Possible dates for the next SCE/CEP meeting & workshop on Nuclear Waste may be Jan 27 or the 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. David Victor 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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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.
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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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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Premature Failure of U.S. Spent Nuclear Fuel Storage Canisters

In a nutshell all we are saying is that this process should be slowed down to ensure the best possible choice of dry cask canisters is made, spend the money wisely “once” to avert another steam generator type disaster and ensure the safety of California’s future. Gene Stone &  Donna Gilmore.

Premature Failure of U.S. Spent Nuclear Fuel Storage Canisters
The California Public Utility Commission (CPUC) should delay funding the new San Onofre dry cask storage system until Southern California Edison provides written substantiation that the major problems identified below are resolved. 
San Onofre’s Chief Nuclear Officer, Tom Palmisano, told the California Senate Energy, Utilities and Communications Committee on August 12th that Edison plans to decide in August or September on a dry cask system vendor. The dry casks systems Edison is considering may fail within 30 years or possibly sooner, based on information provided by Nuclear Regulatory Commission (NRC) technical staff. And there is no technology to adequately inspect canisters and no system in place to mitigate a failed canister.
Edison created an artificial date of June 2019 to have all the spent fuel assemblies loaded into canisters. We don’t need to rush into another “steam generator” like boondoggle.  Edison’s Tom Palmisano told the California Senate Energy, Utilities and Communication Committee on August 12th that issues regarding high burnup fuel and dry cask storage have been addressed. However, these issues have not been resolved.
Canisters may need to be replaced within 30-42 years or sooner. 
Recent information provided by the NRC technical staff indicates dry storage canisters may need to be replaced within 30-42 years or sooner, due to stress corrosion cracking of the thin (1/2 to 5/8 inch) stainless steel canisters (due to our coastal environment). Similar stainless steel materials at nuclear plants have failed within 16 to 33 years.  The concrete overpacks also have aging issues that are accelerated in coastal environments.                                          sanonofrecaskloadingintostoragebunker
Southern California Edison has budgeted $400 million dollars for the dry storage system. As Commissioner Florio stated after the recent CPUC meeting in Costa Mesa, “We don’t want to have to buy these again.”
No remediation plan to repair or replace failed canisters.
The NRC stated that if one of the canisters becomes defective (e.g. 75% through-wall stress corrosion cracks), there is no way to repair or replace the canister; especially if the spent fuel storage and transfer pools are demolished, as Edison plans to do. And before a canister can be transported (inside a transport cask), the canister must not have cracks.
No technology to adequately inspect canisters for stress corrosion cracking.
The NRC states technology does not exist to adequately inspect steel canisters for stress corrosion cracks or to measure how or when the cracks will go through the wall of the canister. They plan to allow the nuclear industry 5 years to try to develop technology. And then they only plan to require inspection of one canister at each nuclear plant.  
No license renewals until aging management issued addressed.
The NRC is in the process of developing an aging management plan due to the new requirement that dry storage systems need to last 100 to 300+ years. They are delaying license renewals until unresolved aging management issues can be addressed. However, they plan to allow the NUHOMS 32PTH2 canister that Edison may procure to be included in an existing license. The NRC is evaluating how long dry storage systems will last. Previously, they only needed to last 20+ years with the assumption there would be a permanent repository.
No canisters approved for high burnup fuel for more than the initial 20 years.
