Frank N. von Hippel

On June 24, 2021, the US Nuclear Regulatory Commission (NRC) voted to accept the recommendation of its staff to discontinue developing regulations for commercial reprocessing in the United States. The NRC Staff argued that making rules for reprocessing was not "cost-justified" since "no industry stakeholders indicated that they plan to submit an application to the NRC for a reprocessing facility in the foreseeable future" and, even looking ahead 10-20 years, there was "limited interest expressed or expected from potential applicants for reprocessing facilities, including advanced reactor designers, in the near-term use of reprocessed spent fuel." At the same time, entrenched interests within the Department of Energy (DOE) and Idaho National Laboratory (INL) and a segment of the nuclear industry are trying to keep alive decades-old hopes for reprocessing and plutonium-fueled reactors.

Learning the reprocessing lesson, again The NRC staff's work on developing regulatory guidance for US reprocessing was initiated sixteen years ago in response to Nevada's legal battle against Congress' imposition of a geological repository for spent nuclear fuel and other high-level radioactive waste. In 2005, the Congressional Appropriations Committees instructed the Department of Energy (DOE), "Given the uncertainties surrounding the Yucca Mountain [radioactive waste repository] license application process...we provide $50,000,000...for the Department [of Energy] to develop a spent nuclear fuel recycling plan." The committees gave the DOE two years to select a site for a government-financed reprocessing plant and three years thereafter to initiate construction.

This Congressional directive reflected the enthusiasm for reprocessing of Senator Pete Domenici (R-NM), then chair of the Senate Appropriations Subcommittee on Energy and Water Development, and his former staffer, Clay Sell, who had been appointed Deputy Secretary of Energy in the administration of the second President Bush. In his 2004 memoir, A Brighter Tomorrow: Fulfilling the Promise of Nuclear Energy, Senator Domenici waxed almost lyrical about a 1998 tour he had been given of France's reprocessing plant at La Hague, concluding, "We must learn lessons from France's nuclear program" (pp. 161-163).

In 2006, Edwin Lyman of the Union of Concerned Scientists and the current author were informed by the then chair and ranking minority member of the House Appropriations Subcommittee on Energy and Water Development that DOE had told them that reprocessing would be less costly than dry cask storage. At the time, the actual cost of reprocessing was ten times higher than that for dry-cask storage.

With the Republicans' loss of control of Congress in the 2006 election, the pressure on DOE to reprocess abated. Industry continued to press the NRC to develop regulations, however. In 2011, France's government-owned fuel-cycle company, AREVA, wrote to the NRC,

"Assuming a final [NRC] rule in 20l5...projections suggest that construction [of an AREVA reprocessing plant in the US] could begin as early as 2020, with receipt of used fuel in 2025, and initial fuel treatment in 2030. Licensing by the NRC is on the critical path."

GE-Hitachi wrote similarly

"to express the continuing commitment of General Electric-Hitachi (GEH) to developing our Power Reactor lnnovative Small Modular (PRISM)/Advanced Recycling Center (ARC) technology."

AREVA went bankrupt in 2016, and was down-sized and restructured under a new name, Orano. GE-Hitachi was unable to find customers for its liquid-sodium-cooled PRISM reactor.

The dream of sodium-cooled reactors refused to die, however. Lowell Wood, a protégé of Edward Teller, who had driven the development of US thermonuclear weapons, convinced Bill Gates that "traveling-wave" sodium-cooled reactors could revive nuclear power. Gates founded a company, Terrapower to foster the development of these reactors.

After the traveling-wave concept proved to be infeasible, Terrapower shifted to promoting sodium-cooled plutonium-breeder reactors of the type that the US Atomic Energy Commission and other leading nuclear-energy establishments around the world had developed in the 1960s and 1970s. This earlier effort had collapsed as global nuclear capacity plateaued after 1990 due to cost and safety concerns. Sodium-cooled fast-neutron reactors had proven to be more costly and much less reliable than light-water reactors and the effort to commercialize them failed despite the expenditure of about $100 billion on research, development and demonstrations worldwide. The program's most important legacy was its facilitation of nuclear-weapon proliferation to India (see, for example, Frank von Hippel, Masafumi Takubo and Jungmin Kang, Plutonium: How Nuclear Power's Dream Fuel Became a Nightmare (Springer, 2019)).

