Allison M. Macfarlane 
I, Allison Macfarlane, do hereby swear that the following is true to the best of my knowledge.
Brief Summary
Based on my experience in analyzing the technical methods for managing and disposing of excess weapons-usable plutonium, I conclude the following about the Department of Energy's current plans:
The Department of Energy's abandonment of the immobilization technology and therefore the dual-track or hybrid method of plutonium disposition, which was to burn some plutonium as mixed oxide (MOX) fuel in reactors and immobilize the rest in solid form, has put the entire disposition program at risk of failure. The whole idea behind the hybrid strategy was to ensure that if one method failed because of technical difficulties or public acceptance, for example, the other would be able to continue the important national security mission of disposing of this dangerous material.
Because the Department of Energy cancelled immobilization of plutonium, large quantities of the material must now be purified prior to fabrication into MOX fuel. This impure plutonium would not have required treatment were it to be immobilized. The purification process will require redesign of the MOX fuel fabrication facility to include additional processing facilities. Processing the impure plutonium will result in the production of new waste streams including transuranic wastes, low level nuclear wastes, and mixed wastes that will require treatment and storage. The processing will also result in worker radiation and chemical doses, and the potential for accidents. All of these factors should be analyzed in a new environmental impact statement.
In a February 2002 Report to Congress, the Department of Energy has claimed that due to the cancellation of the immobilization disposition strategy, it has been able to reduce the cost of disposing of 34 metric tons of plutonium by $2 billion. In fact, canceling immobilization only accounts for a cost decrease of about $1 billion. The other $1 billion in cost reductions comes from reductions in capital and operating costs for the Pit Disassembly and Conversion facility to be constructed at the Savannah River site. The Department of Energy has not explained how they are able to achieve such a cost reduction while processing the same amount of material through this facility as before and doing it at a faster rate. Costs to cover the now-necessary purification of impure plutonium are also not explicitly included in the Department's Report to Congress. It is not clear how they are able to acquire such a large savings.
In an unprecedented move, the Department of Energy has decoupled plutonium disposition from storage and made plans for its long-term storage independent of its ultimate disposition. In the past, the Department of Energy has always regarded long-term storage as one disposition method that was not seriously considered as viable in terms of meeting national security goals and international agreements. But on April 19, 2002, the Department of Energy selected the Savannah River site to be the location for long-term storage of plutonium.
Due to a number of factors, including problems with Russian plutonium disposition, a funding shortfall, and potential lack of private partners to burn MOX fuel, the plutonium disposition program may be substantially delayed. Delay will create long-term storage of plutonium at the Savannah River Site in South Carolina. Long-term storage of plutonium at the Savannah River site will result in environmental impacts that should be assessed. These impacts include worker and public doses and the potential for significant accidents. The Department of Energy does not yet have available necessary plutonium stabilization facilities at the Savannah River site, though they intend to move plutonium there as early as May 15, 2002.
Background and Qualifications
1. My current position is Senior Research Associate in the Security Studies Program at the Massachusetts Institute of Technology in Cambridge, Massachusetts. From November 1998 to December 2000, I served on a National Academy of Sciences panel on the Spent Fuel Standard and Plutonium Disposition. The final report of that panel was issued in November 2000.
2. I am trained as a geologist (PhD, MIT, 1992) specializing in structural geology, metamorphic petrology, and geochronology. I did geochemical analysis at MIT's research nuclear reactor as a post-doctoral fellow. I taught geology as a faculty member at George Mason University in Fairfax, Virginia for 5 years (from 1993-1998). For part of that time (1996-1997), I held a Bunting Fellowship at Radcliffe College and a Kennedy School Fellowship at Harvard University, where I studied science policy issues, in particular, those associated with plutonium disposition.
3. The following year (1997-1998) I held a science fellowship at Stanford University's Center for International Security and Cooperation, during which I did more research on plutonium disposition. At that time I published a number of papers on plutonium disposition. From 1998-2000 I held a Social Science Research Council – MacArthur Foundation fellowship in Peace and International Security at Harvard University's Kennedy School of Government.
Background on Plutonium Disposition
4. A decade ago, at the end of the cold war, it became clear that some of the plutonium that powered nuclear bombs would no longer be needed, due to bilateral treaties and unilateral pledges that promised reductions of nuclear warhead stockpiles. Both the United States and Russia worked towards a joint plan to deal with material considered a "clear and present danger" to international security by the National Academy of Sciences (National Academy of Sciences, Management and Disposition of Excess Weapons Plutonium, National Academy Press, Washington, D.C., 1994, p. 1). On September 1, 2000, the United States and Russia signed an historic agreement on the management and disposition of plutonium declared excess to military needs. The agreement sets forth a formal plan and schedule to deal with a combined total of 68 metric tons (MT) of weapon-grade plutonium.
