Presented by: Philippe Soenen Decommissioning Environmental and Licensing Manager February 22, 2019

Presented by:

Page 3: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Describe the components used to handle and store spent nuclear fuel (SNF) and discuss greater than Class C (GTCC) waste

Outline unique requirements for the Diablo Canyon Independent Spent Fuel Storage Installation (DC ISFSI)

Describe the basis for evaluating expediting transfer of spent fuel from wet storage to dry storage.

Next Steps

DC Fuel Cycle Video 2

Purpose

Page 4: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Fuel Assembly Thimble Screw Grid

Bottom Nozzle

Dashpot Region

Thimble Tube

Control Rod Fuel Rod

Top Nozzle

Hold Down Spring

Rod Cluster Control Assembly

• Westinghouse-type pressurized water reactor 17x17 fuel assembly

• 17 x 17 rod array • 264 rods per assembly • ~14 ft. overall length • The fuel assembly structure

consists of a bottom nozzle, top nozzle, guide thimbles, and grids

3

Fuel Assembly

Page 5: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

A type of low-level waste created during decommissioning • Example: portions of the reactor vessel internals

GTCC waste is stored at ISFSIs until a permanent off-site repository is available

• Stored in casks, similar to SNF

DCPP GTCC Waste • NRC license amendment will be required to store up to 10 casks at the DC

ISFSI • DC ISFSI will need additional storage space if the existing dry cask storage

system is used for remainder of SNF • Expected doses exceed those of SNF

4

Greater than Class C Waste

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SNF assemblies are stored in the SFP • Concrete Structure PG&E

Design Class I

• High density fuel storage racks, SFP liner, liner leakage detection, level monitoring, temp and rate of temp change, and local radiation levels

• Technical Specifications require minimum of 23 ft. of water above irradiated fuel assemblies

5

Spent Fuel Pool

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Components Used to Handle and Store Nuclear Fuel

6

Page 8: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

DC ISFSI Orientation

• DCPP currently has a site-specific 10 CFR Part 72 license • Utilizes the Holtec HI-STORM 100SA cask system

− Anchored cask design for seismic considerations • Current ISFSI pad will hold all SNF for the licensed plant life • Current status:

− 7 loading campaigns − 1,856 SNF assemblies

stored at the DC ISFSI in 58 casks

7 N

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Five areas of additional seismic restraint

• Cask pit region restraints • Cask Washdown Area (CWA) restraint • Vertical Cask Transporter (VCT) seismic restraint and bumpers • Cask Transfer Facility (CTF) structure, seismic restraints, and anchors • ISFSI pad and anchor embedments

8

Unique Seismic Requirements

Page 10: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Base Plate

Drain Line Guide Tube

Components for Nuclear Fuel Handling

Multi-Purpose Canister (MPC) - 32

• 181.3 in. (15.1 ft.) tall, 68.5 in. (5.7 ft.) outer diameter

• MPC thicknesses: • 0.5 in. shell • 9.5 in. lid • 2.5 in. base plate

• Up to 45 tons with SNF loaded • Welded lid • Sealed to maintain dry,

helium-filled environment

MPC Cut Away View

9

Fuel Basket

Lid

MPC Shell

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Components for Nuclear Fuel Handling

MPC-32 Loading Limits for DCPP • Initial fuel assembly enrichment ≤ 5.0 wt. % 235U • Technical Specification calculation provides

burnup (Licensing Basis Limit ≤ 62 GWD/MTU*) • Loading pattern in cask determines heat limits

• Regionalized loading total allowable MPC heat load: 25,572 Watts (W) Region 1 assembly limit ≤ 1,131 W (red) Region 2 assembly limit ≤ 600 W (blue)

• Uniform loading total allowable MPC heat load: 28,736 W Each assembly limit: 898 W (purple)

*Gigawatt-days per metric ton of uranium 10

Page 12: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Wate

Components for Nuclear Fuel Handling

HI-TRAC 125D (Transfer Cask) • Holds the MPC during SNF loading, transfer to the

cask transfer facility (CTF), and MPC transfer to the HI-STORM overpack

• 192.5 in. (16 ft.) tall, 104 in. (8.7 ft.) outer diameter • Up to 117 tons with full MPC loaded • Provides capability for cooling and

additional shielding of MPC during loading and processing

• Provides method to prevent contamination of MPC external surface in SFP

Outer r

and jacket inner cavity shells

Shielding

11

Bottom lid

Page 13: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

HI-TRAC/MPC Lowered into SFP and Assemblies Loaded

Fuel Handling Building (FHB) Crane

• Single-failure-proof overhead bridge crane

• 125-ton capacity main hook and 15-ton auxiliary hook

SFP Platform Structure and Restraints

• Seismically secure • Isolates the HI-TRAC from

remainder of SNF racks • Secures a HI-TRAC while loading

SNF in the MPC 12

Restraint cup

Main Hook

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HI-TRAC/MPC to CWA, Back Filled and Placed on LPT

Cask Washdown Area (CWA) Seismic Restraint

• Secures the HI-TRAC transfer cask during loading activities

• Consists of a wall mounted platform, seismic restraining strap, and a floor mounted restraining plate

Low-Profile Transporter (LPT)

• Analyzed to ensure no overturning or lateral movement with a fully loaded HI-TRAC

• Dedicated-use multi-roller heavy haul device • HI-TRAC is secured to the LPT baseplate

through bolts

Wall- mounted platform

Restraining plate

Not Shown: CWA restraining

strap under walkway

LPT Rails

13

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Vertical Cask Transporter (VCT) • Self-propelled, open-front, tracked vehicle; custom-designed for DCPP conditions • Designed to remain stable and not overturn, experience structural failure, or leave the

transport route during a seismic event • Contains a redundant load

support system • Contains lateral cask restraint

and bumpers • 27.5 ft. tall, 19.2 ft. wide • 95 tons unloaded • Rated load is 185 tons • Top speed 0.6 mph • 20 gal/mile with HI-TRAC (fuel tank < 50 gallons)

14

HI-TRAC/MPC Loaded in VCT and Transported to CTF

Redundant drop prevention

Cask restraint

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Loaded MPC Transferred from HI-TRAC to HI-STORM

Cask Transfer Facility (CTF) • Designed for loads imposed during

DCPP-applicable earthquakes

• Comprised of reinforced concrete support structure, interlaying steel shell, and removable seismic restraints

• Facilitates transfer of a loaded MPC between the HI-TRAC and the HI-STORM overpack

• Mating device is used to guide the MPC transfer while providing shielding and seismic stability

Seismic Restraint Anchor

20 ft.

Empty CTF steel shell, 150” diameter

CTF Loaded with HI-STORM

CTF During Construction 15

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HI-STORM 100SA Overpack • Rugged, heavy multi-walled, cylindrical, steel (epoxy-coated)

and concrete structure

• Bottom baseplate includes 16 holes for anchor studs to seismically anchor to the ISFSI pad

• 229.5 in. (19.1 ft.) tall, 146.5 in. (12.2 ft.) outer diameter

• 1-in. thick steel outer shell, 27.5-in. thick concrete, 1-in. thick steel inner shell

• Up to 180 tons with a loaded MPC • Capability to withstand the loads created

by all design basis accidents and natural phenomena

Inlet/ outlet vents

Anchor

stud holes

Pedestal

16

Components for Nuclear Fuel Storage

Conc

rete

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68

HI-STORM Overpack Anchored to ISFSI Pad

Anchor Embedment

DC ISFSI • 7 storage pads

• Steel-reinforced concrete

• Design is based on the maximum weight of the loaded overpacks

• Provide the embedment for anchored overpacks

• Anchored configuration for all design-basis conditions of storage, including seismic events

• Prevents sliding and tip over

ISFSI Pad Construction

105’

17 7.

5’

Page 19: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Expedited Spent Fuel Offload Evaluation

18

Page 20: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Purpose “the site-specific decommissioning study will update the 2015 NDCTP [Nuclear Decommissioning Cost Triennial Proceeding] forecast and incorporate the costs of …a plan for expedited post- shut-down transfer of spent fuel to Dry Cask Storage as promptly as is technically feasible using the transfer schedules implemented at the San Onofre Nuclear Generating Station as a benchmark for comparison, and provided PG&E will also provide the plan to the CEC [California Energy Commission], collaborate with the CEC, and evaluate the CEC’s comments and input…”

Joint Proposal Agreement (JPA), page 13 19

Basis for Expedited Fuel Offload Evaluation

Page 21: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Conclusion 5 “It is reasonable to assume for cost estimation purposes that some spent nuclear fuel assemblies will require 7 years of wet cooling. In the 2018 Nuclear Decommissioning Cost Triennial Proceeding, the Commission would benefit from Pacific Gas and Electric Company providing information comparing annual cost impacts of strategies to reduce wet cooling periods, including assessment of expedited dry cask loading pre and post- shutdown.”