Nuclear Idaho The persistence of US interest in reprocessing comes in large part from Idaho National Laboratory (INL), the center since the 1960s and 1970s of US efforts to develop sodium-cooled plutonium breeder reactors. INL has remained enamoured with its concept of Integral Fast Reactor complexes in which groups of sodium-cooled plutonium-breeder reactors would have their own "pyroprocessing" plants (INL's preferred reprocessing technology) onsite to recycle plutonium from their spent fuel into fresh fuel. INL has sustained its pyroprocessing program for three decades by using it to convert the spent fuel of its shutdown Experimental Breeder Reactor II (EBR II) into a stable waste form suitable for disposal in a deep-underground radioactive waste repository. The EBR II fuel could not be disposed directly in a spent fuel repository because it contains liquid sodium to conduct heat from between the fuel "meat" and cladding. Sodium burns on contact with air or water. INL's pyroprocessing program has, however, suffered huge cost overruns and schedule slippages, and has failed in its mission to produce stable radioactive waste forms.

Idaho's Republican Senators took the lead in the effort to get DOE funding to promote the demonstration of sodium-cooled reactors. They were joined by an influential group of Senate Democrats who had become convinced that a revival of nuclear power would be necessary to achieve the goal of phasing out fossil fuels. Together, the bipartisan group managed to pass the Nuclear Energy Innovations Capabilities Act of 2017 which mandated that DOE pursue the construction of a "versatile reactor-based fast neutron source" and bring it into operation by 2025.

Under the Trump Administration, DOE's Office of Nuclear Energy, led by a former INL staffer, decided to contract with Terrapower and GE-Hitachi to construct a multi-billion dollar, plutonium-fueled "Versatile Test Reactor" (VTR) at INL to test fuels and materials for fast-neutron reactors. It also initiated a cost-sharing arrangement with Terrapower and GE-Hitachi for the construction of a "Natrium" demonstration power reactor (natrium is Latin for sodium). The designs of both reactors are based on the PRISM reactor, whose design is based in turn on that of the EBR II, which operated at INL from 1964-94. Congress has thus far only supplied the first tranches of funding for these efforts.

The INL fuel design that GE-Hitachi and Terrapower have adopted must be reprocessed to create a stable waste form. On May 19, 2021, DOE announced a $40 million initiative to "limit the amount of waste produced from advanced nuclear reactors" - code for reprocessing - and, on June 28, 2021, it announced a cost-sharing agreement under which Argonne National Laboratory is to transfer pyroprocessing technology for separating plutonium from spent nuclear fuel to Oklo, a $25-million startup that proposes to mass-produce potassium-cooled, 1.5 megawatt fast-neutron microreactors, which would also use the INL fuel design.

In parallel, in Canada, Moltex, a UK startup, proposes to pyroprocess spent Canadian nuclear fuel to obtain plutonium to fuel small molten-salt-cooled fast-neutron reactors, and to make Canada a hub for exporting these reactors and their small pyroprocessing plants. Canada's Ministry of Natural Resources has announced a CAD50.5 million grant in support the development of this proposal. A group of senior US nonproliferation experts wrote to Canada's government requesting a non-proliferation and waste-management review of Moltex's proposal. A similar request for a nonproliferation review of DOE's promotion of reprocessing has been submitted to the Biden Administration.

Reprocessing is much more costly than spent-fuel storage and direct disposal. Since nuclear energy is already struggling economically to compete with renewables, making it still more costly will do it no favors. And DOE's promotion of pyroprocessing could once again legitimize reprocessing R&D in countries seeking a nuclear-weapon option.

