- Email: [email protected]
Need for USA high level waste (HLW) alternate geological repository (AGR) and for a different methodology to enhance its acceptance
Nuclear Engineering and Design 240 (2010) 3665–3668
Contents lists available at ScienceDirect
Nuclear Engineering and Design journal homepage: www.elsevier.com/locate/nucengdes
Need for USA high level waste (HLW) alternate geological repository (AGR) and for a different methodology to enhance its acceptance Salomon Levy ∗ 3425 South Bascom Avenue, Suite 225, Campbell, CA 95008, United States
a r t i c l e
i n f o
Article history: Received 2 March 2010 Received in revised form 25 May 2010 Accepted 4 June 2010
a b s t r a c t In early February 2010, the administration stopped work and withdrew the Department of Energy (DOE) application for a construction permit for the Yucca Mountain geological repository from the Nuclear Regulatory Commission (NRC). Also, a “blue ribbon” Commission was appointed to explore alternatives for storage, processing, and disposal, including evaluation of advanced fuel cycles and to provide a final report in 24 months. That decision, however, failed to recognize that: (1) the U.S. will need an early alternate geological repository (AGR) for its HLW irrespective of the findings of the “blue ribbon” Commission; (2) the once-through spent fuel inventory from commercial nuclear power reactors will continue to rise and so will the damages against the government for its failure to remove spent fuel from reactors sites, as specified in contracts; (3) there are prepackaged DOE and nuclear weapons HLW ready for shipment to a repository which must be taken into account because of government penalties for failure to do so; (4) the current Nuclear Waste Policy Act (NWPA) needs to be modified to allow the early search and approval of Alternate Geological Repository (AGR) and for an interim centralized HLW storage facility to reduce government liabilities; and (5) the methodology used to license Yucca Mountain needs to undergo serious modifications, including a different non-politicized management and siting credo. This paper reviews and discusses all the preceding shortcomings and proposes significant changes to pursue AGR as soon as possible and to get site approval by the NRC first under a formal, stepwise, well-structured risk-informed decision approach as recommended by the (National Academy, 2001). © 2010 Elsevier B.V. All rights reserved.
1. Introduction In 1957, the National Academy of Sciences concluded that nuclear HLW disposal in deep geological repositories (GR) would provide the best protection to humans and the environment against the intense, long-lived, and hazardous radioactivity of nuclear HLW (National Academy of Sciences, 1957). That conclusion has been reinforced several times by the (National Academy, 2001) and by the pursuit of GRs by practically all other nuclear countries, including Belgium, Canada, Finland, France, Germany, Hungary, Japan, Spain, Sweden, Switzerland, and the United Kingdom (Nuclear Energy Agency, 2009). In 1983, under the Nuclear Waste Policy Act (NWPA), DOE was given responsibility for studying several locations for possible disposition of nuclear waste. In 1987, NWPA was amended by President Reagan to restrict the study to only Yucca Mountain. The long history of Yucca Mountain from 1987 to its demise 23 years later has been recounted many times, with the latest account produced by the U.S. Government Accountability office (GAO in 2009). This report will not repeat that history but instead
will put emphasis on the lessons that could be learned from it. Section II will repeat previous opinions why the “blue ribbon” Commission will not eliminate the need for AGR. Also it will cover the urgency for an AGR as soon as possible. Section III will develop why another non-politicized organization is needed to manage the search of AGR. Section IV will propose a modified siting credo and licensing approach with the NRC first approving the AGR site and subsequently the facility, which could last from 4 to 8 years. During the time span of Sections II–IV, DOE and its contractors or another designated management organization as recommended above will pursue the recommendations of the “blue ribbon” Commission and be in a position to recommend the forms, volumes, and characteristics of HLW to be dispositioned in the NRC approved site. The AGR management entity will then prepare a submittal to NRC and obtain its approval for design, construction, and operation of the repository facility. This orderly stepwise approach will provide the way to reach a long overdue solution to the disposal of the continually growing U.S. HLW. 2. Why AGR
∗ Tel.: +1 408 369 6500; fax: +1 408 377 2846. E-mail address: [email protected]. 0029-5493/$ – see front matter © 2010 Elsevier B.V. All rights reserved. doi:10.1016/j.nucengdes.2010.06.036
U.S. nuclear power plants generated close to a remarkable 800 billion kilowatt-hours (kWh) of electricity in 2009 and a renais-
3666
S. Levy / Nuclear Engineering and Design 240 (2010) 3665–3668