D.17-05-020, page 78

20

Basis for Expedited Fuel Offload Evaluation

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June 2018 Spent Fuel Offload Scenarios

21

Page 23: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

DCPP Expedited Fuel Offload Future Actions

22

Page 24: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Confirmed: It is safe and feasible to offload spent fuel from the spent fuel

pools to the DC ISFSI within 7 years after final Unit 2 shutdown Significant additional engineering is required to determine a

holistic strategy in concert with GTCC waste Further expediting might be achieved and will be driven by

responses to the RFP process Additional loading campaigns during operations extends critical

path of decommissioning Diablo Canyon – delaying fuel transfer to ISFSI – and committed additional SNF to current dry cask system design

NRC licensing action needed for any strategy to reduce loading time to ISFSI from spent fuel pool 23

2018 NDCTP Conclusions

Page 25: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Action Plan:

PG&E’s 2018 NDCTP Application: cost estimate based on a 7-year offload schedule

Issue a vendor RFP in 2019 after CEC, Engagement Panel, NDCTP SNF public workshops, and other stakeholder consultation

2021 NDCTP: Update the cost estimate using RFP responses

Pursue LAR and other needed regulatory approval for updated ISFSI system

24

DCPP Expedited Fuel Offload Future Actions

Page 26: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Thank You Philippe Soenen Decommissioning Environmental and Licensing Manager [email protected]

25

Page 27: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Overview of the Spent Fuel Management

Michael Layton, Director Division of Spent Fuel Management

Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission (NRC)

Page 28: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Roles and Responsibilities • Licensing, Certification and Inspection

– Spent fuel storage facilities – Spent fuel dry cask storage systems – Radioactive material transportation packaging – Vendor, QA, and ISFSI inspections

• Coordination with: – State and federal agencies (most notable DOT

and DOE, but also EPA) – Foreign and international regulatory agencies – Native American tribes

• Public Outreach on storage and transportation activities

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Independent Spent Fuel Storage Installations (ISFSIs)

Page 30: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Dry Cask Storage, Certificates of Compliance • NRC’s Requirements - 10 CFR Part 72 • Approximately 12 Certificates of

Compliance (CoCs) • 20-30 storage cases each year • Increased engagement with

stakeholders on dry storage matters • Coordination with DOE project

planning and research

Page 31: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Spent Fuel Storage at Diablo Can on

U.S.NRC United States Nuclear Regulatory Commission

Protecting People and the Environment

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Spent Fuel Storage at Diablo Canyon

Page 33: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Inspection Program • Design • Fabrication • Construction • Preoperational Testing • Operations • Inspection Reports • Enforcement Actions • Allegations

Page 34: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Spent Fuel Security • ISFSI security is maintained as part of the

overall reactor security program during the plant operations.

• During decommissioning, the security posture is focused on the Spent Fuel Pool and the ISFSI.

• After decommissioning, the security posture of the ISFSI is maintained.

Page 35: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

transportation issues

Transportation of Spent Fuel

• NRC Requirements – 10 CFR Part 71 • 50-70 transportation cases each year • Work closely with DOT in both domestic and

international transportation • Engagement with states on transportation matters • Significant international involvement on

Page 36: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

ISFSI License and Dry Cask Storage System CoC”

• Aging management program

License Renewal • NRC Requirements - 10

CFR Part 72.42 and Part 72.240

• Duration of license/certificate • Initial term up to 40 years • Renewal term up to 40 years

• NUREG-1927, “Standard Review Plan for Renewal of

Page 37: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

argument on contention admissibility and standing on January 23-24, 2019, in Albuquerque, NM.

• Engage stakeholders within our role

Consolidated Interim Storage • Interim Storage Partners (ISP) in Texas

– June 2018 – ISP requested restart of application review – August 2018 - Staff resumed the safety and environmental reviews – November 2018 – Staff issued Requests for Additional Information (RAIs)

• Holtec International & Eddy Lea Energy Alliance in New Mexico

– February 2018 - Staff accepted application for docketing, began detailed review

– April, May 2018 - Staff held 6 environmental scoping meetings in New Mexico and Maryland

– March, September, October 2018 - Staff issued RAIs – Atomic and Safety Licensing Board was established and held an oral

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Acronyms

• QA – Quality Assurance • ISFSI- Independent Spent Fuel Storage

Installations • DOT- Department of Transportation • DOE- Department of Energy • EPA- Environmental Protection Agency

Page 39: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Contact Information

Michael. Layton @ nrc.gov

Page 40: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

U.S.NRC United States Nuclear Regulatory Commission

Protecting People and the Environment

Page 41: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Diablo Canyon Decommissioning Engagement Panel - Spent Fuel Workshop

California Energy Commission

Drew Bohan, Executive Director February 22, 2019 California Energy Commission

Page 42: Diablo Canyon Decommissioning Engagement Panel Spent Fuel … · 2019-03-06 · years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent

Establishment & Purpose

California’s primary energy policy and planning agency

Established by the Warren-Alquist Act in 1974

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California Seismicity

In 2017, there were more than 3300 metric tons of

uranium stored in California 30-year M≥6.7 Earthquake Probability • HB ~ 1/10 SNF < 400 asmb. • DC ~ 1/100 SNF > 3000 asmb. • SO ~ 1/100 SNF < 4000 asmb. • RS ~ 1/10,000 SNF < 500 asmb.

Source: Uniform California Earthquake Rupture Forecast, Version 3 (UCERF3)—The Time-Independent Model

SO

DC

RS

HB

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Nuclear Moratorium – No new nuclear plants until a solution to radioactive waste disposal is in place Factors Influencing California's Nuclear Policy Long History of Seismic Concerns at Diablo Canyon and San Onofre

• Assembly Bill 1632 Report • Independent Peer Review Panel Review of Seismic Studies

Events at Fukushima Daiichi

Impact of Renewable Generation

Early Shutdown of San Onofre Nuclear Plant

Storage of Spent Nuclear Fuel

Nuclear Power in California

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Statutory authority in Warren-Alquist Act Liaison Officer to the U.S. Nuclear Regulatory Commission Western Governors Association and Western Interstate Energy Board Since 1989, coordination with the California Nuclear Transport Working Group

Nuclear power facility reports, IEPR chapters, and public workshops Independent Peer Review Panel that focuses in seismic issues Energy Commission chair appoints a Diablo Canyon Independent Safety Committee

members

Energy Commission’s Role in Nuclear Power and Waste Management

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Report annually to the Energy Commission on: • Spent nuclear fuel storage in pools and dry cask facilities • Aging management programs

Engage in NRC efforts that impact: • Decommissioning regulations • License amendments • Regulations and policies that impact California

Engage with DOE on nuclear materials transport/storage Review and engage on key seismic and environmental studies Engage with the Independent Peer Review Panel and Diablo

Canyon Independent Safety Committee

IEPR Nuclear Recommendations

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NRC regulates nuclear plants, but California engages as follows:

Energy Commission intervened with the Atomic Safety Licensing Board, challenging the adequacy of U.S. DOE’s environmental review

Engaged in NRC Continued Storage Rule and Power Reactor Decommissioning Rulemaking

Engaged in DOE Consent-Based Siting Initiative

The Energy Commission is committed to improving the management of spent nuclear fuel at California’s nuclear power facilities.

Federal Engagement

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California’s four nuclear plant sites store more than 3,300 metric tons of spent fuel • Humboldt Bay & Rancho Seco: 100% dry storage • San Onofre: 100% dry storage by 2019 (estimated) • Diablo Canyon: majority of storage remains “wet” until after 2025

Current NRC regulations – limit state and local stakeholders engagement, do not address site-specific issues

California requires site restoration to original condition, and activities beyond NRC requirements

On-site spent fuel means additional burdens for the local community & state

Diablo Canyon San Onofre Rancho Seco Humboldt Bay

Nuclear Plant Decommissioning

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In the Joint Proposal, PG&E stated 2018 Decom filing would include: • “…a plan for expedited post-shut-down transfer of spent fuel to Dry Cask Storage as

promptly as is technically feasible using the transfer schedules implemented at the San Onofre Nuclear Generating Station as a benchmark for comparison, and provided PG&E will also provide the plan to the CEC, collaborate with the CEC, and evaluate the CEC's comments and input…”

• PG&E briefed Commission staff on 12-7-2018 and 01-16-2019

• PG&E did not consult with the Energy Commission on any of the topics outlined in the filing documents, Vol. 1 – Chapter 6 Spent Nuclear Fuel, during plan development

• Energy Commission staff have reviewed the plan and are ready for the next step

PG&E’s Spent Fuel Plan

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The Energy Commission and PG&E agree that dry storage is the path forward

The next step is additional discussion and engagement with PG&E on the proposed Spent Fuel Plan • Collaborate to develop the best possible plan by including key stakeholders • Incorporate lessons learned from recent spent fuel transfer campaigns

End Goal is the safe expedited transfer of spent fuel to dry storage

Spent Fuel Collaboration – Next Steps

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Questions?

For additional information or follow-up questions please contact: Justin Cochran, Ph.D.

Senior Nuclear Policy Advisor California Energy Commission

916-657-4353 [email protected]

Thank You

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Diablo Canyon Community Engagement Panel

Orano TN

Christopher Miller February 22, 2019

Copyright 2019 Orano – All Rights Reserved

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Summary 1. Orano Overview

2. Dry Storage Solutions

3. Aging Management

4. Centralized Interim Storage

2

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01

Orano Overview

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Orano, a strategic refocusing on nuclear fuel cycle business

Diablo Canyon CEP - Orano TN 2/22/2019 – 4 ©2018. All rights reserved

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Back End an internationally renowned business

Recycling Nuclear Packages & Services • La Hague and Melox: the only • Only vendor to provide all

facilities in the world to operate at logistics services (multi-modal a large, industrial scale transportation, dry storage casks, long-

term storage…)

Dismantling • Renowned expertise in engineering,

project management and activities in highly radioactive areas

• Proven experience for the design and operation of industrial nuclear cycle sites

• Very high value-added expertise in fuel cycle logistics and waste management

• Unique know-how used for Orano’s industrial sites (La Hague…) and for its customers, in France (CEA and EDF) and worldwide (US, UK, Germany and Japan)

Diablo Canyon CEP - Orano TN 2/22/2019 – 5 ©2018. All rights reserved

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Orano TN, the only vendor to provide all logistics services Key figures

#1 in transport

operations

#1 in used fuel dry storage solutions for utilities worldwide

Three Business Lines to serve customers of the nuclear fuel cycle worldwide

Transport

• Comprehensive Transport Services ( Mines, Conversion, Enrichment, fresh fuel, MOX, used fuel,..)

