Friday, December 20, 2013

Comments on Scope of Environmental Impact Statement Supporting the Rulemaking to Update the Waste Confidence Decision and Rule (Docket ID: NRC-2012-0246)

To: Rulemaking.Comments@nrc.gov

I would like to respond to the Nuclear Energy Institute's (NEI's) self-serving claim that the Nuclear Regulatory Commission (NRC) "need not assess the environmental impacts of nuclear plant operation more generally" in order to fulfill the requirements of the Waste Confidence Decision (WCD).

Perhaps this is true -- they "need not" as in, it is not explicitly stated that they do so by the judgement. But assessing environmental impacts of nuclear plant operation more generally is implicitly required because if there is no waste confidence, it is immoral to continue making nuclear waste. Furthermore, if the costs of waste disposal are so great as to make it impossible to operate nuclear power plants cost-effectively, that fact must be recognized. Once the economic and environmental realities are acknowledged, it becomes possible to assess whether the "intractable" problem of storing ever-increasing quantities of spent nuclear fuel is best solved by not making any more in the first place. On the other hand, one only has to look at Fukushima to know what will happen if we keep on running our nuclear reactors until they break. Loss of lives. Loss of land. Loss of income.

For these reasons it is equally inappropriate for the NRC staff to repeatedly describe nuclear waste management as "a small piece of the puzzle" as they have been doing. Waste Confidence is a lynch-pin, an Achilles' Heel, a show-stopper. Over time it will undoubtedly become the most expensive piece of the puzzle, by far -- not small at all.

No wonder NEI is attempting to convince the NRC to interpret the WCD as being so restricted in scope such that the sheer lunacy of producing more nuclear waste in the first place is ignored! NEI claims that "site-specific and generic" Environmental Impact Statements (EISs) cover all permutations of this basic question: Is what we're doing logical? However, they do not: Invariably, ALL other NRC and DOE EISs assume that the waste problem can be solved, thus relegating the dangers of continued operation, continued production of nuclear waste, and continued mining of uranium to matters which can be assessed through Probabilistic Risk Assessments (PRAs). In reality, PRAs utterly fail to assess the dangers of ongoing operations with no end in sight. 100-year floods and earthquakes become inevitable instead of rare if you wait long enough -- and that seems to be exactly what the nuclear industry wants: For us all to wait until there is a disaster, only to claim they never saw it coming.

Regarding NEI's specific responses to comments made during the hearings, I take particular exception to NEI's first "correction," their description of the 1998 Aberdeen proving ground dry cask test as "not a conclusive indicator" of dry cask resiliency. America cannot afford even ONE catastrophic dry cask accident, so even ONE failure -- and that test was indeed a failure -- is a show-stopper. A hole was successfully punched in the dry cask, using far less powerful weaponry than might be available to modern-day terrorists -- who might even be using our own weapons against us, such as A-10 Warthog anti-tank airplanes (perhaps by turning an American pilot into a terrorist while rising in the ranks of our own military), or by using a tank stolen from a local military training facility or even a National Guard station (it happened in San Diego in the 1990s). It is also possible that terrorists will acquire some other nation's high-powered weapons on the black market.

The Sandia National Laboratory test NEI refers to was similarly insufficient: A "typical" anti-tank weapon is not necessarily a shaped-charge weapon, it is probably nothing more than a Rocket-Propelled Grenade or RPG, and certainly does not "typically" explode once inside a tank or dry cask (it never gets inside but can disable a tank tread, for instance). Such a weapon "typically" is not even made of so-called "depleted" uranium. Are they talking about pea-shooters or real weapons that real terrorists might use? Are they talking Molotov Cocktails or MOABs (Mother Of All Bombs, a thermobaric weapon deployed with great horror by the U.S. Military during the early stages of the Afghan war)? To say the Sandia test used a "device" (unnamed) "30 times more powerful than a typical anti-tank weapon" is evading the issue, and has no real meaning. What if a terrorist gets hold of a nuclear weapon and discharges it near the dry casks? It can happen.

Regarding the "large commercial aircraft traveling low to the ground at 350 MPH" this description clearly belies that it was not tested to be able to survive a jumbo-jet intentionally flown into the facility at 500 MPH or more, and wouldn't stand a chance against a mildly-well-trained suicidal pilot flipping the big bird over on its back, pulling back on the control stick, and diving at 700 MPH or even faster directly into the facility from above. It is a "1-G" maneuver, for that matter -- the passengers would barely even notice if it's done right!!

And an F-16? The "Fighting Falcon" is a beautiful LITTLE jet that barely cracks the speed of sound at sea level. 21 tons maximum takeoff weight, and that drops pretty quickly as it burns fuel. Maximum speed at sea level: Mach 1.2. For the test described by NEI, I believe the F-16 body was on a pulled rail system, well below its maximum speed, and was NOT loaded with fuel (or bombs) during the test.

A Boeing 747, on the other hand, weighs in at about 420 tons, so at least 20 times the inertia of an F-16 -- and nearly half that weight is fuel. Cruises at Mach 0.84. The four turbine shafts for the engines weigh, together, about as much as an F-16.

Every other one of NEI's claims is similarly twisted logic and should not be considered. NEI has a vested interest in the outcome of this WCD and has exhibited bias in favor of the nuclear industry which funds them, instead of in favor of public safety, at every juncture in these proceedings.

Sincerely,

Ace Hoffman
Carlsbad, CA

Link to NEI's comment (#154) submitted by Ellen Ginsberg, on FR Doc # 2012-26295
http://www.regulations.gov/#!documentDetail;D=NRC-2012-0246-0158


Tuesday, December 17, 2013

Nuclear waste: Get rid of it! But where? How? When? And who's gonna pay for it?

Hearings on the Nuclear Regulatory Commission's proposed Generic Environment Impact Statement (GEIS) for nuclear waste were held nationally over the past few months and attended by more than 1400 people. The comment period (for written comments) for "NRC NUREG-2157" ends December 20th.

In California, about 150 people attended a hearing in Carlsbad, and over 200 attended the San Luis Obispo meeting.

Tonight in San Clemente, citizens will ask their city council to request an extension of the comment period. Concerned citizens hope to be able to get additional requests from other local communities, to force the federal government to remove nuclear waste from the now-closed San Onofre Nuclear (Waste) Generating Station, or at least, to give us hardened on-site storage, which neither the current dry casks nor the spent fuel pools provide.

"Hardened" might mean underground, behind earthen berms, separated from each other, moved away from rail, ship, aerial and truck bomb access points, fewer assemblies in each cask, etc. etc.. These are standard anti-terrorism procedures which are NOT being done at our ISFSIs (Independent Spent Fuel Storage Installations, the current acronym for "semi-permanent nuclear waste dump and blight on the land.")

Yesterday Donna Gilmore and I were suddenly interviewed by Fox 5 San Diego about Southern California Edison's shipment of Unit II's original reactor pressure vessel head to Clive, Utah. It's a dome-shaped object approximately 14 feet across. Edison says it weighs 77 tons, and says that standing six feet away from it for an hour will give you about as much radiation as watching television for about a year. Do they mean modern OLED screens or old tube TVs? Do they mean the most modern types of dental x-ray equipment when they say it's equal to a dental x-ray, or do they mean older machines that give out nearly an order of magnitude more radiation? Or even older ones that were even worse?

Here's a link to the report based on the on-site interview with Donna Gilmore:

http://fox5sandiego.com/2013/12/16/san-onofre-transports-nuclear-waste-out-of-state/#ixzz2nh3ycGur

This report by 760KFMB gives additional information:

http://www.760kfmb.com/story/24237142/77-ton-nuclear-component-on-the-road-from-san-onofre-to-utah

Here's a link to my own animation of San Onofre's reactors, which shows the exact part they are moving (screen two (the two triangles at the top advance the screens)). Notice that the RPVH is a pretty small piece of the entire system:

http://www.acehoffman.blogspot.com/2013/02/new-animation-shows-what-could-happen.html

The RPVH is highly radioactive, although presumably it will be shipped facing down, so that most of the gamma emissions will be shielded by 8 inches of steel (with a lot of holes, which aim straight up, but presumably have been plugged with something). Underneath perhaps they will have a heavy metal plate several inches thick bolted to the bottom, and any gamma emissions that get through it will, presumably, mainly go into the ground beneath the vehicle as it travels down the road. Few will get through the eight inches of steel, few will get through the bottom plate and then bounce off the ground into where other vehicles with people might be, and so it is called "low level waste." The inner liner of the RPVH is made of the finest stainless steel available -- and millions of kid's braces could have been made with that steel, if it were not irradiated. Some of it might find its way into kid's braces some day by accident anyway.

