Consolidated Record of Decision for Tritium Supply and Recycling

DEPARTMENT OF ENERGY

Consolidated Record of Decision for Tritium Supply and Recycling

AGENCY: U.S. Department of Energy.

ACTION: Consolidated Record of decision for tritium supply and

recycling.

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SUMMARY: The U.S. Department of Energy (DOE) completed the Tritium

Supply and Recycling Final Programmatic Environmental Impact Statement

(PEIS) (DOE/EIS-0161) in October 1995. The Tritium Supply and Recycling

PEIS assessed the potential environmental impacts of technology and

siting alternatives for the production of tritium for national security

purposes as well as the impacts of constructing a new Tritium

Extraction Facility (TEF) at the Department's Savannah River Site near

Aiken, SC.

On December 5, 1995, DOE issued a Tritium Supply and Recycling

Record of Decision (ROD) [60 FR 63878] that selected the two most

promising alternative technologies for tritium production and

established a dual-track strategy that would, within 3 years, select

one of those technologies to become the primary tritium supply

technology. The other technology, if feasible, would be developed as a

backup tritium source. Under the dual-track strategy, DOE would: (1)

Initiate the purchase of an existing commercial reactor (operating or

partially complete) or irradiation services with an option to purchase

the reactor for conversion to a defense facility; and (2) design,

build, and test critical components of an accelerator system for

tritium production. Any new facilities that might be required, the

production-scale accelerator and a Tritium Extraction Facility to

support the commercial reactor alternative, would be constructed at

DOE's Savannah River Site. Subsequent to the PEIS and the December 5,

1995 ROD, DOE prepared three site-specific EISs: the Accelerator

Production of Tritium at the Savannah River Site (APT) (DOE/EIS-0270),

the Production of Tritium in a Commercial Light Water Reactor (CLWR)

(DOE/EIS-0288), and the Tritium Extraction Facility at Savannah River

Site (TEF) (DOE/EIS-0271). The December 1995 ROD also stated that,

although it was rejected as a reasonable long-term supply alternative

in the PEIS, DOE's Fast Flux Test Facility (FFTF) at the Hanford

Reservation in Washington would be re-examined to determine whether it

should play any tritium production role.

On December 22, 1998, the Secretary of Energy announced his

selection of the commercial light water reactor alternative as the

primary tritium supply. This consolidated Record of Decision documents

that decision and announces a series of three tiered decisions which,

taken together, comprise the Department's plans for establishing a new

domestic source of tritium to support the nuclear weapons stockpile.

Each decision results from the preparation of a related environmental

impact statement. In the order presented, this consolidated record of

decision makes the following decisions based on their associated

environmental impact statements (EIS):

1. Supplemental Programmatic Decision for Tritium Supply and

Recycling: Documents the Secretary of Energy announcement of December

22, 1998; selects the purchase of irradiation services using commercial

light water reactors as the primary tritium supply technology; and

designates the accelerator system at the Savannah River Site as the

backup technology. This ROD supplements the December 1995 ROD described

above. Environmental analysis is contained in the Tritium Supply and

Recycling PEIS (DOE/EIS-01621, October 1995).

2. Site-specific Decision for the Production of Tritium in a

Commercial Light Water Reactor. Selects the Tennessee Valley

Authority's (TVA) Watts Bar Unit 1, Sequoyah Unit 1, and Sequoyah Unit

2 reactors for use in irradiating tritium-producing burnable absorber

rods (TPBARs). This decision is tiered from and implements the

supplemental programmatic decision described above. Environmental

analysis is contained in the Final EIS for the Production of Tritium in

a Commercial Light Water Reactor (DOE/EIS-0288, March 1999). This EIS

is tiered from the Tritium Supply and Recycling PEIS.

3. Site-specific Decision for Construction and Operation of a

Tritium Extraction Facility at the Savannah River Site. Selects the

alternative that would design, construct, test, and operate a new TEF

in the H-Area immediately adjacent to and west of Building 233-H at the

Savannah River Site. This facility is an essential element of the

system for producing tritium using commercial reactors. This decision

is tiered from and implements the supplemental programmatic decision

described above. Environmental analysis is contained in the Final EIS

for Construction and Operation of a TEF at the Savannah River Site

(DOE/EIS-0271, March 1999) which is tiered from the Tritium Supply and

Recycling PEIS.

4. Site-specific Decision for the Accelerator Production of Tritium

(APT). Selects the specific location at the Savannah River Site and the

technologies to be used for the backup tritium supply technology,

should its construction be required. This decision is tiered from and

implements the supplemental programmatic decision described above.

Environmental analysis is contained in the Final EIS for Accelerator

Production of Tritium (DOE/EIS-0270, March 1999) which is tiered from

the PEIS.

FOR FURTHER INFORMATION CONTACT: For further information on the

commercial reactor program and the Tritium Extraction Facility, contact

Stephen M. Sohinki, DP-62, 1000 Independence Avenue SW, Washington, DC

20585, by phone (202-586-0838), or electronically (Tritium web site:

www.dp.doe.gov and click on ``Tritium Project Office Home Page'') For

further information on accelerator production of tritium, contact

William P. Bishop, DP-61, 1000 Independence Avenue SW, Washington, DC

20585, by phone (202-586-0046).

For general information on the DOE National Environmental Policy

Act process, please contact: Carol M. Borgstrom, Director, Office of

NEPA Policy and Assistance, EH-42, U.S. Department of Energy, 1000

Independence Avenue, SW, Washington, DC 20585, (202) 586-4600 or leave

a message at (800) 472-2756.

SUPPLEMENTARY INFORMATION:

I. Background

DOE has prepared this consolidated ROD pursuant to the Council on

Environmental Quality (CEQ) regulations for implementing the procedural

provisions of the National Environmental Policy Act (NEPA)(40

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CFR 1500-1508) and the DOE NEPA regulations (10 CFR part 1021). This

ROD is based on the Tritium Supply and Recycling Programmatic

Environmental Impact Statement (PEIS), and the three site-specific EISs

identified above. Non-environmental considerations such as cost,

technical maturity, and policy issues are also discussed in this ROD.

The Department of Energy is responsible for supplying nuclear

materials for national security needs and for ensuring that the nuclear

weapons stockpile remains safe and reliable. Tritium, a radioactive

isotope of hydrogen, is an essential component of every nuclear weapon

in the current and projected U.S. stockpile. Unlike other materials

used in nuclear weapons, tritium decays at a rate of 5.5 percent per

year. Accordingly, as long as the Nation relies on nuclear weapons,

tritium in each weapon must be replenished periodically. Currently, the

U.S. nuclear weapons complex does not have the capability to produce

tritium to support the Nation's stockpile.

The President's Nuclear Weapons Stockpile Plan sets forth national

security requirements for the current and projected nuclear weapons

stockpile. At present, this plan is based on the Strategic Arms

Reduction Treaty (START I) between the U.S. and former Soviet

Republics. START I, which was signed in July 1991 and became effective

in December 1994, reduces the number of strategic nuclear weapons in

each side's stockpile. Under the Presidential guidance, new tritium

would be needed by about fiscal year (FY) 2005 to offset the decay of

tritium in the stockpile, in the required 5-year reserve, and in

various operating inventories. Although the actual requirement is

classified, the unclassified representation of the steady-state

production rate to offset decay would be about 2.5 kilograms per year.

If needed to replenish the tritium inventory, the new tritium source

should be able to achieve a maximum production rate of around 3

kilograms per year. The START II agreement, which further reduces

nuclear stockpiles, was signed in July 1991, but has not been ratified

by Russia and is, therefore, not in force. If Russia ratifies START II,

the date when new tritium is needed may be as late as 2011 and the

steady-state production rate may be as low as about 1.5 kilograms per

year.

The Department has not produced any new tritium since the shutdown

of the last of its nuclear materials production reactors in 1988. Since

that time the Department has examined various methods of producing new

tritium. The Department announced on November 11, 1991, that analyses

of tritium production alternatives would be incorporated into a

programmatic environmental impact statement for the Reconfiguration of

the Nuclear Weapons Complex. On October 28, 1994, the Department

announced that a separate PEIS for Tritium Supply and Recycling would

be prepared (59 FR 54175). On October 27, 1995, the Notice of

Availability of the Final PEIS was published (60 FR 55020). Following

publication of the Final PEIS, a Record of Decision was issued on

December 5, 1995, which stated that the Department would pursue a dual

track on the two most promising tritium supply alternatives: (1) to

initiate the purchase of an existing commercial reactor (operating or

partially complete) or irradiation services with an option to purchase

the reactor for conversion to a defense facility; and (2) to design,

build, and test critical components of an accelerator system. Within a

three-year period, the Department would select one of the tracks to

serve as the primary source of tritium. The other alternative, if

feasible, would be developed as a backup tritium source. The ROD

further stated that the Savannah River Site is selected as the location

for an accelerator, should one be built. The ROD also stated that a

tritium extraction facility will be constructed at the Savannah River

Site if a commercial reactor alternative becomes the primary tritium

source. Finally, the ROD stated that the existing tritium recycling

facility at the Savannah River Site would be consolidated and upgraded.

In the December 1995 ROD, the Department indicated that the FFTF,

which had been rejected as a reasonable long-term production

alternative, would be re-evaluated to determine whether it could

reasonably play any role in meeting future tritium requirements. In

January 1997, the reactor was placed in a stand-by status while

additional evaluations were conducted. At the time, placing the reactor

in a stand-by condition was thought to provide near-term insurance

while the study of the two dual-track options continued.

On December 22, 1998, the Department announced that commercial

light water reactors would be used for the production of new tritium

and the accelerator would be developed, but not constructed, as the

backup technology. Selection of the commercial light water reactor

confirms the prior plan to construct a new TEF, an element of the

system to produce tritium using reactors. The use of existing

commercial reactors was chosen as the preferred alternative. In

addition, the Department decided that the FFTF would have no role in

tritium supply plans because the Department has high confidence that

the primary and back-up roles assigned to the commercial light water

reactor and accelerator technologies, respectively, would assure that

future tritium requirements are met.

During the 30-day waiting period following publication of the three

project-specific EISs in March 1999, DOE received four letters. One

from the Department of Human Health and Services regarding the Final

EIS for the Tritium Extraction Facility. That letter stated that the

potential concerns of the Department of Human Health and Services were

addressed in the Final EIS, and that there were no additional comments.

The second letter was received from the Department of the Interior

regarding the Final EIS for Accelerator Production of Tritium at the

Savannah River Site and expressed a number of concerns relating to the

biota. Since the APT has been designated as the backup, none of these

impacts to biota are expected. However, if a decision is made to pursue

the APT at a later date, these concerns would be addressed. The third

and four letters, which were from the Environmental Protection Agency's

(EPA) Region 4 Office in Atlanta, Georgia, concerned the APT and TEF

EISs. The letters stated that DOE adequately responded to all EPA

comments, but that EPA continues to have environmental concerns related

to the wetlands, surface water, and groundwater impacts for the APT

project, and the response to, and potential environmental impacts,

associated with accidental releases for the TEF project. If a decision

is made to pursue the APT, these concerns would be addressed. The

concerns regarding the TEF project will be addressed in further detail

during the design and permitting process. No other comments or letters

were received.

II. Supplemental Programmatic Decision for Tritium Supply and

Recycling

A. Tritium Supply and Recycling Alternatives

The dual-track strategy established in the December 1995

Programmatic Record of Decision defined the alternatives that would

remain under consideration: (1) the purchase of an existing commercial

reactor (operating or partially complete) or irradiation services with

an option to purchase the reactor for conversion to a defense facility;

and (2) design and construction of an accelerator system for tritium

production. New construction of an

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accelerator and/or a new tritium extraction facility would be located

at DOE's Savannah River Site near Aiken, SC. No new tritium recycling

capabilities or facilities are required or contemplated. This decision

was based on the Final Tritium Supply and Recycling Programmatic

Environmental Impact Statement (PEIS) (DOE/EIS--0161, October 1995).

This supplemental programmatic ROD makes a choice between the two

programmatic alternatives. It compares the alternatives with regard to

their ability to meet military requirements in terms of technical

maturity, capacity, and schedule risk; regulatory and licensing issues;

cost; nonproliferation policy issues; flexibility to meet changing

requirements, and environmental impacts.

The commercial reactor alternative has narrowed somewhat since

1995. DOE sought proposals from electrical utilities that operate

commercial light water reactors (CLWR). No proposals were submitted to

sell a reactor (operating or partially complete) to DOE. The Tennessee

Valley Authority (TVA) offered to provide irradiation services using an

incomplete reactor, for which DOE would provide funds to finish, plus

use of its currently operating reactors as needed. TVA also offered the

use of its currently operating reactors alone.

