In a report issued in September, 2017, the GAO described the results of its recent study of the DOE's strategies for disposing of 34 MT of surplus plutonium, pursuant to an agreement entered into with the Russians in 2000, by the Clinton Administration. This agreement mandated the conversion of weapons grade plutonium into mixed-oxide (MOX) fuel to be burned in specially designed nuclear reactors, for the purpose of generating electricity, and in order to render the plutonium unusable in new nuclear weapons. This process, once completed, was considered to be irreversible.
Alternately, the agreement, as later modified at the behest of the US, also allowed for the disposition of the surplus plutonium by any other means acceptable to the parties, if agreed upon in writing at some future time.
NNSA began constructing the MOX Fuel Fabrication Facility (MOX facility) in 2007 at DOE’s Savannah River Site in South Carolina, under the G. W. Bush Administration.
In its fiscal year 2014 budget justification, DOE under the Obama Administration stated that pursuing the MOX approach might be unaffordable due to the growth in costs for completing the program, and it proposed a slowdown of program activities while it assesses other alternative plutonium disposition approaches. [Regarding things nuclear, it might be fair to say that the Obama Administration's views were a bit incoherent.]
In April 2014, DOE completed an analysis of plutonium disposition options that identified an alternative disposition approach that could significantly reduce the life-cycle cost of the Plutonium Disposition Program. This alternative would involve diluting the plutonium and disposing of it in a geologic repository.
Russia suspended its implementation of the agreement in October 2016, citing delays in the United States’ program.
It remains to be seen what the new Trump Administration will choose to do with the 34 MT of surplus plutonium, if anything.
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PLUTONIUM DISPOSITION
September 2017
United States Government Accountability Office (GAO)
Report to the Subcommittee on Strategic Forces, Committee on Armed Services, U.S. Senate (By Summary Points)
Proposed Dilute and Dispose Approach Highlights Need for More Work at the Waste Isolation Pilot Plant
Recent Cost Estimates for the MOX and Dilute and Dispose Approaches
WIPP and TRU Waste Volumes
DOE’s TRU Waste Planning
February 2014 Accidents at WIPP
DOE Capital Asset Acquisition Process
GAO Cost-Estimating Best Practices
DOE’s Revised Cost Estimate for Constructing the MOX Facility Substantially Met Best Practices, but NNSA Has Not Yet Applied Best Practices to the Revised Life-cycle Cost Estimate for Completing the Overall Program
DOE’s Revised Cost Estimate for Constructing the MOX Facility Substantially Met Best Practices and Can Be Considered Reliable
NNSA Has Not Yet Applied Best Practices When Revising Its Life-Cycle Cost Estimate for the Plutonium Disposition Program Using the MOX Approach
NNSA Is Developing a Life-cycle Cost Estimate for Completing the Plutonium Disposition Program Using the Dilute and Dispose Approach
NNSA Has Determined It Will Need to Expand Its Plutonium Preparation Capabilities for Dilute and Dispose
NNSA Has Determined It Needs Additional Equipment and Facilities to Dilute Plutonium and Is Estimating the Cost to Acquire It
NNSA Is Assessing Potential Costs Associated with Disposing of Diluted Plutonium at WIPP
WIPP Does Not Have Sufficient Space to Meet Current TRU Waste Disposal Needs, and Future Volumes May Exceed Statutory Capacity Even Without Diluted Plutonium
WIPP Will Need to Be Expanded to Dispose of Defense TRU Waste Already Planned for WIPP
DOE’s Inventory of TRU Waste Planned for WIPP Is Not Comprehensive, and Additional Waste Could Exceed WIPP’s Statutory Capacity
DOE Is Reviewing Alternative Waste Counting Methods That Would Allow It to Dispose of More Waste, including Diluted Plutonium, at WIPP without Exceeding the Statutory Capacity
DOE Has Not Developed Plans for Expanding WIPP’s Disposal Space and Changing the Waste Counting Method
Expansion of WIPP Disposal Space
Revision of Method for Counting Waste Volumes
Conclusions:
DOE is currently in the process of reevaluating the best approach for disposing of 34 MT of surplus weapons-grade plutonium.
DOE’s 2016 revised cost estimate of $17.2 billion for construction of the MOX facility substantially followed best practices, and we believe it can be considered reliable. However, NNSA’s revised life-cycle cost estimate for the Plutonium Disposition Program using the MOX approach of $56 billion does not yet incorporate cost estimating best practices as we have previously recommended. Reviews by NNSA and some outside experts found that the dilute and dispose approach has the potential to cost significantly less, but NNSA is still developing a life-cycle cost estimate for this alternative. If the decision is made to move forward with the dilute and dispose approach, DOE will need to ensure that there is sufficient disposal space and statutory capacity at WIPP to dispose of the diluted plutonium. WIPP is a geologic repository for defense TRU waste and will need to accommodate all such waste unless DOE pursues an additional repository.
