US EPA dose rate standard of 15 mrem/yr for long term disposal makes no sense
Matt Wald responded to the comment I described in my post titled Too Hot to Touch – Matt Wald’s review of new book on nuclear waste issue. As a brief reminder, in that post I told him that he and the authors of Too Hot To Touch were misinforming the public by stating that the EPA’s dose rate standard was designed to protect the public from significant radiation doses over a period of 10,000 to on million years.
My claim is that the EPA’s 15 mrem/year (0.15 mSv/year) standard attempts to control insignificant doses with an imposed limit that is 1/20th of normal background radiation. Heck, it is nearly impossible to measure the source of such a dose without specialized apparatus that counts for a long time in an area shielded from normal background levels.
Wald posted the following response on the now defunct Green blog.
Matthew L. Wald
Energy reporter, The New York Times
You and I agree.The book characterizes the dose you mention as insignificant, which I think is a reasonable outlook. The licensing criteria set that 15 millirem as an upper limit, meaning that the rules prohibit a significant dose for milennia.
The point here is not the maximum dose allowed, but the incredibly long time period to which it applies.
(Emphasis added.)
I responded to that with the following comment.
Matt – perhaps I did not make myself clear. If the regulations were aimed at preventing SIGNIFICANT doses, they would have been set at something near or even above normal background. Until you get to that level, spending more money in prevention is like trying to purify already clean, potable water. It is simply not worth the effort if the goal is human health protection, but it can become exceedingly expensive.
If the dose rate limit for Yucca was set at 300 mrem (3 mSv) per year, I am pretty sure that the scientists and engineers would have been able to guarantee compliance for whatever time frame is imposed.
The key, unchangeable characteristic of radioactive material is that it gets less radioactive with every passing day. Extending the calendar requirement does not matter once the material has decayed to a certain level.
Infinity would be fine as a standard if the dose rate was reasonable.
Like your wax analogy, if the standard was “do not harm the people” rather than “do not allow wax to touch the tablecloth” there would no longer any problem to solve. The R&D money spigot would shut, and the nuclear industry would be able to move forward smartly to address the triple challenge of providing sufficient supplies of reliable energy without dumping CO2 into our shared atmosphere.
Rod Adams
Publisher, Atomic Insights
(The final paragraph has been revised from the original. That is what writers do whenever they have a chance to improve their work.)
It occurs to me that the NRC is engaged in a game of preparing for the zombie apocalypse, only taking it seriously and using real money.
@Engineer-Poet – sorry to be a political pedant here, but the NRC is not the agency that establishes the dose rate limit. That role has been assigned to the Environmental Protection Agency. The NRC’s role as the license evaluator is to evaluate the models that show that the applicant meets the standard.
The number we need to attack is the 15 mrem per year. I still cannot understand why the “industry” did not fight that stupidity with all of the resources at its disposal. (Actually, I can understand it. Parts of the “nuclear industry” were salivating with the thought of all of the resources they could capture by designing systems to meet that standard.)
Rod, Using background as a reference that is 22 dB below background! That is so inconsequential that there is no discernible difference. The only way to know that it is there is to analyze the energy spectrum of the radioisotopes and at those levels even that is difficult.
Sorry about using a pseudonym, but I live and work in a politically hostile environment; Rod is right. My background is in measurement and analysis of information as well as in data processing. In order for a measurement to be meaningful it needs to rise above “background”. Sound is like this. Once a sound lowers to around 30 or 40 db or so, and continues lower, it is no longer audible because background sound has overwhelmed it. The content of the sound is no longer meaningful, and cannot be measured.
When discussing the total energy involved in all this background radio action, or in sound, the added contribution on one particular sound source (or radiation source) is trivial in total energy versus the total energy coming in from ambient sources (the rest of the universe). This is very basic science and basic applied science. In developing experiments, or measurements one needs to consider exactly these kinds of things.
Also, it is not a question of simply being able to measure small amounts of radiation. Remember man evolved to be able to LIVE in health in a constant downpour of background radiation. Background radiation is the norm. Nothing helpful comes from addressing lower amounts.
