January 23, 2001

Ms. Linda J. Keen
President and CEO
Canadian Nuclear Safety Commission
280 Slater Street
P.O. Box 1046
Ottawa KIP 5S9
Canada

Dear Ms. Keen:

The undersigned groups call on the Canadian Nuclear Safety Commission (CNSC) to suspend the “Parallex” mixed oxide (MOX) plutonium fuel qualification tests scheduled to begin this month at the Atomic Energy of Canada’s (AECL) Chalk River Nuclear Laboratory’s National Research Universal reactor (NRU). We call for this suspension because serious concerns have recently surfaced about potential problems with quality assurance of the plutonium fuel pellets to be tested in the NRU. We feel strongly that the fuel, fabricated at the U.S. Department of Energy’s (DOE) Los Alamos National Laboratory (LANL), must undergo a thorough quality assurance inspection prior to use in the NRU reactor. The inspection must involve a thorough review of Los Alamos quality assurance documents and full non-destructive and destructive analysis of the Parallex pellets by AECL, with all data immediately and fully available to the public.

The CNSC must take action immediately because the “test-burn” of MOX fuel pellets containing both U.S. and Russian weapons-grade plutonium is scheduled to begin soon. According to the test plan prepared by Oak Ridge National Laboratory (ORNL)--DOE”s lead laboratory for plutonium fuel use in nuclear reactors--Parallex is designed to “qualify MOX fuel” for use in Canadian Deuterium-Uranium (CANDU) nuclear reactors, and “to demonstrate the infrastructure involved in the disposition of excess weapons plutonium as MOX fuel in reactors.” So Parallex is more of a fuel qualification exercise than a test.

However, ORNL reported in December 2000 that it had discovered problems with similar experimental MOX fuel pellets DOE used in the Idaho National Engineering and Environmental Laboratory’s (INEEL) Advanced Test Reactor (ATR) as part of the U.S. plutonium disposition program. ORNL reported that the pellets--fabricated at Los Alamos, irradiated at the ATR, and then examined by ORNL--contained “numerous plutonium-rich agglomerates...up to 500 microns in size and unevenly distributed.” This evidence suggests that Los Alamos’ initial characterization of these pellets was inaccurate and flawed. Since ORNL only found out about the quality assurance problems upon discovering unanticipated irregularities after irradiation, the Canadian authorities should be wary of mistakes made by the U.S. Department of Energy.

The presence of such large agglomerates in the fuel could lead to safety problems during the test irradiation that would not have been accounted for in whatever safety analysis AECL had to do to approve the Parallex tests. Plutonium oxide uniformity in MOX fuel, called “homogeneity,” is a critical issue for plutonium fuel use in CANDU and other reactors. According to the ORNL test plan, large plutonium oxide-rich areas could effect the burnup threshold where increasing gas release begins or could produce hot spots on the cladding. According to Los Alamos, “issues associated with very large plutonium oxide agglomerates” include “hot particle ejection and overpower reactivity insertion,” therefore Los Alamos sought to keep “mean plutonium oxide agglomeration size” to less than 40 microns. The presence of agglomerates as large as 500 microns in size means that in the event of an overpower transient, severe cladding failures and fuel dispersal could occur. If this were to occur on a large scale with a full CANDU core loading, it could possibly result in loss of coolable geometry, fuel-coolant interactions and pressure pulses which could conceivably bring about a core melt and massive radionuclide release.

According to the ORNL test plan, the first bundle of plutonium fuel in the CANDU fuel qualification effort was to contain a highly homogeneous mix of MOX fuel. It is unlikely, given LANL’s documented inability to make highly homogeneous fuel for the Advanced Test Reactor, that the U.S. MOX fuel sample already sent to Chalk River meets the specifications for the fuel qualification test.

Other evidence supporting suspension of this project pending inspection and analysis of the plutonium fuel includes:

In 1998 Los Alamos fabricated fourteen batches of MOX test fuel pellets for the ATR “High Power Test” (HPT) that failed to meet technical specifications and/or were characterized by unacceptable “end capping,” cracking on top, and bubbling when submerged in alcohol.

In 1996 Los Alamos fabricated an unspecified amount of MOX fuel pellets for the CANDU MOX fuel qualification program that “did not meet the required specifications...because of cracks and chips on the final sintered pellets.”

In 1999 Los Alamos admitted that its difficulty fabricating suitable MOX fuel was "complicated by the aging of the fuel fabrication equipment." The lab used four 20-year-old presses to fabricate MOX fuel, and in 1999 two of these presses were so worn that LANL reported they “may no longer operate smoothly enough to produce good [MOX] pellets." What was the condition of the equipment when the CANDU fuel was made?

In November 2000 the U.S. National Academy of Sciences reported that the CANDU MOX fuel option will not meet the so called “spent fuel standard” which is supposed to insure security of the plutonium remaining in the used fuel.

