Global Nuclear Energy Partnership: DOE Should Reassess Its Approach to Designing and Building Spent Nuclear Fuel Recycling Facilities
Published: 2008-04-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Department of Energy (DOE) proposes under the Global Nuclear Energy Partnership (GNEP) to build facilities to begin recycling the nation's commercial spent nuclear fuel. GNEP's objectives include reducing radioactive waste disposed of in a geologic repository and mitigating the nuclear proliferation risks of existing recycling technologies. DOE originally planned a small engineering-scale demonstration of advanced recycling technologies being developed by DOE national laboratories. While DOE has not ruled out this approach, the current GNEP strategic plan favors working with industry to demonstrate the latest commercially available technology in full-scale facilities and to do so in a way that will attract industry investment. DOE has funded four industry groups to prepare proposals for full-scale facilities. DOE officials expect the Secretary of Energy to decide on an approach to GNEP by the end of 2008. GAO evaluated the extent to which DOE would address GNEP's objectives under (1) its original engineering-scale approach and (2) the accelerated approach to building full-scale facilities. GAO analyzed DOE plans and industry proposals and interviewed DOE and industry officials concerning the pros and cons of both approaches.
section_title: What GAO Found
paragraphs: DOE's original approach of building engineering-scale facilities would meet GNEP's objectives if the advanced technologies on which it focused can be successfully developed and commercialized. The advanced technologies would reduce waste to a greater degree than existing technologies by recycling radioactive material that a geologic repository has limited capacity to accommodate. The advanced technologies would also mitigate proliferation risks relative to existing technologies by increasing the difficulty of theft or diversion of weapons-usable nuclear material from recycling facilities. Nonetheless, DOE's engineering-scale approach had two shortcomings. First, it lacked industry participation, potentially reducing the prospects for eventual commercialization of the technologies. In particular, the approach included some technologies that may introduce unnecessary costs and technical challenges while creating waste management challenges; industry representatives have questioned whether such technologies could be commercialized. Second, DOE's schedule called for building one of the recycling facilities (a reprocessing plant for separating reusable materials from spent nuclear fuel and fabricating recycled fuel) before conducting R&D on recycled fuel that would help determine the plant's design requirements. This schedule unnecessarily increased the risk that the spent fuel would be separated in a form that cannot be recycled. The other two facilities DOE had planned to build (an advanced reactor for using recycled fuel and an R&D facility) would allow DOE to conduct R&D that existing DOE facilities have limited capability to support. DOE's accelerated approach of building full-scale facilities would likely require using unproven evolutions of existing technologies that would reduce radioactive waste and mitigate proliferation risks to a much lesser degree than anticipated from more advanced technologies. Two of the four industry groups that have received funding under GNEP proposed evolutionary technologies for recycling spent fuel in existing reactors even though the GNEP strategic plan ruled out such technologies. While the evolutionary technologies could allow DOE to begin recycling a large amount of spent fuel sooner than under its original approach, fully meeting GNEP's waste reduction and nonproliferation objectives would require a later transition to more advanced technologies. Two other industry groups proposed technologies that would address GNEP's waste reduction and nonproliferation objectives by using technologies that are not mature enough to allow DOE to accelerate construction of full-scale recycling facilities. Under any of the proposals, DOE is unlikely to attract enough industry investment to avoid the need for a large amount of government funding for full-scale facilities. For example, the industry groups have proposed that DOE fund an advanced reactor, which DOE and industry officials expect would at least initially be more expensive than existing reactors to build and operate and thus not be commercially competitive. DOE acknowledges the limitations of its accelerated approach but cites other benefits, such as the potential to exert more immediate international influence on nonproliferation issues.

section_title: Letter
paragraphs: The Global Nuclear Energy Partnership (GNEP) is an administration  proposal, announced in February 2006, to encourage the expansion of  nuclear energy while addressing the burden of spent fuel disposal and the  risk of nuclear weapons proliferation. According to the Department of  Energy (DOE), which is responsible for implementing GNEP, nuclear  energy is critical to meeting the growing demand for electricity, both  domestically and internationally. DOE considers nuclear energy to be the  only proven technology that can reliably generate large amounts of  electricity without air pollution or emissions of greenhouse gases.  However, the spent fuel from nuclear power plants remains radioactive for  many thousands of years and requires proper disposal to protect public  health and the environment. To date, the nation’s commercial nuclear  power plants have created more than 50,000 metric tons of this radioactive  waste, which is currently stored at sites around the country subject to  oversight by the Nuclear Regulatory Commission (NRC). Recognizing that  the accumulation of spent nuclear fuel is a national problem, the Nuclear  Waste Policy Act of 1982 established federal responsibility for its  permanent disposal. In particular, the act directed DOE to construct an  underground geologic repository to dispose of spent nuclear fuel and  other high-level radioactive waste.
In the quarter century since passage of the Nuclear Waste Policy Act, the  problem of spent fuel disposal has not been resolved, and it is likely to  grow. DOE is preparing a license application to NRC for a nuclear waste  repository at the Yucca Mountain site in Nevada, but the project is decades  behind schedule. DOE’s estimate of the federal government’s liability for  the department’s failure to begin accepting spent nuclear fuel from  existing commercial nuclear power plants was $11 billion as of September  30, 2007. In addition, DOE estimates that the amount of spent nuclear fuel  produced by commercial nuclear power plants will reach Yucca  Mountain’s statutory limit of 70,000 metric tons by about 2010. The gap  between the statutory limit on the amount of spent fuel that DOE may  dispose of in the repository and the amount produced by nuclear power  plants will increase as existing plants continue to operate and as utilities  submit license applications for new plants to meet the nation’s growing  electricity demand. In relation to this problem, the Nuclear Waste Policy  Amendments Act of 1987 required the Secretary of Energy to report to the  President and Congress not later than January 1, 2010, on the need for a  second repository. The director of DOE’s Office of Civilian Radioactive  Waste Management, which is responsible for the Yucca Mountain project,  has said that if current circumstances persist, the Secretary’s report will  indicate the need for a second repository.
Furthermore, the international development of nuclear energy increases  the risk, highlighted by revelations about the nuclear programs of Iran and  North Korea, that other countries might develop nuclear weapons. The  proliferation risk stems in part from the fact that two of the technologies  associated with a civil nuclear industry—spent fuel reprocessing and  uranium enrichment—can also produce weapons-usable nuclear material.  In particular, existing reprocessing technologies chemically separate  plutonium from other components of spent fuel. Commercial  reprocessing, such as is done in France, separates the plutonium so that it  can be recycled into new fuel for nuclear power reactors. However, the  separated plutonium can also be used in nuclear weapons. Because of  proliferation concerns, the United States has pursued a policy since the  1970s of discouraging the reprocessing of commercial spent nuclear fuel  internationally.
DOE proposes under GNEP to reprocess and recycle the nation’s  commercial spent nuclear fuel in a manner that is consistent with the  policy of discouraging the spread of reprocessing internationally and that  addresses the following objectives:    Reduce nuclear waste. A cornerstone of GNEP is the proposal to develop  advanced technologies for recycling not only plutonium but also other  highly radioactive material in spent fuel that existing recycling  technologies dispose of as waste. The advanced technologies would not  eliminate the need for a geologic repository because some of the high-level  radioactive material in spent fuel cannot be recycled. However, according  to DOE, widespread use of advanced technologies could eliminate the  need for a second repository during this century.
Reduce the risk of nuclear proliferation. DOE aims to mitigate the  proliferation risk associated with current technologies for recycling spent  fuel. The advanced reprocessing technologies that would allow more  extensive recycling would not separate out pure plutonium but rather  keep it mixed with other radioactive material in spent fuel. Such advanced  technologies are intended to make it more difficult for rogue states or  terrorists to divert or steal plutonium from facilities that recycle spent  nuclear fuel. DOE has also proposed that the use of such technologies be  limited to the United States and certain countries that have operational  reprocessing plants: China, France, Japan, Russia, and the United  Kingdom.
GNEP would address these objectives through a domestic component and  an international component. The domestic component—the subject of this  report—is the proposal to design and build three new facilities to begin  recycling spent nuclear fuel as an alternative to direct disposal in a  geologic repository. Two of the new facilities—an advanced reprocessing  plant for separating reusable materials from spent nuclear fuel and  fabricating them into recycled fuel, and an advanced reactor that produces  electricity using recycled fuel—would be the first of multiple plants and  reactors needed to provide sufficient recycling capacity to balance out  existing and planned nuclear power plants, which would continue to  generate spent fuel. The third facility would be built at a DOE site to  conduct research and development (R&D) on advanced recycling  technologies. The R&D facility would provide support to the other two  facilities in using advanced recycling technologies. (See fig. 1 for the  domestic component of GNEP.)
The international component of GNEP addresses the risk that countries  might develop nuclear weapons under the guise of peaceful development  of nuclear energy. DOE anticipates that GNEP’s domestic component  would help advance its international component because development of  domestic spent fuel recycling facilities would enable the United States to  influence how new reprocessing plants and nuclear power plants being  planned or built worldwide are designed and operated with respect to  nonproliferation and waste disposal. In particular, DOE proposes that a  consortium consisting of the United States and other countries with  advanced nuclear technologies provide a reliable source of fresh fuel and  take back the spent fuel from countries with less developed nuclear  industries. In exchange, such countries would refrain from enriching  uranium for nuclear fuel and reprocessing spent fuel. Twenty countries  had agreed as of February 2008 to partner with DOE under the GNEP  statement of principles to cooperate on development of such a system of  reliable fuel services. Development of advanced recycling technologies  that do not separate pure plutonium, with the long-term goal of ceasing  separation of plutonium and eventually eliminating stocks of separated  civilian plutonium, is also part of the statement of principles.
Since announcing GNEP, DOE has outlined two possible approaches to  designing and building a demonstration of the reprocessing plant and  advanced reactor envisioned under GNEP’s domestic component: either at  an engineering scale or a commercial scale. (The R&D facility would  remain the same under either approach.) Under the original approach for  an engineering-scale demonstration, DOE national laboratories would lead  the design and construction of both facilities at a scale smaller than  required for commercialization but larger than for laboratory-scale R&D.  Engineering-scale demonstrations typically precede commercial-scale  deployment and are meant to ensure technologies work as intended before  an investment is made in a larger plant. Shortly after announcing GNEP,  DOE estimated that the total project cost for all three facilities under an  engineering-scale demonstration could range from $4.2 billion to $9.7  billion and that the facilities could begin operating between 2011 and 2019.  DOE anticipated commercialization could follow a successful engineering- scale demonstration within as few as 10 years.
