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{{#Wiki_filter:W'Domniniou Industry Views on Spent Fuel Pool Storage and Adequacy Of Existing Requirements January 6, 2014 David A. Heacock President and Chief Nuclear Officer, Dominion Nuclear
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,i;ODominiont Industry Position
* The industry agrees with and supports the overarching conclusions of both recent NRC staff evaluations:
* "...spent fuel pools protect public health and safety."- Consequence Study
* "...expedited transfer of spent fuel to dry cask storage would provide only a minor or limited safety benefit..."9 Regulatory Analysis
 
0Dominioi SFP Earthquake Experience Supports Industry Position
" NRC staff reviewed 20 SFPs in Japan and I in the US that experienced major earthquakes
    - Kashiwazaki-Kariwa (2007)
    - Fukushima Daiichi and Daini (2011)
    - North Anna (2011)
" In all cases there was no significant damage to the fuel, pool structure, penetrations, and only minor loss of water inventory.
3
 
U7D0mi nion Dominion Spent Fuel Situation Kewaunee North Anna 4.
 
WDominion Fukushima Daiichi Unit 4:
Example of SFP Robustness
* Fourth largest earthquake in recorded history (since 1556).
" Entire reactor building damaged by a major hydrogen explosion.
" The pool structure, which is on the operating deck, remained largely intact with only limited damage, retained sufficient water inventory and no damage to the fuel.
 
~uDnominions Consequences Study Went Far Beyond Experience
* Reference plant similar to Fukushima
* Analyzed earthquake:
  - much larger than plant design (6X SSE)
  - even larger than the one that struck Fukushima Daiichi
" The worst the study could find was an extremely small chance that the spent fuel pool would leak.
b
 
u~Domninion*
Consequences Study Demonstrates Pool Safety
* Experience and many reviews demonstrate the safety of spent fuel pools using current practices.
* Small difference in safety between pool (low density or high) and dry storage
* Public health risk from either pool or dry storage is extremely low
* The difference between the risks of the two options is the small difference between extremely small values.
 
Mitigation is the Key
* If fuel in pool is damaged, existing emergency procedures would keep the population around the plant safe.
* Off-site effects will be greatly reduced (or prevented altogether) through successful mitigation.
* Industry instituted pool mitigation initiatives following the 2001 terrorist attacks (B.5.b) and the accident at Fukushima Daiichi (FLEX) 18
 
uDominion Conservative Approach
" Study used conservatisms to ensure benefits of expedited pool off-load were maximized.
" Assumed mitigation only effective in low-density storage cases, not in high-density storage cases.
" Assumed mitigation only by B.5.b requirements, not FLEX, which is far more reliable.
* Study did not consider risks of moving fuel from pool to dry cask storage.
 
ilODonuiniomr Summary
  " The risks of spent nuclear fuel storage in pools under current practices are very, very small and spent fuel pools are safe and secure.
  " Based on the very low risk of pool storage and the ability of plants to mitigate beyond-design-basis events, there is no reason to require a reduction of the density of spent fuel storage in pools.
 
,*Dominion Acronyms
" SFP = Spent Fuel Pool
* SSE = Safe Shutdown Earthquake
* B.5.b = Section of 2002 Interim Compensatory Measure requiring mitigation capability following 2001 terrorist attacks (codified at 1 OCFR50.54(h)(h)
* FLEX = Industry's Diverse and Flexible Coping Strategy developed in response to 2011 Fukushima Daiichi accident (NRC Order EA-12-049)
J.11
 
.1 Spent Fuel: Expedited Transfer and Research Needs January 6, 2014 Christine King, Director EPRI Fuel, Chemistry, and High-Level Waste ELETURIC POWIE?
lES EARfCH IMMIIJU R~
 
. I Spent Fuel Storage
* Many factors to consider for expedited transfer
      -Plant  operation, economics, risk
* Current and future research focused on aging management and various aspects of high burnup fuel
 
EPRI Analysis of Expedited Transfer
* Evaluated three cases
  -  Base, 10 years, 15 years
* Assumptions in several areas
  -Future    spent fuel discharges
  -Dry    storage technology
  -Available time and associated dose
  - Cost of additional equipment and design changes
 
. I .A Impact of Expedited Transfer
* Reduced inventory, Cs-137 source term, and decay heat
* Loading of additional canisters
(+130-190)
* Increased worker dose (+1500-1900 person Rem)
* Change in public dose (increased distance and/or shielding)
 
EPRI's Research Focus Fundamental data on the behavior of dry storage systems and fuel over multiple decades
-Aging management plans for long-term storage
- Time-limited aging analyses
- Transportation after long-term storage
 
!
* I .j Spent Fuel Storage
* Many factors to consider for expedited transfer
          - Plant operation, economics, risk
* Current and future research will be focused on aging management and various aspects of high burn up fuel
 
COMMISSION BRIEFING SLIDES/EXHIBITS BRIEFING ON SPENT FUEL POOL SAFETY AND CONSIDERATION OF EXPEDITED TRANSFER OF SPENT FUEL TO DRY CASKS JANUARY 6, 2014
 
I INSTITUTE FOR RESOURCE IRSS.      AND SECURITY STUDIES NRC Commissioners' Briefing on Spent Fuel Pool Safety and Consideration of Expedited Transfer of Spent Fuel to Dry Casks
* Rockville, MD, 6 January 2014 *
"Imperatives for Expedited Transfer" A presentation by Gordon Thompson-
 
Low-Density, Open-Frame Rack for Storing Spent Fuel (PWR)
* Criticality is suppressed by geometry 9 If water is lost, fuel will be cooled by 3-D convective circulation of air and steam e Spent fuel is passively protected against zirc. self-ignition across a broad range of water-loss scenarios
 
Modes of Water Loss from a Spent-Fuel Pool Mode of Water        Relevant to            Relevant to Loss          Accidents?            Attacks?
Sloshing                  Yes*                    Yes Displacement              Yes                    Yes Tipping of pool            Yes                    Yes Siphoning or                No                    Yes Pumping Boiling                    Yes                    Yes Leakage                    Yes*                    Yes
* Modes considered by NRC Staff, but only for earthquake initiation
 
"Severe Reference" Case for Water Loss
* This case represents        jol4*,*
r'O #V      -
many water-loss            of .4te" scenarios
* Could proceed to zirc.-steam ignition e Paks-2 accident in                                          *,&C ,ýs 2003 provides a partial analog o NRC refuses to study  wit this case Figure from: Braun, 2010.
 
Ignition Delay Time in Severe Reference Case (PWR fuel)
Fuel Age                  Ignition Delay Time 10 days                        1.4 hours 100 days                        3.9 hours 1,000 days                        21 hours Notes:
(a) Here, ignition delay time (IDT) = time required for decay heat to raise fuel temp. from 100°C to 1,000°C under adiabatic conditions, for a fuel bumup of 50 GWt-days per Mg U.
(b) IDT is 30% higher for BWR fuel (with channel boxes).
 
Onsite Radiation Field Created by a Reactor Release: An Illustrative Case Indicator          Av. Over 1 Day      Av. Over 7 Days Dose rate                    44 Sv/hr              18 Sv/hr Time to accrue              4 minutes            10 minutes median lethal dose (3 Sv)
Notes:
(a) This case assumes uniform distribution, across a circle of 200 m radius, of 10% of I and Cs, and 5% of Te, in the core of a 2910 MWt reactor.
(b) Radiation dose is whole-body groundshine without shielding.
(c) Calculations are in a Nov. 2000 report by Gordon Thompson.
 
Some Outcomes Associated with Atmospheric Release of Cs-137 Actual Releases
" Chernobyl (85 PBq): "Perhaps the real cause of the collapse of the Soviet Union" (Gorbachev, 2006)
* Fukushima (36 PBq released; 6 PBq fallout on Japan):
Displacement of 160,000 people; all nuclear power plants in Japan currently shut down Potential Releases
" Peach Bottom (330 PBq): Long-term displacement of 4.1 million people (NRC average case)
* Dampierre (100 PBq): Economic damage of $0.4 trillion to $8.1 trillion; "an unmanageable European catastrophe" (IRSN studies)
 
Some Inventories of Cs-137 Peach Bottom Pool:              2,200 PBq (One of two neighboring pools)
Fukushima #1 Unit 4 Pool:      1,100 PBq Fukushima #1 Unit 3 Reactor:      350 PBq Dry Cask (32 PWR assemblies):      67 PBq Fukushima Fallout on Japan:        6 PBq
 
Some Observations About Radiological Risk
" The statement: "risk = (probability)x(consequences)"-is ideology, NOT science
" If consequences could be severe, an appropriate indicator of probability would be the number of occurrences per century across all US facilities
* Qualitative factors could be major determinants of probability and consequences
* NRC's consideration of pool fires has focused on rapid, total loss of water; this is a reprise of a 1960s focus on large-break LOCAs, which warped reactor design
 
A Wake-Up Call: Fukushima #1 Unit 4 Some Observations About Reverting to Low-Density, Open-Frame Racks
" The major driver of cost would be the transfer of excess spent fuel to dry casks
* This transfer will occur anyway, after reactors are shut down
* Thus, the incremental cost of acting now is simply the time value of the transfer cost
* Presence of high-bumup fuel could increase transfer cost; this is symptomatic of larger problems with high-bumup fuel
 
Conclusions
" NRC should order the rapid reversion of all pools to low-density, open-frame racks
" NRC should scrap the Staff's pool-fire study and Tier 3 analysis
" NRC should sponsor a thorough, open, science-based inquiry into phenomena related to pool (and cask) fires, including pool-reactor risk linkages
* NRC should seek to internationalize the inquiry, in view of pool hazards elsewhere (e.g., La Hague)
 
.4 INSTITUTE FOR RESOURCE AND SECURITY STUDIES 27 Ellsworth Avenue, Cambridge, Massachusetts 02139, USA Phone: 617-491-5177 Fax: 617-491-6904 Email: gthompson@irss-usa.org Declaration of 2 January 2013 by Gordon R. Thompson:
Recommendations for the US Nuclear Regulatory Commission's Consideration of Environmental Impacts of Long-Term, Temporary Storage of Spent Nuclear Fuel or Related High-Level Waste I, Gordon R. Thompson, declare as follows:
I. Introduction (I-1) I am the executive director of the Institute for Resource and Security Studies (IRSS), a nonprofit, tax-exempt corporation based in Massachusetts. Our office is located at 27 Ellsworth Avenue, Cambridge, MA 02139. IRSS was founded in 1984 to conduct technical and policy analysis and public education, with the objective of promoting peace and international security, efficient use of natural resources, and protection of the environment.
My professional qualifications are discussed in Section II, below.
(1-2) I have been retained by a group of environmental organizations to assist in the preparation of comments invited by the US Nuclear Regulatory Commission (NRC).'
The NRC has invited comments on the scope of an environmental impact statement (EIS) that the NRC proposes to prepare, which is referred to hereafter as the NRC's "proposed EIS". 2 That EIS would support a rulemaking by the NRC to update the NRC's Waste Confidence Decision and Rule. In this declaration I set forth some recommendations on the scope of the proposed EIS. These recommendations address selected issues.
Absence of discussion of an issue in this declaration does not imply that I view the issue as insignificant, or that I have no professional opinion on the manner in which the issue should be addressed in the proposed EIS.
(1-3) The issues discussed in this declaration are outlined in Section III, below. These issues all pertain to the concept of radiological risk, which is defined in Section IV, below. In brief, in this declaration the term "radiological risk" refers to the potential for harm to humans as a result of unplanned exposure to ionizing radiation.
These organizations include: Beyond Nuclear; Blue Ridge Environmental Defense League; Citizens Allied for Safe Energy; Ecology Party of Florida; Friends of the Earth; Missouri Coalition for the Environment; Nevada Nuclear Waste Task Force; NC WARN; Nuclear Information and Resource Service; Nuclear Watch South; Public Citizen; Riverkeeper; San Luis Obispo Mothers for Peace; SEED Coalition; and Southern Alliance for Clean Energy.
2 NRC, 2012.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HLW Page 2 of 55 (1-4) The NRC's invitation to submit comments3makes the following statement about scenarios to be considered in the proposed EIS:
          "Possible scenarios to be analyzed in the EIS include temporary spent fuel storage after cessation of reactor operation until a repository is made available in either the middle of the century or at the end of the century, and storage of spent fuel if no repository is made available by the end of the century."
(1-5) The latter part of that statement by the NRC envisions storage of spent fuel for an unspecified period. In that context, it should be noted that the NRC previously embarked on a related EIS, and published a draft document setting forth preliminary assumptions that would apply to that EIS.4 That document is referred to hereafter as the NRC's "preliminary-assumptions document". The preliminary-assumpgtions document called for a time horizon of about 2250 in the EIS then under discussion. That document also assumed that a repository would ultimately become available. 6 (1-6) From the perspective of the radiological risk posed by temporary storage of spent fuel, a time horizon of about 2250 has some logic. A major determinant of the risk, especially in terms of atmospheric release, is the inventory of Cesium- 137, which has a half-life of about 30 years. 7 Between 2012 and 2250, a given inventory of Cesium-137 would shrink to a value of about 0.004 (0.4 percent) of its initial value. At that point, the radiological risk posed by storing spent fuel would not disappear, but would be entering a different phase. Moreover, the NRC's preliminary-assumptions document represents a body of work by the NRC staff, and reflects some public input. Accordingly, I recommend as follows:
Recommendation #1: The NRC's preliminary-assumptions document should be a point of departure for determining the scope of the proposed EIS, especially in regard to storage after the end of the 2 1st century.
(1-7) Spent fuel can more precisely be described as spent nuclear fuel (SNF). I typically use that term hereafter. Also, the NRC's preliminary-assumptions document has introduced the possibility that some SNF discharged from NRC-licensed reactors will be reprocessed in the future. 8 If that outcome were to occur, reprocessing would generate high-level waste (HLW) that would contain most of the radioactivity present in the SNF that is reprocessed. 9 Accordingly, I recommend as follows:
3 NRC,  2012, page 65138.
4NRC,  2011.
5NRC, 2011, Section 7.
6NRC, 2011, Section 8.
7 The inventory of Cesium-137 is an indicator of biological hazard and decay heat production; both properties are determinants of radiological risk.
NRC, 2011, Section 8.
9 Here, "radioactivity" refers to the inventory of radio-isotopes, measured in Bq.
 
46 Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 3 of 55 Recommendation #2: The proposed EIS should not only address the storage of SNF, but also the potential storage of HLW from reprocessing of SNF.
(1-8) It does not follow from my Recommendation #2 that I recommend the future reprocessing of SNF discharged from NRC-licensed reactors, or that I view the future introduction of such reprocessing as likely. Indeed, as discussed in paragraph VI-3, below, trends in the nuclear-power industry over the past two decades suggest that the most likely outcome for that industry over the next few decades is general decline in its activities. Such a future would be inconsistent with reprocessing.
(1-9) The NRC's statement quoted in paragraph 1-4, above, refers to "temporary spent fuel storage after cessation of reactor operation" [emphasis added]. That statement is imprecise, and could be seriously misleading in regard to the radiological risk posed by storage of SNF. At all contemporary US commercial reactors, SNF assemblies are discharged only when the reactor is shut down. Thereafter, the SNF assemblies may be stored adjacent to an operating reactor from which they were discharged, adjacent to another operating reactor, or at a location not adjacent to an operating reactor. As discussed in Section VIII, below, the radiological risk could be substantially greater if SNF is stored adjacent to an operating reactor. Accordingly, I recommend as follows:
Recommendation #3: The proposed EIS should consider the radiological risk posed by storage of SNF from the moment of its discharge from a reactor.
(I-10) This declaration has the following narrative sections:
I.      Introduction II. My Professional Qualifications III. Issues Discussed in this Declaration IV. Radiological Risk V.      The Future Risk Environment VI.      Scenarios to be Considered in the Proposed EIS VII. SNF and HLW Storage Modes and Dynamics to be Considered in the Proposed EIS VIII. Phenomena Relevant to Radioactive Release from SNF or HLW IX.      Assessing Likelihood and Impacts of Radiological Incidents X.      Summary of Recommendations (I-11) In addition to the above-named narrative sections, this declaration has two appendices that are an integral part of the declaration. Appendix A is a bibliography.
Documents cited in the narrative or in Appendix B are listed in that bibliography unless otherwise identified. Appendix B contains tables and figures that support the narrative.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 4 of 55 II. My Professional Qualifications (II- 1) As stated in paragraph I- 1, above, I am the executive director of the Institute for Resource and Security Studies. In addition, I am a senior research scientist at the George Perkins Marsh Institute, Clark University.
(11-2) I received an undergraduate education in science and mechanical engineering at the University of New South Wales, in Australia, and practiced engineering in Australia in the electricity sector. Subsequently, I pursued graduate studies at Oxford University and received from that institution a Doctorate of Philosophy in mathematics in 1973, for analyses of plasma undergoing thermonuclear fusion. During my graduate studies I was associated with the fusion research program of the UK Atomic Energy Authority. My undergraduate and graduate work provided me with a rigorous education in the methodologies and disciplines of science, mathematics, and engineering.
(11-3) My professional work involves technical and policy analysis in the fields of energy, environment, sustainable development, human security, and international security. Since 1977, a significant part of my work has consisted of analyses of the radiological risk posed by commercial and military nuclear facilities. These analyses have been sponsored by a variety of non-governmental organizations and local, state and national governments, predominantly in North America and Western Europe. Drawing upon these analyses, I have provided expert testimony in legal and regulatory proceedings, and have served on committees advising US government agencies.
(11-4) To a significant degree, my work has been accepted or adopted by relevant governmental agencies. During the period 1978-1979, for example, I served on an international review group commissioned by the government of Lower Saxony (a state in Germany) to evaluate a proposal for a nuclear fuel cycle center at Gorleben. I led the subgroup that examined radiological risk and identified alternative options with lower risk.'l One of the risk issues that I personally identified and analyzed was the potential for self-sustaining, exothermic oxidation reactions of fuel cladding in a high-density SNF pool if water is lost from the pool. For simplicity, that event can be referred to as a "pool fire". In examining the potential for a pool fire, I identified partial loss of water as a more severe condition than total loss of water. I identified a variety of events that could cause loss of water from a pool, including aircraft crash, sabotage, neglect, and acts of war. Also, I identified and described alternative SNF storage options with lower risk; these lower-risk options included design features such as spatial separation, natural cooling, and underground vaults. The Lower Saxony government accepted my findings about the risk of a pool fire, and ruled in May 1979 that high-density pool storage of SNF was not an acceptable option at Gorleben."1 As a direct result, policy throughout 10 Beyea et al, 1979.
11Albrecht, 1979.
 
t Thompson Declaration:Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, Temporary Storage of SNF or HL W Page 5 of 55 Germany has been to use dry storage in casks, rather than high-density pool storage, for away-from-reactor storage of SNF.
(11-5) Since 1979, I have been based in the USA. During the subsequent years, I have been involved in a number of NRC regulatory proceedings related to the radiological risk posed by storage of SNF. In that context I have prepared a number of declarations and expert reports.ý2 Also, I co-authored a journal article, on SNF radiological risk, that received considerable attention from relevant stakeholders.' 3 The findings in that article were generally confirmed by a subsequent report by the National Research Council.14 As a result of my cumulative experience, I am generally familiar with: (i) US practices for managing SNF; (ii) the radiological risk posed by those practices; (iii) NRC regulation of that risk; and (iv) alternative options for reducing that risk. Also, I am familiar with the US effort since the 1950s to implement final disposal of SNF and HLW, and have written a review article on that subject.
(11-6) I have performed a number of studies on the potential for commercial or military nuclear facilities to be attacked directly or to experience indirect effects of violent conflict. A substantial part of that work relates to the radiological risk posed by storage of SNF or HLW. For example, in 2005 1was commissioned by the UK government's Committee on Radioactive Waste Management (CORWM) to prepare a report on reasonably foreseeable security threats to options for long-term management of UK radioactive waste.' 6 The time horizon used in my report was, by CORWM's specification, 300 years.
IIl. Issues Discussed in this Declaration (111-1) The primary purpose of this declaration is to set forth recommendations regarding the scope of the proposed EIS with respect to the environmental impacts of long-term, temporary storage of SNF or related HLW. My declaration is complementary to the declaration of Dr. Arjun Makhijani,17 which addresses some SNF storage issues and also some issues      of SNF  disposal.
(111-2) In this declaration I focus on environmental impacts that are associated with radiological risk, which is defined in Section IV, below. In addressing radiological risk, I focus on the potential for unplanned release of radioactive material, especially atmospheric release. Within that focus, I consider two categories of initiating event -
conventional accidents, and attacks.
12 See, for example: Thompson, 2009.
13 Alvarez et al, 2003.
14 National Research Council, 2006.
  '5 Thompson,  2008a.
16 Thompson, 2005.
17 Makhijani, 2013.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, Temporary Storage ofSNF or HL W Page 6 of 55 (111-3) Analysts who examine the radiological risk associated with potential attacks affecting nuclear facilities have a double duty. First, they owe the public an accurate assessment of the risk. Second, they should refrain from publishing information that could directly assist a potential attacker. This declaration satisfies both requirements. It does not purport to provide a comprehensive assessment of radiological risk. Instead, it offers recommendations for such an assessment. From that perspective the declaration is, I believe, accurate and reasonably complete. At the same time, this declaration does not provide information that could directly assist an attack on a particular nuclear facility.
Accordingly, this declaration is appropriate for general distribution.
(111-4) The NRC's preliminary-assumptions document called for a time horizon of about 2250 when considering the environmental impacts of long-term, temporary storage of SNF or HLW. Given such a distant time horizon, a risk assessor should consider the potential for substantial change in the risk environment. In Section V, I outline a process for considering such change.
(111-5) Most stakeholders would agree that the proposed EIS should consider a range of scenarios for the future, and a range of alternative options for storing SNF or HLW.
Moreover, I understand that considering these matters is a legal requirement for an EIS.
Accordingly, I offer recommendations regarding scenarios and alternative options., I also offer recommendations on improving the state of knowledge about the radiological risk posed by storing SNF or HLW.
IV. Radiological Risk (IV-1) In this declaration, I define the general term "risk" as the potential for an unplanned, undesired outcome. Risk, so defined, is an inevitable part of human existence. However, risk can be managed. Indeed, as shown in Table IV-1, management of risk could be one of three major pillars of a framework of principles for the design and appraisal of infrastructure projects in the 2 1 s' century. Facilities for long-term, temporary storage of SNF or HLW would be appropriate projects for employment of that framework.
(IV-2) Table IV-2 shows some categories of risk that could be posed by a commercial nuclear facility. Radiological risk is defined as the potential for harm to humans as a result of unplanned exposure to ionizing radiation. The exposure could arise from unplanned release of radioactive material, or from line-of-sight exposure to unshielded radioactive material or a criticality event. In this declaration I focus on exposure arising from unplanned release, especially atmospheric release. That mode of exposure would typically dominate the radiological risk posed by storage of SNF or HLW, at least during the first few centuries of storage.
(IV-3) The effects of an unplanned release of radioactive material could be among the most severe impacts that arise from storing SNF or HLW. Thus, assessing radiological
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HLW Page 7 of 55 risk should be a major function of the proposed EIS. Accordingly, I recommend as follows:
Recommendation #4: Assessment of radiological risk should be a major function of the proposed EIS, this category of risk being defined as the potential for harm to humans as a result of unplanned exposure to ionizing radiation.
(IV-4) Defining radiological risk as "the potential for harm" does not imply that any single indicator can adequately describe this risk. To the contrary, assessment of radiological risk requires the compiling of a set of qualitative and quantitative information about the likelihood and characteristics of the unplanned exposure and resulting harm. That approach is consistent with my general definition of "risk" as the potential for an unplanned, undesired outcome. The NRC has articulated a similar definition.' 8 (IV-5) In the nuclear industry and elsewhere, one often encounters a more limited definition, in which risk is the arithmetic product of a numerical indicator of harmful impact and a numerical indicator of the impact's probability.1 9 That definition is hereafter designated as the "arithmetic" definition of risk. The arithmetic definition can be seriously misleading in two respects. First, the full spectrum of impact and/or probability may not be susceptible to numerical estimation, and numerical estimates may be incomplete or highly uncertain. Second, many subscribers to the arithmetic definition argue that equal levels of the numerically-estimated risk should be equally acceptable to citizens. Their argument may be given a scientific gloss, but is actually a statement laden with subjective values and interests.
(IV-6) Quantitative analysis is essential to science, engineering, and other fields. Yet, the limitations of quantitative analysis should be recognized. Analysts should be especially careful to avoid the intellectual trap of ignoring issues that are difficult to quantify. Many practitioners of radiological risk assessment fall into that trap. Thus, important risk factors are ignored. Examples include: (i) acts of malice or insanity; and (ii) gross errors in design, construction, and operation of facilities. Risk assessments for nuclear facilities routinely ignore these and other factors that may be major determinants of risk.2 ° 18 The NRC Glossary defines risk as: "The combined answer to three questions that consider (1) what can go wrong, (2) how likely it is, and (3) what its consequences might be. These three questions allow the NRC to understand likely outcomes, sensitivities, areas of importance, system interactions, and areas of uncertainty, which can be used to identify risk-significant scenarios." (See: httlp://wwwvnrc.2ov/i'eading,,-
r'/basic-reflossary/risk.html, accessed on 16 February 2012.)
19 Often, the arithmetic product will be calculated for each of a range of impact scenarios, and these products will be summed across the scenarios.
For example, there is evidence that a major risk factor underlying the 1986-Chernobyl reactor accident was endemic secrecy in the USSR. (See: Shlyakhter and Wilson, 1992.) Also, there is evidence that a major risk factor underlying the 2011 accident at the Fukushima #1reactor site was collusion among government, the regulators, and the licensee (TEPCO). (See: Diet, 2012, page 16.) Radiological-risk
 
9 Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 8 of 55 (IV-7) A nuclear facility typically has the potential to experience unplanned releases of radioactive material across a spectrum ranging from small releases to large releases. Risk analysts who subscribe to the arithmetic definition often conclude that small releases are more probable. With their arithmetic approach, it then appears that large releases with low probability are equivalent to small releases with high probability. Often, these analysts leap to the assumption that the apparent equivalence is "scientific". Thus, they argue, equal levels of the numerically-estimated risk should be equally acceptable to citizens. In fact, the assumption of equivalence lacks a scientific basis. It is a subjective statement that reflects the values and interests of this group of analysts. From the perspective of a citizen, the potential for a large release may be much less acceptable than the potential for a small release, regardless of probability. That perspective could have a solid, rational basis, because a large release could have effects that are qualitatively different from the effects of a small release. Moreover, a prudent citizen will be skeptical of the probability findings generated by arithmetic risk analysts, given the propensity of these analysts to ignore important risk factors.
(IV-8) Radiological risk assessment requires the identification of potential events that could initiate a radiological incident. One category of initiating events, which I categorize as "conventional accidents", encompasses events such as random failure of equipment, random human error, or natural forces such as earthquakes. This category of events has been extensively studied in the context of commercial nuclear facilities.
(IV-9) The NRC's preliminary-assumptions document called for consideration of another category of potential initiating events under the rubric of "terrorism". In discussing such events the document stated:21 "The staff plans to consider the environmental impacts of terrorism related to storage and transportation at a generic level. The terrorism consideration will be developed using available information in agency records and other available information for current facilities, package technologies, and transportation infrastructures; current technologies and reasonably foreseeable technologies that are being explored in depth; mitigation measures; and security arrangements that have a bearing on likely environmental consequences."
(IV-10) I welcome the NRC's willingness to consider initiating events that are beyond the category of conventional accidents. However, I find the above-quoted NRC statement on terrorism to be unsatisfactory. For example, it does not define terrorism or explain why this phenomenon should be considered to the exclusion of other potential events that involve violence.
studies performed by the nuclear industry and its regulators do not consider secrecy or collusion as risk factors.
2 NRC, 2011, Section 8.1(9).
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 9 of 55 (IV- 11) Events involving violence could be significant for the radiological risk posed by storing SNF or HLW. My view is that such events should be categorized as "attacks",
with the understanding that an attack could adversely affect stored SNF or HLW either directly or indirectly. Accordingly, I recommend as follows:
Recommendation #5: The proposed EIS should assess the radiological risk arising from a range of conventional accidents or attacks that could affect stored SNF or HLW.
(IV- 12) Table IV-3 shows that the NRC has publicly examined potential attacks on stored SNF. In that instance, the potential, hypothesized attacks were "sabotage events" at an SNF storage pool.
(IV-13) As discussed in paragraph 111-5, above, there is a general expectation and, I understand, a legal requirement that the proposed EIS should consider alternative options and their respective impacts. Accordingly, given that the effects of an unplanned release of radioactive material could be among the most severe impacts that arise from storing SNF or HLW, I recommend as follows:
Recommendation #6: The comparative radiological risk posed by a range of alternative options for storing SNF or HLW should be assessed in the proposed EIS as a major indicator of the comparative impacts of these alternatives.
V. The Future Risk Environment (V-1) As discussed in paragraph 1-4, above, the NRC currently envisions that the proposed EIS will consider scenarios including:
* temporary storage of SNF until a repository is made available in either the middle of the 21 "tcentury or at the end of the 21 st century
* temporary storage of SNF for an unspecified period if no repository is made available by the end of the 21s" century (V-2) The NRC's preliminary-assumptions document called for consideration of temporary storage of SNF within a time horizon of about 2250. Accordingly, in this declaration I assume that the "unspecified period" mentioned in the second bullet of paragraph V-1 would extend until about 2250.
(V-3) As discussed in Section IV, above, assessment of radiological risk should be one of the major features of the proposed EIS. There is a considerable body of experience with radiological risk assessment. In this instance, however, there are unusual challenges in risk assessment because of the extended time frame. Thus, before attempting to assess the radiological risk posed by storage of SNF or HLW over a period of decades or centuries, a risk assessor should seek to understand the risk environment throughout that period. In this declaration, the term "risk environment" refers to the array of societal,
 
I Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HLW Page 10 of 55 technical, and natural factors that, taken together, have significant influence on risk.
Over a period of decades and centuries, these factors, and their interactions with each other, could change substantially. Therefore, a credible risk assessment would systematically examine the potential for substantial change, over time, in the risk environment.
(V-4) There have been many serious efforts to forecast the future risk environment or factors that could influence that environment. Such efforts find, unsurprisingly, that uncertainty grows as the time horizon of the forecast becomes more distant. Three examples of forecasting are illustrative:
* The World Economic Forum (WEF) has now published seven editions of its "Global Risks" report. The seventh edition, published in 2012, examines fifty global risks across five categories. A 10-year time horizon is employed. Risks were assessed by surveying 469 experts and industry leaders. Five "centers of gravity" of risk are identified: (i) chronic fiscal imbalances; (ii) greenhouse gas emissions; (iii) global governance failure; (iv) unsustainable population growth; and (v) critical systems failure.22
* The US National Intelligence Council (NIC) has now published five editions of its "Global Trends" report. The fifth edition, published in December 24  2012, has a time horizon of 2030.23 Findings in that report include the statement:
                  "Extrapolations of the megatrends would alone point to a changed world by 2030 - but the world could be transformed in radically different ways.
We believe that six key game-changers- questions regarding the global economy, governance, conflict, regional instability, technology, and the role of the United States - will largely determine what kind of transformed world we will inhabit in 2030."
The Stockholm Environment Institute (SEI) convened its Global Scenario Group in 1995. The Group's work led to SEI's "Great Transition" report of 2002.25 The time horizon in that report varied by scenario, extending to 2065 in some cases.
The report identified six global scenarios in three categories: (i) conventional worlds; (ii) barbarization; and (iii) great transitions. These scenarios are described further in Table V-1.
(V-5) The forecasting efforts mentioned in the preceding paragraph, and numerous other studies, have identified human abuse of natural resources as a factor that could adversely 22 WEF, 2012.
23 NIC, 2012.
24 NIC, 2012, page iii.
25 Raskin et al, 2002.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page II of 55 affect human welfare over the coming decades. For example,26 a group of authors examining the "safe operating space for humanity" has said:
        "Human activities increasingly influence the Earth's climate (International Panel on Climate Change (IPPC) 2007a) and ecosystems (Millennium Ecosystem Assessment (MEA) 2005a). The Earth has entered a new epoch, the Anthropocene, where humans constitute the dominant driver of change to the Earth System (Crutzen 2002, Steffen et al. 2007). The exponential growth of human activities is raising concern that further pressure on the Earth System could destabilize critical biophysical systems and trigger abrupt or irreversible environmental changes that would be deleterious or even catastrophic for human well-being. This is a profound dilemma because the predominant paradigm of social and economic development remains largely oblivious to the risk of human-induced environmental disasters at continental to planetary scales (Stem 2007)."
(V-6) Societal response to the threats mentioned in the preceding quotation is inhibited by a number of factors, including a widespread lack of recognition of the rapidity of action that is needed to prevent adverse outcomes. For example, government leaders meeting in Copenhagen in 2009 committed their countries to holding the human-caused increase in average global temperature below 2°C. Yet, although accumulating scientific knowledge indicates that a 2°C increase may be dangerously high, current trends in 27 greenhouse gas emissions make it unlikely that the increase can be held below 20C.
Correcting those trends to achieve a 2°C limit would, according to analysis published in November 2012 by Pricewaterhouse Coopers, require an unprecedented reduction in global carbon intensity (CO 2 emissions per unit of economic product) averaging 5.1% per year throughout the period from the present until 2050.28 There is no international agreement or plan to achieve such reduction.
(V-7) Adverse outcomes for human welfare, as a result of our abuse of natural resources, could include direct effects, such as reduced agricultural yields and increased incidence of infectious diseases. These direct effects could be accompanied and amplified by indirect effects, with the potential for a descending spiral in the human condition. Many analysts have noted that indirect effects could include an increase in violent conflict. For example, the Defense Science Board has examined29the implications of climate change for national and international security, and has stated:
          "Climate change is likely to have the greatest impact on security through its indirect effects on conflict and vulnerability."
26 Rockstrom et al, 2009.
27 Anderson and Bows, 2011.
28 PwC, 2012.
29 Defense Science Board, 2011, page xi.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HLW Page 12 of 55 (V-8) The NRC envisions storage of SNF until about 2100 if a repository becomes available, or until about 2250 if no repository is available by the end of the 2 1st century.
Both time horizons are considerably more distant than the time horizons of the forecasts outlined in paragraph V-4, above. Those forecasts acknowledge substantial uncertainty in their projections. One could reasonably expect that the NRC would acknowledge a much greater degree of uncertainty, in view of the comparatively distant time horizons it envisions. As discussed below, the NRC's preliminary-assumptions document did not meet that expectation. The proposed EIS should rectify that deficiency.
(V-9) The NRC's preliminary-assumptions document postulated that the risk environment throughout the period ending in 2250 will be little changed from what it is now. Indeed, the document specifically stated that "the EIS will minimize speculation about future conditions". 30 Consistent with that position, the document proposed a range of status quo assumptions. For example, nuclear fission power would continue providing about 20 percent of US electricity production. The SNF generated from that activity would have properties similar to the SNF generated by the present generation of light-water reactors. The NRC or an equivalent governmental entity would provide regulatory oversight that is at least as stringent as present requirements. The responsible entities would continue to fund the storage of SNF, "regardless of cost".31 (V-10) The NRC's preliminary-assumptions document acknowledged that a public commenter requested the NRC to "include in the EIS a scenario that accounts for a collapse of society and loss of government institutions, with a resulting lack of control over, and knowledge about, nuclear plants and radioactive waste". The    3 2 document refused to meet that request, offering the following argument as justification:
        "The request to include a societal-collapse scenario would require an analysis of the impacts of storage under a highly speculative scenario in which societal institutions, knowledge, and controls no longer exist. However, as described above, the trend in modem society is toward more awareness and control over issues that pose a risk to humans and their environment. The staff concludes that a loss of societal structures and the associated knowledge base is not reasonably foreseeable and, in fact, is highly unlikely to occur within the 200-year timeframe to be considered in the EIS. The staff's view, therefore, is that any of the impacts associated with this scenario are also not reasonably foreseeable."
(V-1 1) The NRC's argument in the preceding quotation fails on at least three grounds, discussed here and in the following two paragraphs. First, the NRC considers only a status-quo scenario and a scenario involving complete collapse of organized society, before excluding the latter scenario. By limiting its view in that manner, the NRC has 30 NRC, 2011, Section 8.1.
3' NRC, 2011, Section 8.1(6).
3"NRC, 2011, Section 8.1(6).
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 13 of 55 failed to understand the range of possible societal conditions. Any serious forecast of societal developments over the period ending in 2250 - or in 2100 - would postulate a broad range of possible scenarios.
(V-12) Second, the NRC claims to see a contemporary societal trend "toward more awareness and control over issues that pose a risk to humans and their environment". If that trend were real, it would have limited relevance across the period ending in 2250, but would be more significant across the period ending in 2100. Regrettably, no such trend can be seen in the contemporary United States with any consistency. Improvements in natural-resource management were made in the 2 0 th century, but much of that momentum has been lost. For example, despite the clear and urgent need for rapid reduction of greenhouse-gas emissions, present US policies will not yield that reduction. The Energy Information Administration's latest reference-case forecast is that US energy-related emissions of carbon dioxide will rise continually from 2016 to 2040."3 Also, the NRC itself is enabling the continued accumulation of SNF without the existence of a repository into which that SNF can be placed, and has indicated a willingness to enable further accumulation until at least 2250.34 Such a policy places a growing burden on future generations without a commensurate benefit, and is the antithesis of sustainable development. These and other examples show that the contemporary societal trend cited by the NRC is not real.
(V-1 3) The third ground on which the NRC's argument fails is that it ignores a human history that includes conflict and the degradation of institutions. Looking forward from 2012 to 2250 is analogous to looking forward from 1774 to 2012. Any informed person knows that there have been numerous, major changes in human affairs within the present territory of the USA since 1774. Just from the perspective of large-scale violent conflict, US history has witnessed a Revolutionary War, a Civil War, two World Wars, a Cold War that came close to nuclear-weapon exchange during the Cuban Missile Crisis, and many other wars. With the exception of the Revolutionary War, these precise events could not have been predicted in 1774 although they were, to some degree, foreseeable.
Such occurrences demonstrate that it is unreasonable to assume that society and its institutions will remain stable over an extended future period.
(V-14) The NRC's preliminary-assumptions document attempted to argue that its exclusive focus on a status quo scenario represented the only "reasonably foreseeable" outcome until 2250. That is the reverse of the truth. Limiting analysis to a status quo scenario across such a time period is speculative in the extreme. The only way to consider reasonably foreseeable outcomes is to articulate a broad range of possible future scenarios, while acknowledging the uncertainty that inevitably accompanies such an exercise. The uncertainty within a time horizon of 2100 would be large, and within a time horizon of 2250 it would be substantially larger.
33 EIA, 2012, Figure 13.
34 The NRC's preliminary-assumptions document assumed that "spent nuclear fuel and high-level waste ultimately [emphasis added] will be transported to a geologic repository for disposal and that at least one repository will need to be constructed". (See: NRC, 2011, Section 8.2.)
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 14 of 55 (V-I15) Drawing from the preceding paragraphs in Section V and other sources with which I am familiar, I recommend in paragraphs V- 16 and V- 17 a process whereby the proposed EIS could be informed by a forecast of the risk environment during the time period covered by the EIS. Across that period, the EIS should assess risks in all relevant categories, including radiological risk. Those assessments should be done for all the scenarios, and all the SNF and HLW storage options, that are considered in the EIS. The risk environment could vary across scenarios, but would typically not vary across storage options. Characteristics of the risk environment could affect both the likelihood and the magnitude of adverse outcomes.
(V- 16) The risk environment can be characterized by a set of indicators that represent an array of natural, technical, and societal factors. At any given time and place, the risk environment is temporarily static. As time and place vary, the risk environment becomes dynamic. Accordingly, I recommend as follows:
Recommendation #7: Risk assessment in the proposed EIS should be supported by a set of indicators that express the dynamic aspects of the potential risk environment across the time period and suite of scenarios considered in the EIS.
(V-1 7) Dynamic aspects of the potential risk environment that are particularly relevant to radiological risk could include:
* Influence of Natural Factors: Global climate change could increase: (i) sea level; (ii) the incidence of high winds and associated surges in coastal water level; (iii) the incidence of drought; and (iv) the incidence of river-basin flooding.
    " Influence of Technical Factors: Technological advances could: (i) increase the capabilities and decrease the costs of instruments that could be used to attack SNF or HLW storage facilities; and (ii) provide new design options for protecting stored SNF or HLW against conventional accidents or attacks.
* Influence of Global Societal Factors: Failure to adequately address natural-resource limits and other global challenges could: (i) increase the incidence of violent conflict involving States and non-State actors; (ii) impoverish large numbers of people; (iii) degrade national and international systems of governance; and (iv) degrade the technological capabilities of societies.
    " Influence of Societal Factors within US Territory: Global societal factors, as discussed above, could influence the risk environment within US territory either directly or indirectly; indirect impacts could include an increased potential for attack on US assets by non-State actors or States.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, TemporaryStorage of SNF or HL W Page 15 of 55 VI. Scenarios to be Considered in the Proposed EIS (VI-1) As shown in Section V, above, if the proposed EIS is to be credible then it must consider a broad range of possible scenarios for the future. Here, in Section VI, I outline the types of scenario that should be considered in order to credibly assess radiological risk.
(VI-2) The future role of nuclear power is one of the issues that should be reflected in the choice of scenarios. As discussed in paragraph V-9, above, the NRC's preliminary-assumptions document postulated that the status quo for nuclear power will persist through all scenarios until 2250, one exception being the possible introduction of reprocessing. From the perspective of 2012, introduction of commercial reprocessing in the USA would be a major policy step. Across the period from 2012 to 2250, however, that step would be only one of numerous possible changes in US energy infrastructure.
35 Scenarios identified in the NRC's preliminary-assumptions document were:
0  Scenario 1 - Extended onsite storage at reactor sites and offsite independent spent fuel storage installations 0 Scenario 2 - Interim onsite storage and shipment to regional storage facilities 0 Scenario 3 - Interim onsite storage and shipment to one centralized storage facility 0 Scenario 4 - Interim onsite storage and shipment to at least one reprocessing facility (VI-3) Trends in the nuclear-power industry over the past two decades suggest that the most likely outcome for that industry over the next few decades is not the status quo, but decline. 36 For example, in the early 1990s the nuclear industry supplied 17 percent of the world's electricity while in 2011 that fraction had fallen to 11 percent. The industry's annual, worldwide production of electricity peaked in 2006 at 2,660 TWh and fell to 2,518 TWh in 2011. The mean age of the world's fleet of operating reactors is now 27 years, and is increasing. The same general picture holds in the USA, where the last completion of a new reactor was in 1996.
(VI-4) A two-decade trend prior to 2012 does not ordain any particular future between 2012 and 2250, but is more significant for the period between 2012 and 2100. Across either time frame, it is clear that reasonably foreseeable outcomes for the US nuclear industry include shrinkage in the number of operating reactors, potentially leading to shutdown of all reactors by the middle of the 2 1st century. An important implication is that the industry's revenue would decline as reactors close. Payment for the management of the SNF remaining from reactor operation could initially come from funds set aside
"  NRC, 2011, Section 8.2.
36 Schneider et al, 2012.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HLW Page 16 of 55 during the years of operation. Over time, those funds could be depleted, at which point the most likely source of payment would be the general funds of the US government.
Also, shrinkage of the US reactor fleet would inevitably reduce national capabilities in nuclear engineering.
(VI-5) From the two preceding paragraphs, it is clear that scenarios in the proposed EIS should cover outcomes in which the nuclear-power industry largely disappears, leaving behind a hazardous residue of SNF and HLW. Management of that residue could be a charge on the general public, who would receive no commensurate benefit. Society's remaining capabilities in nuclear engineering could be severely limited. These conditions could apply even if the general society at that time is prosperous and technologically competent. Also, as discussed in Section V, above, reasonably foreseeable factors could lead to prosperity, technological competence, and the quality of governance being at lower levels than in 2012.
(VI-6) Conversely, scenarios in the proposed EIS should also cover outcomes in which the nuclear-power industry employs new technology or expands the scale of its operations. As discussed in paragraphs VI-3 and VI-4, above, such outcomes would be inconsistent with current trends. However, they are as reasonably foreseeable as is a status quo scenario for the industry.
(VI-7) One potential new technology that is relevant to radiological risk is the use of ceramic fuel cladding as a replacement for the zirconium alloy (zircaloy) fuel cladding that is now used in light-water reactors. In situations where the fuel overheats, ceramic cladding may behave better than zircaloy cladding. Experience and analysis show that zircaloy cladding can readily undergo exothermic reaction with air or steam, and a steam-zircaloy reaction can yield a copious amount of hydrogen. These phenomena can greatly exacerbate the severity of a fuel-overheating incident. Currently, efforts to develop ceramic cladding appear to be focused on a "triplex" silicon carbide cladding. The developers hope to begin a prototype test program - in which complete fuel assemblies made with the triplex cladding are placed in commercial reactors - by about 2020.37 (VI-8) As mentioned in paragraph VI-2, above, the NRC's preliminary-assumptions document identified a scenario in which SNF is reprocessed. The technology to be employed for reprocessing was not discussed but, given that document's preference for the status quo, would presumably be the prevailing current technology (i.e., PUREX).
(VI-9) Consistent with paragraph VI-6, above, scenarios in the proposed EIS should cover a range of outcomes in which the nuclear-power industry expands the scale of its operations and/or employs technology that is "new" by comparison with the prevailing technology now used in light-water reactors. Potential new technology could include, in addition to ceramic fuel cladding and current-technology reprocessing:
37 Yueh et al, 2010.
 
Thompson Declaration.-Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, Temporary Storage of SNF or HL W Page 17 of 55
* Mixed-oxide (MOX) fuel
* Burning of light-water SNF in CANDU-type reactors (i.e., the DUPIC cycle)
* Reactors fueled by TRISO particles embedded in pebbles or prismatic blocks
* Sodium-cooled, fast-neutron breeder reactors
* Electrometallurgical pyroprocessing of SNF
* Accelerator-driven subcritical reactors
* Fusion reactors
* Fusion-fission hybrid reactors (VI-10) Paragraphs VI-2 through VI-9 outline how reasonably foreseeable future roles of nuclear power should be reflected in the proposed EIS. To summarize, I recommend as follows:
Recommendation #8: The scenarios considered in the proposed EIS should cover a range of potential outcomes regarding the role of nuclear power, including: (i) shrinkage in the number of operating reactors, with potential shutdown of all reactors by the middle of the 21s century; (ii) expansion in the number of operating reactors; and (iii) introduction of new technology.
(VI- 11) I pursue a related matter in Section VII, below. That matter is the potential variation, over time, in the inventories and modes of storage of SNF and HLW. In Section VII, I recommend that storage scenarios should be articulated to express a dynamic view of the inventory of stored SNF and HLW.
(VI-12) Other issues are also important in choosing scenarios. Notably, the scenarios should reflect the full range of potential variation of the risk environment, as discussed in Section V, above. Thus, I recommend as follows:
Recommendation #9: The scenarios considered in the proposed EIS should cover future societies exhibiting a range of variation in prosperity, technological capability, and the quality of governance.
(VI-13) The variation mentioned in Recommendation #9 could significantly influence radiological risk. For example, an impoverished society with degraded technological capability and governance might be unable or unwilling to maintain an SNF or HLW storage facility and the associated arrangements for security and emergency response. In that situation, the probability and consequences of a conventional accident or attack could increase.
(VI-14) As a corollary to Recommendation #9, the scenarios considered in the proposed EIS should cover a broad range of situations in which States and non-State actors are involved in violent conflict. During such situations, stored SNF or HLW could be
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 18 of 55 attacked directly or could experience indirect effects of violent conflict. A range of possible attacks is reasonably foreseeable.
(VI-15) Table VI-1 outlines the types of attack that could occur at an SNF storage facility, and the atmospheric releases of radioactive material that could ensue. This table assumes that the stored SNF has zircaloy cladding. The table would apply to high-density pool storage of SNF, or to storage of SNF in dry casks, but the event details would vary across those two cases. The table could also apply to dry-cask transportation of SNF. A somewhat similar table could be prepared for storage of HLW, with details varying according to the mode of storage.
(VI-16) A notable feature of Table VI-1 is that the atmospheric release of volatile radioactive species, including Cesium-137, would not necessarily scale linearly with the apparent violence of the attack. The apparent violence would decrease progressively as one moved from a Type 1 attack to a Type 4 attack. Yet, the release of volatile species from a Type 4 attack could exceed the release from a Type 3 attack or even a Type 2 attack. The reason is that a successful Type 4 attack would exploit the propensity of zircaloy cladding to undergo exothermic reaction. In the case of high-density pool storage of SNF, a Type 4 attacker might rely on self-ignition of the zircaloy, but in the case of dry-cask storage the attacker might use an incendiary device to ignite the zircaloy.
(VI-17) Table VI-1 shows some of the instruments that might be used to attack an SNF storage facility. The instruments that are mentioned have been available since World War II or, in some cases, much earlier. Attack scenarios that are considered in the proposed EIS should consider the use of a range of possible instruments and modes of attack. That range should include all relevant instruments and modes of attack that are now available to States or non-State actors.
(VI- 18) The shaped charge can illustrate some of the instruments of attack that are currently available. Table VI-2 outlines the status and potential applications of shaped-charge technology. Table VI-3 and Figures VI-1 through VI-3 provide supporting information. It is clear that an appropriate shaped charge could penetrate the structure of any commercial reactor or SNF storage facility in the USA. The capability to design, build, and use a shaped charge is widely distributed around the world. Many of the non-State actors that have engaged in violent conflict in recent decades could have deployed that capability, and some have done so (e.g., Iraqi insurgents).
(VI-19) Some potential attacks on nuclear facilities would involve the use of general-aviation aircraft. Figure VI-4 illustrates the fact that general-aviation aircraft have been used as instruments of attack. In the context of the proposed EIS, reasonably foreseeable events include attacks in which general-aviation aircraft are equipped with explosive charges, potentially including shaped charges.
 
Thompson Declaration.-Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, Temporary Storage of SNF or HLW Page 19 of 55 (VI-20) Paragraphs VI-14 through VI-19 outline how reasonably foreseeable acts of violence affecting stored SNF or HLW should be considered in the proposed EIS. To summarize, I recommend as follows:
Recommendation #10: The scenarios considered in the proposed EIS should cover a range of potential future outcomes regarding the propensity for violent conflict, and should cover situations in which stored SNF or HLW would experience attacks involving States or non-State actors.
VII. SNF and HLW Storage Modes and Dynamics to be Considered in the Proposed EIS (VII-1) The NRC's preliminary-assumptions document envisioned the long-term temporary storage of SNF and related HLW. Subsequently, in the context of the proposed EIS, the NRC introduced the possibility that a repository may affect the need for storage. As discussed in paragraph 1-4, above, the NRC envisions the possibility that storage will continue "until [emphasis added] a repository is made available". The implication is that the repository would absorb the entire stored inventory of SNF and HLW immediately upon becoming "available". That outcome is impossible. In fact, transfer of stored SNF and HLW would occur over a period of decades.
(VII-2) Table VII-1 shows the estimated duration of phases of implementation of the Yucca Mountain repository. For the case in which the repository would receive 105,000 MTHM of commercial SNF, one sees that the Construction phase would occupy 5 years.
Thereafter, emplacement of SNF would occupy an additional 38-51 years. (The Development and Emplacement phases would occur in parallel.) It is notable that legislation limited the amount of SNF that could be placed in Yucca Mountain to 63,000 MTHM, and that the Blue Ribbon Commission published a projection that 133,000 MTHM of SNF will be accumulated in the USA by 2050.38 The same projection indicates that an increasing fraction of the SNF inventory will be in dry storage.
(VII-3) Thus, a range of reasonably foreseeable situations could unfold over time. For example, the national inventory of stored SNF could rise over several decades, then fall over several more decades while emplacement in a repository is occurring, then resume growing when the repository is full. During that process, there could be significant shifts of SNF from one storage mode to another.
(VII-4) It is clear that, if the proposed EIS is to be credible, it must examine a range of possible trends in SNF and HLW storage over time, throughout the period covered by the EIS. This matter is significant from the perspective of radiological risk, as discussed below. Accordingly, I recommend as follows:
38 BRC, 2012, Figure 15.
 
