A research consortium of The Texas A&M University System and The University of Texas System

Senior Technical Review Report March 1996

The Group once again emphasized the urgency of both the U.S. and Russia moving forward with selecting and implementing plutonium disposition options.

Comments and Recommendations Based on the PEIS Briefing

The DOE representatives gave a reasonably detailed presentation on the draft PEIS on "Storage and Disposition of Weapons-Usable Fissile Materials." Based on this presentation and an examination of several parts of the Summary document, the Review Group has several concerns, indicated in the following comments.

The absence of significant discussion on safeguards and security in the presentation was striking. We understand this is a result of limitations on what is to be included in a PEIS. We further understand that the PEIS is only one of three "pathways" to the decision on storage and disposition of weapons materials, the other two being costs and proliferation issues. (This is clearly described on page S-1.) However we believe any public discussion of the PEIS should explicitly describe these three factors because the fundamental concerns relate to the safeguards and security aspects.

We are skeptical about the feasibility of the deep borehole concept, which has been included as a "reasonable" disposition option. Obtaining approval for a site will be difficult. Licensing the site for an approach never examined by EPA or NRC will be extremely time consuming. We realize that the deep borehole concept has some potential advantages, but we remain skeptical about being able to achieve these on a competitive timescale. Proceeding with this option is inconsistent with our previous recommendation to proceed with plutonium disposition on an urgent basis. In our judgement, this option should not be described as "reasonable" but, rather, as "not necessarily unreasonable".

We were surprised to find that electrometallurgical treatment continues as a "reasonable" option for immobilization. Previous presentations to the Review Group had indicated this approach was being dropped. We believe it should have been.

Some of the Review group believe that elimination from the PEIS of the European MOX fabrication/irradiation option is inappropriate and decidedly premature. Under NEPA, exclusion of this option from the PEIS will preclude further consideration. However, environmental impacts of this option are almost exclusively overseas and are therefore excluded from NEPA coverage. Thus, there is no environmental impact basis for excluding the option. The reason cited for elimination of this option is that European fabricators have expressed an unwillingness to fabricate U.S. plutonium for irradiation in European reactors primarily because of the fabricators' concern that this would have an adverse impact upon the market for reprocessing services, which they also offer. This objection, however, would not necessarily apply to a limited program of irradiating a few assemblies or even a few reloads. Moreover, commercial objections might be subject to reversal for policy reasons and because of future changes in the market. Indeed reactor grade MOX fabrication and irradiation already are licensed and commercially proven activities in Europe. NRC licensing of MOX might be achieved quickly, but there is no guarantee of this. This existing capability provides the potential for acceleration of the disposition process if the political and commercial problems, as well as transportation issues, can be resolved. Therefore some members of the Review Group believe that the European pathway to early implementation, particularly through initial demonstrations of the disposition process, should not be foreclosed at this time.

The Summary (page S-15) indicates the possibility of using LWRs both for the disposition of plutonium and for the production of tritium. We consider that, both from a policy and public perspective, these two requirements should be kept separate, and should not be accomplished in the same reactor or reactors. The Office of Fissile Material Disposition should be involved only in the various aspects of storage and disposition of plutonium and HEU, and not in the production of new weapons material.

Finally, the Review Group strongly objects to misleading presentations in the Summary, for example, of what are purportedly calculations of latent cancer fatalities in the public and the work force for various disposition options. While we have not reviewed the entire draft PEIS, the following comments, based upon review of the Summary, indicate our concerns:

1. We were informed that it was assumed that new nuclear plants would not displace any existing operating units of any kind. This is an insupportable assumption.
   

2. Figures S-14 through S-18, S-23, S-25, S-27 through S-31, and S-39 through S-44 are unclear in their comparison among existing LWRs, partially completed LWRs, and evolutionary LWRs. A reader easily could conclude that evolutionary LWRs will cause more latent cancer fatalities, emit more radiation and produce more radioactive waste than existing LWRs. Yet they have been designed to reduce both radioactive emissions and radioactive waste. We were informed that these descriptions were based on two requirements: (a) actual data were used for existing plants, but maximum allowable limits were used for unfinished or evolutionary plants; (b) no error bars or uncertainty limits were allowed to be used, leading the reader to conclude the graphs are accurate. Both requirements lead to highly misleading presentations, which are accentuated by not having an explanation in appendices A and B to put the calculations into perspective. We understand that the DOE Office of General Counsel ordered that no error bars be shown. The General Counsel should be asked to reconsider this order since it affects the determination of technical issues.
   

