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February 11, 1999

Mr. Andrew Grainger
NEPA Compliance Officer
U.S. Department of Energy
Savannah River Operations Office
Building 742A, Room 183
Aiken, SC 29802

Comments on the Department of Energy's
Draft Environmental Impact Statement on
Spent Nuclear Fuel Management

Dear Mr. Grainger:

The Nuclear Control Institute (NCI) welcomes the opportunity to comment on the draft EIS issued by the U.S. Department of Energy on how to manage spent nuclear fuel, targets, and other material now stored at the Savannah River Site (SRS). NCI is supportive of those aspects of the Draft EIS which seek to implement a policy to avoid reprocessing of nuclear materials at SRS by development of alternative stabilization methods that do not result in separation of weapons-usable material. We congratulate the Department for issuance of a document with this stated goal.

NCI believes that DOE has made progress in implementing non-reprocessing alternatives, as decided in the 1996 Record of Decision (ROD) on the Final EIS on a Proposed Nuclear Weapons Nonproliferation Policy Concerning Foreign Research Reactor SNF, and is pleased to see that DOE has devised a non-reprocessing plan to deal with HEU-bearing aluminum-clad spent fuel. We urge the Department to stand by its current assessment that "DOE has greater confidence now than at the time the Foreign Research Reactor EIS's Record of Decision in the feasibility and availability of non-chemical reprocessing technologies" (Draft EIS, p. S-6). We also urge further progress toward implementation of such non-chemical processing technologies once the ROD for the SRS Spent Nuclear Fuel Management Final EIS is issued.

Selection of the "Melt and Dilute " technique for 97% (in volume) of this material presents a solution which is stable for geologic disposal and unattractive for nuclear weapons use, as it will result in ingots which do not contain highly-enriched uranium (HEU). The alternative of reprocessing the spent fuel in the H-Canyon at SRS would produce purified, weapon-usable HEU as an intermediate product and extend the life of the aging plant for anywhere from five to thirty years, posing a continued and unacceptable proliferation and environmental risk. Development of Melt and Dilute will also provide a technological alternative which can be used by other countries to manage their own aluminum-clad HEU spent fuel.

Although the largest volume of material -- representing 60% in mass of materials considered in the EIS -- is proposed to be dealt with using the Melt and Dilute method, we are discouraged that DOE is considering reprocessing of 40% of materials by mass -- primarily declad EBR-II uranium metal spent fuel. DOE's claim that such treatment is necessary because it "presents a potential health and safety vulnerability, is in a form that may be unacceptable for placement in a geologic repository, and/or for which the development of a second non-reprocessing technology would be too expensive" (Draft EIS, p. S-15) should be re-examined. Given that maintaining of the canyons in an operable mode is exorbitantly expensive, we are convinced that a concerted DOE effort to develop non-reprocessing alternatives, perhaps as simple as placing EBR-II canisters in an additional corrosion-resistant sleeve, could yield results both technologically and economically efficient.

While DOE states in the Proposed Action that operation of the canyons for reprocessing of spent nuclear fuel would not be extended beyond the closure target date of "about 2005," little assurance is given in the EIS that this date will be met. We are concerned that DOE will once again allow the date for closure of the canyons to slip, thereby providing an opening for new reprocessing missions to be developed. Along with issuance of the ROD, DOE should make a clear commitment that the canyons will be closed within the "current planning basis" and that no slippage of that deadline will be tolerated. Given the commitment to the Melt and Dilute technique, it is now time for DOE to present a firm closure date for the SRS reprocessing canyons.

DOE's contention in the EIS that operation of the canyons is needed for stabilizing nuclear materials that present health and safety vulnerabilities carries an undesirable message with potentially negative ramifications for international non-proliferation interests. Other nations engaged in or planning for reprocessing can use this same justification to continue operation of their own facilities, with resultant separation of weapons-usable material. Thus, we continue to question the soundness of DOE's reasoning in making the stabilization argument. While health and safety considerations must be taken into account in handling the materials at SRS, DOE should not allow the canyons to become a technology in search of a use.

