Nuclear Regulatory Commission
NRC Needs to Do More to Ensure that Power Plants Are Effectively Controlling Spent Nuclear Fuel Gao ID: GAO-05-339 April 8, 2005Spent nuclear fuel--the used fuel periodically removed from reactors in nuclear power plants--is too inefficient to power a nuclear reaction, but is intensely radioactive and continues to generate heat for thousands of years. Potential health and safety implications make the control of spent nuclear fuel of great importance. The discovery, in 2004, that spent fuel rods were missing at the Vermont Yankee plant in Vermont generated public concern and questions about the Nuclear Regulatory Commission's (NRC) regulation and oversight of this material. GAO reviewed (1) plants' performance in controlling and accounting for their spent nuclear fuel, (2) the effectiveness of NRC's regulations and oversight of the plants' performance, and (3) NRC's actions to respond to plants' problems controlling their spent fuel.
Nuclear power plants' performance in controlling and accounting for their spent fuel has been uneven. Most recently, three plants--Vermont Yankee and Humboldt Bay (California) in 2004 and Millstone (Connecticut) in 2000--have reported missing spent fuel. Earlier, several other plants also had missing or unaccounted for spent fuel rods or rod fragments. NRC regulations require plants to maintain accurate records of their spent nuclear fuel and to conduct a physical inventory of the material at least once a year. The regulations, however, do not specify how physical inventories are to be done. As a result, plants differ in the regulations' implementation. For example, physical inventories at plants varied from a comprehensive verification of the spent fuel to an office review of the records and paperwork for consistency. Additionally, NRC regulations do not specify how individual fuel rods or segments are to be tracked. As a result, plants employ various methods for storing and accounting for this material. Further, NRC stopped inspecting plants' material control and accounting programs in 1988. According to NRC officials, there was no indication that inspections of these programs were needed until the event at Millstone. NRC is collecting information on plants' spent fuel programs to decide if it needs to revise its regulations and/or oversight. In addition to reviewing specific instances of missing fuel, NRC has had its inspectors collect basic information on all facilities' programs. It has also contracted with the Department of Energy's Oak Ridge National Laboratory in Tennessee to review NRC's material control and accounting programs for nuclear material, including spent fuel. It further plans to request information from plant sites and visit over a dozen of them for more detailed inspection. These more detailed inspections may not be completed until late 2005, over 5 years after the instance at Millstone that initiated NRC's efforts. However, we believe NRC has already collected considerable information indicating problems or weaknesses in plants' material control and accounting programs for spent fuel.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-05-339, Nuclear Regulatory Commission: NRC Needs to Do More to Ensure that Power Plants Are Effectively Controlling Spent Nuclear Fuel
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Report to Congressional Requesters:
April 2005:
Nuclear Regulatory Commission:
NRC Needs to Do More to Ensure that Power Plants Are Effectively
Controlling Spent Nuclear Fuel:
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-339]:
GAO Highlights:
Highlights of GAO-05-339, a report to congressional requesters
Why GAO Did This Study:
Spent nuclear fuel”the used fuel periodically removed from reactors in
nuclear power plants”is too inefficient to power a nuclear reaction,
but is intensely radioactive and continues to generate heat for
thousands of years. Potential health and safety implications make the
control of spent nuclear fuel of great importance. The discovery, in
2004, that spent fuel rods were missing at the Vermont Yankee plant in
Vermont generated public concern and questions about the Nuclear
Regulatory Commission‘s (NRC) regulation and oversight of this
material.
GAO reviewed (1) plants‘ performance in controlling and accounting for
their spent nuclear fuel, (2) the effectiveness of NRC‘s regulations
and oversight of the plants‘ performance, and (3) NRC‘s actions to
respond to plants‘ problems controlling their spent fuel.
What GAO Found:
Nuclear power plants‘ performance in controlling and accounting for
their spent fuel has been uneven. Most recently, three plants”Vermont
Yankee and Humboldt Bay (California) in 2004 and Millstone
(Connecticut) in 2000”have reported missing spent fuel. Earlier,
several other plants also had missing or unaccounted for spent fuel
rods or rod fragments.
NRC regulations require plants to maintain accurate records of their
spent nuclear fuel and to conduct a physical inventory of the material
at least once a year. The regulations, however, do not specify how
physical inventories are to be done. As a result, plants differ in the
regulations‘ implementation. For example, physical inventories at
plants varied from a comprehensive verification of the spent fuel to an
office review of the records and paperwork for consistency.
Additionally, NRC regulations do not specify how individual fuel rods
or segments are to be tracked. As a result, plants employ various
methods for storing and accounting for this material. Further, NRC
stopped inspecting plants‘ material control and accounting programs in
1988. According to NRC officials, there was no indication that
inspections of these programs were needed until the event at Millstone.
NRC is collecting information on plants‘ spent fuel programs to decide
if it needs to revise its regulations and/or oversight. In addition to
reviewing specific instances of missing fuel, NRC has had its
inspectors collect basic information on all facilities‘ programs. It
has also contracted with the Department of Energy‘s Oak Ridge National
Laboratory in Tennessee to review NRC‘s material control and accounting
programs for nuclear material, including spent fuel. It further plans
to request information from plant sites and visit over a dozen of them
for more detailed inspection. These more detailed inspections may not
be completed until late 2005, over 5 years after the instance at
Millstone that initiated NRC‘s efforts. However, we believe NRC has
already collected considerable information indicating problems or
weaknesses in plants‘ material control and accounting programs for
spent fuel.
[See PDF for image]
[End of figure]
What GAO Recommends:
GAO recommends that NRC (1) establish specific requirements for the
control and accounting of loose rods and fragments and plants‘ conduct
of their physical inventories and (2) develop and implement appropriate
inspection procedures to verify plants‘ compliance with the
requirements.
Commenting on the draft report, NRC generally agreed with GAO‘s
conclusions and recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-05-339.
To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Jim Wells at (202) 512-3841 or
wellsj@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Nuclear Power Plants Have Had Unaccounted-For Spent Nuclear Fuel:
NRC Regulations and Oversight Activities Are Insufficient to Ensure
Control of All Spent Fuel:
NRC Is Studying Spent Fuel Control and Accounting Problems but Has Yet
to Revise Its Regulations or Oversight Policies:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendixes:
Appendix I: Scope and Methodology:
Appendix II: Summary Results of GAO Survey of NRC Senior/Lead Resident
Inspectors:
Appendix III: Comments from the Nuclear Regulatory Commission:
Appendix IV: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Staff Acknowledgments:
Figures:
Figure 1: Example of Fuel Rods in a Nuclear Power Reactor:
Figure 2: Example of Dry Cask Storage:
Abbreviations:
DOE: Department of Energy:
ISFSI: independent spent fuel storage installation:
NRC: Nuclear Regulatory Commission:
OIG: Office of the Inspector General:
TI: temporary instruction:
Letter April 8, 2005:
The Honorable James M. Jeffords:
Ranking Minority Member:
Committee on Environment and Public Works:
United States Senate:
The Honorable Patrick Leahy:
United States Senate:
The Honorable Bernie Sanders:
House of Representatives:
The Honorable John Olver:
House of Representatives:
Spent nuclear fuel--the used fuel periodically removed from reactors in
nuclear power plants--is one of the most hazardous materials made by
humans. Without protective shielding, the fuel's intense radiation can
kill a person within minutes if directly exposed to it or cause cancer
in those exposed to smaller doses. The nation's 103 operating nuclear
power plants, which generate about 20 percent of U.S. electricity,
annually produce over 2,000 metric tons of spent fuel. Absent a
national repository, these materials must be stored on site. Given the
potential harm to human health and the environment, the Nuclear
Regulatory Commission (NRC) requires licensees or operators of
commercial nuclear power plants to strictly control and account for
their spent fuel. However, several recent discoveries of missing or
unaccounted-for spent fuel have raised concerns about nuclear power
plants' control over these materials and NRC's oversight. The terrorist
attacks of September 11, 2001, heightened these concerns by raising
questions about whether these highly radioactive materials could be
diverted or stolen and used maliciously.
A commercial nuclear power plant's reactor is fueled by small ceramic
pellets of uranium, roughly the size of the tip of one's little finger.
These pellets are placed end-to-end inside hollow metal tubes (made
today of zirconium alloy), which are then gas pressurized and welded
closed. The filled metal tubes are called fuel rods or pins. Rods are
grouped together into fuel assemblies (also known as fuel bundles),
typically about 5 to 10 inches square and 12 to 14 feet long, and
placed in the reactor core. Depending on the type of reactor, an
assembly consists of 36 to 289 rods and the core contains from 150 to
800 assemblies.[Footnote 1] An assembly can weigh over half a ton.
About every 12 to 18 months, the reactor must shut down for refueling.
During this time, about one- fourth to one-third of the fuel assemblies
are removed from the reactor core and replaced with new fuel
assemblies. Removed assemblies are those that have become too
inefficient to power the nuclear reaction (but which have become
intensely radioactive and will continue to generate some amount of heat
for tens of thousands of years).
