US Department of Energy
Los Alamos National Laboratory
Los Alamos New Mexico
Fax: (505) 665 4872
Dear Mr. Triebel:
RE: Environmental Assessment of the "Parallex Project"
Proposed Action: Fabrication and Transport of MOX
On behalf of the Canadian Coalition for Nuclear Responsibility, a federally-incorporated organization with a charitable tax-free status, I am writing concerning the "Parallex Project", which involves the fabrication of weapons-grade plutonium into reactor fuel ("MOX") at Los Alamos, and transport of said fuel to Chalk River, Ontario, for testing in an experimental reactor. I understand that the "test burn" is a precursor for the possible eventual large-scale importation of plutonium MOX fuel for use in CANDU nuclear reactors over a period of two or three decades.
In particular, I refer to the preliminary Environmental Assessment prepared by the US Department of Energy on the Parallex Project. As one of the credible scenarios described therein involves a traffic accident resulting in the release of plutonium oxide particles to the atmosphere and subsequent inhalation of such particles by members of the public, it is clear that a full-scale environmental assessment process must be initiated so that the details of this analysis can be critically scrutinized and alternative scenarios studied.
It is noteworthy that the preliminary EA does not specifically discuss security measures or armed guards for the transport of plutonium fuel, other than to describe a tamper-proof on-board satellite tracking system for the trucks. However, it is apparent that any attempt to hijack the shipments by force of arms could have environmental consequences, and is just as credible as the other accident scenarios discussed in the EA. Such scenarios must be included in a comprehensive environmental assessment process.
In Canada, seven CANDU reactors are slated for shutdown due to a poor "safety culture", manifested in sub-standard practices, sloppy management and a huge backlog of safety-related maintenance problems at Ontario Hydro. The reactors to be shut down include the Bruce A reactors which were selected by AECL and Ontario Hydro as the best candidates for eventual use of MOX fuel. This calls into question the judgment of AECL officials and the wisdom of consigning MOX fuel to AECL without any independent oversight. Indeed, we believe that the same "safety culture" problems that have been identified at Ontario Hydro may well apply to AECL also.
As stated in the EA, "environmental assessment of activities conducted in Canada would be the responsibility of the Canadian government". However, there has been no environmental assessment process initiated in Canada. In fact, there has been no public process of any kind to involve the Canadian parliament or the Canadian population in approving, disapproving, or otherwise commenting on this project. For US authorities to approve the project under such circumstances would inevitably lead to strong public opposition within Canada. We urge the DOE to request the Canadian government to conduct an environmental assessment in parallel with your own. I have read the Predecisional Draft of the Environmental Assessment for the Parallex Project Fuel Manufacture and Shipment, prepared by the Los Alamos Area Office of the US Department of Energy on August 18, 1997, "to provide sufficient information so that DOE may determine whether a Finding of No Significant Impact is warranted for the Proposed Action or whether an Environmental Impact Statement (EIS) must be prepared."
I believe that the draft document contains so many questionable assumptions that it cannot be used to support a finding of "no significant impact". A sample of these questionable assumptions is given below. Thus a full-scale Environmental Impact Assessment must be conducted, beginning with the preparation of an Environmental Impact Statement.
From the Executive Summary:
"All spent fuel resulting from the tests would be disposed of in Canada under the Canadian spent fuel program."
There is at present no accepted spent fuel disposal program in Canada. The report of a Federal Environmental Assessment Panel on AECL's CONCEPT of geological disposal is still not completed, and there has been no political decision made as to whether or not the concept will be considered acceptable. Thus there is no spent fuel disposal program in Canada at present.
During the hearings on the AECL disposal concept, the overwhelming majority of intervenors expressed their strong objections to Canada accepting nuclear waste from other countries, even if the geologic disposal concept were to be conditionally approved. While the MOX fuel may not be regarded as nuclear waste by DOE or AECL, the fact that Canada would be responsible for guarding the resulting spent fuel in perpetuity would be regarded by many Canadians as setting a very undesirable precedent. Thus, the assumption stated in the draft DOE document reveals a significant misunderstanding of the present situation in Canada regarding spent fuel and its "disposal".
In the EIS to be prepared, the option that the spent MOX fuel will be returned to the USA should be considered, with the transport, environmental and waste management implications discussed accordingly.
