— Briefing Backgrounder —
Toward an Evidence-Based Nuclear Energy Policy: Gaps in Research, Regulation, Policy, and Practice in the U.S. Nuclear Industry, and What Policymakers Can Do to Bridge Them
(PDF)

The Environmental and Energy Study Institute (EESI) held an online briefing on nuclear energy issues, including the current economics of the U.S. nuclear power industry, how to approach decommissioning as more civilian reactors shut down, and what to do with their high-level radioactive waste. In particular, the briefing assessed the impacts of extending the licenses of existing nuclear plants and pursuing “advanced reactors” as a way to fight climate change.

As U.S. nuclear plants age out or become unprofitable, the growing number of shuttered reactors has spawned a new decommissioning business model that promises to remediate sites quickly, but also raises new questions about safety, financial assurance, cleanup standards, and waste disposition. Decommissioning companies want to ship highly radioactive spent fuel through 75 percent of Congressional districts to their proposed consolidated interim storage facilities (CISFs) in New Mexico and Texas, which overburdened residents there oppose. Congress will likely be asked to change basic provisions of the Nuclear Waste Policy Act this year to enable CISFs. Meanwhile, the Nuclear Regulatory Commission is proposing to lengthen the duration of license extensions for operating nuclear plants, potentially allowing them to keep running and generating radioactive waste for more than 80 years.

To help inform major decisions on nuclear energy policy facing Congress, the briefing pointed out gaps in current research and data, federal policy, and regulatory oversight, and what can be done to fill them. It examined how some other countries safeguard their radioactive waste, and offered practical recommendations to help make pending U.S. policy and regulatory decisions about nuclear energy more evidence-based, and better aligned with science and environmental justice.

 

Highlights

 

These highlights include clarifications and added context for clarity that were not originally part of the oral presentations. These additions are enclosed in brackets.

 

 

Introduction by EESI Executive Director Daniel Bresette.

  • Nuclear power inspires passionate reactions from people—some see it as more good than bad, others as a greater source of risks than benefits. In any case, nuclear power will continue to be part of the U.S. energy mix for some time.
  • According to the latest edition of the Sustainable Energy Factbook (see our March 12 briefing), nuclear power contributed 20 percent of U.S. energy generation in 2020, just as it has for the past 10 years.
  • This consistent share of U.S. energy generation could change in the coming years, though, as dozens of nuclear power plants are slated to close in the coming decades, whereas only two are planned for construction. There are discussions about keeping some of those plants online.
  • These imminent closures lead to several questions: What will take the place of nuclear power in the U.S. energy mix? Will it be zero- or low-carbon? And what do we do with decommissioned power plants and their radioactive waste? The answers will have implications for climate change, of course, but also national security, environmental justice, and the long-term safety of affected communities.
  • Some argue that reducing the number of nuclear power plants will make it more difficult to address climate change within an acceptable timeframe. Others point out that the economics of nuclear power make it unsustainable: increasingly competitive renewable energy resources can replace nuclear power while keeping carbon emissions down.
  • One big unknown, and a central topic of this series of briefings over the past three years, involves the fate of high-level nuclear waste, including highly radioactive spent nuclear fuel. Addressing radioactive waste requires a thoughtful, informed policy response.

 

