Sunday, December 28, 2014

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.

Wednesday, December 10, 2014

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 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:

Tuesday, November 25, 2014

San Onofre Dry Cask Danger founder Donna Gilmore's presentation to the NRC on dry cask nuclear waste storage issues at the San Onofre Nuclear Waste Dump, delivered by invitation as part of an NRC Regulatory Conference held Nov. 19-20, 2014 in Rockville, Maryland.

San Onofre Dry Cask Danger
San Onofre Dry Cask Danger Be Advised
Related articles

Tuesday, October 28, 2014

My full statement to the NRC, Oct 27, 2014

I'd like to thank the NRC for hearing our comments today. I'am happy to see many friends here today that will speak for the safety of CA.
I must say, I no longer believe that SCE is considering doing the state of the art decommissioning that they promised us at the first Community Engagement Panel meeting. Nor do I believe that the NRC will demand or require that of them! But a more standard approach to decommissioning.
The NRC should have to be more proactive with its approach to SCEs PSDAR? The fact that the NRC does not approve or disapprove this minimalist approach to the safe storage of nuclear waste is very disappointing & alarming. Going forward with a plan that uses canisters that were designed for short-term storage does not make sense.
What would make sense to me is if the NRC would take an active regulatory role forcing & working with the industry to improve the design of the dry cask canisters and set in place a real & effective system of defense in depth, a aging management plan, for long-term storage of nuclear waste and a real method of inspection and monitoring of these improved canisters.
Thank you for listening to the people who will speak to you today for the safety of California's 8.4 million people, it's children & environment and the economy of SoCal.
You may now check this meeting off your list as another NRC public relations meeting where the public was heard but not listen too! We expect & need more than that from the NRC.
Gene Stone, ROSE, SCE/CEP Member

Wednesday, October 1, 2014

A Little EcoShaming – Powerful Motivation


For years my wife and I put off that Solar Array for our roof.  We’d checked into it several times, but the cost always seemed too great to pull the trigger.  Then 3/11/11 brought massive destruction and unthinkable death and suffering for the people of Japan.  It was a wakeup call to me, seeing the Fukushima Daiichi plant in a state of complete disarray.  The earthquake and tsunami left them completely crippled and unable to stop hydrogen explosions in the containment, and unprecidented, three separate reactor core meltdowns.  I immediately started looking for how I could learn more about our local nuclear plant.  I found people who had been actively concerned about the safety of nuclear power for more than 35 years.  As I attended activism rallies and NRC meetings, there were a few voices who seemed to be a little off message at first.  That message was, “If you live in Southern California, and you don’t have solar on your rooftop, then you are part of the problem.  You need to get solar!”  As that sunk in over the next few months, I also was reflecting on the fact that shutting down our unsafe plant would create a new void in our local grid.  After all, one seemingly strong argument Southern California Edison kept making was, “Like it or not, you need our nuclear plant to keep your lights on.”  So 14 months after the Japanese disaster and following the surprise SCRAMming of San Onofre, an act that would eventually become a permanent shutdown, we switched on our 36 panel, 11.5 kW system for the first time.
How did we make the numbers work?  We’re lucky to be pretty well off, but very few of us have $35-$70,000 set aside for ecological feel good renovations.  The truth is, in addition to San Onofre activists encouraging us, there was a solar wave hitting our coast.  Our electric bill had been rising alarmingly for years, now accentuated with 4th tier penalty rates.  Having a koi pond and a swimming pool meant no amount of cutting back on air conditioning on our inland home in Fallbrook was putting a dent in our excessive $400/month bill.  The economy is still pretty weak, and an entire generation of children is asking the question, “What’s an interest rate on a savings account?”  I saw the immense rebates being offered that assured a 30% return on our investment, via a federal solar credit, plus $2500 from California.  Viewed from that perspective, solar was a great initial investment and also one we knew would keep paying us back.  Top it off with the knowledge that we’re now part of the climate change solution, rather than continuing to be part of the problem, and the EcoShaming that a few folks planted in my mind was now a blessing in disguise.  We withdrew a big portion of our rainy day money and took the plunge.
In two and a half years, we’ve generated 44 MegaWatt hours, an average of around 48kWh per day.  Last year, we replaced our original pool pump with a high efficiency variable speed run four times as long at 1/4 the flow rate, resulting in ~75% electric savings on that electric pig.  With that electricity freed up, and because we overbuilt our system as much as we could, we hope to buy an electric vehicle soon, and really start helping to solve climate change, and a whole host of other problems oil dependance has caused.  Notice we put the solar first and the EV car next, making sure that we don’t increase electricity demand from power companies who seem unable to ride the solar wave thus far.  Their loss.  It’s my dream that rooftop solar is adopted by every homeowner and every business nationwide.  Power companies will still be needed to maintain the grid.  They will also need to build and operate hydraulic pump storage to meet our nighttime power needs, including charging electric vehicles.  If you research it a little, you’ll see that pump-storage hydro is now excess power is stored for later usage the world over, even at Helms east of Fresno (  I hope our personal story might help encourage you, or someone you know, to ride the solar wave, perhaps with a productive bit of EcoShaming.  Now about that Diablo Canyon…

