#CSDSO II Directions & Live Stream

The Community Symposium on Decommissioning San Onofre 2, with Dr Tom English, advisor to President Jimmy Carter on high-level nuclear waste and Joe Moross head Nuclear tech at Safecast, 3- 5:30 PM in San Clemente, free and open to the public, if you would like to attend remotely CLICK HERE FOR LIVESTREAM! 

#CSDSO II Real facts about what’s in the “cans” and what could come out of them.

#SaveTrestles; Thick Casks Not Thin Cans; Hot Cell Onsite For Damaged Can Repair & Real Time Public Third Party Radiation Monitoring #CSDSO

To Attend #CSDSO II In Person CLICK HERE FOR DIRECTIONS
 Address: 1201 Puerta Del Sol, San Clemente, CA 92673

Community Symposium On Decommissioning San Onofre II

2nd Nuclear Waste Symposium/Radiation Monitoring

ROSE, invites you to attend our upcoming 2nd event on Nuclear Waste with Tom English and Joe Moross. Real facts about what’s in the “cans” and what could come out of them. There will also be a discussion about Independent Real-Time Radiation Monitoring at San Onofre Nuclear Waste site with Joe Moross from Safecast on Oct 18, 2018, at 1201 Puerta Del Sol Suite 100 San Clemente, California 92673, 3 to 5:30 pm.  We will also discuss the higher radiation readings Darin and I got on our last visit to San Onofre Nuclear Waste site.

We plan to stay on these two topics because of the time factor. Also, we want to have lots of time for a real back and forth discussion on both topics, so bring your questions. They will be answered with the best information we have.

SCE was invited to participate in this symposium, but they declined because they do not want to come out and speak in public until sometime in November when the NRC will hold a meeting with their findings from the September 10 inspection. Joe Moross from Safecast is only here until late October which is why we are going ahead with this symposium.

Sincerely,

Gene Stone
Residents Organized For a Safe Environment (ROSE)
On twitter @gene_stone
http://residentsorganizedforasafeenvironment.wordpress.com/

Watch The 1st Community Symposium On Decommissioning San Onofre Streamed Oct 19, 2013 

ACTION ALERT! Support Real Time Public Radiation Monitoring

Gene Stone & Darin R. McClure on the top of the Nuke Dump with Our bGeigies 

Dear Readers, here is our updated text for this extremely urgent Residents Organized for a Safe Environment action alert. Hope you have time to let the CEP here from you today. Please share with your friends. If we want to make this work every email counts. Thank you in advance.

CLICK HERE FOR >> Independent Real Time Radiation Monitoring at San Onofre

Below is an action alert that ROSE is sending to some members of the CEP. I hope you may want to join us in this action for our community. We need 1000 people to send an email to the CEP ASAP!  If you are willing please send them a note, copy and paste or write your own text.

Then send it to these email addresses: david.victor@ucsd.edu,
manuel.camargo@sce.com, Tom.Palmisano@sce.com, danstetson@me.com,
garry@coastkeeper.org, marnimagda@gmail.com, genston@sbcglobal.net,

The subject line should read "Independent Rad Monitoring/Symposium on Radiation"

Community Engagement Panel members,

I am asking each of you as CEP members to support and to take action ASAP along with SCE for a public CEP meeting on "Independent Public Real-time Radiation Monitoring" for  San Onofre Nuclear Waste Dump, and a second CEP meeting for an "Educational Symposium on Radiation" with "independent" radiation experts along with experts from SCE and the NRC. This a necessary step for all the stakeholders to understand what is in and what could come out of these cans now or in the future. Thank you for your consideration of these two programs for the safety of our community.

Sincerely,

Sincerely, Gene Stone
Residents Organized For a Safe Environment (ROSE)
On twitter @gene_stone
http://residentsorganizedforasafeenvironment.wordpress.com/
http://partofthearth.blogspot.com/

"The secret of change is to focus all of your energy not on fighting the old, but on building the new." Socrates

THE POWER TO CHANGE

“If the ideas that rule our culture are stopping us from saving ourselves, then it is within our power to change those ideas.”  Naomi Klein

We humans are adept at fighting for what we are against.  Can we fight as hard for what we are for?  Socrates reminds us “The secret of change is to focus all of your energy not on fighting the old, but on building the new.”

