A
Minority Opinion: Dissenting Statement of Gilinsky and Macfarlane

These remarks concentrate on the Global Nuclear Energy Partnership (GNEP), the most prominent U.S. Department of Energy (DOE) R&D program addressed in the committee’s report. The committee report criticizes DOE’s excessive eagerness to start building commercial-scale facilities when the technologies it relies on are still unproven.

However, the committee does not question the desirability of a substantial “closed” fuel cycle R&D program; moreover, it recommends a reprocessing and fast reactor R&D program along the lines of GNEP’s predecessor, the Advanced Fuel Cycle Initiative (AFCI). Nor does the committee question whether DOE and its laboratories should have a key role in developing the new fuel cycle technologies, despite DOE’s poor track record in developing commercial technologies.

Our own views on these issues may be summarized as follows: (1) commercial reprocessing and recycle will not help solve resource or waste or proliferation problems and are not sensible technical goals for the United States for the foreseeable future—we would close down GNEP and hold DOE R&D spending in this area to pre-2003 levels, before AFCI; and (2) DOE is the wrong agent for developing commercial technologies beyond the early laboratory stage—it has been unsuccessful in the past and its overall record of managing sizeable projects is very poor. Our thinking is explained below.

It is important to clear up one point at the outset. No one appearing before the committee argued that conserving uranium was a reason for pursuing reprocessing and recycle. The resource argument does not appear in the GNEP Strategic Plan. Instead, the Strategic Plan argues that reprocessing and fast reactors would solve the waste disposal and proliferation problems that bar expanded use of nuclear energy.

WASTE DISPOSAL: DEALING WITH SPENT FUEL

GNEP proposes to operate the nuclear fuel cycle so as to eliminate the need for more than one U.S. waste repository for the rest of the 21st century, even if the number of power reactors—now at about 100—increased by many hundreds. This goal drives the design of both GNEP reprocessing and fast reactor technologies. (By comparison, the “proliferation” constraint—no pure plutonium—is only a wrinkle on the basic pattern.)

GNEP’s waste logic runs as follows. A much larger U.S. nuclear program operated on the current once-through basis—with direct disposal of spent fuel—would require many repositories—say, one for every 100 reactors. But the struggle over DOE’s proposed Yucca Mountain nuclear waste repository proves, the argument goes, there will never be any additional repositories. We therefore need a closed fuel cycle that could accommodate a large expansion in nuclear power and still use only one repository.

GNEP plans to finesse Yucca Mountain’s design capacity—limited by temperature constraints on the repository rock—by leaving the heat-generating waste out of the repository. In particular, it would leave the hottest fission products (shown in red in Figure A-1) in surface storage. This does not expand repository capacity; it just puts less of each reactor’s waste inside. Of course, you could do that without GNEP by putting spent fuel in dry cask surface storage, which is essentially unlimited. But GNEP excludes this option. If Yucca Mountain fails to get a license and long-term surface storage is acceptable, the GNEP story collapses; and the same is true if people accept other repositories in the future.

Note that GNEP would leave the radioactive cesium-137 and strontium-90 on the surface. The half-lives of these isotopes are about 30 years, so they would have to remain in such storage for at least 300 years. There is no word on where DOE would store this material. As this would involve roughly as much storage capacity as would the original spent fuel, it is difficult to see any gain over the current once-through fuel cycle, especially considering that reprocessing would produce other waste streams as well.

The proposed technology is complex and would inevitably be very expensive. The design requirements for GNEP’s form of light water reactor (LWR) spent fuel reprocessing



