Matter, life and mind: some very personal opinions on the Asse mine

Rainer Gellerman (NCC GmbH) presented.

In 2016, the German Commission on Radiological Protection (SSK) adopted recommendations concerning radiation protection during the decommissioning of the Asse II mine. First of these recommendations provides that the three principles of radiation protection (justification,

optimization, and limitation of radiation exposures) can be respected and that these principles are

adequately respected. Some aspects that are necessary for understanding the assessments of SSK are described in the following.

Salt mining took place at the Asse mine between 1909 and 1964. From 1965, radioactive waste disposal occurred with operations continuing until 1978. During this time, 125,000 drums of LLW were disposed of at a depth of 750 m below surface and 1,300 drums of ILW were disposed of at a depth of 511 m below surface. The disposals were “for research”. Different disposal technologies were applied, including upright and horizontal piled up disposal. The waste inventory was only roughly documented. Since 1988, several m³ of water per day has flowed into the mine and the state of the mine is now regarded as ‘decrepit’.

The Asse mine was selected for research around radioactive waste disposal due to its immediate availability rather than any advantageous properties in terms of safety. The legal status of the mine was that of a mine and was, therefore, regulated according to Mining Law, but the research was done in an irreversible way so it was effectively disposal of radioactive waste. Some 20 years following the first emplacement of waste, attempts were made to try and prove the long-term safety of the mine. The instability of the rock was, however, a big issue and decommissioning of the mine was declared necessary latest in 2016.

From the early times of radioactive waste disposal in Asse II this has been criticized by local citizens and the media have helped to propagate the fear of radiation among the public. In 2008, citizen movements compelled regulatory action and the Atomic Energy Act was amended such that the Nuclear Law now applied to the Asse II mine. It was set down that all costs of future

decommissioning would have to be funded by the state (i.e. taxpayers) and the Federal Office for Radiation Protection (BfS) was charged with the operation of the mine beginning in January 2009.

Due to this political decision^, the status of the mine was suddenly not according to the legal requirements defined by the Nuclear Law. In order to find out how the decommissioning of the mine has to be done feasibility studies were commissioned by BfS with three options being considered:

 Complete backfilling of the mine;

 Internal relocation; or

 Retrieval of waste.

The conclusion of the authors of the study regarding backfilling was that the mine would be long-term safe if proper backfilling were carried out. But the safety assessment that this decision was based upon was rather uncertain and the understanding of the behavior of the system was not robust. Nonetheless, the study stated that if the safety assessment was improved, backfilling remained an option that could be recommended for further consideration.

Summarizing the results of the three feasibility studies the final judgement of BfS was, that based on the present state of knowledge, the best option would be to retrieve the waste from the mine due to the impossibility of proving long-term safety. But because no final repository for the retrieved waste was available the option was explained with a fictional disposal site that will meet the requirements. When BfS issued its final recommendations in January 2010 it declared that further investigations of the facts were needed and, in parallel, technical measures to stabilize the mine rock were to be continued with works progressing over the next 7 to 8 years. However, in February 2013, the Atomic Energy Act was amended again to require the decommissioning of the Asse II mine after retrieval of waste. This law sets – for avoiding doses of future generations in the order of 0.3 mSv per year- a very strong legal obligation for waste retrieval and opens the

possibility that authorities will increase the accidental planning dose criteria to a higher level than the current 50 mSv due to accidental risks identified in the feasibility studies of about 100 mSv.

Moreover, in the parliamentary debate of this law the fundamental radiation protection principles, in particular justification and optimisation have explicitly declared to be not to apply for

cancellation of the retrieval process.

The whole process that emphasises the protection of people against very low doses as its primary goal but pass in silent much higher risks in case of accident and has no sound solution for a long-term safe disposal of the retrieved waste can therefore be considered as an example of ‘security theatre’, a term created following the events of 9/11 (Figure 4-13).

FIGURE 4-13.WIKIPEDIA DEFINITION OF ‘SECURITY THEATRE’, HTTPS://EN.WIKIPEDIA.ORG/WIKI/SECURITY_THEATER. Personal views expressed were that the emplacement of large amounts of radioactive waste in the Asse mine was never a research project and consequently was never justified. Rather, the mine was intended for the development and demonstration of safe radioactive waste disposal in salt rock, in particular in Gorleben salt dome. With the political declaration that the Gorleben salt dome is unsuitable for a final repository due to the unsafe geology, the “decrepit” Asse mine could not be declared safe for radioactive waste to be left in place. The real reason for retrieval of waste is therefore considered to stem from the parties declaring the mine unsafe need to ensure they are not proved wrong; if waste remained in the mine and no contamination of groundwater or exposure of future generations occurred.

From a scientific point of view, it has to ask for the rationale that resulted in such a contradictory situation. This leads to another important aspect, the power of emotions related to radioactive waste in a political framework. Due to the complexity of problems that are considered on the scientific level of radioactive waste disposal political and societal views tend to be more influenced by emotional rather than rational views and the problem of safe disposal of radioactive waste is superimposed by other themes of highr priority (Figure 4-14).

FIGURE 4-14.VIEWS AROUND THE DIFFERENT PERSPECTIVES INVOLVED WHEN CONSIDERING RADIOACTIVE WASTE. However, the radioactive waste cannot be made to disappear and the case of Asse mine

demonstrates that decisions must be made on where and how retrieved wastes will be disposed of.

In order to avaoid any short-term need for decision the political wisdom is therefore that stakeholders have to be involved for reaching the best solution.

In summary it was concluded that the Asse II mine was and remains an interesting example of the views of society toward radioactive waste. It demonstrates the power of emotions and the limits of radiation protection. It is an outstanding example of ‘security theatre’ with respect to radioactive waste and demonstrates the meaninglessness of radiation protection principles in politics.

Nevertheless, radiation protection experts should accept their role with modesty but trust in the power of scientific truths.

4.9 The importance of ichthyofauna of radioactively-contaminated reservoirs