Thursday, December 31, 2015

Re: SONGS story to air (my response to David Victor)

Here's my opinion of Mr. Victor's management of Southern California Edison's Citizen's Engagement Panel, prompted by his dressing-down of a local reporter over an upcoming news item (expected to be aired this evening).

Best regards,

Ace Hoffman
Carlsbad, CA

Postscript: Here is the news story on the internet:

http://bit.ly/1UiNzcI

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

Mr. Victor,

Outside your ivory tower, today was a work day for most working-class people. And the news never sleeps.

It's a lot like rust in that respect -- something that should concern you greatly, since you are helping "authorize" (although you claim to have no "authority" and no power) the storage of extremely large quantities of extremely poisonous, extremely delicate, extremely "hot" (radioactively and thermally) nuclear waste in our midst (in rust-prone "stainless" steel containers).

The waste is dangerous for hundreds of thousands of years and could remain at San Onofre for centuries (or longer). You say you want it moved out of here, of course, but that's not the reality. And you've done nothing to prevent a catastrophic release at Diablo Canyon, having learned nothing about how much LESS dangerous nuclear waste is even just a few years after the reactor is shut down. Can you imagine being responsible for something that is a thousand times more dangerous than spent fuel, and a thousand times more likely to suffer an accident? That's the sorry situation at Diablo Canyon, but you've said nothing to them about what a mess you have on your hands here -- a mess that grows every day in San Luis Obispo, but fortunately, is no longer growing here.

My humble opinion, having attended (and filmed) many of the CEP meetings, and watched all but one of the rest of them, is that you were picked for the job because someone at Southern California Edison was sure you would do their bidding. And they have no intention of getting rid of you, I'm sure of that.

From early on, you've been cutting off discussions you don't like. From early on, you've helped SCE ignore the fact that by delaying demolition of the reactor site for up to 60 years, SAFSTOR reduces exposure to radiation, for both workers and the public. The cumulative dose (especially to workers) is much higher if we demolish the plant sooner rather than later. But SCE doesn't want to wait, so...neither do you.

SCE wants to move forward, but probably for financial reasons. What's your reason? SCE also has willing workers (who presumably are unaware of the full extent of the dangers). Who knows who they'll be able to find to do that dirty work in the future?

One thing there is unlikely to be in the future is a cheap place to store the waste. Few options are available for long-term storage of the radioactive debris from decommissioning, and those options are becoming more and more rare, and more and more expensive. So Edison certainly feels it's in their best interest to dismantle SanO quickly, but is it in ours (including the workers who eagerly wish to be irradiated)? And what's best for America? To "solve" one nuclear waste problem by creating another one somewhere else?

Google "Cactus Crater Marshall Islands" to learn what a mess nuclear "experts" have made of long-term storage of irradiated debris in the past. The cement dome is cracking, water is leaching in, radionuclides are leaching out, and the radioactive metals dumped in the middle of the lagoon are being brought to the surface for scrap by poor natives, and then sold to unscrupulous buyers who recycle the metal into everyday things.

So even the broken-up radioactive cement -- and the dust -- will have to be guarded for centuries! And you're in charge. Can't work holidays? Somebody's got to do it.

But the debris from decommissioning, and the worker exposures during the process, are minor worries compared to thinking about the spent fuel. 365 days a year -- for what is essentially an eternity (thousands of years), it will have to be guarded. Someone will have to not be with their families, not just holidays, but day and night, 24/7, as long as it's here and probably a lot longer than that. In thin casks, in a corrosive environment (our beach).

You say that the spent fuel is "just one of many issues" and evidently don't seem to grasp that it's almost the ONLY issue.

Every day that waste sits here, it's vulnerable to earthquakes, tsunamis, airplane strikes (accidental or otherwise), terrorist attacks, and decaying, cracking, embrittling metallurgical issues. For a couple of hours every three months, you control a room full of people, most of whom haven't got any idea of the biological consequences of their decisions. Nor are they aware that the Nuclear Regulatory Commission is practically clueless about what condition the cement will be in, or the metals. Nor does the NRC know of any way of inspecting the casks on the inside -- or much of the outside. They know of no way of burrowing below the cement base to check on the condition of the Holtec Honeycomb-Style Waste Storage Pits without risking structural damage, water intrusion damage, etc.. Cement experts weren't invited to your CEP meetings, but they were invited to speak at some NRC hearings this past summer (which is how I know the NRC is practically clueless). I don't think you were in attendance then, nor, as far as I can tell, are you at most of the NRC hearings on San Onofre issues (I attend (and record) as many of them as possible). You certainly don't speak up if you do attend.

Holtec has decided not to use reinforced concrete overpacks in the spent fuel "islands" (ISFSIs) they want SCE to buy (with ratepayer money, of course). No demolition experts were invited to the CEP to knock holes in that decision!

You never allow enough time for public comment, and it's far too rigidly controlled. If a lot of people show up, you act like you're running some sort of government hearing and cut down the minutes each person gets to speak. You actually have used the lamest excuse of all -- that the room was only rented for so long, and no longer! (The seats are dreadfully uncomfortable in Oceanside, so I guess when the meetings are held there, it's just as well they're short.) SCE can afford better. The CEP chairman should demand it.

Any lost time during the "main" portion of the meeting invariably comes out of the public comment period at the end. Panelists will not respond to questions they don't like -- just like a government hearing.

You act like you think you're king of something -- and you are: You're king of the most deadly substance in California. Your efforts are a major factor in determining how that deadly waste will be guarded -- or not -- for the next 300 years -- or longer.

You're forcing it down our throats. And don't say it's not your fault that the waste is (still) here. I've attended more than 20 years of hearings on San Onofre. Never saw you at one before the plant closed. So you had decades to help shut the plant down sooner, knowing -- as we all knew, who bothered to look -- that there was no place to put the waste once the plant closed. So yes, of course it's your fault as much as anybody's.

In short, you've done little since the beginning except push SCE's agenda -- and you ignore criticism. Regarding the upcoming NBC news item, it's very specifically concerned about statistical shenanigans Southern California Edison has apparently been playing for years -- that directly relate to their ability to properly and safely dismantle a nuclear power plant! Specifically, the allegation is that they co-mingle measured samples from highly contaminated areas with measurements from lightly contaminated areas in order to achieve a passing level in the NRC's far-too-lenient allowable releases. Such behavior leaves a lot of room for bias, if not outright cover-up of accidental large releases. It's a serious allegation which evidence clearly suggests was happening.

So I find it strange that as head of the Citizen's Engagement Panel, you would have no comment yourself!

Except, of course, that all this was to be expected. The very purpose of the CEP has been, and IS, to block activists from "controlling" the conversation. With your efforts the CEP has done far better than SCE, NRC or NEI could ever have imagined -- SanO's public participation system for decommissioning a reactor is being held up nationwide by the nuclear industry and even the NRC as a great example of how to do it right! You've even traveled across the country to talk about it, haven't you? (The only time you've spoken at an NRC event, as far as I can recall. Correct me if it's what bothers you about this letter, of course. Was it NEI you spoke to? Or both?)

In the two years during which you've almost completely controlled the post-near-apocalyptic-steam-generator-failure discussion about San Onofre's terrifying legacy of nuclear waste (pun intended), you've accomplished nothing that has helped get the waste removed, and blocked activist's attempts to get better, thicker dry casks and stronger cement overpacks (steel reinforced, for starters, with drainage systems for jet fuel to be removed in well under 20 minutes).

Citizens attempting to work with SCE through the CEP have found it a fruitless endeavor in large part due to your attitude towards opinions you don't share. You've listened to nuclear industry representatives for many hours -- not experts (except Dr. Singh, of course) but merely salesmen -- tell bald-faced lies to the CEP panelists and said nothing. But you control the conversation immediately when any activist -- or even other panelists -- try to speak out on any subject you don't agree with.

