San Onofre Safety

Sign Petition to recall thin-wall nuclear fuel waste storage systems — now!

Recall and replace defective thin-wall nuclear fuel waste storage systems with proven thick-wall transportable storage casks.

Holtec and other thin-wall nuclear fuel waste canister storage systems are lemons. 

Solution to prevent major radiological releases

• STEP ONE: Thin-wall canisters (only 1/2″ to 5/8″ thick) must be recalled, and the nuclear waste repackaged into thick-wall transportable storage casks (10″ to 19.75″ thick) that meet ASME N3 Nuclear Pressure Vessel storage and transport certification.

Only proven thick-wall casks can be inspected, repaired, maintained and monitored in a manner to prevent major radioactive leaks and hydrogen gas explosions. 

• STEP TWO: Thick-wall casks must be moved to a safer location away from coastal and flooding risks. Store thick-wall casks in hardened buildings for additional security and environmental protection.

• Must do STEP ONE BEFORE STEP TWO: Nuclear fuel waste must be transfered into thick-wall casks BEFORE it can be transport to another location.  Cracking thin-wall canisters with uninspected brittle fuel rods are not safe for storage or transport.

• Thin-wall nuclear waste canister storage systems pose a clear and imminent danger to the health and lives of the citizens, and pose potential financial and ecological disaster for the state of California, and beyond. Action is needed now.

NRC and Southern California Edison engineers admit it’s impossible to inspect nuclear fuel waste canisters for cracks per ASME Nuclear Pressure Vessel standards

You cannot put lipstick on a pig, yet both the NRC and Southern California Edison refuse to admit Holtec and other thin-wall canister systems are lemons and must be recalled and replaced. 

The NRC is not protecting our safety. Instead, they give numerous exemptions to American Society of Mechanical Engineers Standards, including ASME N3 Nuclear Pressure Vessel storage and transport certification requirements.

Only thick-wall cask systems can meet ASME N3 Nuclear Pressure Vessel storage and transport certification requirements. 

Switzerland is an example of a country that requires dry storage systems that meet or exceeds ASME N3 standards.

Switzerland and other countries store thick-wall casks in hardened passively cooled building for additional environmental and security protection. 

The Swiss also have a dry transfer system (hot cell) facility, so they can transfer fuel from one cask to another, inspect inside casks and maintain casks and contents.

The U.S. has no large hot cells designed to do this. There is no U.S. plan in place to prevent or stop major radioactive releases from the canisters.

Handouts and U.S. Dry Storage Inventory

• Cracking Canister Problems, Recommendations, and Nuclear Storage Myths
• U.S Dry Cask Inventory, Sorted by State (2 pages) – includes age of canisters
• NRC admits San Onofre Holtec nuclear waste canisters are all damaged, 11/29/2018
• More Handouts

Legislation

Congress should not allow the NRC to give exemptions to ASME and other safety regulations and laws. Instead, proposed federal legislation promising to move the nuclear waste somewhere else, creates more problems than it solves.

Bills such as 2019 S.1234 co-sponsored by U.S. Senator Diane Feinstein (D-CA), and 2017 H.R.3053 co-sponsored by U.S. Rep. John Shimkus (R-IL) and a similar House bill 2019 S.2699 co-sponsored by U.S. Rep. McNerney, Jerry [D-CA-9] and Senate bill 2019 S.2917 co-sponsored by U.S. Senator John Barrasso (R-WY) will:

• Remove critical safety requirements from the Nuclear Waste Policy Act (NWPA).
• Allow title transfer to the federal government at existing nuclear waste locations, such as San Onofre.  Current federal nuclear waste sites, such as Hanford and Savannah River have for decades leaked radiation into the environment, including into fresh water sources.
• Current mandatory funding from the Treasury’s Judgment Fund for nuclear fuel waste storage will become discretionary with Congress, according to Congressional Budget Office analysis of H.R.3053.  We’ll be at the mercy of Congress for adequate funding of nuclear waste.
• Learn more about unresolved storage and transport issues that will be made worse by this legislation: Holtec Nuclear Waste webpage.

Unresolved Problems at San Onofre

Edison plans to store a total of 136 thin-wall canisters at San Onofre — indefinitely

• 73 Holtec thin wall canisters are loaded with highly radioactive fuel waste and store in vented holes near the beach. There are no drains in these holes. Both Edison and the NRC admit every new Holtec canister is damaged as it’s lowered into each storage hole — the entire length of the thin canister wall.  The NRC is ignoring this and other critical safety issues.
• 51 aging NUHOMS thin-wall canisters are already loaded with radioactive waste. Fifty (50) canisters are filled with highly radioactive fuel waste and one canister with other highly radioactive waste called Greater Than Class C (GTCC) highy radioactive waste.
• Canister loading started in 2003. The NRC refuses to provide the radiation levels from the rooftop outlet air vents where each NUHOMS aging canister is stored. The State of California Radiological Unit is aware of this, but refuses to investigate.  What are they hiding?
• 12 additional NUHOMS canisters will be filled with GTCC radioactive waste.

The inferior Holtec engineering system lacks a precision canister downloading system, resulting in significant damage to the walls of all the Holtec canisters as they are downloaded into storage holes. There is no proven method to prevent or repair the damage.  These canisters cannot be inspected (inside or out), maintained or monitored to prevent major radioactive releases. The NRC approved this fatally flawed design. Learn more about canister storage and transport problems on this webpage and on the Holtec Nuclear Waste webpage.

March 25, 2019 NRC Webinar 

The Nuclear Regulatory Commission (NRC) conducted a virtual public meeting/webinar on Fuel Loading at San Onofre to discuss enforcement decisions related to an almost drop of a Holtec nuclear waste canister over 18 feet (see whistleblower video).

However, the NRC is ignoring the problem that the Holtec system lacks a precision downloading system, resulting in significant damage to the walls of all the canisters as they are downloaded into storage holes. The system is a lemon and must be recalled.

• Presentation was NRC on final enforcement decision regarding findings of a special inspection conducted at the plant following an Aug. 3 almost drop of a canister over 18 feet. See NRC inspection report.
• NRC discussed preliminary findings and observations of recent inspections to verify adequacy of corrective actions at the plant.
• Many of the public comments were screened out, so this webinar format is unacceptablek, but the NRC refuses to stop using it.

The Nuclear Regulatory Commission continues to allow  highly radioactive nuclear fuel waste to be unsafely stored in thin-wall canisters, with no plan to prevent or stop leaks and explosions. This is a nationwide problem with all thin-wall canisters.

Each canister holds about the amount of radioactivity as released from the 1986 Chernobyl nuclear disaster, admits Southern California Edison.

The NRC admits the walls of all 29 San Onofre thin-wall Holtec canisters already stored are likely damaged (gouged and scraped) due to the poorly engineered Holtec downloading system that lacks precision to avoid metal to metal contact between the walls of each 54-ton steel canister and a steel 2″ thick MPC Guide ring inside each storage hole. There is only 1/4″ clearance between the canister and the MPC Guide. A 0.50″ diameter difference between the canister and the MPC Guide, results in unavoidable scraping and banging of the canister walls against the MPC Guide. HI-STORM UMAX System FSAR Revision 3 (ML16193A339), June 29, 2016 (page 3-46).

This is the same HI-STORM UMAX dry storage system proposed by Holtec for consolidated interim storage (CIS) in New Mexico. These thin-wall canisters are not safe to store, let alone transport to New Mexico or elsewhere.

Learn more about Holtec systems and transport issues here.

Related News

• NRC meeting on defective San Onofre Holtec nuclear waste storage system, January 24, 2019
• NRC ASLB Holtec New Mexico CIS Nuclear Waste meeting, January 23-24, 2019
• NRC ignores Holtec design problem that gouges walls of all San Onofre nuclear waste canisters, January 9, 2019
• NRC admits San Onofre Holtec nuclear waste canisters are all damaged, November 29, 2018
• San Onofre defective Holtec nuclear waste storage system must be recalled, November 8, 2018

Canisters cannot be inspected or repaired admits NRC and Holtec canister vendor 

NRC Commissioner David A. Wright asked NRC engineer Christian Araguas the status of ability to inspect and repair canister cracks. Araguas admitted they have no ability to inspect canisters for cracks. They have no ability to “detect the flaws” or “understand and characterize the flaws”. He did not respond to Commissioner’s question regarding repair technology.  Transcript of NRC Commissioners October 11, 2018 meeting: Strategic Programmatic Overview of the decommissioning and Low-Level Waste and Spent Fuel Storage and Transportation Business Lines (ML18295A698) (page 104 and 105).  NRC Commissioner David Wright video.

Holtec President Kris Singh admits even a microscopic through-wall crack will release millions of curies of radionuclides into the environment and it’s not feasible to repair cracks even if you could find them.  Kris Singh video      Transcript of Singh video

No pressure monitoring or pressure relief valves in thin-wall canisters

Thin-wall canisters are pressure vessels, but the NRC doesn’t require pressure monitoring or pressure relief valves, making them vulnerable to hydrogen gas and other types of explosions.

The NRC allow these and other exemptions to American Society of Mechanical Engineers (ASME) pressure vessel safety standards. ASME standards should be enforced, not exempted. The NRC should require ASME N3 container certification for both storage and transport containers.  Only thick-wall casks (such as the Castor) meet ASME N3 requirements.  See ASME reference for ductile cast iron casks.

Inventory of  U.S. Spent Nuclear Fuel Containers

• Over 3000 nuclear fuel waste dry storage containers are located nationwide.
• Most of these are unsafe thin-wall canisters.
• Hundreds more added every year.
• U.S Dry Cask Inventory, sorted by state (2 pages)

Urgent action is needed to replace unsafe thin-wall nuclear waste canisters with proven thick-wall casks.  

• Contact your Senators, other elected officials and those who may have influence.
• Tell them they need to advocate for proven thick-wall metal casks that can be maintained and monitored to prevent leaks and explosions — not unsafe thin-wall nuclear waste canisters.
• The NRC must enforce regulations. Instead, they allow numerous safety exemptions to ASME pressure vessel safety standards.
• It is urgent the President and Congress stop the Nuclear Regulatory Commission (NRC) from allowing thin-wall cracking nuclear waste storage canisters. They cannot be inspected for cracks, let alone repaired. The NRC falsely assumes nothing will go wrong.
• Replace thin-wall canisters with proven thick-wall casks that can be inspected, maintained and monitored to prevent major leaks and explosions.No one would buy a car that doesn’t meet those basic safety requirements, yet the NRC allows this to store highly radioactive nuclear fuel waste. 
• Each canister holds roughly a Chernobyl nuclear disaster. If we don’t get this right, nothing else will matter.

Share handouts with elected officials and others

• Action Needed to Require Safest Nuclear Waste Storage, October 21, 2018 
• San Onofre Nuclear Waste Dump — Problems and Solutions, October 24, 2018
• Urgent San Onofre Nuclear Waste Storage Problems and Solutions, October 8, 2018

Get educated. Get involved. Contact us to become more involved.

Transporting cracking thin canisters across the country to another location will not stop them from leaking or exploding.

Congress is focused on nuclear waste bills such as H.R. 3053, which propose to transport and store nuclear waste in unsafe thin-wall cracking canisters, with no plan if something goes wrong. This will no more make us safe than rearranging the deck chairs on the Titanic would stop it from leaking.

Congress must opposes nuclear waste bills, such as H.R. 3053, that:

• Remove basic safety requirements from the law (Nuclear Waste Policy Act of 1982).
• Remove federal, state and public rights for input, oversight and transparency.
• Preempt other federal, state and local rights, including site specific environmental impacts.
• Allow nuclear waste ownership transfer to the Department of Energy at existing sites.
• Remove mandatory spending for nuclear waste management. Instead, requires funding approval from Congress.

Demand the President and Congress force the NRC to do their job of protecting us
Require:

• Stop loading nuclear waste in unsafe thin-wall canisters.
• Replace existing thin-wall canisters with proven thick-wall metal casks that can be maintained and monitored to prevent major cracks and radioactive releases into our environment and that are transportable.
• Store thick casks in hardened buildings on higher ground away from coastal and flooding risks.
• Require continuous radiation monitoring with on-line public access.

The NRC and California government allows unsafe San Onofre nuclear waste storage by the beach at Camp Pendleton

Southern California Edison refuses to use safer storage.  Instead, they continue to load tons more nuclear waste at San Onofre in inferior thin-wall Holtec canisters that are already cracking.  They have no plan in place to prevent or stop major radioactive releases into our communities. San Onofre is located near Trestles beach on Camp Pendleton in North San Diego county, near San Clemente. 

A nuclear disaster at San Onofre can result in major permanent evacuations across multiple counties.

Disneyland would likely be a ghost town. 

Camp Pendleton would be useless.  

We must act now to stop this from happening.

Holtec almost dropped a San Onofre canister 18 feet.

Whistleblower Industrial safety inspector, David Fritch, revealed Holtec engineering and other safety problems at San Onofre nuclear waste facility.  Fritch states the Holtec system is an engineering design problem and workers are understaffed, not qualified and not adequately trained to load nuclear fuel waste canisters into the Holtec dry storage system.  He said safety is not the first priority with Holtec or Southern California Edison. 