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a minority opinion: dissenting statement of Gilinsky and macfarlane These remarks concentrate on the Global Nuclear Energy reactors—now at about 100—increased by many hundreds. Partnership (GNEP), the most prominent U.S. Department of This goal drives the design of both GNEP reprocessing and Energy (DOE) R&D program addressed in the committee’s fast reactor technologies. (By comparison, the “prolifera- report. The committee report criticizes DOE’s excessive tion” constraint—no pure plutonium—is only a wrinkle on eagerness to start building commercial-scale facilities when the basic pattern.) the technologies it relies on are still unproven. GNEP’s waste logic runs as follows. A much larger However, the committee does not question the desirability U.S. nuclear program operated on the current once-through of a substantial “closed” fuel cycle R&D program; moreover, basis—with direct disposal of spent fuel—would require it recommends a reprocessing and fast reactor R&D program many repositories—say, one for every 100 reactors. But the along the lines of GNEP’s predecessor, the Advanced Fuel struggle over DOE’s proposed Yucca Mountain nuclear waste Cycle Initiative (AFCI). Nor does the committee question repository proves, the argument goes, there will never be any whether DOE and its laboratories should have a key role in additional repositories. We therefore need a closed fuel cycle developing the new fuel cycle technologies, despite DOE’s that could accommodate a large expansion in nuclear power poor track record in developing commercial technologies. and still use only one repository. Our own views on these issues may be summarized as GNEP plans to finesse Yucca Mountain’s design capac- follows: (1) commercial reprocessing and recycle will not ity—limited by temperature constraints on the repository help solve resource or waste or proliferation problems and rock—by leaving the heat-generating waste out of the reposi- are not sensible technical goals for the United States for the tory. In particular, it would leave the hottest fission products foreseeable future—we would close down GNEP and hold (shown in red in Figure A-1) in surface storage. This does not DOE R&D spending in this area to pre-2003 levels, before expand repository capacity; it just puts less of each reactor’s AFCI; and (2) DOE is the wrong agent for developing com- waste inside. Of course, you could do that without GNEP by mercial technologies beyond the early laboratory stage—it putting spent fuel in dry cask surface storage, which is es- has been unsuccessful in the past and its overall record of sentially unlimited. But GNEP excludes this option. If Yucca managing sizeable projects is very poor. Our thinking is Mountain fails to get a license and long-term surface storage explained below. is acceptable, the GNEP story collapses; and the same is true It is important to clear up one point at the outset. No if people accept other repositories in the future. one appearing before the committee argued that conserving Note that GNEP would leave the radioactive cesium-137 uranium was a reason for pursuing reprocessing and recycle. and strontium-90 on the surface. The half-lives of these The resource argument does not appear in the GNEP Strate- isotopes are about 30 years, so they would have to remain gic Plan. Instead, the Strategic Plan argues that reprocessing in such storage for at least 300 years. There is no word on and fast reactors would solve the waste disposal and prolif- where DOE would store this material. As this would involve eration problems that bar expanded use of nuclear energy. roughly as much storage capacity as would the original spent fuel, it is difficult to see any gain over the current once- through fuel cycle, especially considering that reprocessing WasTe disPosal: dealiNG WiTh sPeNT FUel would produce other waste streams as well. GNEP proposes to operate the nuclear fuel cycle so as to The proposed technology is complex and would inevita- eliminate the need for more than one U.S. waste repository bly be very expensive. The design requirements for GNEP’s for the rest of the 21st century, even if the number of power form of light water reactor (LWR) spent fuel reprocessing 

