Saturday, March 26, 2016

A modest proposal for SCE's Community Engagement Panel... and their "hot potato"

March 26th, 2016

David Victor showed his hand last Thursday evening at the Community Enragement Panel of Southern California Edison, also known as the "let's find a way to pretend this waste doesn't exist" committee.

We can all see the deck is stacked. The outcome of CEP recommendations has to be in SCE's favor. SCE would have it no other way, which presumably is why they picked David Victor to chair the committee.

One panelist, an elected official from Oceanside, was lauded for passing around a timid resolution to other nearby cities, endorsing any form of interim storage and the basic idea of moving the waste away from San Onofre as soon as possible.

Not one of the CEP panelists who spoke is actually focused on the waste issue -- other than asking the federal government to "do its job" and "take the waste." Every CEP panelist who spoke about "waste" at the meeting assumed that the reason the waste remains on site is simply politics at the federal level. They do not realize or acknowledge the insurmountable technological hurdles that have kept the nuclear waste issue from being resolved for ~75 years. They want to implore the feds to do something. They want to bypass the federal regulations somehow (but of course, they expect the feds to regulate the waste, since, as one of them put it, "nobody else understands it"). They want to find a loophole that will let SCE and other utilities pay off some small community and ship the waste away from our crowded, lovely coast. They want to magically make our problem be somebody else's problem.

Everyone on the panel wants the waste to be moved -- a unanimous opinion. But no one on the panel faces the real question of how to properly handle the waste while it's here -- for decades, maybe centuries, maybe forever. They leave that question -- what to do in the meantime -- to SCE. And yet, from the citizen's perspective, from the ratepayer's perspective, those immediate questions are, by far, the most important -- and we were asking them long before the plant shut down in 2012. What are we going to do with the waste? What is society going to do with the waste? Exasperated with having to ask it, activists have long-suggested that pro-nukers either: Eat it, carry it around with them, or keep it on their own property (and their children's property, etc.). Not one person, not one community, has come to a CEP meeting to say they want the waste, and would SCE please just ship it over to them. And none will.

During the meeting, the public was implored several times to attend a Department of Energy hearing in Sacramento, California on April 26, 2016. The subject of the hearing is: "Consent Based Siting" of interim nuclear waste storage. Not that anyone present was expected to encourage their own community to HOST a nuclear waste site! No, we are supposed to let the DOE know how badly we want them to find -- and force -- someone else to take the waste!

Meanwhile, places like Diablo Canyon and Palo Verde continue to spew out new nuclear waste. Each reactor produces, on average, about 250 pounds of new high-level nuclear waste per day. The reactor owners -- the large utilities -- block solar and other renewable energy implementations which could have completely replaced all five of those reactors with safe power generation for the amount of money spent on Palo Verde and Diablo Canyon's steam generator replacement projects (even though theirs were "successful" compared to San Onofre's steam generator replacement fiasco).

It is clear that if there are ever to be "interim" storage sites for nuclear waste, San Onofre's CEP needs to take a look at the already-operational nuclear waste sites -- operating nuclear power plants and a few other closed sites. Why does CEP think those operating, fully-staffed nuclear sites, which already store spent nuclear fuel of their own, can't take the much-cooler (since none of it is "fresh" out of the reactor) spent fuel waste from nearby permanently-closed nuclear power plants like San Onofre? Problem solved: We have "consolidated interim storage" without even having to ask for it, and without having to find new willing communities to take the waste.

But the CEP won't look at Palo Verde, even though it's currently (because it's open and operational) the most logical place for SanO's waste to be stored: Away from the coast, away from the earthquake zone Diablo Canyon is also in.

Disclosure: My sister and her family live in Tucson, about 150 miles from PVNPP, so I'm not advising we do that, of course.

But I'm quite amazed that the CEP won't even discuss asking SCE about storing San Onofre's nuclear waste at Palo Verde. The CEP could recommend that since SCE is a part owner of Palo Verde (15.8%), SCE immediately move forward with putting San Onofre's waste there. Yet they don't even suggest it, let alone demand it ("demand" would have no legal authority, of course, since the CEP is toothless, but it would look good and get media attention, that's for sure!). Actually, SCE could probably move the waste there without asking anyone's permission except the Nuclear Regulatory Commission -- who, of course, would grant it. (The NRC will license a mule-pack full of uranium ore and give a miner lung cancer. They'll license anything.).