Tim Judson, Executive Director, Nuclear Information and Resource Service

  • Nuclear decommissioning is the dismantling and site remediation process that takes place after a nuclear power plant shuts down. It can take up to 60 years to complete and can cost upwards of $1 billion per reactor. Decommissioning includes radioactive waste management and encompasses a range of issues, including radioactive and toxic cleanup, worker and health safety, economic redevelopment, and environmental justice.
    • The Yankee Rowe nuclear power plant in western Massachusetts began decommissioning in 1990 and completed the process in 2007, yet the site continues to adversely impact surrounding communities.
    • The Energy Solutions Radioactive Waste Dump in Barnwell, South Carolina, is where Yankee Rowe’s waste was deposited. This area is a 47% African American, low-income community and the waste dump site is leaking radioactive material into the local aquifer and water supply.
  • Current regulations around nuclear decommissioning were originally overturned in 1995 with Citizens Awareness Network v. Nuclear Regulatory Commission (NRC). Since then, the ability to establish and enforce regulations on nuclear corporations has been limited, especially given the economic pressures the industry is facing, such as reactor closures, decommissioning fund shortfalls, and corporate liability. The NRC is proposing a rule to further deregulate decommissioning.
  • Communities face challenges when it comes to decommissioning. Decommissioning companies overpromise, saying they can keep costs low and timelines quick while maintaining safety. They also hold out the false prospect of remediating the site to a greenfield standard for unlimited redevelopment. [The value of decommissioning trust funds (DTFs) is significantly lower than projected decommissioning costs. Decommissioning companies use a compartmentalized LLC structure that shelters them from liability if the DTFs are depleted before decommissioning is completed, potentially leaving states and host communities to cope with the risks and costs of a contaminated site.]
  • A new, fast decommissioning approach has recently emerged, in which companies promise to complete the process [in as little as two to five years]. Two decommissioning companies have proposed consolidated interim storage facilities (CISFs), centralized facilities where spent nuclear fuel would be concentrated and stored in shallowly buried casks. Holtec International has proposed a facility in southeastern New Mexico, and Northstar/Orano has proposed one in west Texas.
  • CISFs pose significant risks. The concept entails the dangerous transport of highly irradiated spent fuel from reactors across the country to “temporary” facilities that are located in low-income communities and communities of color already burdened with impacts from the nuclear industry. It therefore violates environmental justice principles.
  • The Department of Energy (DOE) is liable for waste storage costs. [Since a permanent repository for nuclear waste failed to open by a mandated 1996 deadline, nuclear plant licensees can sue DOE to be reimbursed for continuing spent fuel management expenses under the Nuclear Waste Policy Act.] Damage payments have amounted to $300 million per year, presenting a business opportunity for corporations like Holtec and Waste Control Specialists (WCS). Nuclear licensees also routinely obtain exemptions to use decommissioning trust funds to pay themselves for ongoing spent fuel management, which can deplete the funds and risk leaving decommissioning sites in limbo when the funds run out.
  • The Nuclear Information and Resource Service (NIRS) has a series of recommendations to regulate decommissioning, including requiring accountable decommissioning plans, restoring public hearing rights and safeguards, enforcing the National Environmental Policy Act (NEPA), requiring fully adequate decommissioning funding upon closure, prohibiting consolidated interim storage, and paying reactor communities for storing waste as proposed in the STRANDED Act. Environmental justice needs to be the central frame through which decommissioning is regulated.

 

Leona Morgan, Co-founder, Nuclear Issues Study Group; Diné or Navajo community organizer and leading advocate for communities in New Mexico impacted by consolidated interim storage facilities and uranium mining

  • Consolidated interim storage (CIS) is a form of nuclear colonialism, defined as the systematic dispossession of Indigenous lands, exploitation of cultural resources, and subjugation and oppression of Indigenous people to further the production of nuclear energy and weapons. Each stage of nuclear energy production produces waste, which affects Indigenous communities and other communities of color.
  • Nuclear power is not a climate change solution. The GHG emissions of nuclear plants are calculated only in terms of what is directly emitted from plant operations (“smokestack emissions”), discounting other emissions and waste generated across uranium mining and milling, plant construction and decommissioning (“lifecycle emissions”). There are over 15,000 abandoned uranium mines across the United States that are vestiges of the nuclear weapons program. Instead of acknowledging its accountability for these mines, the federal government attempts to find responsible parties to fund patchwork cleanup efforts that are insufficient. These abandoned mines continue to impact Indigenous communities, including the Diné nation and others.
  • Consolidated interim storage sites are currently being proposed by Holtec International and Waste Control Specialists. These two proposals are awaiting final approval from the Nuclear Regulatory Commission within the coming months. Public interest groups have challenged these proposals, asking the permitting process not to be fast-tracked during the pandemic and citing the illegal imminent and substantial endangerment threats posed by consolidated interim storage. Many groups, including Don’t Waste Michigan, the Alliance for Environmental Strategies, the Sierra Club, and Beyond Nuclear, brought a total of 50 contentions objecting to CISF permitting to the NRC’s Atomic Safety and Licensing Board. The board denied every single contention, refusing to consider any.
    • New Mexico and Texas do not consent to hosting these facilities. [In New Mexico, Holtec’s CISF is opposed by Governor Lujan Grisham, the New Mexico State Land Commissioner, the All Pueblo Council of Governors, the Diné Uranium Remediation Advisory Commission, and numerous community, municipal, and county organizations.]
  • Uranium extracted from the western United States has predominantly provided energy benefits to the country's coastal regions. The proposed CIS projects threaten to consolidate nuclear waste storage in parts of the country that experienced little to no benefits from nuclear energy. There has been no established recourse once the waste has been moved to CIS sites, meaning temporary storage could become indefinite and even permanent.
  • Land, water, economic, and cultural resources across New Mexico would be negatively affected by consolidated interim storage sites. [The cumulative impacts of preexisting oil and gas developments, abandoned uranium mines, and above-ground nuclear testing in New Mexico are being ignored in the NRC permitting process.] CISFs violate the principles of consent-based siting and environmental justice.

