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Surplus Plutonium Draft Environmental Impact Statement Comments September 15, 1998
Laura Holgate, Director Ms Holgate: Thank you for this opportunity to comment on the Surplus Plutonium Draft Environmental Impact Statement (EIS) of the U.S. Department of Energy. These comments are supplemental to comments already submitted by me on behalf of Nuclear Information and Resource Service in North Augusta, SC in August (provided again below to insure their inclusion in the record). We remain unalterably opposed to the use of plutonium fuel in reactors, here in the US, in Russia, Canada, anywhere. I take this opportunity to formally protest the fact that a major federal action is being undertaken without providing side by side parallel levels of information on the various options. Plutonium disposition via immobilization only should be compared to a specific analysis of the dual track putting MOX in an existing light water reactor (LWR) and immobilization. It seems the Department of Energy (DOE) is already completely committed to following the dual track MOX option prior to the issuance of the Record of Decision (ROD) on this EIS (which is ostensibly to inform that decision) and prior to any substantive analysis of the impacts that the MOX option would have on specific existing reactors. The evidence for this is DOE's issuance of a Request for Proposal from MOX fabricators and irradiators (reactors) and the intention to forge a contract on MOX work, possibly before the ROD is out. It would seem that communities around the DOE sites under consideration for plutonium processing and MOX fuel fabrication can look for protection under the National Environmental Policy Act, but those who will be directly affected by the introduction of experimental, never-been-tried-before fuel in the local nuclear power reactor. This is not acceptable. (European MOX does not have gallium added, not is it pure Pu-239.) It is also not acceptable the on three separate occasions members of your Office staff have offered to me the advice that reactor communities can impact the federal decision- making process by intervention in the Nuclear Regulatory Commission's (NRC) license amendment process for any reactor that may use MOX fuel. This is completely inappropriate. It is almost like saying -- the automobile manufacturer doesn't have to bother with any safety analysis or tests of a completely new design of an automobile -- just go ahead and build it and sell it and then we will see what happens with the local license inspection. Your office, the Secretary of Energy and the President and Vice President have the responsibility to make a decision based on information about all of the impacts that a MOX program may have. The current document is completely lacking in any consideration of the reactor impacts. In a recent conversation with members of your staff, I was referred to the Programmatic Environmental Impact Statement (PEIS) on Plutonium Disposition when I raised issues associated with the use of aging power reactors for this challenging mission. A return to this document yields the comments I offer below. By the way, they left the existing civilian reactor so-called "low-level" waste out of the PEIS, no matter what the NEPA officer says! I do however, want to assure you that the reactor communities across the country are well aware of their right to intervene on the license amendment process. I also want to point out that even in areas where the community is not what might be called "anti-nuclear," there is already official and documented willingness to oppose use of weapons plutonium in existing reactors. We recommend that you add this information to the uncertainty factor on any cost estimates you make for this program. I would also commend to you the fact that novel procedures such as using environmental reports previously filed with the NRC that may be decades old or the invocation of "proprietary information" under a vendor procurement deal which may require that a local community has to "take DOE's word for it" will not build DOE credibility. In fact, such an approach by your office may also provide procedural loopholes that could result in administrative or legal delays. We sincerely hope that your office retains and pursues its stated high level of commitment to the non-MOX options for plutonium disposition, since there is wide consensus that this disposition should proceed. FOR CONSIDERATION UNDER A TRUE NEPA PROCESS: Utilization of the environment reports filed at the time of reactor licensing may be decades out of date. What are the plans to upgrade and update this information? Given the aging of nuclear reactors -- including embrittlement of major components that has caused multiple reactor shut-downs (permanent) well in advance of license expiration (Trojan, Yankee Rowe, Big Rock, Oyster Creek (soon), Maine Yankee to name a few in the last 5 years), combined with the environment of utility restructuring and competition among electrical service providers, it is plausible (even likely) that tax-dollars for the service of plutonium irradiation will keep reactors on-line that would other-wise close. THEREFORE, a true NEPA analysis of the existing reactor MOX option MUST include the shut-down scenario. It is not only a comparison between LEU (scenario: reactor continues to operate on LEU but all surplus plutonium is immobilized) and MOX (scenario: plutonium fuel is loaded in x many specified existing-LWRs and they get costs plus some financial benefits). It must go one step further: LEU vs MOX vs no reactor (scenario: all plutonium is immobilized and the reactor closes due to market forces). In any economic analysis running parallel to the NEPA analysis, there must be a consideration of the impact of federal tax-dollar protectionism of these reactors on the utility markets that they are part of. What are the long-term environmental consequences of privileging nuclear over bio-mass, wind, solar, small hydro and energy