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Opposition to High-Level Nuclear Waste:
Information on Private Fuel Storage's Proposal
to Locate a High-level Nuclear Waste Storage Facility
on the Skull Valley Goshute Indian Reservation

| Background | Concerns | Contact |

 

Background

Private Fuel Storage L.L.C. (PFS) filed a license application in June 1997 with the U.S. Nuclear Regulatory Commission to build and operate a commercial, centralized, away-from-reactor, high level nuclear waste storage facility on the Skull Valley Band of Goshute Indian Reservation, Utah. The proposed facility location is in a seismically active area and near a military bombing range—the Utah Test and Training Range.

High Level Nuclear Waste

Commercial high level nuclear waste is generated from nuclear power reactors. In the United States, there are currently 104 commercial nuclear reactors located in 31 states. The bulk of commercial high level nuclear waste is generated east of Colorado where 92 percent of the reactors are located. Amount of Waste. PFS plans to store in Utah up to 40,000 metric tons of uranium (MTUs) of high level nuclear waste. The storage of this volume of waste in one location is unprecedented and is approximately the equivalent volume of all commercial high level nuclear waste currently in the United States. PFS plans to store the waste in up to 4,000 uncovered concrete storage casks on concrete storage pads. In contrast, today there are 436 dry storage units storing commercial high level nuclear waste in the entire United States. Moreover, 12 of the13 dry cask storage sites store between 0 and 44 storage units.

Transportation and Storage Casks

At the reactor sites, high level nuclear waste will be placed in steel canisters either directly in spent fuel pools or using a dry transfer system. Once the spent fuel is loaded into the canisters, the canisters are then filled with helium and welded shut. PFS plans to transport the canisters in steel transportation casks. These transportation casks typically weigh 150 tons. Once the transportation casks arrive at the storage facility, the canisters will be lifted from the transportation casks into transfer casks to shield radiation during transfer. The canisters will then be placed in concrete storage casks. The storage casks will be stored outside on concrete pads.

Away-from-Reactor Storage

There are 11 private and two U.S. Department of Energy (DOE) dry cask storage sites which store commercial high level nuclear waste. Unlike PFS's away-from-reactor storage proposal, 12 dry cask storage sites are located within 3,300 feet of the waste originating reactor. The other dry cask storage facility is located on a DOE reservation in Idaho.

Transportation of Waste

PFS plans to transport up to four casks of high level nuclear waste per week by rail across the country to Rowley Junction, Tooele County, Utah. From Rowley Junction, PFS will either continue transporting the spent nuclear fuel shipment by rail down the western part of Skull Valley or transfer the waste to heavy haul trucks for transport along Skull Valley Road to the PFS storage facility on the Skull Valley Goshute Indian Reservation. PFS plans to build a 34-mile rail spur in Skull Valley on public lands or a transfer facility at Rowley Junction, also on public lands. These lands are managed by the U.S. Bureau of Land Management. The rail spur will pass near a proposed wilderness area in the Cedar Mountains.

Transportation Routes

The high level nuclear waste will enter Utah near Evanston, Wyoming, Grand Junction, Colorado, or southern Utah. Waste from the east may enter Utah near Evanston, then travel across prime watershed areas in Weber Canyon, through Davis County and Salt Lake City, then west to Rowley Junction. Other waste from the east will enter Utah near Grand Junction, Colorado, then pass Green River and Price, and cross the watersheds in Price and Spanish Fork canyons, to Springville. From Springville the waste will likely travel north along the Wasatch Front through Utah and Salt Lake counties, then to Tooele County. Waste from Southern California will enter Utah near Uvanda, then travel north through Delta to Lynndyl. From Lynndyl the waste may be routed through Nephi, then up through Utah and Salt Lake counties or directly to Tooele Valley past the chemical weapons incinerator to Rowley Junction.