Typical Shuttle mission – 300-400 km – 2 weeks – 8 mSv (800 mrem)
Typical Station mission – 300-400 km – 6 months – 80 mSv (8000 mrem)
Obviously mankind will not be getting very far with Radiophobia at this level if it is ever applied to commercialization, exploration and colonization of space. Unreasonable fear is a dead end.
Rod, seems like an article about where the 15 mrem threshold came from might be helpful.
You can read what the EPA had to say about the standard hear http://www.epa.gov/radiation/yucca/about.html
I have never found any basis for the selection of 15 mrem/year for 10,000 years (all pathways) or the 100 mrem/yr for the next 100 years.
This paragraph indicates political pressure played at least as much role as anything else:
Rod,
The political pressure can only exist with the idea of ALARA, because reasonable can be defined however is necessary and is an entirely arbitrary level. LNT is simply disgusting policy.
If I were to identify any single constraint that needs to be resolved before mankind can begin to fully embrace nuclear technology it is LNT. Without removing this poor policy, nuclear will always be entirely subjugated by such political determinism.
If I recall the old articles correctly, the major problem for the long-term exposure issue is Tc-99.
I’m not a chemist, but how hard can it be to chemically separate technetium and isolate it separately? It creates little heat and a single element would be much easier to confine to an inert waste form than the melange in raw spent fuel.
The problem then becomes the government’s ban on reprocessing of SNF. Because that’s done so much to keep N. Korea, Pakistan, and Iran from becoming nuclear weapons states….
Technetium is easy to isolate. It’s a fairly noble metal.
In fact, adding technetium to alloys results in improved corrosion protection. Far more effective than chromium. It is especially useful to nuclear piping, pressure vessels and heat exchangers, where the tiny background dose rate from technetium is lost to the radioactive environment anyway.
Please don’t bury this stuff. It’s valuable.
That would ultimately increase the amount of technetium-containing material to be isolated after its useful life is over. On the other hand, arc-melting scrap steel into ingots which are cast into ceramic forms, sealed with more of the same and put away seems pretty straightforward.
@Cal – it is always worthwhile to seek to alter the fundamental basis for poor decisions. After that, we have to keep pushing to show just how silly the rules have become and how they have been created for the specific purpose of enriching some pretty nefarious and unpopular types of people.
Therein lies the problem. Why in the world would we leave it in Yucca Mt. for even 1,000 years? The material is worth too much now to leave it there for even 100 years. By then we should come to our senses and re-use the material. We will defiantly have before another 500 years – that or we may be living like the cavemen.
@Rich L
I have been convinced by people that I strongly respect that there are some materials that do need a permanent repository. A substantial portion of used nuclear fuel can be reused, but not all. There are also defense program-related wastes that have no useful purpose to serve.
If we are going to recycle, we still need a place to put the materials that are left over from that process and those materials. Of course, there is no sense of urgency, but the mere fact of having an operating repository would serve to help stop a whole lot of conversations about how the nuclear industry has never come up with a program for dealing with its waste.
That is one of the reasons that there was so much political capital invested in halting Yucca Mountain’s licensing review. It would have removed a barrier that was effectively being used to constipate the industry. We would not have a licensing hiatus today if that review had been complete because the basis for the Waste Confidence Rule would have been upheld in court. It was the fact that there was no permanent repository that won the case for the opposition.
Now look at how much effort is being expended in activity that is not moving us forward at all. We are farther behind today than we were in 1982.
I’m not convinced in the least. Actinides can all be either recycled into fuel for advanced reactors or shallowly buried (depleted uranium, put it back from the mine where it came from).
After 300 years you basically have some fission products such as I-129 and Tc-99 that you could worry about. Tc-99 is valuable in industrial uses, with markets far bigger than what we could ever produce. I-129 is not valuable but not dangerous either; it’s 800 million times less radioactive than I-131 that IS a concern.
People claiming we “need” permanent repositories, even for limited wastes, strike me as either mis/uninformed or partial to building repositories (eg scientists and engineers involved in Yucca whose job depends on this project continuing). Neither are particularly appealing motives to me, as an independent observer.
I have a can of paint in my garage, which will be toxic a billion years from now if I don’t do anything with it.
That doesn’t imply a need for permanent repositories for paint.
Cyril – Really? And what would you do with the legacy waste that has been left over from various military and research reactors? Much of this stuff was generated long ago, and the government doesn’t have a good idea today of what exactly is in it.