While DOE has not ruled out this original engineering-scale approach,  DOE now favors an accelerated approach of partnering with industry and  using the latest commercially available technology to design and build a  commercial-scale reprocessing plant and advanced reactor without first  building engineering-scale facilities. According to the GNEP strategic plan,  partnering with industry could increase the speed and reduce the overall  cost of arriving at a commercially operated system of prototype recycling  facilities. In particular, the strategic plan established a goal of developing  the facilities in a way that would not require a large amount of government  funding for construction and operation and stated that industry had  indicated a potential willingness to make substantial investments in  building and operating recycling facilities. DOE anticipates that  commercial-scale facilities could begin operating by 2025, with the final  cost and schedule dependent upon industry proposals. Nonetheless,  commercial-scale facilities would be significantly more expensive than  those built at an engineering scale. For example, a commercial  reprocessing plant built in Japan had capital costs estimated at around $20  billion.
DOE officials expect the Secretary of Energy to decide whether and how  to proceed with GNEP by the end of 2008 at the latest. In the meantime,  DOE is engaged in various efforts to help inform that decision. In  accordance with the National Environmental Policy Act of 1969, DOE is  preparing an environmental impact statement to evaluate programmatic  alternatives for managing the spent fuel produced by commercial nuclear  power plants. The alternatives include the status quo, in which nuclear  power plants would continue to store the fuel until DOE can dispose of it  in a geologic repository; recycling spent nuclear fuel as proposed under  GNEP; and several alternatives suggested in public comments on DOE’s  notice of intent to prepare a programmatic environmental impact  statement. In response to congressional direction, DOE is also evaluating  13 sites as possible locations for one or more of the three initial GNEP  facilities, although the department will not select sites for the reprocessing  plant and advanced reactor until it has selected which programmatic  alternative to pursue. In keeping with its preference for accelerating  commercialization of spent nuclear fuel recycling, the department  announced in October 2007 that it had completed cooperative agreements  with four industry consortia. DOE plans to provide the consortia with up  to a total of $60 million to develop, among other things, conceptual design  studies (including costs and schedules) for the reprocessing plant and  advanced reactor and business plans for commercializing them. The  industry consortia submitted their preliminary design studies and business  plans to DOE in January 2008. After reviewing industry’s preliminary  documents, GNEP program officials recommended continued funding for  all four consortia, and DOE announced in March 2008 that it had awarded  additional funds to the four consortia.
DOE has supported R&D on the advanced reprocessing and nuclear  reactor technologies envisioned under GNEP for a number of years under  an existing program, the Advanced Fuel Cycle Initiative. Under this  program, DOE has evaluated options for managing spent nuclear fuel,  including variations of recycling using different reprocessing technologies  and types of reactors. DOE also conducted extensive R&D in the 1970s,  1980s, and early 1990s on previous concepts for advanced reprocessing  and reactor technologies. These previous concepts were not implemented,  in part because of concerns about their cost and technical challenges.
Similar concerns have been raised about implementing GNEP. Although  Congress provided for an Advanced Fuel Cycle Initiative program in the  Energy Policy Act of 2005, subsequent committee reports have expressed  skepticism about specific aspects of DOE’s efforts under GNEP—for  example, whether DOE has focused on the recycling technologies best  able to achieve GNEP’s objectives. Organizations concerned about nuclear  energy and nuclear nonproliferation have also raised concerns about  whether GNEP will achieve its objectives. Some have argued that a U.S.  decision to participate in reprocessing of commercial spent nuclear fuel  would encourage other countries that do not currently have reprocessing  capabilities to develop them, increasing the risk of nuclear weapons  proliferation rather than reducing it. Finally, DOE has a poor record of  managing major design and construction projects, particularly those that  use new technologies. For example, we reported in 2007 that most of  DOE’s major projects we reviewed had exceeded cost or schedule  estimates, in part because DOE had not systematically ensured that  critical technologies reflected in its project designs had been  demonstrated to work as intended before committing to construction  expenses for full-scale facilities.
This report focuses on the extent to which deployment of the three initial  facilities for recycling spent fuel would address GNEP’s objectives.  Because the Secretary of Energy has not yet decided on the approach to  implementing GNEP, we evaluated the extent to which GNEP’s objectives  would be addressed by (1) DOE’s original approach of demonstrating  advanced spent nuclear fuel recycling technologies in engineering-scale  facilities and (2) the accelerated approach of working with industry to  design and build commercial-scale recycling facilities. We did not evaluate  whether recycling spent nuclear fuel is preferable to other options, such as  directly disposing of spent fuel in a geologic repository. Such a  comparison would require an analysis of the respective costs and benefits  and would have to take into account other aspects of GNEP, such as the  proposal to develop an international system of reliable fuel services.
To evaluate DOE’s original engineering-scale approach, we analyzed  DOE’s technology development plan and other documents for GNEP and  the Advanced Fuel Cycle Initiative. We specifically analyzed how DOE had  selected the advanced spent nuclear fuel recycling technologies on which  to focus its R&D, the maturity of those technologies, and DOE’s plan for  developing them. We interviewed DOE officials responsible for managing  the R&D, as well as DOE national laboratory officials responsible for  conducting it. We observed spent fuel recycling R&D activities at four  DOE national laboratories and one university laboratory. We selected the  DOE laboratories based on their leading roles in implementing spent fuel  recycling R&D.
To evaluate DOE’s accelerated approach to deploying commercial-scale  facilities, we analyzed DOE documents related to its decision to consider  working with industry, including the GNEP strategic plan, DOE’s August  2006 request for industry expressions of interest in designing and building  commercial-scale facilities, and the funding opportunity announcement for  conceptual design studies and other reports. Furthermore, we reviewed  two sets of documents submitted to DOE: 18 expressions of interest  submitted in September 2006 by companies proposing to design and build  GNEP facilities and by other entities; and preliminary deliverables  submitted in January 2008 by the four industry consortia to which DOE  awarded funding for conceptual design studies, business plans, and related  documents. We considered all of these documents, including the less  recent expressions of interest, because the terms under which DOE would  work with industry are still evolving. Many of the documents contain  proprietary information; to protect such information, this report does not  disclose details of the various industry responses. We interviewed  representatives of the lead firms of the four industry consortia that  received funding under GNEP, as well as representatives of the Nuclear  Energy Institute, which represents the nuclear power industry.
We also interviewed DOE officials in the Office of Nuclear Energy, which  is responsible for implementing GNEP, and offices with responsibility for  related efforts, such as the Yucca Mountain project. In addition, we met  with representatives of organizations that have raised concerns about or  studied issues related to the implementation of GNEP, such as the Union  of Concerned Scientists and NRC’s Advisory Committee on Nuclear Waste  and Materials. (App. I presents a detailed discussion of the scope and  methodology of our review.)
We conducted this performance audit from November 2006 to April 2008,  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: GNEP is part of the administration’s Advanced Energy Initiative for  reducing the nation’s reliance on foreign sources of energy and increasing  energy supplies in ways that protect the environment. The initiative seeks,  among other things, to increase funding for R&D to enable the generation  of more electricity from nuclear energy. Benefits of nuclear energy cited  by the administration include avoidance of air pollution and greenhouse  gas emissions, sufficient North American uranium reserves to fuel nuclear  power plants for the foreseeable future and thus contribute to energy  security, and the relatively low cost to operate nuclear power plants once  they have been built and paid for. Under GNEP, the administration seeks  to address two of nuclear energy’s drawbacks—the need to dispose of  spent nuclear fuel and the risk of nuclear proliferation.
DOE’s Office of Nuclear Energy has primary responsibility for GNEP and  has established a steering group to coordinate its implementation. The  steering group includes other DOE offices with responsibility for programs  related to GNEP, such as the Office of Civilian Radioactive Waste  Management and the National Nuclear Security Administration, a  separately organized agency within DOE that has responsibility for the  department’s nuclear nonproliferation programs. DOE national  laboratories contributing to development of GNEP technologies include  Argonne, Brookhaven, Idaho, Lawrence Berkeley, Lawrence Livermore,  Los Alamos, Oak Ridge, Pacific Northwest, Sandia, and Savannah River.  The Office of Nuclear Energy directed the Idaho National Laboratory to  establish a technical integration office to serve as a point of contact with  the other laboratories; integrate R&D and technology development  activities; collect, analyze, and integrate financial and schedule data; and  perform other administrative functions. The technical integration office  oversees seven technical campaigns responsible for specific aspects of  GNEP, each headed at a national laboratory by a campaign manager.
As required by the department’s project management guidance, the Office  of Nuclear Energy is currently evaluating alternative approaches and  recycling scenarios for implementing GNEP’s domestic component.  Recycling scenarios differ by the technologies used and materials in spent  fuel that are recycled. Such differences impact the degree to which  GNEP’s objectives would be addressed—for example, by the degree to  which recycling of spent nuclear fuel would extend the technical capacity  of a geologic repository to accommodate the remaining high-level  radioactive waste (or, conversely, by the number of geologic repositories  needed to dispose of the waste). DOE has estimated that, without  recycling spent fuel, as many as four repositories could be required by  2100, assuming that nuclear energy maintains its current level of electricity  generation and each additional repository has a limit of 70,000 metric tons.  Even more repositories would be needed if, as DOE hopes, nuclear energy  increases its share of the nation’s electricity generation beyond the current  level of 20 percent. In contrast, DOE hopes to develop advanced recycling  technologies that would result in needing only one geologic repository this  century.
