Saturday, October 25, 2014

Speak out Monday (10/27/2014) in Carlsbad, California to protect southern California from becoming a nuclear wasteland...

Some time in the future, possibly today, a full-scale nuclear meltdown in America is virtually inevitable. There are simply too many cracks in the regulatory system for any other result.

It happened at Chernobyl in Russia, it happened at Fukushima in Japan, and it has already nearly happened many times at various nuclear power plants in America. We've been lucky, and luck runs out.

The Nuclear Regulatory Commission's rules for making rules are the problem, because of the layer upon layer of roadblocks to logical conclusions. The inevitable result will be a meltdown in America, because the rules are getting softer, not tougher, just as the industry is in need of more and more loopholes and shortcuts to make money and stay mildly competitive. In some states, including California, they are helped by the states' Public Utilities Commissions, which insures the utility a profit, in many cases by blocking cheaper (for the ratepayer) renewable energy options.

The NRC has many rules, and many of them change all the time. Some get weaker, if things don't go wrong, while others get stronger, if things do. (The American nuclear industry is still bucking even the relatively minor changes (which would cost about two dozen plants in America a few tens of millions of dollars) following the Fukushima accident three years ago.)

Among these rules, however, are a few very special rules designed to prevent duplication of effort, wasted expense, wasted time, and uneven regulatory enforcement.

These rules make it very difficult to revisit an issue which has been previously decided in the nuclear industry's favor. If a new plan for a replacement part is submitted to the regulators and rejected for some reason, the industry can always make a change and resubmit the application. But once the plan has been accepted, there is little that can be done to withdraw or alter that acceptance. Furthermore, the NRC assumes that fabrication of parts is always done correctly, and that every operation they fail to inspect was properly done. None of these assumptions are based on reality.

Over time, a bias is introduced in favor of anything that passed acceptance, rightly or wrongly. Over time, the effect of that bias grows, with one inevitable result: A meltdown.

For example, computer-controlled equipment abounds at nuclear power plants. It's more efficient. Efficiency means a lot when you're trying to make money by boiling water, to turn into steam, to turn into a spinning object, to turn into a magnetic field, to turn into electrons flowing back and forth in wires, to convert through many different amperages and phases along miles of wires every inch of which introduces additional losses, in order to deliver electricity to homes and businesses which are flooded with it from wind and sun daily.

The overall inefficiency is staggering, so of course they've computerized everything.

Then along came computer viruses. So the industry bought anti-virus software.

Then along came Stuxnet, which attacked the motor controller boards at a nuclear facility in Iran. Many features of it were very easy to copy, and many varieties quickly followed.

Along with these software threats came counterfeit parts inside the "mil-spec" hardware components that are used to make the motherboards that control the machines.

The military has a huge problem with counterfeit parts. Every industry does. The nuclear industry is both a major user of enormous quantities of computer equipment, and a major target of industrial, political and terrorist espionage attempts.

A perfect storm.

Late to the party, the NRC is (finally) holding special hearings (mostly or entirely closed-door, as far as I know) with other agencies about hackers, viruses, encryption and other software security issues. (I'm not sure the hardware dangers are going to be considered at this time.)

Nuclear power plants are notoriously complicated machines. Try as they might, no one has been able to simplify them. In fact, it's only gotten worse with added computerization in the control room and in the machinery throughout the plant.

The nuclear reaction itself is a complex balance of the density of neutron moderators against the available quantity of various isotopes for fissioning and for neutron absorption. To use the energy that is released by the reaction, water, which also acts as a neutron moderator, is heated under extremely high pressure (about 1200 PSI for Boiling Water Reactors (BWRs), and about 2200 PSI for Pressurized Water Reactors (PWRs). Change the density of the water just a little bit (by changing its temperature), and the water's ability to moderate neutrons (slow them down) can change dramatically. Stop circulating the water, and the metal overheats, the zirconium catches fire, the fission products are released, and finally, the ceramic pellets of uranium and plutonium oxides melt down through the steel reactor pressure vessel in a radioactive blob known as corium.

There are three blobs of corium in Japan and one in Russia. No American reactor accident has resulted in an unapproachable (even with proper protection) blob of corium, although SL1, Santa Susana, Fermi 1** and Three Mile Island all suffered partial or complete meltdowns. (Two were relatively small "research" reactors.)

Even without a meltdown, no one can go near the reactor while it is operating for months at a time. Fixing problems usually requires shutting the reactor down, which is not risk-free. Utilities are very limited in how often they are allowed to shut a reactor down. Half a dozen times in a year would be very alarming, for instance, to the regulators. That is, until relicensing time, when all that will be forgotten as it is expected that licenses will soon routinely be extended to 80 years.

Accidents can be so severe that at least one of the reactor's backup systems "MUST" function. At least, that's the claim -- that at least one backup system will work and prevent a catastrophic release of radiation to the public.