But the Palo Verde option is never put on the table because the nuclear industry knows there is no PROFIT for whoever ends up with the waste, and no one in the industry wants continued responsibility for the waste after the plants have closed. In fact, the utilities plan to sue the federal government for every penny spent on nuclear waste (that is, everything they can't soak out of the ratepayer via the Public Utilities Commission). They are already suing -- and winning -- because Yucca Mountain did not come to fruition.

The nuclear utilities are far more interested in the legal ramifications of keeping possession of the spent fuel, than their moral obligations in dealing properly (as much as such a thing is possible) with the spent fuel hazardous waste they produced. They will only settle for a plan that helps Diablo Canyon stay open, even though it's obvious that the problem they are trying to solve is unsolvable, and pretending Diablo Canyon will ever have a cost-effective, safe, reliable solution to their waste problem is absurd. Nuclear waste is the "hot potato" game we all learned as a kid (whether we actually played it or not, we knew about it), but in this case the "hot potato" is really hot, really dangerous, and would kill you instantly if you held it -- and weighs far more than you might expect (uranium is a very dense metal).

The nuclear industry could solve San Onofre's problem -- but not every reactor's problem -- by simply moving San Onofre's nuclear waste to Palo Verde. This could be started sooner and completed faster than any other temporary, interim, or "permanent" solution.

However, no nuclear power plant owner/operator anywhere wants to be the one to get everyone else's waste. And even those communities that support their local nuclear power plant, would object to getting any extra waste that wasn't produced by their own nuclear waste production facility, aka nuclear power plant, the power being a fleeting byproduct of the operation, the real product is hazardous radioactive fuel assemblies. To each his own, and to their children, and their children's children.

The CEP should be telling the public about what a "hot potato" this waste really is. Every nuclear power plant would gladly pay hundreds of millions of dollars -- that's a lot of money -- for someone -- anyone- -- to take their waste. They would even pay billions if they could -- as the saying goes -- wash their hands completely of responsibility for the waste they created. But there are no takers, even at those prices. (I'm sure they've considered -- and perhaps even tried -- putting it on ebay.)

But this is the Internet age, and every community out there knows the score. Even SCE executive/spokesperson Tom Palmisano agreed that any timetable for disposing of (he means moving) San Onofre waste would depend on several needed solutions that don't yet exist. There are no "interim" sites available at this time and only two supposedly under consideration, one in Texas and one in New Mexico, neither of which would be anything but a disaster-waiting-to-happen, being under flight paths, not underground, not covered with 8 to 20 feet of reinforced concrete...just huge pads of deadly radioactive cylinders. These would be the same cylinders San Onofre plans to place in several cement (NOT reinforced concrete (except the base plate)!) "islands" on site at San Onofre -- a plan Palmisano has taken to calling "underground" but it isn't underground, it's merely recessed into the earth a bit.

Palmisano assured the public all of the waste that is currently in dry casks at San Onofre could be moved "today" and the rest within 10 years -- if there is a place to put it. And a vehicle to transport it in, and the right infrastructure (roads, bridges, etc.) between hither and yon. But assuming all that was in place, he assured the community the waste could be moved now or within a decade.

Palo Verde plans to remain operational far longer than that, and most of the route from San Onofre to Palo Verde is fairly desolate. So why won't the CEP, or SCE consider Palo Verde as the "perfect" spot for their nuclear waste? (Should I mention a train struck an army fuel tanker truck at a "desolate" crossing along that route about a year ago, causing a massive fire and closing the nearby highway for about 5 hours?)

Or for that matter, why isn't the CEP considering shipping the waste to Diablo Canyon? Pro-nuclear activists around that site have already stated in public to this author that they would "gladly" take the waste! So why won't PG&E "gladly" take it off our hands?

Disclosure: I have friends who live near DCNPP, so I do not endorse this idea!

If such locations are deemed safe enough for their own nuclear spent fuel waste, aren't they safe enough for San Onofre's waste, too? And haven't those communities already consented to be nuclear waste dumps, at least until a decade or more after their own reactors close?

So why isn't this option being explored by the CEP?

I suspect it's because it leads to one inevitable conclusion: No plant will want to remain open if it means becoming a repository of another plant's nuclear waste. Not even when the two facilities are owned (15.8%) by the same company! That's how deadly, despicable, and dangerous nuclear waste really is.