When removed from the reactor, spent fuel assemblies are placed in
racks in a spent fuel pool. Spent fuel pools are typically 40-foot
deep, steel-lined, concrete vaults filled with water. Water is a
natural barrier to radiation, and it allows the fuel to cool as it
becomes less radioactive. Over the course of years, the spent fuel
within the pools has been typically moved or rearranged to accommodate
more spent fuel while maintaining safety. At some nuclear power sites,
spent fuel has also been transferred to dry storage casks to await
permanent disposition at a national repository for spent fuel, such as
the deep underground repository planned at Yucca Mountain, Nevada.
Spent fuel is typically cooled for 5 years before it can be moved to
dry storage casks, which are extremely large and heavy containers made
of steel or steel surrounded by additional concrete that can hold from
7 to 68 fuel assemblies. However, the majority of spent fuel at nuclear
power plants remains within spent fuel pools. In addition, at a number
of nuclear power plants, fuel assemblies have been disassembled or
reconstituted[Footnote 2] due to damaged or leaking fuel rods or for
inspection and testing purposes. Disassembly or reconstitution is a
delicate process involving heavy machinery. These individual fuel rods
and, if broken, rod fragments are also stored in the spent fuel pool,
either placed at the bottom or in special containers, repackaged, or in
some cases, put back into the parent spent fuel assembly.
This report discusses (1) nuclear power plants' performance in
controlling and accounting for their spent nuclear fuel, (2) the
effectiveness of NRC's regulations and oversight of nuclear power
plants' performance in controlling and accounting for spent nuclear
fuel, and (3) actions that NRC is taking in response to licensees'
spent fuel control and accounting difficulties. In the context of this
report, control and accounting for spent nuclear fuel refers to plants'
tracking of and record-keeping for the movement and storage of their
spent nuclear fuel. We did not assess plants' safety procedures for the
handling or storage of spent fuel or plant security and the
vulnerability of spent fuel to theft or terrorist attacks.
To assess nuclear power plants' performance in controlling and
accounting for their spent nuclear fuel, we reviewed and analyzed
relevant documents, including NRC and nuclear power plant licensees'
event reports, NRC studies and investigations of missing fuel rods, and
other related documents. We also interviewed NRC and nuclear power
plants officials. To assess NRC's material control and accounting
requirements for spent fuel stored at nuclear power sites, we reviewed
and analyzed relevant regulations, NRC orders and policies, and
interviewed NRC and industry officials to identify the key NRC
requirements and how they are implemented. To determine how NRC
performs oversight of nuclear power plant material control and
accounting activities, we reviewed NRC inspection policies,
instructions, and reports; analyzed relevant Inspector General reports
and internal NRC analyses and studies; interviewed appropriate NRC
program and regional officials; and conducted an e-mail survey of all
NRC lead/senior inspectors located on site at plants about inspection
practices, management controls, and suggestions for improvements, if
viewed necessary. To determine the status of NRC actions and plans in
response to licensees' spent fuel control and accounting problems, we
reviewed internal NRC memoranda, instructions, and reports and
interviewed appropriate program officials.
A more detailed description of our scope and methodology is presented
in appendix I. More detailed results of our survey of NRC resident
inspectors is presented in appendix II. We performed our work between
July 2004 and February 2005 in accordance with generally accepted
government auditing standards.
Results in Brief:
Nuclear power plants' performance in controlling and accounting for
spent nuclear fuel has been uneven. Most recently, three nuclear power
plants have reported missing or unaccounted-for spent nuclear fuel to
NRC. These plants were the Millstone Nuclear Power Station in
Connecticut in 2000, the Vermont Yankee plant in Vermont in 2004, and
the Humboldt Bay Power Plant in California in 2004. The Millstone and
Vermont Yankee plants are still operating, while the Humboldt Bay plant
has been shut down since 1976. The unaccounted-for material from
Millstone was never found, while the unaccounted-for material at
Vermont Yankee was found 3 months later in its spent fuel pool but in a
location other than that indicated by the inventory records. At
Humboldt Bay, NRC and licensee officials are still investigating the
plant's missing spent nuclear material. In all three cases, the missing
spent fuel was in loose fuel rods or segments of fuel rods that had
been removed from the fuel assemblies. NRC is also aware of several
earlier instances of lost or unaccounted-for spent fuel at other
facilities. In 1990, a nuclear power plant shipped one more spent fuel
rod than planned. The licensee discovered the discrepancy in 1991, then
notified NRC and corrected its records. On several occasions, licensees
reported "lost" or "missing" spent fuel but, according to NRC, in each
case, the spent fuel was known to be contained within the facility,
either in the reactor coolant system, the spent fuel pool, or a
refueling pathway. Moreover, information NRC has collected in response
to the unaccounted-for spent fuel at Millstone indicates that spent
fuel rods outside of fuel assemblies are an issue at additional nuclear
power sites. NRC inspectors often could not confirm that containers
that were designated as containing loose fuel rods in fact contained
the fuel rods. The containers, in some cases, were closed or sealed
and, in other cases, the contents were not visible when looking into
the spent fuel pool. Thus, spent fuel may be missing or unaccounted for
at still other plants.
Although NRC requires plants to maintain an accurate record of all
their spent fuel and its location, NRC regulations do not specify how
licensees are to conduct physical inventories nor how they are to
control and account for loose spent fuel rods and fragments. NRC
regulations require licensees to perform a physical inventory at least
once every 12 months. However, NRC guidance for material control and
accounting does not characterize what constitutes a physical inventory
or how to conduct one. Consequently, implementation is inconsistent
among the licensees. Physical inventories of spent fuel in spent fuel
pools may include anything from comparing a map with the actual
assembly racks in the pool to identify misplaced fuel assemblies to
performing a comprehensive identification of fuel assemblies according
to their serial numbers. Additionally, NRC regulations do not
specifically require licensees to track individual fuel rods or
fragments, and individual rods, fragments, or other controlled nuclear
material may or may not be accounted for in the inventory. Licensees
also employed various methods of storing and accounting for this
material. In 1988, NRC decided to no longer conduct routine inspections
of plants' compliance with material control and accounting regulations
for spent fuel because it considered the potential risk for spent fuel
to be lost or stolen from a plant to be very low. According to NRC
officials, the agency viewed spent fuel assemblies as "self protecting"
because of the extremely high level of radiation they emit and their
large size and weight.
In light of the missing spent fuel rods at Millstone and subsequent
concerns, NRC is re-assessing its decision to no longer conduct routine
inspections of plants' compliance with material control and accounting
regulations for spent fuel. For example, NRC is using a three-phase
approach under which its inspectors are collecting information on the
status of material control and accounting programs at plants. It has
also contracted with the Department of Energy's Oak Ridge National
Laboratory in Tennessee to review NRC's material control and accounting
programs for nuclear materials, including spent fuel. The third phase
under which NRC inspectors will collect more detailed information at
selected plants will not likely be completed until late in 2005, over 5
years after the spent fuel rods were discovered to be missing at
Millstone. However, these efforts, along with the more recent instances
of missing spent fuel at Vermont Yankee and Humboldt Bay as well as a
2003 NRC Office of the Inspector General report outlining weaknesses in
NRC's oversight of nuclear materials (including spent fuel), have
already provided NRC with considerable information on nuclear power
plant licensees' control and accounting programs, and NRC officials
anticipate that changes in NRC's regulations and oversight activities
will be necessary. According to NRC officials, this spring they plan to
present the results of the Oak Ridge review and other information to
the NRC Commissioners, who will decide whether the agency will take any
action.
We are making recommendations to NRC aimed at improving its regulation
and oversight of spent fuel by defining how licensees are to conduct
physical inventories, specifying control and accounting requirements
for loose rods and rod fragments, and taking timely action to monitor
licensees' compliance with material control and accounting
requirements. In commenting on a draft of this report, NRC generally
agreed with the report's conclusions and said that it will develop
guidance concerning control and accounting of spent fuel rods and
pieces and the conduct of physical inventories. NRC also said that it
will revise its existing procedures for inspecting material control and
accounting of spent nuclear fuel to include instructions on inspecting
control and accounting of rods and pieces. NRC's comment letter is
included in appendix III.
Background:
NRC is an independent agency established by the Energy Reorganization
Act of 1974 to regulate civilian uses of nuclear materials. It is
responsible for ensuring that those who use radioactive material--in
generating electricity, for experiments at universities, and for other
uses such as in construction and medicine--do so in a manner that
protects the public, the environment, and workers. NRC has issued
licenses to the 103 operating nuclear power plants and the 7 facilities
that produce fuel for these plants.[Footnote 3] In addition, NRC, or
the 33 states that have agreements with NRC, regulates about 22,000
other entities that use nuclear materials. For example, in the medical
field, nuclear material licensees annually perform millions of
diagnostic and therapeutic procedures using radioactive material.
NRC is headed by a five-member commission appointed by the President
and confirmed by the Senate. The President designates one commissioner
as Chairman and official spokesperson. NRC has over 3,000 employees who
work in its headquarters office in Rockville, Maryland, and its four
regional offices. NRC is financed primarily by fees it imposes on
commercial users of the nuclear material that it regulates. For fiscal
year 2005, NRC's appropriated budget of $669 million included
approximately $540 million financed by these fees.
