To Utilities Board Members On UAMPS Carbon Free Power Project

Los Alamos

Utilities Board Members,

I hope you will choose to take this unexpected off-ramp rather than continue to delay the inevitable.  The UAMPS CFPP project looks to be slowly dying, because not enough communities believe it to be a viable project.

I recognize there’s not a lot of money at stake but neither is there a lot of hope, and it’s a distraction we don’t need while trying to plan for the carbon-free future.  If we have to have nuclear, maybe we should look into the Gates/Buffet project in Wyoming.

The design has undergone two paper upgrades in the output of each module, from 50 MWe to 60 MWe to 77MWe, and reductions in the plant size from 12 to 6 modules, with corresponding convenient decreases in the LCoE just as UAMPS members were reducing their subscriptions or departing completely. The ability  to willy-nilly  make these enormous  output changes  with no accompanying design changes suggests to me that the design is not in fact complete, contrary to representations.

Such drastic changes in technology and economics should be transparent and supported by transparent analysis. As this project would depend overwhelmingly on taxpayer subsidies, the public needs a full and complete understanding of the proposal. 

I am concerned about a number of areas where NuScale has not been forthcoming on important aspects of the CFPP project.  I believe we should insist on answers to the following:  

ECT: The project lives or dies on its economic competitiveness. I understand that if NuScale delivers a project that passes the Economic Competitiveness Test, CFPP members  must pay for the development phase. It’s entirely reasonable that we have access to that test, and understand the assumptions and sensitivities. Again, the public would be paying for this project; the public should understand whether NuScale and UAMPS are making reasonable assumptions about the financial exposure. 

Fuel:  I understand that the NuScale reactor uses a new form of fuel and a redesigned and untested fuel assembly that are unique among reactors globally. Please update us on the status of the development by Fromatome.

Schedule: In February 2020 NuScale publicly advised an Australian government inquiry that our project was on track for operation in 2026. In July a schedule presented to our community by Burns & McDonnell showed the first module coming online in mid-2029, with completion in mid-2030. Nuscale later told the Australian inquiry that the delay was due to UAMPS requirements, but they were capable of delivering earlier. Why did UAMPS delay the schedule, and how has the schedule changed in the last 12 months?

Self-consumption: All power generators use some of the power generated for their own systems, sometimes this is called auxiliary power. Of the 462MW gross generation, how much will be sent out to the grid, and is our share amount based on the  gross or the net generation?

Water: We learned last year that the design was being modified to use “air cooling”, which dramatically reduces the water requirements, a wise move in a changing climate. Air cooling still requires some water. What is the annual water consumption of the plant? What is the proposed source of the annual water? Does CFPP actually own the necessary water rights?

Operator: This time last year it was proposed that Energy Northwest, an experienced nuclear plant operator, would operate the plant for us. I understand that Energy Northwest has withdrawn its interest in operating the plant. When did Energy Northwest withdraw, why did they withdraw, and who will operate the plant in its place?

DoE Appropriations: Has the DoE agreed to keep the aggregate allocation of $1.355bn given the halving of the size of the project? What happens to the LCoE/ECT if the DoE reduces the grant size, or, heaven forbid, the expected appropriation isn’t made in a given year?

Subscription: What happens if the project remains under-subscribed through the development process?

These are points of interest relevant to decision makers that UAMPS and NuScale simply avoid discussing. Disclosure of these would go a long way toward improving the credibility of NuScale, UAMPS, and the community boards who are putting their own credibility on the line by subscribing to this project.

We must not forget that our ratepayer and taxpayer monies are being used to underwrite this ambitious project. We are owed transparency in return.