Nuclear Control Institute • Natural Resources Defense Council • Energy Research Foundation

July 1, 1997
The Honorable Federico F. Pea
Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585

Dear Secretary Pea:

We are writing to you to express our concern regarding the direction of DOE's research and development (R&D) program for the immobilization of excess plutonium. As long-time supporters of the immobilization approach, we greatly appreciate the fact that DOE has decided to immobilize a minimum of 8 tonnes (and perhaps all) of the declared excess plutonium inventory in a glass or ceramic form, and is devoting resources toward implementation of this approach. Given the urgency of the task of plutonium disposition, we believe that it is essential that the viability of can-in-canister (CIC) immobilization be demonstrated at the earliest possible date, provided that stringent standards of environmental protection and occupational safety can be met.

In view of this, we are concerned that the Office of Fissile Materials Disposition (MD) is considering a strategy that could cause unnecessary delays in carrying out a full-scale, "hot" demonstration of CIC. The Westinghouse Savannah River Company (WSRC) is proposing to carry out the project entirely at the Savannah River Site (SRS), and projects that an integrated hot demonstration could be conducted at the Defense Waste Processing Facility (DWPF) in May 2000. The Lawrence Livermore National Laboratory (LLNL) has floated a competing proposal that would establish a glovebox facility at LLNL for conducting equipment and process development, although for reasons of quality assurance the ultimate fabrication of cans for the hot demonstration would most likely have to be carried out at SRS. We understand that MD is supportive of the LLNL proposal, even though this approach would delay completion of the integrated hot demonstration at DWPF by one to two years and may cost several million dollars more. While we cannot assess whether the SRS timetable is a realistic one (and indeed, experience has shown that schedule predictions are often overly optimistic), we think the SRS proposal should be given favorable consideration.

In addition to the delays already anticipated, we fear that other factors associated with the LLNL proposal may slow down progress in immobilization. Unlike LLNL, SRS has accumulated a significant amount of experience with vitrification of radioactive materials at both pilot and production scales. Direction of scarce immobilization program funds to LLNL, rather than SRS, is not the best way to utilize this experience effectively.

Moreover, SRS, unlike LLNL, is a candidate site for the production-scale CIC immobilization facility, as well as the site where the integrated hot demonstration will be carried out. Thus it makes more sense to continue to develop the experiential base for plutonium immobilization at SRS, provided that this activity can be done safely and, if it utilizes F-Area facilities in the near-term, does not interfere with DOE's policy of phasing out reprocessing operations at the SRS canyons and deactivating them as quickly as possible.

We understand that the choice between the SRS and LLNL proposals is linked to some extent to the question of whether glass or ceramic is ultimately chosen as the matrix for plutonium immobilization. To our knowledge, no technical obstacles have arisen that would disqualify glass matrices for plutonium immobilization, and their greater flexibility relative to ceramics may render them superior for handling the impure forms of plutonium that have already been designated for immobilization. We believe that the remaining unresolved issues associated with glass performance are minor and should not be allowed to interfere with the goal of timely execution of an integrated hot demonstration.

Nonetheless, it is prudent to continue funding LLNL at present levels for further qualification of ceramic matrices as a back-up option in the event that unforseen problems are encountered in the glass development program. In this way, both approaches to immobilization can be pursued in a manner that ensures even-handedness and avoids delay. Also, since ceramics development is centered at LLNL, the final selection of immobilization matrix should be made by an independent panel whose members are chosen by your office, and not by a panel chosen by LLNL itself, which we understand to be the current plan.

If the SRS proposal will result in a cost-effective hot demonstration at an earlier date than the LLNL proposal, we urge you to give this fact, along with environmental, safety and health considerations, the highest priority in making your decision.

Edwin S. Lyman
Nuclear Control Institute

Thomas Cochran
Natural Resources Defense Council

Brian Costner
Energy Research Foundation

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