NRC states that their Environmental Impact Statement (EIS) will cover building and operating the plutonium fuel (also called MOX) factory, transporting the plutonium fuel to the reactors near Rock Hill, SC and Charlotte, NC as well as using the fuel in the reactors. The questions, comments and thoughts on this sheet are intended to help you consider your own questions and comments.

General Environmental Concerns

ØWhat impacts will there be on the Savannah River basin and estuaries, fish and other life?

ØWide-scale, on-going plutonium fuel use, as anticipated by NRC’s creation of new rules that apply to “any plutonium fuel factory anywhere”, implies a return reprocessing of irradiated fuel. Include the environmental and health and safety impacts of full-scale reprocessing OR make it a SITE SPECIFIC ONLY evaluation of MOX fuel on ONLY the 4 Duke reactors.

ØIt is time to consider radiation’s impacts on EVERYONE, including children, born and unborn

The “No Action” Alternative

Environmental evaluations usually compare the action considered, MOX fuel production and use, with alternatives, including “no action.” Since the MOX program is the result of a record of decision by the Department of Energy to pursue a “dual track” for weapons plutonium of both the reactor option – MOX and the waste alternative – known as immobilization, NRC should NOT consider “no action” to be no plutonium disposition, rather, NRC should consider 100% immobilization as the “no action.”

Plutonium Fuel Factory Construction and Operation

ØHandling plutonium is risky business. What experience does NRC have with regulation of weapons-grade plutonium?

ØHas weapons grade plutonium EVER been manufactured into reactor fuel? Has it ever been used in a commercial reactor? Provide this data in the EIS.

ØWhat is the track record of COGEMA? This is vital since DCS plans to lean on COGEMAs design for the factory. What are worker exposures? What is the plutonium content in so-called “low-level” waste from plutonium fuel production? Where will that waste be disposed?

ØWhat are the processes that will impact radioactivity in air and water?

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ØIsn’t the process backwards? Why is the construction of a fuel factory being considered unless the use of the fuel has been approved? What is the possibility that NRC will deny the use of the fuel after already allowing its production?

Regional Transport of Plutonium Fuel 

ØImpact of secret shipments on local emergency crews who still may be first responders

ØComplete accident scenario including fire and also credible sabotage / theft / diversion

ØOK of the US plutonium fuel program will have direct impact on implementation of MOX fuel program in Russia, and Russia plans to sell unirradiated weapons MOX fuel to their trade partners, resulting in very wide distribution of weapons-grade plutonium. Include this outcome in the analysis of transportation impacts of Ok-ing this program.

Use of Plutonium in Duke Reactors

ONLY SITE SPECIFIC EVALUATION OF REACTOR USE SHOULD BE INCLUDED. Any “generic” treatment of reactor use of MOX fuel should be undertaken with a much wider scope to include every US reactor in operation today, and also the specter of new reactors using MOX. Instead, NRC should limit the evaluation to the four Duke reactors that are currently specified in the DOE contract with DCS. If MOX is implemented, and any other reactors are added to the contract in the future, then additional SITE SPECIFIC analysis of those reactors should be done at that time.

ØIn a site-specific analysis of plutonium fuel use, the consequences of station black-out (loss of electric power to the site, and also loss of back-up power) must be evaluated, not dismissed.

ØWhat are the other loss-of-containment scenarios? NRC must include a credible analysis of the impacts, in the event these situations arise, not dismiss them based on a numbers game.

ØWhat is the tolerance level for residual gallium in the fuel? What is the performance level of the nuclear fuel industry in producing to this level of accuracy? What is NRC’s history of regulatory enforcement on faulty fuel cladding such as may be caused by gallium? What are the environment and health consequences of faulty fuel?

ØAn evaluation of the impact of plutonium fuel use on control rod performance, including all DATA from the use of weapons grade plutonium

ØImpacts on rate and types of reactor aging due to use of weapons plutonium fuel, data please!

ØScenarios that contemplate several levels from 25% to 100% MOX fuel in use…including impacts on air and water discharges, curie content of all waste, worker exposures, and source term (projected environmental releases) from both routine and accident scenarios.

Other Impacts

The reactor is NOT THE END POINT!!! The scope of plutonium fuel use must also include impacts on the operations of a variety of other facilities (many of which will also be utilized by the fuel factory as well), including:

ØNuclear laundries

ØNuclear waste storage (pool and casks) and disposal on site

ØNuclear waste transport – irradiated MOX fuel and all process wastes

ØStorage, incineration and disposal off-site of both so-called “low-level” and high-level as well as TRU waste, specifically in relation to the closure of Barnwell to 2 of these reactors

ØDecontamination services

ØOff-site repairs

ØDecommissioning wastes

Each of these should be a SITE SPECIFIC analysis, since Duke’s contracts are known. Each should look at releases of all types to the environment, facility waste streams, worker and pulic exposures and decommissioning.

Southeast office