January 29, 2021

Galan: In response to the December 16, 2020 Notice of Intent referenced above, I write on behalf of the 10,000 members of the American Nuclear Society (ANS) and over 100,000 workers in the nuclear industry to provide comments on the scope of the proposed National Nuclear Security Administration (NNSA) SPDP EIS. [...] In the notice, NNSA proposes the dilute and dispose approach as the preferred alternative for disposition of the full 34 metric tons of surplus weapons-usable plutonium that is the responsibility of the SPDP. [...] From a nonproliferation perspective, it would be preferable to use the material as reactor fuel, thereby destroying some plutonium and transmuting much of the remainder so it would not be attractive for use in nuclear weapons. [...] • Use of dilute and dispose for all of the surplus plutonium would have significant adverse impacts on the Waste Isolation Pilot Plant (WIPP), the country’s only geological disposal facility for transuranic waste. [...] Accordingly, ANS recommends that NNSA consider use of the surplus plutonium as advanced reactor fuel as another alternative to be evaluated in the EIS.