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Global Nuclear Energy Partnership Requires Full Assessment of Impacts

UCS Comments on the Scope of the Global Nuclear Energy Partnership Programmatic Environmental Impact Statement

June 4, 2007

The Union of Concerned Scientists (UCS) continues to oppose the Department of Energy's Global Nuclear Energy Partnership (GNEP) in the strongest terms, as stated in its May 8, 2006 comments on the March 22, 2006 Advance Notice of Intent (ANOI). Although the proposal described in the January 4, 2007 Notice of Intent (NOI), is considerably different from the program described in the ANOI, our specific comments on the ANOI still continue to apply to the full-blown GNEP program, instead of the now-defunct Technology Development Program (TDP).

To reiterate, UCS calls for a full assessment of the impacts of the proposed action on the threats of nuclear proliferation and nuclear terrorism; a comprehensive assessment of the costs to taxpayers and ratepayers of the full GNEP program necessary to achieve its highly ambitious waste management goals; a full evaluation of radiological sabotage impacts, and an assessment of the impacts of storage and disposition of the reprocessed uranium that would be separated. UCS requests that all prior comments on the ANOI be addressed in the UCS Comments on the  Programmatic Environmental Impact Statement (PEIS).

UCS finds the revamped GNEP program to be even more objectionable than the initial GNEP proposal. In particular, what began as a research and development program into so-called "proliferation-resistant" reprocessing, fuel fabrication and burner reactor technologies has transmuted into a much more extensive program involving the near-term construction of industrialscale reprocessing and plutonium-based fuel fabrication plants and fast neutron reactors, all based on conventional, proliferation-prone PUREX technology or minor variants thereof. Although UCS does not believe that the technologies proposed for development under GNEP would actually be proliferation-resistant in any meaningful sense, UCS did appreciate DOE's acknowledgment that the growing stockpiles of separated plutonium around the world produced by ongoing reprocessing activities presents a major proliferation threat. However, the new GNEP proposal would undermine efforts to get those stockpiles under control.

The conventional facilities DOE is now planning under GNEP would commence operation before completion of R&D on the "proliferation-resistant" alternatives, and would somehow be later modified to utilize those alternatives. In the interim period, which could last for several decades, these conventional facilities would separate, store, transport and process vast quantities of vulnerable, direct-use nuclear weapon materials, of which only a small fraction would actually be utilized in reactor fuel and irradiated to a self-protecting state. The net outcome would be a major increase in the risk of diversion or theft of weapon-usable materials and an associated risk of nuclear terrorism.

The cost of providing security alone for the GNEP complex would be an enormous burden. In an attempt to reduce costs, it is likely that the Nuclear Regulatory Commission (if given licensing authority over GNEP facilities) will continue its efforts to substantially weaken physical protection and material control and accounting requirements for weapon-usable materials at civil facilities.  Such a relaxation of security requirements, presumably inconceivable in the post-September 11 era, has already begun as NRC seeks to change its rules to weaken the security requirements for storage of mixed plutonium-uranium oxide (MOX) fuel at reactor sites.

An even worse consequence of the GNEP program is the erroneous message that it has already sent around the world that reprocessing of spent fuel is not only useful but essential for the future of nuclear power. DOE's feeble protestations that it does not seek to encourage the additional production of "separated plutonium" is clearly disingenuous given that it has not required any commitment from its GNEP international "partners" such as France, Russia, China and Japan to halt the senseless growth of stockpiles of separated plutonium or to convert their reprocessing facilities to use "proliferation-resistant" technologies if such technologies become available.

And in any event, UCS and others have already extensively documented that the so-called "proliferation-resistant" technologies being proposed for development under GNEP will not be effective. By continuing to perpetuate the discredited notion that technical fixes can be found for the proliferation risks of reprocessing and the closed fuel cycle, DOE is providing cover for a large-scale reversal of the international reluctance to pursue reprocessing. A case in point is the spent fuel electrometallurgical treatment ("pyroprocessing") facility under development in South Korea, which may be sanctioned by the United States as a "proliferation-resistant" technology under GNEP even though many studies have shown that pyroprocessing presents serious proliferation concerns.[1]

Thus there is little doubt that despite its grandiose visions for the long-term, the outcome of the GNEP program for the foreseeable future can only be more separated weapon-usable materials and more risk. Therefore, UCS strongly endorses the "no-action alternative" and urges DOE to abandon the GNEP program before it does further damage to international non-proliferation and counter-terrorism efforts.

1. See, e.g., National Research Council, An Assessment of Continued R&D into an Electrometallurgical Approach for
Treating DOE Spent Nuclear Fuel, National Academy of Sciences, 1995, p. 27, 30.

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