Avoidance of use of reprocessing facilities at SRS will result in a reduction of high-level waste solution pumped into storage tanks at the facility (for which, due to the failure of the In-Tank Precipitation method, there is no viable stabilization path at the present time). It will also send a signal internationally that viable alternatives exist to reprocessing of such material. Also, early shutdown of the SRS canyons will be seen internationally as a good-faith disarmament effort and will facilitate negotiations and eventual implementation and verification of a ban on production of fissile materials.

We support the goal of having the Melt and Dilute process in operation by the year 2005, but DOE should establish a concrete timeline of technological milestones and funding which would make this happen. As the technology is within reach, DOE should insure that full funding for the Melt and Dilute technique is in the budget for FY 2000 and in subsequent years. Use of existing facilities associated with the L-Reactor is seen by us as a practical and efficient way to proceed as long as that those facilities meet the most stringent health and safety standards. In this regard, we are encouraged by DOE's assessment that an off-gas system to capture fission products volatilized during melt-and-dilute treatment "could be designed using proven approaches for managing off-gases" (Draft EIS, p. S-18), and we urge DOE to provide adequate funding to support a focused effort to design and demonstrate such as system.

We also support the plan presented in the draft EIS to transfer to dry storage 20 MTHM of non-aluminum clad spent fuel now stored in the Receiving Basin for Offsite Fuel (RBOF). We applaud the associated goal of phasing out the use of RBOF by 2006, and thus would like to see active development of the L-Reactor Disassembly Basin to which aluminum-clad fuel could be transferred. The ROD should also include a commitment to a closure of RBOF within a specified period, thus underscoring the commitment to development of alternative storage and handling techniques for materials now stored in that basin. Establishing a timeline for development of alternative storage and management techniques will help to ensure the RBOF is emptied and decommissioned by a date certain, along with the associated reprocessing facility.

It is clear that the end of the operational lives of the SRS reprocessing canyons is now in sight. The stated strategy and preference of DOE in the draft EIS "to use non-chemical separation processes when practical" (Draft EIS, p. S-6) should facilitate their shutdown in a time frame consistent with current planning basis (by about 2005), provided adequate resources are made available to fully develop the technology alternatives. The final EIS should make a clear commitment to ensuring the availability of the necessary funding resources.

We summarize our comments on and requests for revisions in the draft EIS as follows:

1) DOE's decision to implement the Melt-and-Dilute process for HEU spent fuel is technologically sound. Its implementation should be fully funded.

2) DOE should present its timeline for implementation of Melt-and-Dilute and keep the public informed as progress toward that goal is made and give explanation if delays are encountered. Development of the system, including off-gas treatment, should be carried out under public review and through application of highest technological standards.

3) DOE needs to present a better analysis of costs of reprocessing and of reprocessing alternatives in the final EIS. This analysis must include costs of current operation on the canyons, including cost of waste management and cost per unit of material reprocessed.

4) For any reprocessing which DOE includes in the final EIS, DOE should more clearly define actual health and safety risks associated with materials designated for reprocessing and should commit not to reprocess if non-reprocessing technologies could be effectively employed.

5) In the final EIS, DOE should describe other pending actions and decisions which might impact any decision to reprocess spent fuel at SRS. For example, if DOE were to import materials not described in the RERTR EIS or to consider reprocessing of spent fuel or fissile materials in storage at DOE sites, then DOE should candidly describe any use of the canyons it might envisage in handling such materials. An assessment of how this would affect the "current planning basis" underlying the spent fuel EIS should be made and justification should be given for use of the canyons versus non-reprocessing alternatives.

Sincerely,

Tom Clements
Executive Director

Dr. Edwin S. Lyman
Scientific Director

attachment: 2-page NCI news release, December 28, 1998

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