Possible dates for the next SCE/CEP meeting & workshop on Nuclear Waste may be Jan 27 or 28

sanonofrecaskloadingintostoragebunkerA number of CEP members have expressed a strong interest in returning to the matter of long-term spent fuel storage early in 2015. We are fortunate to have been approached by the Washington DC-based Bipartisan Policy Center (BPC) to organize a joint meeting with the CEP in January as part of an 18-month effort to generate action on the movement of used nuclear fuel in the U.S. With the short timeframe, we will need to finalize the event very quickly.
BPC is working on an initiative, “America’s Nuclear Future: Taking Action to Address Nuclear Waste,” to reinvigorate and expand the discussion on nuclear waste, identify barriers inhibiting progress on nuclear waste, and explore options to break through the barriers. The effort is being run by Tim Frazier who previously ran the President’s Blue Ribbon Commission on America’s Nuclear Future. I am mindful that a joint program with the BPC will be far more impactful than a program that we might endeavor to execute on our own.
Important to the BPC effort are regional meetings to identify and discuss the barriers to moving forward on nuclear waste and potential actions to remove the barriers. BPC has hosted meetings in the Northeast at MIT in June, in the Southeast at Georgia Tech in Atlanta in September, and in the Midwest in Chicago in November. A joint BPC/CEP meeting for Southern California is planned for the evening of Tuesday, 27 January, or Wednesday the 28th.
 Meeting Overview
Plans include two panel discussions. The intent is to present a range of viewpoints and panelists are to be announced. The first panel will focus on federal issues as facilitated by Tim Frazier. I will chair a second panel discussion with a focus on San Onofre and state issues. The second panel discussion will include the full CEP, a facilitated public comment period, and serve as our Regular Meeting for 1Q 2015.
The doors are opening wider on our discussion of Nuclear Waste at San Onofre. Once again we have the opportunity to bring this topic forward on to the national stage. The question is will you join us? Only you can make your voice heard.
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PLEASE Turn off a light for Fukushima USA / San Onofre

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What’s up with the #SCECEP

SCECEP meetingIn my opinion, I’m very concerned about the way the SCE/CEP was set up and the direction the leadership of SCE/CEP is now taking us. Instead of taking the neutral position and uncovering and observing the evidence as presented they consistently and obviously put a positive spin on it. Everything is fine and SCE is doing the best job possible.
  1. We must ask ourselves does this repeated positive spin serve the public interest? In my opinion No.
  2. Is this Community Engagement Panel doing the best job possible to protect the safety of our communities and California? In my opinion we are not.
  3. Can or will the SCE/CEP make the changes necessary in its charter to become an effective and strong safety advocate for the decommissioning and safe storage of nuclear waste at San Onofre that the people of California deserve until such time as the DOE takes possession of this long-term problem? In my opinion that is still up in the air.
To this point SCE’s attempt to be inclusive and transparent clearly has it’s limits. While asking me and others to bring up the safety concerns of the local citizens, SCE and the SCE/CEP leadership has then glossed over them, seeing these concerns only to be checked off their list one by one. Example; Tim Brown told the CA Senate Energy, Utilities and Communications Committee on Aug 12, 2014 that local concerns have be heard and addressed. Implying some sort of conclusion or satisfaction by all with SCE’s predestined decommissioning plan. Link for Senate hearing http://youtu.be/_q6YulhHpcU?t=1h2m9s starting time for Tim Brown 1:02:10 to 1:17:45. Nothing of course could be further from the truth for many in our local communities. SCE, Inclusiveness is not just a tool to be used on the “Yellow Brick Road to decommissioning”, we are not in the Land of Oz after all. We are however in the backyards of over 8.4 million Californians.   SCE and its CEP leadership now have a consistent record of spinning information to fit the SCE agenda. For example, regarding “defense in depth”, the chairman, after being concerned at first at the lack of defense in depth for dry cask long-term storage, concluded after his ‘”careful research”, that citizen activists had not asked about ” defense in depth” for waste storage before and that the nuclear industry and the NRC has done a poor job in defining  and getting the word out about “defense in depth” for nuclear waste and dry cask storage. Citing “defense in depth” as cladding on fuel rods, ceramics on the fuel pellets , even the 5/8″ thickness of the canister itself and concrete overpack of the casks as if these were “defense in depth” that were unspoken of in the past. And he was right they were not spoken of in the past as “defense in depth” because they were not considered nor should we consider them today as “defense in depth”. While these have some small measure of defense, they are not in anyway sufficient or adequate for long-term storage of nuclear waste within a heavily populated area like Southern California, and everyone in this nuclear industry knows the calculated risk they are betting on with California’s future.
David Victor’s report Safety of Long-term storage in casks: Issues For San Onofre Dec 9, 2014 does have some items we do agree on:  “It  is  likely  that  spent  fuel  will  be  stored  in  dry  casks  at  the  San  Onofre  nuclear   site  for  very  long  periods  of  time—most  likely  well  beyond  the  20-­‐year  period  for   initial  licensing  of  the  casks.” page 2 of report. “Some  elements  of  what  will  be  needed  for  “defense  in  depth”  are  not  yet  fully   in  existence—for  example,  actual  equipment  that  would  allow  removal  of  fuel  from   a  cask  without  an  onsite  pool  has  been  designed  and  a  prototype  was  demonstrated   in  the  1990s,  but  no  such  full  scale  commercial  system  currently  exists.  Similarly,   full-­‐blown  procedures  for  repairing  all  forms  of  cask  cracking  are  not  yet  fully   certified” page 4 of report. Other than these items there is not much here other than “pro nuclear industry spin.” Read full report at:https://docs.google.com/document/d/13DurWxC8l3l_VCNEGXz5bg0V4FJteepR7LVuUjPz4Xk/edit?usp=sharing

