Nuclear Information and Resource Service has filed Contentions October 21, 2003 in the proceeding before the Atomic Safety Licensing Board on the matter of whether the US Nuclear Regulatory Commission (NRC) should approve Duke Energy’s application for a license amendment to put 4 test weapons-grade MOX fuel assemblies in the Catawba ice condenser reactors in South Carolina.
The document (16 pages, double spaced) is posted as of 3:00 pm today on the NIRS website, http://www.nirs.org
Please call either Mary Olson 828-675-1792 for comment, or Michael Mariotte, NIRS DC office 301-270-6477
CONTENTIONS OF NUCLEAR INForMATION AND RESOURCE SERVICE
Duke Power has applied to the Nuclear Regulatory Commission to amend the licenses of Catawba 1 & 2 and for exemption from specific regulations in order to test four MOX fuel assemblies, made from weapons-grade plutonium, in one of the two nuclear power ice condenser reactors on Lake Wylie in South Carolina. Nuclear Information and Resource Service (NIRS) and the members we represent oppose this plan for multiple reasons.
Our choice of offering a narrow scope of contentions at this time should in no way be seen to imply that other issues are unimportant. This document reflects overall resource issues, including the recognition that the resources of all parties will be better served with respect to some of our concerns at a future juncture, should Duke Power apply for batch use of MOX fuel.
1. Duke’s proposed plan is lacking key benchmarks
This contention points out the need for Duke to collect and present key data that will help prove in the future that these tests are “representative” of the US made weapons-grade MOX fuel they plan to load, as soon as 2008 at 40%. Currently they have no plan to collect key data that will be needed to make their case that safety issues will have been bounded.
2. Provisions for Irradiated MOX Test Assemblies
There are many reasons to doubt that MOX high-level waste (irradiated fuel) will hold up (structurally) as well as irradiated uranium fuel. We ask them to plan for this, and also its transport since it will have different heat and criticality (ability to start fission process again) profiles as well.
3. Duke’s License Amendment Underscores Regulatory Gap Between NRC and DOE: Duke’s License Amendment Precedes The Department of Energy’s Fulfillment of It’s Responsibility Under the National Environmental Policy Act. Only the No Action Alternative is Consistent with the Overall Goal for Plutonium
This points out that DOE has not done an EIS on sending the test plutonium (300 pounds) by land and water to France.
4. Only the No Action Alternative is Consistent with the Overall Goal for Plutonium
A lengthy case is made for the fact that MOX does not fulfill the stated goal to prevent nuclear weapons proliferation in the world, supported by a number of authorities.
5. An Environmental Impact Statement is Needed to Inform This Decision
A history of the fact that no environmental impact statement has yet included the people of North and South Carolina on the issue of use of weapons-grade plutonium in Duke reactors is given and the case for focussing such an analysis on our children.
Director of the Southeast Office
Nuclear Information and Resource Service