The NRC has not extended licenses past the initial 20 years for storage of high burnup fuel (>45GWd/MTU) due to unknowns about high burnup fuel in storage and transport. This fuel is over twice as radioactive and hotter than lower burnup fuel.  The NRC has allowed nuclear plants to burn fuel longer, without the research to show that it is safe in storage and transport. The protective fuel cladding can become brittle and crack; resulting is higher risk for radiation exposure, if the canisters fail.
NUHOMS dry canister license certification expires in less than nine years.
The NUHOMS DSC-32PTH2 canisters that Edison wants to procure are not yet licensed by the NRC. If approved, the license will expire in less than nine years (February 5, 2023), since Areva-TN decided to avoid a new license certification and include it in their existing license for the DSC-24PT series, which has a different design.
New design of the NUMHOMS DSC-32PTH2 eliminates failed fuel cans.  
Unlike the existing 24 fuel assembly canisters, the new 32 fuel assembly canisters have no provision for Failed Fuel Cans. This means damaged fuel assemblies (of which San Onofre has many) cannot be used in the DSC-32PTH2 canisters. The NRC and DOE require fuel assemblies to be retrievable so they can be transferred to other containers. The Failed Fuel Cans met this requirement.
Background
On July 14th, 15th and August 5th the NRC had public meetings to address aging management issues with dry cask storage system. Their goal is to require an aging management plan before relicensing or issuing new licenses, now that the NRC knows on-site or interim dry cask storage will be needed for up to 300 years or more. The NRC stated the earliest date for a permanent repository is 2048 and that is optimistic. They are researching on-site and interim dry cask storage requirements for 40,100, 150 and 300+ years. No NRC canisters are certified for extended storage or for geological repository storage. Canister licenses for the more dangerous and unstable high burnup (>45GWd/MTU) spent fuel have not been renewed for more than the initial 20 year license, even for expired licenses. And the NRC’s Bob Einziger states there are still transportation problems with high burnup fuel. NRC staff plan to have a draft for public comment regarding dry cask storage relicensing by the end of 2014, according to Mark Lombard, Director, Division of Spent Fuel Storage and Transportation. However, this will not address our current issues.
Stainless Steel Dry Canister Problems
Darrell Dunn, an NRC materials engineer, stated stainless steel dry storage canisters are vulnerable to failure within about 25 – 42 years. If any of the fuel cladding in the canister fails, there is no protective barrier and we could have a serious radiation release. The NRC said they have no current mitigation plan for that consequence.  They suggested we MIGHT be able to put the fuel back in the spent fuel pool.  However, Edison plans to destroy the spent fuel and transfer pools. And there is no technology to repair the canisters. The NRC said they HOPE there will be a solution for mitigation in the future. Even an NRC May 2nd High Burnup Fuel letter admits there are mitigation problems.
No Inspections of Stainless Steel Canisters
To make matters worse, these stainless steel canisters are not inspected after they are loaded into the unsealed concrete overpacks (Areva NUHOMS) or concrete casks (Holtec and NAC Magnastor).  The NRC proposed having each nuclear plant inspect the outside of only ONE stainless steel canister before they receive a license renewal and then do that once every 5 years.  The industry balked at having to even check one canister at every plant. The problem with the stainless steel canisters is they do not protect against gamma rays; so it’s not a simple task to remove a canister from the concrete overpack/cask to examine the exterior for corrosion or other degradation. And since welded canisters do not have monitoring for helium leaks, we may not have any warning of an impending radiation release. 
Concrete Overpack Corrosion Problems
Darrell Dunn discussed serious corrosion problems with the concrete overpacks/casks, especially in coastal environments.   
Ductile Cast Iron Casks may be a better solution
