This is the accessible text file for GAO report number GAO-08-483 
entitled 'Global Nuclear Energy Partnership: DOE Should Reassess Its 
Approach to Designing and Building Spent Nuclear Fuel Recycling 
Facilities' which was released on May 22, 2008.

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as part 
of a longer term project to improve GAO products' accessibility. Every 
attempt has been made to maintain the structural and data integrity of 
the original printed product. Accessibility features, such as text 
descriptions of tables, consecutively numbered footnotes placed at the 
end of the file, and the text of agency comment letters, are provided 
but may not exactly duplicate the presentation or format of the printed 
version. The portable document format (PDF) file is an exact electronic 
replica of the printed version. We welcome your feedback. Please E-mail 
your comments regarding the contents or accessibility features of this 
document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

Report to Congressional Committees: 

United States Government Accountability Office: 
GAO: 

April 2008: 

Global Nuclear Energy Partnership: 

DOE Should Reassess Its Approach to Designing and Building Spent 
Nuclear Fuel Recycling Facilities: 

GAO-08-483: 

GAO Highlights: 

Highlights of GAO-08-483, a report to congressional committees. 

Why GAO Did This Study: 

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. 

What GAO Found: 

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. 

What GAO Recommends: 

GAO recommends that DOE reassess its preference for accelerating GNEP. 
DOE stated it will continue to assess alternative approaches to GNEP. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-483]. For more 
information, contact Gene Aloise at (202) 512-3841 or aloisee@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

DOE's Original Engineering-Scale Approach Would Meet GNEP's Objectives 
If Advanced Recycling Technologies Are Successfully Developed: 

DOE's Accelerated Approach Would Likely Rely on Technologies That Fall 
Short of Meeting GNEP's Objectives: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: DOE's Use of Technology Readiness Levels to Assess the 
Maturity of Spent Fuel Recycling Technologies: 

Appendix III: Comments from the Department of Energy: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: Materials in Spent Nuclear Fuel and Their Potential 
Disposition under GNEP: 

Figures: 

Figure 1: Advanced Technologies for Recycling Spent Nuclear Fuel 
Envisioned under GNEP: 

Figure 2: Nuclear Fuel Assembly and Uranium Pellet: 

Abbreviations: 

DOE: Department of Energy: 

GNEP: Global Nuclear Energy Partnership: 

MOX: mixed oxide: 

NRC: Nuclear Regulatory Commission: 

R&D: research and development: 

TRL: technology readiness level: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

April 22, 2008: 

Congressional Committees: 

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.[Footnote 1] 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.[Footnote 2] 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.[Footnote 3] 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.[Footnote 4] 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.) 

Figure 1: Advanced Technologies for Recycling Spent Nuclear Fuel 
Envisioned under GNEP: 

[See PDF for image] 

This figure is an illustration of the advanced technologies for 
recycling spent nuclear fuel envisioned under GNEP. The following 
information is illustrated: 

Existing and planned nuclear power plants: 
* Fresh fuel is supplied to existing/planned reactors (continuous 
process); 
* Spent fuel is sent to Advanced reprocessing plants where there is a 
separation of reusable materials from remaining waste (continuous 
process); 
* Waste is sent to Geologic disposal or other waste storage/disposal 
(continuous process). 

New facilities: 
* From advanced reactors: 
* Spend recycled fuel is sent to Advanced reprocessing plants where 
there is a separation of reusable materials from remaining waste 
(continuous process); 
* Recycled fuel is returned to the Advanced reactor (continuous 
process); 
* Waste is sent to Geologic disposal or other waste storage/disposal 
(continuous process). 

Source: GAO analysis of DOE information. 

[End of figure] 

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.[Footnote 
5] 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.[Footnote 6] 

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,[Footnote 7] 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.[Footnote 8] 

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. 

Results in Brief: 

DOE's original approach to the domestic component of GNEP--building 
engineering-scale facilities--would meet GNEP's objectives if the 
advanced spent nuclear fuel recycling technologies on which it focused 
can be successfully developed and commercialized. Successful 
development of the advanced technologies would have a greater long-term 
impact, compared with existing technologies, on GNEP's waste reduction 
objective because the advanced technologies would recycle not only 
plutonium but also other radioactive elements that a geologic 
repository has limited capacity to accommodate. Keeping plutonium mixed 
with these other elements would mitigate proliferation risks relative 
to existing technologies because the mixture would be more difficult to 
steal or divert and to fashion into a nuclear weapon than pure 
plutonium. However, DOE's engineering-scale approach had two 
shortcomings. First, it lacked industry participation, potentially 
reducing the prospects for eventual commercialization of advanced 
recycling technologies. In particular, DOE's original approach included 
managing some of the radioactive waste separated from spent fuel in a 
way that would add to the cost and difficulty of operating a 
reprocessing plant while creating waste management challenges; recent 
industry proposals under DOE's accelerated approach include potentially 
less costly and complex alternatives for managing this waste. Second, 
while building an advanced reactor and R&D facility would allow DOE to 
conduct R&D that existing facilities have limited capability to 
support, DOE's schedule called for building an engineering-scale 
reprocessing plant before developing recycled fuel and other recycling 
technologies that would help determine design specifications for the 
plant. The schedule unnecessarily increased the risk that the plant 
would separate the materials in spent fuel in a form not suitable for 
recycling. 

