Fast Flux Test Facility - Public Comment

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:

  1. The medical isotope supply is in crisis due to aging international reactor infrastructure.

  2. Domestic production of the isotope Pu-238 did not start and production planning has failed.

    1. Record of Decision confirmed the need to reestablish a production capability.

    2. 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.”

    3. US purchase of Russian Pu-238 will end, and cannot be used for national security.

  3. Civilian reactor R&D is constrained due to lack of testing and certification facilities and programs.

    1. R&D projects and Intelectual Property are moving off-shore; to China, South Korea, India, Russia, Ukraine, France, Canada, et.al.

  4. RL’s VIT plant needs ~70 MWe which could easily be supplied by the FFTF with a Power Block.

  5. And most significantly, on December 22, 2009, DOE Secretary Steven Chu wrote:

    1. The closed fuel cycle cannot be implemented without a fast neutron spectrum…”

    2. …research is needed now to provide options for future policymakers.”

    3. The Administration had pledged that a Blue-Ribbon panel will consider all alternatives to Yucca Mt…”

    4. …other nations are pursuing the technology…”

    5. 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:

  1. FFTF was a fully licensed nuclear reactor with a 20 year full power life.

  2. Even though the liquid sodium coolant has been drained, FFTF could be restarted.

  3. 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

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12 comments to Fast Flux Test Facility – Public Comment

  • Tom Clements

    For years, local entities around Hanford have tried to resuscitate FFTF, with proposed missions from medical isotopes to plutonium-238 production. Alas, the efforts have been for naught and the reactor is dead, with the sodium having been drained. May FFTF’s wandering for a mission now be terminated in peace.

  • The sodium has been drained and allowed to cool in large adjacent tanks. All sodium systems are preserved under pure argon gas.
    The reactor is not dead, it is in cold standby. We’ll see what the Secretary says in his Record of Decision.
    All of those proposed missions are still viable but for …
    Thanks for your comment.

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