One canister was hanging by a 1/4″ on the upper MPC Guide ring located about 4 feet down from the top of the hole.  [NRC photo labels it a Shield Ring.] See ML16193A339 FSAR for details]. The canister came close to dropping 18 feet into the storage hole — and this wasn’t the first time. See David Fritch video statements and other statements from August 10, 2018 Edison Community Engagement Panel (CEP) meeting.  David Fritch transcript.

UMAX Holtec Shield Ring in the canister storage hole is referred to as an “MPC Guide” system in the approved FSAR. It’s purpose is to guide the canister into the storage 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 all the canisters bump and grind against the sides of the metal guide ring as they are lowered into each hole, resulting in pit corrosion cracking. Once cracks start, they continue to grow through the canister walls.  See NRC findings on NRC Special Inspection websiteEdison has no solution if a large 54-ton Holtec thin-wall canister falls. They have no method to inspect contents for damage or determine if canister has cracks. Tom Palmisano, San Onofre Chief Nuclear Officer, admitted San Onofre welded thin-wall canisters are too hot to unload back into the pool, even though it is a license requirement. No thin-wall welded canister has ever been unloaded. One bolted lid thick-wall cask was unloaded in a pool at Peach Bottom. This cask  is designed to be opened — not welded shut. It also had much cooler fuel than San Onofre.  Peach Bottom low burnup fuel cooled for decades in the pool and almost 10 years in dry storage.

All San Onofre Holtec canisters are damaged — NRC ignores problem

The NRC approved the Holtec UMAX system in spite of knowing there is only 0.5 of an inch gap (diametral clearance) between the MPC [canister] and the MPC Top Guide Plates.  This means there is only a 1/4-inch clearance between the canister and Guide plate (aka ring), making it impossible to download canisters without gouging and scratching the walls of every 54-ton canister.  HI-STORM UMAX System FSAR Revision 3 ML16193A339, June 29, 2016 (page 3-46).

• Did the NRC know at the time this would cause the walls of every 54-ton canister to be gouged as it is scraped and banged (“metal to metal”) against the MPC Guide all the way down into the storage hole?
• Why is the NRC not citing Holtec and Edison for this serious safety engineering problem?
• Why did they allow 29 canisters to be loaded and damaged?
• Are they going to allow 44 more canisters to be loaded, knowing they will also be damaged?
• The NRC admits canister gouging and scratching is a problem, but wants to ignore it, claiming it can be dealt with years later once they figure out how to inspect and repair canisters — even though Holtec President, Kris Singh, admits his Holtec canisters cannot be inspected or repaired.
• This is the same Holtec system proposed for New Mexico.

San Onofre has worst NRC safety complaint record in the nation.

San Onofre had the worst NRC safety complaint record in the nation from employees while the nuclear reactors were operating, so this whistleblower revelation is not surprising to those familiar with Southern California Edison’s history.  San Onofre also had the highest rate of retaliation against employees.

The NRC and nuclear industry plan is to hide radiation releases.

The NRC is allowing nuclear facilities to hide radiation levels from outlet air vents of canister concrete overpacks — where radiation levels will be highest from through wall cracks.  Areva NUHOMS Amendment #4 request to NRC for their 24PT1 and 24PT4 dry storage canisters (DSC) (slide 6) requires only measuring peak radiation levels from inlet air vents of the AHSM concrete overpack.  The NRC already approved this request for Calvert Cliffs in Maryland.  Calvert Cliffs thin-wall canisters are up to 25 years old, cannot be inspected and could already be leaking, but they are not required to report radiation levels at the outlet air vents.

San Onofre radiation levels at older Areva NUHOMS canisters (up to 15 years old), already have high radiation levels, but the NRC will not tell us why.  Radioactive counts per minute up to 2024 CPM (6.06 microsieverts per hour) at San Onofre waste storage inlet air vents on 9/6/2018.

Radiation Levels San Onofre 10/22/2018

San Onofre Holtec thin-wall canisters are already cracking.

August 10, 2018 Edison press release statement on almost 18 foot canister drop downplays the problems.  Edison ignores the Holtec engineering design problems as noted by the industrial safety inspector, David Fritch, and other problems below.

• Edison ignores the lack of ability to return fuel assemblies back to the pool for inspection if a canister falls even a few inches.
• If a canister drops more than 11 inches inside a transfer cask, contents must be inspected (NRC ML003711865, page 3-10 Accidental Drop).  Each canister is approximately 49 tons, according to the NRC August 24, 2018 San Onofre Inspection Report (ML18200A400). However, 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)
• Multiple Holtec canisters are scratched, but Edison has no method to find the scratches. Even microscopic scratches can remove the thin ~2nm (nanometre) layer of chromium oxide film on the stainless steel canisters, which creates pitting corrosion cracking by mechanical means. Once cracks start they can grow through the wall in 16 years (NRC).  The NRC must resolve this issue for all the canisters, not just the ones with the near-drops. Holtec workers cannot see a canister when loading it in the hole, likely resulting in scratches to canisters as they try multiple times to aligned the canister properly in the hole. However, Edison and Holtec have nothing in place to inspect the outside or inside of the canisters or inspect for cracks.  Edison admits in their August 10, 2018 press release: “Holtec was loading the spent fuel canister into the [steel lined concrete hole] Cavity Enclosure Container (CEC) on the dry cask storage pad when the canister got caught on an inner [MPC Guide] ring that helps to guide it into place. There is a very snug fit in the CECs, and it is not unusual for it to take the downloading team a few manipulations to get the canister aligned appropriately.”
• No Decommissioning Trust Fund monies should be released to Edison by the California Public Utilities Commission (CPUC) until these issues are resolved.  The Reactor Unit 2 and Unit 3 Trust Fund contained over $4.3 billion before Edison began loading Holtec thin-wall canisters. Edison knows these uninspectable canisters are vulnerable to short-term cracks and leaks and they have no plan if something goes wrong, but they continue to use them, anyway.
• The Coastal Commission San Onofre permits should be revoked.
• The State Lands Commission should deny Edison’s permit request and put EIR on hold. See comments to State Lands Commission, August 30, 2018.

Videos reveal major nuclear waste storage problems at San Onofre

• Southern California Edison response by Tom Palmisano
• Camp Pendleton position on San Onofre waste storage
• Tom Palmisano claims that Edison is in compliance with its Nuclear Regulatory Commission (NRC) license and Systems Analyst Donna Gilmore, SanOnofreSafety.org, objection to his claim by citing the NRC license condition requiring the ability to unload fuel from canisters back into the pool. She states Edison has no method to unload damaged canisters as required by their NRC license.  Palmisano then admits this is a requirement of their NRC license, but plans to obtain an NRC exemption to destroy the pools once they are empty, in spite of having no other plan in place to unload damaged canisters.  The only other option to unload defective canisters or inspect inside the canisters is using a large hot cell (a dry fuel handling facility filled with an inert gas so nothing explodes).  Edison has no plans to build a hot cell.

Video of full Edison San Onofre CEP August 9, 2018 meeting.  Whistleblower at 2:20:00.

Instead of protecting our safety Southern California Edison’s plan appears to be to hide radiation leaks and hide the fact they are out of compliance with their Nuclear Regulatory Commission (NRC) license. See Condition 8 of License, page 3 (ML16341B080)and August 24, 2018 San Onofre NRC Inspection Report (ML18200A400). This handout with more details (No Plan for Cracking Cans) was presented to Southern California Edison at the August 9th, 2018 Community Engagement Panel meeting.

Areva NUHOMS Amendment #4 request to NRC for their 24PT1 and 24PT4 dry storage canisters (DSC) (slide 6) would require only measuring peak radiation levels from inlet air vents of the AHSM concrete overpack.  Leaking canister highest radiation levels will be from outlet air vents. The NRC already approved this request for Calvert Cliffs in Maryland.  Calvert Cliffs thin-wall canisters are up to 25 years old, cannot be inspected and could technically already be leaking, but they are not required to report radiation levels at the outlet air vents.

In this August 9, 2018 CEP meeting video clip, Donna Gilmore called out Tom Palmisano on his lie that Edison is in compliance with their NRC license.  He finally admitted their current license requires they must be able to return defective canisters back into the pool.  They cannot do this as he admitted in the March 22, 2018 CEP meeting (second video below).

Tom Palmisano admits Edison has no ability to unload defective hot spent fuel canisters back into the spent fuel pools, March 22, 2018. This is a requirement of their NRC license. See page 2, Condition 8 of License (ML16280A017).

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).  He claims it is possible, yet there is no evidence to support this and no one has developed doing this in the decades they have been loading hot fuel in dry storage.  He said the fuel is 200 to 300 degrees C. Water boils at 100 degrees C. He called it a “reflooding” problem.  Yet Edison continues to load fuel in dry storage that is over twice as hot as their previous dry storage containers. The only other option to unload fuel on site is a hot cell, but Edison has no plans to build one.

The real reason Edison wants to empty the pools quickly is made clear in this Nuclear Energy Insider, October 4, 2017 article, California utilities seek fast reactor dismantling, regulation to control costs, states Edison:

“Swift fuel transfer into dry cask storage generates significant cost savings for operators by reducing monitoring and security requirements and cutting labor costs.”

In an August 10th San Diego Tribune article, Edison claims canisters are designed to with withstand an 18 foot drop, but has provided no evidence. On the contrary, the August 17, 2018 NRC Charter admits that a canister drop was not analyzed in the Holtec Final Safety Analysis (FSAR) approved by the NRC. And in Holtec HI-STORM canister (MPC) analysis of a canister drop inside a transfer cask,  it states if a canister drops more than 11″, the canister must be inspected for damage. Since they cannot open or inspect canisters, they have no way to do this.

Edison mismanaged the replacement steam generator project, resulting in shutdown of the reactors on January 31, 2012.  The NRC concluded Edison was at fault: “…a significant design deficiency in replacement steam generators, resulting in rapid tube wear of a type never before seen in recirculating steam generators.”  In the NRC’s December 23, 2013 NRC Notice of Violation to Edison, they state: “…design control measures were not established to provide for verifying or checking the adequacy of certain designs”.

More Handouts

• Spent Nuclear Fuel Fact Sheet (short), July 11, 2018
• Save Trestles and our Coastline, August 4, 2018
• Spent Nuclear Fuel Dry Storage Fact Sheet with source links
• Why Thick Casks needed at San Onofre, June 27, 2018
• U.S Dry Cask Inventory, Sorted by State (2 pages)
• City Council handouts and sample resolutions
• More handouts and reports

Each canister holds roughly a Chernobyl nuclear disaster — the amount of radioactive Cesium-137 and other radionuclides release from the 1986 Chernobyl nuclear disaster.

Thin-wall “Chernobyl cans” cannot be inspected (inside or out), repaired, maintained or monitored to PREVENT major radioactive releases into the environment.

Nuclear waste generators have no feasible plan in place to stop major radioactive releases.

Peak radiation levels may not be reported to the public. The Nuclear Regulatory Commission (NRC) is allowing some facilities to exclude reporting radiation levels from the outlet air vents.  This is where the highest levels will be when canisters have through-wall cracks.

Partially cracked canisters cannot be safely transported.  Facilities have no method to inspect for cracks or the condition of the fuel and other contents of the canisters prior to shipment. Spent nuclear fuel can degrade after dry storage.

The Nuclear Waste Technical Review Board (NWTRB) recommends spent nuclear fuel and its containment must be monitored and maintained in dry storage in a manner to prevent hydrogen gas explosions for both short-term and long-term storage and transport.  This is not currently being done and cannot be done with the thin-wall welded canisters.  It can only be done with thick-wall bolted lid casks, like those used in most of the world and at some US facilities.  See NWTRB report to the United States Congress and the Secretary of Energy, Management And Disposal Of US Department Of Energy Spent Nuclear Fuel, NWTRB, December 2017.

NRC licenses require the ability to unload canisters back into spent fuel pools, but only requires simulations that this can be done. The NRC admits the waste may need to be stored at existing facility indefinitely. They claim nothing can go wrong in spite of their own evidence to the contrary.

The Nuclear Regulatory Commission (NRC) is aware of these issues, but refuses to require safe standards that would result in use of proven thick-wall metal casks (10″ to 19.75″ thick), used throughout the world, that can be inspected, maintained and monitored to prevent radioactive leaks. 

NRC management makes decisions that value industry profits over public safety.  They mislead the public, elected officials and others. They have mislead NRC Commissioners (who are appointed by the President and confirmed by the Senate).

Darrell Dunn, NRC materials corrosion engineer, claims there is not enough humidity at San Onofre for corrosion and cracking.

Darrell Dunn ignores frequent fog, on-shore winds and surf at the San Onofre nuclear facility and elsewhere.  Dunn ignores Diablo Canyon 2-year old Holtec canister, filled with hot and highly radioactive nuclear fuel waste, that has a low enough temperature for moisture to stay on the canister surface and dissolve salts. He admits these are major triggers for chloride induced stress corrosion cracking. Instead, he references reports that exclude this data.

Darrell Dunn erroneously stated at the Nuclear Waste Technical Review Board (NWTRB) Summer 2018 Board Meeting (June 13, 2018) that thin-wall canisters are not vulnerable to cracks in 20 years, but did not explain why. 

