Steeves, Keith W.

Date: 2005.08.31st (Wednesday, 4:28 P.M.)


Elizabeth Dowdeswell

President Nuclear Waste Management Organization (NWMO)

49 Jackes Avenue Toronto,

Ontario M4T – 1E2

Tele.: (416) – 934 – 9814

Toll Free: 1- (866) – 249 – 6966

From: Keith W. Steeves


Madam, Subject: Option 5: Extraterrestrial Disposal of Reprocessed Nuclear Fuel Waste Via Solar System Ejection

It was stated in the Assessment Framework (Choosing a Way Forward, Draft Study Report, P.47) that one of the key objectives was determined to be “Adaptability” of the Management Approach, as specified in the quote:

“To ensure a capacity to adapt to changing knowledge and conditions over time.”

With this statement in mind, I offer NWMO Option # 5 as a modification to the recommended Adaptive Phased Management method for nuclear fuel waste. This option is being offered as it is thought to be Safer, Cheaper, and Better.

In terms of ‘Safer’, the reprocessed High – Level Nuclear Fuel Waste would be permanently removed from the Earth’s biosphere forever, and would require no further monitoring.

In terms of being ‘Cheaper’, the following Total Cost estimate for this management approach from a simple rough calculation is estimated to be:

Total Capital Cost C$ 6.2 B Total Operating Cost 5.0 B Total Insurance Cost 1. 6.2 B Total Financing Charge 3.8 B Total Cost2 C$ 21.2 B

1 Insurance cost does not include third party liability. Assumed to be equivalent to Total Capital Cost for illustration purpose. Further analysis of this figure is required. For example, long – term nuclear liability insurance would be greatly reduced

2 Total Cost is in 2005B$ covering a 50 year operating period. This Total Cost covers ARLV operations only. Does not include reprocessing nuclear fuel waste cost at either BNFL’s Sellafield, England facility or COGEMA/Areva’s Le Hague, France facility, and the associated transocean shipping expense in INF3 – type ships. Also, does not include interim storagecosts for both used nuclear fuel waste and reprocessed nuclear fuel stored at nuclear reactor sites.

As for being a ‘Better’ solution, this option would not encounter problems with issues of “Fairness” and “Community Well – Being”. Similarly, it would also greatly reduce conflict over issues involving “Public Health & Safety”, “Worker Health & Safety”, “Security”, “Environment Integrity”, and “Economic Viability”. Furthermore, this option is a better solution as compared to NWMO’s recommended APM approach because Option # 5 would lead to better constructive results by further developing the future business potential of both the Nuclear Industry and the embryonic Space Industry as opposed to the limited APM approach that leads no where in further technological development and progress, and leads only to a dead-end in terms of future business opportunities with no future profit potential to the Nuclear Industry.

At the very least, Option # 5 would be justified on moral grounds since reprocessing is required now because the Benefits that have already been extracted from the used fuel have been accrued to the present generation whereas the Costs of reprocessing will be borne by future generations. This structural arrangement would constitute an irresponsible action by the present generation and will create an intergenerational “Fairness” issue if reprocessing is not carried out by the present generation.

This recommendation of Disposal in Space option is not (and can not be at present technological levels) a panacea for nuclear waste disposal; however, by including this recommendation in the APM recommendation, the whole dynamic of the nuclear waste problem and the discussion changes. With Option # 5, a deep geological disposal system is not needed and the required monetary expenditure for its construction is also not required. Likewise, the Phase 2 demonstration of long – term isolation technology and the construction and operation of an underground research laboratory is not required. Also, the “Transport used fuel to central site in Phase # 3” in the recommended APM programme would become a ‘transport of used fuel for reprocessing’ issue to reprocessing sites in England and France. The reprocessed “resource material” would be returned for interimstorage under either the Option # 2 or 3 method. The inclusion of Option 5 could be thought of as a continuation of this transportation issue in terms of placing High – Level nuclear waste on an infinite voyage without end away from Earth and humanity. Therefore, the inclusion of Option # 5 short circuits the management method and reduces the management oversight to Option # 2 or 3. As for the Advanced Reusable Launch Vehicle (ARLV) needed to carry out this task, the required developmental work activity for an ARLV would take place during the same budgeted APM Phase I stage time span.

In the “Executive Summary” stated in Asking the Right Questions (on page 9) under the question: “Have the appropriate ways to deal with the problem been identified?”, two of the three questions asked were:

“Given limited time and resources, on which technical methods should the NWMO focus?” [underlining emphasis added]


“Is the preliminary depiction of these methods accurate?

