SNF Storage on the Salado: What Could Go Wrong?

Into the Salado

As you read this, a complex and contentious narrative is unfolding in the arid expanses of Lea County, New Mexico.

Central to this discourse is the proposed location of a Consolidated Interim Storage Facility (CISF) for spent nuclear fuel (SNF) within the Salado formation, a geological feature whose suitability for such a critical role is increasingly being called into question.

Equally potent is the opposition from New Mexico's governor and legislature, adding another layer of complexity to the unfolding narrative.

Between the increasingly debated suitability of the Salado Formation as a storage site and the mounting opposition from New Mexico's state authorities, there's an intricate interplay of scientific and political factors shaping the future of the Holtec facility. The nexus of these issues centers on the necessity for sound scientific judgment and democratic decision-making in the realm of nuclear waste management.

Navigating these intertwined challenges requires informed leadership, a role that NRC Commissioner Jeffrey Baran has been playing with a unique approach. His professional differing opinion within the Commission not only represents a counterpoint in this complex discourse but also underscores the importance of maintaining a diversity of perspectives in such critical matters.

Much like Admiral Rickover's nuclear navy, which prided itself on a near-flawless safety record achieved through the diversity of professional opinion, Baran's stance serves as a reminder that consensus should not be pursued at the expense of critical, independent thought.

Despite the growing chorus of opposition, the U.S. Nuclear Regulatory Commission (NRC) recently approved a license that allows the Holtec facility to move forward. The significance of this decision cannot be overstated, as it sets a precedent for future nuclear waste storage sites and raises crucial questions about the intersection of science, politics, and public safety in nuclear waste management.

This article aims to dissect these multifaceted issues, uncovering the intricate layers of nuclear waste storage in the United States and exploring the entangled controversies surrounding the Holtec site. As we delve into the geological, political, and design elements of this critical issue, we invite you to join us in fostering a greater understanding and promoting informed dialogue about the future of nuclear waste storage.

A Geological Gamble?

The Salado Formation, a vast underground structure that spans approximately 26,000 square miles beneath New Mexico and Texas, is a significant character in this narrative. Known for its stability and thick salt deposits, the Salado has been viewed as an ideal geological formation for the subsurface disposal of nuclear waste. Yet, recent research has begun to challenge this notion for surface storage.

The Salado's very stability comes from its being primarily composed of halite, with pockets of anhydrite, red beds, and potash salts such as sylvite, carnallite, and polyhalite. It was formed under extreme conditions over 250 million years ago, and its relative isolation from seismic activity and water intrusion has led to it being considered an ideal location for deep geologic nuclear waste disposal (see the Waste Isolation Pilot Plant, WIPP).

However, a closer examination of the geological and chemical composition of the Salado raises concerns: the Salado Formation contains not-insignificant quantities of magnesium chloride (MgCl), an aggressive compound known to rapidly induce chloride-induced stress corrosion cracking (CISCC), a type of corrosion that could lead to breaches in the canisters containing the spent nuclear fuel. While the exact quantity of MgCl throughout the Salado is not precisely known, its presence raises the stakes considerably.

In light of these findings, the decision to site the Holtec facility in the Salado Formation appears increasingly fraught.

While the formation's stability and isolation offer some advantages, the potential for leakage and corrosion cannot be overlooked. The question that arises then is — are we taking a geological gamble with our nuclear waste? 

Sidebar: The Dissonance Between DOE Research and NRC Decision-Making

When it comes to the potential dangers of Chloride-Induced Stress Corrosion Cracking (CISCC) in spent nuclear fuel storage, the Department of Energy (DOE) and the Nuclear Regulatory Commission (NRC) seem to be playing out different scripts.

On the one hand, the DOE has been actively pursuing research to understand the true magnitude of CISCC risk. Studies like the Savannah River National Laboratory's examination of welded plate material from a mockup spent nuclear fuel dry storage canister are emblematic of this effort. The DOE's research, characterized by its stringent and realistic testing conditions, has been instrumental in highlighting the significant potential for CISCC in spent nuclear fuel canisters.

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On the other hand, the NRC has been moving forward with licensing decisions, including the controversial Holtec site in the Salado Formation, seemingly without giving due consideration to the concerns and knowledge gaps raised by the DOE's research.

