Carbon-Free Power Project: Don’t Continue To Delay The Inevitable

Los Alamos

Los Alamos County Councilors,

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, apparently because not enough communities believe it to be a viable project, or perhaps because of a lack of transparency.  If you choose to continue, then you can make this a better project.

I submitted the questions below to the Utilities Board prior to their July 21 meeting.  The Director of the Utilities Department asked CFPP to address these questions at the July 21 meeting, and Mr. Baker and Mr. Hughes did address most of them during their presentation and under questioning by Ms. Walker.  Their responses were  incomplete, contradictory, and generally unsatisfying.  The three of most  importance are the Economic Competitiveness Test (ECT), the work on the reactor core being done by Fromatome and Enfission, and the rather curious explanations of the 54% change in output with no design changes.

We were told that CFPP is willing to release a non-proprietary version of the ECT to the public and you should request that immediately.  The ECT is critical to subscribers because it determines whether or not they will be liable for the development costs at the next off-ramp, and other liabilities to be incurred at various stages of the project.  The assumptions that go into the model, the sensitivity of the model to various parameters (apparently there are around 50 inputs), and the calculations that go into determining the input parameters  should be subject to public scrutiny,  perhaps even an independent audit, to assure the public that the model is above board and error-free.  CFPP insists that there is business information involved that must remain proprietary, but when you go into the public sphere for support and public moneys are involved you give up the privacy you are entitled to in the business world.  I urge you to insist that the ECT be made public without restriction as a condition of further participation by Los Alamos.

NuScale has always insisted that this is a ‘First-of-a-Kind” nuclear reactor. Paradoxically, it then turns around and insists the nuclear core is a given because it uses “well-known and established pressurized light water reactor technology.”  As early as 2015 Areva/Fromatome were retained to develop the reactor core; in 2016 they announced their new design, the HPT-2.  In nuclear trade journals NuScale and Enfission announced new fuels for NuScale, the latest a metallic fuel new to the industry (original fuels were ceramic pellets containing Urania and Gadolinia).  A nuclear-fueled prototype of the new HTP-2 has never been tested by NuScale.  All these point to the existence of a complex development program of the reactor core, the very essence of a nuclear reactor, that does not even appear in the schedules!  Shrouded in mystery, the work is apparently being done by Fromatome and Enfission, a collaboration between Fromatome and Lightbridge.  Meanwhile NRC filings continue to reference the ceramic fuel.  I urge the Council

to insist that the details and progress of the development work on the reactor core and fuel be made public and put into the schedule for the CFPP project.   

CFPP failed to deliver a satisfactory explanation of the two-step power jump from 50 to 60 to 77 MWe with no design changes.  They cited: (1) a small increase in the enrichment; (2)  some jiggering of the load-following scheme that that was inconsistent and contradictory between the two representatives  and that seems to suggest that the stated MWe does not include a reserve for load-following so a reduction in load-following ability can increase the  stated MWe; and (3) some manipulation of the “residual margins” in the operating parameters, including safety margins that could be shaved without affecting safety.  They did acknowledge that they knew these would affect the input parameters to the ECT and thus the LCoE.  I can find no reference to any of these changes in NRC filings by NuScale. I urge the council to demand a proper written explanation of these changes and their impact on safety and schedule.

Submission to the Utilities Board:  

The design has undergone two paper upgrades in the output of each module, from 50 MWe to 60 MWe to 77 MWe, 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.