Your Comments to NRC on production and use of weapons-grade plutonium
Your Comments to NRC on production and use of weapons-grade plutonium fuel (MOX) are needed NOW
The U.S. Nuclear Regulatory Commission (NRC) is engaged in a licensing process for a new nuclear fuel factory at the Savannah River Site in SC that would make experimental nuclear fuel from plutonium recovered from nuclear weapons (and residues from the bomb-making process) for use in commercial nuclear power reactors. Since the plutonium would be mixed with uranium, it is a "mixed oxide" or "MOX" fuel. This proposal is mirrored by a similar program in Russia. Justified as "disposition" programs for surplus weapons-grade plutonium, these programs have far reaching consequences. MOX production & use in the US would reverse decades of policy against plutonium use, as well as "blend" civilian and military nuclear programs. MOX fuel could be in reactors near you, if current legislative proposals (S 472, S 388 and HR 1679) promoting the reprocessing of nuclear waste become law.
NRC must do an environmental impact statement to "inform" their MOX licensing decision. NRC is now collecting public comments on the "scope" of this EIS. Background information and points for comments are below.
Please note: MOX is a cross-cutting issue spanning nuclear weapons/materials/waste concerns and nuclear power reactor operation/fuel/waste concerns. Though NIRS' focus is on the reactor side, we intend no diminishment of the full range of concerns. Links to allied organizations focused on the nuclear arms/non-proliferation aspects of this program are at the end of this message. We invite others to put out additional scoping comment information.
COMMENT DEADLINE: MAY 21, 2001--please include in your comments a request for comment extension, as this whole program is in rapid change.
HOW TO SEND COMMENTS:
Via "snail mail:" Michael T. Lesar, Acting Chief, U.S. Nuclear Regulatory Commission, Rules & Directives Branch, Division of Administrative Services, Office of Administration, Mail Stop T6D59,
Washington, DC 20555.
Via e-mail: teh@nrc.gov -- they will be received by Tim Harris
Via fax at: 301-415-5398, Attention: Tim Harris.
PLEASE ALSO SEND YOUR COMMENTS TO YOUR US SENATorS (hard copy please) and other elected officials of your choice. Mail to: US Senate
Washington, DC 20510
BACKGROUND: The Department of Energy plan to address surplus plutonium from the nuclear weapons program, resulting from bi-lateral US/Russian arms reductions, is to make it into commercial nuclear reactor fuel.
A second "track" in the US plutonium disposition program--preferred by most NGO's-ceramic immobilization of plutonium with existing high-level wastes, is jeopardized by proposed Bush administration funding cuts.
Immobilizing plutonium treats it as a waste, provides a safeguard of a highly radioactive jacket and would keep it within federally controlled boundaries.
MOX fails spectacularly as a non-proliferation strategy. Putting weapons-grade MOX into commerce vastly decreases security. This is compounded by the Russian nuclear agency's intent to export weapons-grade MOX fuel to their nuclear "client nations," which of course, includes some typically referred to as "rogue nations" by US leaders. In any case, global trafficking in weapon's grade plutonium is a bad idea, whether done by US or Russia.
In 1999, DOE put out an EIS and a Record of Decision designating the Savannah River Site as the location for the new US plutonium fuel factory as well as all the plutonium processing steps-- and there will be many to make reactor fuel from nuclear weapons pits. DOE also defined a series of contracts for the design, construction and operation of the new factory as well as "irradiation services," which, like immobilization, would make the weapons plutonium fuel so highly radioactive that it would be "theft proof." Until this is accomplished, MOX fuel is uniquely vulnerable to theft since it is not highly radioactive and unlike uranium fuel, the plutonium can be separated chemically and is still weapons grade.
Claims that use of weapons MOX fuel will "get rid of the plutonium" are false. The net reduction in plutonium would actually be quite small since new plutonium is formed in the reactor at the same time.
