UPDATED Jan. 17, 2014 | On January 10, 2013 the Snake River Alliance submitted comments to the Idaho Department of Energy regarding the restart a 55 year old reactor at Idaho Nation Laboratory.
January 10, 2014
To: Chuck Ljungberg, Department of Energy
From: Beatrice Brailsford, Snake River Alliance
Re: Draft Environmental Assessment for the Resumption of Transient Testing of Nuclear Fuels and Materials By e-mail: email@example.com
The Snake River Alliance has served as Idaho’s grassroots nuclear watchdog since 1979. We have reviewed the draft environmental assessment for the Resumption of Transient Testing of Nuclear Fuels and Materials (DOE/EA-1954), and I submit the following on behalf of our dues-paying members.
In the current EA, the Department of Energy is proposing to resume transient testing and its preferred alternative is to do so at the Transient Reactor Test Facility (TREAT) at the Idaho National Laboratory. The TREAT reactor first began operations in 1959; it has been shuttered for the past 20 years. The DOE has conducted no transient tests for more than a decade. Neither the program nor the TREAT reactor has ever undergone review under the National Environmental Policy Act. Both the program and TREAT operation would run for 40 years, by which time TREAT would be about a century old. The Alliance will focus most of our comments here on the preferred alternative: TREAT restart.
The current EA should be withdrawn and both the transient test program and TREAT refurbishment, restart, operation, and decommissioning be analyzed in a full environmental impact statement.
This major federal action falls squarely within the “Classes of Actions that Normally Require EISs” according to the DOE’s own NEPA Implementing Procedures (10 CFR 1021 Appendix D to Subpart D): “Siting, construction, operation, and decommissioning of power reactors, nuclear material production reactors, and test and research reactors.”
Furthermore, the transient test program has never been evaluated as a whole, and DOE has not conducted a transient test for more than a decade. The program itself must undergo NEPA evaluation.
The current EA does not adequately analyze the purpose and need for the proposed action.
The statement of purpose and need is a cornerstone of the analysis of a proposed major federal action under the National Environmental Policy Act. Furthermore, clearly delineating the purpose and need for federal actions is key to prudent decisions regarding the deployment of public resources.
Some information about the purpose and need is available in this EA, the Mission Need Statement (2010), and in the Alternatives Analysis (2013). It’s probably understandable that the three discussions differ in emphasis. Most certainly, the full discussion should have been included in the EA.
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It is notable that none of the documents mentioned here include any attempt to substantiate the asserted role of transient testing in reducing the potential for proliferation of nuclear materials.
The DOE shut down the Transient Reactor Test Facility in early 1994 because “there were no customers for the facility at that time.” And today? In April the DOE asked itself – and then did not answer: “Are there specific, identified customers who are willing to pay to use transient testing capability? If so, who?” Here the DOE did at least refer to efforts to develop accident tolerant fuel. But according to a presentation made the same month by the DOE Director for Fuel Cycle Research and Development, that office is already overseeing six accident tolerant fuel projects. Two of those projects involve the INL; none seem to hinge on the availability of either of the current EA’s alternative facilities. Instead, they seem to call for using currently operating research reactors.
In fact, the DOE’s true focus for TREAT may be on far more distant prospects than developing safer fuel for currently operating reactors. For instance, much is made of a cooperative effort with France and Japan to develop sodium-cooled fast reactors. Such reactors have been around for decades but have never been extensively deployed because they are so much more dangerous and hard to operate than other designs. In a real reach, the Mission Need Statement for transient testing posits a research need to develop fuel for the second generation of advanced small modular reactors (SMRs), even though the first generation of SMRs hasn’t even been designed.
The current EA’s discussion of environmental impacts, including cumulative and accident effects, is markedly cursory.
In fact, it’s not even clear what is actually going to happen if the proposed action is approved. For instance, the Alternatives Analysis for the Resumption of Transient Testing Program and the current EA were both published in November 2013. But the facility operations costs presented in the Alternatives Analysis are based on 10 transient tests per year. The discussion in the current EA, on the other hand, anticipates up to 20 static and 14 closed loop tests annually.
The current EA does not adequately cover any potential challenges involved in restarting a 65-year old reactor, nor does it discuss decommissioning, including its cost, in any way.
For all impact analyses, it would be useful to see a discussion of the first 31⁄2 decades of TREAT operation (1959-1994).
The spent fuel produced by the operation of TREAT and the tests conducted there will be added to the considerable spent fuel inventory already stored at the Idaho National Laboratory. A full discussion of that cumulative impact is needed.
The disposal pathway for all waste created by this proposed program should be discussed.
I appreciate the prompt response from DOE-ID to my requests under the Freedom on Information Act for additional documents. The Mission Need Statement for the Resumption of Transient Testing and the Alternatives Analysis for Resumption of Transient Testing both contain information useful in considering the action proposed here. I regret that I did not request some of the other references included in the EA. But from a broader perspective, the Department of Energy, as part of a robust effort to encourage public participation, should make all documents referred to in NEPA analyses easily available.
If you have any questions about the comments here, please feel free to contact me. Thank you.
During transient testing, nuclear fuel or other material such as cladding is subjected to short bursts of very intense, high power radiation. One result can be to see what will happen to the fuel or cladding during an accident. The Transient Test Reactor (TREAT) started operating at the Idaho National Laboratory in 1959. It was part of the safety program for fast breeder reactors such as INL’s Experimental Breeder Reactor II. It shut down in early 1994 because, according to the DOE, “there were no customers for the facility at that time.”
Now the DOE has issued an environmental assessment on resuming transient testing, either in New Mexico or Idaho. Refurbishing and operating TREAT in Idaho is the “preferred alternative,” in part because of “the remoteness of the INL.” Even if the tests themselves are conducted in New Mexico, preparing tests and analyzing results and handling nuclear waste (including spent fuel debris) would happen here.
True, in some analyses, including the “Mission Need Statement,” the DOE makes passing mention of improving the fuel used in today’s reactors. But early efforts to develop more accident tolerant fuel seem to call for using currently operating research reactors. The DOE’s focus for TREAT is on far more distant prospects. For instance, much is made of a cooperative effort with France and Japan to develop sodium-cooled fast reactors. Such reactors have been around for decades but have never been extensively deployed because they are so much more dangerous and hard to operate than other designs. In a real reach, the “Mission Need Statement” for transient testing posits a research need for advanced small modular reactors (SMRs), even though the first generation of SMRs hasn’t even been designed. The DOE also makes passing mention of a role for TREAT in non-proliferation efforts. But DOE does not describe those efforts either.
Tellingly, in April the DOE asked itself – and then did not answer: “Are there specific, identified customers who are willing to pay to use transient testing capability? If so, who?”
Congress would eventually have to decide if it is prudent to spend upwards of $900 million to restart TREAT and operate it for 40 years. In doing so, Congress would do well to realistically consider nuclear power’s future. This spring, former Nuclear Regulatory Commissioner Peter Bradford predicted an “economics-driven US nuclear phase-out” by the late 2050s. That’s about the time the current proposal to bolster nuclear power would end.
The DOE is accepting comments on the current environmental assessment for the resumption of transient testing of nuclear fuels and materials through Friday, January 3, 2014. Comments can be submitted by mail to Chuck Ljungberg, 1955 Fremont Ave., mailstop 1216, Idaho Falls, Idaho, 83415 or by e-mail to firstname.lastname@example.org.