1. Description of Tritium Production Using Commercial Reactors

This section describes the process of producing tritium in a CLWR.

Current tritium requirements dictate that two CLWRs would be utilized

at any given time. DOE-designed Tritium Producing Burnable Absorber

Rods (TPBARs) would be placed in the reactors. DOE would have TPBARs

manufactured commercially under contract. A maximum of approximately

3400 TPBARs would be inserted in any one reactor for one fuel cycle.

TPBARs perform the same functions as burnable absorber rods, which are

used or have been used in commercial reactors to absorb excess neutrons

to control local power levels and fuel burnup rates. Commercial

burnable absorber rods absorb excess neutrons using the isotope Boron-

10 in ceramic form. TPBARs would also use a ceramic but substitute the

isotope Lithium-6 for Boron-10. Lithium-6 changes to tritium when

neutrons are absorbed. TPBARs would be placed in the reactors during

normal refueling outages. The TPBARs would remain in the reactors

throughout their normal operating cycle, usually a 15-18 month period.

The irradiated TPBARs would be replaced in the reactors with new ones

during refueling operations. Reactors potentially engaged in tritium

production must have their operating licenses amended by the Nuclear

Regulatory Commission (NRC). To meet current requirements, DOE plans

for the first irradiation cycle to begin in early FY 2004.

After irradiation, TPBARs would be transported in approved shipping

casks to a new TEF which would be constructed at DOE's Savannah River

Site and ready for operation no later than February 2006. The tritium

in each TPBAR is not gaseous, but is held in a solid matrix by several

internal structures. These structures are so effective in retaining the

tritium that a high-temperature furnace must be used to remove the

tritium as a gas. The TEF would use remotely operated handling

equipment and the furnaces that would heat the irradiated TPBARs to

around 1,000 degrees Celsius. The gases removed from the TPBARs would

be partially purified and pumped to the existing Tritium Recycle

Facility at the Savannah River Site for further processing and delivery

to the nuclear weapons stockpile. Following extraction, TPBARs,

classified as low-level radioactive waste, would then be sent to a low-

level radioactive waste disposal facility at the Savannah River Site.

2. Description of Accelerator Production of Tritium

The production of tritium in the proposed Accelerator Production of

Tritium facility may be viewed as a four-step process. First, protons

are accelerated to high energies. Second the protons strike tungsten to

produce neutrons through a nuclear process called spallation. Tritium

is produced in the third step, when the neutrons are captured by a

helium-3 feedstock (He-3) causing a nuclear reaction which produces

tritium and other isotopes of hydrogen. The final step is to separate

the tritium from the feedstock and purify it for use in the stockpile.

The APT would use radiofrequency waves to accelerate protons

(positively charged atomic particles). Electrical power would be

converted to radiofrequency waves outside the accelerator beam, and

waveguides (hollow metal conduits) would transmit the waves to cells

along the beam path. The accelerator design would enable the proton

beam to intersect with the radiofrequency waves in the proper

orientation to cause the protons to accelerate; in other words, the

radiofrequecy waves would push the protons down the beam tube faster

and faster.

Once the protons reached the desired energy, they would be directed

toward a target/blanket assembly of tungsten surrounded by lead. The

high energy of the protons striking the tungsten target would cause the

nuclei of the tungsten atoms to break into fragments, ejecting neutrons

and secondary particles in all directions (spallation). These neutrons

and some protons would be scattered to surrounding lead blanket modules

where more neutrons would be produced through additional nuclear

reactions. The neutrons freed during spallation would strike and be

absorbed by the feedstock material (i.e., He-30) in the target/blanket.

This absorption of neutrons would result in the production of tritium

and byproduct atoms. The tritium would then be separated from the

feedstock and purified. The purified tritium would be transported to

the Tritium Loading Facility at the Savannah River Site where it would

be used to refill tritium reservoirs in nuclear weapons.

B. Comparison of Non-Environmental Impacts of Tritium Supply

Alternatives

DOE is responsible to the President and its primary customer, the

Department of Defense, for establishing an assured source of tritium on

a schedule that meets the requirements discussed in the background

section above. Several factors, not directly related to environmental

impacts, are important in assessing the probability that each tritium

supply alternative will meet that responsibility. The factors discussed

below are: ability to meet military requirements; regulatory and

licensing issues; cost; nonproliferation issues; and flexibility to

meet changing requirements.

1. Ability To Meet Military Requirements

To meet military requirements, a tritium source must have low

technical risk, must have the capacity to produce tritium at required

rates, and must meet schedule deadlines. The tritium supply options are

assessed in these terms below:

Technology Maturity/Risk

Since its inception, the APT Project has sought to develop and

demonstrate critical components of a tritium production system and to

reach a level of maturity in the design of a full-scale production

system so that its technical risks, costs, and schedule can be fully

understood. At this point a majority of the accelerator system's

preliminary design has been completed and a low-energy demonstration

accelerator at the Los Alamos National Laboratory in New

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Mexico has undergone construction and successful operational testing.

Several external reviews have revealed no technical ``showstoppers.''

However, accelerators have never made tritium on a continuous

production scale, and the APT would be a first-of-a-kind facility.

Tritium production in reactors has been demonstrated to be safe and

technically straightforward. Although there are variations in the

technical details, in the past the only method used to produce tritium

has been with reactors and tritium-producing ``targets'' containing

lithium. DOE began considering commercial reactor target designs for

tritium production in the 1960s. The TPBAR to be used in commercial

reactors was designed and extensive development and testing done during

DOE's previous New Production Reactor Program (1988-1992). Commercial

nuclear power is supported by a well developed, mature industrial

infrastructure. During that program, rods of essentially the same

design as those to be used in commercial reactors were irradiated in

DOE's Advanced Test Reactor at the Idaho National Environmental and

Engineering Laboratory. Post-irradiation non-destructive and

destructive examinations have shown that the rods performed even better

than predicted. Various laboratory tests have consistently shown TPBAR

component performance to be as good or better than expectations.

Following two extensive technical reviews by the Nuclear Regulatory

Commission (NRC) and the approval of an amendment for its operating

license issued in September 1997, the Tennessee Valley Authority's

(TVA) Watts Bar reactor irradiated 32 TPBARs over a normal operating

cycle for a confirmatory demonstration. Frequent monitoring of the

reactor coolant and neutron flux indicated no problems with the rods.

Following irradiation, the rods were removed from the reactor's spent

fuel on March 19, 1999, and visually inspected. The inspection of the

32 TPBARs showed no indications of any kind of problem. In February

1999, DOE submitted the Tritium Production Core Topical Report to the

NRC. NRC's review of the report has raised no significant concerns and

a Safety Evaluation Report to this effect is now being finalized by the

NRC.

Conclusion: While much progress has been made in addressing the

technical issues that existed regarding the APT at the time of the 1995

Record of Decision, tritium production technology for light water

reactors is more technically mature, and carries with it less technical

risk than the APT.

Capacity

The commercial reactor alternative and the APT alternative would

both have a maximum production capacity of about 3 kilograms of tritium

per year. Commercial reactors routinely operate at full power for

extended periods of time. The national average capacity factor for

commercial reactors is in excess of 75 percent, including all refueling

shutdown periods. The Watts Bar reactor, while irradiating 32 of DOE's

TPBARs, recently shut down for refueling, having been in continuous

high-power operation for 353 consecutive days. The availability of

multiple candidate reactors for irradiating TPBARs also provides high

confidence that tritium production capacity requirements can be met.

Although much progress has been made, the APT project has not yet

demonstrated its tritium production capacity.

Conclusion: Although either alternative should be able to meet

capacity requirements, the availability of multiple commercial reactors

and their demonstrated capacity factors provides a greater degree of

confidence that production goals can be met consistently.

Schedule

The commercial reactor alternative could begin producing its first

batch of tritium in October 2003 when one of the candidate reactors is

scheduled to complete a refueling outage. Because many technical and

regulatory issues have been addressed already, there is a high degree

of confidence that this initial irradiation schedule can be met. The

first batch could be delivered to the stockpile as tritium gas as soon

as the TEF is operational. Selection of the incomplete reactor approach

would not impact the schedule because an existing reactor would be used

to irradiate the initial batch of TPBARs. Under both reactor

alternatives, current START I requirements would be met without the use

of the 5-year tritium reserve. The APT alternative would be operational

around 2008 and would begin continuous tritium production at that time.

This would require that 3 years of the 5-year reserve be utilized for

stockpile support. The APT would need to operate at its maximum

capacity for a number of years to replace the depleted reserve.

Conclusion: There is a high likelihood that, with adequate funding,

the reactor alternatives can meet the schedule and the tritium reserve

would not be impacted. The APT would require that at least 3 years of

the reserve be consumed and that the machine operate at maximum

capacity until the reserve has been restored. Any schedule delay beyond

2008 would potentially utilize the balance of the reserve and thus

potentially impact the stockpile. If START II is ratified and

implemented, any schedule risk would be eliminated. However, for

current stockpile requirements, the commercial reactor alternative has

the best chance for meeting schedule requirements.

2. Regulatory and Licensing Issues

Both the reactor and accelerator alternatives would be overseen by

bodies external to DOE. The potential for oversight/regulatory issues

to impact the tritium alternatives is discussed below.

The NRC would have to amend the operating licenses of existing

commercial reactors to permit production-scale irradiation of tritium-

producing rods. Requests for license amendments would be submitted in

the middle of calendar year 2000. It is expected that the NRC would be

in a position to act upon the amendment requests well in advance of the

planned October 2003 start of irradiation. Some experience has already

been gained in this area because the Watts Bar reactor's operating

license was amended in September 1997 to permit the confirmatory test

irradiation of 32 TPBARs. That licensing process was completed in a few

months. The NRC has completed two reviews of technical reports on the

TPBAR submitted by DOE and a third review of a reactor-specific request

to amend the Watts Bar reactor's operating license for the confirmatory

irradiation demonstration. No significant safety issues were

identified.

If a partially complete reactor were finished and brought on line,

the facility would have to be licensed as a new nuclear power plant.

The licensing process is likely to take up to 5 years. As discussed

above, this would not impact national security because initial tritium

production would begin with an existing reactor. However, delays in

getting the incomplete plant into operation could delay and possibly

reduce DOE's receipt of revenues from the plant's power sales. Thus,

the only potential regulatory impact would be financial in nature.

The APT design, construction, and operation would be overseen by

the Defense Nuclear Facilities Safety Board (DNFSB). To date, the DNFSB

has not identified any issues that would affect the availability of

this facility. The APT would not require a license for its construction

or operation.

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Conclusion: The APT option appears to have no regulatory and

licensing issues. The existing-reactor sub-option is not likely to be

impacted by regulatory and licensing issues. The incomplete reactor

sub-option has potential for these issues to impact its schedule, but

is not likely to affect tritium production because initial irradiation

would be with an existing reactor.

3. Cost

Cost is determined in terms of investment cost and life-cycle cost.

Investment cost is defined as the total of all remaining up-front costs

necessary to design, develop, construct, startup, or otherwise

establish tritium production capacity. Investment costs are generally

the same as project costs. Life-cycle cost is defined as the total

amount of money spent to produce 100 kilograms of tritium over the life

of the alternative to meet current START I requirements. Life-cycle

cost includes investment cost, all operating costs, and decontamination

and decommissioning (D&D) costs. All cost discussions refer to constant

FY 1999 dollars.

The investment cost remaining (FY 1999-2008) to develop, design,

construct, and startup the APT facility, sized to meet START I tritium

requirements, would be $3.4 billion. The investment cost remaining to

establish capabilities to produce tritium through irradiation services

with existing commercial reactors and to design, construct, and startup

the TEF would be $580 million. This investment cost would increase by

$1.2-1.8 billion if finishing an incomplete reactor is included.

The annual operating cost of the APT would be $135 million when

meeting START I tritium requirements. The annual operating cost to

produce START I quantities of tritium using existing reactors would be

$20-60 million. At the high end of this range DOE would pay for the

incremental increase in the enrichment of the host reactors' fuel as

needed to accommodate TPBARs for tritium production. At the low end of

the range DOE would provide blended-down highly enriched uranium from

its national security stocks, and the host utility would reimburse DOE

for that portion not directly attributable to tritium production. If

DOE provides funds to finish an incomplete reactor, under some

scenarios, the Government would share in the power sales revenue of

that reactor. These revenues would depend on the amount of investment

money provided and whether the funds were provided over a short period

or an extended period. Large ``block'' investment payments would result

in the highest revenue share. Reduced, extended payments would provide

no revenue share. Depending on the investment, the annual operating

cost to DOE would range from around $30 million of net income to around

$25 million of net outlay.