5. In the United States, the U.S. Department of Energy (DoE) oversees the management of the surplus plutonium. In January, 1997, DoE issued a Record of Decision that officially accepted a dualtrack plan for plutonium disposition: some plutonium would be burned as mixed oxide fuel (MOX) in existing, domestic nuclear power reactors and the rest would be immobilized in a solid waste form. According to the National Academy of Sciences, who first recommended it, "Since it is crucial that at least one of these options succeed, since time is of the essence, and since the costs of pursuing both in parallel are modest in relation to the security stakes, we recommend that project-oriented activities be initiated on both options, in parallel, at once." (p.417, National Academy of Sciences, Management and Disposition of Excess Weapons Pu: Reactor-Related Options, National Academy Press, Washington, DC, 1995, p. 417). DoE echoed these reasons behind the hybrid approach in their 1997 Record of Decision on the Storage and Disposition of Weapons-Usable Fissile Materials Final Programmatic Environmental Impact Statement, "The additional expense of pursuing the hybrid approach would be warranted by the increased flexibility it would provide...to ensure that plutonium disposition could be initiated promptly should one of the approaches ultimately fail or be delayed." (Federal Register v. 62, no. 13, 62 FR 3014, January 21, 1997, p. 3027)
6. Furthermore, the United States wanted an alternative process to deal with plutonium in the military complex that was not suitable for use in nuclear reactors. In its 1997 Record of Decision, DoE affirmed that "approximately 30 percent of the total quantity of plutonium (that has or may be declared surplus to defense needs) would require extensive purification to use in MOX fuel, and therefore will likely be immobilized." (p. 3014)
7. The total 52.5 MT of U.S. plutonium available for disposal under the original plan originates from a variety of sources and will be disposed of through a number of different routes. DoE has indicated that 38.2 MT of the 52.5 MT is weapons-grade plutonium, the remainder being non-weapons grade.[1] Only 34 MT of weapons grade plutonium is covered in the Bilateral Agreement with Russia, and of that 25.6 MT of clean metal was to be burned as MOX fuel. The remaining 8.4 MT of impure metal and oxide was to be immobilized. The weapons-grade plutonium not covered by the Bilateral Agreement was to have alternative disposition routes; 0.6 MT of plutonium fuel was to be sent directly to a geological waste repository (when available) and 3.1 MT of residues with low concentrations of plutonium was to be sent to the U.S. Waste Isolation Pilot Project underground repository, located near Carlsbad, New Mexico. Finally, of the 14.3 MT of non-weapon-grade plutonium 6.9 MT of spent fuel were to be sent directly to a repository and 7.4 MT of impure metal, oxide and other forms were to be immobilized.
8. In 1996, DoE provided an inventory of plutonium declared surplus to military needs. The majority of the excess weapons-grade plutonium was located at two facilities, the Pantex facility in Amarillo, Texas (21.3 MT), and the Rocky Flats facility near Denver, Colorado (11.9 MT). The rest of the weapons grade plutonium was located at the Hanford site in Washington state (1.7 MT), the Los Alamos National Laboratory in New Mexico (1.5 MT), the Savannah River Site in South Carolina (1.3 MT), the Idaho National Engineering Laboratory (0.4 MT), and other sites (0.1 ton). Of a total of 12.8 MT of declared excess plutonium at Rocky Flats, the majority of it was weapons-grade (11.9 MT), and most of it was in metal form (6.6 MT), with the remainder as oxide (3.2 MT), in liquids (0.1 MT), and in residues (2.9 MT). Only the metal, oxide, and potentially the liquid forms would be available for inclusion in the Bilateral Agreement with Russia; the plutonium residues are scheduled to go to the Waste Isolation Pilot Project, though this is opposed by Senator Pete Domenici. The feedstocks for plutonium disposition are clean plutonium metals, oxides, impure metal and oxides, fresh plutonium-based reactor fuels and other forms (see Appendix I).
