State of Nevada; Denial of a Petition for Rulemaking, 60288-60290 [E7-20919]
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Federal Register / Vol. 72, No. 205 / Wednesday, October 24, 2007 / Proposed Rules
increase in training and experience
hours was generally necessary for
physicians authorized under § 35.390, to
qualify as an authorized user under the
limited authorization of performing oral
administration of sodium iodide I–131,
a physician must have 80 hours of
classroom and laboratory training and
the specified supervised work
experience. As noted in the
SUPPLEMENTARY INFORMATION (70 FR
16336; March 30, 2005), the NRC based
its determination on licensee use, NRC
inspections, and experience with
medical events reported after the
effective date of the 2002 rule. The
petitioner has not provided sufficient
specific information that would warrant
the NRC to reconsider this
determination.
The petitioner has asserted that the
training and experience requirements
for the parenteral administration of
unsealed byproduct material are unduly
burdensome and that an entire class of
physicians is unfairly discouraged from
providing FDA-approved and
commercially available treatments. The
petitioner believes this results in an
adverse impact on their ability to
practice medicine and discourages
medical oncologists/hematologists from
providing these FDA-approved and
commercially available treatments. The
NRC is unaware of problems in
Agreement States or non-Agreement
States with patient access to these
treatments that would indicate that the
training and experience requirements
represent an unnecessary burden.
Neither the petitioner nor the
commenters supporting the petition
provided specific information or data
supporting the assertion that there is a
problem with patient access to these
treatments resulting from unnecessarily
burdensome requirements for training
and experience. The training and
experience requirements are intended to
ensure that authorized users of
byproduct material are properly trained
and adequately informed. The NRC
believes that the currently required
amount of training and experience for
the parenteral administration of
unsealed byproduct material requiring a
written directive is appropriate and
does not represent an unnecessary
burden.
The NRC notes that its requirements
are not written to favor or penalize any
class of physician (e.g., any physician
can qualify as an authorized user for the
oral administration of sodium iodide I–
131), but are written to reflect the
training necessary to ensure that
authorized user physicians have
adequate training. The alternate
pathways for acquiring the training and
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experience necessary to become an
authorized user were developed to
provide physicians with a way to
qualify for authorized user status,
without having to acquire board
certification or to have any particular
specialty. Consequently, the NRC does
not believe that medical oncologists/
hematologists or any other class of
physician are unfairly discouraged from
becoming an authorized user or treating
their patients.
The NRC’s regulatory approach is
intended to provide a flexible, riskinformed approach to the regulation of
medical uses of byproduct material. In
addition, the existing approach reduces
the need to revise requirements for
individual radiopharmaceuticals. The
training and experience requirements
for the medical use of byproduct
material are a matter of strict
compatibility between the NRC and the
Agreement States and have been
assigned Compatibility Category B. This
means that Agreement States should
adopt program elements essentially
identical to those established by the
NRC. In addition, training programs for
candidates of the medical specialty
boards may have to adapt their training
programs to remain current with
changes to NRC and Agreement State
training and experience requirements.
The current approach to training and
experience for the medical use of
unsealed byproduct material
accommodates the introduction of new
radiopharmaceuticals without requiring
additional rulemaking, with its
associated costs to the Agreement
States. Attempting to tailor the training
and experience requirements to specific
uses of unsealed byproduct material and
to the amount of flexibility that a user
may wish to have would significantly
increase the complexity of the
regulatory oversight. The NRC does not
believe that such added complexity
would be of benefit to patients, the
Agreement States, licensees, current and
prospective authorized users, or the
medical specialty boards.
The decision to deny the petition is
consistent with the NRC strategic goals
and strategies as described in the NRC
Strategic Plan for fiscal years 2004
through 2009 (NUREG–1614). The
training and experience requirements
for the parenteral administration of
unsealed byproduct material, including
Quadramet, Bexxar, and Zevalin, do not
present a significant regulatory
impediment to the safe and beneficial
use of these radioactive materials. In
addition, the amount of classroom and
laboratory training required to become
an authorized user for the
administration of these
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radiopharmaceuticals is necessary to
protect public health and safety and the
NRC regulations would not be improved
by changing the requirements.
