April 9, 1999
Nuclear Control Institute Comments on the
Department of Energy's Notice of Intent to
Prepare an Environmental Impact Statement for
Electrometallurgical Treatment of
Sodium-Bonded Spent Nuclear Fuel
1. The proposed structure of the Environmental Impact Statement as described in the Notice of Intent is inconsistent with DOE's approach to spent fuel management at other sites and prematurely promotes a preferred option for managing sodium-bonded spent nuclear fuel.
By presuming that the proposed action is electrometallurgical treatment (EMT) of the sodium-bonded spent nuclear fuel (SNF) inventory, the proposed structure of the EIS effectively establishes this treatment as the preferred alternative for stabilization of this material. While alternatives will be considered, they are clearly relegated to second-rank status, and the language in the NOI, as well as the National Research Council (NRC) analysis to which the NOI refers, strongly suggests that these alternatives have already been ruled out.  While it is reasonable to rule out obviously impractical alternatives in the scoping process, several of the alternatives described in the NOI are technically viable and should not be prematurely dismissed. This approach is highly prejudicial and inconsistent with DOE's policy for managing other types of metallic SNF, such as N-Reactor fuel at Hanford and aluminum-clad research reactor fuel at the Savannah River Site (SRS).
For example, the EIS on spent nuclear fuel management at SRS asks the question "What is the best approach for managing aluminum-clad SNF at SRS and what actions are necessary to implement that approach?" All reasonable alternatives are initially considered on an equal footing, and the discussion of issues such as the relative maturity of the different options is appropriately conducted in the EIS. The SRS SNF EIS was structured in this way even though a treatment option exists that is clearly more mature than the proposed alternatives --- namely, PUREX reprocessing. In fact, despite being relatively immature, a non-reprocessing alternative (melt-and-dilute) was selected in the SRS SNF EIS as the preferred option for most of the aluminum-clad SNF at SRS, because of both environmental and non-proliferation advantages. 
DOE therefore cannot logically defend the present structure of the NOI for sodium-bonded SNF by arguing that electrometallurgical processing should receive main consideration because it is the most mature option, even if it were clear that this is the case (which it is not). We therefore strongly suggest that the NOI be recast in a manner similar to that of the SRS SNF EIS, so that it poses the question "What is the best approach for managing sodium-bonded SNF in Idaho and what is necessary to implement that approach?" This would remove the prejudicial aspects of the current NOI and provide more confidence to the public that the alternatives will be evaluated fairly.
Additionally, announcement of the NOI at this time is premature. The current research and demonstration project, as well as both DOE and NRC assessments of the project, should have been completed before commencement of the EIS process. Moreover, research on selected alternatives should also have been carried out to support a defensible analysis of their feasibility in the EIS. We therefore question the issuance of the NOI at this time and believe that it should be withdrawn pending compilation of all the technical documentation necessary to inform the scoping process.
2. The technical distinction between high-burnup driver and low-burnup blanket elements should be more clearly presented, and the management and disposition of the two types of material should be evaluated separately.
The chief justification for the necessity of electrometallurgical processing of sodium-bonded spent fuel is the presence of elemental sodium in the fuel elements, which according to some statements would preclude direct disposal of this material in a geologic repository. However, the NOI does not make clear the fact that the severity of this problem is dramatically different for driver and blanket fuel elements. As discussed in the Environmental Assessment (EA) for the EMT demonstration project, it is only in the high-burnup EBR-II driver elements that elemental sodium diffuses to a significant extent into the fuel meat, and becomes difficult to mechanically remove. 
This is not the case for the low-burnup blanket elements.  In the 1980s, 17 MTHM (7000 rods) of declad EBR-II blanket fuel were declad with a laser at a California facility. These rods were so thoroughly cleaned of elemental sodium with alcohol that DOE has proposed reprocessing them in H-Canyon, which cannot tolerate even low levels of elemental sodium in its dissolvers.  Similarly, the level of residual sodium after this relatively simple treatment most likely would not be a problem for direct disposal.