sance program is underway to increase that capacity. All those plants are operating using the once-through fuel cycle which removes spent fuel from the reactors after it is depleted and stores it for disposal as HLW. That total nuclear power waste and DOE HLW is at about 70,000 metric tons (MT) and is expected to more than double to 153,000 by 2055 (GAO, 2009). Originally, DOE had set January 31, 1998 to start accepting HLW but in July 2008 DOE moved that date to 2020. That shift resulted in the need for additional storage at the nuclear power plants. Utility lawsuits for that site storage against the government were supported by the courts and are estimated to cost taxpayers $12.3 billion in damages through 2020 and could cost $500 million per year after 2020 (GAO, 2009). Furthermore, DOE has agreements with specific states to remove DOE HLW which is supposed to go to a repository and which will not enter the Commission deliberations. Those agreements involve penalties such as $15,000 per day with the state of Colorado and $60,000 per day with the state of Idaho if the DOE HLW is not removed from those states by January 1, 2035 (GAO, 2009). The total government liabilities readily could exceed $30 billion by 2055 which is a very good reason for an urgent pursuit of AGR. Another reason for pursuing AGR is that, under the evaluation of alternate fuel cycles by the Global Nuclear Energy Partnership (GNEP) (DOE, 2008), it was pointed out that “all reprocessing technologies under consideration as part of GNEP would produce wastes requiring disposal in a repository”. Furthermore, in the Strategy for Nuclear Energy Research and Development issued by the Electrical Power Research Institute (EPRI) and the Idaho National Laboratory (INL) (EPRI, 2009) it was noted that “management of used fuel and the portion that is ultimately disposed as a nuclear waste, is a key issue for public confidence in nuclear energy and that a “mined geological repository should be developed for HLW that offers little or no economic potential for recycle”. Currently, the HLW is being dispersed over many areas of the U.S.A., increasing the associated safety risks and to the dislike of some local populations. It is realized that interim centralized storage has been suggested to correct that situation (Levy, 2009), assuming that states willing to host such facilities could be found. The best solution would be to combine interim centralized storage with AGR because AGR needs a receiving area (not allowed at Yucca Mountain) to improve HLW movement and logistics. That combination also would avoid the need for two transportations of HLW to the centralized storage site and subsequently to AGR. Unfortunately, the pursuits of an AGR or an interim centralized spent fuel facility are not possible right now because they were prohibited under NWPA to achieve the acceptance of Yucca Mountain. The Congress and the President need to modify NWPA to increase its flexibility in terms of repository location and centralized interim storage facilities. It is not obvious that a revision of NWPA will be forthcoming right away because several members of Congress continue to believe that Yucca Mountain should be selected and many may prefer to delay any change until the next election of 2010. However, reality will set in when the “blue ribbon” Commission report is issued, noting the need for a repository even though time and money could have been saved by an earlier decision which would have stopped the loss of personnel familiar with geological repository development.
3. Different management It is recommended that another non-politicized organization lead the search for AGR and for an adjoining centralized spent fuel storage facility. The reason is that DOE did not do a good job of managing the Yucca Mountain project. It spent $14 billion and 28 years without having much to show for it. One principal reason is
its strong push of Yucca Mountain for geological repository even though the site community and the state of Nevada were definitely against it and were able to mount a strong political, legal, and technical opposition effort. Similar circumstances had led to the abandonment of nuclear power plants during their licensing process. The management of the Yucca Mountain project had several other problems. The project quality assurance was found to be inadequate and led to a significant redo of the work and loss of schedule. Also, the National Academy recommendation to consider the time for peak dose from the repository was not accepted. Subsequently, it was supported by the Court of Appeals and it led to an Environmental Protection Agency (EPA) standard change to cover 1,000,000 years instead of 10,000 years. I had the opportunity to consult for the Yucca Mountain staff in 1999–2001. I noticed the very large and excessive number of contractors employed at the site and that several contractors were working on topics of their choosing rather than subjects and schedules imposed by the project. I also noted the absence of personnel from the spent fuel owners even though they were providing 80% of the costs. The biggest shortcoming may have been the failure to recognize that the “biggest challenges to waste disposal are societal” and “require open, transparent, and broadly participatory decision making” (National Academies Press, 2005). DOE is also subject to political influence. Its management personnel and their role tend to change with the political party in power. In 2002, DOE recommended approval of Yucca Mountain for the disposal of HLW without approval of the NRC and had the President and Congress adopt it. That decision is difficult to comprehend since the NRC was formed to assure independent safety evaluation of nuclear risks. DOE has operated in the past under the premise that it has the authority to propose and to approve HLW disposal plans. However, the Academy has pointed out that DOE may have had a conflict of interest (National Academies Press, 2005) under those circumstances, which is certainly the case for the disposal of commercial spent fuel. For instance, when the Private Fuel Storage (PFS) program, a consortium of 11 utility companies decided to go ahead with a 40,000 MT storage of spent fuel in Utah, it sought approval by the NRC. That standard of seeking NRC approval should be maintained for AGR and it is one more reason for recommending another non-politicized organization to manage the pursuit of AGR and a centralized