In conclusion, the NRC is denying the
petition because the NRC has
determined that the current
requirements establish the appropriate
amount of training and experience for a
physician to become an authorized user
for the parenteral administration of
Quadramet, Bexxar, and Zevalin and
that the NRC requirements do not
impose an unnecessary regulatory
burden for the use of Quadramet,
Bexxar, Zevalin, and similar
radiopharmaceuticals. The existing NRC
regulations provide the basis for NRC to
have reasonable assurance that public
health and safety is adequately
protected. Neither the petitioner nor the
commenters supporting the petition
have provided sufficient information
such as would warrant the regulatory
relief sought by the petitioner.
For the reasons cited in this
document, the NRC denies this petition.
Dated at Rockville, Maryland, this 5th day
of October, 2007.
For the Nuclear Regulatory Commission.
William F. Kane,
Acting Executive Director for Operations.
[FR Doc. E7–20918 Filed 10–23–07; 8:45 am]
BILLING CODE 7590–01–P
NUCLEAR REGULATORY
COMMISSION
10 CFR Part 63
[Docket No. PRM–63–2]
State of Nevada; Denial of a Petition
for Rulemaking
Nuclear Regulatory
Commission.
ACTION: Petition for rulemaking: Denial.
AGENCY:
SUMMARY: The U.S. Nuclear Regulatory
Commission (NRC or Commission) is
denying a petition for rulemaking
submitted by the State of Nevada (PRM–
63–2). The petition requests that NRC
amend its regulations for the proposed
geologic repository at Yucca Mountain,
Nevada (YM) to specify the limits of
permissible spent fuel storage at the YM
site. Petitioner believes that the U.S.
Department of Energy (DOE) is planning
to construct an Aging Facility at the YM
site designed to store 21,000 metric tons
of heavy metal in what petitioner
believes is a manifest violation of the
Nuclear Waste Policy Act of 1982, as
amended, and the Commission’s
regulations. NRC is denying the petition
because NRC’s current regulations are
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consistent with law and do not permit
storage of spent nuclear fuel at the YM
site unless such storage is integral to
waste handling, necessary treatment,
and disposal at the proposed repository,
including storage which is integral to
the thermal-loading strategy for disposal
that DOE may include in its design of
the entire repository system. DOE must
make the case, in its anticipated license
application, that any contemplated
storage of spent nuclear fuel is
permissible because it is integral to
waste handling, necessary treatment,
and disposal activities. NRC believes
that, without an application currently
before the agency, the issues raised by
the petition are best addressed during
the agency’s review of the application
when a final design will be available
and an opportunity to request a hearing
will be offered.
ADDRESSES: Publicly available
documents related to this petition,
including the petition for rulemaking
and NRC’s letter of denial to the
petitioner may be viewed electronically
on public computers in NRC’s Public
Document Room (PDR), 01F21, One
White Flint North, 11555 Rockville
Pike, Rockville, Maryland. The PDR
reproduction contractor will copy
documents for a fee. Publicly available
documents created or received at NRC
after November 1, 1999, are also
available electronically at the NRC’s
Electronic Reading Room at https://
www.nrc.gov/reading-rm/adams.html.
From this site, the public can gain entry
into the NRC’s Agencywide Documents
Access and Management System
(ADAMS), which provides text and
image files of NRC’s public documents.
If you do not have access to ADAMS or
if there are problems in accessing the
documents located in ADAMS, contact
the PDR reference staff at (800) 387–
4209, (301) 415–4737 or by e-mail to
pdr@nrc.gov.
FOR FURTHER INFORMATION CONTACT: E.
Neil Jensen, Office of the General
Counsel, U.S. Nuclear Regulatory
Commission, Washington, DC 20555–
0001, telephone (301) 415–1637 or Toll
Free: 1–800–368–5642, e-mail:
enj@nrc.gov.
SUPPLEMENTARY INFORMATION:
The Petition
On December 22, 2006, the State of
Nevada (petitioner or the State)
submitted a ‘‘Petition for Rulemaking to
Amend Part 63 to Clarify the Limits on
Spent Fuel Storage at the Yucca
Mountain Site’’ (petition) which was
docketed as a petition for rulemaking
under 10 CFR 2.802 of the
Commission’s regulations (PRM–63–2)
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(available in the Agencywide Document
Access and Management System
(ADAMS) No. ML070030020). The State
supplemented its petition by letter of
January 23, 2007 (ML070330245). The
petition requests amendments to 10 CFR
part 63, NRC’s regulations governing the
disposal of high-level radioactive waste
(HLW) in a proposed geologic repository
at YM. The petitioner believes that 10
CFR part 63 must be amended to specify
the limits of permissible spent fuel
storage at YM, together with related
changes to 10 CFR part 71.
