arch/ive/ief (2000 - 2005)

Plutonium Management Background Paper 1
Number 1
Summary of Issues and Chronology of the Plutonium/MOX fuel
Lead Test Assembly Program in the
Department of Energy's Surplus Plutonium Management Program
I. Summary
According to information recently obtained through a Freedom of Information Act
request by the Blue Ridge Environmental Defense League, the Department of Energy (DOE) is
pursuing fabrication of four plutonium/MOX fuel "Lead Test Assemblies" that utilizes European
plutonium fuel processing facilities and involves the transatlantic shipment of 115 kilograms
(253 pounds) of purified, highly dispersible plutonium oxide powder.
This information has been previously reported only as an alternative by the Nuclear
Industry trade press. The information obtained by BREDL indicates that the "EuroFab"
approach was the only alternative considered after June 2000, and no evidence was found
indicating serious consideration of another option.
The Lead Test Assembly program is an essential component of the overall "Fuel
Qualification Plan" to obtain Nuclear Regulatory Commission (NRC) certification and approval
of large-scale irradiation of plutonium/MOX fuel, and therefore a cornerstone of DOE's overall
plutonium "disposition" efforts. (See LTA Fact Sheet). The program is filled with uncertainties
and inherently flawed by political, technical, and regulatory complexities as well as excess
transportation requirements.
The most recent information indicates the fuel qualification program involves:
the probable use of British military plutonium instead of U.S. surplus plutonium, although ·
the source of the plutonium for the lead assembly program is uncertain and unidentified.
A March 2001 foreign trip report by a DCS manager who identified the probable source
as the British Ministry of Defense, stating that in the U.S. there was "lack of adequate
material from the 34 metric tonnes declared excess."2 A second motive identified by
1 Prepared by Don Moniak, Environmental Information Specialist and Consultant, PO Box 3487,
Aiken SC 29802. June 11, 2002.
2 . Lawrence Losh. Framatome ANP. Foreign Travel Trip Report. Report Date March 4, 2001, for
Travel to Bristol Abbey Wood, United Kingdom on 2/27/01 to 3/3/01. Obtained by BREDL through
FOIA.
DCS was avoiding the "difficulties in commercial shipment of the material as indicated in
the Canadian experience," referring to DOE'S transportation fiasco with plutonium fuel
rods from Los Alamos to Canada across the Great Lakes region in the middle of winter
in December 1999.
plutonium oxide/powder purification at Los Alamos National laboratory; where attempts ·
to fabricate plutonium/MOX test fuel suffered repeated failures and equipment
problems.3
one or more transatlantic shipments of purified, deadly plutonium oxide powder from Los ·
Alamos to Belgium for manufacturing plutonium/MOX fuel lead test assemblies (LTAs)
involving a total of 115 kilograms of weapons-grade plutonium--enough to build more
than 50 nuclear weapons;
transatlantic shipment of four plutonium/MOX fuel assemblies from Belgium to McGuire ·
Nuclear Power Plant near Charlotte, North Carolina for irradiation;
shipment of plutonium fuel "scrap" produced during fabrication back to the U.S. to an ·
undetermined or undisclosed location;
shipment of irradiated MOX fuel assemblies to Oak Ridge National Laboratory for post ·
irradiation exams.
The Lead Test Assembly program is pivotal to the overall success of DOE's Pu/MOX fuel
program (see LTA Fact Sheet), yet it has already been delayed one year and is likely to face
further delays if DOE indecisiveness and inaction continue. According to Pu/MOX fuel
contractor Duke Cogema Stone and Webster (DCS), the schedule for "delivery of the Lead
Assemblies in early Calender Year 2004" were "in jeopardy" due to inaction and indecision
surrounding fuel fabrication.4 Specifically, these actions involve a supplemental analysis under
NEPA to justify another Amended Record of Decision to its January 2002 SPDEIS, and
government to government negotiations and agreements to authorize the project.5
The latest available project report from DCS is from February 2002 and was submitted
to DOE on April 9, 2002. It states that a final proposal is due this month, meaning that LTA
3 . For more information, see January 23, 2001 letter to the Canadian Nuclear Safety Commission
(CNSC) at http://www.bredl.org/sapc/CNSC_letter012301.htm.
4 . Duke Cogema Stone and Webster. January 2002 and February 2002 (DCS-DOE-000779) MOX
Fuel Project Reports, Management Area 2, Fuel Qualification. Sections 2.0, 2.1, 2.8, 2.9.
Obtained by BREDL through FOIA.
5 . Ibid.
fabrication is unlikely to be completed prior to 2005. "Upcoming critical activities" were cited
as:
III. Upcoming Critical Activities
A. Develop baseline plan for Eurofab option
B. Complete development of a plan for DCS to acquire DUO 2 for the MFFF
C. Develop subcontracts for lead assembly fabrication plants
D. Meet with LANL and DOE to review plutonium oxide powder specification and packaging requirements
E. Framatome ANP will host FBEC for a visit to the Lynchburg manufacturing facility
Figure 1: List of Critical Activities from DCS's February 2002 MOX Monthly Project Report
This complicated, expensive, and risky approach to "qualifying"-- i.e., gaining approval
from the Nuclear Regulatory Commission-- the use of nuclear fuel from weapons plutonium
involves eventual use of plutonium fuel in Duke Power's Catawba and McGuire nuclear power
plants in the Charlotte, NC metropolitan area. The approach was recommended by DOE
contractor Duke Cogema Stone and Webster not long after DOE's January 2000 Record of
Decision to fabricate lead test assemblies at Los Alamos National Laboratory.
