Record of Decision for the Surplus Plutonium Disposition Final Environmental Impact Statement

Federal RegisterJan 11, 2000

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DEPARTMENT OF ENERGY

Record of Decision for the Surplus Plutonium Disposition Final

Environmental Impact Statement

AGENCY: Department of Energy.

ACTION: Record of decision.

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SUMMARY: In November 1999, the Department of Energy (DOE or the

Department), in accordance with the National Environmental Policy Act

(NEPA), issued the Surplus Plutonium Disposition Final Environmental

Impact Statement (SPD EIS)(DOE/EIS-0283). The SPD EIS was the

culmination of a process started on May 22, 1997, when DOE published a

Notice of Intent (NOI) in the Federal Register (62 FR 28009) announcing

its decision to prepare an EIS that would tier from the analysis and

decisions reached in connection with the Storage and Disposition of

Weapons-Usable Fissile Materials Final Programmatic EIS (Storage and

Disposition PEIS)(DOE/EIS-0229). Accordingly, the Surplus Plutonium

Disposition Draft Environmental Impact Statement (SPD Draft EIS) (DOE/

EIS-0283-D) was prepared and issued in July 1998. It identified the

potential environmental impacts of reasonable alternatives for the

proposed siting, construction, and operation of three facilities for

the disposition of up to 50 metric tons of surplus plutonium, as well

as a No Action Alternative. These three facilities would accomplish pit

1 disassembly and conversion, plutonium conversion and

immobilization, and mixed oxide (MOX) 2 fuel fabrication.

The SPD Draft EIS also analyzed the potential impacts of fabricating a

limited number of MOX fuel assemblies, referred to as lead assemblies,

for testing in a reactor before starting full production of MOX fuel,

and the potential impacts of examining the lead assemblies after

irradiation.

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\1\ A nuclear weapon component.

\2\ A physical blend of uranium oxide and plutonium oxide.

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For the alternatives that included MOX fuel fabrication, the SPD

Draft EIS described the potential environmental impacts of using from

three to eight commercial nuclear reactors to irradiate MOX fuel. The

potential impacts were based on a generic reactor analysis included in

the Storage and Disposition PEIS that used actual reactor data and a

range of potential site conditions. In May 1998, DOE initiated a

procurement process to obtain MOX fuel fabrication and reactor

irradiation services. In March 1999, DOE awarded a contract to Duke

Engineering & Services, COGEMA Inc., and Stone & Webster (known as DCS)

to provide the requested services. Full implementation of the base

contract was contingent upon the successful completion of the NEPA

process. A Supplement to the SPD Draft EIS (DOE/EIS-0283-S) was issued

in April 1999, which analyzed the potential environmental impacts of

using MOX fuel in six specific reactors named in the DCS proposal.

Those reactors are: Catawba Nuclear Station Units 1 and 2 in South

Carolina, McGuire Nuclear Station Units 1 and 2 in North Carolina, and

North Anna Power Station Units 1 and 2 in Virginia. The SPD Final EIS

addresses the comments received during the public review process for

the SPD Draft EIS and the Supplement to the draft.

The Department has decided to implement a program to provide for

the safe and secure disposition of up to 50 metric tons of surplus

plutonium as specified in the Preferred Alternative in the Surplus

Plutonium Disposition Final Environmental Impact Statement. The

fundamental purpose of the program is to ensure that plutonium produced

for nuclear weapons and declared excess to national security needs (now

and in the future) is never again used for nuclear weapons.

Specifically, the Department has decided to use a hybrid approach for

the disposition of surplus plutonium. This approach allows for the

immobilization of approximately 17 metric tons of surplus plutonium and

the use of up to 33 metric tons of surplus plutonium as MOX fuel. The

Department has selected the Savannah River Site in South Carolina as

the location for all three disposition facilities. Based upon this

selection, the Department will authorize DCS to fully implement the

base contract. In addition, the Department has selected the Los Alamos

National Laboratory in New Mexico as the location for lead assembly

fabrication and Oak Ridge National Laboratory in Tennessee as the site

for post-irradiation examination of lead assemblies.

As previously stated in the Storage and Disposition PEIS Record of

Decision (62 FR 3014, January 21, 1997), the use of MOX fuel in

existing reactors will be undertaken in a manner that is consistent

with the United States' policy objective on the irreversibility of the

[[Page 1609]]

nuclear disarmament process and the United States' policy discouraging

the civilian use of plutonium. To this end, implementing the MOX

alternative will include government ownership and control of the MOX

fuel fabrication facility at a DOE site, and use of the facility only

for the surplus plutonium disposition program. There will be no

reprocessing or subsequent reuse of spent MOX fuel. The MOX fuel will

be used in a once-through fuel cycle in existing reactors, with

appropriate arrangements, including contractual or licensing

provisions, limiting use of MOX fuel to surplus plutonium disposition.

EFFECTIVE DATE: The decisions set forth in this Record of Decision are

effective upon publication of this document, in accordance with DOE's

National Environmental Policy Act Implementing Procedures and

Guidelines (10 CFR Part 1021) and the Council on Environmental Quality

regulations implementing NEPA (40 CFR Parts 1500-1508).

ADDRESSES: Copies of the SPD EIS and this Record of Decision may be

obtained by placing a call to an answering machine or facsimile machine

at a toll free number (1-800-820-5156), or by mailing a request to:

Bert Stevenson, NEPA Compliance Officer, Office of Fissile Materials

Disposition, U.S. Department of Energy, Post Office Box 23786,

Washington, DC 20026-3786.

The full SPD EIS, including the 54-page Summary, and this Record of

Decision are available on the Office of Fissile Materials Disposition's

web site. The address is http://www.doe-md.com. The full SPD EIS is

also available on DOE's NEPA web site at http://tis.ch.doe.gov/nepa.

FOR FURTHER INFORMATION CONTACT: Questions concerning the plutonium

disposition program can be submitted by calling or faxing them to the

same toll free number (1-800-820-5156), or by mailing them to Mr. Bert

Stevenson at the above address. Comments may also be submitted

electronically by using the Office of Fissile Materials Disposition's

web site. The address is http://www.doe-md.com.

For general information on the DOE NEPA process, please contact:

Carol Borgstrom, Director, Office of NEPA Policy and Assistance, U.S.

Department of Energy, 1000 Independence Avenue, S.W., Washington, DC

20585, 202-586-4600 or 1-800-472-2756.

SUPPLEMENTARY INFORMATION:

Background

The United States and Russia are working together to reduce the

threat of nuclear weapons proliferation worldwide by disposing of

surplus plutonium in a safe, secure, environmentally acceptable and

timely manner. Comprehensive disposition actions are needed to ensure

that surplus plutonium is converted to proliferation-resistant forms.

In September 1993, President Clinton issued the Non-proliferation and

Export Control Policy in response to the growing threat of nuclear

weapons proliferation. Further, in January 1994, President Clinton and

Russia's President Yeltsin issued a Joint Statement Between the United

States and Russia on Non-Proliferation of Weapons of Mass Destruction

and the Means of Their Delivery. In accordance with these policies and

statements, the focus of U.S. non-proliferation efforts is to ensure

the safe, secure, long-term storage and disposition of surplus weapons-

usable plutonium and highly enriched uranium (HEU). In July 1998, the

United States and Russia signed a 5-year agreement to provide the

scientific and technical basis for decisions concerning how surplus

plutonium will be managed and a statement of principles with the

intention of removing approximately 50 metric tons 3 of

plutonium from each country's stockpile. The Department is pursuing

both the immobilization and mixed oxide (MOX) fuel approaches to

surplus plutonium disposition, which include the siting, construction,

operation, and deactivation of three facilities at one or two of four

DOE candidate sites:

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\3\ Some materials are already in a final disposition form

(i.e., irradiated fuel) and will not require further action before

disposal.

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1. A facility for disassembling pits (a weapons component) and

converting the recovered plutonium, as well as plutonium metal from

other sources, into plutonium dioxide suitable for disposition.

Candidate sites for this facility are the Hanford Site (Hanford) near

Richland, Washington; Idaho National Engineering and Environmental

Laboratory (INEEL) near Idaho Falls, Idaho; the Pantex Plant (Pantex)

near Amarillo, Texas; and the Savannah River Site (SRS) near Aiken,

South Carolina.

2. A facility for immobilizing surplus plutonium for eventual

disposal in a geologic repository pursuant to the Nuclear Waste Policy

Act. This facility would include a collocated capability for converting

non-pit plutonium materials into plutonium dioxide suitable for

immobilization. The immobilization facility would be located at either

Hanford or SRS.

3. A MOX fuel fabrication facility for fabricating plutonium

dioxide into MOX fuel. Candidate sites for this facility are Hanford,

INEEL, Pantex, and SRS. Also part of the proposed action are MOX lead

assembly 4 activities at five candidate DOE sites: Argonne

National Laboratory--West (ANL-W) at INEEL; Hanford; Lawrence Livermore

National Laboratory (LLNL) in Livermore, California; Los Alamos

National Laboratory (LANL) near Los Alamos, New Mexico; and SRS. The

Department would fabricate a limited number of MOX fuel lead assemblies

for testing in reactors before starting full production of MOX fuel

under the proposed MOX fuel program. Post-irradiation examination

activities would be performed at one of two sites, ANL-W or Oak Ridge

National Laboratory (ORNL) in Oak Ridge, Tennessee.

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\4\ A MOX lead assembly is a prototype reactor fuel assembly

that contains MOX fuel.

