Brunswick Spent Fuel Pool Petition

Good Day:

On behalf of NC WARN, NIRS, and UCS, I submitted the attached 2.206 petition to the NRC earlier today.
 
It seeks revisions to the technical specifications (part of the operating license) for the two reactors at the Brunswick nuclear plant in North Carolina.
 
As outlined in the petition and its attached brief, the problem involves requirements for irradiated fuel in the spent fuel pools.
 
More precisely, the problem involves a near complete lack of requirements.
 
Unless an irradiated fuel bundle removed from the reactor core within the past 24 hours is being moved in the spent fuel pool, there's no legal requirement that the spent fuel pool contain even a drop of water. Or containment integirty. Or ac power. Or dc power. Etc.
 
The petition seeks to rectify this problem by revising the technical specifications to require all those preventative and mitigative measures when freshly irradiated fuel is being moved within a spent fuel pool whenever irradiated fuel is in the spent fuel pool period.
 
Such requirements cannot be too onerous or costly -- many already exist in the technical specifications for the Pilgrim nuclear plant in Massachusetts and have done do for years.
 
Earlier this year, the NRC ordered plant owners to install instrumentation to monitor the water level and its temperature inside spent fuel pools.
 
Without the actions we seek in our petition, plant owners could install the instrumentation to comply with the NRC's order and then immediately disable it - except when freshly irradiated fuel is being moved. After all, since the technical specifications do not require water to be in the spent fuel pool sans movement, there's no legal requirement to monitor the level or temperature of the non-required water.
 
Many other boiling water reactors in the US - like Cooper in Nebraska and Browns Ferry in Alabama - have this same shortcoming. As time permits, UCS will be glad to work with local groups as we did with NC WARN and NIRS in North Carolina, to draft and submit petitions to the NRC to fix these plants, too.
 
Thanks,
Dave Lochbaum
UCS

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