Timothy J. Maloney 4210 Little Streams Trail Lambertville, MI 48144 March 4, 2013 Michael Brune Director, Sierra Club 85 Second Street San Francisco, CA 94105 Dear Mr. Brune, Congratulations on your principled act of civil disobedience on February 13. The rally /march on Sunday was emotionally invigorating. But let us not overlook the fact that it required a specific hateful project, the Keystone pipeline, to arouse such interest. In the absence of such a specific motivating cause we have no chance of conveying to the American people the extreme danger posed by fossil fuels to earth's ecosystem. The Sierra Club's strategy of promoting wind and solar energy, based on appeals to our rational long-term interest, cannot possibly succeed in affecting the American lifestyle. The only way to budge citizens' attitudes about energy is to provide a fossil-fuel replacement that is equally reliable and less expensive. It must be less expensive in current accounting, not just long-term. I urge the Sierra Club to cease its opposition to Generation-4 nuclear technology, specifically Liquid Fuel Thorium Reactors - LFTR. It is the only current technology that can satisfy the public's demand for 99.9% reliability (less than one-half day per year of electric power outage), and low price. If Milton Friedman is correct that when a crisis occurs people pick up whatever ideas are lying around, then it is imperative that the LFTR idea be perfected and in place before the crisis. It would be a pity if the only post-crisis idea lying around were WWS interconnected by an undependable "smart" grid, and relying on Natural Gas Combustion Turbines for backup since it is patently unrealistic to expect WWS to store its own energy for more than a few hours. WWS would not be low-price, it would not be sufficiently reliable, and it would not even eliminate CO2 from electric generation. Toward prompting a change in Club policy, I undertake below to rebut the Sierra Club's specific objections to molten salt reactors. Sincerely, Timothy J. Maloney, Ph.D. Sierra Club Wilderness Guardian 734 856 7345 t.maloney@bex.net www.timothymaloney.net Sierra Club objections to Molten Salt (Thorium) Reactors March 25 2013 see page 9 for cover letter; see pages 7 and 8 for official Sierra Club policy 1. Thorium fuel cycle is highly dependent on fossil fuels for mining, shipping and processing. Mining leaves tailing and radioactive dust. Rebut: Very little Thorium needs to be mined because it all gets fissioned, and it all is the useful isotope, Th-232. In both respects this is unlike the Uranium problem. It will require only one beach-ball of Thorium to operate a 1000-Megawatt electric plant for one year. Because so little Thorium is needed for fuel, the mining effort required is about one two-hundredth (1 / 200) the amount for the equivalent amount of Uranium fuel. The preparatory processing of Thorium is simple and not fuel-intensive because there is no need to separate one isotope from another (such as U235 from U238). Earth's Thorium is all Th232. Our current stockpiled inventory of Thorium metal, an unused byproduct from the mining of rare-earth metals, is about 3200 tonnes. This stockpile would be sufficient to energize the US electric grid for about 7 years, all by itself, before we needed to mine even one additional gram of Thorium. The manufacture of solar PV cells requires mining for rare-earth elements, especially Indium and Gallium, besides the usual culprits - Copper and its Arsenic by-product. The mining footprint of Thorium must be set against the mining footprint for these solar elements. The same footprint issue applies to wind-energy turbines, which use permanent magnets containing Neodymium, Nd, another rare-earth element. Not to mention the large amount of steel in the support tower and concrete in the foundation pad. 2. Thorium must be kick-started with weapons-grade material. Rebut: It doesn't need to be weapons-grade (U235 > 20%). Low Enriched Uranium - LEU - will suffice. But if weapons-grade fissile material is used, so much the better, because that eliminates proliferable material. This is our motive for purchasing decommissioned Russian weapons material and blending it into our LWR fuel. What are we going to do with all the bomb-grade material that has already been created? Estimated world plutonium stocks: Weapons: ~ 200 tonnes + Reactor Waste: ~ 800 tonnes = Total Plutonium made by humans: ~ 1000 tonnes There is no way to get rid of this plutonium, other than by fissioning it. Pu doesn't occur in nature and doesn't participate in biochemical reaction or degradation. If we don't subject it to fission, it