Premature failure of U.S. spent nuclear fuel storage canisters

Stress Corrosion Cracking NRC Slide2 2014-07-14

Component failure observed in 11-33 years. NRC 7/14/2014

The California Public Utilities Commission (CPUC) should delay funding the new San Onofre dry cask storage system until Southern California Edison provides written substantiation that the major problems identified below are resolved.

Sign petition to STOP California from wasting $400 million on inferior nuclear waste storage canisters.

Print version: Premature Failure of U.S. Spent Nuclear Fuel Storage Canisters 8/28/2014

San Onofre’s Chief Nuclear Officer, Tom Palmisano, told the California Senate Energy, Utilities and Communications Committee on August 12th that Edison plans to decide in August or September on a dry cask system vendor.

  • The dry cask systems Edison is considering may fail within 30 years or possibly sooner, based on information provided by Nuclear Regulatory Commission (NRC) technical staff.
  • There is no technology to adequately inspect canisters.
  • There is no system in place to mitigate a failed canister.
  • Edison should consider other dry casks systems that do not have these problems.

Edison created an artificial date of June 2019 to have all the spent fuel assemblies loaded into canisters. We do not need to rush into another “steam generator” like boondoggle. Edison’s Tom Palmisano told the California Senate Energy, Utilities and Communication Committee on August 12th that issues regarding high burnup fuel and dry cask storage have been addressed. However, these issues have not been resolved.

Canisters may need to be replaced within 30-42 years or sooner. 

NUHOMS 32PTH canister

NUHOMS canister

Recent information provided by the NRC technical staff indicates dry storage canisters may need to be replaced within 30-42 years or sooner, due to stress corrosion cracking of the thin (1/2 to 5/8 inch) stainless steel canisters (due to our coastal environment). Similar stainless steel materials at nuclear plants have failed within 16 to 33 years.  The concrete overpacks also have aging issues that are accelerated in coastal environments.

Southern California Edison has budgeted $400 million dollars for the dry storage system. As Commissioner Florio stated after the recent CPUC meeting in Costa Mesa, “We don’t want to have to buy these again.”

No remediation plan to repair or replace failed canisters.

The NRC stated that if one of the canisters becomes defective (e.g. 75% through-wall stress corrosion cracks), there is no way to repair or replace the canister; especially if the spent fuel storage and transfer pools are demolished, as Edison plans to do. And before a canister can be transported (inside a transport cask), the canister must not have cracks.

No technology to adequately inspect canisters for stress corrosion cracking.

Intergrain Stress Corrosion Cracking

Stress Corrosion Crack

The NRC states technology does not exist to adequately inspect steel canisters for stress corrosion cracks or to measure how or when the cracks will go through the wall of the canister. They plan to allow the nuclear industry 5 years to try to develop technology. And then they only plan to require inspection of one canister at each nuclear plant.

No license renewals until aging management issued addressed.

The NRC is in the process of developing an aging management plan due to the new requirement that dry storage systems need to last 100 to 300+ years. They are delaying license renewals until unresolved aging management issues can be addressed. However, they plan to allow the NUHOMS 32PTH2 canister that Edison may procure to be included in an existing license. The NRC is evaluating how long dry storage systems will last. Previously, they only needed to last 20+ years with the assumption there would be a permanent repository.

No canisters approved for high burnup fuel for more than the initial 20 years.

Cross Section Fuel Rod Significant Radial Hydride Orientation DE-NE-0000593

High burnup fuel cladding damage

The NRC has not extended licenses past the initial 20 years for storage of high burnup fuel (>45GWd/MTU) due to unknowns about high burnup fuel in storage and transport. This fuel is over twice as radioactive and hotter than lower burnup fuel.  The NRC has allowed nuclear plants to burn fuel longer, without the research to show that it is safe in storage and transport. The protective fuel cladding can become brittle and crack; resulting is higher risk for radiation exposure, if the canisters fail.

NUHOMS dry canister license certification expires in less than nine years.

The NUHOMS DSC-32PTH2 canisters that Edison wants to procure are not yet licensed by the NRC. If approved, the license will expire in less than nine years (February 5, 2023), since Areva-TN decided to avoid a new license certification and include it in their existing license for the DSC-24PT series, which has a different design.

New design of the NUMHOMS DSC-32PTH2 eliminates failed fuel cans.  

Unlike the existing 24 fuel assembly canisters, the new 32 fuel assembly canisters have no provision for Failed Fuel Cans. This means damaged fuel assemblies (of which San Onofre has many) cannot be used in the DSC-32PTH2 canisters. The NRC and DOE require fuel assemblies to be retrievable so they can be transferred to other containers. The Failed Fuel Cans met this requirement.


