44 Feet 

Forty-four feet isn't all that high. It's halfway up the tall side of the county courthouse. If you stacked Guy Fieri seven-and-a-half times on top of himself, his platinum blond hair would reach 44 feet high. Forty-four feet is also the height above today's sea level where 37 tons of radioactive waste from the former PG&E Humboldt Bay power plant is entombed in a concrete vault at the edge of the bay. A new coalition called, you guessed it, 44 Feet has brought together state agencies, federal and local political interests, scientists, a few folks with no titles at all and, to some extent, the nuclear plant's owner, PG&E. Like nanoplastics and deep-fried butter, most of us do not want to think about radioactive waste stored nearby, but 44 Feet is trying to plan for its future safety, even if that future is 100,000 years away.

PG&E's old nuclear power plant sat next to U.S. Highway 101 at King Salmon. It ran a brief and ignominiously leaky life from 1963 to 1976. Still, it produced high-level radioactive waste from the uranium fuel it used to create electricity. The radioactivity has cooled somewhat in the intervening years, but it will remain hot and toxic for more than 100,000 years.

The nuclear waste now sits astride Buhne Point, opposite the entrance to Humboldt Bay. It's positioned in an area with three adjacent earthquake faults, encroaching sea level, potential tsunamis and general erosion. In fact, according to the California Coastal Commission, the area "has experienced one of the highest coastal erosion rates documented in the state." It may be safe. But then again, "the bluff where the spent fuel sits used to be 96 feet above sea level in the 1800s, it's now 44 feet above sea level," said Jennifer Marlow, assistant professor in Cal Poly Humboldt's Department of Environmental Science and Management and founder of 44 Feet (44feetabovesealevel.com).

If that's such an awful location for storing highly toxic waste, you might be wondering, then why is it there? The waste remains near the old nuclear power plant because the federal government made a promise it couldn't keep. A long-term storage facility for all the nation's nuclear waste was supposed to be built in a geologically safer area, Yucca Mountain, Nevada. But it turned out Nevada didn't want it and no one else has volunteered their own backyards, either. So far, the federal government has no feasible option and Humboldt's radioactivity stays here, as the bureaucrats say, "in perpetuity."

The federal bureaucracy, in the form of the Nuclear Regulatory Commission, usurps almost all local and state authority over what happens in and around nuclear power plants. Anything that has to do with "health and safety" is firmly under the NRC. But, when the Humboldt nuke was officially deemed decommissioned last year — after nearly four decades of work and more than $1 billion in cost — the federal government packed up and headed back to headquarters. The NRC says there is no more need for concern because, according to an NRC spokesperson, "there is no accident scenario that would lead to a radiation release." The feds will check in again in a few decades to review the storage site license, but that's about it.

44 Feet is attempting to fill that void.

"The gravity of the situation is important to address in this lifetime," said Marlow. So far, the organization has brought together state agencies, PG&E (with a low profile), scientists and regular folk for two workshops to determine how long-term safety can be addressed in the absence of federal oversight and given local governments' restrictions.

While getting the federal government's attention, much less action, on nuclear waste safety is a daunting task, 44 Feet's most recent workshop Aug. 26, included three county supervisors (Rex Bohn, Mike Wilson and Steve Madrone, representing the county's First, Third and Fifth districts, respectively), a member of Rep. Jared Huffman's staff, the Coastal Commission's senior deputy director, representatives from Redwood Coast Energy Authority, the Humboldt Bay Harbor, Recreation and Conservation District, CalTrans, the Humboldt Community Services District, county planning, PG&E, environmentalists and academics.

The general premise of the gatherings so far has been that the safety of the radioactive waste depends on past assumptions and scientific data that no longer apply. 44 Feet participants contend that Humboldt Bay is, shall we say, fluid; change is inevitable and safeguards must be adaptive.

"As humans, we're not very good at planning hundreds, thousands, of years in the future," said Marlow. "So, we must maintain adaptability." Meanwhile, federal regulators, and thus PG&E, contend that safety requirements based on old data are sufficient, hence the situation is under control.

Marlow concedes that "at this time we are as protected as we can be, but we haven't figured out how tsunamis and earthquakes alter the status quo." Perhaps, radioactivity will remain safe in the storage vault forever, but she's not certain of it. Neither is Tom Marlow, Jennifer Marlow's father and a former utility employee in the nuclear power industry. While he declares himself to be "a proponent of nuclear power," he "maintain[s] a strong questioning attitude by challenging assumptions, shaped by understanding that accidents often result from a series of decisions and actions that reflect flawed assumptions," and that the design of the canisters and vault holding the waste is the most important factor in preventing radioactive release.