Kazakhstan's National Nuclear Center reported that it completed the process of downblending the HEU fuel of the IGR uranium-graphite research reactor. On 23 April 2021, the material was delivered to the reactor site in Kurchatov, where it was placed in storage. Fresh HEU fuel was downblended at the Ulba Metallurgical Plant.

The IGR reactor is expected to be decomissoned. There is still some irradiated HEU fuel stored at the reactor site.

By Hui Zhang

20210321 Jinta.png Figure 1: The demo reprocessing and MOX facilities under construction at Jinta, Gansu. Satellite image from 1 March 2020 (Coordinates: 40.333750, 98.494167). Credit: DigitalGlobe. Note that significant construction activities for reprocessing facility project II likely started after December 2020. This March 2020 image just shows related ground preparations.

Commercial bidding and purchase documents and other accounts suggest China is likely to start construction of a second spent fuel reprocessing plant of the same capacity and at the same site as its first such plant, the CNNC Gansu Nuclear Technology Industrial Park in Jinta, Gansu province.

Since 2015, China has been constructing a civilian "demonstration" reprocessing plant for spent light-water reactor fuel, with a capacity of 200 tons per year (tons of Heavy Metal, tHM/year). The construction activities and equipment purchases suggest that this first plant (Project I) could complete its civil engineering stage and begin equipment installment in late 2020. Project 1 is expected to be operational in 2025. The start of work on the second reprocessing plant (Project II) in late 2020 or early 2021 suggests that it could be commissioned before 2030.

In contrast to the launch of construction of Project I, there have been no official statements or news coverage so far concerning this new facility. There have been a number of announcements, however, including bid requests for various studies and services for "spent fuel demonstration reprocessing plant project II":

  • Jiangsu Shentong company, an equipment supplier, stated in a report dated 18 November 2019 that the China National Nuclear Corporation planned to build two 200 tHM/year reprocessing plants according to CNNC's 2012 "Long Teng 2020" (Dragon Soars 2020) technology innovation plan.
  • Bid for investigation of the impact of Project II on the environment and the adjacent community to be completed by 28 February 2021(posted on 5 November 2020).
  • Bid for supplementary investigation of average and extreme weather conditions in the Project II area for completion by 28 February 2021 (posted on 5 November 2020).
  • Bid for analysis of the environmental noise around the site of Project II, with completion required before 30 December 2020 (posted on 2 November 2020).
  • Bid for statistical analysis of meteorological parameters required for the design of the heating, ventilation, and air-conditioning system for Project II (posted on 9 December 2020).
  • Bid for design of auxiliary facilities for Project II with a bidding period of 28 February 2021 to 5 March 2021 (posted on 28 February 2021).

Satellite images suggest that, as of November 2019 the buildings hosting spent fuel reception pools for the first demonstration reprocessing plant seem to have been finished and the high stack of the first reprocessing plant is also complete. The main processing buildings were under construction. The company started to order equipment for the reprocessing line in the same period. In December 2019, CNNC called for a bid for a fluidized-bed facility for the reprocessing plant to be received by September 2020. In January 2020, the company finished the bidding process for procurement of a nitrogen oxide exhaust gas treatment system.

Since 2018 CNNC has also been building a demonstration mixed uranium-plutonium oxide (MOX) fuel fabrication line with a capacity of 20 tons/year near the demonstration reprocessing plant. In 2019, the company started to order equipment for the MOX fabrication line. The civil engineering stage was expected to be completed and equipment installation started in 2020, with the plant to be commissioned by 2025.

The two 200 tHM/year per year reprocessing plants, operating at 50% capacity, and the 20 tons per year MOX plant could support the plutonium needs (about 2 tons of plutonium) of China's two CFR600 fast reactors under construction at Xiapu, Fujian Province. Construction on these reactors started in December 2017 and December 2020, and they are planned to be operational in 2023 and 2026 respectively. The first CFR600 will commence operating with HEU fuel rather than MOX; Russia's TVEL contracted in 2019 to supply the initial HEU core and reloads for seven years. It is currently unclear if the second reactor also will start out with HEU fuel or operate only with domestic MOX fuel.

