May 8, 2001 Charlotte, North
Carolina U.S. Nuclear Regulatory Commission Scoping
Hearing For the Preparation
of an Environmental Impact Statement To Inform NRC Decision on Whether to
License a Tax Funded Proposal to Produce Weapons Grade Plutonium Fuel for Use in
Duke Power's Catawba and McGuire Nuclear Power Reactors
I would like to thank the Nuclear Regulatory Commission for responding
to the efforts of people in North Carolina to be directly heard in the
process of NRC's decision on whether to license the production, and use
of weapon's grade plutonium fuel in Carolina nuclear power reactors. We
were distressed that the Department of Energy's decision to promote
their tax-funded program for surplus weapons grade plutonium did not
include any public hearings in our communities, which are so directly
impacted by this new government plan, if implemented.
Since the Nuclear Regulatory Commission has the authority and
responsibility for protection of public health, safety and our
environment, I would like to underscore some reasons that the
no-NRC-action (denial of any license for the use of plutonium as a
fuel), would best serve your mandate for such protection.
First, I would like to remind the Nuclear Regulatory Commission and all
present that the question of a license to change the type of fuel used
in these commercial nuclear power reactors is NOT strictly a business
decision by Duke Power. To the contrary, the "customer" paying the bills
for this program is all of us, the taxpayers.
Global non-proliferation and national security needs have been given as
justification for taking on the additional risks and expense associated
with plutonium fuel. These dimensions also clearly extend this decision
far beyond the Duke Board Room. The increased risks and real questions
about whether plutonium fuel would actually serve the goal of reducing
global nuclear weapons dangers are worthy of our attention, our comments
and our involvement in this overall process.
Since there is an approved alternative for what to do with plutonium -
known as immobilization - these comments are not to be taken to imply
that we should do nothing with this surplus plutonium. Rather, they are
offered in the context of NRC's decision, which is limited to the
licensing step for plutonium fuel production and use.
Making weapons grade plutonium into a commodity for commercial trade is
just not a very credible way to safeguard it from falling into the
"wrong hands." In the age of the Internet and the free-flow of
information, nuclear non-proliferation depends in large part on the
control of weapons-usable nuclear materials. Until the plutonium fuel
has been used in the reactor, it can still easily be reused for a bomb.
Each assembly of plutonium fuel could theoretically produce 8 nuclear
weapons. It has already been reported that Russian plutonium fuel
produced in the twin fuel program under US/Russian accords, may be
exported to their nuclear client nations, including countries like Iraq
and North Korea. How will the US plutonium fuel Program limit this
delivery of weapons-usable material to these states that have been
hoping for entry into the "nuclear club?"
Indeed, the transportation of new, unused weapons-grade fuel in the
Southeast is a real vulnerability of the US program. Asheville is not on
the route between the Savannah River Site where the fuel would be made
and the Duke reactors, but many other Carolina towns and cities are. On
the other hand, Asheville could be directly impacted if there were to be
even an unsuccessful attempt at diversion of one of these shipments, if
it were highly publicized. Certainly any shipping accident - and there
will be between 430 and 650 shipments (depending on the number of rods
per shipment) over the duration of the program - would not only have
immediate impacts on those whose health and safety are at risk, it could
also impact public perception of this area. The possibility of adverse
consequences on tourism and seasonal residence, so vital to the economy
of Western North Carolina, are very real.
In addition to these factors, the proximity of Asheville to McGuire and
Catawba nuclear power stations raises very real public health and safety
concerns. There is no previous experience using weapons grade plutonium
in commercial nuclear reactors. While it is known that indeed, any
plutonium, including reactor grade can be used to make at least a
primitive nuclear bomb, it is really not known if bomb-grade plutonium
can be safely used in a reactor. While the NRC assures us that a margin
of safety will be preserved, it is rather incredible that the very first
test in the US will be in the Duke reactors. There is no pilot program
planned, or rather, we are it.
Members of the NRC's own Advisory Committee on Reactor Safeguards,
composed of acknowledged experts have stated that there will be
"criticality headaches" at every step of the way, since the
characteristics of plutonium are very different from uranium. Further, a
member of this same committee --Dr. Dana A Powers - has raised specific
concerns about the "vulnerable containment" of Duke's four reactors.
They are of a rare ice-condenser design, which lacks the huge reinforced
concrete containment domes that other reactors designed by Westinghouse
feature. What possible justification would NRC have, under the mandate
of protection of public health, safety and our environment, to license
reactors which are already known to have a higher level of risk in the
event of catastrophic accident to use fuel which is completely
experimental, and known to be more difficult to control. This is
particularly startling since plutonium fuel is more deadly than uranium.
What possible justification can there be for further jeopardizing this
beautiful region and the lives of so many?
This program would also nearly insure the extension of the license of
the Duke reactors since the program would extend beyond the current
operating licenses of Catawba and McGuire. There are significant aging
factors at these sites, which deserve evaluation without the pressure of
the plutonium disposition program.
As a public official who takes my role and responsibility to my community
very seriously, I urge you to take all of these factors into
consideration and refrain from licensing this very risky, ill-advised
program.