By Karl Aldinger
Fallbrook, CA

Thursday, August 21, 2014

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.
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 website.  A link to the NRC July and August presentations as well as other documents discussed here are on the following pages.
Donna Gilmore                                                                     
Gene Stone
Residents Organized for a Safe Environment (ROSE)                              
Member, SONGS Community Engagement Panel
High Burnup Fuel
High Burnup Nuclear Fuel −Pushing the Safety Envelope, M. Resnikoff, D. Gilmore, Jan 2014
Letter from Chairman Macfarlane regarding high burnup fuel, May 2, 2014
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
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
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 1998
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
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

Saturday, July 19, 2014



Please write to all the NRC Commissioners in support of the Chairperson MacFarlane idea to update the NRC Regs in a effort to make it clear for all Plant owners and the public on the decommissioning process for nuclear plants and the handling of "HBF" (high burn fuel). Please ask the Commissioners to have the NRC open a old cask with HBF in it to check on condition of this highly dangerous fuel and the cask condition.

Here are the email address:


Both proponents and opponents of nuclear power expect the
Environmental Protection Agency in coming months to relax its rules
restricting radiation emissions from reactors and other nuclear
facilities. EPA officials say they have no such intention, but they
are willing to reconsider the method they use to limit public
exposure—and the public’s level of risk. Comment by August 3, 2014.
The EPA is seeking public input here!documentDetail;D=EPA-HQ-OAR-2013-0689-0001 upper right corner "comment now".

Thanks for your activism.


Gene Stone, ROSE

Thursday, July 17, 2014

Recommendations for temporary storage of Nuclear Waste at San Onofre

How long will SONGS be a Nuclear Waste Dump? That answer is unclear at best. But for sure it will be here longer than anyone wants. So it will be safest and cheapest to store it right the first time! SCE and NRC love’s to say the risks are small, but they don’t like to tell us how BIG a nuclear waste accident can be. Anyone remember Chernobyl and Fukushima?

ROSE advocates relocation of nuclear waste as soon as is feasible from the SONGS site to a less populated area and a less earthquake prone area. Temporary or permanent, although a permanent situation is preferred.
1. Storage of dry cask of any type should be within it’s own building to protect them from the salt air at San Onofre as some other countries do .
2. The best canister we have seen is the V-19 German canister. (The V-19 and 21 canisters are an example of a better made product for our site at San Onofre. It was not meant to be a recommendation to buy, just the type of construction method we may want to look at.)
3. There should be a fuel pool with crane on site to mitigate any accident with any of the dry casks.
4. There should be some type of pressure or radiation monitoring of cask in real time which the V-19 canister has.
5. NRC needs to update it’s procedures to include inspections of decommissioned cask storage areas on a regular and timely basis.
6. DOE needs to set a firm date as to when they will takeover SONGS nuclear waste and exactly how they will do that.