Dry Storage

Unrivalled expertise in

transport risk 900 management employees

worldwide

Waste Logistics

• Interim Spent Fuel Management Services (supply of dry storage systems, loading services, aging management services…)

• A new Business Line to meet

future market demand (pool clean- up, packaging and transportation services,……)

Diablo Canyon CEP - Orano TN 2/22/2019 – 6 ©2018. All rights reserved

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Our Core Competencies

Engineering Design of Packaging systems and associated equipments Material, shielding, criticality, mechanical and thermal behavior

Licensing Safety Analysis Reports Licensing process management

Supply of transport and storage solutions

Casks and associated supporting hardware, Manufacturing, Supply chain management

Logistics Transport and logistics services, leasing of casks and transport means…

Services Technical Assistance, Loading operations, Pool to Pad Services, Maintenance activities, Training…

Diablo Canyon CEP - Orano TN 2/22/2019 – 7 ©2018. All rights reserved

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#1 in Nuclear Transports

Around 4,300 shipments per year including

Shipments for the front end of the cycle Shipments per for the Back End of the cycle

• Used fuel • MOX fuel • Vitrified and compacted waste

Shipments for research reactors and laboratories

Considerable resources

2,200 casks from 1MT to 130 MT 70 trucks designed for heavy casks, 47 special rail cars An integrated organization of transportation-related risk management (nuclear and industrial safety, image/media)

Diablo Canyon CEP - Orano TN 2/22/2019 – 8

©2018. All rights reserved

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Diablo Canyon CEP - Orano TN 2/22/2019

02

Dry Storage Solutions

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US Fuel Storage History 1980s: spent fuel pool reracking, dry storage begins with metal casks; regulation anticipates short term need – 20 year license

1990s: First commercial welded canister system (NUHOMS®) deployed; by end of the decade, canisters begin to dominate. Yucca Mountain fails to open 1998 as promised.

2000 to present: Yucca Mountain project is halted; plants are decommissioned with no place to send the fuel. Private entities develop centralized interim storage to fill this need.

Diablo Canyon CEP - Orano TN 2/22/2019 – 10 ©2018. All rights reserved

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Orano TN Dry Storage and Transport Expertise

Metallic cask for transport and storage of used fuel

Presence in Australia, Belgium, Germany, Italy, Japan, Spain, Switzerland and the USA

NUHOMS transportable storage canister

Stainless steel canister placed horizontally in a concrete module Up to 37P, 89B, 50 kW decay heat Presence in the US(40% market share), China and Armenia

TN MW® “All in One” Solution for Waste transport, storage and final disposal

Leading Centralized Interim Storage project in Texas

Nearly 1,500 packaging systems loaded worldwide

Diablo Canyon CEP - Orano TN 2/22/2019 – 11 ©2018. All rights reserved

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Storage on NPP sites Main two products available for dry storage of Spent Fuel Assemblies (SFA) on NPP sites include Bolted metal casks Welded canisters/concrete systems - vertical concrete silos or horizontal storage modules

Both can meet the requirements for safe interim dry storage of spent nuclear fuel and both are currently used in the USA and in Spain

In the USA, metal casks have been selected for 8% of the SFA unloaded from the NPP pools (only in 5 plants, 4 of which have eventually changed to canisters), while canister concrete systems are used for 90% of the SFA

Metal cask

NUHOMS modules Diablo Canyon CEP - Orano TN 2/22/2019 – 12

©2018. All rights reserved

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Key Features: Metal Casks Thick steel for shielding and protection

Typical weight on crane hook 108 to 114 t

Plastic or grout for the neutron shield

The lid (1 or 2) is bolted with a metal seal

The space between two seals is pressurized and monitored for seal leakage

For transport, remove pressure monitoring system, and add shock absorbing covers

To retrieve fuel, unbolt the lid in a preparation area, and remove the lid and fuel in a pool or in a hot cell

Diablo Canyon CEP - Orano TN 2/22/2019 – 13 ©2018. All rights reserved

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Key Features: Welded Canisters 12 to 16 mm stainless steel canister shell

Shielding during loading provided by a thick canister lid, and by a transfer cask

Typical weight on the crane hook 90 to 114 t

Canister lids are welded with 2 barriers

Shielding and physical protection during storage by a ventilated concrete module, either horizontal or a vertical silo.

For transport, remove the canister from the concrete module directly in a transport cask.

To retrieve fuel, cut the lid welds in a preparation area, and remove the lid and fuel in a pool or in a hot cell

Diablo Canyon CEP - Orano TN 2/22/2019 – 14 ©2018. All rights reserved

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Dry Shielded Canister (DSC)

Horizontal Storage Module (HSM)

Transport Cask (offsite) – Part 71

Yoke Extension

Transfer Trailer and Transfer

Cask (onsite) – Part 72

Lifting Yoke

Automated Welding

System (AWS)

Vacuum Drying

System (VDS)

NUHOMS Equipment Terminology

Diablo Canyon CEP - Orano TN 2/22/2019 – 15 ©2018. All rights reserved

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NUHOMS EOS System NUHOMS – EOS 37PTH 37 assemblies Payload 37 PWR Intact Fuel Assemblies Non-Fuel Assembly Hardware Reconstituted Fuel Assemblies

Intact Fuel Min Cooling Time – 2 years Max Burnup – 62 GWd/MTU Max Heat Load – 50 kW

NUHOMS DSC Identification

Diablo Canyon CEP - Orano TN 2/22/2019 – 16 ©2018. All rights reserved

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171

NUHOMS EOS Canister

Increased capacity 37 PWR 89 BWR

Increased decay heat to 50 kW

Simplified basket construction, shorter time to manufacture, no proprietary materials

Simplified closure welds

Duplex stainless option to resist stress corrosion cracking

Adding damaged fuel end caps at license amendment 1, in progress

DLaiatebslot TCeacnhynoonlogCieEsP–- MOraadnriod,TJNan2u/2a2ry/22001199– ©2018. All rights reserved

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NUHOMS EOS Corrosion Proof

NUHOMS EOS Canister in Duplex Stainless Steel Not susceptible to stress corrosion cracking in chloride environments Highly resistant to localized and general corrosion Exceptional heat transfer capabilities Exceptional mechanical strength and energy absorption

Diablo Canyon CEP - Orano TN 2/22/2019 – 18 ©2018. All rights reserved

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NUHOMS EOS Design Philosophy

Reinforcing the NUHOMS Advantage Simplicity – Construction and Operation Lowest Risk Highest Seismic Capability Lowest Dose Secure Protection from Environmental Hazards

Diablo Canyon CEP - Orano TN 2/22/2019 – 19 ©2018. All rights reserved

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Improved concrete module system: MATRIX

The space required for the Matrix (two-tiered horizontal storage modules) is less than 60% of that for vertical casks or concrete silos

Construction of Matrix array Diablo Canyon CEP - Orano TN 2/22/2019 – 20

©2018. All rights reserved

Footprint reduction Vertical cask → NUHOMS → Matrix

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Canister loading in MATRIX

Diablo Canyon CEP - Orano TN 2/22/2019 – 21 ©2018. All rights reserved

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Heat Removal in Dry Storage

The criterion that controls thermal design is holding the fuel cladding below 400°C at the hottest location

The internal structure (basket) can be the same in metal casks and canisters, so the heat removal from the fuel to the inner wall can be the same

Metal casks conduct the heat through several layers of steel and neutron shielding to the environment. Typical metal cask limit is ~35 kW.

Canisters conduct heat through a single layer of steel directly to a convective environment. The NUHOMS EOS system has been licensed to 50 kW

Natural convection in a NUHOMS module Diablo Canyon CEP - Orano TN 2/22/2019 – 22

©2018. All rights reserved

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Fuel Transfer

Prime mover Pintle hook height 25”-30” 32 RubberTires Steerable trailer Weight evenly distributed over 32 tires 10,000 lbs/tire 8 (4x2) axle sets Support skid assembly Features Hydraulic 3-stage RAM Special haul paths not required Horizontal transfer quicker and safer (Non- 1E)

NUHOMS Loading Video

Diablo Canyon CEP - Orano TN 2/22/2019 – 23 ©2018. All rights reserved

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NUHOMS University

Diablo Canyon CEP - Orano TN 2/22/2019 – 24 ©2018. All rights reserved

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PIGA Stamp / Title of the presentation

03

Aging Management

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NUHOMS EOS Inspection

Inspections NUHOMS EOS horizontal storage modules have built-in inspection port Above ground system allows for ease of inspection of DSCs without lifting

Non-Destructive Examination (NDE) Tools NDE techniques include high resolution cameras, surface deposit sampling, eddy current inspection Established NDE techniques used to inspect canisters with implementation tool well into development

Diablo Canyon CEP - Orano TN 2/22/2019 – 26 ©2018. All rights reserved

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Canister Surface Inspection

NDE tools designed to read location of any surface defects found for easy repair

Capability for numerous testing methods such as visual, Eddy Current, Ultrasonic tests

Built-in radiation shielding features for worker safety during inspection

Diablo Canyon CEP - Orano TN 2/22/2019 – 27 ©2018. All rights reserved

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Aging management: Canister inspection with MATRIX

Because there are no mechanical seals to leak, there is no pressure monitoring system for welded canisters.

