September 18, 2000


Ms. Colette E. Brown, Document Manager

Office of Space and Defense Power Systems (NE-50)

Office of Nuclear Energy, Science and Technology

U.S. Department of Energy

19901 Germantown Road

Germantown, MD  20874


Re:  Comments on Draft PEIS for Isotope Production and FFTF


Dear Ms. Brown,


Following are comments on the DOE’s Draft Programmatic Environmental Impact Statement for Accomplishing Expanded Civilian Nuclear Energy Research and Development and Isotope Production Missions in the United States, Including the Role of the Fast Flux Test Facility.


1.  The Final NI PEIS must fully present and clarify U.S. policy concerning supply of medical isotopes.


While recommendations have been made by certain committees that the Department of Energy (DOE) assess national needs for isotope production for medical and research needs,  the Draft PEIS fails to address exactly what the current U.S. policy is concerning medical isotope supply.  While the Draft PEIS implies that development of an indigenous supply of isotopes is the goal, the current U.S. policy appears to place reliance on foreign sources of certain isotopes and to actively work with producers of such isotopes to meet U.S. needs.  As foreign supply of medical isotopes to the U.S. will continue and as new foreign sources could be realized, the Final NI PEIS must accurately spell out how U.S. policy relates to both foreign and domestic supplies.


Recent ambiguity by DOE in implementing a decision concerning medical isotope production highlights the lack of clarity in U.S. policy concerning foreign isotope production for U.S. consumption.  In 1996, the DOE issued a Record of Decision announcing that the Annular Core Research Reactor (ACRR) located at Sandia National Laboratory would be the sole producer of molybdenum-99 and might be called on to produce iodine-125, iodine-131, and xenon-133.  This decision was made after completion of an EIS and, according to a 1996 news release from Sandia, after “Congress requested that DOE develop a reliable domestic source of moly-99.”  This project has never been carried out and it appears that a program “to make Sandia the sole U.S. producer of molybdenum-99” has been postponed.  Thus, DOE appears to have made a decision at this time not to foster domestic competition with reliable foreign moly-99 producers.


Given DOE’s earlier interest in the ACRR for medical isotope production a discussion of the status of use of this reactor for the isotope mission must be included in the Final PEIS.   


2.  The Draft NI PEIS ignores foreign supply of medical isotopes for U.S. needs.


The Draft PEIS fails to examine what quantity of foreign isotopes currently meet U.S. demand and what the foreign supply is anticipated to be in the future.  Supply of isotopes from Canada is of special note.  As DOE is well aware, the Nuclear Regulatory Commission (NRC) recently issued an export license to Canadian entities for U.S.-supplied highly enriched uranium (HEU) to produce molybdenum-99 for the U.S. market.  MDS Nordion, a Canadian company, and Atomic Energy of Canada Limited (AECL) received an export license on July 27, 2000, and in the NRC’s Staff Requirements Memorandum issued on that day, the NRC reflected the importance of the Canadian source of moly-99 by stating that “the Commission was sensitive to the importance of maintaining an uninterruptible supply of medical isotopes.”  In oral testimony before the NRC on at least two occasions in the past 2 years and in various written submissions, officials from the U.S. State Department expressed strong support for such export in order to ensure isotope production for U.S. needs.  At no time in the license review process has either the NRC or the State Department questioned the reliance on a foreign source for this critical isotope supply as being contrary to U.S. policy. 


DOE’s own Argonne National Laboratory is integral in helping Nordion and AECL to meet the requirements of the Schumer Amendment in converting two medical isotope production reactors at AECL’s Chalk River Laboratory from HEU targets to LEU targets, an effort strongly supported by the Nuclear Control Institute (NCI).


Other foreign producers of medical isotopes exist and other sources might be developed yet the Draft PEIS has failed to review the potential of any of these sources to fill U.S. isotope demand.  In order to fully address the need for DOE to guarantee that the necessary supply of isotopes is achieved will require an assessment of foreign supply as well as domestic supply.  As the Nuclear Energy Research Advisory Committee has addressed the need for “dependable” sources of isotopes, it is incumbent on DOE to assess foreign supply as foreign sources could well prove to be dependable and cheaper than U.S. sources.


For more information on the NCI’s involvement in the issue of medical isotope production and intervention with the NRC concerning the export HEU to Canada for isotope production, go to our web site at   


3.  The Draft PEIS fails to review current production of each medical isotopes and projected need of each isotope.


The Draft PEIS assumes that needs for medical isotopes will grow in the future but has not quantified the specific demand nor provided any details about such growth in demand.  Statements in the Draft PEIS are speculative and not backed up by any actual data.  Without quantifying actual demand of each isotope and projected future demand, the Draft PEIS presents a weak case for isotope production needs.


Along with presenting a much clearer picture of present and future isotope demand, the Final PEIS should clarify exactly which isotopes are being considered for production and in which specific facility they would be produced.  In the Draft PEIS, a list of possible isotopes is presented and the reader is left with no way to determine which isotopes on the list will be actually produced.  


4.  The Final NI PEIS must fully explain how closed test loops and assemblies in FFTF will be cooled and how production of specific isotopes is compatible with either open or closed loops in FFTF.


