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Open Letter to Secretary of Energy Steven Chu
Pro-nuke euphoria followed President Obama’s generally welcomed pronouncement supporting nuclear power and your Facebook posting, http://www.facebook.com/note.php?note_id=336162546856&comments#!/notes.php?id=79707582290
There is talk of a renaissance and environmentalists’ recognition that nuclear power can provide large amounts of carbon-free power that is always available.
But what is the status of your infrastructure from decades of decline?
Medical imaging is entering a crisis. Moly99, a reactor produced medical isotope is just becoming unavailable. 40,000 procedures a day are coming to a grinding stop. The U.S has no domestic supply for 40,000 procedures a day, and two international reactors have failed, simultaneously.
The Department has known of this deficiency since the 2001 Programmatic Environmental Impact Statement evaluation of the reactor infrastructure needed for medical isotopes.
Our deep space probes will remain at home because the Department cannot produce the Pu-238 required for space power because there is no domestic research reactor.
New civilian reactor concepts like the Traveling Wave, Pebble Bed, Molten Salt, etc,, require fuel and material testing for design and certification but there is no domestic reactor for such tests.
Many have asked the Department, “Isn’t it time to bring back the Fast Flux Test Facility (FFTF)?”
The FFTF sits in cold standby, with deactivated systems, but maintained with protective argon gas.
You recently wrote,
“The closed fuel cycle cannot be implemented without a fast neutron spectrum…research is needed now to provide options for future policymakers…other nations are pursuing the technology…If the United States does not have a broad fast reactor research program we will have no opportunity to influence design of these foreign reactors from a vital national security perspective such as proliferation resistance.”
The FFTF now remains preserved giving “options for future policymakers.” This fully licensed test reactor has a certified 20 year full-power core life. Deactivated, yes; preserved, yes; and, recoverable, yes.
Will your upcoming Decision destroy the FFTF?
PUBLIC COMMENT
Draft TC&WM EIS which includes FFTF Decommission decision
January 26, 2010
Benton County sued DOE in November 2002 to stop liquid sodium drain and to stop the rush to destroy the Fast Flux Test Facility (FFTF). Benton County argued that Decommissioning was not allowed, and DOE argued that only Deactivation was ongoing.
Benton County lost the case, but in Judge Shea’s Feb. 28, 2003, ORDER we won the knowledge that any action at FFTF must be accomplished under the rules of the National Environmental Policy Act (NEPA). NEPA allows for Public Comment, the analysis of Alternatives, and the consideration of NEW Information.
The previous NEPA document is the Programmatic EIS that was completed in January 2001.
Very significant events and new information should be evaluated by DOE. Most significantly:
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The medical isotope supply is in crisis due to aging international reactor infrastructure.
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Domestic production of the isotope Pu-238 did not start and production planning has failed.
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Record of Decision confirmed the need to reestablish a production capability.
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DOE-IG “Continuing delays in reestablishing a domestic Pu-238 production capability could adversely impact the Department’s ability to meet its core national security mission, as well as those of the DoD, NASA, and other Government users.”
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US purchase of Russian Pu-238 will end, and cannot be used for national security.
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Civilian reactor R&D is constrained due to lack of testing and certification facilities and programs.
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R&D projects and Intelectual Property are moving off-shore; to China, South Korea, India, Russia, Ukraine, France, Canada, et.al.
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RL’s VIT plant needs ~70 MWe which could easily be supplied by the FFTF with a Power Block.
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And most significantly, on December 22, 2009, DOE Secretary Steven Chu wrote:
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“The closed fuel cycle cannot be implemented without a fast neutron spectrum…”
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“…research is needed now to provide options for future policymakers.”
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“The Administration had pledged that a Blue-Ribbon panel will consider all alternatives to Yucca Mt…”
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“…other nations are pursuing the technology…”
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“If the United States does not have a broad fast reactor research program we will have no opportunity to influence design of these foreign reactors from a vital national security perspective such as proliferation resistance.”
The FFTF in now in cold standby with the sodium system piping under argon cover gas, also known as Stage II Surveillance and Maintenance. Is that correct?
The April 2007 study accomplished by Columbia Basin Consulting Group for DOE’s GNEP concluded:
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FFTF was a fully licensed nuclear reactor with a 20 year full power life.