 

Paul Gunter, Director of the Reactor Oversight Project, Beyond Nuclear

  • The Davis-Besse Nuclear Power Station provides a case study of how regulators oversee and industry manages the effects of aging on the reliability of safety-critical reactor systems, structures and components. [During its initial 40-year operating license, the site’s reactor pressure vessel experienced stress corrosion cracking, a known age-related degradation that went undetected over several refueling cycles despite obvious warning signs.] Both industry and the Nuclear Regulatory Commission (NRC) still lack critical information on how such cracking initiates and grows. They have previously failed to detect and measure the progress of another case of stress corrosion cracking, which resulted in a 2002 near miss nuclear accident.
  • “Age management” is more safety-critical as operating license extensions become longer in duration. NRC has extended the bulk of the nation’s reactor operating licenses from 40 to 60 years. NRC is proceeding with the approval of industry applications for 60- to 80-year extensions while publicly discussing extensions out to 100 years. [Extreme license extension is out of step with the trends, both economic and age-related, responsible for accelerating reactor closures and decommissioning, with 11 units having closed since 2013. Given the failure to produce a “renaissance” in new construction, the nuclear industry is pushing operational extensions as its one apparent bridge to the future.]
  • In response, the NRC contracted the Pacific Northwest National Laboratory (PNNL) to identify and document information and technical "gaps" in the nuclear industry’s age management programs, gaps that would need to be addressed as part of the license extension application review process. [Specifically, the laboratory was to develop criteria, guidance and make recommendations for the “strategic harvesting” of aged materials from decommissioning nuclear power stations for aging analysis. Harvested material samples can be analyzed for the observable and measurable science necessary to understand material degradation mechanisms affecting the reliability and safety of reactor operations projected into the license renewal period.] As tasked, PNNL identified scores of technical knowledge gaps and made recommendations that were published in a December 2017 report.
    • [The PNNL report determined that the license renewal review process for 60- to 80-year extensions would likely require the harvesting of real-world aged materials from decommissioning nuclear power stations for laboratory analysis. The analysis could then be used to benchmark, in real time, degradation mechanisms like the neutron embrittlement of reactor metals, welds and internals.]
    • The PNNL report focused attention on knowledge gaps in license extension regarding the combined effects of extreme heat, humidity, and radiation on other safety-critical systems, such as electrical cable qualification and condition assessment. Similarly, gaps needing strategic harvesting for analysis include alkali-silica reaction-caused and irradiation-assisted degradation in the concrete comprising irreplaceable safety structures like reactor containments.
    • PNNL made two recommendations to address technical knowledge gaps in effective age management programs using scientific evidence on age degradation. Even though the NRC Office of Research’s original contract instructions stated that PNNL “shall” identify technical "gaps," the NRC Materials Licensing Division criticized the report and suggested that references to gaps be “scrubbed” from the entire report. Responding to questioning from Beyond Nuclear in September 2018, the NRC immediately pulled PNNL’s report, which had been public for nine months, from three government websites. The NRC then posted a March 2019 revised report to its website that no longer included text referencing technical knowledge gaps. The NRC further removed PNNL’s recommendation to “require” harvesting and lab analysis of aged materials from decommissioning reactors. The 2019 report does not say whether or how the deleted knowledge gaps regarding the reliability and safety of plant components beyond 60-year license extensions would be scientifically addressed.
  • As NRC license renewal application approvals are proceeding, there is a need for regulatory transparency and industry accountability. In particular, validating the qualifying science by harvesting and analyzing materials from decommissioned plants is necessary for an evidence-based license extension review process. [Beyond Nuclear advocates for the test results of strategic harvesting and laboratory analysis to be incorporated into the NRC license extension review approval process]. Beyond Nuclear suggests pursuing action through the Government Accountability Office and through Congressional hearings.