will remain on earth for a long time. (HL = 24,000 years) As start-up fuel for LFTR it is eliminated from the earth. Also, the world has several hundred thousand tonnes of spent Uranium fuel, of which about 1% is U235. Thus we have several thousand tonnes of U235 with no convenient place to put it for long-term. It also can be eliminated, consumed as start-up fuel for LFTR. 3. The use of Thorium does not solve the radioactive waste issue. Rebut: It certainly does solve the radioactive waste issue, for three reasons: 1. The amount of waste [fission products (medium-size atoms) and actinides (large atoms)] is tremendously smaller, in mass and volume, than for a solid-fuel Uranium reactor. For a 1000-Megawatt LFTR plant operating for one year, the FP waste will be about 0.7 tonne and the actinide waste is virtually zero. Compare that to 35 tonnes of spent UO2 fuel plus its zirconium fuel-rods. Thus, LFTR waste has only 2% as much mass and a correspondingly small volume. This is a consequence of all the fuel being eventually fissioned ("burned"), unlike solid-fuel Uranium LWR technology in which only about 3% of the Uranium fuel is actually fissioned. The remaining 97% of the uranium is not fissioned because the entrapped UO2 pellets become so contaminated with medium-weight FPs that the reactivity of the fuel deteriorates to the point that it cannot support a chain-reaction. 2. The spectrum of fission products from Thorium - LFTR - is approximately the same as that for solid Uranium - LWR. But a LFTR's FPs do not accumulate inside a fuel-rod in their unstable-isotope states. They are continuously recirculated in the fuel-loop where the short-lived isotopes (HL < 150 years) contribute their radio-decay heat to the reactor core's useful thermal output. Some FPs, those that have application for radiation medicine (thorium-229, molybdenum-99) or metallurgical use in magnets (non-radioactive neodymium), can be continuously extracted by chemical processing. Of the 0.7 tonne (700 kg) of FP annual production, only about 17% (120 kg) is long-lived (HL > 150 years). Those isotopes cannot contribute much to the core's thermal output because they so seldom undergo a decay event. Therefore they will be continuously removed from the fuel by chemical processes; there's nothing nuclear about it. It will not be difficult to vitrify the 120 kg for safe permanent storage, either on-site or at a central facility. The volume of the vitrified material will be only about 2 m3 (picture a cube, 4 feet on a side). The other 83% (580 kg) has HL < 150 years. Even if the 580 kg of short-lived FPs were to be chemically removed from the fuel liquid, it would decay to a safe* level of radio-intensity in about 10 years. It would occupy a volume of only 0.1 m3, unvitrified. (picture a cube, 17 inches on a side) *equal to that of naturally-occurring uranium ore Contrast these masses and volumes with the amount of coal ash for 1000 MW-yr of electric energy: approximately 600 tonnes; volume 500,000 m3. By mass, coal-ash (which is itself slightly radioactive and chemically dangerous because of its mercury content) is greater by almost a million to one . 3. The waste from the Thorium fission process contains virtually zero large atoms - less than 1 kilogram. Of that, only about 100 grams (4 ounces, or one teaspoon**) is Plutonium, and even that is a harmless (not weapons-useable) isotope. That teaspoon of Pu can be recycled back into the liquid fuel to be fissioned, or it can be stored with the other 900 grams of heavy elements - actinides. **Pu density = 20 g / cm3 4. If irradiated fuel is not reprocessed, Th-232 is long-lived and its decay products build up in used fuel. Rebut: The irradiated fuel is reprocessed, continually. Short-lived fission products recirculate in the fuel loop until their radioactive isotopes decay into stable atoms. Long-lived FPs can be continually removed by standard chemical engineering processes utilizing differences of vaporization temperature, bubbling with helium gas, etc. Furthermore, Th-232 has such a long half-life because it very rarely has a natural decay event. So fission product occurrence by natural (as opposed to chain reaction-induced) thorium decay is a non-issue. Also, mining of any mineral brings some thorium to the surface since it is abundant in earth's crust. For example, neodymium for use in wind-turbine /generators is commonly found with thorium ore. Gathering thorium from resulting mine-tailings for use in LFTR consolidates the dispersed material into a controlled setting. 