3. The figures used to describe the impact of the proposed operations are misleading as they lack the perspective of existing baseline values and, in some instances, a time-frame. Also the scales on which the data are displayed exaggerate very small effects. For example:
   
   1. Figures S-17 and S-18 are for the life of operation. They indicate that during this period the operation's radiological impact on cancer fatalities would be less than 3.5 or less than 6 additional cancer deaths among the resident and worker populations, respectively. However, they do not reflect the several million "spontaneous" (non-radiation related) cancer deaths that would be expected to occur among these populations during the same period. Nor do they indicate the bounds of the uncertainties around these estimates, thus the reader could conclude that the estimates are precise. However, both BEIR and NCRP have indicated that, at very low doses, zero effect is within the range of likelihood. Specifically the National Committee for Radiation Protection, in Report #121, 'Principles and Application of Collective Dose in Radiation Protection', recommends "When the collective dose is smaller than the reciprocal of the relevant risk coefficient, the risk assessment should note that the most likely number of excess cancer deaths is zero. This recommendation applies in this case, which the reader can only discover by reading the Appendices carefully."
      

   2. Figure S-22 is another example of deceptive graphics in which the graphics developed to describe risks misrepresent the impact of the proposed operations in that they do not include baseline values (levels). The reader will not realize that the chart shows additional low level waste generated by the alternatives. The several thousand times greater volume generated by evolutionary LWRs compared to existing LWRs is because the large volume generated by the existing LWRs is not included in the chart. Also, Figures S-4 through S-13 give no indication whether they represent total or additions to existing quantities or, for that matter, whether the numbers shown for different options have been calculated on the same basis.
      

      We recommend that the figures be revised where applicable to reflect existing operations and the cancer death rate among the general, non-exposed population.
      

4. In several parts of the text, it is stated that "the dose to the population living within 80 km (50 mi) of the site would be within 100 person-rem per year". However, the reader is not told whether this is acceptable or how it compares with other population doses, including those received from natural sources.
   

   In summary, the Review Group is skeptical about some of the retained alternatives, disturbed about the misleading character of the Summary, and concerned about the lack of discussion of the major reason for the program, i.e., the safeguards and security (or proliferation) issue.
   

Comments on Reactor Disposition Options

The DOE Team presented the status of the efforts to evaluate the disposition option that would utilize LWRs or CANDUs. The STRG's comments on the review are as follows:

LWR OPTIONS

The team reported that the major technical focus in utilizing LWRs has been on full core loading of mixed U-Pu oxide (full MOX core), revealing some developmental issues primarily associated with relatively new applications of burnable absorbers. To avoid potential delays in resolving these technical issues and in licensing a newer technology, DOE has shifted its emphasis to evaluating partial (1/3) core loading of MOX fuel.

While disappointed that the DOE did not begin by focusing on the 1/3rd core option, the STRG endorses this shift and a strategy that would apply the partial MOX core in the initial stages of a disposition campaign, followed by full MOX core applications when the developmental problems are resolved. The STRG recommends that this strategy, including development work, be defined in detail, along with an implementation plan that reflects the urgency of starting a disposition option. The strategy and implementation plan should include the following characteristics:

1. Proven technology for the initial applications:
   
   • MOX fuel and reactor designs should be patterned on existing commercial MOX experience; European design and operational experience should be utilized fully. DOE should consider obtaining all such pertinent experience from the Europeans and make it available to U.S. utilities that have shown strong interest in the MOX disposition option.
     

   • Changes in the number of control rods or the configuration of the reactor vessel head or internals should be barred from consideration for partial core loading.
     

   • Pu metal conversion processes should be selected that will provide oxide with essentially the same characteristics as present commercially used MOX, (excepting the Pu isotopic distribution and possibly some gallium residue in the MOX fuel).
     

   • Existing facilities should be used wherever practical at each stage (conversion, fuel fabrication, and reactor operation). There is potential through this approach to reduce the time to start the disposition and the costs of the disposition process as well as to minimize the introduction of new facilities which will later have to be decommissioned. DOE should also take into account potential difficulties in documenting design basis and equipment qualifications for existing facilities. The STRG concurs with the DOE position to consider initially only those reactors that will not require license renewal or extension during the length of the disposition program.
     

