Tom ClementsNonproliferation Policy Director

Alliance for Nuclear Accountabilityhttp://www.ananuclear.org/

tel. 803-834-3084tclements@ananuclear.org

Time to Reconsider NNSA’sPlutonium Fuel (MOX)

Program

Admirable Goal: Dispose of 34 MT of surplus weapons

plutonium – MOX chosen over disposition as waste

L-Reactor at Savannah River Site, 1954-1988, plutonium and tritium for nuclear weapons

Why is the MOX program failing? Where did it go wrong?

Continual delays since inception in mid-1990sCosts out of control and growing $5+ billion spent, perhaps $20 billion to go – NNSA refuses to give estimatesNo reactors secured to use MOX – no decision by TVAMOX is hotter, makes reactor harder to control, storage

problemsAs weapons-grade MOX has never been used before, MOX

testing in reactors will cause more delaysOperating license of MOX plant being challenged before

NRCStart-up of the MOX plant could be problematic; no

operational schedule for MOX plantUnknown what MOX fuel would be produced first – BWRs,

PWRs, other reactors?

MOX Problems, continued“MOX Services turnover rate increased from 15% in FY 2010

to 24% in FY 2011 with the result that the project has experienced a nearly complete turnover of construction management personnel in the last year. Finding experienced replacements has become difficult and expensive.”

Part of DOE pattern for mismanagement, cost overruns for large projects – price tag is unknown

Continues to pose proliferation risks by establishing plutonium infrastructure and introducing plutonium into commerce

Has become jobs program for South CarolinaOptions exists to manage plutonium and must be analyzed

before more money is wasted, but NNSA is failing to develop a “Plan B”

Proposed MOX reactors byTennessee Valley AuthorityBrowns Ferry – Athens,

AL

GE Mark I Boiling Water Reactor – Fukushima

design

Sequoyah – Chattanooga, TN

Pressurized Water Reactor

Energy NorthwestColumbia Generating Station –

Richland, WA

GE Mark II BWR

Plutonium Fuel (MOX) Plant at the DOE’s Savannah River Site –

under construction by Shaw AREVA MOX Services

Past NNSA budget requests for MOX plant – challenges from the start

FY2002: “…include the FY 2003 construction start, FY 2006 construction plant start-up, and FY 2007 full-scale operations start date (to meet the irradiation start date).“

Now: unspecified production start-up in 2018

FY2004: “The overall estimated cost for the MOX FFF is $1,622 M Total Estimated Cost (TEC). This amount includes the MOX FFF design budget ($171 M). The construction costs are estimated to be $1,451 M (including contingency).”

Now: $4.8 billion with no public update in years

Plutonium Disposition Funding, FY13

FY 13 budget request from NNSAMOX plant construction $389

millionOther plutonium disposition $499

millionTotal $888 million

House Approps $748 million

($132 million cut in committee, $17 million cut by full House)

Senate Approps $888 million

HOUSE ENERGY AND WATER DEVELOPMENT APPROPRIATIONS BILL, 2013 - REPORT

MOX plant cost increase from $4.8 to $5.4 billion or $5.7 billion? NNSA refuses to release new cost estimate.

“Construction continues to slip behind schedule due to unanticipated complexity of the work, poor contractor performance, delays in procurements, and the inclusion of additional work scope. The Department is now reporting internally that the total project costs could be understated by as much as $600,000,000 to $900,000,000, and that the project will overrun its projected completion date by months if not years.”

HOUSE ENERGY AND WATER DEVELOPMENT APPROPRIATIONS BILL, 2013 - REPORT

“However, due to the rampant cost growth that has been reported to construct and operate the MOX facility, the remaining funding available within this account is highly constrained and the amount has been reduced from the request. If the NNSA is unable to contain the escalating costs of the ongoing MOX project, funding for other priorities, such as the uranium enrichment project, will be severely limited. Similarly, the Committee will consider whether additional steps, including legislation, are necessary to protect the taxpayers’ investments in this program.”

SENATE ENERGY AND WATER DEVELOPMENT APPROPRIATIONS BILL, 2013 - Report

“Estimated operating costs have grown from $156,000,000 a year in fiscal year 2011 to $356,000,000 a year in fiscal year 2012 and now are estimated at $499,000,000 a year—an increase of more than 200 percent in just 2 years.”

“The Committee is also concerned about testing needed to use fuel made from weapons-grade plutonium for boiling water reactors. Testing may significantly increase costs and it is not clear whether the Nuclear Regulatory Commission [NRC] has sufficient resources to evaluate the testing data to make a determination about the safe use of this fuel.”

