This blog was co-authored by Sara Barczak, former Regional Advocacy Director with the Southern Alliance for Clean Energy, and Mandy Hancock, SACE's former High Risk Energy Organizer.

Guest Blog | July 8, 2011 | Energy Policy, Nuclear

The U.S. Nuclear Regulatory Commission (NRC) recently asked for stakeholder input on the potential to begin rulemaking proceedings regarding the reprocessing of used (spent) nuclear reactor fuel. Reprocessing is the separation of ‘fissionable’ uranium and plutonium from used nuclear fuel. A plutonium-based fuel could then be produced, often referred to as mixed-oxide fuel or “MOX,” for use in a nuclear reactor. Currently the U.S. does not reprocess nuclear fuel nor use plutonium-based fuel.

Even though reprocessing, if implemented, would have national and international implications, the NRC only held three public meetings, one of which was in Augusta, Georgia very near the most likely candidate for reprocessing facilities, the Department of Energy’s sprawling, polluted nuclear weapons complex in South Carolina, the Savannah River Site (SRS). Further, the ongoing Japan nuclear disaster at the Fukushima-Daiichi nuclear complex, has prompted experts, including engineers at M.I.T, to  recommend moving away from reprocessing.

We need regulators here in the U.S. to pay attention and we need YOU to take action today!

Reasons to oppose reprocessing of used nuclear fuel: it’s expensive, risky and polluting

• It increases the volume of hazardous, radioactive waste that already plagues our country. The Department of Energy (DOE) estimates that reprocessing generates much larger waste streams than commercial reactors using conventional nuclear reactor fuel, with 3 to 11 times more low-level radioactive waste and a staggering 163 times more “Greater than Class C Waste” created (see page 20 of from the link above to view the table);
• Reprocessing does not eliminate highly radioactive, long-term fission products such as iodine-129 and cesium-135, which have half-lives of millions of years. Proponents have misleadingly and inaccurately referred to reprocessing as “recycling” in order to confuse the public and policymakers into supporting this highly polluting technology;
• SRS, along the banks of the Savannah River, already has a severe radioactive waste problem. The highly contaminated site currently has the second largest volume of high-level liquid radioactive waste and the most amount of radioactivity at any DOE site in the nation. Reprocessing will only make this already staggering and unacceptable problem worse;
• Despite proponents’ claims that reprocessing benefits nuclear non-proliferation efforts, reprocessing nuclear fuel actually creates new proliferation risks by creating new streams of plutonium that must be secured. Brookhaven National Laboratories concluded that all of the reprocessing technologies available have about the same proliferation risk because of the “ease [with which] various plutonium-bearing materials or the reprocessing process itself could be converted to produce separated plutonium;”
• Internationally, reprocessing has been abysmal failure. As the Alliance for Nuclear Accountability documented, Russia continues reprocessing with no use of separated plutonium, continuing to pile up highly toxic waste. France reuses little of the contaminated uranium removed via reprocessing, and dumps 100 million gallons of radioactive waste into the English Channel every year. The United Kingdom has released over 1,000 pounds of plutonium into the Irish Sea. More than $20 billion has been spent on the Japanese reprocessing plant Rokkasho, which has failed to start after more than two years of attempts;
• If international examples aren’t compelling enough, the disastrous U.S. experience with commercial reprocessing at West Valley, New York from 1966-1972 was a total failure that contaminated the environment and resulted in a multi-billion dollar clean-up program that is still proceeding; and
• Reprocessing, development and use of plutonium fuel (or MOX) are much more costly than traditional, uranium-fueled reactors, with fuel cycle cost increases estimated as high as 300%. As is usual with nuclear projects, these costs will likely fall on U.S. taxpayers and utility ratepayers. For instance, TVA may participate in the troubled plutonium fuel scheme.

Some recommendations for the NRC:

• Before rulemaking is even considered, the overall consequences of reprocessing and all aspects of this activity as it relates to the entire nuclear fuel cycle must be analyzed. The NRC should conduct a full-scale analysis under the National Environmental Policy Act – a Programmatic Environmental Impact Statement – from “cradle to grave” before embarking on rulemaking. Financial impacts to ratepayers and taxpayers; effects on waste management, the environment and public health; and implications for international non-proliferation efforts should be part of the analysis open for public debate;
• The NRC must thoroughly reject the nuclear industry’s and proponents’ inaccurate and misleading greenwashing effort of referring to reprocessing as “recycling.” Reprocessing is like nuclear waste generation on steroids–hardly an apt characterization of what the public considers recycling; and
• Despite industry pressure, the NRC should not proceed to rulemaking for reprocessing regulations that are not needed and for which no urgency, except for those standing to profit such as Areva, the French-owned company pushing the concept, has been established.

Please submit your own comments to the NRC as soon as possible

Although the extremely brief comment period ended on July 7, that deadline was unclear and continuing to engage the NRC on this important issue will only strengthen the case against proceeding with rulemaking at this time. Please send this alert to your friends and allies!

Resources:

• Federal Register Notice (details the public commenting process)
• NRC Documents and Transcripts from Meetings
• Transcripts from Augusta Meeting
• SACE’s Submitted Comments
• Congressional Testimony of Richard K. Lester, stating the economic and technical case against reprocessing, July 2005
• The Mythology and Messy Reality of Nuclear Fuel Reprocessing by Dr. Arjun Makhijani of the Institute for Energy and Environmental Research
• Backgrounder of the Savannah River Site’s troubled history from the Alliance for Nuclear Accountability

Where/how to send comments:

• E-mail comments to: Rulemaking.Comments@nrc.gov. If you do not receive a reply e-mail confirming that they received your comments, please call the NRC directly at 301-415-1677.
• Fax comments to: Secretary, U.S. Nuclear Regulatory Commission at 301- 415-1101.
• Mail comments to: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, Attn: Rulemakings and Adjudications Staff.
• Send copies of your comments to your Congressional Representatives and U.S. Senators. Find them here.
• Please note: Because your comments will not be edited to remove any identifying or contact information, the NRC cautions you against including any information in your submission that you do not want to be publicly disclosed.