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PLEASE Turn off a light for Fukushima USA / San Onofre

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San Onofre Priorities: On-Site Safety, Off-Site Storage

San Onofre Priorities: On-Site Safety, Off-Site Storage

June 7 marks the first anniversary of Southern California Edison’s decision to permanently close the troubled San Onofre nuclear plant near San Clemente. Gene Stone of Residents Organized for a Safe Environment (ROSE) summed it up this way: “We are safer – but we are not yet safe.”
There are two crucial matters: the quality of storage technology on-site at San Onofre, and the prospects for long-term storage at a remote site.
The accuracy of Stone’s words was confirmed at a May 6 workshop on managing nuclear fuel waste. Tom Palmisano, senior nuclear officer for Edison, reported that cooling pools at San Onofre currently hold 2668 spent fuel assemblies including 1115 “high burn-up,” a fuel type that is hotter both thermally and radioactively than conventional fuel.
Spent fuel from Unit 1 is already in dry casks holding 24 assemblies each. Removal of Unit 2 and Unit 3 fuel from pools will require 100 more 32-unit casks. This will triple the footprint of the concrete storage structure, from today’s 200 x 400 feet to an ultimate 400 x 600 feet.
Experts are unanimous that fuel pool hazards are far greater than dry cask storage and the intent is to complete transfer in 5 to 7 years. At that point the focus shifts to long-term safety of casks.
A lively debate at the May 6 workshop pitted Marvin Resnikoff of Radioactive Waste Management Associates against Michael McMahon from cask manufacturer AREVA and Drew Barto, lead on spent fuel storage and transportation for the U.S. Nuclear Regulatory Commission (NRC).
Resnikoff reviewed the performance hazards and risks in cask safety for long-term on-site storage and off-site transport. McMahon and Barto countered with advances in design technology that they say provide a robust and secure storage system even for high burn-up fuel. Through this exchange of sharply differing views, the workshop added value by throwing the spotlight on key technical issues in specific ways that can be debated to a point of resolution. Nuclear safety advocates will be watching the outcome closely.
The other major contribution of the workshop was to confirm a striking degree of unanimity regarding the need to revitalize the process for locating and developing sites for long-term remote storage. Gains in on-site safety promised by technology advances did not diminish the consensus that spent fuel waste should be removed from San Onofre at the earlier possible opportunity.
In part this reflects the unusually exposed nature of the San Onofre site. But sentiment runs deeper. Per Peterson, a member of the NRC’s Blue Ribbon Commission, expressed a feeling little short of dismay at the national failure to identify and develop remote storage. Edison said it is committed to this outcome as the fully satisfactory solution. Members of the expert panel as well as the Citizens Engagement Panel (CEP) that hosted the event made it clear that indefinite on-site storage remains unacceptable.
Message to the NRC: San Onofre may be the test case where all parties are urging a better way than the grotesque and inappropriate land-use outcome of constructing a nuclear waste mausoleum at San Onofre or at any other closed nuclear plant.
Dr. David Victor of UC San Diego chairs the CEP, which organized the workshop. He summed up the discussion this way: “We have an obligation to make the long-term storage of fuel as safe as possible and practical. We need a strategy for federal action on consolidated storage and ultimate repositories. Toward that end, we should articulate what we as a community need—and carry through with the Governor and Congress to assure they give priority to what is most important.”
Enter Senator Barbara Boxer and colleagues Sanders and Markey. On May 16 they introduced Senate bills S. 2324, 2325 and 2326, which would:
• Require the NRC to cease its current practice of issuing exemptions to emergency response and security requirements for spent fuel at closed nuclear reactors, unless all fuel storage at the site is in dry casks.
• Ensure that host states and communities have a meaningful role in shaping decommissioning plans for retired nuclear plants.
• Require for the first time that the NRC to explicitly and publicly approve or reject each proposed decommissioning plan.
• Ensure operator compliance with the NRC requirement that spent nuclear fuel be removed from pools and placed into dry cask storage within 7 years after the decommissioning plan is submitted to the NRC.
• Provide funding to help reactor licensees implement plans for decommissioning nuclear plants.
• Expand the emergency planning zone for non-compliant reactor operators to 50 miles.
The Boxer-Sanders-Markey bills are classic legislative oversight. They close safety-related loopholes and provide a more accountable and participatory process for affected area residents.
These sensible steps do not in themselves deal with on-site storage design technology or remote site development. But they are in the spirit of comprehensive nuclear waste management, which remains one of America’s largest environmental challenges.
By Gleen Pascall
Sierra Club
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Private Profit, Public Debt, The Nuclear Saga Continues In San Clemente

Would you give 3 hours of your time on Tuesday to lower cancer rates in San Clemente and adjacent communities?Studies show that communities who are actively involved in the decommissioning of their power plants result in lower radiation readi…

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The intent of this plan is to help you understand and educate yourself about the dangers of “HIGH BURNUP FUEL” in your reactors and the problem they present in waste management and storage of these extremely dangerous fuels.