Petitioner asserts that, at an August
29, 2006 technical exchange and
management meeting between NRC and
DOE, DOE indicated that its design for
the geologic repository included both a
‘‘Receipt Facility’’ and an ‘‘Aging
Facility’’ or ‘‘Aging Pad’’. (Meeting
summary, ML062710597). The Receipt
Facility would be designed to receive
commercial spent nuclear fuel (SNF)
from off-site and prepare it for the Aging
Facility. The Aging Facility would be
designed to store 21,000 metric tons of
heavy metal (MTHM) on the YM site.
See DOE, Office of Civilian Radioactive
Waste Management, Surface Facilities
Overview and Canister Receipt and
Closure Facility, slides presented to
NRC/DOE Technical Exchange and
Management Meeting on Design
Changes Approved Through DOE’s
Critical Decision (CD–1) Process, August
29, 2006, Las Vegas, Nevada (DOE
slides) (ML062510423). Petitioner
further asserts that, in an NRC Staff
response to the State’s letter asking
about what surface storage of SNF might
be allowed at YM under the Nuclear
Waste Policy Act of 1982, as amended
(NWPA), 42 U.S.C 10101 et seq., and 10
CFR Part 63, NRC stated that surface
storage is permissible ‘‘to the extent
such storage is integral to waste
handling and disposal at the proposed
repository,’’ and that ‘‘storage may also
be integral to the thermal-loading
strategy the applicant may adopt in its
design of the entire repository system.’’
See Letter to Robert R. Loux from Jack
R. Strosnider, December 4, 2006
(ML062900384).
Petitioner believes that it is unclear
why a thermal loading strategy must
necessarily require the storage of
significant quantities of SNF on the YM
site and holds that ‘‘it is absurd to
suppose that storage in capacities
approaching anywhere near 21,000
MTHM on the Site could be justified as
part of a ‘thermal loading’ strategy that
‘is integral to waste handling and
disposal.’’ Petition at 1. Further,
petitioner supplemented its petition to
state that DOE’s preliminary
specifications for a transportation, aging
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60289
and disposal (TAD) canister system
suggest that DOE is planning on longterm storage of SNF at YM. See DOE,
Office of Civilian Radioactive Waste
Management, Civilian Radioactive
Waste Management System: Preliminary
Transportation, Aging and Disposal
Canister System Performance
Specification, Revision A, DOE/RW–
0585, November 2006 (DOE
Performance Specification) (Licensing
Support Network No. DN20023585505).
Petitioner believes that DOE’s plans
for an Aging Facility that could contain
21,000 MTHM are ‘‘manifestly
unlawful’’ and requests that NRC amend
10 CFR part 63 to specify by rule the
limits of permissible spent fuel storage
at YM, together with related changes to
10 CFR part 71. As support for its
petition, the State provides an analysis
of provisions of the NWPA which
demonstrate, in petitioner’s view, that
storage of SNF at YM is unlawful. In
brief, petitioner argues that the structure
and text of the NWPA show that
Congress intended the repository to be
for disposal only. This is because
Congress provided for a repository for
disposal of SNF in Subtitle A of the
statute, but separately provided for a
limited interim storage program in
Subtitle B and for potentially longer
term storage in a monitored retrievable
storage facility (MRS) in Subtitle C. Both
Subtitle B and Subtitle C contain
provisions which would effectively
prevent storage in a state being
considered for a repository. Petitioner
points out that ‘‘if Congress had
intended a repository site to be used for
storage, neither Subtitle B nor Subtitle
C would have been necessary, and the
statutory prohibition on co-location of a
repository and an interim storage
facility or MRS would have been
nonsensical.’’ Petition at 3. Thus,
petitioner concludes, the structure of
NWPA demonstrates that a repository is
for disposal only.