Edison sent out a press release about moving the RPHV and assured the public it was safe. Certainly, it won't catch fire and spread radiation, thus contaminating the local population and the air, water and land. The spent fuel at San Onofre, that is NOT being removed, can certainly do that.

Each time Edison does a transfer to dry casks, that operation is about a million times more dangerous than this RPHV transfer, but there are no announcements warning about those operations. It just goes on daily, about one new cask per month, until the job is done and Edison can walk away, leaving southern Californians with a pile of waste which can destroy our paradise at any moment, for who-knows-how-many-generations.

Edison has NO plans for removing the nuclear waste, and neither does the NRC. Outrageous!

I have attended nearly every Nuclear Regulatory Commission hearing on San Onofre for nearly 20 years. For more than a decade we were told by Southern California Edison (with no objection from the NRC) that the waste problem was essentially solved because the waste would go to Yucca Mountain. But Yucca Mountain is an imperfect solution: Before the federal government stopped the project (or at least slowed it to a crawl), one of the last problems they could not be sure they had any good science about was "drip shields" which were to protect the fuel rods -- that were to be permanently entombed at the site -- from water dripping from above. The shape, material, thickness, and expected durability of the shields were all undecided, but my recollection is that the last design was an upside-down flattened out V shape made out of 4-inch thick titanium. And no one knew how long it would last, but 300 years was an outside estimate, or at least the hope. After that, good luck.

What the transport vehicles would look like, and whether they would use rail or roads or both, was all undecided when the project was stopped, despite 10s of billions of dollars having been spent.

Geologic storage, if we choose that route, will not be easy and will not be risk free. And we're nowhere near it at this point.

Instead, we've apparently chosen to practically randomly assign approximately 75 sites around the country to be nearly-permanent or virtually-permanent (100s of years, which only George Orwell and the NRC can call temporary) nuclear waste dumps. SanO is one of them.

I say "randomly" because the sites were never picked because they would be waste dumps at all, let alone appropriate ones: When the reactors were built, the public was told the waste would be removed within a few MONTHS after it is discharged from the reactor! Instead, virtually all of SanO's used reactor cores remain on site. (It should be noted that the used fuel is actually much easier to transport if its temperature is above about 800 degrees Fahrenheit, because the zirconium cladding is much more ductile above that temperature. However, when the fuel is naturally that hot thermally, the damage if an accident were to occur would be much greater, because the fuel is also radioactively much "hotter" a few months after discharge than it is, say, 20 years or 50 years afterwards.)

Is San Onofre a good location for a nuclear waste dump, permanent or not? Hardly! Earthquakes, tsunamis, sabotage, large surrounding population, poor egress, no radiation emergency supplies to speak of anywhere in the nearby counties to handle a spent fuel fire resulting from an airplane impact... and it's upwind from the entire United States, so everyone in the country will be contaminated if there is an accident at SanO.

Frankly, I can't think of many WORSE places to store nuclear waste than most of the places we are currently storing it nationally: Invariably near population centers, because that's where the energy was/is produced.

Diablo Canyon, 250 miles to the north of SanO, is even more dangerous than SanO: Its freshest spent fuel is dozens of times more radioactive than anything at San Onofre -- now that SanO has been shut for nearly 2 years. And the fuel that's still inside DC's reactors is thousands of times more radioactive than that!

At the very least, all the used reactor cores (aka "spent" or "used" fuel) in California should be consolidated into ONE protected location, the best one possible, wherever we decide that is -- with DC shut down, of course, so no more waste is being produced here. There is NO reason for California to wait for a national repository -- it could be centuries away. The fuel should be retrievable in case a permanent national repository does become available. Spent fuel should NOT be reprocessed. Reprocessing takes an enormous amount of energy and creates additional radioactive and chemical waste streams (no matter how many nuclear proponents claim otherwise).

Ace Hoffman
Carlsbad, CA


E-mail comments to: Rulemaking.Comments@nrc.gov, citing Docket ID No. NRC-2012-0246

Submit comments online at: www.regulations.gov using Docket ID No. NRC-2012-0246
Mail comments to:

Secretary
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
ATTN: Rulemakings and Adjudications Staff
  


======================================================
A testimony by the wife of a former (27 years at the plant) San Onofre Nuclear Reactor Operator:
======================================================

This is a compelling view of the problems at San Onofre:

http://www.animatedsoftware.com/environment/no_nukes/2013/Flow-Accelerated-Corrosion.pdf

================================================
Contact information for the author of this newsletter:
=================================================

-----------------------------------------
Ace Hoffman, computer programmer,
author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Subscribe to my free newsletter today!
Email: ace [at] acehoffman.org

-----------------------------------------

Friday, November 29, 2013

Thanksgiving in the USA: A time for gluttony, thanks, and hope...

Many Americans today are enjoying a factory-raised defrosted frozen turkey, a box of stuffing (just add water!), dried reconstituted mashed potato mixture (just add more water!), a box of gravy (microwave and serve!), a can of string beans (tastes just like mom used to make), jellied cranberry sauce (ditto), store-bought pumpkin and apple pies, and alcohol. Lots of alcohol.

Today we live like kings: Drunken kings of gluttony.

At this time of year, most Americans also give pause -- a moment's pause before going shopping -- for things we are thankful for. I have a lot to be thankful for this year: The twin nuclear power plant near where I live was closed permanently -- my thanks to the activists who fought to keep it shut, to the Nuclear Regulatory Commission who wouldn't let it re-open, and to the plant's owners/operators, Southern California Edison, for finally giving up on that rusty old behemoth. Cancer rates in the area are likely to go down, and thanks to the National Academy of Science, a study which may reveal that possibility is being undertaken.

My wife's cancer is being treated, first with a mastectomy last August (on our 36th wedding anniversary), now with chemo drug therapy, next with radiation therapy, and then with (anti-)hormone therapy (for ten years). But she's alive and the prognosis is good, so I am thankful for that.

And meanwhile, she's going to try a new procedure as an experiment during the rest of her chemo sessions, something I proposed and her doctors approved: Exercise DURING the chemo session! I believe that it's the best way to get the chemo drugs into the cells where they're needed. It's well known that cancer cells need a lot of blood and force the body to supply it by building extra blood vessels into the cancer cluster(s). By exercising while the cancer drugs are being administered, instead of sitting practically motionless the whole time, we believe the drugs will be much more effective. We proposed the exercise program to my wife's oncologist and we're planning to begin a larger research project to study the idea, with her as the first patient. Most of the nausea and weakness you hear about from chemo are after-effects, NOT what happens while the drugs are being administered. (Many of the modern chemo combinations are much better than previously, too.) Chemo drugs kill fast-dividing cells, but to do so, they need to reach every cancerous cell in the body. Getting the blood pumping seems the best way to make that happen.

So perhaps I have more to be thankful for than most people right now. Fukushima is far, far away... or is it? It's in everything I ate and drank today. It's in everything I will eat and drink tomorrow, and every day for the rest of my life. Just as surely as a few atoms of great Caesar's last breath are mixed into every breath WE take, so too, is Fukushima, and people need to be aware of this fact.

Below is a Thanksgiving greeting from the Fukushima Fallout Awareness Network, and a link to a video of Cathy Iwane, speaking at the Nuclear Regulatory Commission's "Waste Confidence" hearing in Carlsbad, California on November 18th, 2013. We've got to stop the radioactive pollution of the planet, first, by closing the nuclear power plants and military reactors, and then securing ALL the waste.

Ace Hoffman
Carlsbad, CA

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Cathy Iwane speaking at the Nuclear Regulatory Commission's "Waste Confidence" hearing in Carlsbad, California November 18, 2013

http://youtu.be/ws-5Hb66Gos

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FUKUSHIMA FALLOUT AWARENESS NETWORK BRINGS YOU A SPECIAL THANKSGIVING DAY GREETING!

FFAN'S THANKSGIVING RECIPE FOR A HEALTHIER FUTURE

1. DONATE your time and/or money to FFAN's crucial effort TODAY!

2. SIGN FFAN's Food Safety Petition "Say Bye Bye Becquerels! KEEP HARMFUL RADIOACTIVITY OUT OF OUR CHILDREN'S FOOD!"

3. SUBMIT Your Comment to the FDA: Insist they lower the acceptable levels of radioactive contaminants allowable in our food supply.

4. WRITE A LETTER (sample here) to your Representative to demand FDA do their jobs to protect our families by monitoring our food supply.

5. JOIN FFAN on Facebook to get up-to-date information. Radiation continues to emit from Japan's Fukushima nuclear plants, affecting the global environment and food supply. Education and awareness are key.