Absent a second repository, DOE would not legally be able to avail itself of  the Yucca Mountain geologic repository’s full technical capacity unless the  Nuclear Waste Policy Act of 1982 were amended. The act allows no more  than 70,000 metric tons of spent fuel, or the high-level radioactive waste  that results from reprocessing no more than 70,000 metric tons of spent  fuel, to be disposed of in the repository unless a second repository is in  operation. In contrast, GNEP is based on the assumption that the  repository has a technical capacity to accommodate the high-level  radioactive waste from reprocessing a much greater amount of spent  fuel—if DOE is successful in developing advanced recycling technologies.  According to an analysis conducted by Argonne National Laboratory, the  repository’s technical capacity would be based on performance  specifications designed to limit releases of the radioactivity in spent  nuclear fuel to the environment. Since the spent nuclear fuel and other  high-level waste stored in the repository can generate heat for long periods  of time and the repository’s performance can be affected by temperature,  many of the performance specifications would be in the form of  temperature limits. DOE proposes under GNEP to recycle or otherwise  manage the materials in spent fuel that are significant contributors to  decay heat, thereby allowing more of the remaining waste to be disposed  of in the repository without exceeding the temperature limits.
subsections: section_title: Materials in Spent Nuclear Fuel
paragraphs: Hundreds of fuel assemblies—bundles of long metal tubes filled with  uranium pellets—form the core of a typical nuclear power reactor (see fig.  2). Reactors produce energy when uranium atoms split (fission) into  smaller elements, called fission products. Some of the uranium atoms do  not split but rather are transformed into transuranics—elements heavier  than uranium—such as plutonium. With the buildup of fission products,  the uranium loses its ability to sustain a nuclear reaction, and the fuel  assemblies are then removed for replacement. Removed assemblies (spent  nuclear fuel) are some of the most hazardous materials made by humans.  Without protective shielding, radiation from the spent fuel can kill a  person directly exposed to it within minutes or increase the risk of cancer  in people exposed to smaller doses.
The uranium, fission products, and transuranics in spent fuel differ in  terms of the impact they have on the technical capacity of a geologic  repository as a result of their decay heat. They also differ in terms of their  energy value and potential to be recycled. Uranium that was present in  fresh fuel forms up to about 96 percent of the material in spent fuel. The  uranium is not highly radioactive and contributes little to the decay heat of  spent fuel. DOE has proposed under GNEP that the uranium, which has  not lost all of its energy value, be stored for future recycling if it becomes  economically viable to do so. Alternatively, DOE has suggested the  uranium could be managed as low-level radioactive waste, which does not  require disposal in a geologic repository. Fission products, which  constitute about 3 percent to 5 percent of the material in spent fuel, do not  have energy value as fuel for a reactor and under GNEP would be disposed  of as high-level radioactive waste. Two key fission products—cesium and  strontium—are significant contributors to the decay heat in spent fuel.  Because the fission products would no longer be contained within a fuel  assembly, other ways of containing them would need to be used to ensure  their safe disposal. DOE has conducted and continues to conduct R&D to  enable disposal of the fission products as high-level waste. Transuranics,  which include plutonium, constitute the smallest percentage of spent fuel.  They are of primary interest under GNEP because they have energy value  if advanced technologies for recycling them in reactors can be successfully  developed. Transuranics also contribute to the long-term decay heat in  spent fuel, and recycling them could extend the capacity of a geologic  repository to accommodate the remaining high-level radioactive waste.  (See table 1.)
section_title: Technologies for Recycling Spent Nuclear Fuel
paragraphs: Recycling spent fuel requires that a reprocessing plant break apart the  used fuel assemblies and separate the reusable materials from the  remaining waste. The reusable materials are then fabricated into recycled  fuel for reactors. Under GNEP, DOE national laboratories are conducting  R&D to develop advanced technologies for each of these steps. PUREX— the reprocessing technology originally developed in the United States to  obtain plutonium for nuclear weapons and now used for commercial  purposes in France, Japan, and other countries—separates out plutonium.  According to DOE, the PUREX reprocessing technology can be adapted to  recombine plutonium with uranium before the plutonium leaves the  plant’s radioactive processing area and thereby reduce the possibility of  using a reprocessing plant to produce plutonium. Japan has made such an  adaptation to its reprocessing plant. In contrast, advanced reprocessing  technologies being developed by the national laboratories (generally  known as the UREX+ suite of processes) would completely avoid  separating out plutonium and would instead keep it mixed with one or  more of the other transuranics, which would provide a higher level of  proliferation resistance. The inclusion of other transuranics is intended to  make it easier to detect theft or diversion of plutonium and to increase the  difficulty of using the plutonium in a nuclear weapon.
The DOE national laboratories are also developing advanced technologies  for fabricating and using recycled fuel that contains not only uranium and  plutonium but also one or more of the other transuranics. In contrast,  recycled fuel derived from existing technologies—called mixed oxide  (MOX) fuel—contains uranium and plutonium but not other transuranics,  which are disposed of as waste despite their potential energy value. Under  GNEP, DOE is considering various options for the recycled fuel and has  not made a final decision on many of them, such as whether the reusable  materials should be in the form of metal or oxide and whether all of the  reusable materials should be fabricated together or some fabricated and  recycled separately. Decisions on such options will in part affect another  set of decisions on advanced reprocessing technologies (e.g., the  technology chosen from among the UREX+ suite of processes).
The advanced reactor envisioned under GNEP would be used to transmute  transuranics, or convert them into materials that generate decay heat for a  shorter period of time, thereby extending the capacity of a geologic  repository to store the remaining waste. The type of advanced reactor  DOE plans to develop under GNEP is a “fast” reactor, as opposed to a  “thermal” reactor. These terms refer to the neutron energy level at which a  nuclear reaction is sustained in a reactor: Fast reactors operate with  higher energy neutrons than thermal reactors. DOE specifically selected a  fast reactor cooled by sodium as the advanced reactor for GNEP, in part  because the technology for sodium-cooled fast reactors is considered to  be more advanced than the technology for other types of fast reactors.  However, while the United States and other countries have built and  operated sodium-cooled fast reactors, largely for research purposes, no  fast reactors are currently operating in the United States. In contrast,  almost all commercial nuclear power plants and other operating reactors  are thermal reactors—particularly light water reactors, which use ordinary  water as a coolant.
NRC would have licensing and regulatory authority to ensure the safety of  any commercial facilities for recycling spent fuel, including reprocessing  plants and advanced reactors. Based on a preliminary assessment, NRC  has concluded that changes in regulations and associated regulatory  guidance would be necessary to support an efficient and effective  licensing review of commercial GNEP facilities. Reprocessing and  recycling spent nuclear fuel would also produce low-level radioactive  waste, potentially in large quantity, and gaseous waste products.  According to NRC, disposal of such wastes would face multiple technical,  legislative, and regulatory challenges that, while not insurmountable,  would nonetheless be significant.
section_title: DOE’s Original Engineering-Scale Approach Would Meet GNEP’s Objectives If Advanced Recycling Technologies Are Successfully Developed
paragraphs: Successful development and commercialization of advanced recycling  technologies envisioned under the engineering-scale approach would have  a greater long-term impact, compared with existing technologies, on  GNEP’s waste reduction objective. The advanced technologies would also  mitigate proliferation risks relative to existing technologies. However, the  engineering-scale approach lacked industry participation, potentially  reducing the prospects for eventual commercialization of advanced  technologies. Furthermore, the approach included building an engineering- scale reprocessing plant before conducting R&D that could help determine  the plant’s design requirements. In contrast, building an advanced reactor  and R&D facility would allow DOE to conduct R&D that existing DOE  facilities have limited capability to support.
subsections: section_title: Successful Development of Advanced Recycling Technologies Would Be an Initial Step toward Greatly Extending the Capacity of a Geologic Repository
paragraphs: DOE’s original approach to GNEP would demonstrate at an engineering  scale advanced technologies for recycling all of the transuranics in spent  nuclear fuel. Transuranics are the dominant contributors over the long  term to the spent fuel’s decay heat, which is a primary limiting factor in  the amount of spent fuel that can be accommodated in a geologic  repository. Thus, successful development and implementation of  technologies for recycling the transuranics could greatly extend the  capacity of a geologic repository to contain the remaining high-level  radioactive waste. For example, according to a recent analysis conducted  by DOE’s Argonne National Laboratory, recycling the transuranics could  result, under certain conditions, in an almost sixfold increase in the  amount of remaining waste that could be accommodated in a geologic  repository with a capacity limited by temperature considerations. While  the precise impact of recycling the transuranics would depend on many  factors, such as the recycling technologies’ effectiveness, the potential  waste benefit of not disposing of transuranics in a geologic repository is  well recognized, and development of advanced technologies for  transmuting them has been a focus of DOE’s Advanced Fuel Cycle  Initiative.
DOE has analyzed various advanced technologies, such as different types  of reactors, for transmuting transuranics in spent nuclear fuel. While an  engineering-scale demonstration of any one set of advanced technologies  may require that DOE narrow its focus to the exclusion of potentially  worthy alternatives, there is substantial technical support for choosing to  recycle transuranics using a fast reactor, as DOE has proposed under  GNEP. The choice of reactor is critical from the standpoint of addressing  GNEP’s waste reduction objective because reactors differ in their ability to  recycle the transuranics. DOE specifically selected a fast reactor as the  advanced reactor envisioned under GNEP because its properties  theoretically enable it to recycle transuranics more efficiently than  thermal reactors. For example, analyses conducted by DOE national  laboratories indicate that, whereas thermal reactors would be able to  recycle the transuranics at most about two times, fast reactors would be  capable of recycling the transuranics repeatedly. Achieving the waste  reduction benefit of not disposing of transuranics in a geologic repository  would require multiple recycling passes because recycled fuel, like  conventional fuel used in light water reactors, loses its ability to sustain a  nuclear reaction and is thus spent before the transuranics in it are fully  consumed. Other organizations that have cited the benefit of successfully  developing fast reactors to recycle transuranics include the Nuclear  Energy Agency, DOE’s Nuclear Energy Research Advisory Committee, and  the Electric Power Research Institute. For example, a Nuclear Energy  Agency report issued in 2006 stated that studies have repeatedly  demonstrated that fast reactors are more efficient than light water  reactors for recycling and transmuting transuranics.
The focus on developing fast reactors under DOE’s original approach to  GNEP is also justified whether they are used alone or in combination with  other reactor types. Because of the ability of fast reactors to transmute  transuranics, many scenarios for recycling transuranics include the use of  a fast reactor as an essential component. For example, DOE’s Oak Ridge  National Laboratory has studied the possibility of transmuting some of the  transuranics in light water reactors and other transuranics in fast reactors.  Such scenarios may provide advantages, such as the ability to use existing  reactors without needing to deploy as many fast reactors, initial models of  which are expected to be more expensive than light water reactors to  build and operate. The advantages of scenarios for recycling transuranics  in a combination of reactor types would have to be weighed against the  disadvantages, such as the increased requirement for R&D on two sets of  recycling technologies.