Although the amount of material is very small compared to the so-called “waste” from commercial nuclear reactors, I’m extremely skeptical that anyone could come up with a plan that would demonstrate that it is more cost effective to classify and pull out all of the “useful” stuff in this material than to simply dig a hole and bury the stuff in the ground (or in the sea or wherever).
You’re still thinking about material from commercial reactors, which is relatively well understood (although not very well understood). I agree that it is possible that all of this material could be dealt with via recycling and recovery in a manner that would result in a net cost that is less than building a repository, but that’s not the entire story.
I’ve always considered people who pooh-pooh the need of some sort of permanent repository to be either extremely naive or very misinformed. My challenge to them is to ask: what are you going to do with the difficult stuff?
What we are doing with it today is fine, more than fine in fact. It is very safe. Far safe than everything else in our society, including the production of teddy bear fluff. No one has ever died from US waste storage aboveground. If you were uninformed about that, you now no longer are. No need to thank me.
Cyril – Don’t worry. I’m not going to thank you for telling me something that I already know.
I’ve never said that storage of this material is causing a serious problem today. You’ve completely missed the point. The relevant question is the following: what are you going to eventually do with this material? Store it indefinitely?!
Your argument hinges on the speculative assumption that we can eventually make use of all of it. While I agree, that we can probably make use of all or almost all of the material in used commercial fuel, I’m not so optimistic that the stuff that the US government is holding can be so easily dealt with.
You might want to look at what the US GAO has to say about it. Do you really think that we could deal with this material in a way that would not be extraordinarily expensive without some sort of permanent repository?
Once again, you allow your ignorance to feed your arrogance. This is not ground for a productive debate.
Eventually mankind will either be gone or space based. That doesn’t mean we should plan now for things so far into the future. We don’t do this for anything else, so nuclear exceptionalism – which costs real money now – is neither fair nor sensible. The issue with wastes is when they are fresh, as they generate enough heat to destroy their containers and are a real threat to health. Old waste isn’t a big deal. Once you recycle actinides, the residual stuff is less toxic than copper after a century or two. Passive dry cask storage – today’s technology – is up for the job.
The two most important things to remember about nuclear waste problem is that it isn’t waste and it isn’t a problem. Most of the stuff is valuable, the remainder is so small and typically so much less toxic than everyday chemicals that it isn’t reasonable to worry about it.
Surprisingly, it is very cheap to do dry storage indefinately. This is because of interest that piles up on a bank account can pay for the limited replacement and maintenance/surveillance. Far cheaper than building a repository. In fact, the billions of dollars that are spent on Yucca Mountain would be more than sufficient in interest to pay for all the dry storage operational cost indefinately.
There is nothing magical about it. There’s fission products, there’s actinides and there’s activated material. All of this material is known, almost all is useful. FPs and activated material need short term storage to be safe, actinides need recycling. US government wastes are no exception.
What did you think, the repository is cheap????
The reason why reprocessing is expensive is the same reason that repositories are expensive. It’s not about technology, it’s about regulations and how we perceive risks. I work in industrial safety analysis. One interesting thing is that you can always spend more money on safety. You can spend 10 billion on a repository. You can spend 100 billion too.
Cyril – If there’s one thing I cannot stand, it is to be out a–h—ed. 😉 Although I must admit that you’re presenting quite a challenge.
The composition of the material isn’t known quite as well as you want to believe. I don’t think that you’re familiar with the work that was done under the auspices of the Yucca Mountain project to identify the composition of spent nuclear fuel. It’s more challenging than you think. If we “knew” with any certainty what was in there, then we wouldn’t have to use such bone-headed conservative assumptions when it comes to criticality safety for handling, storage, and disposal of the material.
This is the commercial stuff, for which we have pretty accurate records of the conditions under which it was irradiated, which should allow us to predict pretty well what is in there. Now consider what the DOE has, stuff left over from TMI-2, Fort St. Vrain, various research and production reactors, including reprocessing wastes, etc. Sure, I suppose that you can warehouse this stuff forever, but almost everyone who has given this matter any serious thought has concluded that its best just to go ahead and dispose of it.
If you want to make use of it, however, then expect the costs to be quite high. It’s difficult to engineer a process when you don’t know what you’re dealing with. Uncertainty breeds conservative assumptions that result in real costs.