D&D costs for the APT would be $260 million. For the reactor

alternative, DOE would be liable only for D&D of the TEF at $8 million.

DOE would have no liability for reactor D&D costs.

The APT and TEF would be designed for a 40-year life. Although the

NRC licenses of currently operating reactors would expire before then,

extension of the reactors' operating licenses is possible, either to

meet power demand or tritium requirements or both. For purposes of this

cost analysis, it is assumed that suitable reactors will be available

throughout the 40-year period.. Thus, all alternatives were compared on

the same life-span basis. Life-cycle cost for the APT is estimated to

be $9.2 billion. Life-cycle cost for the use of commercial reactors is

estimated to be $1.2 billion to $2.9 billion, depending on the

investment-revenue combination discussed above.

The present discount value of the APT alternative, using a 3.6

percent discount rate, would be $5.2 billion. The present discount

value of the commercial reactor alternative would range from $880

million to $2.0 billion, depending on the investment and fuel

enrichment strategies, as discussed above.

Conclusion: Under current requirements, the commercial reactor

alternative would cost significantly less than the APT alternative in

terms of investment costs, operating costs, D&D costs, life-cycle

costs, and present discount value.

Cost To Meet Reduced START II Requirements

If START II comes into force, the tritium need date could be around

2011 and the maximum tritium production rate may be reduced to about

1.5 kilograms per year. If so, a smaller accelerator could be

constructed, reducing its investment cost to $2.8 billion. The existing

commercial reactor alternative's investment cost remains about the same

as the START I case. The accelerator alternative's life-cycle cost

under this reduced-requirement scenario would be $7.5 billion. Life-

cycle cost for the commercial reactor alternative, using existing

reactors would be $2.2 billion or less, depending on the fuel

enrichment strategy. Adding completion of an unfinished reactor could

drive the life-cycle costs up or down, depending on the investment

strategy.

Conclusion: Under START II requirements, the commercial reactor

alternative would cost significantly less than the APT alternative in

terms of investment cost, operating costs, D&D costs, and life-cycle

costs.

4. Nonproliferation Issues

Concerns have been expressed by members of Congress and other

individuals and groups regarding the use of a civilian reactor to

assist a defense mission. As a result of these concerns, the Congress

requested the Department to facilitate a high-level interagency review

of the nonproliferation implications of the various tritium production

technologies. Participants in the review included the National Security

Council, the Department of Defense, the Department of State, the Arms

Control and Disarmament Agency, the White House Office of Science and

Technology Policy, the Office of the Vice President, and the NRC. The

report, Interagency Review of the Nonproliferation Implications of

Alternative Tritium Production Technologies Under Consideration by the

Department of Energy, was provided to the Congress in July 1998. A

summary of conclusions of the report follows:

The interagency report noted that tritium is not a fissionable

material, and thus there is no legal prohibition on the production of

tritium in a commercial reactor to support the stockpile. The report

concluded that ``the nonproliferation policy issues associated with the

use of a commercial light water reactor are manageable, and that the

Department should continue to pursue the reactor option as a viable

source for future tritium production.'' This conclusion was based on a

number of factors, including the following:

Use of commercial reactors for tritium production is not

prohibited by statute or international treaty;

There have been several exceptions over the past several

decades to the practice of distinguishing between the civilian and

military uses of nuclear power.

Commercial reactors engaged in tritium production would

remain eligible for the application of International Atomic Energy

Agency safeguards.

The commercial reactor option would be operated in

compliance with international agreements imposing restrictions on use

of transferred materials for peaceful purposes only, e.g., no reactor

fuel or component

[[Page 26374]]

transferred under these agreements would be used by any reactor making

tritium; and

Further mitigation is offered if the existing reactors are

operated by TVA. TVA's statutory charter assigns it a national security

mission. TVA's reactors are already government facilities. TVA has made

contributions to national security in the past including production of

munitions and providing power for the enrichment of uranium for

civilian and military purposes. It would, therefore, be entirely

appropriate for TVA to be assigned the tritium production mission.

The interagency review concluded that the accelerator option would

raise no significant nonproliferation policy issues, assuming that

export control measures are maintained. Subsequent to the issuance of

the report, concerns have been expressed, applicable to both the APT

and to the completion of an unfinished reactor, that the commitment to

a major new weapons facility would be inconsistent, either in fact or

in appearance, with our commitment to further stockpile reductions and

thus to our obligations under the Nuclear Nonproliferation Treaty.

These concerns were considered in the tritium technology decision

process.

Conclusion: Although concerns have been expressed about each of the

tritium production alternatives, nonproliferation policy issues would

not preclude the selection of any alternative.

5. Flexibility To Meet Changing Requirements

Since tritium production stopped in 1988, the U.S. tritium

requirements have been reduced by almost 75 percent, primarily because

of the stockpile reductions resulting from bilateral arms control

agreements. The current tritium production requirement is based on

supporting a stockpile sized for START I. If START II is ratified by

the Russian Duma (legislature), the U.S. may decide to reduce its

tritium production requirements, thus moving the need date to 2011 and

reducing tritium production requirements. Stockpile reductions beyond

START II are possible and would hopefully occur, potentially resulting

in further extension of the tritium need date and reductions in tritium

production requirements.

The APT has significant flexibility to change its rate of tritium

production and therefore its operating costs. It is less flexible in

its avoidance of capital investment costs. The APT project plan calls

for construction of a ``modular'' accelerator sized to produce about

1.5 kilograms per year, the capacity sufficient for a START II

stockpile. According to the plan, if current tritium requirements are

not reduced by early FY 2000, accelerator construction would proceed

with a full-size machine having a capacity of 3 kilograms per year with

a $500 million increase in investment cost. If tritium requirements are

reduced after early FY 2000 much of the investment cost of the APT

would be ``sunk.''

The use of the existing, operating reactors is the most flexible

option with respect to changing stockpile levels. If the tritium need

date is extended during FY 1999-2000, most investment for this

alternative could be suspended indefinitely and then restarted later. A

substantial portion of DOE's operating costs would be based on tritium

demand on a pay-as-you-go basis. Except for minimal standby costs, DOE

would pay for irradiation services, TPBAR manufacturing, and

transportation operations only during those years when tritium is

actually required. The amount spent for irradiation services would, to

a great degree, depend on the amount of tritium produced. If the

tritium need date is extended before the TEF handles its first

increment of radioactive material, that facility could remain in

standby indefinitely for less than $1 million per year.

If completion of an unfinished reactor is considered, the reactor

alternative's flexibility characteristics become much like those of the

APT. While there is great flexibility in amounts of tritium that can be

produced, the large up-front investment cost would have no relation to

tritium requirements. Once DOE committed itself to completion of the

reactor, there would be no opportunity to reduce investment costs if

stockpile tritium requirements were reduced. Revenues would be returned

to DOE whether tritium is needed or not, but the cost per kilogram

would obviously be higher if tritium requirements were substantially

reduced as a result of further arms reduction agreements. The annual

net operating cost (positive or negative) of this alternative would

vary somewhat with tritium demand because of reductions in the cost for

TPBAR manufacturing and transportation, thus reducing the total-life

cycle cost.

Conclusion: The use of existing reactors potentially results in the

greatest degree of flexibility to meet changing requirements,

especially in view of the potential for future reductions in the

nuclear weapons stockpile.

C. Comparison of Environmental Impacts of Tritium Supply Alternatives

Since the December 1995 Tritium Supply and Recycling PEIS ROD, a

substantial amount of work has been accomplished on both the CLWR

tritium production alternative and the APT alternative, including the

issuance of project-specific Environmental Impact Statements. In the

course of preparing this supplement to the December 1995 ROD for the

tritium supply technology decision, in order to select between the two

technologies, DOE reviewed the Tritium Supply and Recycling Final PEIS

to ensure that the information contained there is still valid. The

conclusion of that review is that the Tritium Supply and Recycling PEIS

remains a valid basis for the programmatic portion of this consolidated

ROD.

In the December 5, 1995 ROD for the Tritium Supply and Recycling

PEIS, environmental impacts of the various tritium supply technologies

were compared and a general conclusion was reached that ``[for all of

the reasonable tritium supply technology alternatives] the

environmental impacts are generally small and, except for the

commercial reactor options to purchase an existing reactor or

irradiation services, the impacts are within the same range. The

Department considers the commercial reactor options of purchasing an

existing reactor or irradiation services to be the environmentally

preferred alternative.'' [60 FR 63889] As discussed below, these

conclusions remain true.

Described below are the relative differences in environmental

impacts between tritium production in operating CLWRs (TVA's Watts Bar

Unit 1 and Sequoyah Units 1 and 2 are used in the analysis) and an

incomplete CLWR (TVA's Bellefonte Unit 1 is used in the analysis), and

construction and operation of the APT at the Savannah River Site. For

an incomplete CLWR, the environmental analysis attributes all of the

impacts from completing construction and operating the plant to the

tritium production mission. Additionally, because any tritium produced

by a CLWR would need to be extracted from TPBARs prior to delivery to

the nuclear weapons stockpile, the impacts associated with operation of

a TEF are included in the discussion below, as appropriate. DOE has

decided previously that a TEF capability would be constructed

regardless of whether the CLWR option is selected as the primary or the

backup tritium supply [60 FR 63890]. In the latter case the TEF would

be needed as part of a viable backup system and could have been

[[Page 26375]]

incorporated as part of the APT facility. Therefore, construction

impacts of TEF apply if either the CLWR or APT option is chosen, but

TEF operating impacts apply only to the CLWR. Because of the

availability of data in the tiered, final EISs for use of commercial

reactors for tritium production, the TEF, and the APT, the discussion

below is based upon the best available information and analyses that

have been developed to date.

1. Construction Impacts

For tritium production in a CLWR, construction impacts would range

from none (for operating CLWRs) to minor (for a CLWR which is currently

approximately 90 percent complete, and would only require internal

modifications). The predominant construction impact associated with an

incomplete CLWR would be on socioeconomics, as approximately 4,500

direct jobs and 4,500 indirect jobs could be created during the peak

year of construction. The creation of approximately 9,000 total jobs

would have a significant positive impact on the economic area

surrounding the incomplete reactor. For the APT at the Savannah River

Site, construction impacts would consist of: land disturbance of

approximately 250 acres; water use of less than 1 percent of current

use; and socioeconomic impacts associated with a peak-year construction

workforce of approximately 1,400 direct jobs and approximately 900

indirect jobs. The creation of approximately 2,300 total jobs would

have a significant positive impact on the economic area surrounding the

Savannah River Site. Construction impacts associated with a TEF at SRS

would be minimal. Land disturbance would occur in a densely developed

industrial area. Water use would be less than 1 percent of current site

use. Socioeconomic impacts associated with a peak-year workforce would

be about 740 direct jobs which would have a positive stabilizing

influence on SRS employment but an insignificant impact on regional

employment.

Conclusion: With respect to construction impacts associated with

tritium production, use of an existing CLWR would have the least impact

on the natural environment. Completion of an unfinished reactor would

have positive socioeconomic impacts, as would the APT at SRS. Using an

existing CLWR would have no socioeconomic impacts. For all

alternatives, the environmental impacts associated with construction

are considered small.

2. Operating Impacts

For an operating CLWR, there would either be no impacts, or

negligible impacts, to resources such as: land, infrastructure, noise,

visual, air quality, water resources (use and quality), geology and

soils, archeological and historic, and socioeconomics. Tritium

production and extraction could cause additional impacts in the

following resources: spent fuel generation; human health (normal

operations and accidents); low-level radioactive waste (LLW)

generation; and transportation.

For the alternative that would complete, start up, and operate an

incomplete reactor, the operating impacts include those impacts

associated with a new commercial nuclear power plant. The following

resources would be affected: infrastructure (including visual

resources); water resources; spent fuel generation; human health

(normal operations and accidents); LLW generation; transportation; and

socioeconomics.

Operation of a TEF at the Savannah River Site would affect the

following resources: infrastructure; water resources; human health

(normal operations and accidents); LLW generation; and socioeconomics.

For the APT, tritium production could cause impacts in the

following resources: infrastructure; surface water; human health

(normal operations and accidents); LLW generation; and socioeconomics.

For the resources potentially affected during operation of any tritium

supply technology, the most significant discriminators between

alternatives are: infrastructure, spent fuel, human health (including

impacts from accidents), low-level waste generation, and

socioeconomics. These resources are discussed below for the tritium

production alternatives, as appropriate.