Successful development of fast reactors, even given their ability to  transmute transuranics, would only be an initial step toward achieving  GNEP’s waste reduction objective. Like any technologies developed for  recycling spent nuclear fuel, fast reactors would require widespread use  and many years of operation before significantly reducing the inventory of  transuranics that would otherwise require disposal in a geologic  repository. For example, according to a hypothetical scenario analyzed by  Idaho National Laboratory, fast reactors would transmute only about one- quarter of the transuranics produced by nuclear power plants by the end  of the century. The scenario assumes that nuclear energy and recycling of  spent fuel would grow at a brisk pace: By the end of the century, nuclear  power would increase its share of the nation’s electricity generation from  about 20 percent to about 33 percent, and fast reactors would account for  about 17 percent of the electricity generated by nuclear power plants. The  scenario also assumes that three reprocessing plants, each with a capacity  of 2,000 metric tons per year, would need to start up between 2020 and  2080.
section_title: Advanced Recycling Technologies Envisioned under DOE’s Original Approach to GNEP Pose Lower Proliferation Risks Than Existing Recycling Technologies
paragraphs: While advanced technologies for recycling spent nuclear fuel would pose a  greater risk of proliferation in comparison with direct disposal in a  geologic repository, they would reduce the risk of proliferation relative to  existing reprocessing technologies that separate out plutonium. Direct  disposal of spent nuclear fuel in a geologic repository provides a higher  level of protection against theft or diversion of plutonium and its  subsequent use in a nuclear weapon than recycling because spent fuel  assemblies are highly radioactive for many years, and plutonium cannot be  obtained from them other than by reprocessing the spent fuel. In contrast,  existing spent fuel recycling technologies increase the risk of proliferation  by separating out plutonium, which could conceivably be stolen or  diverted more easily than a large radioactive fuel assembly. Existing  recycling facilities address this risk through high levels of security and  safeguards technologies to detect theft or diversion of nuclear materials.
DOE’s advanced recycling technologies offer the possibility of reducing— but not eliminating—the risk of proliferation relative to existing recycling  technologies. The advanced reprocessing technologies that DOE is  developing (the UREX+ suite of processes) would keep plutonium mixed  with one or more of the other transuranics. Of these technologies, the one  that DOE had identified as the preferred option under its original approach  to GNEP (the UREX+1a process) would keep plutonium mixed with all of  the other transuranics, the radiation of which could create a barrier to  handling the plutonium mixture and fabricating it into a nuclear weapon.  However, even with this radiation barrier, the risk of theft or diversion  from a reprocessing plant would necessitate high levels of security and the  use of safeguards technologies. For example, the Savannah River Site’s  engineering analysis of a commercial-scale reprocessing plant using DOE’s  advanced reprocessing technology found that nuclear materials in the  plant would fall into a category requiring a high level of protection under  DOE security standards. The risk of theft or diversion from an advanced  reprocessing plant could be even higher if DOE designed the plant to use  one of the other UREX+ processes, which generally keep plutonium mixed  with fewer radioactive transuranics.
DOE’s original approach would further address the risk of proliferation by  developing advanced safeguards technologies, such as equipment capable  of near real-time monitoring of materials being reprocessed, and testing  them in the initial facilities proposed under GNEP, particularly the R&D  facility. According to the GNEP safeguards campaign manager, existing  safeguards technologies are not capable on their own of meeting the  standard for detecting plutonium diversion that DOE hopes to meet with  advanced technologies. Furthermore, the use of advanced reprocessing  technologies that keep plutonium mixed with other transuranics would  require the development of new safeguards technologies capable of  detecting and identifying not only plutonium but also other transuranics.
section_title: Lack of Industry Participation Could Reduce the Prospects for Commercialization and Widespread Use of Advanced Recycling Technologies
paragraphs: DOE’s original approach to GNEP did not reflect the input of industry on  how to commercialize advanced technologies for recycling spent nuclear  fuel. In particular, DOE’s original approach to GNEP included the proposal  to manage two of the key fission products—cesium and strontium—in a  way that some in industry have questioned as too ambitious. DOE had  planned to develop advanced reprocessing technologies to separate  cesium and strontium and to dispose of them separately from other high- level radioactive waste placed in a geologic repository. According to  Argonne National Laboratory’s analysis, separately disposing of cesium  and strontium would multiply the capacity-extending effect of recycling  transuranics. The analysis suggests that keeping cesium and strontium as  well as the transuranics out of a geologic repository with a capacity  limited by temperature considerations could result in about a 100-fold  increase in the amount of remaining waste that could be accommodated.  According to the analysis, separation and disposal of cesium and  strontium would not, on its own, allow any increase in the amount of  remaining waste that could be accommodated in a temperature-limited  repository since the transuranics are the dominant contributors to decay  heat over the long term.
Separation of cesium and strontium would nonetheless create waste  management challenges while also increasing the cost and complexity of a  reprocessing plant. Although the impact on the capacity of a repository  could be dramatic, cesium and strontium would still need to be managed  as radioactive waste while undergoing radioactive decay—for  approximately 300 years according to DOE’s estimate. DOE has suggested  that a site for cesium and strontium could be located at the reprocessing  plant. DOE national laboratory officials have suggested that an alternative  to storing cesium and strontium at a reprocessing plant is to create a  dedicated site at the Yucca Mountain repository. However, the need to  create such a site would entail challenges, such as public opposition.  Furthermore, an engineering analysis of a commercial-scale reprocessing  plant prepared by DOE’s Savannah River Site found that separation of  cesium and strontium could account for 25 percent of the plant’s life-cycle  cost and over 20 percent of its area and could reduce the plant’s  performance and reliability because of the engineering challenges  involved.
Representatives of two of the industry consortia that received funding  under GNEP have expressed similar concerns about separating cesium  and strontium and have instead suggested alternatives. For example, one  suggestion is to keep cesium and strontium with other high-level  radioactive waste and store the waste temporarily, for decades rather than  centuries, to allow some radioactive decay before disposal in a geologic  repository. Such alternatives may not achieve the same extension of Yucca  Mountain’s capacity estimated by Argonne National Laboratory but  nevertheless indicate the potential insights DOE can attain by working  with industry. DOE officials told us they agree that working with industry  is critical under either its original approach for an engineering-scale  demonstration or its accelerated approach of building commercial-scale  facilities, and DOE is considering industry suggestions for alternatives to  separating cesium and strontium.
section_title: DOE’s Original Approach to GNEP Included Building a Separate Engineering- Scale Reprocessing Plant Before Conducting R&D That Would Help in Designing the Plant
paragraphs: DOE’s original schedule for building the three facilities envisioned under  GNEP called for an engineering-scale reprocessing plant to start up  between 2011 and 2015—several years before the R&D facility and the fast  reactor, which would start up between 2014 and 2019. The more recent  GNEP technology development plan pushed back the schedule for all  three facilities, with the reprocessing plant starting up around 2020, the  R&D facility between 2020 and 2022, and the fast reactor between 2022  and 2024. Regardless of the precise dates, scheduling the engineering-scale  reprocessing plant before the other two facilities would not allow testing  and development conducted at the other two facilities, particularly the  R&D facility, to be incorporated into the design of the plant.
Specifically, the reprocessing plant would not benefit from testing and  development on recycled fuel and advanced reprocessing and safeguards  technologies. The recycled fuel R&D schedule spans about 20 years,  beginning with testing small samples of different types of recycled fuel and  progressing to entire fuel assemblies, which would be fabricated in the  R&D facility and tested in the fast reactor. DOE is at the beginning of this  effort and has not yet developed technology to overcome key challenges,  such as how to remotely fabricate highly radioactive recycled fuel. Given  the 20-year fuel development schedule, an engineering-scale reprocessing  plant built before making further progress on fuel R&D would increase the  risk that the plant would separate transuranics in a form not suitable for  fabrication into the type of recycled fuel DOE ultimately chooses to  develop. The DOE Savannah River Site’s engineering analysis of a  commercial-scale reprocessing plant ranked the risk of incompatibility  between the output of the plant’s spent fuel separations process and  recycled fuel fabrication as the most severe programmatic risk associated  with the plant. In addition, an engineering-scale reprocessing plant built  before the R&D facility could not initially take advantage of advanced  reprocessing and safeguards technologies that DOE intends to test and  develop at the R&D facility. While DOE national laboratories are currently  conducting R&D on such technologies at existing facilities, the testing is  generally at a smaller scale, using kilogram quantities of spent fuel, than  would be possible at the R&D facility envisioned under GNEP, which  would be designed to handle metric tons of spent fuel.
Under DOE’s original time frame, an engineering-scale reprocessing plant  would also be built earlier than needed because it would separate  transuranics before the fast reactor would recycle them as fuel. DOE’s  plans for the fast reactor do not call for it to initially use recycled fuel  produced by the reprocessing plant. It would instead start up using  conventional fast reactor fuel, consisting of either uranium or a  combination of uranium and plutonium. Recycled fuel assemblies, which  would initially be fabricated at the R&D facility, would only gradually  begin to replace the conventional fuel as R&D on the recycled fuel nears  completion. Thus, from the standpoint of providing sufficient quantities of  recycled fuel for the first fast reactor, the reprocessing plant would not be  needed until the reactor’s need for recycled fuel exceeded the fabrication  capacity of the R&D facility.
While a separate engineering-scale reprocessing plant would not initially  be needed, it could serve at a later point to increase the maturity of  advanced recycling technologies prior to commercialization and  demonstrate the technologies in an industrial setting with higher  requirements for operational efficiency and continuity of operations than  an R&D facility. An expert panel convened by DOE recommended an  annual throughput of 100 metric tons of spent fuel as sufficiently large to  demonstrate the feasibility of scaling up to a commercial plant, which  could have an annual throughput of as much as 2,000 to 3,000 metric tons.  Jumping directly from an R&D facility to a commercial-scale reprocessing  plant would increase the risk that new technologies would not work as  intended. In fact, the Savannah River Site engineering analysis of a  commercial-scale reprocessing plant placed a high risk on the possibility  that a plant using new processes would require changes or adjustments  during or following startup and stated that unanticipated problems  requiring equipment modification or replacement would be likely. A recent  report by the National Academies echoed this concern and recommended  engineering-scale facilities for GNEP because they could be modified  faster and at less cost than large-scale facilities. An engineering-scale  reprocessing plant would also cost substantially less to build than a  commercial-scale plant. DOE’s March 2006 mission need statement for  GNEP estimated the cost of an engineering-scale plant at between $0.7  billion and $1.7 billion. In contrast, DOE has suggested that the cost of a  commercial plant could be estimated by scaling up the almost $20 billion  cost of an 800-metric ton reprocessing plant built in Japan. Using this  approach, and DOE’s guideline for scaling facilities of different sizes, a  reprocessing plant with an annual throughput of 3,000 metric tons of spent  fuel per year could cost approximately $44 billion. The Savannah River  Site’s engineering analysis of a 3,000-metric ton reprocessing plant  suggests that the cost could also be significantly higher than $44 billion  given the uncertainties in designing a plant to use new technologies.