It contains fission products which are radioactive isotopes of elements which mimic biologically-useful elements such as calcium. It also contains plenty of fissionable heavy metals, such as uranium and plutonium, which some people want to extract and use again. These isotopes can no longer be used directly in a reactor because other radioactive elements that are not fissionable (by neutrons) are interfering with the nuclear reaction. That's why the "spent" fuel was removed from the reactor: NOT because it was empty of fuel, as the name implies, but because it was full of "poisons," which is a nuclear industry term for the nuclear waste isotopes that build up and prevent the chain reaction from continuing. It is also the proper term for what radioactive substances all are in the first place: Poison.

At the end of Thursday's CEP meeting, David Victor wished for anyone willing to call his organization "criminal" to step forward and do so. I'll gladly do that, Mr. Victor! Your organization is hoodwinking the media and the public, claiming to be something it is not -- namely, a central gathering of ideas. Instead it is a blockade to the truth. It is as if the tobacco industry had made a committee of government "volunteers" and a few heads of charities to pronounce tobacco safe for children and other living things! With one hand-picked token "environmental" group -- the Sierra Club. The SC rep believes simplistically in "deep geologic storage" as the best solution, but Interim Storage Anywhere But Here is also alright with him, so he graciously goes along with everything the CEP chairman and SCE representative want. (Note: In a developing story, the SC panel member referred to a letter signed by another SC volunteer from a national SC working group as a "hoax," but in fact, he is the real "hoax" since his job description both at the CEP and at the Sierra Club includes engaging with other activists in the local community, which he refuses to do -- instead he denigrates them unjustly to the rest of the CEP panel, and never responds to their viewpoints in any logical fashion.)

Nuclear waste can be as complicated to handle properly as a nuclear reactor is to run. And like flying an airplane or operating a nuclear reactor, most of the time nothing out of the ordinary seems to be happening at all, until one day, all hell breaks loose.

Spent fuel can have accidents that are just as large as what an operating reactor can do and perhaps even larger, since there is usually more than one reactor-load of spent fuel at any spent fuel location. Although such accidents are reasonably considered far less likely than an accident at an operating reactor, they are nevertheless possible.

The same day that the CEP held its quarterly meeting, it was revealed that the Brussels attackers, the terrorists who killed 30 people at coordinated sites in Belgium earlier in the week (including at least two Americans) -- had 12 hours of footage taken outside the house of a top official at one of Belgium's nuclear research/medical isotope facilities. They were undoubtedly planning a kidnapping of some sort, and using him (or his keys or codes) for access to the facility. "Non-essential" crews at two Belgian nuclear facilities were "sent home" soon after the terrorist attacks at the airport and subway station in Belgium -- presumably because authorities wanted to recheck every person on site to be sure they had not already been infiltrated. Reportedly several workers were "stripped of their security badges."

Not a word of this terrifying incident was spoken at the CEP meeting by any of the panelists, even though nuclear waste is capable of destroying an area approximately as large as a nuclear power plant accident can destroy: Far more than was lost in Fukushima or Chernobyl, which were bad accidents, but nowhere near as bad as a complete vaporization of the uranium fuel, the worst of all possible hazards. Could spent fuel be vaporized in an airplane crash and subsequent fuel fire and/or criticality event? Perhaps, but if that's not enough, additional explosives and high-temperature flammable material could be included as cargo on board a private jet with a suicidal pilot on board. No interim storage site is planned anywhere that can withstand all possible attacks by humans or by mother nature. Instead, the government makes calculations as to the likelihood of various events (called "Probabilistic Risk Assessments" (PRAs)), and even this week, terrorism by air is still discounted almost entirely by the NRC (they assume TSA will stop such events every time, giving them a PRA value statistically equivalent to zero). So is drone terrorism, and even cyber terrorism. The largest ground attack force is estimated to be about three people -- and the theoretical attackers are not even suicidal, and have, at most, help from only one inside operator.

Numerous very real threats to our nuclear stockpiles get lip service, nothing more.

But admittedly, in some cases, nothing more CAN be done than to pay lip service to the threat, and hope it doesn't happen. Meanwhile, another 400+ foot tunnel was found between the U.S. and Mexico.

San Onofre is vulnerable to tunneling, airplane strikes, drone strikes and cyber attack, and perhaps even easier (or more effective) vectors of penetration, including exploding an LNG ship at the planned offshore distribution hub that is being considered for the now-closed San Onofre reactor complex. Is there anyone on earth who doesn't want the waste moved before LNG ships arrive offshore?

