In October 2022, Gov. Glenn Youngkin announced a goal of building a new nuclear reactor in Southwest Virginia within the next 10 years, setting off a flurry of excitement among local economic development officials and outrage among local residents who are concerned about the health and safety risks of nuclear power.

Youngkin was not proposing to build another massive nuclear plant, like Dominion Energy’s 1,800-megawatt North Anna plant in Louisa County, Virginia, but rather to seek to become a leader in developing a new generation of relatively small nuclear plants called small modular reactors or SMRs. These reactors range from 25 to 300 megawatts in size (less than a third the size of a traditional nuclear reactor), and are modular, meaning they can be mostly assembled in a factory to reduce costs.

Little is actually known yet about the cost, performance and safety of this new generation of nuclear power because there are currently only six SMRs that are operating or under construction worldwide, with another 65 more in various stages of planning and design. SMR advocates claim that the technology will have major benefits over traditional nuclear power plants by reducing the cost, time and space needed for construction and that they will be far safer designs than traditional plants.

Of course, the cost and safety claims of SMR advocates have not been proven yet, but the Youngkin administration and some local economic development officials seem prepared to take the nuclear industry’s claims at face value and are jumping on board the governor’s plan to promote SMR development in Southwest Virginia. In April of this year, the LENOWISCO Planning District Commission in Southwest Virginia went so far as to release a feasibility study of SMR development in the region, and proposed seven specific sites where they believe deployment of a nuclear SMR would be safe and viable.

While Appalachian Voices does not oppose research and development of SMRs in general, there is a long history of economic and political leaders in Southwest Virginia prioritizing economic investment and jobs over health and safety concerns — the tens of thousands of acres of barren and blasted landscapes from the legacy of mountaintop removal coal mining in the region are a testament to that history of neglect. So we did a deep dive into the literature about SMRs and reviewed LENOWISCO’s feasibility study in detail to offer our members, supporters and allies some additional perspective on Youngkin’s plans for an SMR in Southwest Virginia and the LENOWISCO planning district’s recommendations for suitable sites.

After reviewing the feasibility study, we do not believe nuclear SMR development should occur on any of the seven sites proposed by LENOWISCO because they are all in or adjacent to previously mined areas, with a risk of undocumented mine voids and other geologic risks resulting from the legacy of coal mining. Local officials we’ve spoken with are clear that nuclear waste from a Southwest Virginia SMR would be stored on site. In the absence of a permanent, off-site storage facility for nuclear waste in the U.S., it has to be assumed that all radioactive waste generated at SMRs and other nuclear facilities in the U.S. must be stored locally on site in perpetuity. That assumption is simply incompatible with the many risks of subsidence and slope instability that exist at the sites evaluated in the LENOWISCO report.

We are also concerned that LENOWISCO’s study did not include any assessment of local community support or opposition to SMRs in their site evaluations, which ought to be an overriding consideration, particularly in communities that have already long suffered from water and air pollution and other health risks from 100 years of coal mining, logging and other forms of extraction in the region.

Below is a detailed analysis of the LENOWISCO planning district’s SMR feasibility study and additional research on nuclear safety to provide further perspective.

The nuclear waste storage problem

Nuclear energy has significant benefits over fossil fuels because it does not emit carbon dioxide and other air pollutants. That does not, however, mean the technology is pollution free. Nuclear power results in the creation of radioactive wastes such as uranium mill tailings and spent reactor fuel. These materials can remain radioactive and dangerous to human health for thousands of years.

To make matters worse, no sites have been developed in the U.S. for permanent geological storage of the waste stream, meaning most waste has to be stored at the site where it was generated. As two nuclear experts recently wrote in Scientific American:

“About 88,000 metric tons of spent nuclear fuel from commercial reactors remain stranded at reactor sites, and this number is increasing by some 2,000 metric tons each year. These 77 sites are in 35 states and threaten to become de facto permanent disposal facilities. Without a geologic repository, there is no way forward for the final disposal of this highly radioactive material. Storing it in pools and dry casks at reactor sites is a temporary solution; it is safe for decades, but not the millennia needed to isolate this radioactive material from the environment.”

While the current sites where nuclear waste is stored across the U.S. are typically in geologically stable locations that were developed many decades ago and where there is little risk of landslides and subsidence, the recently mined sites in the LENOWISCO report would be far riskier because of the recent history of major disturbance that increase the risks from landslides, floods and undetected mine voids that could cause unexpected subsidence.