• Dunn did not disclose facts that would have contradicted his statement.  Dunn stated there is inspection and repair technology, but did not mention once canisters are loaded with spent nuclear fuel they have no technology in place that can adequately find or measure cracks, let alone repair them. See Spent Nuclear Fuel Dry Storage Fact Sheet.
• Dunn did not mention the NRC approves systems that do not meet the NWTRB DOE Management and Disposal of Spent Nuclear Fuel December 2017 report  recommendations that all spent nuclear fuel and its containment must be monitored, maintained and retrievable in a manner to prevent hydrogen gas explosions in both short-term and long-term storage, and in transport.
• Dunn did not mention the NRC Aging Management Plan (NUREG-1927 Rev. 1) only requires one canister at each site to be “inspected”, unless they find problems. Since they cannot inspect, they cannot find problems.
• Dunn did not mention the Aging Management Plan requires canisters with 75% through-wall cracks to be taken out of service, but there is no current method approved and in place that can to do that. (NUREG-1927 references the ASME Boiler and Pressure Vessel Code that specifies the 75% maximum, but NRC refused to add the term “75%” to the document.)
• The NWTRB meeting was about transport yet Dunn did not mention:
  • Facilities have no method to inspect for cracking canisters, or damaged fuel, fuel baskets or other internal components, before transport (per NRC Reg. 10 CFR § 71.85).
  • NRC Holtec transport cask certificate does not include unloading.  This is up to the receiver of the cask.
  • Holtec’s application for a New Mexico UMAX CIS facility states canisters arriving leaking will be returned to sender.  See SOS Holtec webpage for details about Holtec issues.
  • Leaking canisters are not approved for transport and receiving facilities have no method to stop leaks or replace canisters.  Holtec’s New Mexico UMAX CIS proposal does not include a plan for cracking or leaking canisters nor a facility to replace canisters.  The NRC has not approved Holtec’s UMAX CIS facility yet.
  • NRC is approving much higher heat loads and more fuel assemblies per canister, risking damage to the fuel and other components, increasing radiation levels near the canisters, and requiring decades more cooling before canisters can be transported.
  • NRC NUREG-2125 Spent Fuel Transportation Risk Assessment Final Report, 2014, excluded high burnup fuel from evaluation.  Michael Ryan, NRC ACRS, told former NRC Chairman MacFarlane the report addressed high burnup fuel and high burnup fuel embrittlement after dry storage.  It does not.

US nuclear facilities have no on-site method to unload defective or leaking canisters.  

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).  He claims it is possible, yet there is no evidence to support this and no one has developed doing this in the decades they have been loading hot fuel in dry storage.  He said the fuel is 200 to 300 degrees C. Water boils at 100 degrees C. He called it a “reflooding” problem.  Yet Edison continues to load fuel in dry storage that is over twice as hot as their previous dry storage containers. The only other option to unload fuel on site is a hot cell, but Edison has no plans to build one.

Edison’s San Onofre Independent Fuel Storage Facility (ISFSI) NRC license requires the ability to unload fuel assemblies from dry storage canisters back into the spent fuel pool (ML16280A017).  This March 27, 2018 Loose Holtec Bolts email correspondence to the NRC (David McIntyre) from Donna Gilmore asked the NRC to confirm whether Edison is out of compliance with their San Onofre ISFSI license.  The NRC responded to other questions in this email exchange, but has yet to respond to that question.  This issue has national implications, since other U.S. ISFSI facilities are in a similar situation. Answers from NRC David McIntyre on “Loose Holtec Bolts” questions.

The information about inability to replace failing canisters was not disclosed to the California Coastal Commission at the time Edison received their 20-year San Onofre Coastal Development Permit to store 73 Holtec UMAX nuclear waste canisters near the beach.  It was disclosed at the March 22, 2018 Community Engagement Panel Meeting. The red arrow above shows location for the 73 Holtec canisters. Behind that are the 51 above ground existing Areva NUHOMS canisters already loaded. Both canister systems are in structures that require air vents for convection cooling of the fuel.

ACTION ITEM #1:  Oppose H.R. 3053 Nuclear Waste Policy Amendment Act of 2018

The proposed Shimkus/Issa bill, H.R. 3053 Nuclear Waste Policy Amendment Act of 2018, now in the Senate, will not solve our nuclear waste storage problems and will make the problems worse.

Those in Congress who support this bill do not know the truth about what is in the bill. The bill promises to move highly radioactive nuclear fuel waste (such as San Onofre nuclear waste) to Yucca Mountain in Nevada, or to consolidated “interim” storage sites, such as those proposed in New Mexico and Texas.  Instead,  H.R.3053 makes the problem worse.

The official summary of H.R. 3053 and other information provided to elected officials by Shimkus and others does not disclose these facts.  H.R. 3053:

• Removes storage, transport and environmental safety requirements necessary to prevent radioactive leaks and explosions.
• Preempts or jeopardizes existing federal, state and local water and air rights, and rights to oversight, input, transparency, and other rights, including congressional oversight.
• Provides inadequate funding to transport and store nuclear fuel waste.
• Makes federal reimbursement for nuclear waste storage discretionary instead of mandatory.
• Allows ownership of nuclear fuel waste to be transferred to the Department of Energy (DOE) at existing nuclear sites, making us vulnerable to insufficient funding for nuclear waste storage. Current DOE nuclear waste sites have repeatedly leaked radiation into groundwater and air partly because of this.
• The proposed Yucca Mountain high-level nuclear waste repository has the potential to expose Native Americans and others to radiation through unique exposure pathways.

“The Western Shoshone people continue to endure adverse health consequences of past radiation exposure from 1,000+ nuclear weapons tests. It is unethical and immoral for any corporation, or government to dispose of the most toxic substance made, that will certainly result in the death of Shoshone.”  Principal Man Ian Zabarte, Western Bands of the Shoshone Nation of Indians, Treaty of Ruby Valley (Consolidated Treaty Series Vol. 127 1863)  Ten Thousand Years Was Only Yesterday 2019

Share handouts with local, state and federal elected officials and others regarding why they should oppose H.R. 3053 as written and demand the Nuclear Regulatory Commission (NRC) stop approving inferior storage containers.  Instead, Congress must mandate that spent nuclear fuel and it’s containment be maintained and monitored in such a manner as to prevent radioactive leaks and explosions in both short and long-term storage. The NRC is currently not doing that.  Instead, the NRC lowers safety standards, by ignoring current Nuclear Waste Policy Act law requirements for monitored retrievable fuel storage. This bill would removes those critical safety requirements from existing law.

• Summary: reasons to oppose H.R. 3053
• Letter to Elected Officials from California Communities regarding San Onofre and H.R. 3053 nuclear waste storage issues
• Reasons to oppose or amend H.R. 3053 NWP Amendment Act and Recommendations
• H.R. 3053 Community Opposition Letter signed by over 100 organizations, October 11, 2017
• H.R. 3053 to Rules Committee with proposed revisions,  and bill status, May 3, 2018
  • The Committee on Rules will meet May 8, 2018 at 3:00 PM in H-313 The Capitol on H.R. 3053 — Nuclear Waste Policy Amendments Act of 2018
  • Process for requesting amendments (due May 8, 2018 10 am)
  • H.R. 3053 bill and current status (prior to Rules Committee proposed revisions)
  • Detailed Changes from H.R. 3053, as reported, to Rules Committee Print 115-69 (Congress must allocate funds to DOE before they can be uses for spent fuel waste storage and transport, eliminates federal contractual liability if due to inadequate allocation of funds, limits allocation, other related changes)
  • Comparing the base document H.R. 3053, as reported, with the Rules Committee Print 115-69
• H.R. 3053 bill and current status (prior to May 3, 2018 proposed revisions to Rules Committee)

• H.R. 3053 final bill to House (as amended) (Union Calendar No. 259), October 19, 2017
• NWPA1982 law with handwritten changes from HR3053, including approved four amendments (red ink)
• Four Amendments to H.R. 3053 approved by Energy and Commerce Committee
  • Unofficial version of HR3053 with amendments incorporated (pdf)
  • Unofficial version of HR3053 with amendments incorporated (docx)
• Nuclear Waste Policy Act of 1982 as amended (nwpa82.pdf)  (current law)
• H.R. 3053 Congressional Budget Office Report
• House Energy and Commerce Committee hearings

ACTION ITEM #2:  Contact the California Coastal Commission and request they revoke San Onofre Coastal Development Permit 9-15-0228.  

• Coastal Commission Special Condition 7 requires these containers be maintained to ensure they can be transported. Edison knew they could not replace defective or cracking canisters at San Onofre, but did not disclose this to the Coastal Commission.
• Send email to joseph.street@coastal.ca.gov
• Attend Coastal Commission public meetings and request permit be revoked.
• Ask local and state elected officials to demand the Coastal Commission revoke the permit.

Other countries and some US nuclear facilities use proven thick-wall metal storage casks (10″ to 19.75″ thick) to store their nuclear waste.

• They are designed to maintain and monitor the fuel and container.
• Thick-wall Areva designed casks survived the 2011 tsunami and earthquake at Fukushima in Japan.
• In Japan and other countries, such as Germany, thick-wall casks (both Castor and Areva designs) are stored in reinforced hardened buildings for additional environmental and security protection.
• France uses thick-wall casks for themselves and others, but sells their NUHOMS thin-wall canisters to the US. Most US nuclear corporations choose short-term lower costs over quality and safety.
• Thick-wall casks are licensed for use in the US and are the oldest and most proven dry storage containers used in the US and elsewhere.

Southern California Edison claims there is no NRC approved thick-wall cask designed for San Onofre is misleading.  Fuel assemblies are frequently a different size at different facilities, so it is common to need an NRC license amendment to modify container designs to accommodate this. Edison needed a license amendment for the NUHOMS 32PTH2 canisters they purchased and took delivery of (but never used), and for the Holtec HI-STORM UMAX canister system they ultimately purchased (for a price they refuse to disclose, even though ratepayers are funding them).

Edison’s MPR 2017 white paper recommends using the Test Area North (TAN) Hot Shop — this hot cell was destroyed in 2007!

Edison is using MPR’s September 2017 white paper as their reference for how they can safely manage the nuclear fuel waste and how they can feasibly replace canisters (by shipping them to the TAN hot cell). MPR’s own technical reference (#21) in their white paper states it was destroyed in 2007, yet they claim it’s feasible to use.  On page 20 of the MPR report it states: “The DOE recently identified a large existing hot cell facility (Test Area North) on the Idaho National Laboratory (Reference 21) that could be dedicated to repackage commercial used fuel canisters.”

Edison (Tom Palmisano) admitted we would likely need a “hot cell” to transfer fuel from one container to another. This is a dry fuel handling facility filled with an inert gas (such as helium) where fuel is handled remotely. The NRC requires the ability to handle fuel in such a “dry fuel handling facility”, even though one has not been identified that can be used.

Edison should not be allowed to destroy their spent fuel pools until they have a hot cell on-site to transfer fuel to new dry storage containers and to maintain and monitor the fuel and the containers. Edison has not provided a cost for such a hot cell, but has been asked numerous times about this.

The Idaho National Laboratory (INL) Test Area North  (TAN) hot shop (hot cell) destroyed in 2007 was the only hot cell identified large enough for unloading large canisters.  The MPR Associates white paper “SONGS Used Fuel Management – Defense in Depth”, September 2017, page 20, incredulously states it is feasible to use this TAN hot shop (hot cell) for San Onofre canisters. MPR’s reference for this claim (Reference #21) actually states the opposite right in the summary on Page v — it states the TAN facility was demolished in 2007.  The scope of the referenced INL report is not even relevant to using a hot cell to replace failing welded lid thin-wall canisters.  The scope was to determine whether “it is possible to receive, open, inspect, remove samples, close, and reseal large, bolted-lid, dry storage casks at INL”  Viability of Existing INL Facilities for Dry Storage Cask Handling, USDOE Report, INL/EXT-13-29035, April 2013.  This appears to be a significant reading comprehension error with the MPR authors.

Edison knew the TAN facility was demolished, yet did not catch this major error in the MPR 2017 report nor that the INL report was not even relevant to MPR’s claim.  Closure of the TAN facility was discussed at the California Public Utilities Commission San Onofre decommissioning proceeding during August 2015 evidentiary hearings.

The MPR 2017 report also ignores other evidence that does not fit their conclusion. For example, it ignores risks of high burnup fuel damage by using outdated references.  It ignores criticality risks if unborated water enters canisters from through-wall cracks.  It ignores hydrogen gas explosion risks. Edison is aware of these risks, yet is promoting this MPR report as evidence they have defense in depth and can only have minor radioactive leaks that they will be able to stop. They have provided no evidence of this — only unsubstantiated promises of future solutions.  See High Burnup Fuel Unstable in Storage and Transport for evidence of cracking, leaking and explosion risks.

Edison received defective nuclear fuel waste canisters from Holtec.

Loose bolts were found inside the bottom of some new Holtec canisters. Holtec loaded four San Onofre Holtec thin-wall canisters with nuclear fuel waste before they noticed the loose bolt (pin) in the bottom of an empty canister. Holtec used a new basket shim design. Only the original shim design was approved by the NRC.  The four canisters were not inspected by Holtec at San Onofre because Edison said they couldn’t see the bottom of the shims in the canister to know there were pins there let alone missing or bent pins. Learn about other Holtec issues here.

Edison did not notify the public for over a month (on March 22, 2018). They were aware of the problem since February 20, 2018 and had loaded four canisters with the defective new shim design. An evening news report on March 18, 2018 by Mike Faher, VTDigger, in the Vermont Brattleboro Reformer reported the problem. In that article, the NRC refused to name the nuclear plant where the loose bolt was found. It was San Onofre.