Based on the MOX fuel requirements of Russia's prototype BN800 fast reactor (an initial core of 15.8 tons of MOX with 20.5% plutonium content), each CFR600 could require an initial core of about 10 tons of MOX fuel. Assuming the CFR600 MOX fuel contains about 20% plutonium, the initial MOX core would require about 2 tons of plutonium. The 200 tons of spent light water reactor fuel processed annually by each of the reprocessing plants that are under construction would also contain about 2 tons of plutonium. Operating at a capacity of 20 tons per year the demonstration MoX plant could produce these two initial cores in a year. Thereafter, each CFR600 may require about 5.5 tons per year of MOX, containing about 1 ton of plutonium (assuming each has a power of 1500 MWt, and average burnup of 80 Mwt-day/kgHM, and a capacity factor of about 80%).

By Piet de Klerk

Veerman.jpegIn the 1970s Frits Veerman (1944-2021) was a young professional photographer in Amsterdam. He was the first to blow the whistle on what was to become the most prominent nuclear technology smuggling ring in history, but was punished for his honest and courageous action. Veerman died a few weeks ago.

At the time Veerman worked at the consultancy FDO (which stands for Fysisch-Dynamisch Onderzoek), part of the Stork concern. One of FDO's large clients was UCN (Ultra Centrifuge Netherlands), for which it researched the metallurgical aspects of gas centrifuges for uranium enrichment. In May 1972 a new colleague arrived: Abdul Qadeer Khan, a Pakistani metallurgist who had studied in Germany and the Netherlands and who had done his PhD in Leuven, Belgium.

Veerman got along well with his new Pakistani colleague, the two shared an office. Khan was an attentive, easy going young man with a ready smile. After a while Veerman started to join Khan for dinner from time to time at his home in Zwanenburg, near Schiphol Airport, where he met Khan's wife Hendrina and their two daughters.

Veerman's new colleague was sent to the UCN plant in Almelo, because Khan's expertise was wanted. Pretty quickly Khan spent a lot of time in Almelo and despite his low clearance he didn't spend his time only in his designated office, but managed to roam around the facility, helping UCN colleagues with their problems.

Veerman started to be somewhat suspicious in 1973, but it was only in mid-1975 that alarm bells went off. He saw highly classified drawings in Khan's house - against all rules. Veerman was asked by Khan to photograph those classified centrifuge drawings before the originals went back to the plant (which Veerman refused). Moreover he heard Khan discuss sensitive centrifuge matters by telephone with his old professor in Leuven. Veerman was concerned and informed his superiors at FDO and other relevant players. The net result of his efforts was that he was told to keep his mouth shut.

The A.Q. Khan story is well known: Khan's letters, prompted by the Indian explosion in May 1974, to Prime Minister Zulfikar Ali Bhutto - who had instructed Pakistani scientists to work on nuclear weapons in 1972; his efforts to collect as much information about centrifuges as possible in the course of 1975; his return to Pakistan, taking control after a while of the Pakistani enrichment efforts, and building the Kahuta enrichment plant that supplied the highly enriched uranium for the Pakistani nuclear tests in 1998.

Veerman was not the only one who became suspicious. In the second half of 1975 several incidents came to light: an order in the UK for frequency converters used for the motors that drive centrifuges, an order in France from the Pakistani embassy in Brussels clearly based on an UCN document, and Khan's suspicious behaviour at a nuclear exhibition in Basel. But Veerman was the first whistle-blower in the Khan case and he was treated the worst.

Veerman and Khan carried on a correspondence after Khan's return to Pakistan in late 1975. Khan's letters included technical questions about classified matters. When Veerman showed one of these letters to his superiors he was told to burn it. In 1978 he was fired.

In 1981 the A.Q. Khan letter resurfaced and played a pivotal role in the Amsterdam court case against Khan. The court sentenced Khan to four years in prison, but that sentence was later annulled for formal reasons: the summons had never reached the accused. The Netherlands Government had done what it could to reach Khan, had gone to his house, where the doorbell wasn't answered, had then invoked the assistance of the Pakistani Foreign Ministry, which said 'no problem', accepted the summons and then probably dropped the document in the waste paper basket.

