Date: October 4, 2022
To: The California Coastal Commission (sanonofrecomments@coastal.ca.gov): The California Coastal Commission (CCC) staff report makes the following claim: -----------------------------------------------------
"When the Commission considered the waste storage facility in 2001, the information available at the time indicated that the U.S. Department of Energy would establish a federal repository for spent nuclear fuel and would begin accepting spent fuel from commercial facilities, including SONGS, by 2010."
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What "information" was the California Coastal Commission going on in 2001 to make that claim? Yucca Mountain was far from a decided thing then (it has since been cancelled completely). There were hundreds of known problems with it (California alone has dozens of significant objections). Only whimsey and fantasy would have allowed anyone to think it was "the information available." The nuclear industry has survived on waste management promises for decades (see link below to the author's review of waste management attempts in America over the past half century, as well as the attached page from a 1970s book called the Anti-Nuclear Handbook). Page 23 of the CCC staff report claims to have analyzed (or had analyzed for them) a 7.5 earthquake (elsewhere up to 7.44 (an oddly specific number for such an inexact science) was indicated). But a 7.8 magnitude earthquake is three times stronger than a 7.5 earthquake, and perhaps one even stronger than that will strike the Independent Spent Fuel Storage Installation (ISFSI) at San Onofre. The CCC staff report repeatedly refers to a "design basis earthquake" and a "design basis tsunami". This conveniently ignores "beyond design basis earthquakes" and "beyond design basis tsunamis" which are certainly possible -- nor does the staff report give any indication of the odds for anything: Instead, they just describe things as "unlikely" or "extremely unlikely." Even if these events are "unlikely" or "extremely unlikely" their impacts could be so devastating that the events must be considered. Beyond Design Basis events are not only possible, but additionally: Even the Nuclear Regulatory Commission (NRC) occasionally considers them and regulates the nuclear industry regarding them. So why can't the California Coastal Commission do so? But what really galls me about the CCC staff report is that they completely ignore consequences of accidents. Not just that they are unlikely, but no consideration of how damaging to SoCal an accident -- however unlikely -- would be. They do this with the excuse that that would be strictly the purview of the Nuclear Regulatory Commission -- which is absurd. The NRC might "regulate" nuclear reactor safety and spent fuel safety, but the consequences will be OUR problem -- not theirs. Another point: The CCC staff report says the containers should be "transportable" so that at some future time they can be moved to either a safer location on the SoCal Edison (SCE) site (which is actually leased from Camp Pendleton (Marine Corps)) or to a permanent repository somewhere. Yet the enormous number of fuel assemblies allowed in each cask -- to save money by using fewer casks -- makes them extremely heavy and to move them away from San Onofre will require them going over (and under) numerous bridges where a far greater fall than the canisters are designed to withstand might occur (the NRC only requires the casks to withstand a drop of 30 feet, and even then, a "back breaker" accident is not considered (where the middle of the cask takes all the force of the impact with a solid object)). So really, the CCC isn't making sure the canisters can be transported even as far as across the bridge that goes over the (eroding) train tracks and the busy I-5 highway to store them further away from the coast on (borrowed) SCE land slightly further inland. If a bridge fails (perhaps because a truck or train crashes into a bridge abutment just when one of the 123 canisters is being moved) then the fall could exceed the drop height the casks are designed to (possibly) withstand. The CCC staff report earthquake estimates are based on a maximum 7.5 magnitude earthquake. But experts now believe the Palos Verdes Fault (PVF) is capable of producing a 7.8 magnitude earthquake. PVF is nearly 70 miles long and the tip is within about 10 miles of San Onofre. The staff report's sea rise estimates and tsunami estimates could also be way off -- and in instance after instance in the Th12a staff report, the NUHOMS horizontal cask system is just barely safe from their estimated worst case scenario. The CCC staff report's beach erosion estimates might be way off too. Especially note that this week, Surfliner has suddenly been cancelled indefinitely between Mission Viejo and San Diego due to coastal erosion in San Clemente. These tracks were the 2nd busiest route in the country -- until suddenly they weren't available and thousands of people are suddenly severely inconvenienced for who-knows-for-how-long, including both commuter and freight traffic. It is expected that sooner or later the tracks will be repaired. Compare this to what would happen from even a "small" accident involving just one of the 123 dry casks stored at San Onofre: The entire area, including the Cities