January 23, 2001

 

Ms. Linda J. Keen

President and CEO

Canadian Nuclear Safety Commission

280 Slater Street

P.O. Box 1046

Ottawa KIP 5S9

Canada

 

Dear Ms. Keen:

 

The undersigned groups call on the Canadian Nuclear Safety Commission (CNSC) to suspend the Parallex mixed oxide (MOX) plutonium fuel qualification tests scheduled to begin this month at the Atomic Energy of Canadas (AECL) Chalk River Nuclear Laboratorys National Research Universal reactor (NRU). We call for this suspension because serious concerns have recently surfaced about potential problems with quality assurance of the plutonium fuel pellets to be tested in the NRU. We feel strongly that the fuel, fabricated at the U.S. Department of Energys (DOE) Los Alamos National Laboratory (LANL), must undergo a thorough quality assurance inspection prior to use in the NRU reactor. The inspection must involve a thorough review of Los Alamos quality assurance documents and full non-destructive and destructive analysis of the Parallex pellets by AECL, with all data immediately and fully available to the public.

 

The CNSC must take action immediately because the test-burn of MOX fuel pellets containing both U.S. and Russian weapons-grade plutonium is scheduled to begin soon. According to the test plan prepared by Oak Ridge National Laboratory (ORNL)--DOEs lead laboratory for plutonium fuel use in nuclear reactors--Parallex is designed to qualify MOX fuel for use in Canadian Deuterium-Uranium (CANDU) nuclear reactors, and to demonstrate the infrastructure involved in the disposition of excess weapons plutonium as MOX fuel in reactors.[1] So Parallex is more of a fuel qualification exercise than a test.

 

However, ORNL reported in December 2000 that it had discovered problems with similar experimental MOX fuel pellets DOE used in the Idaho National Engineering and Environmental Laboratorys (INEEL) Advanced Test Reactor (ATR) as part of the U.S. plutonium disposition program. ORNL reported that the pellets--fabricated at Los Alamos, irradiated at the ATR, and then examined by ORNL--contained numerous plutonium-rich agglomerates...up to 500 microns in size and unevenly distributed.[2] This evidence suggests that Los Alamos initial characterization of these pellets was inaccurate and flawed. Since ORNL only found out about the quality assurance problems upon discovering unanticipated irregularities after irradiation, the Canadian authorities should be wary of mistakes made by the U.S. Department of Energy.

The presence of such large agglomerates in the fuel could lead to safety problems during the test irradiation that would not have been accounted for in whatever safety analysis AECL had to do to approve the Parallex tests. Plutonium oxide uniformity in MOX fuel, called homogeneity, is a critical issue for plutonium fuel use in CANDU and other reactors. According to the ORNL test plan, large plutonium oxide-rich areas could effect the burnup threshold where increasing gas release begins or could produce hot spots on the cladding. According to Los Alamos, issues associated with very large plutonium oxide agglomerates include hot particle ejection and overpower reactivity insertion, therefore Los Alamos sought to keep mean plutonium oxide agglomeration size to less than 40 microns.[3] The presence of agglomerates as large as 500 microns in size means that in the event of an overpower transient, severe cladding failures and fuel dispersal could occur. If this were to occur on a large scale with a full CANDU core loading, it could possibly result in loss of coolable geometry, fuel-coolant interactions and pressure pulses which could conceivably bring about a core melt and massive radionuclide release.

 

According to the ORNL test plan, the first bundle of plutonium fuel in the CANDU fuel qualification effort was to contain a highly homogeneous mix of MOX fuel. It is unlikely, given LANLs documented inability to make highly homogeneous fuel for the Advanced Test Reactor, that the U.S. MOX fuel sample already sent to Chalk River meets the specifications for the fuel qualification test.

 

Other evidence supporting suspension of this project pending inspection and analysis of the plutonium fuel includes:

 

         In 1998 Los Alamos fabricated fourteen batches of MOX test fuel pellets for the ATR High Power Test (HPT) that failed to meet technical specifications and/or were characterized by unacceptable end capping, cracking on top, and bubbling when submerged in alcohol.[4]

 

         In 1996 Los Alamos fabricated an unspecified amount of MOX fuel pellets for the CANDU MOX fuel qualification program that did not meet the required specifications...because of cracks and chips on the final sintered pellets.[5]

 

         In 1999 Los Alamos admitted that its difficulty fabricating suitable MOX fuel was "complicated by the aging of the fuel fabrication equipment." The lab used four 20-year-old presses to fabricate MOX fuel, and in 1999 two of these presses were so worn that LANL reported they may no longer operate smoothly enough to produce good [MOX] pellets."[6] What was the condition of the equipment when the CANDU fuel was made?

 

         In November 2000 the U.S. National Academy of Sciences reported that the CANDU MOX fuel option will not meet the so called spent fuel standard which is supposed to insure security of the plutonium remaining in the used fuel.

 

All told, the Los Alamos MOX fuel fabrication experience has been substandard and the fuel manufactured by Los Alamos is unlikely to represent typical plutonium fuel that would be used in CANDUs. If the test fuel is not representative of the potential mission fuel because of the probable presence of large agglomerates and the nontypical methods used to fabricate the test fuel, the Parallex tests would provide no useful information and therefore would be worthless with the present fuel batch. Finally, given the experience with scandalous falsification of quality assurance records for plutonium fuel fabricated by British Nuclear Fuels, Ltd. (BNFL) and shipped for use in Japan, a rigorous review of quality assurance records is warranted at this time. Otherwise, the credibility of the CNSC and the entire Canadian nuclear program may be severely damaged.