Donna Gilmore talking about dry cask storage for San Onofre Nuclear (Waste) Generating Station

By Gene Stone

Wednesday, July 16, 2014

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.
By Gene Stone, ROSE

Monday, June 16, 2014

Fukushima To San Onofre Sunseting On Nuclear Power

Public Meeting on San Onofre -- Public can speak out about PUC Dysfunction and Sky High Power Rates

Hundreds of secret documents in PUC San Onofre files may halt settlement

Opponents "GAGGED" at San Onofre Public Meeting but PUC Allows Hours of Private Meetings With Utilities

The California Public Utility Commission (CPUC) announced a public meeting regarding the San Onofre proposed settlement, Monday, June 16, 2014, at the Costa Mesa Neighborhood Community Center, 1845 Park Ave., Costa Mesa, CA 92627, 4pm to 7pm. The public is invited to present their views and ask questions

Opponents to the settlement will also hold a press conference at 3:30pm in the patio of the center just prior to the main event, which is considered the kick off to the "World Cup of Bailouts."

Some members of the public have said the CPUC is a "Kangaroo Court" and there are rumors that wild kangaroos will invade the meeting.

The settlement was negotiated by Southern California Edison (SCE) and San Diego Gas & Electric SDG&E) in secret meetings starting in May 2013, with one outside party, TURN (The Utility Reform Network) and one CPUC internal party, the Office of Ratepayer Advocacy (ORA). The final settlement was first revealed to the public and to other parties on March 27, 2014, with the stipulation that it could not be modified in any way.

It provides that SCE receive $3.3 billion for the crippled San Onofre Nuclear Generating Station (SONGS). Proponents have sold this as a $1.4 billion "refund" but in reality, that figure is simply the difference from the original absurd utility request of $4.7 billion and the proposed settlement figure.

Opponents believe ratepayers should receive refund checks of about $250 million.

"The difference in the two sides is stark. The utilities and their followers want ratepayers to provide the net asset value of the base plant PLUS a return of 2.65%, a situation unheard of, even in the distorted world of public utilities," said Ray Lutz, National Coordinator of Citizens Oversight, representing the Coalition to Decommission San Onofre (CDSO) a leading opponent to the bailout settlement. "It is clear that the Commission had this rigged from the beginning, as the meat of the investigation was delayed so long while they fiddled with inconsequential issues."

"The Commission has likely jumped to a conclusion to support the unfair settlement, without allowing the proceedings to complete, and that's why rumors are circulating that wild kangaroos may be invading the meeting," said Charles Langley, a San Diego Gas & Electric ratepayer.

In response to a recent Public Records Request, the CPUC revealed hundreds of secret documents provided to the Commission by technical consultants and never provided to other parties. "It is highly improper to collect all this data and share with the utilities but not with the other parties in the proceeding," said Michael Aguirre, who represents Ruth Henricks, a party in the CPUC San Onofre investigation. "Technical consultants have apparently been working for the Commission and with Commission lawyers for months, generating this treasure trove of secret documents that will likely kill the settlement on the spot. This looks like a way to set up a back-channel with utilities to allow the settlement to be discussed." The consultants were slated to be used for the Phase 3 investigation, which never was started.

The PUC’s pattern of stifling public participation is troubling. Last week a Court issued a decision to stop ratepayers from going to Superior Court to prevent closed door meetings in violation of the Bagley Keene Open Meeting Act.  Ratepayer advocate, Maria Severson, has called on state legislators to draft a bill that ensures the PUC – like every other state agency – has no closed door meetings and complies with the Public Records Act, and if they try to shut the door to the public, the ratepayers can go to Superior Court to stop them.  These “Sunshine” and “Open Meeting” Laws are not being obeyed by the Commission. Last month, PUC President Michael Peevey, a former Southern California  Edison officer, weighed in on the public’s right to participate in PUC proceedings. His position articulated on the attached five-second mp3 recording.