Thompson Declaration.-Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HLW Page 20 of 55 Recommendation #11: The proposed EIS should take a dynamic view of the potential inventories and modes of storage of SNF and HLW, by considering a range of storage scenarios.
(VII-5) Taking a "dynamic view" would mean that scenarios of the type discussed in Section VI, above, would be accompanied by storage scenarios that account for at least the following factors and their variations over time:
* Discharge of SNF from reactors
* Initial mode of storage of SNF (e.g., high-density pool storage, or low-density pool storage)
* Reprocessing of SNF
* Initial mode of storage of HLW (e.g., liquid in tanks, or vitrified canisters in vaults or dry casks)
* Transfer of SNF or HLW from one storage mode to another (e.g., transfer of SNF from high-density pool storage to dry-cask storage)
* Movement of SNF or HLW from one site to another
* Emplacement of SNF or HLW in a repository (VII-6) The radiological risk posed by a particular facility for storing SNF or HLW could vary in response to at least five major factors, as follows:
* The threat environment at the facility could change over time.
* The mass of SNF or HLW stored at the facility could change over time.
* The modes of storage could vary in the radiological risk that they pose, for a given mass of SNF or HLW.
* The radiological risk posed by a given mode of storage (e.g., a high-density SNF storage pool) could vary according to the operational status of an adjacent facility (e.g., a reactor).
* The radiological risk posed by a given mass of SNF or HLW tends to decline with age, other factors being equal, because: (i) its radioactive decay heat production declines over time, resulting in a decreased propensity to overheat and release radioactive material to the atmosphere; and (ii) the inventory of radioactive material that is available for release also declines (VII-7) From paragraph VII-6 it is clear that each storage scenario of the type discussed in paragraph VII-5 would have its own profile of radiological risk over time.
(VII-8) In paragraph VII-6, above, I note that: (i) modes of storage could vary in the radiological risk that they pose, for a given mass of SNF or HLW; and (ii) the radiological risk posed by a given mode of storage (e.g., a high-density SNF storage pool) could vary according to the operational status of an adjacent facility (e.g., a reactor). These observations support a more general point, which is addressed in my Recommendation #6, namely that the comparative radiological risk posed by a range of
 
Thompson Declaration:Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, Temporary Storage ofSNF or HL W Page 21 of 55 alternative options for storing SNF or HLW should be assessed in the proposed EIS as a major indicator of the comparative impacts of these alternatives. Accordingly, I recommend as follows:
Recommendation #12: The proposed EIS should use a range of storage scenarios as vehicles to help assess the comparative radiological risk posed by alternative options for storing SNF or HLW.
(VII-9) The comparative radiological risk posed by alternative options for storing SNF or HLW is determined by a number of factors. One factor that can be a significant determinant of comparative risk, other factors being equal, is the extent to which the storage facility is placed below ground level. In illustration, Holtec has developed a design for an SNF dry-cask storage module that is said to be more robust against attack than conventional modules. The module in question is the HI-STORM 1OOU module, which would employ the same internal canister (MPC) as is used in the conventional Holtec modules. For most of its height, the IOOU module would be 39below ground level.
Holtec has described the robustness of the 100U module as follows:
          "Release of radioactivity from the HI-STORM 1OOU by any mechanical means (crashing aircraft, missile, etc.) is virtually impossible. The only access path into the cavity for a missile is vertically downward, which is guarded by an arched, concrete-fortified steel lid weighing in excess of 10 tons. The lid design, at present configured to easily thwart a crashing aircraft, can be further buttressed to withstand more severe battlefield weapons, if required in the future for homeland security considerations. The lid is engineered to be conveniently replaceable by a later model, if the potency of threat is deemed to escalate to levels that are considered non-credible today."
(VII-10) In considering the storage of SNF or HLW below ground level, it should be noted that there is considerable discussion about the roles of reversibility and retrievability in the design of repositories for radioactive waste. 40 Indeed, the Yucca Mountain repository was nominally designed for retrievability during the Emplacement and Monitoring phases that are shown in Table VII-1. Reversibility and retrievability at a repository are issues relevant to discussion about the extent to which nuclear power could be compatible with sustainable development. In the context of this declaration, it is notable that retrievable emplacement of SNF or HLW in a repository, deep underground, would be a form of storage that could pose lower radiological risk than would storage at the surface. Accordingly, I recommend as follows:
Recommendation #13: In assessing the comparative radiological risk posed by alternative options for storing SNF or HLW, the proposed EIS should regard retrievable emplacement in a repository as a mode of storage.
'9 Holtec, 2007.
40 Nuclear Energy Agency, 2011.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage ofSNF or HL W Page 22 of 55 (VII-1 1) In paragraph 11-4, above, I mention the concept of a "pool fire". That term refers to the occurrence of self-sustaining, exothermic oxidation reactions of fuel cladding in a high-density SNF pool if water is lost from the pool. More precisely, a pool fire would involve the following sequence of events:
* loss of water from the pool due to leakage, boiling away, siphoning, or other mechanism
* failure to provide water makeup or cooling
* uncovering of SNF assemblies
* heat-up of some SNF assemblies to the ignition point of zircaloy, followed by combustion of these assemblies in steam and/or air
* a hydrogen explosion (not inevitable, but likely) that damages the building surrounding the pool
* release of radioactive material from affected SNF assemblies to the atmosphere
* propagation of combustion to other SNF assemblies (VII-12) A pool-fire event sequence would unfold over a timeframe ranging from a few hours to a number of days. During this timeframe, there might, in principle, be opportunities for personnel to halt or mitigate the event sequence through actions such as plugging holes in a pool, or adding water. However, addition of water after zircaloy ignites could be counter-productive, because the water could feed combustion.
Circumstances accompanying the pool-fire event sequence, such as a core-damage event sequence at an adjacent reactor, could preclude mitigating actions. This matter is discussed in Section VIII, below.
(VII-13) The NRC concedes that a pool fire could occur, but argues that its probability is very low. 4' Nevertheless, the NRC acknowledges this event in its planning for emergencies. For example, a workbook used to train personnel in use of NRC's dose-projection code RASCAL contains an exercise in which trainees are asked to calculate offsite radiation doses in the event 42  of a pool fire. The exercise is introduced with the following    description  of the event:
          "The plant staff are calling you from San Onofre, Unit 2 because there has been an earthquake in the vicinity. The spent fuel pool has lost much of its water due to a large crack possibly flowing into a sink hole. Due to a malfunctioning pump, it has not been possible to provide enough water to make up for the loss. The water dropped to the top of the fuel at 8:49 A.M., and appears likely to continue dropping. Estimates are that the fuel will be fully uncovered by 11:00 A.M. The pool has high density racking and contains one batch of fuel that was unloaded from the reactor only 2 weeks earlier. (A batch is defined as one-third of a core) 41For example, in a 2008 decision the NRC stated: "Thus, the very low probability [emphasis added] of an SFP zirconium fire would result in an SFP risk level less than that for a reactor accident." (See: NRC, 2008, page 46212.)
42 Athey et al, 2007, page 116.
 
Thompson Declaration:Recommendationsfor NRC's Consideration ofEnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HLW Page 23 of 55 Another batch was unloaded about a year before that, and 8 batches have been in the pool for longer than 2 years. The spent fuel building has been severely damaged and is in many places directly open to the atmosphere."
(VII-14) One notable feature of pool fires is that the potential for their occurrence derives almost entirely from the practice of employing high-density racks in SNF pools.
That practice is now almost universal at US pools. If the high-density racks were replaced with low-density racks, SNF would not spontaneously ignite across a broad range of water-loss scenarios. The nuclear industry is reluctant to make the change to low-density racks, primarily because of the cost involved. Another notable feature of pool fires is that a pool fire could release a large inventory of radioactive material, especially Cesium-137, creating substantial radiological impact.
(VII- 15) SNF stored in a dry cask could, in principle, experience an event analogous to a pool fire. I term that potential event a "cask fire". Occurrence of a cask fire would require that three conditions are satisfied. First, a circulating pathway between SNF and the atmosphere must exist, so that air can reach the SNF and combustion products (and Cesium-137) can reach the atmosphere. Second, circulation of fluid through this pathway must be driven by natural convection. Third, the temperature of the cladding of a portion of the SNF in the cask must be raised to the ignition point, so that a self-sustaining reaction can begin.
(VII-16) A pool fire could be initiated by a conventional accident or by an attack. By contrast, a cask fire could be initiated by an attack, but its initiation by a conventional accident is comparatively unlikely. This matter is addressed further in Section VIII, below. A cask fire could release a substantial fraction of the volatile radioactive material, such as Cesium-137, in the cask. Thus, a cask fire could create substantial radiological impact.
(VII- 17) In light of the discussion in paragraphs VII- 11 through VII- 16, above, I recommend as follows:
Recommendation #14: In assessing the comparative radiological risk posed by alternative options for storing SNF or HLW, the proposed EIS should give special attention to the potential for radioactive release from stored SNF as a result of a pool fire or a cask fire.
(VII-18) My Recommendation #12 is that the proposed EIS should use a range of storage scenarios as vehicles to help assess the comparative radiological risk posed by alternative options for storing SNF or HLW. Two SNF storage scenarios could be particularly useful to illustrate the options available, and their comparative radiological risk. These SNF storage scenarios would be: (i) an Extended Status Quo scenario; and (ii) a Nuclear Power Rundown with SNF Risk Minimization scenario.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HLW Page 24 of 55 (VII-19) The Extended Status Quo storage scenario would involve:
* Production of SNF continues at about the present level
* Newly-discharged SNF is placed in high-density pools adjacent to reactors
* Excess SNF is placed in dry casks on reactor sites
* This situation continues for some number of centuries (VII-20) The Nuclear Power Rundown with SNF Risk Minimization storage scenario would involve:
* The present reactors shut down at the ends of their license periods or earlier, and no new reactors commence operating
* Newly-discharged SNF is placed in low-density pools adjacent to reactors
* Excess SNF is placed in dry casks on reactor sites, with additional protection (e.g., the HI-STORM IOOU system, or placement of casks within berms, robust buildings, or tunnels)
* A repository begins receiving SNF as soon as possible (VII-21) To summarize the discussion in paragraphs VII-18 through VII-20, above, I recommend as follows:
Recommendation #15: The SNF storage scenarios to be considered in the proposed EIS should include: (i) an Extended Status Quo scenario; (ii) a Nuclear Power Rundown with SNF Risk Minimization scenario; and (iii) a range of other scenarios.
VIII. Phenomena Relevant to Radioactive Release from SNF or HLW (VIII- 1) My Recommendation #14 indicates that the proposed EIS should give special attention to the potential for radioactive release from stored SNF as a result of a pool fire or a cask fire. To date, the phenomena associated with a pool fire or a cask fire have not been adequately examined. I address that matter in the following paragraphs. Section VIII closes with some brief observations on phenomena relevant to radioactive release from HLW.
(VIII-2) As stated in paragraph 11-4, above, I publicly identified the potential for a pool fire in 1979, and the Lower Saxony government accepted my findings. Independently, a group at Sandia Laboratories identified the same potential in a report prepared for the NRC.4 3 In light of knowledge that has accumulated since 1979, the Sandia report generally stands up well, provided that one reads the report in its entirety. However, the report's introduction contains an erroneous statement that complete drainage of an SNF 43 Benjamin et al, 1979.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HLW Page 25 of 55 pool is the most severe situation in the context of a pool fire. The body of the report clearly shows that partial drainage can be a more severe case, as I had previously recognized. Unfortunately, NRC continued, until October 2000, to employ the erroneous assumption that complete drainage is the most severe case.
(VIII-3) After receiving the Sandia report, the NRC conducted and sponsored a number of analyses related to pool fires. Those analyses were published over a period of about two decades. I identified and critiqued that body of work in a February 2009 report, reaching the following conclusion:4 "NRC has conducted some analyses related to the radiological risk described in conclusion C2. [That conclusion addressed both pool fires and cask fires.] The analyses that have been published, taken together, provide an incomplete and inaccurate assessment of the risk. None of the published analyses meets the standards of an EIS prepared under NEPA. NRC has issued statements about the radiological risk associated with malice-induced accidents affecting spent fuel, but has neither published any technical analysis of that risk, nor published any citation to a secret analysis that could meet the standards of an EIS prepared under NEPA."
(VIII-4) After September 2001, the NRC ceased publishing analysis on pool fires, but claims to have done some secret studies. To my knowledge, the NRC has not published any significant analysis on pool fires or cask fires since February 2009. Thus, my conclusion of February 2009, as quoted in paragraph VIII-3, remains valid.
(VIII-5) The US Government Accountability Office (GAO) confirms that the NRC has, indeed, done some secret studies on pool fires. However, according to the    45 GAO, the NRC has    lost track of  those studies. An August 2012  GAO  report states:
        "Because a decision on a permanent means of disposing of spent fuel may not be made for years, NRC officials and others may need to make interim decisions, which could be informed by past studies on stored spent fuel. In response to GAO requests, however, NRC could not easily identify, locate, or access studies it had conducted or commissioned because it does not have an agencywide mechanism to ensure that it can identify and locate such classified studies."
(VIII-6) I identified a similar problem in my February 2009 report, which .1discuss in paragraph VIII-3, above. In that report, I examined statements, in two official NRC documents published in 2008, regarding secret studies allegedly conducted or sponsored  46 by the NRC in order to improve technical understanding of pool fires. I concluded:
44 Thompson 2009, Section 11, Conclusion C3.
4' GAO, 2012, Highlights.
46 Thompson, 2009, Section 5.2, pp 24-25.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, Temporary Storage of SNF or HLW Page 26 of 55 "To summarize, the Draft Update, issued in October 2008, mentions one set of secret studies, while the rulemaking petition decision, issued in August 2008, mentions a different set of secret studies. This inconsistency represents, at a minimum, carelessness and a lack of respect for the public."
(VIII-7) The experiences outlined in paragraphs VIII-5 and VIII-6 illustrate the corrosive, counterproductive effects of an entrenched culture of secrecy. Such a culture is not compatible with a clear-headed, science-based approach to the understanding of radiological risk. Entrenched secrecy perpetuates dogma, stifles dissent, encourages conflicts of interest, promotes laziness, and can create a false sense of security. Indeed, secrecy can significantly increase radiological risk. For example, there is evidence that a major risk factor underlying the 1986 Chernobyl reactor accident was endemic secrecy in the USSR.47 (VIII-8) There is no justification for secrecy about the phenomena associated with potential pool fires. A pool fire could be initiated by either a conventional accident or an attack. In either case, the phenomena associated with the fire itself would be similar.
Effective management of the radiological risk of a potential pool fire, in the context of conventional accidents, demands open, transparent consideration of all associated phenomena. The resulting publication of information would not significantly assist an entity that contemplates an attack on an SNF pool. A capable entity in that category would already possess, or could readily obtain, the information needed to plan an attack.
The NRC itself has published sabotage scenarios, as shown in Table IV-3, that could, with modest adaptation, lead to an unstoppable pool fire with severe offsite impacts. In any event, if the NRC determines in future that an attack-initiated pool fire is a significant threat, the mitigation of that threat could be simple. The NRC could order its licensees to re-equip their SNF pools with low-density racks, which could be accomplished comparatively quickly.
(VIII-9) In light of the discussion in paragraphs VIII-2 through VIII-8, above, I recommend as follows:
Recommendation #16: In assessing the potential for radioactive release from stored SNF as a result of a pool fire, the proposed EIS should rely on an updated, transparent, fully published body of analytic and empirical investigation that adequately describes all relevant phenomena, including: (i) the dynamics of cladding self-ignition across a range of water-loss and fuel-loading scenarios; (ii) propagation of exothermic reactions between fuel assemblies; (iii) hydrogen generation; (iv); heat generation; and (v) atmospheric release of radioactive material.
17 Shlyakhter and Wilson, 1992.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, TemporaryStorage of SNF or HL W Page 2 7 of 55 (VIII- 10) My Recommendation # 16 addiesses phenomena associated with a pool fire, rather than the pre-conditions and initiating events that could cause a pool fire to commence. To date, these matters have not been adequately examined. I address them in the following paragraphs.
(VIII- 11) As mentioned in paragraph VII-12, above, a pool-fire event sequence would unfold over a timeframe ranging from a few hours to a number of days. During this timeframe, there might, in principle, be opportunities for personnel to halt or mitigate the event sequence. For a particular event sequence, the timeframe, and the existence of potential opportunities to halt or mitigate the sequence, would reflect factors including:
(i) the facility design; (ii) the age and disposition of SNF in the pool; and (iii) the nature of the initiating event, which could be a conventional accident or an attack.
(VIII- 12) Although potential opportunities to halt or mitigate a pool-fire event sequence might exist in principle, circumstances accompanying the sequence could prevent personnel from exploiting those opportunities. One category of such circumstances would be the degradation of site conditions caused by an incident at an adjacent facility.
For example, that incident could block cooling and water makeup to the pool, and access by personnel to restore those services could be precluded by phenomena such as high radiation fields, fires, explosions, damage to equipment and structures, and release of high-temperature steam and gases. That situation is not speculative, because it occurred at the Fukushima #1 site in 2011. Figure VIII-1 shows Unit 4 at that site during the 2011 accident. A concrete pumping truck is shown, spraying water into the SNF pool. Prior to the arrival of that truck, unsuccessful attempts had been made over anumber of days to add water to SNF pools at the site, employing fire trucks, police riot control vehicles, and bags of water suspended from helicopters. Yet, despite this vivid illustration of the threat, the NRC has never published a credible analysis of the potential for degraded-site conditions to enable or exacerbate a pool fire.
(VIII-13) In light of the discussion in paragraphs VIII-1 1 and VIII-12, above, I recommend as follows:
Recommendation #17: In assessing the potential for initiation of a pool fire at a given facility, the proposed EIS should account for factors including: (i) the potential occurrence of a range of conventional accidents or attacks at the facility; (ii) a range of water-loss and fuel-loading scenarios; and (iii) the potential occurrence of degraded-site conditions due to an incident at an adjacent facility (e.g., a reactor).
(VIII-14) In paragraph VII-l15, above, I outline the conditions that must be satisfied for a cask fire to occur. In paragraph VII- 16, I note that an attack could satisfy those conditions. The NRC has not yet conceded that an attack could initiate a cask fire.
However, the NRC has been reliably informed that a reasonably foreseeable attack could
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 28 of 55 penetrate a cask, damage SNF inside the cask, and cause a release of radioactive material to the atmosphere. That point has been established by a body of empirical work whose findings have been openly published. For example, consider a 2008 Sandia report on tests related to potential sabotage of an SNF storage or transport cask. The report states :48 "In some plausible, intentional sabotage scenarios, such as an attack employing a high energy density device (HEDD), i.e., explosive armor-piercing weapons, it is possible that a cask could be penetrated. Then, a small percentage of aerosolized particles produced within from disrupted fuel rod and pellet materials could be released as a radiological inhalation source hazard. If released to the environment in a significant quantity, the spent fuel respirable particles have the potential to cause radiological consequences."
(VIII- 15) From the preceding paragraph, it is clear that attack-induced penetration of an SNF cask, leading to atmospheric release, is a reasonably foreseeable event. With a few additional steps, attackers could initiate a cask fire. I addressed that matter in a 2008 declaration, being careful to avoid disclosing information that could directly assist an attacker. 49 I conclude that an attack-induced cask fire is a reasonably foreseeable event.
(VIII- 16) My position on the foreseeability of an attack-induced cask fire differs from the public position of the NRC. The difference boils down to a question: Could attackers who are capable of penetrating an SNF cask take the additional steps needed to initiate a cask fire? That question could be addressed by commissioning an independent "Red Team" of persons who have relevant experience in practice and research. That team could conduct tests at a national laboratory or military base, to determine how readily a cask fire could be initiated. The tests could involve the use of tracer materials, thereby contributing to estimation of the radioactive release that could result from a cask fire.
The general findings of the tests should be published, but some details of the tests may not be appropriate for publication.
(VIII- 17) Figure VIII-2 shows that the NRC has sponsored a test burn of an SNF assembly. The findings from that test could improve understanding of both pool fires and cask fires. Accordingly, those findings should be published. Findings from similar tests should also be published.
(VIII-18) In light of the discussion in paragraphs VIII-14 through VIII-17, above, I recommend as follows:
Recommendation #18: In assessing the potential for radioactive release from stored SNF as a result of a cask fire, the proposed EIS could rely on a body of analytic and empirical investigation that is not fully published, provided that the 41 Molecke et al, 2008, Section 1,page 9.
49 Thompson, 2008b, Section V.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 29 of 55 NRC has engaged an independent Red Team to determine through representative tests whether a cask fire can be initiated and, if so, what release of radioactive material would be likely to occur.
(VIII- 19) The preceding paragraphs in Section VIII have addressed phenomena associated with a pool fire or a cask fire. That focus of attention is consistent with my Recommendation #14. However, as stated in my Recommendation #2, the proposed EIS should address the potential storage of HLW as well as SNF. Thus, the proposed EIS should be supported by a thorough examination of phenomena relevant to radioactive release from HLW. I have studied such phenomena in several contexts. One such context is the storage of HLW in liquid form at the Sellafield site in the UK. 50 IX. Assessing Likelihood and Impacts of Radiological Incidents (IX-1) My Recommendation #4 is that assessment of radiological risk should be a major function of the proposed EIS. Such assessment will require estimation of the likelihood and the impacts of potential radiological incidents. I address these matters in the following paragraphs.
(IX-2) An analyst who seeks to estimate the likelihood of potential radiological incidents can employ various sources of information and various analytic tools. One of those tools is the art of probabilistic risk assessment (PRA). The high point of PRA practice in the nuclear-power sector to date was the NRC's NUREG-1 150 study, which examined the radiological risk posed by five US nuclear power plants, in the context of conventional 5
accidents. 1 (IX-3) PRA techniques, if judiciously applied, could contribute to an assessment of the likelihood of radiological incidents involving stored SNF or HLW. However, as discussed in paragraph IV-6, above, the limitations of PRA techniques should be recognized.5 Accordingly, I recommend as follows:
Recommendation #19: In assessing the likelihood of a radiological incident, the proposed EIS should rely on diverse sources of information, and should not rely solely upon the findings of probabilistic risk assessment.
(IX-4) An analyst who seeks to estimate the impacts of potential radiological incidents should consider a range of impacts. In the context of incidents involving atmospheric release, I recommend as follows:
Recommendation #20: In assessing the impacts of a potential radiological incident involving atmospheric release, the proposed EIS should consider types of impact including: (i) plume exposure; (ii) ground contamination and resulting 5o Thompson, 1998.
5" NRC, 1990.
52 For additional information on the limitations of PRA, see: Hirsch et al, 1989.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, Temporary Storage of SNF or HLW Page 30 of 55 exposure; (iii) exposure via food and water pathways; (iv) health effects pursuant to total exposure; (v) abandonment of assets; (vi) cleanup costs; (vii) direct and indirect economic impacts; and (viii) social impacts.
(IX-5) In paragraphs (IV-5) through (IV-7), above, I describe the "arithmetic" definition of risk and show how that definition can be seriously misleading. Nevertheless, the NRC  53 is prone to using the arithmetic definition in official documents. Here is an example:
        "Risk is defined as the probability of the occurrence of a given event multiplied by the consequences of that event."
(IX-6) The quoted statement is inconsistent with the NRC's Glossary, as footnoted in my paragraph (IV-4), above. Moreover, the quoted statement is inconsistent with its own footnote, which refers to an ASME standard. In light of these inconsistencies and my finding that the arithmetic definition can be seriously misleading, I recommend as follows:
Recommendation #21: In considering radiological risk, the proposed EIS should repudiate the arithmetic definition of risk.
(IX-7) Radiological risk is one category of potential impacts from storage of SNF or HLW. A related category is the set of implications of storage options for national security. I address that matter in Table IX-1, with a focus on the threat of attack by non-State actors. That table shows how robust and inherently-safer design of infrastructure facilities, such as facilities for storing SNF or HLW, could contribute to a national strategy of protective deterrence. Accordingly, I recommend as follows:
Recommendation #22: In assessing the overall impacts of storing SNF or HLW, the proposed EIS should consider the implications of alternative storage options for a national strategy of protective deterrence.
53 NRC, 2008, page 46207.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HLW Page 31 of 55 X. Summary of Recommendations (X-1) Numbered recommendations regarding the scope of the proposed EIS are set forth within Sections I through IX of this declaration. Here, the recommendations are repeated, grouped by the sections where they are set forth. Each recommendation should be read within the context of the narrative that surrounds it. The recommendations are:
SECTION I Recommendation #1: The NRC's preliminary-assumptions document should be a point of departure for determining the scope of the proposed EIS, especially in regard to storage after the end of the 2 1 st century.
Recommendation #2: The proposed EIS should not only address the storage of SNF, but also the potential storage of HLW from reprocessing of SNF.
Recommendation #3: The proposed EIS should consider the radiological risk posed by storage of SNF from the moment of its discharge from a reactor.
SECTION IV Recommendation #4: Assessment of radiological risk should be a major function of the proposed EIS, this category of risk being defined as the potential for harm to humans as a result of unplanned exposure to ionizing radiation.
Recommendation #5: The proposed EIS should assess the radiological risk arising from a range of conventional accidents or attacks that could affect stored SNF or HLW.
Recommendation #6: The comparative radiological risk posed by a range of alternative options for storing SNF or HLW should be assessed in the proposed EIS as a major indicator of the comparative impacts of these alternatives.
SECTION V Recommendation #7: Risk assessment in the proposed EIS should be supported by a set of indicators that express the dynamic aspects of the potential risk environment across the time period and suite of scenarios considered in the EIS.
SECTION VI Recommendation #8: The scenarios considered in the proposed EIS should cover a range of potential outcomes regarding the role of nuclear power,
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 32 of 55 including: (i) shrinkage in the number of operating reactors, with potential shutdown of all reactors by the middle of the 21s' century; (ii) expansion in the number of operating reactors; and (iii) introduction of new technology.
Recommendation #9: The scenarios considered in the proposed EIS should cover future societies exhibiting a range of variation in prosperity, technological capability, and the quality of governance.
Recommendation #10: The scenarios considered in the proposed EIS should cover a range of potential future outcomes regarding the propensity for violent conflict, and should cover situations in which stored SNF or HLW would experience attacks involving States or non-State actors.
SECTION VII Recommendation #11: The proposed EIS should take a dynamic view of the potential inventories and modes of storage of SNF and HLW, by considering a range of storage scenarios.
Recommendation #12: The proposed EIS should use a range of storage scenarios as vehicles to help assess the comparative radiological risk posed by alternative options for storing SNF or HLW.
Recommendation #13: In assessing the comparative radiological risk posed by alternative options for storing SNF or HLW, the proposed EIS should regard retrievable emplacement in a repository as a mode of storage.
Recommendation #14: In assessing the comparative radiological risk posed by alternative options for storing SNF or HLW, the proposed EIS should give special attention to the potential for radioactive release from stored SNF as a result of a pool fire or a cask fire.
Recommendation #15: The SNF storage scenarios to be considered in the proposed EIS should include: (i) an Extended Status Quo scenario; (ii) a Nuclear Power Rundown with SNF Risk Minimization scenario; and (iii) a range of other scenarios.
SECTION VIII Recommendation #16: In assessing the potential for radioactive release from stored SNF as a result of a pool fire, the proposed EIS should rely on an updated, transparent, fully published body of analytic and empirical investigation that adequately describes all relevant phenomena, including: (i) the dynamics of cladding self-ignition across a range of water-loss and fuel-loading scenarios; (ii) propagation of exothermic reactions between fuel assemblies; (iii) hydrogen
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HLW Page 34 of 55 I declare, under penalty of perjury, that the facts set forth in the foregoing narrative, and in the two appendices below, are true and correct to the best of my knowledge and belief, and that the opinions expressed therein are based on my best professional judgment.
Executed on 2 January 2013.
Gordon R. Thompson
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 35 of 55 APPENDIX A: Bibliography (Albrecht, 1979)
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(Alvarez et al, 2003)
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Jan Beyea, Yves Lenoir, Gene Rochlin, and Gordon Thompson (group chair), "Potential Accidents and Their Effects," Chapter 3 in Report of the Gorleben InternationalReview, March 1979. (This chapter was prepared in English and translated into German for submission to the Lower Saxony State Government.)
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(Brick, 2010)
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(Nuclear Energy Agency, 2000)
Nuclear Energy Agency, Nuclear Energy in a Sustainable Development Perspective (Paris: OECD, 2000).
(PwC, 2012)
Pricewaterhouse Coopers LLP, Too latefor two degrees?: Low carbon economy index 2012 (London: Pricewaterhouse Coopers LLP, November 2012).
(Raskin et al, 2002)
Paul Raskin and six other authors, Great Transition: The Promiseand Lure of the Times Ahead (Boston, Massachusetts: Stockholm Environment Institute, 2002).
(Raytheon, 2008)
Raytheon Company, "Raytheon Unveils New Record-Breaking Bunker Busting Technology", 12 March 2008, accessed on 7 March 2012 at:
http://www.ravtheon.coini/newsroom/feature/bb 03-10/
(Rockstrom et al, 2009)
Johan Rockstrom and twenty-eight other authors, "Planetary Boundaries: Exploring the Safe Operating Space for Humanity", Ecology and Society, Volume 14, Number 2, Article 32, 2009. Accessed on 1 November 2012 at:
http://\-\v.ecologNxanclsocietv.org/vol 14/iss2/art32/
(Schneider et al, 2012)
Mycle Schneider and Antony Froggatt with Julie Hazemann, World Nuclear Industry Status Report 2012 (Paris: Mycle Schneider Consulting, July 2012).
(Shlyakhter and Wilson, 1992)
Alexander Shlyakhter and Richard Wilson, "Chernobyl: the inevitable results of secrecy",
Public Understandingof Science, Volume 1, July 1992, pp 251-259.
(Thompson, 2009)
Gordon R. Thompson, EnvironmentalImpacts of Storing Spent Nuclear Fuel and High-Level Waste from Commercial Nuclear Reactors: A Critique of NRC's Waste Confidence Decision and EnvironmentalImpact Determination(Cambridge, Massachusetts: Institute for Resource and Security Studies, 6 February 2009).
 
Thompson Declaration:Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, Temporary Storage of SNF or HL W Page 39 of 55 (Thompson, 2008a)
Gordon R. Thompson, "The US Effort to Dispose of High-Level Radioactive Waste",
Energy and Environment, Volume 19, Nos. 3+4, 2008, pp 391-412.
(Thompson, 2008b)
Gordon R. Thompson, "Declaration of Dr. Gordon R. Thompson on Behalf of San Luis Obispo Mothers for Peace in Support of Contention 2 Regarding the Construction and Operation of the Diablo Canyon Independent Spent Fuel Storage Installation", 14 April 2008.
(Thompson, 2005)
Gordon R. Thompson, Reasonably ForeseeableSecurity Events: Potentialthreats to optionsfor long-term management of UK radioactive waste (Cambridge, Massachusetts:
Institute for Resource and Security Studies, 2 November 2005).
(Thompson, 1998)
Gordon Thompson, High Level Radioactive Liquid Waste at Sellafield: Risks, Alternative Options andLessons for Policy (Cambridge, Massachusetts: Institute for Resource and Security Studies, June 1998).
(Warwick, 2008)
Graham Warwick, "VIDEO: Raytheon tests bunker-busting tandem warhead",
Flightglobal,26 February 2008, accessed on 7 March 2012 from:
http://Hvvxvv.fl ight gl.obal .coni/news/articles/vid.eo-ravtlheon.-tests-bun.ker-busting-tandei-warhead-22 1842/
(WCED, 1987)
World Commission on Environment and Development, Our Common Future (Oxford, UK: Oxford University Press, 1987).
(Weber, 2011)
Michael Weber (US Nuclear Regulatory Commission), "Ensuring Spent Fuel Pool Safety", viewgraphs for display at American Nuclear Society meeting, 28 June 2011.
(WEF, 2012)
World Economic Forum, Global Risks 2012 (Geneva: WEF, 2012).
(Yueh et al, 2010)
Ken Yueh, David Carpenter, and Herbert Feinroth, "Clad in clay", Nuclear Engineering International,8 March 2010.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HLW Page 40 of 55 APPENDIX B: Tables and Figures List of Tables Table IV- 1: A Possible Framework of Sustainable-Development Principles for Design and Appraisal of Infrastructure Projects Table IV-2: Some Categories of Risk Posed by a Commercial Nuclear Facility Table IV-3: Potential Sabotage Events at an SNF Storage Pool, as Postulated in the NRC's August 1979 Generic EIS on Handling and Storage of Spent LWR Fuel Table V-1: Future World Scenarios Identified by the Stockholm Environment Institute Table VI-i: Potential Types of Attack on an SNF Storage Facility Leading to Atmospheric Release of Radioactive Material Table VI-2: The Shaped Charge as a Potential Instrument of Attack Table VI-3: Performance of US Army Shaped Charges, M3 and M2A3 Table VII- 1: Estimated Duration of Phases of Implementation of the Yucca Mountain Repository Table IX-1: Selected Approaches to Protecting Critical Infrastructure in the USA From Attack by Non-State Actors, and Some Strengths and Weaknesses of these Approaches List of Figures Figure VI-1: Schematic View of a Generic Shaped-Charge Warhead Figure VI-2: MISTEL System for Aircraft Delivery of a Shaped Charge, World War IT Figure VI-3: January 2008 Test of a Raytheon Shaped Charge, Intended as the Penetration (Precursor) Stage of a Tandem Warhead System Figure VI-4: Aftermath of a Small-Aircraft Suicide Attack on an Office Building in Austin, Texas, February 2010 Figure VIII-1: Unit 4 at the Fukushima #1 Site During the 2011 Accident Figure VIII-2: Outcome of Test Bum of a BWR Fuel Assembly
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 41 of 55 Table IV-1 A Possible Framework of Sustainable-Development Principles for Design and Appraisal of Infrastructure Projects Objective                      Design Approach Dictated by Objective
#1. Build and preserve assets        Design for preservation and enhancement of:
                                        " Human capital
* Natural capital
                                        " Engineered capital
#2. Create options for the future    Design for:
0 Reversibility 0 Resilience
* Adaptability
* Flexibility
#3. Manage risk                      Prepare for unusual events by:
                                          " Identifying and characterizing potential events
                                          " Designing infrastructure to ride out events or to fail consistent with objectives #1 and #2
* Planning for emergency response Notes:
(a) This particular framework of principles is attributable to Gordon R. Thompson. Each principle in the framework has been widely discussed by many authors and has, to some extent, been applied to the design of infrastructure. (See, for example: Nuclear Energy Agency, 2000.) However, at present there is no generally accepted framework that integrates these principles.
(b) This framework reflects the definition of sustainable development that was set forth by the World Commission on Environment and Development in 1987, as follows (WCED, 1987, beginning of Chapter 2):
        "Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs."
(c) Infrastructure should serve a societal purpose. A particular societal purpose could be served by a variety of configurations of infrastructure. A framework such as the one set forth here could be used to appraise the comparative sustainability of proposed configurations, across a range of options.
(d) Logically, the principles used to appraise an infrastructure project should be identical to the principles used to design the project.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 42 of 55 Table IV-2 Some Categories of Risk Posed by a Commercial Nuclear Facility Category                    Definition                        Mechanisms Radiological risk        Potential for harm to          Exposure arising from:
humans as a result of
* Release of radioactive unplanned exposure to                  material via air or water ionizing radiation                    pathways, or
* Line-of-sight exposure to unshielded radioactive material or a criticality event Proliferation risk        Potential for diversion of    Diversion by:
fissile material or
* Non-State actors who defeat radioactive material to                safeguards procedures and weapons use                            devices, or
* The host State Program risk              Potential for facility        Functional divergence due to:
function to diverge                0 Failure of facility to enter substantially from original            service or operate as design objectives                      specified, or
                                                            " Policy or regulatory shift that alters design objectives or facility operation, or
* Changed economic and societal conditions, or
* Conventional accident or attack affecting the facility Notes:
(a) In this declaration, the general term "risk" is defined as the potential for an unplanned, undesired outcome. There are various categories of risk, including the three categories in this table.
(b) In the case of radiological risk, the events leading to unplanned exposure to radiation could be conventional accidents or attacks.
(c) The term "proliferation risk" is often used to refer to the potential for diversion of fissile material, for use in nuclear weapons. Here, the term also covers the potential for diversion of radioactive material, for use in radiological weapons.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of.SNF or HLW Page 43 of 55 Table IV-3 Potential Sabotage Events at an SNF Storage Pool, as Postulated in the NRC's August 1979 Generic EIS on Handling and Storage of Spent LWR Fuel Event Designator        General Description of Event              Additional Details Mode I                o Between    I and 1,000 fuel
* One adversary can carry 3 assemblies undergo extensive        charges, each of which can damage by high-explosive            damage 4 fuel assemblies charges detonated under water
* Damage to 1,000 assemblies
                      - Adversaries commandeer the        (i.e., by 83 adversaries) is a central control room and hold it    "worst-case bounding estimate" for approx. 0.5 hr to prevent the ventilation fans from being turned off Mode 2                ° Identical to Mode 1 except that, in addition, an adversary enters the ventilation building and removes or ruptures the HEPA filters Mode 3                  o Identical to Mode 1 within the
* Adversaries enter the central pool building except that, in      control room or ventilation addition, adversaries breach two building and turn off or disable opposite walls of the building    the ventilation fans by explosives  or other means Mode 4                  o Identical to Mode I except that, in addition, adversaries use an additional explosive charge or other means to breach the pool liner and 1.5 m-thick concrete floor of the pool Notes:
(a) Information in this table is from Appendix J of: NRC, 1979.
(b) The postulated fuel damage ruptures the cladding of each rod in an affected fuel assembly, releasing "contained gases" (gap activity) to the pool water, whereupon the released gases bubble to the water surface and enter the air volume above that surface.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, Temporary Storage of SNF or HLW Page 44 of 55 Table V-1 Future World Scenarios Identified by the Stockholm Environment Institute Scenario                                    Characteristics Conventional Worlds Market Forces              Competitive, open, and integrated global markets drive world development. Social and environmental concerns are secondary.
Policy Reform              Comprehensive and coordinated government action is initiated for poverty reduction and environmental sustainability.
Barbarization Breakdown                  Conflict and crises spiral out of control and institutions collapse.
Fortress World            This scenario features an authoritarian response to the threat of breakdown, as the world divides into a kind of global apartheid with the elite in interconnected, protected enclaves and an impoverished majority outside.
Great Transitions Eco-Communalism            This is a vision of bio-regionalism, localism, face-to-face democracy and economic autarky. While this scenario is popular among some environmental and anarchistic subcultures, it is difficult to visualize a plausible path, from the globalizing trends of today to eco-communalism, that does not pass through some form of barbarization.
New Sustainability        This scenario changes the character of global civilization Paradigm                  rather than retreating into localism. It validates global solidarity, cultural cross-fertilization and economic connectedness while seeking a liberatory, humanistic, and ecological transition.
Source: Raskin et al, 2002
 
Thompson Declaration:Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, Temporary Storage of SNF or HLW Page 45 of 55 Table VI-1 Potential Types of Attack on an SNF Storage Facility Leading to Atmospheric Release of Radioactive Material Type of Event        Facility Behavior          Some Relevant          Characteristics of Instruments and            Atmospheric Modes of Attack                Release Type 1:
* All or part of
* Facility is within
* Radioactive Vaporization or      facility is vaporized    the fireball of a        material in facility is Pulverization        or pulverized            nuclear-weapon            lofted into the explosion                atmosphere and amplifies fallout from nuc. explosion Type 2: Rupture and
* Facility structures
* Aerial bombing
* Solid pieces of Dispersal (Large)    are broken open
* Artillery, rockets,    various sizes are
* Fuel is dislodged      etc.                      scattered in vicinity from facility and
* Effects of blast etc. ° Gases and small broken apart              outside the fireball    particles form an
                      - Some ignition of        of a nuclear-weapon aerial plume that zircaloy fuel              explosion                travels downwind cladding may occur,                                  - Some release of typically without                                    volatile species (esp.
sustained                                            Cesium- 137) if zirc.
combustion                                          combustion occurs Type 3: Rupture and
* Facility structures
* Vehicle bomb
* Scattering and Dispersal (Small)    are penetrated but
* Impact by              plume formation as retain basic shape        commercial aircraft      in Type 2 event, but
* Fuel may be
* Perforation by          involving smaller damaged but most          shaped charge            amounts of material rods retain basic
* Substantial release shape                                                of volatile species if
* Damage to cooling                                  zirc. combustion systems could lead                                  occurs to zirc. combustion Type 4: Precise,
* Facility structures
* Missiles (military
* Scattering and Informed Targeting    are penetrated,            or improvised) with      plume formation as creating a release        tandem warheads          in Type 3 event pathway
* Close-up use of
* Substantial release
* Zirc. combustion        attack instruments      of volatile species, is initiated indirectly    (e.g., shaped charge,    potentially by damage to              incendiary, thermic      exceeding amount cooling systems, or        lance)                    in Type 3 release by direct ignition      I                        I        _I
 
Thompson Declaration.Recommendationsfor NRC's Consideration of Environmental Impacts ofLong-Term, Temporary Storage of SNF or HL W Page 46 of 55 Table VI-2 The Shaped Charge as a Potential Instrument of Attack Category of Information                    Selected Information in Category General information
* Shaped charges have many civilian and military applications, and have been used for decades
                            - Applications include human-carried demolition charges or warheads for anti-tank missiles
                            - Construction and use does not require assistance from a government or access to classified information Use in World War II
* The German MISTEL, designed to be carried in the nose of an un-manned bomber aircraft, is the largest known shaped charge
* Japan used a smaller version of this device, the SAKURA bomb, for kamikaze attacks against US warships A large, contemporary
* Developed by a US government laboratory for mounting device                      in the nose of a cruise missile
                            - Described in detail in an unclassified, published report (citation is voluntarily withheld here)
* Purpose is to penetrate large thicknesses of rock or concrete as the first stage of a "tandem" warhead
* Configuration is a cylinder with a diameter of 71 cm and a length of 72 cm
* When tested in November 2002, created a hole of 25 cm diameter in tuff rock to a depth of 5.9 m
* Device has a mass of 410 kg; would be within the payload capacity of many general-aviation aircraft A potential delivery
* A Beechcraft King Air 90 general-aviation aircraft can vehicle                      carry a payload of up to 990 kg at a speed of up to 460 km/hr
* The price of a used, operational King Air 90 in the USA can be as low as $0.4 million Source:
This table is adapted from Table 7-6 of: Thompson, 2009.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 47 of 55 Table VI-3 Performance of US Army Shaped Charges, M3 and M2A3 Target                  Indicator                        Value for Stated Material                                              Type of Sha ped Charge Type: M3          Type: M2A3 Reinforced        Maximum wall thickness        150 cm                90 cm concrete          that can be perforated Depth of penetration in        150 cm              75 cm thick walls Diameter of hole
* 13 cm at entrance
* 9 cm at entrance
* 5 cm minimum
* 5 cm minimum Depth of hole with second      210 cm              110 cm charge placed over first hole Armor plate        Perforation                    At least 50 cm      30 cm I Average diameter of hole      6 cm                4 cm Notes:
(a) Data are from US Army Field Manual FM 5-25: Army, 1967, pp 13-15 and page 100.
(b) The M2A3 charge has a mass of 5 kg, a maximum diameter of 18 cm, and a total length of 38 cm including the standoff ring.
(c) The M3 charge has a mass of 14 kg, a maximum diameter of 23 cm, a charge length of 39 cm, and a standoff pedestal 38 cm long.
 
Thompson Declaration: Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 48 of 55 Table VII-1 Estimated Duration of Phases of Implementation of the Yucca Mountain Repository Phase of Repository                          Duration of Phase (years)
Implementation                  If Yucca Mountain If Yucca Mountain total inventory of    total inventory of commercial spent      commercial spent fuel = 63,000          fuel = 105,000 MTHM                    MTHM Construction phase                                        5                    5 Operation and          Development                      22                    36 monitoring phases      Emplacement                    24-50                  38-51 Monitoring                    76-300                62-300 Closure phase                                          10-17                  12-23 Notes:
(a) These estimates are from: DOE, 2002, Volume I, pages 8-8 and 2-18.
(b) The Development and Emplacement phases would begin on the same date. Other phases would be sequential.
(c) The Construction phase would begin with issuance of construction authorization, and end with issuance of a license to receive and dispose of radioactive waste.
 
Thompson Declaration.Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, TemporaryStorage of SNF or HL W Page 49 of 55 Table IX-1 Selected Approaches to Protecting Critical Infrastructure in the USA From Attack by Non-State Actors, and Some Strengths and Weaknesses of these Approaches Approach                      Strengths                      Weaknesses Approach #1: Offensive
* Could deter or prevent
* Could promote growth of military operations          governments from                non-State groups hostile to internationally              supporting non-State actors      the USA., and build hostile to the USA              sympathy for these groups in foreign populations
                                                              - Could be costly in terms of lives, money, etc.
Approach #2: International
* Could identify and
* Implementation could be police cooperation within a  intercept potential attackers    slow and/or incomplete legal framework
* Requires ongoing international cooperation Approach #3: Surveillance
* Could identify and
* Could destroy civil and control of the domestic  intercept potential attackers    liberties, leading to population                                                    political, social, and economic decline of the USA Approach #4: Secrecy about
* Could prevent attackers
* Could suppress a true design and operation of      from identifying points of      understanding of risk infrastructure facilities    vulnerability
* Could contribute to political, social, and economic decline Approach #5: Active
* Could stop attackers          - Requires ongoing defense of infrastructure    before they reach the target    expenditure & vigilance facilities (by use of guards,
* May require military guns, gates, etc.)                                              involvement Approach #6: Robust and
* Could allow target to
* Could involve higher inherently-safer design of    survive attack without            capital costs infrastructure facilities      damage, thus contributing to protective deterrence (Note: This approach could    - Could substitute for other be part of a "protective      protective approaches, deterrence" strategy for the  avoiding their costs and USA.)                          adverse impacts
* Could reduce risks from accidents & natural hazards Notes:
(a) These approaches could be used in parallel, with differing weightings.
(b) Approach #6 would contribute to "protective deterrence", which is distinct from "counter-attack deterrence".
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 50 of 55 Figure VI-1 Schematic View of a Generic Shaped-Charge Warhead i
I Notes:
(a) Figure accessed on 4 March 2012 from: http://en.wikipedia.orgiwiki/Shapcd chargc (b) Key:
Item 1: Aerodynamic cover Item 2: Empty cavity Item 3: Conical liner (typically made of ductile metal)
Item 4: Detonator Item 5: Explosive Item 6: Piezo-electric trigger (c) Upon detonation, a portion of the conical liner would be formed into a high-velocity jet directed toward the target. The remainder of the liner would form a slower-moving slug of material.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 51 of 55 Figure VI-2 MISTEL System for Aircraft Delivery of a Shaped Charge, World War II Notes:
(a) Photograph accessed on 5 March 2012 from:
http://www.historyofwar.or,/Pictures/pictures Ju 88 mistel.html (b) A shaped-charge warhead can be seen at the nose of the lower (converted bomber) aircraft, replacing the cockpit. The aerodynamic cover in front of the warhead would have a contact fuse at its tip, to detonate the shaped charge at the appropriate standoff distance.
(c) A human pilot in the upper (fighter) aircraft would control the entire rig, and would point it toward the target. Then, the upper aircraft would separate and move away, and the lower aircraft would be guided to the target by an autopilot.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 52 of 55 Figure VI-3 January 2008 Test of a Raytheon Shaped Charge, Intended as the Penetration (Precursor) Stage of a Tandem Warhead System Before Test Notes:
(a) These photographs are from: Raytheon, 2008. For additional, supporting information, see: Warwick, 2008.
(b) The shaped-charge jet penetrated about 5.9 m into a steel-reinforced concrete block with a thickness of 6.1 m. Although penetration was incomplete, the block was largely destroyed, as shown. Compressive strength of the concrete was 870 bar.
(c) The shaped charge had a diameter of 61 cm and contained 230 kg of high explosive.
It was sized to fit inside the US Air Force's AGM-129 Advanced Cruise Missile.
 
Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 53 of 55 Figure Vl-4 Aftermath of a Small-Aircraft Suicide Attack on an Office Building in Austin, Texas, February 2010 Notes:
(a) Photograph and information in these notes are from: Brick, 2010.
(b) A major tenant of the building was the Internal Revenue Service (IRS).
(c) The aircraft was a single-engine, fixed-wing Piper flown by its owner, Andrew Joseph Stack III, an Austin resident who worked as a computer engineer.
(d) A statement left by Mr Stack indicated that a dispute with the IRS had brought him to a point of suicidal rage.
 
                                                                              .0 Thompson Declaration:Recommendationsfor NRC's Consideration of EnvironmentalImpacts of Long-Term, Temporary Storage of SNF or HL W Page 54 of 55 Figure VIII-1 Unit 4 at the Fukushima #1 Site During the 2011 Accident Source:
Accessed on 20 February 2012 from Ria Novosti at:
http://en.rian.ru/analysis/20110426/163701909.html; image by Reuters Air Photo Service.
 
V Thompson Declaration:Recommendationsfor NRC's Consideration of Environmental Impacts of Long-Term, Temporary Storage of SNF or HLW Page 55 of 55 Figure V111-2 Outcome of Test Burn of a BWR Fuel Assembly Notes:
(a) This figure is from: Weber, 2011.
(b) The figure shows the outcome of a test to investigate the burning of SNF. An inactive 9x9 BWR fuel assembly with zircaloy-2 cladding was burned in air. The assembly was at reactor scale although not all rods were full length. The assembly was electrically heated (via 74 electric heater rods) at a rate of 5 kW.
(c) The fuel assembly was surrounded by thermal insulation - the white material in the photograph.
(d) This test did not attempt to simulate the release of Cesium or other materials from the damaged fuel.
 
INSTITUTE FOR RESOURCE AND SECURITY STUDIES 27 Ellsworth Avenue, Cambridge, Massachusetts 02139, USA Declaration of 1 August 2013 by Gordon R. Thompson:
Comments on the US Nuclear Regulatory Commission's Draft Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a US Mark I Boiling Water Reactor I, Gordon R. Thompson, declare as follows:
I. Introduction (I-1) I am the executive director of the Institute for Resource and Security Studies (IRSS), a nonprofit, tax-exempt corporation based in Massachusetts. Our office is located at 27 Ellsworth Avenue, Cambridge, MA 02139. IRSS was founded in 1984 to conduct technical and policy analysis and public education, with the objective of promoting peace and international security, efficient use of natural resources, and protection of the environment.
My professional qualifications are discussed in Section II, below.
(1-2) I have been retained by a group of environmental organizations to assist in the preparation of comments invited by the US Nuclear Regulatory Commission (NRC).'
Specifically, NRC has invited comments on a draft technical study, dated June 2013, that NRC staff has prepared.2 The draft study is titled "Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a US Mark I Boiling Water Reactor".3 Hereafter, in this declaration, I refer to that study as "NRC's Draft Consequence Study" or "the Study".
(1-3) On 2 January 2013, I completed a declaration that set forth recommendations for NRC's consideration of environmental impacts of long-term, temporary storage
'These organizations include: Beyond Nuclear, Blue Ridge Environmental Defense League, Center for a Sustainable Coast, Citizens Allied for Safe Energy, Don't Waste Michigan, Ecology Party of Florida, Friends of the Coast, Friends of the Earth, Georgia Women's Action for New Directions, Green States Solutions, Hudson River Sloop Clearwater, Missouri Coalition for the Environment, NC WARN, Nevada Nuclear Waste Task Force, New England Coalition, No Nukes Pennsylvania, Nuclear Energy Information Service, Nuclear Information and Resource Service, Nuclear Watch South, Physicians for Social Responsibility, Public Citizen, Riverkeeper, SEED Coalition, San Luis Obispo Mothers for Peace, Sierra Club Nuclear Free Campaign, and Southern Alliance for Clean Energy.
2 FederalRegister, Volume 78, Number 127, Tuesday 2 July 2013, pp 39781-39782.
3 Barto et al, 2013.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 2 of 44 of spent nuclear fuel (SNF) or related high-level waste (HLW).4 Those recommendations would apply to NRC's Waste Confidence Generic Environmental Impact Statement (GEIS), which has been issued as a preliminary draft report for comment dated August 2013.5 Some issues addressed in my 2 January 2013 declaration are relevant to NRC's Draft Consequence Study. Accordingly, I incorporate here by reference the findings and recommendations in my 2 January 2013 declaration.
(1-4) Here, I comment on selected aspects of NRC's Draft Consequence Study. The scope of my comments is constrained by time and budget limitations. Absence of discussion of an issue in this declaration does not imply that I view the issue as insignificant, or that I have no professional opinion on the manner in which the issue has been addressed in NRC's Draft Consequence Study. Although I comment only on selected aspects of the Study, these aspects have comparatively high significance for public health and safety. Moreover, my review of the Study is sufficient to support the findings presented here.
(1-5) NRC's Draft Consequence Study examines, among other matters, the potential for self-sustaining, exothermic oxidation reaction of fuel cladding in a spent-fuel pool if water is lost from the pool. For simplicity, that event can be referred to as a "pool fire".
(1-6) A pool fire is a potential event at every nuclear power plant in the USA. That is so because the spent-fuel pools at all plants are equipped with high-density, closed-frame racks. The nuclear industry began installing these racks in the 1970s, to replace the low-density, open-frame racks previously used. The high-density racks offered a comparatively cheap option for storing a growing inventory of spent fuel.
(1-7) This declaration has the following narrative sections:
I.      Introduction II.      My Professional Qualifications III. A Brief History of Pool-Fire Analysis IV.      What Pool-Fire Analysis Should NRC Have Published Now?
V.      NRC's Draft Consequence Study: Structure, Apparent Scope, and Messages VI.      NRC's Draft Consequence Study: Actual Scope, and Credibility VII. NRC's Use of the MELCOR Code VIII. Conclusions and Recommendations (1-8) In addition to the above-named narrative sections, this declaration has two appendices that are an integral part of the declaration. Appendix A contains tables and figures that support the narrative. Appendix B is a bibliography. Documents cited in the narrative or in Appendix A are listed in that bibliography unless otherwise identified.
4 Thompson,  2013.
'NRC, 2013.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 3 of 44 II. My Professional Qualifications (II-1) As stated in paragraph I-1, above, I am the executive director of the Institute for Resource and Security Studies. In addition, I am a senior research scientist at the George Perkins Marsh Institute, Clark University.
(11-2) I received an undergraduate education in science and mechanical engineering at the University of New South Wales, in Australia, and practiced engineering in Australia in the electricity sector. Subsequently, I pursued graduate studies at Oxford University and received from that institution a Doctorate of Philosophy in mathematics in 1973, for analyses of plasma undergoing thermonuclear fusion. During my graduate studies I was associated with the fusion research program of the UK Atomic Energy Authority. My undergraduate and graduate work provided me with a rigorous education in the methodologies and disciplines of science, mathematics, and engineering.
(11-3) My professional work involves technical and policy analysis in the fields of energy, environment, sustainable development, human security, and international security. Since 1977, a significant part of my work has consisted of analyses of the radiological risk posed by commercial and military nuclear facilities. These analyses have been sponsored by a variety of non-governmental organizations and local, state and national governments, predominantly in North America and Western Europe. Drawing upon these analyses, I have provided expert testimony in legal and regulatory proceedings, and have served on committees advising US government agencies.
(11-4) To a significant degree, my work has been accepted or adopted by relevant governmental agencies. During the period 1978-1979, for example, I served on an international review group commissioned by the government of Lower Saxony (a state in Germany) to evaluate a proposal for a nuclear fuel cycle center at Gorleben. I led the subgroup 6      that examined radiological risk and identified alternative options with lower risk. One of the risk issues that I personally identified and analyzed was the potential for self-sustaining, exothermic oxidation reaction of fuel cladding in a high-density SNF pool if water is lost from the pool. That event is referred to here as a pool fire. In examining the potential for a pool fire, I identified partial loss of water as a more severe condition than total loss of water. I identified a variety of events that could cause loss of water from a pool, including aircraft crash, sabotage, neglect, and acts of war. Also, I identified and described alternative SNF storage options with lower risk; these lower-risk options included design features such as spatial separation, natural cooling, and underground vaults. The Lower Saxony government accepted my findings about the risk of a pool fire, and ruled in May 1979 that high-density pool storage of SNF was not an acceptable option at Gorleben.7 As a direct result, policy throughout Germany has been to use dry storage in casks, rather than high-density pool storage, for away-from-reactor storage of SNF.
6 Beyea et al, 1979.
7 Albrecht, 1979.
 