Asked if San Onofre would be better off using ductile cast iron casks like the CASTOR, due to our coastal environment, Aladar (Al) Csontos, NRC Branch Chief in the Division of Spent Fuel Storage and Transportation (SFST), said that might be a better option near the ocean. Casks, such as CASTOR, may eventually have aging issues with bolts and seals. The CASTOR has double sealed lids, so even if one fails, we’ll still have a sealed canister. And Edison would be able to easily monitor for cask material degradation with all the casks.
The NRC licensed the CASTOR V/21 ductile cast iron cask years ago and the cask is still in use. In fact, a CASTOR V/21 was used to prove low burnup fuel is safe to store for over 15 years. However, none of the current U.S. cask designs have been tested even though they use a different storage technology.  The U.S. industry chose a different technology (stainless steel/concrete overpack/cask) mainly due to the cost of ductile cast iron at the time and with the assumption that the canisters would only be needed until Yucca Mountain opened. The CASTOR V/21 was considered the “Cadillac” of the industry and the CASTOR line is still very popular in other parts of the world for BOTH storage and transport (including high burnup fuel). The CASTOR canisters have multiple certifications for quality manufacturing, unlike the U.S. stainless steel canisters that are allowed exceptions to ASME and other standards. Material prices for stainless and cast iron have changed, so the price point should be lower.
The CASTOR has pressurized lid monitoring to detect helium leaks and temperature changes. The welded U.S. canisters do not have this capability, but the NRC and Department of Energy (DOE) state this is a high priority issue to resolve.
The inside of the CASTOR cask, including the sealing surface, has a nickel coating for corrosion protection. On the outside, the cask is protected by an epoxy resin coating in the fin area and nickel coating elsewhere.  And unlike the U.S. stainless steel canisters, it does not have stress corrosion cracking issues and does not require a concrete overpack/cask.
The original CASTOR V/21 is almost 15″ thick as opposed to the 1/2″ to 5/8″ stainless steel canisters.  The newer model CASTOR V/19 is almost 20″ thick. There are other ductile cast iron canister brands that are used in other countries. However, the U.S. emphasis on cost rather than longer term safety discourages competition from better quality casks vendors. With new U.S. needs for longer term onsite and interim dry cask storage, this should change.
Forged Steel Casks (AREVA TN Series)
Areva makes thick walled forged steel casks (TN series), which were approved for limited use years ago by the NRC. The TN cask is much thicker than the stainless steel canisters and doesn’t require a cement overpack/cask.  Its specifications are not as robust as the CASTOR, but better than the Areva NUHOMS system that Edison may procure.  Fukushima Daiichi and Germany use some TN casks. Germany mainly uses the CASTOR casks. 
Enclose Casks in Buildings
Both Japan and Germany enclose their casks in buildings for protection from the environment and other external forces. This is something Edison should consider.
Action Needed
No dry cask solution is even close to perfect, but we need to buy ourselves as much time as possible. Given the issues with stress corrosion cracking, concrete degradation, lack of monitoring, and lack of external inspection of stainless steel canisters, we can do better. Spent fuel pools are dangerous. However, the spent fuel needs to cool in the pools for a number of years, so we have time to do a better job selecting a dry cask storage system. Edison’s artificial deadline of June 2019 to have all canisters loaded should not be the driving factor for the future of California.
The NRC does not proactively research dry storage system designs. They only respond to vendor requests for licensing. Vendors will only do this if they think they have a customer lined up for their product. California needs to be that customer. 
Edison should reopen the bidding to include vendors with other cask technology. Edison’s Community Engagement Panel (CEP) had a presentation from Areva, but from no other dry cask storage vendors. Edison only solicited bids from three canister system manufacturers who all have the problems mentioned in this document. Edison requested the NRC approve the NUHOMS 32PTH2 design – it was not licensed when they decided to use it. That license amendment (Docket No. 72-1029, Certificate of Compliance No. 1029 Amendment No. 3) may be approved in August.  However, the CPUC should not approve funding for this canister system.