Ace Hoffman
Carlsbad, CA


At 12:05 AM 12/31/2015 +0000, David G. Victor wrote:
>Dear JW August
>
>At 11:14am this morning you sent me an email requesting comment from me and the Community Engagement Panel on a story that, I gather, your station has already completed and intends to air tomorrow evening. Barely two hours later, at 1:01pm, you sent an email to 39 people (to which I am replying all) that elliptically suggests that the Community Engagement Panel (which I chair) has failed to comment. That is an extraordinary claim that has no basis in fact nor does it reflect any reasonable standard for professional news reporting.
>
>Nearly the entire nation (myself included) is on vacation this week and we are not sitting next to our email, ignoring our families waiting to respond to your random requests for information. You have been working on this story for months and yet you demand, in the middle of a holiday with no advance warning, responses to a complicated story for which the facts really matter. And your offer a schedule that allows no realistic opportunity to do a thorough review of all the materials and solicit feedback from a wide array of sources so that we can help provide to the public truly accurate information about the decommissioning process. I saw your earlier (Sept 22, 2015) story and was deeply disturbed by your reliance upon unnamed expert sources as well as on-camera interviews with individuals who are engaged in other legal actions that clearly raise questions about the reliability of their information. For such reasons I would want to be doubly careful before commenting that I had seen all the materials you allege to have on hand and read the full reports—not just pluck phrases out of context here and there. My interest is in accuracy—not sensatiionalism.
>
>Your email to me this morning referred to earlier requests for information on 11 December and 18 December. Yet those emails were addressed “To Whom it May Concern” and sent to a list of people (copying me) with sprawling, unfocused questions that referred to unnamed “experts” regarding how "SCE does damage control.” You also demanded to know if SCE or the Navy were “lying.” These questions are the stuff of gotcha campaigns and not a serious, focused and professional exchange of information aimed at obtaining the truth. Moreover, those questions seemed to be addressed to SCE and other officials on your email list—not to me. You should not,, in any way, pretend that because I happened to be copied on those messages, which were not addressed to me, that I or the Community Engagement Panel has been unresponsive. If you report that in your new story you will be reporting information that is willfully inaccurate.
>
>The Community Engagement Panel is not a watchdog agency. It does not investigate SCE, NRC or any other body that has formal decision making and regulatory responsibilities at the plant. Nor is our job to defend or promote those organizations. We are a group of 18 volunteers who are providing a conduit of information. We help provide SCE with information about what concerns the public—informmation that has led to an array of tangible changes in how SCE is implementing its decommissioning process. And we help provide the public with information on the process of decommissioning—including information that iss often steeped in jargon and technical detail that we help translate so that it is accessible to everyone. We are particularly focused on the plant itself whereas much of your reporting seems to be focused on events back in the 1980s on the Mesa site—across the road from thee main plant. Mindful of our role as a conduit for information, we have circulated links to your earlier reports and discussed them and also circulated copies of responses from SCE to your reporting. And we will do the same as new stories appear. Beyond that, I don’t see that there is a specific role for us in your story.
>
>With best wishes for the New Year,
>
>David Victor
>
>
>
>
>From: "August, J.W (NBCUniversal)" <JW.August@nbcuni.com>
>Date: Wednesday, December 30, 2015 at 1:01 PM
>To: Maureen Brown <Maureen.Brown@sce.com>, "Saunders, Lee H CIV NAVFAC SW" <lee.saunders@navy.mil>, "pendleton.media@usmc.mil" <pendleton.media@usmc.mil>, "OPA4.Resource@nrc.com" <OPA4.Resource@nrc.com>, "Donovan, Stephanie" <SDonovan@semprautilities.com>, "info@coastkeeper.org" <info@coastkeeper.org>, David Victor <david.victor@ucsd.edu>, Dan Stetson <dstetson@ocean-institute.org>, "lisa.bartlett@ocgov.com" <lisa.bartlett@ocgov.com>, "Smith, Steve" <steve.smith@10news.com>, "Lightfoot, Anita" <Anita.Lightfoot@sdcounty.ca.gov>, "August, J.W (NBCUniversal)" <JW.August@nbcuni.com>, "Walsh, Lynn (NBCUniversal)" <Lynn.walsh@nbcuni.com>, Michael Aguirre <maguirre@amslawyers.com>, Bart Ziegler <bziegler@toxco.net>, Ace Hoffman <rhoffman@animatedsoftware.com>, Daniel O Hirsch <dhirsch1@cruzio.com>, Vinod Arora <vinnie48in@gmail.com>, Mark Sauer <MSAUER@kpbs.org>, "pfinn@kpbs.org" <pfinn@kpbs.org>, "tom@sdnews.com" <tom@sdnews.com>, "julie@sdnews.com" <julie@sdnews.com>, Jamie Court <jamie@consumerwatchdog.org>, Jamie Hampton <jamie@sdcoastkeeper.org>, "travis@sdcoastkeeper.org" <travis@sdcoastkeeper.org>, Diane Takvorian <Diane@environmentalhealth.org>, "Adams, Andie (NBCUniversal)" <Andie.Adams@nbcuni.com>, "Galindo, Ramon (NBCUniversal)" <Ramon.Galindo@nbcuni.com>, noverflo <noverflo@aol.com>, "harvey@consumerwatchdog.org" <harvey@consumerwatchdog.org>, JW August <jwaugustsd@gmail.com>, "Giametta, Salvatore" <Salvatore.Giametta@sdcounty.ca.gov>, "Ernie Cowan (Ernie@nsdcar.com)" <Ernie@nsdcar.com>, "Goldstein, Daniel" <dgoldstein@marketwatch.com>, PEACE RESOURCE CENTER <caroljahnkow@gmail.com>, "maryannepintar@gmail.com" <maryannepintar@gmail.com>, Bree Walker <breewalker2263@gmail.com>, "2263@gmail.com" <2263@gmail.com>, "anchor@studio45.tv" <anchor@studio45.tv>
>Subject: SONGS story to air
>
>As of this date, December 30, 2015, neither of the principals in this story, SCE & SDGE, have commented.
>The first request for comment was e mailed on December 11th, a follow up on the 18th of December. The request for specific comments to allegations is shown below and was sent to both SDGE and SCE as the responsible parties on the lease of the SONGS
>property.
> Of the agencies copied on this request for comment, only the NRC provided any feedback.
>The Community Engagement Panel, which is tasked with being the public’s eyes and ears on the shutdown of SONGS, has also been asked for comment. Several members of that panel are included in this e mail.
>You will find in the attachments with this e mail the criticisms of our original story.
>That story can be seen at:
>http://www.nbcsandiego.com/news/local/Documents-Detail-How-Nuclear-Material-Was-Handled-at-San-Onofre-328292351.html
>The updated story on the SONGS land will air in the 6pm broadcast tomorrow night on KNSD in San Diego. In addition, on the KNSD website will be the companion story with links provided for
>documents used in producing this story.
>
>
>Here is the request for comment:
>From: "August, J.W (NBCUniversal)" <JW.August@nbcuni.com>
>Date: December 18, 2015 at 5:15:16 AM PST
>To: JW August <jwaugustsd@gmail.com>
>Cc: "maureen.brown@sce.com" <maureen.brown@sce.com>, "lee.saunders@navy.mil" <lee.saunders@navy.mil>, "pendletonmedia@usmc.mil" <pendletonmedia@usmc.mil>, "OPA4.Resource@nrc.gov" <OPA4.Resource@nrc.gov>, "OPA.Resource@nrc.gov" <OPA.Resource@nrc.gov>, "sdonovan@semprautilities.com" <sdonovan@semprautilities.com>, "info@coastkeeper.org" <info@coastkeeper.org>, "david.victor@ucsd.edu" <david.victor@ucsd.edu>, "dstetson@ocean-institute.org" <dstetson@ocean-institute.org>, "Lisa.Bartlett@ocgov.com" <Lisa.Bartlett@ocgov.com>, Steve Schmidt <steve.schmidt@sdcounty.ca.gov>, "anita.lightfoot@sdcounty.ca.gov" <anita.lightfoot@sdcounty.ca.gov>, "Walsh, Lynn (NBCUniversal)" <Lynn.walsh@nbcuni.com>
>Subject: Re: 2nd request for comment on KNSD report on SONGS, second story in series
>On Dec 11, 2015, at 3:48 PM, JW August <jwaugustsd@gmail.com> wrote:
>To whom it may concern
>We are preparing to â€&lsqauo;broadcast and webcast a story regarding the SONGS plant â€&lsqauo;in the near future regarding SDGE/SCE lease with the US Navy and the condition of the land around the plant that was under the control of SCE/SDGE partnership.
>Our initial story resulted inâ€&lsqauo;no response from SDGE and SCE did not provide any specific comments for the story even though they had a advance copy of the story and ample time to respond. We were referred to the SCE website press releases andvideo press conferences where various unrelated comments and statements were made. Eventually SCE’s public information â€&lsqauo;office did provide a more through response â€&lsqauo;accusing KNSD of scare tactics, shoddy reporting, calling the story sensational and inaccurate. The utility requested corrections to be made to the original story. For the record, â€&lsqauo;KNSD never did a correction as requested by SCE â€&lsqauo; because we believe our sources and the information we have compiled are accurate and factual given the information we have.It was â€&lsqauo;ten days after the story aired before the utility did respond to specific issues and we note the letter was sent not just to KNSD but throughout the stakeholders community. One of our experts told us this was the typical way SCE does damage control. Would you care to comment?
>â€&lsqauo;In regards to the story now in production, a key â€&lsqauo;element in the story is a statement from SCE contained in their letter criticizing the coverage; “There is no current radiological contamination on the Mesa property we plan to return to the Navy, as you implied; all Mesa survey readings are normal background radiation levels”â€&lsqauo;That is from the letter sent to KNSD from Maureen Brown of the SCE.â€&lsqauo;However, a response from a FOIA request â€&lsqauo;made by KNSD â€&lsqauo;to the United States Navy in regards to the Mesa â€&lsqauo;radiation â€&lsqauo;
>readings says, quoting from Mr. David Bixler of the Engineering Command, “The Mesa site may be contaminated from activities conducted during SCE’s occupancy and use” This letter is dated August 20, 2015â€&lsqauo;, just days before our story would air. â€&lsqauo;
>
>
>Was the Navy lying? â€&lsqauo;We are also reporting when SCE employees gathered samplesâ€&lsqauo;to check for radioactive levels from various locations on the Mesaâ€&lsqauo;, theymixed them together . According to our expert Dan Hirsch â€&lsqauo;this is a common practice by utilities when sampling to “average them together and try to find a way to force the numbers lower than they should be” We also reference in our new story an incident from NRC inspection records where contaminated soil, asphalt and concrete located close to a containment structure was moved to the Mesa. Sometime later it was removed—390 fifty five gallon druums were shipped off site. â€&lsqauo;Can â€&lsqauo;you tell me where the drums disposed of properly? Where were they shipped?
>
>â€&lsqauo;SCE's Media Relations Project Manager complained about our producer/reporters lack of knowledge about basic science saying “It appears your reporters and producers are unaware that radiation exists in everyday life” However after reviewing our documents and the SCE letter Mr. Hirsch said “the arguments that were made about radiation levels we are exposed to is completely irrelevant” He also added this sharp reaction is the typical â€&lsqauo;method of operation for SCE when they are questioned about their practices, saying SCE views this as a "public relations problem not a health problem."
>Please feel free to comment to one or all of these statements.
>Thank you
>
>cid:image001.jpg@01D0623B.5ADA68C0
>
>J W August
>Investigative Producer
>o 619.578.0214 | c 619.992.2210
>225 Broadway, San Diego CA 92101
>
>
>
>
>
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>Content-Description: image001.jpg
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** Ace Hoffman
** Carlsbad, California
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Wednesday, November 25, 2015

New videos: Oral Histories and presentations of atomic veterans...

November 25th, 2015

Dear Readers,

I recently posted nine videos on You-Tube which were recorded October 24-26, 2015 at an Atomic Veterans Reunion event in Las Vegas, Nevada. The event was held at the National Atomic Veterans Museum, near the strip. URLs for all nine videos are shown below.

The videos feature three Oral History interviews and more than half a dozen presentations by atomic veterans. These are complete interviews and presentations, minimally edited (except for extensive audio cleanup, so that audience and moderator comments could be heard).

One of the most interesting presentations was by Peter M. Livingston, who proposes several suggestions about what to do with spent nuclear fuel. He believes (and has numerous credentials and patents to back up his claims) that America can invent a "gamma ray photon" laser which will be able to reduce the fission product content of nuclear waste (it can't do anything about the plutonium, unfortunately). This would actually produce additional useful energy from the fuel waste, while using up the most dangerous byproduct of nuclear fission: The fission products.

Dr. Livingston also has concepts for using spent fuel in pools for creating: "a surprising cornucopia of chemicals, such as alcohols, aldehydes, ketones, ketenes, carbon monoxide" and other chemicals from the radiochemical reduction of carbon dioxide using gamma radiation emitting from spent fuel -- at a profit. Spent fuel is "one to ten million times" more radioactive than a medical cobalt-60 source.

All the presentations were fascinating to listen to and I highly recommend checking out the whole set. Some of the storytellers are old and talk slowly, some talk about some pretty mundane things sometimes, but I still suggest you view (or just listen) to each one in its entirety (total a little over five hours).

Taken together, they present a picture of an important part of history that is becoming impossible to find eyewitnesses to. These men watched, between them, scores of nuclear blasts. They laid cables for tests, stood in trenches near the blast, sent out reports on the telegraph wire...one even parachuted into a radioactive drop zone within about an hour after the detonation!

Included is also one World War Two veteran's story presented at the same event, about landing on the beach in Normandy and the next four months he spent on that same beach, often under fire from German planes, never showering the entire four months, unloading equipment for the war machine (including my father) which was marching across Europe.

You'll cry, you'll laugh, you'll disagree with something, you'll be horrified by many things, but you'll be glad you viewed these tapes of these amazing gentlemen, who each just randomly ended up having something to do with The Bomb (or, in Gaetano Benza's case, ended up on the blood-soaked, body-littered beaches of Normandy on D-Day).

Ace Hoffman
Videographer/interviewer/film editor
Carlsbad, California

----------------------------------------------
Videos from National Atomic Testing Museum Atomic Veterans Reunion 2015:
----------------------------------------------

Wally Lyons (Oral History and Presentation, 33:28):
(Signal Corps)
https://youtu.be/FEklHAhkUto

Roger Stenerson (Presentation, 37:14):
(Measured radiation effects of half a dozen blasts)
https://youtu.be/PmkoyQuqVjQ

Gaetano Benza (Presentation, 14:32):
(D-Day landings)
https://youtu.be/241p_4qKP3U

Bud Hinshaw (Presentation, 17:39):
(Airplane mechanic)
https://youtu.be/j8rxeq_5Xtw

Al Tseu (Oral History, 49:57):
(82nd Airborne)
https://youtu.be/e91MeIF0kvY

Al Tseu (Presentation, 33:47):
https://youtu.be/9CwBeNvCf_g

Peter Livingston (Oral History and Presentation, 55:41):
(Atomic blast EMP and x-ray studies)
https://youtu.be/EuNmZvdilys

Leo "Bud" Feurt (Presentation, 13:34):
(Saw dozens of blasts while stationed on the U.S.S. Boxer aircraft carrier)
https://youtu.be/FlDayvO9z_k

Al Gettier and Larrie Adams (Presentations, 1:02:14):
(Enewetok cleanup)
https://youtu.be/NT3kypIX-pI

###

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


************************************************
** Ace Hoffman, Carlsbad CA 92018
** home page: www.animatedsoftware.com
************************************************

Friday, November 20, 2015

Darrell Issa's change of heart on the intractable problem of nuclear waste...

November 20th, 2015

Representative Darrell Issa used to think nuclear waste was simply not a problem. Store it in pools. Store it in dry casks. Ship it to Yucca Mountain (some day). No worries.

Then after San Onofre (in his own district) shut down permanently, he had a change of heart. His solution?

Give it to someone else!

Below is Issa's press release about his proposed bill on nuclear waste. The first sentence of the first paragraph is a lie, and it goes downhill from there.

Issa claims that Yucca Mountain "has been stalled for years due to political posturing."

In reality, Yucca Mountain is STILL moving forward, albeit VERY slowly (there is a closing for comments period at the Nuclear Regulatory Commission today, for instance, regarding groundwater issues). The real problems (potential groundwater poisoning being just one of many) that have stalled Yucca Mountain are NOT political: Some of the problems are technical, such as the as-yet-undesigned and untested titanium drip shields proposed for the water intrusion problems they discovered after decades of thinking the place was always nearly totally dry. Drip shields might help, but other problems are technically unsolvable, such as the volcanic and earthquake activity in the general vicinity of Yucca Mountain. For those problems, the "experts" are attempting to show that catastrophic accidents will be unlikely -- but they can't make them impossible.

Very few Nevadans want Yucca Mountain. Nevadans have every right not to want a nuclear waste dump in their state, where over 800 nuclear bomb tests occurred, poisoning a 680-square mile area of the state.

Of course, every other state in the country feels the same way. Western states, fearing a push from Congress, have all signed a pact that prohibits a nuclear waste dump in any western state -- unless the governor of that state agrees to accept the waste. It's a large loophole in a pact of questionable legality in the first place, but so far no permanent solution is being seriously considered anywhere in America. And certainly, no one could possibly get elected governor of Nevada on a platform supporting Yucca Mountain.

The second sentence of Darrell Issa's nuclear waste proposal is equally absurd. Issa claims that the Yucca Mountain failure has "littered communities across the nation with high level nuclear waste." Yes, the waste exists, but the waste was created because those same communities (including mine) allowed nuclear reactors to be built before a waste solution existed, on the assumption that one would eventually exist. At 99 reactors around the country, waste problems still grow and some day will need to be faced. Or ran from.

There is one part of Issa's second sentence that is correct: Current storage is, indeed, in "less than ideal conditions." The waste is stored in thin (1/2 inch to 5/8ths inch thick) stainless steel canisters. There are no earthen berms to protect the waste from aircraft impacts. There is no way to monitor the contents of the canisters for degradation. The canisters themselves cannot be adequately inspected for cracks that might form over time. The canisters and the fuel will both degrade over time, becoming more and more difficult to transport as we wait.

The next paragraph of Issa's statement introduces Issa's "creative" solution. It is indeed creative -- so is all fiction. The fiction here is that there would be a "volunteering" region that will want to host an interim storage site. What Obama's Blue Ribbon Commission determined was that laws would need to be drastically changed for such a place to exist, because surrounding larger communities would object, state governments would object, and everyone along the transportation routes would object. So the BRC suggested making undemocratic laws that would force people to accept the consequences if some very tiny Indian tribe, corporation, or township wanted to take the waste. So much for being a democratic nation.

The fourth paragraph calls Yucca Mountain "our best bet." That phrasing is particularly interesting because it admits that nuke waste storage solutions are ALL a gamble. Then that paragraph says Issa's proposal would not take away funding from the Yucca Mountain plan, because it would only take away the interest from that funding. But since monetary inflation is an ongoing fact of life, the reality is that would make the Nuclear Waste Fund smaller and smaller in terms of real dollars.