Thompson Declaration: Comments on NRC's Draft Consequence Study Page 4 of 44 (11-5) Since 1979, I have been based in the USA. During the subsequent years, I have been involved in a number of NRC regulatory proceedings related to the radiological risk posed by stora ge of SNF. In that context I have prepared a number of declarations and expert reports. Also, I co-authored a journal article, on SNF radiological risk, that received considerable attention from relevant stakeholders. 9 The findings in that article were generally confirmed by a subsequent report by the National Research Council." As a result of my cumulative experience, I am generally familiar with: (i) US practices for managing SNF; (ii) the radiological risk posed by those practices; (iii) NRC regulation of that risk; and (iv) alternative options for reducing that risk. Also, I am familiar with the US effort since the 1950s to implement final disposal of SNF and HLW, and have written a review article on that subject.II (11-6) I have performed a number of studies on the potential for commercial or military nuclear facilities to be attacked directly or to experience indirect effects of violent conflict. A substantial part of that work relates to the radiological risk posed by storage of SNF or HLW. For example, in 2005 1 was commissioned by the UK government's Committee on Radioactive Waste Management (CORWM) to prepare a report on reasonably foreseeable security threats to options for long-term management of UK radioactive waste. 12 III. A Brief History of Pool-Fire Analysis (111-1) Any review of the merit of NRC's Draft Consequence Study should be informed by the history of analysis regarding the potential for a pool fire. Here, I provide a brief history from March 1979 through May 2013 (i.e., just prior to publication of NRC's Draft Consequence Study in June 2013). This history does not purport to be exhaustive.
Instead, it addresses some important highlights.
(111-2) Two studies completed in March 1979 independently identified the potential for a pool fire. One study was by members of an international review group commissioned by the government of Lower Saxony, as discussed in paragraph 11-4, above. That study was done under time and budget constraints, so it used simple, scoping analysis to address pool-fire phenomena. The second study was done by Sandia Laboratories for NRC.13 In light of knowledge that has accumulated since 1979, the Sandia report generally stands up well, provided that one reads the report in its entirety. However, the report's introduction contains an erroneous statement that complete drainage of the pool would be the most severe mode of water loss.'4 The body of the report clearly shows that partial loss of water could be a more severe case, as was recognized in the Lower Saxony study.
8  See, for example: Thompson, 2009.
9 Alvarez et al, 2003.
10 National Research Council, 2006.
" Thompson, 2008.
12 Thompson, 2005.
13 Benjamin et al, 1979.
14 Benjamin et al, 1979, page 11.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 5 of 44 (111-3) The 1979 Sandia report explicitly recognized a point that was obvious then and has remained so. The point is that the pool-fire issue became salient when the nuclear industry abandoned the use of low-density, open-frame storage racks and switched to high-density, closed-frame racks. The nuclear industry made this switch, beginning in the 1970s, because high-density racks offered a comparatively cheap option for storing a growing inventory of spent fuel. Figure 111-1 shows a low-density, open-frame rack for pressurized-water-reactor (PWR) fuel. If water were lost from a pool equipped with such racks, fuel would be readily cooled by three-dimensional, natural convective circulation of air and steam. Human intervention would not be required. Contemporaneous racks used for boiling-water-reactor (BWR) fuel were not as fully open to three-dimensional convective circulation of air and steam, in the event of water loss, as would be the rack shown in Figure III-I. However, a BWR rack could be constructed with a configuration similar to that in Figure 111-1. If necessary, channel boxes could be removed from BWR fuel assemblies before their placement in that rack, as discussed in the following paragraph.
(111-4) If low-density, open-frame racks were used, water loss from a pool would lead to fuel ignition only in very rare circumstances. These circumstances might include deformation and coverage of racks by a falling object, and/or the presence in the pool of fuel assemblies from a reactor shut down a short time previously. A thorough investigation of pool-fire risk would identify and characterize such circumstances. Also, such an investigation would determine the potential for ignition and fire propagation for cases in which channel boxes were, or were not, removed from BWR fuel. Convective circulation of air and steam, in the event of water loss, would be enhanced if the channel boxes had been removed. Overall, it is clear that re-equipping the present high-density pools with low-density, open-frame racks would dramatically reduce the risk of a pool fire. In the case of BWR fuel, removal of channel boxes might be an appropriate adjunct step.
(111-5) By the latter part of 1979, at least six points about potential pool fires were clear to any technically-competent person who was paying attention to this issue. First, loss of water from a pool with high-density racks could lead to exothermic air-zircaloy or steam-zircaloy reactions under some conditions. Second, the intensity of exothermic reactions could lead to propagation of ignition to some fuel assemblies that had not initially ignited. Third, a water-loss case involving the presence of residual water would be a more severe case than one involving total drainage, other factors being equal, because the residual water would inhibit convective heat transfer. Fourth, a pool-fire scenario would develop more slowly than a reactor core melt, because the output of decay heat would be smaller in the pool situation. Fifth, the fire threat could be dramatically reduced by reverting to low-density, open-frame racks. Sixth, the fire threat can be roughly characterized using simple, scoping analysis, but developing a thorough understanding would require sophisticated modeling backed up by experiment.
(111-6) Given these six points, one can easily identify a water-loss scenario that represents a test of the credibility of an analysis of pool-fire risk. Any such analysis fails
 
0 -
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 6 of 44 if it does not characterize this scenario. This scenario is not necessarily the "worst" case of water loss from a pool. It does, however, capture the role of residual water in the pool.
I refer to it here as the "Severe Reference" scenario of water loss. In the basic version of this scenario, water level would fall rapidly (i.e., within a few minutes) to about mid-height of the fuel. Variants of the scenario would explore the implications of different timing and magnitude for the initial fall of water level, and different outputs of decay heat.15 After the initial fall of water level, water loss would be evaporative, driven by decay heat. There would be no water makeup. The exposed portion of the fuel would gradually increase in temperature. Eventually, a zircaloy-steam reaction could begin in this portion, commencing first in fuel assemblies with the highest decay heat. The availability of steam would initially limit the rate of this reaction. The fire could propagate across the pool. Over time, fuel and rack degradation, and evaporation of residual water, would alter the fire characteristics. Outcomes could include the initiation of a zircaloy-air reaction.
(111-7) A thorough and comprehensive investigation of pool-fire risk would begin by characterizing the Severe Reference scenario, its variants, and a range of other water-loss scenarios, in terms of phenomena related to zircaloy ignition, fire dynamics, and radioactive release. Then, and only then, would the investigators be ready to move to the next analytic step. That step would be to identify and characterize a full range of event sequences that involve water loss and could lead to a pool fire. The need to work in this manner - completing phenomenological analysis before proceeding to event analysis -
has been clear to any technically-competent pool-fire analyst since 1979. I address this matter further in Section IV, below.
(111-8) A credible analysis of event sequences would certainly consider earthquake as a potential initiating event. However, other pool-fire initiating events, including accidents and attacks, would receive at least equal attention. Notably, a credible analysis would thoroughly examine potential situations in which a reactor adjacent to a spent-fuel pool experiences core melt and a substantial release of radioactive material. The onsite impacts of that release and associated phenomena (e.g., hydrogen explosion) could preclude actions, such as water makeup, that could prevent a pool fire.
(111-9) The physical proximity of spent-fuel pools to operating reactors, and their sharing of safety systems, means that the use of high-density racks creates strong linkages between reactor risk and pool risk. A reactor core melt - a comparatively fast-developing event - could enable a pool fire - a slower-developing event. This coupling could be manifested through an accident or an attack. The potential for pool-reactor linkages has, since 1979, been clear to any technically-competent person who was paying attention to the pool-fire issue. The Severe Reference scenario for water loss, as articulated in paragraph 111-6, above, is particularly pertinent to these linkages.
ISSome variants would include a zero magnitude for the initial fall of water level (i.e., water would be lost only by evaporation).
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 7 of 44 (III-10) NRC has publicly postulated an attack on a spent-fuel pool, in its August 1979 GEIS on Handling and Storage of Spent LWR Fuel.' 6 Table III-1 summarizes the nature of the postulated attack. NRC did not examine the potential for this attack to cause a pool fire. However, the adversary capabilities and other assumptions reflected in Table III-1 would be consistent with an attack that causes a linked core melt and pool fire as outlined in paragraph 111-9, above. NRC is currently reluctant to discuss the threat of attack on a pool and/or reactor, but has not repudiated its discussion of attack in the August 1979 GEIS.
(III-11) After receiving the 1979 Sandia report described in paragraph 111-3, NRC conducted and sponsored a number of studies related to pool-fire risk, which were published over a period of two decades. Unfortunately, those studies employed the erroneous assumption that complete drainage is the most severe case of water loss, until NRC indirectly corrected this error in October 2000. Thus, for two decades NRC personnel failed to acknowledge the effect of residual water on heat transfer, which is the third of six points I articulate in paragraph 111-5, above. The studies also had other deficiencies. I provided a critical review of the various NRC studies in a February 2009 report. 17 In short, those studies did not provide a credible technical basis for assessing the risk of a pool fire.
(111-12) NRC's belated acknowledgment of the effect of residual water on heat transfer came indirectly. It came in the context of determining the maximum age of spent fuel at which the fuel could ignite if water were lost from a pool equipped with high-density racks. 8 If residual water were present, heat transfer from the exposed portion of the fuel would be comparatively feeble.' 9 Thus, in the absence of sophisticated modeling of heat transfer, a prudent analyst would assume that the exposed portion of the fuel would be in an approximately adiabatic situation. It follows that comparatively old fuel - perhaps as old as 10 years - could ignite. This issue arose during a license-amendment proceeding in regard to the expansion of spent-fuel-pool capacity at the Harris nuclear power plant. I served as a technical adviser for Orange County, North Carolina, the intervenor in that proceeding. In filings during March and April 2000, the NRC staff repeatedly disparaged my statements that comparatively old fuel could ignite. A few months later, however, the staff adopted my position. NRC staff members stated that loss of water from pools containing fuel aged less than 5 years "would almost certainly result in an exothermic reaction", and also stated: "Precisely how old the fuel has to be to prevent a fire is still not resolved." 20 Moreover, the staff assumed that a fire would be inevitable if the water level fell to the top of the racks.
(111-13) In October 2000, NRC released a study, which was formally published in February 2001, that addressed the potential for a pool fire at a nuclear power plant 1
6 NRC,  1979.
17  Thompson, 2009.
  '8  Here, "age" refers to time since the fuel experienced fission.
  '9Colleagues and I have addressed this heat-transfer situation in various documents. See, for example:
Alvarez et al, 2003.
20 Parry et al, 2000, paragraph 29.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 8 of 44 undergoing decommissioning. 2 1 The study -NUREG-1738 - was in some respects an improvement on previous NRC studies that addressed pool fires. It reversed NRC's longstanding, erroneous position that total drainage of a pool is the most severe case of water loss. However, it did not consider attack. Nor did it add significantly to the weak base of technical knowledge regarding the propagation of a fire from one fuel assembly to another. Its focus was on a plant undergoing decommissioning. Therefore, it did not address potential risk linkages between pools and operating reactors, as mentioned in paragraphs 111-8 and 111-9, above.
(111-14) The preceding two paragraphs show that, in October 2000, NRC suddenly reversed an erroneous technical position it had held for two decades. The context in which this reversal occurred is significant today. I return to this matter in paragraphs III-23 and 111-24, below.
(111-15) After publishing NUREG- 1738, NRC ceased publishing analysis on pool-fire risk, but claims to have done some secret studies. The US Government Accountability Office (GAO) confirms that NRC has, indeed, done some secret studies on pool fires.
However, according to GAO, the NRC has lost track of those studies. An August 2012 GAO report stated:2 "Because a decision on a permanent means of disposing of spent fuel may not be made for years, NRC officials and others may need to make interim decisions, which could be informed by past studies on stored spent fuel. In response to GAO requests, however, NRC could not easily identify, locate, or access studies it had conducted or commissioned because it does not have an agencywide mechanism to ensure that it can identify and locate such classified studies."
(111-16) I identified a similar problem in a February 2009 report that I mention in paragraph 111-11, above. In that report, I examined statements, in two official NRC documents published in 2008, regarding secret studies allegedly conducted or sponsored            23 by NRC in order to improve technical understanding of pool fires. I concluded:
          "To summarize, the Draft Update, issued in October 2008, mentions one set of secret studies, while the rulemaking petition decision, issued in August 2008, mentions a different set of secret studies. This inconsistency represents, at a minimum, carelessness and a lack of respect for the public."
(111-17) Since 1979, NRC has consistently and unequivocally argued, in many contexts and with somewhat varying language,    24    that high-density storage of spent fuel in pools afeth protects public health and safety. Yet, after the attacks of 11 September 2001 on New York and Washington, NRC placed its work on pool-fire risk behind a veil of secrecy.
21 Collins and Hubbard, 2001.
22 GAO, 2012, Highlights.
23 Thompson, 2009, Section 5.2, pp 24-25.
24 For example, NRC's Draft Consequence Study says (Barto et al, 2013, page iv): "The NRC continues to believe, based on this study and previous studies that spent fuel pools protect public health and safety."
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 9 of 44 The lengths to which NRC would go to preserve this secrecy were evident from its confrontation with the National Academy of Sciences (NAS).
(111-18) In 2003, eight authors, of which I was one, published a paper on the radiological risk of pool fires and the options for reducing this risk. 25 That paper aroused vigorous comment, and its findings were disputed by NRC officials and others. Critical comment was also directed to a related report I had prepared.26 In an effort to resolve this controversy, the US Congress requested NAS to conduct a study on the safety and security of spent-fuel storage. NAS submitted a classified report to Congress in July 2004, and released an unclassified version in April 2005.27 Press reports described considerable tension between NAS and NRC regarding the inclusion of material in the unclassified NAS report.28 NRC was the party demanding greater secrecy.
(111-19) NRC has never explained how its ongoing statement that high-density pools protect public health and safety could be reconciled with its vigorous efforts to hide pool-fire risk behind a veil of secrecy. An adequate explanation is hard to imagine. If the pools truly posed an insignificant risk, then spent fuel in the pools would not ignite in the event of water loss, regardless of how that water loss proceeded or what was its cause. In that case, there would be no need for secrecy.
(111-20) Assessing the radiological risk posed by a reactor or spent-fuel pool involves science that was at the cutting edge a comparatively long time ago - mostly in the first half of the 2 0 th century or earlier. Nevertheless, a risk assessment must conform to scientific principles if it is to be credible. Those principles include transparency, accountability, openness, support for independent teams of investigators who can critique each other's work, peer review, and opportunities for open dialogue among investigators.
(111-2 1) In theory, NRC has processes available to it that would allow some of the principles of scientific discourse to be applied to radiological risk assessment. One such process is an evidentiary hearing. Although that process is more legalistic than a scientist would prefer, it does allow for the public cross-examination of expert witnesses under oath. That cross-examination can help to elucidate the scientific reality underlying a contentious issue.
(111-22) Since the 1980s, I have been a technical adviser to various entities - state and local governments, and citizen groups - that have sought to intervene before NRC regarding pool-fire risk. These entities have repeatedly requested the holding of an evidentiary hearing, in the full knowledge that their own expert witnesses would be subjected to rigorous, public cross-examination. NRC has consistently denied these requests, on legalistic grounds.
25 Alvarez et al, 2003.
26 Thompson, 2003.
27 The unclassified version was ultimately published as: National Research Council, 2006.
28 Wald, 2005.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 10 of 44 (111-23) Over this period of three decades, I have had one opportunity to present my findings on pool-fire risk at an NRC-sponsored event that approximated the characteristics of a scientific dialogue. That opportunity came when I asked NRC's Advisory Committee on Reactor Safeguards (ACRS) if I could present my findings to them. ACRS agreed, and I presented my findings at two public meetings of ACRS in the latter part of 2000. A remarkable feature of the first meeting was that NRC staff members who made presentations at the meeting suddenly reversed NRC's longstanding, erroneous position that total loss of water from a pool would be the most serious case of water loss. That reversal then made its way into the NRC staff position in the Harris license proceeding, and into NRC's report NUREG-1738, as discussed in paragraphs III-12 and III-13, above.
(111-24) This interaction before ACRS, unique in my experience with NRC, clearly demonstrated the efficacy of scientific discourse. NRC staff members, required for the first time in decades to justify their technical position in a public setting where they could be challenged, suddenly changed that position. Regrettably, however, NRC never repudiated the bad analysis it had done over the preceding two decades, based on its misunderstanding of the 1979 Sandia report. Also, from my observation, NRC has subsequently been careful to avoid placing itself in a similar public setting in which it could be challenged.
(111-25) As stated in paragraph 111-5, above, it was clear in 1979 that the threat of a pool fire can be roughly characterized using simple, scoping analysis, but developing a thorough understanding would require sophisticated modeling backed up by experiment.
When did NRC acquire the capability to perform such modeling and experiment? A reasonable case can be made that NRC had acquired an appropriate capability by the time of its work on reactor risk that led to publication of the NUREG- 1150 study in 1990.29 Regrettably, however, the NUREG- 1150 work did not address pool fires.
(111-26) The history described in paragraphs 111-1 through 111-25 began in March 1979 and ended just prior to publication of NRC's Draft Consequence Study in June 2013. To summarize, at the end of that period NRC's technical credibility on the pool-fire issue was low. NRC had done demonstrably bad analysis that it never repudiated. NRC had claimed that high-density pool storage protects public health and safety while simultaneously demonstrating the falsity of that claim by hiding pool-fire risk behind a veil of secrecy since 2001. NRC had avoided scientific settings in which its technical position could be publicly challenged. When obliged by ACRS to appear in such a setting in 2000, NRC suddenly changed its position. NRC failed to conduct sophisticated modeling and supporting experiments that could have resolved technical issues central to pool-fire risk, despite having an appropriate capability prior to 1990.
29 NRC, 1990.
 
Thompson Declaration: Comments on NRC's Draft Consequence Study Page 11 of 44 IV. What Pool-Fire Analysis Should NRC Have Published Now?
(IV-1) As summarized in paragraph 111-26, above, in May 20i 3 NRC's technical credibility on the pool-fire issue was low. If NRC had made a serious commitment to begin restoring its credibility, and to provide the public with useful information about pool-fire risk, what technical analysis would NRC have published in June 2013? This question assumes, of course, that NRC would have made its commitment well in advance of June 2013 and would have done the appropriate work before that date.
(IV-2) The answer to the question in paragraph IV-1 is that NRC should have focused its initial attention exclusively on establishing a solid technical understanding of phenomena directly related to a potential pool fire. To do this, NRC would have started with a clean slate and used the best available modeling capability backed up by experiment. This modeling and experimental work would have been done according to scientific principles that I discuss further in paragraph IV-3, below. Tasks in the investigation would have included:
: 1. Identify a range of rack and pool configurations: The key point here would be to compare a pool with high-density racks to a pool with open-frame, low-density racks. (See paragraph 111-3, above.)
: 2. Identify a range of rack loadings: In the high-density cases, the range of rack loadings would include different phases of the reactor operating cycle, and different distributions of younger and older spent fuel across the pool. In the low-density, open-frame cases, the range of rack loadings would include removal of fuel from the pool if above a certain age, such as five years.
: 3. Identify a range of water-loss scenarios: Mechanisms for water loss could include various combinations of: leakage; evaporation; sloshing; displacement; siphoning; pumping; and tipping of the pool. To reflect the various combinations and their timeframes, the investigation would identify a range of water-loss scenarios.
These scenarios would include, but would not be limited to, situations in which leakage occurred through a hole at the level of the pool floor. The scenarios would include the Severe Reference scenario, and its variants, as discussed in paragraph 111-6, above.
: 4. Identify collateral conditions that could affect fuel ignition or fire dynamics: The potential for fuel ignition, in the event of water loss, could be affected by collateral conditions. Those conditions could also affect the development and propagation of a fire. Relevant conditions could include: the presence of extraneous objects in the pool (e.g., transfer cask, fuel-handling machinery, overhead crane, debris from the upper portion of the pool building); the ventilation status of the pool building; and deformation of racks.
: 5. Determine combinations of conditions that would lead to fuel ignition: Tasks I through 4, above, would identify ranges of rack/pool configurations, rack loadings, water-loss scenarios, and collateral conditions. The various combinations of conditions could be grouped where appropriate. Then, each
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 12 of 44 combination would be examined to determine if, and with what timing, it would lead to fuel ignition.
: 6. Predict fire behavior: For each instance where Task 5 determined that ignition would occur, the development and propagation of the resulting fire would be predicted. Relevant fire characteristics would include the production of hydrogen and its behavior in the pool building.
: 7. Estimate the atmospheric release: For each fire sequence examined in Task 6, the resulting release of radioactive material to the external atmosphere would be estimated in terms of isotopic magnitudes, timing, and other relevant characteristics.
(IV-3) If NRC were truly committed to restoring its credibility and providing useful information, it would have performed Tasks I through 6 according to generally accepted scientific principles. As discussed in paragraph 111-20, above, those principles include transparency, accountability, openness, support for independent teams of investigators who can critique each other's work, peer review, and opportunities for open dialogue among investigators. To satisfy those principles, NRC would have funded independent investigators and made its models available to them for their own use. NRC would have financed independently-run workshops where NRC investigators and independent investigators could engage in open, scientific discourse. NRC would have provided full documentation of all supporting experiments.
(IV-4) Further to paragraph IV-3, NRC would have performed Tasks 1 through 6 with explicit treatment of uncertainties. Also, NRC would have done sensitivity analyses to test the implications of changing modeling assumptions or input conditions. At this stage of risk assessment, however, modeling of mitigating actions would have been premature.
(IV-5) Completing Tasks I through 6, consistent with paragraphs IV-3 and IV-4, would have involved the publication of a number of documents, including NRC analyses, independent analyses, peer reviews, and responses to those reviews. The issues addressed would be purely technical, pertaining to Tasks 1 through 6 as described above.
When all issues had been resolved to a reasonable scientific standard, a summary document would be published. Then, and only then, would NRC have been ready to move to the next analytic step.
(IV-6) The next analytic step would have been to identify and characterize a full range of event sequences that could lead to the combinations of conditions that would, according to the analysis done in Tasks I through 6, be associated with a significant radioactive release. Hereafter, for simplicity, I refer to this step as "event analysis". If assessment of pool-fire risk is to be done properly, it is essential that event analysis be preceded by acquisition of a thorough understanding of pool-fire phenomena. Otherwise, analysts would lack essential knowledge about how particular combinations of conditions could affect fuel ignition and fire dynamics. In the absence of such knowledge, it is likely that analysts would ignore or misunderstand some event sequences that are significant to pool-fire risk.
 
Thompson Declaration: Comments on NRC's Draft Consequence Study Page 13 of44 (IV-7) The event sequences addressed in a properly-executed event analysis would include a range of potential accidents and attacks. Earthquake would certainly be considered as a possible initiating event, but other types of credible initiating event would receive at least equal attention. Careful attention would be given to potential risk linkages between reactors and pools, as discussed in paragraphs 111-8 and 111-9, above. In this context, the 2011 Fukushima accident was a wake-up call. Figure IV-1 illustrates two aspects of such linkages. First, the Unit 4 building at Fukushima was badly damaged by explosion of hydrogen that has been attributed to core damage in Unit 3. Second, a concrete-pumping truck was, at the time of this photograph, providing makeup water to the Unit 4 pool, reminding us of several days of futile attempts, earlier in the accident, to provide makeup water to Units 1 through 4 by other means.
(IV-8) Fortunately, the Fukushima accident did not proceed to a pool fire. However, any competent analyst who thinks about the Fukushima accident could readily identify a range of event sequences in which a core melt would be linked to a pool fire. Such an event sequence need not involve an earthquake or tsunami. The key point is that the event sequence would involve a timeframe such that a portion of the fuel in the pool would be above water, in a situation involving limited heat transfer, for a period long enough that the youngest fuel would heat up to its ignition temperature. The Severe Reference scenario for water loss, as articulated in paragraph 111-6, above, addresses this point.
(IV-9) This declaration is intended for general distribution. Accordingly, it does not contain any information that would assist persons who could plausibly attack a US nuclear power plant. A large body of information of this type is already in the public domain. Moreover, many persons in the USA and worldwide have already acquired, through military experience or otherwise, the knowledge and practical skills that would be needed to mount a plausible attack. At any given time, some persons in that group may have motivation and resources sufficient to mount an attack with a substantial conditional probability of causing a reactor core melt and/or pool fire. The feasibility of such an attack is illustrated by the publicly-available information presented in Tables IV-1 through IV-3 and Figures IV-2 through IV-5. The probability of such an attack is cumulative across the population of nuclear power plants and the years of their operation.
V. NRC's Draft Consequence Study: Structure, Apparent Scope, and Messages (V-i) Section IV, above, explains why any NRC study on pool-fire risk that is published now (i.e., mid-2013) should have focused exclusively on establishing a solid technical understanding of phenomena directly related to a potential pool fire. Such a study, done appropriately, could potentially have established NRC as a credible source of information about pool-fire risk. NRC did not follow that path. Indeed, NRC took a radically different approach. It published a study that is misleading, incomplete in its examination of risk, and designed to support pre-determined conclusions.
(V-2) NRC's Draft Consequence Study is structured as though it were a comprehensive assessment of the risk of a pool fire. It begins by identifying a single threat - an
 
Thompson Declaration. Comments on NRC's Draft Consequence Study Page 14 of 44 earthquake - and proceeds through a series of steps that end with a "regulatory analysis" (Appendix D) to determine if the threat justifies expedited transfer of spent fuel to dry storage. The scope of the Study is actually much narrower than would be the case in a comprehensive assessment, as discussed in Section VI, below. The Study itself acknowledges this fact in its interior sections. However, the Study's initial sections -
Foreword, Abstract, and Executive Summary - propagate a different story. As NRC personnel undoubtedly know, many readers of the Study will never penetrate beyond these initial sections. Such readers will receive strong messages that the risk of a pool fire is very low, that expedited transfer of spent fuel to dry storage is not necessary, and that further analysis would not alter these findings.
(V-3) One of the messages in the Study's initial sections is that, by considering a particular earthquake threat, the Study has addressed the major source of risk of a pool fire. In this context, the Study says:30 "Previous studies have shown that earthquakes present the dominant risk for spent fuel pools, so this analysis considered a severe earthquake with ground motion stronger than the maximum earthquake reasonably expected to occur for the reference plant."
(V-4) To complement that message, the Study provides strong messages that the risk of a pool fire is very low, and3expedited transfer of spent fuel is not necessary. In those contexts, the Study says: '
        "This study's results are consistent with earlier research studies' conclusions that spent fuel pools are robust structures that are likely to withstand severe earthquakes without leaking cooling water and potentially uncovering the spent fuel. The study shows the likelihood of a radiological release from the spent fuel after the analyzed severe earthquake at the reference plant to be about one time in 10 million years or lower. In addition, the regulatory analysis included with this study does not support accelerated spent fuel transfer to casks for the reference plant."
(V-5) Expedited transfer of spent fuel to dry storage would allow a pool to be re-equipped with low-density, open-frame racks. As discussed in paragraphs 1-6 and 111-3, above, the pool-fire issue became salient in the 1970s when the nuclear industry abandoned the use of low-density, open-frame racks and switched to high-density, closed-frame racks. Thus, if a concerned citizen learns that NRC is now studying the merit of a switch to low-density pool storage, that citizen could reasonably assume that NRC is considering the use of low-density, open-frame racks. Such a citizen, reading only the initial sections of NRCs Draft Consequence Study, would not encounter any information to contradict that assumption. 32 Moreover, the citizen would be told that a
'0 Barto et al, 2013, Executive Summary, page vi.
31 Barto et al, 2013, Executive Summary, page vi.
32 The Study's Executive Summary refers to high-density and low-density scenarios for pool loading. (See:
Barto et al, 2013, Executive Summary, page vi.) A person reading only the initial sections of the Study
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 15 of 44 switch to low-density storage would not reduce the potential for a pool fire. In this context, NRC says:33 "The likelihood of a spent fuel pool release [due to a pool fire] was equally low for both high- and low-density fuel loading. This is because high- and low-density fuel loading contains the same amount of new, hotter spent fuel recently moved from the reactor to the spent fuel pool."
(V-6) The preceding NRC statement is highly misleading. As discussed in paragraph 111-4, above, if low-density, open-frame racks were used, then water loss from a pool would lead to fuel ignition only in very rare circumstances. NRC does not dispute that fact. Instead, NRC uses the phrase "low density" to refer to a situation in which a substantial fraction of the cells in a high-density, closed-frame rack do not contain fuel.
That situation cannot offer the dramatic reduction in pool-fire risk that would come from reverting to low-density, open-frame racks.
(V-7) This one example demonstrates that the initial sections - Foreword, Abstract, and Executive Summary - of NRC's Draft Consequence Study contain a highly misleading statement. Given that the Study is lengthy and complex, many readers will not penetrate beyond these initial sections, as NRC personnel undoubtedly know. Thus, it is reasonable to conclude that NRC made this misleading statement deliberately, in order to serve some purpose.
(V-8) In Section VI, below, I discuss this one example further. I also discuss other instances in which NRC's Draft Consequence Study is misleading, incomplete in its examination of risk, and/or designed to support pre-determined conclusions.
VI. NRC's Draft Consequence Study: Actual Scope, and Credibility (VI-1) As discussed in Section V, above, NRC's Draft Consequence Study seeks to create the appearance of being a comprehensive assessment of the risk of a pool fire.
That image is conveyed by the structure of the Study, by the way the Study is described in its Foreword, Abstract, and Executive Summary, and by unequivocal statements that high-density spent-fuel pools protect public health and safety. 34 In fact, the Study's scope is narrow. As a result, the Study cannot support the broad findings that it presents.
(VI-2) To its credit, the Study does acknowledge the limitations in its scope, to a reader who penetrates to the interior sections of the Study. For example, Section 2 of the Study articulates many of the questionable assumptions and analytic limitations that permeate would be unlikely to realize that the allegedly low-density scenario does not involve the use of open-frame racks.
33 Barto et al, 2013, Executive Summary, page vii.
34 For example, the Study's Executive Summary concludes with the statement: "The NRC continues to believe, based on this study and previous studies that spent fuel pools protect public health and safety."
(See: Barto et a], 2013, Executive Summary, page xii.)
 
Thompson Declaration.-Comments on NRC's Draft Consequence Study Page 16 of 44 the Study. Overall, the Study has misleading parts and comparatively honest parts. This internal difference may be attributable to different authorship for different parts.
(VI-3) As discussed in paragraphs V-5 and V-6, above, the Study claims to compare the respective risks posed by high-density and low-density modes of fuel storage in a pool.
In fact, the Study makes no such comparison. Instead, the Study adopts misleading terminology, using the phrase "low density" to refer to a reduced inventory of fuel in a high-density, closed-frame rack. NRC explains its failure to assess the risk 35  implications of reverting to low-density, open-frame racks with the following statement:
          "Re-racking the pool would represent a significant expense, along with additional worker dose, and was not felt to be the likely regulatory approach taken based on consultation with the Office of Nuclear Reactor Regulation. Much of the benefit of low-density racking is achieved by the implementation of a favorable fuel pattern (1x4). Additionally, to get the full benefit of low-density racking, BWR fuel would likely need to have the channel boxes removed."
(VI-4) This statement by NRC is revealing. It shows that, when NRC began the Study, some of its conclusions were pre-determined. In this instance, NRC rejected the option of reverting to low-density, open-frame racks on the basis of no analysis whatsoever.
This rejection was done before the Study commenced, on the basis of a "feeling".
(VI-5) As discussed in Section III, above, between 1979 and 2000 NRC's work on pool-fire risk employed the erroneous assumption that complete drainage of a pool would be the most severe case of water loss. This error apparently arose from the failure of NRC personnel to fully understand a 1979 Sandia report that NRC had commissioned. NRC indirectly acknowledged this error in 2000.
(VI-6) Curiously, in light of this history, NRC's Draft Consequence Study focuses exclusively on complete drainage of a pool. The Study examines two cases. In the "moderate" leak case, drainage would be complete after about 6 hours, while in the "small" leak case, drainage would be complete after about 40 hours.3 6 Such cases are more useful for pool-fire risk analysis than the assumption of instantaneous, total drainage, which NRC employed in some of its previous studies. However, these two cases do not cover a full range of water-loss scenarios. Notably, they do not cover the Severe Reference scenario and its variants, as discussed in paragraph 111-6, above. That scenario, although not necessarily the "worst" case of water loss from a pool, does capture the role of residual water in the pool.
(VI-7) The implications of the presence of residual water for fuel ignition are illustrated by some simple calculations set forth in Section VII, below. These calculations assume a pool loading (see Figure VII-I) and operating cycle phase (OCP4) as used in NRC's Draft Consequence Study. The contrast with that study is that drainage of water would 35 Barto et al, 2013, Table 3, page 23.
36 Barto et al, 2013, Figures 52 and 54.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 17 of 44 not be complete. Instead, residual water would be present in the pool for an extended period. The calculations yield estimates of the time between fuel exposure and fuel ignition. Here, I refer to that time as "ignition delay time". Results are summarized in paragraph VII-13, below. Assuming an adiabatic situation for exposed fuel yields an ignition delay time of about 5 hours. Extrapolation of NRC's moderate-leakage and small-leakage cases yields ignition delay times of about 7 hours and 20 hours, respectively.
(VI-8) These time estimates provoke two immediate questions. First, how significant for risk is an ignition delay time in the range 5 to 20 hours? Second, how accurate are these time estimates? I address these questions in order, in the following two paragraphs.
(VI-9) During the Fukushima accident in 2011, the Japanese nuclear industry and government struggled unsuccessfully for several days to establish water makeup to spent-fuel pools. Eventually, they established water makeup using the concrete-pumping truck shown in Figure IV-1. Yet, the Fukushima experience was far from a worst case in terms of onsite phenomena, such as radioactive contamination from a reactor core melt accident, that could preclude mitigating actions. Thus, we have ample evidence that water makeup and other mitigating actions could be precluded for a period substantially exceeding 20 hours. Accordingly, if the ignition delay time is 20 hours, or even longer, it is entirely realistic to consider an event sequence involving: (i) an initial rapid exposure of fuel followed by the presence of residual water for an extended time; (ii) no water makeup; (iii) fuel ignition; and (iv) propagation of a pool fire.
(VI-10) As to the accuracy of these time estimates, neither the adiabatic assumption nor the extrapolation from NRC findings is adequate for the purpose of thoroughly investigating pool-fire risk. However, in the absence of better analysis, these estimates are reasonable for illustrative purposes. Appropriate analysis would require sophisticated modeling backed by experiment, done in a scientific manner. NRC has never done such analysis in a pool-fire context.
(VI-I 1) These illustrative calculations show that a pool fire could occur if water loss occurred during a particular operating cycle phase - OCP4. NRC's Draft Consequence Study finds (see Figures VII-2 and VII-3) that a pool fire would not occur in OCP4 with the same pool loading. That finding reflects NRC's decision to focus its analysis exclusively on water-loss scenarios involving total drainage of water from a pool. By adopting that focus, NRC has ignored a substantial part of the pool-fire risk.
(VI-12) Water could be lost from a pool as a result of an accident or an attack. NRC's Draft Consequence Study dismisses the possibility of an attack by stating:37 "Note that sabotage events have been excluded from the scope of this study." No further explanation is offered. Thus, NRC arbitrarily excludes a category of events that contributes substantially to pool-fire risk. As discussed in paragraph IV-9, above, an attack causing a reactor core melt and/or pool fire is a credible threat. The probability of 37 Barto et al, 2013, page 8.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 18 of 44 an attack with a substantial likelihood of success is at least equal to the probability of the earthquake that NRC does consider (i.e., 1 in 60,000 years). 3 Also, knowledgeable attackers could time and shape their attack in a manner that maximizes the potential for radioactive release.
(VI-13) As discussed in paragraphs IV-7 and IV-8, above, risk linkages among pools and reactors at a particular site could be major determinants of pool-fire risk at that site.
NRC's Draft Consequence Study actually provides a useful introduction to these 39linkages
- which they term "interplays" - under the rubric of "multi-unit considerations".
40 Having identified this risk-significant issue, the Study goes on to say:
          "To the extent practicable, this study has attempted to qualitatively account for some of these effects. For example, when the reactor and SFP are hydraulically connected (during refueling), the decay heat and water volumes from both sources are considered. The study also explores these effects on mitigation (Section 8),
and addresses some aspects of the uncertainty associated with this treatment (Section 9). However, explicitly modeling multiunit effects was not a focus of this study, because of the existing limitations with the available computational tools. An ongoing project described in SECY-1 1-0089 will attempt to more rigorously address these effects in the framework of a multiunit Level 3 PRA for Vogtle Electric Generating Plant Units 1 and 2."
(VI-14) In other words, NRC recognizes that pool-reactor linkages are significant to risk, says that a future effort will "attempt" to overcome the limitations of relevant analytic tools, but cannot resist the temptation to include a shoddy treatment of these linkages in NRC's Draft Consequence Study. That inclusion adds to the misleading nature of the Study.
(VI-15) Paragraph IV-2, above, discusses the need to consider "collateral conditions" in a thorough investigation of pool-fire phenomena. One such condition would be the presence of debris in a pool. NRC acknowledges the significance of this issue and then proceeds to ignore it, further adding to the misleading nature of the Study. NRC says:41 "The occurrence of a hydrogen combustion event from a concurrent reactor accident has the potential to generate debris which could impair SFP natural circulation air or steam cooling (should the fuel in the SFP become uncovered) for conditions in which the fuel might otherwise be cooled by means of these passive cooling modes. However, this latter situation is inherently tied to the study's lack of a comprehensive treatment of multiunit aspects."
(VI-16) NRC's Draft Consequence Study focuses its attention exclusively on one pool-fire initiating event - an earthquake with a probability of 1 in 60,000 years. At the same 38 Barto et al, 2013, Figure ES-2, page x.
39 Barto et al, 2013, Section 2.2, pp 28-29.
40 Barto et al, 2013, page 29.
4' Barto et al, 2013, Table 3, page 25.
 
Thompson Declaration: Comments on NRC's Draft Consequence Study Page 19 of 44 time, as discussed above, NRC acknowledges the risk significance of pool-reactor linkages but proceeds to ignore them. Yet, the probability of a reactor core melt is at least equal to the probability of the earthquake that NRC does consider. Generation 2 commercial reactors have accrued about 15,000 reactor-years of operating experience worldwide, and have experienced five core melts.
(VI-17) The feasibility and effectiveness of mitigating actions - such as providing makeup water to a pool - are significant to pool-fire risk. The Study addresses this matter in its Section 8, under the rubric of "human reliability analysis". In the Study, human error probability is equated to mitigation failure probability.      42 The Study acknowledges        the limitations  of  its analysis in this area, saying:
          "Consistent with the limited scope of the SFPS, a limited scope human reliability analysis (HRA) was performed, to develop initial insights into the likelihood of successful operator actions to prevent spent fuel damage for the specific seismic event and consequence scenarios studied. A full scope HRA would primarily be useful as part of a PRA analysis. A PRA would necessarily consider a much broader scope than the SFPS."
(VI- 18) Despite this acknowledgment, the Study proceeds to make unequivocal statements about the feasibility of mitigation. For example, in addressing the potential for a boil-off scenario of water loss, the Study says that the probability of mitigation failure extending for 7 days is "negligible". 43 That statement is based on no analysis, and reflects a pre-determined conclusion. NRC ignores, for example, the possibility that radiation fields and other onsite impacts of a reactor core melt could preclude mitigation for an extended period.
(VI-19) NRC's Draft Consequence Study addresses an issue that is significant in terms of public health and safety. This significance is illustrated by one of the Study's findings.
In modeling the offsite impacts of a potential pool fire, the Study considers a case in which modeling indicates that 4.1      44 million people would experience long-term displacement      from  their homes.
VII. NRC's Use of the MELCOR Code (VII-1) NRC has adapted the MELCOR code package, version 1.8.6, to examine the physical and chemical phenomena directly associated with a potential pool fire. Section 6 of NRC's Draft Consequence Study describes MELCOR and its use in this instance.
Here, I discuss selected points regarding this application of MELCOR. This discussion does not purport to be a comprehensive review, but addresses some important points.
(VII-2) In Section IV, above, I outline a process whereby a code such as MELCOR could be used to address pool-fire issues in a manner consistent with the principles of 42 Barto et al, 2013, page 173.
43 Barto et al, 2013, page 175.
44 Barto et al, 2013, Table 33, page 162.
 
I I Thompson Declaration.-Comments on NRC's Draft Consequence Study Page 20 of 44 science. The process would include NRC funding of independent investigators who would have access to MELCOR, and NRC funding of independently-run workshops where NRC investigators and independent investigators could engage in open, scientific discourse. To my knowledge, NRC's application of MELCOR in the pool-fire context has not employed such a process.
(VII-3) MELCOR was developed to model a reactor core melt. Accordingly, its fuel-behavior module employs a two-dimensional cylindrical geometry. By contrast, a pool, in plan view, is a rectangle within which the racks form a combination of rectangles. In an effort to accommodate this difference, NRC has assumed that spent fuel in a pool would be arranged in "rings" whose boundaries roughly approximate concentric circles, with overlap between some of these boundaries. Figure VII-1 illustrates this assumption.
Each ring would be composed of fuel with a particular age and burnup. Also, NRC has added a modeling capability to account for the presence of racks, which are not present in a reactor core.
(VII-4) If NRC's application of MELCOR had employed a scientific process as discussed above, then an independent reviewer could examine the associated documents and form a professional opinion on the validity of NRC's findings. To my knowledge, no such documents exist. Thus, at this time, I do not have a professional opinion on the quality of the MELCOR findings presented. by NRC. It is, however, easy to identify issues and questions that should be addressed in a scientific process to examine NRC's findings. Consider, for example, two issues pertaining to the validity of MELCOR in the pool-fire context:
: 1. MELCOR has no capability to model the deformation of fuel cladding as temperature rises. Yet, NUREG-1738 predicted that cladding would balloon and burst in a temperature range of 700-850'C. That outcome could reduce heat transfer and promote ignition of cladding. NRC says that these effects would not be significant, but rests that claim on secret, unpublished studies.45
: 2. Radiative heat transfer is an importantconsideration in pool-fire modeling. Yet, MELCOR employs a simplified approach to modeling this mode of heat transfer.
In this context, NRC says: 46 "It should be noted that there is a temperature gradient within each ring, and MELCOR attempts to model a multidimensional geometry with a simplified two-surface radiation model."
(VII-5) In addition to questions about the validity of MELCOR, there are questions about NRC's input assumptions. For example, how closely does the pool layout shown in Figure VII- 1 correspond with actual practice in the nuclear industry? In that context, there is a puzzling NRC assumption associated with Figure VII-1. That figure shows a total of 284 newly-discharged fuel assemblies. Of these, 88 assemblies are assumed by NRC to produce decay heat at the rate of 10.9 kW per assembly when aged 20 days, 45 Barto et al, 2013, Table 3, page 26.
46 Barto et al, 2013, footnote 23, page 110.
 
. I Thompson Declaration:Comments on NRC's Draft Consequence Study Page 21 of 44 while the remaining 196 assemblies produce 6.6 kW per assembly at the same age. 47 If this is typical practice, then licensees are forgoing substantial available bumup of the majority of their fuel assemblies, with a resulting economic penalty.48 As a related matter, Figure VII- 1 shows a rather elaborate layout of fuel, whose achievement would involve substantial shuffling of assemblies. NRC says that this layout is comparatively favorable in terms of the risk of a pool fire. Yet, licensees are allowed a period of time, during and perhaps after a refueling outage, to perform the shuffling needed to achieve a favorable layout. The length of that period of time is a secret because, NRC says, this information could be useful to an adversary. 49 Thus, is it appropriate to assume, as a MELCOR input, that a comparatively favorable layout has been achieved before water is lost?
(VII-6) In the Study, NRC has focused its analysis exclusively on water-loss scenarios involving total drainage of water from a pool. By adopting that focus, NRC has ignored a substantial part of the pool-fire risk. Here, I provide some simple calculations that illustrate the implications of NRC's narrow focus. These calculations show how the presence of residual water could affect fuel ignition. One calculation employs the simplifying assumption that, if residual water is present, the exposed portion of a fuel assembly in a high-density rack is in an adiabatic situation. Using that assumption, anyone with technical training can use pencil and paper to calculate the time required for the temperature of the fuel cladding to rise to its ignition point. The other calculations determine that time by extrapolating from NRC's findings using MELCOR. As indicated above, I do not necessarily accept that MELCOR is valid for its application by NRC to the pool-fire problem, or that NRC's input assumptions are appropriate.
(VII-7) These illustrative calculations consider loss of water from the pool considered in NRC's Draft Consequence Study. This event would occur during operating cycle phase 4 (OCP4). According to NRC, OCP4 and higher-risk phases account for 34 percent of the duration of the total operating cycle. 50 Attention is focused here on Ring 1 fuel, as shown in Figure VII-1. The pool would be loaded at high density.
(VII-8) The assumed scenario for water loss is the Severe Reference scenario as articulated in paragraph 111-6, above. Initially, water level would fall rapidly to a point between the top and bottom of the racks. Thereafter, residual water would be lost comparatively slowly by evaporation. 51 The presence of residual water would block air 47 These  decay heat outputs are calculated from data in Table 25 of: Barto et al, 2013. The same data apply to Figure VII-1 in this declaration.
48 Other factors being equal, decay heat output increases with burnup.
49 Barto et al, 2013, Section 9.3, page 208.
50 Barto et al, 2013, Table 16, page 78.
51 The rate of loss of residual water by evaporation can be estimated as follows. The floor of the pool is 12.2 m by 10.8 m (Barto et al, 2013, page 103) and the total decay heat output in OCP4 is 1,868 kW (Barto et al, 2013, Table 25). Let the submerged fraction of the active length of the fuel be F, and assume uniform output of decay heat along the active length. Assume 60% water content by volume in the lower portion of the pool. Set water density at 960 kg/m 3 and latent heat of evaporation at 2,260 kJ/kg. Then, the rate of fall of the water surface due to evaporation = F,(1,868)/((2,260)(960)(0.6)(12.2x10.8)) = F,(1.09E-05) m/s
    = 0.04F, m/hr. For comparison, active length of the fuel is about 4 m.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 22 of 44 flow beneath the racks. The exposed portion of the fuel would gradually increase in temperature.
(VII-9) For the first illustrative calculation, assume that the exposed portion of the fuel is in an adiabatic situation. As shown in Table VII-1, it is easy, with this assumption, to calculate the rate at which fuel temperature would rise. According to NRC, Ring I fuel in OCP4 has a decay heat output of 26.6 kW per Mg U. 52 From              53 Table VII-1, one sees that  fuel temperature    would    rise at the  rate of 170 K  per  hour.
(VII-10) Now, consider MELCOR outputs for NRC's examination of a moderate-leakage case in OCP4, as shown in Figure VII-2. During the evolution of this case, there would be a period of time when the upper portion of the fuel is exposed and residual water is present. That period would extend from about t = 3 hours to about t = 6 hours.
During that 3-hour period, at the "Lev 5" elevation of the fuel, cladding temperature would rise from about 300 K to about 700 K. Thus, the average rate of temperature rise would be about 130 K per hour. This finding indicates that the exposed portion of the fuel at the Lev 5 elevation would be in an approximately adiabatic situation, at least for temperatures up to 700 K.
(VII- 11) Now, apply the same process, as in the preceding paragraph, to NRC's examination of a small-leakage case as shown in Figure VII-3. In that case, the period of time when fuel at the Lev 5 elevation is exposed and residual water is present would extend from about t = 28 hours to about t = 40 hours. During that 12-hour period, the temperature of fuel cladding at the Lev 5 elevation would rise from about 350 K to about 900 K. Thus, the average rate of temperature rise would be about 46 K per hour.
(VII-12) The slower average temperature rise in NRC's small-leakage case, compared to the moderate-leakage case, appears to be attributable to a MELCOR finding that heat transfer from exposed fuel would be more effective at temperatures between 700 K and 900 K than it would be at temperatures below 700 K.54 Radiative heat transfer would be a substantial contributor to that effect.
(VII-13) NRC assumes that zircaloy ignition would occur at a temperature of about 1,200 K. If the initial fall of water level is rapid, then exposed fuel would have an initial temperature of about 300 K. Thus, ignition would require a temperature rise of about 900 K. Accordingly, the three illustrative calculations, as described above, yield a time to ignition, after exposure of fuel, as follows:
: 1. Adiabatic assumption: Adiabatic heatup would lead to a temperature rise of 170 K per hour. Thus, time to ignition = 900/170 = 5.3 hours 52 NRC says (Barto et al, 2013, Table 25) that 88 Ring  1fuel assemblies have a combined decay heat output of 422 kW in OCP4. If the mass of one assembly is assumed to be 0.18 Mg U, then decay heat output (422/88)/(0.18) = 26.6 kW per Mg U.
53 In Table VII-1, set R = 26.6 kW per Mg U. Then, rate of temperature rise = (26.6)(6.38) = 170 K/hr.
54 Note the respective shapes of the Lev 5 curves in the temperature-time charts in Figures VII-2 and VII-3.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 23 of 44
: 2. Extrapolation of NRC's moderate-leakage case: If temperature rise continued at 130 K per hour, time to ignition = 900/130 = 6.9 hours
: 3. Extrapolation of NRC's small-leakage case: If temperature rise continued at 46 K per hour, time to ignition = 900/46 = 19.6 hours (VII-14) Extrapolation of NRC's findings is reasonable for illustrative purposes, in the absence of better analysis. However, neither the adiabatic assumption nor the extrapolation used here is adequate for the purpose of thoroughly investigating pool-fire risk. As discussed in Section IV, above, a thorough, comprehensive investigation would begin by establishing a solid technical understanding of phenomena directly related to a potential pool fire, including heat transfer, zircaloy ignition, and fire dynamics. The necessary modeling and experimental work would be done according to scientific principles. That work could yield, for example, scientifically-defensible estimates of ignition delay time in a Severe Reference scenario for water loss. It is far from clear that MELCOR can yield good estimates of this time, given MELCOR's simplified treatment of radiative heat transfer.
(VII-1 5) If ignition of fuel occurred in a Severe Reference scenario for water loss, the fire would begin as a steam-zircaloy reaction. Progress of the fire would be limited by the amount of steam that would be generated from residual water and rise through each fuel assembly. Note, however, that the flow of steam reaching the exposed portion of a particular assembly would be determined primarily by the decay heat output of that assembly. Thus, for a pool layout as shown in Figure VII-l, Ring I fuel would not only be the first fuel in the pool to experience steam-zircaloy ignition, but would also experience the highest flow of steam that could feed a steam-zircaloy fire.
VIII. Conclusions and Recommendations Conclusions (VIII-1) Prior to publication of the Draft Consequence Study, NRC's technical credibility on the pool-fire issue was low. Over a period exceeding three decades, NRC had published bad analysis and hidden other analysis behind a veil of secrecy. Moreover, NRC failed to conduct sophisticated modeling and supporting experiments that could have resolved technical issues central to pool-fire risk, despite having an appropriate capability prior to 1990.
(VIII-2) NRC's Draft Consequence Study seeks to create the appearance of being a comprehensive assessment of the risk of a pool fire. That image is conveyed by the structure of the Study, by the way the Study is described in its Foreword, Abstract, and Executive Summary, and by unequivocal statements that high-density spent-fuel pools protect public health and safety. In fact, the Study's scope is narrow. As a result, the Study's examination of pool-fire risk is incomplete, and cannot support the broad, unequivocal findings that the Study presents. This disjunction between the apparent and actual scope of the Study is misleading. Moreover, in specific instances, the Study is
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 24 of 44 misleading and is designed to support pre-determined conclusions. Examples of specific deficiencies in the Study are provided in the following paragraph.
(VIII-3) Some specific instances in which NRC's Draft Consequence Study is incomplete, misleading, and/or designed to support pre-determined conclusions are as follows:
: 1. Pretence of considering low-density storage: The Study does not consider the risk implications of reverting to low-density, open-frame racks. Instead, NRC misuses the phrase "low density" in order to create a false impression of the Study's scope. This pretence reflects pre-determined conclusions based on a "feeling".
: 2. Limited consideration of water-loss scenarios: The Study focuses its analysis exclusively on water-loss scenarios involving total drainage. By so doing, the Study ignores a substantial part of the pool-fire risk. For example, the Study makes no effort to determine how the presence of residual water could affect fuel ignition. Extrapolation of Study findings indicates that consideration of this issue would substantially increase the estimated risk.
: 3. Limited consideration of initiating events: The Study considers only one type of initiating event - an earthquake. That narrow focus reflects a pre-determined conclusion that earthquake is the dominant contributor to the risk of a pool fire.
: 4. No consideration of attack: The Study ignores the potential for an attack on a pool and/or adjacent reactor to initiate a pool fire. Yet, the probability of an attack with a substantial likelihood of success is at least equal to the probability of the severe earthquake that the Study does consider. Thus, the Study significantly under-estimates pool-fire risk.
: 5. No analysis of risk linkages among pools and reactors: The Study identifies the potential for risk linkages, but does not properly analyze them. For example, the Study does not analyze a situation in which onsite radioactive contamination and other impacts of a reactor core melt would preclude mitigating actions that might prevent a pool fire. Yet, the probability of a core melt at an adjacent reactor is at least equal to the probability of the severe earthquake that the Study does consider. Thus, the Study significantly under-estimates pool-fire risk.
: 6. Misleading statements regarding mitigating actions: The Study concedes that its analysis of the feasibility of mitigating actions is very limited. Yet, the Study makes unequivocal statements about this feasibility. Some of those statements are misleading, and reflect pre-determined conclusions.
(VIII-4) In the Study, NRC employs the MELCOR code to model phenomena related to a pool fire - including heat transfer, cladding ignition, and fire dynamics. MELCOR findings are significant to NRC's estimation of pool-fire risk. Yet, the validity of MELCOR in this context, and the appropriateness of NRC's input assumptions, have not been tested through a process of open scientific inquiry. There are significant issues that should be addressed through such a process, including MELCOR's simplified treatment of radiative heat transfer.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 25 of 44 (VIII-5) In the Study, NRC has erected an elaborate superstructure of analysis on a weak foundation of basic knowledge about pool-fire phenomena. This superstructure culminates in a regulatory analysis. As discussed in paragraph VIII-2, above, the findings emanating from this superstructure lack scientific credibility and are misleading.
Thus, the design of the Study is fundamentally and irredeemably flawed.
(VIII-6) The Study addresses an issue that is significant in terms of public health and safety. This significance is illustrated by the Study's finding that a pool fire could lead to long-term displacement from their homes of more than 4 million people. Thus, citizens deserve a much better analysis of pool-fire risk than the incomplete, misleading work presented in NRC's Draft Consequence Study.
Recommendations (VIII-7) NRC's Draft Consequence Study should be scrapped.
(VIII-8) In addressing the pool-fire issue, NRC should focus its initial attention exclusively on establishing a solid technical understanding of phenomena directly related to a potential pool fire. To do this, NRC would start with a clean slate and use the best available modeling capability backed up by experiment. This modeling and experimental work would be done according to scientific principles. Further recommendations regarding such work are provided in Section IV, above.
I declare, under penalty of perjury, that the facts set forth in the foregoing narrative, and in the two appendices below, are true and correct to the best of my knowledge and belief, and that the opinions expressed therein are based on my best professional judgment.
Executed on 1 August 2013.
Gordon R. Thompson
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 26 of 44 APPENDIX A: Tables and Figures List of Tables Table 111-1: Potential Sabotage Events at a Spent-Fuel Pool, as Postulated in NRC's August 1979 Generic EIS on Handling and Storage of Spent LWR Fuel Table IV-I: Some Potential Modes and Instruments of Attack on a Nuclear Power Plant Table IV-2: The Shaped Charge as a Potential Instrument of Attack Table IV-3: Performance of US Army Shaped Charges, M3 and M2A3 Table VII- 1: Adiabatic Heatup of a Spent BWR Fuel Assembly List of Figures Figure III-1: Typical Low-Density, Open-Frame Rack for Pool Storage of PWR Spent Fuel Figure IV-i: Unit 4 at the Fukushima #1 Site During the 2011 Accident Figure IV-2: Schematic View of a Generic Shaped-Charge Warhead Figure IV-3: MISTEL System for Aircraft Delivery of a Shaped Charge, World War II Figure IV-4: January 2008 Test of a Raytheon Shaped Charge, Intended as the Penetration (Precursor) Stage of a Tandem Warhead System Figure IV-5: Aftermath of a Small-Aircraft Suicide Attack on an Office Building in Austin, Texas, February 2010 Figure VII-1: One of the Pool Layouts Modeled in NRC's Draft Consequence Study: The OCP2, High-Density, lx4 Case Figure VII-2: Findings from NRC's Draft Consequence Study: Water Level and Ring I Cladding Temperature for Unmitigated High-Density Moderate Leak (OCP4)
Figure VII-3: Findings from NRC's Draft Consequence Study: Water Level and Ring I Cladding Temperature for Unmitigated High-Density Small Leak (OCP4)
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 27 of 44 Table 111-1 Potential Sabotage Events at a Spent-Fuel Pool, as Postulated in NRC's August 1979 Generic EIS on Handling and Storage of Spent LWR Fuel Event Designator        General Description of Event              Additional Details Mode 1
* Between 1 and 1,000 fuel
* One adversary can carry 3 assemblies undergo extensive        charges, each of which can damage by high-explosive            damage 4 fuel assemblies charges detonated under water      - Damage to 1,000 assemblies
                        - Adversaries commandeer the      (i.e., by 83 adversaries) is a central control room and hold it  "worst-case bounding estimate" for approx. 0.5 hr to prevent the ventilation fans from being turned off Mode 2
* Identical to Mode 1 except that, in addition, an adversary enters the ventilation building and removes or ruptures the HEPA filters Mode 3
* Identical to Mode 1 within the
* Adversaries enter the central pool building except that, in      control room or ventilation addition, adversaries breach two  building and turn off or disable opposite walls of the building    the ventilation fans by explosives or other means Mode 4
* Identical to Mode 1 except that, in addition, adversaries use an additional explosive charge or other means to breach the pool liner and 1.5 m-thick concrete floor of the pool Notes:
(a) Information in this table is from Appendix J of: NRC, 1979.
(b) The postulated fuel damage ruptures the cladding of each rod in an affected fuel assembly, releasing "contained gases" (gap activity) to the pool water, whereupon the released gases bubble to the water surface and enter the air volume above that surface.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 28 of 44 Table IV-1 Some Potential Modes and Instruments of Attack on a Nuclear Power Plant Attack Mode/Instrument                Characteristics              Present Defenses
_  at US Plants Commando-style attack
* Could involve heavy          Alarms, fences and lightly-weapons and sophisticated      armed guards, with offsite tactics                        backup
                                - Successful attack would require substantial planning and resources Land-vehicle bomb
* Readily obtainable            Vehicle barriers at entry
* Highly destructive if        points to Protected Area detonated at target Small guided missile
* Readily obtainable            None if missile launched (anti-tank, etc.)
* Highly destructive at point  from offsite of impact Commercial aircraft
* More difficult to obtain      None than pre-9/ 11
                                - Can destroy larger, softer targets Explosive-laden smaller          - Readily obtainable            None aircraft                        - Can destroy smaller, harder targets 10-kilotonne nuclear            - Difficult to obtain          None weapon                          ° Assured destruction if I detonated at target          I Notes:
(a) This table is adapted from: Thompson, 2007, Table 7-4. Further citations are provided in that table and its supporting narrative. For additional, supporting information of more recent vintage, see: Ahearne et al, 2012, Chapter 5.
(b) Defenses at nuclear power plants around the world are typically no more robust than at US plants.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 29 of 44 Table IV-2 The Shaped Charge as a Potential Instrument of Attack Category of Information                    Selected Information in Category General information
* Shaped charges have many civilian and military applications, and have been used for decades
* Applications include human-carried demolition charges or warheads for anti-tank missiles
                            - Construction and use does not require assistance from a government or access to classified information Use in World War II
* The German MISTEL, designed to be carried in the nose of an un-manned bomber aircraft, is the largest known shaped charge
                            - Japan used a smaller version of this device, the SAKURA bomb, for kamikaze attacks against US warships A large, contemporary        - Developed by a US government laboratory for mounting device                      in the nose of a cruise missile
* Described in detail in an unclassified, published report (citation is voluntarily withheld here)
                            - Purpose is to penetrate large thicknesses of rock or concrete as the first stage of a "tandem" warhead
* Configuration is a cylinder with a diameter of 71 cm and a length of 72 cm
* When tested in November 2002, created a hole of 25 cm diameter in tuff rock to a depth of 5.9 m
* Device has a mass of 410 kg; would be within the payload capacity of many general-aviation aircraft A potential delivery
* A Beechcraft King Air 90 general-aviation aircraft can vehicle                      carry a payload of up to 990 kg at a speed of up to 460 km/hr 0 The price of a used, operational King Air 90 in the USA can be as low as $0.4 million Source:
This table is adapted from Table 7-6 of: Thompson, 2009.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 30 of 44 Table IV-3 Performance of US Army Shaped Charges, M3 and M2A3 Target                  Indicator                        Value for Stated Material                                            Type of Shaped Charge Type: M3            Type: M2A3 Reinforced        Maximum wall thickness          150 cm              90 cm concrete          that can be perforated Depth of penetration in        150 cm              75 cm thick walls Diameter of hole
* 13 cm at entrance
* 9 cm at entrance
* 5 cm minimum
* 5 cm minimum Depth of hole with second      210 cm              110 cm charge placed over first hole Armor plate      Perforation                    At least 50 cm      30 cm Average diameter of hole      6 cm                4 cm Notes:
(a) Data are from US Army Field Manual FM 5-25: Army, 1967, pp 13-15 and page 100.
(b) The M2A3 charge has a mass of 5 kg, a maximum diameter of 18 cm, and a total length of 38 cm including the standoff ring.
(c) The M3 charge has a mass of 14 kg, a maximum diameter of 23 cm, a charge length of 39 cm, and a standoff pedestal 38 cm long.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 31 of 44 Table VII-1 Adiabatic Heatup of a Spent BWR Fuel Assembly Indicator                                          Value Zircaloy                      U0 2 Pellets Mass per Mg U of fuel                        564 kg                        1,130 kg (includes cladding, channel box, and grid spacers)
Specific heat (av., approx.)              400 J/kg/K                    300 J/kg/K Radioactive decay heat                      R kW per Mg U (or W per kg U) of fuel Rate of temperature (T) rise                  T' = R/(400x0.564 + 300x 1.13) K/s from decay heat, if pellets                      = R(1.77E-03) K/s (or R(6.38) K/hr) and zircaloy are a tightly coupled adiabatic system Notes:
(a) Zircaloy mass is from Table 3.2 of: Roddy et al, 1986.
(b) The specific heats shown are averages over the temperature range 100-1,000 'C. For zircaloy, specific heat spikes sharply between about 800 'C and 1,000 'C. (See: IAEA, 1997, Figure 4.2.1. 1.) For U0 2 , specific heat does not spike until temperature approaches 3,000 K. (See: Popov et al, 2000, Figure 4.2.)
(c) This calculation applies to any portion of the active length of a fuel assembly, provided that decay heat output is uniform along the active length.
(d) The influence of materials other than zircaloy and U0 2 (e.g., fission products) is neglected here. That influence could be examined in a more precise calculation.
(e) No credit is taken here for heat output from exothermic reactions.
 