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Even though the liquid sodium coolant has been drained, FFTF could be restarted.
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Then, the GNEP EIS was canceled.
In conclusion, with the minor yearly cost of Surveillance and Maintenance, I believe it is incumbent upon EM to preserve the reactor, as the NO ACTION alternative describes.
So as in Secretary Chu’s own words, “…to provide options for future policymakers.”
Respectfully submitted:
Carlgh
NEPA Planning – a Fast Flux Test Facility commentary
By: Carl Holder Monday, January 03, 2005
The motive for Benton County v US Department of Energy (DOE) in November 2002 was to find something, anything that would stop sodium drain at the Fast Flux Test Facility (FFTF). Benton County lost the case, but won the knowledge that any action at FFTF must be accomplished under the rules of the National Environmental Policy Act (NEPA). For this reason DOE is now preparing an Environmental Impact Statement (EIS) on the FFTF Closure Project. OK, so what?
DOE and Fluor Hanford had contracted the Closure activity under the rules of Comprehensive Environmental Remediation Liability Act (CERCLA), which is the “Superfund” legislation. OK, so what?
Superfund/CERCLA is for cleanup of an existing hazardous waste pile. NEPA is getting good information to make good decisions to continue to do a good job right.
Under no circumstance can the FFTF be considered a hazardous waste pile; not yet. There is no radioactive contamination in the 400 area today; but with the preferred alternative of entombment, there will be a new radioactive and chemically volatile waste dump, “repository” where the FFTF exists today.
But how did the process go off track? This is where the story gets real interesting. On December 14, 2001, Secretary Abraham approved following NEPA, deactivation of the FFTF (a last day Clinton Administration decision). Deactivation has been suspended many times since 1995. In fact, the 1995 Finding of No Significant Impact (FONSI) is the current authority at the plant.
On July 15, 2002, DOE Chief of Staff McSlarrow wrote that the Secretary directed decommissioning of the FFTF, but gave no legal direction (NEPA or CERCLA). It was DOE-Richland that began to use CERCLA in correspondence beginning on August 15, 2002. The wrong switch was thrown, and train was going down the wrong track (according to Judge Shea). This is important because under CERCLA, public input happens much later and is more restrictive, and the alternatives are narrowed considerably. In that CERCLA based FFTF Closure Project contract it said, “the facility will be entombed.”
Now DOE believes that it is back on track by giving us the Decommission Environmental Impact Statement. But they are not. OK, but why not?
The DOE has just notified of the Intent to prepare an Environmental Impact Statement for a segment of the Programmatic Environmental Impact Statement (PEIS) that is/was flawed. But this is just symptomatic. The entire 2000 Nuclear Infrastructure-PEIS is suspect because national policy has changed, and new programmatic operations require a rapidly expanding need for neutrons, particularly fast neutrons.
Under Clinton, a new source of neutrons was not planned and the old sources, without the FFTF, were deemed to be adequate. Just now, Secretary Abraham has gone to France to buy access to fast neutrons at the Phenix, saying “this capability does not exist in the USA.” What?
The requirements for research neutrons are expanding greatly. The President’s National Energy Policy, programmatic change within DOE, and the Hydrogen Initiative create new emphasis and demand for neutrons. Fast neutrons are in high demand for work in fuel and transformation of nuclear waste. Dr. William Martin, Chairman the Nuclear Energy Research Advisory Committee (NERAC), 04/28/04, “recommends a study on the need for steady and fast neutron facilities in the U.S.”
With such dramatic new requirements for neutrons, particularly fast neutrons, and the possible reasonable alternative of the FFTF, under NEPA rules, in the Consolidation Environmental Impact Statement require that the facility cannot be destroyed prior to the Record of Decision. Under NEPA rules, all reasonable alternatives must be preserved, and the FFTF remains recoverable.
The decision to destroy the Fast Flux Test Facility must now be a new Secretarial decision, not based upon an interpretation of the 1995 FONSI, especially now that the Secretary has traveled to France to buy fast neutron capability. DOE Secretary Spencer Abraham has resigned!
“Nuclear energy technology has the potential to improve the quality of life for people around the world if we are successful in solving issues such as economics, waste and proliferation,” said DOE Secretary Abraham in Paris, France, August 24, 2004.