If Issa wants to fund an Interim storage site, he should find the money elsewhere and not rob the Nuclear Waste Fund of the interest it can accrue (which will probably not be enough to keep up with inflation anyway).

In the last paragraph of Issa's statement, he admits to some of the reasons that storing nuclear waste at San Onofre (and more than 100 other sites around the country) is "not an option." But Issa utterly fails to recognize the real problem: Operating reactors. There is no such thing as a "permanent" solution as long as you are still making nuclear waste!

If -- magically -- you removed ALL the waste that could be removed (that is, if an interim storage site existed) from operating reactors right now, it would do little to actually reduce the risk, because operating reactors are at least 1,000 times more likely (perhaps 10,000 times more likely) to have a catastrophic accident than spent fuel, per unit of time, while the reactor is operating. However, over decades and centuries, the spent fuel is, of course, far more likely to be catastrophically released, because sooner or later (perhaps millennia, perhaps tomorrow), something is bound to go wrong at every nuclear waste dump.

Even if Yucca Mountain opened today, it would take about 30 years to fill, during which time more waste than will fit there will be created, and all the 2200+ dry casks that exist now will become more and more embrittled. More than 10,000 dry casks will be needed just for the fuel that already exists -- plus another ~10,000 dry casks for the spent fuel that will be created during the next 30 years, which will have nowhere to go even if Yucca Mountain is built! And Yucca Mountain has an enormous number of "unknowns" regarding what will happen to it in 500 years, or 1000, or 10,000, or 100,000, or a million years. (Nevada submitted almost 300 "contentions" to the Nuclear Regulatory Commission and the Department of Energy regarding Yucca Mountain, none of which have been resolved.)

Perhaps the worst thing about Issa's "best bet" -- Yucca Mountain -- is that the nuclear waste will not be retrievable after 300 years. That sounds good? It isn't. It means that IF a way to neutralize the waste were to be invented we wouldn't be able to retrieve the waste in order to process it! For example, this author recently talked to an expert with more than 50 years in the nuclear business, who says all we really need is a "gamma ray photon laser" which, according to the expert (Peter M. Livingston, Ph.D.), might be invented in the coming decades. Dr. Livingston also says there is enough latent, retrievable energy (retrievable with that not-yet-invented "gamma ray photon laser") in the waste we now have to power all of America's energy needs for about 7 years. That's a lot of latent, wasted energy! There have always been proposals for solving the nuclear waste problem, and after 70 years of creating waste, none of them have worked. Dr. Livingston's might not work either -- the gamma ray photon laser hasn't been invented yet -- but if we bury the waste improperly (as Issa wishes to do at Yucca Mountain), we won't be able to do anything when/if these solutions come to fruition.

Without a proven, working solution, we are risking accidents as big or bigger than Fukushima at every nuclear waste dump. But even if a solution to the waste problem existed, we would still risking a Fukushima or Chernobyl-scale event at every operating reactor because there is no such thing as a fail-safe nuclear reactor.

Darrell Issa should focus on closing the still-operating reactors in America (and especially near his district, in California and Arizona) if he wants to truly help solve America's growing nuclear waste debacle. He should get out of the nuclear waste guessing game. Operating reactors present an enormous risk to all Americans, and are continuously making the waste problem bigger and harder to solve.

Ace Hoffman
Carlsbad, CA

---------------------------------------------------------------
From:
http://issa.house.gov/press-releases/2015/09/issa-sponsors-bill-to-create-interim-storage-site-for-nuclear-waste/

Issa Cosponsors Bill to Create Interim Storage Site for Nuclear Waste

September 29, 2015

WASHINGTON, DC ­ Congressman Darrell Issa (CA-49) today released a statement following the introduction of the Interim Consolidated Storage Act:

"Progress on moving the nation's nuclear waste to the designated site at Yucca Mountain has been stalled for years due to political posturing. This failure of government to act has littered communities across the nation with high level nuclear waste stored in less than ideal conditions, including at the closed San Onofre Nuclear Generating Station in my own district.

"The Interim Consolidated Storage Act provides for a creative solution to a critical infrastructure need. The legislation would pair a region that is volunteering to host an interim waste storage facility with communities around the country that have nuclear waste demanding a better storage solution.

"The bill would neither replace Yucca Mountain ­ which remains our best bet for a permanent nuclear waste storage facility ­ nor would it take from Yucca Mountain's funding, taking only from the interest that has accrued to the Nuclear Waste Fund.

"Maintaining the status quo is not an option. The waste from the closed San Onofre nuclear plant sits near an active fault line, adjacent to the heavily-trafficked Interstate 5 and the Pacific Ocean, and sandwiched between densely-populated Orange and San Diego Counties. This is just one example out of 120, nationwide. Continuing to do nothing while the can is perpetually kicked down the road is no longer an option, and the Interim Consolidated Storage Act is a decisive, tangible step to circumvent political and bureaucratic gridlock, and it makes Americans safer in the process."

###

============================================
A useful video for Darrell Issa to view:
============================================

How I Became An Anti-Nuclear Activist (Dr. Gordon Edwards):
https://youtu.be/AYJUSlRyd44
or:
https://youtu.be/M-JdQL59HYE

=============================================
Beyond Nuclear web page on Yucca Mountain:
=============================================

http://www.beyondnuclear.org/yucca-mountain/

=============================================
U.S. Government web site to go to, to submit comments about Yucca Mountain:
=============================================

http://www.regulations.gov/#!home

Search for: NRC-2015-0051

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

Please conserve resources: Do not print this document unless absolutely necessary.

Note: This communication may have been intercepted in secret, without permission, and in violation of our right to privacy by the National Security Agency or some other agency or private contractor.
-----------------------------------------

Thursday, October 29, 2015

Recent AP news item continues the fiction that the nuclear waste problem can be solved.

Dear Readers,

There are several inaccuracies in Dave Gram's recent AP article on nuclear waste funding (the full article is shown below (bottom)).

Many of the "mistakes" are seen regularly in news articles written by pro-nuclear "science" writers who accept the basic (erroneous) idea that the world needs nuclear power -- so somehow, we are going to find a way to deal with the problems it causes.

Here are some comments about five errors in the article:

>>>>>>>>>
(1) "It was not envisioned they [ratepayers] also would have to pay for indefinite storage of spent fuel on the roughly 100 nuclear plant sites around the country."
>>>>>>>>>>

It certainly was obvious that someone would have to pay for it. The problem of storing nuclear waste indefinitely was described decades ago as "intractable." Anyone could have done the math and seen that there could never be enough storage space on earth, or safe enough storage locations, for nuclear power to be practical or economical. Ionizing radiation destroys ANY chemical bond that exists in nature. Therefore it can (and will) destroy ANY container you put it in. Ionizing radiation destroys materials: steel alloys, weld joints, molecular structures (including DNA strands) at the atomic level, and even at the sub-atomic level. Radiation accelerates embrittlement, resulting in cracks, leaks, and environmental damage. This was all known more than half a century ago (see quote from a 1979 NYTimes article (below, top)).

>>>>>>>>>>
(2) "Nuclear industry spokespeople, government officials and industry critics agree the retirement fund raids have been triggered by the failure to date of the U.S. Department of Energy to open a permanent disposal site for spent nuclear fuel. "
>>>>>>>>>>

Perhaps they say that, but it is not the whole truth. The U.S. DOE's failure was due to the fact that Yucca Mountain, like every other site on earth, is not an appropriate place to store nuclear waste. For one thing, Yucca Mountain is riddled with cracks that water can seep through. For another, it's in a volcanically-active area. And sometimes, when it rains it pours there -- witness the recent Beatty, Nevada fire that burst out due to water seepage at a long-closed low-level nuclear waste dump a few miles away from the proposed Yucca Mountain site.

>>>>>>>>>>
(3) "For years, the government had been planning a disposal site at Nevada's Yucca Mountain, but that plan has been scuttled by a lack of funding from Congress."
>>>>>>>>>>

Again, this is only part of the whole situation. The plan was delayed for more than two decades after problems first started to arise. After 30 years and about as many billions of dollars, Congress finally decided to let all the scientists (10,000+) go do something more productive somewhere else. By the time Congress canceled funding, probably 98% of the Yucca Mountain scientists had little or nothing to do anyway. But a small % of the scientists were stuck on difficult problems, such as designing huge, heavy titanium drip shields to try to get around the water intrusion problem for a few hundred years. Another small percentage had problems for which there were simply no good (or half-good) solutions. Those scientists were instead busily trying to calculate the likelihood of unstoppable catastrophic events (such as earthquakes and volcanoes), and had to try to prove those events weren't very frequent. Proving that...proved very difficult indeed!

These were the real show-stoppers that caused Congress to finally give up. Nobody simply backed out. Instead, the futility of moving forward became inescapable. (The so-called "Blue Ribbon Commission" accomplished nothing, and only called for abrogating people's right to stop a "temporary" or "interim" nuclear waste dump near their house (but that's another story).)

One more factor caused the Yucca Mountain project to be all but abandoned: The nation unwittingly accepted an alternative solution that is relatively cheap to start with, but can't last very long, and is vulnerable to terrorist attacks and numerous environmental events -- if it doesn't manage to fall apart all by itself first: Dry cask storage.

>>>>>>>>>>
(4) "Entergy Corp., closed the plant at the end of last year because it was becoming less competitive against electricity generated with cheap natural gas."
>>>>>>>>>>

Actually, natural gas is "cheap" because renewables are even cheaper, so natural gas has to be relatively cheap to compete (it could be even cheaper, but doesn't have to be to find a market). More importantly, even cheap, inadequate solutions to the problem of nuclear waste disposal are not being included in nuclear power plant calculations of their so-called "operating costs." Nor are cancers in the community (now confirmed by several studies). Nor is the shared cost (that all nuclear power plants globally should be paying) of all previous radiation releases: Chernobyl, Fukushima, Santa Susana, Three Mile Island, SL-1 and all the other accidents, large and small, that have happened (plus weapons releases, NASA accidents, hospital waste and so on). The toll on human life from Chernobyl alone is probably already over a million people dead (a number supported by a meta-analysis of tens of thousands of individual studies conducted in Russia after the event).

>>>>>>>>>>
(5) "The spent fuel bottleneck leaves closed and soon-to-close nuclear plants with the prospect that for the indefinite future, they will look like the site of the former Maine Yankee plant."
>>>>>>>>>>

Why only closed and soon-to-close nuclear power plants? All nuclear power plants should be looking at these sorts of problems and costs. If the energy users (customers) had to fully pay for all future nuclear waste storage of the waste generated by their own electricity usage, customers would demand immediate closure because the price would be sky-high. Every dry cask is a catastrophe just waiting to happen, and the fewer any one site is left with, the better.

Dry casks cannot and will not be properly inspected. Dry casks can be cracking from the inside out OR the outside in. The first sign of a crack could be a catastrophic loss of integrity of the entire containment system. Cracks can go from microscopic to through-wall in a matter of months -- or even mere moments -- if the stress on the area with the crack is in the right direction. Welds near support structures are, of course particularly vulnerable and particularly hard -- or impossible -- to inspect. There are now over 2,200 dry casks in America, and enough spent nuclear fuel for more than 10,000. That's a lot of chances for a catastrophic accident somewhere.

It's time to stop making more nuclear waste. There is no such thing as economical -- or safe -- nuclear power.

Ace Hoffman
Carlsbad, CA

================================================================
From NYTimes, 1979:
U.N. Agency Accused of Hiding Data on Hazards in Nuclear Energy:
================================================================

5/19/1979
New York Times

"An environmental "watchdog" organization has accused the United Nations Environment Program of suppressing its own report on possible health hazards in nuclear energy and the dangers of accident at nuclear-powered installations.
....
"Lack of Disposal Methods

"The [UNEP] report concedes that no adequate permanent disposal method has been devised for highly radioactive wastes, which 'will remain active over immense time scales and, unless continuously isolated, will present dangers to our remote descendants.' It estimates that it would take 10 to 20 years just to determine the feasibility of some 'promising ideas' for disposal."
...

================================================================
From 2015:
Nuclear plants dip into dismantling funds to pay for waste
================================================================

By DAVE GRAM

Oct. 25, 2015 1:21 PM EDT

MONTPELIER, Vt. (AP) ­ With a federal promise to take highly radioactive spent fuel from nuclear plants still unfulfilled, closed reactors are dipping into funds set aside for their eventual dismantling to build waste storage on-site, raising questions about whether there will be enough money when the time comes.

It violates Nuclear Regulatory Commission rules for the plants to take money from their decommissioning trust funds to pay for building the concrete pads and rows of concrete and steel casks where waste is stored after it is cooled in special storage pools. But the NRC is granting exemptions from those rules every time it is asked.

"All of the plants that have permanently shut down in recent years have sought, and been approved for, the use of decommissioning funds for spent fuel storage costs," NRC spokesman Neil Sheehan wrote in an email in response to questions from The Associated Press this past week.

These include the Kewaunee plant in Wisconsin, San Onofre 1 and 2 in California, Crystal River 3 in Florida, and Vermont Yankee in Vernon, in Vermont's southeast corner, which closed at the end of last year. The Zion 1 and 2 reactors in Illinois, which shut down in the late 1990s, had gotten a similar OK to use decommissioning money for spent fuel storage, Sheehan said.