To prevent that, reactors are designed to withstand the worst earthquake postulated for the region, the worst tornado, the worst tsunami, the worst flood, the worst fire, the worst power outage, the worst attack by a small group of lightly armed non-suicidal terrorists ... but of course, once it's been decided that something is the worst threat in a particular realm (worst earthquake expected, worst tsunami, etc.) the NRC is very reluctant to revisit that issue, even as new science comes along. In fact, especially as new science comes along that could result in getting a reactor shut down permanently. And even if a new, more strict ruling is made, it can take decades to get that rule implemented: Reactor companies ask for extensions and exemptions all the time -- and they are almost invariably granted.

All the while, each operating nuclear reactor is creating radioactive waste at the rate of about 10 pounds per hour per reactor (10 tons per day for the U.S. as a whole) which must be guarded essentially forever.

Legally, for at least a million years.

The NRC affirmed the million-year figure recently, by concluding that the proposed (and cancelled and reborn) Yucca Mountain repository would protect humanity for that long. The timing of the release of the NRC's conclusions appears to be a political move prior to the November midterm elections. The NRC did not provide backup documentation for their decision -- that's still to be published. The NRC has a habit of withdrawing documents, then rereleasing watered-down or altered versions prior to releasing any backup documentation, if it ever comes out at all. And the backup documentation may not even back up their conclusions -- this author has seen that happen many times, as well.

The State of Nevada is fighting the legal battles one might expect them to be concerned about: They don't want Yucca Mountain to happen at all and have numerous good reasons why it's inadequate: Water intrusion, earthquake issues, volcanic issues, transportation issues (they don't want that waste anywhere near Las Vegas, but that's exactly how some of the routes go), human fallibility issues (will it be constructed according to specifications and who's gonna check? And who's gonna check the checkers?).

However, the State of Nevada doesn't want to appear anti-nuclear or -- egads -- unAmerican, so in their official submissions opposing Yucca Mountain, to the NRC or to a judge, they always state that on-site storage of spent fuel at the reactor sites is safe and will remain so until an alternative site is selected.

However, onsite storage is NOT safe, and every other potential permanent repository location has already been eliminated for one reason or another, time and again. Nobody in their right mind wants the waste anywhere near them. Especially not a wised-up American.

Having no other place on earth for the highly radioactive used reactor cores puts residents of southern California at grave risk of a catastrophic spent fuel accident, with no solution in sight. Even though San Onofre is closed, the spent fuel is still a problem, and so is Diablo Canyon: Los Angeles is far closer to Diablo Canyon than Tokyo is to Fukushima. And Tokyo might have had to be abandoned if Fukushima's "corium" blobs had exploded violently (or might still have to be, if the corium explodes some time in the future...). So Los Angeles is certainly not yet safe from San Onofre, let alone, from Diablo Canyon.

Much of the risk these reactors have imposed on Californians has been the inevitable result of the NRC being a "captured" regulatory agency. And for what? For energy we don't need: Losing SanO did not cause blackouts, and there is already more than enough electricity available in California to make up for Diablo Canyon's output to the grid, and more renewable energy is coming online every day. And with a new Public Utilities Commissioner, perhaps we will see even more renewable energy (hard to believe we could do worse than Michael Peevey has been).

San Onofre's steam generator replacement project failure has become legendary within engineering circles, and somebody has to take the blame. SCE deserves a lot of the blame, but the NRC chose to absolve them of it all and instead, take the blame for the guilty-as-sin utility's engineers and executives, who the NRC protected from criminal indictments at every step. Probably to protect their own skin.

For example, after citizens demanded a "thorough" investigation into what failed in San Onofre Unit 3 on January 31, 2012, and what -- if anything -- was different about Unit 2's virtually identical replacement steam generators, NRC formed an Augmented Inspection Team (AIT) and experts were consulted. But the experts couldn't agree on the cause, and the committee concluded it might be one thing or another, but then again it might be something else, and that was the end of the investigation. The net result? It could happen again, at another reactor site. The "root cause" was never found.

The question came up (like a freight train rumbling through a small village) of whether or not Southern California Edison (SCE) should have applied for a license amendment before replacing the steam generators, -- a license amendment which SCE specifically tried to avoid. After the AIT investigation into what happened that went nowhere, NRC concluded that SCE had satisfied all the requirements for submitting data about the replacement steam generators to the NRC. However, the NRC could not produce the documentation they supposedly used to support their conclusion.

After the leak that shut down the plant, the 18-month delay (from January 31, 2012 to June 7, 2013) before deciding to permanently close San Onofre cost ratepayers in California hundreds of millions of dollars. That money could have gone directly into solar and other renewable projects.

