FUKUSHIMA NEWS

~ ~ ~ ~ ~ ~ ~

Help the
NO NUKES Y'ALL
campaign
y'all

Nuclear Watch South is a 501(c)(3) tax-deductible charitable organization.

{ thanks }

PayPal
It's your safe and secure
way to donate on-line

~ ~ ~ ~ ~ ~ ~

to Nuclear Watch South using
safe, secure

Nuclear Watch South is
a 501(c)(3) tax-deductible charitable organization

thanks

~ ~ ~ ~ ~ ~ ~

Educating and activating the grassroots to create a
nuclear-free future

~

PO Box 8574
Atlanta, GA 31106
404-378-4263
nukewatchsouth@mindspring.com

NO NUKES Y'ALL!

ACTION CENTER | STOP THE MOX BOONDOGGLE

No Plutonium in TVA Reactors

Stop MOX ~ Study Plutonium Disposition Alternatives

YOUR COMMENTS NEEDED — GO ON RECORD FOR THE FUTURE!

The National Environmental Policy Act (NEPA) requires governments and corporations to seek, record and respond to PUBLIC INPUT on major hazardous projects, like MOX PLUTONIUM FUEL through an Environmental Impact Statement (EIS) process. The EIS is required under NEPA to "analyze all possible environmental impacts of the proposed project." NEPA is a powerful tool for the public because a deficient EIS is open to LEGAL CHALLENGE. The the public is invited to comment on the DRAFT SUPPLEMENTAL PLUTONIUM DISPOSITION EIS. You can comment on the SEIS using the handy e-mail researched and written by experts provided here. DEADLINE FOR COMMENTS IS OCTOBER 10, 2012. Background on the MOX issue is provided below and elsewhere on nonukesyall.org.

E-MAIL ACTION LETTER!

This handy e-mail action letter will help you make the most of this great opportunity to make a difference in plutonium disposition.

You may edit the letter as you wish. There are many resources and links on nonukesyall.org to help you get more information about plutonium and plutonium disposition options. Because the MOX plutonium program relies heavily on the buy-in of Tennessee Valley Authority, the TVA board is being sent a copy of your comments as well.

October 10, 2012

Ms. Sachiko McAlhany
SPD Supplemental EIS NEPA Document Manager
U.S. Department of Energy
P.O. Box 2324
Germantown, MD 20874-2324

RE: SUPPLEMENTAL SURPLUS PLUTONIUM DISPOSITION DRAFT ENVIRONMENTAL IMPACT STATMENT

Dear Ms. McAlhany,

I appreciate the National Environmental Policy Act and the opportunity to comment as a member of the affected public on the draft Supplemental Environmental Impact Statement on plutonium disposition. I am aware that the need for another SEIS is an indication of on-going problems confronting DOE’s administration of the plutonium disposition program and that cost overruns, safety concerns, schedule delays, technical challenges and lack of mission clarity continue to plague DOE and the plutonium disposition program.

This current EIS process began more than five years ago which reveals the confusion persisting with the MOX plutonium program. Furthermore, the NEPA process for the overall plutonium disposition program began in June 1994, with the Storage and Disposition of Weapons-Usable Fissile Materials Programmatic Environmental Impact Statement (SPEIS). In the subsequent 18 years not a single gram of plutonium, beyond small amounts of test material, has been disposed of via the so-called “preferred alternative” — use of the controversial mixed oxide fuel (MOX) for nuclear power reactors.

The MOX plutonium program stands as a monument to DOE ineptitude in pursuing a misguided mission that has fallen prey to manipulation by special interests such as the French government-owned company AREVA and giant, Warren Buffett-owned, Shaw Industries. The MOX program is 15 years behind schedule, 400% over budget, and there are still no reactors willing to load the controversial MOX plutonium fuel.

Following are some of the serious concerns that must be analyzed but still are not addressed adequately in the draft SEIS:

1) Plutonium fuel (MOX) must be reconsidered as the “preferred alternative” for plutonium disposition. The MOX plutonium fuel program appears destined to fail to secure plutonium because there are no reactors to irradiate MOX. The TVA reactors being pursued by DOE are old reactors with unsafe designs and troubled operating histories and TVA has expressed reluctance to rush into the experimental MOX program. Previous experience with DOE to produce tritium, hydrogen for nuclear weapons, has showcased DOE exploitation and unfair treatment of TVA. TVA should heed the experience and take a pass on MOX.

2) DOE has not outlined the operational schedule of the MOX plutonium fuel factory under construction at the Savannah River Site and it is clear that production levels at the MOX plant, if it is ever operates, will be greatly constrained not only because of lack of reactors but also because experimental MOX testing required in the Browns Ferry (GE Fukushima-type) boiling water reactors (BWRs), test review and Nuclear Regulatory licensing for commercial use will take 10 years or more. A previous experimental MOX plutonium fuel test in Duke Power reactors failed and the test will have to be repeated, or irradiation periods shortened resulting in inefficient plutonium protection.The $5-billion MOX plutonium factory at SRS is at risk of sitting idle even if it can obtain an operating license (which is being challenged by Nuclear Watch South and others) and complete start-up testing. Global Nuclear Fuel in NC has recently entered into MOX production discussions and affirms that testing will be required for experimental MOX fuel, pushing against industry and DOE speculation that the NRC can be convinced to waive further experimental MOX testing.