Frits Veerman's role was one of the many pieces of the Khan Affair, especially if we define the Khan Affair not only as Khan's key part in the Pakistani nuclear weapons programme, but include also his central part in the smuggling ring that offered centrifuge technology to Iran, Iraq, Libya and North Korea - until his enterprise came crashing down in 2003. But Veerman's role is important because he took classification and non-proliferation rules seriously and acted on his suspicions in an honest and courageous way.

Veerman was starting to be recognized for his actions when the Whistleblowers Authority - a Dutch institution that was created in 2016 - came to the conclusion that Veerman was unfairly treated at the time, as it considered it likely that whistleblowing was the reason for firing him in 1978. And he was at the center of the documentary Under the Spell of the Bomb.

It is likely that commercial interests explain to a large extent why Veerman's s efforts in the 1970s were ignored, but what else played a role is unclear. There are still many unanswered questions in the Khan Affair, related to events in the Netherlands, the United States, Pakistan and elsewhere. Getting to the bottom of them would help make non-proliferation policy more effective.

Photo: Transparency International Netherlands

The MSZ Plant in Electrostal, near Moscow (part of the TVEL division of Rosatom), set up a production line that will manufacture uranium fuel for China's CFR-600 fast neutron reactor. According to the fuel supply contact that was signed in December 2018, TVEL will provide fuel for the initial load and then for reloads during first seven years of CFR-600 operation. The production line will also manufacture fuel for Russia's BN-600 reactor and for China's CEFR reactor. The first shipment of CFR-600 fuel is expected in 2023, when the reactor is expected to begin operations.

While the official sources do not specify the level of enrichment of uranium in fuel, at least some of it will contain HEU. Russia's BN-600 reactor uses uranium fuel with three levels of enrichment - 17%, 21%, and 26%. It was reported earlier that CEFR fuel contains uranium with 64.4% enrichment. It is likely that CFR-600 will use HEU in some of its fuel elements as well, with enrichment similar to that of BN-600.

Russia has already supplied fuel for the CEFR reactor, which was reloaded in 2020. That fuel was also manufactured by MSZ, although at a different production line.

It appears that China plans to switch CFR-600 to plutonium-based fuel after 2030. It planned to begin irradiation of MOX fuel assemblies in CEFR in 2018 (or even in 2015), but it appears that the plan has been reconsidered.

In December 2020, China began construction of a second CFR-600 reactor, which is expected to begin operations in 2026. At this point it is not clear whether the reactor will start with HEU fuel and whether Russia will supply fuel for it as well.

Plutonium for the CFR-600 program is likely to be separated at two reprocessing plants that are currently under construction at Jinta, located near Jiuquan city of Gansu province. Construction of the first plant with the capacity of 200 MTHM/year began in 2015. A second 200 MTHM/year plant (Project II) appears to have begun in the late 2020 or early 2021. Jinta is also the site of a MOX fuel fabrication facility with the projected capacity of 20 MT of fuel per year. This combination of two reprocessing plants and a MOX facility appears to be sufficient to support operations of two CFR-600 reactors when they switch to MOX fuel.

Commercial satellite imagery obtained by the IPFM shows significant new construction at the Dimona site in Israel, officially known as the Negev Nuclear Research Center. The imagery was acquired by the SuperView-1 (SV-1) satellite on Monday, 4 January 2021. The construction site is located in the immediate vicinity of the buildings that house the nuclear reactor and the reprocessing plant (to the south-west from the buildings, around the point with coordinates 31.000, 35.143). It can be seen on the satellite image posted below.

dimona-spacewill-04january2021.jpg SuperView-1 image from 4 January 2021 at 2-meter resolution. Credit: SpaceWill

The exact date the construction began is uncertain. The last satellite image available from Google Earth, which was obtained in September 2011, does not show any activity at the site. The first signs of construction are visible on an image available from the HERE WeGo service (the date of that image is unknown).