This plan consists of 3 actions that must be taken:
 1. Education on High Burnup Fuels:
    a. Who to educate, the Congress, activists, communities, all forms of news outlets.
    b. EVERYONE NEEDS TO HEAR ABOUT “HIGH BURNUP FUEL.” Very few people know about it.
   c. This fuel came to your reactor very quietly without the knowledge of the public, plant workers and their unions, only a few top executives seem to be aware this was happening.
 2. Clear and present dangers of High Burnup Fuels:
     a. Reactor problems caused by High Burnup Fuels.
     b. Waste management & storage issues of High Burnup Fuels.
     c. Much higher levels of radiation with High Burnup Fuels that are now sitting near you.
 3. Action Alert process:
     a. Email & phone call campaign to Senators and Congressmen & the 5 NRC Commissioners, state governors and legislators, petitions.

 Residents Organized for a Safe Environment (ROSE) & Coalition Against Nukes (C.A.N.) are taking a group of six activists from around the country to talk with the NRC commissioners and several senators in the third week in January to discuss this important issue. We hope this campaign will provide a minimum of 10,000 phone calls and emails to the groups listed above prior to our arrival to deliver this message.

The use of “HIGH BURNUP FUEL” has gone almost completely unnoticed by everyone and now must be brought to the forefront of our battle to shutdown the remainder of America’s nuclear power plants and to get a handle on our nuclear waste problem that is only magnified by the use of these extremely dangerous fuels. STOP THE PRODUCTION OF MORE NUCLEAR WASTE NOW.

 Below you will find a detailed summary about High Burnup Fuels by Dr. Marvin Resnikoff noted waste management expert and Donna Gilmore.

High Burnup Fuel Fact Sheet High Burnup Nuclear Fuel

Pushing the Safety Envelope by Marvin Resnikoff and Donna Gilmore January 2014

As commercial reactor economics have declined, utilities, with the acquiescence of the Nuclear Regulatory Commission (NRC), have burned nuclear fuel longer and crammed more of it into storage containers. This experiment has unresolved serious safety issues for storage, transportation and disposal of this highly radioactive waste; issues that have been essentially overlooked by nuclear regulators and the general public. 

For high burnup fuel (HBF), the cladding surrounding nuclear fuel, is thinner, more brittle, with additional cracks. In a transportation accident, the cladding could shatter and a large inventory of radioactivity, particularly cesium, could be released. The NRC should stop use of HBF and make solving HBF storage problems one of its highest priorities.

High Burnup Fuel Problems 

Almost all commercial reactors have HBF. Since the 1990’s almost all spent nuclear fuel (SNF) being loaded into dry casks is HBF.[3] HBF is low-enriched uranium that has burned in the reactor for more than 45 GWd/MTU (GigaWatt days per Metric Ton of Uranium).[4] Many Pressurized-Water Reactors have fuel with projected burnup greater than 60 GWd/MTU.[5] Cross Section Fuel Rod Significant Radial Hydride Orientation DE-NE-0000593

Fig. 1. Cladding cracks

The only issue NRC staff consider is the highest heat within a storage cask, but this ignores the fact that the cladding of HBF is thinner, more brittle, with additional cracks, as shown in Fig. 1. Longer cooling time will not solve these problems.

Uranium fuel pellets, stacked within long thin tubes called cladding, are struck by neutrons and fission, producing heat. A collection of these tubes is called a nuclear fuel assembly, shown in Fig. 2. After 3 to 4 years, extremely radioactive and thermally hot fuel assemblies are removed from the reactor and stored underwater in a fuel pool. Following a cooling period of 7 to 20 years, 24 to 32 fuel assemblies are removed from the fuel pool and inserted into a fuel canister, which are then pushed into a concrete overpack shown in Fig. 3. Because of the poor economics of nuclear power, utilities are pushing the limits for how long fuel remains in reactors with dire consequences.

Here are the high burnup fuel issues: 

HBF is dangerously unpredictable and unstable in storage – even short-term. HBF is over twice as radioactive and over twice as hot. The higher the burnup rate and the higher the uranium enrichment, the more radioactive, hotter and unstable fuel and cladding become. Fig. 4 shows the increase of heat output of fuel assemblies as a function of burnup.
HBF requires a minimum of 7 to 20+ years of cooling in spent fuel pools before storage in dry casks. The years of cooling depends on the burnup rate, percent of uranium enrichment and other factors as defined in the dry cask system’s technical specifications.[6] Lower burnup fuel requires a minimum of 5 years. See Fig. 5. HBF requires more storage space between fuel assemblies due to the higher heat, higher radioactivity, and instability,[7] yet the NRC approves high density of fuel assemblies in fuel pools and dry casks systems. San Onofre requested use of a new dry cask system that crowds 32 fuel assemblies into the same space that currently holds 24.[8] Absent a comprehensive safety analysis, the NRC should NOT approve the NUHOMS® 32PTH2 cask system for HBF, but is considering doing so this year. The NUHOMS system consists of a welded canister that holds 24 or 32 fuel assemblies; the canister slips inside a concrete storage overpack, shown in Fig.3. Diablo Canyon now uses a HOLTEC 32 fuel assembly cask system. No transportation casks for HBF have been approved by the NRC,[9] so even if a waste repository were available, HBF could not be relocated. Nuclear fuel is approved for only 20 years storage in dry casks, based on faulty assumptions about how HBF reacts in the first 20 years of storage.[10] There is insufficient data to approve dry casks for over 20 years, per Dr. Robert Einziger, Senior Materials Scientist, NRC Division of Spent Fuel Storage and Transportation.[11] Experimental data show fuel with burnup as low as 30 GWd/MTU have signs of premature failure.[12] As was done at Maine Yankee,[13] all HBF assemblies should be containerized in damaged fuel cans for dry storage. The NRC has no adequate strategies to detect and mitigate unexpected degradation of HBF during dry storage.[14, 15, 16]