The NRC's actions have raised questions about the depth of consideration given to these critical issues during the licensing process.

This dissonance between the DOE's diligent research and the NRC's decisions underscores the need for more coordinated efforts. The potential risks and consequences associated with CISCC are too severe to be left to disparate actions. There is an urgent need for the NRC to better integrate the findings from DOE's research into their decision-making processes.

In conclusion, as we grapple with the challenges of safe and responsible nuclear waste management, it is imperative that comprehensive research and its findings inform regulatory decisions. Addressing the identified knowledge gaps and aligning the efforts of the DOE and NRC could pave the way for more robust safety measures, ensuring the long-term security of spent nuclear fuel storage sites.

The Opposition, Host State Consent, and the NRC's Anti-Consent Stance

The NRC's recent decisions have sparked controversy and triggered strong opposition from state legislatures, marking a stark testament to the NRC's role as an anti-consent federal agency.

Remarkably, the NRC is two-for-two in eliciting state legislation against its decisions - a feat that underscores its unparalleled capability to undermine consent. Texas and New Mexico, both targeted for spent nuclear fuel storage, have passed laws banning the operation of the two facilities the NRC has licensed.

‘I will use every tool in my toolbox’ to block nuclear waste storage in New Mexico — Gov. Grisham, NM

In New Mexico, led by Governor Michelle Lujan Grisham and backed by the state legislature, a potent resistance against the proposed Holtec site has emerged. They argue that the NRC's decision, made without adequate consultation with state and local stakeholders, is a significant violation of democratic principles and puts undue environmental and public health risks on New Mexico's residents.

The Nuclear Waste Policy Act (NWPA) placed a requirement for host state consent for the very reasons that are now being highlighted by these opposition movements: the need to protect state rights, the importance of local knowledge and stakeholder participation, and the understanding that the storing of nuclear waste is a long-term commitment that impacts future generations.

The NRC, however, has chosen to sidestep this requirement by claiming that their authority to license a Monitored Retrievable Storage (MRS) facility is rooted in the Atomic Energy Act (AEA), not the NWPA. This move has further inflamed opposition, as it's seen as a blatant disregard for the NWPA's consent provision and a violation of the spirit of cooperative federalism.

Adding to this opposition are the concerns about the geological stability of the proposed site in the Salado Formation, which have been largely overlooked in the Holtec licensing process.

Notably, southeast New Mexico, where the Salado Formation lies, has been experiencing significant underground subsidence, a geological phenomenon that results in the gradual (or sudden) sinking of an area of land. This subsidence, coupled with the presence of seismic activity in the region, raises concerns about the long-term stability of a spent nuclear fuel storage site in this area. These potential geological hazards, if not appropriately considered and mitigated, could compromise the integrity of the storage site and pose a serious threat to the surrounding environment and communities.

The failure of the NRC to thoroughly assess these risks as part of the Holtec licensing process has further fueled opposition and skepticism about the proposed storage facility.

The opposition from Texas and New Mexico is not merely about the storage sites; it is a stark rejection of the NRC's disregard for state and local consent.

The states' legislative responses underscore the urgent need for the NRC to reassess its approach and consider more transparent, equitable, and informed decision-making processes. As Governor Lujan Grisham has stated, "New Mexico deserves better than to be a dumping ground for the nation's nuclear waste."

This clarion call for respect of state rights and local consent in the face of federal overreach has become a rallying cry for those demanding better, more responsible handling of spent nuclear fuel storage.

The Questionable Design of a "Temporary" Storage Facility

The Holtec SNF CISF site, while licensed for "temporary" storage, is a project designed with up to a 100-year lifespan in mind. However, a critical analysis of this proposition reveals serious shortcomings. The notion of a century-long temporary solution is problematic in itself. It underlines the lack of a robust, long-term strategy for nuclear waste disposal in the United States.

The design of the facility is another point of contention. Despite being a site for hazardous nuclear waste, the Holtec design lacks provisions for the repackaging of leaking or damaged canisters.

This is a glaring oversight, considering the severe risks associated with the release of nuclear materials. Canister failure could lead to a catastrophe, with environmental and health impacts that could extend far beyond the site's immediate vicinity.

