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The NRC analysis for the DEIS does not take the behavior of CRUD into account. In a Category 6 accident, involving damage to fuel, Cobalt-60 that adheres to the outside of fuel assemblies and Cobalt-60 within the metal matrix will be released. In contrast, the other particulates would be released only in the event of damage to the fuel cladding.(1)
Moreover, the Staff's calculation of the release fraction for Cobalt-60 is also inconsistent with other studies. As discussed previously, SAND88-1358 assumed that 100% of CRUD would be spalled from fuel rods for all impact-related releases. Moreover, the consequence assessment for the "maximum reasonably foreseeable accident scenarios" performed for the DEIS for the Yucca Mountain repository is based on default assumptions contained in the RISKIND computer code, which include a 100% spallation and release of CRUD into the environment in the event of a severe accident.(2)
As seen in the following table, the State's calculations show that including CRUD and employing the software program RISKIND, a person residing in an area contaminated by an accidental release for one week would incur a 10% greater dose. If a person resided in a contaminated area for one year, the increased dose due to CRUD release would be 23.5%.
| long-term exposure time | 100% CRUD Release Fraction1 | 10-5 CRUD release Fraction2 | % difference | ||
|---|---|---|---|---|---|
| population-dose | LCF | population-dose | LCF | ||
| 1 week | 6880 | 3.44 | 6190 | 3.095 | 10.0 |
| 1 year | 24300 | 12.15 | 18600 | 9.3 | 23.5 |
| 50 years | 194000 | 97 | 157000 | 78.5 | 19.1 |
Accordingly, the DEIS underestimates the radiological consequence of a severity 6 accident and, thus, does not comply with NEPA.
1. 1 The State notes that the listing of "physical/chemical group" and "dispersibility category" do not appear in the PFS ER. These have been constructed by Staff contractors for the DEIS.
2. 2 ANL/EAD-1, Yuan et al., "RISKIND - A Computer Program for Calculating Radiological Consequences and Health Risks for Transportation of Spent Nuclear Fuel" (November 1995), Argonne National Laboratory.
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