Yes: The people at the planned destination location. That can't be resolved diplomatically, because they are nobody's fool anymore. They (and the people surrounding them, and the state they live in) all have a democratic system of government to protect them (in America). Ah, but do they? Obama's Blue Ribbon Commission tried very hard to get around that little problem of democracy in siting an "interim" nuclear waste site. They are still stymied, as time marches on (and reactors make waste piles bigger).

Perhaps this is why attorney Michael Aguirre described the CEP as part of a criminal organization. They -- and especially their chairman -- kowtow to Southern California Edison. The chairman makes up rules on the spot, rules which make it impossible for a citizen to interact with the utility itself, or even with the other CEP panelists, for that matter: Even when a panelist tries to answer a commentator, that panelist is cut off by CEP chairman David Victor!

California government representatives, including local elected officials, should no longer attend these SCE "engagement panel" meetings. Instead, they should hold real hearings locally, with local residents allowed to speak for as long as required. Any real solutions anyone comes up with are bound to take more than 3 minutes to explain!

The CEP chairman reminds the public regularly that the CEP is NOT a government agency. But the news media refer to their meetings as "hearings" and every time a government representative speaks at a CEP meeting, the impression is strengthened that something important goes on there.

But in reality, the CEP and its chairman David Victor are defending an indefensible, unworkable solution, and seeking public approval of a dangerous plan with deadly consequences of failure. Sooner or later, yelling louder than the next guy is all David Victor has left, he has no moral ground for his stance, and has to resort to yelling and cutting off the microphone of members of the public, because the public is fed up with what SCE and other reactors have been offering: thin dry casks which are inadequate containment for the world's most dangerous substances.

The #1 thing the CEP should have learned by now is that if we close Diablo Canyon and Palo Verde, the southwestern states will finally all be on the same playing field about what to do with our nuclear waste. No one will be profiting from its production.

No one in the west wants east coast waste shipped to their state, that's for certain. You can bet every east coast state is eyeing "solutions" SCE might come up with for their own mounting problem.

So, until PVNPP and DCNPP are closed, it makes gruesome sense to ship San Onofre's waste to one of those sites for storage for the foreseeable future. That will scare the bejesus out of all the remaining operating reactors! Something needs to scare them and if events in Belgium don't, perhaps nothing will. Except financial ruin. No corporation survives that! And whoever ends up with the waste will surely be financially ruined sooner or later.

A modest proposal indeed!

Ace Hoffman
Carlsbad, CA

The author, a 59-yr old bladder cancer survivor, has attended, in person, approximately 100 NRC, DOE, CCC, CEC, and CPUC hearings, and well over 100 more similar public hearings via web link and phone line since those have become available from the NRC and other agencies (oddly, such two-way connections are NOT available for the CEP meetings). He has attended, in person or via phone link, all but one CEP meetings (despite dealing with another cancer in the family, and other issues at the time).


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Quotes collected by Ace Hoffman:
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"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)
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"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)
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"There is no such thing as a pro-nuclear environmentalist." -- Sen. Tom Harkin (D-Iowa, 1992)
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"Know thy self, know thy enemy. A thousand battles, a thousand victories." -- Sun Tzu (Chinese general b.500 BC)
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"Stupidity is the same as evil if you judge by the results." -- Margaret Atwood (Canadian poet/novelest/environmentalist/etc.)
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"The sun shows up every day and produces ridiculous amounts of power." -- Elon Musk (5.1.2015)
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"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)
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"Any dose is an overdose." -- Dr. John W. Gofman (another pioneer nuclear physicist who saw the light (9.21.1918 - 8.15.2007))
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"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)
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"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)
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"There are no warlike peoples - just warlike leaders." -- Ralph Bunche (8.7.1903 - 12.9.1971)
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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.
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"Resistance to tyrants is obedience to God." -- Thomas Jefferson
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"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
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"Please send this to everyone you know!" -- Ace Hoffman (original collector of the above quotes)
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This email was sent by:
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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

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.
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Saturday, March 19, 2016

124 unavailable CPUC documents vs the public's right to know

March 19th, 2016

The CPUC needs to release 124 documents relating to Southern California Edison's San Onofre nuclear (waste) generating station, and the $3.3 billion financial windfall SCE is receiving at the expense of ratepayers, as payback for destroying their own reactor through a combination of improper design, improper oversight (possibly due to misleading statements from the utility), and improper operation.