HBF has major implications for pool storage before movement to dry storage. The NUHOMS 32 assembly cask requires up to 20 years and longer if HBF is to be transported. As seen in Fig. 4, HBF would require more than 30 years in storage before it could be transported. This has major ramifications for decommissioning reactors. Essentially, reactors cannot be immediately dismantled after ceasing operation. SAFSTOR[17] is the only option. The reactor license must be retained for this period. A longer time is required before HBF can be removed from the reactor site. In addition, the current high spent fuel pool densities present an even greater risk due to inclusion of HBF assemblies.
HBF has major implications for disposal in a repository. If DOE intends to open NUHOMS and HOLTEC canisters and repackage HBF for disposal, major problems may arise. Because the cladding is brittle and has cracks, it may be damaged during transportation and storage. Each HBF assembly may have to be containerized before storage, similar to damaged fuel assemblies.
HBF has major implications for transportation. Transportation issues have not been well examined by NRC in NUREG-2125, the latest transportation risk assessment, a 509 page report with numerous references.[18] But NUREG-2125 does not investigate transportation of HBF, a major oversight, as is discussed below.

NRC Transportation Accident Analysis

Public input on NUREG-2125 was unwisely curtailed at 60 days. The report was sold to the Commissioners by NRC Staff as a way to gather input from stakeholders, but in practice, this did not meaningfully happen. NRC staff required 7 years to produce this report, yet the State of Nevada’s request for an additional 30 days review was denied.
NUREG-2125 should have been critically reviewed. NUREG-2125 is essentially a transportation risk analysis. As the critique by the State of Nevada[19] shows, the NRC picked and chose which of its reports to include as references. Important accident sequences were not included. Here are just 3 examples of many, some of which are discussed in footnote 19.

Transportation casks have impact limiters at each end. Therefore, the most vulnerable position is a side impact, where the impact limiters are avoided, the so-called backbreaker accident. The references not chosen by NRC discuss this accident. NUREG-2125 does discuss a side impact by a train at a RR crossing. If the train sill directly impacts a transportation cask, the forces and accelerations can be great enough to stretch the bolt lids and leave an opening to the cask interior. But cited references do not include the 1-ton impact limiters at each end, which would increase the bending. For HBF, 140 g forces, a 60 mph side impact, would easily shatter the brittle cladding. HBF has over twice the cesium inventory. There are serious unanswered questions about long duration, high temperature fires and effect on cask and fuel cladding. Casks have neutron shielding on the outside, generally boronated plastic, within a thin metal cylinder. Fuel would heat up with this plastic blanket, except for the fact that metal brackets that hold the thin outer metal cylinder in place are heat conductors. But in a fire accident, these metal conductors can serve as heat inputs to the cask. This is not correctly modeled by cask manufacturers.

The State of Nevada has been asking for some time for full cask testing. These double layer casks, a canister within a transportation overpack, should be fully physically tested. Instead cask manufacturers rely on computer simulations and scale models. It is important to benchmark these computer models. Examples of failures by manufacturers to properly evaluate effectiveness can be found in the fire insulation failures throughout the US nuclear fleet due to inaccurate manufacture qualifications. NRC Security Analysis

Finally, malevolent events should be seriously examined. We do not have confidence this has been done. Anti-tank weapons such as the Russian Kornet, or French Milan, can easily penetrate 1 meter of metal. For transportation, the concern is about events that include entrance and exit holes. This is of particular concern with HBF, with large Cesium inventories and suspect fuel cladding. High Burnup Fuel Recommendations It is imperative the NRC Stop approval of high burnup fuel (HBF) use. Stop approval of HBF dry cask storage. Make solving high burnup fuel storage problems one of its highest priorities. The DOE EPRI “Demonstration Project” (EPRI High Burn-up Dry Storage Cask Research and Development Project),[20] that NEI is promoting[21] is not a solution. This project only tests HBF in existing cask technology (TN-32). The TN-32 cask isn’t even approved for HBF.[22] Over ten years after HBF was first produced and stored in dry storage casks, the industry has finally begun to study the consequences. The NRC has been asleep at the switch, allowing this dangerous experiment in the field to proceed. Develop adequate strategies to detect and mitigate unexpected degradation during dry storage. Absent a comprehensive safety analysis, not approve 32 assembly casks for HBF, such as the NUHOMS® 32PTH2 cask system. Require all HBF assemblies be containerized in damaged fuel cans for dry storage. Require full cask testing, rather than computer simulations and scale models. Reject NUREG-2125 Spent Fuel Transportation Risk Assessment as inadequate as it does not address HBF. Time is of the essence. As of 2012, most fuel in pools for future loading is high burnup and approximately 200 loaded-casks contain HBF.[23] Dry cask storage of HBF in the U.S. started about a decade ago: Since 2003, Maine Yankee casks contain HBF up to 49.5 GWd/MTU. (Maine Yankee HBF is in damaged fuel cans, due to unknowns with HBF) Since 2005, HB Robinson casks contain HBF up to 56.9 GWd/MTU Since 2006, Oconee casks contain HBF up to 55 GWd/MTU After 2008, many other sites have casks that contain HBF up to 53.8 GWd/MTU, according to the Nuclear Energy Institute.[24]