5. and 7. The MSR experiment at Oak Ridge was only experimental, and there are still unanswered questions about large-scale development of MSRs. Development of large-scale MSRs will have to be underwritten by taxpayer subsidies and insured by government underwriting. This diverts money from other technologies and takes many years. Rebut: It is true that the MSR at ORNL was experimental. The experiment was a complete success. The reactor functioned for more than 20,000 hours over a 4-year period; it was shut down and restarted almost nightly, and much useful experience was gained. Of course LFTR development will require government subsidy and underwriting - all grand projects that change human society's relations to the world require such governmental intervention. This was true for the Lewis & Clark exploration of 1804, to the transcontinental railroad project of 1863, to the Apollo moon project, to the Internet. Furthermore, the financing and insurance costs of a LFTR development program, though counted as part of the "levelized" cost of the energy, are essentially just artifacts of a financialized social economy. They are not part of the tangible resource requirements and actual construction costs of the technology. Only tangible resources and construction effort are relevant for assessing society's ultimate cost for energy. Regarding preservation of earth's ecosphere, financing and insurance issues don't matter in the long run they will fall away. Concerning time requirements, American physicists and engineers believe that 25 years for commercial implementation is feasible. In 2011 the Chinese Academy of Sciences announced that their Shanghai Institute of Applied Physics is beginning work on an MSR. Their timetable envisions an operating research reactor in 7 years, scaling up over 10 years to commercial production by year 2030. Their annual research budget was originally stated as $70 M. In 2012 they announced a budget increase but declined to state an exact amount. Thus the Sierra Club estimate that Thorium MSRs are billions of dollars and decades away is not wrong, if decades is taken to mean 17-25 years What else should we expect for a complete solution to the energy needs of industrial civilization? The 2012 study by National Renewable Energy Laboratory - NREL - envisions scaling up WWS and doubling America's transmission capacity by year 2050, a longer time frame than the LFTR schedule. 6. Other Club concerns: a) Beryllium is toxic and must be kept isolated from workers and environment. Rebut: The beryllium is in the fluoride molecule, BeF2 , which is chemically inert. Even elemental beryllium is less toxic than arsenic, which is used in manufacture of PV panels. Likewise for cadmium. Moreover, manufacture of integrated circuits requires worker protection and containment of many toxic substances, including arsenic. LFTR's liquid fuel containing beryllium fluoride must be safely contained within its plumbing, certainly. This is not a difficult challenge since all LFTR plumbing operates at near atmospheric pressure, lower than our household drinking water. b) High gamma-radiation during start-up requires effective containment and shielding. Rebut: Of course plant personnel must be shielded by steel / concrete barriers. But the material emitting the gamma-rays is a liquid; it cannot vaporize into a gas to contaminate the air that personnel breath, nor can it throw off solid particulates into the air. The liquid fuel will just freeze en masse if it cools below 500 deg C. c) Waste is still highly radioactive, and some of its components are soluble in water (danger to surface and underground water supplies). Rebut: Yes, but there's so little of it (see rebuttal of Objection No. 3) that it is easily managed. For short half-life FPs, storage is in a stainless-steel welded cylinder. For long half-life FPs, it's in a vitrified glass block impervious to water. d) Tritium is produced. Rebut: A 1000-MWe LFTR produces only about 150 grams of tritium per year, which is inexpensively removed by bubbling helium and normal hydrogen through the fuel stream. The 12.5-year half-life tritium can be stored on-site as tritiated water. It emits only beta radiation, the easiest of the three to shield, and decays to 95% stable (non-radiating) hydrogen in 54 years. e) and f) Used fuel disposal danger. Rebut: There is no "used" fuel in an operating LFTR. Fuel is essentially recycled forever. Even when a LFTR plant is decommissioned at the end of its 50-year working life, its liquid fuel can just be loaded into a new LFTR. g) Costs are likely to be high, the same as for Uranium LWR. Rebut: Not true. See rebuttal of Objection No. 8. LFTR has no explosion-proof Reactor Pressure Vessel, no high-pressure plumbing, no emergency cooling equipment, and no cooling tower. 