After nearly three decades of R&D efforts, close observers are asking themselves if perhaps the Swedish nuclear industry hasn't reached a dead end concerning nuclear waste storage. The question arises after SKB AB, the industry's jointly owned company for nuclear waste solutions, published a "preliminary" environmental impact statement (EIS) on the KBS-3 scheme in December of last year. The report fails to meet even rudimentary requirements of an EIS. On the whole, it seems a half-hearted effort.
In January 2010 the SKB AB unilaterally declared the termination of public consultations on the project (consultations mandated by the Swedish Environmental Code, 1998). SKB AB makes no apologies, but simply notes that long-awaited updates will be filed together with the formal application. This is a blatant violation of the Code (ch. 6, para. 4), which requires that the public be given an opportunity to discuss and question all the aspects covered in an EIS.
Consultations are an integral part of the approval process. It should be noted, however, that the consultations have never been the dialogues envisaged by the lawmakers. (*1) SKB has shown a lack of interest that borders on hostility on the part of SKB AB. As the largest umbrella organization, MKG (the Swedish NGO Office for Nuclear Waste Review*2), puts it: "The company's chief purpose in the consultations appears to have been to rebut and reject participants' comments and questions rather than discuss them in any open manner".
It is a matter of public record that the KBS project has encountered difficulties with both of the man-made barriers that are intended to isolate the fuel waste. KBS-3 involves storage of spent fuel rods in copper canisters, about 400 meters down in granite bedrock. No resolution of the problems (uncertainty about the behavior of the clay buffer in the repository after closure, and empirical evidence that copper corrodes, even in the absence of atmospheric oxygen) has been reported.
Add to this a recommendation in January of this year from the Swedish National Council for Nuclear Waste, a body of scholars that advises the Swedish Government on issues relating to nuclear waste storage, that retrievability of the waste should be considered. The recommendation is a total reversal of government policy. SKB AB has earlier made a point of how difficult it would be for anyone to access and retrieve the contents of a KBS repository, once sealed.
The approval process
An EIS, addressed to one of Sweden's Environmental Courts, must accompany all applications for permits to undertake a project. Sets of requirements concerning aspects that have to be taken into account are set out in the Code and in the Law on Nuclear Technology (KTL) (1983).
Briefly the approval process is this: SKB AB submits an application as provided in both the Environmental Code and KTL, which incorporates criteria set out in the Radiation Protection Law. The application under the Environmental Code is considered by the Environmental Court; the application under KTL is considered by the regulator, the Nuclear Safety Authority. The Court and the Authority submit their findings to the Cabinet, which decides whether or not the project is allowable. (The Cabinet may choose to override the findings of the Court. This happened in a previous case involving the upgrading of reactors at Ringtails)
A "preliminary" EIS
The essential purpose of an Environmental Impact Statement is to describe a project's actual, probable and possible consequences for human beings and the natural environment. The document SKB AB issued in December 2009 is marked "preliminary", but even that label hardly prepares the reader for what is to come. The most central issues – those relating to the long-term safety of the repository, the choice of method and evaluation of alternative methods, the siting – receive the least attention. The company states, without supporting argumentation, that the proposed method for storing nuclear fuel waste will not have any impacts on human beings or the natural environment.
The principal faults – those to be discussed here – are (1) a nearly total absence of discussion of radiological consequences, in either the short or long term, (2) a failure to update safety analyses since the most recent report in 2006, then clearly "work in progress", (3) an overall limitation of the time-frame to the construction and loading phases, (4) no attempt to justify the choice of KBS-3 in terms of "best available technology", which would entail serious evaluation of alternative methods, (5) SKB AB's literal interpretation of the so-called "zero alternative", i.e., as making no attempt to do anything, only to "make do" with what already exists, and last, but hardly least (6) no attempt to convince either the court or the general public that the location (immediately adjacent to the Forsmark reactors in Östhammar) is the best Sweden has to offer.