Prior to SCE's abandoning the reactor the NRC, to their credit, delivered several dozen technical questions to San Onofre's owners for their engineers to answer. But realistically, the NRC could have and should have told Southern California Edison there was no way they were EVER going to approve any restart of EITHER reactor -- even if the steam generators are replaced again -- because SCE was no better at keeping records of what went wrong than the NRC was, and the documentation for who screwed up the calculations appears to be missing -- so who would know what else might be bogus in that hunk of junk by the sea?

NRC should never have allowed the steam generator replacement project to move forward anywhere, but especially at San Onofre. In making their decision, the NRC apparently never considered what else might have been going wrong at the plant (such as: not going on fire watches, worker intimidation, not test-starting or inspecting backup generators for years at a time, not properly setting the welding speeds on automatic welding equipment, etc. etc. etc. ).

NRC should have shut San Onofre down -- and all the others -- because of the waste problem. It's not just unsolved. It's unsolvable.

This Monday (October 27th, 2014) the NRC will hold a hearing (in Carlsbad, where I live) regarding how to proceed with decommissioning San Onofre, after SCE finally decided it couldn't squeeze the public to pay for a thousand useless high-paying jobs anymore, and so they cut the workforce to a "skeleton" size of about 350 people, and submitted a decommissioning plan (called a PSDAR) which calls for completing the project as quickly as possible -- except for the waste, which will just sit there.

The NRC meeting is to hear from the public regarding SCE's PSDAR, which is filled with utterly fantastic predictions: That the nuclear waste problem will be solved by 2024 when a national repository will open; that San Onofre's waste will be removed from the site by 2049; that giving workers a few hundred REM of radiation is okay; and that the public has been properly engaged and knows what's going on at the plant.

When the decommissioning process starts, hundreds more people will be hired. SCE is keen to see that happen. SCE already has (our) money to pay them, and the money has to just sit there, hopefully earning enough interest so that whenever decommissioning does start, there will still be enough money to pay for it. But if not, they'll just get it from the ratepayers.

Local unions want decommissioning to start -- they see jobs, and if it's dangerous -- well, that pays even better. They can't see radiation. They're not afraid of it because construction work -- and deconstruction work -- always carries a risk. That's what people do to build skyscrapers and so forth -- they take a risk that the cables and crossbeams will hold: That the design is correct. That the materials are good.

NRC has calculated the overall radiation doses the workers will receive. If deconstruction is delayed for a few generations of workers instead of started immediately as SCE is proposing, the cumulative doses those workers who finally do the deconstruction will get will be about 1/20th of the radiation dose that workers will get if the deconstruction work is started as soon as possible (10s of REM cumulatively, versus several hundred REM cumulatively).

Figures were not available for doses to the public, but those would be reduced as well -- although those are already promised to be extremely low.

The Office of Inspector General's (OIG's) report on the NRC's handling of the San Onofre steam generator replacement project was very critical of the NRC -- but still didn't go far enough. As if in response, almost immediately after the OIG's report was released, this ne'er-do-well, corrupted, captured, hook-line-and-sinker pro-nuclear regulatory agency published a ruling that is supposed to stand for a million years or more!

And the NRC's chairperson resigned -- poof, off to a cushy university.

When she was appointed, Allison Macfarlane had been lauded by Obama for her work on the Blue Ribbon Commission -- which accomplished nothing except to say that we've got to stop allowing citizens to stop a nuclear waste dump, just because they live near a small group of tribal Indians or other "sovereign" land owners who are willing to take money for taking nuclear waste.

This BRC "solution" is called such Orwellian terms as "community choice" for "interim storage solutions." (In the case of Yucca Mountain, that site is within the Nevada Test Site, which is on land already taken from the Shoshone people, and they don't want it further desecrated.)

And speaking of Orwellian terms, 70+ years and as many billions of dollars later, the unsolved nuclear waste problem is now called the "waste confidence" problem, as if half-inch thick stainless steel canisters with thousands of pounds of nuclear waste in each one is somehow safe, and as if such flimsy canisters are a defense-in-depth (as was promised by the nuclear industry and the NRC) method to store nuclear waste for hundreds of years, come what may: Fires, floods, wars... larger-than-design-basis earthquakes... the crumbling sands of time... tsunamis...

The dry casks are only tested, built for, assumed to be able to withstand 40 feet of submersion, while the waves that washed over Fukushima were nearly double that, and underwater landslides among the submerged canyons off the coast of California can cause mountainous tsunamis far taller than that. A new study was promised for decades but of course, never materialized. And even Allison Macfarlane has admitted, you can't predict when these things will happen.

The NRC says the canisters will last at least 100 years right here on our coast, but anyone who lives here knows metals don't last very long along the coast. They become embrittled, they rust, they flake, they crack... and the NRC's own studies* confirm that we'll be lucky to get 30 years from the dry casks (the ones in Diablo Canyon are showing signs of stress corrosion cracking after only about two years). If we can't figure out a good way to thoroughly inspect these canisters periodically, we won't know if they've even started to crack until it's a through-wall crack and the canisters have already started to leak.

