By Marcos Buser, André Lambert and Walter Wildi
From the sectoral plan to site selection
According to the conceptual part of the “Deep Geological Repository” sectoral plan (2008, revised on 30 November 2011, Figure 6, see also Figure 1 below), Switzerland’s waste management programme is currently in stage 3, which comprises the “site selection and general licence (Rahmenbewilligung) procedure” (“2.5 – 4.5 years”), which includes, in accordance with the Swiss Federal Nuclear Energy Act, “preparation and submission of the general licence application” and “review and licensing procedure”.
The SFOE internet site (Swiss Federal Office of Energy, consulted on 17 March 2020) specifies the tasks of the waste producers in stage 3 as follows: “Deep drilling, preparation of general licence application, identification of sites, granting of general licence, November 2018 to the end of 2029”. The next stage of the procedure is: “Approval of the Federal Council’s decision of the general licence by the parliament and possible subsequent referendum, from early 2030 to the end of 2031”.
Nagra, the Swiss radioactive waste managing company, intends to implement this timetable as follows: “Nagra will carry out an in-depth investigation of the three remaining siting regions Jura East, North Lägern and Zurich Northeast, and then compare them with each other again. The investigation programme comprises the seismic surveys already carried out, as well as quarterly surveys and deep drilling. The deep boreholes are intended to complete the overall geological picture of the geological underground in the siting areas. On the basis of the results of these investigations and the safety comparison of the siting areas, Nagra will announce the site or sites for which it intends to prepare general licence applications by around 2022. Nagra will then prepare the applications, which are expected to be submitted in 2024.”
On the basis of the results of the ongoing investigations, Nagra therefore believes that it will be able to propose one or two sites (a combined storage facility, or a storage facility for high-level waste and a second storage facility for low and intermediate level L / ILW) by around 2022. The form this proposal will be submitted is not specified. The SFOE refers to the general licence procedure in response to the request by the Pro Bözberg association to the “Technical Forum on Safety” (Question 147). Nagra states more precisely: “The “selection of sites for the preparation of the general licence application” is to be understood as a declaration of intent by Nagra as to the site or sites for which it intends to submit a general licence application, and ensures that neither the authorities nor the public are surprised by the choice made in the application. Nagra intends to publish a short report explaining the reasons for the “Selection of sites for the preparation of the general licence application”. The SFOE adds “that by the end of 2019, Nagra must set out in a concept which reference reports will be completed and ready for publication at what time”. This concept is not yet available by mid-March 2020. In addition, there is no longer any mention of the above-mentioned “safety comparison of siting regions” as a fundamental basis for site selection. Surely it cannot be that the public is not to be informed about this central analysis!
Figure 1: Excerpt from the Deep Geological Repository sectoral plan (Fig. 6) for stage 3. This 2011-version is not available in English.
A risky procedure
From the above, it can be concluded that Nagra will be able to publish a “short report” in two to three years’ time – without any official requirement specifying the content! The Federal Council’s licence, if any, should be available in 2029, and a popular vote could be held in 2031.
This timetable means in fact that the site(s) for the deep geological repository(s) will be designated by Nagra in 2022, and due to the long time required until a definitive assessment is made by the safety authorities, it would be virtually impossible to change it, even in the case of serious deficiencies. The Swiss Federal Nuclear Safety Inspectorate (ENSI) is expected to approve Nagra’s proposal in the foreseeable future, and the Federal Council will do likewise in 2029, so Nagra’s “brief report” will present the final result of the site selection process in just two years. And in this way it wants to create a fait accompli in a surprise coup!
With this procedure, there is a risk that Nagra’s results and the conclusions drawn from them with regard to the storage sites and the technical concepts for the realisation of the repository will only be seriously discussed in the context of the referendum on the general licence application in just over 10 years’ time. The risk that the people will reject Nagra’s application is high in this case, as the history of the Wellenberg project has shown in 2002.