8. LFTR is expensive , and unknown, and must be heavily subsidized. Rebut: LFTR is well known in terms of basic physics principles. It has operated successfully for more than 20,000 hours over a 4-year period, functioning with a daily stop-start cycle. Its chemistry and physics are clearly understood. The only unknown technical hurdles are metallurgical - the specific formulation of metal alloys for core-tubes and pumps . It is not expensive. Informed estimates of construction cost are in the range of $2 per watt, continuous. This is cost-competitive with conventional coal and substantially cheaper than advanced coal (even without Carbon Capture & Sequestration) in terms of plant construction alone. LFTR's fuel costs are so low as to be negligible. [Estimate ~ $250,000 per year for a 1000-MWe facility producing ~ 9 billion kWh annually, with retail value of about $1 Billion. That is, a factor of 0.000 25, or less than one-tenth of one per cent of product value]. So LFTR's total life-cycle costs, even with "levelized" financing and insurance, will absolutely beat coal. If LFTR achieves its projected 1.5 cents per kWh "naked" (considering tangibles only) life-cycle cost, it will even beat conventional hydropower, until now the cheapest generation method in the human repertory. As for government insurance subsidies, of course they are necessary in a forward-looking national energy policy. That's what a useful national policy is supposed to do - support development of technology that leads to a sustainable future. When private insurers realize how inherently safe LFTR is, they will compete among themselves to get the business. 9. and 10. Rapid development of proven clean energy (WWS) and smart grid can meet our energy needs. Baseload plants are not the wave of the future (instead distributed generation is the future ). Germany is converting rapidly and economically to a green-powered society. Rebut: It is not at all clear that distributed variable generation, wind and solar, with sophisticated gridsharing and expanded transmission capacity, can actually work reliably. In order for that plan to work, transmission capacity and regional interconnectedness must be expanded enormously. That would require the assertion of government eminent-domain authority, which is bound to lead to big political / legal disputes that drag on for long periods. Assuming the wind and solar siting and transmission problems can be politically solved, niche on-shore wind might become economically competitive with coal on a strict free-market basis, but niche solar never will be. PV solar is now about 2X the price of advanced coal without CCS, and thermal solar is about 3X. Mass-produced PV cells are approaching their theoretical maximum solar-to-electric conversion efficiencies, and the easy improvements in manufacturing methods have already been realized. The low-hanging fruit has been picked. It's going to get harder from here. Price is not the only consideration. Reliability demands are stringent in modern life. Intermittent renewable sources, WWS, must fall back on 1) Energy storage; or 2) Grid-sharing; or 3) Gas-fired backup turbines. Energy-storage methods: a) Pumped Storage Hydropower - PSH; b) Compressed Air Energy Storage - CAES; c) Concentrated Solar Power - CSP with thermal storage of hot liquid in tanks, and d) Batteries all have very limited time-durations measured in hours, not days***. Therefore distributed generation renewables will never be able to rely solely on their own renewable reserve in storage. If they can't make up their own shortfall by importing from a distant region on the smart grid, distributed renewable installations must then rely on their own dedicated fast-start natural-gas combustion turbines NGCTs. Such turbines should have their construction and fuel costs factored into the levelized costs of nonniche WWS renewables, but this is almost never done when cost comparisons are made. So if renewable WWS is ever to expand beyond its current niche status, it's 2X or 3X cost disadvantage stated above is really even worse than that. Germany is making nice progress, but in 2011 it was still at only 21% renewable energy, and 6% of that came from biomass, environmentally equivalent to burning wood. Only 15% of Germany's energy came from wind and solar. 