Specifically, the CPUC is in violation of Art I, Sec 3 (b)(1) of the California State Constitution, which, according to Michael Aguirre and Maria Severson in the document linked to below, requires the CPUC to construe laws about public access: "broadly [if they increase] the people's right of access, and narrowly if they limit the right of access."

We are 124 documents short of that goal. But with the CPUC controlled by a few large utilities (instead of the other way around), there's little hope for a fix as long as the CPUC remains corrupt -- and thus, little hope for saving ratepayers $3.3 billion, by charging the failure of San Onofre to those responsible: The owners/investors in this faulty technology in the first place.

Because 12 years ago, the writing was on the wall. The Steam Generator Replacement Project (SGRP) was a risky and foolhardy plan from the start, but opposition was crushed by the CPUC itself, as the utility assured them and the public (through a complacent and often supportive news media) that there would be a savings of about a billion dollars over a 20 year period if the steam generators were replaced. That assurance wasn't worth the paper it wasn't printed on, as time would tell.

There was nothing "unprecedented" about the steam generator failure, insofar as, the evidence shows that what actually destroyed the steam generators was not just the faulty design, but also this: The utility ran the reactor (Unit 3) too hot, too hard, beyond their own pre-set limits, and outside the boundaries set by the Nuclear Regulatory Commission! And that's what destroyed Unit 3. Unit 2 was run a few degrees cooler, and that's why it didn't experience the coordinated vibration of tubes that Unit 3 suffered from, known as Fluid Elastic Instability (FEI), that caused the leak, that wore out the tubes, that destroyed the reactor.

They were greedy.

And the CPUC has stood in the way of every attempt by the public to get at the facts.

They have not, however, stayed away from the utilities or their major investors.

There are four investment firms -- just four -- who together own more than $16 billion of the $66 billion (market value) the three California utilities (PG&E, SCE and SDG&E) are currently worth. Much of the rest of the market value is tied up in a few dozen other large firms.

These large firms don't want their nuclear investments going south, and they had every opportunity to tell the CPUC what to do to prevent that, because CPUC commissioners met with representatives from these large investment firms in private meetings on the 29th of February, 2012 (less than a month after San Onofre permanently shut down), and again in September of that year, and many other times as well. For example, they met dozens of times at posh locations around San Francisco, and dozens more times outside the United States (where they apparently felt they could ignore some of the disclosure rules and talk more freely with each other). Meetings were held in more than two dozen different countries just since 2000.*

In the case of the San Onofre investigation, what the CPUC did was: Nothing. Rather than initiate an immediate investigation into what went wrong, they delayed initiating that investigation (which their own rules required them to initiate at some point) as long as legally possible, which was six months after the utility itself finally admitted what we all knew within a few weeks of the sudden shutdown on January 31, 2012: The plant could never reopen again without replacing the steam generators for a third time around -- which wasn't going to happen.

Once the CPUC "OII" investigation got started, it was divided into three phases: First, one phase to gather evidence, then one to decide what to do, and finally, one to establish fault. Which, of course, was backwards. How can you decided who to charge for the failure, when you haven't determined who is at fault? What the CPUC did next was even more bizarre: Having determined that the ratepayer should pay (the second phase of the investigation), the CPUC concluded that the third phase -- determining fault -- simply was no longer necessary. It was cancelled outright!

The NRC's investigation was a failure, too. The NRC would not release the actual operational numbers because the utility claimed the information (on a failed pair of reactors of a unique design, that would never run again) was confidential. The NRC apparently also wouldn't USE the numbers they wouldn't release to figure out what happened (flow rates, temperatures, pressures, percentages of steam to water at various points in the process, circulation ratios, numbers like that).

Instead, the NRC investigation concluded that they couldn't decide what caused FEI to occur in Unit 3 but not in Unit 2, but that it was, in their opinion, probably due to minute differences in the tolerances of the manufacturing processes for the Unit 3 replacement steam generators versus the Unit 2 replacement steam generators.

The difference in manufacturing procedures between Unit 2 replacement steam generators and Unit 3 replacement steam generators supposedly cut the resistance to vibration in Unit 3 compared to Unit 2 by half. However, the friction force in Unit 2 was still only about 6% of the amount of force needed to prevent vibration in the tubes. So this was not the real cause of FEI occurring only in Unit 3's steam generators, and not in Unit 2. The manufacturing differences were, at best, only a small contributing factor.