The Swedish environmental groups are unanimous in their criticisms of an extraordinarily poor document and focus on essentially the same points. Interestingly, in addition, two municipalities – one of which the intended site of the repository – criticize the document, as does the provincial government of Åland (Finland). The following comments synthesize these comments.
The criticisms of the environmental movement fall into two categories: complaints about SKB ABs procedure, and concern about the actual safety of the KBS project.
The procedural complaints are specifically Swedish. Briefly, they focus on SKB AB's failure to submit updated safety data and analysis for consultation.
The most recent safety report (SR-Can) was published in 2006. A lot has happened since then. For one thing, the more detailed investigation of the two prospective sites has produced a lot of data. Also, SKB AB has acquired and presumably implemented new modeling software. A progress report published in 2007 assured readers that new modeling software would greatly improve the company's ability to understand interactive processes and to assess risks. Also, the above-mentioned problems concerning bentonite clay and copper corrosion have surfaced since the 2006 report. None of these developments are discussed in the EIS document.
Secondly, the preliminary EIS is essentially limited to the construction and loading phases of the project, i.e., the next 70 years or so. The reason given for this is that there will not be any leakage from the repository for at least 100.000 years. Consequently, there are no effects and environmental consequences to be reported. This is pure conjecture on SKB AB's part.
The EIS comes nowhere near fulfilling the requirements of an EIS according to Swedish law.
Scenarios should be elaborated for all possible contingencies: one or more broken canisters, erosion of the buffer, climate-instigated flooding of the repository in sea water, a serious accident in a Forsmark reactor, deliberate incursion, a terrorist attack, societal developments that lead to abandonment of the facility, etc. Low probability does not eliminate the need to consider all that may go wrong.
Time and again the radiation protection authority, SSI (now part of SSM) has urged the company to pay more attention to risk management and safety analysis. As late as 2007 authorities called for better quality assurance of the predictive models and pointed to the need to consider the eventuality that the repository might leak early on in the process. Time and again the company has procrastinated. First, until the prospective locations were inventoried, then until the safety follow-up would be published (it hasn't been), and now for the findings of dozens of technical reports that both exist (there are references to specific pages) and do not exist (they have yet to be published). Why the secrecy?
The key factors in terms of long-term safety are the toxicity of the waste, the extreme length of time involved, and the risk of nuclear proliferation.
The radiological safety of the project remains by far the most important aspect. In contacts with the public, however, SKB AB has consistently played down issues relating to the high rates of radiation in the fuel waste and the long-term threat from long-lived isotopes. As MKG, the largest umbrella group puts it: "Had the environmental movement not been present at the consultations, the average citizen would most probably have been left with the impression that it was simply a question of burying a bunch of copper canisters”.
A major question with regard to long-term safety is the prospect of a coming ice age. The repository must withstand at least one period of glaciation, which entails enormous stresses.
The integrity of the bedrock will have been compromised by the installation itself. Will a KBS-3 repository only 400 m. down in the midst of a tectonic zone survive?
Non-retrievability is a criterion for what may be considered a "final storage" solution in Swedish law. Two of the original aims of the KBS project were to produce a repository that (1) prevents unlawful handling of nuclear waste, and (2) requires no supervision or maintenance. Neither of these aims has been achieved.
There is no discussion of the need to guard or monitor the KBS-3 repository. On the contrary, the company continues to maintain that no supervision will be necessary.
The environmental movement's position is this: There is plutonium in a nuclear waste repository for over 100.000 years. This means that a repository of the KBS type has to be guarded that long. And, clearly, there is a need to monitor emissions from the repository after it is sealed.
BAT? Who's to say?
Back in the 1980s, SKB engineers were quick to settle on the KBS concept. For many years, any backing away from KBS-3 might endanger the nation's commitment to nuclear energy.
The environmental movement's principal complaints concern
• Uncertainty about the performance of the man-made barriers (copper canisters and clay buffer);
• The scarcity of copper as a resource;
• The waste of the remaining energy in spent fuel;
• No fuel waste repository should rely primarily on man-made barriers.