NRC regulates the nation's commercial nuclear power plants by
establishing requirements for plant owners and operators to follow in
the design, construction, and operation of nuclear reactors. NRC also
licenses the reactors and the people who operate them. To ensure that
nuclear reactors are operated within their licensing requirements and
technical specifications, NRC oversees them by inspecting activities at
the plants and assessing plant performance. NRC's inspections consist
of both baseline inspections and supplemental inspections to assess
particular licensee programs or issues that arise at a particular power
plant. Inspections may also occur in response to a specific operational
problem or event that has occurred at a plant. NRC maintains from two
to three inspectors at every operating nuclear power site in the United
States and supplements the inspections conducted by these resident
inspectors with inspections conducted by staff from headquarters and/or
its regional offices. Generally, inspectors verify that the plant's
operator qualifications and operations, engineering, maintenance, fuel
handling, security, emergency preparedness, and environmental and
radiation protection programs are adequate and comply with NRC
requirements. An important part of NRC's regulatory strategy is that
licensees have programs that include monitoring, maintenance, and
inspection to ensure safe operations.
In addition to the construction and operation of commercial nuclear
power plants, NRC regulates the storage, transportation (together with
the Department of Transportation), and disposal of spent fuel. Although
nuclear power licensees ship a small amount of spent fuel off site for
storage and some fuel is stored in dry casks on site, most spent fuel
is taken from the reactor and moved directly to the nuclear power
site's spent fuel pool.
Figure 1: Example of Fuel Rods in a Nuclear Power Reactor:
[See PDF for image]
[End of figure]
Spent fuel pools are constructed according to NRC requirements,
typically with 4-to 6-foot thick steel-lined concrete walls and floors.
Pools are typically 30 to 60 feet long, 20 to 40 feet wide, and 40 feet
deep. The location of these pools is dependent on the type of reactor.
Essentially, all commercial nuclear power reactors in the United States
are one of two types, either a boiling water reactor or a pressurized
water reactor.[Footnote 4]For most boiling water reactors, the pools
are located close to the reactors, several stories above ground. For
pressurized water reactors, the pools are located in structures outside
the reactor building, on the ground or partially embedded in the
ground. Regardless of reactor type, these pools are required by NRC to
be constructed to protect the public against radiation exposure, even
after a natural disaster, such as an earthquake. The water in the pool
is constantly cooled and circulated, and the fuel assemblies are
generally 20 feet below the surface of the water.
In 1982, under the Nuclear Waste Policy Act, the Congress directed the
Department of Energy (DOE) to construct an underground repository for
the disposal of spent fuel and other high-level radioactive waste. The
Congress amended the act in 1987 and required DOE to only consider
Yucca Mountain, Nevada, as a potential site for the repository. In
2002, the President recommended to the Congress, and the Congress
approved, Yucca Mountain as a suitable site for the development of a
permanent high-level waste repository. For a variety of reasons, DOE is
unlikely to open the repository in 2010 as planned.
Lacking a long-term disposal option now, some nuclear utilities must
move a portion of their spent fuel into dry storage or face shutting
down their plants because their spent fuel pools are reaching capacity.
The majority of dry storage facilities are located on site but licensed
at a different time from the power plant. These facilities are known as
independent spent fuel storage installations, or ISFSIs. Once dry
storage is approved by NRC, spent fuel is loaded into dry storage
casks, which are steel containers surrounded by additional steel,
concrete, or other material meant to provide radiation shielding, and
are backfilled with inert gas. The full casks are welded or bolted shut
and placed either horizontally or vertically in concrete vaults or on a
concrete pad, depending on the design. Dry storage casks are very
large. According to NRC, a vertical cask may be 20 feet tall and 9 feet
in diameter and could weigh 125 tons fully loaded. Once in place, the
fuel is cooled by air. NRC requires these storage systems to be capable
of protecting against radiation exposure and surviving natural
disasters. Because the move to dry storage is time consuming and
expensive, utilities are, wherever possible, modifying wet pool storage
capacity so they can store larger quantities of spent fuel in these
pools.
Figure 2: Example of Dry Cask Storage:
[See PDF for image]
[End of figure]
To ensure that all spent fuel is accounted for and that unauthorized
acts such as theft or diversion are detected, NRC regulations require
each licensee to (1) establish, maintain, and follow written procedures
that are sufficient to enable the licensee to control and account for
the material in storage; (2) conduct a physical inventory of the spent
fuel; and (3) maintain records of receipt as well as records on the
inventory (including location), disposal, and transfer of the material.
The physical inventory is required to be performed at intervals not to
exceed 12 months. Compliance with these requirements is a condition of
each plant's operating license.
There is a high public perception and fear that spent nuclear fuel, if
lost or stolen, could be used maliciously. According to NRC, the
control of spent fuel is of great importance because of the potential
health and safety implications. However, NRC stated that the very high
radiation level of spent fuel makes its theft difficult, dangerous, and
very unlikely. NRC also explained that individual spent fuel rods
contain only a very small amount of nuclear material, making it
unlikely that stolen rods could be used to manufacture a weapon. Theft
of many rods would be necessary to acquire enough material to
manufacture a weapon. To expose a large number of people to the harmful
effects of radiation, the spent fuel would have to be released from its
protective containers and dispersed over a wide or densely populated
area. Unlike many other hazardous materials, spent fuel is neither
explosive nor volatile.[Footnote 5] Putting the material in a
dispersible form would be a difficult and dangerous task involving
extensive preparation using special equipment and radiation shielding.
In the event of a dispersal, the most significant health effects would
involve persons who inhaled very small particles. Such particles would
be absorbed into the body and possibly remain there for many years.
According to NRC officials, protective systems at nuclear power
reactors are designed using the concept of "defense in depth." The
officials pointed out that it is very unlikely that pieces of spent
fuel could be out in the public domain because power reactors have
layers of protection and controls to detect and prevent spent fuel from
leaving the spent fuel pool. Material control and accounting is one of
these layers. Physical security, another layer, relies on measures such
as portal radiation monitors, fences, guards, locks, and limited
access. Additional layers relate to safety. For example, reactors store
spent fuel under at least 20 feet of water because of the heat and
radiation. If an item of spent fuel is raised out of the spent fuel
pool, extremely sensitive detectors in the pool area alarm. The
officials said that NRC requires licensees to respond to these alarms
and keep records of them. All parties agree that it is very important
to fully account for this material.
Nuclear Power Plants Have Had Unaccounted-For Spent Nuclear Fuel:
Three nuclear power plants have recently reported the discovery of
missing or unaccounted-for spent nuclear fuel to NRC. These plants were
the Millstone Nuclear Power Station in Connecticut in 2000, the Vermont
Yankee plant in Vermont in 2004, and the Humboldt Bay Power Plant in
California in 2004.[Footnote 6] NRC's actions in response to the
missing or unaccounted-for spent fuel at Millstone led directly to
identifying the problems at Vermont Yankee and help identify the
problems at Humboldt Bay. In all three cases, the missing or
unaccounted-for spent fuel was in loose fuel rods or segments of fuel
rods that had been removed from the fuel assemblies. Other plants have
also identified possible instances of lost or unaccounted-for spent
fuel.
Millstone:
At Millstone, two nuclear fuel rods were discovered to be missing when,
in November 2000, the licensee, Northeast Utilities, was involved in a
records reconciliation and verification effort to support preparations
to move spent fuel into dry cask storage. The location of the two full-
length fuel rods was not properly reflected in special nuclear material
records. The licensee reported that in 1972, a fuel assembly was
disassembled after it was removed from the reactor during a shutdown.
In 1974 when the fuel assembly was reassembled, two rods that were
damaged were not placed back into the assembly. Instead, they were
placed in a container for individual rods and stored in the spent fuel
pool. Records dated 1979 and 1980 show the individual fuel rods in the
container in the spent fuel pool. However, spent fuel pool map records
after 1980 do not show either the fuel rods or the container. Records
do not indicate what happened to these rods. The licensee's
investigations of the loss centered on the significant spent fuel pool
activities that occurred between 1980 and 1992, which potentially
related to the missing fuel rods. These activities included two re-
racks, which modified the racks to accommodate more fuel assemblies,
and several shipments to facilities licensed to receive irradiated
nonfuel components. The unaccounted-for material from Millstone was
never found; the licensee concluded that the rods were shipped to a low-
level waste disposal facility in Barnwell, South Carolina. NRC
undertook a special inspection to review the licensee's efforts to
locate the missing fuel rods and in February 2002 agreed with the
licensee that the two missing rods were most likely shipped to the
Barnwell facility. In June 2002, NRC took enforcement action against
the licensee and fined the licensee $288,000 for failure to adequately
account for the special nuclear material contained in the two fuel rods
and for failure to report missing material to NRC in a timely manner.
Vermont Yankee:
Spent fuel at Vermont Yankee was discovered missing in April 2004, as
the NRC resident inspectors at the plant conducted an inspection
required by NRC headquarters in response to the lost spent fuel rods at
Millstone. The resident inspectors found that although the licensee had
been performing an annual physical inventory of the spent fuel pool,
the inventory did not verify that two fuel rod segments contained in a
special container stored on the bottom of the pool were still present
in the container. In responding to the NRC senior resident inspector's
questions, the licensee determined that two spent fuel rod pieces, the
product of a 1979 fuel reconstitution to replace corroded fuel rods
that had failed, were not in the storage location identified in the
inventory records. The two fuel rod pieces were approximately one-half
inch in diameter by approximately 9 inches and 17.75 inches in length.