The only routine inspection for welded canister systems is daily verification that the air vents are clear.

The MATRIX roller tool can raise and rotate the canister for complete surface NDE inside the module.

Diablo Canyon CEP - Orano TN 2/22/2019 – 28 ©2018. All rights reserved

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US 9595358B2

Aging management: Concrete module liner for a damaged canister

Liner Body Technologies for in situ repair are being developed in case inspection finds damage, e.g., stress corrosion cracking, on a canister.

An alternative is to move that DSC to a concrete module with a sealed and monitored liner. This has been implemented for

Patent EP2011/073331 the NUHOMS storage of Three Liner Lid

Mile Island waste at Idaho Nat’l Lab.

Diablo Canyon CEP - Orano TN 2/22/2019 – 29 ©2018. All rights reserved

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04

Centralized Interim Storage

Diablo Canyon CEP - Orano TN 2/22/2019 – ©2018. All rights reserved

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Centralized Storage: Interim Storage Partners

The approach of Interim Storage Partners (Texas) shows the following advantages:

Elimination of multiple ISFSIs around the country Elimination of management costs and support functions for multiple ISFSIs Communities at shutdown sites will be able to repurpose or monetize property The centralized storage facility is simple, only the concrete pads, security, and a facility for transport cask maintenance. No storage building and no below ground storage: it is clear the public that this is temporary. For welded canisters, direct geologic disposal could be possible*. In this case, no fuel transfer. Dry Fuel Storage Technology provided by NAC International and TN Americas.

* See US DOE FCRD-UFD-000129, 2015

Diablo Canyon CEP - Orano TN 2/22/2019 – 31 ©2018. All rights reserved

CIS will store casks and canisters as they were stored at the NPP

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Interim Storage Partners Timeline

Orano / WCS Cooperation Orano / WCS JV for CIS

Start of License WCS WCS CIS License NRC Licensing Application License License Review Review Process Submitted Accepted on Hold restart complete

CIS for Spent Nuclear Fuel and Reactor-Related Requested

RAIs (**) * NRC letter received accepting authorization to possess 5,000

MTU (ER covers 40,000 MTU) for dry-cask storage for an initial

duration of 40 years

revised application and new review schedule. NRC review complete

Aug 2020, hearings possibly begin

Diablo Canyon CEP - Orano TN 2/22/2019 – 32 (**) Responses for Additional Information ©2018. All rights reserved

* Q3

2020 Jan 2019 2018 2018

June Nov Jan Apr 2017 2017

Apr 2016 2014

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Complete Solution for Spent Fuel Onsite Storage

On Site Loading Services ISFSI Pad and Dry Storage Solutions Aging Management, Turnkey ISFSI Management, Maintenance

Logistics Assets and Services

Consolidated Storage Geologic Repository

33 Offering full service & long term UNF management, optimizing inventory management across sites

Diab

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rano

TN

2/2

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orano Giving nuclear energy its full value

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Spent Fuel Dry Storage by GNS Dirk Becher

PG&E February 22, 2019

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GNS Corporate Information

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GNS - Gesellschaft für Nuklearservice

Competence for Nuclear Services Founded in 1974, based in Essen/Germany.

Competence Centre of the German utilities for the management of spent fuel and all nuclear wastes (HLW/ILW/LLW) from the operation and the dismantling of the German power plants

Worldwide operations : • one of the leading manufacturers of casks for ILW (MOSAIK®)

and spent fuel/HLW (CASTOR®, CONSTOR®)

• processing of every kind of radioactive waste, decommissioning and related engineering and consulting services

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 3

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Structure of GNS Group Employees: ca. 450 Turnover: ca. 250 Mio EUR

Subsidiary:

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

Headquarter Essen - Corporate Functions - Project Planning and Controlling - Development of Casks and

Equipment

Mülheim - Cask Assembly (SF, HLW, ILW) - Training and Test Facility

Jülich - Conditioning and Packaging of solid

LLW

PG&E / Feb. 22, 2019 / Dirk Becher / 4

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Competence Areas of GNS

Management of nuclear waste from operations and dismantling of nuclear power

plants (ILW/LLW) Management of spent fuel as well as ILW

and HLW from the reprocessing of German spent fuel abroad

Casks for transport and storage of spent

fuel and nuclear waste (HLW/ILW) Consulting, engineering and equipment

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 5

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Latest Situation in Germany

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Germany‘s Phase-Out Road-Map

Operations Postoperational Phase Decommissioning

Würgassen (E.ON)

Stade (E.ON)

Mühlheim-Kärlich (RWE)

Obrigheim (EnBW)

Biblis A (RWE)

Biblis B (RWE)

Brunsbüttel (EnBW)

Isar-1 (E.ON)

Krümmel (E.ON)

Neckarwestheim-1 (EnBW)

Philippsburg-1 (EnBW)

Unterweser (E.ON)

Grafenrheinfeld (E.ON)

Gundremmingen B (RWE)

Philippsburg-2 (EnBW)

Brokdorf (E.ON)

Grohnde (E.ON)

Gundremmingen C (RWE)

Emsland (RWE)

Isar-2 (E.ON)

Neckarwestheim-2 (EnBW)

2009 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029 2031 2033 2035 2037 2039 2041 2043 2045

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

Politically induced immediate shutdown after the Fukushima accident

Political decision (June 2011) for German phase out by 2022

PG&E / Feb. 22, 2019 / Dirk Becher / 7

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Fundamental Changes in Germany

German utilities are financially stricken by the consequences of the phase-out decision and the „Energiewende“.

Newly started site selection process for a final repository prolongs the interim storage periods for several decades.

There were concerns, that the utilities – in the long run – might not be able to finance the dismantling and the unplannable interim storage phase.

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 8

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New Responsibilities The operators remain responsible for decommissioning and

dismantling of the NPP as well as for the packaging of the nuclear waste.

The German government assumes responsibility for the management and financing of interim storage and final disposal.

• The funds for interim storage and final disposal will be provided by the energy utilities.

• To do so the operators had to transfer their provisions (about 24 bn €) for interim storage and final disposal into a public fund

In fact a fair allocation of the costs to those who are really responsible for them!

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 9

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Transfer of the Responsibility for Interim Storage GNS handed over its interim storage activities to the

German Federation as of 1st August 2017 • Centralized interim storage facilities at Ahaus and Gorleben

• Bundled in newly formed BGZ Gesellschaft für Zwischenlagerung mbH, which was founded specifically for this purpose by GNS

In 2019: The 12 interim storage facilities for Spent Fuel on the NPPs‘

sites will be transferred to the state (BGZ).

In 2020: The 12 interim storage facilities for ILW/LLW on the NPPs‘ sites will be transferred to the state (BGZ).

The experienced GNS interim storage organization has become a Federal Corporation with responsibility for all the nuclear waste from the German NPPs for many decades until the availability of final repositories.

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 10

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GNS Spent Fuel Management

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The CASTOR® Cask

Since the very first dry storage cask loading in 1983 the design principle of CASTOR® casks remains unchanged

First CASTOR® cask Still in operation/storage

• Dual-Purpose Casks • No overpack required for transportation and storage • “Load & Go” / “Store & Go”

• Monolithic DCI cask body • No welding seams • Metal sealings in all lids

Transport of a CASTOR® cask • Suitable for long-term storage

• Continuous pressure monitoring

• 24/7 monitoring for any possible leakage CASTOR® casks at

an indoor storage facility

PG&E / Feb. 22, 2019 / Dirk Becher / 12

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The CASTOR® Cask

CASTOR® is the internationally established trademark for a high-tech product by GNS designated for the safe transport and storage of spent fuel and HLW.

Protection goals:

Safe enclosure of the radioactive inventory

Shielding of radiation

Dissipation of the decay from the radioactive materials

Guarantee of subcriticality

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 13

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CASTOR® Variety Customized to a variety of reactor types including:

PWR, BWR, VVER 440, VVER 1000, MTR, etc.

Type B(U)F approval certificates (incl. validations) inculding: • Germany, • Belgium, • Czech Republic, • Netherlands, • Switzerland, • France, • UK, • USA.

Storage licenses in many countries worldwide

PG&E / Feb. 22, 2019 / Dirk Becher / 14

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Germany 1266 Lithuania (Ignalina) 203 Czech Republic ( Dukovany, Temelin) 124 USA (e.g. Surry) 35 Switzerland 14 Bulgaria (Kozloduy) 13 Belgium 7 South Africa 4 Additional casks delivered to:

GNS Casks Worldwide

Casks loaded and in interim storage:

Finland, France, the Netherlands, Russia, Korea

As of December 2018

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

GNS has already developed and manufactured almost 1700 casks for High Level Waste and Spent Fuel.