 

Ben Wealer, Research Associate in Nuclear Power Economics, Berlin Institute of Technology; Guest Researcher, DIW Berlin (German Institute for Economic Research)

  • The World Nuclear Waste Report 2019 outlines nuclear waste management issues globally and in the United States. Over 60,500 tons of spent nuclear fuel are in interim storage.
  • Nuclear waste in Germany and Switzerland is stored in interim storage facilities. In Germany the facilities are operated by federally-owned companies [Germany is a federation], while in Switzerland the facility is operated by a stock corporation, which is owned by Swiss nuclear power plant-operating companies.
    • These facilities are meant to be a short-term solution to deal with high-level waste. Starting in the 2040s, spent fuel will be transferred to a central waste management facility, if all goes according to plan.
  • Small modular reactors (SMRs) have been pitched as lower-cost, small- to medium-sized nuclear generators that can be mass-produced in factories.
  • However, an expert report conducted by the German nuclear regulatory agency (BASE) found that, to generate the same amount of power, construction costs are higher for SMRs than for large nuclear power plants due to the loss of economies of scale.
    • About 3,000 SMRs would have to be produced before it would be economically worthwhile for a reactor vendor to start SMR production.
  • As with large-capacity nuclear plants, the supply of SMRs is predominantly government-owned or demand-led by the government (including the military), both in the United States and around the world.
    • [While SMRs are touted as new, innovative, or disruptive technologies, they have been around for at least 50 years. Most "advanced" SMR concepts are simply smaller light-water reactors with lower output; light-water reactors are actually an old nuclear technology.]
    • There are currently no innovative private companies or start-ups involved in these "advanced" SMRs. Around the world, the companies that are proposing them are generally either long-established nuclear companies, or subsidiaries of those companies. The existing, large-scale nuclear power industry is the major driver of SMR development. U.S. National labs, such as Idaho National Lab and Oak Ridge National Lab, are also involved.
  • The analysis, in the BASE expert report, of plants currently under construction or in operation finds that SMRs are not expected to lead to shorter construction times.
  • Modularity [combining several SMRs together] and new manufacturing processes require new regulatory approaches. However, no SMR-specific national or international safety standards exist today.
    • SMRs proponents claim they have safety advantages over large-capacity nuclear power plants since they would have a smaller radioactive inventory per reactor and aim for a higher level of safety. However, the large number of SMRs that would be required to replace existing nuclear plants or make significant contributions to the grid would multiply their risk many times over.
    • [SMR proponents claim safety requirements for small modular reactors are lower than for conventional reactors, since they have more diverse safety systems or passive safety features. However, lower safety requirements would increase risk. The industry is pursuing them to reduce their costs, not because SMRs are inherently safer than large reactors.]
    • Some SMR designs would run on unconventional fuels such as higher-enriched uranium or reprocessed spent fuel, which would compound spent fuel problems compared to conventional reactors, and also pose new proliferation risks [since some of the fissile material involved could be used to make nuclear weapons].
  • The BASE expert report on SMRs found that their particular safety risks are largely neglected in nuclear waste management planning, especially when it comes to transport, dismantling, and interim and final storage.

 

Amory Lovins, Adjunct Professor of Civil and Environmental Engineering, Stanford University