MPR was hired by Edison to assess the risks of the defective Holtec new shim design.  This is the same company that recommended the INL TAN hot cell as a a possible option for transferring fuel waste to a new container — the hot cell their own reference said had been demolished in 2007. According to Edison, MPR claims the four loaded Holtec San Onofre canisters with the defective shim design are safe.  The NRC is still investigation this. However, the NRC has never required any misloaded or otherwise problem canisters to be replaced.  Over half the Diablo Canyon Holtec canisters were loaded incorrectly.  These were also loaded by Holtec.

This is a Holtec design and quality control problem. No independent inspections are required by the NRC. Holtec was hired to manufacture and load the San Onofre canisters. Edison has resumed loading canisters with the older NRC approved basket shim design while claiming the four canisters loaded with the new defective design are safe.

According to the NRC, Holtec has been using this defective design since 2016. Holtec notified the following sites that have loaded or received canisters with the defective basket shim design: Dresden, Grand Gulf, Hatch, Vermont Yankee, Columbia, San Onofre, Watts Bar and Callaway.   No one apparently knows the condition of the four San Onofre canisters or other canisters that may have been loaded with the defective shim design.  Vermont Yankee had already loaded 30 canisters, with 15 additional remaining to load.  It is unclear which canisters contain the defective new shim design.

The basket shims are 18 foot long hollow aluminum, with over 1/2″ thick walls. The bottom of each shim is supported by only three 7/16″ x 4″ stainless steel pins (bolts). At the bottom of each canister are a total of 88 bolts (pins).  The open space at the bottom of the basket shims allows helium to circulate around the fuel assemblies.  Source:  Nuclear Regulatory Commission and Southern California Edison. Holtec provided most of the information to them. Loose Holtec bolts NRC emails with Donna Gilmore as of March 27, 2018

Technology does not exist to safely store nuclear fuel waste in a  permanent repository — even in the short-term, 

NWTRB admits no permanent repository solution exists

The Nuclear Waste Technical Review Board (NWTRB) admitted no country has short-term storage and monitoring technology solutions needed to implement a safe permanent geological repository.  Webinar, slides and transcript at March 28, 2018 NWTRB Spring Meeting website.

In the NWTRB May 2018 report on Geologic Repositories, the Board admitted “Long-term research, development, and demonstration of monitoring and sensor technologies are needed to address current technology limitations.”  In other words, they have no clue how to ever make any geological repository work in the short-term or long term.  This myth of a “one and done” permanent storage solution was created by the nuclear industry to justify the economic costs of nuclear power.  The reality that there is no long-term solution and the “interim” nuclear waste storage costs will be never ending has not been addressed — even for the short-term.

Geologic Repositories: Performance Monitoring and Retrievability of Emplaced High-Level Radioactive Waste and Spent Nuclear Fuel, NWTRB report to Congress, May 2018

The Nuclear Waste Technical Review Board December 2017 report to Congress states spent nuclear fuel waste needs to be monitored and maintained in dry storage in a manner to prevent hydrogen gas explosions for both short-term and long-term storage.  This is not currently being done and cannot be done with the thin-wall welded canisters.  It can only be done with thick-wall bolted lid casks, like those used in most of the world and at some US facilities.  See Nuclear Waste Technical Review Board report to the United States Congress and the Secretary of Energy,  Management And Disposal Of US Department Of Energy Spent Nuclear Fuel, NWTRB, December 2017.

The best available current technology solution is to store spent nuclear fuel waste above ground in hardened buildings for additional environmental and security protection. The  best available technology that can meet NWTRB requirements are thick-wall bolted lid casks, currently the standard in most of the world (except the U.S.).  Most U.S. nuclear waste generators chose thin-wall canister systems because of  lower initial cost.

The NRC (unlike other countries) approves inferior thin-wall canisters for storing and transporting highly radioactive spent nuclear fuel.  Current federal law, the Nuclear Waste Policy Act of 1982 (NWPA), requires monitored retrievable spent nuclear fuel storage.  The NRC has chosen to ignore these NWPA requirements. The bill H.R. 3053, The Nuclear Waste Policy Amendment Act of 2018, (now pending in the Senate) proposes to eliminate NWPA safety requirements. It also proposes to remove our federal, state, local and public rights for oversight, input and transparency.

ACTION #3:  Educate the public and elected officials. 

Please take action to help stop use of these inferior “Chernobyl cans”. This affects you and your family and is a “now” problem. Demand proven thick-wall casks that do not have the design flaws of the inferior thin-wall canisters.  Oppose legislation that makes us less safe and does not solve the urgent nuclear waste dry storage problems we now face.

• Share website: SanOnofreSafety.org
• Share handouts: 
  • Short Term Cracking and Leaking Risks
  • Urgent Nuclear Waste Canister Problems
    
  • High Burnup Fuel Unstable in Storage and Transport
• Go to City Handouts webpage for tools you can use to reach out to your elected officials.  Contact us for additional assistance.
• Locate nuclear waste in your state: U.S dry storage inventory

ACTION ITEM#4:  Oppose Senate Bill S.2396 and House Bill H.R.4441

S.B.2396 and H.R.4441 are titled The Safe and Secure Decommissioning Act of 2018, but the opposite is true. The bills encourage expediting highly radioactive spent nuclear fuel out of the pools into dry storage — even in unsafe thin-wall dry storage canisters.  Each can contains about as much lethal highly radioactive Cesium-137 as was released from the 1986 Chernobyl nuclear disaster.

Contact local, state and federal elected officials and tell them to oppose S.B.2396 and H.R.4441.  Emergency and security regulations and requirements should be continued until all spent fuel is removed from the site. And no thin-wall cracking Chernobyl cans! 

These bills propose to eliminate emergency and security regulations and requirements once all fuel at a nuclear plant is in dry storage, even though this lethal highly radioactive spent fuel waste is still at the site.

State and local governments receive millions of dollars in emergency funding from operating reactor corporations (licensees).  However, the NRC currently grants exemptions that result in termination of these funds once nuclear reactors are permanently shutdown — even though the lethal nuclear waste is still in our communities and even though state and local governments must respond to radioactive nuclear disasters.

The NRC officially assumes nothing will go wrong once nuclear reactors are shutdown, even thought they know better. See these Comments to the NRC (ML16082A004) as to why NRC’s claimed assumptions are wrong — based on their own evidence.

It appears elected officials sponsoring these bills are believing the wrong “experts”, who are telling them these thin-wall cans are safe enough and safer than the spent fuel pools. However, the pools have defense in depth (redundancies). The thin-wall cans have no redundancies. The fuse is likely lit on these Chernobyl cans, but we have no idea how deep the cracks are to know how much time we have left. The nuclear corporations have no approved plan in place to prevent or stop leaks, criticalities, or explosions. They cannot repair or adequately inspect for cracks. Even partially cracking canisters cannot be transported per NRC regulations. High burnup transport casks require intact canisters (no cracks). Learn more on SOS Holtec webpage.

S.B.2396 and H.R.4441 Bill Summary:  This bill amends the Atomic Energy Act of 1954 to prohibit the Nuclear Regulatory Commission from approving the request of a licensee for a waiver of, or exemption from, a covered regulation applicable to a civilian nuclear power reactor that has permanently ceased to operate.

A covered regulation includes: (1) an emergency preparedness or response regulation or requirement, or (2) a security regulation or requirement applicable to spent nuclear fuel.

This prohibition shall not apply to a civilian nuclear power reactor at which all spent nuclear fuel has been transferred to spent nuclear fuel dry casks.

S.2396 sponsors: Senators Kamala Harris, Edward J. Markey, Bernie Sanders and Kirsten E. Gillibrand;
H.R.4441 sponsor: Rep. Nita M. Lowey.

ACTION: Revoke San Onofre Coastal Commission nuclear waste storage permit.  

• Download Petition to Revoke Coastal Permit and collect signatures.  
• Share handout Coastal Commission should revoke nuclear waste storage permit
• Coastal Permit to storage San Onofre nuclear fuel waste in thin-wall canisters that cannot be inspected, transported, monitored or maintained should be revoked.
• Coastal Commission requires waste must be transportable per Special Condition No. 7. The Commission and Southern California Edison know these canisters are vulnerable to cracks. Partially cracked canisters cannot be transported per Nuclear Regulatory Commission (NRC) regulation 10 CFR § 71.85).
  

  NRC Regulation 10 CFR § 71.85 Packaging and Transportation of Radioactive Materials. Preliminary determinations. Before the first use of any packaging for the shipment of licensed material — (a) The certificate holder shall ascertain that there are no cracks, pinholes, uncontrolled voids, or other defects that could significantly reduce the effectiveness of the packaging.

• Edison has not provided evidence to support they can meet Coastal Commission and NRC requirements and recently disclosed plans to destroy spent fuel pools, which is their only currently approved on-site method to replace cracking canisters.
• Tom Palmisano (Edison) disclosed at the September 2017 Community Engagement Panel meeting that partially cracked canisters have no earthquake (seismic) rating and Edison has no current ability to know if any of these canisters are cracking.
• The NRC states once a crack starts it can grow through the canister wall in about 16 years. The existing 51 Areva NUHOMS thin-wall canisters have been at San Onofre for up to 14 years.
• A Diablo Canyon thin-wall canister (also located along the California coast) was found to have conditions for cracking in a two-year old canister.
• Coastal Commission staff report said cracks would not start for 30 years per the NRC August 5, 2014 document.  However, the staff did not report that this was before the NRC knew that conditions for cracking could occur in only two years with temperatures low enough on the canister to dissolve salt particles.
• Given this incorrect information regarding 30 years before a crack could start and the fact partially cracked canisters do not have a seismic earthquake rating, the Commission made their decision with incorrect information.
• Instead of requiring that Edison solve these problems before granting a Coastal permit, Edison received Coastal Commission permit to load 73 more thin-wall canisters in a partially buried unproven system, with only a promise they will solve these problems.  See Holtec UMAX canister system.
• Commissioner Shallenberger grills NRC Mark Lombard and Edison’s Tom Palmisano about lack of ability to inspect for cracks (video). Neither Lombard or Palmisano mentioned that even if they could find cracks in these thin-wall canisters, they have no plan in place to repair or replace canisters. 
• Coastal Commission Regulations Article 16. Revocation of Permits
• Special Conditions for San Onofre Coastal Permit
• Coastal Commission 9-15-0228 Adopted Findings with exhibits
• Coastal Commission Tu14a-10-2015 Addendum to 9-15-0228 – includes response to public comments

The above Google map shows the location of the Southern California Edison San Onofre Nuclear Waste Dump in San Diego County on Camp Pendleton leased land, near the border of Orange County. The Holtec UMAX dry storage system (circled) is under construction with plans to load 73 high level nuclear fuel waste canisters starting in December 2017. Each Holtec thin-wall canister can hold 37 fuel assemblies.

Located directly behind the Holtec system shown above are 51 Areva NUHOMS storage canisters, each stored in a horizontal concrete overpack. Each Areva NUHOMS thin-wall canister holds 24 fuel assemblies.  Both storage systems require air vents so the nuclear fuel waste does not overheat.  The steel canister walls are only 5/8th of an inch thick and are susceptible to short term cracking. The Areva NUHOMS canister system is approved under separate Coastal permit (No. E-00-014), expires November 15, 2022.

Below is diagram showing distance to water table and surf. System is built half underground with dirt piled up on the sides. The NRC approved generic Holtec UMAX design is for a below ground system with only the top pad and lid above ground.  And the NRC and Southern California Edison are ignoring the fact partially cracked canisters have no seismic rating.

HANDOUTS: Key nuclear waste handouts to share with elected officials and others

• Urgent nuclear waste canister problems
• Nuclear Waste Storage & Transport Problems & Solutions, August 24, 2017
• Coastal Commission should revoke nuclear waste storage permit
• Comments to DOE consent based siting: Plan risks major radioactive leaks
• Dry Cask Inventory by State as of June 30, 2013
• Sierra Club comments to NRC proposed rule for regulatory improvements for decommissioning power reactors, Docket NRC-2015-0070, submitted March 18, 2016   (NRC ML16082A004)

Is Southern California Edison’s real plan to hide radiation leaks from cracking canisters?

Edison did not admit for over 17 days that radioactivity was released to the atmosphere during the steam generator tube leak on January 31 2012.  Now it appears their plan may be to hide radioactive leaks from the thin-wall dry storage canisters.

• Areva NUHOMS Amendment #4 request to NRC (slide 6) would require only measuring peak radiation levels from inlet air vents.  Leaking canister higher radiation levels will be from outlet air vents.
• Weakens other safety requirements in existing 51 thin-wall San Onofre spent fuel canisters, each holding about as much lethal radioactive Cesium-137 as was released from the 1986 Chernobyl nuclear disaster.
• Eliminates spent fuel pools, providing no other option for unloading cracking “Chernobyl” cans.
• Each canister contains about as much highly radioactive Cesium-137 as was released from the Chernobyl nuclear disaster.

The following federal and state government agencies know these canisters are susceptible to short-term cracks and leaks; that the canisters cannot be inspected (inside or out), cannot be repaired, maintained or monitored to PREVENT radioactive leaks. Edison has no approved plan in place to deal with cracking leaking canisters. Canisters with even partial cracks are not approved for transport and have no seismic rating. In spite of all this, these agencies are allowing Edison to build this nuclear waste dump which the U.S. Nuclear Regulatory Commission acknowledges might stay here indefinitely.