But you’re not going to be able to recycle all of the actinides. The existence of WIPP — a deep geological repository, by the way — is evidence of that. Sure, you can recycle most of the actinides, especially the low hanging fruit in the commercial fuel, but what do you do about the rest?
Frankly, I don’t think that $0.001 per kWh is all that expensive. Do you?
Anyhow, once someone starts going all science-fictiony on me, I know it’s time to stop, so this will be my last comment in this thread. I’ve got better things to do than to discuss space travel and extinction events.
Good, if this is your last comment here then at least you won’t misinterpret my points anymore. If you want to continue on with this underground-vault-forever nonsense that only makes the public more concerned about nuclear waste (if we must spend 10 billion on a 100,000 year vault then the stuff MUST be dangerous) then go ahead. Know that it’s a complete waste of intellectual and financial capital. We’ve got huge waste problems in fossil fuel usage, where the waste cannot be contained even for 100 seconds. We’ve got heavy metal wastes which stay toxic for the next trillion years at least. Yet we’re not building a trillion year vault for them.
If you do not know the exact composition of the waste, then the last thing you want to do is bury it in a geologic layer which isn’t known 100% either. You’re compounding uncertainties. Of course this is more nonsense from you, as it’s easy to discern the exact nature of isotopes by measuring the type and energy of the radiation. Critility safety is easy, load with neutron poison. Not that this is necessary – if it can go critical it still has economical fissile value left which can be extracted.
Sure, with PUREX you can’t recover all actinides. That’s not the only, and certainly not the best, way to reprocess.
More than 99% of the radioactivity is currently stored aboveground. For good reason. Thermal reasons, accessibility reasons, quality control reasons (a geologic stratum doesn’t comply with any quality control standard).
Even if we go for repositories, it makes sense to wait a long time with dry storage, before putting it in the repository. This is because of heat load on the repository. Easy with dry storage, passively cooled, difficult with underground structures, passively insulated.
As much as I am all for Yucca Mountain and think that it is a perfectly safe, reasonable place to put all of our used fuel, these insane regulations are the reason that I am happy that the project was shut down. One of the reasons that the initial compliance period of 10,000 years was chosen was because it was considered about the extent of reliable modeling. Any attempt to predict beyond 10,000 years is generally not very accurate. Compound that to the fact that you are trying to show a small (100 mrem/yr) release at those extended time periods is a fools errand. Of course, the anti-nukes are never ones to let bad regulations go to waste and so there was movement to try and file lawsuits claiming that the regulation contained a double standard and that the dose requirement should be 15 mrem/year out to the 1 million year mark.
Trying to show compliance with these standards will raise lawsuits about every possible point in the models. Over a million year time scale a small rounding error in a rate constant can have significant effect. The issue is further compounded by the different climate change models that are being developed. Again, changes in average rainfall can accumulate into significant amounts of water ingress over 1 million years.
What I would like to see come out of the closure of Yucca Mountain is renewed interest in reprocessing. Adoption of reprocessing gives us the chance to re-write these standards. Hopefully the next time around we can be smarter than we were and develop sane standards to govern our used fuel storage.
Maybe I’m not getting it either because I’ve been in the area 60 miles north of Las Vegas and nobody lives there. As far as I can tell, no one would willingly move there for the next 10,000 years either. I’ve not been to the Yucca site, but close enough to say it’s just more desert land. It’s not a fun place. The desert can be pretty in places, but also naturally foreboding, something instinctual just tells you this would not be a good place to live.
So just based on the average distance that most of the populated areas are relative to Yucca, shouldn’t that be enough to ensure a minimal, if nothing at all, exposure probability? If there was a 100 pound ball of cobalt-60 sitting in the open air, I wouldn’t be so concerned if I was 100 miles away from it and even less so if it was buried a few hundred feet underground.
I think impossible goals were created for the sole purpose of derailing the project to failure. As long as the waste chain can be continually yanked to hold back nuclear energy, someone will want to pull it.
@Rod
You said:
“If we are going to recycle, we still need a place to put the materials that are left over from that process and those materials.”