DOE's accelerated approach of building commercial-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. 
In addition, this approach would likely require significant government 
investment. Two of the four industry consortia that received funding 
under GNEP proposed evolutions of existing technologies that recycle 
plutonium and uranium as mixed oxide, or MOX, fuel in existing reactors 
even though the GNEP strategic plan ruled out MOX technologies. Such 
technologies would reduce the quantity of high-level radioactive waste 
requiring geologic disposal to a much lesser degree than the advanced 
technologies envisioned under DOE's original approach. The evolutionary 
MOX technologies would also mitigate proliferation risks to a lesser 
degree because a plutonium-uranium mixture for recycling into MOX fuel 
would not contain other radioactive elements that would be recycled 
using more advanced technologies--elements that could pose barriers to 
obtaining pure plutonium for weapons. While the evolutionary 
technologies could allow DOE to accelerate recycling of spent nuclear 
fuel, fully meeting GNEP's waste reduction and nonproliferation 
objectives would require a later transition to more advanced 
technologies. The other two industry consortia proposed to address 
GNEP's waste and nonproliferation objectives by using technologies that 
are no more mature or in some cases less mature than the advanced 
technologies DOE had deemed appropriate for engineering-scale 
demonstration under its original approach. Thus, these proposals do not 
meet a goal of DOE's accelerated approach of working with industry: to 
avoid the need for engineering-scale facilities and increase the speed 
of arriving at commercial facilities. Under any of the industry 
proposals, DOE is unlikely to meet its goal of developing commercial- 
scale facilities in a way that will not require a large amount of 
government investment. For example, our review of all four industry 
proposals and interviews with DOE officials indicate that none of the 
consortia have proposed a way to pay for the initial advanced reactor 
other than through government funding. DOE officials acknowledge the 
limitations of the department's accelerated approach but cite other 
benefits, such as the potential to exert international influence on 
nonproliferation issues. They have also said that, if DOE pursues 
evolutionary MOX technologies, the department will only do so as part 
of a plan for a later transition to more advanced technologies. 

Because DOE can fully address GNEP's waste reduction and 
nonproliferation objectives only by developing advanced technologies 
that are not yet ready for commercial deployment, we recommend that DOE 
reassess its preference for an accelerated approach to implementing 
GNEP. If DOE decides to pursue design and construction of engineering- 
scale facilities, we further recommend that DOE work with industry in 
doing so and defer building an engineering-scale reprocessing plant 
until conducting sufficient testing and development of recycled fuel to 
ensure that the output of the reprocessing plant is suitable for 
recycling. 

We presented a draft of this report to DOE and NRC for comment. 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. 

Background: 

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.[Footnote 9] 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. 

Materials in Spent Nuclear Fuel: 

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. 

Figure 2: Nuclear Fuel Assembly and Uranium Pellet: 

[See PDF for image] 

This figure contains an illustration of a nuclear fuel assembly and a 
photograph of a uranium pellet. 

[End of figure] 

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.) 

Table 1: Materials in Spent Nuclear Fuel and Their Potential 
Disposition under GNEP: 

Material: Uranium; 
Percentage of spent fuel[A]: 96; 
Decay heat characteristics of significance to the technical capacity of 
a geologic repository: Uranium is not a significant contributor to 
decay heat in spent fuel; 
Potential disposition under GNEP: Storage for later recycling or, if 
not recycled, disposal as low-level waste. 

Material: Fission products (e.g., cesium and strontium); 
Percentage of spent fuel[A]: 3; 
Decay heat characteristics of significance to the technical capacity of 
a geologic repository: Cesium and strontium dominate decay heat for 
decades after spent fuel is removed from a reactor; 
Potential disposition under GNEP: Disposal as high-level waste in a 
geologic repository, or, in the case of cesium and strontium, potential 
storage to allow radioactive decay to low-level waste. 

