NRC Waste Confidence Meeting
Grand Pacific Resort, Carlsbad, CA Nov. 18, 2013
Notes prepared by: Roger Johnson, PhD
Several hundred people attended the 3 hour NRC public meeting held in Carlsbad on Nov. 18. The meeting was preceded by a press conference with reporters and TV crews. The NRC distributed a 472 page document entitled “Waste Confidence Generic Environmental Impact Statement” (GEIS) prepared by the Office of Nuclear Material Safety and Safeguards. This report is a draft, and the purpose of the meeting was to solicit public comment. In attendance were members of the staff of Senator Dianne Feinstein. No one attended from the office of Rep. Darrell Issa (San Onofre is located in his district).
Background. Since the first U.S. nuclear power plant opened in 1958, radioactive waste has accumulated in “temporary” storage at each facility. According to the Nuclear Energy Institute (the political arm of the nuclear industry), a typical nuclear power plant generates 20 metric tons of used nuclear fuel per year. There are now 69.720 metric tons of highly-radioactive waste being stored on site at nuclear power plants across U.S. At San Onofre, thousands of tons are now stored in pools of water or in concrete casks. If storage casks in the U.S. were stacked end-to-end and side-by-side, they would cover a football field about seven yards deep.
The Search for a Permanent Solution. When the nuclear industry began, the assumption was that sooner or later there would be a solution to the nuclear waste problem so that this highly toxic material would eventually be moved to a permanent deep underground repository. This assumption was codified in 1984 by an NRC Waste Confidence Rule. Such a repository never materialized due to strong opposition from scientists, politicians, and members of the public. Since no state wanted to allow permanent storage of nuclear waste, the NRC revised its Waste Confidence rule in 2010 making it possible for nuclear waste to be stored on site for long periods of time. This plan made the same assumption as the old plan: nuclear power plants can store current waste and generate more waste in the future because eventually a solution will be found. In 2012 the U.S. Court of Appeals in Washington, DC vacated this rule. It argued that this was a hope rather than a plan, and that it did not consider the environmental consequences. As a result, the NRC was prohibited from licensing any new nuclear power plants or relicensing old ones until it came up with a better plan. The GEIS plan just submitted by the NRC is an attempt to meet court objections.
Summary of the Plan. The new plan would allow nuclear reactor operation for 40 years. After that, plants could have their license renewed for an additional 40 additional years. When a plant is finally closed, operators would be allowed to use the site for “temporary” storage for an additional 60 years. The plan assumes that by the end of this 60 year period all spent fuel would be moved to a permanent repository somewhere else. If no permanent repository was found, the nuclear waste would remain on site for another 100 years. It would now be called “long-term storage” rather than “short-term storage.” If no repository is found after the 160 years following plant closing, the name would change again and be called “indefinite storage.” The storage casks would be replaced on site every 100 years.
The Generic Plan. The plan is called “generic” because the same formula applies to all nuclear power plants regardless of location. No distinctions are made between plants located in metropolitan areas and those located in rural areas. No distinctions are made between plants located in earthquake fault or tsunami zones and those located elsewhere. Since there is currently no plan for a permanent repository, the plan is to make every nuclear power plant a radioactive waste disposal site possibly for centuries.
How this Impacts California. In 1976, California lawmakers were concerned about the lack of a plan for permanent storage of nuclear waste. They passed a law which prohibited the construction of any new nuclear power plants in California until a permanent repository is found. In 55 years of nuclear power plant operation (and accumulation of waste), no repository has been found and as a result no nuclear power plants have been built in California. Diablo Canyon and San Onofre ended up being the only commercial nuclear power plants in California, and Diablo Canyon is the only one still in operation. If the NRC plan is accepted, both of these locations will become nuclear waste storage sites possibly for centuries.
What is Meant by “Spent” Fuel? The term “spent fuel” may suggest that the radioactive fuel rods are somehow depleted. This is not the case. The term “spent” means that profitability of the nuclear fuel rods diminishes and it is more profitable to replace them about every 18 months and put the old ones in storage. The radioactivity of fuel rods does dissipate with time, but this happens very slowly. Uranium 235, for example, becomes hazard free in 7.4 billion years.
What is Highburn Fuel? In 1996, Edison switched to a new type of fuel called Highburn fuel which burns hotter and longer and is much more radioactive. This new type of fuel is more profitable, but it also magnifies the storage problem. Regular nuclear fuel must stay in pools of water for about 5 years before it can be entombed in concrete and steel casks. Highburn fuel must remain in cooling pools for 20 years or longer. Since the cooling pools are much more vulnerable to earthquakes, tsunamis, accidents, or terrorist attacks, this extended period exposes the surrounding populations to added risk. The nuclear industry has little experience with entombing highburn fuel in casks, and the new NRC plan says only that it may take up to 60 years to get all spent fuel rods out of pools and into dry cask storage. For more information about highburn fuel (and other issues), visit: http://www.sanonofresafety.org/
What about Low-Level Waste? The new plan says little about low-level waste as if to suggest that low-level means low risk. According to the NEI, low-level radiation will decay to background levels in about 500 years. Low-level radiation is regularly released by all nuclear power plants in operation. During decommissioning, there will low-level exposure caused by demolition work which will reduce the whole facility to rubble. This rubble will vary in contamination levels from Class A (slightly contaminated) to Class C or greater (which is so contaminated it can go only to one place in the United States which is Andrews, Texas). Some of the less contaminated waste will be trucked to Clive, Utah. It is possible that some contaminated waste will end up in landfills or be bulldozed and remain on site forever. The new NRC GEIS plan specifically excludes any consideration of the more contaminated forms of waste (Class C or greater).
The term “low level waste” does not necessarily mean that this form of radiation is safe. The BEIR-7 reports (Biological Effects of Ionizing Radiation: http://www.nap.edu/openbook.php?isbn=030909156X ) prepared by the National Research Council in 2006 concluded that even low levels or radiation can lead to cancer, especially in children, and that there is no such thing as a safe threshold below which radiation is safe. The National Academy of Sciences is now engaged in a 3 year epidemiological study to see whether the low-level radioactivity which Edison has released into the ocean and atmosphere for decades is having health consequences on people who live within 31 miles of San Onofre (http://www.nap.edu/catalog.php?record_id=13388).
Risk and Probability. The GEIS document employs “probability-weighted impacts” and frequently defines risk in terms of probability. It says that the probability of a successful act of terrorism or sabotage is small, and therefore the risks are small. Similarly, it says that the probability-weighted impacts of fuel pool accidents are small. Much of the report is devoted to statements that risks to the environment or to surrounding populations are small, and therefore it is safe to store large quantities of radioactive waste on site, even in highly populated urban areas. Many in the audience were quite critical of the report. They argued that the true risks are grossly underestimated and that a generic approach is inappropriate. The NRC hopes that the GEIS report will satisfy the courts and allow the NRC to license new plants, relicense old plants, and store radioactive waste on site for decades or centuries.
Period of Public Comment. The NRC will accept public comments until Dec. 20, 2013. Email comments to Rulemaking.Comments@nrc.org citing Docket ID No. NRC-2012-0246.
Notes prepared by Roger Johnson, PhD