The documents obtained by BREDL-- fourteen months after the original FOIA request--
indicate that DOE's frequent changes to its plutonium management program involves continued
violations of the National Environmental Policy Act's (NEPA) provisions for timely public
notification and participation in supplemental analyses. Instead of adhering to NEPA statutes
and its own policy to follow "the spirit of NEPA," DOE is pursuing a plan driven more by a
more by a desire to avoid public scrutiny than economic or technical considerations.
DOE failed to analyze this new plan in its environmental impact statements and in fact
rejected the use of European facilities for plutonium fuel fabrication in its January 1997 Record
of Decision to pursue the "dual-track" plutonium disposition strategy.
Other important information contained in the documents obtained by BREDL, and
discussed in Part 2 of the Chronology include:
There is uncertainty as to whether meeting the "spent fuel standard," the basis for ·
DOE's entire plutonium management scheme, is sufficient to end international
monitoring requirements for plutonium.
Although Los Alamos was authorized to begin liquid acid processing (called ‘polishing' by ·
the plutonium industry) to prepare five (5) kilograms of plutonium for Lead Test
Assembly operations in Europe, the lab had only completed two kilograms by the end of
February 2002.
Duke power is already pursuing exemptions and a license amendment request with the ·
NRC, and a final Lead Assembly Project Plan was scheduled for completion by the end of
March 2002;
Duke Cogema Stone and Webster withheld important information in documents it ·
submitted to the NRC in support of its efforts to license Pu/MOX fuel use in Duke
Reactors;
Evidence that DOE knowingly issued a false Record of Decision in January 2000 by ·
stating that Los Alamos was its choice for LTA fabrication. Two weeks after this
"decision" DCS officials signed the first revision of its complex Fuel Qualification Plan
that stated Los Alamos was questionable and then waited seven months to submit the
revised plan to the NRC.
Overall, the developments cited here provide more evidence that DOE's Plutonium
Disposition Program is being managed for failure (for more information see
http://www.bredl.org/sapc), that the Department cannot keep its word or live with its decisions,
and the Pu/MOX fuel program is characterized by deception. The decision to cancel the
Plutonium Immobilization Program left DOE with a single means--Pu fuel--for long-term surplus
plutonium management, an option with complications, cost increases, and technical difficulties
that demand the program be cancelled once and for all.
II. PLUTONIUM FUEL APPROVAL/QUALIFICATION,
A TWO-PART CHRONOLOGY
PART 1: 1995 to January 2000
Promises and Lofty Rhetoric
1995: The National Academy of Sciences publishes its report titled Management and
Disposition of Excess Weapons Plutonium. The report was sponsored by the U.S. Department
of Energy (DOE), legitimized an approach to plutonium "disposition"6 called the "spent fuel
standard," described as:
6 The term plutonium "disposition" is a misnomer, since there is no feasible existing technology that can
destroy plutonium in the next 100+ years, and the intent of the "disposition" program for surplus
weapons plutonium is to make the plutonium less attractive for reuse and theft, and to reduce costs and
complications associated with accounting, security, and other safeguards necessary for storage of highly
concentrated separated plutonium.
"An appropriate standard for the final product of disposition options is that they transform the
weapons pu into a physical form that is at least as inaccessible for weapons use as the much
larger and growing stock of Pu that exists in spent [irradiated] fuel from commercial Nuclear
Power Plants."
In regard to fabrication of Pu/MOX fuel in Europe, the Academy described the option of
substituting weapons-grade plutonium for the reactor-grade plutonium in commercial use in
Europe and planned for Japan. While not recommending that approach, the Academy stated that
the "option should be kept open."
February 1996: Secretary of Energy Hazel O'Leary announces the declassification of the U.S.
inventory of plutonium, including the locations of 38.5 metric tonnes of weapons-grade
plutonium deemed "excess to national security needs."
December 1996: After more than two years of preparation, DOE publishes the Storage and
Disposition of Weapons-Usable Fissile Materials Final Programmatic Environmental Impact
Statement (Storage and Disposition PEIS), in which it analyzed the options for managing
surplus weapons-grade plutonium as well as 14.3 metric tonnes of surplus fuel-grade,
weapons-usable plutonium and 7.0 MT of weapon-grade plutonium likely to be declared surplus
as a result of future arms reduction treaties.
January 14, 1997. DOE issues its Record of Decision (ROD) for the Storage and January 14, 1997. DOE issues its Record of Decision (ROD) for the Storage and
Disposition PEIS, Disposition PEIS, in which it stated it would approach plutonium disposition "that would make
surplus weapons-usable plutonium inaccessible and unattractive for weapons use." DOE approach
was termed the "dual-track," since it allowed "for both the immobilization of some (and potentially
all) of the surplus plutonium, and use of some of the surplus plutonium as MOX fuel in existing
domestic, commercial reactors. The disposition of surplus plutonium would also involve disposal
of both the immobilized plutonium and the MOX fuel (as spent nuclear fuel) in a potential geologic
repository."7
European fuel fabrication was analyzed, though not in depth, as an option, with DOE deciding
that "the preferred alternative and the decisions in this ROD do not involve European MOX fuel
fabrication. . "
May 1997. DOE issues a Notice of Intent to conduct a Surplus Plutonium Disposition
Environmental Impact Statement (SPDEIS) to build upon the January 1997 dual-track
decision and determine whether or not to employ the plutonium/MOX fuel option and where to
7 . U.S. DOE. Office of Fissile Materials Disposition. Record of Decision for the Storage and
Disposition of Weapons-Usable Fissile Materials Final Programmatic Environmental Impact
Statement.