6. DONATE $5 TO FFAN TODAY! Help us continue this vital work.

PLEASE SHARE FFAN'S RECIPE WITH FAMILY & FRIENDS.
LET'S GIVE OUR CHILDREN A CHANCE FOR A HEALTHY LIFE!
HAPPY THANKSGIVING!
http://FFAN.US

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This newsletter was distributed by:
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-----------------------------------------
Ace Hoffman, computer programmer,
author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Subscribe to my free newsletter today!
Email: ace [at] acehoffman.org
-----------------------------------------

Sunday, November 17, 2013

Stop The Nuclear Waste Con Job! Attend NRC Public Hearing tomorrow (Monday, 11/18/2013) in Carlsbad, California!

Tomorrow (Monday, November 18th, 2013) the Nuclear Regulatory Commission is meeting in Carlsbad, California, one of about 15 meetings with the public in which the public is not allowed to show videos or even slide shows, and will have their time cut off even if only a few people show up, just because the NRC doesn't like people to have the time to complete a complicated thought. Unfortunately, nuclear waste is a very complicated problem which needs a lot of thought.

Please come to Carlsbad tomorrow evening to talk about getting nuclear waste out of the area. We no longer have an operating nuclear power plant nearby, but nearly every pound of deadly waste it ever produced sits dangerously unprotected and dangerously close to nearly 9 million people within 50 miles, and about 20 million more just beyond the 50 mile mark in Tijuana, Los Angeles and other nearby communities. San Onofre produced about 4 million pounds of high level nuclear waste over the 40+ years of operation of the three reactors, and unless the citizens demand it be removed -- it will just sit there for hundreds, and perhaps even thousands of years, until a terrorist, airplane, tsunami, earthquake, or rust and embrittlement damage it and cause a release of its deadly contents. The waste is much more deadly now than ever, and needs proper long-term arrangements NOW -- NOT any "temporary" solution which involves leaving the waste sitting on our coast for up to 100 years, only to be repackaged (somehow, at great danger to the workers and community) and left to sit for another century!

San Onofre is closed but the danger still remains. This is our best chance to do something about it. This hearing was postponed due to the government shutdown and is part of a federally-mandated requirement that the NRC pay attention to the community voices on the issue of "Waste Confidence" -- but there is NOT cause for ANY confidence in the federal nuclear waste management procedures!

Please come out to Carlsbad tomorrow. Enjoy our fine restaurants at all price levels (see list below) and then give the NRC a piece of your mind.

Ace Hoffman
Carlsbad, CA

My 2 minute video on nuclear waste (recorded October, 2013):
http://youtu.be/2m2sr78g9uI

My 30 minute video on nuclear waste (recorded July, 2013):
http://youtu.be/xfVx-UysJoI

==================================

Coalition to Decommission San Onofre (CDSO) and
Sierra Club Angeles Chapter

PRESS RELEASE AND MEDIA ADVISORY

FOR IMMEDIATE RELEASE

Media Contacts:
Donna Gilmore, SanOnofreSafety.org 949-204-7794 donnagilmore@gmail.com
Martha Sullivan, Women Occupy San Diego, 858-945-6273 marthasullivan@mac.com
Glenn Pascall, Sierra Club Angeles Chapter, 949-248-3183 gpascall@att.net
Gary Headrick, San Clemente Green, 949-218-4051 gary@sanclementegreen.org

Stop the Nuclear Waste Con!

November 14, 2013 (Carlsbad, CA) The NRC Draft Waste Confidence Generic Environmental Impact Statement is unacceptable. Much of it appears to be based on unsubstantiated hope.

WHAT: U.S. Nuclear Regulatory Commission Public Meeting to receive comments on the Draft Waste Confidence Generic Environmental Impact Statement Report and Proposed Rule.

WHEN: MONDAY, November 18, 2013
5 p.m. CDSO Press Conference
5 - 7 p.m. Overpass Light Brigade
6 - 7 p.m. NRC Open House (Q&A with NRC Staff)
7 - 10 p.m. NRC Public Comment Meeting

WHERE: Sheraton Carlsbad Resort and Spa, 5480 Grand Pacific Drive, Carlsbad CA 92008

Background: As described by the NRC Chairman, Alison Macfarlane, in a recent speech, "in June 2012, the D.C. Circuit Court of Appeals vacated the NRC's 2010 Waste Confidence rule. In the court's opinion, the Commission's conclusion that a high-level waste repository would be available 'when necessary' lacked an appropriate discussion of the environmental consequences of failing to achieve that objective. The ruling also expressed concern about potential spent fuel pool leaks and fires. In the time since the court issued its decision … NRC staff has been working to revise the Waste Confidence rule and develop a generic environmental impact statement. From the beginning, the Commission made it clear that public involvement must be an essential part of this process. Starting last month, the NRC has been holding a series of public meetings around the country to get important input for our final products." [1]

The public meeting in Carlsbad on November 18, 2013, is one of 12 being held by the NRC around the country to take comment on the Draft "Waste Confidence Generic Environmental Impact Statement" Report,[2] including a second California public meeting in San Luis Obispo on November 20th. See complete schedule at:

http://www.nrc.gov/waste/spent-fuel-storage/wcd/pub-involve.html#schedule

Stop the Nuclear Waste Con: "The NRC Draft Waste Confidence Generic Environmental Impact Statement (GEIS) is unacceptable. Much of it appears to be based on unsubstantiated hope and it ignores the unsolved problems of high burnup fuel. The NRC won't approve short-term storage or transport of high burnup used nuclear fuel because they have no confidence it is safe," states Donna Gilmore of SanOnofreSafety.org. The Waste Confidence GEIS needs to address:

HIGH BURNUP FUEL ­ Too hot to handle

No short-term storage or transportation solutions for high burnup fuel waste.[3]
The NRC and DOE are concerned with the instability of high burnup nuclear waste in both storage and transport, yet the NRC continues approving this dangerous fuel for reactors.

The NRC won't approve high burnup dry cask storage over 20 years because they have NO CONFIDENCE it can be stored longer without releasing radiation into the environment, even though it must be stored for thousands of years.

The NRC won't approve transportation[4] of high burnup used fuel because they have NO CONFIDENCE it can be transported without releasing radiation into the environment.

San Onofre's high burnup used fuel is so hot and radioactive, it requires up to a MINIMUM 20 YEARS cooling in the crowded spent fuel pools, instead of the minimum 5 years for lower burnup fuel.

Generic Environmental Impact Statement ­ NOT acceptable for California

California didn't "sign up" for permanent (100+ years) nuclear waste dumps.

California nuclear waste sits in the world's earthquake "ring of fire", the same as Fukushima, the most active and dangerous earthquake zone in the world. California's nuclear waste is surrounded by known active earthquake faults and the USGS says no one has ever predicted a major earthquake.

California's nuclear waste sits along an eroding coastline, in tsunami zones, and is exposed to a highly humid and corrosive coastal environment. NRC's NUREG/CR-7030 states atmospheric corrosion of sea salt can lead to stress corrosion cracking within 32 and 128 weeks in austenitic [corrosion resistant] stainless steel canisters.[5]

It would be impossible to evacuate the millions of people living near California's waste. Of the 34 million people in California, over 8.5 million reside within 50 miles of San Onofre.

A radiological disaster impacts the nation's and world's security, economy and food supply.
· California is the eight ranking economy in the world, virtually tied with Italy and the Russian Federation, and larger than Canada, Australia and Spain.[6]

· More than 40 percent of containerized imports enter the country through California ports, and nearly 30 percent of the country's exports depart through them.[7]

· California produces nearly half of the U.S. grown fruits, nuts and vegetables. California remained the number one state in cash farm receipts in 2011, with its $43.5 billion in revenue representing 11.6 percent of the U.S. total. U. S. consumers regularly purchase several crops produced solely in California.[8]

· San Onofre is located adjacent to the primary vehicle transportation artery between Los Angeles and San Diego (I-5), and one of the largest military installations (and targets) on the West Coast (Camp Pendleton).

We oppose NRC's proposed rule that future licensing can be based on the assumption spent fuel can be safely stored above ground virtually forever.

In the proposed NRC rule[9] that accompanies the draft GEIS, the NRC proposes to incorporate into every reactor license the Draft GEIS' conclusion that spent fuel can be safely stored above ground indefinitely.

This proposal would in effect forbid any further public discussion, in individual reactor licensing actions, of the serious question of whether generation of additional spent fuel is justifiable in light of the absence of any means of safe disposal.

The Coalition to Decommission San Onofre includes Citizens Oversight, Inc., Peace Resource Center of San Diego, San Clemente Green, SanOnofreSafety.org, and Women Occupy San Diego. For more information on nuclear waste, go to SanOnofreSafety.org.