Edison has not shared with us the documents they used to solicit bids (Request for Proposal), so we have no idea what the requirements are in that bid package.  That would be useful information and the public should have access to this information.
If you have questions about sources for any information, contact Donna Gilmore. There are also detailed references on the SanOnofreSafety.org website.  A link to the NRC July and August presentations as well as other documents discussed here are on the following pages.
Donna Gilmore                                            
SanOnofreSafety.org                                  
949-204-7794, dgilmore@cox.net 
Gene Stone
Residents Organized for a Safe Environment (ROSE)                              
Member, SONGS Community Engagement Panel
949-233-7724, genston@sbcglobal.net
References
High Burnup Fuel
High Burnup Nuclear Fuel −Pushing the Safety Envelope, M. Resnikoff, D. Gilmore, Jan 2014  http://sanonofresafety.files.wordpress.com/2014/01/hbffactsheet01-09-2014.pdf
Response from Donna Gilmore to NRC regarding May 2, 2014 request for NRC high burnup fuel technical basis, June 25, 2014
NRC Presentations
NRC Meeting to Obtain Stakeholder Input on Potential Changes to Guidance for Renewal of Spent Fuel Dry Cask Storage System Licenses and Certificates of Compliance, July 14th/15th, 2014 (includes slide presentations)
Chloride-Induced Stress Corrosion Cracking Tests and Example Aging Management Program, Darrell S. Dunn, NRC/NMSS/SFST, Public Meeting with NEI on Chloride Induced Stress Corrosion Cracking Regulatory Issue Resolution Protocol, August 5, 2014
CASTOR Dry Casks (Ductile cast iron cask technology)
CASTOR V/21 NRC Certificate of Compliance and Safety Analysis Report, August 17, 1990   http://pbadupws.nrc.gov/docs/ML0330/ML033020117.pdf
CASTOR brochure (includes the CASTOR V/19 and other ductile cast iron casks).
GNS’ [CASTOR] experience in the long-term storage at dry interim storage facilities in Ahaus and Gorleben, IAEA Vienna, May 20, 2014  http://bit.ly/1jUSNOZ
Spent Fuel Storage and Transportation Experience, Idaho National Engineering Laboratory (GNS Castor V/21, Transnuclear TN-24P, Westinghouse MC-10, NAC S-100-C), 1987
BAM test results for CASTOR transport containers
Fracture Mechanics Based Design for Radioactive Material Transport Packagings, Historical Review, Sandia SAND98-0764 UC-804, April 1998http://www.osti.gov/scitech/servlets/purl/654001
GNS CASTOR Presentation, June 09-11, 2010, Varna, Bulgaria (slide 18: CASTOR V/19, V52)
Areva TN Series Casks (forged steel cask technology)
TN-24 NRC Certificate of Compliance and Safety Analysis Report, November 4, 1993
AREVA Innovation in the Design of the Used Fuel Storage System, CRIEPI Tokyo, November 15-17, 2010 (includes information on TN 24 casks)
AREVA Dual Purpose Casks in Operation, AREVA TN Experience, Vienna, May 19-21, 2014 http://bit.ly/1l9xO5R
NUHOMS 32PTH2 and San Onofre Decommissioning Plans
NRC Certificate of Compliance for Spent Fuel Storage Casks, COC 1029, Docket 72-1029, Amendment 3, Model No. Standardized Advanced NUHOMS®-24PT1, 24PT4, and 32PTH2,  expires 02/05/2023 (pending NRC approval as of 8/20/2014)
Comments on Direct Rule re List of Approved Storage Casks (79 Fed. Reg. 21,121 (April 15, 2014), Request for Rescission of the Direct Rule, and Request for Publication of a New and Revised Notice of  Proposed Rulemaking, Docket No. 13-0271, Diane Curran, on behalf of 20 environmental organizations and individuals.
February 10, 2012 letter from Edison to NRC: Support for NRC Review of Transnuclear Inc. Application for Amendment 3 to the Standardized Advanced NUHOMS® Certificate of Compliance No. 1029, San Onofre Nuclear Generating Station, Units 2 and 3 and Independent Spent Fuel Storage Installation Docket Nos. 50-36, 50-362 and 72041
Update on Decommissioning Plans, Tom Palmisano, Vice President & Chief Nuclear Officer, August 12, 2014 presentation to CA Senate Energy, Utilities and Communications Committee, Chairman Alex Padilla
Community Engagement Panel Correspondence
High Burnup Fuel and Dry Cask Storage Issues, July 17, 2014 letter to CEP Chairman David Victor from Donna Gilmore, San Onofre Safety
David Victor testimony to NRC Commissioners, July 15, 2014
Additional references at SanOnofreSafety.org
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Notes from David G. Victor SCE/CEP Chairman