Petitioner requests three changes to
NRC’s rules. First, 10 CFR 63.21(c)(22)
(regarding the contents of the license
application) would be amended to add
a new paragraph viii at the end:
viii. Plans for the emplacement of spent
nuclear fuel in the underground facility
within a reasonably short time after it is
received (in no event longer than one year),
and information to explain why any facilities
for the storage of spent nuclear fuel in the
repository operations area or on the Site are
integral to safe waste handling and disposal
in the underground facility.
Second, 10 CFR 63.41(b) (regarding
required license conditions) would be
amended to add a new subsection (c):
(c). The license shall include additional
conditions as follows: (1) No spent nuclear
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fuel may be received in the geologic
repository operations area, or on the Site,
unless there is reasonable assurance that it
can be moved into the underground facility
within a reasonably short time (in no event
later than one year after receipt); (2) no spent
nuclear fuel may be stored in the geologic
repository operations area, or on the Site,
unless such storage is necessary for the safe
and efficient emplacement of spent fuel in
the underground facility; and (3) no spent
nuclear fuel may be stored in the geologic
repository operations area, or on the Site, for
the purpose primarily of aging (cooling or
radioactive decay) prior to emplacement in
the underground facility. The foregoing
conditions do not preclude the construction
of storage space to allow retrieval of spent
fuel after its emplacement in the
underground facility or for the amelioration
of emergency conditions associated with the
repository’s operation.
Third, to ensure proper coordination
between DOE and reactor licensees
desirous of sending spent fuel to the
repository, 10 CFR 71.5 would be
amended by adding a new subsection
(c):
(c). No licensee possessing spent reactor
fuel may deliver the fuel to the Department
of Energy or to a carrier for transport to
Yucca Mountain, or transport the fuel to
Yucca Mountain, unless the fuel either
complies with waste disposal criteria
(including thermal loading criteria) approved
by the Commission, or the fuel is expected
to do so within one year after receipt at the
Yucca Mountain site. In complying with this
subsection, a licensee may rely on
compliance certifications provided by the
Department of Energy.
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Reasons for Denial
Petitioner recognizes that NRC’s
regulations are currently in harmony
with its view of what storage is
permissible:
In the preamble to the original Part 63,
NRC stated that no license to receive waste
or spent fuel would be issued until NRC is
able to find that DOE has completed
construction of sufficient underground
storage space for initial operations, and it
concluded that Part 63 does not allow early
use of surface facilities for storage of spent
fuel. 66 FR 55738 (November 2, 2001). This
is consistent with the text of 10 CFR
63.41(a)(1), which provides that no license
may be issued until NRC finds that
construction of ‘‘[a]ny underground storage
space required for initial operation [is]
substantially complete.’’ Thus, NRC’s
regulations appear consistent with NWPA in
eliminating the possibility of spent fuel
storage that is decoupled from actual
repository operations and logistics.
Petition at 4, n.3. Indeed, NRC
recently reaffirmed this interpretation of
its regulations when it informed
petitioner that surface storage of spent
fuel is only permissible, under 10 CFR
part 63, to the extent such storage is
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15:24 Oct 23, 2007
Jkt 214001
integral to waste handling and disposal
at the proposed repository (including
storage which is integral to the thermalloading strategy the applicant may
adopt in its design of the entire
repository system). See NRC Staff Letter
of December 4, 2006. In the preamble to
NRC’s final rule incorporating 10 CFR
part 63 into its regulations, the
Commission stated:
The DOE has not indicated to the
Commission any intention to seek an
authorization for early use of the surface
facilities for storage of spent nuclear fuel.
Such an authorization likely would
necessitate a change to (or an exemption
from) the regulations. Before NRC would
make changes of this type to its regulations,
NRC would need to publish the proposed
changes and seek public comment (66 FR
55738; November 2, 2001).
These statements make it clear that
the Commission does not regard its
regulations as sanctioning the type of
spent fuel storage imagined by
petitioner; i.e., storage of large amounts
of spent nuclear fuel on an Aging Pad
divorced from waste handling,
necessary treatment, and disposal
operations.
Petitioner’s concern about DOE’s
supposed intent to construct a
‘‘gigantic’’ Aging Facility in violation of
law apparently stems from information
exchanged between DOE and NRC at the
August 29, 2006 NRC/DOE Technical
Exchange and Management Meeting.
