Related Policies
APHA policy statement 57-03: Radiologic health programs1
APHA policy statement 56-04: Protection from radiologic hazards2
APHA policy statement 58-11: Responsibility for protection against radioactive substances3
APHA policy statement 78-45: The public health impact of energy policy4
APHA policy statement 79-09: Nuclear power5
APHA policy statement 2004-06: Affirming the necessity of a secure, sustainable,
and health-protective energy policy6
APHA policy statement 99-11: Declare proposed national permanent nuclear waste repository site unsafe7
Since 1956, the American Public Health Association (APHA) has demonstrated commitment to “improve the health of the public and achieve equity in health status” by acknowledging the health concerns caused by nuclear power production and nuclear waste management and disposal.
Early on, the organization led efforts to monitor radiation hazards, develop radiologic health programs, and train health professionals in the field of nuclear energy.1–3 With regard to energy policy, APHA has promoted the development of nonnuclear, renewable energy sources.4 In 1979, APHA recognized that nuclear energy production could be accompanied by incidents resulting in adverse effects on the health of nuclear power plant workers and the surrounding communities. As a result, APHA supported the moratorium on construction of nuclear power facilities until standards and practices could be reviewed and licensed, a safe working environment was ensured, and the problem of waste disposal had been rectified.5 APHA also recognizes that nuclear power is one of the nation’s most significant sources of energy and that it creates unresolved environmental and security vulnerabilities in the disposal of spent fuel and the threat of vehicle crashes, terrorist attempts, and other acts of sabotage.6
In 1999, APHA declared Yucca Mountain an unsafe national repository for spent nuclear fuel (SNF).7 APHA also noted that the transportation of SNF and other high-level nuclear waste (HLNW) to an interim storage facility or the permanent repository would affect 43 states, putting at least 50 million people at risk as a result of the proposed transportation routes and toxic nature of SNF. Further, APHA recognized vehicle crashes as an inevitable risk of transportation, and, as a result, APHA recognized the need to explore alternative ways for managing and disposing of SNF.
APHA endorses the Precautionary Principle, recognizing that public health decisions must often be made in the absence of scientific certainty and with imperfect information.8 The Precautionary Principle recognizes that cause-and-effect relationships may be difficult to establish, especially when there may be latent periods before health impacts are realized, as is the case with cancers and other health effects of SNF and hazardous waste exposure. This principle should be followed to protect vulnerable populations.Although previous policy statements serve as guiding precedents for advocacy on issues related to SNF and other HLNW, the association currently lacks a comprehensive position on the intrastate and interstate transport of SNF. In light of the ongoing deliberations of the Blue Ribbon Commission on America’s Nuclear Future,9 and as a response to calls for increased reliance on nuclear energy,10 it is an opportune time for APHA to adopt a position that ensures a public health perspective is considered in these discussions. The position outlined here builds on the history of APHA’s involvement in the nuclear waste and energy policy to—
- Eliminate transport of spent nuclear fuel as much as possible,
- Minimize transport of spent nuclear fuel, and
- Ensure safe transport of spent nuclear fuel when necessary.
Problem Statement and Evidence
The transportation of spent nuclear fuel from nuclear reactors, a toxic stew of radioactive materials, unnecessarily increases the risk of a public health catastrophe.
Spent Nuclear Fuel: A Primer
What Is Spent Nuclear Fuel (SNF)?
SNF is a “back-end” byproduct of commercial nuclear energy generation, defense plutonium production, and research activities that use nuclear reactors or fission product nuclides. HLNW are distinguished from SNF by a specific association with historic nuclear weapons production. HLNW resulting from weapons production are typically stored at government facilities, whereas US policy is to transport nuclear power–related SNF from production and storage locations to a permanent disposal site.11 Because of its larger quantity and higher frequency, the scope of this position paper is limited to intrastate and interstate transport of SNF.
Where Is SNF produced?