E Thompson Declaration:Comments on NRC's Draft Consequence Study Page 32 of 44 Figure II1-1 Typical Low-Density, Open-Frame Rack for Pool Storage of PWR Spent Fuel Source:
Adapted from Figure B.2 of: NRC, 1979.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 33 of 44 Figure IV-1 Unit 4 at the Fukushima #1 Site During the 2011 Accident Source:
Accessed on 20 February 2012 from Ria Novosti at:
http://en.rian.ru/analysis/20110426/163701909.html; image by Reuters Air Photo Service.
 
AI Thompson Declaration:Comments on NRC's Draft Consequence Study Page 34 of 44 Figure IV-2 Schematic View of a Generic Shaped-Charge Warhead Notes:
(a) Figure accessed on 4 March 2012 from: http://en.wikipedia.org/wiki/Shaped charge (b) Key:
Item 1: Aerodynamic cover Item 2: Empty cavity Item 3: Conical liner (typically made of ductile metal)
Item 4: Detonator Item 5: Explosive Item 6: Piezo-electric trigger (c) Upon detonation, a portion of the conical liner would be formed into a high-velocity jet directed toward the target. The remainder of the liner would form a slower-moving slug of material.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 35 of 44 Figure IV-3 MISTEL System for Aircraft Delivery of a Shaped Charge, World War II Notes:
(a) Photograph accessed on 5 March 2012 from:
http://www.historyofwar.org/Pictures/pictures Ju 88 mistel.html (b) A shaped-charge warhead can be seen at the nose of the lower (converted bomber) aircraft, replacing the cockpit. The aerodynamic cover in front of the warhead would have a contact fuse at its tip, to detonate the shaped charge at the appropriate standoff distance.
(c) A human pilot in the upper (fighter) aircraft would control the entire rig, and would point it toward the target. Then, the upper aircraft would separate and move away, and the lower aircraft would be guided to the target by an autopilot.
 
I Thompson Declaration:Comments on NRC's Draft Consequence Study Page 36 of 44 Figure IV-4 January 2008 Test of a Raytheon Shaped Charge, Intended as the Penetration (Precursor) Stage of a Tandem Warhead System After Tprat (viPwPd frnm thp nftiwkrkd fiwe'l Notes:
(a) These photographs are from: Raytheon, 2008. For additional, supporting information, see: Warwick, 2008.
(b) The shaped-charge jet penetrated about 5.9 m into a steel-reinforced concrete block with a thickness of 6.1 m. Although penetration was incomplete, the block was largely destroyed, as shown. Compressive strength of the concrete was 870 bar.
(c) The shaped charge had a diameter of 61 cm and contained 230 kg of high explosive.
It was sized to fit inside the US Air Force's AGM-129 Advanced Cruise Missile.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 37 of 44 Figure IV-5 Aftermath of a Small-Aircraft Suicide Attack on an Office Building in Austin, Texas, February 2010 Notes:
(a) Photograph and information in these notes are from: Brick, 2010.
(b) A major tenant of the building was the Internal Revenue Service (IRS).
(c) The aircraft was a single-engine, fixed-wing Piper flown by its owner, Andrew Joseph Stack III, an Austin resident who worked as a computer engineer.
(d) A statement left by Mr Stack indicated that a dispute with IRS had brought him to a point of suicidal rage.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study                            -A Page 38 of 44 Figure VII-1 One of the Pool Layouts Modeled in NRC's Draft Consequence Study: The OCP2, High-Density, 1x4 Case Em19m6 (ne.t&wwgo)
E 315 (Ito, oIfle*+1 *am prtvlon)
                                                  ,ga1 P      8 Ring 2 0- Ring 7 Notes:
(a) This figure is a copy of Figure 46 from: Barto et al, 2013.
(b) OCP2 (operating cycle phase 2) is described in Table 25 of: Barto et al, 2013.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 39 of 44 Figure VII-2 Findings from NRC's Draft Consequence Study: Water Level and Ring 1 Cladding Temperature for Unmitigated High-Density Moderate Leak (OCP4) 12 10 8
E 6
U. 4 U) 2 0
0        12          24          36      48          60          72 time [hr]
1800 1600 1400
          . 1200 E
o1000
        ,a    800 600 i    400 200 0      12          24          36      48          60          72 time [hr]
Notes:
a) These figures are copies of Figures 52 and 53 from: Barto et al, 2013.
(b) OCP4 (operating cycle phase 4) is described in Table 25 of: Barto et al, 2013.
(c) Vertical nodalization (Lev 1, etc.) is shown in Figure 41 of: Barto et al, 2013.
(d) Distribution of fuel (Ring 1, etc.) is shown in Figure 46 of: Barto et al, 2013.
 
I Thompson Declaration:Comments on NRC's Draft Consequence Study                A Page 40 of 44 Figure VII-3 Findings from NRC's Draft Consequence Study: Water Level and Ring 1 Cladding Temperature for Unmitigated High-Density Small Leak (OCP4) 12 10 8
0
          -J 0
6 4-
: 0. 4 IL.
0, 2
0 0      12          24          36        48        60          72 time [hr]
1800
* 1600
          -    1400 a    1200 E
a1000 V      800 600 IX      400 200 0    12          24          36        48        60          72 time [hr]
Notes:
(a) These figures are copies of Figures 54 and 55 from: Barto et al, 2013.
(b) OCP4 (operating cycle phase 4) is described in Table 25 of: Barto et al, 2013.
(c) Vertical nodalization (Lev 1, etc.) is shown in Figure 41 of: Barto et al, 2013.
(d) Distribution of fuel (Ring 1, etc.) is shown in Figure 46 of: Barto et al, 2013.
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 41 of 44 APPENDIX B: Bibliography (Ahearne et al, 2012)
John F. Ahearne and eight other authors, with editing by Charles D. Ferguson and Frank A. Settle, The Future ofNuclear Power in the UnitedStates (Washington, DC:
Federation of American Scientists, and Washington and Lee University, February 2012).
(Albrecht, 1979)
Ernst Albrecht, Minister-President of Lower Saxony, "Declaration of the state government of Lower Saxony concerning the proposed nuclear fuel center at Gorleben" (English translation), May 1979.
(Alvarez et al, 2003)
Robert Alvarez, Jan Beyea, Klaus Janberg, Jungmin Kang, Ed Lyman, Allison Macfarlane, Gordon Thompson, and Frank von Hippel, "Reducing the Hazards from Stored Spent Power-Reactor Fuel in the United States", Science and Global Security, Volume 11, 2003, pp 1-5 1.
(Army, 1967)
Department of the Army, Explosives andDemolitions, FM 5-25 (Washington, DC:
Department of the Army, May 1967).
(Barto et al, 2013)
Andrew Barto and nine other authors, Consequence Study of a Beyond-Design-Basis EarthquakeAffecting the Spent Fuel Poolfor a US Mark I Boiling Water Reactor,Draft Report (Washington, DC: US Nuclear Regulatory Commission, June 2013).
(Benjamin et al, 1979)
Allan S. Benjamin and three other authors, Spent Fuel Heatup FollowingLoss of Water DuringStorage,NUREG/CR-0649 (Washington, DC: US Nuclear Regulatory Commission, March 1979).
(Beyea et al, 1979)
Jan Beyea, Yves Lenoir, Gene Rochlin, and Gordon Thompson (group chair), "Potential Accidents and Their Effects," Chapter 3 in Report of the GorlebenInternationalReview, March 1979. (This chapter was prepared in English and translated into German for submission to the Lower Saxony State Government.)
(Brick, 2010)
Michael Brick, "Man Crashes Plane Into Texas IRS Office", The New York Times, 18 February 2010.
 
I Thompson Declaration.Comments on NRC's Draft Consequence Study Page 42 of 44 (Collins and Hubbard, 2001)
T. E. Collins and G. Hubbard, Technical Study of Spent Fuel Pool Accident Risk at DecommissioningNuclear Power Plants, NUREG-1 738 (Washington, DC: US Nuclear Regulatory Commission, February 2001). (This document was first released in October 2000.)
(GAO, 2012)
US Government Accountability Office, Spent Nuclear Fuel: Accumulating Quantitiesat Commercial Reactors PresentStorage and Other Challenges, GA 0-12-797 (Washington, DC: GAO, August 2012).
(IAEA, 1997)
International Atomic Energy Agency, Thermophysicalproperties of materialsfor water cooled reactors,IAEA-TECDOC-949 (Vienna: IAEA, June 1997).
(National Research Council, 2006)
National Research Council Committee on the Safety and Security of Commercial Spent Nuclear Fuel Storage (a committee of the Council's Board on Radioactive Waste Management), Safety and Security of Commercial Spent NuclearFuel Storage: Public Report (Washington, DC: National Academies Press, 2006).
(NRC, 2013)
US Nuclear Regulatory Commission, Waste Confidence Generic EnvironmentalImpact Statement, NUREG-2157, Draft Reportfor Comment (Washington, DC: US Nuclear Regulatory Commission, August 2013).
(NRC, 1990)
US Nuclear Regulatory Commission, Severe Accident Risks: An Assessment for Five US NuclearPower Plants,NUREG-1 150 (Washington, DC: US Nuclear Regulatory Commission, December 1990).
(NRC, 1979)
US Nuclear Regulatory Commission, Generic EnvironmentalImpact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel,NUREG-0575 (Washington, DC: Nuclear Regulatory Commission, August 1979).
(Parry et al, 2000)
ASLBP No. 99-762-02-LA, "Affidavit of Gareth W. Parry, Stephen F. LaVie, Robert L.
Palla and Christopher Gratton in Support of NRC Staff Brief and Summary of Relevant Facts, Data and Arguments upon which the Staff Proposes to Rely at Oral Argument on Environmental Contention EC-6", 20 November 2000.
 
Thompson Declaration.-Comments on NRC's Draft Consequence Study Page 43 of 44 (Popov et al, 2000)
S, G. Popov and three other authors, Thermophysical Propertiesof MOX and U02 Fuels including the Effects of Irradiation,Report ORNL/TM-2000/351 (Oak Ridge, Tennessee:
Oak Ridge National Laboratory, November 2000).
(Raytheon, 2008)
Raytheon Company, "Raytheon Unveils New Record-Breaking Bunker Busting Technology", 12 March 2008, accessed on 7 March 2012 at:
http://www.raytheon.com/newsroom/feature/bb 03-10/
(Roddy et al, 1986)
J. W. Roddy and four other authors, Physical andDecay Characteristicsof Commercial L WR Spent Fuel, ORNL/TM-9591/VI&R1 (Oak Ridge, Tennessee: Oak Ridge National Laboratory, January 1986).
(Thompson, 2013)
Gordon R. Thompson, Declaration, "Recommendations for the US Nuclear Regulatory Commission's Consideration of Environmental Impacts of Long-Term, Temporary Storage of Spent Nuclear Fuel or Related High-Level Waste", 2 January 2013.
(Thompson, 2009)
Gordon R. Thompson, EnvironmentalImpacts of Storing Spent Nuclear Fuel and High-Level Waste from CommercialNuclear Reactors: A Critique ofNRC's Waste Confidence Decision andEnvironmentalImpact Determination(Cambridge, Massachusetts: Institute for Resource and Security Studies, 6 February 2009).
(Thompson, 2008)
Gordon R. Thompson, "The US Effort to Dispose of High-Level Radioactive Waste",
Energy and Environment, Volume 19, Nos. 3+4, 2008, pp 391-412.
(Thompson, 2007)
Gordon R. Thompson, Risk-Related Impactsfrom ContinuedOperation of the Indian Point Nuclear Power Plants (Cambridge, Massachusetts: Institute for Resource and Security Studies, 28 November 2007).
(Thompson, 2005)
Gordon R. Thompson, Reasonably ForeseeableSecurity Events: Potentialthreats to optionsfor long-term management of UK radioactivewaste (Cambridge, Massachusetts:
Institute for Resource and Security Studies, 2 November 2005).
(Thompson, 2003)
Gordon Thompson, Robust Storage of Spent Nuclear Fuel: A Neglected Issue of Homeland Security (Cambridge, Massachusetts: Institute for Resource and Security Studies, January 2003).
 
Thompson Declaration:Comments on NRC's Draft Consequence Study Page 44 of 44 (Wald, 2005)
Matthew L. Wald, "Agencies Fight Over Report on Sensitive Atomic Wastes", The New York Times, 30 March 2005.
(Warwick, 2008)
Graham Warwick, "VIDEO: Raytheon tests bunker-busting tandem warhead",
Flightglobal,26 February 2008, accessed on 7 March 2012 from:
http://www.flightglobal.com/news/articles/video-raytheon-tests-bunker-busting-tandem-warhead-221842/
 
INSTITUTE FOR RESOURCE AND SECURITY STUDIES 27 Ellsworth Avenue, Cambridge, Massachusetts 02139, USA Declaration of 19 December 2013 by Gordon R. Thompson:
Comments on the US Nuclear Regulatory Commission's Waste Confidence Generic Environmental Impact Statement, Draft Report for Comment (September 2013)
I, Gordon R. Thompson, declare as follows:
I. Introduction (I-1) I am the executive director of the Institute for Resource and Security Studies (IRSS), a nonprofit, tax-exempt corporation based in Massachusetts. Our office is located at 27 Ellsworth Avenue, Cambridge, MA 02139. IRSS was founded in 1984 to conduct technical and policy analysis and public education, with the objective of promoting peace and international security, efficient use of natural resources, and protection of the environment.
My professional qualifications are discussed in Section II, below.
(1-2) I have been retained by a group of environmental organizations to prepare this declaration.' This declaration provides comments invited by the US Nuclear Regulatory Commission (NRC). 2 NRC has invited comments on a September 2013 draft version of a generic environmental impact statement (GEIS) that addresses the subject of "waste confidence". 3 In the remainder of this declaration I refer to that document as the "draft GEIS". The stated objective of the draft GEIS is to:4 "examine the potential environmental impacts that could occur as a result of the continued storage of spent
'These organizations include: Alliance to Halt Fermi 3, Beyond Nuclear, Blue Ridge Environmental Defense League, Center for a Sustainable Coast, Citizens Allied for Safe Energy, Citizens' Environmental Coalition, Don't Waste Michigan, Ecology Party of Florida, Friends of the Coast, Friends of the Earth, Georgia Women's Action for New Directions, Green States Solutions, Hudson River Sloop Clearwater, Missouri Coalition for the Environment, NC WARN, Nevada Nuclear Waste Task Force, New England Coalition, No Nukes Pennsylvania, Northwest Environmental Advocates, Nuclear Energy Information Service, Nuclear Information and Resource Service, Nuclear Watch South, Physicians for Social Responsibility,- Public Citizen, Promoting Health and Sustainable Energy, Radiation and Public Health Project, Riverkeeper, SEED Coalition, San Clemente Green, San Luis Obispo Mothers for Peace, Sierra Club Nuclear Free Campaign, Snake River Alliance, Southern Alliance for Clean Energy, and Vista 360.
2NRC, 2013a.
3 NRC, 2013b.
4NRC, 2013b, page iii.
 
Thompson Declaration: Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 2 of 120 nuclear fuel (spent fuel) at at-reactor and away-from-reactor sites until a repository is available."
(1-3) NRC states that it has prepared the draft GEIS to support a proposed rule. The proposed rule is the most recent of a sequence of formal NRC findings, over several decades, about waste confidence. In this context, the term "waste" refers to spent nuclear fuel (SNF) or other forms of high-level radioactive waste (HLW) arising from the operation of commercial nuclear reactors.
(1-4) In a declaration dated 2 January 2013, I set forth 22 recommendations for the scope of the draft GEIS, together with information and analysis to support those recommendations. 6 Hereafter, I refer to that declaration as the "Thompson scoping declaration". It accompanies this declaration as Exhibit #1. In the present declaration, I incorporate by reference the information, analysis, and recommendations provided in the Thompson scoping declaration.
(1-5) This declaration addresses selected issues. Absence of discussion of an issue in this declaration does not imply that I view the issue as insignificant, or that I have no professional opinion on the manner in which the issue has been addressed in the draft GEIS.
(1-6) The issues discussed in this declaration are outlined in Section III, below. These issues all pertain to the concept of radiological risk, whose definition is discussed in Section IV, below. In this declaration the term "radiological risk" refers to the potential for harm to humans as a result of unplanned exposure to ionizing radiation. The consequences of this exposure could be direct or indirect. In the context of the draft GEIS, the set of direct and indirect consequences constitutes a set of environmental impacts.
(1-7) When spent fuel is discharged from a reactor of the type now used in the USA, it is initially stored under water in a pool adjacent to the reactor. The fuel assemblies are held upright in racks sitting on the floor of the pool. At each commercial reactor in the USA, the adjacent pool is now equipped with high-density, closed-frame racks. The nuclear industry began installing these racks in the 1970s, to replace the low-density, open-frame racks previously used. The high-density racks offered a comparatively cheap option for storing a growing nationwide inventory of spent fuel.
(1-8) At each commercial reactor in the USA, fuel takes the form of long, narrow tubes made of zirconium alloy (i.e., zircaloy), containing uranium oxide pellets. A group of these tubes makes up a fuel assembly. The zircaloy tubes are often referred to as fuel "cladding". Zircaloy has the property that at a comparatively high temperature (e.g.,
SNRC, 2013c.
6 Thompson,  2013b.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 3 of 120 about 900 'C) it can begin reacting exothermically (i.e., with production of heat) with either air or steam.
(1-9) Spent fuel generates internal heat from decay of radioactive isotopes. When the fuel is under water in a normally functioning pool, the decay heat enters the surrounding water, which is in turn cooled by pumping it through heat exchangers. However, if the water level were to fall below the top of the fuel, the fuel temperature would begin to rise. This temperature rise would be exacerbated by storage of spent fuel in high-density, closed-frame racks, as is now universally practiced in the USA. The fuel temperature could continue rising to the point at which an exothermic reaction of zircaloy with air or steam would begin. That reaction could then accelerate, in a runaway process. In this manner, loss of water from a pool could lead to a self-propagating exothermic reaction of zircaloy cladding with air or steam. That phenomenon is often referred to as a "pool fire". Conditions determining the onset and progression of a pool fire would include the timing of water loss and the level of decay heat production in the fuel. The level of decay heat production declines with increasing age of the fuel after discharge from a reactor.
(I-10) As part of its consideration of radiological risk, the draft GEIS considers the potential for a pool fire. Later in this declaration, I show that the draft GEIS is deficient in its examination of both the probability and the consequences of a pool fire. In examining these matters, the draft GEIS cites a number of studies that NRC has performed in the context of pool fires.
(I-11) In June 2013, NRC published a draft version of a pool-fire study that is not cited in the draft GEIS. That study is titled "Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a US Mark I Boiling Water Reactor".7 Hereafter, I refer to that study as "NRC's draft consequence study". It accompanies this declaration as Exhibit #2. In a declaration dated 1 August 2013, I provided a critical review of NRC's draft consequence study, with recommendations for further NRC investigation in this area. 8 Hereafter, I refer to that declaration as the "Thompson draft consequence declaration". It accompanies this declaration as Exhibit #3. In the present declaration, I incorporate by reference the information, analysis, and recommendations provided in the Thompson draft consequence declaration. NRC's draft consequence study was re-published in final form in October 2013, with no substantial change. 9 Thus, my critical review of the draft study had no effect on the final study. I assume that the technical parts of the draft and final versions are identical. Thus, the Thompson draft consequence declaration applies equally to both.
7 Barto et al, 2013a.
8Thompson,    2013a.
9The October 2013 version is: Barto et al, 2013b. It was published as an enclosure under the SECY memo: Satorius, 2013a. That memo stated: "None of the comments or responses [i.e., on the draft version of the study] has necessitated making substantial dhanges to the report." (See:
Satorius, 2013a, page 3.)
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 4 of 120 (1-12) The draft GEIS assumes that spent fuel will be stored initially in pools and subsequently in dry casks. The potential for a pool fire has been mentioned above. There is also a potential for a "cask fire". Such an event could occur if a malevolent actor gains access to a dry cask containing spent fuel and attacks the cask in a manner that produces a self-propagating reaction between air and zircaloy fuel cladding. Later in this declaration, I address the probability and consequences of a cask fire.
(1-13) As mentioned in paragraph 1-6, above, the issues discussed in this declaration all pertain to radiological risk. Accordingly, I focus my comments on the draft GEIS on selected portions of that document. Portions of the draft GEIS that I address include, but are not limited to:
* Section 4.18 - Environmental Impacts of Postulated Accidents
* Section 4.19 - Potential Acts of Sabotage or Terrorism
* Appendix F - Spent Fuel Pool Fires (1-14) As mentioned in paragraph 1-2, above, this declaration has been prepared on behalf of a group of environmental organizations. This declaration complements three other declarations - by Arjun Makhijani, David Lochbaum, and Mark Cooper - prepared on behalf of the same group of environmental organizations.
(1-15) This declaration has the following narrative sections:
I.      Introduction II. My Professional Qualifications III. Issues Discussed in this Declaration IV.      Definition of Radiological Risk V.      Estimation of Radiological Risk VI.      Malevolent Acts and Radiological Risk VII. The Future Risk Environment VIII. Linkage of Pool Risk and Reactor Risk IX. Risk Implications of Nuclear-Power Scenarios X.      Pool Fire: Probability and Consequences XI. Cask Fire: Probability and Consequences XII. Risk-Reducing Options XIII. Conclusions (I-16) In addition to the above-named narrative sections, this declaration has four appendices that are an integral part of the declaration. Appendix A contains tables and figures that support the narrative. Appendix B is a bibliography. Documents cited in the narrative or in Appendix A are listed in Appendix B unless otherwise identified.
Appendix C is a list of exhibits that accompany this declaration. Each exhibit is a document that is listed in Appendix B. My curriculum vitae is provided in Appendix D.
 
Thompson Declaration:Comments on NRC's September.2013 Draft GElS on Waste Confidence Page 5 of 120 II. My Professional Qualifications (11-1) As stated in paragraph I-1, above, I am the executive director of the Institute for Resource and Security Studies. In addition, I am a senior research scientist at the George Perkins Marsh Institute, Clark University. My curriculum vitae is provided here in Appendix D.
(11-2) I received an undergraduate education in science and mechanical engineering at the University of New South Wales, in Australia, and practiced engineering in Australia in the electricity sector. Subsequently, I pursued graduate studies at Oxford University and received from that institution a Doctorate of Philosophy in mathematics in 1973, for analyses of plasma undergoing thermonuclear fusion. During my graduate studies I was associated with the fusion research program of the UK Atomic Energy Authority. My undergraduate and graduate work provided me with a rigorous education in the methodologies and disciplines of science, mathematics, and engineering.
(11-3) My professional work involves technical and policy analysis in the fields of energy, environment, sustainable development, human security, and international security. Since 1977, a significant part of my work has consisted of analyses of the radiological risk posed by commercial and military nuclear facilities. These analyses have been sponsored by a variety of non-governmental organizations and local, state and national governments, predominantly in North America and Western Europe. Drawing upon these analyses, I have provided expert testimony in legal and regulatory proceedings, and have served on committees advising US government agencies.
(11-4) To a significant degree, my work has been accepted or adopted by relevant governmental agencies. During the period 1978-1979, for example, I served on an international review group commissioned by the government of Lower Saxony (a state in Germany) to evaluate a proposal for a nuclear fuel cycle center at Gorleben. I led the subgroup that examined radiological risk and identified alternative options with lower risk.' 0 One of the risk issues that I personally identified and analyzed was the potential for a pool fire. In examining that potential, I identified partial loss of water from a pool as a more severe condition than total loss of water. I identified a variety of events that could cause loss of water from a pool, including aircraft crash, sabotage, neglect, and acts of war. Also, I identified and described alternative SNF storage options with lower risk; these lower-risk options included design features such as spatial separation, natural cooling, and underground vaults. The Lower Saxony government accepted my findings about the risk of a pool fire, and ruled in May 1979 that high-density pool storage of spent fuel was not an acceptable option at Gorleben.11 That ruling accompanies this declaration as Exhibit #4. As a direct result of that ruling, policy throughout Germany 10 Beyea et al, 1979.
11Albrecht, 1979.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 6 of 120 has been to use dry storage in casks, rather than high-density pool storage, for away-from-reactor storage of SNF.
(11-5) Since 1979, I have been based in the USA. During the subsequent years, I have been involved in a number of NRC regulatory proceedings related to the radiological risk posed by storage of SNF. In that context I have prepared a number of declarations and expert reports. For example, in 2009 1prepared a report that critiqued proposed NRC findings on waste confidence.' 2 That report accompanies this declaration as Exhibit #5.
Also, I co-authored a 2003 journal article, on SNF radiological risk, that received considerable attention from relevant stakeholders.' 3 That article accompanies this declaration as Exhibit #6. The findings in that article were generally confirmed by a subsequent report by the National Research Council.14 That report accompanies this declaration as Exhibit #7. As a result of my cumulative experience, I am generally familiar with: (i) US practices for managing SNF; (ii) the radiological risk posed by those practices; (iii) NRC regulation of that risk; and (iv) alternative options for reducing that risk. Also, I am familiar with the US effort since the 1950s to implement final disposal of SNF and HLW, and have written a review article on that subject. 15 That article accompanies this declaration as Exhibit #8.
(11-6) I have performed a number of studies on the potential for commercial or military nuclear facilities to be attacked directly or to experience indirect effects of violent conflict. A substantial part of that work relates to the radiological risk posed by storage of SNF or HLW. For example, in 2005 I was commissioned by the UK government's Committee on Radioactive Waste Management (CORWM) to prepare a report on reasonably foreseeable security threats to options for long-term management of UK radioactive waste. 16 That report accompanies this declaration as Exhibit #9. The time horizon used in that report was, by CORWM's specification, 300 years.
(11-7) On behalf of the Nautilus Institute, I prepared a handbook that analysts in various countries could use to support their assessment of radiological risk arising from management of spent fuel.' 7 That handbook accompanies this declaration as Exhibit #10.
III. Issues Discussed in this Declaration (111-1) The primary purpose of this declaration is to provide comments on the draft GEIS, regarding selected issues. These issues all pertain to radiological risk, with a focus on the potential for a pool fire or a cask fire. The definition of radiological risk may appear to be an academic matter, but it has substantial practical implications. I discuss this matter in Section IV, below, explaining why I reject the definition employed in the 12  Thompson, 2009.
13 Alvarez et al, 2003.
14 National Research Council, 2006.
15 Thompson, 2008.
16 Thompson, 2005.
17 Thompson, 2013c.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 7 of 120 draft GEIS. In addressing radiological risk in this declaration, I focus on the potential for an unplanned release of radioactive material, especially an atmospheric release. Within that focus, I consider two categories of initiating event for the release: (i) accidents; and (ii) attacks. Accidents would involve events such as equipment failure, human error, or natural forces (e.g., earthquake). Attacks would involve deliberate, malevolent acts or the collateral effects of such acts. Accidents and attacks have features in common.
Therefore, they should be considered in parallel, which is the approach I take in this declaration.
(111-2) Analysts who examine the radiological risk associated with potential attacks affecting nuclear facilities have a double duty. First, they owe the public an accurate, general picture of the risk. Second, they should refrain from publishing information that could directly assist a potential attacker. This declaration is designed to meet both requirements. Also, this declaration does not purport to provide an assessment of radiological risk. Instead, it comments on the risk assessment provided in the draft GEIS.
From that perspective this declaration is, I believe, accurate and reasonably complete. At the same time, this declaration does not provide information that could directly assist an attack on a particular nuclear facility. Accordingly, this declaration is appropriate for general distribution.
(111-3) After radiological risk is properly defined, one can identify quantitative and qualitative indicators that, taken together, describe the risk in a particular situation. Then, analysts can seek to estimate values for those indicators. The resulting set of values constitutes a risk assessment. Section V, below, discusses approaches that can be used to estimate the values of relevant indicators. In that discussion I describe the strengths and limitations of probabilistic risk assessment (PRA), which provides the basis for the draft GEIS'si estimation of radiological risk.
(111-4) Section VI, below, provides some background discussion on the contribution of malevolent acts (i.e., attacks) to radiological risk. Section VII provides some background discussion on the "risk environment", a term that refers to the array of societal, technical, and natural factors that, taken together, have significant influence on the radiological risk posed by a particular facility. Those discussions inform this declaration's critique, in Sections X and XI and elsewhere, of risk assessment in the draft GELS.
(111-5) The potential for a pool fire can be affected by the potential for a radioactive release from a nearby, operational reactor, and vice versa. In other words, the radiological risks associated with a pool and with a nearby reactor can be linked. Section VIII discusses the nature and significance of this linkage, and its neglect in the draft GEIS. The linkage is discussed further in Section X.
(111-6) The development of waste-related radiological risk over future decades would be affected by the nature and scale of activity in the country's nuclear-power sector during that period. Section IX discusses the risk implications of nuclear-po6wer scenarios, and NRC's neglect of this issue in the draft GELS.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 8 of 120 (111-7) Section X provides a critical review of the assessment of pool-fire risk in the draft GELS, in terms of probability and consequences. Section XI discusses the probability and consequences of a cask fire, and NRC's neglect of this threat in the draft GEIS.
(111-8) Section XII discusses options for reducing waste-related radiological risk, and NRC's neglect of these options in the draft GEIS.
(111-9) Conclusions are presented in Section XIII.
IV. Definition of Radiological Risk (IV-1) In this declaration, I define the general term "risk" as the potential for an unplanned, undesired outcome. Risk, so defined, is an inevitable part of human existence. However, many aspects of risk can be managed. That is especially true when the risk arises from a technological project. In such a case, the first step in risk management is to understand, as deeply as possible, the risk arising from the project. The second step is to identify and characterize a range of options for reducing the risk. The remaining steps are to choose, implement, and follow up a set of risk-reducing options.
(IV-2) Table IV- I shows some categories of risk that could be posed by a commercial nuclear facility. I define radiological risk as the potential for harm to humans as a result of unplanned exposure to ionizing radiation. The exposure could arise from unplanned release of radioactive material, or from line-of-sight exposure to unshielded radioactive material or a criticality event. In this declaration I focus on exposure arising from an unplanned release, especially an atmospheric release. That mode of exposure would typically dominate the radiological risk posed by storage of SNF or HLW, at least during the first few centuries of storage.
(IV-3) By defining radiological risk as "the potential for harm", I do not mean to imply that any single indicator can adequately describe this risk. To the contrary, assessment of radiological risk requires the compiling of a set of qualitative and quantitative information about the likelihood and characteristics of the unplanned exposure and resulting harm. The required information can be expressed as values of qualitative and quantitative indicators.
(IV-4) NRC has articulated several, inconsistent definitions of risk. The definition in the NRC Glossary is, on its face, similar to my definition. Other NRC definitions, discussed below, deviate from the NRC Glossary to the point where they become fundamentally flawed. The NRC Glossary defines risk as:l 18 NRC website, http://www.nrc..iov/reading-rni/basic-ref/glossa-\/risk.html, accessed on 21 October 2013.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 9 of 120 "The combined answer to three questions that consider (1) what can go wrong, (2) how likely it is, and (3) what its consequences might be. These three questions allow the NRC to understand likely outcomes, sensitivities, areas of importance, system interactions, and areas of uncertainty, which can be used to identify risk-significant scenarios."
(IV-5) In the draft GEIS, the concept of risk is first introduced using a definition close to, but not identical with, the definition in NRC's Glossary. The Executive Summary of the draft GEIS says:19 "NRC's concept of risk combines the probabilityof an accident with the consequences of that accident. In other words, the NRC examines the following questions:
* What can go wrong?
                  "How likely is it?
                  "What would be the consequences?"
(IV-6) Later in the draft GEIS, the definition of risk deviates further from NRC's Glossary and becomes fundamentally flawed. In Section 4 of the draft20 GEIS, this later definition is embedded in an instructive paragraph. The paragraph is:
          "The consequences of a severe (or beyond-design-basis) accident, if one occurs, could be significant and destabilizing. The impact determinations for these accidents, however, are made with consideration of the low probability of these events. The environmental impact determination with respect to severe accidents, therefore, is based on the risk, which the NRC defines as the product of the probability and the consequences of an accident. This means that a high-consequence low-probability event, like a severe accident, could still result in a small impact determination, if the risk is sufficiently low."
(IV-7) Through this deviation, NRC has ended up with a particular, limited definition of risk, as the arithmetic product of a numerical indicator of harmful consequences and a numerical indicator of the probability that those consequences will occur.21 I refer to that definition hereafter as the "arithmetic" definition of risk. The arithmetic definition is flawed from several perspectives, as discussed below. It is, however, used extensively in the nuclear industry.
(IV-8) The above-quoted paragraph from the draft GElS suggests a powerful motive for use of the arithmetic definition of risk. Consider the following situation. The consequences of a potential event could be severe; indeed, they could be "significant and
'9 NRC, 2013b, page xxx.
20 NRC,  2013b, pages 4-68 and 4-69 (emphasis added).
21 Often, the arithmetic product is calculated for each of a range of scenarios, and these products are summed across the scenarios to yield an overall "risk".
 
Thompson Declaration:Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 10 of 120 destabilizing", to use the words of the draft GEIS. Yet, if the event has, allegedly, a sufficiently low probability, then its "risk", arithmetically defined, would be very low. A devotee of the arithmetic definition could then argue that no action is required to mitigate the risk. In that way, the cost of mitigating actions would be avoided.
(IV-9) In the context of radiological risk in the commercial nuclear sector, the arithmetic definition of risk is flawed from at least four overlapping perspectives:
* First, numerical estimates of consequences and probability are typically incomplete and highly uncertain.
* Second, significant aspects of consequences and probability are not susceptible to numerical estimation.
* Third, larger consequences can be qualitatively different than smaller consequences.
      " Fourth, devotees of the arithmetic definition typically argue that equal levels of "risk", as they define it, should be equally acceptable to citizens. Their argument may be given a scientific gloss, but is actually a statement laden with subjective values and interests. An informed citizen could reject their argument on reasonable grounds.
(IV-10) I address the first and second of these four perspectives in Section V, below, and elsewhere in this declaration. I address the third and fourth perspectives in the remainder of Section IV, and elsewhere in this declaration.
(IV- 11) The third perspective is that larger consequences can be qualitatively different than smaller consequences. There is ample evidence to support this proposition. For example, analysts at the French government's Institut de Radioprotection et de Surete Nucleaire (IRSN) have found a qualitative difference between larger and smaller radiological consequences. The IRSN analysts estimated the costs (i.e., economic damage) that would arise from an accidental, atmospheric release of radioactive material from the Dampierre nuclear generating station in France. They considered two types of release - a "controlled" (smaller) and a "massive" (larger) release. A paper summarizing their findings was presented at the 2012 Eurosafe conference.22 That paper accompanies this declaration as Exhibit #11.
(IV- 12) The IRSN analysts concluded that the costs arising from a massive release would differ "profoundly" from the costs arising from a controlled release, in terms of both qualitative and quantitative factors. Indeed, they described the massive release as "an unmanageable European catastrophe". Their paper concluded with the statement: 23 "Safety decisions may also be informed by this picture, in particular if it is realized that the most severe cases actually carry huge stakes for the nation and 22 Pascucci-Cahen and Patrick, 2012.
23 Pascucci-Cahen and Patrick, 2012.
 
I Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 11 of 120 therefore that their lower probability may not balance their catastrophic potential."
(IV-1 3) To illustrate the potential for qualitative difference between larger and smaller consequences, consider the IRSN description of a massive release as "an unmanageable European catastrophe". Underlying that description is the potential for major socio-political impacts that would, in Europe, have substantial trans-boundary dimensions. The European Union might not survive the political stress arising from this event.
(IV-14) There is strong evidence that the 1986 Chernobyl accident was a principal cause of the dissolution of the Soviet Union. Political unrest related to the accident was noted in a 1987 paper by the US Central Intelligence Agency. That paper accompanies this declaration as Exhibit #12. The paper's concluding statement was:24 "As public dissatisfaction grows, the Chernobyl' accident may provide a focal point around which disgruntled citizens can organize, and Moscow may discover that Chernobyl' is a continuing irritant with a potential for social and ethnic tensions for years to come."
(IV-15) Public dissatisfaction did indeed grow, and the Warsaw Pact and the Soviet Union dissolved in 1991. Mikhail Gorbachev, the'last head of state of the Soviet Union, confirmed in a 2006 essay that the Chernobyl accident was a principal cause of the Union's dissolution. That essay accompanies25this declaration as Exhibit #13.
Gorbachev's essay began with the statement:
            "The nuclear meltdown at Chernobyl 20 years ago this month, even more than my launch ofperestroika,was perhaps the real cause of the collapse of the Soviet Union five years later. Indeed, the Chernobyl catastrophe was an historic turning point: there was the era before the disaster, and there is the very different era that has followed."
(IV- 16) The full array of consequences of a large, atmospheric release of radioactive material from a nuclear facility in the United States is difficult to predict. The nature and scale of those consequences would vary according to the characteristics of the release and other factors. It is clear, however, that there are unresolved socio-political tensions in this country. Thus, the consequences of a large release could include substantial political stress. It is unlikely that aggrieved citizens would be comforted if they learned that NRC had determined, at a prior time, that the release was a low-risk event.
(IV- 17) As mentioned above, the arithmetic definition of risk is used extensively in the nuclear industry, despite its flaws. It is also used in other contexts. One manifestation of this definition is the "probability-threshold position" on risk. Supporters of that position 24 CIA, 1987.
25 Gorbachev, 2006.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 12 of 120 argue that levels of risk below some numerical threshold can be ignored. That position means, in effect, that risks below the threshold are assigned a value of zero. The threshold might be, for example, an average probability of human fatality of 1x10-6 per annum. The probability-threshold position has been critiqued in a paper by the philosopher Kristin Shrader-Frechette. 26 That paper accompanies this declaration as Exhibit #14. Shrader-Frechette found that arguments for the probability-threshold position are fundamentally flawed.
(IV-18) Devotees of the arithmetic definition of risk often claim that their position is "scientific" and "rational". It is neither. The arithmetic definition is laden with subjective values and interests, and is prone to abuse. It is given a scientific gloss because it is expressed in numbers. However, the neatness of its numerical expression is achieved by ignoring significant factors that are not susceptible to numerical assessment.
Ignoring such factors is the antithesis of a scientific approach. Moreover, the arithmetic definition pre-empts important ethical considerations, such as the tolerability of large consequences. Accordingly, the Thompson scoping    27 declaration offered the following recommendation,      which  I continue to endorse:
          "Recommendation #21: In considering radiological risk, the proposed EIS [i.e.,
the draft GEIS] should repudiate the arithmetic definition of risk."
V. Estimation of Radiological Risk (V-1) For many societal hazards, such as automobile accidents, there is a rich body of data on actual incidents. In these cases, statistical methods can be used to predict probability. Also, in cases where the consequences are well defined, as is true for most automobile accidents, statistics can be used to predict consequences.
(V-2) The hazard of interest in this declaration is an unplanned release of radioactive material from a commercial nuclear facility. More specifically, the unplanned release contemplated here would be substantially larger than the authorized, routine release from a facility over a period of a year or so. There is, fortunately, a limited body of experience with unplanned releases of this nature. Thus, statistics cannot be used to predict probability or consequences.
(V-3) In the absence of reliable statistics, other approaches to radiological risk assessment must be taken. Three approaches are discussed here:
* Probabilistic risk assessment
* Direct experience
* Insurers' judgment 26 Shrader-Frechette, 1985.
27 Thompson, 2013b, Sections IX and X.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 13 of 120 (V-4) The great majority of experience with radiological risk assessment for commercial nuclear facilities is for reactors. Thus, I provide here a discussion of reactor risk assessment. This discussion shows the strengths and limitations of PRA, which provides the basis for estimation of radiological risk in the draft GEIS. Moreover, spent-fuel-pool risk is strongly linked with reactor risk, as shown in Section VIII, below.
(V-5) Figures V-1 through V-3 show PRA findings for two commercial reactors - a pressurized-water reactor (PWR) at the Surry site, and a boiling-water reactor (BWR) at the Peach Bottom site. Figures V-I and V-2 show the estimated probability of an accident involving substantial damage to the reactor core. Such damage would involve melting of some or all of the fuel in the core. The probability is expressed as core damage frequency (CDF) per reactor-year (RY). Figure V-3 shows the estimated conditional probability (i.e., probability given core damage) of various types of containment failure. A failure of containment would lead to a release of radioactive material to the atmosphere. The earlier the failure, the larger the release, other factors being equal.
(V-6) The findings shown in Figures V-I through V-3 are from NRC's NUREG- 1150 study.28 That study was the high point of PRA practice worldwide. The study was well funded, involved many experts, was conducted in an open and transparent manner, was done at Level 3 (i.e., with estimation of offsite consequences), considered internal and external initiating events, explicitly propagated uncertainty through its chain of analysis, was subjected to peer review, and left behind a large body of published documentation.
While there are deficiencies in the NUREG- 1150 findings, these could be corrected by fresh analysis and the use of new information. The process of correction is possible because the NUREG- 1150 study was conducted openly and left a documentary record.
(V-7) PRA practice in the USA has degenerated since the NUREG-1 150 study. Now, PRAs or similar studies are conducted mostly by the nuclear industry, with limited transparency. NRC formerly sponsored independent reviews of industry PRAs, but no longer does so. Recent NRC work on PRA has not attained the scope, quality of review, and other aspects of NUREG-1 150 that are mentioned in paragraph V-6.
(V-8) The first reactor PRA was the NRC's Reactor Safety Study (RSS). 29 NRC set up a group of experts, chaired by the physicist Harold Lewis, to review the RSS. Their report accompanies this declaration as Exhibit # 15. In their report, the review group succinctly described the challenge of developing a credible PRA as follows:"
        "RSS was faced with the problem of estimating the probability of occurrence of an extremely rare event - core melt - in a system of great complexity, a nuclear power reactor. Since the event has never occurred in a commercial reactor, there 28 NRC,  1990.
29 NRC, 1975.
30 Lewis et a], 1978, page 6.
 
Thompson Declaration. Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 14 of 120 are no direct experimental data on which to base an estimate. The only datum that exists is the observation that there have been no core melts [as of 1978] in several hundred reactor-years of light water power reactor operation, and this fact provides at best an upper bound on the probability to be estimated. Therefore, it is necessary to resort to a theoretical calculation of the probability. But since the system is so complex, a complete and precise theoretical calculation is impossibly difficult. It is consequently necessary to invoke simplified models, estimates, engineering opinion, and in the last resort, subjective judgments."
(V-9) The preparation of a "complete and precise theoretical calculation" of core damage frequency remains "impossibly difficult" today, just as it was when Lewis and his colleagues wrote in 1978. This difficulty is intrinsic to the complexity of a reactor and the large number of potential failure modes. The difficulty is compounded when PRA analysts move from estimation of CDF (Level 1) to estimation of radioactive release (Level 2) and to estimation of offsite consequences (Level 3). At Level 2 there are many phenomenological uncertainties and variabilities. At Level 3 there is great variation in a variety of factors, such as atmospheric characteristics, and basic difficulties in characterizing indirect consequences. Thus, the radiological risk posed by a reactor is much more uncertain than other technological risks that are readily susceptible to actuarial analysis (e.g., automobile accidents).
(V-10) The complexity of a reactor is not the only reason why PRA findings are uncertain. Another reason is that a PRA examines an idealized system. The idealized system is properly designed, properly built, properly operated, and composed of independent components that typically fail randomly. PRA analysts have recognized that component failures may not always be independent. In response, they have developed analytic techniques to account for "common mode" failures that are attributable to influences (e.g., an earthquake, or a maintenance error) that can simultaneously affect more than one component. Although these techniques are useful, they leave some significant threats unaddressed.
(V- 11) Three exemplary threats show how the idealized system examined in a PRA can be an incomplete representation of reality. First, a PRA cannot account for gross errors in design, construction, or operation. Second, it cannot account for malevolent acts.
Third, it cannot account for deficiencies in institutional culture and practice. Each threat is significant. All three threats can lead to common mode failures. PRA's inability to account for malevolent acts is notable because a malevolent human intellect can identify weak points in a system, and can exploit destructive forces that are latent in the system.
(V- 12) Reactor core-melt accidents have occurred at the Three Mile Island (TMI) site in 1979, the Chernobyl site in 1986, and the Fukushima #1 site in 2011. In each instance, retrospective investigations identified dominant risk factors that were non-quantifiable and could not have been accounted for in a PRA. These factors reflected, in differing ways, substantial deficiencies in institutional culture and practice. The three instances are discussed in the following three paragraphs.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 15 of 120 (V-13) A commission, chaired by John Kemeny, was established by US President Carter to investigate the TMI accident. The commission's report accompanies this declaration as Exhibit # 16. The commission concluded that systemic deficiencies in human behavior and organization were the dominant causes of the accident. To illustrate, their report included the statement:31 "We are convinced that if the only problems were equipment problems, this Presidential Commission would never have been created. The equipment was sufficiently good that, except for human failures, the major accident at Three Mile Island would have been a minor incident. But, wherever we looked, we found problems with the human beings who operate the plant, with the management that runs the key organization, and with the agency that is charged with assuring the safety of nuclear power plants."
(V-14) Two Harvard University physicists, one of whom had previously worked in a reactor physics group in the USSR, published a paper in 1992 that examined the Chernobyl accident. Their paper  3 accompanies this declaration as Exhibit # 17. The abstract of their paper stated: 2 "The Chernobyl accident was the inevitable outcome of a combination of bad design, bad management and bad communication practices in the Soviet nuclear industry. We review the causes of the accident, its impact on Soviet society, and its effects on the health of the population in the surrounding areas. It appears that the secrecy that was endemic in the USSR has had profound negative effects on both technological safety and public health."
(V-1 5) The National Diet (i.e., parliament) of Japan established an independent commission to investigate the Fukushima accident. The executive summary of their report accompanies  33 this declaration as Exhibit #18. The commission's principal conclusion was:
          "The TEPCO Fukushima Nuclear Power Plant accident was the result of collusion between the government, the regulators and TEPCO, and the lack of governance by said parties. They effectively betrayed the nation's right to be safe from nuclear accidents. Therefore, we conclude that the accident was clearly "manmade". We believe that the root causes were the organizational and regulatory systems that supported faulty rationales for decisions and actions, rather than issues related to the competency of any specific individual."
"' Kemeny et al, 1979, page 8.
32 Shlyakhter and Wilson, 1992.
33 Diet, 2012, page 16.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 16 of 120 (V-16) The combined experience of these three incidents strongly suggests that a non-quantifiable factor, which cannot be accounted for in a PRA, will be a major or dominant risk factor underlying the next core melt at a commercial nuclear reactor. Thus, reliance on PRA to estimate the probability of the next core melt would be neither reasonable nor prudent.
(V-17) One might expect that responsible authorities would learn from these three incidents, and ensure that hitherto neglected risk factors are considered in future assessments of radiological risk. However, a paper by the sociologist John Downer shows that entrenched institutional cultures in the nuclear industry can suppress learning and promote the continuation of favored narratives. Downer's paper accompanies    34 this declaration as Exhibit #19. The paper's conclusion begins with the statement:
        "The disaster-punctuated history of nuclear power ought to speak for itself about the limitations of risk assessments, but our narratives obfuscate that history by rationalizing it away. For experience can only "show" if we are willing to "see,"
and the lessons of Fukushima, like those of the accidents that preceded it, will always be opaque to us if our narratives consistently interpret it as exceptional.
So it is that even as the dramas of Fukushima linger, and in some ways intensify, the Ideal of Mechanical Objectivity survives with its misleading impression that expert calculations can objectively and precisely reveal the "truth" of nuclear risks. This has critical policy implications."
(V-18) Another approach to assessing radiological risk is to examine direct experience.
In the case of a reactor, the most relevant experience consists of incidents in which a reactor core suffered severe damage. The next most relevant experience consists of incidents in which the core could have suffered severe damage if the incident had continued to develop. NRC categorizes incidents of the second type as accident sequence precursors (ASPs).
(V-19) Testimony to the US Senate by Thomas Cochran, soon after the Fukushima accident, listed twelve incidents involving severe damage to fuel in the core of a power reactor. 35 Cochran's testimony accompanies this declaration as Exhibit #20. His list of incidents excludes similar incidents at non-power reactors. For example, it excludes the core fire and radioactive release experienced in 1957 by a reactor at the Windscale site in the UK. That reactor was used to produce plutonium and other materials for nuclear weapons.
(V-20) Of the twelve core-damage incidents at power reactors, five have both: (i) occurred at a Generation II commercial reactor; and (ii) involved substantial fuel melting.
These five incidents were at TMI Unit 2 (a PWR) in 1979, Chernobyl Unit 4 (an RBMK) in 1986, and Fukushima #1 Units 1 through 3 (BWRs) in 2011. These incidents occurred 34 Downer, 2013, page 17.
35 Cochran, 2011.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 17 of 120 in a worldwide fleet of commercial reactors. About 430 reactors are currently operable, although none of Japan's 50 nominally operable reactors is actually operating at present.
Currently-operating reactors and previous reactors in the worldwide fleet had accrued 14,760 RY of operating experience as of February 2012.36 Thus, about 15,500 RY of experience will be accrued through 2013.
(V-21) These five core-melt incidents provide a data set that is comparatively sparse and therefore does not provide a statistical basis for a high-confidence estimate of CDF.
Nevertheless, this data set does provide a reality check for PRA estimates of CDF. From this data set - five core-melt incidents over a worldwide experience base of about 15,500 RY - one observes a CDF of 3.2x10-4 per RY (1 event per 3,100 RY). This value can be regarded as a "simple" estimate of CDF.
(V-22) A PRA analyst employed by NRC, Raymond Gallucci, has written a paper that develops CDF estimates based on direct experience. 37 Gallucci's paper accompanies this declaration as Exhibit #21. The paper considers both reactor core-melt and ASP experience, leading to a "simple" CDF estimate of 6.Oxl104 per RY (1 event per 1,700 RY). The paper does not adopt that estimate. Instead, it makes some analytic assumptions, and ultimately concludes that CDF, worldwide and in the USA, is in the range 0.7x10-4 to 4.0x10 4 per RY (between 1 event per 14,300 RY and 1 event per 2,500 RY). I question the assumptions underlying this downward adjustment of the "simple" CDF estimate. However, Gallucci's analysis deserves careful consideration in view of his professional expertise. On another note, Gallucci ends his paper by expressing his personal willingness to tolerate a CDF of the level that he has identified. On that matter, his opinion has no more weight than the opinion of any citizen.
(V-23) As shown in the preceding paragraphs, direct experience suggests a CDF as high as 6.0xl0.4 per RY. The lowest value in the range suggested by Gallucci is 0.7xl 0-4 per RY. It is instructive to compare these numbers with the CDF estimates shown in Figures V-I and V-2. The only CDF estimates in those figures that approach direct-experience levels are the upper-bound (95th percentile) levels of earthquake-caused CDF using Livermore seismic estimates. Thus, direct experience indicates that NUREG-1 150 substantially under-estimated CDF. This finding does not mean that NUREG-1 150 was a bad study. On the contrary, as stated above, NUREG- 1150 was the high point of PRA practice. My finding simply confirms that PRA cannot account for all of the factors that determine the probability component of radiological risk.
(V-24) CDF estimates are typically presented as the number of incidents per RY. These estimates could also be presented as the cumulative number of incidents across a fleet of reactors, during a calendar year or some other time interval. At present, there are 100 36 See: World Nuclear Association (WNA) website, http://www.world-nuclear.or,4. Data on cumulative reactor-years worldwide were obtained from the WNA website on 17 February 2012.
The WNA website no longer provides such data.
37 Gallucci, 2012.
 