Material: Transuranics (plutonium, neptunium, americium, and curium); 
Percentage of spent fuel[A]: 1; 
Decay heat characteristics of significance to the technical capacity of 
a geologic repository: Transuranics dominate decay heat for thousands 
of years after spent fuel is removed from a reactor; 
Potential disposition under GNEP: Recycling in an advanced reactor, 
assuming successful R&D on recycled fuel containing the transuranics. 

Material: Total; 
Percentage of spent fuel[A]: 100; 

Source: GAO analysis of DOE information. 

[A] The percentages of materials in spent fuel vary depending on the 
characteristics of particular fuel assemblies and do not include the 
structural hardware of the assemblies. 

[End of table] 

Technologies for Recycling Spent Nuclear Fuel: 

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[Footnote 10]--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. 

DOE's Original Engineering-Scale Approach Would Meet GNEP's Objectives 
If Advanced Recycling Technologies Are Successfully Developed: 

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. 

Successful Development of Advanced Recycling Technologies Would Be an 
Initial Step toward Greatly Extending the Capacity of a Geologic 
Repository: 

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.[Footnote 11] 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. 

Advanced Recycling Technologies Envisioned under DOE's Original 
Approach to GNEP Pose Lower Proliferation Risks Than Existing Recycling 
Technologies: 

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. 

Lack of Industry Participation Could Reduce the Prospects for 
Commercialization and Widespread Use of Advanced Recycling 
Technologies: 

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. 

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: 

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. 

The R&D Facility and Advanced Reactor Would Enable DOE to Develop the 
Advanced Recycling Technologies Envisioned under Its Original Approach 
to GNEP: 

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. 
[Footnote 12] 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.[Footnote 13] 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. 

DOE's Accelerated Approach Would Likely Rely on Technologies That Fall 
Short of Meeting GNEP's Objectives: 

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. 

Two Industry Consortia Have Proposed Using Evolutions of Current 
Technologies for Addressing GNEP's Objectives: 

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. 

Two Other Industry Consortia Proposed to Address GNEP's Objectives by 
Using Technologies That Are Not Mature Enough for Commercial 
Deployment: 

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,[Footnote 14] 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. 

The Government Would Likely Bear Substantial Costs for Commercial-Scale 
Recycling Facilities: 

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.[Footnote 15] 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. 

DOE Officials Recognize the Limitations of Accelerating Deployment of 
Commercial-Scale Facilities but Cite Other Benefits: 

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.[Footnote 16] 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. 

Conclusions: 

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. 

Recommendations for Executive Action: 

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. 

Agency Comments and Our Evaluation: 

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 [hyperlink, 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. 

Signed by: 

Gene Aloise: 
Director, Natural Resources and Environment: 

List of Committees: 

The Honorable Carl Levin: 
Chairman: 
The Honorable Norm Coleman: 
Ranking Member: 
Permanent Subcommittee on Investigations: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Jeff Bingaman: 
Chairman: 
Committee on Energy and Natural Resources: 
United States Senate: 

The Honorable John D. Dingell: 
Chairman: 
The Honorable Joe Barton: 
Ranking Member: 
Committee on Energy and Commerce: 
House of Representatives: 

The Honorable Bart Gordon: 
Chairman: 
The Honorable Ralph M. Hall: 
Ranking Member: 
Committee on Science and Technology: 
House of Representatives: 

The Honorable Edward J. Markey: 
Chairman: 
Select Committee on Energy Independence and Global Warming: 
House of Representatives: 

The Honorable Bart Stupak: 
Chairman: 
The Honorable John Shimkus: 
Ranking Member: 
Subcommittee on Oversight and Investigations: 
Committee on Energy and Commerce: 
House of Representatives: 

[End of section] 

Appendix I: Scope and Methodology: 

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.[Footnote 17] 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.[Footnote 18] 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. 

[End of section] 

Appendix II: DOE's Use of Technology Readiness Levels to Assess the 
Maturity of Spent Fuel Recycling Technologies: 

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.[Footnote 19] 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. 

[End of section] 

Appendix III: Comments from the Department of Energy: 

Department of Energy: 
Washington, DC 20585: 

April 14, 2008: 

Mr. Gene Aloise: 
Director: 
Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G St., NW: 
Washington, DC 20548: 

Dear Mr. Aloise: 

The Office of Nuclear Energy received a copy of the draft Government 
Accountability Office (GAO) report, "Global Nuclear Energy Partnership: 
DOE Should Reassess Its Approach to Designing and Building Spent 
Nuclear Fuel Recycling Facilities" (GAO-08-483), which was sent to the 
Secretary of Energy on March 27, 2008, and coordinated a Departmental 
review. This letter provides our response to your report. 