Any argument for processing, as opposed to direct disposal, of sodium-bonded spent fuel can therefore only be made for the sodium-bonded driver fuel. Blanket fuel can be mechanically declad and stripped of elemental sodium without the need for dissolution and separation of the solid fuel. Furthermore, to our knowledge DOE has not even demonstrated that there is a safety-based need to process the driver fuel by experimentally assessing the actual impact of elemental sodium on radionuclide leach rates. Even if the sodium-bonded driver fuel is more reactive than other types of SNF under repository conditions, the relatively small amount of such fuel (less than 0.01% by weight of the total repository inventory) would make a negligible contribution to overall radionuclide release from the repository.
While the minimal discussion of this in DOE documents stresses the technical difficulties of this approach (such as the contamination of the sodium by cesium), it is extremely hard to believe that the difficulties, costs and risks of such minimal processing would be greater than those incurred by EMT of the fuel, which requires bulk dissolution at high temperature and the separation of the fuel into at least three waste streams. According to the EA on the EMT demonstration project, the amount of Cs-137 contaminating the sodium in blanket assemblies is less than 4% of the total Cs-137 content and less than 1% of the total activity. 
It is difficult to understand DOE's argument that the mechanical decladding option is not as mature as EMT, since it was employed for fifteen times as many blanket rods as those that will ultimately processed during the EMT demonstration. Moreover, because the blanket fuel contains depleted uranium metal, the non-proliferation argument invoked to justify EMT and blend-down does not apply either.
Robert Benedict of Argonne National Laboratory (ANL)-West claimed at the DC public scoping meeting that none of the documents pertaining to wastes generated by the mechanical decladding campaign can be located. Such mismanagement, if true, is of concern and should be investigated. We request that a greater effort be undertaken to find these documents and make them publicly available during the EIS comment period. In any event, their "loss" surely does not support DOE's argument that mechanical decladding is a new and unproven technology.
Both DOE and NRC underplay the significance of the mechanical decladding of 17 MTHM of blanket fuel (NRC even refers to this material as a "small amount" even though it is 75% of the existing EBR-II blanket inventory). This is only one example of the loaded language in the NOI and its reference documents that strongly suggests that the mechanical decladding alternative is not being fairly evaluated.
Despite the crucial distinction between the blanket and driver fuel, the NOI does not even mention how the 26 MTHM of EBR-II spent fuel and 36 MTHM of other sodium-bonded spent fuels is distributed among these two groups. Such information ---- for example, that 22.4 MTHM of the 26 MTHM of EBR-II fuel, as well as the entire 35 MTHM of Fermi-I sodium-bonded fuel, is actually blanket fuel --- obviously could severely undercut DOE's justification for the costly development of EMT processing.
Therefore, it is essential that the inventories and technical distinctions between driver and blanket sodium-bonded SNF be clearly articulated and that the disposition pathways for these materials be separately evaluated as distinct material categories. We request that this approach be built into the forthcoming EIS.
3. DOE should initiate a process similar to the Processing Needs Assessment (PNA) to determine at the earliest possible date the "small quantities of certain spent fuels" that may be considered for electrometallurgical treatment in the future. Such an effort is essential for shutdown and decommissioning planning purposes.
The history of the EMT program demonstrates clearly that it always has been a technology in search of a mission. EMT technology has been discussed in the past (and in some cases continues to be discussed and actively researched) for disposition of excess weapons plutonium, N-Reactor SNF, K-Basin sludge, Hanford single-pass reactor SNF, Al-clad SNF, Fast Flux Test Facility (FFTF) fuel, Three Mile Island-2 core rubble and commercial oxide SNF, despite the fact that this technology is inappropriate for most of these materials unless they undergo substantial pretreatment.
While the NOI states that "the Department has no plan or intention to apply this technology to any other types of spent nuclear fuel," it clearly leaves the door open for other applications and raises the concern that ANL-West will continue to actively hunt for other materials that can be used to keep the EMT apparatus operating after the sodium-bonded fuel campaigns are completed, or even to justify construction of new facilities.
This open-ended approach is of concern because of its severe implications for non-proliferation. Although the current sodium-bonded SNF campaign has been extensively modified to reduce (but not eliminate) proliferation concerns by skipping the plutonium extraction stage, the application of EMT for many of these other materials raises other proliferation issues. Of greatest concern is the continuing drive to adapt EMT for treatment of oxide SNF, including commercial fuel, which requires development of an oxide reduction process. DOE is well aware of support among some legislators for halting development work at Yucca Mountain in favor of attempting to develop an accelerator transmutation system that uses EMT as a pretreatment process for commercial SNF. Such an approach to commercial SNF management is counter to the U.S. policy of direct disposal.
