textfiles-politics/politicalTextFiles/reconfig.txt

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         Testimony of Dr. Arjun Makhijani on the Programmatic
 Environmental Impact Statement for the Proposed Reconfiguration
 of the Nuclear Weapons Complex, given at Washington, D.C., June
                            12, 1991.

                                     

     My name is Arjun Makhijani.  I am representing the Institute
for Energy  and Environmental  Research of Takoma Park, Maryland,
of which  I am  the president.   I appreciate this opportunity to
present my  views.   I am  submitting a written statement for the
record.

     There are  a number  of  overarching  issues  regarding  the
scientific  and   technical  content   and   integrity   of   the
Programmatic  Environmental   Impact  Statement   which  must  be
addressed  so   that  the   range  of   reconfiguration   options
corresponds to  the reality  of a  rapidly changing world and the
immense needs  for money  and technical resources of the problems
of nuclear  and non-nuclear  hazardous wastes  which have already
been created from past weapons production.  The scope proposed by
the DOE  for the  reconfiguration PEIS is fundamentally deficient
on a number of grounds.

     The  most  fundamental  deficiency  has  already  been  much
discussed as  part of  extensive and  repeated public comments on
the scope  of the  Environmental Restoration and Waste Management
PEIS   --    the    modernization    PEIS    and    Environmental
Restoration/Waste Management  PEIS need  to be a part of a single
interconnected document.   Despite these many comments the DOE is
single-mindedly pursuing  and original, flawed decision to do two
documents, each  highly flawed  in  its  own  concept,  in  large
measure because of the failure to properly consider nuclear waste
issues.

Risk Minimization

     In my  own  comments  on  the  scope  of  the  Environmental
Restoration and  Waste Management  PEIS, I  had noted  that  risk

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minimization should  be a  primary goal of the entire PEIS.  This
should include  the approach  to the  problem, the  way in  which
scenarios  are   set  and  may  other  aspects  of  environmental
evaluation.   One of the most basic aspects of risk minimization,
as I  noted in  my testimony  of January 14, 1991, is that it "is
not only  each risk  from each  operation that  is to be reduced.
Rather, a  programmatic statement  is done  precisely because  we
seek  to  minimize  overall  risk."    This  cannot  be  done  if
modernization, production for existing plants and risks from past
activities are considered separately.

     During that  same process  of comment  on the  scope of  the
Environmental Restoration  and Waste Management PEIS, some twenty
groups sent a letter to Secretary Watkins asserting that it would
be absurd  and unacceptable  to consider  a clean-up  plan  which
excluded waste generation from new weapons production activities.
It is  similarly absurd and unacceptable to exclude crucial waste
management aspects  from an  environmental impact statement about
modernization that claims to be a "programmatic" statement.

Waste Management Impacts

     There are  a number of practical problems which arise out of
the omission of critical waste management issues.  First, some of
the waste  generated may  need to  be sent  either to  high-level
waste repository  or to  a transuranic  waste repository.   Space
considerations for  these  repositories,  waste  forms,  geologic
isolation criteria  for specific  waste  forms,  and  many  other
factors will  impact on  the environment and the health of future
generations.   Yet, both  Yucca Mountain  and the Waste Isolation
Pilot Project  are excluded  from the  scope of the modernization
PEIS.   Indeed, the modernization PEIS does not even consider one
of the  most important  elements of the proposed modernization --
the New Production Reactor.

     The excuse  for excluding  the NPR  is the  same as that for
excluding Yucca  Mountain and  WIPP -- that they are the subjects
of separate  EIS processes.  Yet it  defeats  the  purpose  of  a
programmatic statement  if the  interactions and  implications of
critical aspects  of the  program are  not considered.   The  New
Production Reactor  will have  spent fuel  driver rods,  possibly
reprocessing wastes,  "low-level" wastes, decommissioning wastes,
as well  as emissions to the environment from routine operations.
While the  modernization PEIS  excludes the  NPR  and  associated
wastes from  its scope,  the NPR  draft  EIS  in  its  turn  also
excludes environmental  impacts from reprocessing driver rods, as
well as  high-level waste  repository impacts.   Thus,  among the
most serious  radioactive waste impacts of tritium production and
possible associated  uranium and  plutonium  recovery  have  been
neatly sidestepped  in this  way.   DOE should  have incorporated
these obvious  aspects into  a programmatic statement on its own.
Not only  has it  failed to  meet the  obvious, minimum  test  of
technical completeness for a programmatic statement, it continues

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to repeatedly  ignore suggestions  that would  enable a minimally
complete PEIS  to be  done.   This is  hardly indicative of a new
culture committed  to environmental  protection above  all  else.
Rather it  looks, walks  and quacks like the same old production-
oriented duck.