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In March 1999, DOE awarded a multi-phase contract to Duke

Engineering & Services, COGEMA Inc., and Stone & Webster (collectively

known as DCS) for the design, licensing, construction, operation, and

eventual deactivation of the MOX fuel fabrication facility and for

irradiating the MOX fuel. Full implementation of the base contract was

contingent upon the successful completion of the National Environmental

Policy Act (NEPA) process. The contract includes future provisions to

use MOX fuel in six specific reactors: Catawba Nuclear Station Units 1

and 2 in South Carolina, McGuire Nuclear Station Units 1 and 2 in North

Carolina, and North Anna Power Station Units 1 and 2 in Virginia.

DOE is aware that a decision to use surplus plutonium in MOX fuel

could be perceived as a change in U.S. civilian fuel cycle policy. In

fact, however, such a decision would not represent a change in policy.

The United States does not encourage the civilian use of plutonium, and

does not itself engage in reprocessing for the purposes of either

nuclear explosives or nuclear power generation. Disposition of excess

plutonium, regardless of the specific option chosen, will not change

this basic fuel cycle policy.

NEPA Process

Surplus Plutonium Disposition Draft EIS

In December 1996, the Department published the Storage and

Disposition PEIS. That PEIS analyzes the potential environmental

consequences of alternative strategies for the long-term storage of

weapons-usable plutonium and highly enriched uranium and the

disposition of weapons-usable

[[Page 1610]]

plutonium that has been or may be declared surplus to national security

needs.5 The Record of Decision (ROD) for the Storage and

Disposition PEIS, issued on January 14, 1997, outlines DOE's decision

to pursue an approach to plutonium disposition that would make surplus

weapons-usable plutonium inaccessible and unattractive for weapons use.

DOE's disposition strategy, consistent with the Preferred Alternative

analyzed in the Storage and Disposition PEIS, allows for both the

immobilization of some (and potentially all) of the surplus plutonium,

and use of some of the surplus plutonium as MOX fuel in existing

domestic, commercial reactors. The disposition of surplus plutonium

would also involve disposal of both the immobilized plutonium and the

MOX fuel (as spent nuclear fuel) in a potential geologic

repository.6

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\5\ DOE addressed the disposition of surplus highly enriched

uranium in a separate environmental impact statement, the

Disposition of Surplus Highly Enriched Uranium Final Environmental

Impact Statement, issued in June 1996, with the Record of Decision

issued in July 1996.

\6\ The Nuclear Regulatory Commission has reviewed DOE's plans

to phase immobilized material into the potential geologic

repository, and has agreed that with adequate canister and package

design features, the immobilized plutonium waste forms can be made

acceptable for disposal in the repository.

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On May 22, 1997, DOE published a Notice of Intent (NOI) in the

Federal Register (FR) announcing its decision to prepare an EIS that

would tier from the analysis and decisions reached in connection with

the PEIS discussed above. The follow-on EIS, the Surplus Plutonium

Disposition Environmental Impact Statement, addresses the extent to

which each of the two plutonium disposition approaches (immobilization

and MOX) would be implemented, and analyzes candidate sites for

plutonium disposition facilities, as well as alternative technologies

for immobilization.7 In July 1998, DOE issued the SPD Draft

EIS. That draft included a description of the potential environmental

impacts of using from three to eight commercial nuclear reactors to

irradiate MOX fuel. The potential impacts were based on a generic

reactor analysis presented in the Storage and Disposition PEIS. In

March 1999, DOE awarded a contract, contingent on completion of the

NEPA process, for MOX fuel fabrication and irradiation services, that

identified the specific reactors that would be used to irradiate the

MOX fuel. After this contract award, DOE issued a Supplement to the SPD

Draft EIS (Supplement) (April 1999) that describes the potential

environmental impacts of using MOX fuel at the three proposed reactor

sites. These site-specific analyses have been incorporated into the SPD

Final EIS.

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\7\ The SPD EIS also analyzes a No Action Alternative, i.e., the

possibility of disposition not occurring but, instead, continuing to

store surplus plutonium in accordance with the Storage and

Disposition PEIS ROD.

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Alternatives Considered

The SPD EIS analyzes the potential environmental impacts associated

with implementing pit disassembly and conversion of the recovered

plutonium and clean plutonium metal at four candidate sites; conversion

and immobilization of plutonium from non-pit sources at two candidate

sites, and MOX fuel fabrication activities at four candidate sites. The

SPD EIS also evaluates immobilizing plutonium in ceramic or glass

forms, and compares the can-in-canister approach with the homogenous

ceramic immobilization and vitrification approaches that were evaluated

in the Storage and Disposition PEIS. As part of the MOX option, the SPD

EIS also evaluates the potential impacts of fabricating MOX fuel lead

assemblies (for test irradiation in domestic, commercial nuclear power

reactors) at five candidate DOE sites, the impacts of subsequent post-

irradiation examination of the lead assemblies at two candidate DOE

sites, and the impacts of irradiating MOX fuel in domestic, commercial

reactors.

Fifteen surplus plutonium disposition alternatives and the No

Action Alternative are evaluated in the SPD EIS. These action

alternatives are organized into 11 sets of alternatives, reflecting

various combinations of facilities and candidate sites, as well as the

use of new or existing buildings.

Each of the 15 alternatives includes a pit conversion facility, but

the need for additional facilities in each alternative varies depending

on the amount of plutonium to be immobilized. Eleven alternatives

involve the hybrid approach of immobilizing 17 metric tons of surplus

plutonium and using 33 metric tons for MOX fuel, and therefore require

all three facilities. Four alternatives involve immobilizing all 50

metric tons, and therefore include only a pit conversion facility and

an immobilization facility. The No Action Alternative does not involve

disposition of surplus weapons-usable plutonium, but instead addresses

continued storage of the plutonium in accordance with the Storage and

Disposition PEIS Record of Decision (ROD), with the exception that DOE

is now considering leaving the repackaged surplus pits in Zone 4 at

Pantex for long-term storage in lieu of Zone 12 as originally planned.

Immobilization Technology Alternatives

The Storage and Disposition PEIS discusses several immobilization

technologies, including the homogenous ceramic and vitrification

alternatives that were evaluated in detail, as well as variants of

those alternatives, which include the ceramic and glass can-in-canister

approaches and a homogenous approach using an adjunct melter. The ROD

for the Storage and Disposition PEIS states that DOE would make a

determination on the specific technology on the basis of ``the follow-

on EIS.'' The SPD EIS is that follow-on EIS, and it identifies the

ceramic can-in-canister approach as the preferred immobilization

technology.

In order to bound the estimate of potential environmental impacts

associated with ceramic and glass immobilization technologies, the

Storage and Disposition PEIS analyzes the construction and operation of

vitrification and ceramic immobilization facilities that employ a

homogenous approach. These facilities are based on generic designs that

do not involve the use of existing facilities or specific site

locations. These generic designs allow for surplus plutonium to be

immobilized in a homogenous form, either within a ceramic matrix and

formed into disks, or vitrified as borosilicate glass logs.

In order to support a decision on the immobilization technology and

form, the SPD EIS evaluates the potential environmental impacts of the

ceramic and glass can-in-canister technologies, and compares those

impacts with the impacts of the homogenous facilities evaluated in the

Storage and Disposition PEIS. Hanford and SRS are the candidate sites

for immobilization based on their existing plans for a high-level waste

vitrification facility.

MOX Fuel Fabrication Alternatives

Alternatives that involve the fabrication of MOX fuel include the

use of the fuel in existing domestic, commercial nuclear power

reactors. The environmental impacts of using MOX fuel in these reactors

are evaluated generically in the Storage and Disposition PEIS. When the

SPD Draft EIS was published, the specific reactors were not known;

therefore, the generic analysis from the Storage and Disposition PEIS

was incorporated by reference in the SPD Draft EIS.

In May 1998, DOE initiated a procurement process to obtain MOX fuel

fabrication and irradiation services. In compliance with its NEPA

regulations in 10 CFR 1021.216, DOE requested that each offeror

provide, as

[[Page 1611]]

part of its proposal, environmental information specific to its

proposed MOX facility design and the domestic, commercial reactors

proposed to be used for irradiation of the fuel. That information was

analyzed by the Department to identify potential environmental impacts

of the proposals, and DOE's analysis was documented in an Environmental

Critique prepared pursuant to 10 CFR 1021.216(g). That analysis was

considered by the selection official as part of the award decision. DOE

awarded a contract (contingent on completion of the NEPA process) to

the team of Duke Engineering & Services, COGEMA Inc., and Stone &

Webster (DCS) in March 1999 to provide the requested services. These

services include design, licensing, construction, operation, and

eventual deactivation of the MOX fuel fabrication facility, as well as

irradiation of the MOX fuel in six domestic, commercial reactors. The

reactors proposed by DCS are Duke Power Company's Catawba Nuclear

Station, Units 1 and 2; and McGuire Nuclear Station, Units 1 and 2; and

Virginia Power Company's North Anna Power Station, Units 1 and 2. Under

the contract, no construction, fabrication, or irradiation of MOX fuel

is authorized until the SPD EIS ROD is issued. Such site-specific

activities, and DOE's exercise of contract options to allow those

activities, would be contingent on decisions in this ROD.