If Yucca Mountain is off the table, why won’t WIPP (Waste Isolation Pilot Project) serve our country’s “nuclear waste” needs? The people of Carlsbad, NM actually want the stuff. They claim that this repository will serve us for the foreseeable future especially when the volume of waste is substantially reduced as Gen IV reactors come on-line.
William Vaughn: I think I may be able to answer this one, actually – one of the features of WIPP is that it is designed as putting nuclear waste into vast salt deposits. They basically hollow out some artificial “caves” in the salt, then put the waste there. But, one of the features of those salt caves is that they naturally, and relatively quickly (I believe in the course of just a few decades), fill back in with salt – the empty voids fill up with salt and all the material is entombed.
If you want to retrieve the material again in 100 or 200 years, it’s maybe not so convenient to have to retrieve it from the salt deposit after it’s become completely entombed within it. Might even be hard just to *find* it again.
Some facts:
1…Uranium and Thorium (U&T) are radioactive waste from an ancient nuclear reactor called a super nova.
2… The complete decay of U&T to stable lead releases about 7 times the radiation released from the fission products of an equal mass of U&T.
3… Nature did not store its radioactive waste in a carefully designed repository.
4… Humans tend to mine U&T close to the earths surface, which is most likely to erode, leach, or diffuse out over geologic time into the air water and food living organisms need.
The EPA is another “Box Mentality” government agency that calculates only the potential direct risk of the activity it regulates. It should be required to calculate the global radiation exposure reductions integrated over all time resulting from nuclear power’s destruction and isolation of U&T, and to subtract that from the exposure from a repository. It should also subtract the risk reduction of not generating that energy by fossil, hydro or unreliable sources, so as to measure the overall impact on humans and other organisms.
By this standard, almost any waste solution would be better than none. My preference is deep seabed disposal, very effective, very cheap.
You make excellent points and I agree with everything you’ve said, except the last bit. We currently have a very good solution to waste storage. Dry casks. The important thing to remember is that the waste becomes around a factor of 1000 less radioactive in about 100 years. So it makes sense to store it in a passively cooled, cheap, controlled dry cask. They are zero maintenance. It’s not kicking the can down the road, it’s simply letting physics help us to solve most of the problem. A 100 year dry storage period gets us such a large reduction in toxicity and heat load, even if we go for burial later, the dry storage will still make sense.
For some reason, all the nuclear engineers I’ve talked to have a knee-jerk answer to bury nuclear wastes in some permanent repository. I think that’s fatally missing very important facts about dry storage, heat loads, values of fission products and actinides, and fundamental processes of radioactive decay. There’s a very good reason why there are so few permanent repositories – we don’t need them. That’s the message we should be spreading. This stuff is not the devil that must be contained forever starting tomorrow.
I hope that future generations will look upon the whole permanent billion dollar million year waste repositories being contemplated in our time as being primitive nonsense, in the same category as 17th century pirates burying treasure on remote islands. Hopefully it will be quite amusing to future enlightened generations, to see such grand superstition and bedevilment about anything nuclear.
Cyril
I am a big fan of dry cask storage. Did you know that spent fuel rods can air cool by natural convection two weeks after reactor shutdown, in open racks with adequate air supply.
Not that I am recommending that, but getting the rods out of water into dry storage is a good thing to do after a reasonable (least cost) time span. But dry casks need to be stored in a high security facility, which is very expensive in perpetuity, and anti nukes have lots of questions about that;
What about the collapse of civilization? What about a nuclear bomb strike, terrorist attack, meteor strike etc?
The deep seabed approach is cheaper, safer and out of site. If somebody needs that material a million years from now they can dig it up.
Putting spent fuel from fuel ponds into dry storage is more of a political solution (ie not a safety solution at all). The actual fact is that the fresh spent fuel can’t be put into dry casks yet, it’s too hot, yet that’s also the fuel that’s in risk of overheating in the event of fuel pond dryout. Passive air cooling arrangements upon dryout of the pool are much better, in that respect, but appear to not be used much. I think the reason for this is the highly politicised and institutionalized nature of anything nuclear, where politicans must be seen to do something rather than effectively tackling the problem.
When society collapses, I have bigger concerns than some dry casks that sit somewhere. They don’t need maintenance. They just sit somewhere. That’s it. They’re tough and strong so you have to go to great lengths to open then up. It won’t work with a simple hammer and a spanner. When society collapses, I would fear for my life and my family, I would fear for getting enough food and drink. Some concrete casks that sit somewhere are at the bottom of my concern list in that situation.