Appendix C of the PEIS briefly discusses open- and closed-loop in-reactor irradiation assemblies but does not specify the coolant used with the closed loops.  As contact with liquid sodium by some targets must be avoided, closed loops with non-sodium coolant must be used.  As irradiation of targets to produce isotopes has health and safety implications, the PEIS must discuss which isotopes which can be produced by which type of loop, what type of coolant is used in the closed loops, and which isotopes are capable of being produced by which production method and in which facility. 


Likewise, the Draft PEIS does not specify in any detail the different production characteristics in the core versus the reflector of the reactor.  As some isotopes, such as molybdenum-99, are produced by fission, and other isotopes are produced by neutron absorption, the PEIS must specify how each isotope is produced and whether such production is feasible in FFTF.  If the reactor must be modified in order to produce certain isotopes a full discussion of such modification must be included in the PEIS.


Also, if the FFTF must be modified to allow for certain research testing, such as the addition of a lead-bismuth loop for testing associated with Accelerator Transmutation of Waste (ATW), there must be a full discussion of such modifications and associated health, safety and nonproliferation implications.


5.  The Final PEIS must discuss production of plutonium-238 for any defense uses.


The Draft PEIS avoids any discussion whatsoever of the use of plutonium-238 by defense and intelligence agencies.  As plutonium-238 is apparently used in communication and detection devices used by the U.S. Navy, any possible production in FFTF and the other reactors for defense use must be discussed in the PEIS.  As no such discussion has taken place in the Draft PEIS one must assume that DOE has ruled out further plutonum-238 production for defense purposes.


It is believed that plutonium-238 is used in the Navy’s Sound Surveillance System (SOSUS),  which consists of hundreds of sea bed monitors   It is also known that the Navy has placed terrestrial devices containing Radioisotopic Thermoelectric Generators (RTGs), which contain plutonium-238, at remote locations for powering instrumentation. 

6.  Import of the SNR-300 (Kalkar) MOX fuel for use in FFTF has negative non-proliferation implications which must be considered in the Final PEIS.


In addition to security issues raised with trans-oceanic shipment of the SNR-300 fuel, which will require a armed escort due to the fact that such fuel contains weapons-usable plutonium, use in a fast reactor in the U.S. will rule out disposal with fewer proliferation implications.  Immobilization of the SNR-300 fuel into high-level nuclear waste in Germany presents fewer proliferation risks than shipment to the U.S., but it appears that DOE has ruled out this option with no discussion.  The SNR-300 MOX presents a perfect opportunity for demonstration in Europe of immobilization of MOX pellets using the can-in-canister approach.  Demonstration of such immobilization will have far-reaching implication in Europe for the massive plutonium stockpiles which continue to build up-- contrary to the Clinton Administration’s 1993 non-proliferation policy--at French and British reprocessing factories and for which no credible plan for use exists.


7.  The Final PEIS must look at waste stream for remanufacturing any Kalkar MOX which might be used in FFTF.


The Draft PEIS does not discuss the waste stream which would arise from disassembly of the Kalkar MOX and reassembly in FFTF assemblies.  Likewise, the document is not specific as to where such handling would taking place.


8.  The Final PEIS must examine all health and safety issues associated with using old FFTF and Kalkar MOX.


As the FFTF and Kalkar MOX are more than ten years old, such things as build up of radioactive decay products such as americium and development of helium pockets due to alpha decay must be discussed in the Final PEIS.  The physical condition of the fuel after so many years of storage, due both to radiation influences and fabrication methods, must be included in the PEIS.


While the Nuclear Control Institute made scoping comments concerning quality control

issues related to fabrication of the FFTF and Kalkar MOX, there was no discussion of this important matter in the Draft PEIS.  The Final PEIS must discuss this matter and present evidence that the fuel will indeed meet current DOE fabrication and safety standards and will not present any health or safety risks outside current standards when used in the reactor. 


9.  The Final PEIS must clearly state plans for final disposition of any imported MOX fuel.


The Draft PEIS neglects to clarify if the irradiated Kalkar MOX will remain in the United States or be returned to Germany for disposition.  Acceptance of such foreign fuel into a U.S. spent fuel repository has health, safety and policy implications not addressed in the Draft PEIS.


10.  The PEIS must consider the impact of oversight of FFTF by the Nuclear Regulatory Commission.


While DOE facilities have operated apart from regulation by the NRC, the Final PEIS should consider such regulation by the NRC as the trend to NRC regulation of DOE facilities is currently operative. As the FFTF would be operated as a commercial facility it should fall under commercial regulation.  If DOE has already made the determination that such oversight has been ruled out then the Final PEIS should clearly state this fact and if the reactor could not meet the rigors of NRC regulation.   


11.  Cost and non-proliferation issues should be made part of the PEIS record.


DOE has made a decision to exclude cost and non-proliferation considerations from the PEIS but we view this decision is an inappropriately narrow interpretation of the National Environmental Policy Act.  Previous DOE EISs, such as DOE’s foreign spent fuel take-back EIS, have included detailed non-proliferation analyses.  Cost analyses have also been included in some EISs as well and should be included in the Final PEIS.


Thank you for considering these comments in preparation of the Final PEIS.


Tom Clements

Nuclear Control Institute

1000 Connecticut Ave., NW   Suite 410

Washington, DC  20036


tel.  202-822-8444

fax  202-452-0892