It must be concluded from this analysis that the procedure was not properly thought through at the time the Sectoral Plan for Deep Geological Repositories was formulated, or was deliberately not formulated in the sense of a realistic approach.
A look back to Absurdistan
At the beginning of 2020, Nagra is still (and probably for some time to come) “drilling”, although in 2 years’ time it intends to set the absolutely most decisive course in its history! This is reminiscent of Asterix’ comic “Mission Cleopatra”, where the architect “Numérobis” is working under time pressure to create skewed structures that are always on the verge of collapsing. After all, how on earth is Nagra to accomplish the feat of conscientiously evaluating and interpreting the exploration results in just 24 months and presenting them in a credible manner in a comprehensive geosynthesis that stands up to scrutiny? Especially as this synthesis must primarily serve as a solid basis for the subsequent safety comparison in order to anchor the “site selection” in a storm-proof manner! For this purpose, the cooperative once “only” needed four years for the proof of disposal (Entsorgungsnachweis 2002).
Were Nagra’s geologists any dumber back then? Perhaps they were. After all, supervision and expert commissions put a stop to Nagra’s absurd idea of using the already mentioned historic proof of disposal feasibility (Entsorgungsnachweis) as a sham for the current site selection.
Situation of the disposal site cantons and regions
Detailed reports on the results of the ongoing deep drilling are still pending, and not even a geological synthesis of the three regions investigated is available as an indispensable basis for their safety comparison. Nevertheless, it is already foreseeable today that, on the basis of a rigorous analysis, none of the three siting regions studied (Jura East = Bözberg, North Lägern, Zurich Northeast = Zürcher Weinland) will meet all the siting criteria defined in the Sectoral Plan (Appendix 1) and specified by ENSI (2018). Exclusion criteria such as the resource conflicts in the case of Bözberg, North Lägern and to some extent Zurich Northeast, the reduced thickness of the inclusion-effective host rocks in part of North Lägern, or the risk of glacier erosion in the Zürcher Weinland (etc.) cannot be conjured away even by additional investigations. And so, a scenario for the general licence application is emerging, the contours of which already appear quite clear:
– On the one hand, advocates of granting a general licence (Rahmenbewilligung) will point out the absolute necessity of a domestic solution for nuclear waste disposal and accept Nagra’s proposals in spite of all loopholes and safety concerns.
– On the other hand, critics will point out that under no circumstances can a rigged selection procedure be accepted in which the hollow phrase “safety has top priority”, repeated like a prayer wheel from all sides, is left behind. Moreover, gaps in research must be closed and deficits must be eliminated in the development of the storage concept or project, in waste conditioning and in the retrievability of waste before the general licence is granted and not only at the time of the construction permit.
The fronts of the discussion on the application for a general licence for one or two deep geological repositories have thus already been largely defined. But what exactly does this mean for the siting cantons, siting communes and regions? What position can and should they adopt, knowing that they can only play a decisive role in the decision once, namely during the vote on the general licence?
For the cantons, namely Aargau and Zurich, the situation is complex: they have the largest stakes in nuclear power plants, and they are potential siting cantons for deep geological repositories. They have a therefore double responsibility in this process.
The situation is somewhat simpler for the municipalities and regions: They are potentially affected above all by the consequences of the site selection process, and therefore have every interest in ensuring that only a sufficiently long-term solution is sought. For them, however, other questions also arise, such as:
– Which organisation will build and operate the repository after the possible acceptance of the general licence application?
– Who will supervise the phases of repository realisation (construction, operation, closure) in terms of safety?
– What participation and co-decision will be accorded to the municipalities and the region during all these phases?
All these questions are already being asked today and are seeking answers within the framework of a public discussion.
Footnotes and references
 BFE 2008 (Revision vom 30. November 2011): Sachplan geologische Tiefenlager, Konzeptteil. Bundesamt für Energie, Bern.
 ENSI 2018 : Präzisierungen der sicherheitstechnischen Vorgaben für Etappe 3 des
Sachplans geologische Tiefenlager. ENSI 33/649.
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