ML23132A064

Comment (1575) of Ann Behrmann on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; TRISO-X Special Nuclear Material License

ML23132A064
Person / Time
Site:	Triso-X
Issue date:	02/11/2023
From:	Behrmann A - No Known Affiliation
To:	Office of Administration
References
NRC-2022-0201, 87FR77146 01575
Download: ML23132A064 (1)

Text

SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 As of: March 08, 2023 Received: February 11, 2023 PUBLIC SUBMISSION ADD: Jill Caverly, Robert Sun, Antoinette Walker- Status: Pending_Post Smith, Mary Neely Tracking No. le0-t6f0-45wm Comment (1575)

Publication Date: 12/16/2022 Comments Due: February 14, 2023 Citation: 87 FR 77146 Submission Type: API Docket: NRC-2022-0201 Notice of Intent to Conduct Scoping Process and Prepare Supplement to Draft Environmental Impact Statement TRISO-X Fuel Fabrication Facility Comment On: NRC-2022-0201-0001 Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement; TRISO-X Special Nuclear Material License Document: NRC-2022-0201-DRAFT-1575 Comment on FR Doc # 2022-27164 Submitter Information Name: Ann Behrmann Email: atbehrma@wisc.edu General Comment Since TRISO-X, LLC is proposing a first-of-a-kind US Nuclear Regulatory Commission (NRC) Category II licensed TRISO-based fuel fabrication facility, all aspects of the facility need to be disclosed. I oppose the opening of a new nuclear fuel fabrication factory especially one that will use nearly bomb grade uranium!

According to the Environmental Report for the TRISO-X Fuel Fabrication Facility (September 2022), TRISO-X FFF manufacturing operations consist of receiving HALEU in the form of triuranium octoxide (U3O8) powder enriched to less than 20 weight percent 235U; converting the U3O8 into a uranyl nitrate solution, into gel spheres, and then into fuel kernels; and processing the fuel kernels through coating, overcoating, fuel form pressing, and high temperature carbonization. These operations are supported by shipping and receiving, laboratory, quality control, research and development, uranium recovery, and waste disposal processes. (Section 1.3).

Beginning with the High Assay Low Enriched Uranium (HALEU), at 20 weight percent 235U, this will be a totally new form of enriched uranium that is currently not produced anywhere in the U.S. From where will the HALEU be obtained? Provide background on how the HALEU is made, including its conversion ostensibly from uranium hexafluoride to triuranium octoxide powder, the source of the uranium and any environmental impacts of the production process, from mining to finished product. Will there be an alternate or backup source for HALEU?

How will the HALEU be shipped to and from the facility? What procedures will be in place to protect the general public during transport? What steps will be involved in handling it upon receipt? What procedures will be in place to protect workers?

What are the steps necessary to convert the HALEU into a uranyl nitrate solution? Into gel spheres? Into fuel kernels? What are the safety and security procedures thatll be in place to protect worker and possible pollution file:///C/...eDrive%20-%20U.S.%20NRC/Desktop/NRC-2022-0201%202023-03-08%2012-04-27_docs/NRC-2022-0201-DRAFT-1575.html[3/28/2023 11:13:31 AM]

of the environment? What chemicals will be used, how will they be obtained and disposed?

Next, describe the various steps from a safety and security perspective in processing the fuel kernels for coating, overcoating, form pressing and high temperature carbonization. Again, what chemicals will be used and how will they be disposed? What other toxic/hazardous materials will be used in the process, how will they be handled and disposed?

Most importantly, how will the HALEU be handled throughout the entire process in order to prevent the possibility of criticality?

Continuing with HALEU, the second sentence of the NOI states: TRISO-X is requesting a license to possess and use special nuclear material for the manufacture of high-assay low-enriched uranium (HALEU) fuel at a fuel fabrication facility (FFF) to be located in Oak Ridge, Roane County, Tennessee. (Emphasis added). The use of the word manufacture would seem to suggest TRISO-X FFF intends to up blend or down blend 235U in order to arrive at 20 weight percent 235U HALEU. Explain what is meant by manufacture and whether TRISO-X FFF intends to alter the percentage of 235U in any way and if so, by how much and why.

A TRISO-X video indicates the TRISO fuel particles will last 60 years. Please explain why it lasts so long, what causes its degradation, the resulting waste and how it will be disposed. Will there be issues of criticality and if so, how will they be addressed? What will be the environmental impact and how will that be addressed? How will the fuel be stored both in the short term and once it has completely degraded. What step or steps within the process pose(s) the greatest risk of contamination and how is that being mitigated?

As for the facility itself, what procedures/safeguards will be in place to prevent the possibility of radioactive or chemical releases into the atmosphere and/or groundwater? What safeguards will be in place to prevent the possibility of fires throughout the fabrication process? What are the safeguards against direct terrorist attacks or other possible assaults against the facility such as cyber-terrorism? Identify the stages in the process that could jeopardize human health or safety should there be a total loss of power onsite?

How would a serious accident be handled? Especially one with widespread offsite contamination? What is the financial ability of TRISO-X, LLC to address such a catastrophic accident? Identify the quality assurance requirements applicable to the facility, who will be responsible and how they will operate?

What are the various steps in the uranium recovery process? Identify all security and risk safeguards. Provide the step-by-step procedures in the waste disposal processes and all safeguards involved.

Will the perimeter of the facility be monitored for radioactive and chemical contamination, how often and if not, why not? Will rainwater be retained onsite and monitored for contaminants?

file:///C/...eDrive%20-%20U.S.%20NRC/Desktop/NRC-2022-0201%202023-03-08%2012-04-27_docs/NRC-2022-0201-DRAFT-1575.html[3/28/2023 11:13:31 AM]