The Vermont Yankee licensee formed an investigation team to search for
the fuel rod pieces. According to the licensee, the investigation
included inspecting the spent fuel pool, reviewing documents,
interviewing past and present Vermont Yankee employees, and
interviewing contractors that had been associated with spent fuel pool
activities and radioactive waste operations at Vermont Yankee. In July
2004, after identifying an aluminum cylinder in the spent fuel pool as
potentially containing the two fuel rod pieces, the licensee opened and
inspected the cylinder, which in fact contained the two fuel rod
pieces. The licensee concluded that the root causes of this event were
that (1) the special nuclear material account devices used in
inventorying the material had not been properly maintained and (2) the
plant's special nuclear material inventory and accountability
procedures did not provide guidance for controlling pieces of special
nuclear material as they do for whole fuel assemblies. According to a
licensee representative, it cost the licensee several million dollars
to locate the spent fuel rod pieces and review the plant's material
control and accounting procedures and activities to determine the root
causes of this incident. The licensee representative also told us that
the plant has already taken or is in the process of taking various
corrective actions. For example, the plant has revised its material
control and accounting procedures to reflect the findings of the root
cause analysis.
NRC conducted a special inspection to review the results of the
licensee's investigation at Vermont Yankee, assess the licensee's
determination of the root cause, determine whether the licensee and its
predecessor were in compliance with applicable regulations, and
identify which findings or observations may have implications for other
nuclear power plants. The inspection was performed from April through
August 2004, and a report was issued to the licensee in December
2004.[Footnote 7] NRC inspectors concluded that the licensee and its
predecessor did not keep adequate special nuclear material inventory
records of the two spent fuel rod pieces, did not follow the licensee's
written procedures when the two spent fuel rod pieces were moved to a
fuel storage container, and did not conduct adequate periodic physical
inventories of the two spent fuel rod pieces. NRC inspectors also
concluded that because the two spent fuel rod pieces remained in the
Vermont Yankee spent fuel pool the entire time the apparent violation
existed, no actual safety consequence resulted from this apparent
violation. Nevertheless, NRC considered the apparent violation a
potentially significant failure of the licensee's material control and
accounting program. Enforcement action against the licensee for its
apparent violation of material control and accounting regulations is
currently under review by NRC management. A decision is expected
sometime in 2005.
Humboldt Bay:
In July 2004, Humboldt Bay officials reported to NRC that in the
process of reviewing records and verifying the contents of the spent
fuel pool in preparation for dry storage operations, the licensee
identified a discrepancy in plant records that questioned the location
of three 18-inch fuel rod segments removed from a single spent fuel
rod. A plant record from 1968 indicated that the three fuel rod
segments were stored in the spent fuel pool in a small container.
However, licensee spent fuel shipment records indicated that the entire
fuel assembly, including the rod segments, had been sent off site for
reprocessing in 1969. The licensee notified NRC of the record
discrepancy in the records and the apparent loss of accountability
records for the special nuclear material. The licensee implemented a
program to search the spent fuel pool for the fuel rod segments, review
additional plant records, and interview plant personnel who were on
site during the 1968 to 1969 time period.
In November 2004, NRC officials initiated a special inspection that
included a review of the licensee material control and accounting
procedures. According to an NRC official, current material control and
accounting procedures appear to be adequate, but there were some
problems with past accounting practices. The licensee has completed its
physical search of the spent fuel pool and other areas of the plant for
the three rod segments and has not conclusively identified the missing
three 18-inch segments. The licensee is continuing its review of plant
records as well as interviewing plant personnel who may have knowledge
of the whereabouts of the three fuel rod segments. The licensee issued
an interim report of its search results and evaluations at the end of
February 2005. NRC plans to issue an interim inspection report after
reviewing the licensee interim report. A final inspection report will
not be issued until the licensee completes its investigation, currently
expected in May 2005.
Other Facilities:
Another example of an inaccurately accounted-for fuel rod occurred at a
plant that is being decommissioned. The material from its spent fuel
pool is being moved to dry cask storage. In 1974, a failed fuel
assembly was being disassembled because it was leaking. A fuel rod from
this assembly was found to be completely broken in two. The broken rod
was supposed to have been put in a fuel rod storage basket in the spent
fuel pool. In 1997, an attempt was made to verify the presence of the
16-inch fuel rod segment before the basket was placed into a dry
storage cask. The attempt failed, and because the basket was too tall,
it was not placed into the dry storage cask at that time. In October
2001, because of the case of the lost fuel rods at Millstone, the
licensee decided to again inspect the basket to verify the presence of
the fuel rod segment. While the licensee successfully examined the
basket, it did not find the fuel rod segment. The licensee undertook a
complete review of the site's spent fuel records and concluded that the
accounting failure resulted from (1) the poor visual clarity in the
spent fuel pool at the time the fuel rod fragment was being placed in
the basket and (2) inadequate care by the operators performing the
task. The licensee also concluded that the fuel rod segment did not
contain any fuel pellets because when the fuel rod broke, the pellets
were ejected into the reactor cooling system and ultimately ground into
powder. In January 2002, when NRC regional inspectors performed a
special inspection at the plant concerning this issue, the inspectors
did not take issue with the licensee's conclusions concerning the
missing fuel rod. However, they did find that--since the same
procedures were being used at the other operating plants on site--the
licensee should examine the fuel assembly and fuel rod storage baskets
at these locations to determine that the fuel rods that are supposed to
be in them are actually present. In February 2004, NRC inspectors
reported that the licensee had inspected the baskets and determined
that the existing inventory sheets were correct. NRC closed this
matter.
NRC is also aware of additional instances of lost or unaccounted-for
spent fuel. In 1990, a nuclear power plant shipped one more spent fuel
rod than planned. The licensee discovered the discrepancy in 1991, then
notified NRC and corrected its records. On several occasions, licensees
reported "lost" or "missing" spent fuel, but, according to NRC, in each
case, the spent fuel was actually known to be contained within the
facility, either in the reactor coolant system, the spent fuel pool, or
a refueling pathway.
The potential exists for missing or unaccounted-for spent fuel rods to
be discovered at additional plants. NRC's inspections at plants in
response to the Millstone incident revealed that many nuclear power
sites (a site may consist of more than one plant) had removed spent
fuel rods from fuel assemblies or had reconstituted fuel
assemblies.[Footnote 8] In performing these inspections, NRC inspectors
were to obtain from the licensee a list of all irradiated or spent fuel
rods that have been removed from their parent assembly. Using the
current fuel pool map, the inspectors were to identify the presumed
location of the separated rods. Then, by observing from the edge of the
pool, the inspector was to answer whether there were rods in all of the
locations on the map identified as containing separate rods. At some of
these sites, this was not possible. Some containers where rods were
presumably stored were closed or their contents were not visible. Even
when containers were not closed, some contents were unverifiable
because of poor water clarity and lighting and container design.
According to NRC officials, the agency has preliminarily chosen these
sites for further inspection.
NRC Regulations and Oversight Activities Are Insufficient to Ensure
Control of All Spent Fuel:
Although NRC requires nuclear power plants to maintain an accurate
record of their spent fuel and its location, agency regulations do not
specify how licensees are to conduct physical inventories of this
material nor how they are to control and account for loose or separated
spent fuel rods and fragments. In addition, NRC oversight does not
include routine monitoring of plants' compliance with its material
control and accounting regulations.
NRC Regulations to Control and Account for Special Nuclear Materials
Have Several Shortcomings:
Under NRC regulations, reactor licensees are required to maintain and
follow written procedures sufficiently to enable them to control and
account for their special nuclear material. They are to keep records
showing the receipt, inventory (including location), disposal, and
transfer of all special nuclear material. Each record of receipt,
acquisition, or physical inventory of special nuclear material must be
retained as long as the licensee has possession of the material and for
3 years following any transfer of such material. Physical inventories
of special nuclear material must be performed at least annually.
However, NRC guidance for material control and accounting of spent
nuclear fuel does not characterize what constitutes a physical
inventory nor how to conduct one.
NRC regulations define physical inventory as the means to determine on
a measured basis the quantity of special nuclear material on hand at a
given time. The regulations also state that the methods of physical
inventory and associated measurements will vary depending on the
material being inventoried and the processes involved. As a result,
licensees implement the physical inventory requirement in different
ways. NRC resident inspectors found that inventories may include
anything from comparing a map with the assembly racks in the spent fuel
pool to performing a comprehensive identification of fuel assemblies
according to their serial numbers. For example, at one site, the NRC
resident inspector reported that the annual inventory is performed in a
"piece counting" manner and does not specifically verify the bundle
serial number and fuel pool location. At another site, the NRC resident
inspector reported that the annual inventory is only conducted for
special nuclear material that has been moved since the last audit.