PG&E / Feb. 22, 2019 / Dirk Becher / 15

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„German Fuel“ vs. Rest of the World German PWR fuel features larger diameters

compared to international established PWR fuel

• Areva : Ø = 214 mm • Westinghouse: Ø = 197 / 214 mm • CE-Type: Ø = 207 mm

Baskets optimized for fuel with largest diameters result in smaller amounts of FA per cask

German NPPs run larger burn-ups compared to most other countries in the world

German NPPs have a demand for shorter cooling times compared to most other countries

Baskets optimized for rather hot fuel result in smaller amounts of FA per cask

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

• KWU: Ø = 230 mm

PG&E / Feb. 22, 2019 / Dirk Becher / 16

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New Cask Development

CASTOR® geo Customized basket design

• Optimized for high fuel capacity

Established design principles incl. DCI cask body • Major cost advantages compared

to forged steel cask bodies

Based on standardized modules and components • Saves time and funds for licensing

Optimized to international crane capacities and standardized handling and dispatch of the casks • Savings in equipment due to standardizations

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

Storage Configuration

Basket for 32 PWR FA

PG&E / Feb. 22, 2019 / Dirk Becher / 17

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First Customers for New Casks

CASTOR® geo Belgium:

• 30 CASTOR® geo contracted in 2016 • Delivery from 2021 onwards

• Units 1-3 of Tihange NPP • Units 3-4 of Doel NPP

Switzerland: • 51 CASTOR® geo contracted in 2016 • Delivery from 2024 onwards

• Gösgen NPP

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 18

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First Customers for New Casks Customer: Synatom, Belgium

CASTOR® geo24B

Capacity 24 PWR-FA / Max. 8 MOX-FA (17x17; 4.1 m)

Max. initial Enrichment 4.5 wt-% U-235 / 7.7 wt-% Pufiss Pu+U)

Max. FA Burn-Up 55 GWd/MTU

Max. Heat Load 33 kW

Max. Mass during Handling w/w 117 Mg

Customer: NPP Gösgen, Switzerland

CASTOR® geo32CH

Capacity 32 PWR-FA / Max. 8 MOX-FA (15x15; 4.1 m)

Max. Initial Enrichment 5.00 wt-% U-235 / 4.81 wt-% Pufiss (Pu+U)

Max. FA Burn-Up 74 GWd/MTU

Max. Heat Load 35 kW

Max. Mass during Storage 135 Mg

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 19

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The CASTOR® CLU System

Next Challenge for GNS: Complete defueling of dated NPPs prior to decommissioning

Boundaries • Crane Capacity often around 100 US-

tons (90,7 Mg) with no option to upgrade

• Reasonable spent fuel specifications in terms of burn-up, cooling times etc.

• Demand for accelerated defueling as many of the old plants retire with immediate decommissioning.

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 20

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The CASTOR® CLU System CLU Cask Loading Unit

Canister based system for internal transfer

increases FA capacity with given pool crane

Dual Purpose Cask with bolted double lid system for storage and public transport

Smooth licensing expected since majority of the existing reviewed safety cases of the CASTOR® cask might be re-used for the CLU system

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 21

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GNS / WTI Design Storage Facilities

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Storage Building Operational function, weather protection and plant safety (access control

and protection against attacks) Additional radiation shielding, natural convection for heat dissipation

CASTOR® storage with building (Germany) CASTOR® storage without building (USA)

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 23

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Spent fuel storage facilities in Germany

2 Central Storage Facilities Ahaus & Gorleben

Used to be part of GNS. Owned and operated by GNS from 1990 until mid 2017

Dry Storage started in the early 1990s

15 On-site Storage Facilities at Nuclear Power Plants

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 24

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GNS - Cask storage facility at NPP Grafenrheinfeld

Cask storage facility

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 25

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Central Interim Storage Facility Ahaus

Spent Fuel, ILW/LLW

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

PG&E / Feb. 22, 2019 / Dirk Becher / 26

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Concept of Dry Interim Storage of Spent Nuclear Fuel

This document may not be cited, reproduced in whole or in part, or made available to third parties without the prior written consent of GNS Gesellschaft für Nuklear-Service mbH, Essen. All rights reserved by GNS.

Dissipation of decay heat

Subcritiality

Radiation shielding

Safe enclosure of radioactive material

PG&E / Feb. 22, 2019 / Dirk Becher / 27

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Spent Fuel Dry Storage by GNS Dirk Becher

PG&E February 18th, 2019

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Storage of Spent Nuclear Fuel at

Diablo Canyon Power Plant

By: Jearl Strickland Dr. Stefan Anton Executive Consultant V.P. Engineering & Licensing

Holtec International February 22, 2019

www.holtec.com | Page 1

Confidential Information

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Storage of Spent Nuclear Fuel at Diablo Canyon Power Plant

Topics About Holtec International History of Dry Storage at DCPP Nuclear Fuel and How it is Stored Holtec’s HI-STORM 100 Systems Protection of Public Heath & Safety Safe Method for Transportation Off-site Holtec’s Consolidated Interim Storage Facility in New Mexico Safe and Low Dose Loading Process

www.holtec.com | Page 2

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About Holtec International

Technical Innovation Protection of the Environment Financially strong with self- financed R&D Impeccable Safety Record Ingrained Nuclear Safety Culture Robust Quality Assurance Program

Committed to the Nuclear Industry

A vertically integrated turnkey supplier of goods and services to

the power generation industry since in 1986

www.holtec.com | Page 3

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Core Business Activities

Safe & Secure Used Fuel Storage Heat Transfer Equipment SMR-160 Consolidated Interim Storage Decommissioning of Retired Nuclear Plants

www.holtec.com | Page 4

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Holtec’s Manufacturing Capabilities Three Major U.S. Manufacturing Plants

1.4M ft2 of Total Shop Space

www.holtec.com | Page 5

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Industry Acceptance of Holtec Systems

www.holtec.com | Page 6

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History of Dry Storage at DCPP

2000: The HI-STORM System was selected by PG&E after a lengthy bid evaluation process that determined it was the best available technology Today : There are 58 HI-STORM Systems successfully loaded and safely stored at DCPP (over 1,200 Holtec systems are safely in use around the globe)

HI-STORMs at DCPP

www.holtec.com | Page 7

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Diablo Canyon Power Plant Independent Spent Fuel Storage Installation (ISFSI)

www.holtec.com | Page 8

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Nuclear Fuel & How it is Stored

www.holtec.com | Page 9

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Technology Overview

Overpack Lid (~24 inches of steel and concrete)

Canister Lid (~9 ½ inches of Stainless Steel)

Fuel Assembly

Basket (Stainless Steel & Neutron Absorber)

Canister (½ inches of Stainless Steel)

Overpack (~27 inches of Steel & Concrete)

HI-STORM 100 System

www.holtec.com | Page 10

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Protection of Public Health & Safety

The HI-STORM System is the most robust system in the industry

The overpack consists of inner and outer steel shells where the space between is filled with

Side View of HI-STORM Overpacks concrete being prepared for Transport

The overpack provides physical protection & radiation shielding

Concrete Poured at Plant Site

www.holtec.com | Page 11

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Protection of Public Health & Safety

External steel structure (no exposed concrete) ensures that the cask will not degrade under extreme environmental conditions No Rebar

So Easy to assemble No cracking due to thermal expansion No radiation streaming pathways

Minimal maintenance Passive heat removal (natural convection) Requires no monitoring systems

HI-STORM 100 on-site at a U.S. Nuclear Plant

www.holtec.com | Page 12

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Protection of Public Health & Safety

Steel exterior protects the cask against impacts Qualified to Withstand a Variety of Missiles: HI-STORM has been analyzed to withstand the impact of a variety of missiles; typical missiles and their incident velocity are listed in the table below (excerpted from the DIABLO CANYON ISFSI FSAR UPDATE)

www.holtec.com | Page 13

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Protection of Public Health & Safety

Qualified to Withstand a Variety of Missiles: Additional missiles and their incident velocity are listed in the table below (excerpted from the DIABLO CANYON ISFSI FSAR UPDATE)

www.holtec.com | Page 14

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Protection of Public Health & Safety

The robustness of the HI-STORM System has been thoroughly evaluated and confirmed by industry organizations and in a licensing proceeding before the NRC’s Atomic Safety & Licensing Board (ASLB) The ruling of the ASLB concluded that the HI-STORM can withstand:

Earthquakes stronger than any experienced in the history of the continental U.S. Over five times stronger than Fukushima Crashing of an F-16 fighter plane laden with fuel Raging brush fire around the storage facility

An Electric Power Research Institute (EPRI) report validated a direct hit by a Boeing 767 aircraft engine at 350 miles per hour does not result in a release of radioactive material

www.holtec.com | Page 15

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Protection of Public Health & Safety

Radiation dose from the HI-STORM systems at DCPP is anticipated to be less than 5 mrem/year This is the same exposure one would receive from a single roundtrip flight from NYC / Los Angeles The average annual radiation dose for an individual is 620 mrem

www.holtec.com | Page 16

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Protection of Public Health & Safety

MPC: Multipurpose Canister Fully-welded, stainless steel, cylindrical vessel that permanently encloses the spent fuel assemblies for storage and transport The canister is licensed for storage and transport using specific overpacks during storage, onsite transfer, and offsite transport Designed and manufactured to the highest levels of nuclear safety standards

An MPC stored inside the

HI-STORM Overpack

www.holtec.com | Page 17

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Protection of Public Health & Safety

The all-welded MPC boundary provides an impregnable barrier against radioactivity release to the environment No loaded canister of Holtec’s (or any other) has ever leaked in long term storage In contrast, bolted metal casks that feature thick steel sections have occasionally leaked at their gasket (seal) locations

An MPC Lid

A Fuel Assembly Being Lowered into an MPC

www.holtec.com | Page 18

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Protection of Public Health & Safety

