Yucca Mountain - Too Little ... Too Late?

NRC Package Performance Study (NUREG-1768)
Talking Points

The Nuclear Regulatory Commission (NRC) has issued a report draft for public comment on the standards for testing high-level radioactive waste transportation casks. Unfortunately, the draft states in more that one place that they do not intend to develop new standards for cask testing, that the agency's current regulations are as adequate as they need to be, and that the report does not imply any commitment on the part of the NRC to conduct any of these tests.

This is a very important issue since the federal government seems determined to start shipping thousands of tons of high-level radioactive waste across the country. We must keep the pressure on them to do the right thing for the safety of the American people.

Shundahai Network (SN) feels that:

- NRC should make full-scale physical testing to failure a licensing requirement for every cask design. (Currently the agency relies mainly on computer modeling.)
- NRC now suggests subjecting just two cask designs to "extra-regulatory" full-scale physical tests. At the very least, the agency should test every cask design proposed for shipments to Yucca Mountain and Private Fuel Storage projects.
- NRC proposes only fire and crash tests. The testing regime should be expanded to include puncture, crushing force, and deep immersion tests.
- NRC's proposed tests will not evaluate cask vulnerability to attack. NRC should expand the testing regime to include the explosive and missile attacks.
- NRC should test full-scale casks, not just scale models.
- NRC should test casks to failure, not just to arbitrary standards.
- The surest way to reduce nuclear waste transportation dangers is to limit the number of shipments!

Shundahai expects:

1) Reevaluation of NRC cask performance standards with meaningful stake holder participation

2) Meaningful stake holder input and participation from ALL affected areas (proposed routes) in development of testing protocols, selection of test facilities, and personnel

3) Full scale testing to failure of casks PRIOR to NRC certification. This would include:
a. every cask model used
b. casks selected at random
c. in real world accident/attack situations
d. testing ALL possible shipping scenarios (train, truck, barge, etc.)
e. scenarios that "could never" happen

4) Openness and transparency

5) Public and media oversight of all tests

The following is a list of specific issues about which the Nuclear Regulatory Commission is specifically soliciting comments. Our responses are listed after each item.

1. NRC--the types and number of cask designs that should be tested.
SN-- A random cask from every model that already is licensed or is to be licensed.

2. NRC--The speed and orientation used in the impact tests.
SN--The maximum speed the cask could be traveling as well as the maximum speed a runaway train and/or truck could be traveling

3. NRC--The method used to conduct the impact tests, dropped from a tower as proposed in this report or propelled along a horizontal track (e.g., on a rocket-sled track)
SN-- Both

4. NRC--The reasonableness of the proposed range of speeds (96 to 144 kph [60 to 90 mph]) given that the frequency with which a rail cask might be expected to impact a hard rock surface at these speed is 10-6 to 10-8 per year.
Public--Same as #2. It does not matter if the "likelihood" is small, if there is any possibility at all it should be tested for.

5. NRC--The appropriateness of the impact speed of 120 kph [75 mph] proposed by the NRC staff or the rail cask collision test and the appropriate speed for the truck cask collision test.
SN-- Same as #2.

6. NRC--The scale of the casks to be tested ( e.g., full-sized casks or partial scale)
SN-- Full size, exact design.

7. NRC --The duration and size of the cask fire test.
SN--Test to failure with the hottest burning substance that is shipped in bulk and can pool on our nations roads and rails.

8. NRC--The position of the cask relative to the fire.
SN--Fully engulfed and concentrated on known and perceived weak spots such as, but not limited to the lid and the welds.

9. NRC--The number and type(s) of fuel assemblies included in the casks, and the ability of the proposed tests to yield risk insights consistent with NRC's risk-informed regulatory initiatives.
SN--We are uncomfortable with the idea of contaminating anyplace or anything either on purpose or accidentally. This question needs more study. However the very real possibility of damaged fuel rods, heat and radionucleide decay in all conditions does need to be fully and openly studied and planned for.

To get a copy of the report online, go to
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1768/
or contact: Office of the Chief Information Officer, Reproduction & Distribution
Services Section
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
E-mail: distribution@nrc.gov
Fax: 301.415.2289

Please send your comments by May 30, 2003 to: Chief, Rules Review and Directives
Nuclear Regulatory Commission
Mail Stop T-6-D-59
Washington, DC 20555-0001
Please specify the report number, Draft NUREG-1768 in your comments.

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