The DOE slides presented design
changes that DOE had approved for the
repository, including the preliminary
hazards analysis (PHA) performed as
part of DOE’s process for approving
design changes. The radiological
consequence analysis of the PHA was
based on key assumptions with respect
to source terms, site weather and the
location of workers and members of the
public. One of these assumptions was
an assumption of aging pads at full
capacity which was identified as being
21,000 MTHM. However, assumptions
used in a hazards analysis are not the
equivalent of an actual plan for SNF
storage. Petitioner also cites DOE’s draft
Performance Specification for a TAD
canister system in support of its claim
that DOE is planning for ‘‘an illegal
Yucca aging pad.’’ This document
explains, inter alia, that a TAD canister
may be aged in an aging overpack which
is used to safely contain a loaded TAD
canister on the aging pad until
repository emplacement thermal limits
are met and that it could take a long
period of time (years) for sufficient
radioactive decay to take place. Clearly,
this document suggests that DOE plans
to age some amount of spent nuclear
fuel for some period of time on an aging
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Fmt 4702
Sfmt 4702
pad at the repository but it provides no
information on the actual amount or
length of time nor explanation as to how
whatever DOE is planning complies
with 10 CFR 63.41(a). This information
should be part of DOE’s license
application and will be subject to
review by the NRC staff.
As stated in NRC Staff’s December 4,
2006 letter, ‘‘NRC fully expects that
DOE would seek authorization for a
facility that complies with Federal law.
If the application includes an aging
facility, the NRC staff would review that
facility in the context of the overall
repository design to determine if it is
integral to waste handling and disposal
at the proposed repository * * *.’’
Precisely what amount of spent nuclear
fuel would meet that test, and precisely
what amount of time can be justified, is
an issue best resolved in the licensing
proceeding. DOE’s technical rationale
supporting its intended use of the Aging
Pad is dependent upon the actual
repository design DOE intends to
implement and will not be fully known
until DOE submits its license
application. DOE’s design will be
subject to scrutiny by the NRC staff in
the licensing proceeding. Potential
parties to the adjudicatory proceeding
may seek to raise contentions on this
issue if, in their view, DOE’s case does
not meet NRC’s regulations.
Conclusion
In sum, NRC’s rules already bar
storage of SNF at the repository which
is not integral to waste handling,
necessary treatment, and disposal
operations. The Commission believes
that, without an application currently
before the agency, the issues raised by
the petition are best addressed during
the agency’s review of the application
when a final design will be available
and an opportunity to request a hearing
will be offered.
For these reasons, the Commission
denies PRM–63–2.
Dated at Rockville, Maryland, this 18th day
of October 2007.
For the Nuclear Regulatory Commission.
Annette L. Vietti-Cook,
Secretary of the Commission.
[FR Doc. E7–20919 Filed 10–23–07; 8:45 am]
BILLING CODE 7590–01–P
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Agencies
[Federal Register Volume 72, Number 205 (Wednesday, October 24, 2007)]
[Proposed Rules]
[Pages 60288-60290]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E7-20919]
-----------------------------------------------------------------------
NUCLEAR REGULATORY COMMISSION
10 CFR Part 63
[Docket No. PRM-63-2]
State of Nevada; Denial of a Petition for Rulemaking
AGENCY: Nuclear Regulatory Commission.
ACTION: Petition for rulemaking: Denial.
-----------------------------------------------------------------------
SUMMARY: The U.S. Nuclear Regulatory Commission (NRC or Commission) is
denying a petition for rulemaking submitted by the State of Nevada
(PRM-63-2). The petition requests that NRC amend its regulations for
the proposed geologic repository at Yucca Mountain, Nevada (YM) to
specify the limits of permissible spent fuel storage at the YM site.
Petitioner believes that the U.S. Department of Energy (DOE) is
planning to construct an Aging Facility at the YM site designed to
store 21,000 metric tons of heavy metal in what petitioner believes is
a manifest violation of the Nuclear Waste Policy Act of 1982, as
amended, and the Commission's regulations. NRC is denying the petition
because NRC's current regulations are
[[Page 60289]]
consistent with law and do not permit storage of spent nuclear fuel at
the YM site unless such storage is integral to waste handling,
necessary treatment, and disposal at the proposed repository, including
storage which is integral to the thermal-loading strategy for disposal
that DOE may include in its design of the entire repository system. DOE
must make the case, in its anticipated license application, that any
contemplated storage of spent nuclear fuel is permissible because it is
integral to waste handling, necessary treatment, and disposal
activities. NRC believes that, without an application currently before
the agency, the issues raised by the petition are best addressed during
the agency's review of the application when a final design will be
available and an opportunity to request a hearing will be offered.