Tests performed on Holtec canisters at Diablo Canyon and Salem / Hope Creek Aging Management Plan is required by the NRC to monitor the condition of dry storage systems Manufacturing process reduces risk of Stress Corrosion Cracking

Reduced the amount of welding on the canister Unique welding technique that minimizes the heat input Designed and implemented fixtures to reduce the amount of handling of the canister

An MPC in Production at Holtec in Camden, NJ

www.holtec.com | Page 19

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Safe Transportation Off-site

Transport is Highly Regulated Transportation of used nuclear fuel is strictly regulated by the Nuclear Regulatory Commission (NRC) and the U.S. Department of Transportation (DOT) The NRC oversees the design, manufacture, use, and maintenance of casks The DOT coordinates with the NRC to set rules for the packaging of nuclear material, regulates carriers, and sets standards for routes. DOT also works with the NRC and affected States to regulate the transport operations while they occur

HI-STAR 100 is licensed for Transport Diablo Canyon Includes Humboldt Bay (HI-STAR HB) Fabricated & in use for storage

HI-STAR 100 Transportation & Storage Cask in Use at U.S. Nuclear Plant

www.holtec.com | Page 20

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Safe Transportation Off-site

Cask Design is Robust and Proven to be Safe Transportation casks for shipping used nuclear fuel are robustly designed to protect the public from releases of radioactive material in the unlikely event of an accident These casks must be demonstrated to survive four successive accident conditions involving free drop, puncture, fire and submersion in water events before it is considered fit for transportation

www.holtec.com | Page 21

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Storage Locations in the US

www.holtec.com | Page 22

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Holtec’s Consolidated Interim Storage Facility in New Mexico

www.holtec.com | Page 23

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Consolidated Interim Storage Safe: The spent fuel storage system is designed and built to withstand natural and man-made events with no release of radioactivity

Secure: The spent fuel storage system and the facility provide an impregnable fortress for protecting the spent fuel against even the most egregious attacks

Retrievable : Allows removal of used fuel canisters from the facility to the final repository in one shift Temporary: The canisters containing the spent nuclear fuel will be shipped off site to the DOE facility in the same manner they were shipped to the site

www.holtec.com | Page 24

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Future HI-STORE CISF

HI-STORE CISF: A Consolidated Interim Storage Facility for Used Nuclear Fuel

Holtec & ELEA Team– Public Private Partnership formed in 2016 Eddy-Lea Energy Alliance

Long-standing NM alliance Owners are: Counties of Eddy & Lea Cities of Carlsbad & Hobbs

Formed in 2006 under the NM Local Economic Development Act

ELEA owns the property Holtec funding licensing and will operate the facility

Robust scientific & nuclear workforce

WIPP URENCO

www.holtec.com | Page 25

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Strong Local Support Strong support:

Local communities State & Local government

Letters from the Cities of Carlsbad and Hobbs

Letters from Counties of Eddy and Lea

Letter from Governor of New Mexico

Memorial Letters from House and Senate of New Mexico

New Mexico State Radioactive & Hazardous Materials Committee

Letter from City of Tatum

www.holtec.com | Page 26

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HI-STORE CISF Utilizes the HI-STORM UMAX Technology

Maximizes safety & security Stores used nuclear fuel in strength-

welded canisters in below ground vertical silos

Produces no pollution Does not need any water, nor does it

emit any water or any chemical It does not make any noise No aquifers or ground water will be

affected The radiation dose at the site’s

protected boundary will be a small fraction of the cosmic radiation that

Reinforced

Concrete Top Pad

Stainless Steel Spent

Fuel Canister

Low

Steel/ Concrete Lid

Steel Liner

Reinforced Concrete Base

bathes the state every single day Compressive

Strength Concrete

Mat

www.holtec.com | Page 27

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Site Layout

Cask Transfer Building

Security Building

HI-STORM UMAX

Initial Storage Capacity = 500 canisters (8,680 MTU) Total Storage Capacity = 10,000 canisters Facility utilizes 500 of the 1,000 acres available Operations could commence by 2023

Admin Building

www.holtec.com | Page 28

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HI-STORE Site-Specific License Timeline

Application submitted to USNRC: Application accepted by USNRC: RAI #1 received 4 of 5 parts: Response to RAI #1 part 1 & half of 2: NRC ASLB Oral Arguments: Response to RAI #1 part 2 remainder: Response to RAI #1 part 3: Response to RAI #1 part 4: RAI #1 part 5 expected: RAI #2 (if needed): NRC completes review:

March 2017 March 2018 various times in 2018 May & November 2018 January 23-24, 2019 January 31, 2019 March 30, 2019 March 15, 2019 TBD 2019 2019 July 2020

www.holtec.com | Page 29

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HI-STORE Construction Timeline

Pending Agreement w/DoE and/or Nuclear Utilities and / or other:

Construction Start: 2020 - 2021 Construction Complete: 2023 Accept First Shipment: 2023

www.holtec.com | Page 30

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Questions

www.holtec.com | Page 31

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Diablo Canyon Decommissioning Engagement Panel

Irradiated Nuclear Fuel Workshop Kevin Kamps

Radioactive Waste Specialist, Beyond Nuclear San Luis Obispo, CA

Feb. 22, 2019

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Overview 1. Continued reactor operations risks (including additional high-level radioactive waste (HLRW) generation) 2. Pool storage risks (fires, leaks) 3. Dry cask storage: Need for Robust, or Hardened On-Site Storage (HOSS), with QA (Quality Assurance)! 4. Consolidated Interim Storage (and CIS company reactor decommissioning takeovers) 5. Yucca Mountain 6. Transport risks

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Continued reactor operations = Additional HLRW generation

Diablo Canyon Unit 1 Diablo Canyon Unit 2

• 2019 to 2024 • 2019 to 2025

5 years X ~20 MT/year = ~100 MT • 6 years X ~20 MT/year =

~120 MT

(HLRW – High Level Radioactive Waste MT – Metric Ton)

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Continued reactor operations = Additional HLRW generation

Additional 2019-2025 Total, from continued operations:

~220 MT

This would be in addition to 1,126 MT at Diablo Canyon by spring 2010 (per DOE, Yucca FEIS, Feb., 2002).

And ~360 MT generated from 2010 to 2019 (~20 MT/reactor, per year)

Grand total: More than 1,600 MT

(HLRW – High Level Radioactive Waste; MT – Metric Ton)

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The first rule of holes:

When you’re in one,

stop digging!

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Reactor risks (2019-2025) • Safety: Pressurized thermal shock (reactor

pressure vessel embrittlement); earthquakes (13 faults in vicinity, including 2 major ones); etc.

• Security (terrorist attack, à la SLOMFP 2006, 9/11, Nuclear Power Plants as Weapons for the Enemy by Bennett Ramberg, etc.)

• Environmental and public health: Planned, permitted/allowable (not safe), “routine” releases of hazardous radioactivity during regular operations -- let alone age-related degradation and other leaks, spills, and unplanned releases

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RPV embrittlement/PTS risks Five worst neutron-embrittled reactor pressure vessels in the U.S., at risk of pressurized thermal shock through-wall fracture:

Atomic reactor, State (Year by which PTS screening criteria is exceeded):

Point Beach Unit 2, WI (2017) Palisades, MI (2017) Indian Point Unit 3, NY (2025) Diablo Canyon Unit 1, CA (2033) Beaver Valley Unit 1, PA (2033)

Citation: https://www.nrc.gov/docs/ML1310/ML13108A336.pdf

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RPV embrittlement/PTS risk Archive and timeline (1948-Present)

http://www.beyondnuclear.org/safety/2014/10/ 30/beyond-nuclear-warns-nrc-against- weakening-rpv-embrittlement.html

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Reactor risks: Three Mile Island, Unit 2 (3/28/1979-2019)

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Pool storage risks: Fires & leaks

Fires: • Alvarez, Macfarlane, Janberg, et al., 2003 • National Academies of Science (NAS), 2004

(redacted), 2006 (public version) • Alvarez, 2011 • Fukushima Daiichi nuclear catastrophe, Japan,

2011 • NAS, 2016 • von Hippel and Schoeppner, 2016 (case study,

Peach Bottom Nuclear Power Plant, PA)

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Alvarez, Macfarlane, Janberg, et al., 2003

Reducing the Hazards from Stored Spent Power-Reactor Fuel in the United States; Robert Alvarez, Jan Beyea, Klaus Janberg, Jungmin Kang, Ed Lyman, Allison Macfarlane, Gordon Thompson, Frank N. von Hippel; Science and Global Security, 11:1–51, 2003

Abstract:

Because of the unavailability of off-site storage for spent power-reactor fuel, the NRC [U.S. Nuclear Regulatory Commission] has allowed high-density storage of spent fuel in pools originally designed to hold much smaller inventories. As a result, virtually all U.S. spent-fuel pools have been re-racked to hold spent-fuel assemblies at densities that approach those in reactor cores. In order to prevent the spent fuel from going critical, the fuel assemblies are partitioned off from each other in metal boxes whose walls contain neutron-absorbing boron. It has been known for more than two decades that, in case of a loss of water in the pool, convective air cooling would be relatively ineffective in such a “dense- packed” pool. Spent fuel recently discharged from a reactor could heat up relatively rapidly to temperatures at which the zircaloy fuel cladding could catch fire and the fuel’s volatile fission products, including 30-year half-life 137Cs, would be released. The fire could well spread to older spent fuel. The long-term land-contamination consequences of such an event could be significantly worse than those from Chernobyl…(emphasis added)

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Alvarez et al., 2003 (Abstract, continued)

…No such event has occurred thus far. However, the consequences would affect such a large area that alternatives to dense-pack storage must be examined—especially in the context of concerns that terrorists might find nuclear facilities attractive targets. To reduce both the consequences and probability of a spent-fuel-pool fire, it is proposed that all spent fuel be transferred from wet to dry storage within five years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent fuel is estimated at $3.5–7 billion dollars or 0.03–0.06 cents per kilowatt-hour generated from that fuel. Later cost savings could offset some of this cost when the fuel is shipped off site. The transfer to dry storage could be accomplished within a decade. The removal of the older fuel would reduce the average inventory of 137Cs in the pools by about a factor of four, bringing it down to about twice that in a reactor core. It would also make possible a return to open-rack storage for the remaining more recently discharged fuel. If accompanied by the installation of large emergency doors or blowers to provide largescale airflow through the buildings housing the pools, natural convection air cooling of this spent fuel should be possible if airflow has not been blocked by collapse of the building or other cause. Other possible risk-reduction measures are also discussed…(emphasis added)

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Alvarez, 2011

Robert Alvarez, IPS

Spent Nuclear Fuel Panis in the U.S.: Reducing thP. Deadly Risks of Storage

from cuvcr

y Robert Alvarez ay2011

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Alvarez, 2011

From the Summary:

After more than 50 years, the quest for permanent nuclear waste disposal remains illusory.