spent fuel storage facility. NWPA should allow it and even encourage it. In conclusion, it is important to establish a new organization to avoid any conflict of interest, to reduce political influence, to pursue AGRs under improved and accountable management and to reduce unnecessary other interferences. This organization called AGR Co. could be patterned after similar organizations employed in all other nuclear countries (Nuclear Energy Agency, 2009), e.g. SKB, Swedish Nuclear Fuel and Waste Management Co. or ANRA, National Agency Radioactive Waste Management, France. Its officers and staff should come from top management nuclear organizations, expert HLW and site research and construction specialists and it should be funded, similarly to Yucca Mountain, 80% by the nuclear power industry and 20% from the government HLW funded programs. AGR Co. should hire top industry officers, project managers, schedulers, cost estimators, licensing engineers, communicators, and convincing presenters. DOE could provide the Technical Director and Transportation Manager and most of the personnel to support them but they are expected to report to AGR Co. management and get paid by it. Much of the personnel from DOE will be those utilized from National Laboratories in the development of the Yucca Mountain Application Report so as not to lose their expertise and work performed. An alternate would be for DOE to provide an oversight in those two areas. AGR Co. initial focus will be to prepare a 5-year plan to pursue two different sites for AGR and a centralized spent
S. Levy / Nuclear Engineering and Design 240 (2010) 3665–3668
fuel storage facility in order to encourage competition and to have one site left if the other falters during the process. The objective of that first phase of the plan will be to obtain NRC approval in two steps: first for the sites and second to follow with a submittal for the design, construction, and operation of the facilities. That second phase should happen after the “blue ribbon” Commission results become available and DOE has determined the forms, amounts and characteristics of HLW to be disposed in the NRC approved AGR site. AGR Co. should have a strong Independent Advisory Council consisting of well known U.S. and foreign HLW experts who will review its organization, plans, and progress and issue periodic reports to the President, Congress, interested parties, and the public.
4. Different site credo and strategy A comprehensive facility credo was developed by (Bunn et al., 2001) for Interim Storage of Spent Nuclear Fuel. Most of its principles should be adopted for AGR Co., including instituting a broad based participatory process, seeking consensus, seeking acceptable sites through a volunteer process, and working to develop trust. The desired outcomes are choosing the sites which best address the problems guaranteeing that stringent safety will be met, and that the NRC approval will be sought, fully addressing all negative aspects of the facilities, working for geographic fairness, and especially making the host community much better off. As soon as AGR Co. is authorized, it will start to appoint its staff, meet with DOE to define their respective responsibilities, and start preparing a 5-year plan. Also, they should have an information meeting with NRC to explain the different site credo and the two-step approach of obtaining NRC site approval first followed by approval of construction and operation of the facilities. Assuming no objection from NRC, they should ask for their comments about potential sites and NRC possible site requirements. Agreement upon future meetings schedule should be agreed to and satisfied. Simplified description of the joint AGR and interim centralized storage facilities, readily understandable by the public should be prepared with emphasis on safety provisions, review by the NRC and seeking broad based participation. Those descriptions should rely upon the available Yucca Mountain and Private Fuel Storage write-ups. A meeting between AGR Co. and DOE also should be held to establish a list of potential sites which should include clay, crystalline rock, and salt formations. The following step would be to issue a Funding Opportunity Initiative (FOI) to Communities and States, to seek volunteers for site studies, and to offer funding for their participation including hiring their own experts, attending public and NRC meetings. The interested parties should be invited to a meeting where their possible future benefits are highlighted in terms of jobs, transportation, and additional possibilities in terms of training and education. It should be pointed out that GAO has estimated that a repository to dispose of 153,000 MT facility cost from $41 billion to $67 billion (in 2009 present value). The 2009 present value cost of a centralized storage of 153,000 MT at the end of 100 years was estimated to range from $15 billion to $29 billion and would increase to $23 billion and $81 billion with final geologic disposal. In other words, total potential work could be very large and cover many years. Finally, it should be noted that at least 11 other countries are pursuing going ahead with a geological repository (Nuclear Energy Agency, 2009). Based upon the response to the FOI, two sites will be selected initially for studies to confirm their suitability. This phase of the program will concentrate on the sites geological stability and predictability over a period of a million years. This means looking especially at infrequent events such as major earthquakes, volcanism, and sudden climatology changes. Also tests will be performed