DOE awarded the MOX contract to a consortium called DCS, composed of Duke Engineering Services, COGEMA, Stone and Webster and a host of subcontractors including Framatome, Nuclear Fuel Services and Duke and Virginia Power. (Virginia Power recently said it is withdrawing from the program, but in fact the contract has not been amended to remove them) The final taxpayer-funded contracts for irradiation (use) of the weapons-grade plutonium fuel would include not only the additional costs of plutonium fuel, but a nice "reward" for taking care of national security.
MOX fuel in Europe is not made from weapons-grade plutonium. There is no wide experience or data to support NRC's licensing action. We do know that both kinds of plutonium fuel--weapons grade and reactor grade--make reactors harder to control and age them more rapidly and therefore decrease the margin of safety against reactor accidents. In the event of a major core breach accident, plutonium fuel is more deadly than uranium. A Chernobyl style accident at a reactor using 100% MOX fuel could cause as many as double the number of deaths from cancer. Ed Lyman of NCI did this work, and he found that when less plutonium fuel is used, there is still an increase in cancer deaths, proportionate to the percentage of plutonium fuel. One would expect increases in all other radiation impacts as well.
The four reactors operated by Duke Power that have been !QS!ed for this program have the weakest physical containment structures in the US fleet. Dr. Lyman calls them "tissue paper containment" and one of NRC's own reports acknowledges that in the event of station black-out there is a 100% chance of core damage and containment failure at the Catawba reactors, and nearly that high a chance at the 2 McGuire reactors. We are calling on NRC to reject these flimsy ice condenser reactors from any further consideration in this program.
It is VITAL that we NIX MOX and send a message NOW that plutonium fuel will not be tolerated!
SOME POINTS TO RAISE IN COMMENTS ON THE SCOPE OF NRC'S ENVIRONMENTAL
IMPACT STATEMENT
--> Support the "No Action Alternative" in this EIS, which would mean that NRC denies a license for the construction of the MOX fuel factory.
This would throw it back to DOE as to what to do, since NRC has no jurisdiction over plutonium disposition. The immobilization track has been de-funded, but not officially canceled. Since DOE's Record of Decision states that the reason for a "dual track" is in case one track fails, it could be argued that the NRC no-action is a 100% immobilization route. It is also possible, however, that DOE would consider export of the surplus plutonium to Canada under the "Parallax Program," so it would be well to specify what alternatives you think they should analyze as part of their "No Action," and then tell them NO to MOX fuel!
--> Reject any further consideration of the Duke Power ice condenser reactors. These reactors have an unacceptable risk level with the use of uranium fuel. Use of even more risky MOX should not even be contemplated!
--> Show us the data on which NRC is calculating any of their projected impacts from the handling and use of weapon's grade plutonium as a reactor fuel. Where there is no data, please provide us with all assumptions and a statement of the degree of uncertainty associated with calculations intended to "model" weapons grade plutonium.
--> Evaluation of plutonium fuel use and reactor impacts must be site specific, not generic. NRC is proposing to do a generic analysis of reactor impacts, even though the contract states clearly which reactors will be used. They also did a generic "standard review plan" for the fuel factory license review and have revised 10 CFR part 70 to accommodate plutonium fuel production any!QW!, any time. We must ensure that this NEPA process is NOT transferable to the entire fleet of US reactors. The Duke ice condenser reactors are not appropriate as "reference reactors" for other types, nor is a more generic "reference reactor" a legitimate base for analysis of these unique systems.
--> A Supplemental EIS (SEIS) should be done at the time that Duke or any other utility seeks a license amendment to use plutonium fuel. This SEIS should be specific to that reactor, and also include all of their ancillary contracts (again site-specific) such as nuclear laundry, so-called "low-level" waste storage, transport, incineration and disposal, high-level waste storage (on and off-site) transport and repository impacts--MOX high-level waste is hotter in temperature and will have 2--4 times as much residual plutonium than uranium waste, so there can be less per container, causing more storage space, more shipments, more space in a repository.