Ratepayers chipped in during nuclear plants' lives to set aside the money it would take eventually to tear down reactors, remove their radioactive components and restore the sites. It was not envisioned they also would have to pay for indefinite storage of spent fuel on the roughly 100 nuclear plant sites around the country.

And long-term, on-site storage of nuclear waste is a bad idea, said Arnold Gundersen, a former nuclear industry executive turned consultant who frequently criticizes the industry.

"You build power plants near water because you have to cool them, and you build nuclear waste storage sites away from water" because of the threat of radioactive materials reaching it, Gundersen said.

"It would be much better to get the stuff underground where terrorists couldn't fly a plane into it," he said.

Nuclear industry spokespeople, government officials and industry critics agree the retirement fund raids have been triggered by the failure to date of the U.S. Department of Energy to open a permanent disposal site for spent nuclear fuel. For years, the government had been planning a disposal site at Nevada's Yucca Mountain, but that plan has been scuttled by a lack of funding from Congress.

That has left reactors redesigning the racks in their spent fuel pools to accommodate more of the waste and expanding into "dry cask" storage, both of which Vermont Yankee did in the years before its owner, Entergy Corp., closed the plant at the end of last year because it was becoming less competitive against electricity generated with cheap natural gas.

The spent fuel bottleneck leaves closed and soon-to-close nuclear plants with the prospect that for the indefinite future, they will look like the site of the former Maine Yankee plant. That plant was permanently shut down in 1997, nearly two decades ago. Today, the reactor is gone, but the site in the coastal town of Wiscasset still features 60 steel canisters encased in concrete that contain the 550 metric tons of spent fuel the plant generated in its 25-year life. The site is guarded 24 hours a day, 7 days a week.

Vermont Yankee's decommissioning fund already is short enough ­ it contains about half the estimated $1.24 billion cost of dismantling the reactor, removing the waste and restoring the site ­ that the plant plans to follow an NRC-allowed procedure called "SAFSTOR," in which the closed reactor is mothballed for up to 60 years in hopes the fund will grow enough to cover the cost.

Vermont Yankee spokesman Martin Cohn said Entergy had taken out a $145 million line of credit to cover capital costs of building its on-site waste storage. But he said the company is planning for $225 million in security and other operating expenses after the spent fuel is in storage.

Gundersen said Vermont is alone among states in that it is trying to limit raids on the decommissioning fund. This month, Vermont won a ruling from an NRC board that Entergy would have to keep it informed of withdrawals from the fund for specific expenses.

Cohn argued that anyone concerned about the costs of on-site waste storage and how they're being paid should not focus their ire on the industry, NRC or even the Department of Energy. Rather, it is the Congress that has failed to fulfill its decades-old promise that the federal government will take highly radioactive spent fuel off the hands of nuclear plant operators.

###

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


========================================
Quotes collected by Ace Hoffman:
========================================

----------------------------------------------
"Nuclear war must be the most carefully avoided topic of general significance in the contemporary world. People are not curious about the details." -- Paul Brians (author; quote is from: Nuclear Holocausts: Atomic War in Fiction)
----------------------------------------------
"When fascism comes to America, it will come wrapped in the flag and carrying a cross." -- Sinclair Lewis (first American Nobel Prize winner in Literature, 2.7.1885 - 1.10.1951)
----------------------------------------------
"There is no such thing as a pro-nuclear environmentalist." -- Sen. Tom Harkin (D-Iowa, 1992)
----------------------------------------------
"Know thy self, know thy enemy. A thousand battles, a thousand victories." -- Sun Tzu (Chinese general b.500 BC)
----------------------------------------------
"Stupidity is the same as evil if you judge by the results." -- Margaret Atwood (Canadian poet/novelest/environmentalist/etc.)
----------------------------------------------
"The sun shows up every day and produces ridiculous amounts of power." -- Elon Musk (5.1.2015)
----------------------------------------------
"The most intolerable reactor of all may be one which comes successfully to the end of its planned life having produced mountains of radioactive waste for which there is no disposal safe from earthquake damage or sabotage." -- A. Stanley Thompson (a pioneer nuclear physicist who later realized the whole situation)
----------------------------------------------
"Any dose is an overdose." -- Dr. John W. Gofman (another pioneer nuclear physicist who saw the light (9.21.1918 - 8.15.2007))
----------------------------------------------
"Choose your leaders with wisdom and forethought. To be led by a coward is to be controlled by all that the coward fears. To be led by a fool is to be led by the opportunists who control the fool. To be led by a thief is to offer up your most precious treasures to be stolen. To be led by a liar is to ask to be lied to. To be led by a tyrant is to sell yourself and those you love into slavery." -- Octavia Butler (science fiction writer, 7.22.1947 - 2.24.2006)
----------------------------------------------
"If you want real welfare reform, you focus on a good education, good health care, and a good job.

If you want to reduce poverty, you focus on a good education, good healthcare, and a good job.

If you want a stable middle class, you focus on a good education, good health care, and a good job.

If you want to have citizens who can participate in democracy, you focus on a good education, good health care, and a good job.

And if you want to end the violence, you could build a million new prisons and you could fill them up, but you never end this cycle of violence unless you invest in the health and the skill and the intellect and the character of our children. You focus on a good education, good health care and a good job.

And other than that, I don't feel strongly about anything."

-- Paul Wellstone (US Senator, D-Minnesota, 7.21.1944 - 10.25.2002)
----------------------------------------------
"There are no warlike peoples - just warlike leaders." -- Ralph Bunche (8.7.1903 - 12.9.1971)
----------------------------------------------
In the execution room, Troy [Davis] used his last words to proclaim his innocence one final time. He then made a call for his movement -- all of our movement -- to bring about [an] end of the death penalty for good. And then, in his final breath, he asked God's mercy upon those about to kill him.
----------------------------------------------
"Resistance to tyrants is obedience to God." -- Thomas Jefferson
----------------------------------------------
"Officials from the San Onofre nuclear reactor said the warning siren that went off yesterday was just a malfunction and no one should worry. Hey, I worry, if they can't even get the siren to work right, what the hell are they doing with the reactor??" Jay Leno 1/20/10
----------------------------------------------
"Please send this to everyone you know!" -- Ace Hoffman (original collector of the above quotes)
----------------------------------------------

This email was sent by:
-----------------------------------------
Ace Hoffman
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

Please conserve resources: Do not print this email unless absolutely necessary.

Note: This communication may have been intercepted in secret, without permission, and in violation of our right to privacy by the National Security Agency or some other agency or private contractor.
-----------------------------------------

Tuesday, October 13, 2015

Welcome to Las Vegas. You're under arrest.

Dear Readers,

Today (October 13, 2015), another old American nuclear reactor announced that it is closing permanently.

Pilgrim opened in 1972 and has been producing nuclear waste ever since. Due to "unprofitable conditions" it will close by 2019, and perhaps much sooner. A wise investor would close it immediately since the risk is not worth ANY possible profit, let alone a loss, but the regional grid operator requires prior notification of voluntary closure, and refueling outages are considered logical times to close nuclear power plants permanently, in order to squeeze the last few dollars of profit out of the reactor.

Across the country, at least 20 reactors are predicted to close over the next decade, mostly because required safety upgrades (such as they are), operating costs, fuel costs, regular maintenance costs, and competitive replacement energy prices (mostly low natural gas prices but also the wonderful low prices for renewables (which will only go even further down as manufacturing capacities ramp up)) -- all add up to one thing: Unprofitability.

Well, whatever it takes, right? Not so fast. Closing 20% of the fleet doesn't solve the nation's biggest liability: Our growing nuclear waste pile. It only slows it down.

The biggest question facing the nation is where to put the waste. What community will take it? What state? Communities around closed reactor sites are especially eager to get their waste removed, but operating reactors want their old waste removed too -- they want a constant stream of removal of old fuel forever. But to where? No one knows.

So the nuclear industry is using activists around the shuttered San Onofre Nuclear (Waste) Generating Station very successfully to try to push the nation towards building an "interim" nuclear waste repository, and/or restarting and then finishing Yucca Mountain, the proposed permanent nuclear waste site in Nevada. For the last 30 years, Yucca Mountain has been the ONLY proposed permanent nuclear waste repository in America. Partly because there really isn't anywhere else that's better. But also because no one wants the waste.

President Obama stopped funding Yucca Mountain research, then he formed a special committee to study alternatives. The so-called "Blue Ribbon Commission" (BRC) came up with nothing: They could not think of any permanent alternative, so instead they proposed changing federal laws to make it easier for a small group of property owners, a tiny township, or a small native American tribe with sovereign land, to build an "interim" waste repository. The laws, which have not yet been completely formulated, would prohibit a state, or any larger community such as a county or nearby large city, from blocking the "interim" storage site. The BRC's proposed new federal laws would also prohibit cities, counties, or states from banning the transport of nuclear waste through their community, on the way to the interim storage location.

In response to the BRC's suggestions, western states formulated a mutual agreement saying they would not allow nuclear waste to be stored in any western state -- unless that state's governor approves it. I have no idea of the legality -- or usefulness -- of the western states' governor's agreement, but it shows how little anyone wants even an "interim" waste repository, let alone, a permanent one.

As plants close around the country, calls for a solution to the problem of nuclear waste storage have intensified tremendously, and will continue to do so. But hold on a minute. First we have to close ALL the reactors. Otherwise, we'll just be enabling them to make more waste.

It was at least six months ago, perhaps more, when I first heard the nuclear industry lavishing praise on Southern California Edison's (SCE's) "Community Engagement Panel" (CEP) as "the way to do it" when interacting with the public during decommissioning. In 2012, San Onofre suddenly closed down permanently, due to poorly-designed replacement steam generators that failed less than a year after installation. Since then, half a dozen other reactors have also shut down, or have announced plans to do so soon. The CEP was initiated about six months after permanent closure was announced. It's headed by a pro-nuclear economist from a local university, and includes a past president of the American Nuclear Society and other nuclear proponents.

The industry is right that it's been very successful, insofar as: Many people (and all the media) around San Onofre -- including once-good activists who were urgently trying to shut down the reactor prior to the steam generator failure -- are now completely misled about how deep the problems with nuclear waste really go. Pun intended. There is no place to put it, but all they can think about is moving it somewhere -- anywhere.

Some activists have even joined with the utility, pushing hard for the Yucca Mountain unfinished permanent repository to restart. Others are content with any parking-lot anywhere, as long as it's away from the current site, which of course would certainly be fine with the utility, and with the local politicians who speak so loudly now, but were silent or belligerently pro-San Onofre before, such as Congressman (and possible future speaker of the house) Darrell Issa.

But wishing for the waste to be moved is not the same as moving it. And the fact is, there are no parking-lots available anywhere where the waste will be safe.

Yucca Mountain is a terrible "solution" to the waste problem. Water leakage from above, water seepage from below, volcanic eruptions in the not-so-distant past, the possibility the area will become lush (again) in the not-so-distant future (due to global warming)...there is only one conclusion: Yucca Mountain's "science" is full of holes.

There never will be any truly safe -- let alone, cost-effective -- solutions to the problem of storing nuclear waste indefinitely. There will always be an element of risk, no matter what solution is implemented.

For this reason, all "solutions" rely on "Probabilistic Risk Assessments" (PRAs) for justification. All PRAs accept that "life is a gamble." All PRAs gamble with your life.

In Nevada, they understand gambling. And they don't want Yucca Mountain.

Bad as Yucca Mountain is, the "interim" solutions are even worse. And worst of all, the area surrounding Yucca Mountain would probably become an "interim" storage site itself for many decades -- with minimal protection since it would be presumed to be very temporary.

Interim solutions offer no real protection for the fuel canisters from earthquakes, volcanoes, tornados and "tornado missiles," real missiles, A-10 Warthogs flown by renegade pilots with live DU shells, a LPG explosion nearby at sea or on the railroad tracks near many of the sites (including San Onofre), rust, apathy, poor welding during manufacture (include San Onofre here, too), transportation hazards, tsunamis...even asteroids.

Southern California's remaining newspapers blame the failure of the feds to open Yucca Mountain, and San Onofre's sudden closing, as the cause of high energy bills in the future. Nothing could be further from the truth.

The bill may be high, but it is because we have the waste -- we already made it, and now we have to protect it. Doing that successfully will cost billions. Failing to do so, however, could cost trillions.

Ionizing radiation destroys any chemical bond of any container you put radioactive substances in. Radiation accelerates decay, corrosion, embrittlement, rust, osteo-ripening, Wigner's disease, hardening, loss of ductility, aging...(these are all basically names for the same thing). So you can't just enclose nuclear waste and walk away. Eventually you have to transfer the waste to a new enclosure, or enclose the original enclosure (as they're doing in Chernobyl already). And then sooner or later, repeat the process.

Yucca Mountain was supposed to "solve" all that by letting the containers crumble under thousands of tons of rock, over a period of hundreds of years (so hopefully, most of the crumbling would start long after most of the fission products will have decayed away). Yucca Mountain is an iffy proposition at best, since predicting the behavior of the radionuclides in the ground over a period of many millennia is basically just guesswork.

Thanks to San Onofre and the complicity of the California Coastal Commission (CCC), the California Public Utilities Commission (CPUC), and the Nuclear Regulatory Commission (NRC), the gullible public enjoyed relatively cheap energy (nevertheless, among the most expensive in the nation) for approximately two generations. But the full cost of that "cheap" energy is to be paid by our children, and our children's children, for thousands of generations.

