In July 1999, the U.S. Nuclear Regulatory Commission (NRC) Spent Fuel Project Office
(SFPO) issued Interim Staff Guidance 8 Revision 1 (ISG8R1) to provide recommendations for the use
of burnup credit in storage and transport of pressurized-water reactor (PWR) spent fuel. Subsequent to
the issuance of ISG8R1, the NRC Office of Regulatory Research (RES) has directed an effort to
investigate the technical basis for extending the criteria and recommendations of ISG8R1 to allow

The benefits of burnup credit and the technical issues associated with utilizing burnup credit in spent
nuclear fuel (SNF) casks have been studied in the United States for almost two decades. The issuance of the
U.S. Nuclear Regulatory Commission (NRC) staff guidance for actinide-only burnup credit in 2002 was a
significant step toward providing a regulatory framework for using burnup credit in transport casks. However,
adherence to the current regulatory guidance (e.g., limit credit to actinides) enables only about 30% of the existing

This publication records the proceedings of a technical meeting organized by the IAEA and
held in London 29 August–2 September 2005 with sixty participants from 18 countries. As
indicated in the title, the objective of this meeting was to provide a forum for exchange of
technical information on spent fuel burnup credit applications and thereby compile state-ofthe-
art information on technical advances related to spent fuel transportation, storage,
reprocessing and disposition.

The American Nuclear Society (ANS) appreciates the opportunity to comment on the draft Nuclear Waste Administration Act (NWAA). The ANS is a not-for-profit, international, scientific, and educational organization with nearly 12,000 members worldwide. The core purpose of ANS is to promote awareness and understanding of the application of nuclear science and technology. As an organization, it has published a number of position statements regarding the issue of spent fuel and radioactive waste.

The American Nuclear Society (ANS) supports the safe, controlled, licensed, and regulated interim
storage of used nuclear fuel (UNF) (irradiated, spent fuel from a nuclear power reactor) until disposition
can be determined and completed. ANS supports the U.S. Nuclear Regulatory Commission’s (NRC’s)
determination that “spent fuel generated in any reactor can be stored safely and without significant
environmental impacts for at least 30 years beyond the licensed life for operation.

It is increasingly apparent that the United States will require a large expansion of nuclear power
generation capacity to meet its future baseload electricity needs while reducing greenhouse gas
emissions. As a result, Congress and the Administration must act to update U.S. nuclear fuel
cycle policy to address these realities. This will likely require a multifaceted approach involving
some combination of on-site/centralized dry cask interim storage, nuclear fuel recycling, and
emplacement of high-level wastes in long-term geological storage.

More than 45 million shipments of radioactive materials have taken place in the United States
over the last three decades, with a current rate of about three million per year. The majority of
these radioactive shipments consist of radiopharmaceuticals, luminous dials and indicators,
smoke detectors, contaminated clothing and equipment, and research and industrial sources.
Fewer than 3,500, or 0.01%, have been involved in any sort of accident, incident, or anything

The American Nuclear Society (ANS) supports (1) the development and use of geological
repositories for disposal of high-level radioactive wastes and (2) expeditious processing of the
Yucca Mountain license application in an open, technically sound manner. Geological disposal
means placing the wastes hundreds of feet underground and far from the biosphere. The U.S.
Nuclear Regulatory Commission (NRC) is following a legislatively well-defined regulatory
process to evaluate the safety of the proposed Yucca Mountain Site to meet both the scientific