Here are two important notes from David G. Victor SCE/CEP chairman.  Reading these carefully will give you insight into David’s understanding and misconceptions of how Southern California should proceed with the decommissioning of SONGS and it’s new life as a Nuclear Waste Dump, and how in the world to work with the NRC.

Overall in my opinion he is starting to get the complexities in decommissioning a Nuke Plant with 8,4 million people within a 50 mile radius and the lack of real direction and oversight by the NRC.
To read these note click on the links below.
Burden
By Gene Stone, ROSE

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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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Issues involving Storage and Transportation of High Burnup Nuclear Fuel

Issues involving Storage and Transportation of High Burnup Nuclear Fuel

By
Marvin Resnikoff, Ph.D.
SCE Community Engagement Panel (CEP)
San Juan Capistrano Community Center
May 6, 2014
In the interests of full disclosure, I once worked for a public interest organization with the trademarked name, CEP, Council on Economic Priorities, and co-authored a book in 1983 on transportation issues, 3 years before Holtec, who supplies dry storage casks for the nuclear industry. The CEP book supported dry storage of nuclear fuel, but I never realized at the time the present situation, the amount of fuel and burnup that the industry would employ. In a way, part of the problem is my doing. As a member of the Sierra Club, we intervened against the only commercial reprocessing operation in the United States, Nuclear Fuel Services in West Valley, NY, and shut them down. The lack of reprocessing has led utilities to store more fuel in storage pools and in dry storage casks. The lack of a final repository is also partly my doing. I work for the State of Nevada as a consultant on nuclear transportation issues and have since 1986. My parents never gave me a middle name, but sometimes I think it’s “Trouble.”
So utilities are left with the problem of spent nuclear fuel and also faced with competition from natural gas. The economics has forced utilities to hold fuel in reactors longer, not 3 years, but 4 ½, which means less shutdown time. And the economics are also forcing the industry to put more fuel into each dry storage cask, moving from 24 PWR assemblies, to 32, which Transnuclear has requested for San Onofre, to 37 PWR assemblies, which Holtec has requested. I’m going to briefly discuss transportation and storage of nuclear fuel, and I’m going to focus on high burnup nuclear fuel (HBF). What and why is HBF? NRC has not fully investigated the technical issues and implications, which in my view, are major and should have required careful study and an EIS. This is work that should have been done before the NRC allowed utilities to go to high burnup, not after. By high burnup, I mean fuel greater than 45 GWD/MTU, but in clearer terms, allowing each assembly to remain in the reactor longer. The implications are the radioactive inventory in HBF is greater. NRC staff have focused on the heat in HBF, which is greater. But heat will decline over time. One implication is decommissioning will take longer. Fuel will sit in fuel pool for 20 years or more. San Onofre has high burnup fuel. The implication of a longer decay time is that the workers at the site will not be available for the decom process. Putting more fuel into the same space, moving from 24 fuel assemblies to 32, as Southern California Edison intends to do, will further the cooling off period. However, while heat is an important consideration, but perhaps of greater import is the impact on fuel cladding. It may surprise you to know that the NRC does not know how much HBF exists across the country. While the NRC has the power and the ability to identify how much HBF is at each reactor. The NRC has inspectors at each reactor. They simply have not made the effort. The Department of Energy (DOE) is conducting a survey which should be released in September. HBF has major implications for decommissioning, storage, transportation and disposal.
Storage Issues
Let’s step back a second. Nuclear fuel assembly – collection of fuel rods. (fuel assembly) Each rod, about 12 feet long is composed of a tube, cladding, with nuclear fuel stacked like poker chips inside. But the cladding is quite thin, not much thicker than heavy duty aluminum foil. During operation and after, the cladding will develop defects. Studies by Argonne show that the zirconium cladding of HBF will become less ductile, or more brittle. How brittle? The NRC has contracted with Oak Ridge to examine cladding of HBF. The Oak Ridge study should have been completed in March, but has not been released. I call on the NRC to release the Oak Ridge study, before it is manicured by public relations specialists. This is a study that should have been done before HBF was licensed, not after the fact. In response the NRC would say, we do have technical support. The NRC will cite a study at Turkey Point reactor. But this demonstration project examined a cask loaded with lower burnup fuel (approximately 30 GWd/MTU average). Following 15 years of storage, the cask internals and fuel did not show any significant degradation (Einziger et al., 2003). According to that report, the data from this study can be extrapolated to maintain a licensing safety finding that low burnup SNF can be safely stored in a dry storage mode for at least 80 years with an appropriate aging management program that considers the effects of aging on systems, structures, and components (SSCs). The limits in ISG-11, Rev. 3, a peak cladding temperature of 400 oC, are all based on data available prior to 2002. None of this is directly relevant to HBF.
The NRC will also cite the 1988 report, PNL-6258, “Assessment of the Use of Extended Burnup Fuel in Light Water Power Reactors,” but this report did not address the cladding problems of HBF.
Cooling during storage may result in hydride-induced embrittlement. According to a more recent Argonne report, “pre-storage drying-transfer operations and early stage storage subject cladding to higher temperatures and much higher pressure-induced tensile stresses than experienced in-reactor or during pool storage.” The Argonne report discussed the problems of embrittlement of cladding of HBF. Due to thinning of cladding and lack of ductility, the cladding is weakened. As a result the cladding may not be an effective barrier to release of radioactivity to the cask canister. A report by the Nuclear Waste Technical Review Board goes into the matter in great detail. Thinning of cladding is correlated with the outer oxide layer on the cladding. As seen in the figure below, at a burnup of 60 GWD/MTU, the outer oxide layer is 115 microns. Considering the initial cladding thickness is on average 600 microns, NWTRB calculates a metal loss on the order of 70 microns or 12% at 60 GWD/MTU. Together with a hydride layer inside the cladding, this represents substantial weakening of the cladding.