• California Coastal Commission: Granted a recent Coastal building permit with the unsubstantiated hope these problems will be solved in 20 years.  Granted an earlier separate 20 year permit for the existing 51 Areva NUHOMS thin-wall canister system.
• Nuclear Regulatory Commission: Licensed Holtec UMAX storage system. Ignored San Onofre high risk location. Refused to consider canister cracking and other unresolved aging management issues in their initial license approval. NOTE: Edison still needs an NRC site license which must be granted before fuel assemblies can be loaded into the Holtec UMAX system.
• California Public Utility Commission: Approved ratepayer Decommission Trust Funds to procure this system. Ignored cost-based case that there are insufficient funds to replace canisters that may fail in the short-term. Ignored Edison’s own testimony that it’s “unlikely” the federal government will take this waste anytime in the forseeable future. Ignored that the Holtec canister warranty excludes corrosion and cracking vulnerabilities. It covers only a limited warranty for manufacturing defects for problems we cannot even see, and this is only 25 years for the canister and void after 10 years, if the concrete structure fails.
• Department of Energy: Ignored Nuclear Waste Policy Act requirements for monitored, retrievable spent nuclear fuel storage. Instead promoted thin-wall canister systems without disclosing problems with the thin-wall canister systems.
• California Energy Commission:  Recommends expediting spent nuclear fuel assemblies into dry storage without recommending minimum safety requirements for the dry storage containers.

Tons of highly radioactive nuclear waste will continued to be unsafely stored at U.S. nuclear plants indefinitely unless action is taken to stop this.

The Koeberg nuclear plant in South Africa had a similar container (a waste water tank) crack and leak after only 17 years with cracks longer (0.61″) than most U.S. thin canisters (0.50″). The tank was at ambient temperature. Cracks grow faster in hotter stainless steel canisters.

Recommendations for Safer Nuclear Waste Storage and Transport

The majority of U.S. nuclear power facilities store highly radioactive nuclear waste in thin-walled canisters (most only 1/2 inch thick) that both the Nuclear Regulatory Commission (NRC) and the Department of Energy (DOE) admit cannot be inspected (on the outside or inside), cannot be maintained, repaired, and can crack and leak in the short-term. Other countries and some U.S. facilities use thick-walled metal casks 10 to 19.75 inches thick that do not have these problems.  The NRC has approved thick wall casks in the past and those are still in use, so licensing should not be a problem.  Thick casks are proven designs for both storage and transport. Thin-wall canisters must be banned from use before they start leaking radionuclides into the environment. Each canister contains about as much lethal Cesium-137 and other radionuclides as was released from the 1986 Chernobyl nuclear disaster.  More details and source links below.

San Onofre: Is nuclear waste being stored safely? PBS SoCal television interview with Oceanside City Council member Jerry Kern and SanOnofreSafety.org founder Donna Gilmore. PBS Studio SoCal moderators Rick Reiff and Elizabeth Espinosa. And Surfrider Foundation Senior Scientist Rick Wilson with PBS reporter David Nazar. September 16, 2016

Japan abolished in October 2015 the use of aluminum alloy baskets that hold the fuel assemblies in place inside the casks, stating they may not last even 60 years. Japan’s Nuclear Regulatory Authority (NRA) said the constant heat causes the baskets to degrade more quickly than expected. This model had been adopted in 2007 guidelines. There are 35 of this type of basket employed in Japan (20 at Fukushima Daiichi and 15 at Tokaimura). Out of the 20 at Fukushima, 11 exhibited the problem. More…

U.S thin-walled canister systems also use aluminum alloy baskets. However, because the lids are welded shut no one knows if there are problems. Japan was able to inspect their baskets because the lids of their casks are bolted instead of welded.

There are no adequate plans in place to prevent or remediate a major radioactive release from these thin-walled canisters.  We will only know of the problem after radiation is released into the environment.

Some vendor claims that they can put a leaking canister into a thick sealed transfer or transport cask are unsubstantiated. No such cask is approved for this purpose. A thermal analysis and other evaluations have not been done or approved by the NRC.  The NRC evaluated use of a cask at Big Rock Point for temporary storage of a thin-wall canister. They approved it for only 270 days. The NRC was not even sure the radiation levels would be safe doing this. Big Rock has lower burnup fuel (40 GWd/MTU or less) and fuel that cooled for decades in the pool.  The NRC allowed Big Rock to destroy their pool with the assumption Big Rock would have a solution after 270 days.  However, they don’t;  yet the NRC has not dealt with this and continues to let other decommissioning facilities destroy their pools. Fortunately, Big Rock and other utilities have not yet had a leaking canister,  However, these thin-wall canisters are near the age where they can start leaking from through-wall cracks.  Big Rock Point References:

ML020250519 – 01/25/02 – Ltr to R. D. Quinn, BNFL From: E. W. Brach Subject: Amendment No. 2 to Certificate of Compliance No. 1026 for the FuelSolutions Spent Fuel Managment System Enclosures: 1.) CoC No. 1026, Amendment No. 2; and 2.) Safety Evaluation Report. (3 page(s), 1/25/2002) 

ML020250586 – Final Safety Evaluation Report for the BNFL FuelSolutions Spent Fuel Management System (CoC No. 1026, Amendment No. 2). (4 page(s), 1/25/2002) 

01/25/02 – Package to R. D. Quinn, BNFL Subject: Amendment No. 2 to CoC No 1026 for the FuelSolutions Spent Fuel Mgmt System (ML020250512.html)

The NRC no longer requires the fuel assemblies to be retrievable from the canisters (ISG-2, Rev. 2), even though the DOE Standard Contract with utilities requires this.

NRC Director Mark Lombard is responsible for approving this change even though he and others know fuel will eventually need to be retrieved from these thin canisters and the canisters cannot currently be inspected or repaired and may crack and leak in short-term storage. Comments to the NRC regarding the impacts of this rule change were dismissed with bureaucratic double talk.

The NRC also allows empty spent fuel pools to be destroyed at decommissioned plants, even though they know this is the only approved method the utilities have to unload failing canisters.

Each canister contains more highly radioactive Cesium-137 than released from Chernobyl.

Even a microscopic through-wall crack will release millions of curies of radiation into the environment states Dr. Kris Singh, President and CEO of Holtec. He said it’s not feasible to repair the cracks even if you could find them.

San Onofre (SONGS) stores 89 times more lethal radiation (Cesium-137) than released from Chernobyl. 

Currently there are 50 “Chernobyl” cans with only 5/8″ thick steel walls and one can with other high level radioactive waste. They began loading in 2003.

Southern California Edison is ignoring the problems of thin canisters. Instead they plan to buy almost 100 Holtec thin canisters and store them in an experimental unproven system. Cost is estimated at $4 million each, including labor. Edison refuses to disclose the actual cost, even though this is ratepayer money.

Please share handouts

• Comments to DOE consent based siting: Plan risks major radioactive leaks, July 31, 2016
• Short-term failure risks of U.S. thin-wall canisters, letter to ACRS, September 20, 2016
• What is the DOE plan to resolve these major nuclear waste issues?
• Urgent nuclear waste canister problems
• Coastal Commission should revoke nuclear waste storage permit
• DOE Nuclear Waste Plan risks major radioactive releases, May 3, 2016
• Comments to DOE: Radioactive spent fuel storage plan is designed to leak
• Sierra Club comments to NRC proposed rule for regulatory improvements for decommissioning power reactors, Docket NRC-2015-0070, submitted March 18, 2016   (NRC ML16082A004)

• U.S. dry storage inventory
  • Dry Cask Inventory by State as of June 30, 2013 (rev 05-18-2017)
  • Total U.S. Nuclear Waste Thin Canisters – Chart and Table
  • Total U.S. Nuclear Waste Thin Canisters with States – Chart
  • Dry Cask Inventory by State, June 30, 2013
  • U.S. Nuclear Spent Fuel Storage Canisters/Casks loaded as of June 2013 (31 pages)
  • Total U.S. Damaged Fuel Assemblies as of June 2013

A Diablo Canyon canister located in a similar marine environment to the Koeberg tank has all the conditions for cracking in a two-year old canister and crack growth rate will be faster in hotter canisters filled with spent nuclear fuel.  EPRI (the utilities research lab) found corrosive salts and a temperature range low enough for salts to dissolve on the canister. No one knows if the Diablo or any other thin canisters are cracking, because they will only know after the canisters leak radiation into the environment.  California climate zone data shows both Diablo Canyon (Zone 5) and San Onofre (Zone 7) are located in high moisture zones (with on-shore winds, surf, and frequent fog); enough moisture to dissolve salts on the canisters.

No one can predict when a crack will start, but once a crack starts it can grow through the wall of the canister in less than 5 years, and in some cases less than a year, due to the higher heat level of thin canisters filled with spent nuclear fuel (canister temperatures, e.g., 60º C (140ºF) to 80ºC (176ºF)).  This Sandia Lab chart assumes a 5/8″ (0.625″) canister wall thickness of which there are very few that thick in the U.S. Most are 1/2″ thick. It demonstrates hotter containers will have much faster crack growth rate.  Draft Geologic Disposal Requirements Basis for STAD Specification, A. Ilgen, C. Bryan, and E. Hardin, Sandia National Laboratories, March 25, 2015, FCRD-NFST-2013-000723 SAND2015-2175R, PDF page 39 and 46  [http://bit.ly/SAND2015-2175R]

The NRC states once a crack starts it can grow through the wall of the canister and leak in about 16 years. Edison has existing canisters that have been loaded since 2003. Southern California Edison plans to continue to unsafely store over 1600 metric tons of highly radioactive nuclear waste on the Southern California coast even though they know all this.

The Nuclear Regulatory Commission (NRC) approves use of these inferior canisters in spite of knowing these problems. Therefore, it is up to our local, state and federal elected officials, regulators and concerned citizens to take action to address these issues before we have major nuclear radiation releases that can create permanent sacrifice zones in our communities, spread highly toxic radiation into our food supply, and disrupt our economy and transport systems.

Each thin canister contains about as much Cesium-137 as was released from Chernobyl.

There is no approved plan to remediate failed canisters once nuclear spent fuel pools are destroyed, as is the plan at San Onofre and other decommissioning nuclear reactors.

Most other countries use thick walled casks (about 10″ to 20″ thick) rather than the mostly 1/2″ thick canisters used in the majority of U.S. nuclear facilities. Thick walled casks do not have the thin canister problems.Most other countries use thick walled casks.

• The two major thick walled storage and transport cask manufacturers are Areva (TN-24 series) and Siempelkamp (e.g., Castor V/19).

• Japan uses the Areva TN-24 thick cask design. Germany uses Castor casks and Areva TN E casks.
• Other countries store their casks in reinforced buildings for additional environmental protection.
• U.S. utilities migrated to thin canisters to save money. However, long term, the thicker casks will likely save money since they do not have the thin canister problems.
• See more details with government and scientific references below and on the Nuclear Waste page.

San Onofre nuclear reactors have been shutdown since January 31, 2012 and the Nuclear Regulatory Commission (NRC) concluded Southern California Edison was at fault.  Therefore, how can we trust them to store the waste safely? 

The San Onofre shutdown resulted from decades of excessive wear in both reactors’ (Units 2 and 3) new steam generator tubes, which resulted in a steam generator radiation tube leak on Unit 3 on January 31, 2012.  The NRC concluded Edison was at fault: “…a significant design deficiency in replacement steam generators, resulting in rapid tube wear of a type never before seen in recirculating steam generators.”  In the NRC’s December 23, 2013 NRC Notice of Violation to Edison, the NRC stated: “…design control measures were not established to provide for verifying or checking the adequacy of certain designs.”

The failed steam generator multi-billion dollar boondoggle is about to be repeated with Edison’s decision to purchase the Holtec HI-STORM UMAX inferior thin canister storage system that may crack within a few years. A system that even Vermont Yankee’s utility, Entergy, considered unproven, too complex and overpriced.

The experience of other facilities substantiates the conclusion that the cost to install an underground dry cask storage system [UMAX] at Vermont Yankee would be considerably more expensive than the above ground HI-STORM 100 system. Additionally, I understand that utilities suing the U.S. Department of Energy (“DOE”) for breach of its contracts to remove spent fuel from their sites are required to take reasonable steps to mitigate the damages incurred as a result of the breach. It is therefore unlikely that the cost of a spent fuel storage system that is significantly more costly than another available alternative can be recovered from DOE. Entergy VY continues to believe that the HI-STORM 100U [UMAX] system not only would be significantly more difficult and substantially more expensive to install than the above-ground HI-STORM 100 system, but also carries significant schedule and cost risks associated with an unproven system.

The Holtec UMAX system is even worse than the other thin-wall canister systems.

Edison plans to store the UMAX system partially underground in moist corrosive soil. The system has air vents connected to pipes in the outer lid to cool the thin hot canisters. However, there are no drains for moisture, water or other debris that enters the vents and pipes (downcomers).  Water and other debris can accumulate and potentially block the opening at the bottom of the pipes and elsewhere. This can block the air flow of the cooling system. Workers are expected to put hoses down the vent holes and pump out any water or other debris. They will be exposed to some radiation, even when the canisters are not leaking from cracks. Workers will need to manually inspect the vents and pipes to determine if there is any blockage. No other thin-wall canister system or thick-wall cask system has this problem. Learn more…

All thin-wall canisters can crack, but cannot be inspected for cracks (inside or out), and cannot be repaired, maintained or monitored to PREVENT radioactive leaks.