of San Clemente and Oceanside, Camp Pendleton, I-5 AND the vital rail line would all be permanently unavailable, just over 1,000 square miles are permanently unavailable around Chernobyl for the foreseeable future from an accident that occurred nearly 40 years ago. It should be noted that EACH dry cask at San Onofre contains as much radiation as was released in the Chernobyl accident. This figure has been admitted in a published letter to the editor by the SCE spokesperson, who claimed there needs to be a "motive force" to release it to the environment. Let me suggest a few "motive forces" that might cause a large dispersal of the nuclear waste at San Onofre: An airplane strike, either intentional or accidental. A large ship settling on the cask structure after being washed inland during a tsunami. A high-powered weapon (even a shoulder-fired weapon could go through both the concrete overpack and the dry cask itself, and that's just ONE trigger pull. There is almost no defensive guard requirements for the ISFSI. It is unlikely that ONE guard with ONE pistol would be able to stop even a small group of well-prepared terrorists). An earthquake that bursts open one or more casks during a rainstorm, or followed by a tsunami, would be particularly disastrous. There are many other ways the spent fuel canister can be breached. A breach can cause the fuel to self-ignite by exposing the canisters to air and water. The zirconium cladding, being pyrophoric (self-igniting) could/would entirely burn off, releasing all the fission products currently held in the "gap" between the uranium/plutonium pellets and the zirconium cladding. This would be a local, state, and global disaster, but it might not, in and of itself, cause the uranium/plutonium/fission/product-laden fuel pellets to also self-ignite since zirconium burns at a much lower temperature than uranium. But it would cause the fuel assemblies to disassemble. The fuel pellets would fall to the bottom of what's left of the canister, and then a self-sustaining criticality event could/would quickly reach a temperature which ignites the entire cask of spent fuel. An American Chernobyl, because the California Coastal Commission didn't do its job. Lastly, why is the Th12a staff report coming so late, just a month before the current San Onofre ISFSI license for the NUHOMS casks expires? Why does it cite a 2001 DOE waste management report that proves how poorly the DOE estimates nuclear waste management timelines as a reason that the DOE will (probably, hopefully, possibly) have a national repository by 2035 -- or any time? I recommend the CCC staff report be thrown out, the relicensing stopped, and SCE be required to repack the fuel in much smaller quantities, and that all spent fuel canisters be moved away from the coast (and away from ANY earthquake zone in California (good luck with that)), and that all spent fuel canisters be separated from each other by a minimum of several hundred yards. Local fire departments need to be constantly trained and retrained about how to handle a fire at the spent fuel installation, and all other possibilities for what might happen at San Onofre should be covered. For example, the ability to dump many tons of sand on a spent fuel fire should be practiced by local/state government helicopter pilots on at least an annual basis if not more frequently. All costs for more properly storing the spent fuel should be borne solely by the owners, Southern California Edison (80%) and San Diego Gas and Electric (SDG&E) (20%), and their shareholders. Ace Hoffman
Carlsbad, California The author, an independent researcher and two-time cancer survivor, has studied nuclear issues for approximately 50 years and has interviewed and/or worked with dozens of technical experts in all related subjects. All views are his own.
Additional information: Palos Verdes Fault: A serious issue for San Onofre; Recent history of fault research in California:
https://acehoffman.blogspot.com/2022/09/palos-verdes-fault-serious-issue-for.html Extending Diablo Canyon's operating license: A fiasco waiting to happen (contains additional discussion about dry cask accident issues):
https://acehoffman.blogspot.com/2022/08/extending-diablo-canyons-operating.html Nuclear Waste Management: The view through the years:
https://acehoffman.blogspot.com/2017/10/nuclear-waste-management-view-through.html Different types of nuclear radiation and why they are all dangerous (a backgrounder on radiation dangers):
https://acehoffman.blogspot.com/2022/07/different-types-of-nuclear-radiation.html
Th12a is available online here:
https://documents.coastal.ca.gov/reports/2022/10/Th12a/Th12a-10-2022-report.pdf
Addendum: Comment on the above from another independent researcher: Regarding "NRC only requires the casks to withstand a drop of 30 feet", This applies to the transport cask and doesn't consider the contents remaining intact. In fact, if a [Holtec] canister drops more than 11 inches inside a transfer cask, contents must be inspected (NRC ML003711865, page 3-10 Accidental Drop). https://www.nrc.gov/docs/ML0037/ML003711865.pdf Regarding ignition/explosion of zirconium, zirconium hydrides (created from burning the fuel) are in small particle or gas form they will ignite in air at any temperature.
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