Outline for Discussion of Dilute and Dispose (D&D)

Transcription

1 Outline for Discussion of Dilute and Dispose (D&D) Rick Lee Chairman of the Governor s Nuclear Advisory Council Charlie Hess VP of High Bridge Associates Today we will present information on the key issues: History South Carolina s Position Cost of MOX D&D D&D Schedule Issues WIPP Obstacles WIPP capacity Criticality issues Inventory Operations Regulatory non-compliance Transportation Safeguards Closing

2 The Historical Path to the DOE s D&D Proposal The Plutonium Management and Dispositoning Agreement (PMDA) bi-lateral agreement with Russia. US has not terminated PMDA. It governs our approach to disposal of the 34 tons of plutonium. It requires the permanent transformation of the Pu into a form unsuitable for weapons. National Academy of Science study in 1994 to identified the best method to make the 34 tons of plutonium unsuitable for a nuclear weapon. Academy established the spent fuel standard which stipulated creation of a radiation barrier to prevent Pu from being used for weapons MOX and Immobilization were selected. The Academy did not select the currently DOE proposed dilute and dispose (D&D) method The MOX method was finally chosen and agreed to by the US and Russia in the 2010 Today the DOE wants to cancel MOX for budgetary reasons and has proposed D&D, mixing plutonium with Stardust, as its replacement 2

3 Academy s Role - Evaluate the D&D Method You are being asked to review a process not selected in 1994 which does not meet the Academy s original Spent Fuel Standard because the DOE has said it is cheaper. D&D - Has significant political risks related to changing administrations and policies Has a performance timeline that covers generations (+/-2047 if all the obstacles are overcome Has significant potential for a criticality in storage at WIPP Doesn t have an approved method for transportation Will require significant expansion at WIPP Does not meet the requirements of the PMDA Has multiple regulatory hurdles Consider the full life cycle process which must be completed to have a successful D&D program. Not just glovebox activity. Pu and Stardust can be mixed. It is the life cycle of D&D that is the problem

4 South Carolina Concerns Goal #1 Remove the plutonium from the State 2002 Agreement Between SC and DOE Build MOX to convert the plutonium the preferred method Get at least 1 ton of plutonium out of SC by 2015 Collect a penalty of up to $100M/yr for each year the removal goal not met DOE has a history of promises Better Faster Cheaper 1998 high level waste, Yucca, March 31, 2017 opening, Deal with South Carolina, WIPP 175,600 cubic meters of storage and 25 years This is the scenario we fear if D&D is implemented: MOX project is cancelled with a promise of D&D of the Plutonium The D&D program encounters technical, legal and performance issues Future DOE administrations get frustrated and cancel the D&D leave the Pu in place South Carolina has no jobs, no liquidated damage payments and becomes a defacto permanent plutonium storage site. If WIPP can t be used and MOX is closed what then At the root of this debate, the DOE says MOX is too expensive. We should ask whether the DOE or the contractor actually know what the cost will be for either MOX or D&D.

5 Category DOE Estimate ($B) Estimate to complete the MOX Project Contractor Estimate ($B) Delta ($B) Comments Total $17.2 $9.9 $7.3 This delta demonstrates the need for a real and unbiased rebaselining. Follow the GNAC recommendation. Escalation from 4% Inflation # $5.1 $0.4 $4.7 4% vs 2.3%. Project data does not support 4%. Obsolescence $0.5 $0.05 $0.5 Unclear how this number was developed or to what it applies. The 15 year MOX operational budget includes $300M for capital improvements and obsolescence in addition to $372M for parts and maintenance Risk $1.4 $0.6 $0.8 NNSA went from 85% to 95% - not typical for mature construction projects Level of Effort $4.7 $3.9 $0.8 Additional effort and cost caused by the 4% escalation rate schedule changes Other $0.5 $0.4 $0.1 Will be added to the contract Completion Date years The NNSA position is a project that is 70% complete will require 31 years to finish from today Normalizing brings both estimates very close. The delta is the combination of under reporting of cost escalation through a 4% inflation rate which increases the level of effort, cost and schedule; additional scope and obsolescence value

6 MOX vs D&D Is the Cost Comparison Accurate? Item MOX - Contractor Estimate Dilute and Dispose (Red Team Report) Cost to Process Plutonium $300M/yr based on actual costs in France DOE estimate in $365/yr. Latest DOE estimate with new costs added is $1B/yr Years to process all 34 MT 15 (2031 construction/hot operation complete - conversion complete years 2047 complete if all obstacles are overcome 272 according to Federal court 8 yrs per ton Construction: Number of Jobs/$ payroll 2,000 jobs /yr $2.2B Not Identified Operations Phase: Number of Jobs Not identified DOE Revenue and Economic Impact $1B Sales to Utilities $50B in Commercial Value (DOE Estimate) $0 $0

7 Is the D&D Schedule Achievable? Court documents of DOE plutonium expert states one ton could be removed at the earliest by the end of FY25 DOE only has one glove box at SR and it is not working, equipment problems, fire hazards Perhaps additional gloveboxes in To achieve 2025 DOE needs more people, shifts 2011 DOE issued Interim Action Determination for 585 kg to be down blended. In 6 years only blended 77kg and shipped 61kg. To meet the DOE schedule (if 5 years per ton per glovebox is possible) Savannah River will need 9 gloveboxes funded by Congress, purchased, assembled and fully operational without interruption from 2028 until years per ton equals 272 years to complete 34 tons DOE proposed in court plans to remove 1000 kg in 8 years. There is no record of production to support this assertion. Significant hurdles related to funding, regulatory approval, criticality analysis, permitting, transportation, classification of material, container approvals, treaty/bi-lateral agreement, Land Withdrawal Act action by Congress and related issues will delay the schedule or prevent the program

