DOE/EIS-0283D (July 1998)
Anita Seth, Global Outreach Coordinator
Hisham Zerriffi, Project Scientist
At the end of the Cold War, the United States and Russia face an unprecedented and unexpected problem: surpluses of plutonium and highly enriched uranium (HEU), the two key materials used to make nuclear weapons.
The more difficult of the two is the surplus plutonium and the question of converting it into forms not usable for making nuclear weapons. The two most technically advanced options to meet the spent fuel standard are to immobilize the plutonium in a ceramic or glass form with high level radioactive waste to form a radiation barrier to theft or to create nuclear reactor fuel with it and use it in a commercial reactor (MOX). It should be noted that the MOX option does not “burn” the plutonium destroy it. While some of the plutonium will be fissioned in the reactor, plutonium is also created through neutron irradiation of the uranium which forms the bulk of the reactor fuel (this occurs in reactors fueled with low-enriched uranium as well). In fact, in some cases the plutonium left in the spent fuel is greater than the amount put into the reactor.  The commonly-used yardstick to measure the resistance to theft and diversion of the final form of plutonium after disposition is the so-called “spent fuel standard.” This criterion was identified by the National Academy of Sciences in their 1994 report, and means that the plutonium should be as inaccessible to theft, diversion, and re-extraction as plutonium in stored commercial low-enriched spent fuel. Both immobilization and the MOX program were considered by the NAS to have met this standard. However, the “spent fuel standard” inherently assumes that the plutonium will remain in spent fuel (or whatever form it has been placed into)–that is, that it be slated for geologic disposal. Taking into account the desire of Russia to reprocess its spent fuel and the risk of creating a plutonium economy in both countries, it is clear that immobilization is a better option for meeting the standard.
Minatom has stated very clearly on numerous occasions that it intends to reprocess spent MOX fuel, rendering the “spent fuel standard” effectively meaningless over the long-term. The U.S. appears to ready to allow Minatom to reprocess spent MOX fuel from the plutonium disposition program. The joint report notes that “. . .Russia will ultimately recycle any plutonium left in the [MOX] fuel. The U.S. objective of plutonium disposition is satisfied when the isotopic composition of the weapons-grade plutonium have been altered by irradiation, the fuel attains a significant radiation barrier, and the fuel is stored for several decades before reprocessing.” 
DOE’s Proposed Action
The Department of Energy analyzes 23 different alternatives in its Surplus Plutonium Disposition Draft Environmental Impact Statement to meet the spent fuel standard. The DEIS analyzes the disposition of a nominal 50 metric tons of plutonium (33 tons is contained in plutonium pits from weapons or in a metal form relatively free of impurities while the rest is in various other forms). The various alternatives analyzed fall into two basic categories: Immobilization and Hybrid Approaches. 
The Immobilization approaches would encase the plutonium (after initial processing to render it into a suitable form – plutonium dioxide) in ceramic discs which would be placed in steel cans. These cans would then be vitrified (encased in glass) along with highly radioactive waste currently being vitrified as part of DOE clean-up operations. Placing the plutonium in a ceramic mixture and then encasing it in glass makes it difficult to extract (in fact, there is less experience with extracting plutonium from a glass or ceramic matrix than from spent fuel). Encasing it in glass which contains highly radioactive waste makes it resistant to theft as the radiation dose near the glass logs would be very high. It has already been determined that this method of immobilization would meet the spent fuel standard.
The hybrid approach would use the immobilization process for a portion of the plutonium surplus and would manufacture the rest into nuclear power reactor fuel for use in a commercial nuclear reactor. Ordinary reactor fuel used in U.S. light water reactors contains uranium oxide slightly enriched in the isotope Uranium-235 (usually about 3-5% with the rest of the Uranium oxide being mainly U-238).  The DOE proposes to produce fuel which would replace the 3-5% U-235 with approximately the same percentage of plutonium oxide. Since the fuel would now be a mixture of plutonium oxide and uranium oxide it is called MOX (Mixed OXide).
The DOE’s preferred alternative is a so-called hybrid approach. Approximately 33 metric tons of plutonium would be manufactured into MOX fuel. These 33 tons are currently in the form of weapon pits or metals mainly free of impurities and DOE believes these materials would meet the high purity standards required of MOX fuel. There are, however, some impurities in both the pits and clean metals which would need to be removed (namely gallium). The other 17 metric tons of material is in a variety of other forms. While they contain weapons-usable plutonium, these materials would require significantly more processing to meet the MOX requirements according to the DOE. Therefore, this 17 tons would be immobilized.
The preferred alternative would involve construction of a Pit Disassembly and Conversion Facility (PDCF) at either Pantex or the Savannah River Site. This facility would take apart the weapons pits, remove tritium if necessary, convert the plutonium to an oxide form and process it to remove gallium and other impurities. The PDCF would also convert the “clean” metal. The plutonium dioxide would then be transferred to a MOX fuel fabrication facility to be constructed at SRS (transportation would be either inter-site or intra-site depending on whether the PDCF is built at Pantex or SRS). Immobilization of the other 17t of plutonium in ceramic would occur at a new facility at SRS and the Defense Waste Processing Facility at SRS would be used for vitrification in high-level waste.