Those who made the waste -- and thus, made the waste problem -- are the ones to blame if rates go up because Yucca Mountain (or any solution) doesn't open up. Likewise, those who made the waste are to blame if rates go up because the NRC (dream on), or the CPUC or CCC decides to require more robust (and more expensive) solutions than the cheap "ISFSI Islands" SoCalEd is proposing to use. If rates go up because we manage to catch the failure of a dry cask BEFORE a catastrophe, and only have to spend billions to repackage each cask, instead of trillions if there is a full release of one or more spent fuel casks, it will be the fault of those who made this awful stuff.

You can never clear the site of an operating reactor of its most dangerous, most risky contents. Risk is only reduced after the reactor is permanently shut down. After that, the fuel has to cool thermally and radioactively...the longer you let it cool, the less risky it becomes. It takes many millennia before it is safe to handle.

For operating reactors, worrying about getting their used fuel offsite is ignoring the more imminent danger: The reactor itself, and the used fuel which was most recently removed from the reactor. The older fuel (actually "old reactor cores") is a growing problem, but not the main problem at open reactors. Closing them is the main problem.

However, at closed reactors, the used fuel is the problem.

Operating reactors have to build several more dry casks every time they refuel, since their spent fuel pools are already full. After filling the stainless steel casks and inserting them into cement bunkers, the utility assumes that Department of Energy (DOE) will "take possession of it at some point." And so they keep operating.

The $30 billion dollars ratepayers across the country have already put into a fund for building a permanent solution is probably going to be siphoned off for "interim" storage solutions. There is currently a proposal to "only" siphon off the interest that is accruing -- but the principal is worth less and less every year because of inflation, so really that's making a permanent solution more and more difficult to fund properly. They've already stopped collecting more money from the ratepayers, because the DOE hasn't been getting anywhere with its plans.

The lesson to be learned by Californians from the San Onofre steam generator debacle and subsequent waste problem we are left with, is to shut down Diablo Canyon immediately and demand that Arizona shut down Palo Verde (20% owned by San Onofre's owner, Southern California Edison). Shutting down the operating reactors is the most important thing local activists around San Onofre can help with, since they can see (if they look) the difference in risk factors between: 1) an operating reactor, 2) "fresh" used fuel which was recently removed from the reactor, 3) older used fuel, and 4) no fuel on site at all (the desired condition everywhere).

But they can also see (if they look) that trying to force Nevada to take the waste is naive. This author was in Nevada for two hearings last month (September, 2015) and has been to five or six hearings there over the past decade and a half. The majority of the citizens of Nevada definitely don't want our waste, and Las Vegas in particular is adamant that THEY don't want it anywhere near them (and Yucca Mountain is VERY near them). And it's not just their elected representatives -- it's the people who elected them. And it's the people with money, too. The ones who own the casinos. They don't want nuclear waste trucked through their town (which would be the preferred route for much of the waste). City officials have even sworn to arrest anyone who tries to drive used nuclear reactor cores through their city.

The transport and storage accident scenarios envisioned by the NRC are farcical: In their fantasies, mere millionths of a single fuel pellet (i.e., tiny fractions of a gram) of nuclear waste ever escapes a dry cask, either during transport or while sitting wherever it may be for the next 300 years (or more). NRC assumes that only these tiny fractional amounts, out of all 10,000+ dry casks worth of fuel which already exists in America, and all that will be made in the coming decades, will ever be released in any "worst case" scenario. It's preposterous.

If we're lucky, all 300+ dry casks' worth that already exists in California will be transported with few accidents, and those accidents (according to the NRC's PRAs) will only release millionths of a gram (or less) of the 20 or so tons of nuclear fuel inside each cask. But perhaps we will not be so lucky, especially since the longer we wait to transport the casks, the more embrittled the containers will be when they are finally moved.

Nuclear power is, of course, completely replaceable with clean renewable energy, such as wind, wave, solar, and so on. These energy sources put zero costs on future generations and zero risk.

It's time for California and the rest of America to switch to clean energy solutions.

Ace Hoffman
Carlsbad, CA

===========================================
Correspondence with Tim Judson, NIRS:
===========================================


To: "Tim Judson" <timj .. nirs.org>
Subject: RE: [NukeNet] NIRS statement on Pilgrim reactor closure announcement
Cc: "Michael Mariotte" <nirsnet .. nirs.org>, "Michael Aguirre" <maguirre .. amslawyers.com>, "Donna Gilmore" <dgilmore .. cox.net>

Tim,

Your policy has enabled the nuclear industry to give us 2,200 dry casks across the country so far. How many more are you willing to put up with? We'll need 10,000+ for all the waste in existence today, with a new one needed every other day in America for as far into the future as anyone can see. Because when the pools got full, NIRS and "1000 local, regional, and national groups across the country" endorsed dry cask storage when shut-down was the only reasonable alternative.

Yet you called this "secure." I don't know what metallurgists you consult, but clearly none I would respect.

Ace

At 10:39 PM 10/13/2015 +0000, Tim Judson wrote:
>Hey Ace,
>
>For over 10 years, NIRS has taken the position that fuel should be transferred from high-density pool storage to Hardened On-Site Storage, along with 1,000 local, regional, and national groups across the country, including those in reactor communities. Pilgrim is a Mark I Boiling Water Reactor, with the fuel pool six stories in the air. There is nothing less secure than that. We understand every site has different kinds of constraints and vulnerabilities. We also believe current dry-cask designs are not good enough, and we push for better standards. But the dangers of high-density pool storage are extreme. There is no good solution to the waste, only bad options ranging from worse to worst. Activists in the Plymouth community want the waste out of the pool. There has been a dispute about the location of the dry-cask pad, not the need to get the waste out of the pool.
>
>Hope that helps,
>Tim
>
>From: Ace Hoffman
>Sent: Tuesday, October 13, 2015 1:49 PM
>To: Michael Mariotte
>Cc: Tim Judson
>Subject: Re: [NukeNet] NIRS statement on Pilgrim reactor closure announcement
>
>Does NIRS officially think the waste can be "secured" properly?
>
>If so, please think again!
>
>Ace
>
>At 05:36 PM 10/13/2015 +0000, NIRS wrote:
>
>
>FOR IMMEDIATE RELEASE Contact: Tim Judson 212-729-1169
>October 13, 2015 timj .. nirs.org
>
>
>Statement by NIRS Executive Director Tim Judson on
>Entergy's Announced Closure of Pilgrim Nuclear Power Plant
>
>NIRS applauds Entergy's decision to close the unsafe, uneconomical, and polluting Pilgrim Nuclear Power Plant, on Cape Cod Bay in Massachusetts. However, Entergy's proposed 2019 closure date is unacceptable, and poses the risk that this dangerous reactor could continue operating for nearly four more years. Pilgrim currently has the worst nuclear safety rating in the country, tied with Entergy's Arkansas Nuclear One plant.
>
>Entergy has been cutting costs on the aging, uncompetitive reactor at Pilgrim for years, which has resulted in the rise in safety violations, equipment failures and even security lapses, and Entergy's decision to close the plant is ostensibly to avoid millions of dollars in costs to meet NRC's minimum safety standards. The NRC cannot allow a reactor to operate without addressing the systemic safety violations that Entergy has at Pilgrim.
>
>In 2013, NIRS, Citizens Awareness Network, Pilgrim Watch, and other organizations petitioned the NRC for enforcement of the agency's financial qualifications regulations at Pilgrim. Such action could have avoided this situation entirely, but NRC inexplicably refuses to enforce that regulation. We also call on New England's electricity grid operator to work with Entergy to release Pilgrim from its capacity commitments and enable the plant to close as soon as possible.
>
>NIRS supports the call of Senator Edward Markey for assistance to Pilgrim workers who may be displaced by the reactors' closure. That plan should begin with a planned, orderly, and responsible decommissioning of Pilgrim. With approximately $900 million in a dedicated decommissioning trust fund, most of the workforce could be retained for 10-20 years in securing the nuclear waste and cleaning up the radioactive and toxic materials at Pilgrim, restoring and protecting the ecology of Cape Cod for generations to come.
>
>-30-
>_______________________________________________________________________
>NukeNet Anti-Nuclear Network (nukenet@energyjustice.net)

========================================
Quotes collected by Ace Hoffman:
========================================

----------------------------------------------
"Nuclear war must be the most carefully avoided topic of general significance in the contemporary world. People are not curious about the details." -- Paul Brians (author; quote is from: Nuclear Holocausts: Atomic War in Fiction)
----------------------------------------------
�When fascism comes to America, it will come wrapped in the flag and carrying a cross.� -- Sinclair Lewis (first American Nobel Prize winner in Literature, 2.7.1885 - 1.10.1951)
----------------------------------------------
"There is no such thing as a pro-nuclear environmentalist." -- Sen. Tom Harkin (D-Iowa, 1992)
----------------------------------------------
"Know thy self, know thy enemy. A thousand battles, a thousand victories." -- Sun Tzu (Chinese general b.500 BC)
----------------------------------------------
�Stupidity is the same as evil if you judge by the results.� -- Margaret Atwood (Canadian poet/novelest/environmentalist/etc.)
----------------------------------------------
�The sun shows up every day and produces ridiculous amounts of power.� -- Elon Musk (5.1.2015)
----------------------------------------------
"The most intolerable reactor of all may be one which comes successfully to the end of its planned life having produced mountains of radioactive waste for which there is no disposal safe from earthquake damage or sabotage." -- A. Stanley Thompson (a pioneer nuclear physicist who later realized the whole situation)
----------------------------------------------
"Any dose is an overdose." -- Dr. John W. Gofman (another pioneer nuclear physicist who saw the light (9.21.1918 - 8.15.2007))
----------------------------------------------
"Choose your leaders with wisdom and forethought. To be led by a coward is to be controlled by all that the coward fears. To be led by a fool is to be led by the opportunists who control the fool. To be led by a thief is to offer up your most precious treasures to be stolen. To be led by a liar is to ask to be lied to. To be led by a tyrant is to sell yourself and those you love into slavery." -- Octavia Butler (science fiction writer, 7.22.1947 - 2.24.2006)
----------------------------------------------
"If you want real welfare reform, you focus on a good education, good health care, and a good job.

If you want to reduce poverty, you focus on a good education, good healthcare, and a good job.

If you want a stable middle class, you focus on a good education, good health care, and a good job.

If you want to have citizens who can participate in democracy, you focus on a good education, good health care, and a good job.

And if you want to end the violence, you could build a million new prisons and you could fill them up, but you never end this cycle of violence unless you invest in the health and the skill and the intellect and the character of our children. You focus on a good education, good health care and a good job.

And other than that, I don't feel strongly about anything."

-- Paul Wellstone (US Senator, D-Minnesota, 7.21.1944 - 10.25.2002)
----------------------------------------------
"There are no warlike peoples - just warlike leaders." -- Ralph Bunche (8.7.1903 - 12.9.1971)
----------------------------------------------
In the execution room, Troy [Davis] used his last words to proclaim his innocence one final time. He then made a call for his movement -- all of our movement -- to bring about [an] end of the death penalty for good. And then, in his final breath, he asked God�s mercy upon those about to kill him.
----------------------------------------------
"Resistance to tyrants is obedience to God." -- Thomas Jefferson
----------------------------------------------
"Officials from the San Onofre nuclear reactor said the warning siren that went off yesterday was just a malfunction and no one should worry. Hey, I worry, if they can't even get the siren to work right, what the hell are they doing with the reactor??" Jay Leno 1/20/10
----------------------------------------------
"Please send this to everyone you know!" -- Ace Hoffman (original collector of the above quotes)
----------------------------------------------

This email was sent by:
-----------------------------------------
Ace Hoffman
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
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-----------------------------------------

Sunday, October 4, 2015

We should all be worrying about SoCalEdison's risky plan to store 1600 tons of "used" nuclear fuel at San Onofre...forever.

October 4th, 2015

Glenn Pascall is a former newspaper reporter for a small California paper, and currently is on Southern California Edison's Community Engagement Panel (CEP), and is the spokesperson for the Sierra Club's "Task Force on San Onofre."

There are about 18 or 20 members of the CEP, including local city council members, county supervisors, a past president of the American Nuclear Society, someone from a local ocean-oriented non-profit, and so on. When it was formed after the nuclear power plant shut down permanently, activist Gene Stone was invited to join the CEP as the "people's representative" and Glenn Pascall was selected as his alternate. Gene resigned from the CEP earlier this year, so Glenn became the "people's representative."

The CEP is run by its dictatorial chairman, David Victor, who has published several articles expressing his pro-nuclear stance. The entire CEP was hand-selected by Tom Palmisano, currently Chief Nuclear Officer and Vice President of Decommissioning at Southern California Edison.

In recent emails (shown below), Glenn has attempted to undermine the arguments against Southern California Edison's (SCE's) plans for storing San Onofre's "used" fuel. Pascall assumes that his position is the only viable position and that I, Donna Gilmore, and others are misguided at best. Pascall dismisses those who support alternatives such as different storage solutions and/or additional safeguards, and a focus on shutting down all remaining nuclear power plants by admitting how big the problem we are left with really is. Pascall's remarks are not just rude, they are defamatory.

If Mr. Pascall truly speaks for the Sierra Club as he claims, then the Sierra Club is equally liable for his defamatory remarks and is similarly deluded about the inherent dangers of storing nuclear waste generally, and the specific limitations of SCE's current plan.