Because the Environmental Critique contains proprietary

information, it was not made available to the public. However, as

provided in 10 CFR 1021.216(h), an Environmental Synopsis of the

Environmental Critique was provided to the U.S. Environmental

Protection Agency, made available to the public, and incorporated into

the SPD EIS. Sections of the SPD EIS were revised or added to include

reactor-specific information and were issued as a Supplement to the SPD

Draft EIS. A Notice of Availability was published in the Federal

Register on May 14, 1999 (64 FR 264019), providing a 45-day public

comment period on the Supplement.8 This Supplement was

distributed to the local reactor communities, to stakeholders who

received the SPD Draft EIS, and others as requested.

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\8\ On June 15, 1999, DOE held a public meeting in Washington,

D.C., to receive comments on the Supplement to the SPD Draft EIS.

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Under the hybrid alternatives, DOE could produce up to 10 MOX fuel

assemblies for testing in domestic, commercial reactors before

commencement of full-scale MOX fuel fabrication, although it is likely

that only two lead assemblies would be needed.9 These lead

assemblies would be available for irradiation to support NRC licensing

and fuel qualification efforts. Potential impacts of MOX fuel lead

assembly fabrication are analyzed for three of the candidate sites for

MOX fuel fabrication (Hanford, ANL--W at INEEL, and SRS), and two

additional sites, LANL and LLNL. Pantex was not considered for lead

assembly fabrication because it does not currently have any facilities

capable of MOX fuel fabrication. Post-irradiation examination of the

lead assemblies would be conducted, if required, to support NRC

licensing activities. Two potential sites for this activity are

analyzed in the SPD EIS: ANL--W and Oak Ridge National Laboratory

(ORNL). As discussed previously, DOE's preferred locations for lead

assembly fabrication and post-irradiation examination are LANL and

ORNL, respectively.

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\9\ The potential impacts of fabricating 10 lead assemblies and

irradiating 8 of them were analyzed in the SPD EIS. Should fewer

lead assemblies than analyzed be fabricated or irradiated, the

potential impacts would be less than those described in the SPD EIS.

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The Department also considered a No Action Alternative, as required

by NEPA. In the No Action Alternative, surplus weapons-usable plutonium

in storage at various DOE sites would remain at those locations. The

vast majority of pits would continue to be stored at Pantex, and the

remaining plutonium in various forms would continue to be stored at

Hanford, INEEL, LLNL, LANL, Rocky Flats Environmental Technology Site

(RFETS), and SRS.

Materials Analyzed

There are eight general categories used to describe the 50 metric

tons of surplus plutonium analyzed in the SPD EIS, which represent the

physical and chemical nature of the plutonium. Two of the categories--

clean metal (including pits) and clean oxide--could either be

fabricated into MOX fuel or immobilized. The remaining six categories

of material--impure metals, plutonium alloys, impure oxides, uranium/

plutonium oxides, alloy reactor fuel, and oxide reactor fuel--would be

immobilized.

Preferred Alternative

As previously noted, DOE's Preferred Alternative for the

disposition of surplus weapons-usable plutonium is analyzed as

Alternative 3 in the SPD Final EIS. The Preferred Alternative

encompasses the following:

Pit Disassembly and Conversion at SRS (new construction)

Construct and operate a new pit conversion facility at SRS to

disassemble nuclear weapons pits and convert the plutonium metal to a

declassified oxide form suitable for international inspection and

disposition using either the immobilization or the MOX/reactor

approach. SRS is preferred for the pit conversion facility because the

site has extensive experience with plutonium processing, and the pit

conversion facility would complement existing missions and take

advantage of existing infrastructure.

Immobilization at SRS (new construction and the Defense Waste

Processing Facility) 10

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\10\ The Savannah River Site was previously designated to be

part of DOE's preferred alternative for immobilization in the Notice

of Intent issued in May 1997.

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Construct and operate a new immobilization facility at SRS using

the ceramic can-in-canister technology. This technology would

immobilize plutonium in a ceramic form, seal it in cans, and place the

cans in canisters filled with borosilicate glass containing intensely

radioactive high-level waste at the existing Defense Waste Processing

Facility (DWPF). This preferred can-in-canister approach at SRS would

complement existing missions, take advantage of existing infrastructure

and staff expertise, and enable DOE to use an existing facility (i.e.,

DWPF).

Implementation of the can-in-canister approach would require the

availability of sufficient quantities of high-activity radionuclides

from SRS high-level waste to DWPF. Due to problems experienced with the

In-Tank Precipitation process for separating high-activity

radionuclides from liquid high-level waste, DWPF is currently operating

with sludge feed, not liquid high-level waste. A thorough search for

alternatives to the In-Tank Precipitation process has identified two

viable processes (ion exchange and small tank precipitation) for

separating the high-activity fraction from the liquid high-level waste

and sending this fraction to DWPF. Extensive laboratory and bench scale

testing has been conducted on both of these processes. Test results

indicate that either process is capable of separating the high-activity

radionuclides from the high-level waste and feeding those radionuclides

to DWPF, although further research and development is

necessary.11 DOE is

[[Page 1612]]

preparing a supplemental EIS on the proposed replacement of the In-Tank

Precipitation process at SRS (NOI at 64 FR 8558, February 22, 1999).

Designation of a preferred process and construction of a pilot scale

plant for scale-up of the preferred process are the next steps planned

to resolve this issue.

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\11\ The National Research Council (the Council) is also

evaluating a replacement technology for the In-Tank Precipitation

process. The Council's study committee issued an interim report in

October 1999. This committee recommends further research and

development for the ion exchange and small tank precipitation

alternatives, and for caustic side solvent extraction, a third

process that would separate high-activity radionuclides that could

be sent to DWPF.

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In addition to these alternatives, the Department is analyzing the

potential environmental impacts of another action alternative, direct

grout, in light of technical and cost considerations. Under the direct

grout alternative, the cesium component of the high-activity

radionuclides would be entombed in grout rather than remain in the

high-activity fraction provided to DWPF for vitrification and eventual

disposal in a geologic repository. Therefore, the direct grout

alternative would not provide the radiation barrier needed for surplus

plutonium disposition using the can-in-canister technology at SRS.

However, a DOE waste management requirement (DOE Manual 435.1,

Radioactive Waste Management, Section II.B.2) provides that, for direct

grout material to be disposed of as now being analyzed, ``key

radionuclides would have to be removed to the maximum extent that is

technically and economically practical.'' This criterion would not be

met in the event that any other action alternative is determined to be

viable after further evaluation. Therefore, DOE regards the direct

grout alternative as reasonable only if all of the other action

alternatives analyzed in the supplemental EIS prove not to be viable.

In summary, although a specific method for providing the high-level

waste needed for the can-in-canister immobilization alternatives for

surplus plutonium disposition has not been determined, DOE is confident

that an acceptable technical solution will be available at SRS. The

ceramic can-in-canister approach would involve slightly lower

environmental impacts than the homogenous approach. The ceramic can-in-

canister approach would involve better performance in a potential

geologic repository and provide greater proliferation resistance than

the glass can-in-canister approach.

MOX Fuel Fabrication at SRS (new construction)

Construct and operate a new MOX facility at SRS and produce MOX

fuel containing surplus weapons-usable plutonium for irradiation in

existing domestic, commercial reactors. SRS is preferred for the MOX

facility because this activity would complement existing missions and

take advantage of existing infrastructure and staff expertise.

Lead Assembly Fabrication at LANL

Based on consideration of the capabilities of the candidate sites

and input from the contractor team chosen for the MOX approach, DOE

prefers LANL for lead assembly fabrication. LANL is preferred because

it already has fuel fabrication facilities that would not require major

modifications, and has existing site infrastructure and staff

experience. Additionally, the surplus plutonium dioxide needed to

fabricate the lead assemblies would already be on site (no

transportation required).

Post-Irradiation Examination at ORNL

If post-irradiation examination is necessary for the purpose of

qualifying the MOX fuel for commercial reactor use, DOE prefers to

perform that task at ORNL. ORNL has the existing facilities and staff

expertise needed to perform post-irradiation examination as a matter of

its routine activities; no major modifications to facilities or

processing capabilities would be required. In addition, ORNL is about

500 kilometers (km) from the reactor site that would irradiate the fuel

(one of the reactors located at the McGuire Nuclear Station in North

Carolina).

Environmental Impacts of Preferred Alternative

Chapter 4 and certain appendices of the SPD Final EIS analyze the

potential environmental impacts of the surplus plutonium disposition

alternatives in detail. The SPD Final EIS also evaluates the maximum

impacts that would result at each of the potential disposition sites.

Based on the analyses in the SPD Final EIS, including public comments

on the SPD Draft EIS, the areas with impacts of most interest are as

follows:

Disposition Facilities During Construction

Socioeconomics At its peak in 2003, construction of the three new

surplus plutonium disposition facilities at SRS under this alternative

would require 1,968 construction workers and should generate another

1,580 indirect jobs in the region. As the total employment increase of

3,548 direct and indirect jobs represents only 1.3 percent of the

projected regional economic area (REA) workforce, it should have no

major impact on the REA. Moreover, construction under the Preferred

Alternative should have little impact on the community services

currently offered in the region of influence. In fact, it should help

offset the 20 percent reduction in SRS's total workforce otherwise

projected for the years 1997-2005.

Facility Accidents. The construction of new surplus plutonium

disposition facilities at SRS could result in worker injuries or

fatalities. DOE-required industrial safety programs would be in place

to control the risks. Given the estimated 6,166 person-years of

construction labor and standard industrial accident rates,

approximately 610 cases of nonfatal occupational injury or illness and

less than one fatality could be expected. As all construction would be

in non-radiological areas, no radiological accidents should occur.

