August 30, 2002
Mike Lesar
Chief
Rules and Directives Branch
Division of Administrative Services
Office of Administration
Mail Stop T-6D59
U.S.
Washington
SUBJECT: NCI COMMENTS ON THE REVISION OF THE NRCS DRAFT
The Nuclear Control
Institute (NCI) has long been concerned about the Department of Energys (DOE)
management of the program to dispose of surplus warhead plutonium. This concern has been reinforced by the havoc
DOE has recently caused by making major mid-course corrections to the program
without careful consideration of the implications of these changes. As a result, millions of taxpayer dollars are
being wasted and multi-year delays continue to occur in carrying out a program
meant to address what the National Academy of Sciences called a clear and
present danger in 1993 --- that is, nine years ago.
A case in point is DOEs
adoption earlier this year of a revised plutonium disposition strategy, which
eliminated one of the two technical approaches for disposition, the
immobilization process, while at the same time proposing a more than 70%
increase in the disposition rate. The
cancellation of the immobilization program, which was to dispose of about
one-quarter of the 34 MT of plutonium committed to under the September 2000
U.S.-Russian Plutonium Disposition Agreement, has raised even more troubling
questions about the viability of the project.
It has also forced the NRC to scrap the Draft Environmental Impact
Statement (DEIS) on the proposed MOX Fuel Fabrication Facility (MFFF) that was
nearly ready to be released, causing a one-year delay in NRCs NEPA process for
the MFFF.
NRC also bears
responsibility for the additional delay, labor and expense associated with a
revision of the DEIS. DOEs intent to
cancel the immobilization program was apparent as early as February 2001, when
it announced that it was suspending the program for ten years or more. In comments on the scope of the original
DEIS, submitted in May 2001, NCI urged NRC to evaluate an alternative in which
the immobilization program were cancelled.[1] NCI recommended that such an evaluation
include an assessment of (1) the impacts on waste generation, worker dose and
accident consequences of augmenting the MFFF polishing unit so that it is
capable of preparing the impure plutonium previously intended for
immobilization to render it suitable for processing into MOX fuel, and (2) the
environmental impacts of the accommodation of more plutonium in the MOX track
through increasing the plutonium loading per reactor, the irradiation time or
the number of program reactors. NRC
ignored these comments and analyzed only the scenario proposed by DCS in its
first Environmental Report (ER). It
should be apparent that had NRC evaluated other options like the one proposed
by NCI, the year-long delay now needed to revise the DEIS could have been
significantly shorter. NRC should keep
in mind the benefits of thinking ahead when evaluating a program subject to
arbitrary and abrupt changes in direction as it identifies the set of
alternatives to be evaluated in the current revision of the DEIS.
1. Immobilization remains a reasonable alternative for plutonium
disposition and must receive full evaluation in the NRC DEIS.
Immobilization of plutonium is demonstrably cheaper,
faster, safer more secure and less of an environmental threat than the MOX
approach. DOE itself has concluded that
immobilization achieves full disposition of 34 MT of U.S. plutonium inventory
at the lowest cost.[2] The sole obstacle to implementation of this
clearly superior technology is the political opposition of entrenched nuclear
bureaucrats in both the
However, one may
expect that the merits of immobilization technology will be better appreciated
by future administrations, both here and in Russia, especially once the
technical difficulties and proliferation risks of implementing the MOX option
become more widely recognized.
Development of the technology was in an advanced state at the time of
its cancellation, and it can be revived as rapidly as it was derailed. Thus immobilization remains a viable and a
reasonable alternative that merits full consideration in the NRC DEIS.
2. The evaluation of the MOX option must consider the disposition of
plutonium previously designated for immobilization that has been stranded by
cancellation of the immobilization program.
Cancellation of the
immobilization program has stranded at least two MT of plutonium of the 34 MT
covered by the U.S.-Russian Agreement without a disposition path, since DOE has
said that the material is too difficult to convert to a form suitable for MOX
fabrication. In addition, at least 8 MT
of weapon-usable plutonium previously designated for immobilization but not
covered by the
3. The assessment of the MOX alternative must fully evaluate new
information about the safety risks associated with the use of MOX fuel.
The additional public
health and environmental risks posed by the substitution of MOX fuel for
uranium fuel in light-water reactors have been well-documented,[3]
but have not been adequately considered in the DOE NEPA documentation to date
on the
NRC has stated that it
intends to consider the use of additional reactors in the MOX program to
accommodate the increased rate of plutonium disposition called for in DOEs
revised disposition strategy. However,
NRC should realize that at least three additional reactors will be required to
dispose of 3.5 MT of plutonium per year without an increase in the MOX core
fraction above the 40% now planned, rather than the two reactors that DOE has
said would be sufficient. Also, NRC must
also consider the distinct possibility that DOE will not be able to locate any
additional reactors willing to accept the costs and risks of MOX use. In such an eventuality, increased disposition
rates could only be accomplished by increasing the MOX core fraction above 40%
in the four Catawba and McGuire reactors already committed to the project. Any increase in the MOX core fraction will
likely require physical modifications to be made to these reactors and will
also be associated with additional safety and environmental impacts. These changes must be evaluated in the DEIS.
Sincerely,
President
[1] E.S. Lyman,
Nuclear Control Institute Comments On The Scope And Content Of The Nuclear
Regulatory Commission Environmental Impact Statement For The Mixed Oxide Fuel
Fabrication Facility, May 21, 2001.
Available at www.nci.org.
[2]
[3]
[4] U.S. NRC, Accident Source Terms for Light-Water Nuclear Power Plants: High-Burnup and Mixed Oxide Fuels, draft, ERI/NRC 02-202, March 2002, p. 50.