An alternative to building a new engineering-scale reprocessing plant is to  modify an existing facility at a DOE national laboratory; however, this  alternative may not be cost-effective. The Savannah River Site studied the  feasibility of modifying two existing DOE facilities that are not currently  being used—the F Canyon at the Savannah River Site and the Fuel  Processing Restoration facility at Idaho National Laboratory. The study  found that, while the facilities would be capable of supporting an  engineering-scale demonstration, both would require major modifications  because they are contaminated from previous use or were designed for  other purposes. The study estimated the cost to backfit the facilities at  $1.3 billion to $1.9 billion and $5.4 billion to $7.9 billion, respectively.
section_title: The R&D Facility and Advanced Reactor Would Enable DOE to Develop the Advanced Recycling Technologies Envisioned under Its Original Approach to GNEP
paragraphs: Under DOE’s original approach to GNEP, the R&D facility and fast reactor  would enable the DOE national laboratories to increase the maturity of  advanced recycling technologies and to conduct the required R&D that  existing DOE facilities have limited capability to support. Many of the  advanced recycling technologies that were the focus of DOE’s original  approach to GNEP are at a low level of maturity and would benefit from  such R&D. For example, testing of DOE’s advanced reprocessing  technologies has to date been conducted at the laboratory scale, using at  most kilogram quantities of spent fuel and with discrete reprocessing steps  performed separately rather than continuously, as in a commercial plant.  (See app. II for more information on the method DOE has used to assess  the maturity of spent fuel recycling technologies and the results of its  assessment.) Under its original approach, DOE estimated the cost of the  R&D facility at $1.5 billion to $3 billion and the cost of the initial fast  reactor at $2 billion to $5 billion.
The R&D facility would provide capabilities—particularly testing and  development of recycled fuel and advanced reprocessing and safeguards  technologies—that the DOE laboratories currently lack. DOE’s plan for  developing recycled fuel containing transuranics calls for the R&D facility  to develop remote fabrication techniques for the fuel and to actually  fabricate recycled fuel assemblies for testing in a fast reactor. While  existing facilities at DOE national laboratories can fabricate start-up fuel  for the fast reactor, they have limited capability to fabricate transuranic- bearing recycled fuel, which would be more radioactive than start-up fuel  and require specialized facilities with heavy shielding to protect workers.  DOE also plans for the R&D facility to have a high level of flexibility and  range of capabilities so that it can help resolve technical challenges  associated with advanced reprocessing technologies. A further advantage  of the R&D facility is that it would enable reprocessing R&D to be  integrated with fuel fabrication, thereby minimizing shipments of  radioactive materials among national laboratories. A fast reactor, like the  R&D facility, would also provide capabilities that DOE currently lacks. In  particular, while DOE can test small samples of recycled fuel either in  domestic facilities that approximate conditions in a fast reactor or in fast  reactors operated in other countries, a fast reactor built and operated in  the United States would enable DOE to test full-scale recycled fuel  assemblies. Testing of full-scale assemblies would be required to  demonstrate safety and obtain approval by NRC, which would, in turn,  enable the commercialization and construction of additional fast reactors  capable of using recycled fuel.
A decision to proceed with design and construction of an R&D facility and  fast reactor would present DOE with choices regarding the size of the  facilities and whether to rely on existing facilities as an alternative to new  ones. Existing DOE national laboratory facilities large enough for  laboratory-scale R&D on advanced reprocessing technologies have  limitations, and some require upgrades. For example, Argonne National  Laboratory cut back R&D on advanced reprocessing technologies after the  laboratory director decided in October 2007 not to pursue necessary safety  upgrades at a facility due to lack of funding. Argonne instead transferred  the R&D to another laboratory. Despite such limitations, DOE is evaluating  the cost and benefits of using existing laboratory facilities as an alternative  to building all or part of a new R&D facility.
Design and construction of a fast reactor would also present choices. DOE  does not currently have plans to restart the last one to operate, the Fast  Flux Test Facility in Washington state, which is currently being  deactivated pending decommissioning. DOE officials believe the cost to  restart the facility could be in excess of $500 million. While it could be  used to test full-scale fuel assemblies, DOE officials noted that the facility  is not well-suited for demonstrating innovative technologies for cost  reduction and competitive electricity generation, which would be needed  for future commercialization of fast reactors. In terms of building a new  fast reactor, DOE is evaluating a wide range of sizes. Under DOE’s original  approach to GNEP, Argonne National Laboratory, the lead laboratory for  fast reactor development, evaluated sizes for the initial reactor ranging  from 125 to 840 megawatts. The laboratory concluded that 250 megawatts  would balance the need for a realistic test environment against the  increased complexity and construction cost of a larger reactor. However,  according to the DOE official in charge of fast reactor development, a 250  megawatt reactor might not be large enough to demonstrate competitive  electricity generation. Thus, DOE is evaluating larger sizes, up to 3,000  megawatts, to determine the size that would best support the reactor’s  commercialization.
section_title: DOE’s Accelerated Approach Would Likely Rely on Technologies That Fall Short of Meeting GNEP’s Objectives
paragraphs: Two of the four industry consortia that DOE has funded under its  accelerated approach to GNEP have proposed using unproven evolutions  of current technologies—particularly the recycling of MOX fuel in existing  reactors—that would reduce waste and mitigate proliferation risks to a  much lesser degree than anticipated from the advanced technologies  envisioned under DOE’s original approach. In contrast, the other two  consortia proposed technologies that would address GNEP’s waste  reduction and nonproliferation objectives; however, the technologies are  not mature enough for commercial deployment and would therefore not  allow DOE to accelerate design and construction of commercial-scale  facilities. Under any of the proposals, DOE is unlikely to meet its goal of  deploying the facilities in a way that will not require a large amount of  government funding. DOE officials recognize these limitations and instead  point to other benefits of its accelerated approach.
subsections: section_title: Two Industry Consortia Have Proposed Using Evolutions of Current Technologies for Addressing GNEP’s Objectives
paragraphs: Two of the four industry consortia that received funding have submitted  proposals for using unproven evolutions of current recycling technologies  that would represent at best an intermediate step toward meeting GNEP’s  waste reduction and nonproliferation objectives. The proposals call for the  initial reprocessing plant to produce MOX fuel (a mixture of plutonium  and uranium), or a variant of MOX, for use in existing reactors—a  technology choice that would not sufficiently reduce the quantity of  transuranics in the high-level radioactive waste stream to meet GNEP’s  waste reduction objective. The two industry consortia also made  proposals for dealing with the transuranics not recycled as part of the  MOX fuel in existing reactors. However, the proposals rely on advanced  technologies that are at a low level of maturity and would require  substantial R&D; implementation of such technologies at a commercial  scale would very likely need to follow after implementation of MOX  technologies. Although DOE officials involved in managing GNEP have  recently expressed support for MOX technologies, the January 2007 GNEP  strategic plan rules out MOX on the grounds that it would offer a minor  benefit to a geologic repository but not meet GNEP’s objectives.
According to DOE estimates, using MOX fuel could increase by about 10  percent the amount of waste that could be disposed of in a geologic  repository limited by temperature considerations. In contrast, as discussed  earlier, Argonne National Laboratory has estimated that successful  development of advanced technologies for recycling transuranics could  increase such a repository’s capacity almost sixfold, or by almost 600  percent.
DOE officials said that, given the minor waste benefit associated with  MOX technologies, they would only pursue MOX technologies as part of a  plan to continue to develop more advanced technologies. Specifically,  DOE and others have concluded that fast reactors are critical to the ability  to recycle transuranics. Even in countries such as France, which currently  operates recycling facilities that produce MOX fuel for light water  reactors, development of fast reactors that use transuranics is a long-term  goal. According to Electric Power Research Institute staff, France did not  originally intend for its reprocessing plant to produce MOX fuel for light  water reactors; rather, it developed MOX programs because fast reactor  technology did not progress as planned and the country needed to address  the costs associated with interim storage and safeguarding of plutonium  that had been separated out through reprocessing.
Both industry proposals for using evolutions of current recycling  technologies to produce MOX fuel would also require DOE to accept less  proliferation-resistant technologies than the department envisioned when  MOX was not under consideration as part of GNEP. DOE’s National  Nuclear Security Administration has raised proliferation concerns about  MOX technology, particularly MOX fuel fabrication, and indicated in a May  2006 GNEP program document that phasing out current reprocessing  technologies (i.e., PUREX) and civilian MOX programs worldwide would  provide nonproliferation benefits. While the evolutionary technologies  would offer some improvement over existing MOX technologies because  they would not separate out pure plutonium, the plutonium mixtures  proposed for recycling into MOX fuel would be less proliferation resistant  than the mixture produced under DOE’s original preferred option  (UREX+1a), which would keep plutonium mixed with additional  transuranics. For example, pure plutonium could be obtained from a  plutonium-uranium mixture for producing MOX fuel without using any  heavy shielding from radiation. Moreover, because DOE’s schedule for the  reprocessing plant calls for it to begin operation at roughly the same time  as the proposed R&D facility, the plant would not incorporate advanced  nonproliferation safeguards that the R&D facility would develop. (As  discussed earlier, the engineering-scale reprocessing plant envisioned  under DOE’s original approach would also face this limitation, as would  any reprocessing plant designed and built prior to the R&D facility.)  Instead, DOE officials have suggested that any new reprocessing plant  built in the United States would incorporate the latest safeguards  technologies available and would also be designed to accommodate more  advanced safeguards as they are developed.
The proposed evolutionary technologies build upon existing commercial  technologies but are in some respects unproven, and their first  deployment at a commercial scale would likely be in the GNEP facilities.  For example, one of the consortia proposed using a process for keeping  plutonium mixed with uranium that, according to the GNEP separations  technologies campaign manager, has only been validated at a laboratory  scale. DOE’s ability to meet its nonproliferation objective would be  reduced if the technologies were not successfully developed and DOE fell  back on less advanced technologies for producing MOX fuel, as both  industry consortia have proposed as a backup option. In particular, such a  backup option could result in a reprocessing plant that separates out  plutonium, as is done in Japan. Other technologies that would likely be  demonstrated for the first time at a commercial scale in GNEP facilities  include technologies for controlling certain radioactive emissions from the  reprocessing plant, which would be needed to meet U.S. environmental  regulations.
