Re: S. 1287 and H.R. 45

["Zack Clayton" <zack.clayton@epa.state.oh.us>]

Suprisingly, I agree with Jim Muckerheide on several of these points, It looks like we disagree on how to deal with them.     I think defeating the bills serves a pronuclear agenda less than passage,  or there is a lot of industry propoganda that I have mis-intepreted.  

I will leave the mobile Chernobyl aspect  alone as I see that as a wash.  Spent fuel on the road is a target of opportunity.  Until such time as on site recycling of spent fuel becomes a reality the material is going to move over the road for either processing or disposal.  (Not something I anticipate in my lifetime - think of the publicly perceived safety record that process has to overcome.)  Economies of scale do factor in on this, especially after a plant closes and is no longer producing revenue.

>>We DO want the plants to be able to take control of their own destiny, not
continue to be subject to the ineptitude and whims of various presidential
administrations, vagaries of Congress, and DOE secretaries and bureaucrats.<<
Amen.  Lets get something going instead of wishy-washying it around for another four years.
At one point California was considering legislation barring future plant construction unless there was a place to send the waste.  I think this was passed into their law.  How many other states have done this?  I don't know, but the concept is out there.  Yucca Mountain would satisfy this requirement.

>>We do NOT want to give DOE another $million for every $thousand worth of work.  << 
Yeah, well the longer we wait the more that becomes self fulfilling.

>>We can NOT depend on DOE to do the job (see their track record - no
responsible executive would put more of their own money down such a rathole),
therefore every responsible plant is building on-site storage anyway. <<  
Agreed, But if you can't get congress to give you money to build a federal project it's real hard to fund the contractors to do it.  Thats what these bills move toward.    Its fine to shout "the Emporer has no chlothes!" But if the emporer is broke how is he going to buy any?  

>>We DO want the DOE waste funds to fund those on-site storage facilities (DOE is
directly responsible for failing to take it on schedule). <<  
This really depends on which State, PUC, and utility you're talking to.  Some do, some don't.   This has been an issue over the history of disposal and came to a head when "The Government", not just DOE, but the legislative, judicial, and executive branch all went limp on the issue of the January 1998 deadline for take title and take posession.  

On-site storage was viewed as a second best stopgap measure by everyone I talked to in industry and state government.   No one wanted the additional licensing burden and liablility of increasing the onsite storage and extending it beyond end of license.   The money was paid in to get a permanent repository, not to put band-aids on a failed government program that would still have to be implemented with reduced funding resources.  I haven't seen any of that rational change since that time.

<<DOE should be able/directed to provide alternative storage (which it can do at
any of hundreds of well-characterized surplus sites), but only if it can meet
the cost/schedule needs of the plants.>>   Agreed.

>>If (cost-effective) central storage is desired, that MUST be a PRIVATE
decision to be made by the plants, who will take the risks on their own
objective basis. Legislation could best address undue barriers to such private
storage alternatives.<<    Except that the legislation exists that the government  will provide permanent central storage of the *spent fuel it has title to*.  Lets clarify this, Who owns spent fuel?  If its the utiltiy, why don't they go ahead and ship it to BNF for reprocessing?  

>>We ABSOLUTELY do NOT want NEI to continue to lie to the public that spent fuel
in on-site storage is dangerous and must be moved for public safety!<<   I hadn't heard that on site storage was dangerous per se,  just more expensive for the plant.

>>AND MOSTLY: We will NOT accept that we will bury spent fuel.<<
Who said anything about burying spent fuel?  I have not heard of any plans to immediatly backfill the storage.  If you think about it,  the entire problem has not been to bury the fuel. its putting it somewhere that you can get it back.  Burial options are a lot easier than Yucca Mountain  The problem with them is you loose the ability to get the material back.  The design difficulty has always been to find a place that will store it safely and allow retrieval.

Mike -  The studies I have seen indicate the regional ground water is about 800 feet below the repository horizon.  To eliminate standing water in that repository horizon install  "footer drains" at whatever level below the repository horizon gives the best  results for keeping standing water away from the fuel.   It's an engineered facility,  engineer a solution to the perceived water problem.

I would like to say that all this represents my personal thoughts on the matter.  I make no claims for my employer, the State of Ohio, the Governor or any other person or legal entity.  





Zack Clayton
Ohio EPA - DERR
email:  zack.clayton@epa.state.oh.us
voice:  614-644-3066
fax:        614-460-8249
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