From the Executive Summary:
"A successful MOX fuel test could lead to the disposition of surplus weapons-grade plutonium from the U.S. and Russia by irradiation in CANDU reactors in Canada."
Although this idea has been proposed by Ontario Hydro and AECL -- both organizations that see distinct advantages to be gained from any scheme that tends to extend the operating lifetime of nuclear reactors in Canada -- there has been no parliamentary debate on this topic, no public consultation of any kind, and no mandate for the Prime Minister to make any such offer as has here been described in the draft document. The more steps that are taken (such as the Proposed Action) based on the assumption that Canadian approval will be forthcoming, without any actual public process or public consultation taking place in this country, the more indignant Canadians will become with the entire concept. It is not advisable for DOE to proceed on the assumption that Canadians will accept this industry-driven proposal.
In fact, quite recently, Professor Franklyn Griffiths of the University of Toronto (Peace and Disarmament Studies) published a report on the proposal to "burn" weapons-derived MOX in CANDU reactors based on a two-day workshop involving representatives of the Canadian government, the Ontario government, Ontario Hydro, AECL, critics of the nuclear industry, and other interested parties (held back in October 1996). After listening carefully to all sides in the debate, Professor Griffiths concluded that "the proposal should be consigned to oblivion". We believe that that may well be the consensus view among Canadians once the public is given a chance to consider the MOX proposal and to comment on it.
It is disquieting to Canadians to see unwarranted and prejudicial assumptions about Canada's eventual role in this scheme expressed in DOE documents. The EIS to be prepared should avoid making such assumptions.
"The fundamental purpose of the program is to maintain a high standard of security and accounting for these fissile materials while in storage, and to ensure the plutonium produced for nuclear weapons and declared excess to national security needs (now or in the future) is never again used for nuclear weapons."
"Burning" weapons-derived MOX in CANDU reactor can not "ensure" that the plutonium contained therein is "never again used for nuclear weapons". Plutonium-239 has a 24,000 year half-life, and only a fraction of the plutonium-239 in the MOX fuel can be fissioned in CANDU reactors before the remainder is ejected in the spent MOX fuel. Indeed, the net reduction in plutonium content (given the additional plutonium created through neutron activation) is only a little more than one-half.
Thus the spent MOX fuel remains a physical repository for weapons-usable plutonium for tens of thousands of years after the so-called "burning" of the MOX. At any time in the future, any regime can take the plutonium out of the spent MOX fuel and use it to make nuclear weapons. For the first few decades, the intense radiation fields caused by the fission products will make plutonium extraction difficult, but by no means impossible. However, as time goes by, the spent MOX will become less and less intensely radioactive, and more and more approachable without the need for space-age shielding. As the centuries tick by, the plutonium will become more and more accessible and usable in nuclear weapons.
I am sure that the scientists at DOE are aware of these facts. However, it is distressing to see incorrect statements, such as the one quoted above, in a draft environmental assessment document produced by those same scientists. It does not inspire confidence or lend credibility to the rest of the document. It would be helpful if the EIS to be prepared would give a more accurate description of the realistically achievable goals of the Proposed Action.
1.3 Purpose and Need for Agency Action
"DOE must test and demonstrate the feasibility of burning MOX fuel in CANDU reactors as part of its ongoing mission to evaluate the disposition of surplus weapons-grade fissile materials."
It is clearly stated in the draft document that AECL will be responsible for all actions that take place once the MOX crosses the border into Canada. Thus DOE will be relying on the evaluation conducted by AECL as to the specific test results and the overall feasibility of the MOX-burning proposal. Yet the draft document seems to imply otherwise: that DOE will "test and demonstrate the feasibility" of this concept. The situation needs to be clarified; what exactly is the assumption here?
As it is stated in Section 2.1, Description of the Proposed Action,
"The AECL would be responsible for conducting all subsequent tests of the fuel's performance and the function of the reactor during the process. Fueling the NRU reactor with MOX fuel would be part of a feasibility test to determine MOX fuel performance in a converted CANDU reactor setup."
Given AECL's track record of operating in secrecy, engaging in self-serving advocacy, and "bending the rules" to achieve what are considered to be desirable ends, we in Canada have no confidence in AECL's reliability to give unbiased advice on such matters. There will be a strong temptation for AECL to interpret the results of the test in as favourable a light as possible in order to win approval for the project. In the absence of independent oversight and/or public process, such a temptation may be exceedingly difficult for AECL to resist. The new EIS should give a clearer account of how the test results and feasibility questions will be assessed, and by whom.