Moving closer to home, for this reason, we are of the opinion, Edison should consider the HBF fuel assemblies to be damaged fuel that should be individually canned; the canned assemblies would then be stored in a HUHOMS concrete containment (NUHOMS being inserted) or a Holtec vertical silo (Holtec silo) for an indefinite period.
Passive cooling works like a chimney. Once fuel is removed and put into storage, after 18 to 20 years, the NRC license can be converted to storage. Here is what remains of CT Yankee reactor (photo). Nuclear fuel in 40 Holtec casks, and reactor internals in 3 casks. San Onofre will have many more casks. But one additional feature distinguishes the San Onofre situation, the salt environment. Documents show that the stainless steel canister has pitting corrosion, after less than 20 years. This is a major concern if casks are going to remain on-site for an extended period, say 40 to 100 years. NRC’s NUREG/CR-7030 states that atmospheric corrosion of sea salt can lead to stress corrosion cracking within 32 and 128 weeks in austenitic [corrosion resistant] stainless steel canisters. How will this corrosion be prevented? Can the canisters be coated to prevent corrosion We do not believe the industry has the experience in transferring failed (damaged) fuel from one cask to another and no procedures for doing this. In fact, no spent fuel bundle, damaged or not, has ever been transferred from one dry cask to another. Since high burnup fuel is more likely to fail sooner in storage, this becomes an even bigger and more urgent problem.
This is not a theoretical problem. Three examples of stress corrosion cracking at San Onofre have already been seen. In the fall of 2009, three examples of chloride-induced SCC which extended through-wall were discovered at the San Onofre Nuclear Generating Station (SONGS) in the weld heat-affected zone (HAZ) of Type 304 stainless steel piping. The piping included 24-inch, Schedule 10 emergency core cooling system (ECCS) suction piping; 6-inch, Schedule 10 alternate boration gravity feed to charging line piping; and an ECCS mini flow return to refueling water storage tank. While the through-wall failures were attributed to chloride-induced SCC, surface pitting was also observed on the surface of the pipes, with a greater concentration in the weld HAZ. All three pipes were exposed to the outside ambient marine atmosphere. Through-wall cracks developed after an estimated 25 years of service….
These are my takeaways on the HBF and storage issue:
• Little technical support for NRC approval of high burnup fuel (HBF). Experiment taking place in the field.
• Total amount of HBF unknown. At a minimum, the NRC should survey utilities.
• HBF will postpone storage up to 20 years; 32 PWR canister extends cooldown period.
• Cladding defects are a major problem for HBF; HBF may not be retrievable. HBF should be canned.
• Because of corrosion, long-term storage may not be possible in a salt environment.
Transportation Issues
Brittleness is important when considering transportation and disposal. One utility, Maine Yankee, has taken the important step of canning the HBF, that is, individually enclosing each fuel assembly in a stainless steel container. Concern is vibrations when transported, and potential shattering of cladding in a transportation accident. Transportation casks must satisfy regulatory accidents. Casks must withstand 30 foot drop onto an unyielding surface. In a hypothetical transportation accident, cask must withstand an end drop (drop from Holtec rpt) where 140 ton casks are cushioned by impact limiters. But a more serious accident involves a side impact where impact limiters are not present. One example is a RR crossing where a cask could be struck by the sill of a locomotive. (picture from NV rpt). NRC has not carefully evaluated such an accident, including the impact limiters. NRC hypothetical accident requires the cask to withstand a 30 inch drop onto a punch.
Another type of accident involves fire. Several major train fires have occurred recently. 140 ton casks would be shipped by train, on the same routes used by oil tankers. Right now, nuclear fuel has nowhere to go, no final repository. But NRC has not done the statistical analysis to determine the statistical likelihood of a nuclear shipment caught in an oil tanker fire. A study of the likelihood of an accident involving an oil tanker fire and a nuclear shipment requires a sophisticated Monte Carlo analysis. In addition to the likelihood of a long duration fire involving a nuclear cask, the NRC must also analyze the consequences of a radioactive release In my opinion, the NRC has not properly taken into account a long duration fire, by not properly taking into account the conduction of fire heat into the cask interior. As seen, fuel sits within a sealed canister, welded shut. The transportation overpack is metal, but this is surrounded by a neutron absorber, generally boronated, hydrogenated plastic, with an outer metal envelope. (picture of cask crossection). Plastic does not effectively conduct heat, so additional metal pieces serve to transfer heat out of the cask, but also conduct heat into the cask in a fire. Oil fire may burn at 1850 oF or higher depending on the air supply. The hypothetical accident fire consists of an all engulfing fire at 1475 oF for 30 minutes, while an oil fire can burn for many hours. The most recent NRC report NUREG-2125 does not correctly take into account a long duration high temperature fire and should be redone.
Here are my takeways on the transportation issue:
• Realistic low probability, high consequence accidents should be examined.
• Side impact rail accidents may shatter HBF cladding.
• Long duration, high temperature fires may involve oil tankers that travel the same tracks. NRC has not properly quantified the statistical likelihood.
Aging Nuke Plants On Fault Lines In Tsunami Hazard Zones = Fukushimas… Any Questions?
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SCE Cited For Major Nuclear Related Safety Violation At San Onofre