I first met Mr. Pascall about two years ago (which he now calls his "long experience" with me). At the time he was utterly naive about nuclear issues (I gave him a copy of my book). But nevertheless he enthusiastically wanted to join the local activists around the by-then-closed San Onofre Nuclear Waste Generating Station. He attended dozens of weekly meetings we held in San Clemente, "we" being myself, Donna Gilmore, Gene Stone, Darin McClure and about half a dozen others. Sometimes as many as a dozen would show up prior to important events.

Glenn wrote the following to me yesterday:

-----------------------------------------
Ace,

I love you as a brother but long experience has confirmed that you see this whole matter as a scenario of inescapable doom. I hope you derive some emotional satisfaction from that stance but as a practical matter I cannot join you.

Best regards,

Glenn
-----------------------------------------

What "whole matter" is he talking about? The storage of about 1600 tons of the most lethal substance known to mankind, called Irradiated Nuclear Reactor Cores.

These "fuel assemblies," also known as "fuel bundles," "spent fuel," and "used fuel" (the nuclear industry has many names for them), are comprised of the uranium and plutonium pellets that produce the radiation, as well as the zirconium rods that hold the pellets, and all the daughter products, all the activation products, that the reactors have ever produced

The only poisons missing from "used fuel" (the current industry name) is the tiny percentages which have already escaped the plant somehow, such as the day the steam generators leaked in January, 2012, or from periodic "batch" releases the plant has been doing since it opened. Everything else is bundled up in those zirconium fuel rods.

And zirconium is highly flammable. The fuel rods are extremely hot, both thermally and radioactively. Built up inside them are substances so deadly, that invisible quantities are fatal. To stand next to an unshielded spent fuel pellet (about the size of a pinky bone) -- just one of them -- for just a fraction of a second is fatal. Contrast that with unused nuclear fuel, which can be handled unshielded with gloves (to protect against alpha radiation of the hands).

Used fuel is the Achilles' Heel of the nuclear industry. (One of them, anyway (an operating reactor's ability to suddenly melt down is another, but that one can be brought to a stop).)

San Onofre still holds all the "used fuel" it ever produced, minus one experimental fuel load in Unit 1, which was removed from the site many years ago. Unit 1 closed more than 20 years ago, due to steam generator leakage problems, and Units 2 and 3 are also now closed. Owning those irradiated reactor cores is, by far, SCE's biggest liability as a corporation -- even though nuclear accidents are insured by the government (for fractions of a penny on the dollar). In the event of an accidental release of the poisons at San Onofre, the victims would pay financially as well as with their lives and/or their health.

Thus, this "whole matter" Glenn Pascall refers to is, in fact, enough to destroy all of southern California, and far beyond. There is enough used fuel to kill and maim millions of Americans, if it were to get out of its containers and be spread around the country. One pound of plutonium is enough to kill every man, woman and child on the planet, if evenly distributed to all. Of the approximately 1,600 tons of used fuel at San Onofre, approximately 16 tons is plutonium. Sixteen tons! The Nagasaki bomb, a plutonium device, had about 10 pounds of plutonium. When in ceramic form and mixed with about 95% uranium-238, and 3% or 4% U-235, and other non-fissile elements, the plutonium in used fuel can't blow up like a nuclear bomb. But, by a number of methods, the plutonium in used fuel can be dispersed as fine particles, which will make much of soCal uninhabitable for tens of thousands of years (plutonium's half-life is about 24,100 years).

Used fuel is especially dangerous (and difficult to deal with) because it gives off gamma rays and neutrons. The used fuel pellets must be kept behind at least half an inch of steel, plus three feet of concrete, for it to be safe for humans to go near them to check the vent-holes around the dry casks for dead animals and excessive radiation leakage from the "sealed" canisters.

The only good news about used fuel at San Onofre is that they are no longer making more of it -- the pile is not growing. Because of that, the radiation levels are constantly and steadily dropping day by day, moment by moment. Unfortunately, after the short-lived radioisotopes have decayed, there are still the longer-lived ones, such as cesium, strontium and plutonium.

Glenn Pascal tells me I: "see this whole matter as a scenario of inescapable doom."

Eventually, yes. An asteroid is bound to hit the planet some day and wipe millions of us out -- maybe even all of us. But by Glenn's logic, the sun will burn out some day anyway, so why bother obeying street lights?

Glenn implies that my and others' efforts to increase the amount of protection from catastrophic events at San Onofre are irrational. Nothing could be further from the truth. And we're not even trying to protect against asteroids -- Yucca Mountain was supposed to do that (to some extent, anyway, and yes: The Yucca Mountain scientists considered that one of its advantages over above-ground storage).

I've outlined a way for Diablo Canyon and Palo Verde (part owned by SCE) to escape from their worst risks and financial liabilities: They should stop making more nuclear waste. As for San Onofre, Southern California Edison is planning to make a fuel storage system that is much more dangerous than it needs to be. They are taking the cheap route, not building something that can be inspected, that is easily transportable if the time ever comes, that is robust in the meantime. Their reasoning for going cheap is based on unsubstantiated hopes of upcoming "interim" storage solutions.

SCE has been operating for decades based on such unsubstantiated hopes for Yucca Mountain. Before that, dozens of other proposed solutions came and went, from abandoned salt mines to rocketing the waste out to space, the former ending when the mine caved in, the latter ending with either Challenger or Columbia, depending on how stubborn you were.

SCE is even claiming it has public support for its plan, with the acquiescence of their hand-picked "CEP," and in particular Mr. Pascall's/Sierra Club's support for SCE's plan to store the waste at San Onofre in thin canisters, for decades, in a marine environment, with no air filtering to prevent corrosion, and with a flimsy outer cement overpack system which is inadequate protection against tsunamis, earthquakes, airplane strikes or terrorist forces.

When the storage pad was announced we were told it would be made of reinforced concrete, and would move as a single unit in an earthquake. But the technical drawings only show a reinforced top pad and a reinforced bottom pad, the middle being subject to shearing forces from an earthquake, which could cause the top pad to shift in relation to the bottom pad, popping open all 75 casks at once!

At the proposed used fuel "island," the canisters will be packed so close together that if any one cask fails for any reason (terrorist's bomb; airplane that dove into the fuel pad; large ship deposited on top of the pad by a tsunami; the pad itself sheared in two by an earthquake as described above) they might all fail. Nobody can get close to unshielded fuel. Water increases the ability for the fuel to "go critical" again (which is supposed to only happen inside the reactor but can still happen thousands of years later if the fuel gets put in the "right" configuration). Water won't put out a zirconium fire -- not that the firemen could get close enough to put a hose on it.

There are many things SCE could do to increase safety (starting with using reinforced concrete throughout the pad, and making the space between each cask much, much bigger). But there's a catch: No improvement will make the fuel "safe," and all reasonable improvements will cost hundreds of millions, or perhaps billions of dollars to implement. SCE wants fuel storage to be CHEAP, and the entire nuclear industry (and Glenn Pascall of the Sierra Club) is all for that.

Profits before safety, even while talking about the most dangerous stuff on earth.

Glenn Pascall is a tool of the nuclear industry. There are lots of those, but his defamatory remarks, as the only "people's representative" on the CEP, and as liaison to the CEP from the Sierra Club, are intolerable. Glenn Pascall should resign immediately as spokesperson for the Sierra Club on San Onofre issues, and as "people's representative" of the mis-named Community Engagement Panel.

Ace Hoffman
Carlsbad, CA

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

Below: Recent (past 48 hours) correspondence between Glenn, myself, and several others on the 'cc' list (including SCE executives and several Sierra Club members) is shown below.

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

Date: Sun, 4 Oct 2015 02:47:21 +0000 (UTC)
From: "Glenn Pascall" <gpascall@att.net>
To: <ace@acehoffman.org>
Cc: "Donna Gilmore" <dgilmore@cox.net>,
"Carole Mintzer - Angeles Sierra Club" <cmintzer@socal.rr.com>,
"NIRS Summit" <Nirs@sanonofre.com>,
"SOS Members" <decommission@sanonofre.com>,
"Rita Conn" <ritamconn@gmail.com>,
"George Watland" <george.watland@sierraclub.org>,
"David G. Victor" <david.victor@ucsd.edu>,
"Gene Stone" <genston@sbcglobal.net>,
"Marni Magda" <marnimagda@gmail.com>,
"Tom Palmisano" <tom.palmisano@sce.com>,
"Manuel Camargo" <manuel.camargo@sce.com>
Subject: Re: Fwd: Re: San Onofre Independent Spent Fuel Storage Installation (ISFSI) Application 9-15-0228 for Tuesday 10/6 Long Beach Coastal Commission meeting

Ace,

I love you as a brother but long experience has confirmed that you see this whole matter as a scenario of inescapable doom. I hope you derive some emotional satisfaction from that stance but as a practical matter I cannot join you.

Best regards,

Glenn



On Saturday, October 3, 2015 7:25 PM, Ace Hoffman <acehoffman@gmail.com> wrote:


Glenn,

Dr. Caldicott just tweeted this article by Ian Farlie from a few days ago, which is quite relevant to this discussion:

http://www.theecologist.org/News/news_analysis/2985577/when_the_partys_over_the_financial_spectre_at_the_end_of_nuclear_power.html

Especially the pull-quote:

"Governments and nuclear enthusiasts have assured the public that final waste repositories are nigh. But they have been saying this since the start of nuclear power in the 1950s, with little to show for it. There may, in fact, be no such method."

This line is also relevant, as is much of the article: " Finding a long term safe home for nuclear waste is the most expensive headache. There are no operating repositories in the world..."

Ace


On Sat, Oct 3, 2015 at 12:17 PM, Glenn Pascall <gpascall@att.net> wrote:
Donna,

Some time ago you challenged the encouragement that I as San Onofre Task Force Chair had given to the efforts of those seeking to develop the possibility of Consolidated Interim Storage (CIS) of spent nuclear fuel. As a result of that challenge, Senior Angeles Chapter Director George Watland and I carefully reviewed Sierra Club policies and precedents and concluded I was representing a consistent position. We see CIS as an appropriate step toward revitalizing a national commitment to the 30 year Sierra Club goal of remote long-term storage

Prior to my sending a statement regarding the ISFSI, George and I went through a similar intensive review process with regard to Edison's application to the California Coastal Commission. We concluded that support for the permit was appropriate and we worked closely together on wording our statement. I will not repeat the reasoning behind our position, which is clearly spelled out in the statement itself.

Logically, there are three approaches one can take regarding spent fuel waste at San Onofre:

1) That fuel pool storage can continue indefinitely, with no time pressure to remove the spent fuel to dry storage.

2) That dry storage is preferable, but stored casks can remain on site at San Onofre indefinitely.

3) That fuel waste should be moved from pools as expeditiously as possible and placed in dry storage, and further, that options for transporting the canisters from San Onofre should be encouraged and developed so spent fuel waste is ultimately removed to a safer site.

We have taken the third position because we believe it to be the most environmental responsible.

With regard to your claim that the Sierra Club endorses storage of "the experimental unproven Holtec UMAX system" our statement makes no mention of that or any other specific system. Indeed, your phrasing verges on misrepresentation.

Logically, the spent fuel must be stored in cansiters of some design. Edison has chosen a specific system over strong objections from yourself and others. Edison, with federal agency approvals, has authority to make that selection. The Community Engagement Panel, as a discussion forum, has no authority to modify or reverse that decision.

In the context of the Coastal Commission permit, we have addressed only the issue at hand rather than issues that lie beyond the scope of the permit. We have, however, noted the importance of using transportable casks and maintaining the capacity to move them.

Deciding, as you have done, to oppose the request to permit an ISFSI because you oppose a specific cask design leaves you in a strange place with regard to removing spent fuel from pools. By default you are endorsing the most environmentally dangerous position. Frankly, if you wish to continue the battle on cask design, you need to find a way of doing it that involves less collateral damage.

Sincerely,

Glenn Pascall



On Saturday, October 3, 2015 11:29 AM, Donna Gilmore <dgilmore@cox.net> wrote:


I see the Angeles Chapter of the Sierra Club is supporting Edison's application to install the experimental unproven Holtec UMAX system (Glenn's statement attached). Please consider my comments below regarding critical concerns with this system and hopefully, reevaluate your position.

I am not aware that any of the local environmentalist nor local members of the Angeles Chapter of the Sierra Club that have been active on the San Onofre issues, including myself, had seen Glenn's email prior to the submittal to the Coastal Commission.

Does Glenn's document represent the national Sierra Club position to the California Coastal Commission? What evaluation was done on the proposed system by the Sierra Club before endorsing this system?

