3.4 FINDINGS AND RECOMMENDATIONS
Based on its review of spent fuel pool risks, the committee offers the following findings and recommendations.
FINDING 3A: Pool storage is required at all operating commercial nuclear power plants to cool newly discharged spent fuel.
Operating nuclear power plants typically discharge about one-third of a reactor core of spent fuel every 18–24 months. Additionally, the entire reactor core may be placed into the spent fuel pool (offloaded) during outage periods for refueling. The analyses of spent fuel thermal behavior described in this chapter demonstrate that freshly discharged spent fuel generates too much decay heat to be passively air cooled. The Nuclear Regulatory Commission requires that this fuel be stored in a pool that has an active heat removal system (i.e,, water pumps and heat exchangers) for at least one year as a safety matter. Current design practices for approved dry storage systems require five years’ minimum decay in spent fuel pools. Although spent fuel younger than five years could be stored in dry casks, the changes required for shielding and heat removal could be substantial, especially for fuel that has been discharged for less than about three years.
FINDING 3B: The committee finds that, under some conditions, a terrorist attack that partially or completely drained a spent fuel pool could lead to a propagating zirconium cladding fire and the release of large quantities of radioactive materials to the environment Details are provided in the committee’s classified report.
It is not possible to predict the precise magnitude of such releases because the computer models have not been validated for this application.
FINDING 3C: It appears to be feasible to reduce the likelihood of a zirconium cladding fire following a loss-of-pool-coolant event using readily implemented measures.
There appear to be some measures that could be taken to mitigate the risks of spent fuel zirconium cladding fires in a loss-of-pool-coolant event. The following measures appear to have particular merit.
Reconfiguring of spent fuel in the pools (i.e., redistribution of high decay-heat assemblies so that they are surrounded by low decay-heat assemblies) to more evenly distribute decay-heat loads. The analyses described elsewhere in this chapter suggest that the potential for zirconium cladding fires can be reduced substantially by surrounding freshly discharged spent fuel assemblies with older spent fuel assemblies in “checkerboard” pattems. The analyses suggest that such arrangements might even be more effective for reducing the potential for zirconium cladding fires than removing this older spent fuel from the pools. However, these advantages have not been demonstrated unequivocally by modeling and experiments.
Limiting the frequency of offloads of full cores into spent fuel pools, requiring longer shutdowns of the reactor before any fuel is offloaded to allow decay-heat levels to be managed, and providing enhanced security when such offloads must
be made. The offloading of the reactor core into the spent fuel pool during reactor outages substantially raises the decay-heat load of the pool and increases the risk of a zirconium cladding fire in a loss-of-pool-coolant event. Of course, any actions that increase the time a power reactor is shut down incur costs, which must be considered in cost-benefit analyses of possible actions to reduce risks.
Development of a redundant and diverse response system to mitigate loss-of-pool-coolant events. Any mitigation system, such as a spray cooling system, must be capable of operation even when the pool is drained (which would result in high radiation fields and limit worker access to the pool) and the pool or overlying building, including equipment attached to the roof or walls, is severely damaged.
FINDING 3D: The potential vulnerabilities of spent fuel pools to terrorist attacks are plant-design specific. Therefore, specific vulnerabilities can be understood only by examining the characteristics of spent fuel storage at each plant.
As described in the classified report, there are substantial differences in the design of PWR and BWR spent fuel pools. PWR pools tend to be located near or below grade, whereas BWR pools typically are located well above grade but are protected by exterior walls and other structures. In addition, there are plant-specific differences among BWRs and PWRs that could increase or decrease the vulnerabilities of the pools to various kinds of terrorist attacks, making generic conclusions difficult.
FINDING 3E: The Nuclear Regulatory Commission and independent analysts have made progress in understanding some vulnerabilities of spent fuel pools to certain terrorist attacks and the consequences of such attacks for releases of radioactivity to the environment. However, additional work on specific issues listed in the following recommendation is needed urgently.
The analyses carried out to date for the Nuclear Regulatory Commission by Sandia National Laboratories and by other independent organizations such as EPRI and ENTERGY have provided a general understanding of spent fuel behavior in a loss-of-pool-coolant event and the vulnerability of spent fuel pools to certain terrorist attacks that could cause such events to occur. The work to date, however, has not been sufficient to adequately understand the vulnerabilities and consequences. This work has addressed a small number of plant designs that may not be representative of U.S. commercial nuclear power plants as a whole. It has considered only a limited number of threat scenarios that may underestimate the damage that can be inflicted on the pools by determined terrorists. Additional analyses are needed urgently to fill in the knowledge gaps so that well-informed policy decisions can be made.
RECOMMENDATION: The Nuclear Regulatory Commission should undertake additional best-estimate analyses to more fully understand the vulnerabilities and consequences of loss-of-pool-coolant events that could lead to a zirconium cladding fire. Based on these analyses, the Commission should take appropriate actions to address any significant vulnerabilities that are identified. The analyses of the BWR and PWR spent fuel pools should be extended to consider the consequences of loss-of-pool-coolant events that are described in the committee’s classified report.
The consequence analyses should address the following questions:
To what extent would such attacks damage the spent fuel in the pool, and what would be the thermal consequences of such damage?
Is it feasible to reconfigure the spent fuel within pools to prevent zirconium cladding fires given the actual characteristics (i.e., heat generation) of spent fuel assemblies in the pool, even if the fuel were damaged in an attack? Is there enough space in the pools at all commercial reactor sites to implement such fuel reconfiguration?
In the event of a localized zirconium cladding fire, will such rearrangement prevent its spread to the rest of the pool?
How much spray cooling is needed to prevent zirconium cladding fires and prevent propagation of such fires? Which of the different options for providing spray cooling are effective under attack and accident conditions?
Sensitivity analyses should also be undertaken to account for the full range of variation in spent fuel pool designs (e.g., rack designs, capacities, spent fuel burn-ups, and ages) at U.S. commercial nuclear power plants.
RECOMMENDATION: While the work described in the previous recommendation under Finding 3E, above, is being carried out, the Nuclear Regulatory Commission should ensure that power plant operators take prompt and effective measures to reduce the consequences of loss-of-pool-coolant events in spent fuel pools that could result in propagating zirconium cladding fires. The committee judges that there are at least two such measures that should be implemented promptly:
Reconfiguring of fuel in the pools so that high decay-heat fuel assemblies are surrounded by low decay-heat assemblies. This will more evenly distribute decay-heat loads, thus enhancing radiative heat transfer in the event of a loss of pool coolant.
Provision for water-spray systems that would be able to cool the fuel even if the pool or overlying building were severely damaged.
Reconfiguring of fuel in the pool would be a prudent measure that could probably be implemented at all plants at little cost, time, or exposure of workers to radiation. The second measure would probably be more expensive to implement and may not be needed at all plants, particularly plants in which spent fuel pools are located below grade or are protected from external line-of-sight attacks by exterior walls and other structures.
The committee anticipates that the costs and benefits of options for implementing the second measure would be examined to help decide what requirements would be imposed. Further, the committee does not presume to anticipate the best design of such a system—whether it should be installed on the walls of a pool or deployed from a location where it is unlikely to be compromised by the same attack—but simply notes the demanding requirements such a system must meet.