Get SCE Out of San Onofre

Background: NRC Spent Fuel Pool Cooling Requirements:


“Each licensee shall develop and implement guidance and strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire ….”
The San Onofre spent fuel cooling fire protection plan in the event of a large fire and/or explosion hinges on the expertise and staffing of the on-sight San Onofre Fire Department.
Since the San Onofre Fire Department and Emergency Planning Personnel Staffing was reduced to a skeleton crew without prior approval from the NRC after a full and proper evaluation, the existing fire plan is now outdated and unrealistic in event of a large fire or explosion.
A Spent Fuel Pool Cooling Accident, in case of a large fire or explosion without adequate and demonstrated mitigation measures is a MAJOR Nuclear Safety Concern for all the millions of Southern Californians living within the 10 Mile Emergency Protection Zone.  Remember Fukushima‘s triple meltdowns occurred because of a failure to keep their reactors cool after the big earth quake and tsunami which occurred on 03/11/11.

Last Friday, the NRC cited SCE, the operator of San Onofre’s nuclear power plant for violating NRC rules by failing to get approval before eliminating 39 emergency-response jobs after the plant closed last year.
Historically, NRC Region IV has had the habit of citing Southern California Edison with only low level violations, even if the violations were actually severe violations.  This cozy relationship was a contributing factor in the radioactive leak that resulted in the early decommissioning of San Onofre Units 2 & 3 and the loss of billions of dollars to SoCal ratepayers that could have been prevented, if the NRC had enforced the Federal Regulations as written.  This type of safety enforcement is not good for Californians or the NRC.  Now a serious review/investigation and proper action/fines are required by the NRC and its Commissioners, to assure Nuclear Safety is maintained at San Onofre and all the other US Nuclear Power Plants.
The question the NRC should ask is, Knowing that the SPENT FUEL POOLS MUST STILL BE KEPT COOL 24/7 no matter what, if a major earth quake occurred tonight, would San Onofre Fire Dept.’s skeleton crew be able to guarantee US that they could prevent a nuclear accident from occurring, especially since the 39 emergency-response positions that were illegally eliminated, probably cost ratepayers much less than even one still employed highly paid nuclear manager who would be home sleeping?  
The question that the CPUC should ask is, “If SEC is really interested in safety as they keep telling us, what is the reasonableness of continually cutting corners on those that actually insure our safety, while at the same time retaining other highly paid nuclear Staff?
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Moving forward with Decommissioning San Onofre

“ROSEMEAD, Calif. June 7, 2013 Southern California Edison (SCE) has decided to permanently retire Units 2 and 3 of its San Onofre Nuclear Generating Station (SONGS).”

 It was a great day for many individuals and groups who had come together to work for the greater good and safety of their communities.  From LA to SD and points in between, and in fact across the nation.  At times it was more than interesting to watch so many different individual opinions and ideas and methods coalesce to work together.  The Angeles chapter Sierra Club, Peace Resource Center of SD, San Onofre Safety, Decommission San Onofre, San Clemente Green and ROSE, these working groups & individuals became known as the “Coalition to Decommison San Onofre”.  It was like the universe itself had appointed this time and place for these people and groups to come together and develop a vortex of energy for the purpose of speaking truth to power about the extreme dangers sitting on the California coastline at San Onofre known as San Onofre Nuclear Generating Station (SONGS). Please believe me when I say it was not any one individual or one single group that did this alone. It was in fact everyone who informed themselves on the issues, worked, organized, prayed, donated time and money and showed up to speak at meetings all around Southern California. I am sure these coalition members and individuals are committed to staying strong and working for the continued good of the community.   It seemed this time and place was appointed by something beyond ourselves.