79% came from coal, Russian gas, and nuclear. As Germany prepares to shut down its nuclear fleet, it is building new coal-burners. Most are being designed to use their domestic lignite (brown) coal, which is the most polluting on earth. Germany is one of the best-organized, most socially cohesive industrialized nations in the world, and it doesn't have long distances to deal with - less than 400 miles in both directions. American transmission planners must use the unit Million Megawatt Mile, MMM, which can be regarded loosely as one thousand miles of transmission line****, while coping with our local prerogatives and resentments. ***The largest PSH facility in the USA, Raccoon Mountain on the Tennessee River near Chattanooga, can operate its generating turbines for just 22 hours. The 2012 study by National Renewable Energy Laboratory projects only an 8-hour average duration for PSH, and only 15 hours for CAES [p. 84]. ****It's the entire output of a big coal-burner or nuke, 1000 MW, carried one thousand miles. Sierra Club ENERGY RESOURCES POLICY Page 22 Adopted by the Sierra Club Board of Directors, September 16, 2006; amended ..... July 25, 2011. Page 19 E. Resources Opposed by the Sierra Club The Sierra Club generally opposes additional development of these resources, and supports phasing out existing uses quickly during the clean energy transition. Sierra Club entities may support public policy proposals that include these resources only if they find that the overall balance of the proposal strongly favors efficiency, renewable energy and greenhouse gas reductions, and that the environmental impacts are insubstantial. The Club will support research designed to minimize the environmental impacts of these technologies if funding is not disproportionate to more promising technologies. Page 20 4. Nuclear Power Plants Nuclear power produces less CO2 than fossil alternatives but more than energy efficiency and most forms of renewable energy on a life cycle basis. But nuclear power is not safe, affordable, or clean with currently available technology and practice. Mining uranium risks workers’ health and creates toxic residues. All current plant designs are complex, prone to accidents and have severe security vulnerabilities. Nuclear waste transportation, storage and disposal problems remain unsolved. The industry is heavily subsidized by public subsidies, incentives and liability shielding everywhere it operates, dependencies that dramatically increased in recent federal legislation. The nuclear fuel cycle increases weapons proliferation and risk among nations and non-state entities. The Sierra Club will continue to oppose nuclear power unless these deficiencies are eliminated. While it is possible that a different approach to nuclear power might substantially address these issues, the likelihood is remote given the decades of research and investment already made. Clean energy resources are sufficient to address climate change and are cheaper than nuclear power. In addition, the huge investment to bring additional nuclear facilities online would siphon capital from much more cost-effective uses of financial resources, especially investments in efficiency. Sierra Club objections to Molten Salt Reactors Sept 2012 1) *** From beginning to end of the nuclear/thorium fuel chain, the whole process is highly dependent on fossil fuels. Thorium must be mined,shipped, processed, etc, much like uranium, and, like uranium, produces radioactive tailings and dust, as well as dangerous radioactive emissions such as Radon 220. All mining operations are highly fossil fuel dependent and very dirty as well. 2) *** Thorium itself is not fissile enough to serve as the sole fuel, and and must indeed be "kick started" by Uranium 235 or Plutonium 239. These two weapons grade materials must be used to keep the chain reaction going until enough of the thorium has fissioned into U-233. The Thorium fuel cycle is not proliferation proof if these two starter materials are needed. In addition, U-233 is just as effective as Plutonium 239 for making bombs. The DOE has concluded that both fuel cycles have "essentially equivalent proliferation risks". [Roald Wigeland et al, "AFCI Options Study", INL, INL/ EXT-10-17639, Sept. 2009]. Sierra Club has been firm in opposition to any energy source that produces and relies on bomb grade materials. 3) *** The use of Thorium does not solve the radioactive waste or byproduct issue. The fission of thorium produces long lived products like Technetium-99 with a half life of over 200,000 years. A range of fission products similar to uranium is produced with the fissioning of Thorium. 4) *** If the irradiated fuel is not reprocessed, Thorium-232 is very long lived, with a half life 1.4 billion years, and its decay products will build up over time in the used fuel. 5) *** The MSR experiment at ORNL was well characterized as experimental, and as such is not ready for "prime time". There are many unanswered questions about the large scale use of a molten salt reactor. 