1.4 Scope of this EA
"When details about a Proposed Action are incomplete a "bounding" analysis is often used to assess potential effects. When this approach is used, reasonable maximum assumptions are made regarding the input parameters needed for the modeling of the Proposed Action scenario. Such an analysis usually provides an overestimation of potential effects."
Many questions come to mind. First of all, in what sense are "details" about the Proposed Action incomplete? Should this not be elucidated?
Secondly, who decides what are "reasonable maximum assumptions", and is there not some inconsistency implied in the coupling of the words "reasonable" and "maximum"? Is there a definition, or criterion, or description, of how the concept of "reasonable" impinges on the concept of "maximum"? This should be spelled out precisely.
Finally, what measurement of probability is in use when one says that this kind of analysis "usually" provides an over-estimation of potential effects? Is this not more of a belief than a statement of fact? Do we have examples where this kind of analysis does not over-estimate the potential effects?
The new EIS should provide the necessary details.
2.1 Description of the Proposed Action
"The environmental review presented herein is limited to the fabrication and transportation of MOX fuel from LANL to the Canadian border. Environmental consequence assessment for activities conducted in Canada would be the responsibility of the Canadian government."
Be that as it may, the Government of Canada has not initiated any environmental review process in Canada. Although this is not the responsibility of the US DOE, would it not be possible for DOE to at least request the Government of Canada to hold a parallel environmental assessment process -- since the "Parallex Project" is, after all, a parallel enterprise?
2.1.1 Manufacture of MOX Fuel and Rods
"The plutonium dioxide is put though a thermal treatment process to remove impurities, such as gallium."
The draft document is strangely quiet about this part of the MOX fabrication process. Are there no conceivable environmental consequences, no special contamination problems, no particular worker exposures, no conceivable accident scenarios, in connection with this thermal treatment process? Just how successful is this process in removing impurities, particularly gallium? Are the anticipated radiation exposures dependent in any way on the degree of "purity" desired in the finished product? The new EIS should have a section devoted to this process.
2.1.2 Shipping Package Description and Rod Packaging
"For relatively low-level radioactive materials, DOT Specification Type A packages are used. These packages are designed to retain their contents under normal transportation conditions. For the Parallex Project, a Type A shipping package on a commercial truck would be used to transport the LANL MOX fuel to Canada."
The description of the shipping package seems to ignore completely the fact that plutonium is a strategic nuclear material. What about armed efforts to steal the MOX fuel or to hijack the shipment in some other way? Such scenarios should be discussed in the new EIS.
"The Type A shipping package proposed for use was designed and manufactured by Canada. It is known as the Model 4H Enriched Fuel Bundle Shipping Package. This package meets DOT Type A specifications."
What evidence does DOE have that this shipping package was tested at full scale, in realistic high speed crash situations? Or are such tests going to be conducted by the DOE? All data related to the testing of the containers should be included in the new EIS.
3.3 Human Health
"The four major sources of manmade radiation are medical radiation procedures, nuclear medicine, consumer products, and other miscellaneous sources (LANL 1995b) (Table 3-2)."
It is disquieting to see no mention of nuclear fallout from bomb testing listed as one of the sources of manmade radiation, particularly in the context of the disposition of excess weapons-grade plutonium.
"Penetrating exposure is used in this EA as the unit of comparison for human effects of routine and accident events for the Proposed Action."
Given the fact that plutonium is an alpha emitter, it is astounding and quite unacceptable that penetrating exposure should be used as the unit of comparison for human health effects in the case of accidents involving the release of plutonium into the environment. The new EIS should not adopt such a policy.
3.3.2 MOX Fuel Transportation
"For shipments that require real-time tracking for security purposes, a TRANSCOM (transportation computerized satellite tracking system) linked truck is used that involves a tamper-proof satellite relay system located within the vehicle."
Again, this understandable preoccupation with security implies the need to include scenarios of armed efforts to hijack the shipments in the EIS.
3.6 Environmental Justice
"Transportation accidents are random occurrences that could potentially affect the population around the accident site. However, the random nature of these accidents precludes any intentional disproportionate effect to minority or low-income populations."
