The Sierra Club believes that nuclear power plants, barring exceptional circumstances, should be dismantled and the sites restored 30 to 50 years after the plant has ceased operating.
Most of the debris from dismantling is not low-level waste. More than 99% is, using 10 CFR Part 61 definitions, B, C, or greater than C in radioactivity. Control rods and fuel assembly parts are to all intents high-level radioactive waste.
This long-lived radioactive debris should be as carefully isolated as other dangerous radioactive wastes. The Nuclear Regulatory Commission and the Department of Energy should devise technology for safely decommissioning nuclear facilities, both commercial and military. These principles must be recognized:
- Pollution of air, earth and water during demolition must be avoided.
- Appropriate repositories for dismantled debris must be found and suitably developed and operated.
- A satisfactory site-selection process must be established and implemented.
- Safe transport of the debris must be devised.
We support the following objectives and responsibilities in the decommissioning and dismantling process:
- Utilities should be required regularly to set aside funds to cover decommissioning costs. Payments should be held in segregated accounts, or in an external sinking fund with insurance to provide against premature shutdown of the reactor or utility bankruptcy. The use of internal unsegregated funds should be prohibited as a financing option. States should require such decommissioning funds if the federal government fails to do so.
- There should be a major independent study of decommissioning and dismantling costs and problems by the Government Accountability Office's Science, Technology Assessment and Analytical Team
. - An environmental impact statement, with full opportunity for public comment, should be required for decommissioning each reactor.
- The debris from decommissioning and dismantling, which includes components with long half-lives, should be classified as high-level waste.
- A 50-year limit on the mothballing of reactors prior to dismantlement should be established.
- Chemical decontamination should be avoided. Such wastes, if generated, should be excluded from low-level waste burial, unless independent research dearly establishes that such disposal is safe.
- Utility liability for decommissioning costs should be strengthened through legislation.
- Current tax deductions should only be allowed for segregated decommissioning funds.
- Decommissioning cost estimates should be revised at least every five years and decommissioning funding adjusted accordingly.
- Entombment should be prohibited as a decommissioning method.
- The maximum permissible level of radiation exposure to nuclear decommissioning and dismantling workers should be reduced at least ten-fold, and a worker registry that monitors radiation exposure for all reactor workers, both permanent and temporary, should be established.
- A residual radiation level of 10 millirem above background annual full body dose at plant sites released for "unrestricted" use should be established.
- Utility rate stockholders should be held responsible under state law for decommissioning and dismantling costs not collected from ratepayers during the operating life of the plant.
Adopted by the Board of Directors, November 15, 1986