9. Under the plan presented in DoE's January 11, 2000 Record of Decision for the Surplus Plutonium Disposition Final Environmental Impact Statement (Federal Register, v. 65, no. 7, 65 FR 1608, January 11, 2000) all new facilities associated with the disposition of plutonium in the United States were to be located at the Savannah River Site in Aiken, South Carolina. DoE planned to construct a Pit Disassembly and Conversion Facility (PDCF), a MOX Fuel Fabrication Facility (MOX FFF), and an Immobilization Facility there. Duke Energy, Cogema, and Stone and Webster were selected as the contractors to run the MOX fuel fabrication facility. Duke Power, Virginia Power, Nuclear Fuel Services, Belgonucleaire, and Framatome Cogema Fuels were named as subcontractors. The light water reactors under consideration to burn the MOX fuel after it was processed at SRS were Virginia Power's North Anna 1 & 2 and Duke Power's McGuire 1 & 2 and Catawba 1 & 2. In 2000 Virginia Power pulled out of the deal, leaving only the four Duke Energy reactors.
Recent Changes in the Disposition Mission
10. 10. With the arrival of the George W. Bush administration in 2001, the entire plutonium disposition program underwent a review by the National Security Council. At the same time, the Bush administration drastically cut the funding for both the U.S. and the Russian portion of the program, which was to be financed by the United States and the G8 countries. In response to the funding cuts, the Office of Fissile Materials Disposition at DoE altered its U.S. plutonium disposition plan by deferring the immobilization track. It decided to spend the reduced funds on MOX, and then revive immobilization at a future date (See Fissile Material Disposition," www.llnl.gov/nai/ppac/fmd.html).
11. After weathering news reports in summer 2001 that the National Security Council intended to scrap the program altogether, they decided to continue the program in light of the events of September 11, 2001, (Phillipp Bleek, 2001, Administration May Abandon Plutonium Disposition Project, Arms Control Today, September, 2001).
12. In the fall of 2001 some members of Congress became concerned that the Bush Administration would drop the plutonium disposition program and required DoE to report to Congress on their plans for U.S. plutonium in the National Defense Authorization Act for FY2002 (Public Law 107-107). In February 2002, DoE issued its report to Congress, which outlined the revised program for U.S. plutonium disposition. The new program resulted in the elimination of the immobilization track of the hybrid strategy, forcing all 34 MT of weapons-grade plutonium covered by the Bilateral Disposition Agreement with Russia into the MOX track. Previously MOX was to handle only the pure plutonium (see Appendix I), in which gallium was the main impurity that required removal. Now impure plutonium would be directed into the MOX track, but this material must first be purified, removing all the contaminants before it can be safely used in a nuclear reactor. DoE plans to purify the plutonium through a process it calls "enhanced aqueous polishing," which is simply a form of reprocessing practiced in the past by DoE to obtain pure plutonium for weapons materials.
13. In its February 2002 Report to Congress (Report to Congress: Disposition of Surplus Defense Plutonium at Savannah River Site, February 15, 2002, National Nuclear Security Administration, Department of Energy), DoE asserts its 2002 plutonium disposition budget projections are $2 billion less than its 2001 estimates (See Appendix II). The reduction is due, they claim, to the elimination of the immobilization program, the streamlined design of the PDCF, and the shorter operating lifetimes of both the MOX FFF and the PDCF. The total cost of the disposition program in 2001 was estimated to be $6.2 billion versus $3.8 billion in the 2002 estimate (see Appendix II). Removing the immobilization facility from the 2001 numbers reduces the difference between the 2001 and 2002 budgets by $1 billion. The remaining $1 billion difference between the 2001 and 2002 cost estimates is from the PDCF, whose capital costs have been inexplicably halved (see Appendix II). Though additional modifications will be required of the MOX FFF, the costs presented in the congressional report do not reflect that. They also do not reflect the capital cost of dealing with the additional waste streams created by plutonium purification. Furthermore, the 2002 cost estimates do not reflect the additional operating time needed to (1) handle more material through the MOX FFF (34 MT versus 25.6 MT, (2) purify the surplus plutonium streams that would previously have remained untreated in the immobilization program, and (3) to handle the additional wastes generated from purifying the contaminated plutonium.
14. In the new plutonium disposition schedule outlined in DoE's 2002 Report to Congress, the PDCF start-up is delayed 3 years from that in both the Bilateral Disposition Agreement and DoE's 2001 Report to Congress, though it finishes its mission 2 years earlier. Somehow DoE is able to gain 2 years on the operating life while at the same time reducing the construction costs by half and the operating costs by 30%, all the while still processing the same or larger amount of plutonium metal into oxide. The MOX FFF is delayed by one year and has a shorter operating life for essentially the same cost as before. The 2001 MOX FFF operating schedule (14 years for completion) assumes a plutonium consumption rate of 2 MT/yr whereas the 2002 schedule (10 operating years) assumes a rate of 3.5 MT/yr. The higher consumption rate is not reflected in the operating costs.