Furthermore, the 100-year design life of the facility raises concerns about what will happen when this period ends. The notion of a "temporary" facility risks becoming a permanent solution by default if no alternative disposal sites or strategies are developed within the next century. This short-term approach to a long-term problem demonstrates a concerning lack of foresight and planning on the part of the NRC.

There are potential solutions to these design issues, although they would require a significant rethinking of the current plan.

One option could be to incorporate a repackaging facility into the design. Another could be the development of more durable canisters that are resistant to degradation and, therefore, less likely to need repackaging.

Either way, it's clear that more thought needs to be given to the long-term safety implications of the design. This is not just a 100-year question - it's a question of ensuring the safety and protection of the environment for generations to come.

A Welcomed Voice of Dissent: Commissioner Jeffrey Baran

While tangential to the matter of Holtec’s CISF licensing, the throttling of any dissent at the highest levels of the NRC is emblematic of the view by many nuclear industry critics that the Commission has been captured by industry and has become a transactional rubber stamp organization where you pay the fees and you get your license.

Commissioner Jeffrey Baran has long been an integral part of the Nuclear Regulatory Commission (NRC), known for his commitment to maintaining an independent voice within the institution.

Appointed by President Obama in 2014 and confirmed by the Senate, Baran brought with him a wealth of experience and a reputation for thorough analysis. His tenure has been marked by a dedication to upholding the core values of the NRC and a commitment to prioritizing public safety above all else.

Despite his unwavering dedication to his role, Baran has been the subject of intense criticism and attacks. These attacks, largely stemming from those who disagree with his dissenting opinions, represent an unfortunate departure from the respect for differing professional views that was once the hallmark of the NRC.

In maintaining an independent voice, Baran embodies the spirit of the NRC's traditional decision-making process – one that values robust discussion, the consideration of diverse perspectives, and the primacy of safety considerations.

The attacks on Baran have significant implications for the NRC's decision-making process. They threaten to stifle dissent, discourage independent thinking, and undermine the safety-centric culture that should define the NRC. They also set a dangerous precedent, sending a message that dissenting voices will not be tolerated.

This is particularly troubling considering the NRC's role in making decisions that significantly impact public safety and the environment. The independent voice Baran represents is crucial in ensuring that all perspectives are considered and that the best decisions are made in the interest of public safety.

Simple Solutions Require Collective Action

Several key concerns have surfaced as we've navigated the complexities of the nuclear waste storage issue at the proposed Holtec site in New Mexico.

From the Salado Formation's greatly enhanced potential to create conditions for the onset of accelerated chloride-induced stress corrosion cracking to the vociferous opposition from New Mexico's government; from the troubling criticisms of Commissioner Jeffrey Baran's independent voice to the questions surrounding the longevity of a 100-year storage facility design without provisions for repackaging damaged canisters — each of these elements underscore the challenging reality of the current nuclear waste management scenario.

Looking ahead, the future of the Holtec site, and indeed the broader context of nuclear waste storage, is shrouded in uncertainty. Yet, this narrative is far from complete.

The ensuing chapters hinge on our decisions today — decisions that bear weighty implications for environmental preservation, public safety, and the political landscape of nuclear waste management.

A critical question looms large in this context: which federal agency is best equipped to lead these endeavors?

The Nuclear Regulatory Commission, despite its crucial role, has no mandates for establishing consent.

On the other hand, the Department of Energy, with its extensive experience operating within communities across the United States, has a long-standing practice of community outreach and engagement. This practice is integral to fostering consent and goodwill, even though the DOE's record isn't flawless.

Ultimately, if our goal is to cultivate a positive vision for the future that effectively addresses the challenges of nuclear waste management, we need a leader who can foster dialogue, nurture transparency, and build consent. With its track record of community interaction, the DOE seems best and solely positioned to lead this effort.

In conclusion, the path forward calls for enhanced transparency, improved facility design, and the valorization of dissenting voices like Commissioner Baran's.

This is not just about the fate of a single site or state; it's about carving out a sustainable, responsible pathway for nuclear waste management. A pathway that prioritizes safety, respects local opposition, and is grounded in a scientific understanding of our choices.

The choices we make now will shape the narrative of nuclear waste management for generations to come. Let's ensure it's a narrative of cooperation, safety, and foresight.