On October 23, 2003, Nobel Laureate Burton Richter, Chairman of a NERAC subcommittee reported, “The final demise of the FFTF is to be regretted. We do point out the limitations of foreign facilities.”
Proper Supplemental NEPA evaluation should prove to the nation that the FFTF is required if we are to be successful, in the U.S., in solving issues such as economics, waste and proliferation. The nation deserves this legally required and intelligent look into the future. The NEPA process requires that the public is involved.
To continue on the current track, specified under CERCLA, could prove very embarrassing to our nation, and illegal and costly for the perpetrators.
“Trouble ahead, Trouble behind, Casey Jones you’d better watch your speed.” Grateful Dead.
Carl Holder ©
Monday, January 03, 2005
http://en.wikipedia.org/wiki/Fast_Flux_Test_Facility
The FFTF Decommission EIS took public scoping comments until October 8, 2004. Then this EIS was was rolled into the Tank Closure and Waste Management TC&WM EIS being performed by SAIC for DOE Richland Office. The Draft TC&WM EIS was published on November 4, 2009. DOE proposes to determine the final end state for the FFTF…
Public Comments are open through March 19, 2010. TC&WMEIS@saic.com or fax 888-785-2865 & contact your Senators and Representatives… and you are welcome to comment here, just click below where it says comment.
In the Draft EIS DOE select will select from three options for the FFTF:
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No Action: FFTF is currently in Surveillance and Maintenance, or cold standby, the major feature being that sodium systems are maintained under inert covergas. The decision is 100 years of administrative controls total cost of $495 million.
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Entombment: Would remove and dispose of a minimum amount of radioactive materials and entomb the rest. ~$260 million cost.
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Removal: Would remove nearly all radioactive materials, including the reactor vessel, internal piping and equipment and attached depleted-uranium shield, and dispose of these materials onsite in an Integrated Disposal Facility. ~$270 million cost.
Other alternatives not evaluated:
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Restart: DOE decided to shut down and deactivate FFTF (DOE 1995a,, 2000a).
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Greenfield: A study in 2000 estimated decommission to Greenfield would cost $2 Billion. The Removal Option 3 is DOE response to Greenfield requests.
Further note:
In a 2007 study funded by for Global Nuclear Energy Partnership (GNEP), … the fully licensed FFTF could be restarted.
FFTF was considered in the Consolidation EIS, and GNEP EIS has been cancelled.
http://www.gc.energy.gov/NEPA/documents/December2009KeyEISChart.pdf
In a 2007 study funded by for Global Nuclear Energy Partnership (GNEP), … the fully licensed FFTF could be restarted.
Thank you for your consideration.
Carlgh
Support: NO ACTION alternative for FFTF Decommission.
DOE offers three alternatives for the FFTF in the current Environment Impact Statement (EIS):
No Action – maintain the current Surveillance & Maintenance (S&M) for 100 years. $2m/yr includes main feature: Maintain inert cover gas on piping.
Entombment (the preferred alternative)
Removal
They do not offer other alternatives:
Restart, or Greenfield – as each are expensive, $ and political.
Both alternatives: Entombment (the cheapest for destruction, $300m) and Removal; both create a CERCLA radioactive waste site – where none exists today.
Greenfield would remove all of the reactor and was expected to cost $2 billion in 2002. HOAN solicits money based upon this alternative.
A Restart study performed for DOE by CBCG in 2007 estimated restart to cost $500 million over 5 years for the fully licensed plant to support Global Nuclear Energy Partnership (GNEP).
In Benton County v DOE, February 2003, Judge Edward Shea ORDERED that DOE shall do a NEPA EIS prior to decommissioning the FFTF, then and now under deactivation, on and off since the 1995 EA & FONSI. Now in S&M, Phase II (cold standby).
The current National Environmental Policy Act (NEPA) evaluation of alternatives has produced a Draft EIS (delayed by the Yucca Mt confounding failure). The current law of the land is Judge Shea’s 2003 Order and the 2000 NEPA Nuclear Infrastructure EIS that was decided by Secretary Richardson on his last day in office, January 2001. What a piece of work that ROD is.
