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POGO Letter to DOE Secretary Bodman regarding the lack of oversight of costs and quality at the MOX Fuel Fabrication Facility

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August 25, 2008

The Honorable Samuel W. Bodman
Secretary of Energy
U.S. Department of Energy
Washington, DC 20585

Via email: The.Secretary@hq.doe.gov


Dear Secretary Bodman:

We are writing to express our concern about the lack of oversight of costs and quality at the MOX Fuel Fabrication Facility being built by Shaw AREVA MOX Services, LLC at the Savannah River Site.

It is problematic that the National Nuclear Security Administration (NNSA) praised the MOX facility construction as “successful” in an August 1, 2008, press release, when only three days later the Nuclear Regulatory Commission (NRC) issued a Notice of Violation on the construction of the MOX plant. On August 4, 2008, this NRC Notice of Violation outlined four examples of Shaw AREVA MOX Services failing to implement the MOX Project Quality Assurance Plan (MPQAP) conditions (see Attachment # 1). This included Shaw AREVA’s failures in June 2008 to:

[I]dentify a condition adverse to quality in that during the BMP-F111 basemat [an early concrete pour] concrete placement, the previously placed concrete had lost its plasticity prior to making the next concrete placement, thus creating a cold joint. … 

[I]dentify during BMP-F112 basemat construction joint inspection activities that foreign material had been left in the construction joint and that there was voiding behind the stay forms.

While stating that “overall, design, procurement and construction activities remain on schedule,” NNSA’s recent press release also failed to mention that in February 2008 NRC found that Shaw AREVA had used rebar that did not meet American Concrete Institute (ACI) standards (see Attachment # 2). AREVA should have inspected the shipments of rebar prior to deploying it in concrete—not afterwards. This record bodes well for NRC’s inspection capabilities, but not for those of the contractor or NNSA.

NNSA should have been on the lookout for problems, given that they have shown up at AREVA sites around the world. For instance, in 2006, problems with AREVA’s concrete were discovered at Finland ’s Olkiluoto reactor site. Then, in March 2008, the l'Autorité de sûreté nucléaire (Nuclear Safety Authority in France ) identified problems with rebar, similar to those at Savannah River , that resulted in two notices of serious infraction for AREVA. The problems include the incorrect positioning of several pinned overlaps between U-shaped bars, which was discovered only after the concrete-pouring operation had already begun.

In addition to the specific problems with AREVA, it is alarming that all of NNSA’s major construction projects are facing serious Quality Assurance (QA) problems.

At $4.8 billion, the MOX facility appears to be traveling down the same troubled path as Los Alamos National Laboratory’s Chemical and Metallurgical Research Replacement (CMRR) facility, which had significant QA and concrete problems (see Attachment # 3).  In addition, the inadequate use of rebar in the early construction of the Y-12’s Highly-Enriched Uranium Materials Facility (HEUMF) was one of the factors that caused the cost of that project to balloon from $350 million to $500 million.

We recommend that DOE’s Inspector General or Office of Health, Safety and Security fully investigate these Quality Assurance failures that plague MOX and other NNSA projects.

Sincerely,


Danielle Brian
Executive Director

Attachments:

1)      NRC Report Number: NA—SRSO-MOXS-MOX-2008-007

2)      U.S. Nuclear Regulatory Commission Operations Center Report, Event #44119

3)      POGO letter to Secretary D’Agostino, 11/30/2007

CC: Representative Peter Visclosky, Chair of House Appropriations Subcommittee on Energy and Water Development, c/o Robert.Sherman@mail.house.gov

Representative Ellen Tauscher, Chair of House Armed Services Strategic Forces Subcommittee, c/o simon.limage@mail.house.gov

Glenn Podonsky, Chief Officer, Office of Health, Safety and Security, glenn.podonsky@hq.doe.gov and c/o Elizabeth.ray@hq.doe.gov

Honorable Gregory Friedman, Inspector General, Department of Energy, c/o dianetaylor@hq.doe.gov

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