Regarding Nuclear Regulatory Commission Docket ID NRC-2019-0073 (submitted March 18th, 2019)

To: "Krupskaya Castellon" <Krupskaya.Castellon@nrc.gov>

Office of Administration, Mail Stop: TWFN-7-A60M
U.S. Nuclear Regulatory Commission
Wash, DC 20555-0001
Attn: Program Management, Announcements and Editing Staff

I am writing about the NRC's intention to choose ten sites for public meetings so that the NRC can learn about the efficacy of "Community Advisory Boards" (as described in document 7590-01-P regarding NRC-2019-0073).

In addition to the fact that ten meetings are not nearly enough, I would like to comment on the issue.

Last week, at a presentation to the newly-formed Diablo Canyon Nuclear Power Plant Decommissioning Review Panel, a member of the DCNPP (quasi-) Independent Safety Review Board (which has existed for many years and never thought to recommend shutting the plant down forever) explained to the new panel's members that the one thing they should concern themselves with is...the spent fuel. He was absolutely right.

He said that the rest of the plant decommissioning process involves a fairly standard set of procedures within the branch of the construction industry that is involved with tearing things down. There are some highly radioactive areas that require special treatment, but he felt that was manageable (I'm not nearly as confident as he is, but we'll set that aside).

For their part, many members of the new decom panel admitted to their lack of understanding of the spent fuel issues. They intend to rely on "experts" to help them come up with suggestions for the decommissioning process.

That is a recipe for disaster. Fresh thinking needs to be applied to the nuclear waste issue!

If such a thing as a "nuclear waste expert" actually existed, there wouldn't be a nuclear waste problem that has remained unsolved despite the world's BEST MINDS applying at least a passing thought to the problem (and sometimes much more than that) for more than 70 years -- since the dawn of the nuclear (waste) age.

The problem is NOT just one of politics -- not by a long shot. Yucca Mountain was chosen as the best possible site (or at least just as good as any other "best possible site") for underground storage of nuclear waste. At the time, researchers already knew no site could be perfect. Yet even Yucca Mountain has not and cannot be built -- not because of political problems, but because the political problems are based on facts: Facts about water intrusion, facts about transport accidents, facts about volcanic activity, earthquake activity, leaching of water into an underlying water table that is moving faster than originally assumed (possibly due to water depletion at the outflow, where the contaminated water would eventually be used). There were drip shield problems and cave-in worries and thermal questions still unanswered. Hundreds of problems, many of which were, or at least should have been, terminal.

So yes, the "expert" who was briefing the new DCNPP decom panel was correct: The worry and the concern should virtually all be about the spent fuel. But he's wrong to think it's likely to go anywhere. There are numerous hurdles to sending the waste to New Mexico for interim storage, including political hurdles, but also including impossible-to-resolve technical issues such as: Major air transport and military air routes at or near the location, flooding, explosive or caustic gasses leaking out of the ground in the area, and the same transportation problems Yucca Mountain will always have, including trillions of dollars that would be needed for infrastructure improvements.

Meanwhile, in Southern California, there's the San Onofre "Community Engagement Panel," set up by SoCalEd four years ago -- with their own approved and hand-picked members -- to figure out what to do with the nuclear waste at San Onofre, which closed permanently due to "unexpected" vibration in its steam generators, leading to leaks and irreparable damage.

Locals call it the "Community Enragement Panel" and it even includes one renegade Sierra Club representative (to make the panel appear "balanced") who advocates nuclear waste policies which run counter to long-standing Sierra Club positions (and who is also the sole "member of the public" on the panel).

The SoCalEd CEP does not concern itself in any way with solving the nuclear waste problem for the country, but ONLY in solving it for Southern California Edison. Their solution? Get the waste moved to somewhere else. Find some sucker state that will take the waste away.

There are a few other decommissioning issues the panel concerns itself with, which thus far has always resulted in approving SCE's plan, whatever that might be. The "expert" from the Diablo Canyon Independent Safety Commission would probably feel all these "side issues" are relatively unimportant.

The real problem (the one SCE's CEP totally ignores) is not, and should not be thought of as: "Where will we put the waste?" but rather: What is the long-term solution to the nuclear waste problem? And if there isn't one (spoiler alert: There isn't) we MUST shut ALL the plants down. The SanO CEP pretends to look at the "problem" of nuclear waste and instead looks at the problem of foisting OUR problem onto someone else! And it doesn't even have to be a state: It could be a tribe, or a country, or -- hey, rocket it to the moon (never mind the cost, the failure rate of rocketry, the man-made space debris field surrounding earth, the natural resources needed to loft tens of thousands of tons of nuclear waste fast enough to escape earth's gravitational forces, etc. etc.).