According to the DOE:
Pursuing the hybrid approach provides the best opportunity for U.S. leadership in working with Russia to implement similar options for reducing Russia’s excess plutonium in parallel. Pursuing the hybrid approach also sends the strongest possible signal to the world of U.S. determination to reduce stockpiles of surplus weapons-usable plutonium, as quickly as possible, in an irreversible manner. The construction of new facilities for the disposition of surplus U.S. plutonium would not take place unless there is significant progress on plans for plutonium disposition in Russia. (p. 1-9)
It is, therefore, apparently the Russian view of plutonium as a “national” treasure and their desire to use it in reactors which is driving the United States to use the MOX option. This rationale will be examined further below. The decision by the DOE to pursue a hybrid approach ignores the clear advantages offered by immobilization and the serious consequences of initiating a MOX program in the United States. The DEIS also has clear deficiencies which need to be addressed including the lack of information on crucial components of the program. These will be outlined below after an overview of the relative costs and benefits of Immobilization versus MOX and a critique of Russia’s role in the decision is presented.
MOX versus Immobilization
There are a number of technical difficulties associated with MOX that DOE has not adequately addressed. First, is the issue of Russian reactors, which is discussed in more detail below. Second, US MOX plans envision the large-scale use of weapons grade plutonium in light water reactors for the first time. While MOX proponents claim that European MOX programs provide ample experience for the US program, that experience is only using reactor-grade plutonium. Furthermore, full MOX cores, which are assumed in DOE’s analysis, have never been used on a large scale.
The Record of Decision for this Environmental Impact Statement will establish whether the United States pursues an Immobilization only approach or a hybrid approach mixing both immobilization and MOX. There are a number of factors which DOE must consider in making a decision, including environmental consequences, cost, schedule for disposition, and proliferation consequences. Each of these major factors will be discussed below. It should be noted, however, that one of the original purposes for pursuing a hybrid approach was to have a back-up technology in case there were problems implementing either immobilization or MOX. However, MOX cannot handle the full spectrum of plutonium requiring disposition. Therefore, this rationale is severely undercut by the fact that immobilization is the only option capable of processing 17 of the 50 metric tons. Given the indispensability of the immobilization option, it would appear more prudent to concentrate energy and resources into this alternative. Back-up should be pursued by developing more than one immobilization option.
DOE’s choice of disposition technologies does not take place in a vacuum, and has a great effect on the debate about the worth of commercial plutonium technology around the world. By relying on MOX for a large part of its disposition program, DOE strengthens the arguments of the plutonium lobby world-wide.
The DOE’s emphasis on MOX brings it into partnership with European commercial plutonium concerns like BNFL, Cogema, Siemens, and Belgonucleaire, whose interest is in promoting continued use and production of plutonium, not in plutonium disposition. By supporting these companies with contracts at a time when they are coming under increasing scrutiny and criticism at home, DOE prolongs their survival and severely undermines the long-standing US position against commercial use of plutonium.
The most serious proliferation consequence of a MOX disposition is the acquiescence and even aiding of Minatom in its pursuit of a long-term plutonium economy. A MOX disposition program would provide Minatom with a MOX fuel fabrication facility, the currently missing link in its plutonium infrastructure.
As DOE is well aware, prior to U.S. encouragement Minatom had not supported a program of loading MOX in existing light water reactors. Minatom has instead been a proponent of storage of plutonium with a view to its eventual use in “advanced” reactors and breeder reactors. DOE has argued that moving Minatom from a position of developing breeder reactors to one of using plutonium in light water reactors represents progress in non-proliferation. This is ironic on two fronts. First, it relies on a differentiation between “weapons-” and “reactor-grade” that the US has implicitly rejected with its policy against commercial plutonium development. Second, it takes Minatom from a policy with very little likelihood of success, given the consistent failure of breeder technologies around the world, to a position much more likely to lead to increased use, transportation, and perhaps even production of plutonium in the short term.
In the name of disposition, the US seems not only to be relinquishing its decades-old policy of not using plutonium in commercial reactors, but aiding and abetting Russian plans to build a plutonium economy. The US will not oppose Russian reprocessing of the MOX fuel fabricated from surplus weapons plutonium, provided that it occurs only after several decades, when the disposition program is complete. DOE has argued that a several-decade moratorium on the re-separation of plutonium from spent MOX fuel is a sufficient safeguard against proliferation. But it won’t matter whether MOX spent fuel is reprocessed now or in a few decades. So long as the infrastructure for MOX fuel production and reprocessing is created and maintained, there will be plenty of other spent fuel to reprocess and plenty of surplus plutonium to occupy MOX fuel fabrication plants in the meantime.
Thus, the net result of the plutonium disposition program will have been for the United States to subsidize the very thing that it should be against: an infrastructure for a plutonium economy in Russia. A similar infrastructure would be created in the United States since a MOX plant would be built and since the U.S. appears increasingly reluctant to shut down its decades-old military reprocessing plants at the Savannah River Site in South Carolina.
