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)

Attachments

Attachments

to Glenn, Carole, NIRS, Rita, SOS, me
Attachments

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>
[]

Attachments area
Preview attachment Sierra Club Statement to CCC.docx
[]

[]
Sierra Club Statement to CCC.docx


joeholtzman@gmail.com

12:00 PM (15 hours ago)
Attachments

Attachments

Attachments

to Donna, Glenn, Carole, NIRS, SOS, me, Rita
Attachments

I totally disagree with Pascall !!

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


Glenn Pascall

Attachments


12:17 PM (14 hours ago)
Attachments

Attachments

Attachments

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

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

Attachments area
Preview attachment Sierra Club Statement to CCC.docx
[]


Sierra Club Statement to CCC.docx

Ace Hoffman <acehoffman@gmail.com>

5:27 PM (9 hours ago)

Attachments

Attachments

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

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

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



************************************************
** Ace Hoffman
************************************************