The 2021 image shows that the construction has expanded and appears to be actively underway with multiple construction vehicles present. At this stage, the construction appears to be centered around a large-scale excavation area with the size of about 140 meters by 50 meters. The purpose of this construction is unknown.

dimona-comparison.jpg Satellite images of the Negev Nuclear Research Center. Left: Google Maps, September 2011, right: HERE WeGo, date unknown.

UPDATE 2/19/2021: The construction apparently began in late 2018 or early 2019 (via Samir @obretix). dimona-2019.png

China's Experimental Fast Reactor (CEFR) operated by the China Atomic Energy Institute (CAIE) has started what was described as "high-power operations," as quoted in a World Nuclear News Report.

The reactor, which is designed to operate with "65MW thermal power and 20MW experimental generation power", first reached criticality in July 2010 and it was connected to the grid in July 2011. In 2014, it operated at full power for 144 hours (72 hours according to a different source). It appears that CEFR was shut down after that to be restarted and connected to the grid for the second time in October 2015, at 20% nominal power.

According to a CNNC report, the reactor was shut down at some point after completing the low-power test phase. It was restarted on 19 June 2020 "for high-power operations." About 40 days of tests appear to have concluded with a "100 percent power manual emergency shutdown test," conducted on 31 July 2021. After that the reactor entered shutdown for its first refueling and maintenance.

The reactor was restarted again on 19 January 2021 and re-connected to the grid on 15 February 2021. It appears that this time CEFR entered the "power test phase" of the tests.

CEFR operates with HEU fuel (64.4% HEU) supplied by Russia. The most recent shipment of fuel took place in July 2019.

China started construction of the second breeder reactor of the CFR-600 type at the site at Xiapu, Fujian province, where it is building the first CFR-600 unit. Construction of the first unit began in December 2017. The first unit is expected to begin operations in 2023, which suggests that the second one will be operational in 2026.

The upcoming construction was first reported by Zhang Hui of the Belfer Center for Science and International Affairs at Harvard University - See "CNNC Embarks on Second CFR-600," Nuclear Intelligence Weekly, 22 May 2020 and Hui Zhang, "China is speeding up its plutonium recycling programs," Bulletin of the Atomic Scientists, 76:4, 210-216.

By Greg Mello

Fundamental technical and political issues remain unresolved in plans to produce new plutonium pits for U.S. nuclear weapons. These plans aim at building and operating two pit factories to meet an Administration requirement (pp. 1, 5-6), subsequently made into law (50 U.S.C. 2538a; refined at Pub. L. 115-232, §3120), for an enduring production capacity of at least 80 pits per year (ppy) beginning in 2030. The plans call for the Savannah River Plutonium Processing Facility (SRPPF) to produce 50 ppy and the Los Alamos National Laboratory (LANL) plutonium facility (PF-4) to produce 30 ppy. Despite fully funding the National Nuclear Security Administration (NNSA's) pit production budget through fiscal year 2020 (FY20), Congress remains unsure about NNSA's approach, which independent reviews have criticized. The Government Accountability Office (GAO) notes (e-p. 2) that no detailed plan and schedule have been prepared for pit production.

The only authorized warhead program needing new pits is the W87-1 warhead for the Ground Based Strategic Deterrent (GBSD), to begin production in 2030. The Congressional Budget Office (CBO) noted in August 2020 that GBSD missiles would have the capability to carry three warheads each, up to 1,200 deployed warheads in all (p. 11). The ~540 W87 warheads available (p. 3) are not enough to provide this capability, if deployed on GBSD directly; neither can they provide enough re-used pits to build W87-1s for the same purpose. Even if rushed, planned pit production may be unable to meet the W87-1 schedule (e-p. 2; also pp. 29-38).