Thanks,

Donna Gilmore
SanOnofreSafety.org
949-204-7794


-------- Forwarded Message --------
Subject: Re: San Onofre Independent Spent Fuel Storage Installation (ISFSI) Application 9-15-0228 for Tuesday 10/6 Long Beach Coastal Commission meeting
Date: Fri, 2 Oct 2015 14:25:01 -0700
From: Donna Gilmore <dgilmore@cox.net>
To: Street, Joseph@Coastal <Joseph.Street@coastal.ca.gov>
CC: Rita Conn <ritamconn@gmail.com>, NIRS Summit <Nirs@sanonofre.com>, John Geesman <johngeesman@greenenergywar.com>, David Peffer <david.a.peffer@gmail.com>, Alison St. John KPBS <astjohn@kpbs.org>, Teri Sforza - OC Register <tsforza@ocregister.com>, Jeff McDonald - old email <jeff.mcdonald@utsandiego.com>, Michael Blood - AP Wire <mblood@ap.org>, Toni Iseman <tiseman2@aol.com>, Don Mosier <donaldmosier44@gmail.com>, KCBS TV News <kcbstvnews@cbs.com>, NBC - Vikki Vargas <vikki.vargas@nbcuni.com>, Lori Donchak - City Council <loridonchak@gmail.com>, Audrey Prosser - Laguna Beach <prosserga@gmail.com>, Verna Rollinger - Laguna Beach <vernarollinger@cox.net>, Ann Doneen <malibudemocraticclub@gmail.com>, Rima Nashashibi - Newport Beach Dem Club <rimanashashibi@gmail.com>, Judy Jones - SONGS Demo <judyjones414@gmail.com>, Dan Hirsch <dhirsch1@cruzio.com>, Arnie Gundersen <sailchamplain@gmail.com>, Matthew Freedman <matthew@turn.org>, RL Miller <envirocaucus@gmail.com>, Richard Mathews <richardm.dem@gmail.com>, Bart Ziegler <bziegler@toxco.net>, Marvin Lewis <marvlewis@juno.com>, Arjun Makhijani <arjun@ieer.org>, Ken Alex <ken.alex@gov.ca.gov>, Kevin Barker - CEC <kevin.barker@energy.ca.gov>, Eric Greene <eric.greene@cpuc.ca.gov>, Morey Wolfson <Moreywolfson@aol.com>, Robert Alvarez <bob@ips-dc.org>


To California Coastal Commissioners and staff.

An additional comment is regarding the very short warranty for the Holtec system. Even though Holtec and SCE claim the system will last 60 to 100 years, the Holtec warranty is for only 10 years for the underground structure and only 25 years for the thin 5/8" thick steel welded canisters (MPC-37). Also, Edison is considering having Holtec load the existing Areva thin canisters into the Holtec system. The Holtec warranty is only two years for these canisters. The below linked Holtec warranty was provided to me by Edison as part of the CPUC Unit 2 and 3 Decommissioning proceedings.

https://sanonofresafety.files.wordpress.com/2013/06/sce-dr-response-w-attachment-to-a-14-12-007-gilmore-sce-001-follow-up-2-q-09-q-12.pdf

Donna Gilmore

On 10/1/2015 6:02 PM, Donna Gilmore wrote:
>To the California Coastal Commissioners and staff:
>
>I recommend the Coastal Commission deny the application for this experimental unproven Holtec spent fuel dry storage system (Application 9-15-0228). This is a very important issue to rush through the approval process with so little time for the public to review the staff's recommendations and related material. However, even with the short review time, I have a number of reasons the proposed system by Southern California Edison (SCE) must be rejected.
>
>The proposed Holtec UMAX underground dry storage system is an experimental unproven system. It cannot be inspected, repaired, maintained, or monitored and does not meet current Coastal Act requirements. The staff's "Approval with conditions" contains conditions that are unlikely to be met. The serious staff concerns that required these conditions demonstrates the inadequacy of this SCE proposed system. It is likely this system will be at our coast for decades, if not longer, as staff has indicated. There is adequate evidence to show that this experimental Holtec system will likely not meet Coastal Commission short term or long term storage and transport requirements. To assume the system can or will be relocated, as the staff suggests, is not a reasonable assumption, based on known evidence. These high capacity (37 fuel assembly) canisters with high burnup fuel may need to cool in dry storage for over 45 years before they are cool enough to transport. (See slide 10 of this Department of Energy presentation. http://www.nwtrb.gov/meetings/2013/april/boyle.pdf ). The NRC has not approved this system in the configuration proposed by SCE and Holtec.
>
>Additional comments and references below.
>The report states SCE expects the service life of the ISFSI and casks to be at least 100 years and no major repairs are anticipated within 60 or 100 years. This is an unsubstantiated claim. (Staff Report page 37). Please have SCE provide technical references for those statements. Are these Holtec technical documents submitted to the NRC? The NRC is only certifying the system for 20 years and is not considering degradation or other aging management issues that might occur after 20 years. The NRC doesn't consider claims by Holtec about those 60 and 100 years as anything the NRC has validated or approved (according to their Sept 2015 UMAX amendment 1 certification approval document). The staff report references email document "SCE 2015b." Please forward a copy of this document.
>http://www.gpo.gov/fdsys/pkg/FR-2015-09-08/pdf/2015-22053.pdf
>
>The statement "NRC has estimated that at least 30 years would be required for the initiation of stress corrosion cracking in steel fuel storage casks" is no longer valid. (Staff Report Page 37). That statement is in the NRC 8/5/2015 meeting minutes on Stress Corrosion Cracking and Aging Management. The reason NRC said 30 years was because they assumed the canisters would not be cool enough for moisture to deliquesce (dissolve) salt on the canister for at least 30 years. However, at that time they were not aware of the two-year old Diablo Canyon canister that had temperatures low enough for salts to deliquesce. I participated in that and other NRC meetings on stress corrosion cracking in marine environments.
>http://pbadupws.nrc.gov/docs/ML1425/ML14258A081.pdf
>https://sanonofresafety.files.wordpress.com/2011/11/diablocanyonscc-2014-10-23.pdf
>
>The Koeberg nuclear plant had a component that leaked from stress corrosion cracks in 17 years. It is located in a similar environment as San Onofre (on-shore winds, moist ocean air, frequent fog). The NRC considers the Koeberg component (a waste water tank) comparable to a stainless steel canister (304L or 316L stainless steel). The Koeberg through-wall crack was 0.61" thick. About the same thickness as the proposed Holtec canisters (0.625" thick). San Onofre has also had stress corrosion cracking in stainless steel pipes that the NRC considers comparable to the thin steel canisters, so it's clear the environmental conditions are present at San Onofre. We do not need to wait 20 years to find this out, so the Coastal Commission should address this in the current application. References:
>http://pbadupws.nrc.gov/docs/ML1231/ML12319A440.pdf
>http://pbadupws.nrc.gov/docs/ML1425/ML14258A082.pdf
>
>Existing Areva NUHOMS canisters have been loaded since 2003, so the idea that Edison needs to have an aging management plan in 20 years is not the case. They need an aging management plan for their existing NUHOMS canisters and system. Does the existing NUHOMS canister ISFSI require a separate Coastal Commission renewal permit? Both the existing NUHOMS and proposed Holtec thin canisters are of the same materials (welded 316L stainless steel). We have only 5 years before we meet the Koeberg timeline. This idea we can wait 20 years is not realistic on many levels. To buy products originally designed for 20 years that do not have aging management built into the design is unacceptable. Edison should be required to provide their aging management plan now, so it can be fully evaluated by the Coastal Commission. What we already know is not adequate. This is too important an issue to base approvals on Edison promises of future solutions. The UMAX system is an experimental unproven system. Over 99 percent of dry storage system in the U.S. and the world are above ground systems. To claim this is typical or a proven U.S. systems is an inaccurate claim. On Staff Report page 11, the footnote states "A small HI-STORM UMAX system...is installed at Humboldt Bay Power Plant". This is not a UMAX system and has a very different design. The Humboldt Holtec HI-STAR HB system uses 1/2" thick canisters, but inserted them in thick steel bolted lid cask before placing them in the underground holes. Also, the fuel cooled for 35 years in the pools and was low burnup fuel, so no air vents were needed to cool the thin canister and fuel. In spite of this, water leaked into this system, which Holtec said would not happen. Their solution was to put caulking around the enclosure.
>https://sanonofresafety.files.wordpress.com/2011/11/ml13151a317.pdf
>http://pbadupws.nrc.gov/docs/ML0531/ML053140041.pdf
>
>The Holtec UMAX system has not been approved by the NRC for the configuration planned for San Onofre and it has not been approved for the site. The NRC will need a license amendment for the changes in order to properly evaluate for seismic, thermal and other technical requirements. The system is approved for 1/2" thick canisters, not 5/8" as proposed. The system is approved for a totally underground system, not the half underground system proposed. The NRC comments in their September 2015 UMAX approval make this clear. I explained this and other items in the letter I sent to staff on September 17, 2015. It appears some of the public comments I have made have not been addressed. Or has Edison or Holtec or the NRC provided you different information?
>https://sanonofresafety.files.wordpress.com/2013/06/ltrtocoastalcommissiondgilmore2015-09-17umax-amend1.pdf
>http://www.gpo.gov/fdsys/pkg/FR-2015-09-08/pdf/2015-22053.pdf
>
>Aging management of the Holtec system is inadequate. Even the Holtec President, Dr. Singh, says the canisters cannot be repaired. They cannot even find cracks, let alone repair them.
>https://www.youtube.com/watch?v=euaFZt0YPi4&feature=youtu.be
>
>Relying on vendor promises of future solutions to be able to inspect and maintain the system should not be relied upon in Coastal Commission decision making. The Coastal Commission should not make decisions based on "vaporware". State agencies are not allowed to procure "vaporware" (capabilities that do not exist), so why would the Coastal Commission make such an important decision assuming these most critical issue will be resolved by vendors? The Coastal Commission should demand Edison use a proven system that can be inspected, maintained, have continuous monitoring, is transportable and doesn't crack. This is the only way to meet Coastal Commission requirements. The NRC is only concerned with 20 years. The Coastal Commission is concerned with longer term requirements. Technology exists to meet both NRC and Coastal Commission requirements. Rejecting the option of the thick casks, such as the German thick Castor casks (manufactured by Siemplekamp, designed by GNS), with the response "these thick-walled casks are not generally licensed for use at U.S. sites by the NRC" is not sufficient to reject thick casks. (Staff Report page 20). There is also the option of thick metal casks such as the Areva TN-24 and TN-32 casks currently used in the U.S. Southern California Edison knows both the German and Areva thick metal casks have been licenses by the NRC, so there is every reason to believe they would receive a license for San Onofre. Given that these options are proven technologies used in the U.S. and are the main storage technologies used for the majority of the rest of the world for both storage and transportation, thick casks should not be a rejected alternative. This would better meet Coastal Commission requirements for longevity and transport and also meet NRC requirements. Thick casks are approximately 10 to 20 inches thick compared to the proposed thin canisters that are only 5/8th of an inch thick.
>https://sanonofresafety.files.wordpress.com/2011/11/reasonstobuythickcasks2015-04-16.pdf
>https://sanonofresafety.files.wordpress.com/2013/06/germanycaskstoragegorlebengns.jpg
>
>There is already evidence for the staff to have sufficient probability that requirements to have canisters transportable and maintainable may not be met with the Holtec UMAX system. Pushing the can down the road another 20 years isn't going to change that. The only reason no thin canisters have leaked yet is because they have not been in use long enough for cracks to go through the wall of the canister. We are at higher risk of cracks due to our corrosive coastal environment. We are the last location that should be using this inferior technology with materials known to crack from corrosive moist salt air. The NRC does not allow transport of cracking canisters. The underground portion of this system is subject to corrosive ground chemicals and yet cannot be inspected due to lack of technology to inspect this design.
>http://pbadupws.nrc.gov/docs/ML1432/ML14323A067.pdf
>
>Regarding Edison's promise of potentially moving the system to higher ground as the coastal environment degrades that would require a major expense and would likely cost over double the existing San Onofre Decommission Plan cost estimates. The cost estimates they submitted to the NRC and CPUC assumes fuel will be picked up at the earliest DOE time frame, even though their documents state these dates are unlikely to be met. They also assume nothing will go wrong with the canisters. They have budgeted about $1.3 billion for spent fuel management and plan to spend it all. They also plan to spend the entire $4+ billion Decommission Trust Fund, so no monies will be available. What is the basis for accepting Edison's promise? Will ratepayers be required to pay for this? Is their promise and this plan reasonable? Choosing thick casks meet Coastal Commission requirements for both relocation on-site and transport. Thick casks are transportable. No additional transportation casks are needed. No protective concrete structures would need to be destroyed and rebuilt. No transfer casks are needed. Systems are installed above ground. Thick cask have seals that can be monitored and replaced. Once a thin canister cracks, it is no longer usable and cannot be repaired. As the staff report clearly indicates there are many uncertainties regarding when or if the Department of Energy will pick up the fuel and many uncertainties about environmental conditions in our future. Therefore, we need to plan now for the best option, not wait for 20 years and hope something magical will change and assume the Holtec system can be relocated or transported. Please protect our coastal resources and do not allow this experimental Holtec UMAX system in our coastal communities. It does not meet current Coastal Act requirements. It is folly to approve a system based on vendor and utility promises of future solutions when we have the facts we need to make better decisions now. Yes. we need an NRC approved system, but one that also meets Coastal Act requirements. Those to items are not mutually exclusive and are obtainable. Edison's unreasonably short artificial timeline should not be a driving factor for this decision that has long term implications for our Coastal resources.
>
>Thank you,
>
>Donna Gilmore
>SanOnofreSafety.org
>949-204-7794
>
>Additional information and references Reasons to Buy Thick Casks and Nuclear Storage Myths
>https://sanonofresafety.files.wordpress.com/2011/11/reasonstobuythickcasks2015-04-16.pdf
>SanOnofreSafety.org
>http://sanonofresafety.org/
>Nuclear Waste Storage and Transport
>http://sanonofresafety.org/nuclear-waste/
>Coastal Commission Staff Report
>http://documents.coastal.ca.gov/reports/2015/10/Tu14a-10-2015.pdf
>Coastal Commission October 6 Agenda and Location
>http://www.coastal.ca.gov/mtgcurr.html
>
>
>On 10/1/2015 8:48 AM, Street, Joseph@Coastal wrote:
>>Donna,
>>
>>I got your message this morning. You should have received a notice regarding the upcoming hearing on the ISFSI permit and the availability of the staff report – I’m sorry if this wasn ™t the case. The report came out last Friday. I’ve attached it here (the file is fairly large, let me know if you have problems and I can split off the exhibits and resend as two files).
>>
>>Joe
>>
>>
>>Joseph Street, Ph.D
>>Environmental Scientist
>>Energy, Ocean Resources & Federal Consistency Division
>>California Coastal Commission
>>45 Fremont St. Suite 2000
>>San Francisco, CA 94105
>>(415) 904-5249
>>joseph.street@coastal.ca.gov
>>http://www.coastal.ca.gov/
>>


Donna Gilmore



11:29 AM (15 hours ago)

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to Glenn, Carole, NIRS, Rita, SOS, me
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I see the Angeles Chapter of the Sierra Club is supporting Edison's application to install the experimental unproven Holtec UMAX system (Glenn's statement attached). Please consider my comments below regarding critical concerns with this system and hopefully, reevaluate your position.