SNF in the United States is produced and stored at both commercial power plants and government sites. The 104 commercially operated nuclear plants in the United States produce nearly 2,000 metric tons of spent fuel every year.12 Although 72 reactors store the waste products on site, others ship their SNF to other reactors, often owned by the same utility, to shared storage space.13 Some SNF may be shipped to research facilities. Between 1998 and 2004, nearly 370 shipments of commercial SNF were generated throughout the United States. The creation of a national repository would drastically increase the number of shipments moving throughout the United States, because all of the nation’s SNF would be transported to this permanent site.
Why Is Storage Needed?
The Atomic Energy Act of 1954 ushered in the age of commercial nuclear power reactors. In the 30 years after the act, more than 100 power reactors were licensed in the United States. It was anticipated that the nuclear power industry would work in a “closed fuel cycle” in which SNF would be reprocessed to recover usable contents for fresh reactor fuel and other radionuclides for industry, medicine, and research. Commercial facilities for reprocessing of SNF were constructed and operated for a short time in the late 1960s and early 1970s. Then, in 1977, President Carter ended the practice of reprocessing of commercial spent fuel because of proliferation concerns. President Reagan reversed this policy decision in 1981, but no reprocessing plants were ever constructed, largely because of economic barriers and public opposition.
As a result, the US practice has been to dispose of rather than recycle SNF. The Nuclear Waste Policy Act of 1982 “establishes both the federal government’s responsibility to provide a place for the permanent disposal of high-level radioactive waste and spent nuclear fuel, and the generators’ responsibility to bear the costs of permanent disposal.” Since 1982, utility fees and interest have credited the federal Nuclear Waste Fund with more than $30 billion toward the cost of permanent disposal. More than $7 billion from the fund have been spent assessing and preparing for a repository at Yucca Mountain, leaving approximately $23 billion in the fund today.14,15 The government’s failure to begin permanent disposal of SNF in 1998 has led to $565 million in settlements payments to utilities as of 2009, and the US Department of Energy (DOE) estimates it may result in $12.3 billion more in liabilities by 2020 and $500 million per year after that, pending the outcome of litigation.14 A plan for a permanent repository has been in the works since the 1950s; however, since the Obama administration’s rejection of the Yucca Mountain site in 2009, the imperative for SNF storage remains urgent.
A Risk In Motion: How Transporting SNF Poses a Threat to Public Health
Health Effects of Radiation
Human exposure to radiation is a serious health concern. Transportation of SNF and HLNW presents the possibility of increased ionizing radiation exposures, which could result in adverse health outcomes. Ionizing radiation is produced by both humanmade and naturally occurring radioactive materials.16 In the United States, the National Academy of Science estimated nearly 80% of typical human exposure comes from natural background radiation, whereas the rest arises from humanmade sources.16 Subgroups of the population may be at risk of having higher levels of radiation exposure (e.g., people who work around radioactive materials). When transporting nuclear waste, the level of exposure to workers depends on the structure and engineering of transportation packages (containers) to protect them from the harmful release of radiation and radioactive material.12 The level of exposure to people who live or work along shipping routes if an accident or terrorist event occurs will depend on the type of material released, its movement through the environment, and its proximity to people.
Health effects caused by radiation exposure are broadly divided into 2 categories: stochastic and nonstochastic. Stochastic health effects are associated with “long-term, low-level (chronic) exposure to radiation.”17 The primary stochastic health effect from radiation exposure is cancer. The probability of developing a cancer because of radiation exposure increases as the dose increases.21 The cancers that have been most strongly and consistently associated with increased radiation exposure through rigorous epidemiological research are leukemia (except chronic lymphocytic leukemia or CLL), thyroid, and breast cancer. Others that have been linked with radiation exposure include skin, esophagus, liver, colon, brain, oral cavity, lung, stomach, ovary, and bladder.18 In addition, gall bladder, rectum, prostate, pancreas, kidney, and uterine cancers are all suspected to be associated with increased radiation exposure.18
Nonstochastic effects occur when people are exposed to “high levels of radiation, and become more severe as the exposure increases.”17 Studies show exposure to high doses of radiation can cause immediate or near-term death as well as acute health symptoms such as epilation, vomiting, fatigue, fever, diarrhea, petechiae of the skin, gastointestinal bleeding, and other oropharyngeal symptoms.19,20 High-dose exposure has also been associated with long-term health effects, including leukemia and other forms of cancer, stroke, thyroid diseases, chronic liver diseases, uterine myoma, heart disease, hypertension, hypercholesterolemia, and changes in immunity and inflammation.18 High-dose radiation exposure also may have implications for subsequent generations. Children of women who experience radiation exposure while pregnant are at higher risk for heart disease, stroke, and mental retardation.16
Thus, radiation exposure of any level should be regarded as potentially harmful, and efforts must be made to minimize the emission of radioactivity to protect the safety and health of the public.