The EMT process can be modified to produce separated plutonium, as a 1992 study conducted for DOE has concluded.  Moreover, there are no plans to place ANL-West facilities under international safeguards. Therefore, from an arms control standpoint (i.e. in the context of a future ban on production of fissile materials outside of safeguards), the FCF must be regarded as a dual-use facility capable of being operated as a reprocessing plant. In view of this, it is highly advisable to plan now for timely shutdown of the facility when any campaigns for which it is determined to be essential (if any) are completed. DOE must therefore act now to establish a firm timeline for shutdown and decommissioning of FCF and any associated facilities. One way to do this is to conduct a study similar to the 1997-1998 Processing Needs Assessment (PNA). The PNA sought to identify all materials in the DOE complex which might need reprocessing in the SRS canyons for stabilization purposes, thus limiting the universe of potential uses for the canyons and facilitating planning for their shutdown. A similar process should be conducted for the FCF as part of the EMT EIS process, with the opportunity for full public participation and comment.
4. DOE should make the non-proliferation assessment of the proposed EMT action a part of the NEPA process. The assessment therefore should be available in draft form for public comment prior to completion of the NEPA action. The assessment should cover not only the proposed action but the broader proliferation implications of continued research and development of this reprocessing technology.
In view of the serious proliferation issues associated with EMT development discussed above, it is essential that DOE's non-proliferation assessment of EMT technology be available for full public review and comment prior to closure of the EIS comment period. Members of the public can provide information and independent perspectives on these issues and should have the opportunity to contribute these to DOE's assessment. Like other documents essential to informed decision-making, the non-proliferation assessment should be done as part of the NEPA process and not outside of it.
One issue which should be covered in the non-proliferation assessment is whether promotion of EMT as a "proliferation-resistant" technology ultimately will prove harmful to U.S. non-proliferation goals. Claims of proliferation resistance may be used to permit widespread dissemination of EMT without any of the restrictions now applied to conventional reprocessing technology. However, if the designation does not have a sound technical basis (as we believe it does not), the ultimate result will be a increased danger of proliferation.
It may become difficult for the U.S. to deny so-called "proliferation-resistant" technologies to nations (like South Korea) that have long desired to reprocess their LWR SNF but have been blocked from doing so because of proliferation concerns. Also, for nations that now reprocess spent fuel, switching to EMT may enable them to argue that their current safeguards burden be relaxed. The proliferation implications of widespread introduction of EMT under these conditions must be carefully evaluated.
Edwin S. Lyman, PhD
The author would like to acknowledge the contributions of Nuclear Control Institute Executive Director Tom Clements and Research Director Steven Dolley in preparation of these comments.
1. The NOI refers to the conclusions of an assessment by the National Research Council (NRC) that "significant research, development and demonstrations would be required to develop these alternative treatment processes to the level of technical maturity of the electrometallurgical treatment process for sodium-bonded spent fuel." To our knowledge, this assessment was based on information provided in a single two-day briefing of the NRC panel by DOE. We do not believe that the NRC's review of alternative technologies was conducted with a depth sufficient to reach any conclusions regarding their feasibility.
2. Of course, restructuring the EIS format will not guarantee consistent selection of the best alternatives. NCI strongly questions the choice of conventional reprocessing as the preferred alternative for treatment of the 17 MTHM of declad EBR-II blanket SNF now stored at SRS, and does not believe non-reprocessing options were adequately explored.
3. U.S. Department of Energy, "Environmental Assessment for the Electrometallurgical Treatment Research and Demonstration Project in the Fuel Conditioning Facility at Argonne National Laboratory-West," DOE/EA-1148, May 15, 1996, p. 7.
4. The argument is also not applicable to the 3.9 MTHM of driver fuel from the Fermi-1 plant, which is not sodium-bonded and apparently will not be considered under this EIS.
5. R. Frazier and D. Campbell, "Production Decladding of Irradiated Fuel Assemblies Using a YAG Laser," Proceedings of the 35th Conference on Remote Systems Technology, 1987.
6. DOE/EA-1148, op cit., pp. 6 and 18.
7. R. Wymer et al., "An Assessment of the Proliferation Potential and International Implications of the Integral Fast Reactor," K/ITP-511, Martin Marietta Energy Systems, May 1992, p. 82.
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