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 REVIEW OF DOE’S NUCLEAR ENERGY RESEARCH AND DEVELOPMENT PROGRAM FIGURE A-1 50 GWd/MTIHM spent PWR fuel actinide and fission product decay heat. GWd, gigawatt days of thermal energy production; MTIHM, metric tonnes initial heavy metal; PWR, pressurized water reactor. SOURCE: R.A. Wigeland, T.H. Bauer, T.H. Fanning, and E.E. Morris. 2004. Spent Nuclear Fuel Separations and Transmutation Criteria for Benefit to a Geologic Repository. Paper presented at Waste Management 2004 Conference, February 29-March 4, 2004, Tucson, Ariz. fig A-1 are driven by the need to separate the various radioactive reduce the repository heat load and long-lived radioactive spent fuel constituents into separate streams to allow dif- isotopes. The main heat source after cesium and strontium’s this is a "fixed image," i.e., difficult to make changes ferent solutions for each. Aside from the radioactive cesium radioactivity subsides is americium-241. A new type of fast and strontium, the main ones are the plutonium and minor reactor would have to be designed to burn actinide fuel (and, actinides neptunium, americium, and curium (shown in blue secondarily, to produce electricity). To make the scheme in Figure A-1), which are destined for transuranic fast reactor work would take about one fast reactor for every four ordi- fuel. The longer-lived fission products, technetium-99 and nary LWRs, so about 100 fast reactors out of a total of, say, iodine-129, are to be sent to a geologic repository. There are 500 nuclear units. DOE acknowledges fast reactors would also assorted other radioactive products, including gases such be more expensive than LWRs; but in our opinion DOE still as tritium and krypton; uranium, which DOE wants to send underestimates the difference in capital and fuel costs. to a low-level waste repository; the cladding hulls, which are Further, as pointed out in Chapter 4, it would take many destined for a geologic repository; and other wastes from the cycles through the fast reactors to burn up a large fraction of reprocessing process. the actinides. That means, in effect, the spent actinide fuel Even if GNEP worked as planned it would likely exacer- from the fast reactors would be reprocessed many times (each bate the nuclear waste problem, at least for a long time. The time separating the hot fission products for surface storage). most important thing to remember is that the hottest fission The fast reactors’ spent fuel would need an entirely new and products would accumulate on the surface for hundreds of different reprocessing technology. Each cycle—residence years. These fission products are the reason that the NRC, in the fast reactor, cooling, reprocessing, and fuel fabrica- the last time it looked at separation and closed fuel cycles, tion—would take a good many years. So in the best of in 1996, recommended the need for geologic repositories. circumstances, many cycles would take the better part of a Putting less of the waste into a repository is a choice we century. But no one has yet fabricated such an actinide fuel, could make now without GNEP—we could leave the spent or designed a reactor to burn it, or developed a reprocessing fuel in surface dry storage and put nothing in a repository. scheme that could handle it. It is premature to be thinking Or we may be able to site other repositories. GNEP’s notion of going beyond the laboratory with reprocessing and fast that siting reprocessing plants and fast reactors and surface reactor technologies. storage for radioactive cesium and strontium would be easier Finally, the GNEP concept applies only if there is a mul- is fanciful. tifold expansion of nuclear capacity. However, even today’s The need for specialized fast reactors comes from GNEP’s optimistic projections involve a relatively small number of decision to burn the plutonium and minor actinides to further reactors (as of July 2007 no new reactors had been ordered);