Thompson Declaration: Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 18 of 120 licensed commercial reactors in the USA. Thus, a CDF of 3.2x1 0-4 per RY would be equivalent to a nationwide core-damage probability of 3.2x1 0-2 per calendar year (i.e., 3.2 percent per year). If that probability were sustained over decades, the occurrence of one or more core-damage incidents would become almost certain.
(V-25) Estimating the probability of core damage is just one step in assessing the radiological risk posed by a commercial reactor. Another step is to estimate the potential release of radioactive material to the environment. Figure V-3 illustrates a part of that step - estimating the conditional probability of failure of containment, given core damage. Additional steps include estimation of the movement of radioactive material in the environment, and estimation of the resulting consequences. As mentioned above, assessment of radiological risk involves the compiling of a set of qualitative and quantitative information about both probability and consequences.
(V-26) Direct experience provides some evidence regarding the release of radioactive material, its movement in the environment, and its impacts. Table V-I shows estimated amounts of the radioactive isotope Cs-137 that were released to the atmosphere during the Chernobyl and Fukushima accidents. Figure V-4 shows the distribution of Cs- 134 and Cs-137 isotopes deposited on Japan after being released to the atmosphere during the Fukushima accident. Table V-2 shows an estimate, by the US Department of Energy, of radiation dose commitment from the Chernobyl release.
(V-27) A paper by Sornette et al reveals the limitations of PRA findings by comparing them with lessons from direct experience. 38 That paper accompanies this declaration as Exhibit #22. The paper considers monetized losses from nuclear-facility incidents, using two sources of information. One source is a reactor PRA. The other source is a compilation of data on actual incidents at nuclear facilities. Figure V-5 of this declaration reproduces a figure from Somette et al. That figure shows that the PRA substantially under-estimates the probability of a monetized loss. The under-estimation grows as losses become larger. In other words, the PRA findings show a thin-tail probability distribution, whereas the empirical data show a fat-tail distribution.
(V-28) Two approaches to radiological risk assessment are discussed above - PRA, and direct experience. A third approach is to examine the judgment of nuclear-facility insurers. Such an examination is set forth in Tables V-3 and V-4. Table V-3 shows insurance premiums for the Darlington nuclear generating station in Canada, to cover liability for bodily injury or property damage at offsite locations. Table V-4 calculates an "implied probability of event", which represents the insurers' assessment of the              39 probability of a claim up to the liability limit, arising from an accident at Darlington.
(Events caused by malevolent acts are not considered in Table V-4.) If, for example, the liability limit is $1 billion, the implied probability of a claim up to that limit ranges from 6.4x10-4 to 1.0xl0 3 per.RY.
38 Sornette et al, 2013.
39 A claim up to the liability limit means that monetized impact exceeds the liability limit.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 19 of 120 (V-29) The calculations presented in Table V-4 show that, in the judgment of the Canadian nuclear insurers, the probability distribution of the monetized impact of an accident at Darlington is close to the distribution shown by the "Empirical Records" curve in Figure V-5. Evidently, the insurers are not persuaded by PRA findings, which show much lower probabilities. In 2012, Ontario Power Generation, the owner/operator      40 of the Darlington station, published the findings of a PRA it conducted for the station.
Those findings accompany this declaration as Exhibit #23. Findings of a previous PRA for Darlington were published in 1987.41 The 2012 PRA estimated the probability of a large, atmospheric release as 9.5x10-6 per RY, while the 1987 PRA estimated that probability as 8.2x10-7 per RY. The Canadian nuclear insurers have access to these PRA studies, but choose to set premiums at much higher levels than the PRAs would imply.
(V-30) At this point in Section V, I have shown that reactor PRAs typically yield estimates of probability (i.e., the probability of accident outcomes) that are substantially lower than is implied by direct experience and insurers' judgment. This finding carries over to PRAs for non-reactor facilities, because it arises from limitations in the art of PRA itself. Those limitations are significant for the draft GEIS, because the draft GEIS relies upon PRA findings for estimation of radiological risk.
(V-3 1) In 1989 1was a co-author of a critical review of the state of the art of PRA.42 The findings of that review remain generally valid today. One of the review's conclusions, with some refraining and updating to match the context of this declaration, provides a useful way to summarize the role of PRA in radiological risk assessment. The reframed and updated conclusion, which refers to a commercial reactor or to various other types of nuclear facility, is:
Actual probability of event = (PRA finding)x(Reality factor #1) + (Reality factor #2)
Where the variables in this equation are as follows:
    " "Actual probability of event" refers to the real-world numerical probability of an outcome such as: reactor core damage; release of a specified amount of radioactive material; contamination of a specified area of land above a specified dose threshold; or accrual of a specified collective dose to people offsite.
    * "PRA finding" refers to a PRA estimate of the probability of the outcome in question - this could be a mean, median, or other representation of a probability distribution.
    * "Reality factor #1" is a number, typically greater than 1, that represents influences that are within the paradigm of PRA but are not properly accounted for in contemporary PRAs - these influences include: complexity; inadequate data; and deficiencies in institutional culture and practice.
40 OPG, 2012.
41 Ontario Hydro, 1987.
42 Hirsch et al, 1989.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 20 of 120
    * "Reality factor #2" is a number that represents influences outside the paradigm of PRA - these influences include: gross errors in design, construction, or operation; and malevolent acts.
And the following observations apply:
* Experience suggests that Reality factor #1 for severe accidents may have a value that exceeds I by several orders of magnitude (i.e., factors of 10).
* Reality factor #2 has two numerical components: (i) a retrospective component that can be determined empirically based on the occurrence of events; and (ii) a prospective component that will remain unknown for the foreseeable future.
* Both Reality factors may vary significantly in response to variations in the future risk environment, as discussed in Section VII, below.
* This version of the equation is applicable when the values of "PRA finding" and "Actual probability of event" are both less than 1. At higher values, the term "probability" would be replaced by the term "frequency".
(V-32) The two Reality factors cannot be fully estimated by PRA techniques, although they may have components that can be estimated in that way. In cases where there is a record of direct experience - such as the occurrence of reactor core damage or the occurrence of ASPs - one can infer a range of values for the Reality factors, drawing upon PRA findings. If there is no record of direct experience of a hypothesized event, PRA findings can provide a kernel of information that can be adjusted by Reality factors that are judged appropriate to the situation. Thus, PRA findings can be valuable items of information. They are, however, only a guide to the assessment of probability, and are not definitive statements of that probability.
VI. Malevolent Acts and Radiological Risk (VI-1) The draft GElS makes assertions about the environmental impacts of malevolent acts affecting stored spent fuel. Later in Section VI, I identify those assertions. Then, in Sections X and XI, below, I critically review those assertions in the contexts of pool fires and cask fires. I begin Section VI by providing some background information about malevolent acts.
(VI-2) In the context of this declaration, it is noteworthy that NRC explicitly considered the impacts of malevolent acts in its 1979 GEIS on Handling and Storage of Spent Light Water Power Reactor Fuel, which was designated NUREG-0575.43 Potential malevolent acts were described in Appendix J of that GEIS. Appendix J accompanies this declaration as Exhibit #24. NRC stated its rationale for considering malevolent acts as 44 follows:
43 NRC, 1979.
44 NRC, 1979, Appendix J, pages J-2 and J-3.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 21 of 120 "The NRC staff is unable to determine the quantitative likelihood of a hypothetical malevolent act being successfully performed by an adversary group.
Instead, a group of selected reference events have been assumed to occur in order to establish a range of potential effects that might be caused by deliberate acts.
The consequences corresponding to these reference events were calculated on a per-fuel-element basis, thus allowing the results to be extrapolated to possibly include massive destructive acts and thereby develop an upper bound on estimates of potential consequences, regardless of the plausibility of the attempted acts."
(VI-3) To implement that rationale in NUREG-0575, NRC considered four types of "sabotage" event at a spent-fuel pool. Table VI-1 summarizes NRC's description of these types of event. One sees from Table VI- 1 that NRC envisioned an attack by up to 83 adversaries. The attackers could hold the control room for about one half hour. They could use explosive charges to breach the walls of the pool building or the floor of the pool itself.
(VI-4) NUREG-0575 did not consider the environmental impact            45 of pool fires. It dismissed the    potential for a  pool fire with the brief statement:
          "Assuming that the spent fuel stored at an independent spent fuel storage installation is at least one year old, calculations have been performed to show that loss of water should not result in fuel failure due to high temperatures if proper rack design is employed".
(VI-5) The citation for the "calculations" mentioned in that statement was to a report prepared by Sandia Laboratories for NRC, under the designation NUREG/CR-0649.46 That report accompanies this declaration as Exhibit #25. Careful examination of NUREG/CR-0649 shows that it did not support the interpretation placed upon it by NUREG-0575. In fact, NUREG/CR-0649 showed that partial loss of water from a spent-fuel pool could lead to a pool fire.47 The significance of partial loss of water is discussed further in Section X, below.
(VI-6) Thus, the authors of NUREG-0575 did not properly understand the potential for a pool fire. Accordingly, they failed to understand that the malevolent acts they postulated in Appendix J could, with slight adjustment, readily initiate a pool fire, as discussed in Section X, below. Nevertheless, NRC did postulate this set of malevolent acts in its 1979 GEIS. To my knowledge, NRC has never repudiated its postulation of these acts.
(VI-7) Since the 1970s, I have written numerous reports, declarations, and other documents that address malevolent acts as potential contributors to the radiological risk posed by reactors, spent-fuel-storage facilities, and other nuclear facilities. Documents in 45 NRC,  1979, page 4-21.
46 Benjamin et al, 1979.
47 See, for example, the "blocked inlets" curve in Figure 26 (at page 77)-of: Benjamin et al, 1979.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 22 of 120 this category that are mentioned up to this point in this declaration include: (i) a January 2013 declaration 48 (Exhibit #1); (ii) an August 2013 declaration49 (Exhibit #3); (iii) a February 2009 report5" (Exhibit #5); (iv) a November 2005 report 51 (Exhibit #9); and (v) a January 2013 handbook 52 (Exhibit #10). Here, I introduce two additional documents I have written that address malevolent acts at nuclear facilities. One document is a November 2007 report that discusses continued operation of the Indian Point nuclear power plants. 53 That report accompanies this declaration as Exhibit #26. The second document is a January 2003 report that discusses threats to spent fuel as a neglected issue of homeland security.54 That report accompanies this declaration as Exhibit #27. Each of the documents listed in this paragraph cites numerous documents prepared by diverse authors.
(VI-8) An August 2012 report prepared at the Congressional Research Service provides a succinct overview of policy, law, and regulation in the United States regarding the threat of malevolent acts at nuclear facilities."5 That report accompanies this declaration as Exhibit #28. A February 2012 report on the future of nuclear power in the United States, by authors including former NRC chair John Ahearne, contains an instructive chapter on the threat of malevolent acts. 56 That report accompanies this declaration as Exhibit #29. Also instructive is a 2007 journal article by staff of the US Environmental Protection Agency, on the sabotage vulnerability of nuclear power plants. 57 That article accompanies this declaration as Exhibit #30. Computer models have been developed to help assess the vulnerability of nuclear facilities to malevolent acts, as discussed in a 2006 journal article by Morris et al. 58 That article accompanies this declaration as Exhibit #31.
(VI-9) For convenience, this declaration includes some tables and figures that appear in one or more of the documents listed in paragraph VI-7, above. I refer here to Tables VI-2 through VI-5, and Figures VI-1 through VI-4. These tables and figures provide clear evidence that reactors and spent-fuel-storage facilities are vulnerable to attack, including attack by non-State actors. I could explain this evidence in detail, but choose not to provide that explanation in a document that is intended for general distribution.
48 Thompson, 2013b.
49 Thompson, 2013a.
50 Thompson, 2009.
51 Thompson, 2005.
52 Thompson, 2013c.
53 Thompson, 2007.
54 Thompson, 2003.
55 Holt and Andrews, 2012.
56 Aheame et al, 2012.
7Honnellio and Rydell, 2007.
58 Morris et al, 2006.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 23 of 120 (VI-10) The documents listed in paragraphs VI-7 and VI-8, the numerous citations within those documents, and the tables and figures identified in paragraph VI-9, provide a thoroughly documented basis for the following conclusions:
: 1. A reactor, spent-fuel-storage facility, or other nuclear facility in the United States could be attacked by a State or by a non-State actor.
: 2. A non-State actor could acquire the capability to execute an attack that releases to the environment a large amount of radioactive material from a reactor core or from stored spent fuel.
: 3. Storage of spent fuel at high density in a pool adjacent to an operating reactor is advantageous to an attacker, because this arrangement would help the attacker to obtain a large, radioactive release from the reactor and the pool.
: 4. The amount of radioactive material that would be released by an attack could exceed the amount that would be released by an accident.
: 5. NRC requires licensees to implement only a "light" defense of a nuclear facility, namely a defense that is designed to resist attacks within the lower end of the spectrum of severity of potential attacks.
: 6. NRC does not require any defense against attack from the air, although a non-State actor could execute such an attack.
: 7. Licensees routinely lobby NRC to reduce the scale of threat against which licensees are required to mount a defense.
: 8. Measures deployed by licensees to mitigate the effects of potential accidents would be ineffective in many scenarios of potential attack.
: 9. The probability of a successful attack cannot be estimated by statistical methods or by analytic arts such as probabilistic risk assessment.
: 10. In light of human history, observation of the contemporary world, and consideration of possible societal trends, a prudent decision maker would conclude that a successful attack on a reactor or spent-fuel-storage facility in the United States over the coming decades is as likely to occur as are major national challenges that are planned for, such as severe natural disasters or engagement in wars.
: 11. Options are available to reduce radiological risk arising from potential attacks.
: 12. The attack-related risk of storing spent fuel could be dramatically reduced by re-equipping spent-fuel pools with low-density, open-frame racks, and by otherwise storing spent fuel in protected dry casks.
: 13. Requiring licensees to implement options that substantially reduce the attack-related risk at nuclear facilities would enhance protective deterrence as a national strategy, with substantial benefits.
(VI-1 1) The draft GEIS addresses the potential for malevolent acts in its Section 4.19, titled Potential Acts of Sabotage or Terrorism. The Executive Summary of the draft GEIS addresses this potential in its Section ES. 13.1.19, also titled Potential Acts of Sabotage or Terrorism. In its Section 4.19, the draft GEIS has separate sub-sections that address attacks on spent-fuel pools, and attacks on independent spent fuel storage
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 24 of 120 installations (ISFSIs). The 59  draft GEIS summarizes its findings on the potential for malevolent    acts as follows:
        "The NRC finds that even though the environmental consequences of a successful attack on a spent fuel pool beyond the licensed life for operation of a reactor are large, the very low probability of a successful attack ensures that the environmental risk is SMALL. Similarly, for an operational ISFSI during continued storage, the NRC finds that both the probability and consequences of a successful attack are low, and therefore, the environmental risk is SMALL.
Therefore, the storage of spent fuel during continued storage will not constitute an unreasonable risk to the public health and safety from acts of radiological sabotage, theft, or diversion of special nuclear material. The environmental impacts of terrorism are an area of particular controversy."
(VI-12) In addressing an attack on a spent-fuel pool, this statement in the draft GEIS acknowledges that the consequences of an attack could be "large". In Section X, below, I provide further evidence about the meaning of that term. Then, the statement asserts that the probability of a successful attack is "very low". Elsewhere, the draft GEIS says that this probability is "numerically indeterminable". 60 I agree with the latter statement, but do not agree that the probability is very low. As summarized in paragraph VI- 10, above, there is an extensive, thoroughly documented body of evidence showing that a successful attack on a reactor or pool is as likely to occur as are major national challenges that are planned for, such as severe natural disasters or engagement in wars.
(VI- 13) The draft GEIS notes that, after loss of cooling at a pool, some days would pass before water boiled away to the point where fuel would be exposed. For a pool containing PWR fuel, the draft GEIS cites boil-away times exceeding 4 to 11 days, depending upon the age of the fuel. The draft GEIS asserts that such a time period would allow the implementation of mitigating actions that would prevent a pool fire. 6' In Section VIII, below, I show that NRC has neglected to consider pool-reactor risk linkage that could hinder or preclude mitigating actions. Pool-reactor risk linkage could preclude mitigating actions during either an accident or an attack. Also, a malevolent actor could preclude mitigating actions directly, and/or could cause a loss of water by mechanisms other than boil-away. I address these matters in Section X, below.
(VI-14) The draft GEIS asserts that additional security measures implemented after the 11 September 2001 attacks reduced the probability of a pool fire. 62 Presumably, the draft GEIS is referring to attack-induced pool fires. However, even with the additional security measures, NRC requires licensees to implement only a light defense of a nuclear 59 NRC, 2013b, Executive Summary, page xiiv. A briefer statement to the same general effect appears 60 at: NRC, 2013b, pp 4-89 to 4-90.
NRC, 2013b, page 4-85.
61 NRC, 2013b, Appendix F, page F-I 1.
62 NRC, 2013b, Appendix F, page F-11.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 25 of 120 facility. The conclusions that I set forth in paragraph VI-10, above, take account of that defense.
(VI-15) As discussed in paragraphs VI- II and VI-12, above, the draft GEIS identifies "large" but vaguely specified consequences of an attack-induced pool fire, and "very low" but numerically indeterminable probability. The draft GEIS proceeds to multiply these indicators together in some unspecified manner, concluding that the risk of an attack on a pool is "SMALL". In effect, the draft GEIS uses the "arithmetic" definition of risk that I discuss in Section IV, above. That definition is fundamentally flawed for the reasons I set forth in Section IV. In this instance, application of the arithmetic definition is additionally flawed because the indicators that are multiplied together are nebulous.
(VI-16) In addressing an attack on an ISFSI, the statement in the draft GEIS that is quoted in paragraph VI- 11 asserts that both the probability and consequences of a successful attack are "low". I discuss this probability and these consequences in Section XI, below. That discussion addresses, among other matters, the role of protective deterrence. The statement quoted in paragraph VI- 11 goes on to assert that the risk of a successful attack on an ISFSI is "SMALL". That assertion reflects use of the arithmetic definition of risk. As stated in paragraph VI-15, above, that definition is fundamentally flawed, and its application in the draft GEIS is additionally flawed because the indicators that are multiplied together are nebulous.
VII. The Future Risk Environment (VII-l) The draft GEIS examines storage of spent fuel over three timeframes. 63 The "short-term storage" timeframe is for 60 years beyond licensed life for reactor operations.
The "long-term storage" timeframe is for 100 years beyond the short-term timeframe.
The "indefinite storage" timeframe extends into the indefinite future.
(VII-2) Assessing radiological risk over such long timeframes poses a daunting challenge to risk assessors. A competent risk assessor would immediately acknowledge that the risk environment could change substantially during the short- and long-term timeframes, and even more so during the indefinite timeframe. In this declaration, the term "risk environment" refers to the array of societal, technical, and natural factors that, taken together, have significant influence on risk. Over a period of decades and centuries, these factors, and their interactions with each other, could change substantially.
Moreover, the risk environment could change non-uniformly across the United States.
(VII-3) Section V of the Thompson scoping declaration discussed the future risk environment. That discussion culminated in my recommendation: 64 63 NRC, 2013b, page 1-12.
64 Thompson, 2013b, Section V and Section X.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 26 of 120 "Recommendation #7: Risk assessment in the proposed EIS should be supported by a set of indicators that express the dynamic aspects of the potential risk environment across the time period and suite of scenarios considered in the EIS."
(VII-4) A report from Argonne National Laboratory examines the challenge of safeguarding spent fuel during very long-term storage (VLTS), which it defines as above-ground, interim, dry storage for a period of more than 50 years. 65 That report accompanies this declaration as Exhibit #32. The challenges identified in the report arise partly from potential changes in the risk environment. Thus, the report illustrates the significance of a potentially changing risk environment66 for the assessment of radiological risk. The report makes the following statement:
          "Safeguarding a VLTS facility with nuclear material for 50, 100, or 200 years will present many challenges. First of all, the integrity of the fuel or cask may deteriorate. The radioactive signature of the fuel will also change. As the fuel cools, it may become more attractive for diversion. Even though the State has the means to handle very radioactive spent fuel, cooler spent fuel will still be more attractive to divert because it is easier to handle and reprocess. Keeping data on the facility for that long may also be a challenge. If the past 50 years are any indication of the future, it is difficult to predict what the safeguards challenges and needs will be in just the next 50 years."
(VII-5) The draft GEIS does consider one aspect of potential change in the risk environment over coming decades. In its Section 4.18, it discusses the influence of climate change on design-basis accidents or severe accidents at spent-fuel pools or at dry cask storage facilities (i.e., ISFSIs). It acknowledges various potential outcomes of climate change, such as increased intensity and frequency of severe weather events, sea level rise, increased storm surges, shoreline retreat, and inland flooding. It assumes, however, that mitigating actions could prevent significant increase in radiological risk as a result of climate change, that NRC will continue to exist and will require the necessary mitigating actions, and that licensees will be willing and able to implement these actions.
(VII-6) Section 1.8.3 of the draft GEIS, titled Analysis Assumptions, sets forth a highly optimistic view of the future conditions that will affect stored spent fuel. It assumes that institutional controls will remain operative into the indefinite future, arguing that this assumption "avoids unreasonable speculation regarding what might happen in the future regarding Federal actions to provide for the safe storage of spent fuel". 67 It further assumes that each ISFSI will be replaced on a 100-year cycle, into the indefinite future.
65 Kollar et al, 2013.
66 Kollar et al, 2013, page 6.
67 NRC, 2013b, page 1-14.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 27 of 120 (VII-7) For the reasons set forth in Section V of the Thompson scoping declaration, the highly optimistic assumptions used in the draft GEIS are neither reasonable nor prudent.
Moreover, assuming static conditions is speculative in the extreme, and shows a profound ignorance of human history. Given the long timeframes envisioned in the draft GEIS, the only reasonable approach is to consider a broad range of scenarios. Section VI of the Thompson scoping declaration discussed this approach. That discussion yielded    68 three recommendations, each of which is pertinent to radiological risk, as follows:
        "Recommendation #8: The scenarios considered in the proposed EIS should cover a range of potential outcomes regarding the role of nuclear power, including: (i) shrinkage in the number of operating reactors, with potential shutdown of all reactors by the middle of the 2 1st century; (ii) expansion in the number of operating reactors; and (iii) introduction of new technology."
        "Recommendation #9: The scenarios considered in the proposed EIS should cover future societies exhibiting a range of variation in prosperity, technological capability, and the quality of governance."
        "Recommendation #10: The scenarios considered in the proposed EIS should cover a range of potential future outcomes regarding the propensity for violent conflict, and should cover situations in which stored SNF or HLW would experience attacks involving States or non-State actors."
(VII-8) The draft GEIS does not implement any of my Recommendations #7 through
#10. Instead, the draft GEIS takes the unreasonable, imprudent, and highly speculative position that the risk environment will remain unchanged into the indefinite future.
VIII. Linkage of Pool Risk and Reactor Risk (VIII-1) The radiological risk posed by a spent-fuel pool is significantly increased if that pool is located near an operational reactor, and vice versa. This linkage of pool risk and reactor risk is discussed below. Before embarking on that discussion, however, I explain why this linkage is significant in the context of the draft GEIS.
(VIII-2) The hazard posed by a nuclear fuel assembly begins at the moment when the assembly first undergoes nuclear fission, which occurs inside a reactor. That moment would be the logical starting point for any GEIS that addresses spent fuel. A less logical, but perhaps plausible, starting point would be the moment when the fuel assembly is discharged from a reactor and placed in a nearby pool. The draft GEIS uses a much later and entirely illogical starting point. The draft GEIS considers the environmental impacts of storing spent fuel during a period that begins when the reactor that discharged the fuel is no longer licensed for operation.
68 Thompson, 2013b, Section VI and Section X.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 28 of 120 (VIII-3) By adopting this later starting point, the draft GEIS excludes from consideration a set of significant environmental impacts that arise in earlier phases of the life of a fuel assembly. That exclusion is illogical. It deserves examination from a legal perspective, but that examination is outside the scope of this declaration.
(VIII-4) For the remainder of this declaration, I adopt the starting point used in the draft GEIS. That adoption does not mean that I endorse this starting point. Discussion in the following paragraphs shows that, even if one adopts the starting point used in the draft GEIS, linkage of pool risk and reactor risk is a significant factor in the radiological risk of storing spent fuel.
(VIII-5) Let us consider spent fuel that has been discharged from a reactor that is no longer operational, and that is currently in the pool into which it was discharged. Let us designate the US inventory of this spent fuel, at any given time, as "draft GEIS fuel in pools" (DGFIP). It turns out, as shown below, that a significant fraction of DGFIP could be located near operational reactors. This finding could hold for a significant period even if nuclear power continues to decline as a US energy source. The same finding could hold for a much longer period if nuclear power revives as a US energy source. Both outcomes for nuclear power are encompassed by the draft GEIS. Later in this declaration, I discuss the implications of nuclear-power scenarios for the radiological risk of storing spent fuel. That discussion is in Section IX, below.
(VIII-6) Currently, 100 commercial reactors are licensed to operate in the United States,      69 at 62 sites. At 35 of these sites, there are multiple (i.e., two or three) licensed reactors.
During future decades, all of the currently licensed reactors will shut down permanently.
However, there is no NRC requirement or expectation that all of the reactors at a particular site will permanently shut down at the same moment. Thus, there could be, and probably will be, significant periods when a significant fraction of DGFIP is located near operational reactors. Moreover, there are 9 sites where two reactors share a single pool, and 8 other sites where the pools serving two adjacent reactors are connected by a transfer canal.7 0 At these 17 sites, any fuel in a pool is intimately associated with two adjacent reactors.
(VIII-7) If nuclear power revives as a US energy source, where might a new fleet of reactors be constructed? This question has been addressed by nuclear industry consultant Karl Fleming in a paper supporting his presentation to NRC commissioners7 in July 2011.
That paper accompanies this declaration as Exhibit #33. The paper states: 1 "It is likely that most if not all of the next fleet of new reactors will be built on one or more of the existing licensed reactor sites in view of the additional costs 69 NRC, 2013d. There are 25 sites with multiple PWRs, and 10 sites with multiple BWRs. There are 13 sites with one PWR, and 14 sites with one BWR.
70 Satorius, 2013b, Enclosure 1, Table 72.
71 Fleming, 2011.
 
Thompson Declaration.' Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 29 of 120 and effort that will be required to approve new sites."
(VIII-8) Thus, if nuclear power revives, a significant fraction of DGFIP could be located near new operational reactors, for a period of many years. That finding, combined with my finding in paragraph VIII-6 for the case of continued decline of nuclear power, shows that a significant fraction of DGFIP could be located near operational reactors for a significant period, regardless of future trends in US nuclear power.
(VIII-9) At this point, I have established that pool storage of spent fuel, as considered in the draft GEIS, could occur, and probably will occur, at locations near operational reactors. It follows that the draft GEIS should have carefully considered the potential linkage of pool risk and reactor risk.
(VIII- 10) PRA practice has neglected linkage of risk among multiple reactors at a site.
That neglect is summarized in Karl Fleming's paper, discussed above. The paper says:72 "Our current state of knowledge about the risks from accidents is derived from PRAs. For the most part PRAs on multi-unit sites have been performed on individual reactors separately. In fact, some multi-unit sites have performed a PRA only for one of the sited reactors, arguing that symmetry considerations justify a single reactor PRA. In order to meet expectations for PRA quality, as defined in the various PRA standards, such PRAs must address certain multi-unit dependencies in the modeling of risks that involve damage to a single reactor.
The capability to use equipment from one reactor to back up failures on another is typically considered, however the probability that resources are consumed by concurrent reactor accidents is almost always ignored."
(VIII- 11) In a 2013 journal article, Schroer and Modarres proffer an event classification schema for applying PRA to multiple reactors at a site. 73 That article accompanies this declaration as Exhibit #34. At the time of publication,    co-author Suzanne Schroer was a 74 member    of the NRC  staff. The  article says:
          "Currently, multi-unit nuclear power plant PRAs consider the risk from each unit separately and do not consider combination events between the units. To gain an accurate view of the site's risk profile, the CDF for the site rather than the unit must be considered. This paper has presented a classification system that utilizes existing single-unit PRAs and combines them into a multi- unit PRA. Six main commonality classes that can cause multiple units to be dependent have been presented: initiating events, shared connections, identical components, proximity dependencies, human dependencies, and organizational dependencies. A seventh 72 Fleming, 2011.
73 Schroer and Modarres, 2013.
74 Schroer and Modarres, 2013, page 49.
 
Thompson Declaration: Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 30 of 120 class, independent events, was only marginally discussed because it does not address dependencies between the units."
(VIII- 12) From the two preceding paragraphs and the documents cited therein, one sees that linkage of risk among multiple reactors at a site has been long neglected, but is beginning to receive some attention from NRC and licensees. Linkage of pool risk and reactor risk at a site has been similarly neglected, but has not been properly addressed by NRC or licensees.
(VIII- 13) Although NRC has not properly addressed the linkage of pool risk and reactor risk, NRC has taken a small, initial step in that direction. This step was taken in a pool-fire study that NRC published in 2013. As discussed in paragraph I-11, above, NRC published a draft version of the pool-fire study in June 2013.75 The study was re-published in final form in October 2013, with no substantial change.76 The October 2013 version, with its cover memo, accompanies this declaration as Exhibit #35. Hereafter, I refer to it as "NRC's consequence study". I assume that the technical parts of the June 2013 and October 2013 version are identical. Thus, the Thompson draft consequence declaration applies equally to both.
(VIII-14) NRC's consequence study took a small step toward addressing the linkage of pool risk and reactor risk in the sense that it identified aspects of that linkage. It did not proceed to analyze those aspects. The identification  77 occurred under the rubric, Multi-Unit Considerations, via the following statement:
          "Observations Regarding a Concurrent Reactor Event:
There are four broad interplays that can be defined between the SFP [spent fuel pool] and the reactor:
I. an initiating event that directly affects both the reactor and the SFP
: 2. a reactor accident that prevents accessibility to the SFP for a prolonged period of time (e.g., due to high radiation fields), leading to a SFP accident
: 3. a reactor accident that includes ex-containment energetic events (e.g., a hydrogen combustion event) or other ex-containment interplays (e.g.,
steaming through the drywell head that affects refuel floor combustible gas mixtures) and creates a hazard to the SFP (e.g., by causing debris to fall in to the pool) or otherwise changes the SFP event progression
: 4. an SFP accident that prevents accessibility to key reactor systems and components for a prolonged period of time or which creates a hazard for 75 Barto et al, 2013a.
76 The October 2013 version is: Barto et al, 2013b. It was published as an enclosure under the SECY memo: Satorius, 2013a. That memo stated: "None of the comments or responses [i.e., on the draft version of the study] has necessitated making substantial changes to the report." (See:
Satorius, 2013a, page 3.)
77 Barto et al, 2013b, Section 2.2, pp 28-29.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 31 of 120 equipment used to cool the reactor (e.g., the flooding of low elevations of the reactor building due to a leak in the pool or excessive condensation from continuous boiling of SFP water), leading to a reactor accident For each of these interplays, large seismic events and severe weather SBO [station blackout] events are logically the most relevant initiators, as they are the type of initiators that are most likely to initiate an accident at the reactor and SFP, while simultaneously hampering further accessibility to key areas, key systems and components, and key resources. To the extent practicable, this study has attempted to qualitatively account for some of these effects. For example, when the reactor and SFP are hydraulically connected (during refueling), the decay heat and water volumes from both sources are considered. The study also explores these effects on mitigation (Section 8), and addresses some aspects of the uncertainty associated with this treatment (Section 9). However, explicitly modeling multiunit effects was not a focus of this study, because of the existing limitations with the available computational tools. An ongoing project described in SECY-1 1-0089 will attempt to more rigorously address these effects in the framework of a multiunit Level 3 PRA for Vogtle Electric Generating Plant Units l and 2."
(VIII- 15) The four "interplays" described in this statement are far from the final word about linkage of pool risk and reactor risk, but they would provide a useful starting point for technical analysis on that linkage. These interplays could occur in situations where pool storage of spent fuel, as considered in the draft GELS, occurs at a location near an operational reactor. Thus, the draft GEIS should have carefully considered the implications of these interplays for the environmental impacts of storing spent fuel in pools. Unfortunately, the draft GEIS failed to consider those implications.
(VIII- 16) The second half of the statement quoted in paragraph VIII- 14 shows clearly that NRC's consequence study does not provide credible technical analysis of the pool-reactor interplays that it identifies. Instead, it says that another project "will attempt" to address these interplays at some future date. Until that work is done properly, NRC will not be able to complete an adequate GElS on the environmental impacts of storing spent fuel.
(VIII- 17) The 2011 Fukushima accident illustrated the potential for risk linkages among facilities at a nuclear site. Figure VIII-1 shows how that potential was manifested at Unit
: 4. The Unit 4 reactor building suffered a violent explosion of hydrogen that reportedly originated from reactor core damage at Unit 3.78 That hydrogen explosion, and other influences at the site, hindered mitigating actions at Unit 4. Those actions were needed to keep the Unit 4 spent-fuel pool in a safe state, because normal systems that provide cooling and makeup to the pool were disabled by the earthquake and tsunami that' 78 The reactor core of Unit 4 had been removed and placed in the adjacent pool prior to the accident.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 32 of 120 afflicted the site. Eventually, water makeup was provided to the pool by the concrete-pumping truck that appears in Figure VIII- 1. That truck was brought to the site after several other methods of providing water makeup had failed.
(VIII- 18) Figure VIII-2 illustrates how intimately a spent-fuel pool can be associated with the reactor it serves. Moreover - as discussed in paragraph VIII-6, above - at 17 sites in the United States, any fuel in a pool is intimately associated with two adjacent reactors. In other instances, the association between a pool and a different, nearby reactor may not be quite so intimate. Nevertheless, physical proximity, sharing of buildings, and/or sharing of support systems could establish a strong linkage of pool risk and reactor risk. One concern is that a release of radioactive material from a reactor could create a radiation field that precludes personnel access needed to keep a nearby spent-fuel pool in a safe state. Lack of that access could lead to a pool fire.
(VIII- 19) One potential manifestation of risk linkage among facilities at a nuclear site would be the occurrence of a cascading sequence of incidents. To illustrate, consider the potential impact of a large aircraft on a reactor. That event could be an accident or a malevolent act. The successful use of a large aircraft as an instrument of attack is, of course, not theoretical. It occurred in the United States three times on 11 September 2001.
(VIII-20) Morris et al describe the use of the VISAC code to analyze the impact of a large aircraft on the containment of a reactor. 79 They note that the hard parts of the aircraft - notably, the jet engine rotors - might not fully penetrate the containment. They consider, however, the entry of a small fraction (apparently, 1 percent) of the aircraft's jet fuel into the annular space between the inner and outer walls of the containment. Perusal of Figure VIII-2 shows analogous spaces in that reactor design. Vaporization and ignition of the jet fuel in this confined space would, with high conditional probability, lead to a violent fuel-air explosion. Morris et al describe VISAC analyses that show, in all cases, significant damage to the containment from this explosion, with holes in both the inner and outer walls. They go on to say:80 "While the damage is significant, subsequent events are most likely responsible for most of the radioactive release predicted. It is unlikely that the staff inside the control room adjacent to the containment building will survive the smoke and toxic fumes resulting from the fire, even if they managed to survive the direct consequences of the crash of the airplane. In view of the fire engulfing the containment building and adjacent structures, it seems unlikely that the separately located auxiliary control room could be reached by the staff members originally located in the main control room. Therefore, even if those in the control room should be unaffected by the air fuel explosion, the additional fire hazard outdoors will prohibit the surviving operators from shutting down the plant in a controlled
'9 Morris et al, 2006.
80 Morris et al, 2006, page 206.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 33 of 120 manner from the auxiliary control room."
(VIII-2 1) The potential events that Morris et al describe can be viewed as stages in a cascading sequence of incidents. First, the aircraft strikes the containment. Second, some jet fuel enters a confined space. Third, a fuel-air explosion breaches the containment and causes other damage. At some point during stages 1-3, or subsequently, the control room, the auxiliary control room, and their personnel are rendered non-functional. Fourth, radioactive material is released from the reactor to the interior of the containment, or directly to the external environment. Fifth, radioactive material passes from the interior of the containment to the external environment. Sixth, the cascade could proceed to one or more pool fires, as discussed in the following paragraph.
(VIII-22) The spent-fuel pool that serves the afflicted reactor, and the cooling and water makeup systems that serve that pool, could be damaged by the aircraft impact or by the fuel-air explosion. That damage could be sufficient to initiate a zircaloy fire in the pool.
A nearby spent-fuel pool, built to serve another reactor, could suffer similar damage, resulting in a zircaloy fire in that pool. Deposition of radioactive material released from the afflicted reactor would create an intense radiation field around the reactor. The radiation field could extend in all directions, because the fire accompanying this disaster would create intense turbulence in the local atmosphere. The radiation field could preclude personnel access for days or weeks, thereby precluding mitigating actions that might prevent the initiation of zircaloy fires in the affected pools. In that situation, a nearby pool that was not affected directly by the aircraft impact could boil dry, leading to a fire in that pool.
(VIII-23) NRC has never, to my knowledge, published a credible technical analysis of a cascading sequence of incidents of this type. Nor, to my knowledge, has NRC ever publicly stated that it has performed such analysis in secret. Until such analysis is done, and done properly, NRC will not be able to complete an adequate GEIS on the environmental impacts of storing spent fuel.
IX. Risk Implications of Nuclear-Power Scenarios (IX-l) Section 1.8.6 of the draft 8
GELS, titled Issues Eliminated from Review in this GEIS, contains the statement: '
        "The NRC is evaluating the continued storage of commercial spent fuel in this draft GEIS. Thus, certain topics are not addressed because they are not within the scope of this review. These topics include:
* noncommercial spent fuel (e.g., defense waste)
                - commercial high level waste generated from reprocessing
                - greater-than-class-C LLW
* advanced reactors (e.g., high-temperature and gas-cooled reactors) 81 NRC, 2013b, pages 1-23 and 1-24.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 34 of 120
* foreign spent fuel
* nonpower reactor spent fuel (e.g., test and research reactors)
* need for nuclear power "reprocessing of commercial spent fuel" (IX-2) By excluding from consideration the "need for nuclear power", the draft GEIS cripples its ability to assess the environmental impacts of storing spent fuel. Nowhere in the draft GEIS is this grave deficiency corrected. The draft GEIS does not set forth any scenario for the future use of nuclear power or, more specifically, for the future creation of spent fuel. Thus, in the draft GEIS, the timeframe for creation of spent fuel spans an unknown but potentially vast range, as does the quantity of spent fuel created in that timeframe.
(IX-3) At the lower end of its range, the timeframe for creation of spent fuel will end when the last of the currently licensed reactors ceases to operate. However, since the draft GEIS sets no upper limit on the time period that it considers, the creation of spent fuel could continue ad infinitum. Thus, the upper end of the range of timeframes is undefined.
(IX-4) At the lower end of its range, the quantity of spent fuel that is created will be the quantity that is discharged from the currently licensed reactors. However, since the draft GEIS says nothing about the future use of nuclear power, it sets no upper limit to the quantity of spent fuel that will be created. Consider a simple, illustrative example.
Suppose that nuclear power soon revives in the United States, leading to a tenfold increase in annual creation of spent fuel by the mid-21st century. Further suppose that this rate of creation continues for a few centuries. At the end of that period, the cumulative quantity of spent fuel that has been created would far exceed the quantity that is discharged from the currently licensed reactors.
(IX-5) If the total quantity of spent fuel that is created were at the lower end of its range, the radiological risk posed by storing this fuel would be bounded. As the inventory of fuel aged, its radiological risk would decline, other factors being equal. Moreover, the inventory would gradually move from pools to ISFSIs, which would reduce its risk. In principle, one could assess the cumulative radiological risk of storing spent fuel, from the present until the moment when the last fuel assembly in the inventory is emplaced in a repository.
(IX-6) If, however, the total quantity of spent fuel that is created is unbounded, then the radiological risk posed by storing this fuel would be similarly unbounded.8 2 The draft GEIS allows for this outcome. Thus, the draft GEIS has denied itself the ability to assess the long-term radiological risk of storing spent fuel. One cannot assess a quantity that is unbounded.
82 This statement holds at any given time, and cumulatively.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 35 of 120 (IX-7) In Sections VI and VII of the Thompson scoping declaration, I set forth a number of recommendations for the use of scenarios.83 These recommendations could have helped the framers of the draft GEIS to avoid the self-crippling of the draft GEIS that I have described in the preceding paragraphs. The framers ignored my recommendations.
Those recommendations would, in principle, have allowed the draft GEIS to bound the radiological risk of storing spent fuel. Moreover, those recommendations would have allowed the draft GEIS to compare the risk posed by different scenarios and different options for managing spent fuel.
X. Pool Fire: Probability and Consequences (X-l) The draft GEIS concedes that a pool fire could occur. More precisely, it concedes that zircaloy combustion could occur in a spent-fuel pool following loss of water from the pool. Here, in Section X, I address five aspects of the draft GEIS's consideration of pool fires, with an emphasis on the probability and consequences of a pool fire. The draft GEIS's consideration of pool fires is deficient in regard to each aspect. As a result, the draft GEIS makes an incorrect determination of the environmental impact of pool fires.
The five aspects are:
* Documents cited in the draft GElS
* NRC's understanding of relevant phenomena
* Probability of a pool fire
* Consequences of a pool fire
* Determination of radiological risk and environmental impact Documents cited in the draft GElS (X-2) The draft GElS provides technical discussions of pool fires in its Sections 4.18 and 4.19 and Appendix F. To support those discussions, the draft GEIS cites a number of documents. However, some relevant documents are not cited. In paragraphs X-3 through X-6, below, I discuss three examples of documents whose omission from the citations in the draft GElS is significant.
(X-3) In paragraph VI-2, above, I note that NRC explicitly considered the impacts of malevolent acts in its 1979 GEIS on Handling and Storage of Spent Light Water Power Reactor Fuel, which was designated NUREG-0575.84 Potential malevolent acts were described in Appendix J of that document. NUREG-0575 is not cited in Sections 4.18 and 4.19 and Appendix F of the draft GELS. That omission is significant because the malevolent acts postulated in Appendix J of NUREG-0575 could, with slight adjustment, readily initiate a pool fire. I discuss that matter below.
83 Thompson, 2013b, Sections VI, VII, and X.
8 4 NRC, 1979.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 36 of 120 (X-4) In paragraph VIII-13, above, and elsewhere in this declaration, I discuss NRC's consequence study. 85 That study, published in draft form in June 2013 and final form in October 2013, is NRC's most recent technical analysis of pool fires. Yet, that study is not cited in Sections 4.18 and 4.19 and Appendix F of the draft GEIS, which was published in September 2013. That omission is significant from several perspectives.
For example, as discussed in paragraphs VIII-14 through VIII-16, above, NRC's consequence study identified an important issue that has not been considered in the draft GEIS. That issue is the linkage of pool risk and reactor risk.
(X-5) The NRC staff incorporated the findings of NRC's consequence study into a staff recommendation regarding the expedited transfer of spent fuel from pools to dry storage.
The staff recommended against expedited transfer in a November 2013 document that I refer to hereafter, following NRC practice, as the "Tier 3 analysis".8 6 That document accompanies this declaration8 as    7 Exhibit #36. The Tier 3 analysis describes its connection to the  draft  GEIS  as follows:
          "Within this Tier 3 analysis, the staff has considered the agency's activities on the waste confidence generic environmental impact statement (GEIS) and rulemaking, and it has ensured that the availability of these documents and interactions with stakeholders are coordinated to facilitate the public's involvement in these activities. Although this Tier 3 analysis was not specifically referenced in the draft GEIS, those who prepared the draft GEIS were aware of the conclusions in this Tier 3 analysis, and the staff has coordinated this activity with the relevant sections of the draft GEIS. To facilitate the public's ability to provide input, a draft of the October 2013 SFP study was released for public review and comment on July 1, 2013. Additionally, the draft evaluation of this Tier 3 issue was released to the public on September 26, 2013, well before the draft GEIS public comment period ends on December 20, 2013."
(X-6) Omission of the Tier 3 analysis from the citations in the draft GEIS is significant because the Tier 3 analysis sets forth an NRC staff position on the radiological risk of pool fires. The draft GEIS does not address that position. Yet, according to the statement quoted in the preceding paragraph, the preparers of the draft GEIS were aware of the conclusions in the Tier 3 analysis, and the two documents were "coordinated" in some manner. Thus, the Tier 3 analysis had a substantial but undocumented influence on the draft GEIS.88 The lack of documentation of this influence handicaps those who seek to comment on the draft GEIS.
85 Barto et al, 2013b.
86 Satorius, 2013b.
87 Satorius, 2013b, page 9.
88 One illustration of a likely influence is the draft GEIS's assertion that air cooling of spent fuel would prevent a pool fire at a point much earlier following fuel offload from a reactor than was considered in the study NUREG-1738. (See: NRC, 2013b, Appendix F, page F-1 1.) The Tier 3 analysis and NRC's consequence study represent NRC's most recent analysis of pool-fire issues such as the role of air cooling, but are not cited in the draft GEIS.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 37 of 120 NRC's understandingof relevantphenomena (X-7) I now turn to addressing NRC's understanding of phenomena relevant to a pool fire. I show that NRC's understanding of these phenomena is deficient, and that the NRC staff seeks to close off further inquiry that could correct the deficiencies. The first phenomenon that I address is the connection between: (i) the presence of residual water in the lower part of a pool that has experienced water loss; and (ii) the initiation of zircaloy combustion. NRC failed to understand this connection for more than two decades, and that misunderstanding continues to influence NRC's current analysis on pool fires.
(X-8) As discussed in paragraph 1-7, above, the pool serving each commercial reactor in the USA is now equipped with high-density, closed-frame racks. The nuclear industry began installing these racks in the 1970s, to replace the low-density, open-frame racks previously used. The high-density racks offered a comparatively cheap option for storing a growing nationwide inventory of spent fuel. Figure X- 1 shows the configurations of the two types of rack.
(X-9) If water were lost from a pool equipped with high-density racks, the racks would inhibit heat transfer from the exposed fuel. Thus, spent fuel in the pool would increase in temperature, potentially leading to ignition and sustained combustion of zircaloy cladding in air or steam. To a technically trained observer, it should be obvious that ignition could be more likely if residual water were present in the pool, other factors being equal.
Residual water would block the flow of air from below, thus reducing heat transfer from the exposed portion of the fuel. Figure X-2 illustrates this phenomenon. As a result, spent fuel with a comparatively high age after discharge from a reactor could burn if residual water were present. The initial phase of "burning" would, in this case, be a steam-zircaloy reaction.
(X-10) As discussed in paragraph VI-4, above, NUREG-0575 dismissed the potential for a pool fire, arguing that spent fuel aged more than one year would not bum if water were lost from a pool. 89 NUREG-0575 was published by NRC in 1979. NRC held a similar position in 1989, when it published the pool-fire study NUREG-1353.9 ° That study accompanies this declaration as Exhibit #37. NUREG-1353 stated:91 "A typical spent fuel storage pool with high density storage racks can hold roughly five times the fuel in the core. However, since reloads typically discharge one third of the core, much of the spent fuel stored in the pool will have had considerable decay time. This reduces the radioactive inventory somewhat.
More importantly, after roughly three years of storage, spent fuel can be air-8 9 NRC, 1979, page 4-21.
90 Throm, 1989.
91 Throm, 1989, page 1-1 (emphasis added).
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 38 of 120 cooled. The spent fuel need not be submerged to prevent melting, although submersion is still desirable for shielding and to reduce airborne activity."
(X- 11) Thus, from 1979 to 1989, NRC failed to understand the significance of residual water for zircaloy ignition. NRC's belief that comparatively old fuel would not ignite derived from NRC's mistaken assumption that the worst case of water loss from a pool would be total, instantaneous drainage. This erroneous belief continued into 1999 and 2000, while NRC was preparing a pool-fire study that was eventually published, in February 2001, as NUREG-1738. 9 That study accompanies this declaration as Exhibit
#38. Preliminary versions of NUREG-1738 were published by NRC in June 1999 and February 2000.
(X- 12) In 1999 and 2000, I was a technical adviser and expert witness for Orange County, North Carolina, supporting the County's intervention in a license proceeding before NRC's Atomic Safety and Licensing Board. The proceeding addressed a proposed expansion of spent-fuel storage capacity at the Shearon Harris nuclear power plant. In a March 2000 filing in that proceeding, the NRC staff disputed my position that comparatively old fuel could ignite if water were lost from a pool. That filing 93 accompanies this declaration as Exhibit #39. In its filing, the NRC staff stated:
          "However, although Dr. Thompson states that for "scenarios which involve partial uncovery of fuel, the reaction could affect fuel aged 10 or more years," he offers no authority to support this conclusion. Dr. Thompson's is the only opinion of which the Staff is aware that holds that fuel five years or more out of the reactor is susceptible to zircaloy fire/exothermic reaction. See, e.g.,
NUREG/CR-0649, Spent Fuel Heatup Following Loss of Water During Storage, at 85-87 (1979) (Exhibit B)."
(X- 13) Later in 2000, NRC corrected its erroneous belief, held since 1979, that comparatively old fuel could not ignite in the event of water loss. The Thompson draft consequence declaration describes the circumstances in which NRC made this correction.94 In brief, NRC made the correction because its representatives were required, for the first time in decades, to justify their technical position in a public setting in which they could be challenged. The correction was acknowledged in NUREG-1738, 95 which stated:
          "The analyses in Appendix 1A determined that the amount of time available (after complete fuel uncovery) before a zirconium fire depends on various factors, including decay heat rate, fuel burnup, fuel storage configuration, building ventilation rates and air flow paths, and fuel cladding oxidation rates. While the 92 Collins and Hubbard, 2001.
93 NRC, 2000, page 21 (emphasis added).
94 Thompson, 2013a, paragraphs 111-12 to 111-13 and 111-23 to 111-24.
95 Collins and Hubbard, 2001, pages 2-1 and 2-2 (emphasis added).
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 39 of 120 February 2000 study indicated that for the cases analyzed a required decay time of 5 years would preclude a zirconium fire, the revised analyses show that it is not feasible, without numerous constraints, to define a generic decay heat level (and therefore decay time) beyond which a zirconium fire is not physically possible. Heat removal is very sensitive to these constraints, and two of these constraints, fuel assembly geometry and spent fuel pool rack configuration, are plant specific. Both are also subject to unpredictable changes as a result of the severe seismic, cask drop, and possibly other dynamic events which could rapidly drain the pool. Therefore, since the decay heat source remains nonnegligible for many years and since configurations that ensure sufficient air flow for cooling cannot be assured, a zirconium fire cannot be precluded, although the likelihood may be reduced by accident management measures."
(X-14) Paragraphs X-7 through X-13, above, yield a significant finding. They show that NRC failed to understand a comparatively simple technical issue for more than two decades. NRC's misunderstanding persisted for this long period because its staff were shielded from public challenge and did not engage in the open discourse that is essential to scientific inquiry. With some limited exceptions, that situation has continued until the present.
(X-15) Before publishing NUREG-1738 in February 2001, NRC had published several studies related to pool fires. These studies, like NUREG-1353, contained erroneous statements about the potential for ignition of comparatively old fuel. They also contained other substantial deficiencies. 96 For example, NUREG-1353 did not consider storage of BWR spent fuel in high-density racks, even though such storage has been common practice for many years. 97 Yet, NRC has neither retracted nor repudiated NUREG- 1353, despite its clear obsolescence. Indeed, the draft GEIS cites NUREG-135398 as a major source of information on the probability and consequences of a pool fire.
(X-16) The potential for a pool fire became clear in 1979. From the beginning, the means of addressing this threat was also clear. The radiological risk of a pool fire could be dramatically reduced by abandoning the use of high-density racks in pools, and reverting to low-density, open-frame racks. 99 Figure X- 1 shows the two types of rack.
Since 1979, numerous parties have intervened in license proceedings and pursued other avenues, seeking to persuade NRC to order the elimination of high-density racks. A corollary of that action would be the transfer of a substantial portion of the US inventory of spent fuel from pools to dry casks. NRC has consistently and vigorously opposed the elimination of high-density racks.
96 Thompson, 2009, Section 5.
97 Throm, 1989, pages 4-9 and 4-10.
98 NRC, 2013b, Table F-I (page F-4).
99 In the case of BWR spent fuel, removal of channel boxes from the fuel could also be appropriate.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 40 of 120 (X- 17) Now, in its Tier 3 analysis, the NRC staff seeks00 to close off any further inquiry into the risk of a pool fire. The staff recommends:1 "The staff's assessment concludes that the expedited transfer of spent fuel to dry cask storage would provide only a minor or limited safety benefit, and that its expected implementation costs would not be warranted. Therefore, the staff recommends that no further generic assessments be pursued related to possible regulatory actions to require the expedited transfer of spent fuel to dry cask storage and that this Tier 3 Japan lessons-learned activity be closed."
(X-1 8) The Tier 3 analysis relies heavily upon NRC's consequence study.' 0 ' I provided a critical review of that study in the Thompson draft consequence declaration.' 0 F I concluded that NRC's03 consequence study is fundamentally and irredeemably flawed, and recommended: 1
          "(VIII-7) NRC's Draft Consequence Study should be scrapped.
(VIII-8) In addressing the pool-fire issue, NRC should focus its initial attention exclusively on establishing a solid technical understanding of phenomena directly related to a potential pool fire. To do this, NRC would start with a clean slate and use the best available modeling capability backed up by experiment. This modeling and experimental work would be done according to scientific principles.
Further recommendations regarding such work are provided in Section IV, above."
(X- 19) I recommend additional investigation of pool-fire phenomena because, more than three decades after the potential for a pool fire was recognized, NRC has not yet established a solid technical understanding of relevant phenomena. Thus, the NRC staff's recommendation to cease investigation of pool-fire issues is imprudent.
Apparently, the NRC staff believes that acquisition of a solid understanding of pool-fire phenomena is unnecessary. The staff has not articulated a clear position on this matter.
Such a position has, however, been articulated by Dr. Dana Powers, a member of NRC's Advisory Committee on Reactor Safeguards (ACRS), in a written commentary on the Thompson draft consequence declaration.10 4 That commentary, with associated documents, accompanies 5this declaration as Exhibit #40. Dr. Powers' commentary 0
includes the statement:'
          "Much of Section IV of Dr. Thompson's report is devoted to outlining an extensive study of accident phenomenology for spent fuel events. The intent seems to be to establish a very comprehensive understanding to a scientific 00 Satorius, 2013b, page 10.
101 Barto et al, 2013b.
102 Thompson, 2013a.
103 Thompson, 2013a, Section VIII.
104 Armijo, 2013, Enclosure 3.
105 Armijo, 2013, Enclosure 3, page 4 (emphasis added).
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 41 of 120 certainty in this phenomenology. Dr. Thompson does not make it clear why this should be done if, in fact, it can be shown that partial drain events are easily remediated with high confidence and that complete drain events are highly improbable. Nor does he provide a ranking of the use of resources for the purposes of studying spent fuel pools in preference to other safety issues. On the basis of results presented to ACRS thus far, it would appear that a systems engineering evaluation would suggest the best use of available resources would be to assure that mitigation of partial drain events was assured and that complete drain events were highly improbable. This would obviate the need for a detailed understanding of accident phenomenology. Should a decision be made to conduct confirmatory research, examination of the Dr. Thompson's list of topics might be useful starting point in the identification of possible avenues of investigation."
(X-20) Dr. Powers' statement is instructive. He and I view the pool-fire problem from opposite perspectives. His confidence regarding the efficacy of mitigating measures, and the validity of probability estimates, is such that he sees no need for a thorough understanding of relevant phenomena. In my judgment, however, there is compelling evidence that: (i) mitigation of loss of water from a pool could not be assured in many potential situations; and (ii) complete or partial loss of water from a pool has a significant probability. Moreover, the consequences of a pool fire could be severe. Accordingly, given present knowledge of pool-fire phenomena, prudence dictates a high-priority action
- the rapid elimination of high-density racks from all pools. A thorough investigation of pool-fire phenomena, conducted in parallel with that action, might yield knowledge that somewhat reduces the urgency and scope of the action, thus reducing its cost. I recommend such an investigation.
(X-2 1) Later in Section X, I discuss the compelling evidence mentioned in the preceding paragraph. Here, I close my discussion of pool-fire phenomena by briefly discussing the influence of two factors on zircaloy ignition and combustion. The two factors are: (i) accumulation of zirconium hydrides in the cladding of high-burnup fuel; and (ii) the ballooning and burst of fuel cladding at temperatures above the normal operating level.
(X-22) In April 2000, the Chairman of ACRS wrote a letter to the Chairman of NRC, discussing some pool-fire phenomena.!°6 That letter accompanies this declaration as Exhibit #41. The letter discussed a number of phenomenological issues that had not been properly considered by NRC. I focus here on one of those issues. That issue is the influence of zirconium hydrides on the ignition of exposed spent fuel. As part of its 07 discussion of that issue, the ACRS letter said:'
        "We also have difficulties with the analysis performed to determine the time at which the risk of zirconium fires becomes negligible. In previous interactions 106 Powers, 2000.
107 Powers, 2000, page 3 (emphasis added).
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 42 of 120 with the staff on this study, we indicated that there were issues associated with the formation of zirconium-hydride precipitates in the cladding of fuel especially when that fuel has been taken to high burnups. Many metal hydrides are spontaneously combustible in air. Spontaneous combustion of zirconium-hydrides would render moot the issue of "ignition" temperature that is the focus of the staff analysis of air interactions with exposed cladding. The staff has neglected the issue of hydrides and suggested that uncertainties in the critical decay heat times and the critical temperatures can be found by sensitivity analyses. Sensitivity analyses with models lacking essential physics and chemistry would be of little use in determining the real uncertainties."
(X-23) Given the trend of driving nuclear fuel to ever-higher burnups, one could reasonably expect that NRC would seriously address the concern expressed by ACRS.
The ACRS letter did stimulate the preparation of an NRC internal memorandum.10 8 That memorandum, with its attached draft report, accompanies this declaration as Exhibit #42.
The memorandum and its attached draft report discussed factors that could influence the ignition of zircaloy when exposed to air or steam. Those factors included the presence of hydrides. They also included the ballooning and burst of fuel cladding, a matter I return to below. The draft report attached to the memorandum contained the statement:. 09 "It would be necessary to conduct actual ignition tests on either spent fuel or pre-oxidized and hydrided cladding to generate experimental data to understand these various effects and to determine unambiguously the potential for autoignition. For lack of such experimental data, the potential for autoignition after ballooning and burst cannot be ruled out at this time."
(X-24) Ignition tests on actual spent fuel would be problematic because the fuel's large inventory of radioactive material would have to be shielded and contained. NRC did sponsor ignition tests on pre-oxidized cladding, as described in the report NUREG/CR-6846, published in 2004.11° That report accompanies this declaration as Exhibit #43. At the time of publication of NUREG/CR-6846, NRC had not sponsored tests on hydrided cladding. Those tests were promised at some future time, as follows:"*
          "The effect of pre-existing hydrides, formed on the cladding surface during in-reactor operation and relevant, in particular, for high bumup operation, is being investigated under a follow-on program at the Argonne National Laboratory. This latter study will be reported separately."
(X-25) NRC's consequence study was published in 2013. In that study, the theoretical model used to represent zircaloy ignition and combustion is drawn directly from 108 Eltawila, 2001.
109 Eltawila, 2001, attached draft report by Chung and Basu, page 9 (emphasis added).
110 Natesan and Soppet, 2004.
111 Natesan and Soppet, 2004, Foreword (by Farouk Eltawila), page xvii.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 43 of 120 NUREG/CR-6846. The model reflects the ignition tests on pre-oxidized cladding that are mentioned in the preceding paragraph. The study notes that this model shows accelerated combustion compared with previous models, and that this effect is confirmed by experiment."12 Thus, the tests on pre-oxidized cladding that are described in NUREG/CR-6846 were a useful step toward simulating the ignition and combustion of actual spent fuel. Moreover, this step revealed that combustion would be more vigorous than previously expected. Yet, NRC's consequence study does not mention the effects of hydrides on cladding ignition and combustion, despite ACRS's highlighting of this issue in 2000 and NRC's promise in 2004 to sponsor appropriate tests. Thus, it seems that a key aspect of the ignition and combustion behavior of actual spent fuel, arising from the presence of hydrides, has been ignored by NRC. Moreover, accumulation of hydrides increases with burnup, and there is a trend of driving nuclear fuel to ever-higher burnups.
(X-26) As discussed in paragraph X-23, above, factors that could influence the ignition of zircaloy include the ballooning and burst of fuel cladding. It is well known that cladding can balloon (i.e., swell) and ultimately burst at temperatures substantially above the normal operating temperature. During the ballooning phase, the cross-sectional area for axial fluid flow through a fuel assembly could be reduced, thereby reducing heat transfer from the fuel. At the time of burst, unoxidized cladding would be exposed to air or steam, which could promote zircaloy ignition. The MELCOR code used in NRC's consequence study lacks a capability to model the ballooning and burst of fuel cladding.1 13 MELCOR has been "benchmarked" against tests involving the ignition of electrically heated structures simulating fuel assemblies, as described in the report NUREG/CR-7143. 14 That report accompanies this declaration as Exhibit #44.
Apparently, the tests did not involve ballooning and burst of cladding, perhaps because the simulated fuel rods were not sealed. Thus, neither MELCOR nor these tests provides any information about the implications of cladding ballooning and burst for zircaloy ignition. NRC's consequence study alludes to secret studies that address this matter, but provides no citation.115 (X-27) An April 2003 accident at the Paks-2 nuclear power plant in Hungary shows how overheated nuclear fuel will balloon and then burst. The accident and a subsequent simulation are described in a 2007 conference paper that accompanies this declaration as Exhibit #45.'16 The accident occurred while fuel was undergoing chemical cleaning inside a tank submerged in the plant's spent-fuel pool. Cooling water was supplied to the tank by a pump submerged in the pool. On this occasion, the water flow was inadequate, reportedly due to design defects and operating deficiencies. As a result, a steam bubble formed in the tank and fuel temperature began to rise. The zircaloy fuel cladding experienced extensive ballooning, followed by cladding burst and zirconium-steam 112 Barto et al, 2013b, pages 93 and 94.
"'  Barto et al, 2013b, Table 3, page 26.
114 Lindgren and Durbin, 2013.
115 Barto et al, 2013b, Table 3 (page 26).
116 Windberg and Hozer, 2007.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 44 of 120 combustion. This accident did not lead to a substantial release of radioactive material to the atmosphere, because it occurred inside a closed tank submerged in a pool.
Nevertheless, this accident provides real-world evidence of the significance of phenomena such as cladding ballooning and burst. Regrettably, NRC's consequence study has not accounted for all relevant phenomena.
(X-28) Paragraphs X-7 through X-27, above, address various aspects of phenomena relevant to a pool fire. The Thompson draft consequence declaration contains a further critique of NRC's consideration of such phenomena."' 7 Taken together, those sources support the following findings:
* NRC failed to understand a comparatively simple technical issue for more than two decades, because its staff were shielded from public challenge and did not engage in the open discourse that is essential to scientific inquiry.
* With limited exceptions, NRC staff remain shielded from public challenge and scientific discourse.
    " NRC's latest analysis of pool fires (i.e., NRC's consequence study) ignores a number of technical issues that are significant to a determination of pool-fire risk.
* The NRC staff proposes to close off further inquiry into pool-fire risk.
* Apparently, the NRC staff believes that the acquisition of a thorough understanding of pool-fire phenomena is unnecessary because the probability of unmitigated partial or total loss of water from a pool is, in their view, negligible.
(X-29) NRC's deficient understanding of pool-fire phenomena is significant for the draft GEIS's determination of the environmental impact of pool fires, because that determination relies heavily on the judgment of NRC staff, especially in the context of malevolent acts. In many instances that reliance is undocumented or poorly documented.
Probabilityof a poolfire (X-30) I now turn to discussing the probability of a pool fire. In this discussion I generally use the term "frequency" instead of "probability", because in some situations this indicator could have a value exceeding 1. A pool fire could be caused by an accident or a malevolent act. In the context of accidents, I have always been concerned about potential situations in which a radioactive release occurs at a reactor near to a pool.
Given such a situation, the radiation field created by the reactor release, and other influences, could preclude mitigating actions needed to keep the pool in a safe state. In the context of malevolent acts, an analogous situation could arise. Additionally, a malevolent actor could preclude pool-related mitigating actions in ways that did not rely on obtaining a radioactive release from a nearby reactor.
(X-3 1) The draft GEIS relies upon the findings of PRA-type studies for its estimation of the frequency of accident-induced pool fires. Drawing upon such studies, the draft GElS asserts that the frequency of a pool fire, caused by an accident, is in-the range 5.8xOLT7-to 17  Thompson, 2013a.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 45 of 120 2.4x10 6 per year." 18 Although not explicitly stated as such, this assertion refers to a frequency per pool-year. A pool-year is analogous to the concept of a reactor-year, which is introduced in paragraph V-5, above. Note that a frequency of 2.4xl 0-6 per pool-year, which is low, would become a much higher value if accumulated across many pools over many years. I address that matter below.
(X-32) The discussion in Section V, above, regarding the limitations of PRA, suggests that the actual frequency of a pool fire may be substantially higher than is asserted in the draft GEIS. Here, I focus on an issue that reinforces that suggestion. That issue is the linkage of pool risk and reactor risk. As discussed in Section VIII, above, NRC has never done a credible analysis of this linkage. Moreover, there is persuasive evidence, including the Fukushima accident, that a reactor accident could be part of a cascading sequence of incidents that preclude mitigating actions needed to maintain nearby pools in a safe state. Finally, as discussed in Section VIII, pool storage of spent fuel, as considered in the draft GEIS, will probably occur at locations near operational reactors.
(X-33) As discussed in paragraph V-21, above, direct experience of reactor accidents suggests that the frequency of accident-induced severe core damage may be in the vicinity of 3.2xl 0-4 per reactor-year. Let us now consider the conditional probability of a pool fire, given severe core damage at a nearby reactor. Experience suggests that this conditional probability is less than 1, because there have been 5 core melts and 0 pool fires at commercial facilities. Given the present state of knowledge, selecting a value of 0.1 for this conditional probability is prudent. Thus, a reasonable estimate for the frequency of an accident-induced pool fire, associated with an accident at a nearby reactor, is 0.1x3.2x10- 4 = 3.2x10"5 per pool-year."19 That value is 13 times higher than the pool-fire frequency (i.e., 2.4x 10-6 per pool-year) at the upper end of the range asserted by the draft GEIS, and 55 times higher than the frequency (i.e., 5.8x10-7 per pool-year) at the lower end of the range.
(X-34) The discussion in the three preceding paragraphs can be structured in terms of the equation that is set forth in paragraph V-3 1, above. In that context, "PRA finding" is the pool-fire frequency asserted by the draft GEIS. The present state of knowledge suggests that "Reality factor #1" has a value of about one order of magnitude (i.e., factor of 10) at the upper end of the draft GEIS's frequency range. That value reflects the fact that the PRA-type analyses cited in the draft GEIS did not account for linkage of pool risk and reactor risk.
(X-35) As discussed in paragraph VI-1 1, above, the draft GEIS asserts that the probability of an attack-induced pool fire is "very low". In Section VI, however, I present evidence to the contrary. In my judgment, a prudent decision maker would i18 NRC, 2013b, Appendix F, Table F-1 (page F-4). Also see: Collins and Hubbard, 2001, Table 3.1 (page 3-9).
119 Here, I make the simplifying assumption that each reactor has a risk linkage with one nearby pool other than its own pool, and vice versa.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 46 of 120 conclude from this evidence that a successful attack on a reactor or spent-fuel-storage facility in the United States over the coming decades is as likely to occur as are major national challenges that are planned for, such as severe natural disasters or engagement in wars.
(X-36) Here, I expand slightly upon the discussion in Section VI, while being careful to not disclose information that would assist a potential attacker. First, consider a potential situation in which a malevolent actor creates a cascading sequence of incidents that includes a radioactive release from a reactor. Given such a situation, the radiation field created by the reactor release, and other influences, could preclude mitigating actions needed to keep nearby pools in a safe state.
(X-37) In paragraphs VIII-19 through VIII-22, above, I draw from analysis by Morris et al to discuss a potential situation in which a large aircraft strikes a reactor. That event could be a malevolent act. I show that the aircraft impact could be part of a cascading sequence of incidents that includes a pool fire. Since the attacks of 11 September 2001 in New York and Washington, acquisition of a large aircraft by a malevolent actor has become more difficult. Also, precise aiming of a large aircraft at low altitude is difficult.
However, a malevolent actor has other options. That actor might, for example, employ a comparatively small aircraft equipped with explosive devices.
(X-38) Now, consider a situation in which a malevolent actor has direct access to a pool.
NUREG-0575 postulated such a situation, as discussed in paragraphs VI-2 through VI-6, above. The malevolent acts postulated in NUREG-0575 are summarized in Table VI-1.
In the Mode 4 case, adversaries are assumed to temporarily take command of a spent-fuel pool while deploying an explosive device that could breach the floor of the pool. In that situation, as a slight adjustment of the Mode 4 case, the adversaries could use the explosive device to breach a wall of the pool, causing rapid drainage of water. The adversaries could ensure that some residual water is present. The exposed portion of the fuel would begin to heat up. Without prompt implementation of mitigating actions, a pool fire could follow. The adversaries could, in various ways, hinder or preclude mitigating actions.
(X-39) NRC proffers two, mutually inconsistent narratives about the threat of an attack on a spent-fuel pool. In one narrative, the pools are safe and secure, and no further action is needed to reduce the risk of a pool fire. In the other narrative, information about the potential for a pool fire must remain secret, because that information could be useful to an adversary.' 20 Both narratives cannot be true. Apparently, NRC recognizes that the pools are vulnerable to attack, but believes that hiding that vulnerability under a veil of secrecy will eliminate the potential for attack. That belief is imprudent. Non-State 120 NRC's consequence study mentions "security assessments" that were completed in 2006-2008, and further states that the results of these studies are not publicly available because they contain "sensitive information that could be useful to an adversary". (See: Barto et al, 2013b, page 14.)
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 47 of 120 adversaries of the United States have repeatedly demonstrated a level of technical knowledge such that they could readily understand the mechanisms underlying a pool fire, without recourse to NRC's secret studies. Thus, NRC's secrecy does not provide protection. Instead, it denies US citizens a full accounting of the risk of a pool fire.
Consequences of a poolfire (X-40) I now turn to discussing the consequences of a pool fire. The draft GEIS provides two types of quantitative estimate of the consequences of a pool fire. One type is the value of an outcome per event (i.e., per pool fire). The second type is the frequency-weighted value of the outcome, which is calculated by multiplying the value per event by the supposed frequency of the event. The supposed frequency is expressed on a per-pool-year basis. The draft GEIS takes the position that the frequency-weighted value is the appropriate indicator of an environmental impact. I reject that position, as discussed below. Here, I discuss consequences on a per-event basis.
(X-41) The draft GEIS sets forth the following estimates of quantitative outcomes of a pool fire, on a per-event basis, in its Table F-1 :121
      " Collective radiation dose ranging from 47,000 person-Sv to 260,000 person-Sv across the population living within 50 miles, with no accounting of collective dose at greater distances.
* Latent fatalities (i.e., deaths occurring months or years after the event) ranging from 20,000 to 27,000, across the population residing at distances up to 500 miles.
* Onsite and offsite economic damage ranging from $56 billion to $58 billion (in 2010 dollars).
(X-42) NRC's consequence study, which is not cited in the draft GEIS, provides some quantitative estimates of pool-fire consequences.' 22 These estimates do not appear in the draft GEIS. I discuss these estimates because they help to show that the draft GEIS substantially under-estimates the potential consequences of a pool fire. These estimates are specific to a potential fire at the Peach Bottom site in Pennsylvania. The particular estimates shown below are for an atmospheric release containing 330 PBq (i.e., 8.8 MCi) of the radioactive isotope Cs-137. That is a minor fraction of the inventory available for release. There are two operational reactors at the Peach Bottom site. Each reactor has its own spent-fuel pool, and each pool now contains about 2,180 PBq (i.e., 59 MCi) of Cs-137.123 The quantity (i.e., mass) of fuel in each pool is equivalent to 5 reactor cores. For 121 NRC, 2013b, Table F-I (page F-4).
122 The pool fire considered in NRC's consequence study would begin in recently-discharged fuel. In this declaration, I consider older spent fuel that falls under the ambit of the draft GEIS.
However, the consequences that I discuss would be determined primarily by the magnitude of release of comparatively long-lived radio-isotopes, principally Cs-137. Thus, the consequences predicted by NRC's consequence study are applicable to the situation that I consider.
123 Satorius, 2013b, Enclosure 1, Table 72 (page 133).
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 48 of 120 a postulated release of 330 PBq of Cs- 137, NRC's consequence study      24    predicts the following average outcomes of a pool fire, on a per-event basis:1 0 Collective radiation dose of 350,000 person-Sv across a population living within an unspecified distance.
* Land area interdicted (i.e., rendered unfit for habitation) of 24,300 square km (i.e.,
9,400 square miles). 125                            26
* Long-term displacement of 4.1 million people.'
(X-43) The numbers shown in paragraphs X-41 and X-42 begin to show the scale of the national disaster that could arise from a pool fire. Long-term displacement of 4.1 million people, which is an average case and not a worst case, would be a disaster of historic magnitude. 127 As discussed in paragraph IV-16, above, this event would cause substantial political stress and other adverse consequences. The social, political, and economic consequences would be diverse and difficult to predict, but would undoubtedly be severe. Moreover, the estimates described in paragraph X-42 assume a release of only 7% of the inventory of Cs-137 in the two pools at the Peach Bottom site. A larger release could occur.
(X-44) The estimate of economic damage that is set forth in the draft GEIS, and is shown in paragraph X-4 1, above, is much lower than other, more credible, estimates. Here, I discuss two estimates of this kind. One estimate is set forth in a 2004 journal article by Beyea et al.128 That article accompanies this declaration as Exhibit #46. The second estimate is set forth in a 2007 report by the French government agency IRSN.' 29 That report accompanies this declaration as Exhibit #47. A related paper by IRSN analysts is discussed in paragraphs IV- 11 through IV-13, above.
(X-45) Beyea et al considered two potential, atmospheric releases. One release would consist of 130 PBq (i.e., 3.5 MCi) of Cs-137, and the other release would consist of 1,300 PBq (i.e., 35 MCi) of Cs-137. These releases represent two possible outcomes of a pool fire. The larger release would represent 60% of the Cs-137 inventory now in each of the two pools at the Peach Bottom site. Beyea et al estimated offsite economic damage for the two releases, at each of five nuclear-power-plant sites. For the 130 PBq release, the estimated offsite economic damage, averaged across the five sites, was $91 billion. For 124  Barto et al, 2013b, Table 33 (page 162).
125  The relationship between the estimated average area of interdicted land and distance is as follows: 1,200 square miles within a 50-mile distance; 3,100 square miles within a 100-mile distance; and 9,400 square miles within a 500-mile distance. (See: Barto et al, 2013b, Table 35.)
126 The relationship between the estimated average number of displaced people and distance is as follows: 780,000 people within a 50-mile distance; 2.0 million people within a 100-mile distance; and 4.1 million people within a 500-mile distance. (See: Barto et al, 2013b, Table 36.)
12' For a given atmospheric release, the estimated number of displaced people varies with wind direction, atmospheric stability, precipitation, and other factors. NRC's consequence study presents an average case.
128 Beyea et al, 2004.
129 IRSN, 2007.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 49 of 120 the 1,300 PBq release, the estimated offsite economic damage, averaged across the five sites, was $385 billion.' 30 Both values are substantially higher than the economic-damage estimate of $56 billion to $58 billion, covering both onsite and offsite damage, that is set forth in the draft GEIS. Yet, Beyea et al did not consider a full range of contributors to offsite economic damage. Nor did they consider onsite economic damage.
(X-46) A more comprehensive set of contributors to economic damage was considered by IRSN. Their findings are set forth in Table X-1, drawing from IRSN's 2007 report.
That report was secret when first prepared, but was leaked to the press in early 2013 and, soon thereafter, was published by IRSN. The report considered an atmospheric release from a reactor at the Dampierre site in France. Economic damage was attributed primarily to the presence of 100 PBq of Cs- 137 in the release. Thus, IRSN's findings are applicable to a pool fire. This pool fire would not be a worst-case event. A release of 100 PBq of Cs-137 would represent only 5% of the Cs-137 inventory now in each of the two pools at the Peach Bottom site.
(X-47) The cost (i.e., economic damage) estimates shown in Table X-1 are in Euro.
Here, I use a currency conversion of US$1.40 per Euro. With that conversion, Table X-1 shows that IRSN's base-case estimate of economic damage from a release of 100 PBq of Cs-137 in France is $1,060 billion (760 billion Euro). The low-case estimate is $410 billion (290 billion Euro), and the high-case estimate is $8,060 billion (5,760 billion Euro). For comparison, the GDP of the United States in 2012 was $15,700 billion.'31 (X-48) A cost study of the type done by IRSN would yield different results if done for a US nuclear site. There is no reason to expect, however, that the estimated economic damage would be substantially lower in the US case. The damage could be higher.
Thus, IRSN's 2007 analysis provides, until a better estimate becomes available, a reasonable default estimate of economic damage from a pool fire in the United States that would release 100 PBq (2.7 MCi) of Cs-137. I am not aware of any other analysis that considers all of the cost contributors that are considered in the IRSN analysis. The draft GEIS's estimation of economic damage, as shown in paragraph X-41, is derived from analysis that is substantially inferior to the IRSN analysis.
(X-49) The economic damage estimated by IRSN would be only part of the consequences of a pool fire. The accompanying social and political consequences would be diverse and difficult to predict, but would undoubtedly be severe. Thus, a pool fire could be a national disaster of historic dimensions. That is why IRSN analysts, whose work is described in paragraphs IV- I1through IV-13, above, said in their 2012 paper that a massive release of radioactive material would be "an unmanageable European catastrophe". 132 In their 2012 paper, these analysts did not disclose the magnitude of a 130 Beyea et al, 2004, Table 3 (page 13 1);
131 World Bank website, "GDP (current US$)", accessed on 13 December 2013 at:
http://data.worldbank.org/indicator/N Y.GDP..M KTP.C D 132 Pascucci-Cahen and Patrick, 2012.
 