As far as the SanO CEP is concerned, as long as taxpayers take fiscal, physical, and legal responsibility for the waste, they don't really care about the details. In short: As long as someone takes it away from "here" (Southern California) and puts it "there" (anywhere else on or off the planet) the SanO CEP will be happy.

But even if a bridge is built strong enough to carry a 300,000-pound load once, or a dozen times, that doesn't mean it's good for 100 such loads, or maybe not even 13.

The total number of bridge structural failures -- partial or complete -- in America over the past few decades is relatively few, but... hardly zero. Here are a few stunning examples:

* The Tacoma Narrows Bridge in 1940. If a spent fuel load had got stuck on that (fortunately they didn't have any spent fuel anywhere at the time), it would probably have been tossed to the riverbed and burst.

* The Mianus River Bridge in Connecticut in 1983. I was driving over that bridge twice a day at the time. The distance the tractor-trailer that went over the edge fell was way beyond what any transport cask is designed to withstand.

* The earthquake in San Francisco during the 1989 "Earthquake World Series." The Loma Prieta earthquake knocked the top level of the Cypress Street Viaduct onto the lower level. That upper section would have crushed a dry cask traveling on the lower section like a tin can.

* The Minnesota I-35W Mississippi Bridge in 2007. No transport cask would have survived being on a rail car underneath, and probably wouldn't have survived the fall if it had been on the bridge.

There have been many more, and many such bridge collapses in other countries, such as in Kobe, Japan in 1995. These are incidents that come quickly to mind, and in each case, the consequences if a spent fuel canister had been involved are fearsome.

There are many other ways a dry cask transportation accident can happen, from head-on collisions with high-speed trains rounding curves too fast, to airplanes falling out of the sky, possibly from a suicidal pilot (it happens), to washed out rail lines and a thousand other things. Actually, way more than a thousand.

All of these nuclear waste accidents would be catastrophic, as would acts of terrorism, and there can even be catastrophic accidents caused by neglect, engineering mistakes, carelessness and ignorance. Especially when there are no "experts" to guide you.

Each additional nuclear waste load that is produced (about one canister worth of new nuclear waste is produced every one to two days in America) requires storage space, transportation, its own expensive canister and periodic inspections. Every collection of spent nuclear fuel canisters requires security guards, guard equipment, infrastructure, fencing, response systems for swarm drone attacks (each drone laden with several pounds of explosives)... It's not cheap, and it goes on forever.

Each cask contains as much radioactivity as was released at Chernobyl. The failure of a single cask would be a catastrophic industrial accident. And it absolutely would be an "industrial" accident, not an act of nature, even if a meteor comes out of the sky and destroys a canister, or a whole group of canisters. Such an event may be unlikely, but it is NOT impossible and the ONLY reason it's possible is because the Nuclear Regulatory Commission (NRC) allowed the canisters to be manufactured -- and filled -- in the first place.

For safety reasons, the NRC and its predecessor the Atomic Energy Commission (AEC) could have insisted that the Uranium-235 be left in the ground, where each U-235 atom is surrounded by hundreds of non-fissile Uranium-238 atoms. The NRC and before them the AEC could have required that the U-235 *NOT* be split, so that it could not become a multitude of fission products that chemically mimic elements that human bodies use. These fission products include iodine, cesium and strontium (radioactive isotopes of these elements are one of the most common results of nuclear fission). Isotopes that are not "useful" to the human body but are still toxic are also produced, and can be inhaled or ingested, and retained for some period of time (possibly for life). Plutonium-239 is roughly 30,000 times more radioactive than Uranium-235. (The half-life of Plutonium-239 is about 24,000 years, which is well beyond the written record, but about 30,000 times shorter than the half-life of U-235.) Both Uranium and Plutonium -- but especially plutonium -- also have horrific "heavy metal" properties because of the swarm of loosely-held electrons surrounding their massive nuclei.

Nuclear power plants create nuclear waste that lasts virtually forever, and the only reason they do this is because, for a fleeting moment, they can create heat which is turned into steam which is turned into rotational motion which is turned into electricity. And no, it's no more efficient than it sounds, and yes that electricity could be created a thousand better ways, dozens of which are capable of industry-scale production, and all of which can produce electricity at a cost far lower than nuclear power.

Note: Fossil fuel prices are set artificially, since it is an easily-withdrawn (once you find it and drill the well) and easily transported nonrenewable resource. Fossil fuels and nuclear power should be required to compete fairly with renewable energy -- and this needs to include paying for the damage they do to the environment, and the waste they create -- for as long as necessary. (Another spoiler alert: They can't compete on those terms. They can't compete on a level playing field.)