Many people, including ninety seven percent of climate scientists, agree that climate warming trends over the past century are very likely due to human activities.  Some of the results of global warming, according to “Global Climate Change: Vital Signs of the Planet” are: global sea levels are rising, the Greenland and Antarctic ice sheets have decreased in mass and the thickness of the Arctic Sea ice has declined rapidly over the last several decades. Glaciers are retreating almost everywhere around the world.  The amount of carbon dioxide absorbed in the upper layer of the oceans is increasing by approximately 2 billion tons per year.  James Hansen, adjunct professor of the Department of Earth and Environmental Sciences at Columbia University, believes that carbon pollution is set to end the era of stable climate.

Solar for Seals project 2014

With these facts pointing to the devastation of life on Earth as we know it, what actions are we willing to take to assure the continuation of life on our beautiful planet?  We must join together now to do what we can do to make the necessary changes to reverse these trends.  Human beings have the capacity to learn and adapt quickly.  We are able to change old thinking and patterns of behavior and create change in positive ways.  There are political and economic forces that sometimes stand in the way of progress, but we do not have to allow these forces to prevent us from doing what we must.  Many individuals are moving forward with ideas to save our planet and creating supportive communities to make effective change.

One of the ways to avert this climate change crisis is to decrease our reliance on fossil fuels.  To this end, it is possible to switch to renewable energy.  People all over the world are creating wind farms, working with tidal power, wave power, solar power, hydroelectricity, and geothermal power.  Our organization, Residents Organized for a Safe Environment (ROSE) and Planet Earth Solar (PES) of San Clemente, CA. have successfully completed two solar projects: Oso Lake Boy Scout Camp Solar project, 2013 and the Pacific Marine Mammal Center Laguna Beach “Solar for Seals”, 2014.  ROSE and PES are currently working on a third solar project, “Solar for Non Profits” project for 2015.  We are committed to bringing people together in a community effort to provide solar power to non -profit organizations.  These organizations are already helping our social and environmental communities in various ways.  By assisting them with conversion to solar power, this adds another layer of depth to their commitment to bettering our world.

Residents Organized for a Safe Environment (ROSE) and Planet Earth Solar (PES) have selected The Center for Spiritual Living Capistrano Valley (CSLCV) in San Clemente, CA. for our 3rd Solar Project 2015.  A 60 kW system consisting of 197 solar panels to provide clean, sustainable and environmentally safe energy will be built for the Center’s facility. As PES and ROSE and CSLCV donate our time and labor for this project, please join us in taking this environmental action as a citizen of the world. Be a part of the solution for our world’s clean and renewable energy future by donating today. The total cost of this project will be $135,000.00. The money the Center saves on energy costs will go to community projects. Your donation to this solar project will be greatly appreciated.

To help us, please use our Razoo fundraising site at:  https://www.razoo.com/story/Center-For-Spiritual-Living-Capistrano-Valley for your “tax deductible” donation.

“We are all flowers in the Great Spirit’s garden. We share a common root, and the root is Mother Earth.” Hopi Prophecy 

“The environment isn’t over here. The environment isn’t over there. You are the environment.” Chief Oren Lyons

It will take all of us working together now if we are to make a positive change for future generations.

Love, Gene and Joyce

ROSE and Planet Earth Solar 3rd Solar project 2015. Join with us.

Hello everyone,

Thinking back, we have not forgotten your kind help with our 2014 “Solar for Seals” project for Pacific Marine Mammal Center of Laguna Beach where we put 87 solar panels on their small roof.  It went so well we looked for a much bigger roof for 2015, and we found it.

We are happy to announce that Residents Organized for a Safe Environment (ROSE) and Planet Earth Solar has selected The Center for Spiritual Living Capistrano Valley (CSLCV) in San Clemente, CA. for our 3rd Solar Project 2015.  A 60 kW system consisting of 197 solar panels to provide clean, sustainable and environmentally safe energy will be built for the Center’s facility. As Planet Earth Solar and ROSE and CSLCV donate our time and labor for this project, please join us in taking this environmental action as a citizen of the world. Be a part of the solution for our world’s clean and renewable energy future by donating today. The total cost of this project will be $135,000.00, saving the Center over $150,000.00 over other bids. You may donate to this Solar project in one of two ways.

1. Make your “tax deductible” check payable to “Center for Spiritual Living Capistrano Valley” please mail check to Gene Stone 1203 Via Presa San Clemente 92672, so I can make sure to get your check into the Solar account at the center. Please note in the bottom left memo area of your check “Rose Solar project.” The check payment method will insure that 100% of your donation will go to the solar project, using the fundraising site we will lose 5% of your donation to Razoo.