An extremely brief evidentiary hearing was held on May 14, 2014 in CPUC headquarters in San Francisco. At that meeting, SCE President Ron Litzinger admitted to Aguirre's questions that there was nothing in the record that would allow the Commission to evaluate whether the settlement adequately addressed ratepayer's claims.

Now, a public participation meeting is being held to allow the parties to make statements and to allow the public to ask questions. "We had to struggle to get equal time," Lutz said. "But now they are trying to control what we can say as well."

At first, they gave opponents no time at all. Then, proponents 40 minutes and opponents only 20 minutes. When the CDSO said they planned to make a Powerpoint presentation and needed more time, perhaps 30 minutes, the ALJ implemented a 'gag' order, disallowing a powerpoint presentation, and requiring all documents to be pre-approved by the ALJs (Administative Law Judges) before it could be presented.

ALJ Melanie Darling said "No projectors, power points, or other argumentative aids will be permitted inside the meeting." and refused to provide a webcast of the meeting.

In response, the CDSO reasserted their request for 30 minutes during the meeting, with the following email, sent to all parties, bringing up the fact that the proponents of the settlement have already met with the Commission in ex parte meetings, including a personal meeting with Florio, the primary Commissioner of the proceeding, for more than two hours.

Dear ALJ Darling:

On April 14, 2014, Southern California Edison and other proponents (SDG&E, TURN, ORA, FOE) of the proposed settlement met in a number of private ex parte meetings. The notice of these meetings is attached. These parties met for 45 minutes with representatives for Commissioner Peevey, 30 minutes with advisors to Commissioner Picker, 30 minutes with advisors to, and with Commissioner Florio, and 30 minutes with Advisors to Commissioner Peterman. During these meetings, they presented their point of view to Commissioner Florio and advisors of the other Commissioners.

There were also other ex parte meetings with the Commission by the proponents of the settlement.

According to the rules of practice and procedure (8.2 and 8.3), such meetings are allowed in ratemaking proceedings with advisors to Commissioners without prior notice. Prior notice was provided for the meeting with Commissioner Florio. This is a ratemaking proceeding. Also, including in those rules, other parties are allowed to request equal time in similar ex parte meetings.

The CDSO hereby makes such a request. We request that we be allowed time at this public meeting to make our presentation to those commissioners and advisors who are present at the meeting. We will not be constrained in what we choose to present to the commissioners. We plan to bring a power point projector and screen so we may effectively communicate our position, since I'm sure the proponents were not constrained in their private presentations, and we will be distributing any material we see fit during our presentation to the Commissioners.

I hereby reassert our request for 30 minutes during this meeting for the opponents to the settlement to use as they see fit.

--Raymond Lutz 

"We have yet to hear back from ALJ Darling, but we are going to assert our rights to make our case as strongly as we can, even though it's clear that this regulatory agency is fully captured by the utilities," Lutz said. 

CONTACT:  Ray Lutz    619-820-5321  / raylutz at citizensoversight dot org

EVENT 1: Orange County Press Conference
WHERE:   Costa Mesa Neighborhood Community Center, 1845 Park Ave., Costa Mesa, CA 92627
WHEN:     (just prior to the public meeting at 4pm)

EVENT 2: CPUC Public Meeting
WHERE:   Costa Mesa Neighborhood Community Center, 1845 Park Ave., Costa Mesa, CA 92627
WHEN:     4-7 pm, Monday, June 16, 2014
NOTE:       Rumors are that wild kangaroos will be invading this "kangaroo court"

Fukushima To San Onofre Sunseting On Nuclear Power
Fukushima To San Onofre Sunseting On Nuclear Power