April 27, 1999

The Honorable Bill Richardson
Secretary of Energy
U.S. Department of Energy
1000 Independence Ave., SW
Washington, D.C. 20585

Decision on FFTF

Dear Secretary Richardson:

We are writing on behalf of the Nuclear Control Institute concerning your impending decision on the future of the Fast Flux Test Facility (FFTF) at the Hanford site. Given the environmental, proliferation and economic risks associated with any attempt to restart this aging liquid-metal, fast-neutron reactor, we ask that you make the sensible decision and order decontamination and decommissioning (D&D) of FFTF to proceed without further delay.

The current push within DOE and on Capitol Hill to find a reason to restart the FFTF is hardly new. Its original mission as an integral part of the plutonium breeder development program ended with termination of that program by President Reagan in the early 1980s---a decision we advocated because DOE should not be in the business of developing proliferation-prone, uneconomic reactors that are designed to maximize production of plutonium. Despite the loss of its raison d'etre, the FFTF was nonetheless operated from 1982-1992 for a variety of ill-defined and ill-advised purposes, including fuel testing for the now-defunct Japanese breeder reactor, Monju. Energy Secretary O'Leary finally ordered shutdown of the FFTF in 1993 after a special panel advised her it could not identify a cost-effective mission for the reactor. But thanks to the FFTF's official "cold standby" status, the reactor's sodium coolant has been kept warm, allowing FFTF stalwarts to keep up the political pressure for finding a new mission that could justify restart at considerable taxpayer expense.

No new practical missions for the FFTF have been identified since 1993. Thus, two decades after FFTF was built it remains a reactor in search of a mission. Once again, a formal review of the FFTF's status is underway. The Nuclear Energy Research Advisory Committee has struggled mightily but cannot arrive at a consensus on the fate of the reactor. Such an outcome should be quite telling: there is simply no practical mission for this relic of the breeder program.

Now, a medical-isotope production mission is being put forward by some as justification for keeping the reactor on standby or for restarting it, but this is simply an inappropriate choice from a technical perspective. A medical-isotope mission for FFTF was previously eliminated by DOE. The National Institute of Medicine and experts from the University of Washington and Fred Hutchinson Cancer Research Center also hold the view that FFTF has no place in medical isotope production. Yet, such a role is being pitched as a last-ditch justification for preparing a new EIS and thereby perpetuating use of the reactor after all these years of having no mission.

Further confounding the attempt to save the FFTF are important, unanswered questions about the source of fuel for the reactor. The FFTF project team tells NCI that either highly enriched uranium (HEU) or plutonium-uranium oxide (MOX) could be used in FFTF. Although the FFTF team claims that enough unirradiated and irradiated MOX fuel exists from earlier days of FFTF operation to fuel the reactor for six years, we question that this old fuel is acceptably safe or appropriate for new missions.

Even assuming a six-year supply of fuel, the fuel source after that period is problematic at best. The Office of Fissile Material Disposition (MD) has not been tasked to consider the production of MOX fuel for FFTF, and we understand that no plans to consider fabrication of FFTF fuel have been initiated by MD itself. Any role for FFTF in plutonium disposition was ruled out in 1996 as being unable to meet the time-lines of the disposition program. The use of MOX in FFTF was briefly reconsidered last year when DOE mentioned using FFTF for tritium production [Appendix D, Surplus Plutonium Disposition Draft EIS, July 1998]. Now that you have wisely rejected use of the FFTF for tritium production, fuel supply for FFTF is no longer within MD's jurisdiction.

Any attempt to use MOX in the FFTF would increase the difficulties faced by an already challenged plutonium-disposition program. Development of MOX fuel for FFTF would require additional and unanticipated research, development, and construction expenditures because FFTF would require MOX fuel with a different plutonium concentration than the fuel being considered for use in light-water reactors. Development and fabrication of plutonium fuel for FFTF also would raise concerns over the use of MOX in a reactor closely associated with breeder-reactor development. Such a course of action could undercut U.S. Government attempts to discourage Russia from pursuing the use of weapons-grade MOX fuel in the BN-600 fast breeder or new fast reactors.

Use of highly enriched uranium (HEU) in FFTF reactor fuel or targets also would undercut DOE's Reduced Enrichment in Research and Test Reactors (RERTR) Program--a major U.S.-led international non-proliferation initiative that has made great strides toward eliminating use of HEU as fuel or target material. In particular, use of HEU in FFTF could destroy the credibility of U.S. negotiations with Russia to convert the plutonium production reactors at Tomsk-7 and Krasnoyarsk-26 to use fuel based on LEU, instead of HEU.

Given all the concerns and liabilities outlined above, we urge you to take decisive action and terminate the fruitless, decades-long search for missions for the FFTF. The time to close the reactor is now. All resources should be directed to efficient and safe decommissioning, which in itself will guarantee many jobs at the Hanford site. Further postponement of a final decision will be costly and will contradict U.S. policies opposed to pursuit of technologies associated with breeder development.

If you were now to authorize preparation of an EIS on FFTF, it would take at least another three years before a Record of Decision were issued and five years before the reactor could be restarted. This would push difficult decisions on FFTF beyond your watch, but taxpayers would be saddled with the cost of keeping the dormant reactor alive during this period. The most cost-effective and responsible path is to finally implement the shut-down decision made in 1993, and we call upon you to do so. Please act decisively for non-proliferation and reject any program that has as its goal the perpetuation and the restart of the Fast Flux Test Facility.

Thank you for your consideration of our views on this urgent matter. We look forward to your response, and we urge you to meet with us and other representatives of the non-proliferation community before coming to your decision.

Sincerely,

 

Paul Leventhal
President

Tom Clements
Executive Director