Cultural Resources. During conduct of the cultural resources

impacts analysis for the Preferred Alternative, it was determined that

construction of surplus plutonium disposition facilities at SRS could

produce impacts on archaeological resources requiring mitigation.

Archaeological investigations performed for the surplus plutonium

disposition program discovered five archaeological sites in the

proposed construction area. At least two of these sites have been

recommended by DOE to the South Carolina State Historic Preservation

Officer (SHPO) as eligible for nomination to the National Register of

Historic Places. It appears that these sites were occupied during

several different prehistoric periods, including the Late Woodland

(A.D. 800-1000) and Mississippian (A.D. 1000-1600) Periods. These

periods are poorly understood in the Central Savannah River Area.

Therefore, these sites could contribute significantly to a better

understanding of the Late Woodland and Mississippian Periods in this

part of North America. Potential adverse impacts on these sites could

be mitigated through either avoidance or data recovery. DOE currently

plans to mitigate impacts by avoiding these sites.

Disposition Facilities During Operations

Socioeconomics. After construction, startup, and testing of the new

SRS facilities in 2007, an estimated 1,120 new workers would be

required to operate them. This level of employment should generate an

additional 2,003 indirect jobs in the region. As the total employment

requirement of 3,123 direct and indirect jobs represents 1 percent of

the projected REA, it should have no major impact on the REA. Moreover,

these jobs would have little impact on community services currently

offered in

[[Page 1613]]

the region of influence. In fact, they should help offset the reduction

in SRS's total workforce otherwise projected for the years 1997-2010 of

33 percent.

Facility Accidents (Impact to the public and workers). The most

severe consequences of a design basis accident for the pit conversion

facility would be associated with a tritium release; the most severe

consequences for the immobilization and MOX facilities would be from a

nuclear criticality. Bounding radiological consequences for the

Maximally Exposed Individual (MEI) 12 are from the tritium

release, which would result in a dose of 0.028 rem, corresponding to a

latent cancer fatality (LCF) probability of 1.4 x 10-5. A

nuclear criticality of 10 19 fissions would result in an MEI

dose of 0.0016 rem from an accident at the immobilization facility and

0.016 rem from an accident at the MOX facility. Consequences of the

tritium release accident for the general population in the environs of

SRS would include an estimated 0.050 LCF. The frequency of either a

tritium release or a criticality accident is estimated to be between 1

in 10,000 and 1 in 1,000,000 per year.

---------------------------------------------------------------------------

\12\ The MEI is the hypothetical off-site person who has the

highest exposure. This individual is assumed to be located at the

point of maximum concentration of contaminants 24 hours a day, 7

days a week, for the period of operations under analysis.

---------------------------------------------------------------------------

The combined radiological effects from total collapse of all three

facilities in the beyond-design-basis earthquake would be approximately

18 LCFs. It should be emphasized that a seismic event of sufficient

magnitude to collapse these facilities would likely cause the collapse

of other DOE facilities, and would almost certainly cause widespread

failure of homes, office buildings, and other structures in the

surrounding area. The overall impact of such an event must therefore be

seen in the context not only of the potential radiological impacts of

these other facilities, but of hundreds, possibly thousands, of

immediate fatalities from falling debris. The frequency of such an

earthquake is estimated to be between 1 in 100,000 and 1 in 10,000,000

per year.

Surplus plutonium disposition operations at SRS could result in

worker injuries and fatalities. DOE-required industrial safety programs

would be in place to control the risks. Given the estimated employment

of 11,535 person-years of labor and the standard DOE occupational

accident rates, approximately 420 cases of nonfatal occupational injury

or illness and 0.31 fatality could be expected for the duration of

operations. If a criticality occurred, workers within tens of meters

could receive very high to fatal radiation exposures from the initial

burst. The dose would strongly depend on the magnitude of the

criticality, the distance from the criticality, and the amount of

shielding provided by the structures and equipment between the workers

and the accident.

Transportation. In all, approximately 2,500 shipments of

radioactive materials would be carried out by DOE under the Preferred

Alternative. The total distance traveled on public roads by trucks

carrying radioactive materials would be 4.3 million kilometers.

The maximum foreseeable offsite transportation accident under this

alternative (probability of occurrence: greater than 1 in 10 million

per year) is a shipment of plutonium pits from one of DOE's storage

locations to the pit conversion facility with a most severe (severity

category VIII) accident in a rural population zone under neutral

(average) weather conditions. If this accident were to occur, it could

result in a dose of 87 person-rem to the public for an LCF risk of

0.044 and 96 rem to the hypothetical MEI for an LCF risk of 0.096. (The

MEI, a hypothetical member of the general public, receives a larger

dose than the public as a whole because it is unlikely that a person

would be in position, and remain in position, to receive this

hypothetical maximum dose.) No fatalities would be expected to occur.

The probability of more severe accidents--e.g., less favorable weather

conditions at the time of accident, or occurrence in a more densely

populated area'was also evaluated, and estimated as lower than 1 chance

in 10 million per year.

The total transportation accident risk was estimated by summing the

risks (which takes account of both the probability and consequence of

each type of accident) to the affected population from all hypothetical

accidents. For the Preferred Alternative, that risk is as follows: a

radiological dose to the population of 7 person-rem, resulting in a

total population risk of 0.004 LCF; and traffic accidents resulting in

0.053 traffic fatality.

Irradiating MOX Fuel at Reactor Sites 13

---------------------------------------------------------------------------

\13\ The operators of the proposed reactors have indicated that

little or no new construction would be needed to support the

irradiation of MOX fuel at the sites. As a result, land use; visual,

cultural, and paleontological resources; geology and soils; and site

infrastructure would not be affected by any new construction or

other activities related to MOX fuel use. Nor would there be any

effect on air quality and noise, ecological and water resources, or

socioeconomics.

---------------------------------------------------------------------------

The environmental impacts described below are based on using a

partial MOX core (i.e., up to 40 percent MOX fuel) instead of a low

enriched uranium (LEU) core at the Catawba Nuclear Station near York,

South Carolina; the McGuire Nuclear Station near Huntersville, North

Carolina; and the North Anna Power Station near Mineral, Virginia.

Reactor Accidents. There are differences in the expected risk of

reactor accidents from the use of MOX fuel compared to the use of low

enriched uranium fuel. The change in consequences to the surrounding

population due to the use of MOX fuel is estimated to range from

9.0 x 10-4 fewer to 6.0 x 10-2 additional LCFs

for design basis accidents, and from 7.0 fewer to 1,300 additional LCFs

for beyond-design-basis accidents (16,900 versus 15,600 LCFs in the

worst accident analyzed). Also, some of the beyond-design-basis

accidents could result in prompt fatalities should they occur. The

estimated increase in prompt fatalities due to MOX fuel being used

during one of these accidents would range from no change to 28

additional fatalities (843 versus 815 prompt fatalities). As a result

of these changes in projected consequences, there would be a change in

the risk to the public associated with these accidents. The change in

risk (in terms of an LCF or prompt fatality) to the surrounding

population within 80 km (50 mi) of the proposed reactors is projected

to range from a decrease of 6 percent to an increase of 3 percent in

the risk of additional LCFs from design basis accidents, and from a

decrease of 4 percent to an increase of 14 percent in the risk of

additional prompt fatalities and LCFs from beyond-design-basis

accidents.

The risk to the MEI would also change with the use of MOX fuel.

Using MOX fuel during one of the design basis accidents evaluated is

expected to change the MEI's chance of incurring an LCF from a decrease

of 10 percent to an increase of 3 percent. The change in risk to the

MEI of a prompt fatality or LCF as a result of using MOX fuel during

one of the beyond-design-basis accidents evaluated is expected to range

from a 1 percent increase to a 22 percent increase. In the most severe

accident evaluated, an interfacing systems loss-of-coolant accident

(ISLOCA), it is projected that the MEI would receive a fatal dose of

radiation regardless of whether the reactor was using MOX fuel or LEU

fuel at all of the proposed sites.

Beyond-design-basis accidents, if they were to occur, would be

expected to result in major impacts to the reactors and the surrounding

communities and environment, regardless of whether the

[[Page 1614]]

reactor were using an LEU or partial MOX core. However, there is less

than one chance in a million per year that a beyond-design-basis

accident would actually happen, so the risk from these accidents is

estimated to be low.

Lead Assembly and Post-Irradiation Examination Activities

The analysis of the potential impacts of conducting the lead

assembly activities and post-irradiation examination indicates that

little or no new construction or operational changes would be needed to

support these activities. As a result, land use; visual, cultural, and

paleontological resources; geology and soils; and site infrastructure

would not be affected by any new construction or other activities

related to lead assembly fabrication or post-irradiation examination.

Nor would there be any effect on air quality and noise, ecological and

water resources, or socioeconomics.

Avoidance and Minimization of Environmental Harm

For the Preferred Alternative, at SRS, storm water management and

erosion control measures will be employed during construction of the

disposition facilities. Cultural resources impacts will be mitigated

either by avoidance or data recovery. Initial indications are the

disposition facilities can be located in an area that will avoid

disturbing known cultural resource areas.

During operation of the disposition facilities, radiation doses to

individual workers will be kept at a minimum by maintaining

comprehensive badged monitoring and ``as low as reasonably achievable''

(ALARA) programs during worker rotations. The storage facilities in the

disposition buildings will be designed and operated in accordance with

contemporary DOE orders and/or NRC regulations to reduce risks to

workers and the public.