DOE has not adequately planned for all possible waste that it may be expected to dispose of in WIPP, complicating its ability to determine whether the waste from the dilute and dispose approach can be disposed of at WIPP. In particular, DOE does not have a schedule for when TRU waste generator sites will complete the determinations on whether the potential waste identified in DOE’s annual TRU waste inventory report can be disposed of at WIPP. Without developing this schedule, DOE cannot be assured that it has timely information on whether to include this waste as part of its planning for WIPP’s future space and capacity needs. In addition, DOE’s TRU waste inventory report does not capture several possible future sources of waste, including waste from thedecontamination and decommissioning of facilities or waste that may be generated after 2050. DOE’s guidance for estimating future waste does not specify how possible future waste should be estimated and reported. Without developing guidance that helps sites produce a more comprehensive estimate for the volumes of TRU waste that may be generated in the future from cleanup operations, including estimates of buried waste, waste that may be generated from facility closure and cleanup, and other potential sources of TRU waste not currently reflected in the TRU waste inventory report, DOE will not have the information it needs to effectively estimate the need for future space for TRU waste disposal and ensure that its plans are in compliance with WIPP’s statutory capacity.
To address WIPP’s future space and capacity needs, DOE will need approvals from EPA and the New Mexico Environment Department. However, DOE is uncertain about the extent of approvals required and has not initiated planning efforts to obtain these approvals. DOE does not have plans to show how additional space will be excavated in time to prevent a disruption in waste shipments after the facility’s existing disposal space is filled in 2026. Without a long-term plan that includes the need for expanding WIPP’s disposal space and an integrated schedule that describes how DOE will complete the regulatory approval process and construction of new space before WIPP’s existing space is full, DOE does not have reasonable assurance that it will be able to expand the repository before waste shipments must be slowed or suspended. DOE also does not have a timeline for determining whether it will change its method of counting waste volumes and therefore does not know whether this action will be completed by 2020, when NNSA’s program requirements for the dilute and dispose approach assume that potential capacity constraints at WIPP will have been addressed. Without DOE developing a timeline to help determine whether it can change its method of counting waste volumes to meet NNSA’s 2020 milestone for resolving potential disposal space constraints at WIPP, DOE and other stakeholders may not have the information they need in a timely manner to know whether possible future waste, such as waste from the dilute and dispose approach, can be added to the waste planned for disposal at WIPP without potentially exceeding the facility’s statutory disposal capacity.
GAO Recommendations for Executive Action:
To ensure that DOE has a full understanding of the department’s long-term TRU waste disposal requirements and the capability of WIPP to meet those requirements, we recommend that the Secretary of Energy take the following four actions:
• Develop a schedule for deciding whether the volumes of “potential waste” identified in the annual TRU waste inventory report can be disposed of at WIPP.
• Develop guidance that helps sites produce a more comprehensive estimate for the volumes of TRU waste that may be generated in the future from cleanup operations, including estimates of buried waste, waste that may be generated from decontamination and decommissioning of nuclear facilities, and waste that may be generated past WIPP’s expected closure date of 2050.
• Develop a long-term plan for disposing of DOE’s TRU waste that includes:
• the need for excavating additional disposal space at WIPP and an integrated schedule that describes how DOE will complete the regulatory approval process and construction of new space before WIPP’s existing space is full, and
• a timeline to help determine whether DOE can change its method of counting waste volumes to meet NNSA’s 2020 milestone for resolving potential disposal space constraints at WIPP.
DOE Comments and GAO Evaluation:
We provided a draft of this report to DOE for review and comment. In written comments, reproduced in appendix VI, DOE concurred with the report’s recommendations. DOE stated that our recommendations were consistent with the department’s commitment to improve management of the national TRU waste program and to efficiently and effectively utilize WIPP for disposal of eligible TRU waste. DOE outlined actions that it intends to take in response to our recommendations, including developing disposal schedules for potential waste once certain prerequisite actions are taken that provide the basis for determining whether or not the waste is TRU waste that can be disposed of at WIPP; developing new guidance by December 2018 to assist DOE sites produce more comprehensive estimates of future TRU waste that may be generated from cleanup operations; and developing a long-term plan by December 2018 for disposal of DOE’s TRU waste, including an initial design for potential new waste disposal panels at WIPP and options for changing the method of counting waste volumes disposed of at WIPP. We believe that these steps, once implemented, would address our recommendations.
In addition, DOE highlighted the following two points:
• DOE’s Office of Environmental Management is focused on the WIPP mission as currently defined by law.
• DOE has not made a final decision to use the dilute and dispose approach to dispose of the 34 metric tons of surplus plutonium that the department previously decided to fabricate into mixed-oxide fuel.
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It remains to be seen what the new Trump Administration will choose to do with the 34 MT of surplus plutonium, if anything.
See my blogpost of March 31, 2016 entitled DOE Decides to Bury Its Waste for further info.
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