  • Nuclear power has been proposed as a clean energy option necessary to fighting climate change. Putting aside any questions about the safety of nuclear operations, spent fuel management, decommissioning, proliferation, security, etc., and focusing solely on the economics of nuclear power vs. renewables, the appeal of nuclear power as a climate solution falls at the first hurdle: it has no business case.
  • Modern renewables have nearly quadrupled their output in the past decade. U.S. renewable energy sources, mostly hydropower, wind and solar, have surpassed electricity production from coal and nuclear power, including nuclear’s current and historic peak output.
  • Using U.S. electricity four times more efficiently by 2050—using only 2010 technologies—would cost only a tenth as much as buying retail electricity today, yet would quadruple the share of electricity needs met by a given amount of renewable generation. Yet most states still reward utilities for selling more electricity and penalize them for cutting electricity bills.
  • Most new nuclear reactors are being built in China, but that ambitious program is missing its targets and losing favor with the Chinese government because modern renewables are bigger, faster, and far cheaper. China doubled its renewable capacity additions last year, adding more wind power than the entire world added the year before.
  • Over 80 percent of the world’s net capacity additions in 2020 were renewable energy sources (91 percent of them solar and wind power), mainly due to their plummeting unsubsidized costs. In contrast, world nuclear output stagnated, and coal power declined. [The International Energy Agency (IEA) expects the world’s renewable share of net capacity additions to average 95 percent during 2020–25.] Renewables are adding about as much global generating capacity every two days as nuclear power adds in a year.
  • Renewables, including hydropower, produced 29 percent of the world’s electricity last year, and IEA forecasts their share to rise to 47–72 percent by 2040, while the share for nuclear stagnates around its current 10 percent.
  • Comparing global growth trends and their effects over the past decade, IEA found that renewables have reduced carbon emissions six times more than coal-to-gas fuel switching and five times more than nuclear growth.
  • Next year, Germany will finish its long-planned phase-out of nuclear energy while cutting fossil fuel generation, and its GHG emissions have fallen dramatically. Reductions in German fossil-fuel and nuclear generation have been more than offset by decreases in consumption [higher efficiency] and increases in renewable energy generation. As a result, German national greenhouse gas emissions fell by 53 percent over the past decade. The German power sector met its 2020 climate target in 2019, before the pandemic, with five percentage points to spare.
  • Japan is on a similar trajectory. Over a third of Japan’s nuclear capacity has closed, and the rest remains in limbo. Nuclear output before the Fukushima disaster has been more than replaced by electricity savings and renewables, both of which are accelerating in growth. Japan has already achieved the renewable fraction of electricity (23 percent) it officially targeted for a decade from now.
  • Since nuclear plants can no longer win in the marketplace, nuclear plant owners often seek and get major new subsidies or preferences from politicians, which is misdescribed as “keeping the nuclear option open.” This displaces opportunities for renewables and efficiency.
  • Operating existing nuclear plants costs more than new modern renewables, with or without their temporary subsidies. Renewable prices are expected to decline further for decades to come.
    • Closing a nuclear plant and replacing it with renewables or efficiency would save several times as much carbon as continuing to run the nuclear plant. Nuclear plant owners could volunteer, regulators could require, or markets could elicit that substitution.
    • As we close coal plants to save carbon directly, we should also close distressed nuclear plants and reinvest their operating costs in cheaper options to save carbon. Replacing a closed nuclear plant with efficiency or renewables would only take one to three years. State-level experience shows that any temporary increase in gas-fired generation during that changeover will be more than made up by greater carbon savings later made by efficiency and renewables, since they cost less than running a gas plant and thus save more carbon per dollar.
  • Initially, small modular nuclear reactors (SMRs) would produce electricity at about twice the cost of today’s light-water reactors, which in turn are three to eight times costlier than modern renewables (and five to 10 times costlier than on-site efficiency). At least the former gap will about double by the time SMRs could scale up. Multiplying those cost differences, and taking into account the foreseeable doubling of the gap, mass production would need to make SMRs about 12–32 times cheaper before they could compete with renewables. That’s completely implausible. Nuclear reactors do not scale down well economically, but small modular renewables do, and have decades’ head start on exploiting their economies of scale. SMRs cannot catch up.
  • New reactor types or fuel cycles cannot help either, because reactors’ non-nuclear systems—which account for most of their prohibitive capital cost—are so uncompetitive by themselves that the nuclear companies would have no business case even if the nuclear parts of the power plant were free.
  • SMRs divert investment and time from off-the-shelf competing technologies that have already proven rapidly scalable and garner half a trillion dollars of private investment each year.
  • Continuing to operate existing nuclear plants is not climate-effective. In modern and competitive power grids, nuclear power offers no benefits for grid reliability or resilience, but on the contrary reduces flexibility and blocks cheaper renewables that have been proven [especially in Europe] to yield economical and highly reliable power supplies.
  • To help protect the climate (and customers), any energy technology must not only be carbon-free but also be climate-effective—saving the most carbon per dollar and per year. Nuclear power empirically fails both those tests.
  • [For all these reasons, nuclear power is not a climate solution. In fact, by diverting resources-money, time, focus-away from renewables, buying new reactors, or just operating most if not all existing ones, will make climate change worse.]