The Department appreciates GAO's evaluation of the Global Nuclear 
Energy Partnership program (GNEP). The GAO evaluation focused only on 
the domestic component of GNEP, which the GAO has acknowledged includes 
a significant international component. As noted in the report, the 
Secretary of Energy has not decided on a path forward for the domestic 
component of GNEP, and the Department is currently engaged in various 
efforts to help inform that decision, including preparing a 
programmatic environmental impact statement in accordance with the 
National Environmental Policy Act of 1969, and obtaining additional 
input from industry. The report accurately notes that the GNEP program 
has evolved since its inception as information was obtained from 
industry and other sources (and, in fact, continues to evolve). 

The Department agrees with many of the GAO findings, including that 
industry feedback and participation in the program is crucial for 
success. We also note the significant GAO finding that building a 
research and development (R&D) facility and an advanced, fast reactor 
would enable the Department to increase the maturity of advanced 
recycling technologies and conduct R&D that existing Departmental 
facilities have little capability to support. The Department 
acknowledges GAO's concerns regarding the timing of an advanced recycle 
plant in relation to an R&D facility and a fast reactor, and will 
address the issue as the program moves forward. 

We would, however, like to emphasize the following points that we 
believe were not properly characterized in the report. The Department 
believes the report gives the erroneous impression (1) that fast 
reactors could never be economically competitive with light water 
reactors (LWRs), and (2) that an LWR mixed oxide (MOX) fuel cycle in 
the near-term would have limited impact on waste reduction and non-
proliferation objectives and draw resources away from developing 
advanced technologies in the long-term. In fact, one of the goals of 
the current research program is to develop a fast reactor concept that 
would eventually be competitive with LWRs. The Department is also 
evaluating industry proposals that would recycle used fuel in LWRs 
during the decades it would take for fast reactors to gain wide-scale 
commercial usage. It is anticipated that LWR recycle facilities would 
be funded and constructed principally by industry only at such time as 
justified by a sound business case. Government funding for any GNEP 
fuel recycle R&D programs should not be impacted by private, commercial 
investment in LWR recycle. A significant benefit of this interim 
approach could be the substantial reduction of the quantity of used 
fuel assemblies across the nuclear fuel cycle system that otherwise 
might remain in storage during future decades prior to the availability 
of commercial fast reactor recycle. Pursuing LWR recycle in the near-
term while performing the remaining R&D required for fast reactor 
recycle could help establish the conditions necessary for the private 
sector to be ultimately willing to switch to fast reactors in the 
future, thus enabling a closed, advanced nuclear fuel cycle. 

GAO frequently refers to using advanced technologies that are more 
proliferation-resistant. The Department believes that any reprocessing 
plant if misused could be modified to create weapons usable material. 
Therefore, it is our view that non-proliferation objectives would be 
largely accomplished through international security and safeguards 
policies that seek to avoid the spread of enrichment and reprocessing 
technologies to additional nations, while at the same time eliminating 
as soon as possible existing inventories of separated plutonium and the 
production of material mixes that are attractive for use in creating a 
nuclear explosive. (These objectives are at the core of our 
international GNEP efforts). Plutonium that is sufficiently diluted 
with non-fissile material has a lower material attractiveness - 
regardless of the reprocessing technology used. The Department is 
developing technologies that do not separate pure plutonium - and can 
support similar approaches described by industry - while maintaining 
its non-proliferation objectives. 

The Department agrees with GAO's recommendations to revise the schedule 
to ensure proper alignment of development and deployment activities, 
and to work with industry to the extent possible. The Department is 
actively engaged in GNEP planning and will continue to perform 
technical, economic, and strategic analyses as appropriate to support 
the Secretary's decision on the program's direction. We are currently 
evaluating reasonable alternatives in the context of the draft GNEP 
Programmatic Environmental Impact Statement and will soon receive 
further detailed input from industry. 

I want to thank you for the opportunity to review your report and ask 
that if you have any questions regarding the Department's comments, 
please direct them to Mr. Paul Lisowski, of my staff, at 202-586-8105. 

Sincerely, 

Signed by: 

Dennis R. Spurgeon: 
Assistant Secretary for Nuclear Energy: 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Gene Aloise, (202) 512-3841 or aloisee@gao.gov: 

Staff Acknowledgments: 

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. 

[End of section] 

Footnotes: 

[1] Public Law 97-425 (96 Stat. 2201). 

[2] For more information on the status of DOE efforts to prepare a 
license application for the repository, see GAO, Yucca Mountain: DOE 
Has Improved Its Quality Assurance Program, but Whether Its Application 
for a NRC License Will Be High Quality Is Unclear, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-07-1010] (Washington, D.C.: Aug. 
2, 2007). 