The DOE itself has already recognized that immobilization alone is preferable to the hybrid approach from an environmental standpoint. In the Record of Decision for the Storage and Disposition of Weapons-Usable Fissile Materials final Programmatic Environmental Impact Statement the DOE states:
For normal operations, analyses show that immobilization would be somewhat preferable to the existing LWR and preferred alternatives, although these alternatives, with the exception of waste generated, would be essentially environmentally comparable.
Severe facility accident considerations indicate that immobilization options would be environmentally preferable to the existing reactor and preferred alternatives, although the likelihood of occurrence of severe accidents and the risk to the public are expected to be fairly low. (p. 10, emphasis added)
The hybrid approaches would require at least one extra facility and possibly even two. Under the hybrid option the three facilities would be a Pit Disassembly and Conversion facility, the MOX Fuel Fabrication Facility, and the Immobilization Facility. Under Immobilization only alternatives, the MOX FFF would be eliminated. Furthermore, it appears technically feasible to design a single facility which could undertake both pit disassembly/conversion and immobilization (see below) and should have been one of the options analyzed. The environmental advantages of a reduction in facilities and operations have not been fully analyzed since a single facility alternative is not included in the DEIS. Furthermore, if the DOE decides to use the Defense Waste Processing Facility at SRS for vitrifying the cans in high level waste, the incremental environmental impacts of immobilization may be reduced further. There are no existing facilities which could be taken advantage of for MOX fuel fabrication.
Due to the high purity requirements of MOX fuel the conversion of plutonium pits and clean metal for MOX require additional processing steps which would be unnecessary for immobilization. At the moment the DOE plans to construct a conversion facility which would remove gallium (a major concern in MOX fuel) using a dry process.5 If the dry process, which is still at the laboratory and pilot stage, does not meet the impurity removal specifications, the DOE proposes using an aqueous process it calls plutonium polishing. The analysis in the DEIS assumes these processes would occur even if the immobilization alternative is chosen, despite the fact they would be unnecessary. Therefore, the DEIS does not allow one to fully compare the environmental impacts of the MOX and immobilization options. A more detailed discussion of plutonium polishing and the DOE analysis of this process is presented below.
In addition to a larger number of operations and facilities, the MOX option also entails an extra transportation step. Under the DOE’s preferred alternative, both MOX fuel fabrication and immobilization would occur at SRS. In the case of immobilization, the glass logs would be stored until shipment to a repository. However, for MOX the unirradiated fuel would have to be shipped to the reactor and then the spent fuel shipped to a repository after irradiation.
According to the DOE’s July 1998 cost estimate report, the cost of MOX and immobilization disposition programs are approximately the same. However, this comparison fails to take into a account a number of factors.
First, the DOE assumes that a fuel off-set will be provided by the reactor companies. The idea behind the fuel off-set is that the MOX fuel would be placed in the reactor instead of the low enriched uranium fuel the reactor operators would normally need to purchase. Thus, the DOE assumes that the bidding consortia would subtract this fuel off-set from the charges for constructing and operating the MOX fuel fabrication facility. DOE estimates this fuel off-set to be approximately one billion dollars. While in principle this is possible, there is no guarantee that the reactor companies will agree to provide the fuel off-set. There is already indication that the bidding consortia of reactor operators and nuclear fuel manufacturers do not intend to undertake this task without reaping a profit.
In fact, one reactor official has stated very explicitly the desire of the nuclear power companies (and by extension the consortium partners which would handle MOX fuel fabrication) to make a profit. Jack Bailey, Vice-president of the Palo Verde nuclear plants stated his company’s requirements for added compensation in March 1996:
We also stressed in our letters to DOE that any initiative should address potential benefits to ratepayers and shareholders… The benefits must be substantial. If not, the entire proposition is a non-starter. What I mean specifically is that any agreement involving Palo Verde would require more than the incremental costs associated with using MOX fuel instead of uranium. That kind of payment would be insufficient. 
Furthermore, the DEIS assumes that MOX fuel would be left in the reactor only long enough to meet the spent fuel standard, not for the maximum length of time a fuel rod would normally be in a reactor (p. 2-99). It is not clear what assumptions were made in the cost estimate as to the residence time of the fuel in the reactor. However, a shorter time in the reactor would mean less of the uranium fuel would be replaced over the timeframe of the disposition mission and would therefore reduce the fuel off-set.
Second, the cost estimate explicitly excludes a number of factors which could increase the cost of the MOX hybrid options.
Costs that would remain the same, independent of where the facility is sited, are not included. Examples of costs that are not included in this report are research and development, environmental analyses, operation of the Defense Waste Processing Facility (DWPF), and nuclear reactor modifications and irradiation services. Total costs shown are, consequently, not full life-cycle costs.  The only cost specific to the immobilization option is operation of DWPF. However, DWPF will operate whether or not plutonium disposition occurs. The costs specific to the MOX portion of the hybrid options are reactor modifications and irradiation services. As there has been no final decision taken about specific reactors to be used for the disposition program, it is not possible to determine how much it will cost to modify the reactors to handle MOX fuel (or if modifications will need to be made). As for irradiation services, it seems unlikely that irradiation service fees will not be part of any bid from the nuclear consortia. As stated above, there is every indication that these companies intend to make a profit from their involvement with this program.