All of these docs are available upon request. Also see file NEPA FFTF & Public Policy. My opinion:
Due to the current political climate (local, state and national), rally to achieve the “NO ACTION” decision that preserves this test SFR for another day.
http://en.wikipedia.org/wiki/Fast_Flux_Test_Facility
I have accepted an invitation to join a forum started at NUCLEARSTREET.com called New Social Media and Nuclear Energy by Dan Yurman a blogger at djysrv.blogspot.com, member of ANS, etc.
My oar in the water concerns that there is a lack of proper National Environmental Policy Act of 1969 (NEPA) analysis of Energy Policy, Energy Policy Planning, and Infrastructure availability.
In a number of critical areas of national policy, good analysis of alternatives is not being accomplished and decision making is being done for pure political motive irrespective of good science, inefficient use of scarce resources, and wanton disregard for basic economics and risk analysis.
The first posting in the new forum is by Ted Rockwell’s “Get the Nuclear Energy Facts.” Check it out… Under proper NEPA analysis, most would concur that abundant and sustainable nuclear power should be the highest national priority. Sorry… wind, solar and biomass should not be diverting all the money and attention.
Energy density rules…
National Environmetal Policy Act
http://ceq.hss.doe.gov/nepa/regs/nepa/nepaeqia.htm
http://en.wikipedia.org/wiki/National_Environmental_Policy_Act
The U.S. and Japan will begin to cooperate on “advanced fuel cycle technologies” for nuclear plants, or reprocessing nuclear waste, according to the Environmental Capital blog.
http://blogs.wsj.com/environmentalcapital/2009/11/13/reuse-recycle-us-and-japan-to-work-on-nuclear-reprocessing/
Reprocessing helps get rid of nuclear waste, which is why both France and Japan have been big advocates. The U.S. killed a reprocessing plan in the ’70s. Then, the Bush Administration began the Global Nuclear Energy Partnership which included reprocessing and sodium-cooled fast burner reactors. GNEP remains alive internationally; but, domestically advanced nuclear R&D is on life-support funding levels only.
In 2007, Columbia Basin Consulting Group studied the Hanford 400 Area for Advanced Nuclear R&D. Valuable facilities exist including the 400 megawatt Fast Flux Test Facility – now in mothballs – awaiting decision making at the DOE.
If the U.S. is serious about international collaboration, we would open up and make available the world’s most advanced fast reactor testing facilities for combined international use. Without these facilities, collaboration from our side has proven fickle.
A typical 1GW coal plant releases the following pollutants INTO THE AIR every DAY:
- 10,136.986 metric TONS of CO2 (per day, per plant)
- 27.397 metric TONS of SO2 (per day, per plant)
- 1.370 metric TONS of “small particulate matter” (per day, per plant)
- 27.945 metric TONS of NOx (per day, per plant)
- 1.973 metric TONS of CO (per day, per plant)
- 0.548 metric TONS of ‘volatile organic compounds’ (per day, per plant)
- 0.466 pounds of Mercury (per day, per plant) (That’s enough to kill two hundred 200lb men in 15 seconds, if ingested.)
- 0.616 pounds of Arsenic (per day, per plant) (That’s enough for roughly 1320 toxic doses for a 200lb human! Are we having fun yet?)
- 0.312 pounds of Lead (per day, per plant)
- 0.014 pounds of Uranium (per day, per plant)
- 0.028 pounds of Thorium (per day, per plant)
There are roughly 600 coal power plants operating in the United States today.
A GW nuclear power plant releases…….
The NW Council is preparing its 6th Plan that projects 85% of future, 2030 energy generation to be supplied by conservation, the rest in wind. In order to achieve such draconian cuts, local networks will plan implementation of smart grid to whip its wasteful consumers into shape. To work efficiently, smart grid requires allowing the individual consumer some control over the quantity, price and time of electricity consumption. Lower price could be available with excess non-spinning reserve supply. Factories could lower electrical costs by working only when the wind blows. New aluminum refineries shall not consider the NW in their strategic plans, as old ones close the doors. Boeing prospered because of the abundance of aluminum. I wonder if Boeing’s strategic plan looked at the 6th Plan and wondered how they were to build more aircraft while reducing electricity consumption 85% by via conservation?
It is time that there is an open conversation about the future cost and availability of abundant electricity. I don’t like the prospect of being cold in my own home. Isn’t Columbia Generating Station (nuclear) providing our lowest cost electricity today? Why not consider nuclear power?
