it would take hundreds more to get into the GNEP ballpark. Nor is it plausible that GNEP would facilitate such an expansion.

PROLIFERATION: INTERNATIONAL ASPECTS OF GNEP

The other main GNEP goal is antiproliferation, keeping additional countries from getting bombs. There is a lot of confusion about this goal. GNEP’s fuel cycle is said to be “proliferation-resistant” because it would keep plutonium mixed with other radioactive elements—the current choice is neptunium—to provide some self-protection.

A committee member pointed out that mixing plutonium with mildly radioactive neptunium is about as effective protection as mixing it with highly enriched uranium, because neptunium-237 and uranium-235 have similar properties. Therefore, the proposed addition of actinides to plutonium does not significantly increase the radiological barriers to theft or make it significantly more difficult to use the material as an explosive. This feature of the reprocessing scheme is really intended to protect against theft and terrorism in the supplier countries that have reprocessing plants and has nothing to do with antiproliferation.

The more important point—GNEP Strategic Plan (Section 2.1.2)—is that the GNEP Strategic Plan is based on there being no technological fix that would make reprocessing safe enough to spread to all countries. The GNEP Strategic Plan argues that antiproliferation dictates finding a way to keep most countries from engaging in reprocessing. Thus GNEP would rely on fuel supply assurances to dissuade most countries—call them B countries—from developing their own enrichment or reprocessing facilities.

These countries would in effect lease fuel from a small number of A countries and return the spent fuel containing plutonium. In this scheme, only the A countries would reprocess and burn the plutonium-actinide mixture in their own fast reactors, so the B countries would never have access to this nuclear explosive. GNEP assumes the B countries would voluntarily forgo reprocessing to get assured access to fresh fuel.

But if this decision were based on economics, there would not be any reprocessing and recycle today (MOX, plutonium-based fuel, is several times as expensive as low-enriched uranium fuel). And there is no problem today for any country adhering to the Non-Proliferation Treaty (NPT) in buying uranium fuel, so what advantage would GNEP assurances have over current fuel contracts? DOE’s Office of Nuclear Energy (NE) said the extra assurances would make it even more difficult than it now is for a country like Iran to justify its own enrichment or reprocessing. That is not a serious reason to spend tens of billions of dollars.

It is also unclear why, as GNEP argues, the United States has to reprocess in order to provide fuel assurances. Since the GNEP idea is that the B countries would just lease fresh fuel and send back spent fuel, why would they care whether the spent fuel is reprocessed or not?

There is also the problem of creating, beyond the NPT, another division of nuclear countries, the As and the Bs—or haves and have-nots. One indicator of the likely reaction is that there are lots of volunteers to be “A” countries but, apparently, none to be a “B” country.

There is another problem: consistency. It is evident from the presentations to the committee that the administration does not intend to take back foreign spent fuel—for one thing because doing so would jeopardize congressional approval of the initial parts of the GNEP program. So the nonproliferation part of GNEP is really about other “supplier” countries—for example, France—taking back foreign spent fuel. It is naïve to expect that the existing reprocessing countries would adopt the more complicated and expensive GNEP technology.

The ultimate nonproliferation argument for GNEP is that only if the United States engages in large-scale reprocessing can it gain a seat at the table in international discussions about the rules for nuclear energy use. The only thing to say about this is that the United States is always going to have a seat at the table.

To sum up, the main point of our discussion is that GNEP’s antiproliferation goal does not provide a rationale for DOE-NE R&D on reprocessing and fast reactors, whether in the context of GNEP or of the original AFCI.

We do want to acknowledge that while we disagree with its planned execution, we agree with some of GNEP’s underlying assumptions about the dangers of easy access to plutonium: (1) that all grades of plutonium, regardless of the source, could be used to make nuclear explosives and must be controlled; (2) that widespread access to reprocessing, no matter what the technology, is equivalent to access to plutonium and poses an international security problem; (3) that widespread use of MOX fuel by both weapons states and nonweapons states is similarly risky, because the contained plutonium can be extracted relatively easily; and (4) that even in the weapons states, the plutonium must be in a self-protecting form.

MANAGEMENT

DOE-NE has no track record of successful project management. We are unaware of any successful historical DOE model for bringing technology to a commercial scale, as the agency intended to do under GNEP; nor was NE able to provide an example.

In fact, DOE has suffered chronic project management problems, as recorded in numerous GAO reports, the latest of which1 states as follows:

1

Government Accountability Office, Department of Energy Consistent Application of Requirements Needed to Improve Project Management, GAO-07-518, May 2007.



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