From a non-proliferation standpoint, the highest standards for

safeguards and security will be employed during transportation, storage

(i.e., the stored weapons standard 14) and disposition. DOE

will coordinate the transport of surplus plutonium and fresh MOX fuel

with State officials, consistent with contemporary policy. Although the

actual routes will be classified, they will be selected to circumvent

populated areas where ever possible, maximize the use of interstate

highways, and avoid bad weather. DOE will coordinate emergency

preparedness plans and responses with involved states through liaison

programs. The packaging, vehicles, and transport procedures being used

are specifically designed and tested to prevent radiological release

under all credible accident scenarios. The NRC regulates safeguards and

security at facilities it licenses commensurate with the type of

facility and type and amount of fissile or radioactive material

present. Commercial nuclear power reactors have stringent regulations

to prevent sabotage or diversion of special nuclear materials. Physical

protection and safeguards and security will be ensured at the reactor

sites by continued implementation of NRC requirements.

---------------------------------------------------------------------------

\14\ The ``Stored Weapons Standard'' for weapons-usable fissile

materials storage was initially defined in Management and

Disposition of Excess Weapons Plutonium, National Academy of

Sciences, 1994. DOE defines the Stored Weapons Standard as follows:

The high standards of security and accounting for the storage of

intact nuclear weapons should be maintained, to the extent

practical, for weapons-usable fissile materials throughout

dismantlement, storage, and disposition.

---------------------------------------------------------------------------

Environmentally Preferable Alternatives

The environmentally preferable alternative is the No Action

Alternative. Under this alternative, surplus weapons-usable plutonium

materials in storage at various DOE sites would remain at those

locations. The vast majority of pits would continue to be stored at

Pantex, and the remaining plutonium in various forms would continue to

be stored at Hanford, INEEL, LLNL, LANL, RFETS, and SRS. The No Action

Alternative would not satisfy the purpose and need for the proposed

action because DOE's disposition decisions in the Storage and

Disposition PEIS ROD would not be implemented. That ROD announced that,

consistent with the Preferred Alternative in the Storage and

Disposition PEIS, DOE had decided to reduce, over time, the number of

locations where the various forms of plutonium are stored, through a

combination of storage and disposition alternatives. Implementation of

much of this decision requires the movement of surplus materials to

disposition facility locations. Without disposition facilities, only

pits that have been moved from RFETS to Pantex would be relocated in

accordance with the Storage and Disposition PEIS ROD. All other surplus

materials would continue to be stored indefinitely at their current

locations, with the exception that DOE is considering leaving the

repackaged surplus pits in Zone 4 at Pantex for long-term storage

instead of zone 12 as originally planned. An appropriate environmental

review will be conducted when the specific proposal for this change has

been determined (e.g., whether additional magazines need to be air-

conditioned). The analysis in the SPD EIS assumes that the surplus pits

are stored in Zone 12 in accordance with the ROD for the Storage and

Disposition PEIS.

Among the ``action'' alternatives analyzed in the SPD EIS, the

environmentally preferable action alternative is the 50-Metric-Ton

Immobilization Alternative with the Immobilization and Pit Conversion

facilities located at SRS. This alternative would involve immobilizing

all 50 metric tons of surplus plutonium at SRS. Under this alternative,

only two facilities, the pit conversion facility and the immobilization

facility, would be needed to accomplish the surplus plutonium

disposition mission. Both the pit conversion and immobilization

facilities would be new construction near the area currently designated

for the Actinide Packaging and Storage Facility in F-Area. In addition,

the canister receipt area at DWPF in S-Area would be modified to

accommodate receipt and processing of the canisters transferred from

the immobilization facility for filling with vitrified high-level

waste. The pit conversion and immobilization facilities would be the

same as those described for the Preferred Alternative, except that all

the plutonium dioxide produced in the pit conversion facility would be

transferred to the immobilization facility. To accommodate the

additional 33 metric tons of plutonium that would be received from the

pit conversion facility, the immobilization facility would be operated

at a higher throughput (5 metric tons per year rather than 1.7 metric

tons per year), and the operating workforce at the immobilization

facility would be increased.

Comparison of Preferred Alternative to Other Alternatives

The Preferred Alternative requires the construction and operation

of three new facilities; some minor modifications to, and work at, two

existing DOE facilities; and use of existing domestic, commercial

nuclear reactors for MOX fuel irradiation. The other hybrid

alternatives would require the same facilities and activities; the

immobilization-only alternatives would require the construction and

operation of only two facilities. The environmentally preferable

alternative, which is the No Action Alternative, does not involve

construction or operation of any facilities, or use of new or existing

facilities, other than those currently in use for the continued storage

of the surplus plutonium. Furthermore, no transportation would be

involved for the No Action

[[Page 1615]]

Alternative, and continued storage under this alternative would not

affect any key environmental resource area at any of the seven storage

locations. However, there would be doses to workers and the general

population (and associated health effects) throughout the storage

period at all of these locations. At SRS, the health effects from 50

years of storage under the No Action Alternative would be lower than

those associated with implementation of the Preferred Alternative.

Nonetheless, the Preferred Alternative would still contribute to the

dose and associated health effects at locations where supporting

activities like lead assembly fabrication and post-irradiation

examination would occur.

The environmentally preferable action alternative, which is an

immobilization-only alternative, would require the construction and

operation of two, rather than three, facilities. For all of the key

environmental resource areas except transportation and worker dose, the

potential impacts of the Preferred Alternative are greater than for the

environmentally preferable action alternative, although for most of the

resource areas, the difference is less than 20 percent. The estimated

LCFs and traffic fatalities are higher for the environmentally

preferable action alternative, although both are well below one LCF.

Worker dose is the same for both the preferred and the environmentally

preferable action alternatives.

Relative ranking of the Preferred Alternative to other action

alternatives varies by resource area. For all alternatives evaluated in

the SPD EIS, the incremental concentrations of criteria air pollutant

concentrations would be less than 2 percent of the applicable

regulatory standard. The relative ranking of Preferred Alternative to

the other action alternatives varies with the specific pollutant; for

some, the Preferred Alternative ranks higher, for others, lower. The

Preferred Alternative produces more, by approximately 5 to 25 percent,

regulated waste than any of the other action alternatives.

All of the action alternatives would generate employment

opportunities at each of the proposed facilities. In general, the

Preferred Alternative requires the greatest number of construction and

operation workers of all the action alternatives. However, for one

alternative, approximately 5 percent more construction workers would be

needed. The amount of land that would be disturbed for implementing any

of the alternatives is relatively small. The Preferred Alternative

requires the most land disturbance, and could potentially affect

cultural resource areas at SRS. However, as previously discussed in

this ROD, DOE currently plans to mitigate impacts by avoiding sites

that are eligible or potentially eligible for the National Register of

Historic Places. SRS is the only candidate site at which cultural

resource issues involving the proposed action have been identified. The

action alternative with the least amount of land disturbance uses

existing facilities at Hanford.

Because of the location of the proposed facilities relative to

other activities at the sites, radiation doses would be received by

construction workers at both INEEL and SRS. Doses to workers from

construction and operation activities for each of the action

alternatives could result in approximately 2.0 LCFs, with essentially

no difference among any of the alternatives. There will be no dose (and

therefore, no LCFs) to the general population for any of the action

alternatives during construction of the proposed facilities. Although

there is a small population dose associated with each of the action

alternatives, no LCFs are expected to occur in the general population

from routine operations for any of the alternatives. The most severe

nonreactor design basis accident postulated for the Preferred

Alternative, and all but one other action alternative, is a design

basis fire in the pit conversion facility resulting in a tritium

release. The resulting dose is highest for the Preferred Alternative,

however, the associated dose would not be expected to result in any

LCFs in the general population. None of the action alternatives is

expected to result in traffic fatalities from nonradiological accidents

or LCFs from radiological exposures or vehicle emissions. Impacts

estimated for routine operations and postulated accidents at the

reactor sites would be identical for all the hybrid alternatives.

Comments on Surplus Plutonium Disposition Final EIS

After issuing the SPD Final EIS, the Department received two

letters. All of the issues raised in these letters have been covered in

the body of the SPD Final EIS and in the Comment Response Document. The

first letter contained a single comment requesting that the decision on

a location for the lead assembly work retain the flexibility to allow

doing the work at SRS. Based on consideration of the capabilities of

the candidate sites and input from the team chosen for the MOX

approach, the Department has decided to use LANL for fabrication of MOX

fuel rods for use in fabrication of lead assemblies. LANL was selected

because it already has facilities that will not require major

modifications for fuel rod fabrication, and takes advantage of existing

infrastructure and staff experience. Additionally, the surplus

plutonium dioxide needed to fabricate the MOX fuel rods for lead

assemblies will already be on site.

The second letter contained numerous comments that opposed the use

of MOX fuel in commercial power reactors. The commentor believes that

the selection process of DCS and the commercial reactors was not opened

to sufficient public scrutiny. The commentor repeated an earlier

request that the Department hold additional public meetings in the

vicinity of the three reactor sites before closing the public comment

period, and that all information on the MOX project, including data

submitted by DCS, DOE's Environmental Critique, and ORNL's data on

expected radionuclide activities in MOX fuel, be made available to the

public. During the public comment period on the Supplement to the SPD

Draft EIS, which included specific reactor analyses, DOE held a public

hearing in Washington, D.C., on June 15, 1999, and invited comments.