Infrastructure

The production of tritium in an operating CLWR would have no impact

on the local infrastructure. The impacts of operating a newly completed

reactor would produce more than 1,200 megawatts of usable electric

power. In an area such as the Tennessee Valley, this beneficial impact

would tend to reduce the need for operation of coal-fired or gas-fired

power plants, or could offset the need for additional power plants in

the future, potentially reducing future air emissions. Although visual

resources surrounding the incomplete reactor site would be negatively

impacted by a cooling tower plume, this would not be significant enough

to change the plant's existing visual resource classification. For the

operation of the TEF, estimates for base load electricity use are

approximately 2.4 megawatts of electric power, which would be provided

through the existing infrastructure at SRS.

For the APT, estimates for base load electricity use are up to 350

megawatts of electric power. Environmental impacts associated with

production of electricity by a coal-fired or gas-fired power plant

would consist mainly of increased air emissions; however, no air

quality standards are expected to be exceeded. The visual impacts of

the APT are not deemed significant because the facility would not be

visible from the Savannah River Site boundaries to ground-level

observers.

Conclusion: Operation of a newly completed reactor would produce a

positive impact on the local infrastructure by producing more than

1,200 megawatts of electric power. An operating CLWR used for tritium

production would have no additional impact on the local infrastructure.

The TEF would have a negligible impact on the local infrastructure at

the Savannah River Site. The APT would have a minor negative

environmental impact on the local infrastructure by requiring

approximately 350 megawatts of electric power.

Spent Fuel

The reactors considered here each use 193 fuel assemblies when

operating. At each refueling a percentage of these assemblies are

removed from the reactor and placed in the reactor's spent fuel storage

pool. The number of assemblies of spent fuel generated by an existing

reactor could increase as a result of tritium production. Increases

could range from approximately 60 spent fuel assemblies per cycle if a

CLWR is loaded with a maximum of 3,400 TPBARs, to no increase in spent

fuel if a CLWR is loaded with less than approximately 2,000 TPBARs. The

environmental impacts associated with long-term, on-site, dry-cask

storage of spent fuel are not significant. For a newly completed CLWR,

approximately 72 spent fuel assemblies would be generated during

reactor operations without tritium production. For nominal tritium

production, the amount of spent fuel generated would not increase as

long as less than approximately 2,000 TPBARs are loaded into the

reactor. If maximum tritium production is needed, up to 3,400 TPBARs

would be used and approximately 69 additional spent fuel assemblies

would be generated per cycle. In this regard, it is DOE's

[[Page 26376]]

intention to minimize, if not eliminate, the generation of additional

spent fuel by limiting the number of TPBARs inserted in a single

reactor. Neither the TEF, nor the APT, would generate spent fuel.

Conclusion: Operation of a newly completed reactor would generate

the most additional spent fuel. Use of currently operating reactors

could lead to a limited incremental increase in spent fuel. The APT

would generate no spent fuel.

Human Health (Normal Operations)

By adding tritium production to the currently operating reactors,

there would be additional radiation doses to workers and the public

from tritium production. The incremental increase in annual average

worker dose is estimated at approximately 1.1 millirem, while the total

population dose within 50 miles is estimated to increase by

approximately 2.0 person-rem per year during normal operations. In

terms of potential impacts, these values are not significant. For

example, a 2.0 person-rem dose translates into a latent cancer fatality

risk of 1 in 1,000 years. For the average worker, a 1.1 millirem annual

dose translates to a risk to that worker of a latent cancer fatality

every 2.3 million years.

By finishing the incomplete reactor and operating it to produce

electricity and tritium, there would be radiation doses to workers and

the public that do not currently occur. The average annual worker dose

is estimated at a maximum of approximately 105 millirem, of which 104

millirem would result from operation of the reactor to produce

electricity, and 1.1 millirem would be from tritium operations. The

annual total population dose within 50 miles is estimated to be a

maximum of approximately 2.3 person-rem. In terms of potential impacts,

these values are not significant. For example, a 2.3 person-rem dose

translates into a latent cancer fatality risk of 1 in 870 years. A 105

millirem annual dose translates to a risk to an average worker of a

latent cancer fatality every 23,000 years.

Operation of the TEF at the Savannah River Site would result in

small radiological impacts to workers and the public from tritium

production. The average annual worker dose is estimated at

approximately 40 millirem, while the total population dose within 50

miles is estimated to increase by approximately 0.77 person-rem per

year. In terms of potential impacts, these values are not significant.

For example, a 0.77 person-rem dose translates into a latent cancer

fatality risk of 1 in 2600 years. For the average exposed worker, a 40

millirem annual dose translates to a risk to that worker of a latent

cancer fatality every 62,500 years.

Operation of the APT would result in small radiological impacts to

workers and the public from tritium production. The average annual

worker dose is estimated at a maximum of approximately 144 millirem,

while the total population dose within 50 miles is estimated to be

approximately 2.0 person-rem. In terms of potential impacts, these

values are not significant. For example, a 2.0 person-rem dose

translates into a latent cancer fatality of 1 in approximately 1,000

years. A 144 millirem annual dose translates to a risk to an average

worker of a latent cancer fatality approximately every 17,600 years.

Conclusion: Radiological impacts for normal operations are

considered small for all alternatives. The APT and commercial reactor

options would have comparable impacts to the population. Use of an

operating CLWR would have the smallest impact to workers.

Human Health (Accidents)

Based upon tests and analyses that had been performed previously as

part of the DOE's New Production Reactor program, the Tritium Supply

and Recycling PEIS concluded that ``it appears that no new significant

safety hazard is introduced as a result of a decision to produce

tritium in an existing CLWR.'' [PEIS, page 4-524] Nonetheless, the PEIS

also acknowledged that a complete reactor-specific evaluation remained

to be completed. The CLWR EIS provides a detailed evaluation of impacts

from accidents on a site-specific basis for the CLWR reactor

alternatives. Based upon the CLWR EIS evaluation, the conclusion in the

PEIS is further supported. The CLWR EIS documents that the potential

impacts from tritium production on accident impacts is small. For

design-basis accidents at operating reactors, the risk of a latent

cancer fatality to an average individual from tritium production in the

50-mile population surrounding a CLWR would be approximately 1 in 490

million years. At the incomplete reactor site, this risk would be

approximately 1 in 1.3 billion years. For beyond design-basis

accidents, tritium production would result in very small changes in the

consequences of an accident. This is due to the fact that the potential

consequences of such an accident would be dominated by radionuclides

other than tritium. At the operating reactors, the additional risks to

the 50-mile population from adding tritium production would be less

than one additional cancer per every 100,000 years from a beyond

design-basis accident. At the incomplete reactor site, the total risk

of the new reactor and the added tritium mission to the 50-mile

population would be approximately 11 latent cancer fatalities per

100,000 years from a beyond design-basis accident.

The potential impacts to the public from accidents associated with

operation of the TEF at the Savannah River Site are extremely small.

For the design-basis accident, the risks to the 50-mile population

would be approximately 7 latent cancer fatalities per 100,000 years.

The potential impacts to the public from either a design-basis or

beyond design-basis accident from the APT are small. For a design-basis

accident, the risk of a latent cancer fatality to an average individual

in the 50-mile population would be approximately 1 in 470 million

years. For beyond design-basis accidents, the risks to the 50-mile

population would be approximately 3 latent cancer fatalities per

100,000 years.

Conclusion: The risks associated with accidents are small for all

the tritium production alternatives. Differences between the CLWR and

APT are not deemed to be significant.

Low-Level Radioactive Wastes

LLW generation at the operating reactors could increase by 0.43

cubic meters annually as a result of tritium production. The impact of

disposing of the additional LLW at the Barnwell commercial disposal

facility at Barnwell, South Carolina would represent much less than 1

percent of the total LLW that is currently disposed of at that

facility. The newly completed reactor would generate approximately 40

cubic meters of LLW annually, which would also be less than 1 percent

of the total LLW that is disposed of annually at the Barnwell LLW

commercial disposal facility. Operation of the TEF would generate

approximately 232 cubic meters of LLW annually. These wastes would be

manageable using existing waste management treatment, storage, and

disposal facilities at the Savannah River Site.

The APT would generate approximately 1,400 cubic meters of LLW

annually. These wastes would be manageable using existing waste

management treatment, storage, and disposal facilities at the Savannah

River Site. The environmental impacts of all waste types for all

alternatives, including LLW, would be small and manageable with

existing facilities.

Conclusion: Although all of the waste generation impacts are

acceptable, the

[[Page 26377]]

use of currently operating reactors would generate the smallest amount

of low-level wastes from tritium production. For all alternatives, the

environmental impacts of all waste types, including low-level waste

would be small and manageable with existing facilities.

Socioeconomics

Little or no socioeconomic impact is expected by adding the tritium

production mission at an operating CLWR. Operation of a newly completed

CLWR would add approximately 800 direct and 800 indirect jobs. The

socioeconomic impacts of the 1,600 total jobs would have a positive

impact on the economic area surrounding the reactor site. Operation of

the TEF would add approximately 108 direct jobs. This would not have

any significant impact on the local socioeconomic area. Operation of

the APT would add approximately 500 direct jobs and 335 indirect jobs.

The socioeconomic impacts of the 885 total jobs would have a positive

impact on the economic area surrounding SRS.

Conclusion: Operation of a newly completed reactor and the APT

would have the greatest positive socioeconomic impacts, while use of

currently operating CLWRs to produce tritium would involve

insignificant socioeconomic impacts.

Transportation

There will be impacts associated with transporting irradiated

TPBARs from the reactor sites to the TEF at the Savannah River Site.

There would be approximately 13 shipments of TPBARs annually to SRS

which would result in an annual human health risk, over the entire

route of the shipments, of less than 1 latent cancer fatality every

100,000 years. The impact on any one individual would be less than

that. Because the Tritium Loading Facility and the APT would be located

at SRS, there are no impacts directly associated with transportation.

Conclusion: Although all the transportation impacts are negligible,

the APT has the least impact.

3. Overall Environmental Conclusion

As described above, and as documented in the environmental analyses

that have been developed, it is expected that the overall environmental

impacts associated with tritium production in either a CLWR or the APT

would be small. Consequently, the environmental impacts associated with

the two alternatives are not considered a major discriminating factor

in this tritium technology decision. The December 1995 Programmatic ROD

stated that the use of existing CLWRs for tritium production would be

the environmentally preferred alternative. Subsequent analyses,

discussed here, confirm this still to be true.

D. Programmatic Decision

Both technology alternatives are feasible. Consistent with the

Department's December 22, 1998, announcement, and based on the above

analysis, DOE selects the use of existing commercial light water

reactors as the primary technology to produce tritium for national

security purposes. In implementing this decision, DOE will construct a

new Tritium Extraction Facility on the Savannah River Site.

The use of commercial light water reactors is selected to be the

primary tritium supply technology because analysis leads to the

conclusion that this technology:

Would have the best chance of meeting all military

requirements due to:

Lowest technical risk.

Lowest schedule risk.

Highest confidence for meeting capacity requirements.

Would have the lowest investment and life-cycle costs.

Offers potential to be the most flexible in meeting

changing requirement.

Offers potential to have the least environmental impact.

The Accelerator Production of Tritium (APT) is designated as the

backup tritium production technology. The APT Project will complete

Engineering Development and Demonstration (ED&D) activities and final

design for a few key elements of the accelerator system. Completion of

these activities would permit expedient initiation of facility

construction if the accelerator is called upon.

In January 1997, the Fast Flux Test Facility (FFTF) was placed in a

safe standby condition as near-term ``insurance'' given the

uncertainties at that time with the dual-track technologies for tritium

production. Because it could not produce enough tritium to meet

production requirements, it could not serve as a potential primary

long-term tritium supply source. The Department's evaluation of FFTF

has focused on whether it can or should play any role as an interim

source of tritium until one of the other technologies is implemented.

The Department is fully confident that the tritium supply strategy

embodied in this decision can meet any current or future tritium

requirements. Consequently, the Department's FFTF will have no tritium

production role. A separate study is being conducted to determine if

that reactor should be restarted and operated for other purposes.

III. Site-specific Decision for the Production of Tritium Using

Commercial Light Water Reactors (CLWR)

A. CLWR EIS Alternatives

In conformance with the Department's December 22 announcement, the

preferred alternative identified in the CLWR Final EIS is to produce

tritium in the Watts Bar and Sequoyah reactors. As a result of the

programmatic decision in this ROD (see section II), DOE will produce

tritium in a CLWR, and the APT is designated as the back-up technology.

Consequently, the comparisons described in this section are focused

solely on the TVA reactor alternatives, and not the APT.