Of course, the whole point about nuclear power is that it can help solve many of the problems, including those that are most likely to lead to societal collapse.
Fuel pools can’t be avoided because even with geological storage, the fresh fuel is too hot. It’s a bit annoying, the fresh fuel that is the biggest problem in a serious situation, can’t be transferred to dry storage yet.
This is really where the safety issues with nuclear energy lie – fresh fission products. If you can manage that – and we can – then everything else becomes easy. Or at least it should be, in a rational world.
Geological storage forever is symptomanic of the radiophobia that has stifled nuclear energy and innovation in that field for decades. We should actively resist this radiophobia, not waste intellectual and financial capital to produce million year vaults in seabeds that are counterproductive to public fears of nuclear power.
@Bill Hannahan
My response is that if civilization collapses, there are a lot more things to worry about than someone breaking into an area full of dry storage casks and then figuring out how to extract the material inside for nefarious purposes.
When people do real financial analysis, future costs often disappear into the weeds due to the effects of the time value of money. You can endow a sufficient future security system with a smaller quantity of today’s dollars than the cost of building an expensive repository.
I guess I want to play both sides of this discussion – keep potentially valuable material like used commercial fuel in dry casks until we are ready to recycle. Take the complex, mixed, former defense wastes and dispose of it permanently.
Deep seabed disposal is cheap. So is deep borehole.
I notice the following in Wald’s reply:
“The point here is not the maximum dose allowed, but the incredibly long time period to which it applies.”
I’m slightly confused by this statement. Is he trying to say that a small dose over thousands of years adds up to a large dose? Because, since people die after about 70 or 80 years, I can’t see how it could possibly make any sense to calculate MULTI-GENERATIONAL doses. . . the effective limit on dosage, no matter how long material remains radioactive, would seem to be the natural lifespan of a human being, wouldn’t it?
According to World Nuclear News, Yucca Mountain has a cost of 96 billion USD.
http://www.world-nuclear-news.org/newsarticle.aspx?id=20196
That is a lot of money for something that offers zero additional safety improvement to the public over today’s situation (which is close to zero risk).
From the link:
Frankly, I don’t think that $0.001 per kWh is all that expensive. Do you?
0.001 is probably not enough. The 96 billion was for about 135 kton SNF (increased by the DOE from a lower figure), at an average burnup of 45,000 MWd/t, 15,000 MWd electrical, this gives 0.2 cent/kWh electrical.
The 96 billion is just the start. With the demands put on it, it could easily double or triple by the time all is said and done. It remains to be seen that it could be done even for 200 billion. I remember figures just years ago of around 20 billion for about half the capacity. Not exactly economy of scale. The demands have gotten increasingly absurd, spending billions for something that, even with LNT, will only at best save a few people, meaning many billions per life saved.
This is real money. I don’t mind spending real money on real problems. What is the gain in public safety and our nuclear future? Should be spend 100-200 billion burying treasure? Isn’t it better to spend 10% of that amount on public education in an attempt to stop the radiophobia that drives these extreme vaults?
That figure came from your reference. Picking and choosing what you want to believe from your own reference just serves to undermine your argument.
But frankly, I don’t think that $0.003 per kWh is all that expensive. Do you?
It’s not very expensive, that depends on what you get. Just because its small per kWh, that doesn’t mean we should waste 100 billion on something that buys us nothing.
More important is the fact that this whole repository thing is symptomanic of the radiophobia that rules every element of nuclear power. 1 cent there, 0.1 cent there, a billion here and there. Pretty soon you’re talking real money.
We should invest to fight this nonsense. Not go along with it. We’ve gone along with it far too long. It’s why a PWR costs 5 billion today and 0.2 billion in the past. It’s streaming endless quality control, endless red tape in every element of the nuclear fuel cycle. It’s not about that 0.3 cent per kWh. It’s about what it does to the total cost of going nuclear, and importantly the delays in going nuclear. While we bicker over whether to store nuclear waste of 100,000 or 1,000,000 years, we can’t even contain fossil waste for 10 seconds. That’s where our problem lies.