efficiency? If we assume that there will be full-core MOX, which is widely assumed by the industry, and we assume a fast thru-put rate, which will be required if predictions hold on the relatively small number of reactors that will remain viable through the entire program, then the MOX program will have extensive impact on the on-site storage of irradiated fuel. The requirement of ten years wet storage for irradiated MOX will certainly force accelerated movement of LEU fuel into dry storage. Once MOX fuel is being put in dry storage, the requirement of relatively few assemblies per container will expand the overall total number of dry casks required. This NEPA analysis should consider how to factor any local or state requirements and restrictions applied to on-reactor-site interim storage. For instance, the Minnesota Supreme Court ruled that cask storage is different than pool storage and is subject to State Legislature approval. Nevada has outlawed storage and Vermont and California also have restrictions in place, to name a few. There has yet to be the constitutional test over the ability of the federal programs to override state law on behalf of nuclear enterprises. This should not be forgotten. Does DOE intend to start exerting "National Security" type arguments over civilian facilities and the communities and States that host them? If so, we had best know that now, and Governors should be advised as well. Again, it is completely unsupportable that these decisions are being made with a systematic exclusion of the reactor impacts analysis at any level where it can inform this decision, and without the active inclusion of the reactor communities. USE OF A GENERIC REACTOR AS PROXY FOR SITE SPECIFIC ANALYSIS There is no such thing as a generic nuclear power reactor. Each was built in a unique place, as a unique fabrication, and many on effectively unique designs. Over the years they have become MORE unique, as can be demonstrated by the very high percentage that are now out of compliance with their own Final Safety Analysis Report and Design Bases documents. It is not at all credible to suggest that the generic analysis provided (such as it is) in the PEIS can stand for a reactor impacts analysis. Some reactor items which are NOT generic:
This is not the complete list. The PEIS references Appendix E for information about the waste associated with the existing-LWR MOX option. Nowhere in Appendix E is the existing-LWR option listed. There is a very cursory discussion of so-called low-level (civilian LLRW includes plutonium even in class A waste, and reactor "low-level waste" may also include sludges from primary coolant and components such as steam generators and the reactor vessel as well as reactor internals that will deliver a lethal dose if unshielded) waste, associated with the Evolutionary LWR scenario. There is no section on the existing-LWR option in Appendix E. References to reactor-site burial of such waste certainly require a site-specific analysis, not a generic dismissal. Disposal off site is simply given as the other option; end of analysis. There is no documentation of the array of radionuclides in so-called low-level radioactive waste (LLRW) that would result from irradiation of MOX fuel vs LEU fuel. There is no consideration of the environmental impacts of shipment to or emplacement of this MOX LLRW in any of the existing "low-level" unlined trench dump-sites: Barnwell in South Carolina near SRS, Envirocare in Utah or Richland in Washington State next to Hanford. Needless to say, there is no analysis of the potential impacts of this plutonium fuel generated waste in any of the proposed new "low-level" dumps -- of greatest interest being Ward Valley in California and Sierra Blanca in Texas because of the ongoing debates about whether these facilities may jeopardize major water supplied in the Colorado and Rio Grande rivers. Another area of nuclear infrastructure completely ignored by the PEIS are all the nuclear services that reactor operators require. These include: nuclear laundries, incineration and compaction facilities for so-called "low-level" waste, decontamination services for components that are not yet considered waste and off-site storage warehouses for all of the above. The question is very real, and as yet unanswered: what does the use of MOX fuel do to the workers, the air and water emissions, and waste streams from each of these nuclear services? How does this impact the environment and public health and safety? Don't the communities that affected by these nuclear service facilities have a right to this information? This information should be factored when considering immobilization only vs dual track. The possibility of reactor closure should also be factored in such an analysis...what is the affect on the environment if you just plain phase out these facilities? It is ridiculous that the "criteria pollutants" for air emissions under the PEIS generic reactor analysis does not include radionuclides. No numbers are given for MOX radionuclide emissions vs LEU air emissions. It is well documented the there has been a history of fuel failure in US reactors with LEU fuel. There is evidence that European MOX fuel is more prone to cladding failure, and that Weapons Pu MOX may be even more prone to cladding failure than European MOX. The interaction of gallium and zircaloy and other factors, such as the chemistry of the core are factored into this projected incident rate. A credible analysis of the existing-LWR MOX option will need to quantify this in a reasonable and defensible manner, and include it in the projected air emissions. It should be noted that the generic reactor portrayed by the PEIS is based on data that is already today 6 to 10 years old. This is not going to reflect the aging issues that are coming to the forefront of reactor hazard concerns. The difference in neutron activity associated with MOX fuel also needs to be assessed for the possible contribution to further acceleration of the aging of these