[1] radwaste@rwma.com; http://www.rwma.com [2] dgilmore@cox.net; http://www.SanOnofreSafety.org [3] DOE EPRI High Burn-up Dry Storage Cask Research and Development Project: Draft Test Plan, Contract No.: DE-NE-0000593, September 13, 2013, Page 2-1http://1.usa.gov/1f6LkJH [4] GAO-12-797 SPENT NUCLEAR FUEL Accumulating Quantities at Commercial Reactors Present Storage & Other Challenges, August 2012,http://www.gao.gov/assets/600/593745.pdf. Low-enriched uranium = up to 5% of U-235. GWd/MTU is the amount of electricity produced (gigawatt-days) per metric ton of uranium. [5] Savannah River National Laboratory, “Inventory and Description of Commercial Reactor Fuels within the United States,” SRNL-STI-2011-00228, March 31, 2011http://sti.srs.gov/fulltext/SRNL-STI-2011-00228.pdf [6] CoC No. 1029 Technical Specifications for Advanced NUHOMS® System Operating Controls and Limits, Appendix A Tables 2-9 to 2-16http://pbadupws.nrc.gov/docs/ML0515/ML051520131.pdf [7] RWMA Marvin Resnikoff, PhD: The Hazards of Generation III Reactor Fuel Wastes, May 2010 http://bit.ly/19dVRsY [8] Edison request for NUHOMS® 32PTH2http://pbadupws.nrc.gov/docs/ML1204/ML12046A013.pdf [9] SFPO Interim Staff Guidance 11, Rev 3 Cladding Considerations for the Transportation and Storage of Spent Fuel 11/17/2003 http://www.nrc.gov/reading-rm/doc-collections/isg/isg-11R3.pdf [10] NWTRB Douglas B. Rigby, PhD: The NRC approved the initial 20 year dry cask storage based on assumptions. However, no information was found on inspections conducted on HBFs to confirm the predictions that were made. U.S. Nuclear Waste Technical Review Board, December 2010 report,http://www.nwtrb.gov/reports/eds_rpt.pdf [11] NRC R. E. Einziger, PhD: insufficient data to support licensing dry casks for >20 years, March 13, 2013 http://1.usa.gov/15E8gX5 [12] DOE FCRD-NFST-2013-000132, Fuel Cycle Research & Development-Nuclear Fuel Storage and Transportation-2013-000132, Rev. 1, June 15, 2013 https://www.hsdl.org/?view&did=739345 [13] Maine Yankee Atomic Power Company’s Response to the NRC’s Request for Comments Regarding Retrievability, Cladding Integrity and Safe Handling of Spent Fuel at an Independent Spent Fuel Storage Installation and During Transportation (Docket ID NRC-2013-0004), March 18, 2013http://pbadupws.nrc.gov/docs/ML1309/ML13091A009.pdf [14] Fancy New Lids for Nuclear Waste Casks, As Contents Get Hotter, Jeff McMahon, May 2, 2013 http://www.forbes.com/sites/jeffmcmahon/2013/05/02/fancy-new-lids-for-nuclear-waste-casks-as-contents-get-hotter/?view=pc [15] NRC 10 CFR Part 72: [Docket No. PRM-72-4]: Prairie Island Coalition; Denial of Petition for Rulemaking, Federal Register, v. 66, no. 25 (February 6, 2001): p. 9058. FR Doc No: 01-3025 http://www.gpo.gov/fdsys/pkg/FR-2001-02-06/pdf/01-3025.pdf [16] NRC Acceptance Review of Renewal Application to Materials License No. SNM-2506 for Prairie Island Independent Spent Fuel Storage Installation – Supplemental Information Needed (TAC NO. L24592)http://pbadupws.nrc.gov/docs/ML1204/ML12046A157.pdf [17] Under SAFSTOR, which utilities refer to as “deferred dismantling,” a nuclear facility is maintained and monitored in a condition that allows the radioactivity to decay; afterwards, it is dismantled and the property decontaminated… http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/decommissioning.html [18] Office of Nuclear Materials Safety and Safeguards, Nuclear Regulatory Commission, “Spent Fuel Transportation Risk Assessment, NUREG-2125, May 2012http://pbadupws.nrc.gov/docs/ML1212/ML12125A218.pdf [19] Memo from Marvin Resnikoff to Bob Halstead, 7/18/2013, “NUREG-2125 Review”http://sanonofresafety.files.wordpress.com/2013/06/nureg-2125-review.pdf [20] DOE EPRI High Burn-up Dry Storage Cask Research and Development Project: Draft Test Plan, Contract No.: DE-NE-0000593, September 13, 2013, Page 2-1,http://1.usa.gov/1f6LkJH [21] NEI High Burn-up Used Nuclear Fuel Extended Storage and Transportation Demo, Rod McCullum, INL High Burn-up Used Fuel Demonstration Workshop, August 22-23, 2012 http://www.inl.gov/conferences/highburnupusedfuel/d/extended-storage-and-transportation-demo.pdf [22] TN-32 Generic Technical Specificationshttp://pbadupws.nrc.gov/docs/ML0036/ML003696874.pdf [23] Storage of High Burn-up Fuel, Nuclear Energy Institute (NEI), Marc Nichol, July 25, 2012 NRC Public Meeting, Slide 3,http://sanonofresafety.files.wordpress.com/2013/06/nei-highburnupslide2012-07-25.pdf [24] DOE EPRI High Burn-up Dry Storage Cask Research and Development Project: Draft Test Plan, Contract No.: DE-NE-0000593, September 13, 2013, Page 2-1http://1.usa.gov/1f6LkJH [25] Data from Characteristics for the Representative Commercial Spent Fuel Assembly for Preclosure Normal Operation, Bechtel SAIC Co., May 2007, OOO-PSA-MGRO-OO700-000-00A, Table 3. Thermal Power (Watts) per PWR Fuel Assembly with 4.0% U-235 http://pbadupws.nrc.gov/docs/ML0907/ML090770390.pdf [26] Data from Characteristics for the Representative Commercial Spent Fuel Assembly for Preclosure Normal Operation, Bechtel SAIC Co., May 2007, OOO-PSA-MGRO-OO700-000-00A, Table 3. Thermal Power (Watts) per PWR Fuel Assembly with 4.0% U-235 http://pbadupws.nrc.gov/docs/ML0907/ML090770390.pdf