----------------------------

[1] http://pbadupws.nrc.gov/docs/ML1330/ML13309A775.pdf
[2] http://pbadupws.nrc.gov/docs/ML1322/ML13224A106.pdf
[3] Sources for high burnup information at http://sanonofresafety.org/nuclear-waste/
[4] http://www.nrc.gov/reading-rm/doc-collections/isg/isg-11R3.pdf
[5] Atmospheric Stress Corrosion Cracking Susceptibility of Welded and Unwelded 304, 304L, and 316L Austenitic Stainless Steels Commonly Used for Dry Cask Storage Containers Exposed to Marine Environments (NUREG/CR-7030) http://pbadupws.nrc.gov/docs/ML1031/ML103120081.pdf
[6] http://www.ccsce.com/PDF/Numbers-July-2013-CA-Economy-Rankings-2012.pdf, http://www.dof.ca.gov/HTML/FS_DATA/LatestEconData/FS_Misc.htm
[7] Pacific Merchant Shipping Association 11/10/13 http://www.pmsaship.com/default.aspx?ID=8
[8] California Agricultural Statistics USDA October 31, 2012 http://www.nass.usda.gov/Statistics_by_State/California/Publications/California_Ag_Statistics/Reports/2011cas-all.pdf
[9] http://pbadupws.nrc.gov/docs/ML1325/ML13256A004.pdf

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Some fine dining choices in Carlsbad, California (excluding large chains):
===========================================

$$$:
Paon (2975 Roosevelt St) http://www.paoncarlsbad.com/
French and worth every penny -- I love it when someone takes me! Reservations recommended.

$$:
Armenian Cafe (101) http://www.thearmeniancafe.com/
Delicious Mediterranean food, with a garlic dip to die for! I think it's 98% garlic. Belly dancing and music Friday and Saturday nights

Greek Corner Cafe North County (Marron Rd) http://www.greekcornercafe.com/
(Also delicious Mediterranean food, but without the garlic dip.)

Village Kitchen & Pie Shoppe (950 Tamarack Ave.) (yes, their pies are wonderful!)
Harbor Fish Cafe (3179 Carlsbad Blvd) (friendly, great view, fresh fish!)
Spiritos Pizza, (North Carlsbad Plaza) (great crust!)
Thai Bistro, (3050 Pio Pico Dr.) (peanut sauce!)
Pizza Port (Carlsbad Village Drive) (home-made beer and root beer!)
New York Pizza (Roosevelt St) (triple-garlic pizza!)
French Bakery Cafe (1005 Carlsbad Village Dr) (great salads and deserts!)
Fish House Vera Cruz (Carlsbad Village Drive) (get it grilled!)
Mas Fina Cantina (State St) (say "hi" to the tall bartender!)
Jay's Pizza (Carlsbad Village Drive & 101) (clam pizza!)
Peking Garden (6990 El Camino Real) (duck!)

$:
Pronto's (Roosevelt St.) (lunch only)
Kasi Indian Restaurant (2675 Gateway Rd #101) (spicy hot sauce!)
Vinaka's Cafe (300 Carlsbad Village Dr #211) (deserts!)
SunFlour Bagel (6955 El Camino Real) (Awesome onion bagels especially!)

Virtually all Mexican restaurants in Carlsbad are terrific and cheap!

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Update on Sharon's breast cancer treatment:
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My wife of 36 years, Sharon, has completed her second of six post-mastectomy chemotherapy treatments at UCSD. Treatments should be completed by mid-February, to be followed by radiation therapy for an inoperable cancerous intermammary lymph node.

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Newsletter authorship information:
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-----------------------------------------
Ace Hoffman, computer programmer,
author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman

Subscribe to my free newsletter today!
Email: ace [at] acehoffman.org
-----------------------------------------

Friday, October 18, 2013

Two events in California tomorrow (one in San Francisco, one in San Clemente)

Tomorrow (Saturday, October 19th, 2013) is a busy day for Californians interested in nuclear issues!

In San Clemente there is the Citizen's Nuclear Waste Symposium. Attached is my brochure (in pdf form) for that symposium. Many thanks to Mary Fish and staff for help putting the brochure together. The symposium, featuring nuclear waste experts Arjun Makhijani and Marvin Resnikoff, will be webcast live, and also recorded for later rebroadcast. Go to SanOnofreSafety.org for more information about the San Clemente symposium.

Also tomorrow, in San Francisco, is a Fukushima Awareness conference, and more information on that is included below and in the second attached pdf. Speakers will include Dr. Robert Gould (Physicians for Social Responsibility) and Prof. Masaki Shimoji, who was jailed in Japan for protesting the burning of radioactive Fukushima rubbish.

I heard from a San Onofre whistleblower today, who told me he has learned that Unit 3 operated at higher pressures than Unit 2 -- the opposite of what we had thought! He also said the boiling in Unit 3 began at the very bottom of the steam generator, near the tube sheet (much lower than it should have). He noted that even today, he doesn't think anybody really knows why Unit 3 suffered Fluid Elastic Instability, and Unit 2 did not.

Ace Hoffman
Carlsbad, CA

My two-page flyer for the event:
SpentFuelFlyer

My video based on Kirk Sorensen's spent fuel explorer program:


==================================================
The Truth and Reality of Fukushima / an Educational Conference:
==================================================

Date and Time: Saturday October 19, 2013 2:00 PM ­ 6:00 PM
Place: San Francisco State University, Room BH1, 1600 Holloway Ave. SF 94132

Admission: Free

Japan and the world continue to be threatened by the Fukushima meltdown and further contamination of the land and sea as well as a growing cancer epidemic of children, workers and the people of Japan.

The conference will challenge the information being propagated that we can overcome radiation and that Fukushima can be decontaminated.

Initial Speakers:

Dr. Robert Gould ­ Physicians for Social Responsibility, An expert on the medical effects of radiation

Prof. Masaki Shimoji ­ Assistant Professor of Osaka Japan, Anti-nuclear activist in Osaka Japan who was imprisoned for organizing against the burning of nuclear rubble in Osaka

Possible speaker by Skype: Taro Yamamoto ­ Member of Parliament from Tokyo

Film: How Nuclear Power Was Brought To Japan

Music: Okinawan music

A link is available here:
http://nonukesaction.wordpress.com/

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Kirk Sorensen talking about spent fuel (2010):
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Kirk Sorensen talking about his spent fuel simulation at a Google tech talk in 2010. At the end of the talk Sorensen promotes spent fuel reprocessing, which I don't agree with, but nevertheless this is an excellent primer on the composition of spent fuel (about 20 minutes):

http://youtu.be/rv-mFSoZOkE

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This newsletter written by:
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Ace Hoffman
Carlsbad, CA

Thursday, October 17, 2013

INVITATION: Community Symposium on Decommissioning San Onofre, San Clemente, October 19

Community Symposium on Decommissioning San Onofre

Saturday, October 19, 2013, 1:30 - 4:30 p.m.

Admission Free - Suggested Donation $10

Center for Spiritual Living,1201 Puerta Del Sol, Suite 100, San Clemente, CA 92673


Pre-register - More symposium information

In June, civic and environmental activists won a big victory when the troubled San Onofre nuclear plant ceased operations permanently. The current dispute over defective technology between Edison and Mitsubishi confirms how necessary this outcome was.

Environmental and citizen groups had only a short time to celebrate averting the risk posed by continued operation of the plant. Almost immediately it became clear that this site, wedged between Interstate 5 and the Pacific shoreline, poses a huge challenge of radioactive nuclear waste stored at the plant.

The issues are multiple. Much of the waste is a highly radioactive form of spent fuel known as "high burn-up," stored in densities far higher than original design specifications. Large uncertainties persist about where the waste will ultimately be stored and for how long. Billions of dollars of expense will be required to resolve these uncertainties.  The issues involved in "decommissioning" San Onofre were secondary during the shutdown debate but now they loom large.

This Saturday, October 19, in San Clemente, the Community Symposium on Decommissioning San Onofre will feature nationally regarded authorities addressing these concerns:

Dr. Arjun Makhijani, expert on Hardened On Site Storage of nuclear waste and long-term high-level waste management issues and President of the Institute for Energy and Environmental Research
Dr. Marvin Resnikoff, expert on nuclear waste management issues and  Senior Associate at Radioactive Waste Management Associates
Dr. Donald Mosier, expert on the health effects of radiation, Department of Immunology at The Scripps Research Institute and City Council member from Del Mar, California


Co-sponsors of the symposium include Residents Organized for a Safe Environment (ROSE), Sierra Club Angeles Chapter, Peace Resource Center of San Diego, San Clemente Green, Women's Occupy, Citizens Oversight Project, and San Onofre Safety.

Our immediate goal is to assure that "best practices" are applied to make the decommissioning of San Onofre as safe as possible.