The CLWR EIS evaluates the following alternatives: (1) No Action

Alternative (which would result in the production of tritium in an

accelerator at the SRS); and (2) Tritium production at one or more of

the following Tennessee Valley Authority (TVA) CLWRs: Watts Bar Nuclear

Plant Unit 1 (Spring City, TN); Sequoyah Nuclear Plants Units 1 and 2

(Soddy Daisy, TN); and Bellefonte Nuclear Plants Units 1 and 2

(Hollywood, AL). The Watts Bar and Sequoyah reactors are existing,

operating CLWRs that produce electricity. Tritium production could be

performed in these reactors without any significant modifications to

these facilities and would not affect electricity production. The

Bellefonte units are unfinished nuclear reactors. Bellefonte Unit 1 is

approximately 90% complete, and Unit 2 is approximately 58% complete.

In order to produce tritium in a Bellefonte reactor, construction would

have to be completed and an operating license would have to be received

from the NRC.

B. Non-Environmental Comparison of CLWR Reactor Alternatives

1. Cost and Flexibility Factors

Investment cost is defined as the total of all remaining up-front

costs necessary to design, develop, construct, startup, or otherwise

establish tritium production capacity at each of the CLWRs. Investment

costs are generally the same as project costs. Life-cycle cost is

defined as the total amount of money spent to produce about 100

kilograms of tritium over the life of the alternative. Life-cycle cost

includes investment cost, all operating costs, and decontamination and

decommissioning (D&D) costs.

[[Page 26378]]

Cost to Meet Current Requirements (cost comparisons are expressed

in constant FY 1999 dollars).

The investment cost for the tritium-supply system that would use

the Watts Bar and Sequoyah reactors is estimated to be about $580

million, of which approximately $350 million are associated with

designing, constructing, and starting up the new TEF. Total investment

costs for the tritium-supply system that includes the Bellefonte

alternative are estimated to be $1.8 billion to $2.4 billion, depending

on the plan selected for payments to TVA to complete the reactor. The

Watts Bar/Sequoyah alternative could be accommodated within the DOE

Defense Programs budget but the Bellefonte alternative cannot.

The life-cycle cost for the Watts Bar and Sequoyah reactors ranges

from $1.4 billion to $2.9 billion, based on the letter agreement

between DOE and TVA signed on February 25, 1999. This includes $8

million for D&D of the TEF. The upper end of the life-cycle cost range

assumes that DOE would pay cash for the incremental increase in reactor

fuel enrichment needed for a reactor to accommodate TPBARs. The lower

end of the range assumes that highly enriched uranium, drawn from DOE's

defense stocks, would be blended down to provide all the fuel for the

host reactors. TVA would reimburse DOE at a market-based rate for that

portion of the fuel cost not directly attributable to tritium

production. Present discount value for the Watts Bar/Sequoyah option

would be in the range of $880 million to $1.6 billion.

Life-cycle cost of the Bellefonte alternative would be $1.2 billion

to $2.8 billion, depending on the plan for payments to TVA and DOE's

share of Bellefonte's power sales revenues. Because annual budget

limitations would likely prevent DOE from making large up-front

payments to TVA to complete Bellefonte, the lower-revenue-share/higher-

life-cycle-cost scenario is far more likely than the high revenue/low

life-cycle cost scenario. For the Bellefonte alternative, no fuel

transactions are assumed. Present discount value would be in the range

of $1.6-2.0 billion. D&D of the TEF, but no other facility, is

included.

Conclusion: The Watts Bar/Sequoyah alternative has the lowest

investment cost which can be accommodated within the DOE national

security programs budget. There is also strong potential for the Watts

Bar/Sequoyah option to have the lowest life-cycle cost because of the

likelihood that Bellefonte life-cycle costs would be near the high end

of the range. In addition, the Watts Bar/Sequoyah alternative has a

significantly lower financial risk because DOE would not pay until

tritium is produced. With the Bellefonte alternative there is a degree

of risk that, having paid for the plant, DOE would not receive any

return from net power revenues because of changes in the power market

or failure of the reactor to go into operation.

Cost To Meet Reduced START II Requirements

If START II comes into force, the tritium need date could be around

2011 and the maximum tritium production rate may be reduced to about

1.5 kilograms per year. If so, the existing commercial reactor

alternative's investment cost would remain about the same as the

current case. Life-cycle cost for the commercial reactor alternative,

using the existing TVA reactors would be in the range of $2.2-2.5

billion, based on the DOE-TVA letter of agreement of February 25, 1999.

The upper end of this range assumes DOE pays cash for incremental

increases in reactor fuel enrichment. The low end of this range assumes

DOE fuel stocks are blended to provide for the incremental increase in

fuel enrichment. The range could be lower still if TVA purchased all

its fuel from DOE. The Bellefonte alternative's relatively high

investment costs would not change under a START II scenario and the

life-cycle cost would be reduced by $100 million or less.

Conclusion: Under a START II scenario, investment and life-cycle

costs would be lowest for the Watts Bar/Sequoyah alternative.

Flexibility To Meet Changing Requirements

If START II is ratified, the U.S. may decide to reduce its tritium

production requirements, thus moving the need date to around FY 2011

and reducing tritium production requirements. Stockpile reductions

beyond START II are also possible and would result in further extension

of the tritium need date and reductions in tritium production

requirements.

The Bellefonte reactor alternative's flexibility characteristics

are limited. While there is great flexibility in amounts of tritium

that can be produced, the large up-front investment cost would have no

relation to tritium requirements. Once DOE committed itself to

completion of the reactor, there would be no opportunity to reduce

investment costs if stockpile tritium requirements were reduced. The

annual net operating costs of this alternative would vary slightly with

tritium demand only because of reductions in the cost for TPBAR

manufacturing and transportation, thus reducing the total life-cycle

cost.

The use of the existing Watts Bar and Sequoyah reactors is the most

flexible with respect to changing stockpile levels. If the tritium need

date is extended, most investment for this alternative could be

suspended indefinitely and then restarted later. A substantial portion

of DOE's operating costs would be based on tritium demand on a pay-as-

you-go basis. Except for minimal standby costs, DOE would pay for

irradiation services, TPBAR manufacturing, and transportation

operations only during those years when tritium is actually produced.

The amount spent for irradiation services would be dependent on the

amount of tritium produced. If the tritium need date is extended before

the TEF handles its first increment of radioactive material, that

facility could remain in standby indefinitely for less than $1 million

per year.

Conclusion: The use of the existing Watts Bar and Sequoyah reactors

results in the greatest degree of flexibility to meet changing

requirements, especially in view of the potential for future reductions

in the nuclear weapons stockpile.

Arms Control/Nonproliferation

The use of the currently operating Watts Bar and Sequoyah reactors

has unique advantages not available with any other alternative,

including the Bellefonte option, which serve to offset the

nonproliferation implications of using these reactors. It is the only

option that does not require a very large up-front capital expenditure.

It is the only option that allows the nation to pursue the goal of

further arms reductions without commitment to a major new weapons

facility. By selecting Watts Bar and Sequoyah, the nation is assured of

a long-term option to make tritium, which may not have to be exercised

for many years if arms reduction efforts are successful, as DOE hopes

they would be.

By not committing itself to the construction of a major new weapons

facility, the U.S. can underscore to other nations, especially would-be

proliferant nations, its continuing pursuit of smaller nuclear weapons

stockpiles. This would be consistent with recent U.S. actions,

including cessation of underground nuclear testing, the stoppage of

plutonium production, and closure or withdrawal of defense missions

from several sites in the nuclear weapons complex. Commitment to a

major new weapons facility could be seen as building up U.S. nuclear

[[Page 26379]]

weapons production capabilities at a time when the U.S. is seeking to

reassure other nations of its commitment to nuclear arms reductions.

These factors offset the fact that the use of the three reactors

for tritium production would depart from the general practice of

maintaining a distinction between U.S. defense and civilian nuclear

activities. Moreover, the Department has determined that the impact of

this issue on U.S. nonproliferation policy is manageable, given the

surrounding circumstances enumerated above.

Conclusion: The use of the currently operating Watts Bar and

Sequoyah reactors is most consistent with stated U.S. nuclear weapons

stockpile reduction and nonproliferation goals.

2. Technical Factors

Capacity and Schedule

The Bellefonte alternative and the Watts Bar/Sequoyah alternative

could both achieve a production capacity of about 3 kilograms of

tritium per year. No matter which alternative is selected, the first

batch of tritium could begin production in early FY 2004 when the Watts

Bar reactor is scheduled to complete a refueling outage. Because many

technical and regulatory issues have been addressed already, there is a

high degree of confidence that this initial irradiation schedule can be

met. The first batch of tritium gas could be delivered to the stockpile

as soon as the TEF is operational. Because the Watts Bar and Sequoyah

reactors would be used to irradiate the initial batches of TPBARs,

delays in completing the Bellefonte reactor would not be expected to

impact the tritium production schedule. Under current START I

requirements, neither reactor alternative would require the use of the

tritium reserve.

Conclusion: Each reactor alternative can achieve capacity

requirements. There is a high likelihood that, with adequate funding,

each of the reactor alternatives can meet the schedule and the tritium

reserve would not be affected.

Regulatory and Licensing Issues

The Bellefonte alternative would have to be licensed as a new

nuclear power plant. The plant's initial NRC operating license would

also permit tritium production. This process is likely to take up to 5

years. This would not affect national security because initial tritium

production would begin with the Watts Bar reactor. Delays in getting

Bellefonte in operation would, however, delay and possibly reduce DOE's

receipt of revenues from Bellefonte power sales, if any.

The NRC would have to amend the operating licenses of the Watts Bar

and Sequoyah reactors to permit production-scale irradiation of

tritium-producing rods. DOE expects that NRC would be in a position to

act upon the amendment requests well in advance of the planned October

2003 start of irradiation. Some experience has already been gained in

this area because the Watts Bar reactor's operating license was amended

to permit the confirmatory test irradiation of 32 TPBARs.

Conclusion: The Bellefonte alternative has potential for these

issues to impact its schedule, but is not likely to affect tritium

production. However, delays in getting Bellefonte on line would reduce

the Government's receipts from its share of Bellefonte revenues, if

any. The Watts Bar/Sequoyah option is not likely to be affected by

regulatory issues. Watts Bar and Sequoyah are preferred over Bellefonte

because the completion and initial licensing of a new nuclear facility

entails greater technical and financial risk than obtaining a license

amendment for existing facilities.

C. Comparison of Environmental Impacts of CLWR Alternatives

The relative differences in environmental impacts between tritium

production in operating CLWRs (Watts Bar and Sequoyah) and the

completion and operation of the incomplete Bellefonte Unit 1 reactor

are described in the Supplemental Programmatic Record of Decision,

Section II.C, above. As described in that section and as documented in

the CLWR EIS, DOE expects that the overall environmental impacts

associated with tritium production in a CLWR would be small.

Consequently, the environmental impacts associated with the CLWR

alternatives are not considered a major discriminating factor in this

decision. Based on all of the environmental factors considered, the use

of the Watts Bar and Sequoyah reactors is the environmentally preferred

alternative.

D. CLWR Decision

DOE selects the Watts Bar Unit 1 and the Sequoyah Unit 1 and 2

reactors as the specific CLWRs to produce tritium for national security

purposes. Compared to completing the Bellefonte reactor, the use of the

currently operating Watts Bar and Sequoyah reactors for tritium

production would have the:

Lowest investment cost and lowest life-cycle cost under

most-likely scenarios.

Lowest financial risk.

Greatest flexibility to meet changing requirements.

Most consistency with stated arms reduction goals.

Lowest overall incremental environmental impact.

By selecting the Watts Bar and Sequoyah reactors, highly enriched

uranium, drawn from DOE's defense stocks, would be blended down to

provide for the enrichment increase.

IV. Site-Specific Decision for Construction and Operation of a

Tritium Extraction Facility (TEF) at the Savannah River Site

A. TEF Alternatives

The proposed action addressed in the Final EIS for the Construction

and Operation of a TEF at the Savannah River Site (SRS) is to design,

construct, test, and operate TEF at SRS to provide tritium extraction

capability to support tritium production technology. The purpose of TEF

is to extract tritium-containing gases from TPBARs irradiated in a CLWR

or from targets of similar design, and deliver the tritium-containing

gases to Building 233-H, the existing Tritium Loading Facility, for

final purification. As described below, DOE evaluated two reasonable

alternatives and a no-action alternative in the TEF Final EIS.