• A Diablo Canyon canister located in a similar marine environment has all the conditions for cracking in a 2-year old canister.
• A similar container at the Koeberg nuclear plant leaked in 17 years.  
• San Onofre has 51 existing canisters and began loading them in 2003.
• The NRC ignores their own regulation by continuing to approve these.

Cracked canisters cannot be safely transported according to NRC regulations.

• NRC Regulation 10 CFR § 71.85 Packaging and Transportation of Radioactive Materials. Preliminary determinations. Before the first use of any packaging for the shipment of licensed material — (a) The certificate holder shall ascertain that there are no cracks, pinholes, uncontrolled voids, or other defects that could significantly reduce the effectiveness of the packaging.
• NRC Certificate of Compliance NUHOMS-MP197HB, Certificate 9302, April 23, 2014 (ML14114A099), Page 17, “For any DSC [Dry Storage thin-wall Canister] that has been used in storage, the condition of the DSC must be evaluated, prior to transportation, to verify that the integrity of the canister is maintained.”
• Safety Analysis Report Holtec HI-STAR 190 Package  (Revision 1), Holtec Report No. HI-2146214, June 8, 2017 (ML17166A448). The NRC used this document to justify the August 2017 approval of the Holtec HI-STAR 190 for high-burnup spent fuel. The NRC is ignoring its own safety regulations with this approval.  For example, the NRC knows there is no current technology that can inspect for cracks in canisters loaded with spent nuclear fuel, yet it approved this. To make matters worse, unloading the canister at the destination location is not part of this Safety Analysis Report (SAR).  PDF Page 23 states: Any further operations, such as unloading fuel assemblies from the MPC [Multi Purpose thin-wall canister] if that is required, and consideration of HBF [High Burnup Fuel] condition during unloading need to be performed under the jurisdiction of the location where the cask is unloaded, and is not part of this SAR. 

Edison is ignoring this data and purchased a Holtec dry storage system that cannot be inspected, repaired or maintained.  

Edison has no plans or funding to deal with leaking or cracking canisters.

Each canister contains about as much or more lethal highly radioactive Cesium-137 and other radionuclides as was released from the 1986 Chernobyl nuclear disaster.

The nuclear industry does not dispute this.  They and their nuclear advocates, such as Community Engagement Panel (CEP) Chairman, David Victor, don’t like us calling these “Chernobyl in a can”. However, their only rebut is stating it’s not a Chernobyl reactor in a can. No, but it contains the amount of lethal radionuclides released from Chernobyl that still contaminate the earth.

It is up to the public to stop this. The NRC ignores their own safety regulations, so we cannot count on them to keep us safe. Learn more and get involved. On this website you will find government and scientific sourced documents that can be used to inform others. Whether you live in California or in other states with nuclear power plants, this affects you, your family and your community.

Action: Request the Coastal Commission revoke Edison’s nuclear waste storage permit.

The California Coastal Commission voted to approve a 20-year permit to install the experimental unproven Holtec UMAX underground nuclear waste thin canister storage system at San Onofre even though they know the system has problems. Instead they added critical “special conditions” that Edison isn’t required to meet for years and it’s unlikely they can ever meet them. Also, these are unfunded conditions. Edison’s cost estimate to the California Public Utilities Commission assumes nothing will go wrong, so it has no funding to remediate problems or relocate the dry storage system on the property, as required by this Coastal permit. 

• Handout: Request Coastal Commission REVOKE Nuclear Storage Permit
• The Commission acknowledged the Holtec system cannot be inspected or maintained. The system is subject to cracking. Cracked canisters cannot be transported. Rather than requiring a system that does not have these critical flaws, they are accepting promises from Edison that these issues will be resolved sometime in the future. 
• The Coastal Commission should only approve a permit for a spent nuclear fuel storage system that can be inspected, maintained, monitored and transported.
  • If they have the authority to require these conditions in 20 years, they can require them now.
  • The Coastal Commission should not lower their standards just because Edison chose an inferior thin canister system that does not meet these critical requirements.
  • Thick metal cask storage options are available that meet Coastal Commission requirements now and can be deployed in a reasonable time frame. This is proven technology used throughout the world and in the U.S.
• Summary of Special Conditions: 
  • Special Condition 2, which authorizes the proposed development for a period of twenty years and requires SCE to return for a CDP Amendment to retain, remove or relocate the ISFSI facility, supported by:
    • (i) an alternatives analysis, including locations within the decommissioned Units 2 and 3 area;
    • (ii) assessment of coastal hazards and managed retreat;
    • (iii) information on the physical condition of the fuel storage casks and a maintenance and monitoring program; and
    • (iv) proposed measures to avoid/minimize visual resource impacts.
  • Special Condition 7, which requires SCE to submit, as soon as technologically feasible and no later than October 6, 2022, a maintenance and inspection program designed to ensure that the fuel storage casks will remain in a physical condition sufficient to allow both on-site transfer and off-site transport, for the term of the project as authorized under Special Condition 2.
  • Special Condition 3, which requires SCE to agree to not enlarge or replace the existing NIA seawall for purposes of protecting the proposed project from coastal hazards.
  • Special Conditions 1, 4, 5, and 6 which require evidence of the Applicant’s legal ability to undertake the development as conditioned by the Commission, assumption of risk, liability for attorney’s fees, and restrictions on future development.
• Coastal Commission Final Approval Documents
  • 9-15-0228 Adopted Findings Special Conditions Pages 6 – 8
  • Coastal Commission 9-15-0228 Adopted Findings without exhibits
  • Coastal Commission 9-15-0228 Adopted Findings with exhibits
  • Coastal Commission Tu14a-10-2015 Addendum to 9-15-0228 – SCE SONGS ISFSI
• The Union of Concerned Scientists endorsed the Holtec thin canister system without addressing the critical problems of the system. Holtec UMAX System email exchange with UCS Dave Lochbaum, October 2015
• Audio and transcript of March 31, 2017 phone conference with Union of Concerned Scientists (Dave Lochbaum) and others regarding dry storage systems risks.
  • Transcript 
  • Audio

Take Action

• Email Joseph.Street@coastal.ca.gov to request the permit be revoked.
• The Coastal Commission granted a 20-year permit for a system that cannot be inspected for cracks, cannot be repaired, may crack in 20 years (or sooner for existing thin canisters) and cannot be transported with cracks.  
• Tell your local and state elected officials to urge the Governor, the Coastal Commission and the CPUC to NOT allow a nuclear waste storage system to be installed that can crack, that cannot be inspected for cracks, cannot be repaired or maintained and cannot be transported. Tell them to:
  • not approve a system based on vaporware — capabilities that do not exist. It is against state government regulations to procure vaporware, so why are we allowing Edison to do this? We’ve had enough broken promises from Edison, the federal government and the nuclear industry, so we should not continue to rely on their promises of future solutions.
  • Other options are available now, but Edison refuses to consider them.
  • The NRC approves systems for 20 years even though they don’t meet these requirements.  However, it is within the states jurisdiction to require a system that is guaranteed to last decades and won’t affect our coastal resources and communities. The NRC would approve such a system, but Edison needs to ask for it.
  • Edison should be required to prove they can meet the special conditions prior to the installation of the system, not 20 year later. 
    • The Coastal Commission included “special conditions” that must be met AFTER 20 years, including ability to inspect, repair, maintain and transport.  If they have the authority to include these special conditions now, then they should require them NOW not in 20 years when it’s too late.
    • The CPUC will be making a decision on whether to give Edison the almost $1.3 billion of our limited ratepayer trust fund to install and manage this inferior system. Edison’s Tom Palmisano said Edison has no money allocated to relocate this system to higher ground as required by one of the special conditions.
• NRC Director of Spent Fuel Management, Mark Lombard, admitted to the Commissioners there is no technology to inspect or repair these systems now and only offered promises they would figure it out in the future.

• NRC’s Mark Lombard did NOT tell the Coastal Commissioners:
  • A 2-year old Diablo Canyon canister has all the conditions for cracking.
  • The Koeberg nuclear plant in South Africa had a similar component crack and leak after 17 years, due to coastal conditions (on-shore coastal winds, surf, frequent fog)
  • The EPRI report he sited saying there would be no problems for at least 30 years excluded the Diablo Canyon and Koeberg data. EPRI cherry-picked the data in that report, even though the Diablo Canyon data is EPRI data.
  • Existing San Onofre thin canisters have been loading since 2003.  This means leaks can start in 5 to 8 years.
  • The NRC only requires quarterly monitoring for radiation leaks and there is no early warning monitoring technology for thin welded canisters.
  • Thick metal casks (10″ to 20″ thick) do not have any of these problems and are transportable so could meet all the Coastal Commission conditions. They can be approved by the NRC if Edison decides to purchase them. Thick casks (Areva TN-24) were used at Fukushima and survived the earthquake and tsunami. The NRC has approved thick casks for storage and transport, such as those at Prairie Island (TN-40). Others in U.S. using thick casks for storage: North Anna (TN-32), McGuire (TN-32), Surry (TN-32, Castor V21 and X33, and Peach Bottom (TN-68).
  • The method used to inspect empty thin canisters for cracks (putting a fluid dye inside the canister) will not be one of their solutions. All the other inspection technologies, even if they find a way to do them, will not be sufficiently reliable.
  • The Holtec UMAX system approved by the NRC is different than the design planned for San Onofre. However, Lombard said they only plan to review the changes and inspect it after it is built.
    • Letter to Coastal Commission – Holtec UMAX not approved for San Onofre, D. Gilmore, September 17, 2015
    • Letter from former NRC Inspector to Coastal Commission – why application should be rejected
• Our decision makers should question the credibility of those who support installation of a system that can crack, that cannot be inspected, repaired, maintained, or transported with cracks, and are willing to recommend vaporware.  See Coastal Commission Addendum that includes correspondence from those supporting and opposing this system. Notice the inadequate justification for those that support this system.
  • The Coastal Commission staff report identified these critical problems. However, it was clear from the “likely impossible to meet” special conditions and setting the scope of review to only 20 years, that this decision was made above their level.

• Send copies of your comments to Joseph.Street@coastal.ca.gov. Reference Coastal Application 9-15-0228, Southern California Edison Company, Construct and operate an Independent Spent Fuel Storage Installation (ISFSI) to store spent nuclear fuel from SONGS Units 2 and 3.
• Coastal Commission related documents
  • Letter To Coastal Commission – deny permit, October 5, 2015
  • Coastal Commission staff report recommending conditional approval
  • Addendum to 9-15-0228 – Southern California Edison SONGS ISFSI Project
  • Coastal Commission March 19, 2015 staff letter asked Edison great questions. Where are the answers?
  • Letter from former NRC Inspector to Coastal Commission – why application should be rejected
  • Letter from former NRC Inspector (Scott Atwater) to NRC – why Holtec UMAX should not be approved for San Onofre
  • Letter to Coastal Commission – Holtec UMAX not approved for San Onofre, D. Gilmore, September 17, 2015
  • Waste storage alternatives exist now that meet Coastal Act requirements, presentation, D. Gilmore, October 6, 2015
  • Holtec HI-STORM UMAX Dry Storage System details
  • SCE alternatives site analysis, May 2015
    • Recommends San Onofre sites that do not require public hearings
    • Identifies major obstacles to relocating fuel off San Onofre and recognizes fuel may need to stay here indefinitely.
    • Recommends San Onofre sites that do not require additional environmental and seismic analysis or review.
    • Doesn’t mention that even though a NRC general license for the ISFSI site allows them to store fuel without a public hearing and NRC prior approval, they still need a licensed product and must following the technical specifications of that license and perform a site specific analysis.  The proposed Holtec UMAX system does not meet NRC approved technical specifications. The NRC plans to inspect the system before fuel is loaded to ensure it complies with the technical specifications — however, this is AFTER it is built. See Holtec UMAX not approved for San Onofre.

Below is the proposed location for the Holtec HI-STORM UMAX thin “underground” spent fuel canister system at San Onofre. Half under ground, and close to the water table and about 100 feet from the ocean. Edison admits the Sea Wall hasn’t been maintained so can’t be counted on for protection. This plan doesn’t meet Coastal Act requirements, but Coastal Commission staff think there are no other options, but there are.