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 APPENDIX A it would take hundreds more to get into the GNEP ballpark. fuel and send back spent fuel, why would they care whether Nor is it plausible that GNEP would facilitate such an the spent fuel is reprocessed or not? expansion. There is also the problem of creating, beyond the NPT, another division of nuclear countries, the As and the bs—or haves and have-nots. One indicator of the likely reaction is ProliFeraTioN: iNTerNaTioNal that there are lots of volunteers to be “A” countries but, ap- asPecTs oF GNeP parently, none to be a “B” country. The other main GNEP goal is antiproliferation, keeping There is another problem: consistency. It is evident from additional countries from getting bombs. There is a lot of the presentations to the committee that the administration confusion about this goal. GNEP’s fuel cycle is said to be does not intend to take back foreign spent fuel—for one “proliferation-resistant” because it would keep plutonium thing because doing so would jeopardize congressional mixed with other radioactive elements—the current choice approval of the initial parts of the GNEP program. So the is neptunium—to provide some self-protection. nonproliferation part of GNEP is really about other “sup- A committee member pointed out that mixing plutonium plier” countries—for example, France—taking back foreign with mildly radioactive neptunium is about as effective pro- spent fuel. It is naïve to expect that the existing reprocessing tection as mixing it with highly enriched uranium, because countries would adopt the more complicated and expensive neptunium-237 and uranium-235 have similar properties. GNEP technology. Therefore, the proposed addition of actinides to plutonium The ultimate nonproliferation argument for GNEP is that does not significantly increase the radiological barriers to only if the United States engages in large-scale reprocess- theft or make it significantly more difficult to use the mate- ing can it gain a seat at the table in international discussions rial as an explosive. This feature of the reprocessing scheme about the rules for nuclear energy use. The only thing to say is really intended to protect against theft and terrorism in about this is that the United States is always going to have a the supplier countries that have reprocessing plants and has seat at the table. nothing to do with antiproliferation. To sum up, the main point of our discussion is that The more important point—GNEP Strategic Plan (Section GNEP’s antiproliferation goal does not provide a rationale 2.1.2)—is that the GNEP Strategic Plan is based on there for DOE-NE R&D on reprocessing and fast reactors, whether being no technological fix that would make reprocessing in the context of GNEP or of the original AFCI. safe enough to spread to all countries. The GNEP Strategic We do want to acknowledge that while we disagree with Plan argues that antiproliferation dictates finding a way to its planned execution, we agree with some of GNEP’s un- keep most countries from engaging in reprocessing. Thus derlying assumptions about the dangers of easy access to GNEP would rely on fuel supply assurances to dissuade plutonium: (1) that all grades of plutonium, regardless of the most countries—call them b countries—from developing source, could be used to make nuclear explosives and must their own enrichment or reprocessing facilities. be controlled; (2) that widespread access to reprocessing, These countries would in effect lease fuel from a small no matter what the technology, is equivalent to access to number of A countries and return the spent fuel containing plutonium and poses an international security problem; (3) plutonium. In this scheme, only the A countries would repro- that widespread use of MOX fuel by both weapons states and cess and burn the plutonium-actinide mixture in their own nonweapons states is similarly risky, because the contained fast reactors, so the b countries would never have access to plutonium can be extracted relatively easily; and (4) that this nuclear explosive. GNEP assumes the b countries would even in the weapons states, the plutonium must be in a self- voluntarily forgo reprocessing to get assured access to fresh protecting form. fuel. But if this decision were based on economics, there maNaGemeNT would not be any reprocessing and recycle today (MOX, plutonium-based fuel, is several times as expensive as low- DOE-NE has no track record of successful project man- enriched uranium fuel). And there is no problem today for agement. We are unaware of any successful historical DOE any country adhering to the Non-Proliferation Treaty (NPT) model for bringing technology to a commercial scale, as in buying uranium fuel, so what advantage would GNEP as- the agency intended to do under GNEP; nor was NE able to surances have over current fuel contracts? DOE’s Office of provide an example. Nuclear Energy (NE) said the extra assurances would make In fact, DOE has suffered chronic project management it even more difficult than it now is for a country like Iran problems, as recorded in numerous GAO reports, the latest of which1 states as follows: to justify its own enrichment or reprocessing. That is not a serious reason to spend tens of billions of dollars. It is also unclear why, as GNEP argues, the United States 1 Government Accountability Office, Department of Energy Consistent has to reprocess in order to provide fuel assurances. Since Application of Requirements Needed to Improve Project Management, the GNEP idea is that the b countries would just lease fresh GAO-07-518, May 2007.

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 REVIEW OF DOE’S NUCLEAR ENERGY RESEARCH AND DEVELOPMENT PROGRAM The presentations to the committee by NE were also For years, GAO has reported on DOE’s inadequate manage- ment and oversight of its contracts and projects and on its fail- disappointing in how they reflected on NE management ure to hold contractors accountable for results. The poor per- capability. The briefing points on GNEP were all pluses and formance of DOE’s contractors has led to schedule delays and no minuses, and the DOE managers were defensive about cost increases for many of the department’s major projects. any possible deficiencies in their arguments and planning. Such problems led us to designate DOE’s contract manage- Perhaps it is natural that they underplayed the technological ment—defined broadly to include both contract administra- uncertainties and difficulties, but they also showed a lack tion and project management—as a high-risk area for fraud, of the intellectual flexibility and depth that managers need waste, abuse, and mismanagement in 1990. . . . Ultimately, to address a complicated new subject. Nor did cost enter in January of this year, we concluded that despite DOE’s ef- importantly into their thinking. We had a similar impression forts to address contract and project management weaknesses, of the Idaho National Laboratory presentations and reports. performance problems continued to occur on DOE’s major We also doubt that the DOE laboratories are able to de- projects, and DOE contract management remained at high risk for fraud, waste, abuse, and mismanagement. velop technology to full scale in a form that is attractive to the commercial world. The problem is that the laboratory Congress has taken note of this in reviewing the FY 2008 R&D environment is not sufficiently cost-conscious. The budget. laboratories have a lot of strengths, but developing commer- cial technology is not one of them.