1. Construct a New Facility in the H-Area (Preferred Alternative)

As identified in the TEF Final EIS, the preferred alternative is to

locate TEF in H-Area, immediately adjacent to and west of Building 233-

H within the boundaries of SRS. The reasons for co-locating TEF close

to Building 233-H are: (1) To share common support facilities,

services, and some personnel; (2) to facilitate the transfer of tritium

between the two facilities; and (3) to use certain gas-handling

processes located in H-Area. TEF would consist of a concrete industrial

facility constructed partly below grade. The facility would be divided

into two major areas: (1) A remote handling area (RHA) and (2) a

tritium processing building. The tritium processing building would be

entirely aboveground; the floor of the RHA would be below grade.

Construction of the proposed facility would require approximately 4 to

5 years. Major process and operation systems included within the

proposed TEF would be: (1) The Receiving, Handling, and Storage System

that would support all functions related to the receipt, handling,

preparation, and storage of incoming radioactive sources and outgoing

radioactive waste materials; (2) the Tritium Extraction System that

would

[[Page 26380]]

get tritium and other gases from irradiated TPBARs, remove contaminants

from the gas stream, and store the hydrogen isotope/helium mixture; (3)

the Tritium/Product Processing Systems that would separate and purify

process gases from the irradiated TPBAR materials; (4) the Tritium

Analysis and Accountability Systems that would support monitoring and

tritium accountability; (5) the Solid Waste Management System that

would receive solid waste generated by TEF for management and storage

prior to disposal in the SRS E-Area vaults; and (6) the Heating,

Ventilation, and Air Conditioning System that would provide and

distribute conditioned supply air to the underground RHA and the

aboveground tritium processing area and also discharge exhaust air to

the environment via a 100-foot stack.

2. Upgrading the Existing Allied General Nuclear Services (AGNS)

Facility

An alternative to constructing a new TEF within H-Area is to

refurbish and use the existing Allied General Nuclear Services (AGNS)

facility located in Barnwell County, adjacent to the eastern boundary

of SRS. AGNS was completed in 1976, and portions of the facility were

tested with natural uranium in anticipation of obtaining an operating

license to process commercial spent nuclear fuel. However, due to a

change in government policy on reprocessing commercial spent nuclear

fuel, the facility never opened. It was cleaned up and placed in

standby in 1977 and shut down in 1983. The AGNS facility was designed

and built to NRC standards. It would not meet all applicable DOE Orders

without major modifications as discussed below. Utilization of AGNS

would necessitate some new construction and some modifications.

Extraction furnaces would have to be designed, built, and installed. A

drying oven to remove pool water from CLWR TPBAR bundles or bundles of

targets of similar design unloaded in the wet basin would be required

(at AGNS, TPBARs would be stored in existing fuel storage basins). A

process gas stripper would have to be added to reduce stack tritium

releases. Although rail lines to the existing facility have been

removed, the tracks within the facility staging area and into the cask

unloading bays are still in place. Roads on the AGNS property need

moderate repair; and a short connecting road tying AGNS into the SRS

road system would have to be constructed. Other requirements include

refurbishing the heating, ventilation, air conditioning (HVAC) fans,

motors, high-efficiency particulate air (HEPA) filters and dampers; and

replacing the chiller water, fire protection, electrical, security, and

personnel protection systems.

3. No Action Alternative

Under the no-action alternative, DOE would not construct and

operate a TEF either at the preferred location in H-Area or at the

alternate location at AGNS. Under the no-action alternative, DOE could

incorporate tritium extraction capability into the APT facility at SRS.

However, because the use of existing commercial light water reactors

has been chosen as the primary tritium supply, selection of no action

for the TEF would result in the inability to extract tritium from the

irradiated TPBARs because an APT (with extraction capabilities) would

not be built. In that case, DOE would not be able to fulfill the

purpose and need for the proposed action. Such a decision would be

inconsistent with the December 5, 1995 ROD for the Tritium Supply

Programmatic EIS, as well as the programmatic decision documented in

this Consolidated ROD. Based on the supplemental Tritium Supply and

Recycling ROD, the no-action alternative for tritium extraction is

unreasonable and is not further discussed in this portion of the

Consolidated ROD.

B. Non-Environmental Comparison of Alternatives

1. Cost and Technical Factors

Cost

The life cycle cost estimate for the TEF at the preferred

alternative (H-Area) is $920 million compared to the AGNS facility

upgrades which is $1085 million. Both estimates are in constant FY 1999

dollars. Because of its close proximity to other tritium facilities in

H-Area, the H-Area alternative for TEF enables the sharing of common

support facilities, services, and some personnel; to facilitate the

transfer of tritium between the two facilities; and to use certain gas-

handling processes located in H-Area. Consequently the life-cycle cost

of operating the TEF at this location is less than AGNS. The AGNS

estimate exceeds the TEF estimate due to the added cost of logistics in

moving the tritium containing gases from the AGNS location to the H-

Area location for final processing and loading and the additional gas

processing equipment needed at the AGNS location.

Conclusion: Locating the TEF in the H-Area would have a lower life-

cycle cost than locating it at AGNS.

Technical

Several technical aspects were considered in evaluating the

alternatives. For the AGNS facility, these technical aspects included:

construction of several new buildings to house the gas processing

equipment needed (existing facilities were not large enough to house

the needed gloveboxes), installation of a drying oven to remove

moisture from TPBARs wetted during underwater cask unloading, the

addition of a waste processing facility, and an overhaul of the AGNS

ventilation system to facilitate the tritium gas processing

requirements. Technical factors involving the location of the preferred

alternative are: (1) To share common support facilities, services, and

some personnel; (2) to facilitate the transfer of tritium between the

two facilities; and (3) to use certain gas-handling processes located

in H Area.

The design basis of the Tritium Extraction Facility (TEF) requires

that tritium-containing gasses be supplied to the existing Tritium

Loading Facility (Building 233-H). Extracted gasses would not be

isotopically separated at TEF but would utilize existing equipment in

Building 233-H for separation of the hydrogen isotopes. In addition,

the TEF would not be designed to separate hydrogen and non-hydrogen

isotopes. The cost savings to the TEF project by not including this

separation equipment is approximately $50 million. If the TEF were

built at the AGNS facility, the TEF would have to include all of the

necessary separation equipment as well as the infrastructure required

for the facility (electrical, waste water, fire protection, staffing,

etc.). The hydrogen isotopic separation equipment would need to

``purify'' the extracted tritium-containing gasses prior to loading on

a hydride bed for transporting to the 233-H facility. Additionally,

utilization of AGNS would require the unloading of shipping casks

underwater which in turn would require the addition of a drying area

for the TPBARs prior to extraction. The introduction of water in or

around a tritium source greatly increases the hazard to operations

personnel in the form of tritium oxide, which is 10,000 times more

hazardous to humans than elemental tritium. However, collective doses

to the population are expected to equal those of the H-Area

alternative.

Conclusion: The ability of the preferred alternative to deliver gas

directly to the 233-H facility offers several technical advantages over

the AGNS alternative.

[[Page 26381]]

C. Comparison of Environmental Impacts of TEF Alternatives

In general DOE considers the expected impacts on the physical,

biological, and human environment for both reasonable alternatives to

be minor and consistent with what might be expected for an industrial

facility. In the comparison of impacts, DOE determined that changes

from current site environmental conditions of less than 5 percent are

within the margin of error and the conservatism inherent in the

analyses. Therefore, DOE finds that in those instances there would be

no measurable change from current environmental conditions. As

documented in the TEF Final EIS, overall, there are not expected to be

any significant differences in environmental impacts between the two

reasonable alternatives. Except for the no-action alternative, the

construction and operating impacts of the TEF would be added to the

impacts of the CLWR alternatives discussed in Section III above.

1. Construction Impacts

Minor differences between the alternatives are expected due to

construction. Because much of the AGNS alternative involves internal

modifications to an existing facility, less land would be disturbed and

less construction waste generated. However, because the land at H-Area

is already a densely developed, industrial area, impacts associated

with land disturbance are not a significant factor. With respect to

construction waste volumes, potential impacts to SRS waste treatment,

storage, and disposal facilities would be small for both alternatives

because of the low volumes of waste to be generated. At the AGNS site,

construction noise and activity could have localized adverse effects on

wildlife; however, this is not expected to be significant. Impacts

associated with socioeconomics would be similar as each alternative

would have a 5-year construction duration and a similar peak workforce

(740 for H-Area, 685 for AGNS). While the creation of these jobs would

have a positive stabilizing effect on the SRS employment, the overall

impact would be minor since either alternative would change the

regional employment by less than one-half of one percent.

Conclusion: Although the environmental impacts associated with

construction are considered small for both alternatives, the AGNS

alternative would have a smaller construction impact.

2. Operating Impacts

Operation of the TEF at H-Area or at AGNS could cause impacts in

the following areas: human health (normal operations and accidents);

waste generation; and socioeconomics. These areas are discussed below:

Human Health

A primary difference between the preferred alternative at H-Area

and the alternative at AGNS is AGNS's proximity to non-government land,

and therefore, its greater potential for impacting offsite individuals

due to releases near the site boundary. Additional differences include

stack height and radionuclides released to the environment. The

quantities released at AGNS would differ from those emitted at H-Area

because each rod would have to be cut three times in order to fit in

the AGNS furnace, while full-height TPBARs would be punctured at H-

Area. While processing CLWR TPBARs, the contributions of

nonradiological air constituents at AGNS would be 0.13 percent of the

applicable standard, and still lower for the onsite H-Area alternative.

The radiological dose for the offsite maximally exposed individual

would be 0.15 millirem per year for AGNS and 0.02 millirem per year for

H-Area. Both of these would be well below the regulatory annual limit

of 10 millirem from airborne releases. Because of the location of AGNS,

some minority or low-income communities could be disproportionately

affected by radiological and nonradiological air emissions; however,

such impacts are expected to be minor and within all regulatory

standards. Compared to the proposed action, for the maximally exposed

individual the AGNS alternative is projected to have a 0.13 millirem

per year higher radiation (due to its closer proximity to the boundary)

but nearly equal collective population doses.

With respect to impacts from potential accidents, the lower

population density in the communities near AGNS would result in a

slightly smaller collective doses from potential accidents. For each of

the alternatives, the design-basis accident would yield risks to the

50-mile population of approximately 7 latent cancer fatalities every

100,000 years.

Conclusion: Although the differences between the two alternatives

are not significant, the preferred alternative (H-area) would have a

lower impact on human health because of its greater distance from the

site boundary.

Waste Generation

Both alternatives would generate 232 cubic yards of waste annually.

The potential impacts to SRS waste treatment, storage, and disposal

facilities would be small because the volumes would be small relative

to existing waste management capabilities.

Conclusion: There is no apparent difference between the two

alternatives' generation of waste.

Socioeconomics

Because of its proximity to other tritium facilities in H-Area, the

H-Area alternative for TEF facilitates the use of common support

facilities, services, and some personnel. Consequently, the operations

workforce for the H-Area alternative is approximately 60 percent as

much as the AGNS alternative (108 versus 175). While the socioeconomic

impact for each alternative is considered minor, the reduced staffing

requirement for the H-Area alternative is a major factor in its reduced

life-cycle cost compared to the AGNS alternative.

Conclusion: Although the AGNS alternative would provide 67 more

jobs for facility operators, the difference is not significant.

3. Environmentally Preferred Alternative

As described in the TEF Final EIS, the potential impacts from the

preferred alternative or the AGNS alternative on the physical,

biological, and human environment would be minor and consistent with

what might be expected for an industrial facility. The preferred site

for TEF is within H-Area, a densely developed, industrialized area near

the center of SRS, approximately 6.8 miles from the nearest (western)

SRS boundary. There are four existing tritium-related facilities in the

immediate vicinity of the proposed TEF site. Advantages to locating TEF

within H-Area include minimal environmental impacts associated with

construction and operation of the proposed TEF due to the developed

nature of H-Area; availability of site infrastructure (i.e., power,

steam, potable water, sewerage); and proximity to existing tritium-

related facilities and processes to support TEF operations. Both the

nonradiological air constituents and annual radiological dose are lower

for the preferred alternative compared to the AGNS alternative.

Consequently, the H-Area alternative is the environmentally preferred

alternative.

D. TEF Decision

The preferred alternative, to design, construct, test, and operate

a new TEF in H-Area immediately adjacent to and

[[Page 26382]]

west of Building 233-H, at the SRS, is selected for implementation.

This alternative has the lowest life-cycle cost, has technical

advantages, and is environmentally preferred.

V. Site-Specific Decision for Accelerator Production of Tritium

(APT)

DOE has prepared this part of the Consolidated Record of Decision

to implement that portion of the December 22, 1998 announcement

designating the APT as the backup technology. It is based on the

analysis from the Accelerator Production of Tritium at the Savannah

River Site Final Environmental Impact Statement (DOE/EIS-0270) issued

in March 1999, along with other factors such as DOE statutory mission

requirements, national security policy, cost, schedule and technical

risks.