In order to exist, the nuclear industry requires a number of things besides high prices for electricity. As long the only real challenger to nuclear power was fossil fuels, there have only been four other things that had to happen in order for nuclear power to be financially viable (i. e., profitable) for a large electric utility company. Because of renewable energy's price pressure, an additional fifth thing is required:

First, the nuclear industry had to get massive federal subsidies, which it did, and still does.

Second, it had to have a special, magical, deceptive and very dishonest insurance policy, one which would limit the liability of the owner/operators of the plants, so that if a major accident occurs, the victims, not the perpetrators, would pay for it. That was accomplished and is still accomplished by the Price-Anderson Act, which is woefully under-funded and can't possibly cover the cost of major accidents, including transport accidents -- costs which could reach into the tens of trillions of dollars. P-A limits liability, which forces the victims to pay.

Third, insurance companies had to get the public to accept home owner's insurance policies that specifically exclude nuclear accidents from the policy. This was done with a brilliant piggyback to the scam national insurance policy that severely limited corporate liability and forced the victims to pay for their own financial losses, health care or funerals. The home owners were told that damages from nuclear accidents would be paid for through the Price-Anderson Act, which would do no such thing in 999 out of 1000 cases, and then only pennies on the dollar.

Fourth, the waste problem had to be solved, which was impossible from the beginning and remains so today because of the physical properties of ionizing radiation and radioactive decay. But rather than solve the problem, everyone, for 70+ years, has been "kicking the can down the road." That's all SanO's CEP wants to do, and that's all DCNPP's decom panel wants to do with nuclear waste.

Fifth, because of price pressure from renewables, the nuclear industry has begun to require (and get) guaranteed minimum price subsidies from nuclear utility ratepayers, who are charged prices well in excess of fair market rates. These price subsides cost those ratepayers billions of dollars. Sometimes specific major subsidies are used to pay for specific major replacements of worn parts, such as steam generators, reactor pressure vessel heads, huge pipes, turbine blades, etc. etc. And if the billion-dollar replacement parts fail, like they did at San Onofre? The ratepayer still pays, often in advance of the replacement work even having begun. The utility actually makes a guaranteed profit even on their own failures!

Meanwhile, viable, if only partial, solutions to some of the problems of storing spent nuclear fuel which are available today are not being tested, implemented, or -- in some cases -- are not even being considered.

Such ideas as:

* Use casks made of thicker ductile cast iron instead of thin stainless steel. The canisters used in America are 1/2 inch thick (Diablo Canyon) to 5/8ths of an inch thick (San Onofre). The casks are huge: 10 to 12 feet in diameter and about 20 feet long, depending on fuel type. The cask walls are barely thicker than an egg shell, proportionately! Yet these casks are expected to carry a much higher density of spent fuel than an egg shell is designed to hold of liquid. Each cask can hold from about a dozen to more than three dozen spent fuel assemblies, each of which weighs around several tons. The massive amount of radiation stored in each cask needs better protection: Many other countries use a much thicker cask made of ductile cast iron. American utilities are too cheap, claiming the waste will be transported elsewhere soon and for some reason, then it won't matter. They've been saying that for decades. The American nuclear industry needs to move to the thicker, better casks, as well as: More space between each cask, more security around them, earthen berms between each cask, fewer fuel assemblies per cask, and most of all: Stop making more nuclear waste.

* Destroy the fissile isotopes of Uranium and Plutonium (primarily U-235 and Pu-239) with laser neutralization (described in detail in the attached article (see below)). Laser neutralization would reduce the length of time the waste stream is ultra-hazardous (i. e., laden with Plutonium and other radioactive substances) from hundreds of thousands of years to less than a thousand years. A millennia is certainly still a long time but is less than 1% of the time needed for storage otherwise. Unfortunately, destroying the fissile isotopes inevitably (that is, "by definition") creates additional fission products. But it eliminates many other potential risks, including those caused by the need to store nuclear waste for longer than the known length of human civilization.

Additional benefits of laser neutralization include eliminating the possibility of the nuclear "waste" being reprocessed and used in future nuclear reactors (which creates more Plutonium, as well as fission products), or to create nuclear weapons (i. e, proliferation concerns). Most importantly, laser neutralization eliminates the possibility of criticality events, which would also create (and release) fission products.

All of these worries and concerns are always present when dealing with spent fuel that has not been laser-neutralized to remove the fissile isotopes. Laser neutralization is a patented concept, and is technically achievable today. But the industry won't do it.