The KBS-3 system is often described as a "multiple barrier system", in which the barriers are copper, bentonite clay and the bedrock. We consider this description misleading. There may be three tiers in the system, but they are all mutually dependent. Functional redundancy is a fundamental principle in safety engineering. That is, all functions of importance to safety should be independent, each able to guarantee safety on its own.
The task before SKB AB today, as they finalize their application for permits to build, is to demonstrate that the Best Available Technology (BAT) will be used at every step and in every phase of the handling and storage of fuel waste and other high-level nuclear waste, while showing that the methods in question have been proven reliable. SKB must show that the KBS-3 method uses raw materials and energy efficiently and economically, and the company is expected to discuss the pros and cons of each alternative relative to the KBS-3 method.
Is this Mission Impossible? To show that KBS-3 makes use of the best available technology presumes that other methods have been evaluated. Consideration of alternative methods has been required by law since the late 1980s, but SKB AB has consistently refused to spend time, money or effort on any of them. That refusal now undermines the company's claim that KBS-3 is the best available technology.
Deep boreholes have emerged as the principal alternative to KBS-3. (*3) MKG, who recommend this alternative, characterize its treatment:
"Over the years, MKG notes, the company's treatment of the literature on deep boreholes has increasingly focused on the problems associated with the method, and most recently, SKB AB has constructed additional problems on its own that have no basis in empirical study”.
SKB AB, for their part, has stated that the company has no need of further data.
Nuclear fuel waste needs to be kept away from human beings and the biosphere for hundreds of thousands of years. It is unreasonable to believe that man-made barriers can do this over such a long time span.
The gaps between the models' predictions and actual performance of the clay and copper have widened considerably in recent years. At the same time SKB AB has shown less interest in further empirical study of the barriers. As the deadline for the application approaches, the company finds itself unable either to describe the performance of the barriers or to verify the accuracy of the models.
A key assumption from the start of the KBS project is that there would be no corrosion of the copper canisters in an oxygen-free environment. Judging from what has been published, however, no long-term studies of corrosion in a simulated repository setting have been done since the early 1980s. There has been no systematic follow-up, and no evidence has been published to support the models' (theoretical) assurance that the rate of corrosion will decline one thousand-fold in the repository environment. On the contrary, say researchers at the Royal Technological University in Stockholm, the KBS canisters may fail after only 1000 years. Obviously, SKB AB's presumption of safety requires some form of validation.
There are concerns about the behavior of the bentonite clay buffer. Will it swell at the rate posited? Analyses of data presented in the most recent safety analysis performed by Swedish regulatory authorities (2006) suggest that it may take thousands of years before the clay has filled the repository chambers. Will the clay remain in the repository through an ice age, considering all the hydrological and seismic events glaciation entails? The Radiation Safety Authority has expressed concern that SKB AB has been optimistic about the risks of erosion.
Finally, most of the empirical studies done to date have approximated the bedrock formation at Oskarshamn, not the much drier rock at Forsmark. No replications adapted to the actual site are planned, SKB AB has announced.
Is Forsmark really the best place?
SKB ABs localization process has not been systematic, has not been based on a priori criteria, and has been guided by other priorities than long-term environmental safety. The criteria for selection of the location have changed with the progress of the process. In the end, the company confined its investigations to the two nuclear energy municipalities, Oskarshamn and Östhammar (Forsmark). The choice seems to have been made more on the basis of political acceptance than geological suitability – which, of course, loses all relevance in the context of 100.000 years. Is Forsmark really the best Sweden has to offer?
SKB AB has not seen fit to outline the motives underlying the choice of site. Some drawbacks are obvious, however. The proposed site is coastal, the bedrock is in a (currently passive) shear zone (i.e. a fault), and the rock is drier than that originally envisaged for the KBS concept. The shallow positioning (400 m. underground) leaves the repository at risk of inundation by sea water – which may have chemical as well as mechanical impacts on the crucial clay buffer.
The environmental movement also questions the wisdom of siting repositories next to reactors.
We also favor an inland site, where leakage can better be contained and retarded (up to one thousand-fold), and the Baltic Sea is not the immediate recipient.