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to determine (a) site response to thermal heating by the waste packages; (b) site ability to provide substantially complete containment of radioactive nuclides, and (c) site capability to avoid erosion and attack of the waste packages. The waste packages will be presumed to be the same as those described in the Yucca Mountain licensing submittal. As the tests on the two sites progress, one site performance will show more potential than the other and it should become the reference site and be given more attention than the second backup site. When sufficient tests and analysis have been carried out with the state support and while keeping NRC informed, it would be time to prepare a Programmatic Environmental Impact Statement (PEIS) and a Site Safety Report for submittal to NRC asking for approval of the site and for permission to proceed with the construction and operation of the interim Centralized Spent Fuel Facility. Also, a transportation safety report should have been prepared and submitted for NRC approval. If hearings approve that request, shipments of spent fuel to the Storage Facility can be started to limit government liabilities associated with once-through spent fuel. It should be noted that the GAO proposed centralized fuel spent storage facility included the case for storing 153,000 MT of HLW for 100 years and that it would cost from $15 billion to $29 billion. This is an alternative option to reprocessing and recycling spent fuel because it would reduce decay heating and it would give DOE considerable time to pursue advanced fuel cycles and reactors as well as how to best use once-through spent fuel. As pointed out by (EPRI and INL, 2009), it can be anticipated that there is a fraction of used spent fuels that should be shipped to AGR because “it offers little or no economic potential for recycle”. Similarly, DOE HLW needs to be shipped to AGR to avoid potential liabilities. The second phase to design, construct, and operate the repository, therefore, should proceed shortly after the NRC site approval. The waste packages for DOE HLW and once-through spent fuel should be those submitted for approval at Yucca Mountain. Through this entire process of getting approval for AGR, formal, well-structured risk-informed decision making process should be employed (National Academies Press, 2005). Human health is a good starting criteria but it is not sufficient. “At a minimum, costs, work-related risks, risks to ecosystems, technical feasibility, cultural and societal impacts, land use implication, preexisting agreements, and other site specific factors” (National Academies Press, 2005) need to be considered. Also, “an effective and credible risk-informed-decision-process is (1) participatory; (2) logical; (3) consistent with current scientific knowledge and practice; (4) transparent and traceable; (5) structured with reasonable independence of the decision authority from the petitioner; (6) subjected to thorough, independent review; (7) technically credible, with believable results; and (8) framed to address the needs of the decision-process” (National Academies Press, 2005). The DOE PEIS and AGR Safety and Transportation for Yucca Mountain will need to be modified to fit the new site and submitted with the approval of the involved community and states. The objective is to do a high quality job and to take the time necessary to get the support of the parties involved and the public and to obtain NRC approval using the NRC process for public involvement followed by Presidential and Congressional approval.
5. Conclusions 1. The pursuit of a joint AGR and a centralized spent fuel storage facility is recommended to limit government liabilities as soon as possible. 2. A modified NWPA is needed which would allow a different nonpoliticized organization to carry the work to avoid any conflict
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3.
4. 5. 6.
S. Levy / Nuclear Engineering and Design 240 (2010) 3665–3668
of interest or political interference, to improve its management and to insist upon accountable performance. A two-step approval is to be sought from the NRC; first site approval, and second facility approval. NRC approval will include opportunity for public involvement within NRC processes. An open participatory process should be employed seeking involvement from voluntary sites and states and from the public. A formal, risk-informed decision approach should be used to assure safety and security for the storage facility and repository. This approach is expected to take advantage of prior work performed on the Yucca Mountain Project as appropriate and to help contain the cost of starting all over again.
References Bunn, M., et al., 2001. Interim Storage of Spent Nuclear Fuel. Harvard University and University of Tokyo.
DOE, 2008 October. Draft Global Nuclear Energy Partnership Programmatic Environmental Impact Statement. DOE. EPRI and INL, 2009. A Strategy for Nuclear Energy Research and Development. GAO, 2009 November. Nuclear Waste Management, Key Attributes, Challenges, and Costs for the Yucca Mountain Repository and Two Potential Alternatives. Levy, S., 2009. Interim storage of power reactor spent fuel (SNF) and its potential application to SNF separations and closed fuel cycle. Nuclear Engineering and Design, doi:10.106/j.nucengdes.2009.04.013. National Academies, 2001. Disposition of High Level Waste and Spent Nuclear Fuel, The Continuing Societal and Technical Challenges, Washington, D.C. National Academy of Sciences, 1957. The Disposal of Radioactive Waste on Land, Washington, D.C. National Academies Press, 2005. Risks and Decisions about Disposition of Transuranic and High Level Radioactive Waste, Washington, D.C., p. 5. Nuclear Energy Agency, 2009. Considering Time Scales in the Post Closure Safety of Geological Disposal of Radioactive Waste, NEA No. 6424, OECD.
