Consent-Based Siting & DOE’s Request for Information

This is incredible.

During the 2021 American Nuclear Society’s Winter Meeting, they hosted an incredible panel included Kim Petry from the DOE. The discussion focused on nuclear waste and included conversations around consent based siting as a revised solution. Here’s a link outlining the process.

Quick Summary

• Consent-based siting is essentially giving local communities the option to store long lived radionuclides (commonly referred to as spent fuel, nuclear waste, and long half-life isotopes) rather than the government mandating where nuclear waste will be stored.
• The DOE is currently asking the public for input through a Request for Information (RFI), and it’s due by 3/4/2022.
• The RFI is relatively simple. It consists of three topics with four to seven questions per topic.
• Responses can simply be emailed to: consentbasedsiting@hq.doe.gov.
• Resources to get up to speed on the topic are at the bottom of this page.

Based on discussions in my circles, many people are simply ignorant about the realities of nuclear waste, it’s trivial impact, minuscule danger, and microscopic relative mass compared to other forms of energy generation. However, those educated on the matter generally agree: it’s a non-issue, and we need to transform public opinion about it. The lack of a permanent storage facility for spent nuclear fuel is a large black mark on the industry, and I truly believe a consent-based siting approach can be a reasonable and rapid solution to the problem.

It’s important to note the DOE is looking for Botha. deep geologic repository and an interim repository. DOE anticipates an interim storage facility will be necessary prior to moving spent nuclear fuel to a final disposal site, but the duration of time it can or should be there is uncertain. It’s also important to note that the nuclear waste policy act won’t allow DOE to begin construction on an interim storage facility until the Nuclear Regulator Commission grants them the construction authorization for a permanent repository. The only repository currently approved is Yucca Mountain, but DOE is not considering it seriously.

I implore my peers, colleagues, and friends to all submit a response to the DOE. If you feel uneducated about the topic, fear not! I’ve included lots of resources and references below for you to get up to speed quickly.

I also intend to publish my responses to the DOE for others to use and learn from if it’s helpful.

Request for Information

The RFI is broken up into three topics with four to seven questions. They’re opinion based and relatively easy to answer.

1. Consent-Based Siting Process
   1. How should the Department build considerations of social equity and environmental justice into a consent-based siting process?
   2. What role should Tribal, State, and local governments and officials play in determining consent for a community to host a federal interim storage facility?
   3. What benefits or opportunities could encourage local, State, and Tribal governments to consider engaging with the Department as it works to identify federal interim storage sites?
   4. What are barriers or impediments to successful siting of federal interim storage facilities using a consent-based process and how could they be addressed?
   5. How should the Department work with local communities to establish reasonable expectations and plans concerning the duration of storage at federal interim storage facilities?
   6. What organizations or communities should the Department consider partnering with to develop a consent-based approach to siting?
   7. What other issues, including those raised in the Draft Consent-Based Siting Process, should the Department consider in implementing a consent-based siting process?
2. Removing Barriers to Meaningful Participation
   1. What barriers might prevent meaningful participation in a consent-based siting process and how could those barriers be mitigated or removed?
   2. What resources might be needed to ensure potentially interested communities have adequate opportunities for information sharing, expert assistance, and meaningful participation in the consent-based siting process?
   3. How could the Department maximize opportunities for mutual learning and collaboration with potentially interested communities?
   4. How might the Department more effectively engage with local, State, and Tribal governments on consent-based siting of federal interim storage facilities?
   5. What information do communities, governments, or other stakeholders need to engage with the Department on consent-based siting of federal interim storage facilities?
3. Interim Storage as Part of a Waste Management System
   1. How can the Department ensure considerations of social equity and environmental justice are addressed in developing the nation’s waste management system?
   2. What are possible benefits or drawbacks to co-locating multiple facilities within the waste management system or co-locating waste management facilities with manufacturing facilities, research and development infrastructure, or clean energy technologies?
   3. To what extent should development of an interim storage facility relate to progress on establishing a permanent repository?
   4. What other issues should the Department consider in developing a waste management system?

Resources on Spent Nuclear Fuel & Consent-Based Siting

• Reports
  • Fall 2012 report titled Designing a Process for Consent-Based Siting of Used Nuclear Fuel Facilities – Analysis of Public Support (report starts on Page 28).
  • January 2017 DOE report on the consent based siting process.
  • Scholarly articles around consent-based siting. Many of these are behind a paywall, but clicking through the abstracts can quickly give a good overview of the research that’s been done so far.
  • Natural Resource Defense Fund remarkably put together a reasonable report in 2016 outlining recommendations for how DOE can approach a consent-based siting process. They include a history of the Yucca Mountain site (Section III) and five recommendations for DOE (Section IV).
• Webinar
  • Dr. Kathryn Huff, Principal Deputy Assistant Secretary for the Office of Nuclear Energy, explains consent-based siting process and participates in a Q&A with attendees.
• Titans of Nuclear Podcast – by far the best podcast for practical information on all things nuclear. The following episodes highlight something insightful or interesting about nuclear waste. Roy Payne specifically addresses Consent Based Siting in the UK. The rest of the episodes are roughly ordered by most relevant to consent-based siting.
  • Roy Payne, Executive Director, GDF Watch
  • Elizabeth Muller, Co-Founder & CEO, Deep Isolation
  • Andrew Daniels, Author, After Fukushima
  • Per Peterson, Chief Nuclear Officer of Kairos Power
  • Jim Conca, Forbes Writer
  • Rory O’Sullivan, CEO, North America, Moltex Energy
  • Margie Doane, Executive Director, Operations, Nuclear Regulatory Commission
  • Jeremy Renshaw, Program Manager, Used Fuel & High Level Waste, EPRI
  • Neil Alexander, Principal Consultant, Bucephalus Consulting
  • Walter Tromm, Head of Waste Management, Safety, & Radiation Research, Karlsruhe Institute of Technology
  • Mohamed Bourham, Alumni Distinguished Graduate Professor, North Carolina State University
  • Laura Leay, Science Writer
  • Paul Dickman, Senior Policy Fellow, Argonne National Lab
  • Madeleine Archer, Sustainability Lead, Sellafield Ltd.
  • Katy Huff, Assistant Professor, Nuclear Engineering, University of Illinois
  • Jean-Michael Hoorelbeke, Senior Advisor, Foresight, & Strategy