"Three things keep me up at night," he said during 44 Feet's latest workshop. These are threats to the storage site's design from earthquakes and tsunamis. The first faintly glowing sheep breaching his somnambulist fence is a tsunami. He said that a "large run-up tsunami after an earthquake" of greater magnitude than what PG&E has designed the storage for, could deposit sand and debris into the vault, which could "interrupt heat transfer" of the decaying spent fuel. If heat increases inside the canisters, it will increase pressure inside on stress welds and other weak spots, increasing the potential of leaks. Then, there's the potential for a tsunami's high velocity water to enter the storage through the drain piping and drains embedded in the bottom of each of the six vault cells. "It's a pathway for water to get in, cause thermal stresses and compromise the [canisters'] integrity," he said.

Finally, he ponders the stability of the bluff's soil and resilience against a tsunami. He said that if soil is "scoured out from under the vault" and there's soil liquefaction coupled with landsliding, the vault could tip over and, in a worse-case scenario, topple into the sea.

Tom Marlow added PG&E might get a heads-up on potential problems like those that keep him awake if the utility monitored the casks for radiation and heat — a low-cost addition — which it currently does not.

"There's no safeguards to give forewarning if things go south," he said. "They're kinda flying blind."

Monitoring, restoring heat transfer to keep the casks from stressing and retrieving a tipped over or toppled vault should be addressed in PG&E's plans, he said.

He noted that PG&E and its consultants have spent thousands of hours of effort to engineer and fabricate 100s of canisters since the mid-1980s, construct the vault, and load and transport the fuel for storage — all without "any release of radioactivity." But the site's natural characteristics, along with the earthquake and tsunami threats, are "formidable." He added, "Mother Nature has the proven potential to overwhelm well researched design assumptions. As my granddaughter lives only a few miles away in Eureka, I'm maintaining a questioning attitude in an effort to ensure Humboldt Bay's is not the first" to defy design assumptions and fail.

Of course, it's possible none of those more extreme, sudden catastrophes will happen, and the real danger could simply be the inexorable rise of the ocean. "We've seen 20 inches of sea level rise since 1970," said Craig Benson, a Cal Poly Humboldt Ecological Restoration and Environmental Conflict Resolution lecturer. "We can't stop hazards like earthquakes but how do we deal with sea-level rise? If you like drinking at Redwood Curtain Brewery in Arcata, that'll be gone. What will be stable 5,000 years from now" when the radioactivity remains toxic?

PG&E relies on data that determined, in 2005, that sea-level rise will be negated by upthrust from earthquakes around Humboldt Bay, so, according to the utility, your beer is unlikely to drown and the coastline will stay pretty much where it is. That report, "Implications of Long-Term Global Warming and Tectonic Displacements at Buhne Hill, Humboldt County, California," reads, "The rate of interseismic uplift at Buhne Point will keep up with expected sea level rise." When asked if that data still stands, Alison Talbott, PG&E's local spokesperson who attended the 44 Feet workshop, declined to answer.

Clearly, no one at 44 Feet thinks sea-level rise at Humboldt Bay will be a wash between upthrusts and sinking and higher water. The easy, short-term fix, according to some at the workshop, is rocks. Some advocate "armoring" the bluff with more rip rap as a relatively low-cost bulwark against whatever nature has in store during our lifetime. Or there could be a more natural alternative available with a little more investigation, noted Jennifer Kalt, director of Humboldt Baykeeper. CalTrans, for instance, is using rocks to shore up U.S. Highway 101 but also uses plants to "armor" the freeway.

It's not as straightforward as rip rap and willows, according to Kate Huckelbridge, California Coastal Commission senior deputy director. She said before the first stone is placed, it's important to know what the rock is protecting against and design accordingly. "If protection is warranted, you have to make sure you have the appropriate design," she said. "It may not be the right solution to just put a bunch of rock there."

The Coastal Commission Is a key player in moving post-decommissioning policy in California because the state did preserve its right to regulate what goes on around the storage site through the commission. Californians can also manage finances through the California Public Utilities Commission, like requiring PG&E to do studies paid for by its customers.