SNF Transportation Risk Analyses
Transportation of SNF poses health and environmental risks through both the hazardous nature of transportation methods and the radioactive characteristics of the cargo.28 Risks posed by increased levels of air pollution from vehicular emissions or collision-related injuries are examples of vehicle-related risks. Cargo-related risks are related to the characteristics of SNF and fall into 3 broad categories:
- The risk of a crash involving a truck or train carrying SNF
- The longer term health risks to workers or residents along transportation routes related to cumulative exposure from shipments
- The risks of potential terrorist attacks on transport casks with SNF, a high-energy explosive material
Risks related to vehicle crashes of truck or rail result in the potential for release and dispersal of radioactive materials via environmental pathways and subsequent human exposure through contaminated ground, contaminated air, or ingestion of contaminated food or water.
During routine transportation of SNF casks, the various groups that could have increased risk of latent cancer caused by radiation include the safety inspectors and security escorts along the truck or rail routes, the drivers or conductors of the modes carrying SNF, service station attendants who interact with the cargo during transport, and the commercial and residential communities along transportation routes.23 Beyond environmental risks, the transportation of SNF poses economic and social risks. Economic risks include the direct economic impact of SNF transportation routes on people and communities and the perception-based impact of these routes on socioeconomic well-being. Finally, both positive and negative social risks arise from the collective processes—such as risk communication, assessment, and decision-making processes for SNF transport—that influence people’s interactions and perceptions.12 The political nature of nuclear energy and the environmental cleanup of nuclear sites have resulted in a public dialogue on issues regarding nuclear wastes. The presence or absence of certain stakeholders has the potential to facilitate or impede the public health goal of safely addressing the transportation and general issues of radioactive waste.
Increasing Demands for SNF Transport
Transportation of SNF in the United States has tapered off since it began in the 1960s, but it is expected to increase if a national repository for HLNW is established. Between 1964 and 2004, the United States transported approximately 3,056 metric tons of commercial SNF, whereas consolidation in a federal repository could require transportation of up to 70,000 metric tons over the course of 2 decades.12 This increase in volume suggests that previous experience is too minimal to serve as a basis for conjecture of future risk.
In addition to exponential increases in the amounts of SNF transported within and between states after the opening of the national repository, new policy directions suggest an increasing reliance on nuclear energy. In February 2010, President Obama announced conditional commitments for $8.3 billion to construct and operate 2 new nuclear reactors in Burke, Georgia.24 As nuclear energy sources increase in the United States, so will the amounts of SNF eventually needing transport for long-term storage.
Finally, in May 2010 the American Power Act was introduced to the US Congress.10 The American Power Act calls for significant increases in nuclear energy development as a means to generate nonfossil energy, yet it contains no provisions for addressing the resultant problem of such increases—how to transport and store the SNF. This policy shift is silent on the health and safety issues of the intrastate and interstate transport of SNF.
Options to Protect Public Health From Radiation Hazards
Challenge #1: Eliminate Transport of Nuclear Waste
By creating an energy system around renewable, nonnuclear sources, the United States can both commit to environmental stewardship and reduce public health risks from storing and transporting SNF. The most precautionary action is to shift reliance to alternative, nonnuclear sources of energy such as wind, solar, and biomass.
The public health risks and high cost of nuclear power plants is evidenced in historical events. After the partial meltdown at Three Mile Island’s nuclear energy plant in 1979, the general public became concerned with the fear of a nuclear accident, high start-up and production costs, and safe nuclear waste disposal issues.25 As a result, nuclear power plant production drastically decreased; all of the new nuclear power stations ordered between 1974 and 1978 were cancelled, and no new orders were placed.25 The 1986 Chernobyl accident added to concerns that a total release could emit hazardous radioactive material, which would result in death, and was shown to be associated with high incidence rates of cancer.