And yet, the NRC is America's last line of defense, which is why, despite it all, I encourage all citizens to come to their meetings and complain.

Ace Hoffman
Carlsbad, CA

* Actually, the NRC didn't do any cask degradation studies themselves, they commissioned Sandia National Labs to do some, because the NRC doesn't have the expertise or resources to do the studies, and the industry doesn't have the interest in doing them.

** Fermi 1 was added after the following letter was received from Kay C.:

Hi Ace,

Just a reminder that one of Michigan's reactors, Fermi 1, also had a partial meltdown in 1966. John Fuller wrote a book about it: "We Almost Lost Detroit." From my understanding, it was a lot like Santa Susanna. 
-----------------------------------------------------------------------------------------------
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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
Carlsbad, CA
Email: ace [at] acehoffman.org

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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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Sunday, October 19, 2014

Judge Sullivan resorts to incomplete logic in order to bar world-renowned expert from testifying in "flowers" case...

Four grandmothers attempted to plant flowers to bring attention to the dangers at Pilgrim nuclear power plant. But Judge James Sullivan refused to allow world-renowned pediatrician and nuclear expert Helen Caldicott to testify in their defense, because he (the judge) sees a huge difference -- when pushed to see it by the District Attorney -- between "potential theoretical harm" and actual imminent harm.

The defendants -- four women 60 to 80 years old -- are using the "necessity" defense. Is there an immediate danger? Is the illegal act (trespassing) effective in addressing and abating the danger? The judge refused to learn how quickly a nuclear power plant can explode. He refused to hear that the plans for evacuation require immediate action for millions of people around the plant. She refused to consider that the warning that it's time to evacuate must be sent out by people who, if they fail to do their duty, will be responsible for the deaths of thousands of people, and end up in Judge Sullivan's court (if he survives the holocaust) to be sentenced for negligent homicide.

How imminent can you get?

And sticks and stones may break my bones but planting flowers never hurt anybody.

The judge would like to turn the issue of nuclear safety away. Not his concern. Not in his courtroom. That's for the Nuclear Regulatory Commission to decide. They say it's safe. And for the judge, that's the end of the "imminent threat" defense.

But as nuclear industry veteran Arnie Gundersen puts it, a nuclear power plant "can have 40 good years and one bad day." That's forty years for activists to address the serious dangers of nuclear power, and get the plant shut down permanently. 40 years to look at the waste problem the plant is creating -- waste which, like at San Onofre, which will never generate nuclear power again -- will have to be watched closely for thousands of generations or it can become a burning cauldron of poisonous gasses, just like Fukushima but with fewer of the short-lived fission products. Zirconium is touchy, dangerous, wicked stuff. And that's just the cladding! Inside are fission products, plutonium and unfissioned uranium -- the "hot" stuff.

I don't like to break the law and don't encourage others to do so, either.

But this industry has to be stopped.

For years, activists went to the Nuclear Regulatory Commission to complain about goings-on at San Onofre. From skipping fire watches to improper welding procedures for the dry casks they were building, to worker intimidations and firings -- all this leaked out, year after year, from whistleblowers and former employees of the plant.

The activists would tell the NRC, the NRC would promise to investigate, and that would be the end of that. Why did a crane fall 80 feet in the turbine room? The crane was being removed after it was rented to replace the turbine shaft, which had run out of oil during a small fire while the fire departments were arguing. Yes, these things really happened, and the turbine shaft suddenly screeched to a halt, bent, and had to be shipped to Japan for repairs which took six months. Local city firefighters who had responded weren't allowed to do their jobs because the on-site fire brigade thought they had it under control. They didn't. When they finally relented, it was too late, the shaft has seized and was damaged. The reactor was SCRAMmed, a violent and dangerous procedure.

It all happens in an instant, but the proper way to prevent it is to shut the plants down. It's shutdown or meltdown for every reactor in the country.

Over the years, local activists talked about all sorts of (non-violent) illegal actions they wanted to take, to try to raise awareness of San Onofre's dangers, but the Nuclear Regulatory Commission has deaf ears, the state agencies close their eyes to anything having to do with "safety" of nuclear power plants, saying the NRC has sole jurisdiction in that area, and the courts? Judge Sullivan finds a two-bit excuse to exclude the whole crux of the problem: You can't hold nuclear power accountable.

