ML20274A310

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Comment (9) of Tom Clements on Behalf of Savannah River Site Watch on the U.S. Nuclear Regulatory Commission'S Scoping Related to Preparation of an Environmental Impact Statement on the Westinghouse Fuel Plant in Richland County, South Caro
ML20274A310
Person / Time
Site: Westinghouse
Issue date: 08/21/2020
From: Clements T
Savannah River Site (SRS) Watch
To:
Office of Administration
References
85FR46193 00009, NRC-2015-0039
Download: ML20274A310 (6)


Text

Additional Comment in Docket ID NRC-2015- 0039, Westinghouse... https ://mail.aol.com/webmail-std/en-us/PrintMessage From : tomclements329@cs.com, To: WEC_CFFF_ElS. resource@nrc. gov, Bcc: greenlawpk@gmail. com,

Subject:

AdditionalComment in Docket lD NRC-2015- 0039, Westinghouse fuel plant & nuclear weapons connection, by SRSWatch/Clements Date: Fri, Aug 21,202010:35 am August 21,2020 SUNI Review Complete Template=ADM-013 To: Office of Administration E-RIDS=ADM-03 ADD: Jessie Quintero, Sarah Achten, Diana Mail Stop: TWFN-7-A60M Toro Diaz, Mary Neely U.S. Nuclear Regulatory Commission, Washington, DC 2055H001 Comment (9)

Publication Date: 7/31/2020 WEC_CFFF_El S. resource@nrc. gov CITATION 85 FR 46193 From: Tom Clements Director, Savannah River Site Watch Columbia, South Carolina httpqlg1swalah.argl srswatch@gmail.com Attachment to SRS Watch Comment of August 20,2020 on the U.S. Nuclear Regulatory Commission's Scoping Related to Preparation of an Environmental lmpact Statement on the Westinghouse Fuel Plant in Richland Gounty, South Carolina -

Docket lD NRG-2015- 0039 I hereby formally submit the article below - The Nuke Factory in Your Backyard -to accompany my scoping comments submitted on August20,2O2O (and linked here:

httpql$gwalqh.org/wp:sq_nle_nUuplqAdq/202Orc8/qgqpqg-ElS-cqrue1lq:by:SfiS-!ryatsh-August-20-2020 pglf.

The article is about the WesDyne facility, located at the Westinghouse facility site, that produces non-radioactive Tritium Producing Absorber Rods (TPBARs) which are irradiated in a commercial TVA reactor to produce radioactive tritium gas used to boost the explosive power of all U.S. nuclear weapons.

The draft EIS must clarify which agency regulates the WesDyne facility. The NRC claims it does not regulate WesDyne but has produced no documentation assuring that. The DOE's National Nuclear Security Administration, which takes delivery of the irradiated tritium rods for processing at DOE's Savannah River Site, is not a regulatory agency. ls the NRC meeting its regulatory obligations concerning WesDyne and any waste it might produce? \A/ho regulates WesDyne and the waste streams it may generate? Does any WesDyne waste, including waste water, that ends up being handled by the Westinghouse facility and its systems?

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Additional Comment in Docket ID NRC-2015- 0039, Westinghouse... https ://mail.aol. com/webmai l-std/en-us/PrintMessage The Nuke Factory in Your Backy ard How the LI.S. quietly turned a civilian atomic power site into a so-called bomb facility and what it means for the global arms race -

An innocuous industrial site belonging to Westinghouse Electric Co. sits off a rural stretch of South Carolina Highway 48, surrounded by a thick forest about 10 miles outside the state's capital of Columbia.

For years, locals believed employees here worked solely on uranium fuel used in civilian nuclear power generation. But somewhere inside the 2-million-square foot complex, a small team of specialists, working on a federal contract for more than a decade, have quietly been assembling special stainless steel rods that are essential in the production of tritium, a radioactive isotope used in the trigger mechanisms for nuclear bombs and missiles. lt's the amount of tritium that's released in the explosion of a nuclear weapon that determines the intensity of its devastating blast.

The activities at the Columbia plant, illuminated here in depth after years of obscurity, offer a rare peek into the widespread and largely unknown civilian participation in America's nuclear weapons complex a scattered and privatized industry that defies efforts to reduce nuclear stockpiles, and arguably undermines official U.S. policy and the key treaty aimed at preventing a runaway global atomic arms race.

"Such assembly has resulted in the de facto conversion of the Westinghouse fuel plant into a nuclear bomb facility," argge_g Friends of the Earth, an environmental group that closely tracks the nuclear industry.