With the heightened alarm about global warming, however, processes that create electricity without producing carbon emissions have become increasingly attractive to solve our energy needs efficiently. This has resulted in steps toward a nuclear renaissance, because nuclear power has the potential to increase energy production while not producing greenhouse gasses. Although reducing greenhouse gas emissions is important, increasing nuclear power plant production is not the safest or most efficient way to solve our energy needs.
Principal Strategy: Increase the use of and reliance on energy sources that are healthy, safe, and clean. Instead of increasing the amount of SNF through continued and expanded use of nuclear power, we should seek ways to limit the amount of SNF we produce, store, and transport. Proponents tout nuclear power as a clean alternative to fossil fuels and, although nuclear power may be cleaner than fossil fuels with regard to carbon emissions and coal ash production, it poses health risks that are potentially far worse, especially for the next generation.
Nuclear energy from 104 nuclear power plants currently produces nearly 20% of the electricity generated in the United States, and the nation’s future energy demands could lead to an increase of as much as a 40% by 2030.26 Power plants, however, have long lead up times, and the energy created by new power plants will not be available as early as needed. At least 1,900 reactors would need to be created over the next 45 years to replace coal plants with the goal of returning our greenhouse gas emissions to Year 2000 levels.27 This process would be costly; the Federal Energy Regulatory Commission estimated in 2008 that a new nuclear power reactor could cost up to $7.5 billion. Delays and cost overruns could further increase the costs.
The United States has the ability to use renewable energy as a replacement for nuclear power and other nonrenewable sources. Current US policy affords fossil fuels—oil, coal, and natural gas—twice the amount of subsidies from the government compared with renewable, nonnuclear sources.28 Replacing reliance on nonrenewable energy begins with providing equal or greater subsidies to clean energy to develop the necessary technologies; such commitment should not be delayed.
Increasing the capacity and availability of renewed energy and reducing energy consumption can offset the lost energy production caused by nuclear phase out. By 2030, wind energy alone could produce 20% of the country’s energy.29 The Western Governors Association estimated, “from Texas to Washington State, potential wind resources could support 250,000 MW at competitive prices, equivalent to the energy output of more than 60 nuclear reactors.”30p115 Building the capacity for solar power can also help offset the energy needs of the nation. A 100-mi2 area of solar thermal power cells (an area the size of 9% of Nevada) could produce enough electricity to power the entire United States.31 Investment in biomass (using methane from food and animal waste) development could produce enough energy to support 10% of the transportation energy consumed by 2020.
Two additional benefits of not relying on nuclear power are the reduction in financial liability to the US government for any nuclear accident (including vehicle crashes involving nuclear cargo) and the reduced likelihood of terrorist attack on nuclear facilities. Under the Price-Anderson Act, the US government agrees to indemnify any nuclear industry liability greater than $10 billion. Decreased reliance on nuclear power plants would reduce the financial exposure of the United States. Finally, since the terrorist attacks of September 11, 2001, there is concern that operational nuclear power plants may be potential terror targets. Phasing out nuclear plants would remove the threat of terrorism, as well as reduce the potential impact of natural disaster on nuclear plants and storage sites. Eliminating these risks will not only protect public health but also eliminate the expense of protecting the plants from terrorist attack or disaster.