ADDRESSES: Publicly available documents related to this petition,
including the petition for rulemaking and NRC's letter of denial to the
petitioner may be viewed electronically on public computers in NRC's
Public Document Room (PDR), 01F21, One White Flint North, 11555
Rockville Pike, Rockville, Maryland. The PDR reproduction contractor
will copy documents for a fee. Publicly available documents created or
received at NRC after November 1, 1999, are also available
electronically at the NRC's Electronic Reading Room at https://
www.nrc.gov/reading-rm/adams.html. From this site, the public can gain
entry into the NRC's Agencywide Documents Access and Management System
(ADAMS), which provides text and image files of NRC's public documents.
If you do not have access to ADAMS or if there are problems in
accessing the documents located in ADAMS, contact the PDR reference
staff at (800) 387-4209, (301) 415-4737 or by e-mail to pdr@nrc.gov.
FOR FURTHER INFORMATION CONTACT: E. Neil Jensen, Office of the General
Counsel, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001,
telephone (301) 415-1637 or Toll Free: 1-800-368-5642, e-mail:
enj@nrc.gov.
SUPPLEMENTARY INFORMATION:
The Petition
On December 22, 2006, the State of Nevada (petitioner or the State)
submitted a ``Petition for Rulemaking to Amend Part 63 to Clarify the
Limits on Spent Fuel Storage at the Yucca Mountain Site'' (petition)
which was docketed as a petition for rulemaking under 10 CFR 2.802 of
the Commission's regulations (PRM-63-2) (available in the Agencywide
Document Access and Management System (ADAMS) No. ML070030020). The
State supplemented its petition by letter of January 23, 2007
(ML070330245). The petition requests amendments to 10 CFR part 63,
NRC's regulations governing the disposal of high-level radioactive
waste (HLW) in a proposed geologic repository at YM. The petitioner
believes that 10 CFR part 63 must be amended to specify the limits of
permissible spent fuel storage at YM, together with related changes to
10 CFR part 71.
Petitioner asserts that, at an August 29, 2006 technical exchange
and management meeting between NRC and DOE, DOE indicated that its
design for the geologic repository included both a ``Receipt Facility''
and an ``Aging Facility'' or ``Aging Pad''. (Meeting summary,
ML062710597). The Receipt Facility would be designed to receive
commercial spent nuclear fuel (SNF) from off-site and prepare it for
the Aging Facility. The Aging Facility would be designed to store
21,000 metric tons of heavy metal (MTHM) on the YM site. See DOE,
Office of Civilian Radioactive Waste Management, Surface Facilities
Overview and Canister Receipt and Closure Facility, slides presented to
NRC/DOE Technical Exchange and Management Meeting on Design Changes
Approved Through DOE's Critical Decision (CD-1) Process, August 29,
2006, Las Vegas, Nevada (DOE slides) (ML062510423). Petitioner further
asserts that, in an NRC Staff response to the State's letter asking
about what surface storage of SNF might be allowed at YM under the
Nuclear Waste Policy Act of 1982, as amended (NWPA), 42 U.S.C 10101 et
seq., and 10 CFR Part 63, NRC stated that surface storage is
permissible ``to the extent such storage is integral to waste handling
and disposal at the proposed repository,'' and that ``storage may also
be integral to the thermal-loading strategy the applicant may adopt in
its design of the entire repository system.'' See Letter to Robert R.
Loux from Jack R. Strosnider, December 4, 2006 (ML062900384).
Petitioner believes that it is unclear why a thermal loading
strategy must necessarily require the storage of significant quantities
of SNF on the YM site and holds that ``it is absurd to suppose that
storage in capacities approaching anywhere near 21,000 MTHM on the Site
could be justified as part of a `thermal loading' strategy that `is
integral to waste handling and disposal.'' Petition at 1. Further,
petitioner supplemented its petition to state that DOE's preliminary
specifications for a transportation, aging and disposal (TAD) canister
system suggest that DOE is planning on long-term storage of SNF at YM.