One thing, however, is clear, whether we like it or not: the largest concentrations of radioactivity on the planet will remain in storage at U.S. reactor sites for the indefinite future. In protecting America from nuclear catastrophe, safely securing the spent fuel by eliminating highly radioactive, crowded pools should be a public safety priority of the highest degree.

With a price tag of as much as $7 billion, the cost of fixing America’s nuclear vulnerabilities may sound high, especially given the heated budget debate occurring in Washington. But the price of doing too little is incalculable. (emphasis added)

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Alvarez, 2011

Figure 9, Spent Fuel Inventories Greater Than 200 Million Curies

[In the U.S., there are] 28 reactor sites that have generated spent fuel containing about 200-450 million curies of radioactivity

Diablo Canyon 1 & 2, CA: ~225 Million Curies

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“In contrast, a large medical center, with as many as 1,000 approved laboratory areas in which radioactive materials are used, may have a combined inventory of only about two curies.”

Excerpt from “ROUTINE RADIOACTIVE RELEASES FROM U.S. NUCLEAR POWER PLANTS,” a pamphlet by Beyond Nuclear board of directors president Kay Drey of University City, MO.

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Re: von Hippel and Schoeppner, 2016 (case study, Peach Bottom Nuclear Power Plant, PA)

Science Magazine reported:

In their simulations, the Princeton duo focused on Cs-137, a radioisotope with a 30- year half-life that has made large tracts around Chernobyl and Fukushima uninhabitable. They assumed a release of 1600 petabecquerels, which is the average amount of Cs-137 that NRC estimates would be released from a fire at a densely packed pool. It’s also approximately 100 times the amount of Cs-137 spewed at Fukushima. They simulated such a release on the first day of each month in 2015.

The contamination from such a fire on U.S. soil “would be an unprecedented peacetime catastrophe,” the Princeton researchers conclude in a paper to be submitted to the journal Science & Global Security. In a fire on 1 January 2015, with the winds blowing due east, the radioactive plume would sweep over Philadelphia, Pennsylvania, and nearby cities. Shifting winds on 1 July 2015 would disperse Cs-137 in all directions, blanketing much of the heavily populated mid-Atlantic region. Averaged over 12 monthly calculations, the area exposed to more than 1 megabecquerel per square meter -- a level that would trigger a relocation order -- is 101,000 square kilometers [nearly 39,000 square miles]. That’s more than three times NRC’s estimate, and the relocation of 18.1 million people is about five times NRC’s estimates.

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Image for July 2015 weather conditions, courtesy of F. von Hippel and M. Schoeppner

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“Spent fuel fire on U.S. soil could dwarf impact of Fukushima,” by Richard Stone,

Science Magazine, 5/24/16 A fire from spent fuel stored at a U.S. nuclear power plant could have catastrophic consequences, according to new simulations of such an event.

A major fire “could dwarf the horrific consequences of the Fukushima accident,” says Edwin Lyman, a physicist at the Union of Concerned Scientists, a nonprofit in Washington, D.C. “We’re talking about trillion- dollar consequences,” says Frank von Hippel, a nuclear security expert at Princeton University, who teamed with Princeton’s Michael Schoeppner on the modeling exercise. (emphasis added)

The revelations come on the heels of a report last week from the U.S. National Academies of Sciences, Engineering, and Medicine on the aftermath of the 11 March 2011 earthquake and tsunami in northern Japan. The report details how a spent fuel fire at the Fukushima Daiichi Nuclear Power Plant that was crippled by the twin disasters could have released far more radioactivity into the environment.

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NAS, 2016 Desperate, ineffective, and high-risk Japan Self Defense Forces helicopter water drops, St. Patrick’s Day, 2011

A pool fire at Fukushima Daiichi Unit 4 was very narrowly averted, by sheer luck (or Divine Intervention?!)

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Pools are outside “robust containment”

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Close call with catastrophe, order(s) of magnitude worse than current one

Fukushima Daiichi Unit 4, Japan (pre-explosion) Prime Minister Naoto Kan

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Fukushima Daiichi Unit 4, Japan Mid-March, 2011, post-explosion

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Risks of Pool Storage & Transfers • Diablo Canyon Units 1 & 2, discovery of pool leakage in 2010,

confirmed by routine surveillance; “Leaked spent fuel pool water was contained within spent fuel pool leakage-collection system”; Table E-4, Occurrence of Spent Fuel Pool Leakage at U.S. Nuclear Power Plants, Appendix E, Analysis of Spent Fuel Pool Leaks, Page E- 23, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, Vol. 1, NUREG-2157, NRC, September 2014.

• Heavy load drop risk of pool drain down, zirconium fire (Prairie Island, MN & Palisades, MI transfer cask crane dangles; Vermont Yankee crane slip)

• Loss of grid power (boil down) • Natural disaster • Terrorist attack, sabotage, or act of war (pools as potential mega

dirty bombs)

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Crane risks

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Dry cask storage: Need for Robust, or Hardened On-Site Storage (HOSS),

with QA (Quality Assurance)! Dr. Arjun Makhijani, IEER Dr. Gordon Thompson, IRSS

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Statement of Principles for Safeguarding Nuclear Waste at Reactors (2006; 2009-2010; 2018)

• Require a low-density, open-frame layout for fuel pools

(to provide convection air current cooling); • Establish hardened on-site storage (retrievability; real-

time monitoring for radiation, temperature, pressure; as close as possible, as safely as possible, to point of generation);

• Protect fuel pools; • Require periodic review of HOSS facilities and fuel

pools; • Dedicate funding to local and state governments to

independently monitor the sites; • Prohibit reprocessing.

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Statement of Principles for Safeguarding Nuclear Waste at Reactors (2006; 2009-2010; 2018)

• https://www.eesi.org/files/Principles_for_Safeguarding_Nuclear_W

aste_at_Reactors.pdf

• Many hundreds of public interest and environmental organizations, representing all 50 states, including these 16 from CA:

Alliance for Nuclear Responsibility; PEACEWORKERS; CA Communities Against Toxics; Desert Citizens Against Pollution; Ecological Options Network (EON); SAVE THE PARK; Western States Legal Foundation; Grandmothers for Peace-SLO County Chapter; Terra Foundation; SLO Mothers for Peace Action Committee; Tri-Valley CARES; Redwood Alliance; Center for Safe Energy; Healing Ourselves and Mother Earth (H.O.M.E.); Committee to Bridge the Gap; Atomic Mirror.

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Dispersed/Concealed HOSS v. Plain View/Clustered Configuration

Graphic from “Robust Storage” by Dr.

“Bowling pins” Gordon Thompson, Jan. 2003

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There is no magic wand… The waste will not move for years, or even many decades The sobering realities:

• Operating reactors like Diablo

Canyon 1 & 2 are at the very back of the line for export of waste

• Even relatively recently shutdown reactors like San Onofre 2 & 3 are a ways down the waiting list for export of waste

• HOSS is a necessary safety and security upgrade, even if off- site storage or disposal were available now (which it is not)

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Cask/Canister Integrity (Or Lack Thereof)

Holtecs at D.C. Cook, MI, on the Lake Michigan shoreline Widespread Quality Assurance violations

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Summary of Whistle-blower Allegations of Holtec QA Violations

• Faulty welds • Unqualified fabrication materials • Defective neutron shielding material • Failure to perform coupon testing, Post-Weld Heat Treatment • Bypassing of hundreds of non-conforming conditions, without re-

analysis of structural integrity • Improper, uncertified design decisions and changes on the fly • No root cause investigation of epidemic of QA violations • Interference with QA audit, falsification of QA documentation • NRC incompetence, or worse—collusion, complicity

<https://web.archive.org/web/20151020093217/http://www.nirs.org/ radwaste//atreactorstorage/shiranialleg04.htm>

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Holtec Whistle-Blowers

Oscar Shirani (deceased), Commonwealth Edison/Exelon, lead Holtec Users Group QA inspector

• Asserted Holtec casks are “nothing but garbage cans” if they are not made in accordance with government specifications;

• Questioned Holtec casks’ structural integrity sitting still, at 0 mph, let alone going 60 mph, or faster (accident forces)

Dr. Ross Landsman, NRC Region 3 dry cask storage inspector (retired)

• Compared NRC/Holtec decision making

to NASA’s, that led to “Space Shuttles hitting the ground”

• Had previously warned in Feb., 1994 at

Palisades, MI: “[It is] the consequences that might occur from an earthquake that I’m concerned about. The casks can either fall into Lake Michigan or be buried in the loose sand because of liquefaction…It is apparent to me that NMSS [NRC’s Nuclear Materials Safety and Safeguards division] doesn’t realize the catastrophic consequences of their continued reliance on their current ideology.”