Moreover, Americans need to be encouraged to reduce energy consumption, which will reduce the need for unhealthy energy sources. Some studies show the possibility of a cost-efficient reduction of the United States’ energy consumption by 25% to 30% over the next 20 to 25 years. By using clean energy sources and reducing consumption, we can reduce our reliance on nuclear power, subsequently eliminating the public health risks associated with SNF transportation.30
Challenge 2: Minimize Transport of Nuclear Waste
As of 2007, 54,000 tons of SNF sits waiting for disposal at both operating and decommissioned nuclear sites across the country. A national nuclear waste repository was expected to open in 2017 at Yucca Mountain—a site that was designated as the sole repository candidate in 1987. However, in March 2009, President Obama suspended funding for the Yucca Mountain site. On February 1, 2010, President Obama sent a budget proposal to Congress confirming the end to more than 20 years of the site’s research and development. In the 2010 budget, the Yucca site was declared “not a workable option,” and all funding for the project was eliminated.32 President Obama’s pronouncement fulfills recommendations put forth in a 1999 APHA Policy Statement, which called on the US Secretary of Energy to “declare the Yucca Mountain site unsuitable for development of a nuclear repository now or in the future, [and] terminate all work at the site.”7
In January 2010, President Obama requested a Blue Ribbon Commission on America’s Nuclear Future to provide advice and recommendations regarding the backend of the nuclear fuel cycle, including alternatives for storing, processing, and disposing of SNF and HLNW and the collection and use of fees in the Nuclear Waste Fund. The commission must analyze the “scientific, environmental, budgetary, financial, and management issues, among others, surrounding each alternative it considers.” It is required to produce an interim report by July 2011 and a final report by January 2012.9
Reaching a conclusion on the final storage site for SNF could take decades. In the meantime, SNF will continue to accumulate at nuclear sites across the nation. The question of what to do with SNF in the meantime, an issue that has been discussed among the nuclear science community for the last decade, is more pertinent than ever. Three options exist:
- Allow nuclear reactors to continue to maintain and expand on-site storage to delay the transport of SNF until the completion of a national repository.
- Establish a consolidated interim storage site to which SNF would be transported from sites across the country.
- Discontinue, at least in the short term, the generation of nuclear waste that must be stored or transported.
Principal Strategy 1: Endorse on-site storage as the responsible option in the absence of a national waste repository at Yucca Mountain. The Nuclear Regulatory Commission (NRC) concluded that existing quantities of SNF would be safe in storage at reactor sites, in cooling pools and dry casks, for at least 100 years without a significant environmental impact.33 On-site storage would even allow for further radioactive decay of SNF.34 Therefore, by keeping waste on site in lieu of at a national repository, the risk of exposure during transport is delayed and possibly reduced. Maintaining on-site storage of SNF also continues to put pressure on the federal government to establish a viable permanent site for a repository.
Opponents of on-site storage claim that it hinders the growth of nuclear power, because reactor sites will have to consider the feasibility of continuing to store old SNF while producing new waste. Utility companies do not have indefinite responsibility for storing SNF and DOE will have to continue to compensate them for storing the waste according to liabilities under judgments and settlements related to the Nuclear Waste Act of 1982. Without a permanent site for SNF, local opposition to reactors may increase as communities learn that waste may remain in their proximity indefinitely.
Given that “there is sufficient space at all nuclear reactors to accommodate all SNF for the duration of the plant licenses,”35 the government should not waste the time or money it would take to select and construct a temporary site. Federal efforts should focus on establishing a permanent site for SNF so that waste can eventually be relocated to a safe and secure site.
Principal Strategy 2: Reject consolidated interim storage of SNF by federal, state, and local authorities on the grounds of posing an unnecessary risk to public health. The idea of designating an interim site for storing SNF has been discussed since the late 1980s. In 1989, the Monitored Retrievable Storage Commission recommended 2 interim site ideas to Congress. A federal emergency storage facility would have served as an emergency backup site for nuclear reactors, capable of storing up to 2,000 metric tons of SNF. A user-funded storage facility would have stored up to 5,000 metric tons of waste, primarily from decommissioned reactors. Neither recommendation, each of which would have cost several hundred million dollars to complete, was pursued. Since then, SNF waste has proliferated beyond what such sites could have accommodated.