 

No information has been publicly revealed about the quality of the Russian MOX fabricated at the Bochvar Institute in Moscow and also scheduled to be tested in the NRU reactor. We believe that prudence dictates that the quality assurance history for this fuel also be established. Underscored by the fact that use of Russian-fabricated MOX in the NRU reactor is a first, we believe it essential that the CNSC direct that this fuel also be fully examined to ensure that it meets the standards established by AECL and DOE. Just as for the LANL MOX review, information on the Russian MOX should be made public.

Based on the information available from Los Alamos and ORNL , which we urge you to obtain from the DOE, we call on the CNSC to exercise whatever authority it has to halt the Parallex test. We recommend that the CNSC require AECL to provide a full report on the quality of the fuel awaiting irradiation and that such document be made public. Due to the concern in Canada and the US over using weapons-grade plutonium fuel in nuclear reactors, we request that actions taken by the CNSC on this matter be made public.

 

Signed,

 

Don Moniak

Community Organizer

Blue Ridge Environmental Defense League

P.O. Box 3489

Aiken, SC

U.S.A.

803-644-6953

Tom Clements

Executive Director

Nuclear Control Institute

Washington, D.C.

U.S.A.

202-822-8444

 

 

Dr. Gordon Edwards, President

Canadian Coalition for Nuclear Responsibility

C.P. 236 Succursale Snowdon

Montral, Qubec

Canada

H3X 3T4

 

Kristen Ostling

National Coordinator

Campaign for Nuclear Phaseout

412-1 Nicholas Street

Ottawa, Ontario

Canada

K1N 7B7

 

 

Irene Kock, Research Consultant

Sierra Club of Canada

Box 104

Uxbridge, Ontario

Canada

L9P 1M6

 

Kay Cumbow

Citizens for a Healthy Planet, and

Citizens for Alternatives to Chemical Contamination

8735 Maple Grove Road

Lake, MI 48632

U.S.A.

 

Dave Taylor, Spokesperson

Concerned Citizens of Manitoba

c/o 674 Riverwood Ave.

Winnepeg, Manitoba.

Canada

 

Glenn Carroll, Coordinator

GANE - Georgians Against Nuclear Energy

P.O. Box 8574

Atlanta, Georgia

 

Michael J. Keegan

Coalition for a Nuclear Free Great Lakes

P.O. Box 331

Monroe, MI 48161

U.S.A

 

Corrine Carey, Board Member

Don't Waste Michigan

c/o 2213 Riverside Dr. NE

Grand Rapids, MI 49505

U.S.A.

 

Keith Gunter

Citizens' Resistance at Fermi Two

P.O. Box 463

Monroe, MI 48161

U.S.A.

 

Pat Ortmeyer

Field Director for Nuclear Issues

Women's Action for New Directions

Missoula, Montana

 

Ole Hendrickson, Researcher

Concerned Citizens of Renfrew County and Area

P.O. Box 981

Pembroke, Ontario K8A 7M5

 

 

 

Susan Gordon, Director

The Alliance For Nuclear Accountability

Seattle, WA

U.S.A.

 

Jay Coghlan, Director

Nuclear Watch of New Mexico

SanteFe, NM

U.S.A.

 

Greg Mello, Director

Los Alamos Study Group

SanteFe, NM

U.S.A.

 

Martin Forwood

Cumbrians Opposed to a Radioactive Environment (CORE)

98 Church St, Barrow

Cumbria LA14 2HJ.

United Kingdom

 

Roger Voelker, staff

Citizens Action Coalition of Indiana

5420 N. College Ave., Suite 100

Indianapolis, IN 46220

 

Harry Rogers, Board of Directors

Carolina Peace Resource Center

Columbia, SC

 

Michael Mariotte

Nuclear Information & Resource Service

World Information Service on Energy / Amsterdam

1424 16th St. NW Suite 404

 

Fran Macy, Director

Center for Safe Energy

Berkeley, CA

 

 

Damon Moglen

Greenpeace International

702 H Street, NW

Washington, DC 20001

 

 

 

 

 

Anne Adelson

Nuclear Issues Circle

Canadian Voice of Women for Peace

203-761 Queen St.East

Toronto, ON CANADA

Brennainn Lloyd

Northwatch

Box 282

North Bay, Ontario

Canada

P1B 8H2

 

Theresa McClenaghan, Counsel

Canadian Environmental Law Association

Suite 401 517 College Street

Toronto, ON M6G 4A2

 

cc: The Honourable Jean Chrtien, Prime Minister of Canada

cc: Ralph Goodale, Minister of Natural Resources

cc: Stockwell Day, Leader of Canadian Alliance Party

cc: Gilles Duceppe, Chef du parti Bloc Qubecois

cc: Alexa McDonough, Leader of New Democratic Party

cc: Joe Clark,Leader of Progressive Conservative Party

cc: Secretary of Energy Spencer Abraham

cc: Laura Holgate, DOE Office of Fissile Materials Disposition