Thompson Declaration: Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 50 of 120 "massive" release. I assume that this release would contain no more than 100 PBq of Cs-137, the amount considered in IRSN's 2007 report. That report was secret when the IRSN analysts presented their 2012 paper.
(X-50) Japan's experience with fallout from the 2011 Fukushima accident is instructive.
The pattern of radioactive fallout across Japan is complex, as shown in Figure V-4. That fallout contained about 6 PBq of Cs-137, as shown in Table V-1. This amount of Cs-137 is comparatively small in the context of a potential release from a pool fire. Yet, the impacts of the Fukushima fallout on Japan are diverse and significant. For example, it is reported that 160,000 people were displaced from land contaminated by the Fukushima accident, and about one-third of this population remains in temporary housing. There is considerable uncertainty about the number of people who may be able to return to their homes.133 Also, all of Japan's nuclear power plants remain shut down, due to public concern about their operation.
Determinationof radiologicalrisk and environmental impact (X-5 1) I now turn to the final subject I address in Section X, namely the determination of radiological risk and environmental impact. As discussed in Section IV, above, NRC employs what I describe as an ."arithmetic" definition of risk. That definition is fundamentally flawed for the reasons I set forth in Section IV.
(X-52) The flawed nature of the arithmetic definition of risk is clearly evident in the draft GEIS, NRC's consequence study, and the NRC staff's Tier 3 analysis. Each of those documents uses frequency-weighted consequences, as discussed in paragraph X-40, above, as a measure of environmental impact. In that manner, disastrous consequences of a potential pool fire, such as the long-term displacement of 4.1 million people, are made to appear small by multiplying the consequences by a supposedly low frequency.
(X-53) Also, NRC focuses on each facility in isolation. That focus is evident in NRC's discussion of frequency in terms of occurrence per reactor-year or per pool-year. For some, limited, technical purposes, this single-facility focus is appropriate. It is, however, inappropriate when considering the risk experienced by a citizen. The United States currently has 100 operational, commercial reactors, roughly the same number of spent-fuel pools, and various other nuclear facilities.' 3 4 A citizen is exposed to the radiological risk associated with a number of facilities. This point is illustrated by NRC's finding, as discussed in paragraph X-42, above, that a pool fire at the Peach Bottom site could lead to the long-term displacement of 4.1 million people. About 800,000 of those people would have resided within 50 miles of the site, while about 1.2 million would have resided between 50 and 100 miles from the site, and about 2.1 million would have resided 03Knight and Slodkowski, 2013.
134 An operational reactor is a reactor that is normally in operation except when shut down for refueling, maintenance, or repair.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 51 of 120 between 100 and 500 miles from the site.' 3 5 Clearly, this event would have long-range consequences, extending far beyond the vicinity of the afflicted site. A citizen at a given location could be vulnerable to impacts of this nature originating at any of a number of sites. 136 (X-54) Moreover, if such an event occurred, citizens would experience significant consequences even if they did not suffer from substantial, immediate injury such as displacement from their homes. The economic, social, and political consequences of this event would be felt by everyone residing in the United States, and by many people outside its borders. This pool fire would be a national disaster with international implications.
(X-55) Thus, in considering the probability of a pool fire, an appropriate indicator would be the frequency of the event occurring anywhere in the United States during a specified time period. Given the existence of operational reactors in Canada and Mexico, the geographic perimeter might logically be extended to North America. For the purposes of this declaration, however, I set that option aside because it would be legally and politically difficult to implement.
(X-56) What would be the appropriate time period for a determination of frequency?
Given that a pool fire could be a national disaster of historic dimensions, a reasonable time period would be a century. If that time period were employed in the context of the United States as a geographic unit, then the frequency of a pool fire would be expressed in terms of the number of occurrences per century, where the occurrence could be at any location within the United States. This concept of frequency would be compatible with the particular characteristics of pool-fire risk. Hereafter, I refer to this concept as "cumulative frequency". Note, as discussed previously, that this indicator could have a value greater than 1.
(X-57) There are now 100 operational reactors in the United States.. As discussed in Section IX, above, the draft GEIS allows for the continuation of this situation indefinitely. Thus, for the purpose of illustrating pool-fire risk, it is reasonable to consider a scenario in which 100 reactors are operational throughout a period of 100 years. In this scenario, each reactor has a risk linkage with one nearby pool other than its own pool, and vice versa. Each of these nearby pools is assumed to fall under the ambit of the draft GEIS because the reactor that it served is no longer licensed for operation. I assume that each nearby pool is equipped with high-density racks, and that the risk posed by each reactor-pool linkage is uniform across the fleet and constant over time. This "status quo" scenario is entirely compatible with the draft GEIS.
5lBarto et al, 2013b, Table 36 (page 169).
136 The flexRISK project in Austria developed a computer-model capability to assess the radiological risk, at any location in Europe, that arises from operation of all nuclear facilities across Europe. That capability could be applied to the United States. An overview of the flexRISK project was accessed on 14 December 2013 from:
hltti://flexrisk.boku.ac.at/en/index.htin I
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 52 of 120 (X-58) For this illustrative scenario, the cumulative frequency of a pool fire can be determined by simple extrapolation of current estimates of pool-fire frequency, which are expressed on a per-pool-year basis. Consider first the frequency estimate of 2.4xl 0-6 per pool-year that is set forth in the draft GEIS in the context of an accident-induced pool fire, as discussed in paragraph X-3 1, above. In that case, the cumulative frequency would be 100x100x2.4x 10- 6 = 0.024 events per century. Now, consider the revised frequency estimate of 3.2x1 0-5 per pool-year that is set forth in paragraph X-33. This revised estimate accounts for linkage of pool risk and reactor risk, still in the context of an accident-induced Fool fire. In this case, the cumulative frequency would be lOOxlOOx3.2x 10 = 0.32 events per century.
(X-59) At this point in Section X, I am ready to evaluate the draft GEIS's assessment of the environmental impact of pool fires. I provide this evaluation in paragraph X-60, addressing accident-induced pool fires, and in paragraph X-61, addressing attack-induced pool fires. In both cases, I find that the draft GEIS's assessment of environmental impact is incorrect. Paragraphs X-60 and X-61 provide my evaluation and its underlying rationale.
(X-60) The draft GEIS asserts that the environmental impact of accident-induced pool fires is SMALL.137 However, as shown above, the draft GEIS indicates that the cumulative frequency of such fires could be 0.024 events per century. Also, NRC's consequence study shows that the consequences of a pool fire could be severe, with outcomes such as the long-term displacement of 4.1 million people. IRSN's analysis shows that outcomes could include economic damage measured in trillions of dollars.
Therefore, the environmental impact of accident-induced pool fires is not SMALL.
Instead, it is LARGE. This finding does not account for linkage of pool risk and reactor risk. If that linkage is accounted for, as is appropriate, the cumulative frequency of accident-induced pool fires could be 0.32 events per century. In that case, it is even more evident that the environmental impact of accident-induced pool fires is not SMALL.
Instead, it is LARGE. Thus, the draft GEIS substantially under-estimates the environmental impact of accident-induced pool fires. Also, the draft GEIS ignores the possibility that the risk environment will become more adverse in the future. In addition, the draft GEIS uses a flawed definition of risk - the arithmetic definition.
(X-61) The draft GEIS further asserts that the environmental impact of attack-induced pool fires is SMALL.' 38 However, from the discussions in Section VI and paragraphs X-35 through X-39, above, it is clear that the cumulative frequency of attack-induced pool fires could be substantial. Also, NRC's consequence study shows that the consequences of a pool fire could be severe, with outcomes such as the long-term displacement of 4.1 million people. IRSN's analysis shows that outcomes could include economic damage measured in trillions of dollars. Therefore, the environmental impact of attack-induced 13' NRC, 2013b, Table 4-2 (page 4-91).
13'NRC, 2013b, Table 4-2 (page 4-91).
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 53 of 120 pool fires is not SMALL. Instead, it is LARGE. Thus, the draft GEIS substantially under-estimates the environmental impact of attack-induced pool fires. Also, the draft GEIS ignores the possibility that the risk environment will become more adverse in the future. In addition, the draft GEIS uses a flawed definition of risk - the arithmetic definition. Moreover, application of the arithmetic definition is additionally flawed in this instance because the indicators that are multiplied together are nebulous.
XI. Cask Fire: Probability and Consequences (XI-1) The draft GEIS assumes that spent fuel will be stored initially in pools and subsequently in dry casks. A group of dry casks will constitute an ISFSI. During cask storage there is a potential for a "cask fire". That event could occur if a malevolent actor gains access to a dry cask containing spent fuel and attacks the cask in a manner that produces a self-propagating reaction between air and zircaloy fuel cladding, leading to a substantial atmospheric release of radio-isotopes including Cs-137. An accident could conceivably cause a cask fire at a storage facility, but I do not consider that possibility here. The draft GElS does not consider the occurrence of a cask fire caused by either accident or attack.
(XI-2) In the Thompson scoping declaration, I outlined the potential for an attack-induced cask fire.139 I first discussed a potential precursor to a cask fire - a reasonably foreseeable attack that would penetrate a cask, damage fuel inside the cask, and cause a release of radioactive material to the atmosphere. The feasibility of such an attack has been demonstrated in tests whose findings have been openly published. In my judgment, an attacker could, with a few additional steps, readily initiate a cask fire. NRC has not conceded that an attacker could take these additional steps and initiate a cask fire.
(XI-3) The difference between my position and that of NRC could be resolved by commissioning an independent "Red Team" of persons who have relevant experience in practice and research. That team could conduct tests at a national laboratory or military base, to determine how readily a cask fire could be initiated. The tests could involve the use of tracer materials, thereby contributing to estimation of the radioactive release that could result from a cask fire. The general findings of the tests should be published, but some details of the tests may not be appropriate for publication. Until such tests are done, NRC will not be able to complete an adequate GEIS on the environmental impacts of storing spent fuel.
(XI-4) The probability and impacts of an attack-induced cask fire are interrelated. Also, the relationship between probability and impacts is influenced by the extent to which casks are protected from attack. Moreover, the difference between the risk of attack-induced pool fires and the risk of attack-induced cask fires is a significant issue in the context of national security. The concept of protective deterrence provides a useful perspective on that difference. These matters are discussed below.
139 Thompson, 2013b, paragraphs VII- 15 through VII- 16 and VIII-14 through VIII- 18.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 54 of 120 (XI-5) The effort needed to successfully attack an ISFSI and produce a cask fire could be roughly the same as the effort needed to successfully attack a spent-fuel pool and produce a pool fire. Let us examine the implications of that finding during a future period when pools and ISFSIs coexist. As discussed in paragraph VI-10 and elsewhere in this declaration, there is persuasive evidence that an attack-induced pool fire is as likely to occur as are major national challenges that are planned for, such as severe natural disasters or engagement in wars. An identical statement could be made about a cask fire, if two provisos were satisfied. The first proviso is that attackers would be able to achieve roughly the same outcomes by attacking a pool or an ISFSI. If that proviso were not satisfied, and the attack on the ISFSI would achieve a lower outcome, the attackers would have a reduced incentive to attack the ISFSI. The second proviso is that the casks sit on concrete pads in the open air without additional protection, which is current practice. If that proviso were not satisfied, and additional protection was provided, the attackers would have to expend greater effort to achieve the same outcome, which would reduce their incentive to attack.
(XI-6) These provisos show how probability and impacts are interrelated. If the expected outcome of an attack on an ISFSI would be smaller than the outcome of an attack on a pool, other factors being equal, then a malevolent actor would be less likely to attack the ISFSI. The probability of the attack would decrease even further if the casks in the ISFSI were provided with additional protection against attack. Thus, either decreasing the expected outcome of an attack, or increasing the effort required to achieve a given outcome, would decrease the probability of attack. In the context of national security, that effect is encompassed within the concept of protective deterrence.
Implementation of that concept could benefit the nation. Accordingly, 0
the Thompson scoping declaration made the following recommendation:14 "Recommendation #22: In assessing the overall impacts of storing SNF or HLW, the proposed EIS [i.e., the draft GEIS] should consider the implications of alternative storage options for a national strategy of protective deterrence."
(XI-7) Table XI- 1 shows how the United States could benefit from policies that ensured that critical infrastructure is designed to be robust and inherently safer. The benefits could include, for example, a reduction in the federal government's perceived need to conduct surveillance of the domestic population. That matter is a subject of current debate. Designing critical infrastructure to be robust and inherently safer would be part of a national strategy of protective deterrence.
(XI-8) Nuclear facilities - including reactors, pools, and ISFSIs using dry casks - are components of critical infrastructure. In the context of storing spent fuel, a dry cask is more robust and inherently safer than is a pool equipped with high-density racks. A dry cask in an ISFSI with enhanced protection would be even more robust and inherently 140 Thompson, 2013b, Section IX and Section X.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 55 of 120 safer. Thus, the aspects of radiological risk that I discuss in this declaration are significant for national security, and could be productively addressed within the context of protective deterrence. The draft GElS is oblivious to this matter, and does not respond to my recommendation as quoted in paragraph XI-6, above. More generally, NRC appears oblivious to its potential ability to benefit the nation by implementing principles of protective deterrence.
(XI-9) The first step in assessing potential consequences of an attack-induced cask fire is to determine the inventory of radioactive material that is in the cask and available for release. Here, I focus on the radio-isotope Cs-137. I consider, as an illustrative example, a cask holding 32 PWR fuel assemblies. With reasonable assumptions, one can readily calculate that the cask contains 67 PBq (i.e., 1.8 MCi) of Cs-137.141 (XI-10) A successful attack on an ISFSI, in which attackers expended an effort roughly the same as the effort needed to successfully attack a spent-fuel pool and cause a pool fire, could cause a cask fire in one or perhaps two casks. For illustration, let us assume that two casks would experience a fire and the fractional release of Cs-137 to the atmosphere would be 50%. In that case, the total atmospheric release from two typical casks holding 32 PWR fuel assemblies per cask would contain 67 PBq of Cs-137. That would be a substantial release, with a magnitude between the Fukushima release (36 PBq) and the Chernobyl release (85 PBq), as shown in Table V-1.
(XI- 11) Section X, above, discusses the consequences of atmospheric releases of various amounts of Cs-137. For example, as discussed in paragraph X-42, release of 330 PBq of Cs-137 could lead to severe consequences including long-term displacement of 4.1 million people. Also, as discussed in paragraphs X-46 through X-48, release of 100 PBq of Cs-137 could create economic damage of about $1 trillion in the "base" case and $8 trillion in the "high" case. In addition, there would be severe consequences of a social and political nature.
(XI-12) Thus, it is clear that a release of 67 PBq of Cs-137 during a cask-fire incident could lead to severe consequences. Yet, a pool fire could lead to a much larger release, with correspondingly greater consequences. For example, as noted in paragraph X-42, each of the two pools at the Peach Bottom site now contains about 2,180 PBq of Cs-137.
The fractional release of Cs- 137 during a pool fire could be substantial, potentially exceeding 50%. At Peach Bottom, where two pools are in close proximity, an attack on one pool could ultimately lead to fires in both pools. Thus, a pool-fire release exceeding 2,000 PBq of Cs-137 is entirely credible.
141 Assumptions in the calculation are: (i) there are 32 PWR spent fuel assemblies in the cask; (ii) each fuel assembly has a mass of 0.45 Mg HM; (iii) the fuel has a burnup of 50 GWt-days per Mg HM; (iv) the fuel is aged 4
10 years after discharge from a reactor; and (v) 1 GWt-day of fission energy yields 1.1 7x101 Bq of Cs-137.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 56 of 120 (XI-13) The effort needed to successfully attack an ISFSI and produce an atmospheric release of 67 PBq of Cs-137 could be roughly the same as the effort needed to successfully attack a spent-fuel pool and produce a pool fire. However, the pool-fire release could be much larger than 67 PBq of Cs-137. As discussed above, at Peach Bottom a pool-fire release could exceed 2,000 PBq of Cs-137. Informed attackers would be aware of this discrepancy in potential outcomes. Accordingly, they would tend to target a pool rather than an ISFSI, other factors being equal. If the ISFSI were provided with enhanced protection, the comparative attractiveness of the ISFSI as a target would be even lower. Section XII, below, discusses some options for providing ISFSIs with enhanced protection.
(XI-14) At present, pools and ISFSIs coexist in the United States. Thus, given the comparative attractiveness of pools and ISFSIs as targets, a successful attack on a pool is currently more likely than a successful attack on an ISFSI. However, the draft GEIS contemplates a future in which there would be ISFSIs and no pools. That situation could continue into the indefinite future. Diminution of radioactive decay heat in spent fuel over time would be irrelevant to the creation of a cask fire. The risk environment could become more adverse over time. For example, security measures at ISFSIs could degrade over time. Also, an increased propensity for violent conflict could find expression through attacks on ISFSIs. Thus, the frequency of successful attacks on ISFSIs could be much greater in the future than it is today.
(XI- 15) The findings set forth in Section XI, up to this point, support three conclusions about the environmental impact of attacks on ISFSIs. Here, I use the creation of one or more cask fires as an indicator of the success of an attack on an ISFSI.
(XI-16) The first conclusion is as follows. As discussed in paragraph VI- 11, above, the draft GEIS asserts that the environmental impact of attacks on ISFSIs is SMALL.
However, the cumulative frequency of successful attacks on ISFSIs could be substantial.
Also, the consequences of a successful attack could be severe. Therefore, the environmental impact of attacks on ISFSIs is not SMALL. Instead, it is LARGE. Thus, the draft GEIS substantially under-estimates the environmental impact of attacks on ISFSIs. Also, the draft GEIS ignores the possibility that the risk environment will become more adverse in the future. In addition, the draft GEIS uses a flawed definition of risk - the arithmetic definition. Moreover, application of the arithmetic definition is additionally flawed in this instance because the indicators that are multiplied together are nebulous.
(XI-17) The second conclusion is as follows. While pools and ISFSIs coexist, as is true today, the cumulative frequency of successful attacks on pools is likely to exceed the cumulative frequency of successful attacks on ISFSIs. However, the-draft GEIS contemplates a future in which there would be ISFSIs and no pools. In that case, the cumulative frequency of successful attacks on ISFSIs could be comparable to the currently-applicable cumulative frequency of successful attacks on pools, if there were no change in the risk environment. Whether or not pools coexist with ISFSIs in the future,
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 57 of 120 the risk environment could become more adverse, leading to an increase in the cumulative frequency of successful attacks on ISFSIs.
(XI- 18) The third conclusion is as follows. The cumulative frequency of successful attacks on ISFSIs, now and in the future, could be decreased by providing ISFSIs with enhanced protection against attack.
XII. Risk-Reducing Options (XII- 1) There are numerous options for reducing the radiological risk arising from management of spent fuel and other radioactive waste produced by the nuclear fuel cycle.
The draft GElS does not discuss any options of this type. Here, I provide a brief discussion of a few options. This discussion does not purport to be comprehensive.
(XII-2) Table XII- I outlines some options for reducing the risk of a pool fire at a nuclear power plant. This table was prepared in the context of a spent-fuel pool that serves an operational reactor. A similar table could be prepared for a pool that no longer serves an operational reactor.
(XII-3) The most effective option in Table XII-I is to re-equip the pool with low-density, open-frame racks. In the case of BWR fuel, a corollary action could be the removal of channel boxes from the fuel. When nuclear power plants in the present US fleet first entered service, their spent-fuel pools were equipped with low-density, open-frame racks.
The margin of safety provided by this configuration was lost when the nuclear industry adopted high-density racks as a way to minimize short-term costs.
(XII-4) Over a period of decades, pursuit of short-term cost minimization has increased the radiological risk of nuclear power production in various respects. This pursuit influenced the design of the nuclear power plants that participated in the Fukushima accident of 2011. Other manifestations of this pursuit include reactor power uprates, use of higher-burnup fuel, shorter refueling periods, and use of high-density racks in spent-fuel pools.
(XII-5) Section XI, above, discusses some of the implications of providing enhanced protection of ISFSIs. In the United States, a typical ISFSI consists of dry casks sitting on a concrete pad in the open air. Other countries provide greater protection.
(XII-6) Sweden has taken an interesting approach to ISFSI design. The Swedes have built the Clab facility, in which spent-fuel pools are located in underground caverns excavated in rock. The Clab facility has been described in a brochure published by SKB,;
the company that manages Sweden's radioactive waste.14 2 That brochure accompanies this declaration as Exhibit #48. One sees from the brochure that the ceiling of each cavern is 32 m below the surface. The intervening rock is granite.
142 SKB, 2006.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 58 of 120 (XII-7) The Clab facility will probably not be replicated in the United States. It represents a comparatively expensive approach to managing spent fuel. Also, although Clab is not designed as a repository, there might be political pressure to employ such a facility as a repository if repeated efforts to build a repository were to fail. For that reason, I recommend that interim storage of spent fuel be done at the surface, to reduce the likelihood that an interim storage facility could become a repository by default.
(XII-8) The German approach to ISFSI design is to store spent fuel in dry casks that are, with one exception, located within buildings at the surface. 143 The design of these buildings is described in a conference paper by Thomauske.44 That paper accompanies this declaration as Exhibit #49. Two basic designs are used. One design is by STEAG, and the other by WTI. Cross-sectional drawings in Thomauske's paper suggest that the STEAG design would be more robust against attack. That observation is confirmed by analyses showing that the STEAG design would be more robust against impact by a large aircraft.
(XII-9) Holtec is a US-based vendor of dry casks used for storing spent fuel at ISFSIs.
The Holtec design approach is modular. Fuel is sealed inside a multi-purpose canister (MPC) that is designed to be placed inside overpacks of various types. Holtec has developed an overpack, known as the HI-STORM 1OOU, that would be more robust against attack than present overpacks. A standard MPC would be placed, in a vertical-axis position, inside the IOOU overpack. The IOOU overpack would be sunk below ground except for its lid. Holtec has described the robustness of the 1OOU system as follows: 145 "Release of radioactivity from the HI-STORM 1OOU by any mechanical means (crashing aircraft, missile, etc.) is virtually impossible. The only access path into the cavity for a missile is vertically downward, which is guarded by an arched, concrete-fortified steel lid weighing in excess of 10 tons. The lid design, at present configured to easily thwart a crashing aircraft, can be further buttressed to withstand more severe battlefield weapons, if required in the future for homeland security considerations. The lid is engineered to be conveniently replaceable by a later model, if the potency of threat is deemed to escalate to levels that are considered non-credible today."
(XII-10) Paragraphs XII-6 through XII-9 show that options are available for providing enhanced protection of ISFSIs. Use of such options at ISFSIs across the United States would support a national strategy of protective deterrence.
143 The exception is the Neckarwestheim ISFSI, which consists of two concrete-lined tunnels in the wall of a quarry.
144 Thomauske, 2003.
145 Holtec, 2007. A current description of the 100U system was accessed on 15 December 2013 from: htip://wwwvk.lioltecinteina-tiotnal.coim/producisandservices/wasteandiuelmanaiementt/hii-storm/
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 59 of 120 XIII. Conclusions (XIII-1) I provide conclusions in two categories. The first category is "reference conclusions". These are set forth at some length, linked consecutively to the portions of this declaration from which they were derived. The second category is "summary conclusions". These are expressed concisely, and are arranged to support a coherent argument.
(XIII-2) The reference conclusions, and the body of this declaration, represent my definitive findings. The summary conclusions may be less exact.
(XIII-3) My reference conclusions are set forth below. The heading for each conclusion shows the portion of this declaration from which the conclusion was principally derived.
These conclusions are:
Reference Conclusion #1 (derived from Section IV)
The draft GElS defines radiological risk as the numerical product of the probability and the consequences of an event, and further argues that a high-consequence, low-probability event, such as a severe accident, could be determined to have a small environmental impact if the risk is sufficiently low. In the context of the draft GEIS, that definition of radiological risk, and the associated determination of environmental impact, are fundamentally flawed from at least four overlapping perspectives:
0 First, numerical estimates of consequences and probability are typically incomplete and highly uncertain.
* Second, significant aspects of consequences and probability are not susceptible to numerical estimation.
0 Third, larger consequences can be qualitatively different than smaller consequences.
0 Fourth, devotees of this definition of risk typically argue, as does the draft GEIS, that equal levels of "risk", as they define it, should be equally acceptable to citizens. That argument may be given a scientific gloss, but is actually a statement laden with subjective values and interests. An informed citizen could reject the argument on reasonable grounds.
Reference Conclusion #2 (derived from Section V)
The draft GElS relies on PRA-type studies for its estimation of radiological risk. Studies of this type can provide useful information about radiological risk, for certain purposes.
However, these studies cannot provide a credible estimate of the probability of a radiological event such as a pool fire. The relationship between a PRA finding and reality can be represented as follows:
 
Thompson Declaration.'Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 60 of 120 Actual probability of event = (PRA finding)x(Reality factor #1) + (Reality factor #2)
Where the variables in this equation are as follows:
    " "Actual probability of event" refers to the real-world numerical probability of an outcome such as: fuel damage; release of a specified amount of radioactive material; contamination of a specified area of land above a specified dose threshold; or accrual of a specified collective dose to people offsite.
    " "PRA finding" refers to a PRA estimate of the probability of the outcome in question - this could be a mean, median, or other representation of a probability distribution.
    * "Reality factor #1" is a number, typically greater than 1, that represents influences that are within the paradigm of PRA but are not properly accounted for in contemporary PRAs - these influences include: complexity; inadequate data; and deficiencies in institutional culture and practice.
    * "Reality factor #2" is a number that represents influences outside the paradigm of PRA - these influences include: gross errors in design, construction, or operation; and malevolent acts.
And the following observations apply:
* Experience suggests that Reality factor #1 for severe accidents may have a value that exceeds I by several orders of magnitude (i.e., factors of 10).
* Reality factor #2 has two numerical components: (i) a retrospective component that can be determined empirically based on the occurrence of events; and (ii) a prospective component that will remain unknown for the foreseeable future.
    " Both Reality factors may vary significantly in response to variations in the future risk environment.
* This version of the equation is applicable when the values of "PRA finding" and "Actual probability of event" are both less than 1. At higher values, the term "probability" would be replaced by the term "frequency".
Reference Conclusion #3 (derived from Section VI)
In light of human history, observation of the contemporary world, and consideration of possible, societal trends, a prudent decision maker would conclude that a successful attack on a reactor or spent-fuel-storage facility in the United States over the coming decades is as likely to occur as are major national challenges that are planned for, such as severe natural disasters or engagement in wars.
Reference Conclusion #4 (derived from Section VII)
The draft GEIS sets forth a highly optimistic view of the future conditions that will affect stored spent fuel. It assumes that institutional controls will remain operative into the indefinite future, arguing that this assumption "avoids unreasonable speculation regarding
 