Another option sought to establish an interim site close to the designated permanent repository. However, the case of Yucca Mountain shows us that the United States may not designate a final site for SNF for several more decades. Private facilities have also been explored as an option. Private Fuel Storage, a consortium of utility companies, began working in 1997 to establish a private interim site on the Skull Valley Band of Goshutes Indian reservation. This project was halted in 2006 because of public opposition.36
The risks associated with this option may have a more significant human and environmental cost.37 Opponents worry that a central interim site will take resources and attention away from the creation of a national repository. The fear that a temporary site may end up becoming a permanent SNF waste site appears especially valid given the recent abandonment of Yucca Mountain. This option would also open the door to increased transportation risks, because SNF would need to be moved from its current location at reactors to the temporary interim site and then again to a permanent location. The option would allow for additional on-site storage, allowing the waste to decay and decreasing the risk of handling it when transporting it to a permanent repository. Alternatively, storage systems may degrade over time, possibly resulting in increased risk to the safety and security of HLNW.38 Especially given the increased fear and attention to risks of sabotage since the terrorist attacks of September 11, 2001, it remains uncertain that current SNF transport containers are capable of withstanding attack from armor-piercing weapons.
The benefit of transporting waste is not worth the risk that could be incurred by moving waste twice, and APHA recommends that reactors continue to establish protocols for safe on-site storage of SNF.
Challenge 3: Ensure safe transport of nuclear waste.
Transport of SNF is an inevitable reality and will continue for the foreseeable future, consistent with current regulatory policies. Transport of spent nuclear fuel is subject to strict regulations set forth by the US Department of Transportation (DOT) and NRC. Although DOT is primarily responsible for regulating the safe transport of radioactive waste, NRC sets regulatory standards for the design, performance, and security of transportation casks.39
Under these regulations, contractors are often used to transport spent nuclear fuel in 1 of 2 ways: trucks and rail. To ensure maximum safety, SNF is shipped in specially engineered casks, designed to prevent release of radioactive chemicals into the environment under both normal and vehicle crash conditions. These casks must demonstrate their ability to contain harmful release of radioactive material to be certified by NRC. The casks must withstand a sequence of tests: a 9-m free fall to an unyielding surface, puncture test (1-m free fall onto a steel rod 15 cm in diameter), all-engulfing fire of 800ºC, and 8-hr immersion under 3 ft of water.39 Besides meeting the safety regulations on the casks, carriers involved in spent fuel transport must—41
- Take only preapproved routes
- Be accompanied by armed escorts for shipments going through densely populated areas
- Coordinate communications with law enforcement agencies before and during shipments
- Provide notification in advance to NRC and states through which shipments pass
In addition to regulating design, performance, and security of transportation casks, DOT is responsible for route selection and notification as well as driving qualification/training, required equipment, inspections, labeling, emergency planning, emergency response, and security.42
With regard to SNF, the “federal government will work with states and tribes before shipments of spent nuclear fuel begin.”43 For example, for highway shipments, each state’s governor has the ability to name his or her preferred routes for use. This and similar interactions ensure all routes meet the regulatory requirements set for safe and secure transport of spent nuclear fuel.43 By contrast, private carriers are allowed to select the shipping routes for highway shipments of most other hazardous materials as long as they are in accordance with regulations. Routes are typically selected to minimize risk with consideration of factors such as distance of shipment, vehicle crash rates, time in transit, population density, time of day, and day of the week.43
Since the early 1960s, thousands of shipments of commercially generated SNF have been transported throughout the United States. Fortunately, no catastrophic incidents of radiological releases to the environment or harm to the public have taken place. Shipments, however, will increase drastically once a federal repository is established, begging the question of whether the shipment of waste can continue to be safe and secure. In addition, until such a permanent waste storage site can be found, transport of waste between commercial sites may continue, and it should be done in the safest way possible.
Although some of the current practices for route selection have been found adequate and reasonable, there is reason for concern about the route selection process and the minimal stakeholder engagement throughout the route selection process.12 Many decision makers and stakeholders are concerned with policy regarding transportation of SNF. Stakeholders exist both within the national context and among the international community.44 DOE, NRC, and DOT all significantly contribute to the decision making and implementation of spent nuclear fuel transportation.45,46 Other important stakeholders are communities and local governments along transportation corridors, as well as tribal nations.