Our ultimate goal is to rejuvenate the national dialog about how the U.S. manages nuclear waste.


San Onofre Task Force
Learn more on the San Onofre Campaign website, email list, and Facebook page

Glenn Pascall
Chair, San Onofre Task Force
Co-coordinator, Community Symposium on Decommissioning San Onofre

George Watland
Conservation Program Coordinator
Co-coordinator, Community Symposium on Decommissioning San Onofre



_____________________________________________________________________________

Sierra Club Angeles Chapter
3435 Wilshire Blvd., Suite 660, Los Angeles, CA 90010  (213) 387-4287
     SUPPORT      JOIN        GET INVOLVED     

Friday, October 4, 2013

Comments regarding written summary of 9/26 meeting in Carlsbad...

The correspondence below has only been very slightly cleaned up. At one point I had written "0.01%" but that has been adjusted to a more accurate (I believe) 0.000001%. A few typos have also been corrected. The estimates (a thousand times this, a hundred times that, etc.) are believed to be reasonably accurate. Please bear this in mind while reading my comments.

Regarding my wife's biopsy mentioned in my original cover letter (also shown below), the lymph node tested positive for cancer. That makes five cancer spots, but four have been removed (three in the breast and one lymph node). After a couple of months of chemo, the remaining cancerous lymph node will be treated with radiation, and then she'll get hormone therapy for five to ten years.

The odds are still in her favor for a five year survival, or much longer, but the next few months are going to be rough.

Ace Hoffman
Carlsbad, CA

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Original cover letter:
======================================


Oct 4th, 2013

Dear Readers,

Below are my comments on the attached notes. I hope people find them useful. I have not had time to proofread them and feel it is urgent that I get them out before the meeting today.

Question thirteen and related questions are probably the most important ones. Sorry if these comments offend anyone, that is not the intent. The intent is to help us all face the reality of what the real dangers are from our nuclear mistakes here in America.

My wife gets the results of her most recent post-mastectomy biopsy today, in about an hour and a half. I want to thank the NRC staff and others who have wished her well. She had a radiation-guided biopsy on Wednesday, a radiation-guided mastectomy on August 30th, and will almost surely be told she'll be getting radiation and chemo when we meet with the oncologist this morning. It has always been my goal to take a reasonable approach to radiation dangers, and I hope the rest of you will, too.

Thank you,

Ace

======================================
NRC Presenter and Response Team:
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Larry Camper
Bruce Watson
Blair Spitzberg
Mike Dusaniwskyj

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Questions:
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Question 1: (from the Coalition) Is the NRC willing to recognize The Coalition to Decommission San Onofre and grant us official status? Will the public have an opportunity to review and comment on significant decommissioning plans, including planned expenditures?

Answer 1: (Camper) We will consider this request. What would it involve?

Response: (Gene Stone on behalf of the Coalition) It would involve the Coalition providing citizen oversight and an independent perspective during decommissioning. The Coalition would be an active participant on safety issues, including joining the NRC during on-site inspections. This role would assure the openness of process sought by the NRC chair.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
1) A "citizen's oversight" on the decommissioning process is practically irrelevant. More useful would be to analyze the one they have at Diablo Canyon and try to be a part of it instead, if someone's dying to be on such a thing. Diablo Canyon is about 1000 times more likely to cause harm right here in Carlsbad, and more so in San Clemente, than even our spent fuel, because it's hot, it's running, and it's on an earthquake fault in a tsunami zone. It's got all the problems we had at SanO only it's still got 'em.

I'm surprised by this request because, of course, its main proponent is physically incapable of walking the site. But the main thing is: We have bigger problems than whether we get to look at the decommissioning process -- especially as frequently as the NRC plans to be there, at least in the beginning. I doubt we could safely go with them on inspection tours without several weeks of training in radiation hazards. Politicians don't get those kinds of tours either. And much of what they do is paperwork checking, anyway. However, if we're talking about a committee that discusses things such as we are doing now, I would certainly prefer that to the madness of last Thursday's debacle, when the citizens could have shown the NRC what such a committee could do. I would recommend the committee's meetings be open to the public for observation and comment, and experts be invited in when they come available. Hey, isn't that happening Oct. 19th? But the NRC won't be there? For shame. (Nor will I, but for personal reasons. At least I'll hear all about it from half a dozen different people.)
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 2: (from the Coalition) We were told by the NRC recently that high burnup has been used at San Onofre since 1996,. We cannot find a public notice of that from the NRC or SCE. The union and other workers we have talked with were not aware of its use. Was notice ever given to the public and workers? Were workers made aware that this high burn-up fuel is more than twice as radioactive?

Answer 2: (Spitzberg) San Onofre has been authorized to use and store high burnup fuel. It does have to remain in pools longer than conventional fuel for cooling – 7 years rather than 5. High burnup fuel will not be transferred from pools to canisters (casks) until this is certified as safe.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
2) I'm sure the workers who handled the fuel knew it was high burn-up and much more radioactive. I don't recall if Lyn, Sharon or I knew about it, but if I run across anything on the subject in my notes I'll let you know (what little goes back that far, other than my own LTEs that were published). What does go back in my documents shows that all the professionals were telling the public that dry cask storage would be "temporary." No one should be fooled thinking dry casks are "temporary." They are the most important containment system the fuel will ever have because they hold the fuel while it is the most dangerous.

I disagree with the 7 year figure for high burn-up's time in the pools; I think NRC's own experts are saying, generally, it's 15, and the NRC's own charts that Donna's dug up also suggest it will be 12 to 20, but not likely to be only 7. Perhaps our fuel is low-high burn up or something, so it can stay in the pools for less time. While lowering the density of pools will certainly increase safety, I am not convinced that removing ALL the fuel to today's idea of safe dry cask storage necessarily accomplishes the same goal. Our dry cask farm is NOT safe.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 3: How does high burnup fuel affect decommissioning, including on-site cask storage, and how much high burnup is on the site?

Answer 3: (Watson) The NRC collects data on spent fuel stored at the site. For any given facility, the amount is security-sensitive. The utility does not have to report on how much is stored.

The NRC agrees there is no way to monitor the behavior of fuel in sealed casks. We are sponsoring a demonstration project with the nuclear power industry to determine if high burnup fuel can be safely stored in dry casks for more than the 20 years we currently approve for the advanced cask model 24 P holding conventional nuclear fuel. In 20 to 25 years we will know more about the technology of casking.

For the record, the standard threshold for high burnup is 45 gigawatt days per metric ton of uranium. This level depends on the time the fuel is used at full power.

(Camper) There is a lot of interest in the characteristics of high burnup. We will make it a future topic for a public hearing.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
3) Security-sensitive? Well, that tells you the relative danger is certainly more with high burn-up fuel than with "regular" (lower U-235 content) fuel! The biggest security threat for several reasons would be from any rods that have not been used. They are the easiest to create a criticality with (I want to assume that, for example, they are stored far away from each other when they are on site). They are also the easiest to handle, you don't need lead, steel and cement shielding. If anyone wants to steal something "useful" to a terrorist, it's the fresh fuel -- any completely unused stuff -- most of all, and second-most, it's the fuel that didn't burn for very long. But that's much MUCH harder to steal than the fresh fuel, which can be handled relatively easily (if you have a crane). It should have been moved offsite to a much more secure place already if there was any on site, and I presume there was. All reactors that shut should, within 30 days or two weeks or something, be required to remove all unused fuel, if nothing else happens quickly, and they should not be allowed to receive it much in advance of emplacement in the reactor (which should not be allowed to operate anyway, of course). Also, see my most recent newsletter for more details on high burn-up:

http://acehoffman.blogspot.com/2013/09/high-burn-up-fuel-problems-multiply.html

Nearly 20 years into its use, it seems the NRC is a little behind in finally sponsoring a demonstration project to discover the potential hazards of long-term storage. This possibility was always on the table that long-term storage might be necessary and it should never have been assumed that it would be safe. It was never logical to assume a great nation like ours would find a desolate, unloved, ignorant enough, poor enough site for a national repository whose roof would leak onto 2-inch thick titanium over-shields and render the area unapproachable within a few centuries. Yucca Mountain was able to be stopped politically because eventually it was going to be stopped on technical grounds anyway.

I am delighted to hear that high burn-up fuel will be the subject of a future public hearing. Also nearly 20 years too late, though.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 4: MOX fuel has some characteristics of high burnup fuel. We understand that MOX was removed from San Onofre and shipped to the GE Morris facility. Does this create a precedent for shipping high burnup fuel?