The Baltic Sea – a "robust recipient"?
FUD-report 2007 (p. 362) describes the Baltic as "the ultimate destination" of leakage from the KBS-3 repository – which the company believes will occur sooner or later in the "life" of the repository. Planned reliance on dilution in the biosphere is not acceptable to environmentalists.
To consider any sea an "appropriate recipient" for radioactive leakage reflects a poor understanding of ecological relationships. The best farmland in the province around Forsmark was sea bottom "only yesterday" in relation to the time the waste will remain a danger.
SKB AB has to clarify how they can state that the environmental impact of releases of drainage from the repository will be "modest" in as much as "the recipient is judged to be relatively robust". No support for the statement is given.
Åland, an archipelago between Sweden and Finland, lies only 60 kilometers from the proposed site. Consequently, the islanders – including the provincial government and the Municipality of Eckerö – are particularly sensitive to the use of the Baltic Sea as a recipient of possible leakage from the repository. Ålanders urge that cumulative effects of nuclear installations around the Baltic Sea be taken into account. The Municipality calls for a stop to the radiological pollution of the Baltic. All comments from Åland object to a coastal siting of the Swedish repository.
The people of Åland are also concerned that SKB AB plans to transport all fuel waste to Forsmark by sea. The EIS, they point out, lacks all discussion of how an accident at sea might be handled. In view of the overall condition of the Baltic Sea they question the wisdom of allowing transports of this kind in Baltic waters.
When one has read the EIS and the well-founded criticisms of it, the question arises: How could SKB AB get it so wrong?
The responses reviewed offer a number of possible explanations.
• Might it be over-confidence on the part of the company's engineers and management? Are they so convinced that all will function perfectly, that they see no reason to problematize their scheme? Does the corporate culture at SKB encourage critical thinking?
• Can it be that SKB still believes that the Environmental Code should not apply to nuclear technologies – a standpoint they lobbied for intensively for many years?
• Some groups put it down to the company's subversion of the consultation process. Had they only been willing to listen ....
Whether or not consultations are a futile exercise, the environmental groups and the Municipality of Östhammar argue that the process cannot be terminated until all relevant data and information have been put on the table. Several groups call for a continuation, but with some other, less partisan body in charge of the meetings and their documentation.
Whatever the reasons, the fact remains that SKB AB seems to have a long way to go before they can fulfill the requirements of the law. And the issue of retrievability alone is enough to send the company's engineers back to their drawing boards for a long, long time.
*1- For a personal assessment of the consultation process, see Hultén, C (2007) "Still Waiting for Glasnost", posted at http://www.nonuclear.se/archive/
*2- The umbrella organization includes the Swedish Society for Nature Conservation with nearly 140.000 members and local chapters throughout Sweden. MKG has full-time staff devoted to nuclear waste storage issues.
*3- For a presentation of the deep borehole approach see Åhåll, KI (2006). Final Deposition of High-level Nuclear Waste in Very Deep Boreholes, posted at http://www.nonuclear.se/archive/
See also: Nuclear Monitor 661, 11 October 2007: "Comparative study of public involvement in radioactive waste management" and Nuclear Monitor 673, 5 June 2008: "Sweden: radiation protection authority faults fundaments in KBS repository scheme"
With one exception the documents, in Swedish only, may be downloaded at www.nonuclear.se/archive/. The Eckerö community response may be accessed at mkg.se/uploads/Samradsinlaga_Eckero_2010000305.
Contributors: Ålands Natur & Miljö/ Aktionsgruppen för ett atomkraftsfritt Åland; Milkas (Swedish Environmental Movement's Nuclear Waste Secretariat); OSS/Avfallskedjan (OSS/The Waste Network); SERO – Sveriges Energiföreningars Riks Organisation
Sveriges Naturförening/MKG (Swedish Society for Nature Conservation/Swedish NGO Office for Nuclear Waste Review); Eckerö community (Åland); Östhammar community (Sweden); Ålands landskapsregering
Source and contact: WISE Sweden, Charly Hultén