Contents lists available at ScienceDirect
Nuclear Engineering and Design journal homepage: www.elsevier.com/locate/nucengdes
Need for USA high level waste (HLW) alternate geological repository (AGR) and for a different methodology to enhance its acceptance Salomon Levy ∗ 3425 South Bascom Avenue, Suite 225, Campbell, CA 95008, United States
a r t i c l e
i n f o
Article history: Received 2 March 2010 Received in revised form 25 May 2010 Accepted 4 June 2010
a b s t r a c t In early February 2010, the administration stopped work and withdrew the Department of Energy (DOE) application for a construction permit for the Yucca Mountain geological repository from the Nuclear Regulatory Commission (NRC). Also, a “blue ribbon” Commission was appointed to explore alternatives for storage, processing, and disposal, including evaluation of advanced fuel cycles and to provide a final report in 24 months. That decision, however, failed to recognize that: (1) the U.S. will need an early alternate geological repository (AGR) for its HLW irrespective of the findings of the “blue ribbon” Commission; (2) the once-through spent fuel inventory from commercial nuclear power reactors will continue to rise and so will the damages against the government for its failure to remove spent fuel from reactors sites, as specified in contracts; (3) there are prepackaged DOE and nuclear weapons HLW ready for shipment to a repository which must be taken into account because of government penalties for failure to do so; (4) the current Nuclear Waste Policy Act (NWPA) needs to be modified to allow the early search and approval of Alternate Geological Repository (AGR) and for an interim centralized HLW storage facility to reduce government liabilities; and (5) the methodology used to license Yucca Mountain needs to undergo serious modifications, including a different non-politicized management and siting credo. This paper reviews and discusses all the preceding shortcomings and proposes significant changes to pursue AGR as soon as possible and to get site approval by the NRC first under a formal, stepwise, well-structured risk-informed decision approach as recommended by the (National Academy, 2001). © 2010 Elsevier B.V. All rights reserved.
1. Introduction In 1957, the National Academy of Sciences concluded that nuclear HLW disposal in deep geological repositories (GR) would provide the best protection to humans and the environment against the intense, long-lived, and hazardous radioactivity of nuclear HLW (National Academy of Sciences, 1957). That conclusion has been reinforced several times by the (National Academy, 2001) and by the pursuit of GRs by practically all other nuclear countries, including Belgium, Canada, Finland, France, Germany, Hungary, Japan, Spain, Sweden, Switzerland, and the United Kingdom (Nuclear Energy Agency, 2009). In 1983, under the Nuclear Waste Policy Act (NWPA), DOE was given responsibility for studying several locations for possible disposition of nuclear waste. In 1987, NWPA was amended by President Reagan to restrict the study to only Yucca Mountain. The long history of Yucca Mountain from 1987 to its demise 23 years later has been recounted many times, with the latest account produced by the U.S. Government Accountability office (GAO in 2009). This report will not repeat that history but instead
will put emphasis on the lessons that could be learned from it. Section II will repeat previous opinions why the “blue ribbon” Commission will not eliminate the need for AGR. Also it will cover the urgency for an AGR as soon as possible. Section III will develop why another non-politicized organization is needed to manage the search of AGR. Section IV will propose a modified siting credo and licensing approach with the NRC first approving the AGR site and subsequently the facility, which could last from 4 to 8 years. During the time span of Sections II–IV, DOE and its contractors or another designated management organization as recommended above will pursue the recommendations of the “blue ribbon” Commission and be in a position to recommend the forms, volumes, and characteristics of HLW to be dispositioned in the NRC approved site. The AGR management entity will then prepare a submittal to NRC and obtain its approval for design, construction, and operation of the repository facility. This orderly stepwise approach will provide the way to reach a long overdue solution to the disposal of the continually growing U.S. HLW. 2. Why AGR
∗ Tel.: +1 408 369 6500; fax: +1 408 377 2846. E-mail address: [email protected]. 0029-5493/$ – see front matter © 2010 Elsevier B.V. All rights reserved. doi:10.1016/j.nucengdes.2010.06.036
U.S. nuclear power plants generated close to a remarkable 800 billion kilowatt-hours (kWh) of electricity in 2009 and a renais-
3666
S. Levy / Nuclear Engineering and Design 240 (2010) 3665–3668