Answer 4: (Camper) Some fuel units were removed from San Onofre between1972 and 1982 but MOX fuel was not among them, nor was MOX fuel ever shipped to GE Morris. It is still stored at San Onofre.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
4) MOX is fuel with additional Pu-239 in it. After burn-up it also has Pu-238, Pu -240, etc. etc.. These isotopes are both extremely hazardous -- even more so than Pu-239, but for comparably less time (Pu-238 half life is ~87.7 years; that of Pu-240 is 6563 years). This is by far the "best" dirty bomb material at San Onofre, and should have been removed to a militarily-defended location long, long ago. Leaving it here for decades sounds like negligence to me.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 5: ([Former] Mayor of Mission Viejo) Were there any problems with decommissioning Unit 1 and have NRC regulations changed since then?

Answer 5: (Watson) The decommissioning of Unit 1 was somewhat unique in one respect. We did a partial rather than unconditional release of the site because we determined that removal of the seawater intake would be more environmentally disruptive than keeping it in place.

(Spitzberg) The Unit 1 license has not been terminated because the reactor vessel is still on-site. I was Branch Chief during the Unit 1 decommissioning. The process went smoothly with the exception of one significant violation – leakage of liquid waste at a truck stop in Utah, which involved a citation.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
5) The containment, too, should have been left alone, at least for a few decades, but they "needed" the room for the dry casks. Demolishing many parts of a decommissioned reactor simply spreads the radiation around and serves no useful purpose.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 6: Were there health impacts as a result of the radiation release?

Answer 6: (Bob Evans, NRC Senior Inspector) The Utah leak was in 2006. The release was cleaned up on the spot.

(Watson) The NRC enforces regulations on transport. Waste cannot be transported in liquid form above a low level of radiation. However, we treated the spill as significant.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
6) Most NRC transport regulations simply assume that releases of more than about 0.000001% of a spent fuel's fuel load are impossible -- or, "beyond design basis" accidents. This is codified in the regulations by stipulating the definition of "robust" to mean, for example, a fall onto a 6 inch post from an 8-foot height. It does not mean being crushed by a bridge falling on it when the driver falls asleep and crashes into a bridge abutment, or simply misjudges his wide load. (A similar accident happened in Washington state recently, with a non-nuclear load.)
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 7: How will the use of money from the Decommissioning Fund be monitored and what will be the end goal of the process?

Answer 7: (Cynthia Walker, California Public Utilities Commission) The CPUC has oversight of decommissioning funds. Edison will file a plan and we will release funds for each stage. The site agreement with the Navy calls for greenfield status, for which California has requirements in addition to those at the federal level.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
7) "Greenfield"? We're dreaming, right? And no mention of the spent fuel.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 8: What is the role of the California Energy Commission in the process?

Answer 8: (Rob Ogilsby, Executive Director, California Energy Commission) CEC's focus is on a reliable electricity supply in the absence of San Onofre. We restarted an old non-nuclear power plant in the summer of 2012 when San Onofre shut down. Now that it is permanently closed we are developing plans for reliable power.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
8) No mention of a push for local solar rooftop incentives, offshore wind farms, demand-response, pumped-water energy storage, atmospheric vortex engines, a smart grid, or getting rid of SCE entirely and replacing them with community choice?
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 9: Who authorizes the use of high burnup fuel?

Answer 9: (Chip Cameron, NRC moderator) At the meeting in 10 days on waste confidence, I'll ask Paul Mitchelak from NRC about this matter. At that meeting we can discuss the generic environmental impact statement on spent fuel storage that NRC is developing as a national document. We are currently in the public comment period.

(note: the October 9 meeting referred to was cancelled on October 3 due to the government shutdown and has not yet been rescheduled).

>>>>>>>>>>>>>>>>>>>>>>>>>>>
9) The Spent Fuel issues are thousands of times, even millions of times more important than the whole rest of the "decommissioning" process combined. Yet it's mysteriously referred to as being in the "non-nuclear" or "non-radiation" portion of the decommissioning process in official NRC documents! One spent fuel rod, probably one spent fuel pellet -- contains more radiation hazards than the entire rest of the reactor.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 10: Given San Onofre's unique site characteristics, shouldn't there be a site-specific environmental impact statement for this facility?
Why was high burnup approved for San Onofre without credible proof that the long-term effects would have no measurable impact?

Answer 10: (Spitzberg) The heat level and the type of assemblies are reviewed by NRC specialists with regard to the type of cask proposed for storage. Historical data on the performance of specific designs is used to evaluate their appropriateness.

(Doug Brodis, NRC Office of Reactor Regulation) In the licensing process for fuel, the operator applies to use fuel and the manufacturer designs the fuel. A site-specific amendment request would be required to use that fuel at a particular plant, and there would be an opportunity for public comment.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
10) The NRC experts are saying there was no data for long-term storage of high burn-up fuel. Therefore, Spitzberg's answer is inaccurate because there was no relevant historical data. And is Mr. Brodis, NRC ORR, saying there were "hearings" in 1996, or just a notice in the Federal Register, or what?
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 11: (Dale ----) Have we learned the lessons of Fukashima? Why is it that while the entire coast of Orange County is rated as tsunami-ready, San Onofre is qualified only as storm-ready? Don't the cooling ponds in particular need to be moved inland?

(no specific reply)

>>>>>>>>>>>>>>>>>>>>>>>>>>>
11) There were many lessons from Fukushima, including that human failure is an inevitable factor in emergencies, in preparation, in "standard operating procedures," in record keeping, in clean-up, and in every other phase of every operation (including letter-writing). NRC has the audacity to believe that every part that is shipped to every reactor has been properly manufactured to NRC-licensed specifications. This absurdity is blatantly described, right in the SanO special panel's own documents (the panel that was recently and inappropriately disbanded).

Another lesson that should have been learned is that clean-up of a melted-down reactor is a far more difficult process than the NRC anticipates, and that the Price-Andersen Act needs to be adjusted accordingly.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 12: (Larry Kramer, San Juan Capistrano City Council) It has been noted that the Unit 1 reactor vessel is still on site. Will the same be true with Units 2 and 3?

Answer 12: (Spitzberg) Spent fuel remains as well. Unit 1 was shut down in 1992 and surface structures related to spent fuel were removed but sub-surface structures are still there with low-level waste. This is a case of "phased decommissioning."

(Watson) Edison will have to determine how to handle the large components. Trojan barged its on the Columbia to Hanford, Washington. Yankee shipped its by sea to South Carolina.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
12) It should be noted that there is no safe place in this world for nuclear waste, and the costs of disposal, if SCE waits, are likely to skyrocket -- especially for disposing of the spent fuel, for which there is no national plan and no nation on earth should think they have a good plan. Nuclear waste does not belong on this planet. (I am not, however, recommending attempting to move it though the space debris field that surrounds earth by any means.)
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 13: (Marnie Mangen, Laguna Beach City Council) The tsunami danger is great. Spent fuel pools are an accident waiting to happen. How do we get the NRC involved so the process doesn't take 60 years? Have you licensed any type of cask for transport?

Answer 13: (Spitzberg) In reply to the question are casks transportable, models 24 PT 1 and 24 PT 4 have been so certified. 32 HP 2 has not yet been certified but Edison has applied for this.

(Camper) We review and ask questions regarding the PSDAR (Post-Shutdown Activities Report but there is no requirement that the NRC approve that report. The activities involved in decommissioning were evaluated as part of the EIR (Environmental Impact Report) during the original license review and approval.

The 60-year time frame is to allow reduction of radiation levels by 99% and volumes by 90% so that transport of spent fuel is less difficult. In both cases the key is rapid decay of one radioactive element - cobalt 60.

A repository for high-level nuclear waste is a significant national issue. The Department of Energy is seeking sites. The NRC would issue the license. This is a very complicated national problem.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
13) Referring to the lack of a national repository as merely "a significant issue" is still ignoring the fact that there is no solution to the waste problem, yet the NRC allows utilities to create more waste! As a Japanese university nuclear physicist said about Fukushima, it's like building a mansion with no sewage facility. No matter how nice the mansion is, how long would you live in it after the toilets backed up? Spent fuel serves no purpose to humanity yet has the ability to wipe us all out, destroy our homes, our property values, our DNA. It is about 10 million times more hazardous than "Depleted Uranium" -- a significant hazard in its own right -- and about a million times more hazardous than even so-called "high burn-up" fresh fuel. Transporting it raises significant hazards including accidents, mishandling, and sabotage. The pellets in high burn-up fuel have fused to the cladding and the stresses are completely different from what they would be if that had not happened. Any cladding failures will release far more fission products to the environment than for "regular" fuel.

