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Testimony of Dr. Arjun Makhijani on the Programmatic
Environmental Impact Statement for the Proposed Reconfiguration
of the Nuclear Weapons Complex, given at Washington, D.C., June
12, 1991.
My name is Arjun Makhijani. I am representing the Institute
for Energy and Environmental Research of Takoma Park, Maryland,
of which I am the president. I appreciate this opportunity to
present my views. I am submitting a written statement for the
record.
There are a number of overarching issues regarding the
scientific and technical content and integrity of the
Programmatic Environmental Impact Statement which must be
addressed so that the range of reconfiguration options
corresponds to the reality of a rapidly changing world and the
immense needs for money and technical resources of the problems
of nuclear and non-nuclear hazardous wastes which have already
been created from past weapons production. The scope proposed by
the DOE for the reconfiguration PEIS is fundamentally deficient
on a number of grounds.
The most fundamental deficiency has already been much
discussed as part of extensive and repeated public comments on
the scope of the Environmental Restoration and Waste Management
PEIS -- the modernization PEIS and Environmental
Restoration/Waste Management PEIS need to be a part of a single
interconnected document. Despite these many comments the DOE is
single-mindedly pursuing and original, flawed decision to do two
documents, each highly flawed in its own concept, in large
measure because of the failure to properly consider nuclear waste
issues.
Risk Minimization
In my own comments on the scope of the Environmental
Restoration and Waste Management PEIS, I had noted that risk
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minimization should be a primary goal of the entire PEIS. This
should include the approach to the problem, the way in which
scenarios are set and may other aspects of environmental
evaluation. One of the most basic aspects of risk minimization,
as I noted in my testimony of January 14, 1991, is that it "is
not only each risk from each operation that is to be reduced.
Rather, a programmatic statement is done precisely because we
seek to minimize overall risk." This cannot be done if
modernization, production for existing plants and risks from past
activities are considered separately.
During that same process of comment on the scope of the
Environmental Restoration and Waste Management PEIS, some twenty
groups sent a letter to Secretary Watkins asserting that it would
be absurd and unacceptable to consider a clean-up plan which
excluded waste generation from new weapons production activities.
It is similarly absurd and unacceptable to exclude crucial waste
management aspects from an environmental impact statement about
modernization that claims to be a "programmatic" statement.
Waste Management Impacts
There are a number of practical problems which arise out of
the omission of critical waste management issues. First, some of
the waste generated may need to be sent either to high-level
waste repository or to a transuranic waste repository. Space
considerations for these repositories, waste forms, geologic
isolation criteria for specific waste forms, and many other
factors will impact on the environment and the health of future
generations. Yet, both Yucca Mountain and the Waste Isolation
Pilot Project are excluded from the scope of the modernization
PEIS. Indeed, the modernization PEIS does not even consider one
of the most important elements of the proposed modernization --
the New Production Reactor.
The excuse for excluding the NPR is the same as that for
excluding Yucca Mountain and WIPP -- that they are the subjects
of separate EIS processes. Yet it defeats the purpose of a
programmatic statement if the interactions and implications of
critical aspects of the program are not considered. The New
Production Reactor will have spent fuel driver rods, possibly
reprocessing wastes, "low-level" wastes, decommissioning wastes,
as well as emissions to the environment from routine operations.
While the modernization PEIS excludes the NPR and associated
wastes from its scope, the NPR draft EIS in its turn also
excludes environmental impacts from reprocessing driver rods, as
well as high-level waste repository impacts. Thus, among the
most serious radioactive waste impacts of tritium production and
possible associated uranium and plutonium recovery have been
neatly sidestepped in this way. DOE should have incorporated
these obvious aspects into a programmatic statement on its own.
Not only has it failed to meet the obvious, minimum test of
technical completeness for a programmatic statement, it continues
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to repeatedly ignore suggestions that would enable a minimally
complete PEIS to be done. This is hardly indicative of a new
culture committed to environmental protection above all else.
Rather it looks, walks and quacks like the same old production-
oriented duck.
Unfunded Obligations from Past Production
The U.S. government, through its DOE budget owes the nuclear
waste fund a very substantial sum of money for disposal costs of
high level radioactive waste from weapons production in the
repository. According to Ron Callen, the director of the Nuclear
Waste Program Assessment office of the national Association of
Regulatory Utility Commissioners, the DOE owes about one billion
dollars to this fund and this amount is increasing, since
interest on this obligation is accruing. The DOE has only
contributed $5 million into this Fund so far, a laughable sum
compared to even the level of obligation of about $500 million
which it itself acknowledges.
The DOE has also reneged on its promise in its first Five
Year Plan to contribute $200 million per year into this fund. It
may be that this is due to the general stringency in which the
present budgetary decisions are being made that these obligations
to the Nuclear Waste Fund are not being met. But that only
illustrates the point that I have made that it is precisely
because there are substantial unfunded and underfunded
liabilities relating to past waste and pollution that the DOE and
the U.S. government should set aside all monies proposed to be
devoted to modernization to a special cleanup fund. The
obligations to the Nuclear Waste Fund should be met forthwith.