8 NNSA Plan for D&D of Plutonium from Court Records Attachment 1 NNSA Plutonium Down Blend Projection on One shift / Four Days per week Operation Fiscal Year PU Down Blended Annually (kg) Pu Down Blended Cumulative (kg) Pu Down Blended and Shipped Pu Down Blended and Shipped Cumulative (kg) Prior Years Since

9 WIPP Obstacles that will drive the cost of D&D and Reduce Probability of Success 1. EM has fully subscribed WIPP for TRU waste disposal GSA 9-17 Report - overcommitted 2. Expanding WIPP is extremely problematic and has not been started Potential cost is unknown Oil and gas wells limits horizontal Variations in geologic consistency requires additional study to go vertical 2 aquifers 3. Risk of reopening the licensing of WIPP to evaluate this new, unanalyzed Pu concentration could lead to unacceptable consequences for the nation Interveners convinced regulators Yucca Mountain should have regulatory concern of 1M years WIPP is licensed using the 10,000 year standard Perhaps new permit requirements would require remediation of current stored materials Where will the D&D plutonium go if that occurs no other place for the material

10 WIPP Obstacles Cont. DOE assumes that the Dilute and Dispose Option is less expensive than the MOX Project The real cost has not been identified Does not include WIPP extended operational costs Cost of expansion of WIPP is unknown Failed to include cost of new packaging and storage facility No shipping costs for the thousands of loads Extended life of equipment at WIPP exceeded design life Re-permitting costs required from a new environmental impact statement Scale up of Savannah River Operations for D&D costs were undervalued Accounting for the cost of the loss of the MOX asset The DOE s chosen container for the D&D option has not been analyzed for use in WIPP and is currently not approved Criticality Control Overpack (CCO)has not been thoroughly analyzed for use at WIPP by DOE Studsvik and Texas A&M said the CCO is not safe for use at WIPP CCO problem is the shape of the CCO which results in concentration of Pu-239 over three times the limit for ignoring criticality concerns (8KG of Pu) The amount of fissile plutonium being added to the repository is nearly three times the amount in the permit. 3 rd largest deposit of Pu in the world WIPP license assumed 21.1 ton of fissile material DOE has 61MTs of surplus Pu Without MOX there is no depository Environmental impact of 82 MT of Pu is significantly different from 21.1MT evenly distributed Original concentration was 0.12 kg/m3 vs the proposed 29.2 kg/m3 has not been analyzed

11 New Mexico Pu 239 Stockpile Ranking vs World Nuclear Powers after D&D Program Completed Country Tons of Stockpiled Weapons Grade Pu 239 on Hand Russia 128 United States 87.6 New Mexico 40 France 6.0 India 5.7 United Kingdom 3.2 China 1.8 Israel.86 Pakistan.2 North Korea.03 Information from the International Panel on Fissile Materials as of 2016

12 Former Secretary of US Dept of Energy and Governor of New Mexico Bill Richardson Statement on D&D New Mexicans and anyone else who cares about the safe reopening of the Waste Isolation Pilot Plant (WIPP) near Carlsbad should be concerned about recent reports of plans to move tons of dangerous nuclear weapons-grade plutonium to WIPP, and overwhelm WIPP s capability to clean up Cold War waste from sites in Washington, Idaho and elsewhere. This is not a good idea for a variety of reasons, but mainly that WIPP is not suitable to be a high-level waste dump. WIPP opened 16 years ago with my approval as Secretary of Energy, but only to accept low-level defense transuranic waste, or TRU, which is mainly contaminated gloves, tools, rags, assorted machinery and sludge. New Mexico could change WIPP s accounting so only the volume of the waste, and not its containers, counts against the cap. But WIPP s Environmental Impact Statement is based on its radioactive inventory. Even after 1,000 years, the added MOX plutonium would still cause WIPP to exceed its EIS curie basis by 430 percent. Former Governor and Secretary of the DOE, Bill Richardson, January

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14 The Academy Recommendation and the Future South Carolina s interest is simple we want the plutonium out of the state the fastest way possible. Demonstrated the many unresolved issues surrounding the use of WIPP for D&D. Even with all of the unresolved issues DOE is going to close MOX the only proven solution to the disposition of the plutonium. MOX does not face any of these issues it is simply a matter of finishing the project. Perform a real baseline cost estimate for MOX and D&D compare and then set public policy How will your report be used - The tie breaker respected organization not subject to politics. Two options: Disapprove D&D Conduct a real baseline evaluation of the cost to complete Appropriate more money but less than the DOE says Keep 2000 people working Create $50B in commercial value Meet the obligations of the PMDA and maybe bring the Russians back to the table Approve D&D SC likely becomes a permanent plutonium storage state Likely will not overcome the obstacles to implementation in the near future Close MOX, 2000 people unemployed Effectively ends the PMDA agreement with the Russians Ends monitoring of Russian Pu activities Reduce the possibility of future cooperation or agreements to control nuclear weapons and plutonium The D&D proposal is rife with technical problems, unproven cost basis and an unpredictable outcome. Urge you to conclude that D&D has a low probability of success. That MOX is the only viable solution to the disposition of the plutonium as your colleagues did in 1994.