Presentation to the Coastal Commission on why they should deny the Coastal Permit, Donna Gilmore, October 6, 2015

Slides from Donna Gilmore October 6, 2015 Coastal Commission presentation

• The Coastal Commission should not approve vaperware (technology that doesn’t exist) nor make decisions based on unsubstantiated hope.
  • Coastal Commission staff recommend kicking the can down the road and approving the permit with the condition that Edison will figure out how to inspect, repair and maintain this inferior system after 20 years.
  • Would you buy a car that cannot be inspected, maintained, repaired and has no early warning system before the car fails?  That is what the Coastal Commission is allowing if they approve this Coastal Development Permit.
  • Edison claims they can relocate the system to another spot a few feet away if the coast erodes and the sea rises. That would cost hundreds of millions of dollars with the current Holtec system (it must be rebuilt) and we all know who will pay for that. Edison plans to spend all the Decommission Trust Fund money and they have not allocated any funds for this.
• The Coastal Commission should require Edison have a ready plan for existing canisters that may leak in as little as 5 years and not allow over 20 years before Edison must have an approved plan.
• Thick casks are the solution. 
  • Thick casks don’t crack and are up to 20″ thick compared to the Holtec thin (5/8″ thick) thin canisters. Edison can choose thick casks, if the Coastal Commission rejects their inadequate application.  
  • Thick casks are designed for longer term storage and transport and can be inspected, maintained and monitored and have proved reliable for over 40 years.
  • Edison refused to allow bids from thick cask vendors. Vendors will not apply for an NRC license unless they have a customer. Edison needs to be that customer.
• Commission staff admit the tons of nuclear waste may be here for decades or longer.
• San Onofre fuel must cool for 25 to 45 years before it can be transported to another facility. For example, the chart below shows 37 fuel assembly canisters must be cooled (wet or dry storage) for 45 years before they can be safely transported.

• Proposed consolidated interim sites require federal legislation and funding and have many other obstacles, so it’s critical we have the best available storage technology until the waste can be moved.

• Read and share detailed comments submitted to Coastal Commission.
• Waste storage alternatives exist now that meet Coastal Act requirements DGilmore, October 6, 2015

Why when the Coastal Commissioners know these canisters cannot be inspected and are subject to cracking would they approve a Coastal Permit? Listen to Commissioner Shallenberger grill NRC Director Lombard:

 

Are California and other U.S. nuclear spent fuel waste canisters cracking?

No one knows because there is no technology to inspect or repair cracks in thin stainless steel canisters filled with spent nuclear fuel waste. (Share handout)

San Onofre canisters could start leaking radiation in 5 years (2020), if San Onofre canisters have a failure similar to a Koeberg nuclear power plant component. San Onofre started loading canisters with spent fuel in 2003.

The Nuclear Regulatory Commission (NRC) reported a similar component at the Koeberg Nuclear Plant cracked and leaked in 17 years. The crack was deeper than the thickness of most U.S. thin canisters. Other factors can also cause canisters to crack and leak. More…

Koeberg is located in a similar corrosive marine environment as San Onofre and Diablo Canyon: on-shore winds, surf and frequent fog.  The Koeberg container had cracks up to a depth of 0.61″. The San Onofre canisters are only 0.625″ thick. The canisters at other California locations, such as Diablo Canyon, are even thinner (0.50″). There are over 2000 loaded canisters in the U.S. Most are 1/2″ (0.50″). More…

The President of Holtec, Kris Singh, says it’s not feasible to repair thin steel canisters. He states even a microscopic crack will release millions of curies of radiation into the environment. In addition, the NRC and their concrete experts state the concrete base of underground storage system are at higher risk of failure (due to moisture and soil chemistry) and are challenging to inspect.

Southern California Edison, PG&E and other U.S. utilities have no adequate plans to replace cracked canisters and monitoring system only alerts us after canisters leak radiation into the environment. The only proposed “solution” is to put the cracked canister into a thick cask, with no plan of what to do with it next.  There is no NRC approved cask design or procedure for this purpose. It would not solve the problem of needing to replace canisters in case of failure or to meet current Department of Energy (DOE) and Nuclear Regulatory requirements. Cracked canisters are not approved for transport.

Edison plan to spend almost $1.3 billion of ratepayer funds to store and manage 1680 metric tons of San Onofre nuclear waste in thin 5/8” steel canisters that may crack within 20 years after loading.  Their $1.3 billion plan assumes no canister will fail. And they want us to buy vaporware — a product with a vendor promise of a future solution for finding and measuring cracks. Even if they manage to find a solution, there is still no repair solution and nothing to stop them from cracking.

The NRC’s plan is to allow up to a 75% crack in these thin canisters. even though the vendors have no way to locate and measure cracks and there is no seismic rating for cracked canisters. The NRC assumes nothing will go wrong in the first 20 years, and consider “out of scope” anything that may happen after that when they approve the first license. They assume the vendors will eventually solve these problems before these canisters fail. They approved a license renewal for Calvert Cliffs Independent Spent Fuel Storage Facility (ISFSI) in spite of their inability to find cracks in canisters loaded with nuclear fuel.  See August 21, 2015 comments submitted to the NRC on their proposed aging management plan in (NUREG-1927 Rev. 1). The NRC has hidden comments from public view (Docket ID NRC-2015-0106).

The unproven experimental Holtec UMAX underground storage system Edison plans to buy has never been used or tested anywhere in the world and has not yet been approved for high seismic areas. Missouri Callaway nuclear power plant installed the underground system recently. Tentative first spent fuel loading is July 2015. The thin welded canisters are to be inserted in steel lined concrete holes. The unsealed thick top lids have air vents, so the thin canisters and spent nuclear fuel waste do not overheat.

The NRC approved a Holtec license amendment to use the Holtec HI-STORM UMAX system in high seismic risk areas effective September 8, 2015. However, it is not approved for any specific site, including San Onofre; that requires additional approvals. And they are only certified safe for 20 years. Any issues that may occur after 20 years are not considered by the NRC, even though they know they must last for decades and they do not have aging issues resolved. See more details below and on Nuclear Waste page.

• Holtec International HI-STORM UMAX Canister Storage System, Certificate of Compliance No. 1040, Amendment No. 1 Direct Final Rule, Federal Register Vol. 80, No. 173, pp 53691 – 53694, effective September 8, 2015
• Letter To Coastal Commission regarding Holtec UMAX NRC approval, September 18, 2015, outlines the limitations of the approval:
  • Excludes site approval, such as San Onofre. This requires additional approvals.
  • Certified safe for only the initial 20 years. Ignores aging management issues.
  • Excludes any plan for storing failed (cracking) canisters. No vendor casks have been approved for storing or transporting failed canisters and no vendor has submitted an application for this purpose.
  • Approved for 0.5” thick canisters – not the 0.625” thickness San Onofre proposes. The NRC has not received a License Amendment Request from Holtec for the 1/8″ thicker canister design. This process can take up to 18 months.
  • The underground system design certified is different than the system design proposed for San Onofre. The San Onofre design is only partially underground.

.The Nuclear Regulatory Commission (NRC) licensed the Holtec UMAX system effective April 6, 2015, for low seismic areas, for 20 years, by ignoring known aging problems that may occur after 20 years. The NRC required additional seismic analysis and conditions before approving the License Amendment for high seismic risk areas. The NRC has a history of approving nuclear power plants and storage canisters in high seismic areas, such as Diablo Canyon in San Luis Obispo County. And the NRC only requires evaluation of seismic risk on intact canisters, not canisters that may be cracking. More…

Conditions for cracking were found on a Diablo Canyon canister in service for only two years. No one knows if it is cracking due to the inability to inspect for cracks, but they know it has all the conditions to initiate cracks. The Diablo Canyon nuclear power plant is located near the Pacific Ocean in San Luis Obispo County.  Salt in marine environments can corrode these stainless steel canisters and leads to “chloride-induced stress corrosion cracking.” Numerous other environmental factors can corrode thin steel canisters and their concrete overpacks, but the NRC has not fully evaluated these yet. More…

The thin canister vendors, nuclear industry and utilities, and others ignore the Diablo Canyon and Koeberg data when they make unsubstantiated claims these canisters will last. They will claim they are not aware of any cracking problems.  That’s because they do not have technology available to inspect for cracks or to measure crack depth.  More…

Other countries use casks up to 20″ thick that don’t crack and that are transportable without the need to buy an additional transport cask, which the thin canisters require.

Take action now

• Share handouts
  • Reasons to buy thick nuclear waste dry storage casks and myths about nuclear waste storage, April 16, 2015
• Propose City Council Resolutions (see samples and handouts)
• Contact us to become more active
• Make presentations or host presentations
  • Dry Storage of Spent Nuclear Fuel Problems and Solutions, Donna Gilmore, May 17, 2015
• Sign petition to STOP California from wasting million on inferior thin nuclear waste storage canisters that may crack within 30 years, and have no adequate method for inspection, repair or replacement. NOTE: Edison’s revised estimate to the CPUC for spent fuel storage and management is almost $1.3 billion dollars ($1,276,196,000). This assumes the Department of Energy will start taking the waste in 2024. However, Edison has provided no data to support this unlikely date. It also assumes the canisters will never crack and will never need to be replaced even though the NRC says the waste may be here indefinitely.

Current Regulatory Actions

• Nuclear Regulatory Commission (NRC)

  • Edison submitted an NRC License Amendment Request on August 20, 2015 to lower safety standards for spent fuel pool cooling.
  • San Onofre Nuclear Generating Station Units 2 and 3 – Review of Post-Shutdown Decommissioning Activities Report (TAC NOS. MF4892 AND MF4893), ML15204A383, August 20, 2015
    • The NRC staff finds that the schedule for decommissioning activities is adequate to achieve SONGS, Units 2 and 3, license termination within 60 years of permanent cessation of operations (June 2013), as required by 10 CFR 50.82(a)(3).  However, the NRC considers out of scope of this review “questions or comments about the performance, design requirements, and the availability of inspection and repair methods of spent fuel storage casks previously certified or under review by the NRC (Note: these issues are addressed during NRC’s licensing of the spent fuel storage casks, or during cask license renewal).”
  • San Onofre Nuclear Generating Station, Units 2 and 3 – Review and Approval of the Irradiated Fuel Management Plan (TAC NOS. MF4894 AND MF4895), ML15182A256, August 19, 2015
    • The NRC staff finds the SONGS IFMP estimates to be reasonable, based on a cost comparison with similar decommissioning reactors, while acknowledging that there are large uncertainties and potential site-specific variances that may impact these cost estimates in the future.
    • The NRC staff has determined that storing fuel in either the spent fuel pool or ISFSI represents an acceptable means for storing irradiated fuel. The licensee’s plan contains both storage methods, with irradiated fuel being taken out of the spent fuel pool and fully transitioned to the ISFSI within 5 years, followed by complete dry storage.
    • The anticipated date to transfer fuel to DOE and subsequent decommissioning of the ISFSls are scheduled to be completed in 2051. This supports the requirement to complete decommissioning within the 60-year timeframe, as required by 10 CFR 50.82. [This schedule assumes there will be a place to start sending this fuel by 2024, which Edison’s own witness said was “unknowable” and unlikely].  It also assumes fuel assemblies will not need to be reloaded into DOE approved casks. Current DOE standard contract requires this.
  • Holtec HI–STORM UMAX Canister Storage System Amendment No. 1 provides a
    seismically enhanced version of the HI–STORM UMAX Canister Storage
    System. Certificate of Compliance (CoC) No. 1040. Amendment No. 1 will be effective September 8, 2015 unless significant adverse comments are received by July 23, 2015.  Comments after this date will be considered if it is practical to do so. Reference Docket ID NRC–2015–0067. See comments submitted by SanOnofreSafety
  • Make comments to the NRC on Edison’s decommissioning plan Docket NRC-2014-0223 via email to carol.gallagher@nrc.gov. Include Docket No. NRC-2014-0223 in subject line. For sample comments,  see Comments submitted by SanOnofreSafety.org
    • ML14269A033 – San Onofre Units 2 and 3 Post-Shutdown Decommissioning Activities Report (PSDAR). (36 pages), 9/23/2014
    • ML14269A034 – San Onofre Nuclear Generating Station, Units 2 and 3, Site Specific Decommissioning Cost Estimate. (93 pages), 9/23/2014
    • ML14269A032 – San Onofre Unit 2 and 3 Irradiated Fuel Management Plan (IFMP), (12 pages), 9/23/2014
    • Comments submitted by SanOnofreSafety.org, December 22, 2014

• California Public Utility Commission (approves funds)

  • Read testimony, and transcripts of August 25 – 27, 2015 evidentiary hearings.
  • CPUC Scoping decision by Commissioner Florio, April 22, 2015
    • Specifically, the Commission must determine if the applicants have
      justified the Nuclear Decommissioning Cost Estimate, the proposed adjustments
      to contributions to the Nuclear Decommissioning Trust, and processes for annual
      review of decommissioning cost expenditures.
    • Edison must also justify its proposed balancing account for unanticipated decommissioning costs, and SDG&E its share of the decommissioning costs and proposed revenue requirement. 
    • The reasonableness of the Nuclear Decommissioning Cost Estimates does
      not include operational decisions, such as vendor selection or equipment
      specifications, but does include the soundness of cost assumptions and
      contingency planning.
    • Schedule for San Onofre Decommissioning Proceeding (A1412007)
      • Applicants serve supplemental testimony –  May 11, 2015
      • Intervenor Testimony served – July 15, 2015
      • Rebuttal Testimony served – August 3, 2015
      • Evidentiary Hearings – August 25, 26, and 27, 2015
      • Opening Briefs – October 15, 2015
      • Edison response to Gilmore brief – October 20, 2015
      • Reply Briefs – November 5, 2015
  • CPUC Pre-hearing conference video, April 2, 2015  [Gilmore comments start at 40:25]
  • Donna Gilmore’s Pre-Hearing Conference Statement (A1412007), March 20, 2015
  • Joint Application of Southern California Edison Company (U 338-E) and 
    San Diego Gas & Electric Company (U 902-E) for 2014 SONGS Units 2 & 3
    Decommissioning Cost Estimate and Related Decommissioning Issues, December 10, 2014 (A1412007)
  • SCE Testimony on the Nuclear Decommission of SONGS 2 & 3, December 10, 2014 (A1412007)
  • Response to CPUC regarding San Onofre Decommissioning Plan and Costs (A1412007), January 9, 2015, submitted by SanOnofreSafety.org
  • CPUC San Onofre decommissioning proceeding information. Enter A1412007