The site doesn't produce tritium itself; that happens at a different civilian nuclear power facility in Tennessee. Here, a Westinghouse subsidiary called WesDyne makes the rods essential to it. lt's a first stop in the little-known production chain that winds around the Southeast and helps tritium end up in some capacity in perhaps all U.S. nuclear weapons.

\Mthout these rods, created exclusively by WesDyne, the U.S. nuclear arsenal could not function normally. Yet disclosures of the work at the facility, which would be required by law and international treaty for almost any other material created at a civilian atomic facility for use in nuclear weapons, have been spotty at best and in at least one case were omitted entirely from a key report on the U.S. nuclear weapons stockpile sent annually to international observers.

Wih_]plp frqrLFreeTfnqq, a local weekly newspaper based in Columbia, War is Boring conflrmed the nuclear weapons activity at WesDyne after receiving a tip from a well-connected observer of the atomic industry and following it up with persistent phone calls and emails and cross-referencing our own findings with obscure government reports.

WesDyne makes no mention of its tritium-rod building business on its Website or in company marketing materials. When we asked about the program at the plant, Westinghouse and government officials contacted for this article offered different characterizations. A Westinghouse spokesperson said it was a classified program with the Department of Energy. The DOE said while there are parts of the program the agency can't discuss, the work being done there isn't classified.

Even so, officials have more than once failed to include any reference to WesDyne in key reports on the U.S. nuclear industry.

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Additional Comment in Docket ID NRC-2015- 0039, Westinghouse... https ://mai l.aol.com/webmai l-std/en-us/PrintMessage ln at least one case, DOE officials chose to omit the Columbia plant activities from the classified nuclear arms report the agency delivers annually to the United Nations' nuclear watchdog. The Obama administration's Sqcfel2O!9 lt_selpSUfq to the lOtenallo1qLAla11lg

_f nergy_lgency, accidenla[y_iejeAqedlqlhe_p_Ublic two years ago, does not mention the key link in the tritium production chain located at the facility in Columbia.

The U.S. National Nuclear Security Administration's 2014 Stockp_!l_e1$te_wA_tdqhjp_ald Management Plan, published last month, identifies some 75 sites in the nuclear weapons supply chain in all but about a dozen states across the country but does not mention the tritium bar fabrication being done by WesDyne in South Carolina. Asked why, a DOE employee speaking for the agency pointed to a 1S-year-old federal report concluding that the rod fabrication does not qualify as a special nuclear material and therefore certain disclosures about it aren't required.

At the same time, a spokesperson for the DOE bristled at any characterization that WesDyne's manufacturing of nuclear weapons components might be considered secret at all, pointing out that it has been in the public record for years. The company's contract, which began in 1999, was disclosed in a 2081_rcpqf! about a campaign for tritium readiness and a 2010 Government Accountability Office repg_t Gbatlllheslabllj_ty_aftbq Ulium supp_ly chain. (These, along with perfunctory references in DOE budget reports, are among the only public documents we found that mention WesDyne's role as the source of the rods.)

lf a handful of disclosures have leaked out about WesDyne from time to time over the years, knowledge about the operation hardly traveled far. A former Westinghouse employee at the Columbia facility, speaking on condition of anonymity, said he had never heard that atomic weapons-related activities were taking place on the same property where he worked on commercial nuclear power five days a week.

Tom Clements, the Columbia-based southeastern nuclear campaign coordinator for Friends of the Earth, an environmental group with offices in California and Washington, D.C., says the general public in the surrounding area is almost totally unaware that assembly of vital hardware for the production of atomic weaponry is being done at the Westinghouse site.

"Nobodv knows about it." he savs.

ffi No dual-use For nearly 60 years, the U.S. has officially espoused a so-called "no-dual-use" policy, meant to separate civilian and military nuclear production and thus shield peaceful uses of atomic energy from the apocalyptic politics of potentially world-destroying nuclear weaponry.

The policy has its roots in the 1954 federalAtomic Energy Act. The ll,uqlear Non-Prqlle1qlol flealy of 1968 doubled down, stating that countries should not develop commercial applications of nuclear energy for nuclear weapons purposes. The treaty is routinely cited by the U.S. to prevent countries like lran and North Korea from developing nukes.

ln 1998, a Defense Authorization Act conference report directed the DOE to review the production of tritium and its relationship between civilian and military nuclear facilities. The review concluded that it is not prohibited by law or international treaty, and that there have historically been exceptions to differentiating between U.S. civil and military facilities, according to the DOE. After the WesDyne contract was drawn up, the DOE and NNSA took the position that nothing the facility was doing in Columbia needed to be declared unless the toxic lithium the rods contain became a safety concern something that fortunately has not occurred.