Further, according to an NRC program official, no definition of
physical inventory is provided in NRC's regulatory guidance for spent
fuel because the concept of physical inventory is a simple "first
course in accounting" term. That is, a physical identification of items
for the purpose of determining the number of items physically on hand
and for comparison with a "book" record, which is the listing of items
according to the accounting records. This NRC official also stated that
it's what large retailers do at least once a year, it's a well-
understood concept, and it has never been thought to require
clarification until now. An NRC resident inspector at still another
site told us that the annual physical inventory was an office paperwork
review to ensure that all the "i's were dotted and t's were crossed"
from past material movements and transfers. The resident inspector
added that the licensee had never actually opened its storage container
to visually verify the accuracy of the paperwork. In responding to our
survey, several resident inspectors suggested that if licensees sealed
their containers--for example, with tamper-safe sealing--the containers
would not have to be opened during the physical inventory. According to
NRC officials, verification of items in spent fuel pools is difficult
and time consuming, raises concerns about radiation exposure, and can
be costly.
Additionally, although NRC regulations state that licensees are to
control and account for all special nuclear material, the regulations
do not specifically require licensees to track individual fuel rods or
fragments that may be stored in their spent fuel pools. Further,
individual rods, fragments, or other controlled special nuclear
material may or may not be specifically accounted for in licensees'
inventories.[Footnote 9] As a result, licensees employed various
methods of storing and accounting for this material. For example,
according to an NRC resident inspector, at one plant the spent fuel
rods are in a closed container in a designated area of the spent fuel
pool. According to the licensee's procedures, the canister is opened
every 6 years and the presence of the correct number of rods is
verified. At another plant, the licensee told the resident inspector
that it was not sure how many fuel rod fragments are in two storage
baskets or how the fragments might be divided up between the baskets.
In responding to our survey, several NRC resident inspectors described
current practices and offered suggestions for best practices for
storing and controlling loose rods and segments. Several respondents
described placing loose spent fuel in "dummy" or "skeleton" fuel
assemblies, which are empty of fuel, or only in specially designed and
approved containers placed in designated cells and racks in the spent
fuel pool. In addition, one resident inspector suggested that given
that fuel rod breaks are often the result of reconstitution, a best
practice would be for the reconstitution of fuel assemblies to be done
off site.
Licensees of nuclear power plants also control and account for their
inventories of spent fuel to help meet requirements relating to U.S.
treaty obligations for the control of nuclear material. NRC regulations
require power reactor licensees to submit a Nuclear Material
Transaction Report to the Nuclear Materials Management and Safeguards
System every time their facilities receive or transfer special nuclear
material or make corrections to their material balances. At least once
a year, licensees must also submit to the system material balance
reports concerning special nuclear material received, produced,
possessed, transferred, consumed, disposed of, or lost, and inventory
composition reports. This system, which is managed by the DOE and
partially supported by NRC, is operated by a DOE contractor. Because
reporting to the system is done in the amount or weight of the nuclear
material, such as plutonium, rather than the number of items of spent
fuel, nuclear power plant licensees use complex computer programs to
provide estimates of the amount of special nuclear material that these
items contain. According to plant officials we spoke with, their sites
send their annual inventory information to their corporate headquarters
to be calculated and reported to the Nuclear Materials Management and
Safeguards System contractor.
NRC Does Not Monitor Plants' Compliance with Its Material Control and
Accounting Regulations:
Since 1988, NRC inspections of power reactor licensees' compliance with
material control and accounting requirements have been done on an
exception-only basis--that is, if a particular problem or incident was
reported by the licensee or identified by NRC that warranted
investigating. Since 1988, NRC has not routinely monitored licensee
compliance with material control and accounting regulations or verified
that licensees' inventories are complete and accurate.
In 1984, NRC's overall inspection program for monitoring nuclear power
plants' compliance with their licenses had three parts: (1) a minimum
program to be completed at all operating nuclear facilities without
exception, (2) a basic program to be completed at all operating
facilities, but under some circumstances parts did not have to be
completed because of extraordinary demands on limited inspection
resources, and (3) a supplemental program of additional inspections to
be done on the basis of an assessed need or problems at a facility.
According to NRC, the basic program included material control and
accounting inspections to be conducted once every 3 years. In 1988,
according to NRC officials, this requirement for the periodic
inspections of material control and accounting was
discontinued.[Footnote 10] Officials said that although there is no
written documentation available, these inspections were discontinued
because spent fuel stored in spent fuel pools was considered to be
"self protecting;" that is, the fuel bundles are heavy, highly
radioactive, and contained in 40-foot deep pools of water. Spent fuel
was viewed as a low-risk danger to public health and the environment
and a low priority for use of NRC's resources.
NRC substantially revised its nuclear reactor oversight process in
2000, but did not reinstitute routine material control and accounting
inspections. According to NRC, the new process--called the Reactor
Oversight Process--uses more objective, timely, and safety-significant
criteria in assessing nuclear plant performance. NRC stated that the
revised program includes baseline inspections common to all nuclear
plants and focuses on activities and systems that are risk significant-
-that is, those activities and systems that have a potential to trigger
an accident, increase the consequences of an accident, or mitigate the
effects of an accident. The Reactor Oversight Process also allows for
inspections beyond the baseline program if there are operational
problems or events that NRC believes require greater scrutiny. Material
control and accounting fall under this criteria. When the new process
was being developed, NRC officials continued to believe that the
material in spent fuel pools was self protecting and that it was
appropriate to perform material control and accounting inspections on
an exception-only basis. NRC officials told us that there were no
indications prior to the discovery of missing fuel rods at Millstone
that routine inspections were needed.
According to NRC officials, a few Reactor Oversight Process inspections
can indirectly involve NRC inspections of licensees' material control
and accounting programs. One of these inspections is of licensee
operations during refueling of the reactor. This inspection includes
verifying that the location of fuel assemblies is being tracked and
that discharged fuel assemblies are placed in permissible locations in
the spent fuel pool. To perform such an inspection, NRC inspectors
observe the movement of a sample of fuel bundles between the reactor
core and the spent fuel pool. NRC officials told us that material
control and accounting problems with spent fuel may also be reviewed
under plant status inspections. These inspections involve a number of
activities surrounding NRC resident inspectors' efforts to be aware of
emergent plant issues, potential adverse trends, equipment problems,
and other ongoing activities that may impact the plant's safety risks.
These efforts include control room walkdowns, attending licensee
meetings, and weekly plant tours. Inspectors generally would not learn
of material control and accounting problems during one of these
inspectors unless the licensee was aware of them and raised them during
meetings with the inspectors. In addition, a few NRC resident
inspectors that we surveyed mentioned some review of spent fuel records
during the loading of dry storage fuel casks.
NRC Is Studying Spent Fuel Control and Accounting Problems but Has Yet
to Revise Its Regulations or Oversight Policies:
In light of the missing or unaccounted-for spent fuel at Millstone and
subsequently at other locations, NRC has various activities under way
to assess the need to revise its regulations and oversight of spent
fuel. While final completion dates for these efforts have not been set,
it will likely be late in 2005 before all of them will be completed.
This date would be over 5 years after the spent fuel rods were first
found missing at Millstone in 2000. We believe that after the more
recent instances of missing spent fuel at Vermont Yankee and Humboldt
Bay, the 2003 NRC Office of the Inspector General report outlining
weaknesses in NRC's oversight of special nuclear materials (including
spent fuel), and information collected during its ongoing efforts, NRC
has considerable information that suggests the need to address nuclear
power plants' material control and accounting problems, including
compliance with NRC regulations. According to NRC officials, they plan
to submit the results of these activities to the NRC Commissioners in
the spring of 2005. The Commissioners will decide what, if any, actions
will be taken in response to the findings.
NRC Is Using a Multifaceted, Phased Approach to Assess the Need to
Revise Its Regulations and Oversight:
NRC has three principal activities under way to assess the need to
revise its regulations and oversight of spent fuel. These are (1) a
three-phase project under which NRC inspectors are collecting
information on the status of material control and accounting programs
at individual plants; (2) a comprehensive program review of NRC
material control and accounting programs for special nuclear materials,
including spent fuel, through the contract with DOE's Oak Ridge
National Laboratory; and (3) a bulletin issued on February 11, 2005, to
nuclear power plant licensees requesting information concerning their
compliance with NRC material control and accounting regulations.
In November 2003, NRC issued a temporary instruction (TI) to its
inspection manual.[Footnote 11] NRC's overall objective in issuing the
TI was to gather site-specific information on nuclear power plants'
material control and accounting programs to determine if the issues
affecting the missing spent fuel rods at Millstone were present at
other power plants. More specifically, NRC wanted to obtain enough
information to determine if:
* material control and accounting guidance for nuclear power plants
should be modified to reduce the possibility of a licensee losing spent
fuel rods in the future;
* licensees can account for all spent fuel, including any rods that
have been separated from their parent assembly; and:
* all items of spent fuel listed in the spent fuel inventory, including
rods that have been separated from their parent assembly, can be
located in the spent fuel pool.
The TI also called for obtaining site-specific data for the purposes of
improving the plants' material control and accounting programs.
According to the TI, several inspection activities were aimed at
identifying conditions for future program improvement rather than
inspections for compliance with regulatory requirements.