Pit production authorization and funding for FY21

Congress authorizes defense programs in each year's National Defense Authorization Act (NDAA) and funds them in appropriations acts. In late July, the House and Senate versions of the FY21 NDAA (H.R. 6395 and S. 4049 respectively) each authorized the full requested amount for NNSA's Weapons Activities budget line ($15.60 billion), including the pit production budget in every detail. A final NDAA has not yet been agreed.

There were concerns. The Senate Armed Services Committee (SASC) draft FY21 NDAA requires (p. 417) a nationwide review of plutonium infrastructure by the GAO. The SASC also sees that the tentative assignment of the surplus plutonium oxidation mission to LANL's main plutonium facility (PF-4) strongly competes with LANL's pit production mission, as GAO has warned. The SASC requests a report detailing oxidation options by March 1, 2021. Currently, the plutonium from surplus pits stored at Pantex is to be oxidized at LANL's PF-4 and then sent to the Savannah River Site (SRS) to be packaged and shipped to the Waste Isolation Pilot Plant (WIPP) in New Mexico for final disposal.

In its markup of the FY21 NDAA, the House Armed Services Committee (HASC) added Section 3115 (pp. 2284-2287), which seems intended to halt pit production at the SRPPF while providing a means of accepting a delay for "up to five years," (p. vii) in the 80 ppy requirement (the Senate had no comparable provision). SRS production, if paused or canceled this way, would be replaced by "temporarily surging the production of such pits at [LANL] and other mitigation strategies." The feasibility of any LANL "surge" is however uncertain at best. NNSA's 2017 Analysis of Alternatives (AoA) found that any PF-4 "surge" was infeasible (p. 2); NNSA's 2018 Engineering Analysis (EA) found that the alternative involving a surge had by far the highest risk (Alt. 2c, slide 8); in 2019 the Institute for Defense Analyses found that any surge in PF-4 would be "very high risk" (p. vii). GAO recently cited a classified LANL study which found that LANL was only "marginally capable" of reaching 30 ppy by 2026 "and sustaining that rate thereafter" (p. 35).

This year's appropriations process has been slow. The government is currently operating under a Continuing Resolution (CR) expiring on December 11, 2020, which limits Department of Energy (DOE) expenditures to FY20 levels for each budget line and prevents new programs and projects.

Prior to the CR, the House passed an appropriations bill (H.R. 7617) that provides $1.08 billion for pit production in FY21, $0.29 billion less than requested but $0.37 billion more than enacted the previous year. The bill cuts $135 million from SRS's and $157 million from LANL's pit production accounts while allowing most (at LANL) or all (at SRS) funds requested for pit infrastructure (pp. 170-171).

The Administration's budget request for FY21 for pit production ("Plutonium Modernization") was $1.39 billion, a dramatic increase from the $0.80 billion and $0.41 billion spent in FY20 and FY19, respectively. An additional $0.24 billion in FY21 was requested in other infrastructure improvements for pit production at LANL, as identified by Senator Heinrich (D-NM), bringing the nationwide FY21 total to $1.62 billion. Including these pit infrastructure projects, the projected FY19-25 total for pit production is $11.67 billion, of which $7.58 billion is earmarked for LANL, $4.09 billion for SRS, and $0.52 billion for other sites (slide 23).

In its report on the draft funding bill, the House Committee on Appropriations notes NNSA has no detailed plan for pit production:

The Committee remains concerned that NNSA has not prioritized the development of a resource-loaded integrated master schedule that includes all pit production-related, project-related and program activities as recommended by the GAO and does not appear to have plans to complete such a schedule until after it would have had to achieve certain pit production milestones. (p. 140)

A GAO report released on September 30 found that "NNSA's plutonium program...has not yet completed an integrated schedule for the overall pit production effort" (e-p. 2). NNSA is directed to submit such a plan within 30 days of enactment.