Transportation accidents caused by armed intervention are not random occurrences, and may intentionally be focussed on areas which are disproportionately populated by minority or low-income populations.
4.0 ENVIRONMENTAL CONSEQUENCES
4.1.1 Human Health
"The health risk to an exposed individual is best expressed as the added probability of that individual developing a fatal cancer."
Given the fact that civilians may inhale or ingest plutonium oxide as the result of an accident, one must look beyond fatal cancers to other detrimental health effects. For example, what about the effects on the foetus of a pregnant woman? What about genetic damage? What about non-fatal cancers?
5.0 ACCIDENT ANALYSIS
"Abnormal events or accidents are hypothetical incidents that are not a planned part of routine operations. This EA evaluates three hypothetical accident scenarios (see Appendix C) that have a reasonable probability of occurrence and are provided as the bounding cases."
The range of accident scenarios is too limited. For one thing, it does not include the possibility of armed intervention in an effort to steal strategic nuclear material, and the potential environmental consequences of such an attack. It also does not include the possibility of an accident on a bridge leading to a drop of the truck or its contents far in excess of the drops usually considered in designing transportation packages.
5.2 MOX Fuel Transportation Accidents
"Two credible transportation accident scenarios were analyzed for the shipment of MOX fuel to the Canadian border . . . .
The first accident relates to an event that leads to the MOX fuel package container breaking open, igniting, and releasing plutonium dioxide particles into the air. As an upper bound, this accident scenario assumes the MOX fuel is transported in a one-shipment configuration. The public is assumed to be near enough to the accident to breathe air contaminated with plutonium dioxide."
Evidently, any accident scenarios leading to this kind of result will have to be scrutinized much more closely. How does the burning of the container result in a release of plutonium oxide into the air? What is it that limits the release of plutonium oxide into the air? If the accident involves a crushing of the container and its contents prior to the fire, how does this affect the outcome? All of this should be discussed in detail in the EIS.
"The maximum potential accident consequence (50-year population dose) for the single-shipment configuration is 1.2 x 103  person- rem committed effective dose (CED) for an urban link of a proposed route."
and again, in Appendix C:
"Radiological consequences (50-year cumulative effective doses or CEDs) are calculated by RADTRAN 4."
Given that plutonium-239 has a 24,000 year half-life, why is the maximum potential consequence limited to a 50-year population dose? A more realistic analysis should be provided in the EIS.
APPENDIX C. RISK ASSESSMENT
"3.1 RADTRAN 4
Computer Code for Transportation Risk Assessment Radiological consequences (50-year cumulative effective doses or CEDs) are calculated by RADTRAN 4. The code uses test data or model predictions of the amount of material that might be released in a given severity of accident, expressed as a fraction of the total or release fraction (RADTRAN variable RFRAC). The release fraction is modified by properties of the material being shipped that determine how much of it might be released in aerosol and respirable aerosol form under various accident conditions, since aerosolization represents two [sic] dominant means by which any released radioactive material might be transported away from the immediate accident site."
Since the hypothesized accident is the only scenario foreseen in the draft document which could lead to a dose to the lungs of the population living along the transportation route, a much more detailed description of the way in which the source term is arrived at should be given. The discussion of the source term here (that is, the amount of plutonium oxide available to be inhaled) is far less detailed than in the case of the glovebox accident described in section 2 of appendix C. The new EIS should go into all the necessary detail on this important point. There should also be a thorough discussion of different factors that may affect the source term.
"In reality, in a very severe accident involving a major fire, the thermal effects would be far more likely to loft any released material higher in the atmosphere, which results in considerable downwind dilution and, hence, lower individual doses."
By spreading the source over a much wider area, however, and taking into account the non-uniformity of population distribution, it is quite possible that "lofting" could result in a higher population dose, even if the individual doses are lower -- and hence a greater probability of cancer induction. This is particularly so in view of the very long half-life of plutonium-239. Clearly, this type of accident requires a much more detailed analysis in the new EIS.
"Since exact locations cannot be predicted in the transportation analysis, the potentially exposed population is estimated for each route segment based on the same population density used for incident-free dose calculations, which is assumed to be uniformly distributed."