Therefore, while DOE indicates that the MOX hybrid and immobilization options would be comparable in cost, it is painting a misleading picture by excluding significant costs of the MOX program. The one billion dollar fuel off-set may not be realized. This would raise the hybrid option costs by approximately 50%. Furthermore, the hybrid option costs can be expected to rise even higher due to reactor modifications and irradiation service fees.
Reactor Related Issues
The vast majority of LWRs were not designed to use plutonium as a fuel. While both plutonium-239 and uranium-235 are fissile materials that generate similar amounts of energy per unit weight, there are a number of differences between them as reactor fuels that affect reactor safety. The basic set of concerns relates to control of the reactor. The chain reaction in a reactor must be maintained with a great deal of precision. This control is achieved using control rods usually made of boron and (in pressurized water reactors) by adding boron to the water. Control rods allow for increases and decreases in the levels of reactor power and for orderly reactor shut-down. They prevent runaway nuclear reactions that would result in catastrophic accidents.
It should be noted that while all commercial LWRs have some amount of plutonium in them which is made during the course of reactor operation from uranium-238 in the fuel, the total amount of plutonium is about one percent or less when low enriched uranium fuel is used. When MOX fuel is used, the total amount of plutonium would at all times be considerably higher. It is this difference that creates most reactor control issues.
Changing the fuel can affect the ability of the control rods to provide the needed amount of reactor control and modifications to the reactor may be required before the new fuel can be used.
Several differences between the use of MOX fuel and uranium fuel affect safety:
- The rate of fission of plutonium tends to increase with temperature. This can adversely affect reactor control and require compensating measures. This problem is greater with MOX made with weapons-grade plutonium than that made with reactor-grade plutonium.
- Reactor control depends on the small fraction of neutrons (called delayed neutrons) emitted seconds to minutes after fission of uranium or plutonium. Uranium-235 fission yields about 0.65 percent delayed neutrons, but plutonium yields only about 0.2 percent delayed neutrons. This means that provisions must be made for increased control if plutonium fuel is used, if present control levels and speeds are deemed inadequate.
- Neutrons in reactors using plutonium fuel have a higher average energy than those in reactors using uranium fuel. This increases radiation damage to reactor parts.
- Plutonium captures neutrons with a higher probability than uranium. As a result, a greater amount of neutron absorbers are required to control the reactor.
- The higher proportion of plutonium in the fuel would increase the release of plutonium and other transuranic elements to the environment in case of a severe accident.
- Irradiated MOX fuel is thermally hotter than uranium fuel because larger quantities of transuranic elements are produced during reactor operation when MOX fuel is used.
Overall, the issues related to reactor control, both during normal operation and emergencies, are the most crucial. Most independent authorities have suggested that only about one third of the fuel in an LWR can be MOX, unless the reactor is specifically designed to use MOX fuel. However, there are some operational problems associated with using partial-MOX cores since MOX fuel is interspersed with uranium fuel. Their differing characteristics regarding control, radiation and thermal energy mean that there are non-uniform conditions in the reactor that can render operation and control more complicated. Some reactor operators claim they can use 100 percent MOX cores without needing to make physical changes to the reactor or control rods. The safety implications of such claims need to be independently verified.
Russia only has eight reactors under consideration for loading of MOX fuel. There has been little publicly-available analysis about the safety of loading VVER-1000s with MOX fuel. Many of these reactors are old, and will be nearing the end of their 30-year license at the time MOX loading would begin. Current plans seem to envision potential operation of Russian reactors well beyond this 30-year period. Certainly, this raises safety concerns to an even greater level. Similar problems surround plans to load the BN-600, located at Beloyarsk, with MOX fuel. By Minatom’s own reckoning, there have been at least 30 sodium leaks at the reactor since its start of operation in 1980.  Numerous other incidents have also been documented.  Given the current political weakness and underfunding of regulatory forces in Russia, notably Gosatomnadzor, it is unlikely that they can guarantee proper regulation of Russian reactors. What would the US responsibility be in event of an accident at a reactor which occurred in the context of a program promoted by the US government over the wishes of the Russian nuclear establishment? If MOX fuel use in VVERs turns out to be unsafe and an accident occurs as a result, what would US liabilities be? What would be the responsibility of the US government to the Russian people who have already suffered so much from nuclear accidents in the past? Will the US be willing to assume responsibility for an accident due to this change in fuel? Would the US be willing to provide insurance against the increased risk of accidents due to the change in fuel? Furthermore, is the US prepared for the social upheaval that would accompany such an accident? The 1986 Chernobyl accident is widely acknowledged as a precipitating cause of the break-up of the Soviet Union (when combined with other factors). Given the social tensions caused by the current economic troubles, it is not hard to imagine that an accident would have a very serious impact on the stability of Russia, not to mention on the security of nuclear materials there.
The Russian public has been an important moderating force on Minatom’s plans for a plutonium economy, consistently opposing large new plutonium projects. In this, DOE’s non-proliferation interests coincide with the Russian public’s desire to protect their health and environment. Given this important conjunction of interests, DOE ought to be promoting the Russian public’s voice in disposition decisions. Instead, it seems inclined to ignore Minatom’s violation of access to information, environmental, and public participation laws.
