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| | | published Monday, November 17, 2008 | 2893 Views :: 0 Comments | |  |
Alliance for Nuclear Accountability Comments for Global Nuclear Energy Partnership draft Programmatic Environmental Impact Statement
The Alliance for Nuclear Accountability (ANA) objects to the Global Nuclear Energy Partnership (GNEP) draft Programmatic Environmental Impact Statement (PEIS)’s support for reprocessing of high level radioactive waste. As stated in the draft PEIS, GNEP intends to provide nuclear power that is safe, secure and economical while “reducing the impacts associated with spent nuclear fuel disposal and reducing proliferation risks.” ANA, however, finds that the GNEP proposal would actually exacerbate the inherent proliferation, cost, safety, waste, and security risks associated with nuclear power.
The draft PEIS diminishes many of these risks by minimizing environmental impacts of reprocessing; and by not providing a full proliferation risk or life cycle cost analysis for GNEP. Furthermore, it overstates the need for reprocessing by exaggerating projections of increased U.S. nuclear power production capacity in the future. Finally, the no action alternative supports funding for the Advanced Fuel Cycle Initiative which conducts research for reprocessing. Instead of the preferred or no action alternatives, the final PEIS should support the establishment of hardened on-site storage (HOSS) of nuclear waste.
Future Projections for Nuclear Power
The draft PEIS overstates the future growth of nuclear power in the United States. It argues that the “underlying purpose and need [for GNEP] is to support expansion of domestic nuclear energy production.” DOE argues that this need derives from projections that U.S. nuclear capacity will increase from 100 to 200 gigawatts over the next 52 to 62 years. For DOE’s scenario to be feasible, 80-100 nuclear reactors would have to go online over that period of time. However, the Energy Information Administration (EIA), a government entity that provides policy-neutral data and energy capacity projections, projects that only 17 gigawatts of increased capacity is projected to come from new nuclear plants over the next 22 years and there are only plans for 24 new nuclear plants. For DOE’s projections to be feasible there would have to be a policy shift supporting an unprecedented increase in federal subsidies and construction rates for nuclear power plants. Considering the current worldwide economic situation and public opinion on nuclear power, this seems unlikely.
Waste Volumes
DOE’s contention that GNEP will reduce waste volumes does not take environmental discharges from reprocessing facilities.
The History of reprocessing in the United States and abroad has demonstrated that these facilities have a catastrophic effect on the environment. The reprocessing facility in West Valley, New York, which was the site of the only commercial reprocessing plant that operated in the United States, accumulated 600,000 gallons of high-level waste onsite.
Since it went on line, the French reprocessing facility at La Hague has discharged 100,000,000 gallons of radioactive liquid wastes annually into the English Channel and continues to blow gaseous forms of krypton-85 and carbon-14 downwind. According to a recent report by the International Panel on Fissile Materials, La Hague is the largest man-made source of radioactivity releases to the environment. In the United Kingdom, the Sellafield reprocessing facility has discharged 1,000 pounds of plutonium into the Irish Sea. In 2001, the European Parliament's Scientific and Technological Options Assessment (STOA) published a report stating that 80% of the collective radiation dose of the entire French nuclear power industry, and 90% of the radioactive emissions and discharges from the British nuclear power program, come from commercial waste reprocessing. According to the report, 70 years of “routine” operations of the French and British reprocessing plants would equal the collective radiation dose of the Chernobyl reactor meltdown.
The draft PEIS must address how DOE will handle waste streams that include, but are not limited to,
strontium, cesium, radioactive lanthanides, technetium, uranium, and krypton gas.
No Proliferation Analysis
For thirty years, the United States has observed a moratorium on reprocessing. The message was essentially “we don’t do need it, so neither should you.” During that time, no additional countries began reprocessing nuclear waste. Since the United States announced the resumption of reprocessing under GNEP, several countries have expressed interest in developing sensitive nuclear enrichment and reprocessing. In one case, the United States has used to GNEP to promote the use of reprocessing technology in a country that previously did not have it. Since 2006, the United States has been assisting the Republic of Korea in the development of pyroprocessing technology.
During testimony to the Senate Committee on Energy and Natural Resources, Harvard University’s Dr. Matthew Bunn stated “GNEP's heavy focus on building a commercial-scale reprocessing plant in the near term would, if accepted, increase proliferation risks rather than decreasing them.” Despite that one of GNEP’s fundamental stated purposes is to reduce proliferation risks, no analysis of GNEP's proliferation impacts is provided. Instead, the National Nuclear Security Administration plans to release a separate nonproliferation assessment to be released at a later date. Due to the dramatic shift in U.S. policy, concerns by many independent experts, and the fundamental rationale for GNEP, the PEIS must include a proliferation impact analysis.
The analysis should also include a risk assessment that addresses the potential for loss of nuclear material or diversion by terrorists. Spent fuel that has not been reprocessed is considered “self protecting” because it is highly radioactive. Separated plutonium is a fine powder, and approximately 18 lbs. are required to make a bomb. The International Atomic Energy Agency already allows for a 3% margin of error in accounting for plutonium in existing reprocessing facilities. All of this increases
the risk that material could be lost or diverted by terrorists.
No Life Cycle Cost Analysis
This draft PEIS does not include a life-cycle cost estimate for GNEP. However, in 1996 the National Academy of Sciences issued a report estimating that a reprocessing project like GNEP could cost more than $500 (1996 dollars) billion. Additionally, the Congressional Budget Office has stated that "Reprocessing of U.S. spent fuel would cost 25 percent more than plans for direct disposal" in a permanent repository. Under the current plan for GNEP, the taxpayer and rate-payers, not the nuclear power industry, would bear this cost. The Department of Energy must provide a full cost analysis for GNEP and its impacts on both rate payers and taxpayers.
No Action/Preferred Alternatives
The PEIS states that under the no action alternative DOE would continue activities associated with the Advanced Fuel Cycle Initiative and other related DOE programs, including programs that address safety, safeguards and security requirements for advanced fuel cycle technologies. The Advanced Fuel Cycle Initiative (AFCI) is a program that essentially supports the research and development of advanced fuel cycle technology for the Global Nuclear Energy Partnership. If DOE decides to move forward with the no action alternative, it should not include research and development under AFCI. Since this PEIS is supposed to assess the feasibility of reprocessing, the alternative to reprocessing should not be continued pursuit of reprocessing while doing nothing to address the growing problem of nuclear waste.
In accordance with the Nuclear Waste Policy Act of 1982, nuclear waste would eventually be stored in a geologic repository. However, disposal in a geologic repository is not the only option available for managing nuclear waste, and other means – like waste storage in dry casks - need to be examined in this report. The Alliance for Nuclear Accountability supports the Principles for Safeguarding Nuclear Waste at Reactors. These principles, which are supported by more than 100 national organizations and local communities near reactors, would store reactor waste in reinforced dry casks as near as possible to the sources of generation. As a result, the waste can be managed for 100 to 200 years while some of the most radioactive elements, such as cesium-137 and strontium-90, decay away, making the waste less dangerous to handle.
The Alliance for Nuclear Accountability is a network of more than 35 local, regional and national organizations representing the concerns of communities in the shadows of the U.S. nuclear weapons sites and radioactive waste dumps. As Americans, we are gravely concerned about the proliferation risks and, as taxpayers, the cost of GNEP. Additionally, many of the organizations within the Alliance are in areas targeted for reprocessing facilities and are gravely concerned that their communities will become nuclear waste dumps just like West Valley, New York, La Hague, and Sellafield.
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