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

“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.”


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.

Los Alamos Board Of Public Utilities Recommends County Continues Participation In Carbon Free Power Project

BPU Board Chair Cornell Wright

Los Alamos Board of Public Utilities (BPU) recommended at its meeting Wednesday that Los Alamos County continue to participate in the Carbon Free Power Project (CFPP).

Los Alamos County Council will consider the recommendation Tuesday night during its regular meeting.

The BPU voted to recommend Council approve continuing the County’s subscription in the CFPP. Board member Steve Tobin abstained, and board member Eric Stromberg was absent.

Several board members voiced their support for remaining in the project.

“If the last year has taught us much it is the future looks more uncertain than ever and I am a little less concerned about the price point right now …  in terms of the market … I would certainly prefer investing in state or regional resources but this is also a fraction of our load – can we do both,” Board member Carrie Walker said. “I think there is room to do both. And I definitely do not want to send this signal that we are not interested in doing that. I would not want to send that signal to staff; I think we can be clear about that, that we want to do both …”

“I think that when you look at costs, when you look at safety records and you look at the fact of nuclear being a firm, dispatchable source of power … I think nuclear has to be one of the components in a balanced energy system in this nation,” Board Chair Cornell Wright said. “And I think it is good for the world for the U.S. to show leadership to the rest of the world … this is an opportunity for our nation to show some technological leadership. Secondly, when I look at the County… they need a certain amount of dispatchable power … we’ve seen spikes that have cost us dearly … I think the problem is just going to get tougher down the road. I think a firm power commitment is a good a thing for the department in the County. Finally, I look at the project and I see a lot of things that are positive …  I think at this point in time … the right thing for the County and for the board to do is to approve remaining in the project.”

The CFPP is a proposed nuclear power generating facility to be built at the Idaho National Laboratory using first-of-a kind small modular reactor technology developed by NuScale Power, according to a County press release.

The press release further states that the facility is slated to be operational in 2030. DPU has been involved in the project since 2015. Additionally, the project is being negotiated between the Department of Energy, NuScale Power and the Utah Associated Municipal Power Systems (UAMPS), which is a joint action governmental agency comprising of multiple municipal-owned utilities – 28 of which are participating in the CFPP.

While there is no change in the number of subscribers, there has been an increase in letters of interest to joining the project. Department of Public Utilities (DPU) Manager Philo Shelton told the Los Alamos Daily Post Thursday that the increase came after the Department of Energy awarded a $1.355 billion grant for the CFPP, adding that this is a multi-year grant award.

DPU Public Relations Manager Julie Williams-Hill told the Los Alamos Daily Post that if Council decides to continue in the project, the County is committed to an investment cap of $1.26 million to keep the CFPP as an option for a future resource. To stay within this cap, the DPU reduced its subscription to 1.86 megwatts with a new target price of $58 per megawatt hour. Originally the cost was $55 per megawatt hour. By the end of this current phase the County will have an opportunity to increase its subscription to the appropriate level.

There have been other changes to the project, Williams-Hill said. For instance, the CFPP reduced the number of small nuclear module reactors at the plant from 12 to six. Also, the capacity of each Nuscale module will be increased to 77 megawatts per reactor for a total plant capacity of 462 megawatts.

DPU entered the CFPP as an option to diversify its energy generation portfolio with firm, carbon-free energy and to meet a BPU goal for the DPU to be a carbon-neutral power provider by 2040, according to the County press release. It also will be leaving the San Juan Generating Station next year, which is a coal plant that provided electric power to the County for many years.

Shelton pointed out that having a variety of energy resources is important.

“I can say the Integrated Resource Plan looks to have a multitude of energy resources,” he said. “You don’t want all your eggs in one basket.”

The great thing about nuclear power, Shelton added, is that it is dispatchable, unlike wind and solar energy, which are dependent on weather conditions.

“At this point having dispatchable power is an important part of the Carbon Free Power Project,” Shelton said. “…that is the benefit of nuclear power – it is available 95 percent of the time.”

It also can give the County greater independence from purchasing energy from the market, which can fluctuate in price and often is generated from fossil fuels, he said.

Deputy Utility Manager Steve Cummins pointed out that the recent heat dome event in the Pacific Northwest caused an increase in power demand, resulting in transmission congestion throughout the west as utility providers scrambled to find power to serve their customers. Consequently, the market price of electricity skyrocketed to $1,750 per megawatt hour, he said.

The County’s objective, Cummins said, is to have the right mix and quantity of generation resources to reduce the County’s exposure to a volatile energy market and to ensure reasonable electric retail rates for its customers, while still taking advantage of market conditions when favorable.

Shelton said that the County is taking steps to exit the San Juan Generating Station, a coal-fired plant, in 2022. DPU plans to replace this resource with clean energy. Most recently, DPU entered into a Power Purchase Agreement for 15 megawatts from the Uniper project, which provides energy from wind and solar projects in New Mexico.

If Council decides to approve the BPU’s recommendation, Shelton said that UAMPS on behalf of the project participants will continue to develop all the information needed for the Combined Operating and Licensing Application for this resource option.

Meantime, the County will continue to work on updating its Integrated Resource Plan to determine the best mix of resources to serve the County’s load as it moves toward the 2040 carbon neutral goal.  

But is there a plan B if council decides to no longer proceed with the CFPP?

“County staff is staying abreast of all resource options available as they arise,” Shelton said, adding that as of now there are no other clean, dispatchable power options available to the County.

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