3) A comprehensive study on options to manage plutonium as waste is needed to effectively compare alternatives with MOX plutonium disposition program. The “glass can-in-canister” option is included in the draft SEIS and I support it as a viable disposition option. DOE must immediately place can-in-canister and other plutonium disposition options back on the table. The MOX program appears fated to total failure and DOE must renew analysis of all non-MOX options, some of which were included in early NEPA analyses. DOE must actively pursue an array of non-MOX disposal options lest the collapse of the MOX program results in a total halt to plutonium disposition. 
 
4) DOE must explain what analysis of experimental MOX use in a “generic reactor…for any additional future potential utility customers” means. DOE has been focused on use of experimental MOX in Tennessee Valley Authority reactors, but inclusion of a “generic reactor” in the SEIS notice indicates that DOE is far from certain it can secure TVA’s old reactors for experimental MOX use. DOE must be transparent if it solicits utilities to potentially irradiate experimental MOX in its reactors. Any modifications to reactors to use experimental MOX plutonium fuel must be discussed including physical modifications needed and associated NRC licensing impacts.

5) DOE must proceed cautiously in the disposal of non-pit plutonium in the Waste Isolation Pilot Plant. The only way that such disposal will be considered is if the requisite Waste Acceptance Criteria and other regulatory requirements are met and if there is sufficient space in WIPP, as specified by law. Any decision to ship contaminated non-MOXable plutonium to WIPP is an affirmation that disposal of plutonium utilizing the “spent fuel standard” — by which plutonium is placed in a matrix with a radiation barrier — is being abandoned. The SEIS must discuss the philosophical shift to the plutonium disposition program and analyze that elimination of the “spent fuel standard” can open the door to cheaper, effective alternative plutonium disposal options that do not necessitate such an extremely high radiation barrier. The possibility that DOE will attempt to dispose of all weapons-grade plutonium in WIPP raises a host of troubling legal, regulatory and environmental concerns. The option to dispose of surplus plutonium in WIPP was rejected in the original Programmatic EIS and its inclusion in the draft SEOS warrants reopening the PEIS process.

I appreciate your diligent consideration of these comments. Please notify me when the final SEIS is issued.

Respectfully submitted,

cc: Tennessee Valley Authority Board of Directors

Your letter will be signed with the information you provide below:

* = Required

* First Name:

* Last Name:

* Address #1:

Address #2:

* City:

* State: * Zip:

* Email Address:

MOX BACKGROUND In 1994, the U.S. Department of Energy (DOE) declared one-half the U.S. inventory of plutonium to e surplus and decided to turn tons of the nuclear weapons-grade material into an experimental, risky and proliferating nuclear reactor fuel called mixed-oxide, MOX, for mixing oxides of plutonium with conventional uranium for a different breed of fuel. DOE proposes to process 50 TONS of plutonium into MOX, a risky business indeed when 15 POUNDS can make a bomb like that which devastated Nagasaki at the close of World War II. PLUTONIUM is man--made and one of the most toxic materials on Earth. It is fissionable and, except for uranium, the only material that produces a nuclear explosion. Plutonium has low-energy radioactivity which means you can hold it in your hand, but it is deadly if even a speck is inhaled. The U.S. and Russia went overboard making plutonium in the Cold War, so now there are tons and tons of this dangerous man-made element with a virtually eternal lifespan on hand and it is a colossal security risk.

TAKE ACTION TO STOP MOX "FACTORY TO NOWHERE"

There is widespread agreement that something must be done to secure plutonium from future use in nuclear bombs. Proponents of the MOX boondoggle purport to "burn" the indestructible plutonium but they are really relying on the intense radiation that results from fissioning radioactive fuel in a nuclear reactor to protect the plutonium from theft. There are currently no customers for the MOX plutonium fuel and if any utilities were to put up their aging reactors, they would face 10 years of rigorous testing and licensing for commercial use of MOX. DOE has been heavily courting Tennessee Valley Authority, another federal agency, to put up its aged ice condenser Sequoyah near Chattanooga, TN, which is bound to the weapons-grade tritium production mission already. In addition, DOE is zeroing in on Browns Ferry, GE Fukushima-style reactors in AL. Another reactor on the Hanford Nuclear Reservation in Washington State rumored to be in talks with DOE backed off because of citizen pressure. The SEIS also speculates about unbuilt reactors and generic reactor licensing, evidence of the blind alley MOX now finds itself in. Because the failure of the MOX program is now obvious, the NEPA mandate to consider alternatives to the proposed project must be revisited. Other concerns with MOX are listed above in the comment letter you can sign and send.