[3] Under DOE's plans for the repository, the statutory limit would 
allow for 63,000 metric tons of commercial spent nuclear fuel and 7,000 
metric tons of government-owned high-level radioactive waste and spent 
nuclear fuel. 

[4] 42 U.S.C. § 10172a. 

[5] The four consortia are led by AREVA and Mitsubishi Heavy Industries 
Ltd.; EnergySolutions LLC; GE-Hitachi Nuclear Americas LLC; and General 
Atomics. 

[6] We previously reported on the challenges faced by such efforts, 
including funding constraints and the high cost and long time needed to 
develop and implement technologies. For further information, see GAO, 
Nuclear Science: Developing Technology to Reduce Radioactive Waste May 
Take Decades and Be Costly, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO/RCED-94-16] (Washington, D.C.: Dec. 10, 1993). 

[7] Congress required DOE to conduct a research, development, and 
demonstration program to evaluate recycling technologies as an 
alternative national strategy for spent nuclear fuel. Pub. L. No. 109- 
58, § 953, 119 Stat. 594, 886 (2005). 

[8] GAO, Department of Energy: Major Construction Projects Need a 
Consistent Approach for Assessing Technology Readiness to Help Avoid 
Cost Increases and Delays, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-07-336] (Washington, D.C.: Mar. 27, 2007). 

[9] References in this report to the capacity of the Yucca Mountain 
geologic repository are to its technical capacity unless otherwise 
noted. 

[10] Specifically, MOX fuel contains a mixture of plutonium oxide and 
uranium oxide. 

[11] The Nuclear Energy Agency is part of the Organisation for Economic 
Co-operation and Development, an intergovernmental organization of 
industrialized countries. The mission of the Nuclear Energy Agency 
includes providing assessments of nuclear energy policy. The Nuclear 
Energy Advisory Committee, formerly the Nuclear Energy Research 
Advisory Committee, provides advice to the DOE Office of Nuclear Energy 
on science and technical issues related to DOE's nuclear energy 
program. The Electric Power Research Institute conducts R&D on behalf 
of the electricity industry, including R&D on nuclear energy 
technologies. 

[12] The Columbia Basin Consulting Group, which favors restarting the 
facility, developed the $500 million estimate. DOE officials do not 
consider the estimate to be reliable because it was developed quickly 
and has not been independently validated. 

[13] These sizes are expressed in thermal power, which is the gross 
power of a reactor and does not take into account the efficiency of 
conversion to electricity. 

[14] The consortium specifically recommended the use of a gas-cooled 
thermal reactor of the type being developed by DOE under a different 
nuclear energy R&D program. For more information on this program, see 
GAO, Nuclear Energy: Status of DOE's Effort to Develop the Next 
Generation Nuclear Plant, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-06-1056] (Washington, D.C.: Sept. 20, 2006). 

[15] The fee is currently set at one mil ($0.001) per kilowatt-hour of 
electricity generated and sold by the power plants. 

[16] For more information on this plan, see DOE, Advanced Fuel Cycle 
Initiative: Objectives, Approach, and Technology Summary (Washington, 
D.C., May 2005). 

[17] Two key National Research Council reports we reviewed include 
National Academy Press, Review of DOE's Nuclear Energy Research and 
Development Program (Washington, D.C., Oct. 29, 2007), and Nuclear 
Wastes: Technologies for Separations and Transmutation (Washington, 
D.C., 1996). 

[18] Development of grid-appropriate reactors scaled for small 
electricity grids and suited to conditions in developing nations is 
part of the international component of GNEP and was not a focus of our 
review. 

[19] GAO, Department of Energy: Major Construction Projects Need a 
Consistent Approach for Assessing Technology Readiness to Help Avoid 
Cost Increases and Delays, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-07-336] (Washington, D.C.: Mar. 27, 2007). 

[End of section] 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink, http://www.gao.gov] 
and select "E-mail Updates." 

Order by Mail or Phone: 

The first copy of each printed report is free. Additional copies are $2 
each. A check or money order should be made out to the Superintendent 
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 
more copies mailed to a single address are discounted 25 percent. 
Orders should be sent to: 

U.S. Government Accountability Office: 
441 G Street NW, Room LM: 
Washington, D.C. 20548: 

To order by Phone: 
Voice: (202) 512-6000: 
TDD: (202) 512-2537: 
Fax: (202) 512-6061: 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]: 
E-mail: fraudnet@gao.gov: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, dawnr@gao.gov: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: