Holtec UMAX lid with lower inlet air vents and upper (round) outlet air vent.

The Holtec nuclear waste dry storage system (Hi-STORM UMAX) is a lemon and is putting California’s safety, economy and security at great risk. It must be recalled. The Nuclear Regulatory Commission (NRC), Southern California Edison, California Coastal Commission (CCC), and California Public Utilities Commission (CPUC) must reject this system on both safety and financial grounds.  They cannot make lemonade out of this lemon. 

Congress must stop focusing on where to transport this unsafely stored nuclear waste and mandate the NRC do their job of protecting our safety.  Pending federal legislation  removes current storage and transport nuclear waste safety requirements, encouraging systems like this to be built, such as a similar one proposed by Holtec in New Mexico (pending state approval and removal of state and federal environmental and other rights).

San Onofre (SONGS) has 89 times the Cesium-137 released from the 1986 Chernobyl nuclear disaster. R. Alvarez

Since Holtec started loading the San Onofre highly radioactive spent nuclear fuel waste into Holtec thin-wall canisters (only 5/8″ thick), there have been numerous Holtec engineering failures that have not and likely cannot be fixed.  Each thin-wall stainless steel canister holds roughly a Chernobyl nuclear disaster. The NRC doesn’t even require pressure monitoring or pressure relief valves in these pressure vessels.

The NRC is investigating numerous Holtec failures at San Onofre, but has yet to issue a final investigation of these engineering failures.  If it wasn’t for whistleblowers, we would not know about any of these serious safety problems that are still unresolved — and likely cannot be solved with this defective Holtec system.

Instead of requiring Holtec take their defective system back, as they likely can do under their limited manufacturing defect warranty, Edison plans to continue loading canisters in order to destroy the spent fuel pools as soon as possible.  The pools cost them millions in overhead costs every year.

Edison also wants to access the over $4 billion in ratepayer Decommission Trust Funds in order to destroy the pools and the rest of the reactor facility (except for the dry storage systems), yet have no other method to replace failing canisters.

Decommission Trust Funds would be better spent replacing the defective thin-wall canister systems with proven thick-wall cask technology used throughout the world. Thick-wall cask systems are 10″ to 19.75″ thick and can be inspected, maintained, repaired and monitored to prevent radioactive leaks and hydrogen gas explosions. They meet Nuclear Waste Technical Review Board (NWTRB) December 2017 recommendations to the United States Congress and the Secretary of Energy, regarding Management and Disposal Of US Department Of Energy Spent Nuclear Fuel, Executive Summary, page 7 – 9. They also meet Nuclear Waste Policy Act of 1982 safety requirements.

Instead, Holtec and Edison are advocating for H.R. 3053 (pending in the US Senate) and other bills that would remove critical safety requirements for both storage and transport and remove a number of federal and state rights, including transparency, input and oversight. The House already approved this bill, under the misguided assumption they can trust the NRC to protect our safety. The bill would allow the DOE to take title to the waste at the current San Onofre site, eliminating Edison’s liability and responsibility for this mess they created.  All funding for waste management is currently mandatory.  This unfunded bill makes funding discretionary with Congress.

Edison plans to load a total of 73 Holtec canisters at the beach on Camp Pendleton.  There are 29 Holtec canisters already loaded with nuclear waste that are likely already cracking from the defective loading system. The NRC states once a crack starts in stainless steel it can grow through the wall in 16 years.  In hotter canisters, cracks can grow faster.  The NRC assumption that cracking will not start for at least 30 years ignores these canisters may already be cracked from the Holtec loading system (pit corrosion cracking by mechanical means) and the EPRI evaluation of a two-year old Diablo Canyon canister that showed it had a low enough temperature for corrosive salt to dissolve on the canister, one of the triggers for crack initiation.  The NRC is planning to “investigate” this issue, eventually.

HOLTEC FAILURE #1: Canister #29 almost dropped 18 feet due to a defective loading system design. Edison hid this information from the public. A whistleblower, David Fritch, spoke at an Edison public meeting about this once he saw Edison was hiding this from the public.  Fritch, Edison and the NRC admit this canister could have fallen 18 feet into the hole. The canister was hanging by a 1/4″ on a canister [MPC] Guide ring ledge located about 4 feet down from the top of the hole. This is a bad engineering design that cannot be fixed with training and procedures. The NRC admitted on the November 8, 2018 webinar that Holtec knew about the bad guide ring design, but did not fix this problem before delivering the system to San Onofre.

• David Fritch video statements regarding the almost canister drop, Community Engagement Panel (CEP)  meeting, August 10, 2018. Includes Edison and others statements.
• David Fritch transcript of statement at CEP meeting.
• NRC Special Inspection Activities Regarding Cask Loading Misalignment webpage

Edison temporarily stopped loading canisters, but downplayed the risk.  Edison did not shared these facts with the public:

• If a canister drops more than 11 inches inside a transfer cask, contents must be inspected (ML003711865), page 3-10 Accidental Drop).
• Each canister is approximately 49- tons, according to the NRC August 24, 2018 San Onofre Inspection Report (ML18200A400). The San Onofre Holtec canister is not in a transfer cask when it’s lowered in the storage hole, so even an over 11 inch canister drop has not been analyzed, as stated by the NRC: “It was estimated that the canister could have experienced an approximately 17-18 foot drop into the storage vault if the canister had slipped off the metal flange [MPC Guide] or if the metal flange failed. This load drop accident is not a condition analyzed in the dry fuel storage system’s Final Safety Analysis Report (FSAR).”  NRC Inspection Charter to Evaluate the Near-Miss Load Drop Event at San Onofre Nuclear Generating Station, August 17, 2018 (ML18229A203)

HOLTEC FAILURE #2: Canister #30 was in the queue for moving to a storage hole, but is now stuck in limbo in a transfer cask in the Unit 3 fuel handling facility. The NRC and Edison refuse to tell us how they are keeping this canister from overheating.  Canisters require either air cooling or water cooling.  Transfer casks are not designed to cool and store these hot canisters that are 200 to 300 degrees Celsius (just under 30kW).  The transfer casks only function is to transfer a canister from the pool to a Holtec storage hole (vault).

There are already 51 aging San Onofre thin-wall canisters previously loaded from another vendor that are up to 15 years old.

None of these or any other welded thin-wall canisters have ever been inspected for cracks, because they cannot be inspected for cracks or repaired once loaded with highly radioactive nuclear waste. The nuclear industry and government have spent millions of dollars and wasted limited resources over the last 27 years to figure this out, yet still no solutions.  It’s a bad design they need to be abandoned before it’s too late.

Even Holtec President, Kris Singh, admits it isn’t practical to repair these canisters, even if you could find the cracks and a way to repair them.   Singh statement transcript.

At the October 11, 2018 NRC Commissioner briefing, an NRC employee admitted to the Commissioners they currently are still trying to figure out how to identify surface defects and how to characterize them in the canisters.  Commissioner David A. Wright asked NRC engineer, Christian Araguas, the status of industry efforts to find a way to repair, mitigate and inspect [the outside] of these canisters. Araguas said ” I think we have confidence in the industry and the direction they’re going to be able to inspect these in the future.”  After over 27 years of trying, it’s unclear why anyone would have confidence in the ability to inspect, let alone repair.  Instead, the NRC approves elimination of pools once all fuel is in dry storage — eliminating the only method to replace cracking canisters.  Instead they should mandate nuclear waste containers that are not vulnerable to these cracking risks and that can be inspected (inside and out), maintained, repaired and monitored to prevent leaks and explosions.

If fresh water enters the canister through cracks, the canister can go critical, per this NRC document ML13032A008. At the November 8, 2018 webinar on these issues, the NRC staff is apparently not aware of this.

HOLTEC FAILURE #3: Holtec loaded fuel in four canisters with defective basket shims. Shims are required to prevent criticality, damage and overheating of the fuel assemblies. Edison said they cannot unload the nuclear fuel back into the pool because the fuel is loaded too hot to return to the pool — even though the ability to unload fuel back into the pool is a requirement of Condition 8 of their NRC license. The NRC is ignoring these issues and pretending Edison can return fuel to the pool.

• Loose Holtec bolts NRC email correspondence with Donna Gilmore as of March 27, 2018
• Southern California Edison (Tom Palmisano) admitted no nuclear facility has ever unloaded fuel assemblies from canisters back into the spent fuel pools, and they have no current method to do this (March 22, 2018 Community Engagement Panel meeting) video.
• More details on SanOnofreSafety.org home page.

UMAX Holtec Shield Ring in the canister storage hole is part of an “MPC Guide” system designed to guide the nuclear waste canister into the hole. Instead, the Gussets guide the canister on to the lip of the guide ring. That lip should not be there. Works cannot see what they are loading. Also, the sides of the canisters bump and scrape against the sides of the metal guide ring as they are lowered into each hole, resulting in pit corrosion cracking by mechanical means. Once cracks start, they continue to grow through the canister walls. https://www.nrc.gov/reactors/operating/ops-experience/songs-spec-insp-activities-cask-loading-misalignment.html

HOLTEC FAILURE #4: Holtec loading system caused damage in canisters walls — 29 canisters loaded so far.  Holtec and Edison knew each canister loaded was making metal to metal contact with the metal canister guide ring, yet they continued loading.  There is only 1/2″ clearance between the canister and the guide ring. Each canister wobbles as it is loaded into each hole due to the inferior engineering design.

The NRC knows even microscopic scratches on the thin ~2nm (nanometres) layer of chromium oxide film on these stainless steel canisters can start the cracking process. Why would they consider allowing Edison to continue loading and cracking more canisters?  Cracking canisters cannot be safely stored or transported. And the high burnup fuel inside the canisters must be inspected for damage before transporting even short distances.

• Frequently asked Questions and Answers Regarding the SONGS Special Inspection, NRC
• NUREG-2224 High Burnup Storage and Transport Draft Comments from Donna Gilmore, Docket NRC-2018-0066, September 24, 2018

Recommendations

The Holtec dry storage system is a lemon and must be recalled.  Edison finally admitted their replacement steam generators were lemons, but waited until after they leaked radiation into Southern California.  They need to declare this Holtec system a lemon before these containers leak and explode in Southern California.

• The NRC should revoke the license of this and other Holtec nuclear waste storage and transport systems.  Holtec has repeatedly demonstrated they are not a qualified vendor.  More Holtec Nuclear Waste issues here.
• Edison should stop loading canisters with fuel and return this system to Holtec. They should issue Requests for Proposals (RFPs) that meet NWTRB and NWPA safety requirements for both storage and transport. The RFP should include a system for replacing all existing thin-wall canisters at San Onofre with thick-wall transportable casks.  This must be done before these canisters start leaking and exploding.
• The Governor should declare a state of emergency. The State of California should revoke San Onofre state permits until this is done. They should create a multi-agency committee to address these issues and facilitate the development of an expedited solution to this critical problem before Holtec and Edison destroy our economy, security, safety and future.
• The CPUC should stop funding this Holtec lemon and any further activities at San Onofre until this is done.

Congress and the President should mandate the NRC enforce safety standards as outlined above and force the NRC to stop misleading them about the safety of the systems they approve.  Transporting these thin-wall cracking canisters to another location will no more solve our nuclear waste problems than rearranging the deck chairs on the Titanic would stop it from sinking. 

Donna Gilmore
SanOnofreSafety.org