Blue Ridge Environmental Defense League

Request for Supplemental Environmental Impact Statement on Surplus Plutonium Disposition and Mixed Oxide Fuel Fabrication Facility

January 10, 2001

Secretary of Energy Bill Richardson
Forrestal Building
1000 Independence Avenue
Washington, DC 20037

Re: Request for Supplemental Environmental Impact Statement on Surplus Plutonium Disposition and Mixed Oxide Fuel Fabrication Facility

Dear Secretary Richardson:

I write on behalf of the Board of Directors of the Blue Ridge Environmental Defense League, Inc. to request that you take immediate action to halt design, construction, and licensing work on the proposed Mixed Oxide (MOX) Fuel Fabrication Facility (MFFF) at the Department’s Savannah River Site in South Carolina. A year ago you signed the Record of Decision (ROD) for the Surplus Plutonium Disposition Environmental Impact Statement (SPDEIS), which approved the use of surplus military plutonium as nuclear reactor fuel in commercial nuclear power plants. Because recent revelations about this program prove that the document you signed was based on incomplete and incorrect information, we ask that you order a Supplemental Environmental Impact Statement before resuming work on the MFFF.

When you signed the Record of Decision allowing for the design and construction of this plutonium fuel factory, the Department claimed that it could handle and manage the liquid radioactive wastes generated by plutonium purification using liquid acid processing--a necessity for making plutonium fuel. For example, in response to concerns about the liquid radioactive waste stream, the Department stated that no remotely handled transuranic waste would be created and “generation rates for contaminated liquid waste would generally be small.” (Page 3-972, SPDEIS). Quite frankly, today’s estimates makes the Department’s final analysis--based largely on the contractor’s proposal--look like fiction.

The new numbers prove this and other similar statements in the Department’s analysis to be untrue.
Instead of generating 680 cubic meters of transuranic waste today the estimate is 3,200 cubic meters. Instead of 570 gallons of liquid low level radioactive waste, today the estimate is 4,280,000 gallons. Without explanation, facility operations have been extended from 10 to 20 years.

Most notable is the fact that more than one million gallons of a new liquid radioactive waste stream at Savannah River Site--called “liquid high alpha activity waste”--will be produced during the operating life of the plant. At the present time, the Department and its contractor only have plans for where to store this waste at the already filled-to-capacity F-Area Tank Farm at Savannah River Site. Neither the Department nor the contractor has a plan for what to do with this new waste, a clear indication that the plutonium fuel program is a throwback to the disastrous era of the “produce first, worry later” operations of the Cold War.

The table below illustrates the stark differences between what the Department predicted in its final analysis one year ago and the reality reported in the Environmental Report (ER) for the Duke Cogema Stone and Webster (DCS) Mixed Oxide (MOX) Fuel Fabrication Facility submitted to the Nuclear Regulatory Commission (NRC) on December 20, 2000. These changes are aggravated by the fact that whereas the Department claimed ten years of operation, the contractor is now claiming twenty years of operation.

Changes in estimates of annual radioactive waste generated at MOX Fuel Fabrication Facility

Waste Stream

SPDEIS November 1999

DCS ER December 2000

Liquid High Alpha Activity Waste DOE anticipated 130 gallons of
contact-handled transuranic waste
81,300 gallons
Liquid Low-level Waste 57 gallons 214,000 gallons
Solid Transuranic Waste 68 cubic meters 160 cubic meters

In essence, this program continues to represent the worst kind of bait-and-switch. The Department’s estimates reported in the final SPDEIS were based on earlier estimates from Duke Cogema Stone and Webster and published by DOE in the Environmental Synopsis of Proposal for MOX Fuel Fabrication And Reactor Irradiation Services in April 1999. Before that, the Department claimed in its Draft SPDEIS in July 1998 that a plutonium fuel plant would generate less than 1 gallon of contact-handled TRU waste and that liquid acid plutonium processing--quaintly called plutonium oxide polishing in official reports--was an “unreasonable alternative.” In reality, the Department decided in September 1997 to abandon its experimental “dry” plutonium pyroprocessing scheme it claimed would work for MOX, but never told the public.

The Department of Energy is obligated under the National Environmental Policy Act to provide accurate and complete information before embarking on projects on federal land. The Department failed in this fundamental duty. While we believe this level of misinformation calls for the Department to abandon the plutonium fuel program, we will accept as a minimum a Supplemental Environmental Impact Statement to be completed prior to the expenditure of additional funds. We at BREDL recognize that you have only a few days in office; therefore, we urge you to act now to right this wrong.

We look forward to hearing your reply to this request.

Respectfully submitted,

Don Moniak

more info: BREDL Press Release , DOE reply to letter , Insights from Offsite (No. 2001-1 2/15/01) , NRC MOX Environmental Review website