1 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 2 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 3 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 4 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, 5 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 6 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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