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PLEASE URGE IDAHO AND WYOMING'S GOVERNORS AND CONGRESSIONAL DELEGATES TO REQUEST A NEW DRAFT EIS ON PLUTONIUM CONSOLIDATION IN IDAHO!!

This July the Department of Energy released its draft Environmental Impact Statement for plutonium production in Idaho and comments were taken by DOE through August 29. The EIS poorly done, failing to address many community concerns such as project need, worker safety, environmental protection (including emissions and waste production), and secrecy. The DOE is expected to release a final EIS sometime in 2006.

WHY DOE MUST DRAFT A NEW EIS

The DOE is under no legal obligation to respond to public comments on the Final plutonium EIS. What this means is if DOE fails to address the issues raised in the draft EIS, and the final EIS is still inadequate, DOE can move ahead with their plan and the public's concerns can be left unheard. The only option at that point is to sue the DOE once it signs a Record of Decision (of the final plan on what's going to happen in Idaho).

September 02, 2010

Subject:

The Department of Energy is proposing to consolidate all plutonium-238 production activities at the Idaho National Laboratory. The draft Environmental Impact Statement for plutonium consolidation was released for public comment in July and August. Because the EIS failed to address the following concerns, and because there are no legal requirements to include comments on the final EIS, I respectfully request that you urge the Department of Energy to submit a new draft EIS on plutonium consolidation. The DOE has failed to establish a need for the project, and its efforts to do so have been confusing if not misleading. On the one hand, the DOE has stated that half the Pu-238 produced would be used by NASA and half by national security entities. Regarding the NASA “need,” it must be noted it is extremely difficult to accurately assess NASA’s future needs. That agency’s focus changes regularly, and missions are frequently pursued and then scrapped. The United States has a two-decades-old agreement with Russia, our partner in a number of space initiatives, to purchase Pu-238 for non-national security purposes. Thus far the US has purchased 20 kg, and no reason to change that practice has been put forward. The national security “need” is shrouded in both secrecy and confusion. The primary justification for Pu-238 consolidation is to increase the production facilities’ security from external threats such as those posed by terrorists. But this justification is substantially undermined by the fact that, through consolidation, the DOE intends to remove Pu-238 activities from two National Nuclear Security Administration sites (Oak Ridge and Los Alamos), which are presumably highly secure because of their central roles in the US nuclear weapons complex, and centralize them at a Nuclear Energy site. It is also called into question by the DOE’s plan to continue Pu-238 activities at Los Alamos. The justification for Pu-238 production is not clear, either. On the one hand, the DOE has told Congress it “manages over $110 million annually from the National Aeronautics and Space Administration and the Department of Defense for the development of advanced radioisotope power systems for space exploration and national security missions” under the category of “work for others and reimbursable funding.” On the other, the DOE asserts in the draft environmental impact statement that the national security need is for “non-defense” purposes and has maintained that the DOD is not the current national security customer. At any rate, the DOE has also admitted that the national security mission could change without public notice. All this obfuscation has implications for independent oversight of the work proposed for INL and for future waste disposal. The Defense Nuclear Facilities Safety Board currently oversees Pu-238 activities at Los Alamos, and it has been highly critical of both particular practices and program management there. The DOE contends that the DNFSB will not have a role at the proposed INL facility because its national security mission is “non-defense.” But the high level of potential danger and the DOE’s own track record demand outsight oversight. Plutonium-238 is far more radioactive than “bomb-grade” Pu-239. That means a given amount of Pu-238 can do a lot more biological damage a lot faster than the same amount of Pu-239. We must be specially mindful of Pu-238’s inherent dangers because the DOE evidently intends to resort to aqueous reprocessing to extract the plutonium from target material. According to the DNFSB, “Aqueous processing of Pu-238 is a particular concern since it results in more particles of respirable size than nearly all other operations; this increases the potential consequences from certain upsets.” And there have been a number of “upsets” at the Los Alamos Plutonium Facility; the latest, on August 5, 2003, has yet to be cleaned up. The DNFSB concluded that one of the root causes was that the DOE “failed to balance management attention and resources between accomplishing the programmatic mission and providing an appropriate level of protection for the workers handling Pu-238.” That conclusion, that the DOE valued plutonium more than people, has broad implications. The draft EIS is not at all specific about what the entire Pu-238 project entails. But it does state that 20 cubic meters of transuranic waste, long a problem at INL, will be produced each year. The draft EIS asserts this additional waste will be shipped to the Waste Isolation Pilot Plant in New Mexico. And indeed, Los Alamos has shipped some of the transuranic waste from its Pu-238 work to WIPP, but only because it is classified as defense waste, the only stream allowed at WIPP. DOE spokespeople acknowledge the potential obstacles to permanent disposal. All waste disposition questions must be resolved before the project’s future can be decided. Our political leaders’ obligation to ensure that federal actions are justified goes beyond the scope of a National Environmental Policy Act review. The consolidation of Pu-238 activities at INL will cost at least $1.6 billion in construction and operation costs. Waste management and disposal, decommissioning and decontamination, and long-term stewardship and monitoring will rocket this cost even higher. A project of this size will necessarily divert attention from INL’s most important mission: cleaning up contamination that threatens Idaho’s water. Idaho and Wyoming are both special places. We are fortunate enough to live in a region with some of the most pristine wilderness and some of the most productive and important agricultural land in the country. Projects with so much potential for long and far-reaching implications, such as the production and handling of plutonium, should be scrutinized to the fullest to ensure worker, community, and environmental protection are a reality. I am familiar with the DOE’s track record and we cannot rely on its promise to “learn from past mistakes,” lest this project become another “past mistake” a few decades from now. I look forward to working with you to ensure the safety of the people of Idaho and Wyoming.
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