Concerns

  1. There is no guarantee that storage will be temporary.
    The proposed facility is to be designed and constructed as a temporary location for the storage of high level nuclear waste. However, there is no way to ensure the waste will ever be removed from the site. The permanent repository at Yucca Mountain, Nevada, is still undergoing extensive testing to determine whether the site is suitable for geologic disposal of high level nuclear waste. If construction of the Yucca Mountain site is not feasible, then the contentious repository siting process will start over again, and the PFS site could become a de facto permanent storage site. If Yucca Mountain is built, there is still no certainty if or when all the high level nuclear waste stored at Skull Valley will be removed to Yucca Mountain. Current federal law limits Yucca Mountain capacity for commercial high level nuclear waste at 63,000 MTUs. Under the existing reactor licenses, DOE projects that more than 63,000 MTUs of commercial spent fuel will be generated and will need a final storage or disposal location.
  2. There is no need for an away-from-reactor storage facility.
    Some reactor sites claim they are running out of existing storage capacity for high level nuclear waste. Other than the fact that communities located near the reactor sites do not want the waste stored near them, there is no good reason to store the waste away from the generating reactor sites. Reactors could build their own dry cask storage at their reactor sites.
  3. Unnecessary handling and transportation of spent fuel creates the risk of accidents.
    The probability of an accident increases the more the spent nuclear fuel is handled or the farther it is transported. Thus, the probability of an accident increases if the spent nuclear fuel is needlessly containerized and shipped to Skull Valley. PFS proposes to ship up to 200 casks—2,000 MTUs — of spent nuclear fuel to Utah each year. PFS may ship up to four casks per week. By contrast, from 1964 to 1994, there were only 345 commercial shipments of spent fuel throughout the United States. Also, the average quantity of commercial spent fuel that has been shipped per year is 75 MTUs. The spent nuclear fuel destined for Skull Valley will travel across the country from as far away as Maine. Such large volumes of spent nuclear fuel have not previously been moved in the United States.
  4. There is no need for PFS's requested 40,000 MTUs storage capacity.
    There are approximately 40,000 MTUs of commercial high level nuclear waste in the entire country. There is no need to concentrate such a large volume of spent fuel in one location, on a small Indian reservation in Utah. Moreover, PFS has not demonstrated a need or market for such a large facility. The NRC should not give PFS a license to store such a large capacity of spent nuclear fuel. PFS has no track record of being able to handle or manage—both practically and financially—such a vast quantity of spent nuclear fuel, and thus, PFS should not be given a license for a 40,000-MTUs facility.
  5. The PFS facility is unique so it should receive special consideration and additional requirements.
    Because the proposed facility is unique, licensing of the PFS facility should receive special consideration. PFS will be the only private away-from-reactor, dry cask storage facility in the United States. Long-term, dry cask technology is unproven because it has only been in existence for approximately 14 years. PFS proposes to keep high level nuclear waste in dry storage casks out in the open in Skull Valley for up to 40 years. Furthermore, there is a real potential that the casks may be on-site for longer than 40 years if Yucca Mountain is not built or will not accept all the waste stored at Skull Valley. The large 4,000 storage cask capacity facility is unprecedented. Today in the entire country there are 436 dry storage units. Moreover, 12 of the 13 dry cask storage sites store between 0 and 44 storage units. Transportation of the volume of spent fuel proposed by PFS is unprecedented and unproven.
  6. PFS has not adequately addressed its financial responsibility and liability.
    PFS is a limited liability company with no assets of its own. As a limited liability company, each member utility company that forms PFS will not be individually liable nor will its assets be individually at risk. NRC has not required PFS to submit detailed financial information. Prior to license issuance, NRC will not require PFS to demonstrate that it will likely be able to obtain sufficient funds to build, operate, and close the proposed facility. Instead, NRC will allow PFS to build the storage facility upon a showing that PFS has sufficient commitments, rather than actual funds in hand, to fund construction of an undisclosed sized facility that is smaller than the 40,000 MTUs requested in the license. In addition, NRC will allow PFS to operate if it has contract commitments, not funds, to cover costs of storing the volume of waste covered by PFS contracts. Allowing PFS to simply show commitments to fund construction and operation after the license is issued excludes any public participation or oversight. To date, PFS and the NRC have considered the majority of PFS financial information to be proprietary and not subject to public disclosure. Therefore, NRC's review will likely be kept confidential because PFS will claim that its financial information is proprietary.