In reply to these questions, with regards to the 14 nuclear waste long – term management options cited as being examined in the August 2003 Enviros Consulting report (NWMO Background Papers 6. Technical Methods, 6-5 Range of Potential Options for the Long – Term Management of Used Nuclear Fuel), I must first state that I have not yet seen the cited papers listed in the Reference section. Even so, I can make the following observations and comments. First, it should be noted that this single Enviros Consulting report only contains a total of 25 citations in the Reference section, of which only seven (7) pertain to the ‘Disposal in Space’ option. Second, the assessment of the 14 management options is not original research work, but merely a summarization of these alternatives as to how they would compare to each other under the four selected criteria; namely, Environmental, Technical, Economic, and Social & Ethical for the purpose of categorization and priorization, in order to make an selection decision among these options. In doing so, an automatic bias was established by the constraints imposed by the limited number and range of the selected criteria; e.g., the criteria rejected the possibility of reprocessing of nuclear fuel waste, and only considered ‘packaging’ as a treatment process. I therefore question if this single report is sufficient in making and coming to a major decision about the selections of the most suitable options to be pursued by NWMO. Next, on reading the report’s Section 18 ‘Disposal in Space’ assessment, does this report give an accurate assessment? In my opinion, I would agree with the five references that refer to ‘Disposal in Space’ as being:

“… extremely expensive for large quantities of waste…”


“It has been suggested that the option would be most suitable for small volumes of the most suitable for small volumes of the most toxic waste” [US National Research Council 2001]

However, I would have serious misgivings about the content in the House of Lords Select Committee 1999 and the Wilkinson et al. 2002 publications that the Enviros Consulting report claims the statement:

“…the high radiological consequences of an accident during launching of the space vehicle.” (P.34)

Therefore, I am forced to summarize these comments about the screened options by asking once again the question: “Is this single report a good enough reason to justify making a firm selection decision for the three primary options mandated in the NWMO’s charter?” In my opinion, no it is not. The limited description in “Appendix 9 – Methods Screened Out” in Choosing a Way Forward (PP. 282) supports my claim. To back up my claim, I further offer the following statements as evidence:

1,) Radioisotopes fuels are now being successfully launched into outer space for use as energy supply sources onboard spacecraft.

2.) Option # 5 does not advocate using either the manned U.S. Space Shuttle as has been previously suggested or an unmanned Expendable Launch Vehicle (i.e., rocket) for nuclear waste disposal into outer space. The rule here is do not assume! What would be proposed instead would be an unmanned ARLV.

3.) As a proof – of – concept, I offer the recent successful example of SpaceShipOne launch vehicle. With a modest US$ 20 million private sector financial backing from Microsoft cofounder and business entrepreneur Paul Allen, airplane designer Burt Rutan, president of Scaled Composites, has won the US$ 10 million Ansari X-Prize competition by managing to have SpaceShipOne reach outer space twice within a five day period. Flamboyant British business entrepreneur Sir Richard Branson, president of Virgin Atlantic airlines, is following up this success by actively committing to establishing Virgin Galactic to develop the space tourism market. Even though the ?V (change in velocity) attained by SpaceShipOne is only a fraction of the full ?V requirement needed to achieve completion of an Option # 5 mission, this example shows that a small non – government sponsored private – sector enterprise can successfully conduct space launch activities.

With regards to the lame excuse of “limited time and resource” in compiling the Enviros Consulting report, I am forced to ask: “What funding has gone into researching and developing these alternative 11 options cited in the Enviros Consulting report?” Also, how do these amounts compare to the previous expenditures of over C$ 800 million paid out over the past previous 27 years since the Hare Commission report specified deep geological disposal as the primary method of nuclear waste disposal? (Source: Choosing a Way Forward, P. 133)

Irregardless of the answer to the previous two questions, what is more important to ask now is; “What funding will go into these other alternative options in the future?” Also, “Will” and/or “How” are the doors to be kept open if better solutions are developed from these alternative options in the future? Finally, the most important question would be: “What happens ‘If’ these other alternative options ‘actually do’ turn out to be better than the recommended APM solution given in NWMO’s Final Report to the federal government?” “Will NWMO have to be mandated by the federal government to actively pursue these alternative options?” In closing my assessment of the Choosing a Way Forward document, I recommend to the NWMO that NWMO include the following two conditions in the Final Report:

1.) Leave open the possibility for the inclusion of alternative options even after the federal government’s decision has been decided and released, and

2.) If any future alternative option is found to be safer, cheaper, and better, then the NWMO be instructed to either terminate or modify its APM recommendation.

Due to the commercial nature of this subject topic, all other information relevant to Option # 5 is deemed to be proprietary information and is not for public disclosure. Please note in closing here, the nuclear industry is now divided into two commercial camps: Those that reprocess and those that do not. In my opinion, the side that manages to close the ‘nuclear fuel cycle’ will ultimately win commercially. Guess which side I’m on? If the Joint Waste Owners association find themselves on the wrong side, too bad!


Yours truly,

Keith W. Steeves

Vancouver, B.C.

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