Noting that the risk of failure is high, the Committee also requires that NNSA submit, by 120 days after enactment, a contingency plan for managing the stockpile in the event the 2030 pit production deadline is not met. This contingency plan must be updated annually and submitted with the budget request. The plan must include:

options to ramp up pit production that extend the current need dates for pit production; how the hedge and fielded stockpile could be configured to serve as an interim solution; and an estimate of how many years current pit production need dates could be extended by advancing pit reuse concepts. (p. 140)

These appropriations requirements are binding even if omitted in the final conference report as long as they are not explicitly negated or modified.

The Senate Appropriations Committee has not acted.

Costs

CBO estimates the marginal pit cost at a 50-ppy SRPPF at $6 million (p. 14), an order of magnitude higher than the $300-750 million estimated by NNSA (p. 22). LANL's costs may be far higher. In 2017 the cost of establishing an average 30 ppy production in the now-ended Plutonium Sustainment program (which "differs significantly" from today's at least 30 ppy requirement; see AoA, p. 1) at LANL was thought to be $3 billion (slide 2). GAO used a similar figure ("up to $3 billion," p. 15). Yet requested pit production startup costs at LANL are $7.6 billion through FY25 (slide 23) and will be about $14 billion through 2030 (slide 29).

One of the reasons for this great increase is the newly-revealed necessity of running PF-4 and surrounding facilities on a 24/7 basis (two production shifts and a maintenance shift) to achieve even 20 ppy (p. 15), necessitating a much larger staff and more support facilities and infrastructure. NNSA has now indicated indirectly that LANL needs 4,000 production and support staff to achieve 30 ppy (slide 29).

Assuming a steady-state production assumption of 43 ppy (AoA, p. 13, more optimistic than GAO's 30 ppy, p. 16), four reasonable production scenarios generate a cost per LANL pit in the range of $38-60 million (slides 29-31), almost an order of magnitude more than at SRS and two orders of magnitude beyond NNSA's estimate.

It is not possible to credibly predict future pit production at LANL, nor will it be, at least not until 2025 given the unresolved problems flagged by the Defense Nuclear Facilities Safety Board (DNFSB) (slides 6-15), some of which may be resolved by then (slide 21).

For the long-standing issue of legacy transuranic (TRU) waste disposition, there is no timely solution. There are roughly 19,000 drums and other containers of TRU stored at LANL, with thousands of these in an unsafe condition above-ground near the public and other thousands in long-term but temporary shallow burial, subject to corrosion. Storage capacity for new TRU waste from pit production is also inadequate (pp. A-13,14).

National Environmental Policy Act (NEPA) compliance

NNSA has issued final NEPA documents for pit production, including a Final Environmental Impact Statement (EIS) for the Savannah River Plutonium Processing Facility (SRPPF) pit production complex at SRS (September 2020, EIS-0541), a Final Supplement Analysis (SA) for the continued operation of LANL under conditions of pit production (August 2020, DOE/EIS-0380-SA-06), and a Final SA for nationwide NNSA and DOE operations under conditions of pit production (December 2019, DOE/EIS-0236-S4-SA-02). Records of Decision (RODs) (site-wide, nationwide) have been issued for industrial pit production at LANL and SRS (project-specific, nationwide). Serious questions have been raised about the adequacy of these NEPA processes but no litigation has yet been filed.

The United States and Kazakhstan announced the elimination of unirradiated HEU fuel of the IGR research reactor. According to the statement, 2.9 kg of unirradiated HEU was transported to the Ulba Metallurgical Plant, where it was downblended. "The downblending process included crushing and grinding the graphite/uranium blocks, oxidizing the graphite material, dry mixing with LEU powder, dissolving the uranium, and adjusting to get the uranium oxide to 19.8% enrichment."

IGR is a pulsed reactor that used uranium-graphite fuel with 90% HEU. It is not clear any irradiated fuel remains on site. The reactor is likely to be decommissioned.

During the 2020 IAEA General Conference the United States and Kazakhstan confirmed their commitment to work together to eliminate all HEU in Kazakhstan and to complete conversion of the remaining HEU research reactor, IVG.1M, to LEU in 2021. In 2017, Kazakhstan conducted first tests of LEU fuel for IVG.1M, supplied by Russia.