In addition, while SMRs are expected to have a number of advantages over conventional light-water reactors, a reduction in the generation of radioactive waste does not appear to be one of them. In fact, according to the author of a recent study on the likely waste generation of several new SMR designs, “Our results show that most small modular reactor designs will actually increase the volume of nuclear waste in need of management and disposal, by factors of 2 to 30 for the reactors in our case study,” despite claims from SMR boosters to the contrary.

Because there are no clear prospects for the development of a long-term, geologic storage facility for nuclear waste in the U.S., any new sites for nuclear generation, even those where next-generation advanced and small modular nuclear reactors are planned, must also be assumed to be sites for permanent storage of hazardous nuclear waste. This fact significantly raises the bar for the safety and community engagement criteria a proposed nuclear site must meet, and we believe it raises the bar higher than any previously mined site or site in close proximity to active surface mining and drilling operations can possibly meet.

Site evaluation criteria

While Appalachian Voices recognizes the limitations of our own expertise (we do not employ any professional engineers on staff), we do not believe Appalachian residents should accept assertions of the stability and safety of mining operations and reclaimed mine sites without abundant evidence and review by impartial experts. From the Buffalo Creek disaster that led to 125 deaths in 1972, to the many smaller-scale disasters of cracked foundations of buildings built on unstable valley fills, the history of the Appalachian coalfields is replete with examples of professional engineers signing off on projects that turned into disasters.

The case of a federal penitentiary that was built on a reclaimed mountaintop removal mine in Martin County, Kentucky, in the late 1990s (just miles from the site of the infamous Martin County slurry spill in 2000) provides an instructive example. According to a story in the New Republic:

“USP Big Sandy was erected on a leveled mountaintop in Martin County, a few miles from the front porch in Inez that Lyndon Johnson visited in 1964, seeking to give a face to his War on Poverty. In the late 1990s, when it was built, Big Sandy was rumored to be the most expensive federal prison ever constructed. It became more expensive when, a year before it opened, one of the 140-foot gun towers started to pitch inward. Perched atop a ‘reclaimed’” strip mine, the $174 million prison was sinking into the blast-softened earth. By 2003, the site had been remediated enough to accept its first batch of prisoners, but locals still call it ‘Sink-sink.’”

Unexpected subsidence in previously mined areas has also created dangerous conditions for Appalachian communities near methane gas pipelines. As a recent Associated Press story detailed:

“In 2009, a Columbia Gas Transmission pipeline broke apart in Pike County, Ky., at a site where the slope of the ground changed over a mine area… Three years before that, another Columbia pipeline ruptured in West Virginia, pulling apart a threaded joint. The cause: ground movement.”

Coal mining companies have long created a strong disincentive for engineers that rely on them for employment to take a critical eye toward the safety and stability of reclaimed mines for post-mining land uses. Our greatest concern is that this long-standing culture of downplaying the stability risks of mined sites in order to facilitate energy project development could lead to catastrophic consequences in the context of a poorly sited nuclear reactor or waste repository.

Community involvement

The community engagement undertaken in the LENOWISCO study falls short of the kind of public involvement necessary for this type of energy project. The initial questionnaire was distributed with short notice to some stakeholders and the low number of respondents cannot accurately reflect the thoughts and concerns of the entire region. Current byproducts of previous energy development projects include acid mine drainage, gob, coal ash and geologic disturbances, all of which have deeply impacted our communities. The storage and containment of the nuclear waste generated by SMRs is an issue that requires extensive community engagement and education, given previous failures to effectively protect residents’ health and the fact that local residents would be living in close proximity to the radioactive waste.

The LENOWISCO report’s authors note that local leaders suggested community benefits, environmental justice, public education and workforce development as topics requiring further investigation. In order for any of those topics to be effectively addressed, local residents and their knowledge of their communities and local dynamics, economic development barriers and current environmental issues must be brought meaningfully into the conversation.

Conclusions

We applaud the leaders of the LENOWISCO planning district for their continued commitment to leverage SWVA’s unique natural and cultural resources to attract emerging industries to the region in order to reverse the economic challenges associated with the decline of the coal industry, and to link the region’s economy to emerging high tech industries and clean energy development.

Unfortunately, we are concerned that the planning district’s recent focus on attracting nuclear SMRs is at best a distraction from building a regional solar industry and innovative mine land reclamation and at worst, risks bringing profound new threats to the physical safety of residents and the long-term economic health of the region.