• California Energy Commission (CEC) (sets energy policy)

  • California’s Nuclear Waste Problems and Solutions slides, D. Gilmore, April 27, 2015
  • Notice to Consider Adoption of Final 2014 Integrated Energy Policy Report Update Docket No. 14-1EP-1 February 25, 2015 10 a.m., Sacramento.
  • Comments submitted to the CEC by SanOnofreSafety.org, February 6, 2015
  • 2015 Integrated Energy Policy Report – make comments by 5/11/2015
    • Suggested comments: Recommendations to CEC Docket 15-IEPR-12 Nuclear Power Plants

• California Coastal Commission (enforces Coastal Act)

  

  Otters 4077 Cleve Nash

  • Edison submitted an NRC License Amendment Request on August 20, 2015 to lower safety standards for spent fuel pool cooling so they can install a air-chiller system that doesn’t meet nuclear grade standards, including earthquake standards. At the August 13, 2015 Coastal Commission meeting, the Coastal Commission approved a permit for this cooling system. However, it was based on assurances from Commission staff and Edison that it met high seismic standards. Therefore, this decision should be reversed.
  • August 13, 2015 Coastal Commission meeting, 9 am, 276 Fourth Ave, Chula Vista, CA
    • Hearing Notice – Application No. 9-15-0162 Southern California Edison application to install independent cooling system, known as “Spent Fuel Pool Island” (SFPI) and replace existing once-through ocean water cooling system serving Units 2 & 3 spent nuclear fuel pools at San Onofre
    • Staff Report and Recommendation for use of experimental air chillers (similar to fish aquarium chillers) to cool the spent fuel pool water. Air chillers have never been used for this demanding application.
    • Addendum to Staff Report 9-15-0162 – SCE SONGS (large file)
      • Provides correspondence on the above-referenced staff report, ex parte communications, proposed revisions to the staff report, and staff’s response to comments.
    • Spent Fuel Pool Island Project
    • SanOnofreSafety Comments on CCC SFPI Staff Recommendation
      • Letter To Coastal Commission – Chillers, 8/9/2015
      • Additional Letter To Coastal Commission – Chillers , 8/11/2015
    • SCE Comments on CCC Staff Recommendations
      • SCE SFPI Comments Staff Report Letter, 8/7/2015
      • SCE SFPI Comments Staff Report Table 8/6/2015
  • Video: Why Coastal Commission should deny permits for Holtec dry cask storage system and for use of air chillers to cool spent fuel pools, May 14, 2015 
  • Videos: May 14, 2015 and other Coastal Commission meetings
  • Letter opposing Coastal Permit Waiver to Convert Spent Fuel Cooling System to chillers, May 14, 2015
  • Proposed Coastal Permit Waiver to Convert Spent Fuel Cooling System to chillers (No. 9-15-0162-W), April 27, 2015
  • Proposed Coastal Permit Waiver to replace SONGS current salt water cooling pumps with smaller dilution pumps, install 2 chillers that are not dependent on ocean water cooling, and reroute an effluent discharge pipe (No. 9-15-0417-W), May 4, 2015

Other Handouts

• Reasons to buy thick nuclear waste dry storage casks and myths about nuclear waste storage, January 30, 2015
• San Onofre’s Decommissioning Plan is not what it’s cracked up to be, October 27, 2014
• Diablo Canyon: conditions for stress corrosion cracking in 2 years, October 23, 2014 Implications for San Onofre and other nuclear plants.
• San Onofre Dry Cask Storage Issues, September 23, 2014
• Petition on Dry Cask Storage for CPUC Action
• San Onofre Dry Cask Storage Recommendations Summary, September 14, 2014
• Presentation: Dry cask storage – We cannot kick this can down the road, D. Gilmore, January 2015,

 Reports and other Documents

• Response to CPUC regarding San Onofre Decommissioning Plan and Costs (A1412007), January 9, 2015
• San Onofre Dry Cask Storage Issues, D. Gilmore, September 23, 2014
• Myths about Continued Storage of San Onofre Used Nuclear Fuel, D.Gilmore, January 2, 2015
• Premature failure of U.S. Spent Nuclear Fuel Storage Canisters, CPUC action needed, August 20, 2014
• Letter to Edison regarding dry cask storage system decision, August 24, 2014
• Dry Cask Storage Recommendations to Edison’s Community Engagement Panel (CEP), July 17, 2014
• High Burnup Nuclear Fuel — Pushing the Safety Envelope, January 2014
• NRC Press Release: August 26, 2014, NRC Approves Final Rule on Spent Fuel Storage and Ends Suspension of Final Licensing Actions for Nuclear Plants and Renewals
• NRC decision for indefinite on-site continued storage of nuclear waste

Issues

San Onofre’s nuclear reactors are shut down. However, thousands of metric tons of radioactive nuclear waste, such as Cesium-137 will remain in California for decades. San Onofre’s spent fuel contains 89 times the amount of Cesium-137 released from Chernobyl.  The waste is not safely stored, putting us at risk for a major nuclear disaster. Please read these facts and share the information. The facts are from the Nuclear Regulatory Commission (NRC) and other government and scientific sources.  More…

The (1/2 – 5/8 inch) thin stainless steel canisters storing radioactive nuclear waste at U.S. nuclear power plants may fail within 30 years. There is no current replacement plan.  Waste may need to be stored at nuclear plants sites for over 100 years. Once canisters are loaded with waste, they are no longer inspected for aging or monitored for helium leaks. These are just some of the problems with U.S. dry storage  systems. More…

1/24/2015 San Luis Obispo presentation slides

11/19/2014 NRC presentation slides

This is SanOnofreSafety.org founder Donna Gilmore’s presentation to the NRC on dry cask nuclear waste storage issues, delivered by invitation as part of an NRC Regulatory Conference held Nov. 19-20, 2014 in Rockville, Maryland. Why are the NRC and Southern California Edison favoring inferior, short-lived, thin-walled, unsafe stainless steel canisters to store San Onofre’s tons of nuclear waste in a corrosive seaside environment instead of the long-lasting, thick-walled, top-of-the-line technology available?

Gilmore presents a strong case for regulators and utilities to take the lead in setting the highest possible standards for America’s growing inventory of radioactive waste that will remain deadly for hundreds of thousands of years longer than human civilization has yet existed. With no safe long-term storage sites having been found despite over half a century of attempts to find them, Gilmore urges officials not to ‘play bureaucratic roulette’ with the future of California and the rest of the nation.

Thanks to EON3 for producing this video.  EON3 is a non-profit organization that can use your help to support producing more videos like these.  Please donate to EON3 here.

Nuclear industry vendor, Areva, admits to having no answer to replacing failed nuclear waste storage canisters once spent fuel pools are destroyed. NRC admits to no current method to inspect for cracks in nuclear waste canisters.

Link to the full November 19-20, 2014 NRC Regulatory Conference

HIGH BURNUP FUEL: San Onofre and other U.S. reactors switched to more dangerous high burnup nuclear fuel over a decade ago. High burnup fuel is low enriched uranium that has burned longer in the reactor than lower burnup fuel.

It’s hotter and over twice as radioactive as lower burnup fuel and unpredictable and unstable in storage and transport. The protective Zirconium fuel cladding is more likely to become brittle and shatter.  

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The San Onofre Nuclear Power Plant has the worst safety complaint record of all U.S. nuclear reactors according to Nuclear Regulatory Commission (NRC) safety allegation data. See charts for details. Employees are retaliated against for reporting safety problems. See Safety Allegations Section for details on this and other safety complaints by employees and others. More…

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The San Onofre Nuclear Power Plant has the worst safety complaint record of all U.S. nuclear reactors according to Nuclear Regulatory Commission (NRC) safety allegation data. See charts for details. Employees are retaliated against for reporting safety problems. See Safety Allegations Section for details on this and other safety complaints by employees and others. More…

San Onofre nuclear fuel waste can explode if fuel is exposed to air. The majority of spent nuclear fuel at San Onofre falls into the danger zone as shown by the yellow in this Waste at SONGS chart.  Moderate and high burnup fuel increases damage to the zirconium fuel cladding (rods) and the uranium pellets. The zirconium and uranium develop metal hydrides. When combined with air, through-wall cracks in the canisters can result in hydrogen gas explosions.  See  comments to NRC Draft NUREG-2224  High Burnup Storage and Transport

Southern California Edison wanted to restart the Unit 2 nuclear reactor without fixing the defective steam generators. Both reactors have been shut since 1/31/2012, when Unit 3 leaked radiation into the environment. All four poorly designed replacement steam generators show decades of tube wear after less than two years of installation — the worst in the nation.  

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The NRC concluded Southern California Edison was at fault.  “…a significant design deficiency in replacement steam generators, resulting in rapid tube wear of a type never before seen in recirculating steam generators.”   In the NRC’s 12/23/2013 NRC Notice of Violation, they stated: “…design control measures were not established to provide for verifying or checking the adequacy of certain

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California has excess power without California’s unreliable nuclear power plants, even during peak summer months, according to California government documents. There should be no power problems with San Onofre shut down, even during the summer. And the California ISO’s electricity grid  Transmission Plan says there will be no grid stability concerns with San Onofre shut down. More…

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The San Onofre and Diablo Canyon nuclear plants kill millions of fish and other marine life every year, due to their once-through cooling (OTC) systems. The Federal Clean Water Act §316(b) regulations declared OTC illegal. However, California is allowing both plants to continue OTC for years.  More….

 

 

 

 

Artwork: Jessica deStefano

“If the NRC does not do its job, the American people will demand the ultimate protection – the shutdown of old nuclear power plants…”, says Senator Barbara Boxer to NRC Commissioners

 

Four NRC Commissioners undermine safety. Former Rep. Darrell Issa appears to support them.

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A nuclear meltdown at San Onofre would poison the nation’s food supply, create permanent “dead zones” and create financial ruin around the nation. If you live within 50 miles of San Onofre, you are at even higher risk of losing everything you care about here.  Five counties are within the 50 mile zone: Los Angeles, Orange, Riverside, San Bernardino and San Diego.

The NRC lowers safety standards to keep old plants running. More…

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There is no safe level of radiation, according to the National Academy of Sciences. Children, unborn babies and women are more susceptible to the effects of radiation. Ingesting radiation is extremely dangerous. More…

Photo of children tested for radiation near Fukushima Daiichi nuclear plant in Japan (Kim Kyung-Hoon/Reuters)

What if the Fukushima nuclear fallout crisis had happened in California? These radioactive plumes from severe nuclear accidents were calculated by NRDC based on the actual weather patterns of March 11-12, 2011. The result on any given day will vary according to the type of reactor accident and on the prevailing weather patterns at the time. These plumes artificially extend only to 50 feet. Winds can carry them further.  See NRDC interactive U.S. map.

 Actions 

Radioactive Cesium from Japan was found in tuna in San Diego. Kelp along the Orange County coast contained Fukushima radiation. Radiation monitoring is inadequate. Government resources and priorities for radiation monitoring are too low to protect us.  More…

The Fukushima Daiichi nuclear disaster continues and radiation from Fukushima has traveled to the U.S., yet limited radiation data is available to the public. See NRC Fukushima Lesson’s Learned for status of what the NRC and U.S. reactors are doing [or not doing] to avoid similar problems.

160 Mile Wind Pattern Map near San Onofre

This map shows the wind rose from the January 2011 San Diego County Nuclear Emergency Response Plan superimposed over the 160 mile evacuation zone contemplated by the former Prime Minister of Japan Naoto Kan and his nuclear experts in the early days of the triple meltdown at Fukushima Daiichi in March 2011 when TEPCO was about to abandon the out of control power plant.

“If the NRC does not do its job, the American people will demand the ultimate protection – the shutdown of old nuclear power plants…”, says Senator Barbara Boxer to NRC Commissioners

 

Four NRC Commissioners undermine safety. Rep. Darrell Issa appears to support them.

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• • SanOnofreSafety.org (SOS)
  • www.SanClementeGreen.org
  • www.SanOnofre.com
  • www.AceHoffman.org
  • Coalition to Decommission San Onofre
  • Coalition For Responsible Ethical Environmental Decisions (CREED)
  • SOS Laguna Woods
  • SOS Solana Beach

Thanks

Southern California Edison decided to decommission the San Onofre nuclear reactors on June 7th, 2013, after the NRC’s Atomic Safety and Licensing Board said restarting the Unit 2 reactor would be a nuclear experiment.  

Thanks to Kendra Ulrich, Shaun Bernie, Damon Moglen and S. David Freeman with Friends of the Earth; Arnie and Maggie Gundersen, Fairewinds Associates; Dan Hirsch, Committee to Bridge the Gap; Senator Barbara Boxer; and California concerned citizens, elected officials and others who vigilantly fought Southern California Edison and the Nuclear Regulatory Commission to allow the truth to prevail.  And a special thanks to the concerned citizens who contributed millions of dollars to help keep Southern California safe from a nuclear disaster.