Activists fighting San Onofre were dogged in their efforts and clear about their targets: The Nuclear Regulatory Commission and the utility itself. Once the new replacement steam generators had failed and the reactor was inoperable, the cry was adamant: PROVE restart of Unit 2 is safe. Show us what's different. Show us how you're going to know what's going on inside the steam generator. And show us how you can be sure a cascade of tube failures can't occur, since adjacent tubes of dime-thin metal were clanging into each other and had worn 99% of the way through. Most of all, show us a plan to handle such an accident if it does occur.

Friends of the Earth (FOE) even took the NRC to court. It could have been Judge Sullivan's court, but fortunately it happened in another part of the country (I believe FOE court cases on behalf of San Onofre's citizens were filed in D.C.)

I don't like to break the law, but if planting flowers on someone's property can get a decent hearing on a critical issue of safety for the community, I'd let it happen. Shame on Judge Sullivan.

It would appear that the system worked for San Onofre and an imminent threat was averted. The people were spared all the potential disasters except (and this is a big exception) those associated with the spent ("used") fuel.

The battle to protect the public from that is a long and daunting one, but the first step is shutting down the plants -- and planting flowers instead.

Ace Hoffman
Carlsbad, CA

Note #1: In the above essay, references to Judge [James] Sullivan have been gender-corrected from the original.

Note #2: A few days later, Dr. Caldicott was allowed to testify.  See:

 http://www.capecodonline.com/apps/pbcs.dll/article?AID=/20141023/NEWS/410220318

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

Judge snubs expert at Pilgrim trial


By CHRISTINE LEGERE
clegere@capecodonline.com
October 18, 2014

PLYMOUTH ­ A Plymouth District Court judge barred an internationally known expert on the medical and environmental dangers of nuclear power from testifying Friday on behalf of four Cape Cod activists charged with trespassing onto the Pilgrim Nuclear Power Station's property on Mother's Day.

Dr. Helen Caldicott had traveled from Australia to serve as the principal expert witness at the trial of the alleged trespassers, who argue that their actions of civil disobedience were performed for a greater good.

Related Links

Read more about Pilgrim Nuclear Power Station

Defendants Diane Turco of Harwich, Sarah Thacher of East Dennis, Mary Conathan of Chatham and Susan Carpenter of South Dennis are using the "necessity" defense, which requires their attorney to prove there was an immediate danger and the action of trespassing was effective in addressing and abating the danger.

The four women, who range in age from 60 to 80 and call themselves "The Grandmothers," say they went onto the Pilgrim property to plant flowers. Their action came at the end of a Mother's Day rally intended to raise awareness of the dangers they say the plant poses to the public.

Instead of allowing Caldicott to testify Friday, Judge James Sullivan ordered her to undergo preliminary questioning so he could determine what direction her testimony would take.

The doctor told the court that while she has spoken and written on the dangers of nuclear power in general, she spent 20 years in the Boston area and has specific familiarity with the Plymouth nuclear plant.

"I've been concerned about Pilgrim for many years and have given lectures on this plant many times," she said. "This is an acute emergency. People on the Cape are at a severe risk."

Plymouth County Assistant District Attorney Amanda Fowle argued that Caldicott and future witnesses for the defense would show "potential hypothetical harm" rather than actual imminent harm.

Sullivan agreed. "She's telling the court what could happen and what the potential risks are," the judge said. "The necessity defense can't be based on speculative information. I have no choice but to preclude her testimony."

The judge told defense attorney Bruce Taub he may allow Caldicott to testify Wednesday "if you bring in other witnesses that make her testimony relative." He suggested nuclear engineers as possible expert witnesses, but then told Taub he could not add any witnesses to the existing list.

Taub intends to have state Sen. Daniel Wolf, D-Harwich, kick off Monday's testimony, followed by Dr. Richard Clapp, founding director of the Massachusetts Cancer Registry, and political scientist Joseph Gerson, who will testify on acts of civil disobedience to prompt social change.

Caldicott said later she was "very annoyed" at the judge's ruling. ­He knew I'm an expert on childhood diseases and I could talk about that," said the doctor, who has been an instructor in pediatrics at Harvard Medical School and a staff member at Children's Hospital Medical Center in Boston.

"I don't think the law should be deciding the medical dangers of the nuclear plant," she said. "We who know medicine should be deciding.

"International studies show children living within 2 miles of a plant have double the incidence of leukemia, and that's almost certainly happening here," she said.

One of the alleged trespassers, Thacher, did testify Friday. The 80-year-old great-grandmother called the plant "an insult to our humanity and to our children."

Fowle asked Thacher why she went onto the Entergy-owned Pilgrim property. "I hoped to bring attention to it and get people as mad as hell about this unfeeling continuation of the poisoning of our atmosphere," Thacher answered. "My effort is for all the children in the world. They're all getting hammered."

During opening statements, Fowle said the prosecution had not been given adequate notice of the witnesses the defense would present.

She said Taub had not provided the list and the background material on the witnesses until Wednesday.

Taub apologized and said it was not intentional.