If these unproven technologies associated with producing MOX fuel for  existing nuclear power plants can be successfully developed, they could  allow the United States to begin recycling spent fuel sooner and on a  larger scale than if DOE relied on more advanced but less mature  technologies. Specifically, the two industry consortia proposed building a  plant by 2023 that could reprocess from 800 to 1,500 metric tons of spent  fuel per year. This throughput would be closer to the rate at which existing  nuclear power plants produce spent fuel—about 2,200 metric tons per  year—than the throughput of an engineering-scale plant.
section_title: Two Other Industry Consortia Proposed to Address GNEP’s Objectives by Using Technologies That Are Not Mature Enough for Commercial Deployment
paragraphs: DOE would not be able to accelerate deployment of commercial-scale  facilities using technologies proposed by the remaining two industry  consortia that received DOE funding. As explained in the GNEP strategic  plan, one of DOE’s goals in working with industry is to avoid the need for  engineering-scale facilities and to increase the speed of arriving at a  commercially operated system of prototype recycling facilities. However,  the two consortia proposed technologies that are in some cases no more  mature or even less mature than the advanced technologies DOE had  planned to demonstrate under its original approach. For example, one  industry consortium proposed to rely on the type of reprocessing  technology (UREX+) that DOE has been developing, which the  department had planned to demonstrate at an engineering scale. The  consortium also proposed a “two-tier” system in which transuranics would  first be recycled in an advanced thermal reactor, then in a fast reactor.  However, the advanced thermal reactor technology is still being  developed, and implementing a two-tier system with dual sets of  technologies would significantly increase the need for R&D. The other  industry consortium proposed a type of advanced reprocessing technology  (electrochemical) that DOE considers even less mature for reprocessing  light water reactor spent fuel than the UREX+ technologies being  developed by DOE. Thus, under either industry proposal, skipping the  engineering phase of development would create an undue risk that the  technologies would not work as intended.
On the other hand, the consortia’s proposed technologies would, if  successfully developed, address GNEP’s waste and nonproliferation  objectives by recycling transuranics in fast reactors and keeping  plutonium mixed with the other transuranics. Representatives of both  consortia have also argued that some of their proposed technologies are  superior to DOE’s—for example, that electrochemical reprocessing would  provide a greater intrinsic barrier to proliferation than DOE’s  technologies, in part because spent fuel would be processed in batches,  thereby facilitating efforts to track the materials separated from spent fuel  and to detect theft or diversion. Similarly, representatives of the  consortium proposing the two-tier system stated that their proposed  combination of technologies would reduce energy costs compared with  recycling only in fast reactors—for example, because an advanced thermal  reactor would extract more energy from recycled fuel and convert the  energy more efficiently to electricity than a fast reactor.
section_title: The Government Would Likely Bear Substantial Costs for Commercial- Scale Recycling Facilities
paragraphs: DOE has cited industry’s potential willingness to invest substantial sums  of private money to construct and operate GNEP facilities as a reason for  considering commercial-scale facilities. Furthermore, the GNEP strategic  plan established a goal of developing and implementing such facilities in a  way that will not require a large amount of government construction and  operating funding to sustain. However, our review of industry proposals  and interviews with DOE officials indicate that the department is unlikely  to meet this goal, at least for the first GNEP facilities. Some industry  proposals state, for example, that initial facilities would rely entirely on  government support and that the need for such support would be reduced  only after demonstration of new recycling technologies in the initial  facilities and development of cost-saving features.
Most notably, industry has generally proposed that design and  construction of the initial fast reactor be funded directly by DOE, perhaps  with ongoing government funding or other incentives, such as fees paid to  the reactor operator for using recycled fuel. According to DOE, the  industry proposals estimated the cost of the initial fast reactor at $2 billion  to $4.5 billion—a cost that may be understated given that DOE’s estimate  for the cost of a smaller test reactor under its original approach to GNEP  was roughly the same: $2 billion to $5 billion. DOE funding would be  required because fast reactors are initially expected to be more expensive  to build and operate than light water reactors and thus unable to compete  with them economically based on sales of electricity alone. According to  DOE, studies by the Nuclear Energy Agency have estimated that a fast  reactor’s capital costs, for example, may be about 25 percent higher than  those for light water reactors. Furthermore, components that would help  reduce the cost of a fast reactor and make it more economically  competitive are at a relatively low level of maturity and, according to some  industry responses, would not be ready for commercial-scale deployment  by DOE’s time frame of 2025.
DOE officials recognize that industry will not pay for design and  construction of the initial fast reactor and have considered two other  options: delaying the reactor or sharing the cost with other countries that  are also interested in developing fast reactors. According to the DOE  official in charge of fast reactor development, delaying the reactor is a  possibility if the department decides in favor of recycling MOX fuel in light  water reactors. In addition, DOE has negotiated a memorandum of  understanding with Japan and France to harmonize fast reactor  development efforts. DOE officials have expressed hope that Japan and  France would contribute to the cost of building a fast reactor in the United  States, where it could be licensed by NRC. A reactor with NRC approval  would, in turn, have a greater potential for commercialization because  utilities would have a higher degree of confidence in the technology.
For the reprocessing plant, two of the industry consortia again proposed  direct funding by DOE. Other funding possibilities might reduce the  government’s financial burden but could still require significant  government support. For example, according to DOE, revenues from sales  of MOX fuel produced by the plant for use in light water reactors would  not significantly offset the plant’s capital costs and would not attract  sufficient private investment. To use MOX fuel, U.S. reactors would  typically have to undergo some physical modification and receive a license  amendment from NRC. Thus, even though it is generally more expensive  to produce, MOX fuel may have to be sold at a discount compared with  conventional fuel in order for it to be commercially attractive to U.S.  utilities. For example, to ensure a market for MOX fuel that is to be  produced at a DOE facility for recycling surplus weapons-grade  plutonium, DOE has agreed to provide the MOX fuel at a discounted price  and to pay for the necessary modifications to light water reactors where it  will be used. Another funding option proposed by industry is obtaining  private financing backed by federal loan guarantees or federal contracts to  treat a specified volume of spent nuclear fuel at a set price that would  cover operating the plant and servicing the debt. The government could  incur a liability under such options if industry defaulted on loans or,  depending on the specific conditions of such funding arrangements, if  factors such as litigation or regulatory delays prevented the plant from  reprocessing spent fuel.
Industry has also proposed, in expressions of interest and deliverables  submitted to DOE, that at least a portion of the fee that nuclear power  plant operators now pay into the Nuclear Waste Fund—a special fund  under DOE’s jurisdiction, subject to annual appropriations by Congress,  for disposal of spent fuel in a geologic repository—be used to pay for a  commercial reprocessing plant. Proponents of this option have called for  establishing a separate government entity that could access the fund,  potentially without the need for annual appropriations. They have also  suggested that the current fee be increased to cover the full costs of spent  fuel disposal, including the cost of both a geologic repository and a  reprocessing plant. Implementing this proposal would require substantial  legislative and regulatory changes. For example, the Nuclear Waste Policy  Act does not allow the Nuclear Waste Fund to be used for reprocessing  activities. DOE officials said that, while they recognize that current  legislation limits how the Nuclear Waste Fund can be used, they would not  rule out proposals to use the fund for GNEP. Instead, a decision by the  Secretary of Energy to support such proposals would be contingent on a  change in legislation.
In addition to requiring direct government funding, working with industry  to design and build commercial-scale facilities would also likely require  that DOE invest significant R&D resources. DOE national laboratories  would need to conduct some of the R&D even under DOE’s original plan  for an engineering-scale demonstration—for example, on technology for  capturing radioactive emissions from a reprocessing plant. However,  industry has requested DOE assistance with other R&D, such as MOX fuel  certification, that could divert resources from advanced technologies  ultimately needed to meet GNEP’s objectives. According to the head of  GNEP’s technical integration office, the national laboratories would give  long-term R&D on advanced technologies a lower priority than industry’s  immediate R&D needs.
section_title: DOE Officials Recognize the Limitations of Accelerating Deployment of Commercial-Scale Facilities but Cite Other Benefits
paragraphs: Given the technologies industry can provide in DOE’s time frame, an  accelerated approach would likely require the department to recycle MOX  fuel in existing commercial nuclear power plants. DOE officials  acknowledge that MOX recycling technologies would constitute an  intermediate step toward GNEP’s objective of reducing radioactive waste  and that achieving this objective would ultimately require development of  advanced technologies for recycling transuranics in fast reactors.  Nevertheless, according to the officials, working with industry to deploy  commercial-scale facilities to recycle MOX fuel in existing reactors would  provide enough of a waste reduction benefit to allow time to develop more  advanced technologies. The proposal to build GNEP facilities for recycling  MOX fuel in existing reactors as an intermediate step is similar to a plan  DOE put forward in 2005 under the Advanced Fuel Cycle Initiative, prior  to the announcement of GNEP in February 2006. The plan called for  developing the ability to recycle spent nuclear fuel in evolutionary stages,  with each stage helping to develop technology required for the next and  providing successively greater benefits in terms of extending the technical  capacity of a geologic repository. According to DOE, the department is  evaluating the possibility of revising the GNEP strategic plan to allow for  the possibility of recycling MOX fuel in existing reactors, as previously  contemplated under the Advanced Fuel Cycle Initiative.
With regard to nonproliferation, DOE officials emphasize that the  international benefits of working with industry to deploy commercial-scale  facilities outweigh what DOE considers to be the manageable risk of  nuclear material theft from such a facility built domestically. In particular,  DOE officials consider deploying commercial-scale recycling facilities as  essential for the United States to play a leadership role among countries  with advanced nuclear capabilities and to persuade other countries that  they should rely on international fuel services rather than developing  domestic uranium enrichment or spent fuel reprocessing capabilities.  While they have not ruled out other industry proposals, DOE officials have  also cited nonproliferation benefits of recycling MOX fuel in light water  reactors, such as the ability to reduce stocks of plutonium that accumulate  in spent nuclear fuel; reducing and eventually eliminating excess stocks of  civilian plutonium is part of the nonproliferation objective set forth in the  GNEP strategic plan. DOE’s Nuclear Energy Research Advisory  Committee has indicated that it may be appropriate to consider using  existing reactors for this purpose, particularly if large-scale deployment of  fast reactors, which would also be capable of reducing plutonium stocks,  does not occur until the middle of the century.