Size of the U.S. Nuclear Arsenal
The requirements for nuclear weapons materials as defined by
the Pentagon have been changing very rapidly due to the evolving
international situation. Thus, a couple of years ago, a
substantial downsizing of the arsenal was not even under
consideration. Yet DOE is now considering scenarios with an
arsenal 15% of the size of the present one. To propose to invest
huge sums of money in a new weapons complex when superpower
military tensions have declined drastically and indeed when they
have even collaborated on settling conflicts around the world
would appear to be financially imprudent, especially in a time
when other social and environmental needs are unmet. This is not
mere speculation. DOE has in the past few years spent hundreds
of millions of dollars trying to restore facilities which are not
required due to the changing international situation. DOE has
yet to analyze this experience and examine its implications for
the modernization program.
It must be borne in mind that the proposed new nuclear
weapons complex is supposed to provide for U.S. nuclear weapons
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requirements until around the middle of the next century.
Planning for such a long time horizon is a chancy business under
any circumstances. Doing so in the present circumstances when
the political assumptions upon which the arsenal has been based
have been changing very rapidly is like trying to predict the
course of Alice in Wonderland as she enters the rabbit hole. It
might be an interesting exercise, but one wouldn't want to bet
tens of billions of dollars of public money on it. It is all the
more shocking that this is being pursued without serious
consideration or discussion of the financial and political risk.
Non-proliferation Considerations
The political and military risk could be considerable. To
begin to spend billions of dollars on a new nuclear weapons
production complex when the United States already has 20,000
nuclear weapons could be regarded in the Third World, and perhaps
even in certain quarters in the Soviet Union as a highly
provocative act at a time when the U.S. is proclaiming interest
in nuclear non-proliferation and superpower cooperation. Even
before this, the nuclear non-proliferation talks for the renewal
of the treaty are mired in controversy over the failure of the
U.S. to even negotiate for a comprehensive test ban and the
practical failure of the superpowers to substantially reduce
their nuclear arsenals.
At the same time we have the spectacle of one of the
superpowers, the Soviet Union, asking for hundreds of billions of
dollars in aid from the other. Such sums would hardly be given
serious consideration if the Soviet Union did not possess and
vast nuclear arsenal. Much less would major Third World
countries' leaders be given serious consideration should they ask
to be present at the economic summit of the major economic
powers. The implications of this are surely not lost on
potential nuclear weapons powers in the Third World.
Even these few basic preliminaries regarding non-
proliferation questions lead to the conclusion that embarking on
a modernization of the U.S. nuclear weapons complex is a highly
risky, politically and militarily. The world has changed too
fast for the implications of this to be thought through
sufficiently to arrive at conclusions regarding the size of the
U.S. arsenal, even according to criteria of the Pentagon.
Indeed, the very criteria are in flux; if they are not, they
should be because the world situation is changing so fast.
Conclusions
The fact that so much has been said on the subject of
integrating the two PEIS statements, that it makes eminent
technical and environmental sense, and that the DOE has continued
to ignore it outright shows that despite a great deal of talk
about public participation, change in culture at DOE and so on,
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there has been little practical cognizance of public comment or
actual change in culture whenever it touches upon nuclear weapons
production. The DOE continues to pursue goals and means that it
has already decided, regardless of public comment, so that public
comment is turning into a farce.
In addition to the futile expenditures which DOE has already
made on facilities which it will never use, there is problem of
whether there will be sufficient money and technical resources
available for clean-up in future years. Clearly, there is
considerable uncertainty whether the clean-up program can be
adequately funded in the long-term, even if DOE cannot
efficiently spend much more money today. It would therefore be
prudent to set aside considerable sums of money for the long-term
clean-up program at the present time when there is no clear
justification for spending money on new production facilities and
when it would be politically prudent to await further
developments over the next three years in terms of U.S.-Soviet
relations and other international political and military issues.
I recommend that all expenditures on modernization be halted
for three years and that such a scenario be explicitly considered
in the modernization PEIS. The total halting of production
activities in the present nuclear weapons complex should also be
part of this scenario. Activities related to reducing the size
of the arsenal should, of course be considered, and various
levels should be incorporated, as part of these same
considerations. Any new facilities needed for reducing arsenal
size, as distinct from modernization should be clearly specified
and clearly distinguished from new production or refurbishing of
old weapons into new designs. If the DOE feels that any of the
facilities associated with the modernization PEIS may be relevant
to clean-up these should be justified only on the grounds of its
being the best available technology for clean-up and have no
production related component. It is unacceptable for DOE to
continue to hide production under the guise of clean-up.
During this time the implications of the U.S. nuclear
program for building a new nuclear weapons complex for waste
management, for the environment, for nuclear non-proliferation,
for U.S.-Soviet relations, for contingencies related to the
possible political break-up of the Soviet Union should all be
examined more carefully and thoroughly. The latter aspects are
not the charge of the DOE, of course, but the modernization
program is profoundly affected by them. A more careful, prudent
course is much more desirable than the spectacle of spending huge
sums of public money on scenarios for arsenal size which change
wildly from year to year.
The funds now earmarked for modernization should be set
aside in a fund earmarked for clean-up, analogous to the nuclear
waste fund. In fact, I recommend that some of the funds
earmarked for production should be put into the nuclear waste
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fund to which the DOE has already huge unfunded obligations.
This issue is worth considering in some detail as it concerns the
failure of the DOE and the U.S. government to attend to waste
management costs for past operations while charging ahead with
plans for further production.
Then instead of having increasing labilities and wastes, we
will in a position that some interest will be to accrue to the
clean-up program from these funds which have been set aside.
This will enable us to begin to meet at least in some modest
measure our commitment to future generations of leaving them a
safer, healthier and more peaceful world. Thank you.
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