NRC is carrying out the TI in three phases. Phases I and II have been
completed. In phase I, NRC regional and/or resident inspectors
determined if nuclear power plant licensees had ever removed irradiated
(spent) fuel rods from an assembly or had reconstituted fuel
assemblies. For licensees that had removed rods or reconstituted
assemblies, phase II was conducted. During phase II, inspectors used
inspections and interviews to fill out a questionnaire about the
licensees' material control and accounting programs. Among the
questions were the following:
* Does the licensee have a program that tracks individual fuel rods
from the point of removal from a fuel assembly to where they are stored
in the spent fuel pool and to their final destination?
* Are there rods in all of the locations identified on the spent fuel
map (or equivalent) as containing separated rods? (The inspectors were
instructed to obtain from licensees a list of all spent fuel rods that
had been removed from their parent assembly and, to the extent
possible, answer this question by observing from the edge of the spent
fuel pool. If the rods were stored in a closed container, they were to
report this under the "Comments" section of the questionnaire.)
* Does the licensee have written material control and accounting
procedures approved by licensee management?
* Does the licensee have written procedures for the movement of
individual spent fuel rods within the spent fuel pool?
* Does the licensee have procedures for performing oversight of all
spent fuel pool operations?
* Does the licensee have records documenting spent fuel pool operations
conducted by contractors or fuel vendors?
* Does the licensee perform an annual physical inventory of the spent
fuel pool that includes resolution of all discrepancies?
The TI did not specify an approach to answering the questions but
instead allowed the resident inspectors to use their best judgment and
experience. Our survey of NRC's senior resident inspectors identified
some differences in what the inspectors did to answer the phase II
questions. The inspectors generally interviewed licensee staff and
reviewed licensees' records and written procedures. For the most part,
they also used the licensee's map to verify materials in the spent fuel
pool. About half used visual tools such as binoculars or underwater
cameras to verify materials in the spent fuel pool. About one-fifth
observed licensee activities.
Phase III, which has not begun, is to expand on the questions in phase
II with more detailed inspection and review of site documentation to
verify that procedures or controls are implemented and that they are
adequate. For a sample of sites, including those for which "no" was
answered to any of the phase II questions, personnel with material
control and accounting expertise, rather than the regional and on-site
inspectors, are to carry out the activities.
The TI called for phases I and II to be completed within 6 months (by
May 2004) and phase III within 18 months (by May 2005). Phases I and II
were carried out from January 2004 to May 2004. The phase I review at
70 sites--all 103 operating nuclear power plants at 65 sites (a site
may contain more than one nuclear power plant), decommissioning plants
at 4 sites, and 1 wet storage facility--identified 65 sites that had
removed irradiated fuel rods from an assembly or had reconstituted fuel
assemblies.[Footnote 12] Phase II was conducted for these sites. On the
basis of the phase II results, NRC officials determined that at least
19 sites were candidates for more detailed phase III review because NRC
inspectors identified that the site had two or more programmatic
issues. As of February 2005, NRC officials told us that they are in the
planning stages for phase III inspections. Because the TI expires 2
years after its November 2003 issuance, if the phase III inspection
were to be performed before this, it would be late 2005 before the
project would be completed.
In September 2001, shortly after the terrorist attacks on the World
Trade Center and the Pentagon, the Chairman of NRC directed the staff
to undertake a comprehensive review of all the agency's safeguards and
security programs. NRC contracted with the Oak Ridge National
Laboratory in August 2003 to review NRC's material control and
accounting programs for special nuclear materials at all NRC licensees.
This contract, which according to an NRC official was for about
$500,000, was part of a broader NRC effort. The Oak Ridge laboratory,
which was chosen because of its expertise in material control and
accounting, began the work under the contract in September 2003. Its
four principal tasks were to (1) review NRC's current material control
and accounting requirements, (2) discuss material control and
accounting with current and former employees involved in these
activities, (3) visit selected facilities representing different types
of special nuclear material licensees to explore current material
control and accounting requirements and inspection practices at each
site, and (4) develop a report that offers Oak Ridge's views on NRC's
material control and accounting requirements across the range of NRC-
licensed facilities, discusses any concerns or deficiencies with the
current regulations and inspection practices, and provides specific
recommendations for programmatic changes. Oak Ridge submitted its
report in August 2004 and concluded its work with a management briefing
in October 2004. NRC is currently reviewing the report. According to
NRC officials, the staff will complete its review of the report and
consider the results of its review, as well as additional
recommendations from the staff, in developing a paper to the NRC
Commissioners. The paper is due to the Commissioners by spring 2005.
In February 2005, NRC issued a bulletin to holders of operating
licenses for nuclear power plants, decommissioning nuclear power plants
storing spent fuel in a pool, and wet spent fuel storage sites. The
bulletin, which requests information about procedural controls and
inventories, responds to issues involving accounting and control of
spent (and other irradiated) nuclear fuel, which were first identified
at Millstone and then at Vermont Yankee and Humboldt Bay. The purpose
of the bulletin is to gather specific information from the licensees
about the status of control and accounting of special nuclear material
at power reactors and other facilities with wet storage of irradiated
fuel. NRC officials told us that results from the bulletin will
contribute to assessing the need to revise the current NRC material
control and accounting regulations and inspection program. The results
from the bulletin will also determine where phase III inspections will
be conducted.
NRC Has Considerable Information Indicating Problems with the Control
and Accounting for Spent Fuel:
The data collected by NRC inspectors during phases I and II of the TI
identified material control and accounting problems or shortcomings. Of
the sites that had removed fuel rods from their parent assemblies or
had reconstituted fuel assemblies, the inspectors reported that some
sites did not appear to be in compliance with all of NRC's material
control and accounting requirements or otherwise had questionable
material control and accounting practices involving procedures,
physical inventory, accounting records, or tracking and control.
Additionally, in May 2003, NRC's Office of the Inspector General (OIG)
issued its report, Audit of NRC's Regulatory Oversight of Special
Nuclear Materials.[Footnote 13] In its report, the OIG concluded that
NRC's oversight did not provide adequate assurance that all licensees
properly control and account for special nuclear material. The OIG
found that NRC performed limited inspections of licensees' material
control and accounting activities and could not assure the reliability
of the tracking system for special nuclear material. It stated that NRC
managers believed that most spent fuel is self-protecting from a health
and safety point of view and that the risk of undetected loss, theft,
or diversion of special nuclear material at power reactors is low.
Therefore, according to the OIG, NRC trusts power reactor licensees to
implement their material control and accounting activities effectively.
The OIG further concluded that without adequate routine inspections of
these activities, NRC cannot reasonably ensure that licensees are
controlling and fully accounting for special nuclear material. The OIG
recommended, among other things, that NRC conduct periodic inspections
to verify that licensees comply with material control and accounting
requirements, including, but not limited to, visual inspection of
licensees' special nuclear material inventories and validation of
report information.
In its October 2003 response to the OIG recommendation, NRC said that
its staff planned to perform a review of the agency's material control
and accounting program (which it did by commissioning the Oak Ridge
study) as part of a comprehensive review of the agency's safeguards and
security program. NRC added that based on the results of the program
review, the staff will determine what changes need to be made to the
inspection program. According to NRC's response, any decision to change
the inspection program would be made during fiscal year 2005, following
completion of the program review. In February 2004, the OIG responded
by stating that delaying any decision to make changes to the material
control and accounting inspection program until fiscal year 2005 was
untimely and did not reflect the importance of ensuring licensee's
compliance with material control and accounting requirements. In March
2004, NRC replied that the staff considered the program review to be
vital to developing and documenting the regulatory basis for subsequent
permanent revisions to the inspection program. An NRC official told us
that once the Oak Ridge study has been completed and its findings and
recommendations have been addressed, the OIG's recommendation can be
closed. The staff currently anticipates that it will develop specific
recommendations and submit them to the NRC Commissioners during the
spring of 2005.
Conclusions:
The effectiveness of nuclear power plants' efforts to control and
account for their spent fuel is uneven. A number of plants have
experienced instances of missing or unaccounted-for spent fuel, and NRC
has identified weaknesses in the material control and accounting
programs at various other plants. Contributing to this unevenness is
the fact that NRC regulations do not specifically require plants to
control and account for loose rods or segments of rods. Although loose
spent fuel rods do not appear to have been a concern when NRC developed
its regulations, recent information collected by NRC indicates that
most plants have removed rods from their fuel assemblies or
reconstituted fuel assemblies. NRC data further indicate that plants
are treating loose rods and segments differently under their material
control and accounting programs. The absence of specific guidance in
NRC regulations for how licensees should conduct physical inventories
has also resulted in unevenness in licensees' compliance with these
important requirements.