Since even the "best" solutions to the problems of nuclear waste are financially expensive and susceptible to "extreme events" (of which thousands are possible), the less nuclear waste there is on the planet, the better. The risk increases linearly with each new spent fuel load.

So I ask the Nuclear Regulatory Commission to: Yes: Hold ten -- or perhaps a hundred -- meetings, with at least one near San Onofre (i. e., near where I live). But instead of just listening to people gripe about how you've got to get the waste MOVED somewhere ("anywhere but here"), why not look for REAL solutions, and if you DON'T find them (or rather, since they don't exist) warn the communities around plants which are still operating that what they are doing is unsustainable and must stop. Specifically, you don't even have to "force" the utilities to stop -- just make them do two perfectly reasonable things other large industries do, and they'll stop all by themselves:

1) Nuclear utilities must take full responsibility for any waste they create. From this day forward and for eternity. The federal government (specifically the Department of Energy) should NOT promise (on behalf of the American people) to take the waste away, because the DOE has already proven they can't keep that promise -- and certainly not without violating someone's civil rights, -- along the transportation routes, around the site(s) where they send the waste, and anywhere on the planet if anyone is harmed by an "accidental" release of the waste. It's not "accidental" if it could have been prevented by not making the waste in the first place. Which is true of all future waste that might ever be created.

2) Nuclear utilities must stop hiding behind Price-Anderson. If the nuclear industry can't find proper insurance for their industrial process (Last spoiler alert: They won't), then it should be stopped. If it is not stopped, then when the meteor finally crashes into a nuclear waste canister, it will be an industrial accident, and today's nuclear industry will be responsible, even if it's 250,000 years from now. When a terrorist attacks, any time in the next quarter of a million years, it will be an industrial accident, because the risk never needed to be taken. The opportunity for destruction never needed to be made available to the terrorist. When a bridge collapses in an earthquake, crushing a dry cask and causing the permanent evacuation of a large city, it will be an industrial accident, not an act of God or Mother Nature. Those rascals (God and Mother Nature) did not create the nuclear waste problem. They did not do anything unexpected. Even the terrorists, whoever they may be, and whenever they may strike, will not be doing anything unexpected. We know they're coming. We just don't know when, where, why, or how, and they don't know any of that either at this point. They may be a thousand generations from being born, yet eventually, our "targets" will still be there, waiting for them: God, Mother Nature, or a terrorist. Or a bad weld that someone didn't report because they were afraid they'd lose their job if they did. A thousand things. 10,000 dry casks. The odds are not good. Stop playing with fire. We're liable to all get burned.

Ace Hoffman
Carlsbad, CA

What is spent nuclear fuel neutralization and why is it the best solution?
http://acehoffman.blogspot.com/2017/11/what-is-spent-nuclear-fuel.html

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Follow-up (March 26, 2019):
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Dear Readers,

I'm happy to report that my previous two newsletters, one from January and one from last week (URLs below), were both very well received by activists around the world!

THANK YOU readers and everyone who forwarded it to others or commented on one or both of them, including: Helen C., Marvin R., Alice S., Conrad M., Gary H. and many others!

Also, David Archer (aka "The Archer") called in from Canada and we did an audio interview that lasted nearly two hours, mostly about the latest newsletter (the letter to the Nuclear Regulatory Commission). You can find Archer's recording of the interview here:

http://tmi1979.libsyn.com/ace-hoffman-california-is-closing-nuclear-power-plants-and-plans-to-move-the-nuclear-waste-around

David Archer has interviewed many interesting people on his podcast: Joe Mangano, Maggie Gunderson, Helen Caldicott, Harvey "Sluggo" Wasserman, Kevin Kamps, Chris Busby, Richard Bramhall, Paul Gunter, Dennis Riches and many others...it was an honor to be on his show again!

Here is the URL where last week's newsletter resides:

Regarding Nuclear Regulatory Commission Docket ID NRC-2019-0073 (submitted March 18th, 2019)
https://acehoffman.blogspot.com/2019/03/regarding-nuclear-regulatory-commission.html

January's newsletter is here:

Who needs a "Screw Nevada" bill when you can just screw Nevada anyway? (January 31, 2019)
https://acehoffman.blogspot.com/2019/01/who-needs-screw-nevada-bill-when-you.html

The earlier David Archer podcast with this writer, mainly about San Onofre:
http://tmi1979.libsyn.com/ace-hoffman-california-and-its-nuclear-problem-0

Ace Hoffman
Carlsbad, CA