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Proposals to put new nuclear reactors near coal mine sites ignore geological hazards

New Economy Program Manager Robert Kell addresses a town hall event on SMR technology. The town hall was organized and hosted by The Clinch Coalition, the Alliance for Appalachia, the Appalachian Peace Education Center, Southern Appalachian Mountain Stewards, and Virginia Organizing. Photo by Rance Garrison

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.

The LENOWISCO feasibility study examined seven potential sites for small modular nuclear reactors in Southwest Virginia. Click to enlarge. Map by Dominion Engineering, Inc. for LENOWISCO Planning District Commission

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.

The Nuclear Regulatory Commission approved its first SMR design in 2020, shown above in an artist rendering from NuScale Power. The project was canceled in November 2023 amid skyrocketing costs. Photo source: U.S. Department of Energy


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

Residents listen to speakers at the town hall on small nuclear reactors in Norton, Va., on Oct. 25. Photo by Rance Garrison

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.

As Appalachian Voices' Director of Programs, Matt has worked on all aspects of the "coal cycle" — from mining, transportation and combustion to the disposal of power plant waste — and is a nationally recognized authority on mountaintop removal coal mining and coal economics. Matt has testified before Congress and appears frequently on expert panels.


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2 COMMENTS
  1. Rees Shearer says:

    I must take issue with Matt’s point that only historically environmentally exploited communities, particularly, should not be placed at risk with SM[nuclear]Rs for environmental justice reasons (as well as geological ones). We needn’t fall into the “not in my backyard” (NIMBY) camp, stating that risks from SM[n]Rs are not acceptable in our environmentally damaged communities, but implying it’s OK to place them elsewhere. Those elsewhere face many of the same risks, perhaps not geologically unstable land, but risks from: 1) onsite high-level radioactive waste storage “in perpetuity,” 2) nuclear accident or terror incident, 3) unproven “advanced” designs – Governor Youngkin said he want a “new SM[n]R design”, 4) the Governor’s proposal for onsite high-level waste reprocessing, which has never been done at a commercial reactor in the U.S. and would greatly exacerbate accident and terrorism risks, 5) if alternatively, that waste is transported for reprocessing, that significantly ups the risk ante. 

    Let’s avoid shrugging off this threat to our communities onto other communities, wherever they are.

    Appalachian Voices is highly invested in excellent work to promote solar energy on restored mine land and at schools and throughout communities. App Voices’ Solar Working Group, Solar Finance Fund, and New Economy Program also build local skills and jobs. Add an energy storage component and we have reliable energy 24/7.

    I’m confident Matt believes, as most of us reading his blog post agree, addressing climate change is an existential imperative for Americans. I don’t understand why Matt doesn’t advocate for App Voices’ own good work to support renewable energy development, now. Surely the decade-long (and likely longer, if ever) design, licensing and construction delay before SM[n]R power generation might become a reality raise concern. Former Nuclear Regulatory Commission Chairwoman, Dr. Allison MacFarlane, in her July 21, 2023, IAI News article, titled “The end of Oppenheimer’s Energy Dream: Modular Reactors Are Supported by Ideology Alone,” writes: “SMRs are ‘Not likely to help cut emissions. Given the development timelines for these new reactor designs, they are not likely to have a significant impact on CO2 emissions reductions for decades, and as a result their relevance to the climate argument shrinks…[how can nuclear compete] in 20 or 30 years, when renewables will presumably be even cheaper?'”

    Financial resources devoted to SM[n]Rs are lost for renewable technologies and are taxing the Virginians twice – once with federal and state subsidies and then again with enormous costs (such as Matt noted with the recently canceled NuScale SM[n]R) which would be borne by all utility ratepayers – residential, commercial and industrial. On top of everything else, SM[n]Rs promoters should not be allowed a double dip into Virginians’ pockets.

  2. Rick Phelps says:

    Matt’s article presents a reasoned and comprehensive view. I am particularly concerned about the lack of community input opportunity.

    However, I also believe that the well presented distaff comment supporting the SMR program has much validity and merit. Further, it appears that the plan is to BUILD them in the mined areas; not operated them. Of course, there must be some operation as part of the construction but minimal .

    I will also note that heavy energy-using industry such as chemical plants, steel and other raw material processing require vast energy input which solar and wind, even geothermal cannot provide. In fact, the very large Eastman Chemical Company , located close to the SWVA coal fields , has completed a joint feasibility study with ORNL which concluded that a SMNR could easily provide the energy needs of this facility which historically burned 100,000,000 lbs of coal DAILY. Now NG.
    The study did not address permitting of public policy concerns. Eastman is an environmentally sensitive company which has the economic ability to absorb the estimated 3-4 billion cost. Unfortunately, as Matt notes, the entire NETN area is karst terrain with unstable character. The waste would have to be shipped off site. The newest SMR designs are safer and . I think, create inherently less waste. Additionally , increased nuclear waste recycling is possible as shown in the Nuclear Fuel Services facility in nearby Erwin, Tn.

    Thanks to AV for closely monitoring this and advocating strongly for the people of Central Appalachia ! And for clean, green energy. Of all types, as well as maximizing energy conservation.

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