To refer to the lack of a national repository as merely a "complicated problem" belies the reality: There is no place on earth for spent fuel. So stop making more at Diablo Canyon and Palo Verde, too. Force Southern California Edison to take back ownership of the spent fuel it created and creates at Palo Verde, of which is a part-owner. If the federal government stopped taking legal possession of spent fuel, every reactor would shut down tomorrow. But the feds take it with nowhere to put it. Reprocessing is preposterous.
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Question 14: (Chris ---------, San Clemente) Is the Yankee reactor successfully decommissioned? (note: Yankee Rowe or Connecticut Yankee, both decommissioned in 2007?)

Answer 14: (Watson) Yankee is absolutely clean. At San Onofre, ground water is monitored to detect any leaks.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
14) Incomplete response from the NRC, especially insofar as, the area under the domes probably has leaked tritium, and has not been monitored and won't be until the domes are removed.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 15: (from the Coalition) Will the NRC allow the resale of non-radioactive equipment and secondary side components, some of which are almost new? If they are sold, will the proceeds go to offset the cost of decommissioning.?

Answer 15: (Cynthia Walker, CPUC) The NRC is not involved in the sale of non-radioactive materials. The PUC is involved. It is out intent that proceeds from the sale of any such items would be applied to offset the cost of decommissioning.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
15) What is the definition of "non-radioactive," expressed in milliSieverts or some other numeric value?
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 16: (from the Coalition) Will public announcements be made whenever any "allowable" toxic waste is to be released into the environment. What the upper limits are for releasing radiation and toxic chemicals during the decommissioning process? When were those limits established and what would trigger a process to reevaluate those limits?

Answer 16: (Watson) Regulations on [monitoring] releases are decades old. They apply to decommissioning. The NRC monitors releases that are radioactive. Others are based on state permits.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
16) Radiation is far more dangerous, especially to fetuses, infants, children and women, than was believed decades ago. Ergo, one would assume the regulations which are decades old are far more lax than they should be.
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Question 17: (from the Coalition) Will the NRC have staff on site during decommissioning?

Answer 17: (Watson) We will have a full-time senior inspector on site during decommissioning for a year and perhaps longer.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
17) I think a year is very optimistic of the NRC considering that SCE doesn't even need to submit a plan until 2015! And I think all ISFSIs should have onsite NRC staff for when something finally happens, as is bound to occur sooner or later. Can't look inside? That's pretty poor planning, too.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 18: (Marsha Padd) What are the safeguards addressing security risks that could endanger the integrity of the plant?

Answer 18: (Spitzberg) There is a security force on site and there are security systems. (Camper) Spent fuel will remain on site for some period either in pools or dry casks. Most waste is low-level class A and a small portion is Class C, which is in canisters. Level A can be treated at facilities in Utah and Texas after USDOT-approved transport to a commercial facility.

(Watson) An aircraft hit on a nuclear plant has been significantly studied. A drone hit would be well within the parameters that the facility could withstand.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
18) The spent fuel is the part that needs a significant security force. Instead it will have one guy with a pop gun.
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Question 19: (questioner name) Have the effects of climate change on sea level been evaluated in its impact on major ocean storms that might impact San Onofre?

Answer 19: (Camper) The effects of climate change would be part of our generic Environmental Impact Statement. In the case of San Onofre, this relates primarily to the use of equipment on site that emits greenhouse gases.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
19) Nineteen was not answered in any way by the NRC. Greater-than-previously-anticipated tsunamis should be expected and dealt with by removing the spent fuel to a safer location.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 20: (Ray Lutz) Given its importance in terms of both economic and environmental impacts, why doesn't the NRC sign off on the PSDAR? This seems like a significant gap in the process.

Answer 20: ((Watson) The rationale for why the NRC does not approve PSDARs came from the Commission itself as a policy decision, the basis of which was that decommissioning could be done safely under the existing license because the operational phase covered by the license is inherently more dangerous and requires a higher level of risk management.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
20) Spent fuel makes the decommissioning process extremely risky and the decommissioning process is significantly different from operating a reactor. It can be (and is being) argued that special experts should be hired to do the decommissioning process, instead of SCE, who don't seem to be experts in much of anything these days. But hiring a whole different company should certainly require new licensing procedures.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 21: (Ray Lutz) Is that an adequate level of oversight, given that decommissioning involves distinct risks that were not present during operations?

Answer 21: (Watson) The process isn't over until the License Termination Plan (LTP) is accepted, and the NRC does approve this. The LTP is a critical part of decommissioning.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
21) The License Termination Plan does not require "greenfielding" does it? Or removal of the spent fuel?
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 22: (questioner) What is the reason all nuclear plants have facilities for indefinite storage of dry casks ?

Answer 22: (Camper) Since we have no repository that can handle spent fuel over geologic time, every decommissioned plant has cask storage on site as a response to this situation.

There is not only no long-range site but no interim storage site. A high-level policy recommendation has been made to establish one or more interim sites. A Utah-based company was issued a license to do this but did not gain federal support on a rail line to service the site. Counties in New Mexico, Mississippi and South Carolina have all expressed interest in being designated as interim sites.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
22) It is absurd to pretend a solution is forthcoming in Mississippi, New Mexico, South Carolina or anywhere else. ANY solution will involve a violation of people's basic human right to life -- which requires clean air, land, and water. No state governor will ever be elected who will allow his or her state to become the nation's permanent [solution] for nuclear waste. Violating States' Rights on this matter is not something the NRC can rely on. Therefore, presuming any solution is forthcoming is the height of absurdity. And that's not even considering that the Yucca Mountain scientific team was allowed to consider any other solution, except deep geologic repository somewhere other than at Yucca Mountain. There were and are no "better" solutions. There are no good solutions to the problem of nuclear waste.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 23: (David Weisman, Alliance for Nuclear Responsibility) Could the movement of spent fuel from pools to casks be expedited? The California energy Commission has recommended this for years. The California Public Utilities Commission controls the use of decommissioning funds and could allocate some of them for this purpose. Shouldn't this be done?

Answer 23: (Dusaniwskyj) The licensee must first decontaminate the facility. At that point, the NRC has no further jurisdiction.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
23) Expedited transfer to dry casks will accelerate the problem of transfer out of dry casks into something better later. Our dry casks as currently designed are insufficient.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 24: (Richard Gardner) What is the current volume of waste and what will be the peak year for decommissioning America's 100 nuclear plants?)

Answer 24: (Camper) The Nuclear Energy Institute says the next bow wave of decommissioning activity will be in the 2035 – 2055 period, premised on all nuclear plants being decommissioned at some point. In the last 12 months, five plants have suddenly announced decommissioning. This has caused us to do a careful review of potential readjustments.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
24) Let's hope the rest of America's misguided nuclear "fleet" is decommissioned far sooner than NEI projections -- starting with Diablo Canyon and Palo Verde on the west coast, and Indian Point, Oyster Creek, Salem, etc. on the East.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 25: (Patrick -----------, Marine Corps Environmental Staff, Camp Pendleton) How does the NRC intend to coordinate with California state requirements as you move toward unconditional release of the site?

Answer 25: (Camper) Some states, including Maine and Connecticut, have developed their own decommissioning standards. California could do the same in cooperation with the Marine Corps.

We seek neither to prolong nor to expedite decommissioning but to adhere to the required process. Ninety percent of our budget comes from fee recovery from the nuclear industry.

>>>>>>>>>>>>>>>>>>>>>>>>>>>
25) I think the Marines would like their land back. I'm not sure they realize the hazards of using explosives near high burn-up fuel.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Question 26: (Pete Dietrich, Edison Chief Operating Officer, San Onofre) The repeated reference to "greenfield" status in the NRC's opening presentation suggests that when decommissioned sites go on unrestricted release, they return to what appears to be natural open space. But isn't it true that in this case Edison must satisfy only the land use requirements of the U.S. Navy, which owns the land as part of an active military base?

(Note: before the hearing began, Edison informed NRC staff that a group of its employees were in attendance and did not wish their presence announced nor questions directed to them but did reserve the right to make a closing statement).