15. Furthermore, the 2002 Report is not clear on exactly what new aqueous polishing facilities are required and how they fit into the cost estimates, other than to call the process "enhanced aqueous polishing." It is also not clear whether the 2001 estimates were just considering gallium removal by aqueous polishing or whether the facility would remove a larger variety of impurities.
Implications of Changes for SRS and South Carolina
16. There will be a number of potential environmental impacts from DoE's change in strategy. These include new waste streams from purifying plutonium for MOX use, additional radiation exposure to workers from purifying the plutonium, the potential for accidents from the plutonium purification process, increased staff required to do the work, increased electricity and water usage for plutonium processing, and the impacts from the construction of the purification facility. If plutonium disposition via MOX is not carried out, then there would be other impacts associated with the long-term storage of plutonium at SRS. These include the potential for accidents (including criticality events), and the potential for exposure to workers and the public.
17. New waste streams will be generated by the "enhanced aqueous polishing" that DoE will perform on at least 6.4 MT of impure plutonium. Previously DoE considered using some plutonium "polishing " processes to remove gallium and americium from "pure" plutonium metal and oxides destined for use as MOX fuel. (MOX fuel must fit stringent purity guidelines to be safely used in nuclear power reactors.) The addition of a large amount of "impure" plutonium will require more complex procedures to remove the impurities. These procedures involve first dissolving the impure plutonium in hot nitric and hydrofluoric acids and then using either or both solvent extraction and ion exchange to remove the impurities. This processing will result in a large amount of transuranic and low-level nuclear waste. Much of this waste will be liquid acidic solutions that will need to be solidified prior to disposal. There will also be solid wastes in the form of contaminated gloves, booties, glovebox tools, wipes, and HEPA filters. Appendix III lists DoE's expected wastes for the relatively simple processing of 33 MT of "pure" plutonium for MOX by removing gallium and a few other impurities; wastes generated from complex processing of the additional 6.4 MT of plutonium would be expected to greatly increase these numbers.
18. Though DoE has expertise in cleaning up impure plutonium for its weapons mission, it plans to build a new facility to deal with the impure plutonium, which will contain a variety of contaminants. These include: americium, uranium, neptunium, aluminum, barium, carbon, calcium, chlorine, iron, fluorine, gallium, potassium, magnesium, molybdenum, sodium, lead, silicon, tantalum, tungsten, and zinc (see Appendix IV for amounts).
19. DoE does not specify what is intends to do with the wastes produced over the long-term. For instance, in Appendix N of its 1998 Draft Surplus Plutonium Disposition Environmental Impact Statement it states "This waste stream is treated by evaporation to recover nitric acid, and the concentrated impurities are solidified for disposal."DoE does not go on to explain where at SRS the wastes will be stored and how and if they will eventually be moved off site. For the solid wastes, DoE states, "These wastes would then be packaged, assayed, and disposed of as appropriate."DoE does not specify what as "appropriate" means.
20. The workers who purify the plutonium and handle the waste streams will receive additional radiation and chemical exposures that will need to be quantified. In addition, DoE should perform analyses of accidents that could result from the enhanced aqueous polishing process. The presence of new waste streams, the potential for worker doses, and the potential for new accidents should be quantified in a supplementary environmental impact statement.
21. DoE's plutonium disposition program will result in the storage of large quantities of plutonium at the Savannah River Site while it awaits use. Indeed, in its most recent Amended Record of Decision on its Surplus Plutonium Disposition Program of April 19, 2002, DoE has decoupled plutonium storage and disposition, which is a major deviation from previous practice. In the past, DoE's Records of Decision always considered long-term storage of plutonium as one of the alternative plutonium disposition strategies and named it the "no action alternative," which it always rejected. DoE stated in its 1997 ROD "Taking into account the likely impact on Russian disposition activities, the no-action alternative [i.e., long-term storage] appears to be by far the least desirable of the plutonium disposition options from a non-proliferation and arms control perspective." (p. 3023) DoE asserts in its amended ROD that it must move the non-pit plutonium from the Rocky Flats facility "soon" to meet site clean-up objectives. It is not clear how this decoupling of storage and disposition will affect plutonium now located at other sites such as Hanford, Pantex, Los Alamos, and others.