sance program is underway to increase that capacity. All those plants are operating using the once-through fuel cycle which removes spent fuel from the reactors after it is depleted and stores it for disposal as HLW. That total nuclear power waste and DOE HLW is at about 70,000 metric tons (MT) and is expected to more than double to 153,000 by 2055 (GAO, 2009). Originally, DOE had set January 31, 1998 to start accepting HLW but in July 2008 DOE moved that date to 2020. That shift resulted in the need for additional storage at the nuclear power plants. Utility lawsuits for that site storage against the government were supported by the courts and are estimated to cost taxpayers $12.3 billion in damages through 2020 and could cost $500 million per year after 2020 (GAO, 2009). Furthermore, DOE has agreements with specific states to remove DOE HLW which is supposed to go to a repository and which will not enter the Commission deliberations. Those agreements involve penalties such as $15,000 per day with the state of Colorado and $60,000 per day with the state of Idaho if the DOE HLW is not removed from those states by January 1, 2035 (GAO, 2009). The total government liabilities readily could exceed $30 billion by 2055 which is a very good reason for an urgent pursuit of AGR. Another reason for pursuing AGR is that, under the evaluation of alternate fuel cycles by the Global Nuclear Energy Partnership (GNEP) (DOE, 2008), it was pointed out that “all reprocessing technologies under consideration as part of GNEP would produce wastes requiring disposal in a repository”. Furthermore, in the Strategy for Nuclear Energy Research and Development issued by the Electrical Power Research Institute (EPRI) and the Idaho National Laboratory (INL) (EPRI, 2009) it was noted that “management of used fuel and the portion that is ultimately disposed as a nuclear waste, is a key issue for public confidence in nuclear energy and that a “mined geological repository should be developed for HLW that offers little or no economic potential for recycle”. Currently, the HLW is being dispersed over many areas of the U.S.A., increasing the associated safety risks and to the dislike of some local populations. It is realized that interim centralized storage has been suggested to correct that situation (Levy, 2009), assuming that states willing to host such facilities could be found. The best solution would be to combine interim centralized storage with AGR because AGR needs a receiving area (not allowed at Yucca Mountain) to improve HLW movement and logistics. That combination also would avoid the need for two transportations of HLW to the centralized storage site and subsequently to AGR. Unfortunately, the pursuits of an AGR or an interim centralized spent fuel facility are not possible right now because they were prohibited under NWPA to achieve the acceptance of Yucca Mountain. The Congress and the President need to modify NWPA to increase its flexibility in terms of repository location and centralized interim storage facilities. It is not obvious that a revision of NWPA will be forthcoming right away because several members of Congress continue to believe that Yucca Mountain should be selected and many may prefer to delay any change until the next election of 2010. However, reality will set in when the “blue ribbon” Commission report is issued, noting the need for a repository even though time and money could have been saved by an earlier decision which would have stopped the loss of personnel familiar with geological repository development.
3. Different management It is recommended that another non-politicized organization lead the search for AGR and for an adjoining centralized spent fuel storage facility. The reason is that DOE did not do a good job of managing the Yucca Mountain project. It spent $14 billion and 28 years without having much to show for it. One principal reason is
its strong push of Yucca Mountain for geological repository even though the site community and the state of Nevada were definitely against it and were able to mount a strong political, legal, and technical opposition effort. Similar circumstances had led to the abandonment of nuclear power plants during their licensing process. The management of the Yucca Mountain project had several other problems. The project quality assurance was found to be inadequate and led to a significant redo of the work and loss of schedule. Also, the National Academy recommendation to consider the time for peak dose from the repository was not accepted. Subsequently, it was supported by the Court of Appeals and it led to an Environmental Protection Agency (EPA) standard change to cover 1,000,000 years instead of 10,000 years. I had the opportunity to consult for the Yucca Mountain staff in 1999–2001. I noticed the very large and excessive number of contractors employed at the site and that several contractors were working on topics of their choosing rather than subjects and schedules imposed by the project. I also noted the absence of personnel from the spent fuel owners even though they were providing 80% of the costs. The biggest shortcoming may have been the failure to recognize that the “biggest challenges to waste disposal are societal” and “require open, transparent, and broadly participatory decision making” (National Academies Press, 2005). DOE is also subject to political influence. Its management personnel and their role tend to change with the political party in power. In 2002, DOE recommended approval of Yucca Mountain for the disposal of HLW without approval of the NRC and had the President and Congress adopt it. That decision is difficult to comprehend since the NRC was formed to assure independent safety evaluation of nuclear risks. DOE has operated in the past under the premise that it has the authority to propose and to approve HLW disposal plans. However, the Academy has pointed out that DOE may have had a conflict of interest (National Academies Press, 2005) under those circumstances, which is certainly the case for the disposal of commercial spent fuel. For instance, when the Private Fuel Storage (PFS) program, a consortium of 11 utility companies decided to go ahead with a 40,000 MT storage of spent fuel in Utah, it sought approval by the NRC. That standard of seeking NRC approval should be maintained for AGR and it is one more reason for recommending another non-politicized organization to manage the pursuit of AGR and a centralized spent fuel storage facility. NWPA should allow it and even encourage it. In conclusion, it is important