>>>>>>>>>>>>>>>>>>>>>>>>>>>
26) Interesting behavior on the part of SCE staff.
<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<

###

======================================
Correspondence regarding above questions:
======================================

At 06:51 PM 10/3/2013 -0700, Glenn Pascall wrote:
>John,
>
>Thanks again for the detailed response and rapid turnaround. I've received expressions of appreciation from several members of the Coalition.
>
>We understand that NRC staff have only Friday and Monday and it will actually be illegal for you to continue working Tuesday and beyond due to the government shutdown.
>
>Because of this situation, I'm getting to you ASAP the companion document to the one you just reviewed. It summarizes the Q-and-A at the evening session on September 26th.
>It would be terrific if your group at NRC could get back to us with a similar response. Given the short timeline you face, we will certainly understand if that's not possible.
>
>Truth in packaging: This second doc is based entirely on my notes and did not have the foundation provided by NRC's power point as with the previous document. I am sharing this
>draft with key members of our working group as well as with you and Larry and Bruce. Please pass it on to Blair and Mary Woolen as well.
>
>One specific option I invite you to use is to "revise and extend" any comments and answers, as they do in the Congressional Record. You will see that when the record of discussion
>is in cold print, a number of replies seem pretty much complete but others are less satisfactory or even a bit off topic. If you wish to close the gaps and fill in the blanks, feel free.
>
>I apologize to you and to the citizen rep's I'm sharing this with for any errors in identifying questioners and respondents, and any misstatement of questions as well as answers.
>
>
>Thanks very much for joining us in this exercise in transparency as we all seek to move toward an environmentally safe and economically fair decommissioning of San Onofre.
>
>
>Sincerely,
>
>Glenn Pascall, Chair
>San Onofre Task Force
>Sierra Club Angeles Chapter
>
>
>From: "Hickman, John" <John.Hickman@nrc.gov>
>To: "gpascall@att.net" <gpascall@att.net>
>Cc: "Camper, Larry" <Larry.Camper@nrc.gov>; "Watson, Bruce" <Bruce.Watson@nrc.gov>
>Sent: Thursday, October 3, 2013 6:14 AM
>Subject: RE: Written summary of your team's 9/26 presentation
>
>Mr. Pascall,
>
>I am replying to your request on behalf of Mr. Camper. Attached is a copy of your meeting summary that has been reviewed by the NRC presenters and other NRC attendees of the public meeting on decommissioning. Our suggested edits are noted in red. Please let me know if you have any questions regarding any of the changes.
>
>Thanks,
>
>John B. Hickman
>Reactor Decommissioning Project Manager
>301-415-3017
>
>From: Glenn Pascall
>Sent: Monday, September 30, 2013 7:21 PM
>To: Camper, Larry
>Cc: genston@sbcglobal.net; george.watland@sierraclub.org
>Subject: Written summary of your team's 9/26 presentation
>
>Larry,
>
>I enjoyed our brief visit after the meeting of NRC staff and public representatives in Carlsbad last Thursday morning.
>At the evening session I focused on closely following what was said. Attached is my summary of your team's opening presentation
>based on the hard copy of power point you provided plus my notes of verbal comments made by team members as they presented.
>For the record, none of this text was done by electronic transfer. I entered this entire document on the keyboard.
>
>We would like to post this summary on the Sierra Club website as public information, and would appreciate your forwarding the attached
>draft to those who spoke and also to Mary Woolen, with whom I visited on these matters at some length. Please feel free to offer any
>suggestions for accuracy or completeness. I made a couple of changes, including moving the discussion of economic issues to the
>end of your opening segment, where it seemed to fit best. Also, as a longtime reporter, I added context in a few cases where a key word
>appeared by itself on a power point. Please let me know if this resulted in any misinterpretation. I will prepare a separate document
>later this week that will summarize questions and answers during the morning and evening discussions.
>
>Thanks for facilitating NRC input on the attached document.
>
>Best regards,
>
>Glenn Pascall, Chair
>San Onofre Task Force
>Sierra Club Angeles Chapter
>
>

-----------------------------------------------------------------

Summary Highlights
Questions and Responses

U.S. Nuclear Regulatory Commission
Hearing on Decommissioning San Onofre

September 26, 2013
Carlsbad, California

[SEE ABOVE FOR Q&A]

======================================
Newsletter author:
======================================


-----------------------------------------
Ace Hoffman, computer programmer,
author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Subscribe to my free newsletter today!
Email: ace [at] acehoffman.org
-----------------------------------------

Thursday, September 26, 2013

High Burn-Up Fuel: The problems multiply...

High Burn-Up Fuel: The problems multiply...
The Power Is Gone,
The Danger Lives On & On.
Spent fuel is hot stuff. It's thermally hot -- about 400 degrees Fahrenheit. That's not residual heat from when the fuel was in the reactor, it's decay heat from fission products with relatively short half-lives - from days or weeks to about 30 years for most of them (most isotopes of iodine, cesium, strontium, etc.). The fuel will stay well above the boiling point of water for centuries or even millennia, although the temperature will keep dropping over time.

(Note: The term "short" for the half-lives of most fission products compares to Uranium, which is a billion years or more, or even Plutonium, which is 10s of thousands of times more radioactive (SHORTER half-life) than Uranium. Fission products are thousands of times more deadly than that, not counting Pu and U's heavy metal horrors.)

And speaking of the boiling point of water, above that you get steam. Steam is particularly hazardous to the zirconium cladding of the fuel rods. The zirconium separates the hydrogen from the oxygen in the water molecules of the steam, and the hydrogen atoms combine with each other as H2, which is explosive. Because it's so hot and radioactive inside the dry cask, they can't monitor this process near where it's happening, inside the "dry" cask. They need to monitor the water content, as well as the hydrogen, oxygen, helium, and "fission gasses" that are emitted.

After draining the fuel rods by slowly lifting the entire dry cask assembly out of the spent fuel pool (about 15 years after it was used in the reactor) about 25 gallons of water will remain in the fuel assemblies in the dry cask. This water must be removed through repeated drying processes which are only partially successful each time. After that, water seepage into the dry cask is also an ever-constant threat.

There are now about 50 and will be approximately 150 dry casks at San Onofre. Each one will need a constantly-operating monitoring system to know the levels of hydrogen and other gasses in each cask. Such systems have not been designed for horizontally-stored casks such as are used at San Onofre. Instead, walk-by monitoring will be done for escaping radiation. That's not sufficient.

The threat of water intrusion comes from many sources. The dry casks will supposedly be submersible to 50 feet of water, according to regulations. But on the other hand, they will barely be above sea level, and the California State coast and waterways brochures state that everywhere along California's coast, 50 foot tsunamis are possible. Should we risk these "dry" casks on a coast with 9 million people within 50 miles and with so little margin of error?

In some ways, it's too bad the fuel isn't hotter, because if the temperature is above the "brittle/ductile boundary temperature" (which varies for every alloy of cladding and everything else in a fuel rod assembly) then it's much easier to move. But instead, the fuel has been cooling to well below that temperature, and now it's very brittle and difficult to deal with. As it gets older it also gets more and more embrittled, and so, even more difficult to deal with. That is where we are heading here at San Onofre.

Additionally, in high burn-up fuel, the ceramic pellets of Uranium Dioxide, which forms the bulk of the mass of the fuel rods (uranium is 1.7 times more dense than lead) fuses to the zirconium cladding. This is a very serious problem during later transport of the fuel, especially during postulated (let alone, greater-than-postulated) accidents, because the weight of the fuel on the ring of zirconium cladding is all concentrated on the very thin areas between the fuel pellets. So a force that was supposed to be spread out along the length of a pellet (about an inch) is instead borne nearly entirely by mere fractions of a millimeter. A crack means deadly fission products escape, a full rupture of a fuel rod means pellets drop out and could cause a criticality event when they gather at the bottom of the cask.

There are no shipping containers which the NRC has licensed for transporting high burn-up fuel, and worries about criticality events is one reason why. There aren't even any dry cask storage containers which have been licensed beyond the 20-year period for storage of high burn-up spent fuel. As recently as last March, the NRC's own experts can be heard at a meeting stating that tests for the quality of such containers should take at least 10 years to conduct -- and that's after the regulators have already conducted preliminary experiments to determine the type of testing that needs to be done! But it's the nuclear industry's job to actually do the tests (according to the NRC). The tests need to be done for each type of cladding. All zirconium alloys behave uniquely, and the industry hasn't even started to develop a plan for a test, let alone started a test of their systems for long-term storage or for transport afterwards.

However, despite these "known unknowns," high burn-up fuel IS being used around the country, and IS being loaded into dry casks, which are currently licensed for up to 20 years sitting on site wherever they happen to be produced. Never mind the pressures from vibrations of ocean waves and rails and truck routes a few feet away and all those unknowns. Never mind that there is no national plan to move the fuel ever. Never mind all that, so that operating reactor sites can keep making more waste.

High burn-up fuel allows reactor companies to keep operating even when they would otherwise be unprofitable. It also wears out the steam generators and/or other components of the reactor faster*. It's no bargain for society to let the utilities get away with using high burn-up fuel!

Ace Hoffman
Carlsbad, CA

* It should be noted that it's usually the ratepayers who pay for the repairs.

NRC symposium on high burn-up spent fuel:

http://www.nrc.gov/public-involve/conference-symposia/ric/past/2013/docs/abstracts/sessionabstract-24.html

(curvature exaggerated for illustration purposes)