Tribal nations have been disproportionately affected by the production of nuclear weapons and energy, as well as the environmental damage from such production.47 The Western Shoshone Nation in Nevada was particularly affected by the siting of Yucca Mountain when the chosen transportation corridor for the repository was entirely within their land claims from the Ruby Valley Treaty (18 Stat. 689). Since the 1940s The Yakama Nation in Washington State has been denied its treaty rights to use historical grounds at the Hanford Nuclear Reservation in the “usual and accustomed” manners guaranteed in the Treaty of 1855 (12 Stat. 951). These examples illustrate why tribal nations continue to express specific concern with regard to DOE’s failure to formally recognize affected tribe status and provide financial and technical assistance to help tribes partake in risk analysis and stakeholder discussions, as well as concern about the representation of the religious and cultural values in impact assessments and decisions regarding sites.
Transport of SNF is anticipated only to increase. There are, however, strategies to reduce the risk of this transport to public health.
Principal Strategy 1. Minimize risks to public health through use of the safest mode possible. One of the key concerns regarding SNF transportation is the mode of transport and the selection of routes. Stakeholders and other interested groups have raised concerns over whether the practices used are always the safest and whether they take into account the welfare of communities through which the waste travels.
Over the past decades, the majority of shipments of commercially generated SNF have been made by truck.12 Comparison between truck and rail modes of transport, however, conclusively finds rail to be the safer mode of transport.12 Endorsing mostly rail transport along with designated rail cars for SNF cargo is the best possible method for reducing the risk from transport. Rail with dedicated trains has been found to reduce the total number of shipments,12 generally has a greater distance from other vehicular traffic or people along transportation routes, and offers clear operational advantages, which makes control of transportation activities more efficient.12
Where truck transport continues despite acknowledgment of mostly rail as the safest mode, truck routes should be diversified. Current truck transport prefers the use of interstate highways and urban bypass loops (when available) to minimize the total distance or time traveled. Various experts have voiced alarm, however, that this preference leads to waste moving through dense urban areas.48 Environmental justice is also a concern, because the burden on minorities increases disproportionately with increased urban travel.48
Analysis of the potential risk reduction from variations on regulated truck routes is inconclusive. Studies have shown both rerouting options that decrease risk as well as rerouting option that increase risk.48,49 Yet diversifying routes can address the social justice issues of static routes, redistributing the burden on minority and vulnerable populations.48,50
Overall, more research is needed to determine the best possible ways to reduce the public health risk of transportation of SNF through diversification of transportation routes.
Principal Strategy 2: Promote the genuine and holistic engagement of stakeholders throughout the decision-making process for the necessary transport of spent nuclear fuel. Although many key stakeholders and multiple overlapping interests challenge the current system for managing the transport of SNF, DOE has vacillated in its approach to stakeholder engagement. In the 1990s, site-specific advisory boards for federal nuclear sites were established,51 and open dialogue between federal-level decision makers and public interests grew. As the political leadership changed, however, so did priorities at DOE. Throughout the start of the 21st century, leadership returned to a “decide, announce, defend” strategy for stakeholder engagement, common through the Cold War. These oscillations have undermined progress in stakeholder engagement and DOE’s openness initiative regarding declassification of information.52
As a solution to problematic and time-consuming state-by-state DOE negotiations throughout the early 2000s, the chairs of the 9 site-specific advisory boards presented a letter to DOE in 2004 asking to be reengaged in a national dialogue and suggested a National Stakeholder Forum to develop “technically sound, fiscally responsible, politically acceptable, sustainable, and comprehensive solutions to DOE’s system-wide waste and material disposition challenges.”53 The letter urged a discussion including elected officials, regulators, tribal governments, and other stakeholders. DOE declined the request. No federal, systemwide advisory committees give comment and advice on the intrastate and interstate transport of spent nuclear fuel or other radioactive wastes. Engaging these voices would increase the safety of necessary SNF transport.
Actions
APHA believes that transportation of spent nuclear fuel poses a national public health threat that is largely preventable. Accordingly, APHA—
- Calls on Congress to address the public health and safety concerns of intrastate and interstate transport of SNF as they consider increased funding for the development of nuclear energy.
- Calls on Congress to provide greater subsidies for renewable, nonnuclear energy sources than nuclear or fossil fuel.