"This is a significant case," Sullivan warned. "The defendants are facing incarceration. It's important we do this the right way."

Turco, who founded the anti-Pilgrim group Cape Downwinders and who is the only defendant representing herself, agreed with the judge.

"It is serious, but it's serious because it's about public health and safety," Turco said. "Jail time is secondary."

Follow Christine Legere on Twitter: @chrislegereCCT.




Re: [NukeNet] Judge denies Caldicott testimony

Cape Cod Times video: Helen Caldicott at Pilgrim Nuclear Plant Trespassing trial


[ go to Re: CCT web page for video)


At 06:47 AM 10/18/2014 -0400, "Diane Turco" <tturco@comcast.net> wrote:
>http://www.capecodonline.com/apps/pbcs.dll/article?AID=/20141018/NEWS/410180309
>
>Cape Cod Times article on the Grandmothers Trial!.Diane
>_______________________________________________________________________
>NukeNet Anti-Nuclear Network (nukenet@energyjustice.net)
>
>Un/subscribe or change your settings at:
>http://energyjustice.net/mailman/listinfo/nukenet_energyjustice.net


Saturday, October 18, 2014

Suggested preamble to San Clemente city resolution...

Here's a suggested preamble to San Clemente's resolution about the nuclear waste, and some comments.

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Our forefathers made a mistake accepting the production of this waste within our community.

Nuclear power was and will forever remain a forbidden fruit, because the so-called by-products in the "production" of electricity are, in fact, the real products of the process, with electricity being just a fleeting byproduct (easily achieved many other ways). We want offshore wind farms. We want clean energy.

The fact that nuclear waste is the product of nuclear fission -- not "just" a by-product -- is a very important point. We're stuck with the waste. And we want to warn others who are making such waste that they should stop now -- don't wait -- the sooner you stop making waste, the less waste you'll have to deal with in the future. And to anyone contemplating this technology: Don't do it.

Nuclear waste has nowhere to go. Don't believe us? After 30 years and 15 billion dollars, the Nuclear Regulatory Commission approved Yucca Mountain as safe for the next million years. That's a big claim. They claim the waste will be safe at San Onofre for hundreds of years. That's a big claim too.

The last big thing the NRC approved for San Clemente was San Onofre's replacement steam generators which were supposed to last 60 years or longer, but which only lasted 11 months and then nearly wiped out southern California when they failed! An investigation by the Office of the Inspector General found numerous procedural flaws in the NRC's methodology -- flaws which can be applied throughout the commission, to every decision they make. The NRC is the ultimate lap-dog agency. Every time anyone within the NRC even thinks about throwing in the towel on nuclear power, they are drummed out of the industry forever.

Were the NRC to ever decide to shut down civilian nuclear power -- AS THEY SHOULD -- the U. S. Nuclear Navy would remind the NRC that the USN uses nuclear power for ships and submarines, and where will their reactor control room operators work after their stint in the navy is through if there are no more "civilian" power reactors?

And the U.S. Air Force has its atomic bombs -- where would they get material for those bombs if not for commercial reactors producing copious quantities of plutonium "just in case" World War III breaks out and it last more than 90 minutes before we're all smoke and ruins?

"With that in mind, we resolve that:..."

After that, San Clemente can continue to beg someone to take the nuclear waste for them. Until then, at least San Clemente can be happy that SCE/CPUC plan to spread out the costs for future generations to pay for the upkeep, replacement shielding, catastrophic loss of life and property (values) -- and all other additional expenses that might be incurred -- among communities far away from San Clemente. But if even a tiny fraction of the waste got out, it would destroy San Clemente first. And the Price-Andersen insurance will limit pay-outs long before even San Clemente's destruction can be covered. A fraction of a single fuel pellet the size of an adult human pinky bone can render San Clemente uninhabitable if its contents ignite and burn. There are millions and millions of fuel pellets, each the size of one adult human pinky bone, being stored at San Onofre. And, if one burns, probably at least all those in that dry canister will also burn, possibly igniting other cani
sters
.

Each pellet will be deadly for far more than a million years, although for the next few decades, and for the first few centuries, the used fuel is especially dangerous because it includes a lot of relatively short-lived fission products (with half-lives in the 30 year range).

Ace Hoffman
Carlsbad, CA

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Notes on what might make a better dry cask:

Thick layers of copper (used in other countries for additional shielding for long-term waste storage, but long-term applicability to its use here has not been confirmed).
Thick layers of gold (probably the 2nd best protection for all the other layers, after iridium (but not enough iridium exists on the planet (nor does enough gold)).
Fewer fuel assemblies per dry cask (this reduces the risk and potential size of a criticality event).
Gold plating on the outside (protects from insects and many other things).
Alternately-magnetized layers of steel -- thousands of them (stops many substances from creeping through the material).
Canister integrity monitoring (to ensure cracks are not developing).
If a monolith is used, fewer casks per monolith (so that the monolith can move more easily as one object in an earthquake).
High stone pyramids (to protect the area from missiles and jet airplane impacts).
After closure of all power reactors, military reactors, and research reactors (they can put one on Mars if they want) -- and ONLY after that time: Reprocessing that removes the zirconium and fission products from the plutonium and uranium, and then stores everything in a safer way.