To some, in dismissing concern about WesDyne's nuclear weapons-related activities and 3 of6 8/2412020,9:42 AM

Additional Comment in Docket ID NRC-2015- 0039, Westinghouse... https ://mail.aol.com/webmai l-std/en-us/PrintMessage not disclosing them to the U.N., American authorities appear to flaunt standards by which the rest of the world is expected to abide. "The rules are not for us," says Greg Mello, director of the Los Alamos S_tUdy_Grqgp in New Mexico and an analyst for nuclear policy organizations. "The rules are for them [North Korea and lran]to follow, and we make them not so much for nuclear security as much as for geopolitical reasons."

Adds Clements: "While it might not be a technical violation of U.S. law, production of tritium for nuclear weapons in a commercial nuclear reactor violates long-standing policies not to use commercial nuclear facilities for production of nuclear weapons materials."

It's unclear how many other commercial nuclear operations in the U.S. also produce components or hardware used in the production of atomic weaponry, Iargely because information about the production chain is scattered in obscure reports; as with WesDyne, you'd have to know what you were looking for and where to look.

Although it's hard to track down potential violations, nuke watchdogs agree that it's unlikely the South Carolina complex is alone in quietly engaging in the production of nukes.

Atomic supply chain Largely outside the awareness of the general public, the privatized U.S. atomic weapons industry spreads its tendrils deep into some surprising places. !t's a creature that appears to be thriving despite rhetoric in Washington about reducing the country's nuclear stockpile.

The number of nuclear warheads in the U.S. arsenal has dropped in the past few decades, according to a 2013 repqrt by the Bulletin of Atomic Scientists. But America's total stockpile still includes approximately 4,650 warheads, of which an estimated 2,150 are deployed.

Number-two nuclear power Russia posesseg_alqun-d_3,500 active warheads_ and both countries have many hundreds of inactive atomic munitions awaiting dismantling. -

All of the active American weapons could contain elements made from a process that has roots in Columbia. A team of three workers tinkering away in a small corner of the big Westinghouse facility quietly builds the special stainless steel rods called tritium-producing burnable absorber rods, or TPBARs, which contain lithium. After processing at the separate facility in Tennessee, the TPBARs help produce the ti!ru$, which is a radioactive form of hydrogen.

"WesDyne is the only manufacturer of TPBARs, which they have done since 1999,' a DOE spokesman says.

Unlike other nuclear materials, tritium has a short half-life, which means it must be continuously replenished as long as America maintains its nuclear arms. Author Ken pelgerqn, who spent 25 years as a physicist in a New Mexico atomic weapons lab and wrote a2002 booke!qU!!rt!um, calls it "the lifeblood of the nuclear arsenal."

After they're fabricated in Columbia, the rods are shipped to the Watts Bar nuclear power facility in Tennessee, where the material in the rods is converted into the tritium gas. The design parameters of the rods are classified, according to a spokesman at the Tennessee facility.

Once inserted into a reactor core during refueling, the TPBARs are irradiated for at least a year and a half, according to the GAO report. After that, the tritium leaves Tennessee for a trip back east to the Savannah River Site nuclear facility on the Georgia-South Carolina border. There the tritium is extracted, packaged and then shipped to the Defense Department where it's loaded into the thousands of bombs, ICBMs and cruise missiles that make up America's vast nuclear stockpile an apocalyptic arsenal that at every step along the uced almost enti

- and entities.

SA workers prepare a nuclear bomb for dismantling. NNSA 4of6 812412020,9:42 ANI

Additional Comment in Docket ID NRCJO15- 0039, Westinghouse... https ://mail.aol.com/webmail-std/en-us/PrintMessage lnching toward zerc?

A privatized U.S. atomic weapons production chain could defy attempts by some politicians and activists to dismantle the world's nuclear arsenals.

Even Pres. Barack Obama has signaled that he wants to shrink the number of U.S. nukes.

"l've determined that we can ensure the security of America and our allies, and maintain a strong and credible strategic deterrent, while reducing our deployed strategic nuclear weapons by up to one-third," Obama said in Berlin in June.

But the president could be in for a reality check. After all, maintaining the nation's nuclear weapons stockpile is big, big business, with mega-corporations performing the atomic maintenance on contract with the feds. "We have an almost fully privatized nuclear weapons business in the United States," says the Los Alamos Study Group's Mello.

Such privatization gives the nuclear industry political clout it would lack if it were fully government-controlled. The owners, managers and employees of contractor-operated nuke sites can contribute to congressional campaigns, utilize political action committees and lobby Congress.