While no additional hearings were held on the Supplement, other means

were provided for the public to express their concerns and provide

comments: mail; a toll-free telephone and fax line; and the Office of

Fissile Materials Disposition Web-site. Also, at the invitation of

South Carolina State Senator Phil Leventis, DOE attended and

participated in a public hearing held on June 24, 1999, in Columbia,

South Carolina.

Most of the information in DOE's Environmental Critique was

included in the Environmental Synopsis released for public review; only

proprietary and business-sensitive information was removed. The Duke,

COGEMA, and Stone & Webster (DCS) team provided DOE with analyses of

the environmental and computer modeling data, and population

projections, but not the input data. The ratio of low-enriched uranium

fuel to MOX fuel, provided by the Oak Ridge National Laboratory, is

contained in the SPD Final EIS. Because the accident calculations are

voluminous, they are not included in the SPD EIS. The calculations

contain all of the input parameters including the MACCS2 computer

files. Principal input parameters, such as accident source terms and

population distributions, are included in the EIS.

The same commentor expressed concern that experience with the use

of MOX fuel in the United States, as well

[[Page 1616]]

as internationally, is limited. The fabrication of MOX fuel and its use

in commercial reactors has been accomplished in Western Europe. DOE

would draw upon this experience in its disposition of the U.S. surplus

plutonium. Electricite de France reactors in France have seen little or

no impact from the use of MOX fuel on radionuclide releases in

effluents. No change would be expected from normal operations, given

that MOX fuel performs as well as LEU fuel and the fission products are

retained within the fuel cladding. FRAGEMA's (a subsidiary of COGEMA

and FRAMATOME) experience with fabricating MOX fuel indicates a fuel

rod fission product leak rate of less than one-tenth of 1 percent.

FRAGEMA has provided 1,253 MOX fuel assemblies, containing more than

300,000 fuel rods, for commercial reactor use. There have been no

failures and leaks have occurred in only 3 assemblies (a total of 4

rods). All leaks occurred as a result of debris in the reactor coolant

system and occurred in 1997 or earlier. French requirements for debris

removal were changed in 1997 to alleviate these concerns. Since that

time, there have been no leaks in MOX fuel rods. Further, as discussed

in response DCR009-1 of the Comment Response Document, NRC would

evaluate license applications and monitor the operations of the

commercial reactors to ensure adequate margins of safety.

The commentor was also concerned that human and technical errors

may lead to safety hazards at the reactors if MOX fuel is used.

Particular safety issues were identified at McGuire, North Anna and

Catawba (e.g., ice condenser problems and corrosion of service water

pipes and auxiliary feedwater pipes). While the Department acknowledges

that there are differences in the use of MOX fuel compared to LEU fuel,

these differences are not expected to decrease the safety of the

reactors. NRC has not considered it necessary to restrict operation of

any of the other reactors in the United States that use ice condenser

containments. All of the factors discussed by the commentor were

evaluated by the proposed reactor licensees to ensure that the

reactors, including those with ice condensers, can continue to operate

safely using MOX fuel, and these factors will continue to be evaluated.

Before any MOX fuel is used in the United States, NRC would have to

perform a comprehensive safety review that would include information

prepared by the reactor plant operators as part of their license

amendment applications.

Another issue raised by the same comentor concerned the stability

of plutonium compared to uranium and the alleged reduction in the

ability to control the chain reaction when plutonium is added to the

reactor in the form of MOX fuel. Differences between MOX fuel and

uranium fuel are well characterized and can be accommodated through

fuel and core design. All of the factors discussed by the commentor

were evaluated by the proposed reactor licensees to ensure that the

reactors can continue to operate safely using MOX fuel and will

continue to be evaluated. Initial evaluations indicate that partial MOX

fuel cores have a more negative fuel Doppler coefficient at hot zero

power and hot full power, relative to LEU fuel cores for all times

during the full cycle. These evaluations also indicate that partial MOX

cores have a more negative moderator coefficient at hot zero power and

hot full power, relative to LEU fuel cores for all times during the

full cycle. These more negative temperature coefficients would act to

shut the reactor down more rapidly during a heatup transient.

The commentor expressed concern that higher energy neutrons from

plutonium are more likely to strike reactor parts such as the stainless

steel containment vessel and degrade the metal parts of the reactor,

resulting in embrittlement problems. Reactor vessel embrittlement is a

condition in which the fast neutron fluence from the reactor core

reduces the toughness (fracture resistance) of the reactor vessel

metal. Analyses performed for the Department indicate that the core

average fast flux in a partial MOX fuel core is comparable, within 3

percent, to the core average fast flux for a uranium fuel core. All of

the reactors identified for the MOX mission have a comprehensive

program of reactor vessel analysis and surveillance in place to ensure

that NRC reactor vessel safety limits are not exceeded.

The commentor was also concerned that the use of MOX fuel would

result in additional harmful radiation exposure to the public during a

failure of the reactor containment structure. The commentor noted a

study by the Nuclear Control Institute estimating that the risk to the

public near McGuire or Catawba of contracting a deadly cancer following

a severe accident will increase by nearly 40 percent when the plants

start using plutonium fuel. DOE believes NCI's analysis overestimates

the risk of using MOX fuel for two reasons. NCI's analysis did not

account for the plutonium polishing step which has been added to the

MOX fuel fabrication process. This step eliminates nearly all of the

americium from fresh MOX fuel, which significantly reduces the actinide

inventory. In addition, NCI performed a generic reactor analysis while

DOE performed plant specific analyses.

Analyses of a 40 percent weapons-grade MOX core indicate there

would be approximately two times more americium-241 and plutonium-239,

and slightly less than one and a half times the curium-242 than a

reactor using LEU fuel. There are differences in the expected risk of

reactor accidents from the use of MOX fuel. Some accidents would be

expected to result in lower consequences to the surrounding population,

and lower risks, while others would be expected to result in higher

consequences and higher risks. There is an increase in risk, about 3

percent, for the large-break loss-of-coolant accident (the bounding

design basis accident). The largest increase in risk for beyond-design-

basis accidents is approximately 14 percent for an interfacing systems

loss-of-coolant accident at North Anna. In the unlikely event that this

beyond-design-basis accident were to occur, the expected number of LCFs

would increase from 2,980 to 3,390 with a partial MOX core and prompt

fatalities would increase from 54 to 60. Both of these accidents have

an extremely low probability of occurrence. At North Anna, the

likelihood of a large-break loss-of-coolant accident occurring is

estimated at 1 chance in 48,000 per year and the likelihood of an

interfacing systems loss-of-coolant accident occurring is estimated at

1 chance in 4.2 million per year.

Another issue raised by the commentor concerned timely and adequate

emergency response to a MOX fuel accident due to limited resources of

volunteer first responders. The subject of emergency response and

subsequent cleanup of an accident that involves the release of nuclear

materials is a topic of continuing discussion and planning between DOE

and State, local, and tribal officials. Prior to any shipment of

hazardous material, a transportation plan will be developed which

includes details of emergency preparedness, security, and coordination

of DOE with local emergency response authorities. Any additional

training or equipment needed would be provided as part of the planning

process. In addition, DOE maintains eight regional coordinating offices

across the country, staffed 24 hours per day, 365 days per year to

offer advice and assistance. Radiological Assistance Program teams are

available to provide field monitoring, sampling, decontamination,

communication, and other services.

[[Page 1617]]

As described in Appendix L of the SPD EIS, DOE anticipates that

transportation required for the disposition of surplus plutonium would

be done through DOE's Safe Secure Transport system. Since the

establishment of the DOE Transportation Safeguards Division in 1975,

the Safe Secure Transport system has transported DOE-owned cargo over

more than 151 million kilometers (91 million miles) with no accidents

causing a fatality or release of radioactive material.

Other Considerations

Cost Reports

To assist in the preparation of this ROD, DOE's Office of Fissile

Materials Disposition prepared two cost reports. The first is Cost

Analysis in Support of Site Selection for Surplus Weapons-Usable

Plutonium Disposition (DOE/MD-0009; July 1998). This report provides

site-specific cost information and analyses to support the selection of

a preferred siting alternative for the alternatives considered in the

SPD EIS. The second report is Plutonium Disposition Life Cycle Costs

and Cost-Related Comment Resolution Document (DOE/MD-0013; November

1999). This report provides full life cycle costs for the Preferred

Alternative as stated in the SPD EIS. It also contains the Department's

responses to cost related comments submitted during the public review

of the SPD Draft EIS.

Cost Analysis in Support of Site Selection

The summary costs listed below do not include the costs that would

be the same, independent of where the facility is sited. Therefore, the

costs are not full life cycle costs. The costs are presented in

constant year 1997 dollars. Cost estimates for each of the required

disposition facilities (Pit Disassembly and Conversion; MOX Fuel

Fabrication; and Immobilization), including the additional supporting

infrastructure, were created for each candidate site and were

aggregated into two cost categories (1) design and construction and (2)

operational. The cost estimates are considered to have an accuracy of

plus or minus 40 percent for design, construction, and decommissioning,

and an accuracy of plus or minus 20 percent for operations.

Hybrid Alternatives (Alternatives 2 through 10 in the SPD EIS). The

estimated costs to design and construct the required facilities range

from $1.21 billion to $1.40 billion, and estimated operational costs

range from $1.40 billion to $1.58 billion. The total costs for the

hybrid alternatives range from $2.67 billion to $2.93 billion. The

total cost of the hybrid alternatives would be reduced by the value of

the MOX fuel provided to the participating reactors; at the time of

this estimate the total cost after credit for the ``fuel offset'' was

$1.71 billion to $2.01 billion.15

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\15\ The MOX Fuel Fabrication Facility would produce nuclear

fuel that will displace LEU fuel that utilities would otherwise

purchase. The value of this fuel, deemed the MOX fuel offset, is

estimated to be $920 million.

