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.