 

NNSA FY2013 request: FY 2014‐FY 2017: $3,591,260,000 to be requested for

plutonium disposition” –$900 million/year into the future-- Impact on defense nuclear nonproliferation funding --

GAO Report on MOX Plant Costs not Enough

Why has Congress given the MOX program a blank check?

HOUSE ENERGY AND WATER DEVELOPMENT APPROPRIATIONS BILL, 2013 – report requirement:

Department of Energy/Nonproliferation ... “Comptroller General review of MOX facility cost estimates”

In-depth review of plutonium disposition needed, including a review on non-MOX options

EIS-0283-S2: “Interim Action DeterminationFlexible Manufacturing Capability for the Mixed Fuel Fabrication Facility (MFFF)“

April 1, 2011 - http://energy.gov/sites/prod/files/EIS-0283-S2-IAD-2011.pdfDOE seeking more reactors beyond TVA, Energy Northwest“DOE proposes to modify the MFFF design to allow the flexibility necessary to manufacture fuel for a variety of reactor designs. The modifications would provide the MFFF with the capability to produce fuel for boiling water reactors (BWR) and next-generation light water reactors, in addition to the current capability for manufacture of pressurized water reactor (PWR) fuel.”

MOX costs – $20 billion yet to be spent?

Remaining MOX plant construction – about $3 billion

MOX plant operating costs - $499 million/year x 20 years = $10 billion

Payment to utilities to modify reactors, use MOX, store hotter irradiated MOX fuel for longer period

Support facilities, such as Waste Treatment Building

Administrative costsDelays, contingencies, accidentsDecontamination and decommissioning

MOX testing by TVA: AREVA trying to avoid testing as it would lead to delays and cost

increases

MOX made from weapons-grade plutonium is a “new fuel form” which must be tested in reactors, but AREVA and NNSA are trying to avoid this given schedule and cost impacts

Tony Ulses, branch chief of NRC’s reactor systems branch, said AREVA “has a steep curve ahead” to demonstrate to staff that MOX fuel made from weapons-grade plutonium can be licensed for use in US power reactors without testing

“In response to your question to DOE and MOX Services,  the decision whether or not to perform additional testing of MOX fuel assemblies will be evaluated and determined by reactor licensees and the NRC, and not by NNSA or its contractors.  At this time, the determination whether additional LTAs are required for licensing BWR MOX fuel has not been made.”  (message to me, Feb. 15)

MOX “lead test assemblies”- show stopper?MOX test in a PWR by Duke Energy from 2005-2008 was

terminated early and only tested for two 18-month cycles and not the normal three

No test of weapons-grade MOX has ever been done in a BWR (Browns Ferry)

Test in Browns Ferry could only be done after MOX plant at SRS produces the test assemblies, starting in 2018 at the earliest

Testing in Browns Ferry could take 6 years, plus cool-down, post irradiation examination = ~10 years

Browns Ferry 60-year licenses end in 2033, 2034, 2036Need to repeat PWR test in Sequoyah?Thus, required MOX testing will cause severe delays and

increase costs far beyond current projections

What about Russia?Breeder reactors can produce weapons-grade

plutonium, thus the U.S. is helping Russia’s ability to have capability to produce more plutonium

“Provide technical support to the DOE in meeting U.S. obligations to support disposition of weapon‐grade

plutonium in Russia. Provide U.S. technical oversight of work in Russia associated with the disposition of surplus

Russian weapon‐grade plutonium in the BN‐ 600 and BN‐800 fast reactors and support the implementation of IAEA verification activities in both the U.S. and Russia.”

- from NNSA FY13 request

Time to halt MOX and explore other disposition optionsSince the program’s inception in the mid-1990s,

not a single gram of plutonium has been disposed of beyond test amounts

Congress has not conducted sufficient oversight, allowing program to spin out of control

Situation could worsen with no reactors able to use MOX and costs increasing, time to pull back is now

Non-MOX options, such as immobilization of plutonium in high-level waste must be reexamined

Comprehensive GAO study neededNNSA must be directed to develop cheaper,

quicker, safer options

Supplemental EIS Coming Soon, “Cut MOX” letter to Sen. Alexander

The Supplemental EIS on plutonium disposition will be released before the end of July. It will analyze use of MOX in TVA reactors, as well as disposal of some contaminated plutonium as waste.In 2010, SEIS meetings were held in Athens, AL, Chattanooga, TN, Augusta, GA and New Mexico and we expect there will be hearings in the same places in August.

Please stay tuned and attend the SEIS meetings and make comments!Comment at TVA Board meeting – August 14, Chattanooga. (August 13 listening session…?)Send the “cut MOX” letter to Senator Alexander!

Tom ClementsNonproliferation Policy Director

Alliance for Nuclear Accountabilityhttp://www.ananuclear.org/

tel. 803-834-3084cell 803-240-7268

tomclements329@cs.com