Aging Nuke Plants On Fault Lines In Tsunami Hazard Zones = Fukushimas… Any Questions?
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Pandora’s Promise is Fukushima USA

Stop the Nuclear Waste Con! 

The NRC Draft Waste Confidence Generic Environmental Impact Statement is unacceptable. Much of it appears to be based on unsubstantiated hope.

WHAT: U.S. Nuclear Regulatory Commission Public Meeting to receive comments on the Draft Waste Confidence Generic Environmental Impact Statement Report and Proposed Rule.

WHEN: MONDAY, November 18, 2013

5 p.m.  CDSO Press Conference
5 – 7 p.m.   Overpass Light Brigade — We need Volunteers to hold Lighted Letters!

6 – 7 p.m.   NRC Open House (Q&A with NRC Staff)

7 – 10 p.m.  NRC Public Comment Meeting

WHERE: Sheraton Carlsbad Resort and Spa, 5480 Grand Pacific Drive, Carlsbad CA 92008

Background: As described by the NRC Chairman, Alison Macfarlane, in a recent speech, “in June 2012, the D.C. Circuit Court of Appeals vacated the NRC’s 2010 Waste Confidence rule. In the court’s opinion, the Commission’s conclusion that a high-level waste repository would be available ‘when necessary’ lacked an appropriate discussion of the environmental consequences of failing to achieve that objective. The ruling also expressed concern about potential spent fuel pool leaks and fires. In the time since the court issued its decision … NRC staff has been working to revise the Waste Confidence rule and develop a generic environmental impact statement. From the beginning, the Commission made it clear that public involvement must be an essential part of this process. Starting last month, the NRC has been holding a series of public meetings around the country to get important input for our final products.” 1

The public meeting in Carlsbad on November 18, 2013, is one of 12 being held by the NRC around the country to take comment on the Draft ”Waste Confidence Generic Environmental Impact Statement” Report,2 including a second California public meeting in San Luis Obispo on November 20th. See complete schedule at http://www.nrc.gov/waste/spent-fuel- storage/wcd/pub-involve.html#schedule

Stop the Nuclear Waste Con: “The NRC Draft Waste Confidence Generic Environmental Impact Statement (GEIS) is unacceptable. Much of it appears to be based on unsubstantiated hope and it ignores the unsolved problems of high burnup fuel. The NRC won’t approve short-term storage or transport of high burnup used nuclear fuel because they have no confidence it is safe,” states Donna Gilmore of SanOnofreSafety.org. The Waste Confidence GEIS needs to address:

√ HIGH BURNUP FUEL – Too hot to handle
No short-term storage or transportation solutions for high burnup fuel waste.3
• The NRC and DOE are concerned with the instability of high burnup nuclear waste in both storage and transport, yet the NRC continues approving this dangerous fuel for reactors.

> The NRC won’t approve high burnup dry cask storage over 20 years because they have NO CONFIDENCE it can be stored longer without releasing radiation into the environment, even though it must be stored for thousands of years.

The NRC won’t approve transportation4 of high burnup used fuel because they have NO CONFIDENCE it can be transported without releasing radiation into the environment.

San Onofre’s high burnup used fuel is so hot and radioactive, it requires up to a MINIMUM 20 YEARS cooling in the crowded spent fuel pools, instead of the minimum 5 years for lower burnup fuel.

√ Generic Environmental Impact Statement – NOT acceptable for California

California didn’t “sign up” for permanent (100+ years) nuclear waste dumps.

California nuclear waste sits in the world’s earthquake “ring of fire”, the same as

Fukushima, the most active and dangerous earthquake zone in the world. California’s nuclear waste is surrounded by known active earthquake faults and the USGS says no one has ever predicted a major earthquake.

California’s nuclear waste sits along an eroding coastline, in tsunami zones, and is exposed to a highly humid and corrosive coastal environment. NRC’s NUREG/CR-7030 states atmospheric corrosion of sea salt can lead to stress corrosion cracking within 32 and 128 weeks in austenitic [corrosion resistant] stainless steel canisters.5

It would be impossible to evacuate the millions of people living near California’s waste. Of the 34 million people in California, over 8.5 million reside within 50 miles of San Onofre.

A radiological disaster impacts the nation’s and world’s security, economy and food supply.

California is the eight ranking economy in the world, virtually tied with Italy and the Russian Federation, and larger than Canada, Australia and Spain.6

More than 40 percent of containerized imports enter the country through California ports, and nearly 30 percent of the country’s exports depart through them.7

California produces nearly half of the U.S. grown fruits, nuts and vegetables. California remained the number one state in cash farm receipts in 2011, with its $43.5 billion in revenue representing 11.6 percent of the U.S. total. U. S. consumers regularly purchase several crops produced solely in California.8

San Onofre is located adjacent to the primary vehicle transportation artery between Los Angeles and San Diego (I-5), and one of the largest military installations (and targets) on the West Coast (Camp Pendleton).