  7. NRC has a poor record of evaluating a licensee's financial reliability.
    NRC's failure to adequately scrutinize funds available to an NRC licensee resulted in inadequate funds to address the Atlas tailings contamination in southern Utah. Atlas declared bankruptcy and, therefore, was not ultimately responsible for the necessary cleanup.
  8. NRC should require nuclear property insurance and off-site liability insurance.
    Federal rules do not require any on-site property liability insurance to ensure liability coverage in the event of accidents at the proposed PFS facility. It is also unclear whether the federal Price Anderson Act will provide liability coverage of spent fuel in the event that spent fuel is transported from another spent fuel storage facility and not the reactor.
  9. There is no funding for local emergency response training and equipment.
    Unlike federal shipments, private shipments of spent fuel do not require any funding for assessment of emergency response needs, local emergency response training, or equipment for radioactive incidents.
  10. PFS transportation requirements are less vigorous than radioactive waste shipments under the Nuclear Waste Policy Act or Waste Isolation Pilot Project.
    As the shipments to the PFS site will be private, PFS is not required to meet the same standards as DOE shipments (e.g., financial support for local and state governments to address infrastructure, emergency response, law enforcement, state input to route selection). Private shipments are not required to ship waste by dedicated service where only spent fuel is allowed to be carried on a train. All past U.S. commercial shipments of spent fuel were conducted as dedicated service rather than as mixed freight. Although PFS has indicated it plans to ship spent fuel by dedicated service, there are no NRC or U.S. Department of Transportation regulations that require PFS to do so. If the spent fuel is not shipped by dedicated service, spent fuel casks may be delayed in various rail yards across the country (including Ogden and Salt Lake) awaiting a connection to Rowley Junction. NRC should require PFS to ship spent fuel by dedicated service.
  11. Transportation risks must be assessed.
    PFS plans to potentially transport more than 4,000 casks of spent fuel across country. The risks associated with the transportation should be evaluated in the NRC licensing proceeding, but the NRC Licensing Board has not allowed Utah to litigate general transportation issues in the PFS proceeding. Spent fuel may be transported through heavily populated areas across the Wasatch Front, including Davis, Salt Lake, and Utah counties. Depending upon the circumstance, spent fuel may be stopped in various rail yards, including downtown Salt Lake City.
  12. Additional risks exist from a proposed intermodal transfer facility located next to Interstate 80.
    PFS may funnel over 4,000 casks of spent fuel through an intermodal transfer facility located 1.8 miles west of Rowley Junction adjacent to Interstate 80 to transfer the spent fuel from rail cars to heavy haul trucks. Although a transfer facility raises the same concerns as the storage facility (e.g., radiation exposure, security, safety, design concerns), NRC will not require PFS to meet any NRC licensing standards for the Rowley Junction facility.
  13. Seismic data quality is questionable.
    Although PFS collected and evaluated site specific seismic data, the State of Utah has numerous concerns with the quality of the data and whether the data accurately estimates the seismic potential of the area.
  14. The PFS storage facility is not currently designed to meet NRC seismic requirements.
    In order to build the facility designed to the standards PFS proposes, PFS must obtain an exemption from current NRC seismic regulations. NRC is ready to grant an exemption to PFS. As a consequence, the storage pads, the canister transfer building, and important safety equipment will be designed to a less rigorous standard and will not be designed to withstand the type of seismic events that NRC regulations currently require.
  15. PFS will not know if its facility's seismic design is exceeded.
    PFS has no plans to install ground-motion monitoring equipment to determine if the facility design is exceeded by a seismic event. PFS will have no indication of non visual damage to its structures to determine if the facility is still safe.
