Comments of the Institute for Energy and Environmental Research to the Nuclear Regulatory Commission on White papers presented by LES (Louisiana Enrichment Services) regarding the proposed enrichment plant at Hartsville, Trousdale County, Tennessee
Arjun Makhijani and Annie Makhijani
14 November 2002
Analysis of need and the no-action alternative
The need for the project must be assessed according to two primary criteria:
- the market for enrichment services in light of existing supply as well as demand
- national security considerations, including the current, projected, and desirable downblending of both Russian and US highly enriched uranium (HEU) for the purposes of fulfilling non-proliferation and disarmament commitments as well as for reducing the risks of nuclear diversion, especially in the aftermath of the tragic events of September 11, 2001.
However, the analysis by LES does not provide an analysis of either of these considerations. Rather it makes reference to “Congressional policy pronouncements” that there is an established need for a domestic source of uranium enrichment capacity. This is a completely insufficient basis for asserting the need for a project that will have a major impact on the supply of enrichment services as well as on national and global security.
LES must provide the documentation and analysis on the basis of which it is asserting the need for the project. If it is going to rely on congressional policy pronouncements, then the economic and technical basis of those pronouncements must be set forth in sufficient detail for an independent assessment of their validity to be made. There is no way in which the NRC or any other body can assess the soundness of LES’s assertion unless such documentation and analysis is provided.