 

Q&A Session

Today was the first meeting of the White House Environmental Justice Advisory Council. Climate change challenges and solutions will obviously be central to this council. Do you have any comments about this first meeting and any suggestions to the people participating in it?

  • Judson: This is a really heartening development and such a welcome change in the federal government’s approach to environmental justice. We would encourage them to look really closely at the environmental justice issues for the whole nuclear fuel chain, from uranium mining to nuclear waste storage and decommissioning. The reality is that communities and Indigenous nations are disproportionately dealing with the impacts of the nuclear fuel chain.
  • Morgan: The creation of this Council is long overdue. The first thing to recognize is that environmental justice is the work that many people do to combat environmental racism. This country is founded on racist policy, including genocide and relocation. People need to understand that this is not history; there is ongoing genocide and displacement, especially when our lands and waters are contaminated by radioactive waste. We have seen this play out especially during the pandemic, when radioactive waste affected the water supply of the Navajo Nation. It is also important to highlight the environmental justice principles that were created by people of color over 30 years ago. This work has been ongoing for Indigenous peoples and people of color. Notably, the Environmental Justice for All Act has been reintroduced.

 

We have heard about the issue of nuclear decommissioning from a lot of perspectives. It is worth reconsidering nuclear power as a climate solution. Yet, the issue is dynamic and things change over time. Thinking toward the future, are there policy, economic, and technological developments you are looking for with respect to nuclear generation?

  • Judson: I envision that the superior economic performance of renewables relative to fossil fuels and nuclear will continue. The solutions to climate change are less technical than they are political; they have to do with the policy solutions and decisions being made. If we are going to solve the climate crisis, we also have to solve the political crisis. A just transition is needed. The United States has been bad at managing economic transitions that do not leave behind working class communities and communities of color. Congress and the Biden administration will need to address that.
  • The uranium mining industry has not taken responsibility for its liabilities. Against this background, there are a lot of concerns from Indigenous communities around safety and sacred places. We need the United States to address this problem in a way that takes into account environmental justice principles, Indigenous sovereignty, and the logistical and equity challenges of nuclear energy. Are communities and agencies ready to deal with accidents? The liability issue has not been resolved. New Mexico does not consent to this waste, and this is definitely a form of environmental racism and nuclear colonialism.
  • Gunter: I am looking forward to the democratization of energy and real accountability for all costs.
  • Wealer: I am looking forward to December 2022, when Germany closes its final reactors and finds solutions to waste storage.
  • Lovins: Germany is one of the world’s most powerful economies and has been largely powered by variable sources of renewable energy. The United States can achieve this faster if we de-subsidize the entire energy system. I look forward to the day when energy options can compete fairly at honest prices on the market, regardless of their type, technology, size, location, or ownership. By 2050, at a historically reasonable speed of change, the United States can run a 2.6-fold larger economy than in 2010 using no oil, no coal, at least a third less natural gas, and no nuclear energy—all while saving $5 trillion (not counting the co-benefits for climate mitigation and public health). The market has evolved very much as we suggested it could ten years ago. The technology for renewables and efficiency has improved dramatically.

 

Conclusion by EESI Executive Director Daniel Bresette

  • Deciding which energy technologies to use is not just about emission reductions. Everything involves trade-offs. We have to take into account the full range of costs and benefits when evaluating energy sources.
  • In the United States, we will have nuclear power for a while because of past investments and policy decisions. That could change pretty quickly, though, which means we have to be willing to evolve our thinking and make sure our policy responses are not just framed to do the right thing by communities and people who have been disadvantaged by past policies, but also that they are designed to follow the evidence to get us to where we need to be sooner rather than later on emission reductions.

 

Highlights compiled by Hamzah Jhaveri and Celine Yang

 

Resources recommended by briefing speakers

Video | Nuclear Waste 101: Fifteen-minute Introduction and Overview by Dr. Gordon Edwards (President, Canadian Coalition for Nuclear Responsibility)
Slides for Nuclear Waste 101

 

This was the fourth EESI briefing on nuclear plant decommissioning and radioactive waste issues. It was a moderated discussion with leading experts and advocates.

This briefing was sponsored by Hudson River Sloop Clearwater, with support from members of the National Decommissioning Working Group and others.