Finally, it is clear that Russia is unable to finance a disposition program without substantial outside help. As we have shown above, DOE’s assertions that MOX and immobilization are approximately equal in cost are grossly misleading. MOX is by far the more expensive option, particularly when the potential costs of modifying reactors is added. The lack of money raises serious questions about the potential for large-scale Congressional appropriations, and he possibility of private investment. The latter is particularly troubling, however, because it implies potential commercial use of the MOX fuel fabrication facility and perhaps other plutonium facilities after the end of the disposition program.
The DEIS contains a number of deficiencies which need to be addressed. These include:
The DEIS does not include an analysis of impacts for specific reactors to be used for the MOX option. Instead, it appears to rely on a generic analysis conducted as part of the Storage and Disposition PEIS (e.g. summary of accident effects on pp. 2-101 and 2-102). Specific reactor analysis will supposedly be included in the Final EIS based upon the response to DOE’s Request for Proposals for MOX Fuel Fabrication and reactor Irradiation Services. However, there are two problems with this approach. First, the use of the “216” process, in which DOE provides summary information on environmental impacts in order to protect proprietary information, does not allow the public and outside experts to adequately judge the information presented. Second, there will be no opportunity for comment by the public concerning reactor-specific issues during the NEPA process. This will exclude the populations surrounding the reactors from publicly participating in the decision-making process at this stage. The DEIS uses a representative site analysis for the source of depleted uranium hexafluoride and for the conversion of the depleted uranium hexafluoride to uranium dioxide. The Portsmouth Gaseous Diffusion Plant is used as the representative site for the source of uranium hexafluoride because it is the only one of the three storage sites with the equipment to transfer the material from its storage containers to the containers used in the conversion process. Of five possible sites for conversion to uranium dioxide, the DOE chose the General Electric Company’s Nuclear Energy Production Facility in Wilmington, North Carolina as a representative site (p. 1-8).
While a rationale is given for choosing the Portsmouth facility, there is no reason given for choosing the GE site. In addition to the lack of a clear reason to choose this facility for a representative analysis of the environmental impacts of this process, there is no demonstration of why this particular facility is representative of all facilities. The burden of proof is upon the DOE to demonstrate not only that representative analysis is acceptable technically, but also that the site chosen is representative of the potential impacts. This should also not act as a replacement for a complete environmental impact assessment once a candidate site has been chosen.
In the final EIS the DOE must clearly show that representative analysis is valid and that the sites chosen are truly representative of the processes and impacts described. The DOE should also state what process will be used for assessing environmental impacts once a site is chosen. The lack of public involvement in this area needs to be addressed as soon as possible.
Comparison of Results
The DEIS does not allow the reader to make a comparison between the alternatives. Section 2.18 is titled “Summary of Impacts of Construction and Operation of Surplus Plutonium Disposition Facilities.” However, it fails in its task of clearly summarizing the impacts in a manner conducive to comparison. This section (as well as parts of Chapter 4) details the integrated impacts of the MOX option (including irradiation in a reactor and transport). It also provides a comparison of the different types of immobilization options (ceramic vs. glass and homogenous vs. can-in-canister). However, there is no summary of the integrated impacts of the full immobilization option, only a comparison of the impacts of the immobilization facilities. In fact, we could find no presentation of the integrated impacts of the immobilization option could be found in the document. It is not acceptable to expect the public to undertake this task.
Furthermore, the two sections present the impacts in different ways. The MOX integrated impacts section provide figures for doses, population doses, increased risk and Latent Cancer Fatalities due to routine operations. The section on immobilization only provides doses and population doses. This is a complicated program with a number of alternatives. It is the DOE’s responsibility to present the information in a manner more conducive to comparison and this should be done in the final EIS.
Waste Isolation Pilot Plant
The DEIS assumes the Waste Isolation Pilot Plant will be open and able to handle the transuranic waste from these processes. However, as has been stated repeatedly by IEER in other contexts, WIPP is not the solution to the transuranic waste problem. Furthermore, WIPP is severely behind schedule, faces a number of challenges to its opening, and cannot handle the volume of waste. WIPP should not be assumed to be the final repository for transuranic waste generated during disposition. A safer assumption would be on-site retrievable storage (in RCRA compliant facilities for mixed waste if necessary).
Decision Making Process
The DEIS fails to clearly specify the criteria that will be used in making the final decision on which disposition alternative will be followed. The environmental impact assessment of any project should not be simply an exercise to justify policy decisions. The results of the analysis must be included in the final decision-making process in a substantive manner. Page 2-11 of the DEIS states that three factors were involved in reducing the large number of possible options to the 23 that the DOE considers “reasonable.” Taken in equal measure, these factors were: worker and public exposure to radiation, proliferation concerns due to transportation of materials, infrastructure cost. This raises a number of issues.
First, why were non-proliferation issues unrelated to transportation ignored in the initial phase of narrowing the options? As discussed above, there are a number of non-proliferation problems with the use of MOX fuel which are not related to transportation. The creation of a plutonium economy which includes reprocessing of spent fuel to extract plutonium will be harder to counter internationally if the United States is using MOX fuel. The desire of the Russian government in particular to eventually extract the plutonium from the spent fuel raises serious non-proliferation concerns.