Loose spent fuel rods and rod segments also were not an issue when NRC
stopped inspecting licensees' compliance with material control and
accounting regulations. Spent fuel was generally viewed in terms of
fuel assemblies, which NRC considered to be, in effect, self-protecting
because of their high radioactivity and large size and weight. However,
individual rods, and especially rod segments, are also highly
radioactive and are much smaller and lighter than fuel assemblies. This
issue was first raised in 2000, with the loss of spent fuel rods at
Millstone. The occurrences of missing or unaccounted-for spent fuel
rods and the unevenness in licensees' compliance with material control
and accounting requirements highlight the need for more effective
oversight of these programs. In the aftermath of terrorist attacks on
the United States, material control and accounting of spent nuclear
fuel has become more important. Material control and accounting
requirements are of great importance because of the potential health
and safety consequences of failing to effectively account for and
control spent nuclear fuel. While NRC's multifaceted and phased
approach to these issues may have been appropriate in the initial
context of a single incident at Millstone, waiting longer to make a
decision on changes in the agency's regulations and oversight is--as
the OIG stated in February 2004--not timely and does not fully reflect
the importance of ensuring that licensees comply with control and
accounting requirements for spent fuel. We believe that NRC has
sufficient information about problems with material control and
accounting at nuclear power plants to proceed with revising NRC's
regulations and oversight.
Recommendations for Executive Action:
To improve the effectiveness of nuclear reactor licensees' material
control and accounting programs for spent nuclear fuel, we recommend
that the NRC Commissioners take action, in a timely manner, on the
following two items:
* Establish specific requirements for the control and accounting of
loose spent fuel rods and rod segments and nuclear reactor licensees'
conduct of their physical inventories.
* Develop and implement appropriate inspection procedures to verify
compliance and assess the effectiveness of licensees' material control
and accounting programs for spent fuel.
Agency Comments:
We provided a draft of this report to NRC for review and comment. In
its written comments (see app. III), NRC generally agreed with the
report's conclusions and stated that, overall, the report is well
written and balanced. Regarding our recommendation that NRC establish
specific requirements for the control and accounting of loose spent
fuel rods and rod segments and nuclear reactor licensees' conduct of
their physical inventories, NRC stated that it will develop guidance
concerning control and accounting of rods and pieces of spent nuclear
fuel and the conduct of physical inventories. According to NRC, its
current regulations are clear that licensees are required to keep
complete records of and conduct annual physical inventories of all
special nuclear material, but the implementation guidance does need to
be enhanced. Regarding our recommendation that NRC develop and
implement appropriate inspection procedures to verify compliance and
assess the effectiveness of licensees' material control and accounting
programs for spent fuel, NRC said that it plans to revise its existing
procedures for inspecting material control and accounting for spent
nuclear fuel to include instruction on inspecting control and
accounting of rods and pieces.
In addition to comments directly relating to our recommendations, NRC
offered a number of comments concerning the report's context. For
example, NRC said that its development and issuance of its temporary
instruction was postponed by the need to devote NRC's limited resources
to areas requiring more immediate attention, especially the
comprehensive security and radiological protection activities conducted
after the September 11, 2001, terrorist attacks. NRC also said that the
report needs to provide balance by giving credit to NRC for making
prioritized decisions based on a variety of factors, including, but not
limited to, risk of malevolent action, attractiveness of the material
for potential malevolent activities, other controls, and available
personnel resources. According to NRC, there is no reason to conclude
that any of the missing fuel segments were removed for any malevolent
purpose. NRC further stated that the report does not make sufficiently
clear that the problems at Vermont Yankee were identified as a direct
result of NRC's implementation of its temporary instruction and that
implementation of the temporary instruction also helped identify the
problems at Humboldt Bay. We believe that our report provides
sufficient context for the issues relating to the instances of
unaccounted-for spent nuclear fuel. It also devotes considerable
attention to describing NRC's actions in response to those instances,
including efforts already under way when we began our review. We have
added language to the report to emphasize that NRC's actions in
response to the Millstone incident led directly to identifying the
problems at Vermont Yankee and helped identify the problems at Humboldt
Bay. While we also agree that there is no evidence that any of the
missing fuel segments were removed for malevolent purposes, we note
that it is still not certain what happened to the missing spent fuel at
Millstone and Humboldt Bay.
As agreed with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
from the date of its issuance. At that time, we will send copies of
this report to interested congressional committees, the Chairman of
NRC, and other interested parties. We will make copies available to
others upon request. In addition, the report will be available at no
charge on the GAO Web site at [Hyperlink, http://www.gao.gov].
If you or your staffs have any questions about this report, please call
me at (202) 512-3841 or contact me at [Hyperlink, Wellsj@gao.gov]. Key
contributors to this report are listed in appendix IV.
Signed by:
Jim Wells:
Director, Natural Resources and Environment:
[End of section]
Appendixes:
Appendix I: Scope and Methodology:
To assess nuclear power plants' performance in controlling and
accounting for their spent nuclear fuel, we reviewed and analyzed
relevant documents, including Nuclear Regulatory Commission (NRC) and
nuclear power plant licensees' event inquiry reports and NRC studies
and investigations of missing spent fuel rods. We also interviewed NRC
and nuclear power plant officials and conducted two site visits to
nuclear power plants. In the context of this report, control and
accounting for spent nuclear fuel refers to plants' tracking of and
recordkeeping for the movement and storage of their spent nuclear fuel.
We did not assess plant safety procedures for handling or storage of
spent fuel or plant security and the vulnerability of spent fuel to
theft or terrorist attacks.
To assess NRC's material control and accounting requirements for spent
fuel stored at nuclear power sites, we reviewed and analyzed relevant
legislation, regulations, and NRC orders and policies and we
interviewed NRC and industry officials to identify the key NRC
requirements and how they are implemented.
To determine how NRC performs oversight of nuclear power plants'
material control and accounting activities, we reviewed NRC inspection
policies, instructions, and reports; analyzed relevant NRC Inspector
General reports and internal NRC analyses and studies; and interviewed
appropriate NRC program and regional officials. To determine the status
of NRC's actions and plans in response to licensees' spent fuel control
and accounting problems, we reviewed internal NRC memorandums,
instructions, and reports and interviewed appropriate program
officials.
To further explore how NRC performs oversight of control and accounting
activities for spent fuel at nuclear power plants, we conducted an e-
mail survey of all NRC lead/senior inspectors located on site at the
plants about NRC inspection practices, management controls, and the
inspectors' suggestions for improvements, if viewed necessary. There
are no sampling errors because this was not a sample survey; rather, we
sent and received a response from every lead/senior inspector at every
site.
Nonetheless, the practical difficulties in developing and administering
any survey may introduce errors, commonly referred to as nonsampling
errors. For example, difficulties may arise in how a particular
question is interpreted or from differences in experiences and
information available to respondents when answering a question. We took
steps in the development of the survey, its administration, and the
data editing to minimize these nonsampling errors. We conducted three
pretests of the survey instrument. The first pretest was with two
inspectors at one location by telephone; the second and third pretests
were with expert NRC officials, both by telephone. We modified the
survey instrument to reflect questions, comments, and concerns received
during the pretests. The instrument was also internally reviewed by one
of our survey methodologists. In addition, we edited all completed
surveys for consistency and contacted NRC inspectors to clarify
responses whenever necessary. While our survey responses reflect the
opinions of NRC resident inspectors, to ensure the reliability that our
survey data was accurate and complete and that spreadsheet calculations
were correct, 100 percent of the data entry and all formulas were
internally and independently checked and verified.
Through discussions with appropriate NRC officials, we determined in
the course of developing our survey that although there are 103 plants
currently in operation in the United States, some reactors are
colocated on a total of 65 sites. Because only one of the two or three
inspectors assigned to each site is designated as the lead NRC
authority, we sent our survey to that person. Therefore, we sent our
survey to a total of 65 senior/lead NRC inspectors. We expected that
given their experience, the lead/senior inspector would obtain
additional views and input from the other resident inspectors if they
felt it was needed. For example, this additional input would be
important if the other inspectors performed the requirements of the
temporary instruction for inspection of material control and accounting
at nuclear power sites, or if the senior resident was newer to and,
therefore, less familiar with the practices and history of the material
control and accounting program at the site. We received 67 responses to
our survey. In one case, we received a response from the senior
inspector and an additional resident inspector at the same site. We
kept only the senior inspector's response in our analysis and deleted
the other response from that site. In the second instance where we
received two responses from one site, special circumstances at that
site provided for two senior resident inspectors, but one of those
inspectors is primarily responsible for the recovery effort of one of
the units at that site. We excluded that inspector's response from our
analysis, retaining only the response from the senior inspector with
the more general role. This left us with 65 responses for a 100 percent
response rate. The detailed results of our survey of NRC resident
inspectors are presented in appendix II.
We performed our work primarily in Washington, D.C., between July 2004
and February 2005, in accordance with generally accepted government
auditing standards.
[End of section]
Appendix II: Summary Results of GAO Survey of NRC Senior/Lead Resident
Inspectors:
[See PDF for image]
[End of figure]
[End of section]
Appendix III: Comments from the Nuclear Regulatory Commission:
UNITED STATES NUCLEAR REGULATORY COMMISSION:
WASHINGTON, D.C. 20555-0001:
March 25, 2005:
Mr. James E. Wells, Jr.:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
Washington, D.C. 20548:
Dear Mr. Wells:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am writing
to thank you and your staff for providing us the opportunity to review
and comment on your draft report concerning the material control and
accounting (MC&A) of spent nuclear fuel. Your willingness to engage the
NRC staff throughout the review process is very much appreciated.
Overall, the NRC believes the report to be well written and balanced.