All told, the Los Alamos MOX fuel fabrication experience has been substandard and the fuel manufactured by Los Alamos is unlikely to represent typical plutonium fuel that would be used in CANDUs. If the test fuel is not representative of the potential mission fuel because of the probable presence of large agglomerates and the nontypical methods used to fabricate the test fuel, the Parallex tests would provide no useful information and therefore would be worthless with the present fuel batch. Finally, given the experience with scandalous falsification of quality assurance records for plutonium fuel fabricated by British Nuclear Fuels, Ltd. (BNFL) and shipped for use in Japan, a rigorous review of quality assurance records is warranted at this time. Otherwise, the credibility of the CNSC and the entire Canadian nuclear program may be severely damaged.

No information has been publicly revealed about the quality of the Russian MOX fabricated at the Bochvar Institute in Moscow and also scheduled to be tested in the NRU reactor. We believe that prudence dictates that the quality assurance history for this fuel also be established. Underscored by the fact that use of Russian-fabricated MOX in the NRU reactor is a first, we believe it essential that the CNSC direct that this fuel also be fully examined to ensure that it meets the standards established by AECL and DOE. Just as for the LANL MOX review, information on the Russian MOX should be made public.

Based on the information available from Los Alamos and ORNL , which we urge you to obtain from the DOE, we call on the CNSC to exercise whatever authority it has to halt the Parallex test. We recommend that the CNSC require AECL to provide a full report on the quality of the fuel awaiting irradiation and that such document be made public. Due to the concern in Canada and the US over using weapons-grade plutonium fuel in nuclear reactors, we request that actions taken by the CNSC on this matter be made public.

Signed,

Don Moniak
Community Organizer
Blue Ridge Environmental Defense League
P.O. Box 3489
Aiken, SC
U.S.A.
803-644-6953

Tom Clements
Executive Director
Nuclear Control Institute
Washington, D.C.
U.S.A.
202-822-8444



Dr. Gordon Edwards, President
Canadian Coalition for Nuclear Responsibility
C.P. 236 Succursale Snowdon
Montréal, Québec
Canada
H3X 3T4

Kristen Ostling
National Coordinator
Campaign for Nuclear Phaseout
412-1 Nicholas Street
Ottawa, Ontario
Canada
K1N 7B7


Irene Kock, Research Consultant
Sierra Club of Canada
Box 104
Uxbridge, Ontario
Canada
L9P 1M6

Kay Cumbow
Citizens for a Healthy Planet, and
Citizens for Alternatives to Chemical Contamination
8735 Maple Grove Road
Lake, MI 48632
U.S.A.

Dave Taylor, Spokesperson
Concerned Citizens of Manitoba
c/o 674 Riverwood Ave.
Winnepeg, Manitoba.
Canada

Glenn Carroll, Coordinator
GANE - Georgians Against Nuclear Energy
P.O. Box 8574
Atlanta, Georgia

Michael J. Keegan
Coalition for a Nuclear Free Great Lakes
P.O. Box 331
Monroe, MI 48161
U.S.A

Corrine Carey, Board Member
Don't Waste Michigan
c/o 2213 Riverside Dr. NE
Grand Rapids, MI 49505
U.S.A.

Keith Gunter
Citizens' Resistance at Fermi Two
P.O. Box 463
Monroe, MI 48161
U.S.A.

Pat Ortmeyer
Field Director for Nuclear Issues
Women's Action for New Directions
Missoula, Montana

Ole Hendrickson, Researcher
Concerned Citizens of Renfrew County and Area
P.O. Box 981
Pembroke, Ontario K8A 7M5


Susan Gordon, Director
The Alliance For Nuclear Accountability
Seattle, WA
U.S.A.

Jay Coghlan, Director
Nuclear Watch of New Mexico
SanteFe, NM
U.S.A.

Greg Mello, Director
Los Alamos Study Group
SanteFe, NM
U.S.A.

Martin Forwood
Cumbrians Opposed to a Radioactive Environment (CORE)
98 Church St, Barrow
Cumbria LA14 2HJ.
United Kingdom

Roger Voelker, staff
Citizens Action Coalition of Indiana
5420 N. College Ave., Suite 100
Indianapolis, IN 46220

Harry Rogers, Board of Directors
Carolina Peace Resource Center
Columbia, SC

Michael Mariotte
Nuclear Information & Resource Service
World Information Service on Energy / Amsterdam
1424 16th St. NW Suite 404

Fran Macy, Director
Center for Safe Energy
Berkeley, CA


Damon Moglen
Greenpeace International
702 H Street, NW
Washington, DC 20001

Anne Adelson
Nuclear Issues Circle
Canadian Voice of Women for Peace
203-761 Queen St.East
Toronto, ON CANADA
Brennainn Lloyd
Northwatch
Box 282
North Bay, Ontario
Canada
P1B 8H2

Theresa McClenaghan, Counsel
Canadian Environmental Law Association
Suite 401 517 College Street
Toronto, ON M6G 4A2

cc: The Honourable Jean Chrétien, Prime Minister of Canada
cc: Ralph Goodale, Minister of Natural Resources
cc: Stockwell Day, Leader of Canadian Alliance Party
cc: Gilles Duceppe, Chef du parti Bloc Québecois
cc: Alexa McDonough, Leader of New Democratic Party
cc: Joe Clark,Leader of Progressive Conservative Party
cc: Secretary of Energy Spencer Abraham