What had caused the problem, then? Who was really to blame? Southern California Edison made most of the mistakes, and acted most egregiously. When the project was presented to the public and to the CPUC, SCE claimed they were proposing a "like-for-like" exchange of shiny new rebuilt steam generators, which would be even better than the originals because they were going to be made with Alloy 690, instead of Alloy 600, and, they told the CPUC, Alloy 690 is much more corrosion resistant and will last much longer -- maybe even 60 years, certainly 40, they said.

Unsaid was that Alloy 690 also happened to be 10% less heat conductive. Because of this, SCE needed to redesign the steam generators pretty significantly to try to get the same kind of PROFIT that they were getting before. They added hundreds more thin tubes to each steam generator (for a total of 9,737 tubes per steam generator) by removing a "stay cylinder" from the middle of each steam generator. In doing so, they didn't account for the loss of a column of relatively cool water that previously rose up the middle of the steam generators. In the replacement design, the central area was being heated just like all the rest of the water in the steam generator secondary loop.

This extra heat transfer area allowed SCE to generate more steam and more PROFIT. But it also caused an area around the top of the "U-bend" of the Unit 3 steam generators to "dry out" completely: There was (approximately) less than one half of one percent water in the mixture of steam and water in an area near the top, the hottest part where there is the highest percentage of steam to water. That is not enough to dampen vibrations, and after just 11 months of operation, one of the Unit 3 steam generators began to leak.

Immediately above the U-bend, most of the remaining water is removed by centrifugal "dryers," which work like the way many modern vacuums remove dust using a tornado-like funnel of air. The water that is removed at the top of the steam generator is immediately pumped back around to recirculate in the steam generator. Before turning to steam, most of the water goes around four to five times in typical pressurized water nuclear reactor steam generators. San Onofre's circulation ratio was much lower: between three and four: They were getting a lot of steam, and quickly -- but the tops of their steam generators were drying out and vibrating.

But the utility was handing out bonuses to the control room operators for successfully producing more steam and more PROFITS!

They were publishing articles about themselves in the trade papers, telling what a wonderful job they had done, passing off a massive improvement in profits as a "like-for-like" routine replacement that would save the public $50 million dollars a year -- which comes to somewhere between about two and three dollars per meter per year. For this, the entire southern California area was to be subjected to the risks of nuclear power for 20, 40, or maybe even 60 more years!

But now, the CPUC wants to make ratepayers pay for SCE's failure, for their greed, and for their mismanagement. Instead of (allegedly) saving a couple of bucks per meter per year, the steam generator replacement project will cost ratepayers several times that amount, for many years to come.

The citizens of southern California are still far better off with San Onofre closed, with the spent fuel pile no longer growing, but there is no reason the ratepayer should have to pay for SCE's criminal negligence. And that this whole nearly-catastrophic failure was criminal negligence is one of the few things that has come out, despite attempts by the CPUC to hold back the facts of what they did, and the NRC's willingness to withhold operational data, and the utility being allowed to say nothing most of the time, and to lie when they do speak.

The utilities are legally allowed to lie, because only the NRC can investigate the veracity of anything they say (the CPUC, CCC, CEC, etc. will all claim not to be "experts" in nuclear matters). And the NRC has already stated that statements made by the public officials of the utilities they regulate are not themselves regulated activities, and therefore will not be investigated. So the utilities can -- and do -- lie any time they want. A little radiation is NOT good for you!

After San Onofre closed permanently, the CPUC added insult to injury by blocking the use of renewable energy from the Imperial Valley which could have been used to replace more than 500 megawatts of electricity San Onofre had been producing (about 25% of SanO's total output). Instead, that power has been provided by new gas-fired power plants, adding to California's CO2 burden, rather than subtracting from it.

And Diablo Canyon needs to be closed because of earthquake risks (and tsunamis risks as well, although it is at a slightly higher elevation than San Onofre). The CPUC relies on the utilities to study the earthquake/tsunami risk, but the NRC lets the utilities use fault-prone (pun intended) risk analysis to show that there "probably" won't be an earthquake significant enough to destroy the reactors, the spent fuel pools or the (ever-growing) "farm" of dry casks.