components, and the consequent reduction in the margin of safety at the site. Additionally, there needs to be some assessment of the institutional issues. Weapons Pu-239 fuel will be a first-time experiment. What are the human factors that are affected by changing basic features of an aging system? The generic reactor analysis further does not give an assessment of the source term associated with the reactor core, the fuel pool or a dry storage unit. Again, the LEU vs MOX comparison must be made, and should be compared to the shut-down reactor possibility. There is ample evidence to suggest that the use of weapons plutonium MOX in existing aging light water reactors subject to utility deregulation may not only increase the probability of a major reactor accident, but would also increase the effects of such an accident, were it to happen. No where in the NEPA process to date are these issues addressed by DOE. What is the justification for taking a major federal action with such potentially grave consequences, without the least consideration of these factors? Finally, there is no justification whatsoever for taking the recommendation for a linear no-threshold model for radiation dose response from the BIER-V report and then applying an arbitrary risk reduction factor to it. Indeed, real-world health studies done by credible scientists are showing a supra-linear dose-response curve, where per-unit of dose there are more health consequences in the low-dose range. All taken together, we recommend that the current EIS be suspended and a design phase for this NEPA process be initiated so that there is no decision on the MOX option until these, and other concerns that may be raised by concerned citizens are addressed. Thank you for your consideration,
Mary Olson
COMMENT PREVIOUSLY GIVEN AT DOE PUBLIC COMMENT MEETING
Nuclear Information & Resource Service Thank you for this opportunity to comment on the Surplus Plutonium Draft Environmental Impact Statement of the U.S. Department of Energy, North Augusta, SC, August 13, 1998 (corrected 9/15/98)
Mary Olson On behalf of the nationwide membership of Nuclear Information and Resource Service, I am here to respectfully tell you to put zero plutonium into MOX (mixed plutonium and uranium oxide) fuel. Our organization was founded by communities that are affected by commercial nuclear power reactors. Over time our members have grown to also include those who are affected by current and proposed nuclear waste sites and waste transport routes. We are offended that the Department of Energy (DOE) has persisted in ignoring these communities that will be directly affected if MOX fuel is produced and introduced into the fuel stream, and so inevitably the waste stream of the nation's reactors. DOE's process has selectively targeted comments from the communities that would be affected by MOX fuel fabrication, but not it's use. We oppose the use of plutonium fuel, therefore we oppose the fabrication of plutonium fuel. We encourage DOE to fully explore the non-reactor alternatives for plutonium disposition. I am here to tell you that you will hear from the reactor communities. You have done little to reach these communities, but when the news arrives that plutonium is on the way, you will hear the cry loud and clear: NIX MOX. Communities simply will not settle for a plan that both increases the possibility of a major reactor accident AND also guarantees that if there is a major release of radiation that the consequences of that accident will be greater than if there were LEU fuel in use, as the reactors were designed for. Communities with aging reactors are taking the safety issues into their own hands and 9 reactors in as many years have closed due to a combination of safety and economic concern. MOX will simply become one more opportunity for those concerned about nuclear hazards at reactors to make their case. Nationally this program will not stand the scrutiny of the electric utility deregulation process. Direct taxpayer subsidy unfairly advantages nuclear power reactors over other forms of electricity. Ultimately, when the consumer can decide where to purchase their electric power, DOE may have to pay a lot to keep MOX reactors on line. When it comes to transportation, MOX will necessarily involve more transportation steps than any other alternative for plutonium disposition. Our experience is that communities are extremely unhappy to hear about nuclear shipments on their roads and rails. The Department's own research has shown that this opposition runs very deep. More than 20 % of those queried (in a social science survey done by the University of New Mexico for DOE) said that they thought that civil disobedience (breaking laws) was justified to stop nuclear shipments through their town, and 80% said that they would vote against any elected official who supported such a plan, as well as give money to groups that would help fight it. People feel very strongly about this, perhaps Vice President Gore should listen! One of the most disturbing aspects of the DEIS that we are here to comment on, aside from the obvious commitment by DOE to implement the MOX option, is the plan to ship plutonium in the powder or oxide form. We would oppose this idea if it were just a few miles, but the current consideration of shipping it across 6 states is ridiculous. Not only is it a enormous security risk, if there were some form of catastrophic disruption of such a shipment, the containment of the plutonium oxide would present a much greater challenge than containment of other forms of the material. The potential dispersal by air (wind or fire plume) or run-off would place countless human generations at greater risk of cancer, birth defects and other health problems, as well as affecting other species adversely. We firmly believe that the U.S. DOE has no right whatsoever to take risks, the consequences of which could result in nuclear devastation, particularly in the name of reducing nuclear dangers. We are further alarmed to realize that