Although the NRC generally agrees with the conclusions reached by the
U.S. Government Accountability Office (GAO), I would note that
significant NRC attention had been redirected to the MC&A area prior to
the commencement of the GAO review. The ongoing efforts by the NRC
staff to address many of these same issues are worthy of mention.
Prior to September 11, 2001, spent fuel was well protected by physical
barriers, armed guards, intrusion detection systems, area surveillance
systems, access controls, and access authorization requirements for
employees working inside the plants. Since September 11, 2001, NRC has
significantly modified its requirements, and licensees have
significantly increased their resources to improve security at spent
fuel facilities and nuclear power plants. The results of security
assessments completed to date clearly show that storage of spent fuel
provides reasonable assurance that public health and safety, the
environment, and the common defense and security are adequately
protected.
The NRC believes that the likelihood that an adversary could steal
spent fuel from a spent fuel pool or storage cask is extremely low,
given the security and radiation protection measures in place and the
ease of detectability and intense, physically disabling radiation from
the spent fuel. [NOTE 1] The actions the NRC has already taken, as well
as the actions being taken, are adequate when considered in the full
context of power plant security. Consequently, the NRC does not
consider the threat of a knowledgeable, active insider stealing a spent
fuel rod, or portion thereof, to be credible. The NRC believes that an
insider could not overcome the multiple physical issues and sensitive
radiation detectors, both around the pool and throughout the plant
associated with preventing the removal of spent fuel rods or pieces
from the pool. Furthermore, the physically disabling radiation would
prevent an insider from surreptitiously removing the spent fuel from
the reactor site for use in a radiological dispersal device (RDD).
As the GAO review indicated, some spent fuel pieces have recently been
reported missing or unaccounted for from spent fuel pools; but, for the
reasons listed above, there is no reason to conclude that any of the
missing or unaccounted for material was removed for any malevolent
purpose. Additionally, for all the missing or unaccounted for fuel rods
or pieces identified to date, the initiating events occurred decades
ago. In response to these events, the NRC has implemented MC&A
inspections under the Temporary Instruction (TI) 2515/154, "Spent Fuel
Material Control and Accounting at Nuclear Power Plants," issued on
November 26, 2003. The NRC is also scheduled to complete the following
activities:
* development of guidance concerning control and accounting of rods and
pieces;
* development of guidance concerning the conduct of physical
inventories; and:
* revision of existing procedures for inspecting MC&A of spent nuclear
fuel to include instructions on inspecting control and accounting of
rods and pieces.
In addition, the NRC plans to conduct additional, more detailed
inspections under TI 2515/154 at plants where questions regarding
potential weaknesses in MC&A practices still exist. On February 11,
2005, the NRC issued Bulletin 2005-01, "Material Control and Accounting
at Reactors and Wet Spent Fuel Storage Facilities," to obtain
additional information to assist the staff in deciding which facilities
will be selected for these inspections.
In NBC's view, the GAO report does not make sufficiently clear that the
problems at Vermont Yankee were identified as a direct result of NBC's
implementation of TI 2515/154. Implementation of the TI also helped
identify the problems at Humboldt Bay. Although NRC agrees with the
report's conclusion that licensees' efforts to account for and control
spent fuel are uneven, this knowledge also came from the NRC
inspections and responses to the TI, as did the knowledge that the
biggest problem is accounting for and controlling pieces of spent
nuclear fuel as opposed to assemblies. Additionally, performance-based
approaches are often more effective and efficient at achieving the
desired outcomes than prescriptive approaches. As a result, dictating
how licensees are to meet the MC&A requirements is not necessarily the
most effective and efficient approach.
The draft report also stresses the importance of timely action.
Providing the broader perspective of overall NRC activities that have
occurred since the events of 9/11 is important contextual information.
For example, development and issuance of the TI was postponed by the
need to devote NBC's limited resources to areas requiring more
immediate attention, especially the comprehensive security and
radiological protection activities conducted after 9/11.
With regard to the measures taken by the NRC since issuance of TI 2515/
154, the report needs to provide balance by giving credit to NRC for
making prioritized decisions based on a variety of factors, including
but not limited to, risk of malevolent action, attractiveness of
material for potential malevolent activities, other controls, and
available personnel resources. Such a context is not present in GAO's
report. As noted above, there is no reason to conclude that any of the
missing fuel segments were removed for any malevolent purpose. There is
an important accounting issue for fuel rod segments, but not a security
or safety issue.
Finally, I would like to note that the current regulations (10 CFR
74.19) are clear and do not appear to need revision. Licensees are
already required to keep complete records of and conduct annual
physical inventories of all special nuclear material. "All special
nuclear material" means not only large spent fuel items, but also loose
rods and pieces. The NRC agrees that implementation guidance does need
to be enhanced to address loose rods and pieces of spent nuclear fuel
and the NRC is working to complete the guidance.
As you are aware, the NRC and GAO staffs have had multiple exchanges
regarding the report's contents and context. These exchanges have been
very beneficial. Should you have questions or concerns on these
additional comments, please contact Ms. Melinda Malloy, of my staff at
(301) 415-1785.
Sincerely,
Signed by:
Luis A. Reyes:
Executive Director for Operations:
NOTES:
[1] The systems and tools used to manipulate spent fuel in pools are
designed to prevent an individual from inadvertently raising spent fuel
to the surface of the pool, due to the dangerous levels of radiation.
Consequently, an insider would have to circumvent specific design
features of the tools and equipment, circumvent sensitive radiation
detectors surrounding the spent fuel pool, circumvent radiation
detectors in the remainder of the plant (e.g., the radiological control
boundary), and circumvent radiation detectors at the protected area
boundary egress points to remove a spent fuel rod successfully from a
reactor site. Further, the sensitivity of these radiation detectors
increases as one moves further away from the reactor since these
systems are part of the licensee's personnel radiation protection
program. Finally, the radiation levels from unshielded spent fuel rods
would typically be physically incapacitating within a few minutes and
lethal shortly thereafter.
[End of section]
Appendix IV: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Jim Wells, (202) 512-3841;
Ray Smith, (202) 512-6551:
Staff Acknowledgments:
In addition to the individuals named above, Ilene Pollack and Melissa
A. Roye made key contributions to this report. Also contributing to
this report were John W. Delicath, Doreen Feldman, Judy K. Pagano,
Keith A. Rhodes, and Barbara Timmerman.
(360500):
FOOTNOTES
[1] In the United States, there are two types of nuclear power reactors
(boiling water and pressurized water) and several designs for each.
With the inclusion of modifications over time, specifications regarding
the number and length of fuel rods and the number of assemblies
required to fuel a reactor core will vary. Specifications may also be
influenced by the type of reactor design.
[2] Reconstitution in this sense refers to the process by which fuel
rods are removed from complete fuel assemblies and the replacement of
these rods with good ones.
[3] NRC has licensed 104 commercial nuclear power plants to operate.
One of these plants has been shut down since 1985. Other nuclear power
plants are in the decommissioning phase. These decommissioning plants
and a wet storage facility not associated with a nuclear power plant
(GE Morris) also still have spent nuclear fuel and are licensed by NRC
for these purposes.
[4] A boiling water reactor uses radioactive steam that is generated in
the reactor to drive a turbine that generates electricity. The water is
returned to the reactor core where it is reheated to steam, driving the
turbines as the cycle is repeated. Pressurized reactors send slightly
radioactive pressurized water to a steam generator, which creates steam
from nonradioactive water kept separated by tubes. The steam drives the
turbine and the slightly radioactive water returns to the reactor where
it is reheated and the cycle repeated.
[5] Spent fuel rods recently discharged from a reactor also contain
some radioactive gases that are a by-product of the nuclear fission
process--these gases account for a small fraction of the total quantity
of radioactive material in spent fuel rods, but because of the short
half lives of the material, the gases decay quickly and may not be
present in older spent fuel.
[6] The Millstone and Vermont Yankee plants are still operating, while
the Humboldt Bay plant has been shut down since 1976.
[7] In June 2004, NRC issued Information Notice 2004-12 to all holders
of operating licenses for nuclear power reactors, research and test
reactors, decommissioned sites storing spent fuel in a pool, and wet
spent fuel storage sites. The notice's purpose was to inform these
licensees of the problems at Millstone and Vermont Yankee. Although no
specific action or written response was required, NRC indicated that it
expected the licensees to review the information for its applicability
to their facilities and consider action, as appropriate, to avoid
similar problems with their spent fuel inventories.
[8] These 70 sites include 65 operating and 4 decommissioning nuclear
reactor sites and 1 wet storage site.
[9] Fuel rods may fail for a variety of reasons, such as corrosion or
gases leaking from the tubes that hold the rods.
[10] Current NRC officials stated that the 1988 change was made because
no problems with material control and accounting for spent fuel had
been identified at that time.
[11] NRC considers this instruction, Spent Fuel Material Control and
Accounting at Nuclear Power Plants (Temporary Instruction 2515/154,
Nov. 26. 2003), to be temporary because it provides for a one-time
inspection and has a short-term expiration date, currently scheduled
for November 2005.
[12] The phase I review also included decommissioned power plants with
wet storage and one wet storage facility.
[13] OIG-03-A-15, May 23, 2003.
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