- Encourages Congress, the Centers for Disease Control and Prevention, and the public health community to recognize energy consumption as a major public health concern and advocate reducing the nation’s energy consumption.
- Expresses serious concern about the production of nuclear waste that must be stored or transported and the research and development of new nuclear technologies.
- Calls on Congress to apply precautionary measures to reduce radiation risks and other hazards and to ensure the safety of proximate communities and to the workforce responsible for transportation and other related activities.
- Calls on Congress, DOE, and the public health community to oppose any efforts to construct a consolidated interim site for SNF and instead focus on a permanent long-term storage site.
- Calls on Congress to financially support safe on-site storage of SNF at its source until permanent disposal options have been designated and completed.
- Urges Congress and DOE to perform full-scale testing of SNF transport casks—including use of modeling and scenario testing.
- Calls on Congress and DOE to increase federal guidelines that standardize the structural integrity of trucks and rail cars transporting SNF so that in the event of a crash the vehicle structures also protect the radioactive cargo.
- Urges Congress and DOE to support more research on the best possible ways to reduce the public health risk of transportation of SNF through diversification of transportation routes.
- Urges DOE to involve state, tribal, and local authorities in every step of the process to identify the safest possible transportation routes and modes for any future federal repositories, ensuring that dedicated rail routing receives priority attention; that the fewest people are exposed, especially considering vulnerable populations; and that stakeholder participation extends through the process of constructing any new infrastructure.
- Encourages DOE to propose primary and secondary routes for current commercial SNF transport needs to states and tribes for review and public comment and to mandate the use of identified routes by private contractors.
- Urges DOE to form a National Stakeholder Forum regarding intrastate and interstate radioactive waste transport, governed by the Federal Advisory Committee Act.
- Urges DOE and DOT to provide technical assistance for and to build capacity of local governments, key community stakeholders, and tribes to understand and partake in risk assessments and emergency preparedness planning for spent nuclear fuel transport. DOE should be responsible for training, preparedness, and response costs.
- Supports DOE’s stated policy of notifying all communities through which spent nuclear fuel will be transported, on rail or road, and provision of tracking and accompaniment at an equal standard.
References
- American Public Health Association. APHA policy statement 57-03: Radiologic health programs. Washington, DC: American Public Health Association; 1957. Available at: www.apha.org/advocacy/policy/policysearch/default.htm?id=385. Accessed November 10, 2009.
- American Public Health Association. APHA policy statement 56-04: Protection from radiologic hazards. Washington, DC: American Public Health Association; 1956. Available at: www.apha.org/advocacy/policy/policysearch/default.htm?id=375. Accessed November 10, 2009.
- American Public Health Association. APHA policy statement 58-11: Responsibility for protection against radioactive substances. Washington, DC: American Public Health Association; 1958. Available at: www.apha.org/advocacy/policy/policysearch/default.htm?id=411. Accessed November 10, 2009.
- American Public Health Association. APHA policy statement 78-45: The public health impact of energy policy. Washington, DC: American Public Health Association; 1978. Available at: www.apha.org/advocacy/policy/policysearch/default.htm?id=922. Accessed November 10, 2009.
- American Public Health Association. APHA policy statement 79-09: Nuclear power. Washington, DC: American Public Health Association; 1979. Available at: www.apha.org/advocacy/policy/policysearch/default.htm?id=931. Accessed November 10, 2009.
- American Public Health Association. APHA policy statement 2004-06: Affirming the necessity of a secure, sustainable, and health-protective energy policy. Washington, DC: American Public Health Association; 2004. Available at: www.apha.org/advocacy/policy/policysearch/default.htm?id=1289. Accessed November 8, 2009.
- American Public Health Association. APHA policy statement 99-11: Declare proposed national permanent nuclear waste repository site unsafe. Washington, DC: American Public Health Association; 1999. Available at: www.apha.org/advocacy/policy/policysearch/default.htm?id=182. Accessed November 10, 2009.
- American Public Health Association. APHA policy statement 2000-11: The precautionary principle and children’s health page. Washington, DC: American Public Health Association; 2000. Available at: www.apha.org/advocacy/policy/policysearch/default.htm?id=216. Accessed November 10, 2009.
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