Unfunded Obligations from Past Production

     The U.S. government, through its DOE budget owes the nuclear
waste fund  a very substantial sum of money for disposal costs of
high level  radioactive waste  from  weapons  production  in  the
repository.  According to Ron Callen, the director of the Nuclear
Waste Program  Assessment office  of the  national Association of
Regulatory Utility  Commissioners, the DOE owes about one billion
dollars to  this  fund  and  this  amount  is  increasing,  since
interest on  this obligation  is accruing.    The  DOE  has  only
contributed $5  million into  this Fund  so far,  a laughable sum
compared to  even the  level of  obligation of about $500 million
which it itself acknowledges.

     The DOE  has also  reneged on  its promise in its first Five
Year Plan to contribute $200 million per year into this fund.  It
may be  that this  is due  to the general stringency in which the
present budgetary decisions are being made that these obligations
to the  Nuclear Waste  Fund are  not being  met.   But that  only
illustrates the  point that  I have  made that  it  is  precisely
because  there   are   substantial   unfunded   and   underfunded
liabilities relating to past waste and pollution that the DOE and
the U.S.  government should  set aside  all monies proposed to be
devoted  to  modernization  to  a  special  cleanup  fund.    The
obligations to the Nuclear Waste Fund should be met forthwith.

Size of the U.S. Nuclear Arsenal

     The requirements for nuclear weapons materials as defined by
the Pentagon  have been changing very rapidly due to the evolving
international  situation.    Thus,  a  couple  of  years  ago,  a
substantial  downsizing   of  the  arsenal  was  not  even  under
consideration.   Yet DOE  is now  considering scenarios  with  an
arsenal 15% of the size of the present one.  To propose to invest
huge sums  of money  in a  new weapons  complex  when  superpower
military tensions  have declined drastically and indeed when they
have even  collaborated on  settling conflicts  around the  world
would appear  to be  financially imprudent,  especially in a time
when other social and environmental needs are unmet.  This is not
mere speculation.   DOE  has in the past few years spent hundreds
of millions of dollars trying to restore facilities which are not
required due  to the  changing international  situation.  DOE has
yet to  analyze this  experience and examine its implications for
the modernization program.

     It must  be borne  in mind  that the  proposed  new  nuclear
weapons complex  is supposed  to provide for U.S. nuclear weapons

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requirements  until  around  the  middle  of  the  next  century.
Planning for  such a long time horizon is a chancy business under
any circumstances.   Doing  so in  the present circumstances when
the political  assumptions upon  which the arsenal has been based
have been  changing very  rapidly is  like trying  to predict the
course of  Alice in Wonderland as she enters the rabbit hole.  It
might be  an interesting  exercise, but  one wouldn't want to bet
tens of billions of dollars of public money on it.  It is all the
more  shocking   that  this  is  being  pursued  without  serious
consideration or discussion of the financial and political risk.

Non-proliferation Considerations

     The political  and military  risk could be considerable.  To
begin to  spend billions  of dollars  on a  new  nuclear  weapons
production complex  when the  United States  already  has  20,000
nuclear weapons could be regarded in the Third World, and perhaps
even in  certain  quarters  in  the  Soviet  Union  as  a  highly
provocative act  at a  time when the U.S. is proclaiming interest
in nuclear  non-proliferation and  superpower cooperation.   Even
before this,  the nuclear non-proliferation talks for the renewal
of the  treaty are  mired in  controversy over the failure of the
U.S. to  even negotiate  for a  comprehensive test  ban  and  the
practical failure  of the  superpowers  to  substantially  reduce
their nuclear arsenals.