And lastly:

A global agreement on what that best way to solve the nuclear waste dilemma. Right now there are a dozen or so different "best" storage solutions for nuclear waste used around the world. None are adequate. There is no safe place to store the waste, no safe way to transport it, no safe way to reprocess it, and absolutely no reason to make more of it.

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Wednesday, October 8, 2014

Comments on the NRC Inspector General Report on San Onofre's Steam Generator failure

The Office of Inspector General's (OIG's) report on San Onofre is out (URL below, provided by Ray Lutz).

It's pretty damning of the Nuclear Regulatory Commission (NRC).

NRC missed opportunities to see that the new steam generator designs were extensively different from the original. They could have seen that the designs were unworkable, or at least prone to vibration. Their procedures rely on random inspections, a method which invariably can miss big problems. They accept unsubstantiated claims by the licensee. They don't have the right experts doing the inspections. And they don't keep good enough documentation to reconstruct the basis for their decisions.

These are the guys in charge of the most dangerous technology in the history of the human race.

And the Augmented Inspection Team (AIT) that NRC set up after the failure? They never answered the question they were tasked with researching! (Namely: Should there have been a "50.59" license amendment procedure? (The answer was: "Yes."))

Perhaps worst of all, the NRC inspectors themselves -- despite many of them individually identifying serious problems -- still believe in the system. But truly, the system is broken because the goal is unreachable.

And what went wrong with San Onofre's steam generators is going wrong with the nuclear industry's dry cask long-term storage solution for spent nuclear fuel (called a "short-term," "temporary," "interim" or "indefinite" storage solution by the nuclear industry). The entire nuclear industry is ignoring "Beyond Design Basis Events (DBEs)" such as airplane strikes, terrorism, larger earthquakes than originally anticipated, larger tsunamis, and numerous other natural and manmade phenomena and combinations of phenomena.

Instead, regarding dry cask storage, the nuclear industry and the NRC are looking almost exclusively at the problem of hydride-induced stress corrosion cracking (SCC), such as occurs in a marine environment like at San Onofre and Diablo Canyon. Even for that, they plan on sampling less than 1% of dry casks in the country, and that's just for visible signs of damage. They might even get away with inspecting less than 1% of 1%, if the industry gets to do inspections of only ONE dry cask at ONE reactor site, as they have asked permission to do.

While SCC is certainly a serious issue, the NRC doesn't even look at the ramifications of that in the real world. For example, through-wall cracks as deep as 75% of the way through the dry cask container wall (which is only 5/8ths of an inch thick to begin with) will be allowed -- even though no seismic studies on how well a degraded cask can withstand even a design basis earthquake have been done!

Regarding the steam generator failure that doomed San Onofre, NRC had plenty of red flags on this project, and plenty of opportunities to step up their regulatory efforts, but made sure they looked the other way. San Onofre, like nearly every other reactor in America, is old and was prone to equipment failures. These "unexpected" occurrences were completely ignored in Southern California Edison's (SCE's) analysis of the cost/benefit of the steam generator replacement project. It was assumed there would never be a significant leakage problem, or vibration problem, just as it was assumed (and still is, at Diablo Canyon and other still-operating reactors) that a Fukushima-size accident simply can't happen. (There are currently 23 reactors in America with the exact same design flaws that doomed Fukushima, and all 87 other operating commercial reactors also have potential pathways to becoming the first American Fukushima -- or worse.)

The projected one billion dollar savings for ratepayers (over a 20 year period) from the replacement steam generator project assumed nothing would go wrong -- including a drop in the price of natural gas (which happened). And let alone, a drop in the price of renewable energy solutions (which also happened). And let alone, a bone-headed engineering SNAFU that could have been avoided if only SCE hadn't tried so hard to avoid regulatory (and public) oversight entirely.

NRC has some very strange ways of doing things. For example, they will accept two changes in opposite directions as being the exact equivalent of no change at all. This can make it very easy for a utility to squeeze by without any deep regulatory review.

In other words, let's say for example that a replacement pipe is made of thinner or weaker metal than the part it is replacing. That would, of course, increase the risk of that pipe bursting. But the utility can call it a wash if a different pipe that's also being replaced at the same time can be made stronger or thicker, which would reduce the risk of that pipe bursting! Such types of calculations MIGHT be okay from a total "risk analysis" point of view. But from the point of view of whether or not something is a change, it's completely ridiculous voodoo math. And perfectly legal at the NRC.