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“Garbage Cans of Death” Deb Katz, Ex. Dir., Citizens Awareness Network of the Northeast “Caravans of Conscience”

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Need for Emergency Cask-to-Cask Transfer Capability

• Empty irradiated nuclear fuel from vulnerable (and in some cases leaking) storage pools into HOSS, but…

• Maintain operability of empty pool, in order to have cask-to-cask transfer capability

• Emergency transfer may be needed, from failed/failing “old” cask/canister, to new replacement cask/canister

• If no pool, then hot cell, or Dry Transfer System (DTS), is needed • But…science fiction/fantasy of NRC’s Nuclear Waste Confidence

[Game], on-site or away-from-reactor “Dry Transfer Systems” (NRC’s empty promise, and false assurance; what about loss of institutional control, here and now!)

• NRC simply assumed safety, and in 2016, the federal court fell for it -- hook, line, and sinker (including D.C. Circuit Court of Appeals Justice – now U.S. Supreme Court Justice -- Brett Kavanaugh)

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Serious complications of returning INF to wet storage pool

• Elevated pools at GE BWRs; • Overlap of systems, structures, and components between

wet storage pool, and the rest of the nuclear power plant – dismantled during decommissioning;

• Disruption of convection air current cooling mechanism in dry cask (40-hour “race-against-the-clock” at Palisades, MI, for example, before overheating begins, in violation of technical specifications);

• Radioactive steam flash when thermally hot (750 degree F) dry cask waste canister enters 100 degree F wet storage pool water (radiation hazard; thermal shock hazard).

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Retention of pools is needed, even after their emptying of INF

But, there is a growing list of decommissioned/decommissioning sites with neither pool, nor hot cell/DTS:

Big Rock Point, MI; Connecticut Yankee; Maine Yankee; Yankee Rowe, MA; Zion, IL; etc.

That is, emergency response to any dry cask failure will have to be ad hoc.

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(CISFs) since Jan. 2018) + Orano (Areva) + NAC = ISP

Consolidated Interim Storage Facilities

Waste Control Specialists, LLC, Andrews County, Texas (WCS) – recently renamed Interim Storage Holtec/ELEA (Eddy-Lea [Counties] Energy Partners (ISP): WCS (owned by J.F. Lehman & Co. Alliance, New Mexico), just 16 miles from WIPP

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CISFs, A.K.A.

De facto permanent, surface storage, “parking lot” dumps

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CISFs multiply transport risks, for no good reason whatsoever

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Risks of decommissioning takeovers by CISF companies

• Holtec/SNC-Lavalin (Oyster Creek, NJ; Pilgrim, MA? Palisades, MI?)

• NorthStar (Vermont Yankee)

• EnergySolutions (Zion, IL – little to no financial auditing or accountability)

• Looting/raids of billion dollar decommissioning trust funds; lack of

adequate radiological cleanup; safety & security shortcuts on irradiated nuclear fuel management; rush to release still- contaminated sites for “unrestricted reuse.”

• Who gets the “cash cow” at Indian Point, NY?!

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Highly questionable corporate character

Holtec—bribery (attempted, as well as proven), racist remarks, QA violations.

SNC-Lavalin—bribery, human trafficking, barred by World Bank for 10 years, Justin Trudeau scandal.

NorthStar:

WCS--previously owned by Harold Simmons, “King of Superfund Sites” and funder of John Kerry’s 2004 “swift-boating”; now owned by J.F. Lehman & Co., of Tailhook scandal infamy.

Orano (Areva)—Niger uranium mining (Tuareg genocide), radioactive pollution of the Atlantic Ocean, externally contaminated HLRW shipments epidemic and cover up.

NAC (Nuclear Assurance Corporation)—HLRW shipping and handling incidents, as documented in Dr. Marvin Resnikoff’s book “The Next Nuclear Gamble” (1987).

EnergySolutions (formerly Envirocare)—Founded on a bribery/extortion scheme.

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“State sounds alarm over sale of Pilgrim for decommissioning,” AP, Feb. 20, 2019

BOSTON--Massachusetts officials raised major concerns Wednesday about Entergy's proposed sale of the soon-to-be-closed Pilgrim nuclear power plant in Plymouth to another company for decommissioning.

In a motion filed with the U.S. Nuclear Regulatory Commission, Democratic Attorney General Maura Healey and Republican Gov. Charlie Baker's administration asked that the state be allowed to intervene in the federal review of the pending deal, citing health, safety and financial risks associated with the planned transfer of Pilgrim's license to a New Jersey-based subsidiary of Holtec International.

Specifically, Healey and state Secretary of Energy and Environmental Affairs Matthew Beaton argue that Entergy and Holtec have failed to demonstrate that sufficient financial resources exist to safely decommission the plant and provide for the long-term storage of spent nuclear fuel at the site…

A citizen's advocacy group, Pilgrim Watch, also filed a motion to intervene on Wednesday, citing similar concerns as those expressed by state officials.

"The actual cost of decontaminating and restoring the Pilgrim site will be more, probably far more, than Holtec has estimated," the group wrote.

(emphasis added)

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Yucca Mountain, Nevada; Geologic Repository (Permanent Burial)

U.S. Rep. John Shimkus (R-IL) throws good [Be sure to count the toes!] money after bad down a rat hole -- $10,000

to $15,000 of taxpayer money, per site visit

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Yucca Mountain Non-Starters

• Illegal (U.S.-Western Shoshone Indian Nation “peace and friendship” Treaty of Ruby Valley of 1863; land title; water rights)

• Environmentally unjust (Nevada Test Site nuclear weapons testing fallout; LLRW dumping at NTS & Beatty, NV)

• Not consent-based, in violation of BRC 2012 Final Report recommendations

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Western Shoshone Indian Nation (Corbin Harney, Raymond Yowell)

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Western Shoshone Indian Nation (Ian Zabarte)

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Yucca Mountain Showstoppers

• “Screw Nevada” (Eastern site search “suspended”; granite geology excluded for political reasons)

• Double standard standards (per Dr. Makhijani: Disqualifying condition for fast-flow rate of water through site; C-14 releases to atmosphere)

• Intergenerational inequity (15 mR/yr standard, from present to 10,000 years; 23-fold increase, from 10,000 years to one million years)

• 11-mile buffer zone for groundwater “dilution” • No accounting for traditional Western Shoshone lifestyle

aggravated/exacerbated impacts • Regional equity (East dumps on West) • Maximized transport risks

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Export? Be careful what you wish for! (Transport risks)

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Risks of off-site transport

• Severe accidents • Attacks • Mobile X-Ray Machines That Can’t Be Turned

Off • Impacts on infrastructure (rails, bridges,

roads) due to very heavy loads (rail-sized casks weighing 100+ tons each)

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High Burnup makes everything worse (thermal heat, radioactivity, fuel cladding brittleness)

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Yucca-bound routes

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CA shipment numbers Under current law (70,000 MT limit at Yucca)*

Rail Casks: 755 Truck Casks: 857 Total Casks: 1,612

*No CA reactors operating with extended licenses, so no additional waste generated in state after 2025

(BUT, beware of multiple other states’ wastes passing through portions of s. and s.e. CA, as by rail, bound for Yucca Moutain, NV, immediately upstream of, and very near, the CA state line!)

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WCS/ISP, TX-bound routes

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WCS/ISP, TX-bound routes

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CA barge shipment route (DOE, Yucca FEIS, App. J, Feb. 2002)

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If not barges, then Heavy-Haul Trucks?! Down Avila Beach Drive?!

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CA road and rail routes

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L.A. area road and rail routes close up view

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Road and Rail Route Map Citations

CA state map: http://www.state.nv.us/nucwaste/news2017/pd f/States_Affected.pdf [Page 4 of 45 on PDF counter]

L.A. area close up view: http://www.state.nv.us/nucwaste/news2017/pd f/Cities_Affected.pdf [Page 9 of 20 on PDF counter]

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Woefully inadequate shipping cask design criteria

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Transport Risk: Underwater Submersion

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Transport Risk: High-Temperature, Long-Duration Fire

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Transport Risk: Attack

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Transport Risk: Mobile X-Ray Machines That Can’t Be Turned Off

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49 Exterior Surface Contamination Incidents in U.S. (1974-1992)

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France: Hundreds of externally contaminated shipments (25-33% of all shipments)

BEWARE reprocessing! Holtec/ELEA La Hague (Areva/Orano, of WCS/ISP CISF) wants to do it! West Valley, NY

cautionary tale

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Transport Risk: Infrastructure Collapse

• Impacts on infrastructure (rails, bridges, roads) due to heavy loads (rail-sized casks weigh 100+ tons each)

• ASCE's 2017 Infrastructure

Report Card | GPA: D+

• Big Rock Point radioactive RPV shipment (290 tons), follow-on train derailments in s.e. MI and the Carolinas, due to track damage in wake of very heavy nuclear waste shipment

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And we don’t even know what to do with the first cupful!