Please include these additional remarks in your transmittal of the subject report to DOE’s Office of Nuclear Energy, Science and Technology.
Perhaps the greatest security threat to the United States today, and of paramount concern to American citizens since September 11, 2001, is that nuclear weapon-usable materials will be stolen, seized, or secretly diverted from nuclear facilities and then used by terrorists to develop and deliver a crude nuclear explosive device, or by a hostile proliferant state to develop more sophisticated nuclear weapons. This is not the time for the United States to be launching an international research effort to develop advanced nuclear fuel reprocessing technologies to be deployed some 30 to 50 years hence. This research effort will likely expand the availability of weapon-usable materials in other countries in the near-term, result in the training and employment of new cadres of scientist and engineers with expertise in actinide (including plutonium) chemistry and metallurgy, but not result in the deployment of new commercially viable nuclear power technologies.
Over the past decade there have been several cases in which individuals or groups of individuals have sought to steal weapon-usable materials from civil nuclear research institutes and naval fuel facilities in Russia. In some cases the individuals were apprehended after the nuclear material was removed from the facility or institute, and in some cases only after it left Russia. The risk of diversion of plutonium or highly enriched uranium from the civil nuclear fuel cycle facilities and government research facilities represents a greater risk today than the potential diversion of nuclear weapons. Al-Qaeda, Iraq, Libya and North Korea have all sought to acquire nuclear weapon-usable materials and nuclear weapons. The United States believes Iran, a signatory to the Non- Proliferation Treaty, is seeking to develop nuclear weapons and in this pursuit is using its2
civil nuclear power development program as a cover to train a cadre of nuclear scientists and to import dual purpose nuclear fuel cycle technologies, primarily from Russia. The United States should seek with great urgency the elimination of weapon-usable highly- enriched uranium and plutonium from commerce, and should not be pursuing a research agenda that will inevitably spread dual-purpose nuclear facilities and expertise around the world.
Two years ago DOE’s Office of Nuclear Energy, Science and Technology initiated the Generation IV (“Gen IV”) program to identify potential nuclear plant designs that in the 2030 time frame and beyond would be economically competitive with fossil-fueled plants, and safer and more proliferation resistant than existing nuclear plants The Office of Nuclear Energy asked the Nuclear Energy Research Advisory Committee (NERAC) to develop a technology roadmap to guide DOE research in this area. NERAC established a Subcommittee on Generation IV Technology Planning to develop the roadmap. In the process of developing the roadmap, the Office of Nuclear Energy organized the Generation IV International Forum (GIF), a consortium of ten countries, to pursue the cooperative development of advanced nuclear reactor and fuel cycle technologies. GIF participants participated in the development of the NERAC subcommittee’s Gen IV roadmap. The roadmap identifies six “next generation” reactor technologies, including gas-, sodium- , and lead alloy-cooled fast reactors, and advanced aqueous- and pyro- processing fuel reprocessing technologies. DOE has also transferred management oversight of the Idaho National Engineering and Environmental Laboratory (INEEL) from the Office of Environmental Management to the Office of Nuclear Energy and anointed INEEL as the lead laboratory for developing Gen IV reactor and fuel cycle technologies.
What began as a small conceptual-study research effort has ballooned into a major international research effort focused on the development of a variety of fast reactor concepts and reprocessing technologies. The original goalto develop a commercially competitive, cheaper, safer and more proliferation resistant nuclear power technologyhas been all but abandoned as the entrenched fast reactor and nuclear fuel reprocessing research communities have sought to promote their own research agendas as they developed the Gen IV roadmap in the GIF meetings. The overwhelming majority of GIF participants represent state-owned or heavily state-subsidized institutions and cannot be considered experts in developing or operating commercially competitive energy businesses...