√ We oppose NRC’s proposed rule that future licensing can be based on the assumption spent fuel can be safely stored above ground virtually forever.

In the proposed NRC rule9 that accompanies the draft GEIS, the NRC proposes to incorporate into every reactor license the Draft GEIS’ conclusion that spent fuel can be safely stored above ground indefinitely.

This proposal would in effect forbid any further public discussion, in individual reactor licensing actions, of the serious question of whether generation of additional spent fuel is justifiable in light of the absence of any means of safe disposal.

The Coalition to Decommission San Onofre includes Citizens Oversight, Inc., Peace Resource Center of San Diego, San Clemente Green, SanOnofreSafety.org, and Women Occupy San Diego. For more information on nuclear waste, go to SanOnofreSafety.org.


1 http://pbadupws.nrc.gov/docs/ML1330/ML13309A775.pdf
2 http://pbadupws.nrc.gov/docs/ML1322/ML13224A106.pdf
3 Sources for high burnup information at http://sanonofresafety.org/nuclear-waste/

4 http://www.nrc.gov/reading-rm/doc-collections/isg/isg-11R3.pdf

5 Atmospheric Stress Corrosion Cracking Susceptibility of Welded and Unwelded 304, 304L, and 316L Austenitic Stainless Steels Commonly Used for Dry Cask Storage Containers Exposed to Marine Environments (NUREG/CR-7030) http://pbadupws.nrc.gov/docs/ML1031/ML103120081.pdf

6 http://www.ccsce.com/PDF/Numbers-July-2013-CA-Economy-Rankings-2012.pdf, http://www.dof.ca.gov/HTML/FS_DATA/LatestEconData/FS_Misc.htm 7 Pacific Merchant Shipping Association 11/10/13 http://www.pmsaship.com/default.aspx?ID=8
8 California Agricultural Statistics USDA October 31, 2012

http://www.nass.usda.gov/Statistics_by_State/California/Publications/California_Ag_Statistics/Reports/2011cas-all.pdf 9 http://pbadupws.nrc.gov/docs/ML1325/ML13256A004.pdf page1image13844

Coalition to Decommission San Onofre (CDSO) and Sierra Club Angeles Chapter


Media Contacts: Donna Gilmore, SanOnofreSafety.org 949-204-7794 donnagilmore@gmail.com / Martha Sullivan, Women Occupy San Diego, 858-945-6273 marthasullivan@mac.com / Glenn Pascall, Sierra Club Angeles Chapter, 949-248-3183 gpascall@att.net / Gary Headrick, San Clemente Green, 949-218-4051 gary@sanclementegreen.org

Aging Nuke Plants On Fault Lines In Tsunami Hazard Zones = Fukushimas… Any Questions?
PLEASE Turn off a light for Fukushima USA / San Onofre

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Community Symposium on Decommissioning San Onofre (HD)

Decommissioning San Onofre and the Ongoing Dangers of Nuclear Waste — San Onofre, The Risks Live On… a community symposium held October 19, 2013 in San Clemente, California. Main speakers: Dr. Arjun Makhijani, Dr. Don Mosier and Dr. Marvin Resn…

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How to support the “Nuclear Waste Symposium”

Please support our Nuclear Waste Symposium today

Two months ago, civic and environmental activists won a big victory in shutting down the San Onofre nuclear plant. It may seem that all is now quiet in San Onofre land – but it is not. Our Coalition to Decommission San Onofre has been startled by the huge challenge in dealing with radioactive nuclear waste at the plant. The issues include: unusually potent forms of fuel, dense storage of spent fuel far beyond design limits, large uncertainties about where the waste will ultimately be stored and for how long, and last but not least, the economics of decommissioning. These issues were below the radar during the shutdown debate but now they loom large.
We are organizing a symposium for October featuring highly-regarded national experts on the key issues, with plenty of time for questions to panelists and group discussion. Our immediate goal is to assure that best practices will be applied to minimize the risk for those who must live with San Onofre as a nuclear waste dump. Our ultimate goal is to reinvigorate the national discussion about what to do with America’s radioactive nuclear waste.  
Our target date is Oct 19, 2013. We need your help to make sure this important symposium comes to life. Please take moment right now to make your tax deductible donation today at paypal https://www.paypal.com/cgi-bin/webscr?cmd=_s-xclick&hosted_button_id=5K6JAPS2EGU4W   Based on necessary expenses for the event, our fund-raising goal is $9000. We have received $1000 as challenge grant from Glenn Pascall to start us off. Anyone who matches or exceeds this generous gift will be invited to join us for dinner afterwards with coalition leaders and with national experts who are our invited guest speakers. Any amount is welcomed.  If you prefer to write a check you can send to my address at 1203 Via Presa, San Clemente CA. 92672 using the name “Coalition to Decommission San Onofre”, bottom, bottom left under memo please write “Nuclear Waste Symposium”.
Our coalition member groups include: Peace Resource Center of San Diego, Citizens Oversight Project, Sierra Club Angeles Chapter, Women Occupy San Diego, San Clemente Green, San Onofre Safety, and Residents Organized for a Safe Environment (ROSE).
Gene Stone
Residents Organized For a Safe Environment (ROSE)
Aging Nuke Plants On Fault Lines In Tsunami Hazard Zones = Fukushimas… Any Questions?
PLEASE Turn off a light for Fukushima USA / San Onofre

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The $742 Million Question:

The $742 Million Question

Who should pay for the extra Decommissioning money, not yet collected?

