Is it really necessary to have a deep geologic repository for used nuclear fuel?

Though I have often received quizzical, almost uncomprehending looks from my type ‘A’ colleagues on submarines and in my other jobs, I’ve often been guided by a simple principal of decision-making – “If it’s too hard, quit.”

Please don’t think that means I’m the type of person who can never get anything done or who gives up easily. What it normally means for me is that I rationally evaluate the chances of success and decide to take a different path if the chance of completion is low. This is sometimes a difficult choice if I have invested a lot of time and energy already, but it is often more rewarding that continuing to invest or working even harder when there is a high probability of failure anyway.

Unlike the too often repeated line from Apollo 13, sometimes failure is an option that should be taken in order to enable a different kind of success. It took some time to learn to give myself permission to quit a task that is too hard to successfully complete, but it was a worthwhile lesson to learn.

It’s time to give the United States nuclear enterprise permission to quit trying to site a deep geologic repository for used nuclear fuel. We’ve invested tens of billions of dollars, there are people who have spent most of their working lives trying to accomplish the feat, and yet we are farther from the goal today than we were when I graduated from college in 1981.

Part of the problem is that is not discussed often enough is that there is a talented and energetic group of people who have worked just as hard to tie the process up in knots as others have worked to solve the various technical and political challenges. The people who want to complete the task so that nuclear energy can prosper have been well matched in a tug of war by those who long ago seized on “the waste issue” as their tool for constipating the industry to ensure that it gradually stops functioning.

The opponents of successfully siting, licensing, building and operating a repository have well-developed plans to add reinforcements to their side at each step of the process; I believe it is time for the supporters to simply let go of the rope.

About a week ago, the NRC (Nuclear Regulatory Commission), issued a final rule that provides the technical basis supporting a decision quit working on a geologic repository, even though it does not say that as clearly as I just did. After a great deal of analysis, public interaction, and thought, the Commission approved a rule called “Continued Storage of Spent Nuclear Fuel,” SECY-14-0072. The rule has an associated Generic Environmental Impact Statement (GEIS) that has determined that the potential environmental impact of continued surface storage of used nuclear fuel over the short-term, long-term, and indefinite future is small.

Chairman MacFarlane wrote the following perceptive statement in her comments about her vote on the rule.

In essence, the GEIS concludes that unavoidable adverse environmental impacts are “small” for the short-term, long-term, and indefinite time frames for storage of spent nuclear fuel. The proverbial “elephant in the room” is this: if the environmental impacts of storing waste indefinitely on the surface are essentially small, then is it necessary to have a deep geologic disposal option?

Almost exactly right! We should ask hard questions of those who maintain that “deep geologic disposal is necessary” because “a majority of the public industry, academia, and regulators” say it is. Here are some questions worth asking:

  • Why do you think a mined deep geologic repository is required?
  • What makes it so important?
  • Where is the recorded vote on which you base your claim that it is the majority opinion?
  • If there was a vote, when was that vote taken?
  • Have there been any changes in circumstances that challenge the validity of that determination?
  • Should options besides a mined deep geologic repository be reconsidered?
  • How much will it cost each year to simply defer action into the indeterminate future?
  • From an accounting perspective, aren’t costs that are deferred far into the future worth less, not more, if they are recalculated into today’s dollars?

Those who have read Chairman Macfarlane’s full comment should recognize that she is not only the source of the “elephant in the room” statement above, but she is also the source of the assertions that the United States must continue pursuing a mined geologic repository because we have a “long-established responsibility to site a repository for the permanent disposal of spent nuclear fuel,” and she wants to make sure that the NRC’s determination that continued surface storage represents a small environmental impact for the indefinite future does not enable “avoiding this necessary task.”

Dr. Macfarlane and I also agree about when we would begin to believe that the US can site, license, built and operate a mined deep geologic repository.

I will have confidence in the timing when a renewed national consensus emerges on a repository for spent nuclear fuel.

(Emphasis added.)

There is no reason to suspect that a sufficiently bulletproof consensus will ever exist. Recent history has proven that it takes just a handful of people elected or appointed into the right positions to derail even the best laid plans made with strong support throughout the rest of the country.

Analysis shows that we can continue to store used nuclear fuel safely, with virtually no environmental impact on the earth’s surface for as long as we need to. Though the Chairman seems concerned about the potential impact if there is a “loss of institutional control,” the controls required to ensure continued safety and environmental protection from used nuclear fuel are simple and easily implemented. As long as we do not believe that future generations will forget how to read, we can be sure enough that they will remember how to keep used nuclear fuel safely isolated.

Many people in Chairman Macfarlane’s generation — which is also my generation — may have watched too many movies depicting that there is going to be an inevitable dystopia in the future; but if that happens, used nuclear fuel will be low on the prioritized lists of risks.

The chairman expressed some concerns about the financial responsibility associated with continued storage of used nuclear fuel. A simple solution would be to have nuclear plant owners establish a used fuel fund that would be as isolated from their normal finances as their decommissioning funds. If plant owners put 1 mill per kilowatt hour of generated electricity into an escrow account — which is the same amount that they used to give to the government under the Standard Contract — they would accumulate plenty of money to endow a fuel management program. If 1 mill is not enough, 2 or 3 mills might be sufficient and still not have much of an effect on the cost of electricity from a nuclear power plant.

In the conclusion of her seven page comment, Chairman Macfarlane included the following statement.

Finally, I note that at least one commenter has suggested that development of a repository in the U. S. has developed into a Sisyphean task. I agree that much in the national management of spent fuel and development of a geologic repository over the past decades fits this analogy.

Once again, I agree with Macfarlane’s preamble. However, we are not subjects of Greek gods condemned to continue the frustratingly impossible task of pushing a rock uphill every day just to have it roll back down at the end of the day. We are free members of a society that has the ability to make choices and to change its mind to adapt to new situations when new information is revealed. The cancellation of Yucca Mountain through actions of a tiny group of people shows that successfully siting a repository in the U. S., with its multiple interest groups and arcane procedural rules is not possible.

The good news is that we don’t really need a repository in order to operate nuclear power plants safely and to store the residues created in that operation safely in a way that produces negligible environmental impacts. We do not need a government program that can be derailed. We do not need to have the federal government — which means us, as taxpayers — to pay the costs of continued storage; the costs are minimal and can be paid with a small fee on each unit of power generation. We are not cursed by an all-powerful god to spend our time and money pushing rocks up hill, either.

Making the choice to quit now and spend resources on something more useful must not be judged as unfair to future generations. Used nuclear fuel has potential value, but we can put aside resources now that can enable conversion of that material into fuel or to make a different long term storage choice in the distant future when there is more general agreement that constipating nuclear energy would be a suicidal course of action for society.

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