Finally, DOE has argued that the government’s investment in commercial- scale spent nuclear fuel recycling facilities would be worthwhile. DOE  officials have said that the benefit of ensuring U.S. leadership on  nonproliferation issues through the construction of commercial-scale  facilities—even ones that rely on evolutionary MOX technologies—would  outweigh the cost to the government. Furthermore, the officials have  suggested that revenues generated by the facilities, such as through the  sale of MOX fuel, would at least offset some of the government’s cost.  Utilities that operate commercial nuclear power plants might be interested  in MOX fuel because it could provide an alternative to uranium fuel,  supplies of which could become limited given the worldwide growth of  nuclear energy. Over the longer term, DOE has argued that recycling spent  nuclear fuel would be an attractive option to the government if the cost of  doing so were comparable to direct disposal, which could require design  and construction of multiple geologic repositories. If DOE chooses to rely  on MOX technologies, this argument hinges on a later transition to more  advanced technologies since, as discussed earlier, recycling MOX fuel in  existing reactors would provide a minor waste reduction benefit.
section_title: Conclusions
paragraphs: Accelerating deployment of commercial-scale spent nuclear fuel recycling  facilities that have a limited impact on GNEP’s waste reduction and  nonproliferation objectives would take DOE down a costly path that  would likely draw resources away from developing the advanced  technologies ultimately needed to meet these objectives. The technologies  closest to being commercially available are evolutions of existing MOX  fuel recycling technologies that would reduce waste and mitigate  proliferation risks to a much lesser degree than is anticipated from  advanced technologies for recycling all of the transuranics in spent  nuclear fuel. If DOE pursues an accelerated approach to deploying  commercial-scale facilities, the timing of a transition to more advanced  technologies that fully meet GNEP’s waste reduction and nonproliferation  objectives is unclear because such technologies are at a low-level of  maturity and require significant R&D. Accelerating deployment of  commercial-scale facilities could serve as an intermediate step—but a  costly one. While the GNEP strategic plan suggests that such facilities  would need little government financial support, industry proposals suggest  the opposite. As a result, the level of government financial commitment  needed to deploy commercial-scale facilities would likely draw resources  away from R&D on more advanced technologies and create a risk of  delaying rather than accelerating progress toward ultimately meeting  GNEP’s waste reduction and nonproliferation objectives.
DOE’s original approach of demonstrating advanced technologies at an  engineering scale appears more likely over the long term to address  GNEP’s waste reduction and nonproliferation objectives than the  department’s accelerated approach. Nevertheless, an engineering-scale  demonstration is not without risks, including the possibility that advanced  recycling technologies currently at a low level of maturity might not  perform as expected and might not be commercially viable. DOE’s original  approach to GNEP in some respects increased these risks. In particular, an  engineering-scale reprocessing plant built according to DOE’s original  schedule—before an R&D facility and advanced reactor that would  support testing and development of recycled fuel—could result in a plant  that separates the materials in spent fuel in a form unsuitable for recycled  fuel fabrication. The schedule would also not allow the plant to  incorporate advanced safeguards and reprocessing technologies  developed at the R&D facility. With regard to commercial viability, DOE’s  engineering-scale approach lacked industry participation that could help  promote future commercialization and widespread use of the advanced  technologies. DOE’s efforts to work with industry under its accelerated  approach to GNEP have mitigated some of the risk that DOE might focus  on developing overly costly and complex technologies, and working with  industry under its engineering-scale approach could continue to mitigate  this risk.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Secretary of Energy direct the Office of Nuclear  Energy to reassess its preference for an accelerated approach to  implementing GNEP through construction of commercial-scale facilities  using spent nuclear fuel recycling technologies that industry can offer in  DOE’s time frame. The reassessment should consider the time and  government resources required to support both the initial spent nuclear  fuel recycling facilities and R&D on more advanced recycling technologies  that fully meet GNEP’s objectives.
If DOE decides to pursue design and construction of engineering-scale  facilities for demonstrating advanced technologies, we further recommend  that the Secretary of Energy take the following two actions:    Revise the schedule for an engineering-scale reprocessing plant so that the  plant is built after an R&D facility and advanced reactor have conducted  sufficient testing and development of recycled fuel to ensure that the  output of the reprocessing plant can be fabricated into recycled fuel and  used in an advanced reactor. The revised schedule should also allow for  the R&D facility to test and demonstrate advanced reprocessing and  safeguards technologies that would be used in the reprocessing plant.
Direct the Office of Nuclear Energy to work with industry to the extent  possible on advanced spent nuclear fuel recycling technologies in order to  obtain industry’s expertise and input on future commercialization of such  technologies.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DOE and NRC for their review and  comment. DOE’s written comments are reproduced in appendix III. DOE  agreed with many of our findings and concurred with our  recommendations, directed toward the department’s original engineering- scale approach to GNEP, to revise its schedule for an engineering-scale  reprocessing plant and to work with industry to the extent possible. With  regard to our recommendation that DOE reassess its preference for an  accelerated approach to implementing GNEP, DOE stated that the  department will continue to perform analyses to support the Secretary of  Energy’s decision on the direction for GNEP. DOE and NRC also provided  detailed technical comments, which we have incorporated into our report  as appropriate.
DOE raised several issues with our draft report. First, DOE stated that the  report gives an erroneous impression that fast reactors can never be  economically competitive with light water reactors. We have clarified the  report to indicate that fast reactors are at least initially expected to be  more expensive to build and operate than light water reactors. We  recognize that one of DOE’s research goals is to develop fast reactors that  are competitive with light water reactors. However, as noted in our report,  technologies that would help make fast reactors more economically  competitive are at a low level of maturity. The low level of maturity of  such technologies is a key reason that industry has proposed the first fast  reactor envisioned under GNEP be funded by DOE.
Second, DOE stated that the report gives an erroneous impression that  recycling MOX fuel in light water reactors in the near-term would have a  limited impact on GNEP’s waste reduction and nonproliferation objectives  and would draw resources away from developing advanced technologies  in the long term. We disagree. With regard to waste reduction, our report  accurately states that the GNEP strategic plan specifically rules out using  MOX in light water reactors because it would offer a minor waste  reduction benefit but not meet GNEP’s objectives. Now that the  department is considering evolutionary MOX technologies, DOE cited the  substantial reduction in the quantity of spent nuclear fuel in storage as a  significant near-term benefit of recycling in light water reactors. Our  report acknowledges that such a MOX program could allow DOE to begin  recycling spent fuel sooner and on a larger scale than more advanced but  less mature technologies. Furthermore, we have clarified the report to  show that DOE has indicated it would only pursue evolutionary MOX  technologies as part of a plan to later transition to more advanced  technologies for recycling in fast reactors, which are anticipated to  provide a much greater waste reduction benefit than evolutionary MOX  technologies from the standpoint of extending the capacity of a geologic  repository. The question, in our view, is whether the intermediate benefit  of reducing the quantity of spent nuclear fuel in storage would be worth  the investment in evolutionary MOX technologies. On this point, DOE  stated that facilities for recycling spent fuel in light water reactors would  be funded and constructed by industry only when justified by a sound  business case, without impacting government funding for R&D on more  advanced recycling technologies. In contrast, our report points out that  industry does not expect the evolutionary MOX technologies to be  profitable—at least under current conditions—without some form of  government support and R&D assistance. Thus, while it is conceivable that  the government could provide the necessary support and R&D assistance  while also continuing to fund R&D on more advanced technologies, the  evolutionary technologies could also draw resources away from the more  advanced technologies.
With regard to nonproliferation, DOE called into question our finding that  evolutionary MOX technologies would mitigate proliferation risks to a  lesser degree than anticipated from the advanced technologies envisioned  under the engineering-scale approach to GNEP. Rather than differentiating  between the proliferation resistance of alternative reprocessing  technologies, DOE stated that any reprocessing plant, if misused, could be  modified to create weapons usable material. Thus, it is the department’s  view that its nonproliferation objectives would be largely accomplished  through international policies that seek to avoid the spread of enrichment  and reprocessing technologies while eliminating existing plutonium  inventories and production of material mixes that are attractive for use in  creating a nuclear explosive. We recognize that the degree of proliferation  resistance of reprocessing technologies is only one aspect of GNEP’s  nonproliferation objective. Nonetheless, our report is consistent with the  GNEP technology development plan, which states that the reprocessing  technology preferred under the original approach to GNEP (UREX+1a)  provides an additional degree of proliferation resistance compared with  other processes precisely because it would not separate plutonium from  any of the transuranics. Based on this reasoning, UREX+1a would also  provide an additional degree of proliferation resistance compared with  evolutionary MOX technologies that, for example, keep plutonium mixed  with uranium but not with other transuranics.
As we agreed with your offices, unless you publicly announce the contents  of this report earlier, we plan no further distribution until 30 days from the  date of this letter. At that time, we will send copies of this report to  interested congressional committees, the Secretary of Energy, the  Chairman of the Nuclear Regulatory Commission, and other interested  parties. We will also make copies available to others upon request. In  addition, the report will be available at no charge on the GAO Web site at  http://www.gao.gov.
If you or your staffs have any questions about this report, please contact  me at (202) 512-3841 or aloisee@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Other staff contributing to this report are listed in appendix  IV.
section_title: Appendix I: Scope and Methodology
paragraphs: To evaluate the Department of Energy’s (DOE) original engineering-scale  approach to implementing the Global Nuclear Energy Partnership (GNEP),  we analyzed (1) how DOE had selected the advanced spent nuclear fuel  recycling technologies on which to focus its research and development  (R&D), (2) the department’s assessment of the maturity of those  technologies, and (3) the plan for developing them:    We analyzed DOE’s selection of advanced technologies by reviewing the  department’s annual Advanced Fuel Cycle Initiative comparison reports,  which assess alternative recycling technologies against waste reduction,  nonproliferation, and other criteria. We also reviewed related DOE  national laboratory documents, including technical analyses of recycling  technologies not selected for development under GNEP. We compared  DOE’s selection with assessments conducted by independent  organizations and entities with expertise in recycling of spent nuclear fuel,  including the Nuclear Energy Agency of the Organisation for Economic  Co-operation and Development and DOE’s Nuclear Energy Research  Advisory Committee, and the National Research Council of the National  Academies. We interviewed officials of the DOE Office of Nuclear Energy,  the National Nuclear Security Administration, and DOE national  laboratories regarding the selection of advanced technologies under  GNEP.