YOUR ACTION SUPPORTS NEW STUDY OF
PLUTONIUM IMMOBILIZATION ALTERNATIVES

There is a better way to secure plutonium, via PLUTONIUM IMMOBILIZATION which is the process of securing plutonium in the glassification process used to stabilize highly radioactive tank waste at Savannah River Site (SRS). Ironically, the vast inventory of tank waste still unprocessed in 60-year-old underground tanks at SRS is leftover from past decades of separating plutonium from irradiated reactor fuel by chopping the radioactive reactor waste into little pieces and dissolving everything in hazardous industrial acids. The tank waste contains all the highly radioactive byproducts from the reactor fuel that produced the plutonium we are now trying to manage. The highly radioactive waste is supposed to be turned into a stable borosilicate glass in the Defense Waste Processing Facility's vitrification project. Managing disposition of the plutonium inventory and high-level waste inventory at SRS in one unified program administered by DOE's Environmental Management program should be given due consideration in the EIS.

STOP MOX Y'ALL!

"To the village square
we must carry the facts
of atomic energy.
From there must come America's voice."

ALBERT EINSTEIN

~~~~~~

FREE STICKERS!

Cool stickers FREE with FREE membership in
Nuclear Watch South!

~~~~~~

PLUTONIUM SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT
Federal Register Notice

~~~~~~

PLUTONIUM WAITS
Glenn Carroll

JUST CAN IT
Edwin S. Lyman, Ph.D.

PLUTONIUM END GAME
Arjun Makhijani, Ph.D.

PLUTONIUM:
THE LAST FIVE YEARS
Don Moniak

RADIOACTIVE WASTES AND THE GLOBAL NUCLEAR ENERGY PARTNERSHIP
Robert Alvarez

ANA MOX FACTS

GREENPEACE
PLUTONIUM FACTS

MORE GREENPEACE PLUTONIUM

NUCLEAR NONPROLIFERATION:
DOE NEEDS TO ADDRESS UNCERTAINTIES WITH AND STRENGTHEN INDEPENDENT SAFETY OVERSITE OF ITS PLUTONIUM DISPOSITION PROGRAM
Government Accountability Office

~~~~~~

PLUTONIUM FACTS

Year plutonium was discovered by Glenn Seaborg and others
1941

Minimum amount of plutonium required for bomb
1 kilogram (2.2 pounds)

Amount of plutonium used in Nagasaki bomb
6.5 kilograms

Average amount of plutonium used in modern atom bomb
3 kilograms

Estimated amount of U.S. weapons-grade plutonium
85,000 kilograms (93.5 tons)

Estimated amount of Russian weapons-grade plutonium
160,000 kilograms (176 tons)

Hazards associated with plutonium
Radiation, fire, inhalation, ingestion, criticality, reactivity, decay

Length of time that
plutonium 239 (weapons-grade) remains hazardous
240,000 years
(Ten 24,000-year half-lives)

Form of plutonium most hazardous to life
Plutonium oxide powder

What happens to plutonium metal when exposed to air
Gradually turns to
plutonium oxide powder

Lethal amount of plutonium oxide powder (inhaled)
2000 micrograms

Lethal amount of plutonium oxide powder (ingested)
500,000 micrograms

Amount of sugar substitute in average 1 gram package
1,000,000 micrograms

Excerpted from Stop Plutonium Fuel: Plutonium Index, compiled by Don Moniak. Blue Ridge Environmental Defense League, www.bredl.org

~ ~ ~ ~ ~ ~ ~

Help the NO NUKES Y'ALL campaign y'all

Nuclear Watch South is a 501(c)(3) tax-deductible charitable organization.

{ thanks }

PayPal It's your safe and secure way to donate on-line

~ ~ ~ ~ ~ ~ ~

to Nuclear Watch South using safe, secure

Nuclear Watch South is a 501(c)(3) tax-deductible charitable organization

thanks

~ ~ ~ ~ ~ ~ ~

Educating and activating the grassroots to create a nuclear-free future

~

PO Box 8574 Atlanta, GA 31106 404-378-4263 nukewatchsouth@mindspring.com

NO NUKES Y'ALL!

ACTION CENTER | STOP THE MOX BOONDOGGLE

No Plutonium in TVA Reactors

Stop MOX ~ Study Plutonium Disposition Alternatives

E-MAIL ACTION LETTER!

Your letter will be signed with the information you provide below:

STOP MOX Y'ALL!

"To the village square we must carry the facts of atomic energy. From there must come America's voice." ALBERT EINSTEIN

~~~~~~

Cool stickers FREE with FREE membership in Nuclear Watch South!

~~~~~~

~~~~~~

MORE ON PLUTONIUM

~~~~~~

PLUTONIUM FACTS

Help the
NO NUKES Y'ALL
campaign
y'all

PayPal
It's your safe and secure
way to donate on-line

to Nuclear Watch South using
safe, secure

Nuclear Watch South is
a 501(c)(3) tax-deductible charitable organization

Educating and activating the grassroots to create a
nuclear-free future

PO Box 8574
Atlanta, GA 31106
404-378-4263
nukewatchsouth@mindspring.com

"To the village square
we must carry the facts
of atomic energy.
From there must come America's voice."

ALBERT EINSTEIN

Cool stickers FREE with FREE membership in
Nuclear Watch South!