Second, the choice of a dual-track strategy as the preferred alternative indicates that these criteria were not considered the most important. As discussed above, immobilization provides advantages from an environmental and human health perspective as well as cost savings and the capability of a faster completion of the mission. This does not even take into account the much greater proliferation and policy consequences of a MOX program which should have been included as a criteria.
Third, if these criteria were suitable for an initial screening of options, are they used as the basis for a final decision? What further factors will be used in the final decision?
The final EIS should answer these questions and lay out the criteria for a decision in this program.
Single Facility Analysis
The DEIS fails to analyze an alternative which is “reasonable.” It is technically feasible to convert and immobilize all 50 tons of plutonium in a single facility, including pit disassembly and conversion. The pit disassembly and conversion facility transforms the plutonium into an oxide form which is necessary for the ceramification process. However, it also includes processes only necessary for the MOX option, the main one being gallium removal. Under the current planning the facility would be constructed and operated with gallium removal even if the decision is made to immobilize all the plutonium.
However, the immobilization facility also includes the capability to convert plutonium to an oxide form (which is necessary for the 17 tons of non-pit material which is slated for immobilization). It would be possible to expand this capability in the immobilization facility and dispense with the separate Pit Disassembly and Conversion Facility entirely. We do not know what effect this would have on the environmental impacts. However, such a facility would not include the gallium removal process or the plutonium polishing process which is being kept as an option if certain impurities cannot be removed. It would therefore require less overall processing and handling than the current plans.
The DOE has stated that a single immobilization facility should be technically feasible but that the obstacle would be keeping the facility open to IAEA inspection.  Under current plans the immobilization facility will be open to inspection by the IAEA. At issue is the fact that the plutonium pits are classified until they are converted into an oxide. However, this argument is disingenuous. It would not be difficult to design the facility in such a way that IAEA inspectors would not have access to the processing sections which contain classified pits, but would have access to the rest of the facility. Indeed, DOE is already designing such a facility. The Pit Disassembly and Conversion Facility layout presented in the DEIS clearly shows a Classified section where pits are received and a non-classified section after they have been processed. There are even IAEA offices clearly labeled in the non-classified section. There is no reason this could not be done in a single pit disassembly, conversion, and immobilization facility. In fact, on p. 2-20 the DEIS discusses the possibility of collocating the pit disassembly and immobilization functions in an existing facility. If this can be done in an existing facility, it surely can be done in a new facility which is specifically designed to allow for both classified and unclassified sections.
The failure of this DEIS to analyze a reasonable alternative which would appear to meet their screening criteria is a fundamental flaw. The needs to be addressed before an informed decision can be made as to the relative costs and benefits of the various alternatives.
Worker Risks in Accidents
The DEIS explicitly excludes analyzing the radiological effects of accidents on involved workers (those workers actually involved in a process when an accident occurs). The analysis is limited to non-involved workers 1000 meters away, the maximally exposed individual and the general public within 80 kilometers. The rationale for excluding workers actually involved in an accident is provided in K.1.4.1 which states:
Consequences to workers directly involved in the processes under consideration are addressed generically, without attempt at an scenario-specific quantification of consequences. This approach to in-facility consequences was selected for two reasons. First, the uncertainties involved in quantifying accident consequences become overwhelming for most radiological accidents due to the high sensitivity of dose values to assumptions about the details of the release and the location and behavior of the impacted worker. Also, the dominant accident risks to the worker of facility operations are from standard industrial accidents as opposed to bounding radiological accidents. (p. K-7) This rationale is not sufficient to exclude those workers likely to bear the brunt of an accident during processing of plutonium. While it may be true that the models employed have problems below 1000 meters, this does not excuse this omission. Models have been developed for use in such circumstances. Alternatively, an attempt to modify the model could have been made or the uncertainty in the model results expanded to reflect the greater uncertainty in modeling workers close to the accident. Assumptions could be made about worker patterns (similar to the way assumptions are made concerning the general population).
The problem is exacerbated greatly by the presentation of the data on the noninvolved worker. The table which summarizes accident impacts for each alternative does not provide an estimate for the number of Latent Cancer Fatalities for non-involved workers despite providing this information for the general public. It should not be difficult for this estimate to be made as DOE presents numbers on how many badged workers are on-site. This omission is repeated in the summary of impacts presented on pages 2-69 to 2-104. Accident impacts are quantified and discussed for the general population and a one paragraph description of consequences for involved workers is included. However, There is no discussion of impacts to noninvolved workers due to accidents. Table 2.4 which is supposed to be a summary of impacts by Alternative and Site only lists the accident Latent Cancer Fatalities for the general public.
The exclusion of involved workers in the accident analysis and the lack of complete results on the effects of accidents on non-involved workers raises serious questions as to DOE’s commitments to worker safety and health. It is a reasonable assumption that the effect of an accident on workers would be greater than on the general public. The probability of Cancer Facility is often ten times higher for the non-involved worker compared to the general public. The probability for the involved worker can be expected to be even higher. By only presenting full results for the public the consequences of accidents appear to be lower than what can reasonably be expected.