--> If a generic approach is taken to reactor use of plutonium fuel, the EIS should also include the impacts of a return to the reprocessing of nuclear fuel, since it is likely that the chosen location of the new factory--the F Area at SRS which has a "canyon" for plutonium recovery and high-level waste tanks--make it an ideal set up the reprocessing of civilian reactor waste. This should also include a "Mobile Chernobyl" scenario for nationwide irradiated fuel transport to South Carolina.
--> The environmental records and operating histories of Duke, COGEMA, Stone and Webster must be made publicly available, and openly cited in NRC's analysis. To date, DCS has submitted the operating and environmental record of Savannah River Site, which is not relevant.
--> Making reactor fuel would require many more steps for purification than immobilization would. One of these steps, called "plutonium polishing," would generate millions of gallons of high-activity alpha-emitting liquid waste. DCS has no plan for what to do with this waste other than put it in one of SRS's tanks, many of which are already leaking. NRC must include the disposition of all process wastes in their analysis.
--> The contract for the MOX fuel factory only specifies "de-activation" at the end of 20 years. Other NRC licenses require provisions for decommissioning. If NRC licenses this facility, they should have regulatory responsibility for it through decommissioning.
--> A complete environmental justice analysis must include not only the communities adjacent to Savannah River Site, but also communities down wind and down river, including subsistence fish consumers, and transport routes for both the source material and the fuel transport, as well as the reactor communities. Further consideration should be given to the fact that this entire program has been located in the Southeastern United States and whether it fits a pattern of "dumping on Dixie."
--> If an analysis of MOX use is undertaken in this EIS, it must include diminished reactor control due to the smaller number of delayed neutrons rendering control rods less effective, and plutonium fission's
characteristic coefficient of heat !QW! the hotter the reactor gets, the easier it is to split plutonium, !QW! uranium is the opposite.
There must also be assessment of acceleration in reactor component aging due to more hard, fast neutrons. Higher levels of heat and fission products should be assessed in terms of routine releases to air and water, thermal impacts, worker exposure and all waste streams. All these analysis should be straight reporting of real consequences, not modified by "risk" factors. Risk analysis should be reported clearly and separately.
--> The source term (amount and type of radioactivity including persistence) used in the analysis of a plutonium core accident must be accurate, and the doses reported from projected accidents not modified by risk factors. The DOE has validated the NCI finding by Dr. Ed Lyman that there is an increased potential for cancer deaths from a core breach accident with plutonium fuel in use A possible doubling in fatal cancers associated with use of 100% MOX fuel, and the projected 25% or more increase in cancer deaths associated with the DCS plan for a 40% core is unacceptable and should be the basis for NRC to !QS! the no-action alternative and reject MOX license.
--> Plutonium fuel increases all nuclear liabilities. The Price-Anderson
Act liability limits and insurance package must be evaluated, especially with regard to increased taxpayer exposure.
Substitution of plutonium for uranium in reactors is such a complex prospect that the list goes on and on... NRC's own credentials for regulation and oversight of weapons' grade plutonium are nil. This alone should be the reason for them to !QS! the No Action alternative!
NIX MOX!!!
For more information about NIRS: http://www.nirs.org
Other organizations active on the plutonium fuel issue:
Blue Ridge Environmental Defense League http://bredl.org
Institute for Energy and Environmental Research http://www.ieer.org
Nuclear Control Institute http://www.nci.org/nci-wpu.htm
WAND Women's Action for New Directions http://www.wand.org/issuesact/nixmox-index.html
To access the NRC's Federal Register Notice of Intent [Federal Register: March 7, 2001 (Volume 66, Number 45)] [Notices] [Page 13794-13797] From the Federal Register Online at http://www.access.gpo.gov/su_docs/aces/aces140.html
Scoping meeting summaries and project-related materials will be available on the NRC's MOX web page:
http://www.nrc.gov/NRC/NMSS/MOX/index.html
Nuclear Information & Resource Service Southeast Office
P.O. Box 7586
Asheville, North Carolina 28802 USA
828-251-2060 fax 828-236-3489
nirs.se@mindspring.com
http://www.nirs.org
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