to establish a new organization to avoid any conflict of interest, to reduce political influence, to pursue AGRs under improved and accountable management and to reduce unnecessary other interferences. This organization called AGR Co. could be patterned after similar organizations employed in all other nuclear countries (Nuclear Energy Agency, 2009), e.g. SKB, Swedish Nuclear Fuel and Waste Management Co. or ANRA, National Agency Radioactive Waste Management, France. Its officers and staff should come from top management nuclear organizations, expert HLW and site research and construction specialists and it should be funded, similarly to Yucca Mountain, 80% by the nuclear power industry and 20% from the government HLW funded programs. AGR Co. should hire top industry officers, project managers, schedulers, cost estimators, licensing engineers, communicators, and convincing presenters. DOE could provide the Technical Director and Transportation Manager and most of the personnel to support them but they are expected to report to AGR Co. management and get paid by it. Much of the personnel from DOE will be those utilized from National Laboratories in the development of the Yucca Mountain Application Report so as not to lose their expertise and work performed. An alternate would be for DOE to provide an oversight in those two areas. AGR Co. initial focus will be to prepare a 5-year plan to pursue two different sites for AGR and a centralized spent
S. Levy / Nuclear Engineering and Design 240 (2010) 3665–3668
fuel storage facility in order to encourage competition and to have one site left if the other falters during the process. The objective of that first phase of the plan will be to obtain NRC approval in two steps: first for the sites and second to follow with a submittal for the design, construction, and operation of the facilities. That second phase should happen after the “blue ribbon” Commission results become available and DOE has determined the forms, amounts and characteristics of HLW to be disposed in the NRC approved AGR site. AGR Co. should have a strong Independent Advisory Council consisting of well known U.S. and foreign HLW experts who will review its organization, plans, and progress and issue periodic reports to the President, Congress, interested parties, and the public.
4. Different site credo and strategy A comprehensive facility credo was developed by (Bunn et al., 2001) for Interim Storage of Spent Nuclear Fuel. Most of its principles should be adopted for AGR Co., including instituting a broad based participatory process, seeking consensus, seeking acceptable sites through a volunteer process, and working to develop trust. The desired outcomes are choosing the sites which best address the problems guaranteeing that stringent safety will be met, and that the NRC approval will be sought, fully addressing all negative aspects of the facilities, working for geographic fairness, and especially making the host community much better off. As soon as AGR Co. is authorized, it will start to appoint its staff, meet with DOE to define their respective responsibilities, and start preparing a 5-year plan. Also, they should have an information meeting with NRC to explain the different site credo and the two-step approach of obtaining NRC site approval first followed by approval of construction and operation of the facilities. Assuming no objection from NRC, they should ask for their comments about potential sites and NRC possible site requirements. Agreement upon future meetings schedule should be agreed to and satisfied. Simplified description of the joint AGR and interim centralized storage facilities, readily understandable by the public should be prepared with emphasis on safety provisions, review by the NRC and seeking broad based participation. Those descriptions should rely upon the available Yucca Mountain and Private Fuel Storage write-ups. A meeting between AGR Co. and DOE also should be held to establish a list of potential sites which should include clay, crystalline rock, and salt formations. The following step would be to issue a Funding Opportunity Initiative (FOI) to Communities and States, to seek volunteers for site studies, and to offer funding for their participation including hiring their own experts, attending public and NRC meetings. The interested parties should be invited to a meeting where their possible future benefits are highlighted in terms of jobs, transportation, and additional possibilities in terms of training and education. It should be pointed out that GAO has estimated that a repository to dispose of 153,000 MT facility cost from $41 billion to $67 billion (in 2009 present value). The 2009 present value cost of a centralized storage of 153,000 MT at the end of 100 years was estimated to range from $15 billion to $29 billion and would increase to $23 billion and $81 billion with final geologic disposal. In other words, total potential work could be very large and cover many years. Finally, it should be noted that at least 11 other countries are pursuing going ahead with a geological repository (Nuclear Energy Agency, 2009). Based upon the response to the FOI, two sites will be selected initially for studies to confirm their suitability. This phase of the program will concentrate on the sites geological stability and predictability over a period of a million years. This means looking especially at infrequent events such as major earthquakes, volcanism, and sudden climatology changes. Also tests will be performed