This approach -- assuming the population is uniformly distributed -- may suffice for some route segments, but would not be acceptable for major population centers. Specific scenarios involving more densely populated areas should be provided in the new EIS. Important non-human species should also be identified and the long-term environmental consequences studied in relation to these species. In addition, costs and risks of decontamination and/or cleanup following such an accident should be addressed.
"The 6M shipping package design is used by the computer model to represent 55-gal. drum-like shipping containers with sealed tops. This design is similar and comparable to the AECL Model 4H shipping package (Figure 5), which is proposed for use in this project.
In the new EIS, there should be a point-by-point comparison of the crash tests and fire tests that have been conducted on full-scale models of the 6M and 4H containers to see what evidence there is that they meet the same standards.
Categories developed from continuous frequency curves representing increasing effect force and fire duration at a fixed reference temperature of 800 degrees C.
In collisions involving some types of flammable fluids, would it not be possible to achieve combustion temperatures higher than 800 degrees? How would these higher temperatures affect the source term and the consequences? These matters should be discussed in the new EIS.
E N D
Thank you for giving me the opportunity to comment on this draft document. I hope these remarks are of use to you.
Yours very truly,
Gordon Edwards, Ph.D., President,
Canadian Coalition for Nuclear Responsibility,
c.p. 236, Station "Snowdon",
H3X 3T4, Canada.
Phone & Fax: (514) 489 5118
internet web site: www.ccnr.org
Gordon Edwards was born in Canada, and currently lives in Montreal. He graduated from the University of Toronto in 1961 with a gold medal in Mathematics and Physics and a Woodrow Wilson Fellowship. While studying Mathematics, Physics and Chemistry at U of T, he worked for the Ontario Fire Marshal's Office as the Lightning Rod Inspector for the Province of Ontario. At the University of Chicago, he earned Masters degrees in Mathematics (1962) and English Literature (1964). After four years of lecturing at the University of Western Ontario, he obtained a Ph.D. in Mathematics from Queen's University (Kingston, 1972).
Dr. Edwards' professional activities have been diverse. From 1970 to 1974, he was the editor of Survival magazine, an international ecology newsletter with subscribers in a dozen countries, most of them scientists. In 1972 he co-authored a book on Lie Algebras. In 1972-73 he worked on the Economics of Ocean Fisheries, and published in the (Canadian) Journal of the Fisheries Research Board. In 1973-74 he coordinated a nation-wide study of the role of the Mathematical Sciences in business, industry, government, education and science, for the Science Council of Canada; the study resulted in seven published volumes. In 1979 he made five half-hour television shows on the evolution of mathematical thought. Since 1974 he has been a professor of Mathematics at Vanier College in Montreal, where he has served as coordinator of the Integrated Science Program and a member of the Board of Directors' Executive Committee.
In 1975 he co-founded the Canadian Coalition for Nuclear Responsibility, and has been its president since 1978. The CCNR is a federally incorporated charitable organization with an educational mandate. In 1977, Dr. Edwards was engaged to give expert testimony and to cross-examine expert witnesses during the Cluff Lake Board of Inquiry into Uranium Mining in Saskatchewan. In 1977-78, Dr. Edwards performed a similar role over a period of several months for the Ontario Royal Commission on Electric Power Planning. Dr. Edwards has worked as a consultant on nuclear issues (such as reactor safety, health effects of radiation, uranium mining and radioactive waste management) for the Select Committee on Ontario Hydro Affairs, the Auditor General of Canada, the Science Council of Canada, and many other governmental bodies (in eight provinces and territories) as well as for such entities as the United Steelworkers of America, Global Television, the Canadian Broadcasting Corporation, and the National Film Board.
Dr. Edwards has written numerous articles and book-length publications on radiation standards, radioactive wastes, uranium mining, nuclear proliferation, the economics of nuclear power, non-nuclear energy strategies, and the history of Canada's nuclear industry. He created and continues to maintain the CCNR website at www.ccnr.org. He is married, with three sons and three grandchildren.
[ The Dangers of Encouraging Plutonium Use ]
[ Bomb Makers Speak Out Against Plutonium ]
[ Plutonium Sub-Directory ]
[ Short Directory ] [ COMPLETE DIRECTORY ]
Since March 27th 1996, there have been over
100,000 outside visitors to the CCNR web site, plus
(counter reset July 2nd 1998 at midnight)