The final environmental impact statement should include a full and complete analysis of worker risks.
Appendix N of the DEIS describes “a polishing process by which impurities, particularly gallium, could be removed from the plutonium feed for mixed oxide (MOX) fuel fabrication.” (p. N-1) It is included as an appendix because DOE considers it a contingency in case the dry processes DOE is developing for gallium removal fail to achieve the necessary purification level for MOX fuel fabrication. The plutonium polishing process would be an aqueous (wet) process. In previous analyses, DOE had rejected an aqueous process because of its higher environmental costs. Aqueous processes generate greater waste volumes and the waste is in a liquid form which is more difficult to handle.
It is difficult to determine, from the information given in the DEIS, exactly what the incremental effects of using plutonium polishing would be in all cases. This is because waste generation figures within each alternative are given for all three facilities. The added waste information presented in Appendix N is very confusing, and makes it very difficult to assess the environmental impact of the addition of plutonium polishing on the PDCF. This comparison would be the most suitable in judging the impacts of plutonium polishing.
Appendix N provides the potential impacts of plutonium polishing at the four sites (Tables N-10 to N-13). For the Hanford and SRS sites the DEIS uses alternatives 2 and 3 which would locate all three facilities at the site in question. Plutonium polishing at these sites would approximately 12% more transuranic waste. However, for INEEL and Pantex which would only have two facilities the incremental production of transuranic waste would be approximately 30%. The same holds true generally for low-level waste, mixed low-level waste, hazardous waste, and non-hazardous waste. In fact, for LLW the increases at Hanford and SRS are 27% and 16% respectively, while the increases at INEEL and Pantex are 33% and 64% respectively. This disparity in the cases being compared is very confusing and underplays the impact of plutonium polishing on waste generation. The incremental impacts on the single facility which would actually house the plutonium polishing module would be even greater.
Furthermore, the DOE has not stated how it would make a decision to use plutonium polishing and what role the potential future use of plutonium polishing will have on its more immediate decisions. If DOE decides to proceed with the hybrid approach and it is discovered in the future that plutonium polishing is necessary, resource commitments already made at that point will likely render it difficult to switch to an immobilization only alternative.
While the DEIS does provide a substantial amount of information on both the MOX and immobilization options there are serious gaps.
- What are the DOE’s plans to account for the failure of the In-Tank Precipitation (ITP) process at the Savannah River Site? DOE has ruled out the only alternative that it was previously considering, the use of cesium-137 from Hanford. (p. S-15) How will ITP failure affect the immobilization program’s technical options and timescale?
- What assumptions were made about the number and siting of reactors in assessing the cumulative impacts of the MOX option (Section 2.18.3)? Reference is made in this section to 188.8.131.52 of the Storage and Disposition PEIS for a generic analysis of light water reactors using 100% MOX cores. That analysis is for a single reactor at a site and clearly states that for multiple reactors at a site the impacts “would be approximately doubled for two rectors or tripled for three reactors.” On p. S-11 of the Surplus Plutonium Disposition DEIS it states that irradiation would occur at 3-8 reactors but does not state any assumptions about the number of sites or how many were assumed for the analysis.
- Why is the DOE reserving the option to use CANDU reactors and moving forward with testing if throughout the DEIS the assumption is that MOX will be used in US LWRs? If the DOE is still considering CANDU reactors, what effect will Ontario Hydro’s recent shutdown of a number of CANDU reactors have on the program? What provisions will be made to ensure that both Canadian and U.S. citizens will have the opportunity for input?
- Who is responsible for unirradiated fuel? What will occur if MOX fuel fabrication commences but either the license to use MOX is rejected by the NRC or the reactor operators decide to cancel the project?
- How long will unirradiated fuel be stored and at what sites? If storage is at the reactor site, what additional security measures will be undertaken?
- What are the implications of siting facilities in the F-Canyon? How will this affect reprocessing policy? How will it affect clean-up of the site? Is there any relation between a decision to use the F-Canyon for the disposition program and the use of the F-Canyon to deal with scrubs and alloys from Rocky Flats by reprocessing them at SRS?
- What are the implications of re-use of the facilities? The DEIS states:
when the missions of the plutonium disposition facilities are completed, deactivation and stabilization would be performed to reduce the risk of radiological exposure; reduce the need for, and costs associated with, long-term maintenance; and prepare the buildings for potential future use. (Chapter 4 of the SPD EIS provides a discussion on deactivation and stabilization.) At the end of the useful life of the facilities, DOE would evaluate options for D&D or reuse of the facilities. D&D of these facilities would not occur for many years. When DOE is ready to propose D&D of these facilities, an appropriate NEPA review will be conducted. (p. S-5)
Section 4.31 states that “it is assumed that the equipment within the building would be deactivated and the facilities stabilized to a condition suitable for reuse.” (p. 4-391, emphasis added) Such a process would include removing both nuclear materials and the equipment. However, DOE does not indicate how it would ensure, either through legal or regulatory means, that the facilities would not be reused for MOX fuel production purposes. The ROD for the Storage and Disposition of Weapons-Usable Fissile Materials Final PEIS indicates that DOE would try to limit facility licenses in order to prevent use of the MOX FFF for commercial MOX production (as well as limiting reactor licenses). This is not discussed in the Surplus Plutonium Disposition DEIS.
