Free Motion for Leave to File - District Court of Federal Claims - federal

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Case 1:98-cv-00126-JFM Document 781-3 Filed 04/07/2004 Page 1 of 1

TABLE 3.

Derivation of Estimated Maximum Feasible Cask loading Rates
PWR- Truck
BWR- Truck

Cask loadin9 Constraints

PWR-Rail

BWR- Rail

Turnaround Time (days)
~asks loaded/year SF assemblies/cask
SF assemblies loaded/yr

182

182

146

104

546
251

1274

MTU laaded per year

229

3066 1410

4992

899

Cask loading rates are based upon one 10more shifts per day are assumed, the maximum feasible loading rate would

hr shift/day. If

i ncrease.
At the s1te of a shutdown reactor, it may be possible and desirable to
exceed the cask loading rates assumed in Table 3.

1. Since definitive data on

the extent to which this would occur is not available, the approach taken in
this study is to use the estimates in Table 3. 1, even if lower than might

actually be achieved, and show that any resulting constraints on system
throughput can be mitigated by reallocation among reactors.

SUMMARY OF CASES ANAL VIED

Table 3. 2

summarizes the nine cases formulated for analysis in this

study in terms of the assumptions discussed above. Cases

2 through 7 do~ument

the development of a shutdown priority scenario that is feasible and has rela-

tively low costs to utilities, beginning with a very literal construction of
the EDF suggestion in Case 2 and making refinements in the allocation rules.

Cases 8 and 9 are sensitivity analyses for the form of allocation among shut-

down reactors and the minimum acceptable fuel age.

Results are discussed in

Sect; on 4.
In each of these cases, the repository s receipt requirements are satis-

fied by applying the allocation and priority rules to the set of reactors to determine a reactor pickup schedule (sequence in which the reactors are serv-

iced and the amount of spent fuel picked up at each). For example, in Case 8
the order ;n which the reactors are serviced and the amount of spent fuel

transported are based upon several criteria. First, those reactors that

OCR

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P A- 165064