See DOE, Office of Civilian Radioactive Waste Management, Civilian
Radioactive Waste Management System: Preliminary Transportation, Aging
and Disposal Canister System Performance Specification, Revision A,
DOE/RW-0585, November 2006 (DOE Performance Specification) (Licensing
Support Network No. DN20023585505).
Petitioner believes that DOE's plans for an Aging Facility that
could contain 21,000 MTHM are ``manifestly unlawful'' and requests that
NRC amend 10 CFR part 63 to specify by rule the limits of permissible
spent fuel storage at YM, together with related changes to 10 CFR part
71. As support for its petition, the State provides an analysis of
provisions of the NWPA which demonstrate, in petitioner's view, that
storage of SNF at YM is unlawful. In brief, petitioner argues that the
structure and text of the NWPA show that Congress intended the
repository to be for disposal only. This is because Congress provided
for a repository for disposal of SNF in Subtitle A of the statute, but
separately provided for a limited interim storage program in Subtitle B
and for potentially longer term storage in a monitored retrievable
storage facility (MRS) in Subtitle C. Both Subtitle B and Subtitle C
contain provisions which would effectively prevent storage in a state
being considered for a repository. Petitioner points out that ``if
Congress had intended a repository site to be used for storage, neither
Subtitle B nor Subtitle C would have been necessary, and the statutory
prohibition on co-location of a repository and an interim storage
facility or MRS would have been nonsensical.'' Petition at 3. Thus,
petitioner concludes, the structure of NWPA demonstrates that a
repository is for disposal only.
Petitioner requests three changes to NRC's rules. First, 10 CFR
63.21(c)(22) (regarding the contents of the license application) would
be amended to add a new paragraph viii at the end:
viii. Plans for the emplacement of spent nuclear fuel in the
underground facility within a reasonably short time after it is
received (in no event longer than one year), and information to
explain why any facilities for the storage of spent nuclear fuel in
the repository operations area or on the Site are integral to safe
waste handling and disposal in the underground facility.
Second, 10 CFR 63.41(b) (regarding required license conditions)
would be amended to add a new subsection (c):
(c). The license shall include additional conditions as follows:
(1) No spent nuclear
[[Page 60290]]
fuel may be received in the geologic repository operations area, or
on the Site, unless there is reasonable assurance that it can be
moved into the underground facility within a reasonably short time
(in no event later than one year after receipt); (2) no spent
nuclear fuel may be stored in the geologic repository operations
area, or on the Site, unless such storage is necessary for the safe
and efficient emplacement of spent fuel in the underground facility;
and (3) no spent nuclear fuel may be stored in the geologic
repository operations area, or on the Site, for the purpose
primarily of aging (cooling or radioactive decay) prior to
emplacement in the underground facility. The foregoing conditions do
not preclude the construction of storage space to allow retrieval of
spent fuel after its emplacement in the underground facility or for
the amelioration of emergency conditions associated with the
repository's operation.
Third, to ensure proper coordination between DOE and reactor
licensees desirous of sending spent fuel to the repository, 10 CFR 71.5
would be amended by adding a new subsection (c):
(c). No licensee possessing spent reactor fuel may deliver the
fuel to the Department of Energy or to a carrier for transport to
Yucca Mountain, or transport the fuel to Yucca Mountain, unless the
fuel either complies with waste disposal criteria (including thermal
loading criteria) approved by the Commission, or the fuel is
expected to do so within one year after receipt at the Yucca
Mountain site. In complying with this subsection, a licensee may
rely on compliance certifications provided by the Department of
Energy.
Reasons for Denial
Petitioner recognizes that NRC's regulations are currently in
harmony with its view of what storage is permissible:
In the preamble to the original Part 63, NRC stated that no
license to receive waste or spent fuel would be issued until NRC is
able to find that DOE has completed construction of sufficient
underground storage space for initial operations, and it concluded
that Part 63 does not allow early use of surface facilities for
storage of spent fuel. 66 FR 55738 (November 2, 2001). This is
consistent with the text of 10 CFR 63.41(a)(1), which provides that
no license may be issued until NRC finds that construction of
``[a]ny underground storage space required for initial operation
[is] substantially complete.'' Thus, NRC's regulations appear
consistent with NWPA in eliminating the possibility of spent fuel
storage that is decoupled from actual repository operations and
logistics.