22. DoE's original plan for non-pit plutonium at Rocky Flats (set forth in an amended Record of Decision, Federal Register, v. 63, no. 156, August 13, 1998) was to move it to Savannah River only if (1) the plutonium had already been stabilized, (2) DoE had completed the new Actinide Packaging and Storage Facility (APSF) to be built at SRS, and (3) SRS was selected for immobilization of non-pit plutonium. At that time, DoE had intended to move the 3.2 MT of oxide, 0.1 MT of plutonium in liquid, 2.9 MT of plutonium in residue, and 0.9 MT of non-weapons grade plutonium to SRS. Of that, only 3.3 MT are covered by the Bilateral Disposition Agreement and would be dispositioned at SRS via MOX.
23. By 1999, DoE had put construction of the APSF on hold. The Defense Nuclear Facilities Safety Board (DNFSB), a Congressionally-mandated watchdog group, complained in a May 14, 1999 letter to Bill Richardson, the then-Secretary of Energy that the "Actinide Packaging and Storage Facility (APSF) at the Savannah River Site (SRS) plays a pivotal role in DoE's plans ... to achieve the stabilization and safe storage of plutonium metal and oxide, as well as neptunium."
24. DoE continued with a rapid series of changes to the plutonium storage planning for SRS. In 2001, they cancelled the APSF due to cost concerns and decided to replace it with an already-existing building, Building 235–F. In their amended Record of Decision on the Interim Management of Nuclear Materials (Federal Register, v. 66, no. 18, January 26, 2001, p. 7889) they note that there are materials types "...that require, or could require, a new [i.e., does not yet exist at SRS] capability to stabilize and package the material to DoE' storage standard..." Clearly, SRS will need some kind of new stabilization facility. The DNFSB complained again in a March 23, 2001 letter to Spencer Abraham, the Secretary of Energy, over DoE's decision stating that DoE had selected a costly and inefficient option to upgrade Building 235–F. Later in 2001 DoE yet again amended their Record of Decision (Federal Register, v. 66, no. 212, November 1, 2001, p. 55166) and cancelled the Building 235-F facility, replacing it with the DNFSB's suggestion: modifying the FB-Line at SRS. In this latest amended Record of Decision, DoE notes that the Rocky Flats facility already has stabilization and packaging facilities unlike SRS (p. 55167). If that is the case, why is there a rush to move material from a site with adequate packaging and storage facilities to one without them?
25. Storage of plutonium at SRS will now be located at the K Area (Building 105-K). This storage facility was to hold up to 15 MT of non-pit plutonium, most of which was to come from the Rocky Flats facility in Colorado, for up to 10 years (Department of Energy, Supplemental Analysis for Storage of Surplus Plutonium Materials in the K-Area Storage Material Facility at the Savannah River Site, DoE/EIS–0229–SA–2, February, 2002). Under the amended Record of Decision of April 19, 2002, DoE is now considering opening the K-Area to storage of plutonium from other DoE sites and using the facility for a period of 20 years or more.
26. DoE has issued a Supplement Analysis for storing plutonium at K Area at SRS (DoE/EIS–0229–SA–2, February 2002), which it believes satisfies National Environmental Protection Act (NEPA) regulations and eliminates the need for further NEPA analysis. There are, however, numerous questions that the SA does not answer, and these issues bear directly on environmental impacts for the state of South Carolina. For instance, will there be adequate physical protection at the K Area? How many containers will be shipped and how well characterized are their contents? Is there going to be an adequate inspection program in place to detect dangerous helium build-up and heating in the containers? What potential accidents could happen? What will DoE do if they find a leaking container – where will they put it?
27. Most importantly, DoE states in the amended ROD of April 19, 2002, that it is building stabilization and packaging facilities in FB-Line at SRS, but it does not state when these facilities will be ready, yet DoE insists on beginning moving plutonium from the Rocky Flats facility as soon as May 15, 2002 (letter of April 15, 2002, from Energy Secretary Spencer Abraham to South Carolina Governor Jim Hodges). It is not clear that DoE can safely operate a storage facility without adequate stabilization and packaging facilities. If a container were to leak, for instance, how would it be stabilized?