While this OIG report is pretty damning of the NRC, it by no means exonerates SCE.

The nuclear industry in America is dying a far-too-slow death. Lack of proper regulatory oversight has kept it alive far too long.

When the NRC was first formed in 1975, this author, naively, thought that, now that the regulatory and promotional parts of the Atomic Energy Commission have at last been separated (the Department of Energy being the other half, of course), the dangers of nuclear power will be recognized by the regulators, who will surely shut down this dangerous and useless technology.

So if I were to tell you that perhaps this report will start to change things at the NRC, you should take it with a grain of salt. And don't hold your breath.

However, after reading NRC regional chief at the time Elmo Collins' comments (see SD-U-T article, below, top), I'm not about to say that. NRC continues to stubbornly cling to the idea that its real duty is to serve the nuclear industry, not the public.

Ace Hoffman
Carlsbad, CA

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From: San Diego Union-Tribune:
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SAN ONOFRE REPORT FAULTS OVERSIGHT BY REGULATORS

'09 inspection cited as "missed opportunity" to identify weaknesses in generator project

By Morgan Lee 5:05 A.M.OCT. 8, 2014

U.S. nuclear safety regulators missed red flags in 2009 when they agreed to pre-approve steam generators at the San Onofre nuclear plant without a thorough review, leading to the installation of faulty equipment, according to a federal inquiry released Tuesday.

San Onofre was permanently shut down last year by plant operator Southern California Edison because of the rapid degradation of newly replaced steam generators.

In a 55-page report, the Office of the Inspector General at the Nuclear Regulatory Commission said a 2009 inspection by the agency failed to recognize "shortcomings" in the way the replacement of the huge steam generators was evaluated. It also raised questions about why Edison was allowed to install new generators without seeking a change in its federal operating license.

The inspection team from the Nuclear Regulatory Commission reviewed a decision by Edison to replace San Onofre's steam generators without prior approval from the agency, the report said. No objections were raised by the nuclear commission at the time, and installation of the new generators began in September 2009.

Edison installed the generators under a frequently used rule that allows plant operators to replace equipment without prior approval, provided they can show the switch does not cause significant changes to plant operation or safety.

A subsequent review, after the plant broke down, turned up questions about shortcomings in Edison's evaluation of changes to the original generator design and whether there was sufficient evidence to sidestep a license amendment, which can take months or years to complete.

The inspector general's report characterized the 2009 inspection as a "missed opportunity" to identify weaknesses in Edison's screening of the project, and said there was "no assurance the NRC reached the correct conclusion" when it agreed that a license amendment wasn't needed to replace the generators.

Edison is reviewing the report and had no immediate comment.

Elmo Collins, the former regional administrator overseeing San Onofre until March 2013, told investigators that if a lengthier license amendment review had been conducted, it is unlikely the steam generators would have been approved.

"The steam generators as designed were basically unlicensable," he said. "We wouldn't approve them."

He said a more thorough review may have prompted probing questions about predictions on steam velocities. Rapid wear among generator tubes at San Onofre was linked to dry, fast-moving steam.

"Some reviewer would have said this is an outlier and we need to understand that," the inquiry report said, paraphrasing Collins.

Sen. Barbara Boxer, D-Calif., faulted both Edison and the nuclear commission and said a hearing is planned before the Senate Environment and Public Works Committee. Boxer heads the committee, which oversees safety regulations for U.S. nuclear plants.

"When Southern California Edison decided to completely replace their steam generators in order to increase their profit margin, they failed to apply for an amended license as they are required to do, and the NRC stood by and did nothing," Boxer said in a statement.

The inquiry report shows that some inspectors on the 2009 team were in the midst of training on how to evaluate whether a major reactor component replacement, such as a steam generator, can go forward without a re-evaluation of the plant's safety systems. Many experts within the agency said better training and guidance is needed.

Steam generators are routinely replaced at nuclear reactors because of corrosion and wear and tear. Since 1989, 53 of the 65 plants that utilize steam generators have replaced their generators without prior approval by the commission.

Six replacements have been made following the license amendment process.

NRC spokeswoman Lara Uselding said the agency was reviewing the report.

Federal authorities traced the generator problems at San Onofre to botched computer codes used to design the generators.

Previously, the commission cited Mitsubishi Heavy Industries for flawed computer codes used in the design of the steam generators. Edison was cited for failing to properly check the design.

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At 12:26 PM 10/8/2014 -0700, Ray Lutz wrote:
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>UT news item:
>http://www.utsandiego.com/news/2014/oct/08/tp-san-onofre-report-faults-oversight-by/
>
>Actual report (55 pages):
http://pbadupws.nrc.gov/docs/ML1427/ML14276A478.pdf

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