Petition at 4, n.3. Indeed, NRC recently reaffirmed this
interpretation of its regulations when it informed petitioner that
surface storage of spent fuel is only permissible, under 10 CFR part
63, to the extent such storage is integral to waste handling and
disposal at the proposed repository (including storage which is
integral to the thermal-loading strategy the applicant may adopt in its
design of the entire repository system). See NRC Staff Letter of
December 4, 2006. In the preamble to NRC's final rule incorporating 10
CFR part 63 into its regulations, the Commission stated:
The DOE has not indicated to the Commission any intention to
seek an authorization for early use of the surface facilities for
storage of spent nuclear fuel. Such an authorization likely would
necessitate a change to (or an exemption from) the regulations.
Before NRC would make changes of this type to its regulations, NRC
would need to publish the proposed changes and seek public comment
(66 FR 55738; November 2, 2001).
These statements make it clear that the Commission does not regard
its regulations as sanctioning the type of spent fuel storage imagined
by petitioner; i.e., storage of large amounts of spent nuclear fuel on
an Aging Pad divorced from waste handling, necessary treatment, and
disposal operations.
Petitioner's concern about DOE's supposed intent to construct a
``gigantic'' Aging Facility in violation of law apparently stems from
information exchanged between DOE and NRC at the August 29, 2006 NRC/
DOE Technical Exchange and Management Meeting. The DOE slides presented
design changes that DOE had approved for the repository, including the
preliminary hazards analysis (PHA) performed as part of DOE's process
for approving design changes. The radiological consequence analysis of
the PHA was based on key assumptions with respect to source terms, site
weather and the location of workers and members of the public. One of
these assumptions was an assumption of aging pads at full capacity
which was identified as being 21,000 MTHM. However, assumptions used in
a hazards analysis are not the equivalent of an actual plan for SNF
storage. Petitioner also cites DOE's draft Performance Specification
for a TAD canister system in support of its claim that DOE is planning
for ``an illegal Yucca aging pad.'' This document explains, inter alia,
that a TAD canister may be aged in an aging overpack which is used to
safely contain a loaded TAD canister on the aging pad until repository
emplacement thermal limits are met and that it could take a long period
of time (years) for sufficient radioactive decay to take place.
Clearly, this document suggests that DOE plans to age some amount of
spent nuclear fuel for some period of time on an aging pad at the
repository but it provides no information on the actual amount or
length of time nor explanation as to how whatever DOE is planning
complies with 10 CFR 63.41(a). This information should be part of DOE's
license application and will be subject to review by the NRC staff.
As stated in NRC Staff's December 4, 2006 letter, ``NRC fully
expects that DOE would seek authorization for a facility that complies
with Federal law. If the application includes an aging facility, the
NRC staff would review that facility in the context of the overall
repository design to determine if it is integral to waste handling and
disposal at the proposed repository * * *.'' Precisely what amount of
spent nuclear fuel would meet that test, and precisely what amount of
time can be justified, is an issue best resolved in the licensing
proceeding. DOE's technical rationale supporting its intended use of
the Aging Pad is dependent upon the actual repository design DOE
intends to implement and will not be fully known until DOE submits its
license application. DOE's design will be subject to scrutiny by the
NRC staff in the licensing proceeding. Potential parties to the
adjudicatory proceeding may seek to raise contentions on this issue if,
in their view, DOE's case does not meet NRC's regulations.
Conclusion
In sum, NRC's rules already bar storage of SNF at the repository
which is not integral to waste handling, necessary treatment, and
disposal operations. The Commission believes that, without an
application currently before the agency, the issues raised by the
petition are best addressed during the agency's review of the
application when a final design will be available and an opportunity to
request a hearing will be offered.
For these reasons, the Commission denies PRM-63-2.
Dated at Rockville, Maryland, this 18th day of October 2007.
For the Nuclear Regulatory Commission.
Annette L. Vietti-Cook,
Secretary of the Commission.
[FR Doc. E7-20919 Filed 10-23-07; 8:45 am]
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