---------------------------------------------------------------------------

Immobilization-Only Alternatives (Alternatives 11 and 12 in the SPD

EIS). The estimated costs to design and construct the required

facilities range from $0.73 billion to $0.89 billion and the

operational costs range from $0.97 billion to $1.0 billion. The

Immobilization Only Alternatives range from $1.71 billion to $1.90

billion. The cost of the alternatives differ by approximately ten

percent, well within the uncertainty of the cost estimates.

Life Cycle Cost for the Preferred Alternative

The summary cost listed below is the cost for the Preferred

Alternative. The cost includes the cost of siting, construction, and

operation of plutonium disposition facilities at DOE's Savannah River

Site, as well as the cost associated with the irradiation of the MOX

fuel in commercial reactors. In addition, the cost includes such costs

as sunk (already spent) funds, and costs for developing and

demonstrating the plutonium disposition technologies, transporting the

plutonium and plutonium disposition products, start-up and deactivation

and decommissioning of the three facilities. The costs are based upon

the Cost Analysis in Support of Site Selection for Surplus Weapons-

Usable Plutonium Disposition, DOE/MD-0009, July 22, 1998.

The total cost of implementing the Preferred Alternative is

estimated to be $4.07 billion in constant year 2000 dollars. The

increase in cost over the 1998 estimate is primarily attributable to

addition of life cycle costs specifically omitted from the 1998 cost

report, technical program changes, specifically the increased size of

the immobilization facility and the addition of the polishing step to

the MOX fuel fabrication process, plus other cost changes (e.g.,

inflation).

Nonproliferation Assessment

To assist in the development of this ROD, DOE's Office of Arms

Control and Nonproliferation, with support from the Office of Fissile

Materials Disposition, prepared a report, Nonproliferation and Arms

Control Assessment of Weapons-Usable Fissile Material Storage and

Plutonium Disposition Alternatives (DOE/NN-0007, January 1997). The

report was issued in draft form in October 1996, and following a public

comment period, was issued in final form in January 1997. It analyzes

the nonproliferation and arms reduction implications of the

alternatives for storage of plutonium and HEU, and disposition of

excess plutonium. It is based in part on a Proliferation Vulnerability

Red Team Report (SAND97-8203. UC-700, October 1996) prepared for the

Office of Fissile Materials Disposition by Sandia National Laboratory.

The assessment describes the benefits and risks associated with each

option. Some of the ``options'' and ``alternatives'' discussed in the

Nonproliferation Assessment are listed as ``variants'' (such as can-in-

canister) in the Storage and Disposition Final PEIS. The following

paragraphs discuss key conclusions of the report, as modified to meet

current conditions.

Disposition of U.S. Excess Plutonium

Each of the alternatives for disposition of excess weapons

plutonium that meets the Spent Fuel Standard 16 would, if

implemented appropriately, offer major nonproliferation and arms

reduction benefits compared to leaving the material in storage in

directly weapons-usable form. Taking into account the likely impact on

Russian disposition activities, the no-action alternative appears to be

by far the least desirable of the plutonium disposition options from a

non-proliferation and arms reduction perspective.

---------------------------------------------------------------------------

\16\ ``Spent Fuel Standard'' is a term coined by the National

Academy of Sciences (NAS, 1994, Management and Disposition of Excess

Weapons Plutonium, National Academy Press, Washington, D.C., pg 12)

and modified by DOE (glossary from Office of Fissile Materials

Disposition web site at http://www.doe-md.com) denoting the main

objective of alternatives for the disposition of surplus plutonium:

that such plutonium be made roughly as inaccessible and unattractive

for weapons use as the much larger and growing stock of plutonium in

civilian spent fuel.

---------------------------------------------------------------------------

Carrying out disposition of excess U.S. weapons plutonium, using

alternatives that ensured effective non-proliferation controls and

resulted in forms meeting the Spent Fuel Standard, would:

Reduce the likelihood that current arms reductions would

be reversed, by significantly increasing the difficulty, cost, and

observability of returning this plutonium to weapons;

Increase international confidence in the arms reduction

process,

[[Page 1618]]

strengthening political support for the non-proliferation regime and

providing a base for additional arms reductions, if desired;

Reduce long-term proliferation risks posed by this

material by further helping to ensure that weapons-usable material does

not fall into the hands of rogue states or terrorist groups; and

Lay the essential foundation for parallel disposition of

excess Russian plutonium, reducing the risks that Russia might threaten

U.S. security by rebuilding its Cold War nuclear weapons arsenal, or

that this material might be stolen for use by potential proliferators.

Choosing the ``no-action alternative'' of leaving U.S. excess

plutonium in storage in weapons-usable form indefinitely, rather than

carrying out disposition:

Would represent a clear reversal of the U.S. position

seeking to reduce excess stockpiles of weapons-usable materials

worldwide;

Would make it impossible to achieve disposition of Russian

excess plutonium;

Could undermine international political support for non-

proliferation efforts by leaving open the question of whether the

United States was maintaining an option for rapid reversal of current

arms reductions; and

Could undermine progress in nuclear arms reductions.

The benefits of placing U.S. excess plutonium under international

monitoring and then transforming it into forms that met the Spent Fuel

Standard would be greatly increased, and the risks of these steps

significantly decreased, if Russia took comparable steps with its own

excess plutonium on a parallel track. The two countries need not use

the same plutonium disposition technologies. However, as the 1994 NAS

committee report concluded, options for disposition of U.S. excess

weapons plutonium will provide maximum nonproliferation and arms

control benefits if they:

Minimize the time during which the excess plutonium is

stored in forms readily usable for nuclear weapons;

Preserve material safeguards and security during the

disposition process, seeking to maintain to the extent possible the

same high standards of security and accounting applied to stored

nuclear weapons (the Stored Weapons Standard);

Result in a form in which the plutonium would be as

inaccessible and unattractive for weapons use as the larger and growing

quantity of plutonium in commercial spent fuel (the Spent Fuel

Standard).

In order to achieve the benefits of plutonium disposition as

rapidly as possible, and to minimize the risks and negative signals

resulting from leaving the excess plutonium in storage, it is important

for disposition options to begin, and to complete the mission as soon

as practicable, taking into account non-proliferation, environment,

safety, and health, and economic constraints. Timing should be a key

criterion in judging disposition alternatives. Beginning the

disposition quickly is particularly important to establishing the

credibility of the process, domestically and internationally.

Each of the alternatives under consideration for plutonium

disposition:

Has its own advantages and disadvantages with respect to

non-proliferation and arms control, but none is clearly superior to the

others;

Can potentially provide high levels of security and

safeguards for nuclear materials during the disposition process,

mitigating the risk of theft of nuclear materials; and

Can potentially provide for effective international

monitoring of the disposition process.

Plutonium disposition can only reduce, not eliminate, the security

risks posed by the existence of excess plutonium, and will involve some

risks of its own. Because all plutonium disposition alternatives would

take decades to complete, disposition is not a near-term solution to

the problem of nuclear theft and smuggling. While disposition will make

a long-term contribution, the near-term problem must be addressed

through programs to improve security and safeguarding for nuclear

materials, and to ensure adequate police, customs, and intelligence

capabilities to interdict nuclear smuggling. All plutonium disposition

alternatives under consideration would involve processing and transport

of plutonium, which will involve more risk of theft in the short term

than if the material had remained in heavily guarded storage, in return

for the long-term benefit of converting the material to more

proliferation-resistant forms.

Both the United States and Russia will still retain substantial

stockpiles of nuclear weapons and weapons-usable fissile materials

after disposition of the fissile materials currently considered excess

is complete. These weapons and materials will continue to pose a

security challenge regardless of what is done with excess plutonium.

None of the disposition alternatives under consideration would make it

impossible to recover the plutonium for use in nuclear weapons, or make

it impossible to use other plutonium to rebuild a nuclear arsenal.

Therefore, disposition will only reduce, not eliminate, the risk of

reversal of current nuclear arms reductions. A United States decision

to choose reactor alternatives for plutonium disposition could offer

additional arguments and justifications to those advocating plutonium

reprocessing and recycle in other countries. This could increase the

proliferation risk if it in fact led to significant additional

separation and handling of weapons-usable plutonium. On the other hand,

if appropriately implemented, plutonium disposition might also offer an

opportunity to develop improved procedures and technologies for

protecting and safeguarding plutonium, which could reduce proliferation

risks and would strengthen United States efforts to reduce the

stockpiles of separated plutonium in other countries.

Large-scale bulk processing of plutonium, including processes to

convert plutonium pits to oxide and prepare other forms for

disposition, as well as fuel fabrication or immobilization processes,

represents the stage of the disposition process when material is most

vulnerable to covert theft by insiders or covert diversion by the host

state. However, such bulk processing is required for all disposition

alternatives. In particular, initial processing of plutonium pits and

other forms is among the most proliferation sensitive stages of the

disposition process, but it is largely common to all the options.

Transport of plutonium is the point in the disposition process when

the material is most vulnerable to overt armed attacks designed to

steal plutonium. With sufficient resources devoted to security,

however, high levels of protection against such overt attacks can be

provided.