And they do. ln the 2012 election cycle, the 14 biggest atomic weapons contractors gave a total of $2.9 million to members of Congress with decision-making power over nuclear spending, according to a Center for International Policy rep_oft. All told, the firms had donated $18.7 million to those same members of Congress over the course of their careers.

Recently, members of North Dakota's congressional delegation went on record saying they oppose cuts to the nuclear arsenal. "They say the U.S. needs a strong nuclear deterrent, especially when countries such as North Korea and lran are working on nuclear arsenals,"

the Associated Press repqrted. Not coincidentally, many of the United States' nuclear missiles are in underground silos in North Dakota.

"Now is not to the time to pursue further strategic nuclear force reductions," U.S. Sen. Jim lnhofe, an Oklahoma Republican and ranking member of the Senate Armed Services Committee, said in a statement, adding that efforts to slow Iran's and North Korea's nuclear ambitions are "failing." lnhofe collected $34,000 in donations from the nuclear arms industry in 2012, against a career total of $285,000 from the industry, according to CIP's tally.

South Carolina's own Sen. Lindsey Graham, a Republican and member of the Armed Services Committee, has vowed to do "everything in [his] power to keep the next generation of nuclear power on track" and has supported the building of new reactors. Graham has also received donations totaling nearly $435,000 from the atomic weapons industry includinq $44,000 in 2012, CIP NNSA emolovee secures nuclear material in Vietnam. NNSA Not fade away The influence of nuclear-arms contractors might be seen in current efforts to ramp up production of nuclear weapons material. Even as the president declares he wants to draw down nuclear weapons, the National Nuclear Security Administration says in its 2014 stockpile management plan that it wants to increase production of tritium, according to The Augusta Chronicle in Georgia. Meanwhile, the NNSA is planning an environmental impact statement on expanding tritium production into two more nuclear reactors in Tennessee, Clements says.

"Because the current inventory is larger than required, only a small amount is produced today," states part of the NNSA management plan, the Georgia newspaper reported.

"However, to meet future tritium inventory requirements, the rate of production must be increased."

The NNSA has increased its 2014 budge!rcquest for the production and maintenance of 5 of6 8124D020,9:42 AM

Additional Comment in Docket ID NRC-2015- 0039, Westinghouse... htps ://mai l.aol.com/webmai l-std/en-us/PrintMessage weapons activities to nearly $8 billion, which is a 7.6-percent jump compared to the 2013 budget and the fourth consecutive annual boost, The Augusta Chronicle pointed out. And the growth could continue. A June 20 version of a U.S. House Energy and Water app-rcp-natiplq !r1l called for an assessment of the national security demand for tritium through the year 2060.

The feds'tritium program currently employs 450 workers at the Savannah River Site, plus at least three in Columbia, among others. The Savannah River Site is already p_le11n1ng_0e_W facilities to accommodate the extra effort as the tritium production effort ramps up.

Tritium has a half-life of 12.5 years, meaning it decays rapidly, as opposed to uranium or plutonium, which can take thousands of years. That means it must be replenished in nuclear weapons at a fairly fast rate.

But not replacing the radioactive gas is an option. Decades ago there was a nuclear arms reduction movement based on just letting the tritium decay and not juicing it back up. The movement's goal never came to fruition, but suspending tritium production remains a viable way of gradually cutting the nuclear arsenal if the U.S. and other nuclear weapons states wanted to do it. -

Just don't count on it actually happening. "The president remains committed to a safe, secure and reliable nuclear deterrent," the NNSA states on its Website. And as for the president's speech in Berlin calling for a reduction in nuclear arms? lt will have "no immediate impact" on the agency's sites, an NNSA spokesman says.

Back in Columbia, Clements of the state Friends of the Earth chapter says he doubts America will ever willingly eliminate its nuclear arms holdings as required by the nuclear nonproliferation treaty. The industry is too powerful and too deeply and sometimes secretly -

embedded in American communities to allow for meaningful nuke reductions anytime soon.

Equally, the upward trajectory of America's thriving nuclear-arms industry reflects outmoded thinking, Clements contends. "The fact that the U.S. has nearly 5,000 nuclear weapons still indicates that there's a Cold War mentality at play and they're always prepared to fight a major nuclear war," he says. "lt's a self-perpetuating machine that has little to do with national defense."

Despite efforts to conceal it, a small part of that machine can be seen in action off a lonely South Carolina highway, where regardless of criticism about policy and treaty, America's atomic practitioners are as busy as ever revitalizing the world's biggest active nuclear arsenal.

With additional reporting by David Axe. Subscribe to War is Boring: medium.com/feed/war-is-boring.

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