* Citizens Clearinghouse for Hazardous Waste
* Friends of the Earth
* Greenpeace
* Military Production Network
* Natural Resources Defense Council
* Nuclear Control Institute
* Nuclear Information and Resource Service
* Peace Action
* Physicians for Social Responsibility
* Public Citizen
* Rocky Mountain Institute
* Safe Energy Communications Council
* Sierra Club
* U.S. Public Interest Research Group

December 20, 1996

The Honorable Hazel R. O'Leary
Secretary of Energy
U.S. Department of Energy
Washington, D.C.

Dear Madam Secretary:

The conversion of surplus military plutonium into a non-weapons-usable form is an extremely important disarmament goal that all of us share with you. We believe this work must be accomplished in a manner that does not introduce new security dangers and also serves to protect the health and the environment of the communities where it is to be carried out, now and for future generations.

For these reasons, we want you to know, as you proceed to your Record of Decision on disposal of excess U.S. military plutonium, we are troubled that the Programmatic Environmental Impact Statement articulates a "dual track" strategy giving equal weight over the next two years to examining both the mixed-oxide (MOX) fuel and the direct immobilization options. Given the proliferation risks associated with fabrication and use of MOX fuel, as well as the additional delays, costs, and safety and environmental risks associated with this option, we ask that you make explicit in your Record of Decision that the direct immobilization option, once successfully demonstrated, will be used exclusively to dispose of all excess U.S. plutonium.

Some of our organizations are unalterably opposed to the Department of Energy introducing any plutonium as MOX fuel in nuclear power plants under any circumstances, while others are willing to consider MOX as an insurance policy to be implemented only if the direct immobilization option proves infeasible or incapable of meeting an agreed timetable for reducing U.S. and Russian plutonium to roughly equal levels.

We are all confident, however, that with an appropriate combination of resolve, resources and independent peer review, your Department can demonstrate that all of the excess U.S. military plutonium, including pits, can be directly immobilized in waste, safely and securely and at a rate that will meet an agreed timetable for reductions. We stand united in our resolve to prevent use of MOX fuel in nuclear power plants once it is demonstrated that MOX use can be avoided altogether by using direct immobilization instead.

We are also united in support of the goal of rapid disposal of excess military plutonium in the United States and Russia in a manner that maintains parity with Russia as both sides work toward the global disarmament objective of eliminating all weapons plutonium. MOX can be shown to be avoidable, and it is imprudent for the United States---after pursuing a two-decade policy of avoiding introduction of MOX fuel at home and not encouraging its use abroad---to open up the United States to this technology and to facilitate its deployment in Russia, particularly when Russia continues to separate plutonium for commercial use. Such a course will only exacerbate the problems of nuclear proliferation and radioactive contamination of the environment. U.S. dollars are now best spent on validating the direct immobilization approach so that it can be available for both the United States and Russia.

Regarding Russian plutonium, the problem at this point is that the United States has no counter to Europeans and Japanese who, with plutonium-fuel technology to sell, are pushing the MOX option in Russia and asking the United States to help pay for it. We, therefore, support the proposal made in a recent New York Times editorial that "America should encourage, and perhaps help to finance, a demonstration plant for vitrification in Russia..."1

From the standpoint of sound engineering and fiscal integrity, DOE should put its priorities in the most promising and least costly technology. One immobilization alternative, "can-in-a-canister," is projected by DOE to begin in the United States six years sooner and be completed 13 years before the alternative method of turning the plutonium into fuel and using it in five existing nuclear powerplants2. The existing-reactor MOX option is also estimated to cost $1.5 billion more3 than the "can-in-canister" approach, although this estimate is highly optimistic because it assumes only a half-billion dollars in incentive payments for electrical utility companies when billions could be required.

Once can-in-a-canister, or an alternative direct immobilization approach, is validated, the United States then will be in a far stronger position than it is today to make a generous offer of this technology in the form of a joint venture with Russia that could serve as an attractive alternative to the MOX option that is now being proposed for Russia by commercial plutonium interests in Europe and Japan.

On the other hand, moving toward rapid implementation of the MOX option by giving it equal priority with immobilization raises a number of clearly avoidable cost, safety and proliferation risks.

We urge in the strongest terms, therefore, that your Record of Decision take the following form:

1. Place top program and budget priority on proving the immobilization option, with particular emphasis on the can-in-a-canister approach that presently appears to be the most promising, but also exploring other immobilization options, including ceramic as well as glass.

2. Make clear that when direct immobilization is validated, it will be used to its full potential---with the goal of disposing of all excess military plutonium, including pits, and not simply reserved to dispose of impure scraps and residues. If you are not prepared to rule out consideration of the MOX approach at this time, you can make clear that the United States is examining the MOX option for insurance purposes only and is not committed to a combination of the MOX and direct immobilization options. Failure to make such a clarification and commitment in your Record of Decision invites active opposition to planned research and development by DOE involving irradiation and post-irradiation experiments on MOX fuel pellets and assemblies in the United States and Canada.

3. Make clear that the United States regards plutonium as a dangerous liability, not as a valuable energy resource. We also ask you to make clear the United States is "strongly opposed" to commercial use of plutonium, and thereby deny European, Japanese and Russian plutonium interests any opportunity to exploit the dual-track approach to their advantage---as they already have begun doing to win public support for their MOX, reprocessing and breeder programs.

Madam Secretary, we hope that in your Record of Decision, you will exercise the leadership that is urgently needed at this critical stage of plutonium disposition by stating a clear preference for direct immobilization as the primary disposal strategy.

Thank you for your consideration of our views on this urgent matter. We would appreciate the opportunity to meet to discuss them with you.



Paul Leventhal
Nuclear Control Institute

Thomas B. Cochran
Natural Resources Defense Council

Carl Pope
Sierra Club

Daryl Kimball
Physicians for Social Responsibility

Tom Clements
Greenpeace International

Maureen Eldredge
Military Production Network

Lois Gibbs
Citizens Clearinghouse for Hazardous Waste

Amory Lovins
Rocky Mountain Institute

Bill Magavern
Public Citizen

Anna Aurilio
U.S. Public Interest Research Group

Jim Adams
Safe Energy Communication Council

Michael Mariotte
Nuclear Information and Resource Service

Courtney Cuff
Friends of the Earth

Gordon Clark
Peace Action

End Notes

1. "Controlling the Risks of Plutonium," New York Times, December 11, 1996. Back to document

2. Office of Fissile Materials Disposition, U.S. Department of Energy, Technical Summary Report for Surplus Weapons-Usable Plutonium Disposition ["TSR"], Rev. 1, October 31, 1996, Table ES-2, p. ES-11. Back to document

3. TSR, Table 4-1, p. 4-5; Table 4-3, p. 4-10; and Table 6-1, p. 6-3. Back to document

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