A. APT Design Features and System Alternatives Considered

The EIS evaluated the no action alternative, and technology and

siting alternatives relating to radiofrequency power, accelerator

operating temperature, feedstock material, cooling water system, APT

site, electric power supply, and APT design variations. The following

section summarizes these alternatives.

1. No Action Alternative

No action for the APT is to produce tritium in a commercial light

water reactor and to construct and operate a tritium extraction

facility. Under the no action alternative the APT is designated the

back-up technology for tritium production. As back-up, DOE would

complete key research and development, and preliminary design

activities for the APT at SRS (but would not construct the facility).

Selection of APT technology and siting alternatives would support the

research and development and preliminary design activities and

facilitate implementation should construction and operation of the APT

be called for in the future.

2. Radiofrequency Power Alternatives

APT would use radiofrequency waves to accelerate protons in the

accelerator. Specially designed vacuum electron tubes would convert

electric power to radiofrequency waves outside of the accelerator. The

waves are then transported into the accelerator and used to accelerate

the protons. The APT EIS evaluated two alternatives to supply the

radiofrequency power for the accelerator, (1) klystron radiofrequency

power tubes (DOE's preferred alternative), and (2) high order mode

inductive output radiofrequency power tubes.

3. Operating Temperature Alternatives

The operating temperature affects the electrical components in the

accelerator. The greater the power converted to heat the greater the

amount of electricity used. If the temperature of some materials (e.g.,

niobium) falls to values near absolute zero (-459 deg.F), the

electrical resistance becomes essentially zero, and the component uses

much less electricity. This is called superconductivity. The APT EIS

evaluated two operating temperature alternatives for the accelerator:

(1) operating electrical components at essentially room temperature,

and (2) operating high energy accelerating structures at

superconducting temperatures and the rest at room temperature (DOE's

preferred alternative).

4. Feedstock Material Alternatives

The feedstock material absorbs the neutrons freed during spallation

resulting in the production of a tritium atom and a byproduct atom. DOE

would use the same target/blanket as the neutron source regardless of

the feedstock material. The APT EIS evaluated two feedstock materials,

(1) Helium-3 (DOE's preferred alternative) and (2) Lithium-6.

5. Cooling Water System Alternatives

The APT requires cooling water to keep target/blanket components,

radiation shielding, beamstops and other components from overheating.

DOE proposes to use a similar method for cooling each component. This

is a primary coolant loop isolated from the environment through heat

exchangers. Components with the potential for radioactive contamination

would require a secondary loop to cool the primary loop and isolate

potential contamination from the environment. The final cooling system,

regardless of the number of loops, would use a cooling water system to

discharge heat to the environment. The APT EIS evaluated four designs

to provide the necessary cooling capacity for the APT: (1) Mechanical-

draft cooling towers with makeup water from the Savannah River and

discharge into pre-cooler Ponds 2 and 5 of Par Pond (DOE's preferred

alternative); (2) mechanical-draft cooling towers with makeup water

from groundwater wells and discharge into pre-cooler Ponds 2 and 5 of

Par Pond; (3) once through cooling using Savannah River water and

discharge into pre-cooler Ponds 2 and 5 of Par Pond; and (4) use the

existing K-Area cooling tower with Savannah River water makeup and

discharge to Pen Branch via Indian Grave Branch. A design variation for

the first three alternatives would be to discharge the heated water to

the head of Pond C of Par Pond but downstream from pre-cooler Ponds 2

and 5.

6. Siting Alternatives

DOE conducted a screening process to select potentially suitable

sites within the SRS for the APT. Based on a weighing and balancing of

the criteria, DOE selected two sites for further analysis. The APT EIS

evaluated (1) a site 3 miles northeast of the Tritium Loading Facility,

and approximately 6.5 miles from the SRS boundary (DOE's preferred

alternative); and (2) a site 2 miles northwest of the Tritium Loading

Facility, and approximately 4 miles from the SRS boundary.

7. Electric Power Supply Alternatives

APT requires large amounts of electricity to operate. Therefore,

DOE evaluated two alternatives for the source of electricity for the

APT: (1) Obtain electricity from existing commercial capacity and

through market transactions (DOE's preferred alternative); (2) obtain

electricity from the construction and operation of a new coal-fired or

a natural-gas-fired generating plant.

8. APT Design Variations

In addition to the cooling water discharge design variation

described above, the APT EIS evaluated two other variations. The first

is a modular, or staged, accelerator configuration. It would use the

same accelerator architecture as the baseline but could be constructed

in stages. An initial stage would produce less tritium than the

baseline APT but would be capable of producing as much tritium as the

baseline APT with the addition of a second stage.

The second variation would combine tritium separation and tritium

extraction facilities to take advantage of common process systems and

would be capable of handling both Helium-3 and Lithium-6 feedstock

material.

B. Non-Environmental Comparison of APT Design Features and System

Alternatives

Technical comparisons are presented for each set of alternatives

described above. These are based on various studies completed for each

alternative.

[[Page 26383]]

1. Technology Factors

Radiofrequency Power

The klystron is an established technology that has been used for

years. Thus, this technology has proven reliability and presents no

technical challenges to its use in the APT. The inductive output tube

has several commercial applications, but additional design and

prototyping is needed to demonstrate the applicability to APT. These

demonstration tests are scheduled for completion this spring. The

inductive output tubes have a greater efficiency in converting DC power

to RF power which would reduce power requirements by 15 percent. The

inductive output tube also uses one half of the voltage resulting in

reduced shielding requirements.

Conclusion: The preferred alternative of klystron power tubes would

be used as the basis for the preliminary design. The inductive output

tube offers technical advantages and reduces operating costs (less

electricity used) and capital costs (less shielding needed). The

continued development is justified to achieve these benefits.

Operating Temperature

The room temperature accelerator technology is based on technology

demonstrated at the Los Alamos National Laboratory. The accelerator

cavities are cooled by the primary water cooling system. As part of the

accelerating structures the cavity lengths would increase in size in

proportion to the increasing proton velocity. This results in greater

complexity of maintenance because each cavity is unique.

The superconducting technology uses two sizes of cavities which are

cooled with liquid helium to almost absolute zero. This cooling method

eliminates the need for water cooling in the superconducting cavities.

The two different sizes of cavities allows for simplified maintenance.

The engineering development and demonstration program has completed the

design and prototyping of these cavities.

Conclusion: The superconducting cavities allow for easier

accelerator maintenance. Experience has shown that liquid helium

distribution systems are less prone to leakage than water systems.

Feedstock Materials

Helium-3 is a nonradioactive gas that exists naturally in small

quantities and is produced through the radioactive decay of tritium.

The helium-3 is contained in tubes within the target/blanket. The

helium-3 would absorb neutrons which converts it to tritium and

hydrogen The helium-3 and tritium mixture would be continuously or

semi-continuously transported via piping to the Tritium Separation

Facility. The helium-3 purified in the separations process is returned

to the target/blanket to produce additional tritium. This results in

reduced inventories of tritium in the target/blanket and prevention of

pollution since the helium-3 is recycled. The production of tritium can

also be varied through controlling the number of neutrons but without

sacrificing continuous separation.

Lithium-6 would be in the form of rods that would be placed in the

blanket area. These rods would be similar to the rods DOE used when it

operated the SRS tritium production reactors. Because the lithium-6 is

incorporated into solid rods, batch production of tritium is required

resulting in a higher inventory of tritium in the target/blanket than

the helium-3 alternative. Also the rods could not be recycled.

Conclusion: The improved safety factors from reduced inventory of

tritium in the helium-3 alternative along with the ability to recycle

the helium-3 provides advantages for the helium-3 alternative. The

added flexibility of varying production rates also makes the helium-3

alternative attractive.

Cooling Water System

The cooling water system alternatives were evaluated using three

evaluation criteria, capital cost, life cycle cost, and permitting

risk. The mechanical draft cooling tower with river water makeup was

rated the lowest capital cost, the lowest life cycle cost, and the

least risk associated with obtaining permits. The evaluation of risks

associated with permits is based on the scope of changes to existing

systems that would require regulatory reviews as well as the

temperature of the blowdown water compared to the threshold limit. This

evaluation placed the mechanical draft cooling tower with river water

makeup as the best alternative. The mechanical draft cooling tower with

ground water makeup was ranked second, once through cooling was third

and the use of K-Area cooling tower was fourth. A separate evaluation

for the design variation of discharge to Pond C of Par Pond was also

completed. This evaluation showed a reduction in costs due to avoidance

of costs associated with upgrades to the pre-cooler ponds.

Conclusion: The mechanical draft cooling tower with river water

makeup was evaluated as the best alternative based on capital cost,

life-cycle cost, and permitting risk criteria. The design variation of

discharging to Pond C of Par Pond added the benefit of reducing costs.

Siting

The two sites evaluated in the EIS, a site 3 miles northeast of the

Tritium Loading Facility (northeast site), and a site 2 miles northwest

of the Tritium Loading Facility (northwest site), were similar in most

characteristics. No differences in engineering factors were identified

in the Site Selection Study (WSRC-TR-96-0279). The ranking factors

where there is a difference between the two sites were in ecology,

where the northeast site was better; depth to groundwater, where the

northwest site was better; and buffer distance to the public off-site,

where the northeast site was better.

Conclusion: Due to increased buffer distance which would reduce

public radiological exposure in the case of an incident, the northeast

site is a better location.

Electrical Supply

The two alternatives evaluated present different technical and

financial challenges. The alternative to construct a new dedicated coal

or gas fired plant would probably require both contractual and

financial guarantees by DOE to the utility providing the electricity.

Prior to a utility constructing a plant, the DOE would need to enter a

long-term power purchase agreement to provide assurance to the utility

that it would have a market for the output of the plant. The

contractual arrangement would therefore entail take-or-pay obligations

on the part of DOE for an amount of time necessary for growth in system

demand to absorb the generating capacity constructed.

In the alternative of relying on existing capacity and contracting

for power purchased on the market, the take-or-pay and/or notice-of-

termination provisions associated with a dedicated plant can be

minimized or entirely avoided. Shorter term retail sales contracts (2

to 5 years) can be accommodated which would permit the DOE to

periodically recompete the APT purchase arrangements. This would also

allow DOE to take advantage of renewable energy opportunities that

could become available in the future.

The electric power industry is presently subject to significant and

widespread changes, with approximately 40 states presently addressing

the issue of restructuring the retail power market to permit

competition among suppliers. A long-term power supply contract tied to

the construction of a dedicated generating

[[Page 26384]]

facility would eliminate DOE's flexibility in taking advantage of

changes in the power supply market over the life of the plant.

Conclusion: The alternative of purchasing power from the electric

grid through market transaction provides DOE with greater long-term

flexibility and avoids the need to commit to a long-term contract for

power.

Modular Design

The modular design was developed to provide tritium production

flexibility in the face of changing stockpile requirements, and to

optimize the project costs and funding profile. Several different

modular designs were evaluated using cost and schedule, technical and

programmatic risk, and the potential for future upgrades as general

criteria. The preferred design meets current requirements, but allows

for a delay in the decision to construct an APT that meets Start I

requirements for several years, while avoiding the commitment to the

cost of a START I sized facility.

Conclusion: The modular design provides the DOE with enhanced

flexibility to only commit to an APT sized to meet requirements in

several years.

C. Comparison of Environmental Impacts of APT Alternatives

The APT EIS presents an evaluation of environmental impacts for the

combination of the preferred alternatives identified above, and the

differences found for each of the alternatives. This summary presents

the same format for comparison of the environmental impacts.

1. Construction Impacts for the Preferred Technology and Site

Alternatives

APT would require conversion of approximately 250 acres of land

from forest to industrial uses. This land would be graded or leveled

during construction. Additional roads, bridge upgrades, rail lines, and

utility upgrades would be required. No geologically significant

formations or surface faults occur on the site. Soils on the site are

not classified as significant. The change in land use would have no

marked reduction in plant and animal abundance or diversity. There are

no impacts to wetlands or threatened or endangered species.

Impact to surface waters are negligible, however, dewatering of the

construction site could result in short-term increases in solids to

receiving water bodies. Impacts to aquatic organisms in Upper Three

Runs and tributaries would be minor due to the use of soil and erosion

control measures.

Air emissions would be negligible at the site, and purchases of

electricity would be dispersed. There are no radiological emissions

during construction. Visual impacts would be negligible. Noise,

primarily from construction equipment is not audible at the SRS

boundary, however, construction workers could encounter noise levels

that would require administrative controls or protective equipment.