But there are clean alternatives -- cheaper alternatives, too, even if they are less juicy to outside investors (such as solar rooftops, made in California and installed with local labor). Since clean alternatives exist, why is "probably" (as in "Probabilistic Risk Assessment") good enough? Why play Russian Roulette at all? Diablo Canyon needs to be closed today! Prevent a Fukushima in the U.S.A. perhaps tomorrow, perhaps in 20 years as it rusts away on the shore, getting more and more corroded as the regulators remain corrupt. The condition San Onofre is in -- all rusted and decaying -- should be crystal-clear proof that Diablo Canyon has had its day. The investors have made all the money they deserve from it -- and more.

The California Public Utilities Commission has been a corrupted, offensive, abusive organization for too many decades, and needs to be cleaned up properly, so that the San Onofre mess can be cleaned up (somehow), Diablo Canyon shut down immediately, and available renewable energy options taken and encouraged. Why this hasn't happened already needs to be exposed. Greater transparency is needed for the greater public good.

Ace Hoffman
Carlsbad, CA

Here is a link to the Aguirre & Severson document:
http://www.animatedsoftware.com/environm/onofre/2016/R_14-11-001-IID_COMMENTS_TO_SCE_3-16-16.pdf

* List of countries outside the United States where the CPUC and other state officials met with utility investors courtesy of the utility-funded California Foundation for the Environment and the Economy (CFEE) (2000 - 2015; from Aguirre & Severson):

Australia, Belgium, Brazil, Canada, Chile, China, Denmark, France, Germany, Holland, Hong Kong, Hungary, New Zealand, Norway, Inner Mongolia, Ireland, Italy, Japan, Poland, Portugal, Singapore, South Africa, South Korea, Sweden, United Kingdom, Spain

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** Ace Hoffman, Carlsbad CA
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Friday, March 18, 2016

Statement to regulations.gov re: decommissioning; comment 1k0-8okr-x2eq)

March 18, 2016

To Whom It May Concern (NRC),

Decommissioning nuclear power plants is a fiasco. Some reactors are entering a third 20-year operating period, and yet they still haven't been able, in the first 40 years, to fully fund their decommissioning accounts.

This is clearly intentional: The lack of funds is used again and again by utilities around the country (and around the world) to justify continued operation of the nuclear power plant, specifically to further fund their own decommissioning.

This is penny-wise and many pounds of radioactive fission products foolish!

Especially because it is unquestionably true that numerous reactors would close today if their decommissioning funds -- which have been growing for three decades or more -- were fully funded.

Furthermore, a so-called "decommissioned" reactor these days is still a very dangerous thing, since invariably the spent nuclear fuel remains on site. The maximum size of the catastrophe that can occur at a closed nuclear reactor is nearly as large as at an operating reactor. Surely the NRC knows this, there is no way they don't. But with the statistical garbage known as a "P.R.A." (Probabilistic Risk Assessment) the NRC and the nuclear industry pretend that the dangers have significantly subsided: Fire brigades that were kept near the reactor when it was operating are nowhere to be found for a "decommissioned" reactor, yet a spent fuel pool drain-down and subsequent fire, or a dry cask fire (perhaps following an airplane strike, accidentally or by a terrorist) would be every bit as catastrophic as Chernobyl or Fukushima was. Maybe worse: There are more than 30 refueling cycles stored at San Onofre. If all were destroyed in an earthquake or other catastrophic event, far more radiation would be released than an operating reactor contains. What would be missing would be the short-lived radioactive products, but fission products with approximately 30-year half-lives would flood the environment, along with hundreds of longer-lived isotopes.

Yet security and fire protection are both significantly reduced at so-called "decommissioned" reactor sites!

It's time to fully fund nuclear reactor decommissioning plans: And as costs keep rising, fund them more. It's likewise time to close the reactors, lest an unaffordable accident happen first, and because there's no benefit in increasing the pile of nuclear waste at any nuclear site.

There is no cost-effective solution to the long-term safety problems created by nuclear power, but the less high-level waste there is to guard, the better. Canisters get old, cracks develop, and costs go up. There is no stopping that progression ("rust never sleeps"), and current approved dry casks, made of so-called "stainless" steel just 1/2 to 5/8th inch thick, are planned to fail, on the assumption they will be moved somewhere that doesn't exist some time before they fail. But that plan has no future, and the time it will take before failure may be far less than the NRC and the nuclear industry assumes.

Ace Hoffman
Carlsbad, California
March 18th, 2016

The author has been studying nuclear power for many decades.

To leave your own comment before midnight tonight (DC time!):
https://www.regulations.gov/#!submitComment;D=NRC-2015-0070-0007;p=1



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** Ace Hoffman, Carlsbad CA
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