6) *** The Club has these concerns re: a molten salt reactor: a) Beryllium toxicity - the salt mixtures contain high levels of beryllium avery poisonous element. This must be kept isolated from workers and the environment to protect against beryllium poisoning. b) During start up, the fission process in the primary salt will produce a high gamma and neutron radiation field, requiring a highly effective containment. c) The waste is still highly radioactive and some fission products in their fluoride form, such as cesium fluoride, have high solubility in water, making them highly problematic for long term storage d) MSRs produce high amounts of Tritium, a radioactive isotope of hydrogen, which can be difficult and expensive to trap, and a health hazard if released. e) Disposal of the used fuel has proven problematic. f) Stabilization and disposal of the remains of the very small MSRE that operated at Oak Ridge has turned into the most technically challenging cleanup problems ORNL has faced and the site has still not been cleaned up. g) Like Light Water Reactors, costs are likely to be very high. 7) *** Like conventional nuclear reactors, MSRs will rely on massive taxpayer subsidies and government incentives to be built on a commercial scale, the insurance will likely be underwritten by taxpayer dollars, and they will divert money away from cleaner, renewable energy sources of the future. Since this is still considered a new technology, it is likely decades and billions of dollars away from contributing to our energy needs. Prototypes will need to be built and tested, designs revisited and changed,all taking many, many years. 8) *** Why we go down this expensive, unknown, heavily subsidized path when so many safer, affordable, cleaner and sustainable energy sources, readily available in the free market, are ready on a global scale? 9) *** Energy efficiency programs and products, coupled with a smart grid and the rapid development of known proven clean energy sources can meet our needs now and in the future. 10) *** There are numerous roadmaps out there, and more in the works, which predict and prove that more complex, dirty and expensive baseload plants are not the wave of the future, and that like Germany the U.S. can convert rapidly and economically to a green powered society, one not so dependent on non-renewable sources like nuclear, coal, oil and gas. Timothy J. Maloney 4210 Little Streams Trail Lambertville, MI 48144 March 4, 2013 Michael Brune Executive Director, Sierra Club 85 Second Street San Francisco, CA 94105 Dear Mr. Brune, Congratulations on your principled act of civil disobedience on February 13. The rally /march on Sunday was emotionally invigorating. But let us not overlook the fact that it required a specific hateful project, the Keystone pipeline, to arouse such interest. In the absence of such a specific motivating cause we have no chance of conveying to the American people the extreme danger posed by fossil fuels to earth's ecosystem. The Sierra Club's strategy of promoting wind and solar energy, based on appeals to our rational long-term interest, cannot possibly succeed in affecting the American lifestyle. The only way to budge citizens' attitudes about energy is to provide a fossil-fuel replacement that is equally reliable and less expensive. It must be less expensive in current accounting, not just long-term. Therefore I urge the Sierra Club to cease its opposition to Generation-4 nuclear technology, specifically Liquid Fuel Thorium Reactors - LFTR. It is the only current technology that can satisfy the public's demand for 99.9% reliability (less than one-half day per year of electric power outage), and low price. If Milton Friedman is correct that when a crisis occurs people pick up whatever ideas are lying around, then it is imperative that the LFTR idea be perfected and in place before the crisis. It would be a pity if the only post-crisis idea lying around were WWS interconnected by an undependable "smart" grid, and relying on Natural Gas Combustion Turbines for backup since it is patently unrealistic to expect WWS to store its own energy for more than a few hours. WWS would not be low-price, it would not be sufficiently reliable, and it would not even eliminate CO2 from electric generation. Toward prompting a change in Club policy, I undertake below to rebut the Sierra Club's specific objections to molten salt reactors. Sincerely, Timothy J. Maloney, Ph.D. Sierra Club Wilderness Guardian 734 856 7345 t.maloney@bex.net www.timothymaloney.net