2. Or use our Razoo funding raising site at for you “tax deductible” donation:

https://www.razoo.com/story/Center-For-Spiritual-Living-Capistrano-Valley

The Center’s Environmental statement:

“The Centers for Spiritual Living are committed to our vision of a world that works for everyone– a world in which resources are valued, cared for, and grown, and where there is generous and continuous sharing of these resources. A big part of that world is sustainable safe energy. At the Center for Spiritual Living Capistrano Valley in San Clemente California, we are contributing to this vision by installing a solar system to provide clean, sustainable and environmentally safe energy for our Center’s facility. We know that other spiritually minded people and organizations will want join us in taking this action for the betterment of all future generations. Not only will this new solar energy system provide our Center with safe sustainable energy, the cost savings recognized by lower energy bills will allow the Center to pursue numerous projects that will benefit our community.”

P.S. Please remember that it was this Center in San Clemente that gave ROSE such a great deal and made it so easy to do the Nuclear Symposium in October 2013.  They are willing and excited to help us with future events. We could not have done it with them.

The Center for Spiritual Living Capistrano Valley in San Clemente California, Planet Earth Solar and Residents Organized for a Safe Environment (ROSE) thank you for your kind and generous donation towards our solar project.
With your action today, you join us in being part of a clean energy future and take a step towards helping manage climate change.  You are now part of the growing number of people around the world who are “being” the change. We are honored and happy to walk down this path with you.

Sincerely,

Gene Stone
Residents Organized For a Safe Environment (ROSE)

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 (http://en.wikipedia.org/wiki/List_of_pumped-storage_hydroelectric_power_stations).  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

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.                                          

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

Letter from Chairman Macfarlane regarding high burnup fuel, May 2, 2014http://sanonofresafety.files.wordpress.com/2013/06/05-02-14-ltr-to-priscilla-star-fm-chairman-macfarlane.pdf

Response from Donna Gilmore to NRC regarding May 2, 2014 request for NRC high burnup fuel technical basis, June 25, 2014

http://sanonofresafety.files.wordpress.com/2013/06/responsetonrc-hbf-recommendations2014dg.pdf

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)

http://www.nrc.gov/waste/spent-fuel-storage/public-involvement.html

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

https://sanonofresafety.files.wordpress.com/2013/06/8-5-14-scc-rirp-nrc-presentation.pdf

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).

http://www.siempelkamp.com/fileadmin/media/Englisch/Nukleartechnik/produkte/CASTOR_A_high_tech_Product_made_of_ductile_Cast_Iron.pdf

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

https://canteach.candu.org/Content%20Library/NJC-1-2-11.pdf

BAM test results for CASTOR transport containers

http://www.tes.bam.de/en/umschliessungen/behaelter_radioaktive_stoffe/behaelterpruefungen/index.htm#castor

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)

http://www.bulatom-bg.org/files/conferences/dokladi2010/Section%203/Report_Thomas.pdf

Areva TN Series Casks (forged steel cask technology)

TN-24 NRC Certificate of Compliance and Safety Analysis Report, November 4, 1993

http://pbadupws.nrc.gov/docs/ML0330/ML033020128.pdf

AREVA Innovation in the Design of the Used Fuel Storage System, CRIEPI Tokyo, November 15-17, 2010 (includes information on TN 24 casks)

http://criepi.denken.or.jp/result/event/seminar/2010/issf/pdf/4-1_powerpoint.pdf

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)

http://pbadupws.nrc.gov/docs/ML1329/ML13290A176.pdf

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.

https://sanonofresafety.files.wordpress.com/2013/06/2014-05-15-comment-letter-to-nrc-re-nuhoms-cask-approval-corrected-2014-05-27.pdf

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

http://pbadupws.nrc.gov/docs/ML1204/ML12046A013.pdf

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

http://seuc.senate.ca.gov/sites/seuc.senate.ca.gov/files/08-12-14%20Edison%20presentation.pdf

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

https://sanonofresafety.files.wordpress.com/2011/11/lettertodavidvictor2014-07-17dg.pdf

David Victor testimony to NRC Commissioners, July 15, 2014

http://www.nrc.gov/reading-rm/doc-collections/commission/slides/2014/20140715/victor-20140715.pdf

Additional references at SanOnofreSafety.org

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 

http://www.youtube.com/watch?v=xLr0WR5oSjU

By Gene Stone

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

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.

Download MR Power Point for May 6, 2014