Since the operators of San Onofre made the financial decision to shut it down prematurely, all decommissioning fees not already collected for Units 2 and 3 by 01/31/12, should be paid by the operators of San Onofre, not ratepayers!

Also the California Public Utilities Commission should required SCE put the Decommissioning of San Onofre out for public bid, instead of just giving the mega billion dollar job to SCE. California ratepayers cannot afford a sole source bid when so many International Companies with nuclear expertise are looking for work.

A public bidding process will save California ratepayers huge amounts of money, money which should not end up in SCE’s shareholders pockets. This single project has the potential to jump start our economy, we cannot allow the CPUC to short circuit our states bidding process by not putting this job out for bid!

   Decommissioning Costs as of 1/1/2012
SONGS 1     $ Million
SONGS 2 $ Million
SONGS 3 $ Million
  Radiological Costs
            Site Restoration
  Fuel Storage (Including ISFSI Decommissioning)
  Estimated Total Budget 2009 (See Note 2)
      Total Collected 10/31/12  (See Note 1)
    Total Projection 1/1/2012
Estimated Loss Due To Poor RSG Design/Operation
           86.2   Previously   Overbilled
        441.4           Shortfall
        300.8              Shortfall

  1. SCE  Letter to NRC (2012) https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?docId=0BweZ3c0aFXcFNHF2ZDVncy1GM0U
  2. SCE Testimony to CPUC (2009) https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?docId=0BweZ3c0aFXcFYlhqWHVQbEYyVkU


The purpose of the Nuclear Decommissioning Trust Funds is to mitigate for ratepayers the high cost of decommissioning nuclear power plants at the end of their lives by collecting reasonable fees over a long period of time. The CPUC directs the investor owned utilities to collect a regular Decommissioning fee on customers’ monthly electric bills for Edison and SDG&E’s San Onofre Plant (30 years old) and PG&E’s Diablo Canyon Plant (28 years old). The expected life of a nuclear power plant is 40 years.

$5.2 billion of ratepayer collection is currently invested with the Trust Funds.

At current liquidation value, combined Decommissioning Trust Funds are ~90% funded. The Trust Funds are currently invested in equities (60%) and investment grade fixed income securities (40%). D.87-05-062 established nuclear decommissioning trusts for funding future decommissioning of the utilities’ nuclear units. Each nuclear plant has decommissioning trusts and a committee that oversees the trust fund; Under Public Utilities Code § 8326, SCE is required to provide a decommissioning cost estimate that includes, among other things,

an estimate of the costs of decommissioning, and

a description of changes in regulation, technology, and economics affecting the estimate of costs.

As SCE explains, and as TURN’s witness Lacy acknowledges, the costs to decommission a nuclear facility include the costs to

store the spent fuel onsite or offsite until it is removed by the DOE;

remove residual radioactivity from the site, including from the spent fuel storage facility, to levels required to terminate the NRC license and to release the site for unrestricted use; and

remove non-radiological structures, systems, and components as required to leave the site in a safe condition, or as otherwise mandated by the state or the site owner.

The Utilities project that they will perform the actual decommissioning in three phases.

During Phase I, the Utilities will decontaminate, dismantle, and dispose of the units and the site common facilities. The Utilities will also continue to maintain the integrity and safety of the spent fuel while it remains on the SONGS site. The Utilities will maintain spent fuel in wet storage in spent fuel pools until it can be safely transferred to the SONGS 2 & 3 Independent Spent Fuel Storage Installation (ISFSI) or removed from the site by the U.S. Department of Energy (DOE). To safely store fuel in wet storage, the Utilities must maintain each plant system required for spent fuel pool operation until the fuel is removed. The Utilities will drain, de-energize, and secure all other plant systems. After the SONGS 2 & 3 spent fuel pools are empty, the Utilities will decommission the pools and their associated support structures and systems. The Utilities assume that by the time the SONGS 2 & 3 fuel has cooled sufficiently to be removed from the spent fuel pools, the DOE will have removed enough SONGS 2 & 3 fuel from the SONGS site that it will not be necessary to further expand the ISFSI pads or to construct additional Advanced Horizontal Storage Modules (ASHM) to accommodate that fuel.

During Phase II, the Utilities will monitor the ISFSI until the DOE removes the last spent fuel from the site, which is assumed to occur by 2051 based on studies developed from the DOE Acceptance Priority Ranking & Annual Capacity Report (DOE/RW-0567), dated July 2004.

During Phase III, the Utilities will dismantle and dispose of the ISFSI, all remaining site common facilities, and the remaining structural foundations; terminate the NRC licenses; and complete the final site restoration work.

Note: The Utilities do not own the site upon which the SONGS facility is located. Instead, they are authorized to use the site under several lease contracts and grants of easement from the U.S. Department of the Navy and the California State Lands Commission. To terminate these agreements, the Utilities are required to remove all improvements they installed or constructed on the site, except as agreed by the lessors/grantors, return the site to a condition satisfactory to the grantor, and return the site to the lessors/grantors.

Aging Nuke Plants On Fault Lines In Tsunami Hazard Zones = Fukushimas… Any Questions?
PLEASE Turn off a light for Fukushima USA / San Onofre

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