I am not aware that any of the local environmentalist nor local members of the Angeles Chapter of the Sierra Club that have been active on the San Onofre issues, including myself, had seen Glenn's email prior to the submittal to the Coastal Commission.

Does Glenn's document represent the national Sierra Club position to the California Coastal Commission? What evaluation was done on the proposed system by the Sierra Club before endorsing this system?

Thanks,

Donna Gilmore
SanOnofreSafety.org
949-204-7794


-------- Forwarded Message --------
Subject:Re: San Onofre Independent Spent Fuel Storage Installation (ISFSI) Application 9-15-0228 for Tuesday 10/6 Long Beach Coastal Commission meeting
Date:Fri, 2 Oct 2015 14:25:01 -0700
From:Donna Gilmore <dgilmore@cox.net>
To:Street, Joseph@Coastal <Joseph.Street@coastal.ca.gov>
CC:Rita Conn <ritamconn@gmail.com>, NIRS Summit <Nirs@sanonofre.com>, John Geesman <johngeesman@greenenergywar.com>, David Peffer <david.a.peffer@gmail.com>, Alison St. John KPBS <astjohn@kpbs.org>, Teri Sforza - OC Register <tsforza@ocregister.com>, Jeff McDonald - old email <jeff.mcdonald@utsandiego.com>, Michael Blood - AP Wire <mblood@ap.org>, Toni Iseman <tiseman2@aol.com>, Don Mosier<donaldmosier44@gmail.com>, KCBS TV News <kcbstvnews@cbs.com>, NBC - Vikki Vargas <vikki.vargas@nbcuni.com>, Lori Donchak - City Council <loridonchak@gmail.com>, Audrey Prosser - Laguna Beach<prosserga@gmail.com>, Verna Rollinger - Laguna Beach <vernarollinger@cox.net>, Ann Doneen <malibudemocraticclub@gmail.com>, Rima Nashashibi - Newport Beach Dem Club <rimanashashibi@gmail.com>, Judy Jones - SONGS Demo <judyjones414@gmail.com>, Dan Hirsch <dhirsch1@cruzio.com>, Arnie Gundersen <sailchamplain@gmail.com>, Matthew Freedman <matthew@turn.org>, RL Miller <envirocaucus@gmail.com>, Richard Mathews <richardm.dem@gmail.com>, Bart Ziegler <bziegler@toxco.net>, Marvin Lewis <marvlewis@juno.com>, Arjun Makhijani <arjun@ieer.org>, Ken Alex <ken.alex@gov.ca.gov>, Kevin Barker - CEC<kevin.barker@energy.ca.gov>, Eric Greene <eric.greene@cpuc.ca.gov>, Morey Wolfson <Moreywolfson@aol.com>, Robert Alvarez <bob@ips-dc.org>
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Preview attachment Sierra Club Statement to CCC.docx
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Sierra Club Statement to CCC.docx


joeholtzman@gmail.com

12:00 PM (15 hours ago)
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to Donna, Glenn, Carole, NIRS, SOS, me, Rita
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I totally disagree with Pascall !!

Sent from my iPhone
><Sierra Club Statement to CCC.docx>


Glenn Pascall

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12:17 PM (14 hours ago)
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to George, David, Gene, Marni, Tom, Manuel, Donna, Carole, NIRS, SOS, me, Rita
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Donna,

Some time ago you challenged the encouragement that I as San Onofre Task Force Chair had given to the efforts of those seeking to develop the possibility of Consolidated Interim Storage (CIS) of spent nuclear fuel. As a result of that challenge, Senior Angeles Chapter Director George Watland and I carefully reviewed Sierra Club policies and precedents and concluded I was representing a consistent position. We see CIS as an appropriate step toward revitalizing a national commitment to the 30 year Sierra Club goal of remote long-term storage

Prior to my sending a statement regarding the ISFSI, George and I went through a similar intensive review process with regard to Edison's application to the California Coastal Commission. We concluded that support for the permit was appropriate and we worked closely together on wording our statement. I will not repeat the reasoning behind our position, which is clearly spelled out in the statement itself.

Logically, there are three approaches one can take regarding spent fuel waste at San Onofre:

1) That fuel pool storage can continue indefinitely, with no time pressure to remove the spent fuel to dry storage.

2) That dry storage is preferable, but stored casks can remain on site at San Onofre indefinitely.

3) That fuel waste should be moved from pools as expeditiously as possible and placed in dry storage, and further, that options for transporting the canisters from San Onofre should be encouraged and developed so spent fuel waste is ultimately removed to a safer site.

We have taken the third position because we believe it to be the most environmental responsible.

With regard to your claim that the Sierra Club endorses storage of "the experimental unproven Holtec UMAX system" our statement makes no mention of that or any other specific system. Indeed, your phrasing verges on misrepresentation.

Logically, the spent fuel must be stored in cansiters of some design. Edison has chosen a specific system over strong objections from yourself and others. Edison, with federal agency approvals, has authority to make that selection. The Community Engagement Panel, as a discussion forum, has no authority to modify or reverse that decision.

In the context of the Coastal Commission permit, we have addressed only the issue at hand rather than issues that lie beyond the scope of the permit. We have, however, noted the importance of using transportable casks and maintaining the capacity to move them.

Deciding, as you have done, to oppose the request to permit an ISFSI because you oppose a specific cask design leaves you in a strange place with regard to removing spent fuel from pools. By default you are endorsing the most environmentally dangerous position. Frankly, if you wish to continue the battle on cask design, you need to find a way of doing it that involves less collateral damage.

Sincerely,

Glenn Pascall

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Preview attachment Sierra Club Statement to CCC.docx
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Sierra Club Statement to CCC.docx

Ace Hoffman <acehoffman@gmail.com>

5:27 PM (9 hours ago)

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to Glenn, Donna, Carole, NIRS, SOS, Rita, George, David, Gene, Marni, Tom, Manuel
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Glenn,

Every time a fuel assembly is lifted, an increased risk is entailed. Every time a dry cask is moved, an increased risk is entailed. Every time nuclear fuel is transferred from one container to another, an increased risk is entailed.

There is no guarantee that spent fuel in dry casks would go to an interim site first (before fuel that is in spent fuel pools, especially at operating reactors with full pools).

It would make more sense (because it would save steps) to move spent fuel from the pools directly into transport canisters, and then to the interim site -- especially if it's been 20 or 40 years or more, and the integrity of the spent fuel assemblies in the dry casks is suspect (as it will be). There are now more than 2,000 dry casks around the USA. Moving all of them before emptying the pools of operating reactors with dangerously full pools seems foolhardy as government policy ("dangerous" by anyone's standards, that is. By my standards, the spent fuel pools were too dangerous as soon as the first spent fuel assembly was placed in them. Dry casks are also too dangerous to exist on earth.).

Fuel in the pools can be much more closely inspected prior to shipment, since the casks will not be opened if they are combined transport/storage canisters. If the canisters cannot be used for transport, then the fuel will need to be transferred before moving, which will probably require immersing the fuel back in water, and repeating the drying process all over again, increasing the risk as well as the worker exposure. And doing so won't help the operating reactors empty their overcrowded pools.

All this complicates the choice of "best (least risky) scenario" and leaves us with more than three "logical" choices based on simplistic assumptions. The best choice depends almost entirely on whether or not an interim storage site is going to be established some time in the next few decades -- an iffy proposition at best. And whether the dry casks and/or spent fuel pools can withstand whatever happens in the meantime. The CCC seems to assume that if there is going to be a problem, it simply won't happen in the next 20 years. Then if nothing's gone wrong, they'll probably assume another 20 years will also be safe. A classic case of passing the hot potato down the line.

Do you really think the Holtec ISFSI protects against tsunamis, airplane strikes, earthquakes and terrorists? The "pad" isn't reinforced concrete throughout (only a few feet on the top and the bottom are reinforced). We were told it would "move as one unit" in an earthquake but that is hardly likely. It is more likely to split apart, along with the thin 1/2-inch stainless steel dry casks within it. That would spell doomsday for soCal.

What are your assumptions -- your own personal guesstimate -- of the likelihood the fuel will actually be moved? Do you think it has, say, a 10% chance of happening in 20 years, but a 90% chance of happening within 60 years? What do you base your optimism that the waste will ever be moved on? As far as I know the Sierra Club has never endorsed a specific location to store nuclear waste and I'm sure most members would oppose whatever location you wish to support -- except, of course, activists near current waste sites and the nuclear industry. Strange bedfellows indeed.

For reference, I think the waste has virtually a zero percent chance of moving anywhere, any time in the next century (or, frankly, ever, unless the nuclear industry is stopped entirely, so that the problem is finite instead of constantly growing). Of course, I've been studying the lack of progress on Yucca Mountain for several decades, so I've seen how long the nuclear industry can stretch these things out for. The nuclear industry was built on false hopes and ignoring real risks. This is their same game.

Lastly, if spent fuel pools are so dangerous, why doesn't your statement include a condemnation of Diablo Canyon's and Palo Verde's spent fuel pools, let alone their operating reactors, which are about a thousand times more risky than San Onofre's spent fuel pool or our dry casks? Fresh fuel recently removed from a reactor is a huge problem in case of a station black out. It's a fire hose, turned on occasionally, for San Onofre.

Ace


--
Ace Hoffman
Carlsbad, CA
www.acehoffman.org

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

Glenn Pascall's Sierra Club statement:


Statement of Glenn Pascall, Chair

Sierra Club Task Force on San Onofre

Re: California Coastal Commission

Application No. 9-15-0228

Agenda of October 6, 2015

I write in support of the application by Southern California Edison

Company to construct and operate an Independent Fuel Storage

Installation (ISFSI) for storage of spent nuclear fuel from Units 2 and

3 at the San Onofre Nuclear Power Station in San Diego County.

Those who care about the California coast have two primary

concerns regarding spent nuclear fuel at San Onofre. The first

concern is to move fuel rods from pools to dry cask storage as rapidly

as possible. The second concern is to remove storage casks from the

vulnerable San Onofre site at the earliest available opportunity.

Opinion is virtually unanimous that worst-case hazards are far more

severe for nuclear waste stored in fuel pools rather than in dry casks.

Construction of concrete structures holding steel canisters is an

essential part of this transition.

Commission staff has wisely suggested that after 20 years an

amendment be required to continue operation of the facility. This is

appropriate not only as a checkpoint to determine whether the ISFSI

is providing safe storage but is also timely for review of alternatives to

For more than 30 years it has been a matter of national policy – and

of Sierra Club policy – that nuclear waste be removed from operating

sites and stored at one or more remote long-term repositories. In the

interim, no site has been licensed for operation. As a result, spent

fuel has remained on-site at all decommissioned commercial nuclear

Some fear that construction of an ISFSI on-site at San Onofre will

simply assure permanent storage there. Yet the ISFSI is essential to

support dry storage and closure of spent fuel pools. To reconcile

these concerns, we would ask the Commission to note the following

additional aspects of project design and operation:

• Dry cask storage should be in canisters that can be transported if

the opportunity arises to remove them from San Onofre.

• Transportation connections at San Onofre should be maintained in

a condition that enable spent fuel removal by rail or truck.

• Efforts at the state, regional and national level should be

encouraged to develop safer, less exposed storage sites to which

spent nuclear fuel can be moved from sites such as San Onofre that

are subject to multiple risk factors.

• If such options develop, with the active support of Edison,

responsible federal agencies should remove the canisters from the

ISFSI and transport them to remote storage.

In conclusion, we support the Commission's authorizing timely construction

of an ISFSI at San Onofre to mitigate unnecessary risks related to the

extended use of wet storage when dry storage options are available onsite.

Every possible threat (earthquakes, tsunamis, hostile acts, operational errors)

that might potentially lead to the release of radiation from spent fuel in dry

storage onsite is magnified many fold by additional risks arising from the

potential loss of electrical power and water supply needed to keep spent fuel

fully submerged and protected in pools.

Once power generation operations stop and remaining spent fuel is moved to

wet storage, as has occurred at San Onofre, every available caution should

be taken by moving the spent fuel to dry storage and ending any use of wet

storage as soon as best practices allow.

Thank you for consideration of our thoughts.

Glenn Pascall, Chair

Sierra Club Task Force on San Onofre

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



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** Ace Hoffman
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