28. DoE has claimed in multiple newspaper reports that part of the reason for moving the plutonium immediately from Rocky Flats to SRS is for national security reasons (see for example, David Firestone, Doubts Are Cast Over Plan for Converting Warheads,New York Times, April 19, 2002). But since by its own admission it will not even begin construction of the MOX FFF until 2004 (DoE's 2002 Report to Congress), there is no reason to move the material to meet the terms of the Bilateral Agreement until at least 2005.
29. Furthermore, if DoE is truly concerned about national security issues, it seems that they need to ensure the security of their own plutonium by providing a secure facility for plutonium storage. Not only must the facility itself be equipped with portal monitors, video cameras, etcetera, but due consideration must be made of all the additional construction workers who will be present building the MOX FFF, the PDCF, and the plutonium storage and stabilization facilities at SRS all the while plutonium is stored there.
Problems with New Disposition Program
30. There are a number of problems with the recently revised disposition program that may lead to delays in disposing of plutonium. Long delays in the program would result in DoE consolidating surplus plutonium at SRS and the facility becoming a long-term storage facility. DoE has already said as much in their amended Record of Decision of April 19, 2002. Delays may originate from numerous sources, but perhaps the biggest wild card is Russia.
31. The problem is that the United States and Russia agreed to conduct work in parallel in the Bilateral Agreement. Congress also requires parity in plutonium disposal, and will not likely continue to fund the program if the Russian program is seen to lag behind that of the United States. At the moment, Russia cannot afford to cover the costs of its plutonium disposition program, so the G8 countries have agreed to try to find the funds for the mission. They were supposed to present their payment plan at the G8 meeting in Genoa in July 2001, but failed to do so. Unless funding on the order of at least $2 billion is acquired in the next year or so, the program definitely will be delayed.
32. To make matters worse, the Russians are less inclined to move quickly on plutonium disposition due to disagreements between the United States and Russia over U.S. abrogation of the Antiballistic Missile Treaty and U.S. development of a national missile defense. Perhaps the biggest problem facing the timeliness of the Russian program at the moment is the lack of availability of a ready MOX fuel fabrication facility. The Russians were counting on the transfer of a never-used German MOX FFF to Mayak in Russia, but no funding was forthcoming from the G8 for this endeavor, so Siemens, the German company that owns the Hanau plant, began to decommission it this winter.
33. Another indication of delay in the MOX program is that both the Nuclear Regulatory Commission, which must license the MOX FFF and Duke Energy, whose reactors will burn the MOX fuel, have expressed doubts about the current plutonium disposition program. DoE lost two reactors it was depending on to burn MOX fuel in 2000 (North Anna in Virginia). Virginia Power, the utility that owns the reactors, claimed the decision to pull out was due to corporate restructuring. DoE now has to find more reactors to accommodate the increased MOX throughput from the cancellation of the immobilization program. At the moment, Duke Energy is the only utility providing reactors (two at McGuire and two at Catawba). If Duke Energy experiences long delays in using MOX fuel, due to delays in the start-up of the plutonium disposition program, if may no longer be in a position to provide this service to DoE.
34. Funding is another possible source of delay. Getting plutonium through SRS and into reactors depends on sustained Congressional funding over an almost twenty-year period, with large expenditures expected over the next ten years (see Appendix II). Finally, MOX faces legal challenges from a variety of non-governmental organizations that may lead to lengthy court battles, resulting in more delay. The bottom line is that the plutonium may reside in South Carolina far beyond the date of 2019 that DoE put forth in its recent Report to Congress with no guarantee it will ever leave once it is shipped there.
35. In its most recent amended Record of Decision of April 19, 2002, DoE states that "No final decisions regarding the MOX portion of the surplus plutonium disposition program will be made until DoE/NNSA has completed [an] analysis." At the moment, according to DoE, they have no firm disposition plans for any of their plutonium. Instead, DoE has reduced its chances for successfully completing the plutonium disposal mission by reducing the number of disposition strategies.
36. DoE's decision on plutonium disposition is similar to that made by Congress on high-level nuclear waste disposal. Congress had originally envisioned simultaneously characterizing and comparing three sites for a nuclear waste repository. Politics intervened and Congress decided to consider only one site, Yucca Mountain, Nevada. Where before the government could have presented the public with the best site of three, they now must make the case for a difficult site. DoE is similarly preparing to hamstring itself by selecting only one method for plutonium disposal.
The affidavit was written in support of a lawsuit of the State of South Carolina against the US Department of Energy on trying to prevent the shipment of plutonium to the Savannah River storage site. The Federal District Court hearing was in June 2002.
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