recent changes in Nuclear Regulatory Commission requirements for plutonium shipping containers no longer require a double walled vessel. DOE should not ship plutonium oxide in bulk at all and any other type of plutonium shipment, the Department should voluntarily use a double (or more) walled container. What is the excuse for increasing risk? This is an inherently hazardous activity, which long term consequences. There would be many advantages to the plutonium disposition mission if the MOX program were canceled. Here is a brief overview along with our recommendations for how to proceed with a successful disposition for this plutonium which we all agree is far better removed from the weapons inventory. Plutonium "polishing" would be minimal for most immobilization methods. An aqueous "pre-processing" step, much like the reprocessing step that separated the plutonium in the first place could be avoided. Reprocessing is known to produce some of the most dangerous and difficult to contain wastes in the history of the nuclear age. There is no reason for the DOE to compound this disaster as is already evident in the environmental devastation of nuclear pollution here at and around Savannah River Site and the Hanford Reservation. If only plutonium immobilization were implemented, fewer facilities would have to be built, reducing the coat as well as the inevitable difficulty associated with approvals, licenses and such. Plutonium would travel less if immobilization where implemented, and not MOX. Nuclear Information and Resource Service is not taking a position on where the immobilization program should be pursued, or even if it should be done in one place. Nonetheless, it is pretty obvious that weapons-usable material would be transported less and spend more time within the boundaries of the DOE complex than in the MOX option. Before it is fissioned in the reactor core MOX fuel is still weapon's usable, requiring only reprocessing technology, not enrichment. Thus it would require national security level security in transport. Further, there would have to be the same level of security instituted at reactor sites. We object to DOE endowing private security services in our communities with a shoot-to-kill authority. Obtaining reactor license amendments for this new fuel type will offer the opportunity to review the reactor safety systems and also the aging issues inherent in the long-term exposure to he heat and radiation of LEU uranium fuel. The increased capacity of plutonium fuel to age components, particularly in the full-MOX cores that the Department seems to be assuming in the DEIS, will provide a wonderful opportunity to target reactors for early closure. On the waste front, immobilization also offers the Department some relief, since the storage of an immobilization end-product can be designed from the ground- up to be appropriate for this new waste type. In contrast, irradiated MOX fuel in the hands of nuclear utilities that are already facing challenges of waste storage is a very different picture. Over-filled fuel pools, many already strained far beyond their original design capacity will not be easier to manage with the greater thermal and criticality factors, as well as cladding stress issues that MOX will introduce. If dry storage is in use at the time that MOX waste would be moving out of the fuel pools, attempted use of current cask designs may also result in problems that will be the Department's to deal with at some point. What is going to become of all that damaged fuel if we ever do have a repository? All this spells more expense, more regulatory and administrative combat with local communities and ultimately if great care is not take and more money is not spent, far greater environmental impact than a system that is designed specifically for the unique aspects of plutonium wastes. The list of all the reasons MOX is a bad idea goes on, and we will supplement these oral comments with further written comments. The bottom line is that MOX will cost a tremendous amount of money to do at all, and then it will cost even more to deal with the legal and administrative aspects of trying to oppose the people you serve, and then it will cost even more than that, since the probability of a real problem at some point are not our imagination, but rather based on 50 years of experience with the Department and three decades of suffering reactor operation. Recommendations for responsible immobilization of surplus weapons plutonium The Department must insure a zero release policy for every site where plutonium is handled. There is no acceptable amount of this material in the environment, in our bodies, in our food, in our air in our water. This means that there has to be a plan for ALL the waste at every step to insure that it is tracked into 100% containment, and that there is no idea that it is OK to vent. The Department should insure that state of the art monitoring will instituted -- with redundancy to insure that this policy is in-force at all times. One of the monitoring systems should be administered completely in the control of the local community. This means that there is a commitment to zero dose to the public in this process. The Department should institute a low as achievable dose policy for workers. This is NOT ALARA -- remove the word "reasonably" before achievable. Cancel MOX and spend the money you would save on meeting these goals, and there will be far greater acceptance of plutonium disposition mission in whatever community you approach to host this vital contribution to the welfare of our planet. Equally Important to protecting the people and the environment from DOE's plutonium handling is the security of this vulnerable material. We recognize that steps must be taken to insure that this material is not diverted. At the same time this must not be at the expense of an open and accessible information base to insure that environment and safety commitments are being met. Thank you. |
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