Thompson Declaration:Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 61 of 120 what might happen in the future". This assumption, like other optimistic assumptions in the draft GEIS, is neither reasonable nor prudent. Moreover, assuming static conditions is speculative in the extreme, and shows a profound ignorance of human history. Given the long timeframes envisioned in the draft GEIS, the only reasonable approach is to consider a broad range of scenarios. Those scenarios would encompass substantial changes in the risk environment over time. The changes could be non-uniform across the United States.
Reference Conclusion #5 (derived from Section VIII)
Pool storage of spent fuel, as considered in the draft GEIS, could occur, and probably will occur, at locations near operational reactors. Accordingly, the draft GEIS should have carefully considered the potential linkage of radiological risk among pools and operational reactors at each site. The draft GEIS has not considered this matter.
Reference Conclusion #6 (derived from Section VIII)
Risk linkages among spent-fuel pools and operational reactors at a site could be manifested in a cascading sequence of incidents that preclude mitigating actions needed to maintain pools in a safe state. Mitigating actions could be precluded by, for example, a radiation field arising from the release of radioactive material. NRC has never, to my knowledge, published a credible technical analysis of a cascading sequence of incidents of this type, or publicly stated that it has performed such analysis in secret. Until such analysis is done properly, NRC will not be able to complete an adequate GEIS on the environmental impacts of storing spent fuel.
Reference Conclusion #7 (derived from Section IX)
The draft GEIS does not set forth any scenario for the future use of nuclear power or, more specifically, for the future creation of spent fuel. Thus, in the draft GEIS, the timeframe for creation of spent fuel spans an unknown but potentially vast range, as does the quantity of spent fuel created in that timeframe. Accordingly, the radiological risk posed by storing spent fuel is unbounded. In this manner, the draft GEIS has denied itself the ability to assess the long-term radiological risk of storing spent fuel. One cannot assess a quantity that is unbounded. This grave deficiency could have been avoided by judicious use of scenarios. A scenario-based approach could, in principle, have allowed the draft GEIS to bound the radiological risk of storing spent fuel. Moreover, such an approach could have allowed the draft GEIS to compare the risk posed by different scenarios and different options for managing spent fuel.
Reference Conclusion #8 (derived from Section X)
The draft GEIS fails to cite a number of documents that are relevant to its findings about the risk of pool fires. Moreover, some recently published documents in this category had a substantial but undocumented influence on the draft GEIS. The lack of documentation
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 62 of 120 of this influence handicaps those who seek to comment on the draft GEIS. Documents not cited in the draft GEIS that are particularly 46 significant include:
* Appendix    J of NUREG-0575.1
* NRC's consequence study. 147 4 8
* The NRC staff's Tier 3 analysis.'
Reference Conclusion #9 (derived from Section X)
The draft GEIS reflects NRC's present understanding of phenomena relevant to a pool fire. That understanding is deficient from the following perspectives:
* NRC failed to understand a comparatively simple technical issue for more than two decades, because its staff were shielded from public challenge and did not engage in the open discourse that is essential to scientific inquiry.
      " With limited exceptions, NRC staff remain shielded from public challenge and scientific discourse.
      " NRC's latest analysis of pool fires (i.e., NRC's consequence study) ignores a number of technical issues that are significant to a determination of pool-fire risk.
* The NRC staff proposes to close off further inquiry into pool-fire risk.
* Apparently, the NRC staff believes that the acquisition of a thorough understanding of pool-fire phenomena is unnecessary because the probability of unmitigated partial or total loss of water from a pool is negligible.
Reference Conclusion #10 (derived from Section X)
The draft GEIS significantly under-estimates the probability of an accident-induced pool fire, in part because it does not consider the linkage of pool risk and reactor risk. The present state of knowledge suggests that the under-estimate is by at least one order of magnitude (i.e., factor of 10).
Reference Conclusion #11 (derived from Section X)
The draft GEIS significantly under-estimates the probability of an attack-induced pool fire. That probability cannot be determined quantitatively. My qualitative assessment is provided in Conclusion #3, above.
Reference Conclusion #12 (derived from Section X)
The draft GEIS substantially under-estimates the consequences of a pool fire. Those consequences could include the long-term displacement of millions of people, economic damage measured in trillions of dollars, and adverse social and political outcomes. A pool fire yielding these consequences would be a national disaster of historic dimensions.
146 NRC, 1979.
147 Barto et al, 2013b.
148 Satorius, 2013b.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 63 of 120 Reference Conclusion # 13 (derived from Section X)
The draft GEIS considers the risk of a pool fire in terms of the probability of its occurrence at a particular pool within a 1-year timeframe. That approach to risk assessment does not account for the potential magnitude and scope of the consequences of a pool fire. Instead, the radiological risk of a pool fire should be considered in terms of the cumulative frequency of its occurrence, over a period of a century, at any location within the United States.
Reference Conclusion #14 (derived from Section X)
The draft GEIS asserts that the environmental impact of accident-induced pool fires is SMALL. However, the cumulative frequency of such fires is substantial, and the consequences of a pool fire could be severe. Therefore, the environmental impact of accident-induced pool fires is not SMALL. Instead, it is LARGE. Thus, the draft GEIS substantially under-estimates the environmental impact of accident-induced pool fires.
Also, the draft GEIS ignores the possibility that the risk environment will become more adverse in the future. In addition, the draft GEIS uses a flawed definition of risk - the arithmetic definition.
Reference Conclusion # 15 (derived from Section X)
The draft GEIS asserts that the environmental impact of attack-induced pool fires is SMALL. However, the cumulative frequency of such fires is substantial, and the consequences of a pool fire could be severe. Therefore, the environmental impact of accident-induced pool fires is not SMALL. Instead, it is LARGE. Thus, the draft GEIS substantially under-estimates the environmental impact of attack-induced pool fires.
Also, the draft GEIS ignores the possibility that the risk environment will become more adverse in the future. In addition, the draft GEIS uses a flawed definition of risk - the arithmetic definition. Moreover, application of the arithmetic definition is additionally flawed in this instance because the indicators that are multiplied together are nebulous.
Reference Conclusion #16 (derived from Section XI)
The draft GEIS asserts that the environmental impact of attacks on ISFSIs is SMALL.
However, the cumulative frequency of successful attacks on ISFSIs could be substantial.
Also, the consequences of a successful attack could be severe. Therefore, the environmental impact of attacks on ISFSIs is not SMALL. Instead, it is LARGE. Thus, the draft GEIS substantially under-estimates the environmental impact of attacks on ISFSIs. Also, the draft GEIS ignores the possibility that the risk environment will become more adverse in the future. In addition, the draft GEIS uses a flawed definition of risk - the arithmetic definition. Moreover, application of the arithmetic definition is additionally flawed in this instance because the indicators that are multiplied together are nebulous.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 64 of 120 Reference Conclusion #17 (derived from Section XI)
While pools and ISFSIs coexist, as is true today, the cumulative frequency of successful attacks on pools is likely to exceed the cumulative frequency of successful attacks on ISFSIs. However, the draft GEIS contemplates a future in which there would be ISFSIs and no pools. In that case, the cumulative frequency of successful attacks on ISFSIs could be comparable to the currently-applicable cumulative frequency of successful attacks on pools, if there were no change in the risk environment. Whether or not pools coexist with ISFSIs in the future, the risk environment could become more adverse, leading to an increase in the cumulative frequency of successful attacks on ISFSIs.
Reference Conclusion #18 (derived from Section XI)
The cumulative frequency of successful attacks on ISFSIs, now and in the, future, could be decreased by providing ISFSIs with enhanced protection against attack.
Reference Conclusion #19 (derived from Section XII)
The draft GEIS does not consider options for reducing the radiological risk arising from management of spent fuel. However, numerous options of this kind are available. For example, options are available for providing enhanced protection of ISFSIs. Use of such options at ISFSIs across the United States would support a national strategy of protective deterrence.
(XIII-4) My summary conclusions are set forth below. They are:
Summary Conclusions
: 1. The draft GElS asserts that the environmental impact of accident-induced or attack-induced pool fires is SMALL in both cases. That assertion is incorrect.
The environmental impact is LARGE in both cases.
: 2. The draft GEIS asserts that the environmental impact of attacks on ISFSIs is SMALL. That assertion is incorrect. The environmental impact is LARGE.
: 3. The draft GEIS's assertions regarding the environmental impacts of pool fires and attacks on ISFSIs are incorrect because the draft GELS: (i) employs an inappropriate definition of radiological risk; (ii) inappropriately assesses radiological risk on a single-facility basis over a one-year period; and (iii) under-estimates the probability and consequences of radiological incidents at pools and ISFSIs.
: 4. An appropriate definition of radiological risk would: (i) account for qualitative factors affecting probability and consequences; (ii) recognize qualitative differences between small and large consequences; and (iii) repudiate the idea that large consequences are tolerable if their supposed probability is low.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 65 of 120
: 5. An appropriate assessment of radiological risk at pools and ISFSIs would examine cumulative risk across all US facilities over a period of a century, and would account for potential changes in the risk environment.
: 6. The draft GEIS under-estimates the probability and consequences of radiological incidents at pools and ISFSIs because: (i) NRC has not conducted the comprehensive empirical and analytic inquiry needed to thoroughly understand probability and consequences in this context; (ii) NRC staff are shielded from public challenge and scientific discourse; and (iii) NRC inappropriately assumes that the risk environment will remain static.
: 7. The NRC staff proposes to close off further inquiry into the probability and consequences of radiological incidents at pools.
: 8. NRC has ignored my recommendation to conduct further inquiry into the probability and consequences of cask fires.
: 9. Options are available to reduce the probability and consequences of radiological incidents at pools and ISFSIs, with collateral benefits to the nation via enhancement of protective deterrence, but these options are ignored in the draft GELS.
I declare, under penalty of perjury, that the facts set forth in the foregoing narrative, and in the four appendices below, are true and correct to the best of my knowledge and belief, and that the opinions expressed therein are based on my best professional judgment.
Executed on 19 December 2013.
Gordon R. Thompson
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 66 of 120 APPENDIX A: Tables and Figures List of Tables Table IV-1: Some Categories of Risk Posed by a Commercial Nuclear Facility: Author's Definitions Table V-I: Amounts of Cesium-137 Related to the Chernobyl and Fukushima #1 Accidents Table V-2: Estimated Human Dose Commitment from the Chemobyl Release of Radioactive Material to Atmosphere in 1986 Table V-3: Insurance Premiums Paid by Ontario Power Generation (OPG) for Nuclear Liability and Terrorism Coverage of the Darlington Station, 2005-2012 Table V-4: Accident-Probability Implications of Insurance Premiums Paid by PPG for Coverage Associated with Operation of the Darlington Station Table VI-1: Potential Sabotage Events at a Spent-Fuel Storage Pool, as Postulated in NRC's August 1979 GEIS on Handling and Storage of Spent LWR Fuel Table VI-2: Potential Types of Attack on a Reactor or Spent-Fuel Storage Facility, Leading to Atmospheric Release of Radioactive Material Table VI-3: Some Potential Modes and Instruments of Attack on a Nuclear Power Plant Table VI-4: The Shaped Charge as a Potential Instrument of Attack Table VI-5: Performance of US Army Shaped Charges, M3 and M2A3 Table X-1: IRSN Estimates of Costs Arising from a "Massive" Atmospheric Release of Radioactive Material from a French 900 MWe PWR Table XI-1: Selected Approaches to Protecting Critical Infrastructure in the USA From Attack by Non-State Actors, and Some Strengths and Weaknesses of these Approaches Table XII-1: Selected Options to Reduce the Risk of a Pool Fire at a PWR or BWR Plant
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 67 of 120 List of Figures Figure V- 1: Core Damage Frequency for Accidents at a Surry PWR Nuclear Power Plant, as Estimated in the NRC Study NUREG- 1150 Figure V-2: Core Damage Frequency for Accidents at a Peach Bottom BWR Nuclear Power Plant, as Estimated in the NRC Study NUREG-1 150 Figure V-3: Conditional Probability of Containment Failure Following a Core-Damage Accident at a Surry PWR or Peach Bottom BWR Nuclear Power Plant, as Estimated in the NRC Study NUREG-1 150 Figure V-4: Contamination of Land in Japan by Radioactive Cesium Released to Atmosphere During the Fukushima #1 Accident of 2011 Figure V-5: Probability Distribution of Monetized Losses from Nuclear-Facility Incidents: Sornette et al's Comparison of Empirical Data with PRA Estimates Figure VI-1: Schematic View of a Generic Shaped-Charge Warhead Figure VI-2: MISTEL System for Aircraft Delivery of a Shaped Charge, World War II Figure VI-3: January 2008 Test of a Raytheon Shaped Charge, Intended as the Penetration (Precursor) Stage of a Tandem Warhead System Figure VI-4: Aftermath of a Small-Aircraft Suicide Attack on an Office Building in Austin, Texas, February 2010 Figure VIII-1: Unit 4 at the Fukushima #1 Site During the 2011 Accident Figure VIII-2: Schematic View of a BWR Reactor with a Mark I Containment, as Used at the Fukushima #1 Site and Elsewhere Figure X-1: PWR Spent Fuel Storage Racks: Low-Density and High-Density Designs Figure X-2: An Argonne Analyst's Illustration of the Effect of Residual Water on Heat Transfer from Spent Fuel in a Partially Drained Pool Equipped with High-Density Racks
 
Thompson Declaration.Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 68 of 120 Table IV-1 Some Categories of Risk Posed by a Commercial Nuclear Facility: Author's Definitions Category                    Definition                        Mechanisms Radiological risk        Potential for harm to          Exposure arising from:
humans as a result of
* Release of radioactive unplanned exposure to                  material via air or water ionizing radiation                    pathways, or
* Line-of-sight exposure to unshielded radioactive material or a criticality event Proliferation risk        Potential for diversion of    Diversion by:
fissile material or
* Non-State actors who defeat radioactive material to                safeguards procedures and weapons use                            devices, or
* The host State Program risk              Potential for facility        Functional divergence due to:
function to diverge
* Failure of facility to enter substantially from original            service or operate as design objectives                      specified, or
* Policy or regulatory shift that alters design objectives or facility operation, or
* Changed economic and societal conditions, or
* Conventional accident or attack affecting the facility Notes:
(a) In this declaration, the general term "risk" is defined as the potential for an unplanned, undesired outcome. There are various categories of risk, including the three categories in this table.
(b) In the case of radiological risk, the events leading to unplanned exposure to radiation could be accidents or attacks.
(c) The term "proliferation risk" is often used to refer to the potential for diversion of fissile material, for use in nuclear weapons. Here, the term also covers the potential for diversion of radioactive material, for use in radiological weapons.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 69 of 120 Table V-1 Amounts of Cesium-137 Related to the Chernobyl and Fukushima #1 Accidents Category                              Amount of Cesium-137 (PBq)
Chemobyl release to atmosphere (1986)                                85 Fukushima #1 release to atmosphere (2011)                            36 Deposition on Japan due to the Fukushima                            6.4
#1 atmospheric release Pre-release inventory in reactor cores of                          940 Fukushima #1, Units 1-3 (total for 3 cores)
Pre-release inventory in spent-fuel pools of                      2,200 Fukushima #1, Units 1-4 (total for 4 pools)
Notes:
(a) This table shows estimated amounts of Cesium-137 from: Stohl et al, 2011. The estimates for release from Fukushima #1 and deposition on Japan may change as new information becomes available.
(b) Stohl et al, 2011, provide the following data and estimates for Fukushima #1, Units 1-4, just prior to the March 2011 accident:
Indicator                Unit I        Unit 2          Unit 3        Unit 4 Number of fuel assemblies            400            548            548            0 in reactor core Number of fuel assemblies            392            615            566          1,535 in reactor spent-fuel pool Cesium-137 inventory in          2.40E+17        3.49E+17      3.49E+17          0 reactor core (Bq)
Cesium-137 inventory in          2.21E+17        4.49E+17      3.96E+17      1.11E+18 reactor pool (Bq)
(The core capacity of Unit 4 was 548 assemblies. The core of Unit 3 contained some MOX fuel assemblies at the time of the accident.)
(c) Assuming a total Cesium-137 release to atmosphere of 36 PBq, originating entirely from the reactor cores of Units 1, 2, and 3, which contained 940 PBq, the overall release fraction to atmosphere for Cesium- 137 was 36/940 = 0.03 8 = 3.8 percent.
 
Thompson Declaration. Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 70 of 120 Table V-2 Estimated Human Dose Commitment from the Chernobyl Release of Radioactive Material to Atmosphere in 1986 Region                50-Year Collective Dose            50-Year Average Commitment (person-Gy)              Individual Dose Commitment (mGy)
USSR (European)                            4.7E+05                        6.1E+00 USSR (Asian)                              1.1E+05                      Not available Europe (non-USSR)                          5.8E+05                        1.2E+00 Asia (non-USSR)                            2.7E+04                        1.4E-02 USA                                        1.1E+03                        4.6E-03 Northern Hemisphere                        1.2E+06                      Not available Total Notes:
(a) These estimated doses are whole-body doses, from: DOE, 1987, Table 5.16, "preferred estimate".
(b) Most of the dose is attributable to Cesium-137 (see: DOE, 1987, page x).
(c) Estimates for non-USSR countries show that, on average, about 50% of the collective dose is attributable to external exposure, and about 50% is attributable to ingestion (see:
DOE, 1987, Table 5.14). Uncertainty in these estimates is greater for ingestion than for external exposure.
(d) In this instance, 1 Gy is equivalent to 1 Sv.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 71 of 120 Table V-3 Insurance Premiums Paid by Ontario Power Generation (OPG) for Nuclear Liability and Terrorism Coverage of the Darlington Station, 2005-2012 Period                  Premium for Period ($)
2012                                          753,680 2011                                          749,654 2010                                          734,585 2009                                          728,262 2008                                          715,920 2007                                          708,934 2006                                          717,413 2005                                          714,373 Total, 2005-2012                            5,822,821 Average Year, 2005-2012                      727,853 Notes:
(a) Premium data were obtained from copies of annual invoices from Marsh Canada Limited to OPG. These copies were provided by OPG to Shawn-Patrick Stensil of Greenpeace Canada in February 2013, pursuant to a request by Stensil under the Freedom of Information and Protection of Privacy Act.
(b) Marsh Canada received the premium payments on behalf of the Nuclear Insurance Association of Canada (NIAC) and other insurance pools, which may have included British Nuclear Insurers and American Nuclear Insurers.
(c) In addition to paying the amounts shown to Marsh Canada, OPG also paid an 8%
sales tax on each amount to the province of Ontario.
(d) The components of the total premium (i.e., nuclear liability, and terrorism) are available, for the years shown, only for 2005. In that year, the terrorism premium was
$88,086 (12.3% of the total premium) and the nuclear liability premium was $626,287 (87.7% of the total premium).
(e) Prior to 2005, a combined premium payment was made for the Darlington and Pickering stations and, in earlier years, for the Bruce station as well.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 72 of 120 Table V-4 Accident-Probability Implications of Insurance Premiums Paid by OPG for Coverage Associated with Operation of the Darlington Station Liability Limit:          -NetPremium to Cover              Implied Probability Coverage A, Accidents              Stated Liability                    of Event (per RY)                        (per RY)
$75 million                              $127,000                        1.69E-03
$650 million                        $508,000 to $762,000            7.82E-04 to 1.17E-03
$1,000 million                    $635,000 to $1,016,000            6.35E-04 to 1.02E-03 Notes:
(a) Table V-3 shows gross, pre-tax insurance premiums paid by OPG for nuclear liability and terrorism coverage of the 4-unit Darlington station, over the period 2005-2012. The annual average gross premium for the station during that period was $727,853. In 2005, the terrorism premium accounted for 12.3% of the gross premium. Here, it is assumed that 30% of the gross premium is allocated to: (i) terrorism premium; (ii) administration; (iii) contingency; (iv) reinsurance premium paid to the Canadian government; and (v) profit. Thus, 70% of the gross premium is assumed here to be the net premium that supports offsite Coverage A (i.e., legal liability for bodily injury or property damage) through the private insurers in the NIAC pool, for an accident not involving a malevolent act. Throughout the period 2005-2012 and currently, the limit on that liability is $75 million. Thus, the net premium per RY for a $75 million maximum liability = $727,853 x 0.7 x 0.25 = $127,000 per RY.
(b) Dermot Murphy of NIAC has said that increasing the liability limit from $75 million to $650 million would require a premium increase by a factor of approximately 4 to 6, while a limit of $1,000 million would require a premium increase by a factor of approximately 5 to 8. (See: Murphy, 2009.) These factors are applied in the second column of the table.
(c) The "implied probability of event", in the third column, is calculated by dividing the amount in the second column by the amount in the first column, for each row. This implied probability represents NIAC's assessment of the probability of a claim up to the liability limit.
(d) As indicated in note (a), above, the "implied probability of event" that is calculated here applies to an accident in which offsite damage (i.e., bodily injury or property damage) arises from a release of radioactive material at Darlington. The calculation shown here does not apply to a release caused by a malevolent act.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 73 of 120 Table VI-1 Potential Sabotage Events at a Spent-Fuel Storage Pool, as Postulated in NRC's August 1979 GEIS on Handling and Storage of Spent LWR Fuel Event Designator        General Description of Event              Additional Details Mode 1
* Between 1 and 1,000 fuel
* One adversary can carry 3 assemblies undergo extensive        charges, each of which can damage by high-explosive            damage 4 fuel assemblies charges detonated under water
* Damage to 1,000 assemblies
* Adversaries commandeer the        (i.e., by 83 adversaries) is a central control room and hold it    "worst-case bounding estimate" for approx. 0.5 hr to prevent the ventilation fans from being turned off Mode 2
* Identical to Mode I except that, in addition, an adversary enters the ventilation building and removes or ruptures the HEPA filters Mode 3
* Identical to Mode 1 within the
* Adversaries enter the central pool building except that, in      control room or ventilation addition, adversaries breach two    building and turn off or disable opposite walls of the building    the ventilation fans by explosives or other means Mode 4                  ° Identical to Mode 1 except that, in addition, adversaries use an additional explosive charge or other means to breach the pool liner and 1.5 m-thick concrete floor of the pool Notes:
(a) Information in this table is from Appendix J of: NRC, 1979.
(b) The postulated fuel damage ruptures the cladding of each rod in an affected fuel assembly, releasing "contained gases" (gap activity) to the pool water, whereupon the released gases bubble to the water surface and enter the air volume above that surface.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 74 of 120 Table VI-2 Potential Types of Attack on a Reactor or Spent-Fuel Storage Facility, Leading to Atmospheric Release of Radioactive Material Type of Event        Facility Behavior          Some Relevant        Characteristics of Instruments and          Atmospheric Modes of Attack              Release Type 1:
* All or part of
* Facility is within    ° Radioactive Vaporization or      facility is vaporized    the fireball of a      material in facility is Pulverization        or pulverized            nuclear-weapon          lofted into the explosion              atmosphere and amplifies fallout from nuc. explosion Type 2: Rupture and
* Facility structures
* Aerial bombing
* Solid pieces of Dispersal (Large)    are broken open
* Artillery, rockets,  various sizes are
* Fuel is dislodged      etc.                    scattered in vicinity from facility and
* Effects of blast etc.
* Gases and small broken apart              outside the fireball    particles form an
* Some ignition of        of a nuclear-weapon aerial plume that zircaloy fuel            explosion              travels downwind cladding may occur,                              ° Some release of typically without                                volatile species (esp.
sustained                                        Cesium- 137) if zirc.
combustion                                        combustion occurs Type 3: Rupture and
* Facility structures
* Vehicle bomb
* Scattering and Dispersal (Small)    are penetrated but
* Impact by            plume formation as retain basic shape        commercial aircraft in Type 2 event, but
* Fuel may be            ° Perforation by        involving smaller damaged but most          shaped charge          amounts of material rods retain basic
* Substantial release shape                                            of volatile species if
* Damage to cooling                              zirc. combustion systems could lead                                occurs to zirc. combustion Type 4: Precise,
* Facility structures
* Missiles (military
* Scattering and Informed Targeting    are penetrated,          or improvised) with    plume formation as creating a release        tandem warheads        in Type 3 event pathway
* Close-up use of
* Substantial release
* Zirc. combustion        attack instruments      of volatile species, is initiated indirectly (e.g., shaped charge,    potentially by damage to              incendiary, thermic    exceeding amount cooling systems, or      lance)                  in Type 3 release I by direct ignition      I        _I
 
Thompson Declaration.Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 75 of 120 Table VI-3 Some Potential Modes and Instruments of Attack on a Nuclear Power Plant Attack Mode/Instrument                Characteristics              Present Defenses at US Plants Commando-style attack
* Could involve heavy          Alarms, fences, and armed weapons and sophisticated      guards, with offsite backup tactics
* Successful attack would require substantial planning and resources Land-vehicle bomb
* Readily obtainable            Vehicle barriers at entry
                                - Highly destructive if        points to Protected Area detonated at target Small guided missile
* Readily obtainable            None if missile launched (anti-tank, etc.)
* Highly destructive at point  from offsite of impact Commercial aircraft
* More difficult to obtain      None than pre-9/1 1
* Can destroy larger, softer targets Explosive-laden smaller          - Readily obtainable            None aircraft
* Can destroy smaller, harder targets 10-kilotonne nuclear
* Difficult to obtain          None weapon
* Assured destruction if I detonated at target          I Notes:
(a) This table is adapted from: Thompson, 2007, Table 7-4. Further citations are provided in that table and its supporting narrative. For additional, supporting information of more recent vintage, see: Ahearne et al, 2012, Chapter 5.
(b) Defenses at nuclear power plants around the world are typically no more robust than at US plants.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 76 of 120 Table VI-4 The Shaped Charge as a Potential Instrument of Attack Category of Information                    Selected Information in Category General information
* Shaped charges have many civilian and military applications, and have been used for decades
                            . Applications include human-carried demolition charges or warheads for anti-tank missiles
                            - Construction and use does not require assistance from a government or access to classified information Use in World War II
* The German MISTEL, designed to be carried in the nose of an un-manned bomber aircraft, is the largest known shaped charge
                            - Japan used a smaller version of this device, the SAKURA bomb, for kamikaze attacks against US warships A large, contemporary
* Developed by a US government laboratory for mounting device                      in the nose of a cruise missile
                            - Described in detail in an unclassified, published report (citation is voluntarily withheld here)
                            - Purpose is to penetrate large thicknesses of rock or concrete as the first stage of a "tandem" warhead
                            - Configuration is a cylinder with a diameter of 71 cm and a length of 72 cm
                            - When tested in November 2002, created a hole of 25 cm diameter in tuff rock to a depth of 5.9 m
* Device has a mass of 410 kg; would be within the payload capacity of many general-aviation aircraft A potential delivery
* A Beechcraft King Air 90 general-aviation aircraft can vehicle                      carry a payload of up to 990 kg at a speed of up to 460 km./hr
                              . The price of a used, operational King Air 90 in the USA can be as low as $0.4 million Source:
This table is adapted from Table 7-6 of: Thompson, 2009.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 77 of 120 Table VI-5 Performance of US Army Shaped Charges, M3 and M2A3 Target                  Indicator                        Value for Stated Material                                            Type of Shaped Charge Type: M3          Type: M2A3 Reinforced        Maximum wall thickness        150 cm                90 cm concrete          that can be perforated Depth of penetration in        150 cm              75 cm thick walls Diameter of hole
* 13 cm at entrance
* 9 cm at entrance
                                                - 5 cm minimum
* 5 cm minimum Depth of hole with second      210 cm              110 cm charge placed over first hole Armor plate      Perforation                    At least 50 cm      30 cm Average diameter of hole      6 cm                4 cm Notes:
(a) Data are from US Army Field Manual FM 5-25: Army, 1967, pp 13-15 and page 100.
(b) The M2A3 charge has a mass of 5 kg, a maximum diameter of 18 cm, and a total length of 38 cm including the standoff ring.
(c) The M3 charge has a mass of 14 kg, a maximum diameter of 23 cm, a charge length of 39 cm, and a standoff pedestal 38 cm long.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 78 of 120 Table X-1 IRSN Estimates of Costs Arising from a "Massive" Atmospheric Release of Radioactive Material from a French 900 MWe PWR Cost Category                        Estimated Cost (billion Euro)
Base Case              Low Case                High Case On-site costs                      10                      5                      15 Off-site radiological            106                    38                    281 costs Contaminated                      393                    130                    4,875 territories Image costs                      130                    75                    176 Costs related to                  90                    30                    360 power production Indirect effects                  31                      9                      50 Total (rounded)                  760                    290                    5,760 Notes:
(a) Data are from: IRSN, 2007, Tables A4.4.4 and A4.4.5.
(b) The assumed release would be from the Dampierre nuclear generating station, which has four 900 MWe PWR units and is located on the Loire River south of Paris. The release is described (IRSN, 2007, page 37) as follows: "Par simplification, le scenario considere la dispersion en deux heures d'un tiers de l'inventaire du coeur, ce qui est le bon ordre de grandeur pour le cesium, contributeur preponderant des couts." Thus, the release apparently includes one-third of one reactor's core inventory of Cesium isotopes, which are said to be the major contributors to the estimated costs. The many radio-isotopes in a reactor core have widely varying volatilities and chemical properties. Thus, their release fractions will vary. The IRSN text, quoted above, does not address this matter.
(c) An estimate of the core inventory of Cs- 137 in a 900 MWe PWR can be made by assuming: (i) total fuel mass = 75 Mg HM; (ii) average fuel burnup at discharge = 50 GWt-days per Mg HM; (iii) Cs-137 yield = 1.17E+14 Bq per GWt-day of fission; and (iv) one-third of the core is discharged at each refueling, and a refueling outage is imminent, so that average fuel burnup in the core = (2/3) x discharge burnup. With those assumptions, the core inventory of Cs-137 = 1.17E+14 x 75 x (2/3) x 50 = 2.9E+17 Bq.
One-third of that inventory = 9.7E+16 Bq =97 PBq.
(d) IRSN used the COSYMA code to estimate plume behavior and radiological impacts for 144 weather conditions. The "base case" estimates shown in the table are said to reflect median results. The "low case" (scenario favorable) and "high case" (scenario defavorable) estimates reflect non-median results and, apparently, changes in analytic assumptions.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 79 of 120 Table XI-1 Selected Approaches to Protecting Critical Infrastructure in the USA From Attack by Non-State Actors, and Some Strengths and Weaknesses of these Approaches Approach                      Strengths                      Weaknesses Approach #1: Offensive
* Could deter or prevent
* Could promote growth of military operations            governments from                non-State groups hostile to internationally                supporting non-State actors    the USA, and build hostile to the USA              sympathy for these groups in foreign populations
* Could be costly in terms of lives, money, etc.
Approach #2: International
* Could identify and            - Implementation could be police cooperation within a    intercept potential attackers  slow and/or incomplete legal framework
* Requires ongoing international cooperation Approach #3: Surveillance
* Could identify and
* Could destroy civil and control of the domestic    intercept potential attackers  liberties, leading to population                                                    political, social, and economic decline of the USA Approach #4: Secrecy about
* Could prevent attackers
* Could suppress a true design and operation of        from identifying points of      understanding of risk infrastructure facilities      vulnerability
* Could contribute to political, social, and economic decline Approach #5: Active            ° Could stop attackers
* Requires ongoing defense of infrastructure      before they reach the target    expenditure & vigilance facilities (by use of guards,                                  ° May require military guns, gates, etc.)                                              involvement Approach #6: Robust and
* Could allow target to        ° Could involve higher inherently-safer design of    survive attack without          capital costs infrastructure facilities    damage, thus contributing to protective deterrence (Note: This approach could ° Could substitute for other be part of a "protective      protective approaches, deterrence" strategy for the avoiding their costs and USA.)                          adverse impacts
* Could reduce risks from I accidents & natural hazards Notes:
(a) These approaches could be used in parallel, with differing weightings.
(b) Approach #6 would contribute to "protective deterrence", which is distinct from "counter-attack deterrence".
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 80 of 120 Table X1i-1 Selected Options to Reduce the Risk of a Pool Fire at a PWR or BWR Plant Option              Passive      Does Option              Comments or        Address Fire Active?    Scenarios Arising From:
Attack? Other Events?
Re-equip pool with low-        Passive  Yes        Yes
* Would substantially density, open-frame racks                                  reduce pool inventory of radioactive material
                                                            - Would prevent auto-ignition of fuel in almost all cases Install emergency water        Active    Yes      Yes    - Spray system must be sprays above pool                                          highly robust
                                                            - Spraying water on overheated fuel could feed Zr-steam reaction
* Pool overflow could disable reactor safety systems (especially at BWRs with Mark I and II containments)
Mix hotter (younger) and      Passive    Yes        Yes
* Could delay or prevent colder (older) fuel in pool                                auto-ignition in some cases
                                                            - Would be ineffective if debris or residual water blocks air flow
                                                            - Could promote fire propagation to older fuel Minimize movement of          Active    No        Yes
* Could conflict with spent-fuel cask over pool                (Most              adoption of low-density, cases)            open-frame racks Deploy air-defense system      Active    Yes        No
* Implementation would (e.g., Sentinel and                                          require presence of military Phalanx) at site                                            personnel at site Develop enhanced onsite        Active    Yes        Yes    - Would require new capability for damage                                        equipment, staff and control                                                      training
                                                            *Personnel must function in extreme environments
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 81 of 120 Figure V-1 Core Damage Frequency for Accidents at a Surry PWR Nuclear Power Plant, as Estimated in the NRC Study NUREG-1 150 I.OE-03 0
0 1.OE-04 A
M A
0    1.OE-05 U
C Y
1.OE-06 1.OE-07 INTERNAL      SEISMIC      SEISMIC            FIRE LIVERMORE        EPRI B Mean      -0 Median Notes:
(a) This figure is adapted from Figure 8.7 of: NRC, 1990.
(b) The bars range from the 5 th percentile (lower bound) to the 95 1h percentile (upper bound) of the estimated core damage frequency (CDF). CDF values shown are per reactor-year (RY).
(c) "Internal" initiating events encompass equipment failure, human error, etc.
"External" initiating events encompass earthquake, flood, strong wind, fire, etc.
(d) Two estimates are shown for the CDF from earthquakes (seismic effects). One estimate derives from seismic predictions done at Lawrence Livermore National Laboratory (Livermore), the other from predictions done at the Electric Power Research Institute (EPRI).
(e) CDFs were not estimated for external initiating events other than earthquake and fire.
(f) Malevolent acts were not considered.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 82 of 120 Figure V-2 Core Damage Frequency for Accidents at a Peach Bottom BWR Nuclear Power Plant, as Estimated in the NRC Study NUREG-I150 1.OE-03 C
0A  1.0E-04 mA 1.0E-05        _
0 a
1.0E-06 U
C c  1.0E-07 1.OE-08    INTERNAL        SEISMIC      SEISMIC    FIRE LIVERMORE        EPRI
                                          " Mean    fi  Median Notes:
(a) This figure is adapted from Figure 8.8 of: NRC, 1990.
(b) Notes (b) through (f) of Figure V-1 also apply here.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 83 of 120 Figure V-3 Conditional Probability of Containment Failure Following a Core-Damage Accident at a Surry PWR or Peach Bottom BWR Nuclear Power Plant, as Estimated in the NRC Study NUREG-1150 Surry - Internal Events                    Peach Bottom - Internal Events Early Failure Late Failure Byl-Late F    ail-                            Vent No Vowel Br.
ore                                        No Vessel 7Br or Vessel Breach/No Containment Failure Vessel Breach/No Containment Failure Surry - Fire                                  Peach Bottom - Fire Late Failure            Early Failure Early Failure Vent No VesselorBr`,*                                                Late IaVessel                        Breech LFa n                        or Vessel Breach/No Containment Failure Vessel Breach/No Containment Failure Surry - Seismic                            Peach Bottom - Seismic Late Failure Early      Early Failure    Failure Vent No Vessel Dr
                                                                                        ~/Late      Failure I
or    1 Vessel Breach/No Containment Failure Note:
This figure is adapted from Figure 9.5 of. NRC, 1990.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 84 of 120 Figure V4 Contamination of Land in Japan by Radioactive Cesium Released to Atmosphere During the Fukushima #1 Accident of 2011 Source:
Asahi Shimbun, 2011.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 85 of 120 Figure V-5 Probability Distribution of Monetized Losses from Nuclear-Facility Incidents:
Sornette et al's Comparison of Empirical Data with PRA Estimates 10 2 10-3 A      10-1 0
10 5 10-6 10 10"          107rn                    loll 1911                  loll S (2006 Dollars)
Notes:
(a) This figure is a reproduction of Figure I from: Sornette et al, 2013.
(b) The curves shown are complementary cumulative distribution functions.
(c) The vertical axis is probability per reactor-year (or facility-year).
(d) The "Farmer Curve" is based on findings from NRC's Reactor Safety Study, which was the first reactor PRA. In this curve, monetized losses are associated with radiological impacts.
(e) The "Empirical Records" curve is based on Sovacool's compilation of data on 99 incidents at nuclear facilities. In this curve, monetized losses may, or may not, be associated with radiological impacts.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 86 of 120 Figure VI-1 Schematic View of a Generic Shaped-Charge Warhead Notes:
(a) Figure accessed on 4 March 2012 from: http://en.wikipedia.org/wiki/Shaped charge (b) Key:
Item 1: Aerodynamic cover Item 2: Empty cavity Item 3: Conical liner (typically made of ductile metal)
Item 4: Detonator Item 5: Explosive Item 6: Piezo-electric trigger (c) Upon detonation, a portion of the conical liner would be formed into a high-velocity jet directed toward the target. The remainder of the liner would form a slower-moving slug of material.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 87 of 120 Figure VI-2 MISTEL System for Aircraft Delivery of a Shaped Charge, World War II Notes:
(a) Photograph accessed on 5 March 2012 from:
http://www.historyofwar.org/Pictures/pictures Ju 88 mistel.html (b) A shaped-charge warhead can be seen at the nose of the lower (converted bomber) aircraft, replacing the cockpit. The aerodynamic cover in front of the warhead would have a contact fuse at its tip, to detonate the shaped charge at the appropriate standoff distance.
(c) A human pilot in the upper (fighter) aircraft would control the entire rig, and would point it toward the target. Then, the upper aircraft would separate and move away, and the lower aircraft would be guided to the target by an autopilot.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 88 of 120 Figure VI-3 January 2008 Test of a Raytheon Shaped Charge, Intended as the Penetration (Precursor) Stage of a Tandem Warhead System A ftpr Tpet tviapwpi frnm thp off arktil fornpl Notes:
(a) These photographs are from: Raytheon, 2008. For additional, supporting information, see: Warwick, 2008.
(b) The shaped-charge jet penetrated about 5.9 m into a steel-reinforced concrete block with a thickness of 6.1 m. Although penetration was incomplete, the block was largely destroyed, as shown. Compressive strength of the concrete was 870 bar.
(c) The shaped charge had a diameter of 61 cm and contained 230 kg of high explosive.
It was sized to fit inside the US Air Force's AGM-129 Advanced Cruise Missile.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 89 of 120 Figure VI4 Aftermath of a Small-Aircraft Suicide Attack on an Office Building in Austin, Texas, February 2010 Notes:
(a) Photograph and information in these notes are from: Brick, 2010.
(b) A major tenant of the building was the Internal Revenue Service (IRS).
(c) The aircraft was a single-engine, fixed-wing Piper flown by its owner, Andrew Joseph Stack III, an Austin resident who worked as a computer engineer.
(d) A statement left by Mr Stack indicated that a dispute with the IRS had brought him to a point of suicidal rage.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 90 of 120 Figure VIII-1 Unit 4 at the Fukushima #1 Site During the 2011 Accident Source:
Accessed on 20 February 2012 from Ria Novosti at:
http://en.rian.ru/analysis/20110426/163701909.html; image by Reuters Air Photo Service.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 91 of 120 Figure VIII-2 Schematic View of a BWR Reactor with a Mark I Containment, as Used at the Fukushima #1 Site and Elsewhere Boiling Water Reactor Design at Fukushima Daiichi Secondary Containment
                                                                      -Spent Fuel Pool Steel Containment Vessel -                                        -  Reactor Vessel Primary Containment Suppression PoollTorus (Part of Primary Containment)
Notes:
(a) This figure accessed on 24 February 2012 from:
http://safetyfirst.nei.org/iapan/background-on-fukushima-situation/
(b) All BWR reactors with Mark I containments have the same basic configuration.
Details vary for specific reactors.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 92 of 120 Figure X-1 PWR Spent Fuel Storage Racks: Low-Density and High-Density Designs Notes:
(a) These drawings are from: Benjamin et al, 1979, page 18.
(b) The upper drawing shows a low-density, open-frame rack, and the lower drawing shows a high-density, closed-frame rack.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 93 of 120 Figure X-2 An Argonne Analyst's Illustration of the Effect of Residual Water on Heat Transfer from Spent Fuel in a Partially Drained Pool Equipped with High-Density Racks
_o _                                          Water addition: adding rot, "water                                                    to the bottom of an empty spent fuel pool can damage an assembly with a heat rate of 7kw or less that has reached equilibrium in air! -- The water can block the circulationof airand I * ,            cause the fuel assembly to
* 4 f'~          overheat The heat removed
                                      *.      -              by the low level of water is
____,___            _                  insufficient to cool the assembly.
Notes:
(a) Figure and accompanying text are from: Braun, 2010.
(b) Braun considers, as a typical example, a fuel assembly that would generate 10 MWt in a reactor at frill power. According to Braun, at a time point after reactor shutdown of 1.0x10 7 sec (116 days), the assembly would produce 7.8 kW of decay heat.
(c) Braun goes on to discuss a related situation in which water level descends slowly from the top of the rack by boiling off due to decay heat. He says:
    " "As the levels drop, steam from the boil-off will cool the uncovered parts of the fuel.
* At some point, the rising steam will be insufficient to cool the uncovered fuel and clad temperatures will rise until they reach the "ignition" point.
* Where is this level? Detailed calculations are needed. Experts suggest that it is somewhere between 20 and 80% of assembly height, possibly around the mid-point.
* When the water is at the bottom of the fuel, say about the 20% level, the steaming rate is probably insufficient to cool the rest of the assembly, and air circulation is not possible. So fuel assemblies that may be safe in air are likely to melt with a low water level.
* Detailed calculations are needed to address specific issues of geometry and heat transfer."
 
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Bruno Thomauske, "Realization of the German Concept for Interim Storage of Spent Nuclear Fuel - Current Situation and Prospects", paper presented at the WM'03 Conference, Tucson, Arizona, 23-27 February 2003.
(Thompson, 2013a)
Gordon R. Thompson, Declaration, "Comments on the US Nuclear Regulatory Commission's Draft Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a US Mark I Boiling Water Reactor", 1 August 2013.
(Thompson, 2013b)
Gordon R. Thompson, Declaration, "Recommendations for the US Nuclear Regulatory Commission's Consideration of Environmental Impacts of Long-Term, Temporary Storage of Spent Nuclear Fuel or Related High-Level Waste", 2 January 2013.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 101 of 120 (Thompson, 2013c)
Gordon R. Thompson, Handbook to Support Assessment of RadiologicalRisk Arising from Management of Spent NuclearFuel (Cambridge, Massachusetts: Institute for Resource and Security Studies, 31 January 2013).
(Thompson, 2009)
Gordon R. Thompson, EnvironmentalImpacts of Storing Spent NuclearFuel andHigh-Level Wastefrom CommercialNuclearReactors: A Critiqueof NRC's Waste Confidence Decision and EnvironmentalImpact Determination(Cambridge, Massachusetts: Institute for Resource and Security Studies, 6 February 2009).
(Thompson, 2008)
Gordon R. Thompson, "The US Effort to Dispose of High-Level Radioactive Waste",
Energy and Environment, Volume 19, Nos. 3+4, 2008, pp 391-412.
(Thompson, 2007)
Gordon R. Thompson, Risk-Related Impactsfrom Continued Operationof the Indian Point Nuclear Power Plants(Cambridge, Massachusetts: Institute for Resource and Security Studies, 28 November 2007).
(Thompson, 2005)
Gordon R. Thompson, Reasonably ForeseeableSecurity Events: Potentialthreats to optionsfor long-term management of UK radioactivewaste (Cambridge, Massachusetts:
Institute for Resource and Security Studies, 2 November 2005).
(Thompson, 2003)
Gordon Thompson, Robust Storage of Spent Nuclear Fuel: A Neglected Issue of HomelandSecurity (Cambridge, Massachusetts: Institute for Resource and Security Studies, January 2003).
(Throm, 1989)
E. D. Throm, RegulatoryAnalysisfor the Resolution of Generic Issue 82, "Beyond Design Basis Accidents in Spent FuelPools",NUREG-1353 (Washington, DC: US Nuclear Regulatory Commission, April 1989).
(Warwick, 2008)
Graham Warwick, "VIDEO: Raytheon tests bunker-busting tandem warhead",
Flightglobal,26 February 2008, accessed on 7 March 2012 from:
http://www.flightzlobal.com/news/articles/video-raytheon-tests-bunker-busting-tandem-warhead-221842/
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 102 of 120 (Windberg and Hozer, 2007)
Peter Windberg and Zoltan Hozer, "CODEX-CT- 1 and CT-2 Integral Tests: Two Possible Scenarios of the Paks-2 Incident", paper presented at the international conference: Nuclear Energy for New Europe 2007, Slovenia, 10-13 September 2007.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 103 of 120 APPENDIX C: List of Exhibits Exhibit #1 Gordon R. Thompson, Declaration, "Recommendations for the US Nuclear Regulatory Commission's Consideration of Environmental Impacts of Long-Term, Temporary Storage of Spent Nuclear Fuel or Related High-Level Waste", 2 January 2013.
Exhibit #2 Andrew Barto and nine other authors, Consequence Study of a Beyond-Design-Basis EarthquakeAffecting the Spent Fuel Poolfor a US Mark I Boiling Water Reactor, Draft Report (Washington, DC: US Nuclear Regulatory Commission, June 2013).
Exhibit #3 Gordon R. Thompson, Declaration, "Comments on the US Nuclear Regulatory Commission's Draft Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a US Mark I Boiling Water Reactor", 1 August 2013.
Exhibit #4 Ernst Albrecht, Minister-President of Lower Saxony, "Declaration of the state government of Lower Saxony concerning the proposed nuclear fuel center at Gorleben" (English translation), May 1979.
Exhibit #5 Gordon R' Thompson, EnvironmentalImpacts of Storing Spent NuclearFuel andHigh-Level Wastefrom CommercialNuclear Reactors: A Critiqueof NRC's Waste Confidence Decision and EnvironmentalImpact Determination(Cambridge, Massachusetts: Institute for Resource and Security Studies, 6 February 2009).
Exhibit #6 Robert Alvarez, Jan Beyea, Klaus Janberg, Jungmin Kang, Ed Lyman, Allison Macfarlane, Gordon Thompson, and Frank von Hippel, "Reducing the Hazards from Stored Spent Power-Reactor Fuel in the United States", Science and Global Security, Volume 11, 2003, pp 1-51.
Exhibit #7 National Research Council Committee on the Safety and Security of Commercial Spent Nuclear Fuel Storage (a committee of the Council's Board on Radioactive Waste Management), Safety and Security of Commercial Spent NuclearFuel Storage: Public Report (Washington, DC: National Academies Press, 2006).
Exhibit #8 Gordon R. Thompson, "The US Effort to Dispose of High-Level Radioactive Waste",
Energy and Environment, Volume 19, Nos. 3+4, 2008, pp 391-412.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 104 of 120 Exhibit #9 Gordon R. Thompson, Reasonably ForeseeableSecurity Events: Potential threats to optionsfor long-term management of UK radioactivewaste (Cambridge, Massachusetts:
Institute for Resource and Security Studies, 2 November 2005).
Exhibit #10 Gordon R. Thompson, Handbook to Support Assessment of RadiologicalRisk Arising from Management of Spent Nuclear Fuel (Cambridge, Massachusetts: Institute for Resource and Security Studies, 31 January 2013).
Exhibit #11 Ludivine Pascucci-Cahen and Momal Patrick (IRSN), "Massive radiological releases profoundly differ from controlled releases", paper for presentation at the Eurosafe conference, Brussels, 5-6 November 2012.
Exhibit #12 Central Intelligence Agency (Directorate of Intelligence), The Chernobyl' Accident:
Social and PoliticalImplications (Washington, DC: CIA, December 1987). This document was originally Secret but was released for publication in February 2011.
Exhibit #13 Mikhail Gorbachev, "Turning Point at Chernobyl", Project Syndicate, 14 April 2006.
Exhibit #14 Kristin Shrader-Frechette, "Technological Risk and Small Probabilities", Journalof Business Ethics, Volume 4, 1985, pp 431-445.
Exhibit #15 H. W. Lewis (chair) and six other authors, Risk Assessment Review Group Report to the US Nuclear Regulatory Commission, NUREG/CR-0400 (Washington, DC: NRC, September 1978).
Exhibit #16 John G. Kemeny (chair) and eleven other commissioners, Report of the President's Commission on the Accident at Three Mile Island (Washington, DC: US Government Printing Office, October 1979).
Exhibit #17 Alexander Shlyakhter and Richard Wilson, "Chernobyl: the inevitable results of secrecy",
Public Understandingof Science, Volume 1, July 1992, pp 251-259.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 105 of 120 Exhibit #18 National Diet of Japan, The official report of The Fukushima NuclearAccident IndependentInvestigation Commission, Executive summary (Tokyo: National Diet of Japan, 2012).
Exhibit #19 John Downer, "Disowning Fukushima: Managing the credibility of nuclear reliability assessment in the wake of disaster", Regulation and Governance, published online 22 July 2013, doi: 10.l1111/rego.12029.
Exhibit #20 Thomas Cochran (Natural Resources Defense Council), prepared statement for an appearance at joint hearings of the Subcommittee on Clean Air and Nuclear Safety, and the Committee on Environment and Public Works, US Senate, 12 April 2011.
Exhibit #21 Raymond Gallucci, ""What - Me Worry?" "Why So Serious?": A Personal View on the Fukushima Nuclear Reactor Accidents", Risk Analysis, Volume 32, Number 9, 2012, pp 1444-1450.
Exhibit #22 D. Somette, T. Maillart, and W. Kroger, "Exploring the limits of safety analysis in complex technological systems", InternationalJournalof DisasterRisk Reduction, in press, accepted 3 April 2013, http://dx.doi.org/l0.1016/j.ijdrr.2013.04.002.
Exhibit #23 Ontario Power Generation, DarlingtonNGS Risk Assessment Summary Report (Toronto:
Ontario Power Generation, 29 May 2012).
Exhibit #24 Appendix J of: US Nuclear Regulatory Commission, GenericEnvironmentalImpact Statement on HandlingandStorage of Spent Light Water Power Reactor Fuel, NUREG-0575 (Washington, DC: Nuclear Regulatory Commission, August 1979).
Exhibit #25 Allan S. Benjamin and three other authors, Spent Fuel Heatup FollowingLoss of Water DuringStorage, NUREG/CR-0649 (Washington, DC: US Nuclear Regulatory Commission, March 1979).
Exhibit #26 Gordon R. Thompson, Risk-Related Impactsfrom Continued Operation of the Indian Point Nuclear Power Plants (Cambridge, Massachusetts: Institute for Resource and Security Studies, 28 November 2007).
 
Thompson Declaration:Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 106 of 120 Exhibit #27 Gordon Thompson, Robust Storage of Spent Nuclear Fuel: A Neglected Issue of Homeland Security (Cambridge, Massachusetts: Institute for Resource and Security Studies, January 2003).
Exhibit #28 Mark Holt and Anthony Andrews, Nuclear Power Plant Security and Vulnerabilities (Washington, DC: Congressional Research Service, 28 August 2012).
Exhibit #29 John F. Ahearne and eight other authors, with editing by Charles D. Ferguson and Frank A. Settle, The Future of Nuclear Power in the United States (Washington, DC:
Federation of American Scientists, and Washington and Lee University, February 2012).
Exhibit #30 Anthony L. Honnellio and Stan Rydell, "Sabotage vulnerability of nuclear power plants",
InternationalJournalof Nuclear Governance,Economy and Ecology, Volume 1, Number 3, 2007, pp 312-321.
Exhibit #31 Robert H. Morris and three other authors, "Using the VISAC program to calculate the vulnerability of nuclear power plants to terrorism", InternationalJournalof Nuclear Governance, Economy andEcology, Volume 1, Number 2, 2006, pp 193-211.
Exhibit #32 Lenka Kollar and three other authors, SafeguardsApproachesfor Very Long-Term Storage of Spent Nuclear Fuel (Argonne, Illinois: Argonne National Laboratory, July 2013).
Exhibit #33 Karl N. Fleming, "On The Issue of Integrated Risk - A PRA Practitioners Perspective",
paper to support a presentation to NRC Commissioners at the meeting: Briefing on Severe Accidents and Options for Proceeding with Level 3 Probabilistic Risk Assessment Activities, 28 July 2011.
Exhibit #34 Suzanne Schroer and Mohammad Modarres, "An event classification schema for evaluating site risk in a multi-unit nuclear power plant probabilistic risk assessment",
Reliability Engineeringand System Safety, Volume 117, 2003, pp 40-5 1.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 107 of 120 Exhibit #35 Andrew Barto and nine other authors, Consequence Study of a Beyond-Design-Basis EarthquakeAffecting the Spent Fuel Poolfor a US Mark I Boiling Water Reactor (Washington, DC: US Nuclear Regulatory Commission, October 2013). This document is provided here with its cover memo: Mark A. Satorius, memo to NRC Commissioners, "SECY-13-0112: Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a US Mark I Boiling Water Reactor", 9 October 2013.
Exhibit #36 Mark A. Satorius, memo to NRC Commissioners, "COMSECY-13-0030: Staff Evaluation and Recommendation for Japan Lessons-Learned Tier 3 Issue on Expedited Transfer of Spent Fuel", 12 November 2013.
Exhibit #37 E. D. Throm, Regulatory Analysisfor the Resolution of Generic Issue 82, "Beyond DesignBasis Accidents in Spent Fuel Pools",NUREG-1353 (Washington, DC: US Nuclear Regulatory Commission, April 1989).
Exhibit #38 T. E. Collins and G. Hubbard, Technical Study of Spent Fuel PoolAccident Risk at DecommissioningNuclear PowerPlants,NUREG-1 738 (Washington, DC: US Nuclear Regulatory Commission, February 2001).
Exhibit #39 US Nuclear Regulatory Commission Staff, "NRC Staff Response to Intervenor's Request for Admission of Late-Filed Environmental Contentions", Docket No. 50-400-LA, ASLBP No. 99-762-02-LA, 3 March 2000.
Exhibit #40 J. Sam Armijo (Chairman, NRC Advisory Committee on Reactor Safeguards), letter and enclosures to Ms. Diane Curran, Esq., 20 November 2013.
Exhibit #41 Dana A. Powers (Chairman, NRC Advisory Committee on Reactor Safeguards), letter to Richard A. Meserve (Chairman, NRC), "
 
==Subject:==
Draft Final Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants", 13 April 2000.
Exhibit #42 Farouk Eltawila (Office of Nuclear Regulatory Research, NRC), memorandum to Gary Holahan (Office of Nuclear Reactor Regulation, NRC), "RES Review of and Response to ACRS Comments on Spent Fuel Cladding Behavior Following a Loss-of-Water Accident During Pool Storage", 15 May 2001. Attached to this memorandum is an undated draft report: H. M. Chung (Argonne) and S. Basu (NRC), "Spent Fuel Cladding Behavior Following Loss-of-Water Accident During Pool Storage".
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 108 of 120 Exhibit #43 K. Natesan and W.K. Soppet, Air Oxidation Kineticsfor Zr-BasedAlloys, NUREG/CR-6846 (Washington, DC: NRC, June 2004).
Exhibit #44 E.R. Lindgren and S.G. Durbin, Characterizationof Thermal-HydraulicandIgnition Phenomena in Prototypic,Full-Length Boiling Water Reactor Spent Fuel Assemblies After a PostulatedComplete Loss-of-Coolant Accident, NUREG/CR- 7143 (Washington, DC: NRC, March 2013).
Exhibit #45 Peter Windberg and Zoltan Hozer, "CODEX-CT-1 and CT-2 Integral Tests: Two Possible Scenarios of the Paks-2 Incident", paper presented at the international conference: Nuclear Energy for New Europe 2007, Slovenia, 10-13 September 2007.
Exhibit #46 Jan Beyea, Ed Lyman, and Frank von Hippel, "Damages from a Major Release of Cs-137 into the Atmosphere of the United States", Science and Global Security, Volume 12, 2004, pp 125-136.
Exhibit #47 Institut de Radioprotection et de Surete Nucleaire, Examen de la methode d'analyse cout-benefice pour la surete, Rapport DSR No. 157, Annex du Chapitre4, Evaluation Economique des Consequences d'Accidents Graves et Enseignements (France: IRSN, 5 July 2007).
Exhibit #48 Svensk Karnbranslehantering AB, "Clab", a brochure about Sweden's interim storage facility for spent nuclear fuel, published in 2006, accessed on 15 December 2013 at:
http://www.skb.se/Templates/Standard          25480.aspx Exhibit #49 Bruno Thomauske, "Realization of the German Concept for Interim Storage of Spent Nuclear Fuel - Current Situation and Prospects", paper presented at the WM'03 Conference, Tucson, Arizona, 23-27 February 2003.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 109 of 120 APPENDIX D: Curriculum Vitae Curriculum Vitae for Gordon R. Thompson June 2011 Professional expertise
- Technical and policy analysis in the fields of energy, environment, sustainable development, human security, and international security.
Current appointments
* Executive director, Institute for Resource & Security Studies (IRSS), Cambridge, Massachusetts (since 1984).
- Senior research scientist, George Perkins Marsh Institute, Clark University, Worcester, Massachusetts (since 2002).
Education "D.Phil., applied mathematics, Oxford University (Balliol College), 1973.
"B.E., mechanical engineering, Univ. of New South Wales, Sydney, Australia, 1967.
"B.Sc., mathematics & physics, Univ. of New South Wales, 1966.
Project sponsors and tasks (selected)
- Nautilus Institute and RMIT University, 2009-2011: conduct policy and technical analysis on transfer of nuclear power plant technology to consumer countries.
- Attorney General of Massachusetts, 2006-2008 and 2011: analyze risk issues and prepare expert testimony associated with the Pilgrim and Vermont Yankee nuclear power plants; current analysis addresses lessons learned from the Fukushima accident of 2011.
- CharityHelp International and other sponsors, 2009-2011: co-convene the Connectivity to Enhance Global Human Security initiative.
- US Institute of Peace and other sponsors, 2005-2011: co-convene the Working Group on US-Iran Health Science Cooperation.
- Texans for a Sound Energy Policy, 2009: review of the US Nuclear Regulatory Commission's Draft Waste Confidence Decision.
- Green Energy Coalition, Pembina Institute, and Ontario Sustainable Energy Association, 2008: prepared testimony for submission to the Ontario Energy Board.
- Greenpeace Canada, 2007-2011: conduct technical and policy analysis on risk and sustainability issues related to the use of nuclear energy.
- World Health Organization, 2006-2007: conducted policy analysis on the potential for "health-bridge" programs to improve cooperation within and between nations.
 
Thompson Declaration:Comments on NRC's-September 2013 Draft GElS on Waste Confidence Page 110 of 120
* Sierra Club of Canada, 2006-2007: prepared a strategy for development of planning and public-engagement tools to facilitate action on climate change.
- Mothers for Peace, California, 2002-2009: analyzed risk issues and prepared expert testimony associated with the Diablo Canyon nuclear power plants.
- Riverkeeper, New York, 2007-2008: analyzed risk issues and prepared expert testimony associated with the Indian Point nuclear power plants.
- Minnesota Center for Environmental Advocacy, and Minnesotans for an Energy Efficient Economy, 2005-2006: conducted technical analysis and provided expert testimony regarding the Monticello nuclear power plant.
- California Energy Commission, 2005: conducted technical analysis and participated in an expert workshop regarding safety and security of commercial nuclear facilities.
- Committee on Radioactive Waste Management (a committee appointed by the UK government), 2005: provided expert advice and technical analysis on long-term safety and security of radioactive waste management.
* Legal Resources Centre, Cape Town, South Africa, 2004-2007: conducted technical analysis regarding the proposed South African pebble bed modular nuclear reactor.
* STAR Foundation, New York, 2002-2004: reviewed planning and actions for decommissioning of research reactors at Brookhaven National Laboratory.
- Attorney General of Utah, 2003: conducted technical analysis and provided expert testimony regarding a proposed national storage facility for spent nuclear fuel.
- Citizens Awareness Network, Massachusetts, 2002-2003: conducted analysis on robust storage of spent nuclear fuel.
* Tides Center, California, 2002-2004: conducted analysis for the Santa Susana Field Laboratory (SSFL) Advisory Panel regarding the history of releases of hazardous material from the SSFL.
* Orange County, North Carolina, 1999-2002: assessed risk issues associated with the Harris nuclear power plant, identified risk-reduction options, and prepared expert testimony.
- William and Flora Hewlett Foundation and other sponsors, 1999-2009: performed research and project development for conflict-management projects, through IRSS's International Conflict Management Program.
* STAR Foundation, New York, 2000-2001: assessed risk issues associated with the Millstone nuclear power plant, identified risk-reduction options, and prepared expert testimony.
- Massachusetts Water Resources Authority, 2000: evaluated risks associated with water supply and wastewater systems that serve greater Boston.
- Canadian Senate, Energy & Environment Committee, 2000: reviewed risk issues associated with the Pickering Nuclear Generating Station.
- Greenpeace International, Amsterdam, 2000: reviewed impacts associated with the La Hague nuclear complex in France.
- Government of Ireland, 1998-2001: developed framework for assessment of impacts and alternative options associated with the Sellafield nuclear complex in the UK.
- Clark University, Worcester, Massachusetts, 1998-1999: participated in confidential review of outcomes of a major foundation's grants related to climate change.
 