2. Program Acceleration Planning
   
   • The STRG is concerned that there is an insufficient sense of urgency in pursuing the disposition options. The new formulation of strategy and planning should place first priority on timeliness, given that the security and health & safety requirements are met. Cost is an important factor but should not be subjugated to timeliness.
     

   • Emphasis should be given to narrowing down the reactor burning options to permit greater focus. Seventeen sub options in this category were identified as still under evaluation.
     

   • In-depth review of licensing issues should be sought with NRC on the several vendor partial MOX core designs, including the impact of the weapons Pu isotopic distribution.
     

   • The STRG considers it important to demonstrate as soon as possible the adequacy of full scale MOX fuel assemblies derived from weapons grade Pu. Specifically:
     
     1. Since MOX fabrication appears to be on the critical path, strategies should be defined to accelerate the fabrication of such demonstration lead assemblies. European commercial facilities should be considered as well as experimental-level facilities in the U.S. National Laboratories.
        

     2. Early demonstration of lead MOX fuel assembly irradiation in commercial reactors should be sought, including European reactors that are already licensed for MOX operation. Elimination of the Euratom MOX fabrication/reactor burning option should be reconsidered if elimination would preclude such early demonstrations.
        

   • The DOE team cited many political and commercial difficulties in utilizing western European capability for the reactor disposition option. Since there is high technical potential to start the process much sooner by that route, the political and commercial issues should continue to be addressed aggressively.
     

3. Necessary R&D
   
   • An effective R&D program should be mounted to evolve as rapidly as possible to the utilization of full MOX core so as to minimize the number of reactor sites and their auxiliary facilities and associated transportation and security requirements.
     

   • The R&D program will need to include in the development of MOX fuel fabrication facilities the impact of using new burnable absorbers as well as reactor design and fuel reliability issues related to new burnable absorber design features.
     

4. Scope
   
   • All criteria governing the disposition process should be included in the strategy and planning. Security and proliferation resistance should be treated explicitly, criteria that were not strongly treated during the DOE team presentations.
     

   • Arbitrary budget constraints, as distinct from defining a focused, cost effective plan, should not be imposed on the planning process. The appropriate full scope of the needed program should be defined, permitting a later, more intelligent application of budget restraints if necessary.
     

CANDU OPTIONS

The DOE team reported that no technical difficulties had arisen in the full core MOX application, that the much shorter fuel pins could be more easily handled in the existing MOX fabrication facility (FMEF) at Hanford, and that political acceptance at this time in Canada was good although the new administration was reviewing the issue.

The small size of the CANDU assemblies raises questions as to the sufficiency of the radiation barrier to comply with the spent fuel standard. The proposed solution was to raise their proliferation resistance to the LWR spent fuel level by latching many assemblies together to increase the radiation level and make them more bulky. Effort is also underway to raise the Pu level in the design to try to achieve a fuel cost reduction of about a factor of two.

The STRG comments on the LWR option also apply to the CANDU option where applicable. Further, the fact that CANDU reactors use on line refueling could result in some increase in proliferation risks.

JOINT U.S./RUSSIAN STUDIES

The LWR disposition option is included in an overall study with the Russians of a broad array of disposition options. This effort is particularly important since it provides the potential for a "middle way" for Russian cooperation (quid pro quo) in the disposition process: between their present preference for the untimely and costly fast reactor disposition option and their complete rejection of weapons Pu direct disposal and immobilization options. This prospect is justification in itself for vigorous pursuit by the U.S. of the LWR disposition option.

SPENT FUEL STANDARD

In defining the components of the spent fuel standard, isotopic denaturing should be included. Although the practical level of isotopic denaturing does not eliminate potential diversion for terrorist nuclear explosive use, it is a significant additional barrier to host nation re-use or rump nation military use.

UTILITY COOPERATION IN THE MOX FUEL DISPOSITION PROCESS

The efforts to explore the interest of the utilities in assisting in the commercial LWR disposition option are important to achieving timely implementation of the option. There is concern, however, that the incorporation of a tritium production mission with the excess weapons Pu disposition mission will introduce complexity, delay, and increased public apprehension into the disposition mission. The STRG also expressed concern on reversing the long-standing U.S. policy of separating nuclear weapons production from nuclear electricity production. As indicated in the STRG comments on the draft PEIS, the Office of Fissile Material Disposition should be involved only in the various aspects of storage and disposition of weapons grade Pu and highly enriched U.