We analyzed DOE’s assessment of the maturity of advanced recycling  technologies as presented in the GNEP technology development plan. We  specifically analyzed how DOE had used technology readiness levels  (TRL), a method for ranking the maturity of technologies, and compared  DOE’s use of the method to Department of Defense guidance for  technology readiness assessments. We also interviewed DOE and DOE  national laboratory officials about the maturity of the technologies and  their use of TRLs. We observed R&D activities related to development of  advanced reprocessing, fast reactor, waste form, and recycled fuel  technologies at four DOE national laboratories (Argonne, Idaho, Los  Alamos, and Oak Ridge) and interviewed DOE national laboratory  researchers about their efforts. We selected the laboratories based on their  leading roles in implementing spent fuel recycling R&D. We also observed  facilities used for R&D on safeguards technologies at Idaho State University’s accelerator center, which we elected to visit because of its  proximity to Idaho National Laboratory.
We analyzed DOE’s plan for developing advanced spent nuclear fuel  recycling technologies as presented in the GNEP technology development  plan, spent nuclear fuel recycling program plan, and mission need  statement; DOE’s budget justifications for the Advanced Fuel Cycle  Initiative; and other planning documents. We interviewed DOE officials  responsible for managing GNEP, including the officials responsible for  directing work on each of the three initial GNEP facilities and for  overseeing R&D on advanced recycling technologies. We interviewed DOE  national laboratory officials responsible for directing R&D on advanced  recycling technologies, including the head of the GNEP technical  integration office established by DOE at the Idaho National Laboratory  and the seven GNEP campaign managers for systems analysis, separations  (i.e., reprocessing), recycled fuel, fast reactors, safeguards, waste forms,  and grid-appropriate reactors. We observed DOE national laboratory  facilities that DOE has evaluated for use in GNEP as an alternative to  building new facilities, particularly the F Canyon at the Savannah River  Site and the Fuel Processing Restoration facility at Idaho National  Laboratory. We also interviewed Savannah River Site officials regarding  their engineering alternative studies for a commercial-scale reprocessing  plant based on the advanced technologies that were the focus of DOE’s  original approach to GNEP.
To evaluate DOE’s accelerated approach of working with industry to  design and build commercial-scale recycling facilities, we analyzed DOE  documents related to the department’s decision to consider working with  industry, including the August 2006 request for industry expressions of  interest in designing and building a commercial-scale reprocessing plant  and fast reactor, the January 2007 GNEP strategic plan, and the funding  opportunity announcement for conceptual design studies, business plans,  and related documents. Furthermore, we reviewed two sets of documents  submitted to DOE: 18 expressions of interest submitted in September 2006  by companies proposing to design and build GNEP facilities and by other  entities; and preliminary deliverables submitted in January 2008 by the  four industry consortia to which DOE awarded funding pursuant to the  funding opportunity announcement. We considered all of these  documents, including the less recent expressions of interest, because the  terms under which DOE would work with industry are still evolving. Many  of the documents contain proprietary information; to protect such  information, this report does not disclose details of the various industry  responses. We evaluated the documents submitted to DOE to determine  the spent nuclear fuel recycling technologies proposed for addressing  GNEP’s waste reduction and nonproliferation objectives; the maturity of  the technologies and the R&D needed to support their use in commercial- scale facilities; and the means proposed for funding initial GNEP facilities.  We also reviewed the results of DOE’s evaluation of the 18 expressions of  interest, as summarized in a November 2006 report, and we interviewed  DOE officials regarding their assessment of industry’s January 2008  preliminary deliverables. We interviewed representatives of lead firms for  the four consortia that received funding under GNEP—AREVA, Energy  Solutions, General Electric, and General Atomics—as well as  representatives of the Nuclear Energy Institute, which represents the  nuclear power industry, and the Electric Power Research Institute.
To evaluate issues of significance to both approaches DOE is considering  for implementing GNEP, we interviewed DOE officials in the Office of  Nuclear Energy, including the Assistant Secretary for Nuclear Energy  (who serves as the GNEP program manager) and the deputy GNEP  program manager; the director and other officials of the Office of Civilian  Radioactive Waste Management, which is responsible for the Yucca  Mountain geologic repository; and the National Nuclear Security  Administration, which assists the Office of Nuclear Energy on  nonproliferation issues related to GNEP. We also interviewed officials of  the Nuclear Regulatory Commission (NRC), which would have regulatory  authority over commercial facilities for recycling spent nuclear fuel; and  the Nuclear Waste Technical Review Board, an independent agency of the  U.S. Federal Government that provides independent scientific and  technical oversight of DOE’s program for managing and disposing of high- level radioactive waste and spent nuclear fuel. We reviewed DOE’s  January 2007 notice of intent to prepare a programmatic environmental  impact statement for GNEP, and we attended two public hearings on the  proposed scope of the programmatic environmental impact statement— one in Ohio near a site being studied to host GNEP facilities and one in  Washington, D.C. In addition, we attended DOE’s October 2007 annual  meeting for GNEP, which included updates on DOE’s R&D efforts and  plans for initial spent fuel recycling facilities; open meetings related to  GNEP convened by NRC’s Advisory Committee on Nuclear Waste and  Materials and the National Academies; and the American Nuclear Society’s  2007 annual meeting, which included sessions related to GNEP and  recycling of spent nuclear fuel. Finally, we met with representatives of  nongovernmental organizations that have raised concerns about or studied  issues related to the implementation of GNEP, such as the Natural  Resources Defense Council, the Union of Concerned Scientists, and the  Institute for Policy Studies.
We conducted this performance audit from November 2006 to April 2008,  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: DOE’s Use of Technology Readiness Levels to Assess the Maturity of Spent Fuel Recycling Technologies
paragraphs: The Office of Nuclear Energy has begun to assess the maturity of spent  fuel recycling technologies using technology readiness levels (TRL), a  method pioneered by the National Aeronautics and Space Administration  for measuring and communicating the risks associated with critical  technologies in first-of-a-kind applications. The Office of Nuclear Energy  also has required that the industry consortia receiving funds under GNEP  apply the method to the technologies they propose for deployment. Using  a scale from one (basic principles observed) through nine (total system  used successfully in project operations), TRLs show the extent to which  technologies have been demonstrated to work as intended. Demonstration  of new technologies at successively larger scales is one way to increase  their maturity, thereby mitigating the risk of cost or schedule overruns in  the design and construction of commercial-scale facilities and limiting  investment in potentially ineffective technologies. GAO considers seven  (subsystem demonstrated in an operational environment) to be an  acceptable level of readiness before proceeding with final design and  committing to definitive cost and schedule estimates. Based on our review  of DOE major projects, we recommended that DOE evaluate and consider  adopting a disciplined and consistent approach for assessing TRLs. DOE  concurred with our recommendation and has piloted the TRL method in  an Office of Environmental Management project, but the department has  not decided whether to incorporate the method into its project  management guidance.
The Office of Nuclear Energy has adopted the use of TRLs to assess the  maturity of spent fuel recycling technologies even though doing so is not a  requirement of DOE’s project management guidance. The GNEP  technology development plan grouped the nine-point scale into three  categories: concept development (1 to 3), proof-of-principle (4 to 6), and  proof-of-performance (7 to 9). The plan placed virtually all of the advanced  spent fuel recycling technologies in the proof-of-principle category:  reprocessing of spent fuel produced by both light water reactors and fast  reactors; development of new waste forms, which would need to be  incorporated into a reprocessing plant to ensure the safe disposal of  radioactive waste separated from spent fuel; recycled fuel containing  plutonium and other transuranics, in terms of both fabrication and  performance; and technologies for reducing the cost of fast reactors.
Based on our review of the technology development plan and interviews  with DOE national laboratory officials, some of the advanced technologies  are in fact at an even lower level of maturity than indicated in the plan. In  particular, the campaign manager for reprocessing technologies provided  us with additional information showing that several of the waste forms are  at a readiness level of 2 to 3 (concept development) as opposed to 4, as  indicated in the plan. Similarly, he provided us with information indicating  that some key technologies for reprocessing spent fuel produced by  existing light water reactors (i.e., the UREX+ technologies) are at a  readiness level of 4 as opposed to 5.
DOE national laboratory officials told us they generally support the use of  TRLs to assess the technology maturity and direct limited R&D resources  but also pointed out limitations of the method. For example, readiness  levels do not indicate the time or resources required to increase the  maturity of spent fuel recycling technologies or the obstacles DOE faces.  In the case of recycled fuel containing plutonium and other transuranics,  the R&D schedule spans about 20 years. DOE is at the beginning of this  effort and has already encountered obstacles. For example, DOE so far  has not manufactured fuel samples that contain curium, one of the  transuranics, because it is highly radioactive and would require remote  fabrication techniques that the department has not yet developed.  Furthermore, DOE plans to rely at least in part on foreign reactors to test  the fuel samples, and it was not able to test one of the samples in the  French fast reactor where it had planned because of regulatory obstacles  in France. The head of the GNEP technical integration office also told us  that high readiness levels can mask the challenges DOE would face in  designing and building a facility, particularly a fast reactor. The United  States has designed and built several fast reactors, so the GNEP  technology development plan assigns many of the basic fast reactor  components a high readiness level. However, construction on the last fast  reactor ended over a quarter century ago. As a result, the United States has  lost much of the technical infrastructure and expertise needed to build  another reactor.
While the Office of Nuclear Energy deserves credit for adopting the use of  the TRLs, despite the method’s limitations and the lack of a DOE  requirement for using it, we noted areas in which the office could improve  its application of the method, particularly if DOE proceeds with its plan to  design and build engineering- or commercial-scale recycling facilities. For  example, the GNEP technology development plan did not assign TRLs to  advanced safeguards technologies even though development of such  technologies is important to achieving GNEP’s nonproliferation objective.
The campaign manager for safeguards technologies said he had not yet  applied the TRL method because the safeguards campaign is new and  because existing technologies are adequate for the Nuclear Regulatory  Commission (NRC) to license the facilities envisioned under GNEP.  Similarly, while the technology development plan assigned TRLs to  advanced reprocessing technologies, it did not assign them to the  individual separations steps and many pieces of equipment that would  make up a reprocessing plant.
section_title: Appendix III: Comments from the Department of Energy
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Daniel Feehan (Assistant  Director), Joseph H. Cook, Nancy Crothers, Chris Kunitz, and Cynthia  Norris made key contributions to this report. Also contributing to this  report were Nabajyoti Barkakati, Doreen Eng, Mehrzad Nadji, Omari  Norman, and Rebecca Shea.