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Time to Reconsider NNSA’s
Plutonium Fuel (MOX) Program
                 Tom Clements
      Nonproliferation Policy Director
     Alliance for Nuclear Accountability
          http://www.ananuclear.org/
               tel. 803-834-3084
         tclements@ananuclear.org
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-1990s
 Costs out of control and growing $5+ billion spent,
    perhaps $20 billion to go – NNSA refuses to give
    estimates
   No reactors secured to use MOX – no decision by
    TVA
   MOX is hotter, makes reactor harder to control,
    storage problems
   As weapons-grade MOX has never been used before,
    MOX testing in reactors will cause more delays
   Operating license of MOX plant being challenged
    before NRC
   Start-up of the MOX plant could be problematic; no
    operational schedule for MOX plant
   Unknown what MOX fuel would be produced first –
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 Carolina
   Options 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 by
       Tennessee Valley Authority
 Browns Ferry – Athens, AL
  GE Mark I Boiling Water    Sequoyah – Chattanooga, TN
Reactor – Fukushima design    Pressurized Water Reactor
Energy Northwest
Columbia 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 NNSA
 MOX plant construction           $389 million
 Other plutonium disposition $499 million
Total                         $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
Determination
Flexible Manufacturing Capability for
the Mixed Fuel Fabrication Facility
(MFFF)
 “
 April 1, 2011 -
 http://energy.gov/sites/prod/files/EIS-0283-S2-
 IAD-2011.pdf
 DOE 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 costs
   Delays, contingencies, accidents
   Decontamination 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,
    2036
   Need to repeat PWR test in Sequoyah?
   Thus, required MOX testing will cause severe delays
    and increase costs far beyond current projections
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 options
 Since 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 needed
   NNSA 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 Clements
 Nonproliferation Policy Director
Alliance for Nuclear Accountability
     http://www.ananuclear.org/
           tel. 803-834-3084
          cell 803-240-7268
     tomclements329@cs.com

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Reconsidering the Plutonium Fuel (MOX) Program

  • 1. Time to Reconsider NNSA’s Plutonium Fuel (MOX) Program Tom Clements Nonproliferation Policy Director Alliance for Nuclear Accountability http://www.ananuclear.org/ tel. 803-834-3084 tclements@ananuclear.org
  • 2. Admirable Goal: Dispose of 34 MT of surplus weapons plutonium – MOX chosen over disposition as waste
  • 3. L-Reactor at Savannah River Site, 1954-1988, plutonium and tritium for nuclear weapons
  • 4. Why is the MOX program failing? Where did it go wrong?  Continual delays since inception in mid-1990s  Costs out of control and growing $5+ billion spent, perhaps $20 billion to go – NNSA refuses to give estimates  No reactors secured to use MOX – no decision by TVA  MOX is hotter, makes reactor harder to control, storage problems  As weapons-grade MOX has never been used before, MOX testing in reactors will cause more delays  Operating license of MOX plant being challenged before NRC  Start-up of the MOX plant could be problematic; no operational schedule for MOX plant  Unknown what MOX fuel would be produced first –
  • 5. 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 Carolina  Options exists to manage plutonium and must be analyzed before more money is wasted, but NNSA is failing to develop a “Plan B”
  • 6. Proposed MOX reactors by Tennessee Valley Authority Browns Ferry – Athens, AL GE Mark I Boiling Water Sequoyah – Chattanooga, TN Reactor – Fukushima design Pressurized Water Reactor
  • 7. Energy Northwest Columbia Generating Station – Richland, WA GE Mark II BWR
  • 8. Plutonium Fuel (MOX) Plant at the DOE’s Savannah River Site – under construction by Shaw AREVA MOX Services
  • 9. 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
  • 10. Plutonium Disposition Funding, FY13 FY 13 budget request from NNSA  MOX plant construction $389 million  Other plutonium disposition $499 million Total $888 million House Approps $748 million ($132 million cut in committee, $17 million cut by full House) Senate Approps $888 million
  • 11. 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.”
  • 12. 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.”
  • 13. 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.‖
  • 14. 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 --
  • 15. 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
  • 16. Determination Flexible Manufacturing Capability for the Mixed Fuel Fabrication Facility (MFFF)  “ April 1, 2011 - http://energy.gov/sites/prod/files/EIS-0283-S2- IAD-2011.pdf DOE 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.”
  • 17. 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 costs  Delays, contingencies, accidents  Decontamination and decommissioning
  • 18. 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)
  • 19. 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, 2036  Need to repeat PWR test in Sequoyah?  Thus, required MOX testing will cause severe delays and increase costs far beyond current projections
  • 20. 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
  • 21. Time to halt MOX and explore other disposition options  Since 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 needed  NNSA must be directed to develop cheaper, quicker, safer options
  • 22. 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!
  • 23. Tom Clements Nonproliferation Policy Director Alliance for Nuclear Accountability http://www.ananuclear.org/ tel. 803-834-3084 cell 803-240-7268 tomclements329@cs.com