APT would generate hazardous solid waste and sanitary solid and

liquid waste. These would be deposited at SRS, and would require some

landfill construction. Estimated annual volumes of waste are 560 cubic

meters of sanitary solid waste, 30,000 cubic meters of construction

debris, and 3.6 million gallons of industrial wastewater.

Impacts to public health during construction would be negligible

because concentrations of non-radiological constituents are below

applicable limits. Increased traffic would result in a small increase

in traffic fatalities. Occupational injuries are not expected to be

different than those occurring on any large construction site.

The work force required for construction is estimated to peak at

1,400 jobs. This would not result in large regional impacts.

2. Operational Impacts for the Preferred Technology and Site

Alternatives

No impacts would occur to landforms, soils, hydrology or geology

during operations. No dewatering is required for operations. Electrical

use is estimated at 3.1 terawatt-hours per year. Negligible impacts to

terrestrial ecology and threatened and endangered species are expected.

Mechanical draft cooling towers would result in salt deposition on

vegetation, however, maximum levels are below threshold levels.

Operations would result in minor impacts to wetlands due to marginally

higher temperature of blowdown water.

Blowdown rates of approximately 2,000 gallons per minute would

cause negligible impact on surface water levels. Using Par Pond and

pre-cooler ponds as discharge points for cooling water, temperatures

would not exceed 90 degrees F. Contaminated sediments could be

resuspended, resulting in negligible additional fatal cancers from

exposure to the public. Impingement and entrainment from intake of

river water would not substantially affect Savannah River fisheries.

Solids in blowdown water would have no impact on aquatic ecology.

Discharge temperatures would only have small localized effects on

aquatic communities.

Non-radiological air emissions would be well within the applicable

regulatory standards. Radioactive airborne emissions would result in

expected latent cancer fatalities of 0.0008 annually. There would be

negligible impacts to visual resources, with plumes visible under

certain meteorological conditions. Noise generated by equipment and

traffic would not be audible at the SRS boundary.

APT operations would generate solid and liquid wastes but no high-

level or transuranic waste; waste volumes would have a negligible

impact on the capacities of waste facilities. The generation of

electricity would produce various types of waste including fly ash,

bottom ash, and scrubber sludge. Estimated annual amounts of waste

generated are 1,800 metric tons of sanitary solid waste, 3,800 metric

tons of industrial waste, 140,000 gallons of radioactive wastewater,

3.3 million gallons of sanitary wastewater, 920 million gallons of non-

radioactive process wastewater, 1,400 cubic meters of low-level

radioactive waste, 3 cubic meters of high concentration radioactivity

low-level radioactive waste, and 12 cubic meters of high concentration

radioactivity mixed waste.

The public would receive source radiation exposure from APT

emissions and transportation of radioactive material. Workers would

receive radiation exposure from facility operations and transportation

of radioactive material and from electromagnetic fields. These would

result in an annual risk of 0.0016 latent cancer fatalities. There

would be negligible consequences from accidents with a frequency of

less than once in the operating lifetime of the facility.

The operational work force would be approximately 500. This would

not result in large regional impacts. No adverse impacts on minority or

low-income populations are expected.

3. Environmental Impacts of Alternatives

Radiofrequency Power Alternative--Inductive Output Tubes

This alternative would have no change in estimated impacts from the

preferred alternative for construction impacts. The only change in

operational impacts from the preferred alternative is in impacts to

surface waters. The

[[Page 26385]]

inductive output tube would require 7 percent less cooling water.

Operating Temperature Alternative--Operating Electrical Components at

Room Temperature

This alternative would have no changes in the estimated

construction impacts as described for the preferred alternative, except

that 100 fewer construction jobs are estimated, resulting in lower

regional community impact; there would be a 9 percent reduction in

sanitary waste generated; and there would be a 6 percent reduction in

occupational injuries. During operations electricity usage is estimated

to be 23 percent higher, and 37 percent more non-radioactive waste

water would be generated.

Feedstock Material Alternative--Lithium-6

This alternative would have no changes in the estimated

construction impacts as described for the preferred alternative. For

operations, the impacts would be similar to the preferred alternative

except for slightly increased doses from airborne radiological

emissions which would slightly increase the latent cancer fatalities.

Also, eight percent more low-level radioactive waste, and 25 percent

more high concentration mixed waste would be generated. A minor

decrease in radiological doses from accidents with low probability of

occurrence would also occur.

Cooling Water System Alternative--Once-Through Using River Water as

Makeup

This alternative would have no changes in the estimated

construction impacts as described for the preferred alternative.

Impacts from operations would also be similar, except blowdown rates of

125,000 gallons per minute (a 2,000 percent increase) would result in

higher temperatures to receiving bodies of water and would adversely

affect aquatic communities. Also an increase of 1.5 feet in the water

levels of the pre-cooler ponds would possibly affect wetland

communities. Impingement of 2,600 fish, and entrainment of 3.4 million

fish eggs and 6.4 million larvae annually would occur. Resuspension

caused by the increased flows would result in slightly increased doses.

Latent cancer fatalities would increase from 0.0016 to 0.0017 annually.

No mechanical-draft cooling tower noise would be heard at the APT site,

but pump noise would be occasionally audible to river traffic. No salt

deposition would occur.

Cooling Water System Alternatives--Mechanical Draft Cooling Towers

Using Groundwater Makeup

This alternative would have no changes in the estimated

construction impacts as described for the preferred alternative.

Impacts from operations would also be similar except the removal of

6,000 gallons per minute on a sustained basis could impact groundwater

flow to streams and compact clay layers. No impingement and entrainment

would occur.

Cooling Water System Design Variation--Discharge to Pond C Avoiding the

Pre-cooler Ponds

This design variation applies to the preferred alternative and the

two cooling water system alternatives above. This variation would have

no changes in the estimated construction impacts as described for the

preferred alternative. The operational impacts would be similar to the

preferred alternative, except that impacts to the pre-cooler ponds are

eliminated, and there would be a minor increase in heated water impacts

to Pond C.

Cooling Water System Alternatives--K-Area Cooling Tower Using River

Water as Makeup

This alternative would have no changes in the estimated

construction impacts as described for the preferred alternative except

the wastewater discharges would go to Pen Branch via Indian Grave

Branch. The water levels in the upper reaches of the stream system

would be raised. Additional cooling water piping to the K-Area would

also be needed. The plume from K-Area cooling tower would likely be

more visible. There would be no mechanical-draft cooling tower noise at

the APT site, but pump and cooling tower noise in the K-Area would

increase.

Site Location Alternative--2 Miles Northwest of Tritium Loading

Facility

This alternative would have no changes in the estimated

construction impacts as described for the preferred alternative except

the water table is deeper and would require less dewatering. Also

traffic fatalities during construction would be twenty percent less.

Changes in operational impacts from the preferred alternative are

higher doses due to closer distance to the SRS boundary. The dose from

all sources would increase latent cancer fatalities from 0.0016 to

0.0017 annually.

Electric Power Supply Alternative--Construct New Plant

The impacts of a new plant would be dependent on the specific

location. A new coal facility would require 290 acres and a natural gas

facility 110 acres. The types of impacts presented for the preferred

alternative would also occur at the specific site for a new plant.

Increased amounts of construction waste would be generated.

Construction would require a peak work force of 1,100. Plant operations

would require an additional 200 jobs.

Design Variations--Modular Design

This variation would have no changes in the estimated construction

impacts as described for the preferred alternative except construction

wastes, health impacts, and peak employment all would be 10 percent

lower. Operational impacts would also be similar with the following

exceptions. Both blowdown water rates and non-radiological air

emissions would be 10 percent lower. Electricity usage would be 2.0

terawatt-hours per year, a 32 percent decrease. Wastes from operations

would be 10 percent lower.

Design Variation--Combining Tritium Separation and Extraction

Facilities

This variation would have no changes in the estimated construction

impacts as described for the preferred alternative. Operational impact

differences would result in an increase in doses from airborne

emissions from 0.0008 latent cancer fatalities to 0.0009.

No Action Alternative

For the APT, no action is to not build the APT, but use the CLWR as

a source of tritium. Since the APT would not be built or operated there

would be no change in the existing environment at SRS.

4. Overall Environmental Conclusion

As described above, and as documented in the environmental analyses

that have been developed, it is expected that the overall environmental

impacts associated with tritium production in an APT would be small.

Consequently, the environmental impacts associated with the APT

alternatives and design variations are not considered major

discriminating factors in the decision. Based on all of the

environmental factors considered, the no action alternative is the

environmentally preferred alternative.

D. APT Decision

DOE selects the APT as the backup tritium supply technology. DOE

will complete preliminary design for the

[[Page 26386]]

APT facility. To focus this design effort DOE has made the following

selections for the different sets of alternatives and design variations

described and analyzed above and in the engineering and environmental

documents.

1. Radiofrequency Power

The preferred alternative of klystron power tubes would be used as

the basis for the preliminary design because the inductive output tube

design is still in development. The DOE would, however, continue with

development of the inductive output tube. If at a future date, the

development of the inductive output tube advances and the APT design is

activated as a source of tritium, the inductive output tube may be

substituted for the klystron power tubes.

The klystron power tube uses additional electricity, but otherwise,

the environmental impacts are similar for the two alternatives. From a

technology and cost perspective, the inductive output tubes have a

lower cost because they are smaller, more efficient and operate at

lower voltage.

2. Operating Temperature

The alternative of using superconducting components is selected as

the preferred alternative for specific higher power sections of the

accelerator. The use of superconducting components would have:

Reduced electricity demands resulting in lower

environmental impacts.

Greater safety margin due to less chance for activation of

the accelerating structures and cooling system that reduces the number

of pipe penetrations into the accelerator.

Only two cavity sizes allowing for simpler design and

maintenance.

3. Feedstock Material

The alternative using helium-3 as a feedstock material is selected

as the preferred alternative for production of tritium. The use of

helium-3 as a feedstock material would have:

The least environmental impact.

Greater flexibility in extracting the tritium on a semi-

continuous basis.

Greater safety margin because the inventory of tritium in

the target blanket and separations facilities is less.

4. Cooling Water System

The alternative of mechanical-draft cooling towers with makeup

water from the Savannah River is selected as the preferred alternative

for the cooling system. The design variation of discharging to the head

of Pond C, but downstream from the pre-cooler ponds, is also selected.

This alternative is selected because it:

Has the least environmental impacts.

Avoids additional costs to upgrade the pre-cooler ponds.

5. Siting

The site 3 miles northeast of the Tritium Loading Facility is

selected as the preferred APT site. This site is selected because it

results in:

Greater buffer distance which would reduce public

radiological exposure in case of an incident.

Less impact to terrestrial and aquatic ecology.

6. Electric Power Supply

The alternative of obtaining electricity from the existing

commercial capacity and through market transactions is selected as the

preferred alternative for electrical power supply. The alternative is

selected because:

It presents the least environmental impact.

It provides the greatest flexibility in reducing costs

through using market mechanisms to obtain bulk wholesale costs.

It provides opportunities to use alternative supplies of

power.

7. Modular Design Variation

The modular design is selected as the preferred design for the APT

because it:

Provides capacity and cost flexibility in meeting changing

tritium requirements.

8. Combine Tritium Separation and Tritium Extraction

This design variation is not selected since the APT was not

selected as the primary tritium source. Since the CLWR was selected as

the primary source, a Tritium Extraction Facility must be built to

support this decision.

VI. Consolidated Tritium Supply and Recycling Decision

The Department of Energy will produce new tritium for national

security purposes on a schedule and at a rate to meet the requirements

of the President's Nuclear Weapons Stockpile Plan. Tritium will be

produced by irradiating DOE-supplied tritium-producing rods in

commercial light water reactors, specifically the Tennessee Valley

Authority's currently operating Watts Bar Unit 1, Sequoyah Unit 1, and/

or Sequoyah Unit 2 reactors. To support this method of tritium

production, a new Tritium Extraction Facility will be designed and

constructed in the H-Area of DOE's Savannah River Site.

The Accelerator Production of Tritium technology will be developed

as the backup tritium supply. Engineering development and

demonstration, preliminary design, and detailed design of key elements

of the system will be completed to permit expeditious initiation of

accelerator facility construction at the preferred location on the

Savannah River Site should it be needed.

The Fast Flux Test Facility will have no role in tritium

production.

Signed this 6th day of May 1999.

Bill Richardson,

Secretary of Energy.

[FR Doc. 99-12019 Filed 5-13-99; 8:45 am]

BILLING CODE 6450-01-P