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November 19, 1999

The Honorable Bill Richardson
Secretary of Energy
Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585

REQUEST FOR A NONPROLIFERATION IMPACTS ASSESSMENT OF THE DEPARTMENT OF ENERGY'S "ATW ROADMAP" REPORT

Dear Secretary Richardson:

We are writing to you in reference to the Department of Energy (DOE) report to Congress entitled "A Roadmap for Developing Accelerator Transmutation of Waste Technology," dated October 1999. The program outlined in this "ATW Roadmap" has very serious proliferation implications that have not been adequately addressed. In particular, the ATW Roadmap program clearly violates the current U.S. policy on reprocessing of commercial spent nuclear fuel (SNF). The Roadmap itself acknowledges that "the societal decision to proceed with deployment [of ATW] would require resolving a number of issues," including "interpretation of the U.S. policy concerning reprocessing as applied to ATW." However, it is foolhardy and wasteful to delay consideration of these issues until after hundreds of millions of dollars have been spent on additional research. Consequently, there is a great need now for a supplemental report that assesses in detail the numerous proliferation concerns left unresolved in the Roadmap.

The "ATW Roadmap" contains a detailed description of a $280 billion program for processing the entire U.S. inventory of spent nuclear fuel (SNF) from commercial power reactors, bombarding plutonium, actinides and selected fission products recovered from this process with neutrons in a system of accelerator-driven subcritical reactors, and repeatedly processing and recycling the spent targets from these reactors over the course of a century. In particular, it recommends the use of an aqueous separations process known as "UREX" for the initial partition of the uranium in SNF from fission products and other actinides, and electrometallurgical treatment (EMT) for the spent ATW targets. Based on its assessment of the feasibility and desirability of this enterprise, the ATW Roadmap recommends that a six-year, $281 million research program be initiated to further develop the concept.

Statements recently published by DOE appear to support the need for a nonproliferation impacts assessment for the ATW Roadmap. For instance, in the Nonproliferation Impacts Assessment for the Treatment and Management of Sodium-Bonded Spent Nuclear Fuel (SBSNF-NIA), issued in July 1999, it concludes that

"future actions involving technologies capable of producing (or being adapted to produce) weapons-usable material should be closely scrutinized to evaluate their consistency with their individual or cumulative impact on U.S. policy concerning reprocessing and nonproliferation."

The technologies which would be utilized in the ATW program fall into this category. In fact, the closed fuel cycle described by the Roadmap is practically identical to that of the Integral Fast Reactor (IFR) cycle, development of which was cancelled by DOE in 1994 because of nonproliferation concerns. The only difference is that instead of using liquid-metal-cooled, metal-fueled fast neutron reactors, ATW involves fast-neutron irradiation of liquid-metal-cooled, metallic targets by accelerator-driven spallation sources.

Besides full-scale deployment of ATW, the high-profile, expensive research program alone is likely to have negative impacts on U.S. nonproliferation efforts. Domestically, it could divert attention, resources and political momentum away from DOE's program to develop a geologic repository for spent fuel at Yucca Mountain. Internationally, it could send a signal to other nations that the U.S. is wavering in its commitment to direct disposal of spent fuel without reprocessing, thereby neutralizing one of the most powerful political arguments the U.S. has for discouraging other nations from reprocessing spent fuel and accumulating stockpiles of weapons-usable plutonium that cannot safely or economically be utilized in their nuclear power programs.

DOE itself has acknowledged this possibility. In the SBSNF-NIA, it states that DOE cancelled the IFR program because

"...continued U.S. research and development emphasis on developing technology for reprocessing and recycling plutonium --- even technologies more proliferation resistant than ... Plutonium-Uranium Extraction (PUREX) ... --- at a time when there was no requirement for such recycling to extend fuel supplies, was seen as potentially encouraging other countries to continue or expand their plutonium reprocessing and recycling programs, undermining the U.S. policy not to encourage plutonium reprocessing."

Since the fuel cycle technologies targeted for research and development in the Roadmap are essentially those of the IFR, it is clear from this statement that the proposed research program could undermine U.S. nonproliferation policy as well.

In view of these concerns, we find it an extremely serious oversight that the Steering Committee for the ATW Roadmap, while including representatives of four DOE program offices (Offices of Nuclear Energy, Science and Technology; Science; Defense Programs and Civilian Radioactive Waste Management), did not include any members representing the Office of Nonproliferation and National Security (NN). The perspective of this office is sorely needed, as the discussion of proliferation issues in the Roadmap is wholly inadequate. For instance, the Roadmap states that all ATW facilities would be under IAEA safeguards, but contains no discussion of the numerous practical difficulties, both technical and financial, that would be associated with the implementation of IAEA safeguards for such a vast system.

Therefore, we request that DOE immediately undertake, under the direction of the Office of Nonproliferation and National Security, a comprehensive assessment of the proliferation implications of the ATW Roadmap report. This should include an analysis not only of the full-scale ATW program as detailed in the Roadmap, but also of the six-year research program that it recommends. Similar assessments have been carried out by NN for several DOE programs, such as the National Ignition Facility, the disposition of surplus plutonium, and the treatment of sodium-bonded spent nuclear fuel. While the Roadmap does not yet represent a proposed action by DOE, its conclusions have grave implications for proliferation that must be fully addressed.

The nonproliferation impacts assessment should be released to the public in draft form for public comment, as similar ones have been in the past, and the final report should be available before DOE's budget request for FY 2001 is issued (February 2000), so that Congress may benefit from it as it considers whether to implement the recommendations of the Roadmap in the next budget cycle.

We would be happy to meet with you and your staff to discuss this issue further. Thank you for your time and consideration.

Sincerely,

Edwin S. Lyman, PhD
Scientific Director

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