Best regards,
Carlgh
Senator Alexander and Senator McCain are leading a large choir and gaining voices daily. “A sea change” notes Senator Barbara Boxer (D-CA). Senator Kerry (D-MA) supports nuclear power in new energy legislation. Carol Browner, an Obama administration official said, “…nuclear energy… It’s something that we believe should be in a comprehensive energy package.”
Simultaneously, Russia and China signed high level agreements including nuclear power. China has purchased two BN-800 fast reactors from Russia. This is the first time that fast reactors have been traded in international commerce for the production of electricity. The fast reactor is the energy production machine of the advanced fuel cycle.
Thanks Marjorie for the post:
Nuclear Power an Important Part of Russia/China Economic Agreements
by Marjorie Mazel Hecht Managing Editor, 21st Century Science & Technology
October 21, 2009 —Russia and China will undertake an advanced nuclear project as part of the package of bilateral agreements signed last week.
In addition to conventional nuclear reactor projects, Russian Prime Minister Putin and Chinese Premier Wen Jiabao signed an agreement to proceed with the design work for two 850-megawatt sodium-cooled fast breeder reactors to be built in China. This advanced nuclear reactor will help China achieve self-sufficiency in its nuclear fuel cycle by “breeding” new nuclear fuel as it produces power. Russia and China already cooperate in the operation of a small, 65-megawatt fast reactor, the Chinese Experimental Fast Reactor at the China Institute of Atomic Energy near Beijing.
In the Atoms for Peace days of the late 1950s and early 1960s, fast breeders were viewed as an essential part of the atom’s incredible potential for uplifting the world economy and living standards, because the fast reactor can produce more nuclear fuel than it consumes, thus eliminating future fuel scarcity and giving real meaning to the concept of renewable energy. In order to reduce world population, the Malthusian oligarchy moved to prevent breeder reactor development by equating fast reactors with plutonium bombs, in the name of “nonproliferation.”
The fast reactor works by using fast neutrons from the fission reaction, to convert a “blanket” of fertile (but non-fissile) material around the reactor core—uranium-238 or thorium-232—into plutonium for new fission fuel.
In a conventional reactor, fast neutrons from the fission process are slowed down by a moderator, usually water, in order to maintain the most efficient fissioning of enriched uranium to produce heat. In the fast reactor, the fast neutrons are not moderated. Each fission produces 25 percent more neutrons than in the uranium fuel cycle; the excess neutrons convert the non-fissionable blanket fuel into fissionable plutonium.
Aside from producing power and fuel, the fast reactor can also use the fast neutrons to burn up the high-level radioisotopes in spent nuclear fuel. It can also be coupled with the fusion process in a fusion/fission hybrid, which was envisioned as a stepping-stone to a full fusion reactor.
- U.S. Left Behind –
Japan chose the fast reactor as its reactor of the 21st Century, with the intention of becoming self-sufficient in power production by producing its own nuclear fuel. India plans to use a fast reactor with a thorium fuel cycle, because it has plentiful supplies of thorium. The Russians used a fast reactor for desalination; Russia’s BN-350 reactor operated for 27 years in Kazakstan. Another fast breeder, the BN-600 has been supplying power to the electricity grid since 1980, and Russia has a larger fast reactor and other fuel cycle designs in the works.
The United States has been left behind. Although the U.S. pioneered the breeder design, operating an experimental breeder, EBR 1, in Idaho in 1951, which produced enough power to run its own facility, the fast reactor program has been repeatedly shut down, including the Clinch River Breeder Reactor in the 1980s, and the Integral Fast Reactor in the 1990s. The Fast Flux Test Facility (FFTF) in Washington state came under continuous attack, and then received a death sentence under George W. Bush in 2005. At the same time, Bush instituted a nominal fast reactor development project under GNEP (the Global Nuclear Energy Partnership), but in reality the goal was to cripple fast reactor development and fuel reprocessing by tying it to “nonproliferation,” and scaring people with the lie that plutonium equals bombs.
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Marje,
The FFTF can still be available for advanced energy research. See the file on this site, AFTRC.
Energy Secretary Steven Chu must decide. The fast reactor technology decision is on his watch. All is not lost, yet.
Also see: www.medicalisotopes.org
Thank you for visiting usa-cargo.
Best regards, Carlgh
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