While I was hoping to take some time off to see the grandkids, finish some art pieces, and maybe take care of my health, California Edison called saying we would like someone from the anti-nuclear perspective to sit on their new Community Engagement Panel (CEP) for the decommissioning of SONGS, and would I as founder of ROSE do it? I had hoped as we all did that others from our highly energized coalition would be represented on the new CEP.  At first I reluctantly said yes. But after thinking about it I can only hope that the universe has made a new appointment for us to help develop a new vortex of energy with the new CEP for the safe, sane and economical decommissioning of units 2 and 3 and the safest storage and removal in time of the extremely dangerous toxic nuclear waste sitting near our homes, and finally to restore the land to the pristine conditions for the future generations of Californians to come.

Residents Organized for a Safe Environment (ROSE) Response and Pledge to SCE’s statement of core principles and values for the decommissioning of San Onofre.

ROSE is pleased to see the SCE “Statement of core principles and values for the decommissioning of San Onofre” and is happy to sit on the Community Engagement Panel (CEP) with other community members. ROSE pledges to Southern California residents & SCE to help Southern California Edison keep these principles and core values alive every step along the way during this process. ROSE pledges to help SCE become a model for the nuclear industry in safe and sane decommissioning of our nation’s dangerous and aging nuclear fleet. ROSE pledges to stand for cleaning the SONGS site of radiation to the best degree possible in the most economical way for the ratepayers. ROSE pledges to stand for worker safety in all areas of decommissioning of San Onofre. ROSE pledges to help SCE understand and use best practices in the process even if we have to rethink them. ROSE pledges to stand for the removal of all radioactive materials from the site as soon as it is possible and restore this site to its natural condition.

It is clear that DOE and NRC studies pertaining to the storage of San Onofre’s High Burnup fuel have not been completed at this point in time, and the best practice for dealing with this extremely high radioactive fuel and the timeframe for doing so is unclear and has no consensus in the community and scientists working on this problem.

I hope other members of the newly appointed CEP will join me in this Pledge to the future of all Californians and the many generations to come.

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San Onofre Cancer Report by Joe Mangano Published

San Onofre Cancer Report by Joe Mangano Published
Joe Mangano The Radiation and Public Health Project  
P.O. Box 1260 Ocean City NJ 08226 
Click here for the RADIOACTIVE EMISSIONS AND HEALTH HAZARDS FROM THE SAN ONOFRE NUCLEAR REACTORS IN CALIFORNIA PDF 

Everyone and especially those with small children should consider making a donation to Joe Mangano’s* The Radiation and Public Health Project for publishing his San Onofre Cancer Report at no cost, as a public service.


Note: This study comes long before similar studies being done by the NRC which will take years to complete, yet the nuclear industry group already claims that they “won’t provide any meaningful data” (see below).

After reading Joe Mangano’s study, you can decide for yourself.
* Joseph J. Mangano, MPH, MBA, is Director, Secretary, and the Executive Director of the Radiation and Public Health Project.
Mr. Mangano is a public health administrator and researcher who has studied the connection between low-dose radiation exposure and subsequent risk of diseases such as cancer and damage to newborns.
He has published numerous articles and letters in medical and other journals in addition to books, including Low Level Radiation and Immune System Disorders: An Atomic Era Legacy. There he examines the connection between radiation exposure and current widespread health problems.


For comparison:

CANCER RISKS STUDIED NEAR 7 US NUCLEAR SITES

— Oct. 24 2:03 PM EDT

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HARTFORD, Conn. (AP) — Federal regulators say a pilot study of cancer risks posed to residents near seven nuclear power sites in the United States will update 22-year-old data, but an industry group says the study won’t come up with anything new.

The Nuclear Regulatory Commission says it will study cancer types in infants and the general population near six nuclear power plants and a nuclear-fuel plant for the Navy. The $2 million study is expected to begin in the next three months and continue at least into 2014.

The Nuclear Energy Institute, an industry group, opposes the study, saying it won’t likely provide any meaningful data.

The sites are in California, Connecticut, Illinois, Michigan, New Jersey and Tennessee.

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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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)
http://residentsorganizedforasafeenvironment.wordpress.com/
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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