Wilson, Humboldt County's Third District Supervisor, is also a coastal commissioner, and he's been following what 44 Feet is up to. Up until the federal government declared all is well at the former nuclear plant when decommissioning was completed in November of 2021, the Coastal Commission was relegated to building permits for the power plant's roads and outbuildings. The U.S. Supreme Court has allowed states vast leeway to control health and safety within their borders — but not with nuclear power. Now that the NRC has stepped away from regulating, Humboldt has a backdoor. The Coastal Commission can keep that door propped open by regulating the hell out of the permitting process. In so doing, it is looking to address at least some safety issues from the structures, erosion and other physical surroundings shoring up the radioactive waste site. It appears the commission is looking to take an active role. "We have to do everything we can to prepare and push for removal, and at the same time we have to protect what's in place," Huckelbridge said.

That raises the question: Should the radioactive waste stay here on the edge of the bay or should it go somewhere — anywhere — else. Anywhere with a more stable geologic structure, that is. The 44 Feet group wants clear direction for that well before 2032, when the federal Department of Energy expects to start either retrieving or writing off spent nuclear waste from 14 of the first shut-down sites around the country.

The Coastal Commission may want it gone but "there's no such a place as 'away,'" Kalt notes. "I've long felt that, ethically, any toxic industry needs to be built with the understanding that the toxic waste cannot be moved somewhere else. And in this case, moving the waste would be really risky, whether it's moved by sea or by road."

In that direction, 44 Feet is looking for new data to determine whether moving the radioactive waste will be possible a decade from now. PG&E, for instance, has a cask transporter but it resides at the Diablo Canyon nuclear plant near San Luis Obispo. Questions like the future ability and wherewithal to barge out waste canisters if roadways are permanently flooded have yet to be addressed.

Dealing with Humboldt's decommissioning experience and the lack of federal post-decommission health and safety policy can be a useful lesson for other closed or soon-to-shut-down nuclear plants. Gov. Gavin Newsom's plan to extend the life of the Diablo Canyon nuclear was signed into law in early September. The two reactors were supposed to begin shutting down in 2025. The state expects to offer PG&E, Diablo Canyon's owner, a $1.4 billion loan to shore up the plant. That loan is marked as "forgivable," meaning the state would "forgive" PG&E if the utility does not pay back the money. PG&E is also in line to receive billions of dollars more from the federal government to prolong the life of, and waste from, Diablo Canyon.

In addition to the state's highly controversial move, the federal government must still approve the nuclear plant's license extension. That appears likely, given the history of the Nuclear Regulatory Commission's unwavering support for the industry. At 2,200 megawatts (more than 30 times more powerful than Humboldt's nuclear plant), Diablo has produced far more radioactive waste than Humboldt's nuke since it went on-line in 1985. And that waste will also have no where else to go but the shaky California coastline for storage.

Meanwhile, local electricity provider Redwood Coast Energy Authority issued requests to contract for replacement energy for the Diablo plant.

While nuclear power remains contentious in California, and the health and safety threat to the public is still debated in policy and budgeting, those backing the 44 Feet project know they've got a lot of convincing to do before the issue of coastal storage becomes a policy priority. The specter of radioactive contamination that may happen with an earthquake tomorrow or corrosion far, far, far in the future is contending with issues that are urgent and undeniable and ghastly. But, face it, having that radioactive waste hanging over the edge of the Pacific Ocean is more than an amorphous annoyance.

Humboldt's nuclear waste is one of the most toxic substances on earth. On a basic physiology level, when radioactivity is absorbed by a body, the radioactivity becomes part of living tissue. Those deadly, invisible, isotopes are what escaped at Chernobyl in 1986 and Fukushima Daiichi in 2011. Radiation can be breathed in, swallowed or assimilated just by exposing some skin. It doesn't just infiltrate humans, it starts killing every living thing it touches, like marine and plant life. Reportedly, cockroaches are the only ones immune. It's a very bad thing, indeed, but it's not yet today's bad thing.

"The planet is decaying before our eyes," conceded Jennifer Marlow. "Inflation. Water. Food. And yet this coalition of scientists, bureaucrats, academics and others think they might make life on this planet and Humboldt Bay safer for thousands of years into the future. We're not nuclear physicists, but we have the capacity to ask the question, 'How to keep the site safe?' although it's not morally clear what you owe the future."

J.A. Savage (she/her) keeps a wary eye out for rogue waves and celebrity chefs when walking Humboldt's shoreline. She is unrelated to, but admires, Jennifer Savage, who appears elsewhere in this publication.