Conclusions Relating to Specific Disposition Technologies

Reactor technology will meet the Spent Fuel Standard. Reactor

technology has some advantage over the immobilization technology with

respect to perceived irreversibility, in that the plutonium would be

converted from weapons-grade to reactor-grade, even though it is

possible to produce nuclear weapons with both weapons and reactor-grade

plutonium. However, the immobilization technology has some advantage

over the reactor technology in avoiding the perception that the latter

approach could potentially encourage additional separation and civilian

use of plutonium, which itself poses

[[Page 1619]]

proliferation risks. Because reactor technology results in accountable

``items'' (for purposes of international safeguards) whose plutonium

content can be accurately measured, this approach offers some advantage

in accounting to ensure that the output plutonium matches the input

plutonium from the process. The principal uncertainty with respect to

using excess weapons plutonium as MOX fuel in domestic reactors relates

to the potential difficulty of gaining political and regulatory

approvals for the various operations required.

Immobilization technology (can-in-canister) is being refined

resulting in an increase in the resistance to separation of the

plutonium cans from the surrounding glass, with the goal of meeting the

Spent Fuel Standard. The immobilization options have the potential to

be implemented more quickly than the reactor options. They face

somewhat less political uncertainty but somewhat more technical

uncertainty than the reactor options.

The ``can-in-canister'' immobilization options have a timing

advantage over the homogeneous immobilization options, in that, by

potentially relying on existing facilities, they could begin several

years sooner. As noted above, however, modified systems intended to

allow this option to meet the Spent Fuel Standard are still being

designed.

Decisions 17

---------------------------------------------------------------------------

\17\ included in these decisions is the Department's decision to

fulfill the Moscow Nuclear Safety and Security agreement to apply

International Atomic Energy Agency safeguards to surplus plutonium

as soon as it is practical. Further, consistent with a Presidential

Directive, the Department is continuing to work towards maximizing

the quantities of materials eligible for International Atomic Energy

Agency safeguards.

---------------------------------------------------------------------------

Consistent with the January 1997 decision on the Storage and

Disposition PEIS, the Department of Energy is affirming its decision to

use a hybrid approach for the safe and secure disposition of up to 50

metric tons of surplus plutonium using both immobilization and mixed

oxide fuel technologies and to construct and operate three new

facilities at its Savannah River Site. The hybrid approach allows for

the immobilization of approximately 17 metric tons of surplus plutonium

and the use of up to 33 metric tons as mixed oxide fuel which would be

irradiated in commercial reactors.

Construction and Operation of a Pit Disassembly and Conversion

Facility

Consistent with the Preferred Alternative in the SPD Final EIS, the

Department has decided to construct and operate a new pit conversion

facility at SRS for the purpose of disassembling nuclear weapons pits

and converting the plutonium metal to a declassified oxide form

suitable for international inspection and disposition, using either

immobilization or MOX/reactor approaches. SRS was selected for the pit

conversion facility because the site has extensive experience with

plutonium processing, and the pit conversion facility complements

existing missions and takes advantage of existing infrastructure.

Construction and Operation of an Immobilization Facility and

Selection of an Immobilization Technology 18

---------------------------------------------------------------------------

\18\ The Department intends to use essentially all of the

plutonium oxide produced by the Pit Disassembly and Conversion

Facility as feed material for mixed oxide fuel. However, some small

amounts may be unsuitable for this purpose and will be shipped to

the Immobilization Facility for disposition.

---------------------------------------------------------------------------

Consistent with the Preferred Alternative in the SPD Final EIS, the

Department has decided to construct and operate a new immobilization

facility at SRS using the ceramic can-in-canister technology. This

technology will be used to immobilize approximately 17 metric tons of

surplus plutonium in a ceramic form, seal it in cans, and place the

cans in canisters filled with borosilicate glass containing intensely

radioactive high-level waste at the existing Defense Waste Processing

Facility. The decision is based, in part, on the fact that the can-in-

canister approach at SRS complements existing missions, takes advantage

of existing infrastructure and staff expertise, and enables DOE to use

an existing facility (DWPF). The ceramic can-in-canister approach will

also provide better performance in a geologic repository and provide

greater proliferation resistance than the glass can-in-canister

approach.

Construction and Operation of a Mixed Oxide Fuel Fabrication

Facility and Irradiation in Commercial Reactors

Consistent with the Preferred Alternative in the SPD Final EIS, the

Department has decided to construct and operate a new facility at SRS

to produce MOX fuel containing up to 33 metric tons of surplus weapons-

usable plutonium for irradiation in existing domestic, commercial

reactors. The decision to use SRS is made, in part, because this

activity complements existing missions and takes advantage of existing

infrastructure and staff expertise. Based on this selection, the

Department will authorize DCS to fully implement the base contract.

As previously stated in the Storage and Disposition PEIS ROD (62 FR

3014, January 21, 1997), the use of MOX fuel in existing reactors will

be undertaken in a manner that is consistent with the United States'

policy objective on the irreversibility of the nuclear disarmament

process and the United States' policy discouraging the civilian use of

plutonium. To this end, implementing the MOX alternative will include

government ownership and control of the MOX fuel fabrication facility

at a DOE site, and use of the facility only for the surplus plutonium

disposition program. There will be no reprocessing or subsequent reuse

of spent MOX fuel. The MOX fuel will be used in a once-through fuel

cycle in existing reactors, with appropriate arrangements, including

contractual or licensing provisions limiting use of MOX fuel to surplus

plutonium disposition.

Selection of a Site for Lead Assembly Fabrication

Consistent with the Preferred Alternative in the SPD EIS, the

Department has decided to use LANL for fabrication of MOX fuel rods for

use in fabrication of lead assemblies. Based on consideration of the

capabilities of the candidate sites and input from the team chosen for

the MOX approach, LANL was selected because it already has facilities

(i.e., Technical Area 55) that will not require major modifications in

order to fabricate fuel rods, and takes advantage of existing

infrastructure and staff experience. Additionally, the surplus

plutonium dioxide needed to fabricate the MOX fuel rods for lead

assemblies will already be on site.

At this time, however, no decision is being made as to which

facility at LANL will be used for final assembly of the MOX fuel rods

into lead assemblies. DOE is currently evaluating whether there may be

the need for additional environmental analysis to support the final

stages of lead assembly fabrication at LANL. Pending completion of that

review, DOE is deferring a decision as to where on the LANL site this

final lead assembly work will be done.

Selection of a Site for Post-Irradiation Examination of Lead

Assemblies

If post-irradiation examination is necessary for the purpose of

qualifying the MOX fuel for commercial reactor use, the Department has

decided to perform that task at ORNL, consistent with the Preferred

Alternative in the SPD Final EIS. ORNL has the existing

[[Page 1620]]

facilities and staff expertise needed to perform post-irradiation

examination as a matter of its routine activities and no major

modifications to facilities or processing capabilities would be

required. In addition, ORNL is only about 500 km from the reactor site

that would irradiate the fuel, considerably closer than ANL--W, which

is about 3,700 km away.

Use of MOX Fuel in Canadian Uranium Deuterium Reactors

In the Storage and Disposition PEIS ROD, DOE retained the option to

use some of the surplus plutonium as MOX fuel in Canadian Uranium

Deuterium (CANDU) reactors, which would have been undertaken only in

the event that a multilateral agreement were negotiated among Russia,

Canada, and the United States. Since the SPD Draft EIS was issued, DOE

determined that adequate reactor capacity is available in the United

States for disposition of that portion of the U.S. surplus plutonium

suitable for MOX fuel. Therefore, DOE is no longer actively pursuing

the CANDU option. However, the CANDU option is still being considered

for the disposition of Russian surplus plutonium. To assist U.S.,

Russia, and Canada in considering this option the three countries are

jointly conducting an experiment which will involve irradiating MOX

fuel pins that have been fabricated from U.S. and Russian surplus

weapons plutonium in a Canadian research reactor. This effort involves

a one-time shipment of a small quantity of weapons plutonium from the

U.S. to Canada.

Conclusion

The Department of Energy has decided to disposition up to 50 metric

tons of plutonium at SRS using a hybrid approach that involves both the

ceramic can-in-canister immobilization approach and the MOX fuel

approach. Approximately 17 metric tons of surplus plutonium will be

immobilized in a ceramic form, placed in cans, and embedded in large

canisters containing high-level vitrified waste for ultimate disposal

in a geologic repository pursuant to the Nuclear Waste Policy Act.

Approximately 33 metric tons of surplus plutonium will be used to

fabricate MOX fuel, which will be irradiated in existing domestic,

commercial reactors. The reactors are the Catawba Nuclear Station near

York, South Carolina; the McGuire Nuclear Station near Huntersville,

North Carolina; and the North Anna Power Station near Mineral,

Virginia. The resulting spent fuel will be placed in a geologic

repository pursuant to the Nuclear Waste Policy Act. Pursuing this

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. Further, it sends the strongest possible

signal to the world of U.S. determination to reduce stockpiles of

surplus weapons-usable plutonium as quickly as possible and in an

irreversible manner. Pursuing both immobilization and MOX fuel

fabrication also provides important insurance against uncertainties of

implementing either approach by itself. 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. In the plutonium disposition effort, the United

States will work with Russia to develop acceptable methods and

technologies for transparency measures, including appropriate

international verification measures and stringent standards of physical

protection, control, and accounting for the management of surplus

plutonium.

Issued in Washington, DC, January 4, 2000.

Bill Richardson,

Secretary.

[FR Doc. 00-594 Filed 1-11-00; 8:45 am]

BILLING CODE 6450-01-P

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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