Center for Arms Control and Non-Proliferation

Comments for Programmatic Environmental Impact Statement on the Global Nuclear Energy Partnership (GNEP)

by Leonor Tomero [contact information]

December 10, 2008

This statement was presented by Leonor Tomero, director for nuclear nonproliferation, at the Department of Energy’s December 9 hearing on the Global Nuclear Energy Partnership (GNEP) Programmatic Environmental Impact Statement (PEIS).

STATEMENT TEXT

The alternatives assessed in detail under the PEIS do not meet the objectives of GNEP – namely the goals of contributing to solve the problem of nuclear waste and decreasing the risk of nuclear proliferation as it relates to nuclear energy – and do not take into account the costs and realistic time-frames of most alternatives while failing to include a detailed study of more promising alternatives.

Many of the alternatives assessed would likely exacerbate, not reduce, the proliferation risks of nuclear energy.

Reprocessing, which is considered in most alternatives discussed in the PEIS, increases the risk that bomb-grade material will fall into terrorist hands. By engaging in steps that remove many of the necessary barriers that prevent terrorists from acquiring material for a bomb and increasing the production of nuclear-weapons-usable material (or material that could be easily converted to pure plutonium), reprocessing increases the risk that this dangerous material will fall into the hands of terrorists. As long as the plutonium remains in spent fuel, it is extremely difficult to steal because of the intense radiation emitted by the fission products in the spent fuel.

France, the United Kingdom and Japan have accumulated over 192 metric tons of plutonium from commercial reprocessing (including foreign-owned plutonium), enough for 24,000 nuclear weapons. The Royal Academy of Sciences of the United Kingdom confirmed in 2007 its 1997 assessment that the plutonium should be disposed of safely given the growing risk of terrorism. As nuclear terrorism remains one of the gravest threat to U.S. security, the United States should pursue policies that will reduce the stocks of plutonium, rather than produce additional plutonium (or material that could be easily separated to yield nuclear weapons-usable plutonium, such as the U-Pu mix or the Pu-minor actinides mix).

Reprocessing weakens U.S. non-proliferation efforts, which is not addressed in the PEIS, and the Proliferation Assessment has not been released yet, despite promises that it would be released in the same time-frame as the PEIS.

Focus on reprocessing and fast reactor technology significantly undermines U.S. and international efforts to prevent the spread of reprocessing and uranium enrichment technologies to other countries. GNEP’s vision of supplier countries that would be allowed to reprocess has already encouraged other countries to seek this technology. In addition, the position that a handful of countries, including the United States, can engage in this process while all other countries should forego these technologies because of the risk that they could use them to produce material for nuclear weapons directly undermines decades of nuclear non-proliferation efforts. As an example, the United States successfully helped convince countries such as Brazil, Germany, South Korea and Taiwan not to reprocess. As a result, today, Japan is the only non-weapon state that reprocesses. Since 2006 when GNEP was announced, South Africa and South Korea have both expressed interest in acquiring reprocessing technology, and the United States has been cooperating with South Korea on these technologies for the past year pursuant to GNEP.

In addition, while the proposal to use CANDU reactors to burn the spent fuel from light-water reactors would not produce plutonium, it would promote the use of CANDU reactors which are generally considered less-proliferation-resistant than light-water reactors since CANDUs do not have to be shut down to be re-fueled and thus efforts to unload spent fuel rods for the purpose of reprocessing would be harder to detect and monitor.

The alternatives assessed in the PEIS do not appropriately assess the cost of the proposed alternatives.

A 1996 National Academy of Sciences report concluded that reprocessing and plutonium re-use would cost tax payers at least an additional $100 billion for waste disposal. The Department of Energy has not released any lifecycle cost estimate for reprocessing and plutonium re-use since a 1999 report that estimated the lifecycle cost of reprocessing and plutonium re-use in fast reactors at $280 billion. The economics of reprocessing do not justify a change from the current “once-through” fuel cycle practice.

GNEP envisions the deployment of dozens of fast reactors. These fast reactors are more expensive than the proliferation-resistant light water reactors that the United States and most countries with nuclear power currently use, and pose more safety risks to operate. The U.S. nuclear industry has not expressed willingness to share in the costs of, or make any investments in, reprocessing, thus the costs would be borne entirely by taxpayers and rate-payers.

The alternatives assessed in the PEIS do not contribute to solving the nuclear waste problem.

The alternatives that include the separation of materials through reprocessing – the re-use of some of the material in fast reactors and/or light-water reactors – do not provide a viable solution to the problem of nuclear waste and will create additional waste streams compared to the no-action alternative. The PEIS acknowledges that low-level waste will result from many of the alternatives proposed but does not propose where to store or dispose of this waste stream. Similarly, many of the proposed alternatives would separate the highly radioactive fission products Cesium and Strontium and propose to dispose of these fission products in a permanent geological repository or store them for 300 years (the PEIS does not provide a proposal of where these would be stored, though they would likely be stored at the reprocessing facility). Re-using plutonium in light-water reactors does not reduce the radioactivity of the waste compared to a once-through cycle (with no reprocessing).

In addition, the PEIS fails to consider the waste streams produced by reprocessing such as Iodine-131 and Iodine-133 and Iodine-129, which in the case of France are dumped into the North Sea. The promise that reprocessing and plutonium re-use in fast reactors will reduce the radiotoxicity of the nuclear waste is still an illusion as safe and economically-viable fast reactor technology is still decades away at best despite years of international research.

The PEIS considers for its 2010-2060 timeframe alternatives that are not yet available on a commercial scale.

Fast reactors and high-temperature gas cooled reactors still need significant research and development. In the case of fast reactors, most in the world have been shut down because of safety and operating problems, high costs and local opposition. Congress terminated plans to build the Clinch River fast breeder reactor in Tennessee in 1983 after costs increased to $8 billion, compared to the original projected costs of $400 million. However, several PEIS alternatives assume the deployment of dozens of these reactors (for example using 40% fast reactors).

Even the more proven technologies such as the available reprocessing technology have been failures. In 1972, the only operating reprocessing plant in the United States, located in West Valley, New York, was shut down after only six years of troubled operation in which it reprocessed the equivalent of only four months worth of the spent fuel currently produced by U.S. nuclear power plants. It left major environmental contamination, the commercial reprocessing part of which is costing over $5 billion to clean-up.

DOE plans for rapid deployment have been criticized. Both a 2007 National Academy of Sciences report and a 2008 Government Accountability Office report criticized the Department of Energy’s premature plans for reprocessing and fast reactors. In addition, a 2007 Keystone report – endorsed by representatives from the Nuclear Energy Institute and nuclear utilities including Exelon, Entergy, Southern Nuclear, GE Energy-Nuclear, Duke Energy and FPL – concluded that GNEP “is not a strategy for resolving either the radioactive waste problem or the weapons proliferation problem” and that “critical elements of the GNEP are unlikely to succeed.”

The PEIS dismissed and failed to consider seriously more promising alternatives.

By focusing on either technology that requires significant research and development or existing technology that does not reduce the radiotoxicity of nuclear waste but increases the cost, safety and proliferation risks of disposal, the PEIS dismissed more cost-effective, safer, more proliferation-resistant and less contaminating alternatives, such as the once-through fuel cycle without reprocessing and fast reactor research and development, interim dry-cask storage on-site and the development of renewable sources of energy. Several of these alternatives could be used immediately without further research and development.