- What are the effects of an accident involving a cask near water? In chapter L, the DEIS describes various tests done on casks (e.g. drop tests). However, the immersion test is done a separate cask, one which has not gone through the series of physical stress tests. How would the accident analysis change if such a test were performed? Are there plausible scenarios for a cask falling from a height and being immersed in water (e.g. accidents on bridges over rivers)? DOE’s final environmental impact statement should answer these questions.
The “dual-track” strategy and its emphasis on MOX rests on a number of faulty political and technical assumptions. Two of the most important are, first, the idea that the US must implement a MOX program to ensure Russian participation in a disposition program.. As we have shown above, this is false for a number of reasons. Second, is the idea that the dual-track provides technical backup in the case of problems with one of the options. This idea is faulty because immobilization is necessary to process 17 of the 50 metric tons of surplus plutonium, and so must be made to operate successfully in any case.
A MOX disposition program poses a number of long-term proliferation risks not adequately considered by DOE. Most significantly, such a program will finance a MOX fuel fabrication facility in Russia, providing the only missing link in Minatom’s plans for a plutonium economy. It also poses severe safety and environmental dangers, particularly in its reliance on again Russian reactors.
Furthermore, immobilization provides a number of other advantages over MOX. Reactor control issues would not be present under an immobilization program. The number of facilities and operations would be reduced and the overall cost of the program would be lower.
The DEIS is insufficient as an environmental analysis document. The DOE has failed to include the communities living near the reactors their opportunity to participate in the process. It is insufficient to assume the NRC re-licensing process will accommodate their concerns. Furthermore, many reactor-related issues have been left out of this document.
Similarly, the DOE has failed to demonstrate that the sites chosen for conversion of uranium hexafluoride to uranium dioxide are representative of the actual sites which may be used. DOE has also failed to involve the affected citizens near these sites in the NEPA process.
The DEIS also has a number of deficiencies which need to be addressed. The DOE has failed to analyze a reasonable alternative which would involve a single facility undertaking the pit disassembly and conversion, as well as the immobilization process. The facility accident analysis does not adequately address the issue of worker risk and the effects of accidents on involved workers. The results for non-involved workers are not fully presented. There are numerous other deficiencies and unanswered questions which need to be resolved.
Unless DOE studies the proper options and provides complete analysis the final environmental impact statement will be fundamentally flawed and incomplete.
The Institute for Energy and Environmental Research strongly urges the Department of Energy to:
- Select immobilization of all 50 metric tons of plutonium. Immobilization is the best alternative for meeting the non-proliferation and disarmament goals of the program while minimizing the impacts. The MOX option should be rejected for both technical and policy reasons, because it could create many safety and proliferation problems, even while addressing the security of surplus weapons plutonium. Certainly, it is in the interest of the US to encourage plutonium disposition in Russia, and to support such a program financially. However, DOE has not adequately explored other options for reconciling Russian policy on plutonium as an economic asset with the need to put surplus plutonium in non-weapons-usable form.
- The DOE should analyze the option of conversion and immobilization of all 50 tons of surplus plutonium utilizing a single facility
- The DOE should revise its accident analysis to include involved workers.
- The DOE should provide integrated impacts for each alternative analyzed. A clear and concise summary of those impacts should be provided and comparisons made between the two major classes of alternatives: Hybrid and Immobilization.
- The DOE should develop technical back-up options by developing alternate immobilization technologies, perhaps through pilot scale work to handle Rocky Flats materials.
- See Table 6-1 of National Academy of Sciences, Plutonium Disposition: Reactor-Related Options. (Washington DC: National Academy Press, 1995). ↩ Return
- Joint study, p. WR-36-37. ↩ Return
- The reason for the large number of alternatives is differences in siting and whether new facilities would be constructed for some parts of the mission or whether existing facilities can or would be utilized. ↩ Return
- Natural uranium contains about 0.711% U-235, 0.005% U-234 and the rest (99.284%) U-238. The enrichment of the U-235 is necessary in order for light water reactors to sustain a chain reaction. ↩ Return
- Jack Bailey, remarks made at the 3rd International Policy Forum: “Deploying the reactor/MOX Option for Plutonium Disposition within the Current System of U.S. and Canadian Nuclear Reactors – Regulatory, Policy Impediments,” Landsdowne, VA., March 21, 1996 ↩ Return
- DOE, Cost Analysis in Support of Site Selection for Surplus Weapons-Usable Plutonium Disposition, (DOE/MD-0009 Rev. 0) July 22, 1998. p. 3-1 ↩ Return
- Joint United States- Russian Plutonium Disposition Study, September 1996, p. Sum-17. ↩ Return
- Leonid Piskunov, Yadernyi Ob’ekt za Okalitsei Uralskoi Stolitsy, Ektaerinburg: 1997. ↩ Return
- Notes of Hisham Zerriffi taken at the Aug. 20 Idaho Falls hearing on the Surplus Plutonium Disposition Draft Environmental Statement ↩ Return