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to determine (a) site response to thermal heating by the waste packages; (b) site ability to provide substantially complete containment of radioactive nuclides, and (c) site capability to avoid erosion and attack of the waste packages. The waste packages will be presumed to be the same as those described in the Yucca Mountain licensing submittal. As the tests on the two sites progress, one site performance will show more potential than the other and it should become the reference site and be given more attention than the second backup site. When sufficient tests and analysis have been carried out with the state support and while keeping NRC informed, it would be time to prepare a Programmatic Environmental Impact Statement (PEIS) and a Site Safety Report for submittal to NRC asking for approval of the site and for permission to proceed with the construction and operation of the interim Centralized Spent Fuel Facility. Also, a transportation safety report should have been prepared and submitted for NRC approval. If hearings approve that request, shipments of spent fuel to the Storage Facility can be started to limit government liabilities associated with once-through spent fuel. It should be noted that the GAO proposed centralized fuel spent storage facility included the case for storing 153,000 MT of HLW for 100 years and that it would cost from $15 billion to $29 billion. This is an alternative option to reprocessing and recycling spent fuel because it would reduce decay heating and it would give DOE considerable time to pursue advanced fuel cycles and reactors as well as how to best use once-through spent fuel. As pointed out by (EPRI and INL, 2009), it can be anticipated that there is a fraction of used spent fuels that should be shipped to AGR because “it offers little or no economic potential for recycle”. Similarly, DOE HLW needs to be shipped to AGR to avoid potential liabilities. The second phase to design, construct, and operate the repository, therefore, should proceed shortly after the NRC site approval. The waste packages for DOE HLW and once-through spent fuel should be those submitted for approval at Yucca Mountain. Through this entire process of getting approval for AGR, formal, well-structured risk-informed decision making process should be employed (National Academies Press, 2005). Human health is a good starting criteria but it is not sufficient. “At a minimum, costs, work-related risks, risks to ecosystems, technical feasibility, cultural and societal impacts, land use implication, preexisting agreements, and other site specific factors” (National Academies Press, 2005) need to be considered. Also, “an effective and credible risk-informed-decision-process is (1) participatory; (2) logical; (3) consistent with current scientific knowledge and practice; (4) transparent and traceable; (5) structured with reasonable independence of the decision authority from the petitioner; (6) subjected to thorough, independent review; (7) technically credible, with believable results; and (8) framed to address the needs of the decision-process” (National Academies Press, 2005). The DOE PEIS and AGR Safety and Transportation for Yucca Mountain will need to be modified to fit the new site and submitted with the approval of the involved community and states. The objective is to do a high quality job and to take the time necessary to get the support of the parties involved and the public and to obtain NRC approval using the NRC process for public involvement followed by Presidential and Congressional approval.
5. Conclusions 1. The pursuit of a joint AGR and a centralized spent fuel storage facility is recommended to limit government liabilities as soon as possible. 2. A modified NWPA is needed which would allow a different nonpoliticized organization to carry the work to avoid any conflict
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4. 5. 6.
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of interest or political interference, to improve its management and to insist upon accountable performance. A two-step approval is to be sought from the NRC; first site approval, and second facility approval. NRC approval will include opportunity for public involvement within NRC processes. An open participatory process should be employed seeking involvement from voluntary sites and states and from the public. A formal, risk-informed decision approach should be used to assure safety and security for the storage facility and repository. This approach is expected to take advantage of prior work performed on the Yucca Mountain Project as appropriate and to help contain the cost of starting all over again.
References Bunn, M., et al., 2001. Interim Storage of Spent Nuclear Fuel. Harvard University and University of Tokyo.
DOE, 2008 October. Draft Global Nuclear Energy Partnership Programmatic Environmental Impact Statement. DOE. EPRI and INL, 2009. A Strategy for Nuclear Energy Research and Development. GAO, 2009 November. Nuclear Waste Management, Key Attributes, Challenges, and Costs for the Yucca Mountain Repository and Two Potential Alternatives. Levy, S., 2009. Interim storage of power reactor spent fuel (SNF) and its potential application to SNF separations and closed fuel cycle. Nuclear Engineering and Design, doi:10.106/j.nucengdes.2009.04.013. National Academies, 2001. Disposition of High Level Waste and Spent Nuclear Fuel, The Continuing Societal and Technical Challenges, Washington, D.C. National Academy of Sciences, 1957. The Disposal of Radioactive Waste on Land, Washington, D.C. National Academies Press, 2005. Risks and Decisions about Disposition of Transuranic and High Level Radioactive Waste, Washington, D.C., p. 5. Nuclear Energy Agency, 2009. Considering Time Scales in the Post Closure Safety of Geological Disposal of Radioactive Waste, NEA No. 6424, OECD.