Thompson Declaration: Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 111 of 120
* UN High Commissioner for Refugees, 1998: co-developed a strategy for conflict management in the CIS region.
- General Council of County Councils (Ireland), W. Alton Jones Foundation (USA), and Nuclear Free Local Authorities (UK), 1996-2000: assessed environmental and economic issues of nuclear fuel reprocessing in the UK; assessed alternative options.
* Environmental School, Clark University, Worcester, Massachusetts, 1996: session leader at the Summer Institute, "Local Perspectives on a Global Environment".
* Greenpeace Germany, Hamburg, 1995-1996: performed a study on war, terrorism and nuclear power plants.
- HKH Foundation, New York, and Winston Foundation for World Peace, Washington, DC, 1994-1996: studies and workshops on preventive action and its role in US national security planning.
- Carnegie Corporation of New York, Winston Foundation for World Peace, Washington, DC, and others, 1995: collaboration with the Organization for Security and Cooperation in Europe to facilitate improved coordination of activities and exchange of knowledge in the field of conflict management.
- World Bank, 1993-1994: a study on management of data describing the performance of projects funded by the Global Environment Facility (joint project of IRSS and Clark University).
- International Physicians for the Prevention of Nuclear War, 1993-1994: a study on the international control of weapons-usable fissile material.
- Government of Lower Saxony, Hannover, Germany, 1993: analysis of standards for radioactive waste disposal.
- University of Vienna (using funds supplied by the Austrian government), 1992: review of radioactive waste management at the Dukovany nuclear power plant, Czech Republic.
- Sandia National Laboratories, 1992-1993: advice to the US Department of Energy's Office of Foreign Intelligence.
- US Department of Energy and Battelle Pacific Northwest Laboratories, 1991-1992:
advice for the Intergovernmental Panel on Climate Change regarding the design of an information system on technologies that can limit greenhouse gas emissions (joint project of IRSS, Clark University and the Center for Strategic and International Studies).
- Winston Foundation for World Peace, Boston, Massachusetts, and other funding sources, 1992-1993: development and publication of recommendations for strengthening the International Atomic Energy Agency.
- MacArthur Foundation, Chicago, Illinois, W. Alton Jones Foundation, Charlottesville, Virginia, and other funding sources, 1984-1993: policy analysis and public education on a "global approach" to arms control and disarmament.
- Energy Research Foundation, Columbia, South Carolina, and Peace Development Fund, Amherst, Massachusetts, 1988-1992: review of the US government's tritium production (for nuclear weapons) and its implications.
- Coalition of Environmental Groups, Toronto, Ontario (using funds supplied by Ontario Hydro under the direction of the Ontario government), 1990-1993: coordination and conduct of analysis and preparation of testimony on accident risk of nuclear power plants.
* Greenpeace International, Amsterdam, Netherlands, 1988-1990: review of probabilistic risk assessment for nuclear power plants.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 112 of 120
- Bellerive Foundation, Geneva, Switzerland, 1989-1990: planning for a June 1990 colloquium on disarmament, and editing of proceedings.
- Iler Research Institute, Harrow, Ontario, 1989-1990: analysis of regulatory response to boiling-water reactor accident potential.
- Winston Foundation for World Peace, Boston, Massachusetts, and other funding sources, 1988-1989: analysis of future options for NATO (joint project of IRSS and the Institute for Peace and International Security).
- Nevada Nuclear Waste Project Office, Carson City, Nevada (via Clark University),
1989-1990: analyses of risk aspects of radioactive waste management and disposal.
- Ontario Nuclear Safety Review (conducted by the Ontario government), Toronto, Ontario, 1987: review of safety aspects of CANDU reactors.
- Washington Department of Ecology, Olympia, Washington, 1987: analyses of risk aspects of a proposed radioactive waste repository at Hanford.
- Natural Resources Defense Council, Washington, DC, 1986-1987: preparation of expert testimony on hazards of the Savannah River Plant, South Carolina.
- Lakes Environmental Association, Bridgton, Maine, 1986: analysis of federal regulations for disposal of radioactive waste.
- Greenpeace Germany, Hamburg, 1986: participation in an international study on the hazards of nuclear power plants.
- Three Mile Island Public Health Fund, Philadelphia, Pennsylvania, 1983-1989: studies related to the Three Mile Island nuclear power plant and emergency response planning.
- Attorney General, Commonwealth of Massachusetts, 1984-1989: analyses of the safety of the Seabrook nuclear power plant, and preparation of expert testimony.
- Union of Concerned Scientists, Cambridge, Massachusetts, 1980-1985: studies on energy demand and supply, nuclear arms control, and the safety of nuclear installations.
- Conservation Law Foundation of New England, Boston, Massachusetts, 1985:
preparation of expert testimony on cogeneration potential at a Maine paper mill.
- Town & Country Planning Association, London, UK, 1982-1984: coordination and conduct of a study on safety and radioactive waste implications of the proposed Sizewell nuclear power plant, and testimony to the Sizewell Public Inquiry.
- US Environmental Protection Agency, Washington, DC, 1980-1981: assessment of the cleanup of Three Mile Island Unit 2 nuclear power plant.
* Center for Energy & Environmental Studies, Princeton University, Princeton, New Jersey, and Solar Energy Research Institute, Golden, Colorado, 1979-1980: studies on the potentials of renewable energy sources.
- Government of Lower Saxony, Hannover, Federal Republic of Germany, 1978-1979:
coordination and conduct of studies on safety and security aspects of the proposed Gorleben nuclear fuel cycle center.
Other experience (selected)
* Principal investigator, project on "Exploring the Role of'Sustainable Cities' in Preventing Climate Disruption", involving IRSS and three other organizations, 1990-1991.
- Visiting fellow, Peace Research Centre, Australian National University, 1989.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 113 of 120
* Principal investigator, Three Mile Island emergency planning study, involving IRSS, Clark University and other partners, 1987-1989.
- Co-leadership (with Paul Walker) of a study group on nuclear weapons proliferation, Institute of Politics, Harvard University, 1981.
- Foundation (with others) of an ecological political movement in Oxford, UK, which contested the 1979 Parliamentary election.
- Conduct of cross-examination and presentation of expert testimony, on behalf of the Political Ecology Research Group, at the 1977 Public Inquiry into proposed expansion of reprocessing capacity at Windscale, UK.
- Conduct of research on plasma theory (while a D.Phil candidate), as an associate staff member, Culham Laboratory, UK Atomic Energy Authority, 1969-1973.
- Service as a design engineer on coal-fired power plants, New South Wales Electricity Commission, Sydney, Australia, 1968.
Publications (selected)
- New andSignificant Informationfrom the FukushimaDaiichiAccident in the Context of Future Operationof the Pilgrim Nuclear Power Plant,a report for the Attorney General, Commonwealth of Massachusetts, June 2011.
- Outline of a Code of Conductfor Transfer of NuclearPower Plant Technology to Consumer Countries,a report for Nautilus Institute and RMIT University, April 2011.
- EnvironmentalImpacts of Storing Spent Nuclear Fuel and High-Level Waste from CommercialNuclear Reactors: A Critiqueof NRC's Waste Confidence Decision and EnvironmentalImpact Determination,a report for Texans for a Sound Energy Policy, Victoria, Texas, February 2009.
- Scope of the EISfor New Nuclear Power Plants at the DarlingtonSite in Ontario:
Accidents, Malfunctions and the PrecautionaryApproach, a report for Greenpeace Canada, November 2008.
- Cost Implications of the Residual RadiologicalRisk of Nuclear Generationof Electricity in Ontario,a report for the Green Energy Coalition et al, July 2008.
- "The US Effort to Dispose of High-Level Radioactive Waste", Energy and Environment, Volume 19, Numbers 3 and 4 (joint issue), 2008, pp 391-412.
- Design and Siting Criteriafor Nuclear Power Plants in the 21st Century, a report for Greenpeace Canada, January 2008.
- Risk-RelatedImpactsfrom Continued Operation of the IndianPoint Nuclear Power Plants,a report for Riverkeeper, Tarrytown, New York, November 2007.
* Assessing Risks of PotentialMalicious Actions at CommercialNuclear Facilities:The Case of a ProposedIndependent Spent Fuel Storage Installationat the Diablo Canyon Site, a report for San Luis Obispo Mothers for Peace, California, June 2007.
- Health as a Bridgefor Peace:Achievements, Challenges, and Opportunitiesfor Action by WHO (with Paula Gutlove), a report for the Department for Health Action in Crises, World Health Organization, Geneva, December 2006.
- "Using Psychosocial Healing in Postconflict Reconstruction" (with Paula Gutlove), in Marn Fitzduff and Chris E. Stout (eds), The Psychology of Resolving Global Conflicts:
From War to Peace, Praeger Security International, 2006.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 114 of 120
* "What Role for Nuclear Power in a Sustainable Civilization?", The Green Cross Optimist, Spring 2006, pp 28-30.
- RadiologicalRisk of Homeport Basing of a Nuclear-PropelledAircraft Carrierin Yokosuka, Japan,a report for the Citizens Coalition Concerning the Homeporting of a CVN in Yokosuka, June 2006.
- Risks and Risk-Reducing Options Associated with Pool Storage of Spent Nuclear Fuel at the Pilgrim and Vermont Yankee NuclearPowerPlants, a report for the Attorney General, Commonwealth of Massachusetts, May 2006.
- Reasonably ForeseeableSecurity Events: Potentialthreats to optionsfor long-term management of UK radioactive waste, a report for the UK Committee on Radioactive Waste Management, November 2005.
* "Plasma, policy and progress", The Australian MathematicalSociety Gazette, Volume 32, Number 3, 2005, pp 162-168.
- "A Psychosocial-Healing Approach to Post-Conflict Reconstruction" (with Paula Gutlove), Mind & Human Interaction,Volume 14, Number 1, 2005, pp 35-63.
- "Designing Infrastructure for New Goals and Constraints", Proceedings of the conference, Working Together: R&D Partnershipsin Homeland Security, Boston, Massachusetts, 27-28 April 2005, sponsored by the US Department of Homeland Security. (A version of this paper has also been published as CRS Discussion Paper 2005-02, Center for Risk and Security, George Perkins Marsh Institute, Clark University, Worcester, Massachusetts.)
- "Potential Radioactive Releases from Commercial Reactors and Spent Fuel",
Proceedings of the conference, Working Together: R&D Partnershipsin Homeland Security, Boston, Massachusetts, 27-28 April 2005, sponsored by the US Department of Homeland Security. (A version of this paper has also been published as CRS Discussion Paper 2005-03, Center for Risk and Security, George Perkins Marsh Institute, Clark University, Worcester, Massachusetts.)
- Safety of the ProposedSouth African Pebble Bed Modular Reactor, a report for the Legal Resources Centre, Cape Town, South Africa, 12 January 2005.
- Releases of HazardousMaterialfrom the Santa Susana FieldLaboratory:A Retrospective Review, a report for the SSFL Advisory Panel, June 2004.
- Decommissioning of Research Reactors at Brookhaven NationalLaboratory: Status, Future Options andHazards, a report for STAR Foundation, East Hampton, New York, April 2004.
- "Psychosocial Healing and Post-Conflict Social reconstruction in the Former Yugoslavia" (with Paula Gutlove), Medicine, Conflict and Survival, Volume 20, Number 2, April-June 2004, pp 136-150.
- "Reducing the Hazards from Stored Spent Power-Reactor Fuel in the United States" (with Robert Alvarez, Jan Beyea, Klaus Janberg, Jungmin Kang, Ed Lyman, Allison Macfarlane and Frank N. von Hippel), Science and Global Security, Volume 11, 2003, pp 1-51.
- "Health, Human Security, and Social Reconstruction in Afghanistan" (with Paula Gutlove and Jacob Hale Russell), in John D. Montgomery and Dennis A. Rondinelli (eds), Beyond Reconstruction in Afghanistan, Palgrave Macmillan, 2004.
 
Thompson Declaration. Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 115 of 120
*PsychosocialHealing: A Guidefor Practitioners,based on programs of the Medical Network for Social Reconstruction in the Former Yugoslavia (with Paula Gutlove), IRSS, Cambridge, Massachusetts and OMEGA Health Care Center, Graz, Austria, May 2003.
- A Callfor Action to Protect the Nation Against Enemy Attack on NuclearPower Plants and Spent Fuel, and a Supporting Document, San Luis Obispo Mothers for Peace, California, April 2003 and May 2003.
- "Human Security: Expanding the Scope of Public Health" (with Paula Gutlove),
Medicine, Conflict and Survival, Volume 19, 2003, pp 17-34.
- Social Reconstruction in Afghanistan through the Lens of Health and Human Security (with Paula Gutlove and Jacob Hale Russell), IRSS, Cambridge, Massachusetts, May 2003.
- Robust Storage of Spent Nuclear Fuel: A Neglected Issue of Homeland Security, a report for Citizens Awareness Network, Shelburne Falls, Massachusetts, January 2003.
- Medical Networkfor Social Reconstruction in the Former Yugoslavia: A Survey of Participants'Views on the Network's Goals andAchievements, IRSS, Cambridge, Massachusetts, September 2001.
* The Potentialfor a Large, Atmospheric Release of Radioactive Materialfrom Spent FuelPools at the HarrisNuclear PowerPlant.: The Case of a Pool Release Initiatedby a Severe ReactorAccident, a report for Orange County, North Carolina, November 2000.
- A Review of the Accident Risk Posed by the Pickering 'A' Nuclear GeneratingStation, a report for the Standing Committee on Energy, Environment and Natural Resources, Canadian Senate, August 2000.
- High-Level RadioactiveLiquid Waste at Sellafield."An UpdatedReview, a report for the UK Nuclear Free Local Authorities, June 2000.
- HazardPotentialof the La Hague Site: An InitialReview, a report for Greenpeace International, May 2000.
*A Strategyfor Conflict Management: IntegratedAction in Theory andPractice(with Paula Gutlove), IRSS, Cambridge, Massachusetts, March 1999.
- Risks andAlternative Options Associated with Spent Fuel Storage at the Shearon HarrisNuclear PowerPlant, a report for Orange County, North Carolina, February 1999.
- High Level RadioactiveLiquid Waste at Sellafield: Risks, Alternative Options and Lessons for Policy, IRSS, Cambridge, Massachusetts, June 1998.
- "Science, democracy and safety: why public accountability matters", in F. Barker (ed),
Management ofRadioactive Wastes: Issuesfor local authorities,Thomas Telford, London, 1998.
- "Conflict Management and the OSCE" (with Paula Gutlove), OSCE/ODIHR Bulletin, Volume 5, Number 3, Fall 1997.
* Safety of the Storage of Liquid High-Level Waste at Sellafield (with Peter Taylor),
Nuclear Free Local Authorities, UK, November 1996.
- Assembling Evidence on the Effectiveness of Preventive Actions, their Benefits, and their Costs: A Guidefor Preparationof Evidence, IRSS, Cambridge, Massachusetts, August 1996.
* War, Terrorism and NuclearPower Plants,Peace Research Centre, Australian National University, Canberra, October 1996.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 116 of 120
* "The Potential for Cooperation by the OSCE and Non-Governmental Actors on Conflict Management" (with Paula Gutlove), Helsinki Monitor, Volume 6 (1995), Number 3.
- "Potential Characteristics of Severe Reactor Accidents at Nuclear Plants", "Monitoring and Modelling Atmospheric Dispersion of Radioactivity Following a Reactor Accident" (with Richard Sclove, Ulrike Fink and Peter Taylor), "Safety Status of Nuclear Reactors and Classification of Emergency Action Levels", and "The Use of Probabilistic Risk Assessment in Emergency Response Planning for Nuclear Power Plant Accidents" (with Robert Goble), in D. Golding, J. X. Kasperson and R. E. Kasperson (eds), Preparingfor NuclearPower PlantAccidents, Westview Press, Boulder, Colorado, 1995.
*A Data Managerfor the GlobalEnvironment Facility (with Robert Goble),
Environment Department, The World Bank, June 1994.
- Preventive Diplomacy and NationalSecurity (with Paula Gutlove), Winston Foundation for World Peace, Washington, DC, May 1994.
- Opportunitiesfor InternationalControl of Weapons- Usable FissileMaterial, International Physicians for the Prevention of Nuclear War, Cambridge, Massachusetts, January 1994.
- "Article III and IAEA Safeguards", in F. Barnaby and P. Ingram (eds), Strengthening the Non-ProliferationRegime, Oxford Research Group, Oxford, UK, December 1993.
- Risk Implications of PotentialNew NuclearPlants in Ontario (prepared with the help of eight consultants), a report for the Coalition of Environmental Groups, Toronto, submitted to the Ontario Environmental Assessment Board, November 1992 (3 volumes).
- Strengthening the InternationalAtomic Energy Agency, IRSS, Cambridge, Massachusetts, September 1992.
- Design of an Information System on Technologies that can Limit Greenhouse Gas Emissions (with Robert Goble and F. Scott Bush), Center for Strategic and International Studies, Washington, DC, May 1992.
*Managing NuclearAccidents: A Model Emergency Response Planfor PowerPlants and Communities (with six other authors), Westview Press, Boulder, CO, 1992.
- "Let's X-out the K" (with Steven C. Sholly), Bulletin of the Atomic Scientists, March 1992, pp 14-15.
- "A Worldwide Programme for Controlling Fissile Material", and "A Global Strategy for Nuclear Arms Control", in F. Bamaby (ed), Plutonium and Security, Macmillan Press, UK, 1992.
- No Restartfor K Reactor (with Steven C. Sholly), IRS S, Cambridge, Massachusetts, October 1991.
*Regulatory Response to the Potentialfor ReactorAccidents: The Example of Boiling-Water Reactors, IRSS, Cambridge, Massachusetts, February 1991.
- Peace by Piece: New Optionsfor InternationalArms Control andDisarmament,IRSS, Cambridge, Massachusetts, January 1991.
- Developing PracticalMeasures to Prevent Climate Disruption (with Robert Goble),
CENTED Research Report No. 6, Clark University, Worcester, Massachusetts, August 1990.
- "Treaty a Useful Relic", Bulletin of the Atomic Scientists, July/August 1990, pp 32-33.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 117 of 120
* "Practical Steps for the 1990s", in Sadruddin Aga Khan (ed), Non-Proliferationin a Disarming World, Proceedings of the Groupe de Bellerive's 6th International Colloquium, Bellerive Foundation, Geneva, Switzerland, 1990.
- A Global Approach to ControllingNuclear Weapons, IRSS, Cambridge, Massachusetts, October 1989.
- JAEA Safety Targets and ProbabilisticRisk Assessment (with three other authors),
Greenpeace International, Amsterdam, August 1989.
- New Directionsfor NA TO (with Paul Walker and Pam Solo), published jointly by IRSS and the Institute for Peace and International Security (both of Cambridge, Massachusetts), December 1988.
- "Verifying a Halt to the Nuclear Arms Race", in F. Barnaby (ed), A Handbook of Verification Procedures,Macmillan Press, UK, 1990.
- "Verification of a Cutoff in the Production of Fissile Material", in F.Barnaby (ed), A Handbook of VerificationProcedures,Macmillan Press, UK, 1990.
* "Severe Accident Potential of CANDU Reactors," Consultant's Report in The Safety of Ontario'sNuclear PowerReactors, Ontario Nuclear Safety Review, Toronto, February 1988.
"Nuclear-FreeZones (edited with David Pitt), Croom Helm Ltd, Beckenham, UK, 1987.
"Risk Assessment Review For the Socioeconomic Impact Assessment of the Proposed High-Level Nuclear Waste Repository at HanfordSite, Washington (edited; written with five other authors), prepared for the Washington Department of Ecology, December 1987.
- The Nuclear Freeze Revisited (with Andrew Haines), Nuclear Freeze and Arms Control Research Project, Bristol, UK, November 1986. Variants of the same paper have appeared as Working Paper No. 18, Peace Research Centre, Australian National University, Canberra, February 1987, and in ADIU Report, University of Sussex, Brighton, UK, Jan/Feb 1987, pp 6-9.
* InternationalNuclear Reactor HazardStudy (with fifteen other authors), Greenpeace, Hamburg, Federal Republic of Germany (2 volumes), September 1986.
* "What happened at Reactor Four" (the Chernobyl reactor accident), Bulletin of the Atomic Scientists, August/September 1986, pp 26-31.
- The Source Term Debate:A Report by the Union of ConcernedScientists (with Steven C. Sholly), Union of Concerned Scientists, Cambridge, Massachusetts, January 1986.
* "Checks on the spread" (a review of three books on nuclear proliferation), Nature, 14 November 1985, pp 127-128.
- Editing of Perspectives on Proliferation,August 1985, published by the Proliferation Reform Project, IRSS.
* "A Turning Point for the NPT ?", ADIU Report, University of Sussex, Brighton, UK, Nov/Dec 1984, pp 1-4.
- "Energy Economics", in J. Dennis (ed), The Nuclear Almanac, Addison-Wesley, Reading, Massachusetts, 1984.
* "The Genesis of Nuclear Power", in J. Tirman (ed), The Militarizationof High Technology, Ballinger, Cambridge, Massachusetts, 1984.
- A Second Chance: New Hampshire'sElectricity Future as a Modelfor the Nation (with Linzee Weld), Union of Concerned Scientists, Cambridge, Massachusetts, 1983.
 
Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 118 of 120 Safety and Waste Management Implications of the Sizewell PWR (prepared with the help of six consultants), a report to the Town & Country Planning Association, London, UK, 1983.
- Utility-Scale ElectricalStorage in the USA: The Prospects ofPumped Hydro, CompressedAir,and Batteries, Princeton University report PU/CEES #120, 1981.
- The Prospectsfor Wind and Wave Power in North America, Princeton University report PU/CEES # 117, 1981.
- HydroelectricPower in the USA: Evolving to Meet New Needs, Princeton University report PU/CEES # 115, 1981.
- Editing and part authorship of "Potential Accidents & Their Effects", Chapter III of Report of the Gorleben InternationalReview, published in German by the Government of Lower Saxony, FRG, 1979; Chapter III published in English by the Political Ecology Research Group, Oxford, UK.
- A Study of the Consequences to the Public of a Severe Accident at a CommercialFBR locatedat Kalkar, West Germany, Political Ecology Research Group, 1978.
Expert presentations and testimony (selected)
- Egyptian Council for Foreign Affairs, Cairo, May 2011: presentation, "Nuclear Technology and Global Child Health: Threats and Opportunities".
- Bibliotecha Alexandrina, Egypt, April 2011: presentation, "Accelerating a Green-Technology Transition: A Leading Role for the BA".
- Conference, Prospectsfor Nuclear Non-Proliferationand Disarmament,Cairo, October 2010: presentation (with Paula Gutlove), "The Potential for Near-Term Confidence-Building Measures and Cooperative Actions for an Eventual Middle East NWFZ, Promoting the 2012 Conference".
- Blue Ribbon Commission on America's Nuclear Future, Washington, DC, September 2010: presentation to the Subcommittee on transportation & storage of radioactive waste.
- Green Cross Strategy Workshop, Geneva, May 2010: presentation, "Nuclear Weapons and Power: Issues and Opportunities".
* Munk Centre for International Studies, University of Toronto, March 2010: presentation (with Paula Gutlove), "Demonstrating a New Approach to Stability in Afghanistan:
Remote Engagement for Community Empowerment and Rural Development".
- Maxwell School, Syracuse University, February 2009: presentation, "A Second Track for Climate Negotiations: The Biosphere as Common Property".
- Marsh Institute, Clark University, February 2009: presentation, "Green Energy, Economic Renewal and Societal Learning: Research/Action Opportunities for Academia".
* Society for Risk Analysis annual meeting, Boston, Massachusetts, December 2008:
presentation, "Multi-Criteria Frameworks for Considering Diverse Risks in Infrastructure Design".
- Institute of Environmental Studies, University of New South Wales, Sydney, Australia, April 2008: presentation, "Citizen Engagement for Sustainable Society".
* Department of Urban and Regional Planning, Shaheed Beheshti University, Tehran, April 2008: presentation, "Sustainable Cities: Challenges and Opportunities".
 
Thompson Declaration:Comments on NRC's September 2013 Draft GEIS on Waste Confidence Page 119 of 120
*National Academy of Sciences, Washington, DC, January 2008: presentation, "What do interested parties think about the expansion of nuclear energy?"
- Abt Associates, Cambridge, Massachusetts, March 2007: presentation, "Creating Informed Action on Climate Change".
- Universities of Medical Science in Tabriz and Isfahan, Iran, April 2007: presentation, "Healthy Design of the Built Environment".
- Minnesota Public Utilities Commission, 2006: testimony regarding trends, risks and costs associated with management of spent fuel from the Monticello nuclear power plant.
- Presentation, "Are Nuclear Installations Terrorist Targets?", at the conference, Nuclear Energy: Does it Have a Future?, Drogheda, County Louth, Ireland, 10-11 March 2005.
- Presentation at the session, "UN Security Council Resolution 1244 and Final Status for Kosovo", at the conference, Lessons Learnedfrom the Balkan Conflicts, Boston College, Chestnut Hill, Massachusetts, 16-17 October 2004.
- California Public Utilities Commission, 2004: testimony regarding the nature and cost of potential measures for enhanced defense of the Diablo Canyon nuclear power plant.
- European Parliament, 2003: invited presentation to EP members regarding safety and security issues at the Sellafield nuclear site in the UK, and broader implications.
- US Congress, 2002 and 2003: invited presentations at member-sponsored staff briefings on vulnerabilities of nuclear-power facilities to attack and options for improved defenses.
- Numerous public forums in the USA, 2001-2006: invited presentations to public officials and general audiences regarding vulnerabilities of nuclear-power facilities to attack and options for improved defenses.
* UK Consensus Conference on Radioactive Waste Management, 1999: invited testimony on information and decision-making.
- Joint Committee on Public Enterprise and Transport, Irish Parliament, 1999: invited testimony on nuclear fuel reprocessing and international security.
- UK and Irish Parliaments, 1998: invited presentations to members on risks and alternative options associated with nuclear fuel reprocessing in the UK.
- Center for Russian Environmental Policy, Moscow, 1996: invited presentation at a forum in parallel with the G-7 Nuclear Safety Summit.
* Lacey Township Zoning Board, New Jersey, 1995: testimony regarding radioactive waste management.
- Ontario Court of Justice, Toronto, Ontario, 1993: testimony regarding Canada's Nuclear Liability Act.
* Oxford Research Group, seminar on "The Plutonium Legacy", Rhodes House, Oxford, UK, 1993: invited presentation on nuclear safeguards.
- Defense Nuclear Facilities Safety Board, Washington, DC, 1991: testimony regarding the proposed restart of K-reactor, Savannah River Site.
- Conference to consider amending the Partial Test Ban Treaty, United Nations, New York, 1991: presentation on a global approach to arms control and disarmament.
- US Department of Energy, hearing on draft EIS for new production reactor capacity, Columbia, South Carolina, 1991: testimony on tritium need and implications of tritium production options.
 
4 Thompson Declaration:Comments on NRC's September 2013 Draft GElS on Waste Confidence Page 120 of 120 Society for Risk Analysis, 1990 annual meeting, New Orleans, special session on nuclear emergency planning: presentation on real-time techniques for anticipating emergencies.
- Parliamentarians' Global Action, 11th Annual Parliamentary Forum, United Nations, Geneva, 1990: invited presentation on the potential for multilateral nuclear arms control.
* Advisory Committee on Nuclear Facility Safety, Washington, DC, 1989: testimony on public access to information and on government accountability.
* Peace Research Centre, Australian National University, seminar on "Australia and the Fourth NPT Review Conference", Canberra, 1989: invited presentation regarding a universal nuclear weapons non-proliferation regime.
*Carnegie Endowment for International Peace, Conference on "Nuclear Non-Proliferation and the Role of Private Organizations", Washington, DC, 1989: invited presentation on options for reform of the non-proliferation regime.
- US Department of Energy, EIS scoping hearing, Columbia, South Carolina, 1988:
testimony on appropriate scope of an EIS for new production reactor capacity.
- International Physicians for the Prevention of Nuclear War, 6th and 7th Annual Congresses, Koln, FRG, 1986 and Moscow, USSR, 1987: invited presentations on relationships between nuclear power and the threat of nuclear war.
- County Council, Richland County, South Carolina, 1987: testimony on implications of severe reactor accidents at the Savannah River Plant.
- Maine Land Use Regulation Commission, 1985: testimony on cogeneration potential at facilities of Great Northern Paper Company.
- Interfaith Hearings on Nuclear Issues, Toronto, Ontario, 1984: invited presentations on options for Canada's nuclear trade and Canada's involvement in nuclear arms control.
- Sizewell Public Inquiry, UK, 1984: testimony on safety and radioactive waste implications of the proposed Sizewell nuclear power plant.
* New Hampshire Public Utilities Commission, 1983: testimony on electricity demand and supply options for New Hampshire.
- Atomic Safety & Licensing Board, US Nuclear Regulatory Commission, 1983:
testimony on use of filtered venting at the Indian Point nuclear power plant.
- US National Advisory Committee on Oceans and Atmosphere, 1982: testimony on implications of ocean disposal of radioactive waste.
- Environmental & Energy Study Conference, US Congress, 1982: invited presentation on implications of radioactive waste management.
 
UCS Perspective on Expedited Transfer of Spent Fuel to Dry Casks January 6, 2014 Dr. Edwin S. Lyman Senior Scientist Union of Concerned Scientists
 
Summary
* UCS supports expedited transfer of spent fuel to dry casks as a prudent, -passive, defense-in-depth measure for significantly reducing risk from accidents and attacks
* The staff has not provided adequate support for its recommendation to close out this issue; Phase 2 should proceed 2
 
The NRC's Responsibility
* Is to protect the health and safety of everyone, not just the "average" citizen affected by an "average" accident
* Even if calculations based on average assumptions suggest action is not warranted, the danger posed by high-risk outliers needs to be addressed 3
 
Staff Non-Concurrences
* The staff non-concurrences to COMSECY-13-0030 raise serious issues with the study methodology and should be given great weight
* The management response to the non-concurrences fails to adequately address the fundamental concerns 4
 
Three Numbers
" Estimated atmospheric Cs-137 release from Fukushima Daiichi:
0.5 MCi
* Peak release estimate, low-density pool scenario, SFPS:
0.33 MCi
" Peak release estimate, high-density 1x4 pool scenario, SFPS:
24.2 MCi 5
 
Three More Numbers
* Estimated collective dose to Japan from Fukushima Daiichi:
32,000 person-Sievert
* Collective dose for low-density pool, no mitigation, SFPS:
27,000 person-Sievert (0.11 MCi)
* Collective dose, high-density 1x4 pool, no mitigation, SFPS:
350,000 person-Sievert (8.8 MCi) 6
 
Dry Casks: Tomorrow's Passive Technology Today
* Dry cask storage and low-density pool storage achieve features the NRC encourages in advanced reactors:
  - Highly reliable and less complex shutdown and decay heat removal systems. The use of inherent or passive means to accomplish this objective is encouraged.
  - Simplified safety systems that ... reduce required operator actions, equipment subjected to severe environmental conditions, and components needed for maintaining safe shutdown conditions.
  - Designs that minimize the potential for severe accidents and their consequences 7
 
The Wrong Methodology
* Staff non-concurrences question use of reactor-focused regulatory analysis guidelines
  - The QHOs are not the right metrics to evaluate land contamination events
  - Cost-benefit analysis does not give adequate weight to features such as
* Impacts beyond 50 miles
* Defense-in-depth
* Non-quantifiable aspects of land contamination
    " Security considerations 8
 
Selected Flaws in SFPS/Regulatory Analysis
* The assumed regulatory baseline does NOT reflect the actual fleet:
  - Assumes immediate offloading into Ux4 configuration
  - Assumes full-core offload capability
" RA is a patchwork of different studies
  - Does not treat PWRs (2/3 of the fleet) on a consistent basis with BWRs
" Studies assume evacuations of up to 30 miles, well beyond the EPZ regulatory requirement                        9
 
Selected Flaws (cont.)
* Base case Cs release fraction of 40% for high-density and 3% for low-density does not account for differences in frequency of these releases
* 72-hour analysis limit is unrealistic and may underestimate base case risk
* 50-mile truncation and use of average meteorology underestimate benefits
  - Use of 9 5 th percentile weather would change the cost-benefit calculus, even for 7% NPV
* Although many of these issues are partially examined in sensitivity analyses, RA does not adequately account for uncertainties                10
 
Mitigation
* SFPS mitigated scenarios assume 50.54(hh)(2) measures, which cannot be assumed to work in BDBEEs or attacks other than a jet crash
  - Portable pump for SFP/core makeup only requires 12 hours of fuel and water supply
    -"notto be treated as safety-related equipment (QA, seismic, EQ, etc.")
* SFPS/RA do not provide quantitative estimates of the likelihood of mitigation
* RA assumption of successful mitigation only for low-density pools appears to affect cost-benefit differential by 10 percent or less        11
 
Security and Defense-in-Depth
* The SFPS demonstrates the danger of uniform loading at high density compared to 1x4
  - Risk within 10 mi is 10 times greater for a uniform high-density pool with mitigation
  - Land interdiction area is 78 times greater for uniform high-density pool than low-density pool without mitigation
  - Land interdiction area for uniform high-density pool with mitigation is nearly 7 times low-density pool without mitigation 12
 
Security and Defense-in-Depth o Yet the NRC will not tell the public how long it takes after a refueling for any reactor to achieve a lx4 configuration or even if all reactors can do it 6"... the specific time requirement is not publicly available information (because it could be ... useful to an adversary)..."
o Transition to low-density pools could
  - greatly reduce the consequences of a terrorist attack soon after an outage
  - reduce reliance on mitigation 13
 
Safety and Defense-in-Depth
" Defense-in-depth has been manifested, in part, in a conditional containment failure probability of <0.1
* One historical measure of a large releases has been > 10 percent of Cs/I
" By this standard, "CCFP" (for the SFPS Bin 3 seismic event) is 0.45 for high-density pools, 0 for low-density
* (UCS does not agree with the NRC decision to phase out CCFP/LRF) 14
 
Hydrogen Mitigation
* The SPFS and RA do not give full credit to low-density pools for the low risk of hydrogen generation and combustion
  - Only high-density scenarios produced sufficient hydrogen for an explosion
  - Avoidance of hydrogen explosions is beneficial not only for reducing population dose but also for reducing occupational hazards, multi-unit accident risk, and site cleanup and decommissioning 15
 
A New Framework The Commission should defer a final decision on expedited transfer until it can be evaluated using revised regulatory analysis guidelines consistent with NTTF Recommendation 1, RMTF, the economic consequences SECY, and a defensible value of a statistical life (at least
$4000/person-rem)                  16
 
Acronyms
" BDBEE: Beyond Design Basis External Event o CCFP: Conditional Containment Failure Probability
" EPZ: Emergency Planning Zone
" LRF: Large Release Frequency
" NPV: Net Present Value
* QHOs: Quantitative Health Objectives                    17
 
Acronyms
" RA: Regulatory Analysis "SFPS: Spent Fuel Pool Study
" UCS: Union of Concerned Scientists 18.
 
U.OSNRC UNITED STATES NUCLEAR REGULATORY COMMISSION ProtectingPeople and the Environment Spent Fuel Pool Safety and Consideration of Expedited Transfer To Dry Cask Storage Commission Meeting January 6, 2014
 
Agenda
* Introduction                M. Johnson
* Background & Overview      J. Uhle 9 Spent Fuel Pool (SFP) Study B. Sheron J. Pires H. Esmaili
* Tier 3 Evaluation Process  F. Schofer
* Findings and Recommendation M. Johnson 2
 
Safety Perspectives
* SFPs provide adequate protection
" Safety and security improvements have been implemented
" Low-density loading provides only minor or limited safety benefit
* Expedited transfer does not meet thresholds for pursuing regulatory actions or additional studies 3
 
Timeline of Major SFP-related Activities Action Plan Activities to                                    Comprehensive Increase SFP Cooling                                        Site Level 3 PRA Reliability (mid-90s)                                                  Study (2012 - 2016)
Transition to High-Density SFP Racking (starting in late 70s)
National Academy of Science S Study (2003 - 2005)
NUREG-1 738 St udy Early SFP Consequence                                                                          Post-for Decommissio II lIly Studies (e.g., NUREG/CR-                                                                Fukushima (1999 - 2001) 0649) and High-Density                                                                    Activities Racking Review Criteria R      esolution  of Generic Issue 82,                        (2011 -2016)
Development (late 70s)            "Beyond  Design Basis        Post-9/11 Securi
                              ,ccidents in Spent Fuel Pools"            Activities (late-80s)                  (2001 - 2009) 4
 
Tier 3 Issue
* Determine whether regulatory action is needed for expedited transfer of spent fuel to dry casks
* Tier 3 plan reflects Commission direction and alignment with relevant activities
    - Phase 1: Evaluate whether additional studies are needed to determine if regulatory action might be warranted (COMSECY-13-0030, November 12, 2013)
    - Phases 2 and 3: Ifdirected, perform additional analyses to reduce conservatisms and consider other factors 5
 
Decision-Making Process Staff followed normal regulatory process utilizing Regulatory Analysis Guidelines (NUREG/BR-0058) 9 Used information from past SFP evaluations and the recent SFP Study
* Conservative analysis that increases calculated benefits of expedited transfer e Recommendation based on safety goal screening and cost-benefit analysis 6
 
Tier 3 Analysis Overview 7
 
SFP Study Objectives
* Determine if accelerated spent fuel transfer to dry cask at a reference plant substantially enhances public health and safety
* Calculate public consequence estimates for a beyond-design-basis earthquake affecting a spent fuel pool under high- and low-density loading conditions
* Provide input to the regulatory analysis for this Tier 3 issue 8
 
SFP Study Approach
* Detailed analysis of a BWR Mark I reactor SFP modeled after Peach Bottom
* Initiating event is a severe earthquake (highest risk contributor)
* Detailed analysis of structural effects for the severe earthquake
* Uses state-of-the-art computational codes
* Analyzed scenarios with and without successful mitigation 9
 
Seismic/Structural Assessment
" Considered a 1 in 60,000 year seismic event
* No liner tearing and no leaking with 90% likelihood
" Liner tearing spreading along the base of the walls with 5% likelihood (moderate leak state)
* Liner tearing localized in parts of the liner at the base of the walls with 5% likelihood (small leak state)
* No leakage of water below the top of the fuel was reported for 20 SFPs affected by two major recent earthquakes in Japan
  - Consistent with low likelihood of leakage estimated for this study 10
 
SFP Study Results Seismic event (0.7 gpeak ground acceleration)
I J
Note The lowdensity pool hasabout SofCs-137invenWycompared to hgo-density pool. Earlyinthe operaUng cycle refers to earlyUme after shutzlown.
11
 
SFP Study Results
" For the severe earthquake studied, the SFP is unlikely to leak (partial draindown not credible)
" For the analyzed configurations, spent fuel can be cooled by air within a few months after it is moved into the pool (even with closed-frame racks)
" Both high- and low-density pool loads generate a release with similar (but very low) frequency; high-density loading can lead to a larger release
" While accidents involving high-density pools could lead to greater economic impacts, public health effects are relatively insensitive to loading patterns 12
 
SFP Study Results, cont'd
" Estimates of public health and environmental effects are generally the. same or smaller than earlier studies
* The Study confirms SFPs adequately protect public health and safety
" The regulatory analysis for the reference plant indicates that faster spent fuel transfer does not substantially enhance safety and costs outweigh benefits 13
 
Tier 3 Analysis Overview 14
 
Tier 3 Evaluation Process
* Safety Goal Screening Evaluation
  - Designed to answer when a regulatory requirement should not be imposed generically because the residual risk is already acceptably low
* Cost/Benefit Analysis
  - Analyzed to compare estimates of potential benefit against cost to determine -whether the alternative is cost-justified 15
 
Safety Goal Screening Results'
* Did not pass the safety goal screening
  - No risk of immediate fatalities due to nature of release
  - SFP accidents are a small contributor to the overall risks for public health and safety (less than one percent of the quantitative health objectives
* Although the safety goal screening did not pass, proceeded to cost-benefit analysis to provide information to the Commission 16
 
Cost-Benefit Analysis Overview
* Screening evaluation representing operating and new plants
* SFP Study and earlier SFP studies provide inputs to the analysis
* Modeled both high - and low-density SFP configurations i Conservative analysis weighted to favor expedited transfer 17
 
Key Conservative Assumptions
" Initiating event frequency
* Failure of SFP liner (liner fragility)
* Inadequate cooling (air coolability)
* Mitigation capabilities
" Amount of material released 18
 
Cost-Benefit Analysis Results
" Did not pass the safety goal screening
" Even if expedited transfer passed the safety goal screening, expedited transfer is not cost-justified
" The staff considers the regulatory analysis an appropriately conservative approach for the decision on whether to proceed with further study in Phases 2 and 3 19
 
Stakeholder Interactions
* Issues raised by stakeholders have been considered by staff
  - SFP Study public comments
  - Consideration of security within analysis
  - Proper use of the Safety Goal Policy Statement
  - ACRS comments on crediting of mitigation
* Other alternatives considered
  - Alternative loading patterns, enhancement of mitigation
  - Does not pass safety goal screening criteria 20
 
Conclusion
* Current SFPs provide reasonable assurance of adequate protection of public safety
* Expedited transfer of spent fuel would provide only a minor or limited safety benefit
* The costs of expedited transfer of spent fuel to dry cask storage outweigh the benefits
* Additional studies are not needed
* No further regulatory action is recommended and this Tier 3 item should be closed 21
 
Acronyms 9 ACRS -Advisory Committee on Reactor Safeguards
* BWR - Boiling Water Reactor 0 Cs- Cesium
*PRA    - Probabilistic Risk Assessment
*SFP  -  Spent Fuel Pool 22
 
January 3, 2014 VIA ELECTRONIC MAIL Allison M. Macfarlane, Chair Kristine L. Svinicki George Apostolakis William D. Magwood IV William C. Ostendorff U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Re:    COMSECY-13-0300 Honorable Commissioners:
The NRC Staff ("Staff") recently forwarded COMSECY-13-0300 to the Commissioners with the recommendation that "no further generic assessments be pursued related to possible regulatory actions to require the expedited transfer of spent fuel to dry cask storage." Id. at 10 (footnote omitted). If the Commissioners decide to take that action and forego further consideration of expedited transfer to dry cask storage, spent fuel will remain in densely packed pools at reactor sites. The undersigned States would like to express their concern to the
.Commissioners that there has not been sufficient review of the environmental impacts of that outcome and potential mitigation measures to address those impacts.
The States very recently learned that the Commission convened a meeting to examine this issue for January 6, 2014. While the Commission invited four industry representatives and non-governmental-organization representatives to participate in the meeting, the Commission did not invite the States. The States request that the Commission provide representatives of the States the same opportunity to present their views to the Commissioners at an open public meeting before taking any action on COMSECY-13-0300.
1
 
For the reasons set forth in this letter and at that meeting, the States request that the Commissioners remand COMSECY- 13-0300 back to Staff for a thorough, objective, and rigorous analysis of the environmental impacts of dense packing of spent fuel pools and potential mitigation measures to address those impacts.
COMSECY-13-0300 relied heavily on the 2013 Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor ("Spent Fuel Consequence Study"), which was provided to the Commissioners in SECY-13-0112, but that study is not an environmental impact statement. In addition, as explained in the States' recent comments and New York's additional comments submitted in the Commission's Waste Confidence rulemaking, which we incorporate by reference here, the study is significantly flawed. Considerationof EnvironmentalImpacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operations,NRC-2012-0246, Comments Submitted by the Attorneys General of the States of New York, Vermont, Connecticut, and the Commonwealth of Massachusetts, the Vermont Department of Public Service, and the Prairie Island Indian Community on the Nuclear Regulatory Commission's Draft Waste Confidence Generic Environmental Impact Statement and Proposed Rule (Dec. 20, 2013) ("States' December 2013 Comments") at 28-34; Additional Comments Submitted by the Attorney General of the State of New York on the Nuclear Regulatory Commission's Draft Waste Confidence Generic Environmental Impact Statement and Proposed Rule (Dec. 20, 2013) (ML13361A000).                  The only analysis available to the Commissioners of the environmental impacts of dense packing of pools is NUREG-0575, Final Generic Environmental Impact Statement On Handling and Storage of Spent Light Water Power Reactor Fuel (August 1979) ("NUREG-0575"). For several 2
 
reasons, that analysis does not provide an appropriate basis for the Commission to conclude that dense packing of pools does not have significant environmental impacts. First, as explained below and in more detail in the States' recent comments regarding the draft Waste Confidence GELS, the analysis in NUREG-0575 was based on several assumptions that have proven incorrect. States' December 2013 Comments at 23-36. Of most concern to the States, the analysis assumed that spent fuel would be moved away from reactors beginning in 2000, which has not happened. Second, as also explained in the States' December 2013 Comments, NUREG-0575 recommended that impacts be analyzed on a site-specific basis, which COMSECY-13-0300 does not contemplate. Id. Third, NUREG-0575 was issued almost twenty-five years ago and, as explained in further detail below, there is considerable new and significant information about spent fuel pools, only some of which is addressed in COMSECY-13-0300, that would substantially alter the analysis in NUREG-0575.
NUREG-0575 Is Not an Appropriate Basis for Concluding that Dense Packing of Spent Fuel Pools Does Not Have Significant Environmental Impacts In 1979, as a result of a number of changes in the previously expected handling of spent nuclear fuel, the Commission issued NUREG-0575 to "examine[ ] alternative methods of spent fuel storage as well as the possible restriction or termination of the generation of spent fuel through nuclear power plant shutdown." NUREG-0575, Vol 1 at ES-1. This generic analysis was relied upon by the Commission in initially approving the use of a densely packed spent fuel pool at many reactors, including Vermont Yankee. See e.g. See e.g., Letter from Vernon Rooney (NRC) to R. W. Capstick (VY Nuclear Corporation), Re: Environmental Assessment And Finding Of No Significant Impact Spent Fuel Pool Expansion, Vermont Yankee Nuclear Power Station (Tac No. 65253) (July 25, 1988), Attachment (Environmental Assessment and Finding of 3
 
No Significant Impact by the Office of Nuclear Reactor Regulation Relating to the Spent Fuel Pool Facility Operating License No. DPP-28 Vermont Yankee Nuclear Power Corporation Vermont Yankee Nuclear Power Station Docket No. 50-271) at 2-4 (ML011640081).
The analysis of environmental impacts in NUREG-0575 would not provide an appropriate basis for the Commission to determine that it can forego further consideration of the expedited transfer of spent fuel to dry cask storage. First, the analysis that spent fuel can continue to remain in densely packed pools without significant environmental impacts was based on the assumption that spent fuel would begin to be moved from spent fuel pools to a permanent, off-site repository, by 2000. Allowing densely packed spent fuel to remain in pools at reactor sites for the indefinite future has never been evaluated in an environmental impact statement.
Second, NUREG-0575 recognized that in making a decision to allow spent fuel to be densely packed and stored in pools at reactor sites, many issues are inherently site-specific and cannot be fully resolved on a generic basis. "Because there are many variations in storage pool designs and limitations caused by spent fuel already in some pools, the licensing reviews must be done on a case-by-case basis." NUJREG-0575 at 8-1. Nonetheless, the Commission has effectively foreclosed a "case-by-case" analysis by relying on NUREG-0575 as the basis for its environmental findings regarding waste confidence and the safety of storage of spent fuel at reactor sites for periods as long as 30 years after plant shutdown.' See Final Waste Confidence The Commission did determine that spent fuel could be stored for 60 years after plant shutdown in densely packed spent fuel pools "safely and without significant environmental impacts" (Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation, 75 Fed. Reg. 81031, 81033 (December 23, 2010) ("2010 Waste Confidence"), but that finding was vacated in New York v. NRC, 681 F.3d 471 (D.C. Cir. 2012).
Also, when NRC made past decisions to treat this issue generically, it used outdated information and assumed that spent fuel would be leaving reactor sites by a date certain and by 2025 at the 4
 
Decision, 49 Fed. Reg. 34658, 34682 (Aug. 31, 1984).
Third, significant new information substantially alters the environmental analysis and mitigation options in NUREG-0575. 2 In particular, NUREG-0575:
: 1. Assumed that there was "little safeguards significance" to spent fuel storage given "the absence of any information confirming an identifiable threat to nuclear activities,"
NUREG-0575 at ES-7, and thus conducted analysis of the safeguards risk uninformed by what the federal government and the Nation have learned from the September 11 attacks and other terrorist acts, the 9-11 Commission Investigation and Report, and the 2005 National Academies of Science report on spent fuel pools. Compare NRC Regulatory Issue Summary 2002-12A Power Reactors NRC Threat Advisory and Protective Measures System (August 19, 2002) and EA-03-086, Issuance of Order Requiring Compliance with Revised Design Basis Threat for Operating Power Reactors (April 29, 2003).
: 2. Was prepared before the events at Fukushima which have dramatically changed the perception and understanding of the safety of spent fuel stored in pools at reactor sites, including new information from the NRC's modeling of significant potential environmental impacts from the loss of coolant at the spent fuel pools at Fukushima.
: 3. Was prepared before the current information regarding the increased risk and consequences from seismic events in the Northeast. See Statement in Support of New York State Contentions and in Response to the April 30, 2007 License Renewal Application Submitted by Entergy for Indian Point Units 2 and 3 by Lynn. R. Sykes, Ph.D. Higgins Professor Emeritus, Earth & Environmental Sciences Lamont-Doherty Earth Observatory of Columbia University, Palisades NY 10964 (Nov. 29, 2007) and Declaration of Leonardo Seeber, senior research scientist at the Lamont-Doherty Earth Observatory of Columbia University (Nov. 29, 2007) both filed as exhibits to New York State Notice of Intention to Participate and Petition to Intervene in Entergy Nuclear Indian Point 2, LLC, Entergy Nuclear Indian Point 3, LLC and Entergy Nuclear Operations, Inc., Docket Nos. 50-247-LR and 50-286-LR (Nov. 30, 2007),
ML073400205.
latest. The D.C. Circuit has now made clear that NRC must consider the possibility that spent fuel may "be stored on site at nuclear plants on a permanent basis." Id. at 479.
2 As the States recently noted, there is "new and significant information since NUREG-0575" and "[i]n Marsh v. OregonNatural Resources Counsel, 490 U.S. 360, 372 (1989) the Court held that NEPA 'impose[s] a duty on all federal agencies to prepare supplements to either draft or final EISs if there "are significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts,"' citing CEQ Regulations." States' December 2013 Comments at 26 n. 12.
5
: 4. Was prepared with little or no consideration of the risk of a catastrophic fire in a densely packed spent fuel pool, a risk that has been determined to be substantially more significant than was believed to be the case in 1979. See, e.g., Declaration of 19 December 2013 by Gordon R. Thompson: Comments on the US Nuclear Regulatory Commission's Waste Confidence Generic Environmental Impact Statement, Draft Report for Comment (September 2013).
: 5. Was prepared assuming that the spent fuel being stored in the spent fuel pool will be low-burnup spent fuel and not the high-burnup fuel now being discharged by reactors.
See States' December 2013 Comments at 95-100.
: 6. Was prepared without the benefit of new insights regarding the impact of the differing profiles presented by "host" spent fuel pool storage sites. See, e.g., Additional Comments Submitted by the Attorney General of the State of New York on the Nuclear Regulatory Commission's Draft Waste Confidence Generic Environmental Impact Statement and Proposed Rule (Dec. 20, 2013); International Safety Research Report No. 13014-02 Review of Waste Confidence Generic Environmental Impact Statement, Francois Lemay, Ph. D. (Dec. 20, 2013); and accompanying documents submitted in RIN 3150-A520, NRC-2012-0246.
This new information is significant and affects the environmental impacts of continued use of densely packed spent fuel pool storage and alternatives to mitigate those consequences.
See COMSECY-1 3-0300 Enclosure 2 (non-concurrence) at 2 ("[O]nly a single alternative is considered. Other alternatives may be more cost beneficial."). For example, the duration of storage of spent fuel in spent fuel pools and at reactor sites is far greater than assumed in NUREG-0575 and the presence of the high-burnup fuel in the pools greatly increases both the likelihood and consequences of the release of substantial radiation in the event of an accident or a malevolent act. See States' December 2013 Comments at 95-100.
For all these reasons, NUREG-0575 does not provide a basis for the Commission to conclude that dense packing of pools does not have significant environmental impacts. As a result, the Commission should remand COMSECY- 13-0300 back to the Staff for an updated analysis of the impacts of dense packing of pools before the Commission determines that it will 6
 
give no further consideration to the expedited transfer of spent fuel to dry cask storage.
Conclusion' The Commission should not foreclose the expedited transfer of spent fuel to dry cask storage without a full examination of the environmental impacts of the indefinite storage of spent fuel in densely packed pools and potential mitigation measures to address those impacts. States that "host" spent nuclear fuel storage facilities have a direct interest in those environmental impacts and the thorough decontamination that would be necessary following any severe accident at a spent fuel pool. Further, the States' important role in the Nation's federalist system warrants that their concerns and expertise be heard as the Commission considers these important public safety matters. Accordingly, the Commissioners should convene a meeting with the States so that the States may make their concerns and expertise known directly to the Commissioners.
Sincerely, William E. Griffin        /                          Lemuel M. Srolovic Chief Assistant Attorney General                      Bureau Chief State of Vermont                                      Environmental Protection Bureau Office of the Attorney General                        New York State Attorney General 109 State Street                                      212-416-8448 Montpelier, Vermont                                  lemuel.srolovic@ag.ny.gov 05609-1001 BGriffin@atg.state.vt.us 7
 
Darren M. Springer      4F    r,-
Deputy Commissioner          f Anthony Z. Roisman Of Counsel State of Vermont Department of Public Service 112 State Street Montpelier, Vermont 05602 Matthew Brock              W          Robert Snook Assistant Attorney General            Assistant Attomey General Commonwealth of Massachusetts        Office of the Attorney General Office of the Attorney General        55 Elm Street, P.O. Box 120 One Ashburton Place                  Hartford, Connecticut 06106 Boston, Massachusetts 02108          (860) 808-5107 (617) 727-2200, ext. 2425            robert.snook@ct.gov matthew.brock@state.ny.us 8}}

Latest revision as of 00:03, 11 January 2025

M140106A: Slides - Industry Views on Spent Fuel Pool Storage and Adequacy of Existing Requirements
ML14006A332
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Issue date: 01/06/2014
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