     At the  same time  we have  the  spectacle  of  one  of  the
superpowers, the Soviet Union, asking for hundreds of billions of
dollars in  aid from  the other.  Such sums would hardly be given
serious consideration  if the  Soviet Union  did not  possess and
vast  nuclear  arsenal.    Much  less  would  major  Third  World
countries' leaders be given serious consideration should they ask
to be  present at  the economic  summit  of  the  major  economic
powers.   The  implications  of  this  are  surely  not  lost  on
potential nuclear weapons powers in the Third World.

     Even  these   few   basic   preliminaries   regarding   non-
proliferation questions  lead to the conclusion that embarking on
a modernization  of the  U.S. nuclear weapons complex is a highly
risky, politically  and militarily.   The  world has  changed too
fast  for   the  implications  of  this  to  be  thought  through
sufficiently to  arrive at  conclusions regarding the size of the
U.S.  arsenal,  even  according  to  criteria  of  the  Pentagon.
Indeed, the  very criteria  are in  flux; if  they are  not, they
should be because the world situation is changing so fast.

Conclusions

     The fact  that so  much has  been said  on  the  subject  of
integrating the  two  PEIS  statements,  that  it  makes  eminent
technical and environmental sense, and that the DOE has continued
to ignore  it outright  shows that  despite a  great deal of talk
about public  participation, change  in culture at DOE and so on,

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there has  been little  practical cognizance of public comment or
actual change in culture whenever it touches upon nuclear weapons
production.   The DOE continues to pursue goals and means that it
has already decided, regardless of public comment, so that public
comment is turning into a farce.

     In addition to the futile expenditures which DOE has already
made on  facilities which  it will never use, there is problem of
whether there  will be  sufficient money  and technical resources
available for  clean-up in  future  years.    Clearly,  there  is
considerable uncertainty  whether the  clean-up  program  can  be
adequately  funded   in  the   long-term,  even   if  DOE  cannot
efficiently spend  much more  money today.  It would therefore be
prudent to set aside considerable sums of money for the long-term
clean-up program  at the  present time  when there  is  no  clear
justification for spending money on new production facilities and
when  it   would  be   politically  prudent   to  await   further
developments over  the next  three years  in terms of U.S.-Soviet
relations and other international political and military issues.

     I recommend that all expenditures on modernization be halted
for three years and that such a scenario be explicitly considered
in the  modernization  PEIS.  The  total  halting  of  production
activities in  the present nuclear weapons complex should also be
part of  this scenario.   Activities related to reducing the size
of the  arsenal should,  of course  be  considered,  and  various
levels  should   be  incorporated,   as  part   of   these   same
considerations.   Any new  facilities needed for reducing arsenal
size, as  distinct from modernization should be clearly specified
and clearly  distinguished from new production or refurbishing of
old weapons  into new  designs.  If the DOE feels that any of the
facilities associated with the modernization PEIS may be relevant
to clean-up  these should be justified only on the grounds of its
being the  best available  technology for  clean-up and  have  no
production related  component.   It is  unacceptable for  DOE  to
continue to hide production under the guise of clean-up.

     During this  time  the  implications  of  the  U.S.  nuclear
program for  building a  new nuclear  weapons complex  for  waste
management, for  the environment,  for nuclear non-proliferation,
for U.S.-Soviet  relations,  for  contingencies  related  to  the
possible political  break-up of  the Soviet  Union should  all be
examined more  carefully and  thoroughly.  The latter aspects are
not the  charge of  the DOE,  of course,  but  the  modernization
program is  profoundly affected by them.  A more careful, prudent
course is much more desirable than the spectacle of spending huge
sums of  public money  on scenarios for arsenal size which change
wildly from year to year.

     The funds  now earmarked  for modernization  should  be  set
aside in  a fund earmarked for clean-up, analogous to the nuclear
waste fund.   In  fact,  I  recommend  that  some  of  the  funds
earmarked for  production should  be put  into the  nuclear waste

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fund to  which the  DOE has  already huge  unfunded  obligations.
This issue is worth considering in some detail as it concerns the
failure of  the DOE  and the  U.S. government  to attend to waste
management costs  for past  operations while  charging ahead with
plans for further production.

     Then instead  of having increasing labilities and wastes, we
will in  a position  that some  interest will be to accrue to the
clean-up program  from these  funds which  have been  set  aside.
This will  enable us  to begin  to meet  at least  in some modest
measure our  commitment to  future generations  of leaving them a
safer, healthier and more peaceful world.  Thank you.


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