  16. Storage casks are not anchored in the event of an earthquake.
    The storage casks will not be anchored but will be freestanding on concrete pads. Thus, in the event of an earthquake, the storage casks will be allowed to slide on the pads or tip over. The cask design requires the storage casks to be upright within 48 hours to ensure the casks do not overheat. The State of Utah has questioned PFS's ability to upright up to 4,000, 175-ton casks in the required 48 hours. NRC has rejected this concern.
  17. The PFS facility is incompatible with surrounding military activities.
    The PFS facility will be located east of the Utah Test and Training Range (UTTR) property and underneath the UTTR airspace designated as a military operating area. The activities approved in the airspace over the PFS storage facility include air-to-air training, low-altitude training, cruise-missile testing, and major military exercises. The main use of the Skull Valley airspace is to allow low- and medium-altitude entries of F-16s into the UTTR from Hill Air Force Base. The State of Utah has raised great concern with the potential of aircraft crashes, including military aircraft, into the storage facility. Additionally, the military tests large footprint weapons, including cruise missiles, on the UTTR. Cruise-missile testing may last up to five hours, as the cruise missile follows a preplanned flight path through the UTTR airspace. Three cruise missiles have crashed since December 1997, including two outside of military property under the military operating area airspace. The State of Utah has raised concerns with the potential of cruise-missile crashes into the storage facility.
  18. The PFS storage facility may negatively impact the training ability of the Fighter Wings at Hill Air Force Base and their military readiness.
    Regardless of NRC's evaluation of the risks related to military activities, the Air Force may be forced to restrict its use of the military operating area in Skull Valley. The State of Utah is also concerned with the potential limits that the PFS storage facility may impose on the Air Force. The UTTR-Dugway Proving Ground is the largest military training land mass in the world. The Air Force, in part, credits its success during Desert Storm and its overall military readiness to its ability to train at the UTTR. Hill Air Force Base's ability to make low- and medium-altitude entries is critical to successful training.
  19. Dry cask technology is not infallible.
    The proposed canisters and casks have not been subject to any actual tests. Moreover, some casks in use today have had numerous problems, such as hairline fractures during manufacturing, an explosion due to a chemical reaction during loading of the casks, and cask-weld failures. Contrary to nuclear industry supporters, the casks are definitely not infallible.
  20. Future land use must be considered now.
    Tooele County is experiencing tremendous population growth. The predominate growth is in Tooele Valley, but the lack of water resources in Tooele Valley may push residential housing demand into Skull Valley. However, the stigma associated with the storage of high level nuclear waste may not make Skull Valley an attractive residential housing area.
  21. NRC can grant exemptions with little or no public scrutiny.
    NRC can grant exemptions to its regulations with virtually no justification of the exemption. For example, NRC will allow PFS to provide decommissioning funds for each storage cask only prior to use rather than before the license is issued as required by the regulations. Additionally, NRC will likely allow PFS to design its facility to withstand lower ground motion from an earthquake than is currently required.
  22. Risk of sabotage must be considered.
    The potential risk of sabotage or terrorism while the spent fuel is in transportation and storage must be considered. New armor-piercing weapons are currently available that may easily penetrate the transportation casks.
  23. Economic impact must be evaluated.
    The economic impact from real and perceived risks must be evaluated. Utah may suffer economically from the stigma, as such large volumes of high level nuclear waste will be transported along the Wasatch Front and be stored close by.
  24. Increased wildfires in Skull Valley have not been evaluated.
    The increased potential for wildfires due to the proposed rail spur in Skull Valley or the storage facility has received only marginal attention before the NRC. Such impacts should be fully evaluated.

Contact

For additional information, contact:

Connie Nakahara, Director
High Level Nuclear Waste Storage Opposition
Utah Department of Environmental Quality
801-366-0523
Visit the Opposition to High-Level Nuclear Waste Web site.

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