I feel I need to comment on the article in the November 2001 issue of NEI: “A deontological solution to the waste problem.” This article provided an interesting discussion of fundamental ethical principles which – to a non-expert in this field like myself – seemed reasonably well argued and competent.

Unfortunately, the ethical arguments were then applied to the topic of high-level nuclear waste management – an area in which I can claim to have some expertise. The article uses a series of absurd assumptions to develop some very silly proposals. Not wishing to throw out the baby with the bathwater, I can accept that there are reasonable arguments to consider alternatives to standard repository concepts – they just don’t appear in this article.

Before starting an analysis of alternatives to deep geological disposal, it is important to note the characteristics which have led this to be chosen as the solution of choice by all advanced nuclear programmes. These include, but are not limited to:

• Extremely high levels of safety. (These are already far beyond those considered for other wastes.)

• Any expected releases occur only in the very distant future (after hundreds of thousands or millions of years; finding a cure for cancer over the next century in no way helps us assess the radio-sensitivity of any exposed creatures at this time).

• Expected releases are orders of magnitude below natural radiation background: it is thus very debatable if anything can be said about “lives saved” or lost as a consequence.

• A deep repository is extremely insensitive to natural or anthropogenic perturbations of the surface environment.

• A sealed repository requires no institutional control or monitoring.

How does this compare with the “monitorable, retrievable surface storage (MRSS)”? The MRSS has a design life of 2000 years and, even though unlikely catastrophic failure due to nuclear war or asteroid strike is noted, it is concluded that for the resultant “small population eking out an existence at survival level…the hazard presented by high-level waste would appear trivial”. What about all the much more likely events which could compromise the MRSS – economic collapse, conventional or limited nuclear war, earthquake, mega-tsunami, terrorist attack with a couple of jumbo jets? A look at world history over the last 50 years indicates just how difficult it is to preclude any one (or even a sequence) of these events. For a few years during a crisis, the fate of the MRSS may be of little interest, but thereafter the consequences of a severely damaged facility could be truly horrific. If there is one thing that has been learned from major cases of environmental pollution it is that it is much cheaper in the long run to make sure that such pollution cannot occur than to attempt to remediate it afterwards.

From the technical point of view, the much greater vulnerability (and consequences of failure) of a surface facility compared to a deep repository is the main stumbling block of this concept. In practical terms, however, the political and socio-economic assumptions behind the staged development of the MRSS are even more dubious. For example:

• Enormously expensive reprocessing is continued even in the absence of a nuclear power programme, based on the assumption that need for separated plutonium 50 years later is “likely”.

• Separation of plutonium “could simplify the management of high-level waste, as the half-lives of nearly all the other isotopes present in the waste would be much less than that of plutonium”. Apart from being technically nonsensical (Pu is never the key safety-relevant element in HLW), this implies that there should be no barrier to vitrified HLW disposal – which is in marked contrast to slow progress in countries disposing of such waste (e.g. F, CH, J) compared to those disposing of spent fuel (SF, S, USA)!

• Storage of accumulated plutonium should “avoid the possibility” of material being acquired by terrorists: a very big assumption over periods of many decades!

• Non-plutonium bearing HLW would be an unattractive target for terrorists. This is assuming that they don’t want to cause a lot of local contamination (blow-up the HLW store) or use the waste in a “dirty bomb” (wrap HLW in lots of conventional explosives and take in a truck/ship to the target of choice).

• The longevity of the MRSS is supported by ancient Egyptian and Roman buildings. Note the counter arguments:

1) only a few such buildings exist, most have been destroyed;

2) the ones that are left are generally in a very bad state and have repeatedly been broken into by tomb robbers and archaeologists;

3) these buildings needed no active control/cooling/drainage;

4) they are generally in more benign climates than found in the UK.

Finally, arguments are made that money saved could save lives in the developing countries. Although certainly true, this is probably the most naïve assumption in the entire article. Lives could be saved much more easily by moving funding from the arms industry into health and education – but this ain’t likely to happen in the foreseeable future either! In conclusion, ethical arguments are important if high-level waste is to be managed in a manner acceptable to the general public. In order to derive alternatives to geological disposal, however, ethical considerations must be supported by technical understanding of the key aspects involved and an awareness of the political and socio-political constraints found in the real world.