On July 14th, 15th and August 5th the NRC had public meetings to address aging management issues with dry cask storage system. Their goal is to require an aging management plan before relicensing or issuing new licenses, now that the NRC knows on-site or interim dry cask storage will be needed for up to 300 years or more. The NRC stated the earliest date for a permanent repository is 2048 and that is optimistic. They are researching on-site and interim dry cask storage requirements for 40,100, 150 and 300+ years.

No NRC canisters are certified for extended storage or for geological repository storage. Canister licenses for the more dangerous and unstable high burnup (>45GWd/MTU) spent fuel have not been renewed for more than the initial 20 year license, even for expired licenses. And the NRC’s Bob Einziger states there are still transportation problems with high burnup fuel.

NRC staff plan to have a draft for public comment regarding dry cask storage relicensing by the end of 2014, according to Mark Lombard, Director, Division of Spent Fuel Storage and Transportation. However, this will not address our current issues.

Stainless Steel Dry Canister Problems

NRC 08-05-2014 Slide 9 Power Plant with SCCDarrell Dunn, an NRC materials engineer, stated stainless steel dry storage canisters are vulnerable to failure within about 25 – 42 years. If any of the fuel cladding in the canister fails, there is no protective barrier and we could have a serious radiation release.

The NRC said they have no current mitigation plan for that consequence.  They suggested we MIGHT be able to put the fuel back in the spent fuel pool.  However, Edison plans to destroy the spent fuel and transfer pools. And there is no technology to repair the canisters. The NRC said they HOPE there will be a solution for mitigation in the future. Even an NRC May 2nd High Burnup Fuel letter admits there are mitigation problems.

No Inspections of Stainless Steel Canisters

Unknown conditions on actual spent fuel storage canisters

EPRI 2012 presentation

To make matters worse, these stainless steel canisters are not inspected after they are loaded into the unsealed concrete overpacks (Areva NUHOMS) or concrete casks (Holtec and NAC Magnastor).  The NRC proposed having each nuclear plant inspect the outside of only ONE stainless steel canister before they receive a license renewal and then do that once every 5 years.  The industry balked at having to even check one canister at every plant. The problem with the stainless steel canisters is they do not protect against gamma rays; so it’s not a simple task to remove a canister from the concrete overpack/cask to examine the exterior for corrosion or other degradation. And since welded canisters do not have monitoring for helium leaks, we may not have any warning of an impending radiation release.

Concrete Overpack Corrosion Problems

Concrete Aging Effects NRC 7/14/2014

Concrete Aging Effects NRC 7/14/2014

Darrell Dunn discussed serious corrosion problems with the concrete overpacks/casks, especially in coastal environments.


Ductile Cast Iron Casks may be a better solution

Castor-V-19 cask

Asked if San Onofre would be better off using ductile cast iron casks like the CASTOR, due to our coastal environment, Aladar (Al) Csontos, NRC Branch Chief in the Division of Spent Fuel Storage and Transportation (SFST), said that might be a better option near the ocean. Casks, such as CASTOR, may eventually have aging issues with bolts and seals. The CASTOR has double sealed lids, so even if one fails, we’ll still have a sealed canister. And Edison would be able to easily monitor for cask material degradation with all the casks.

The NRC licensed the CASTOR V/21 ductile cast iron cask years ago and the cask is still in use. In fact, a CASTOR V/21 was used to prove low burnup fuel is safe to store for over 15 years. However, none of the current U.S. cask designs have been tested even though they use a different storage technology.

The U.S. industry chose a different technology (stainless steel/concrete overpack/cask) mainly due to the cost of ductile cast iron at the time and with the assumption that the canisters would only be needed until Yucca Mountain opened.

The CASTOR V/21 was considered the “Cadillac” of the industry and the CASTOR line is still very popular in other parts of the world for BOTH storage and transport (including high burnup fuel).

The CASTOR canisters have multiple certifications for quality manufacturing, unlike the U.S. stainless steel canisters that are allowed exceptions to ASME and other standards. Material prices for stainless and cast iron have changed, so the price point should be lower.

The CASTOR has pressurized lid monitoring to detect helium leaks and temperature changes. The welded U.S. canisters do not have this capability, but the NRC and Department of Energy (DOE) state this is a high priority issue to resolve.

The inside of the CASTOR cask, including the sealing surface, has a nickel coating for corrosion protection. On the outside, the cask is protected by an epoxy resin coating in the fin area and nickel coating elsewhere.  And unlike the U.S. stainless steel canisters, it does not have stress corrosion cracking issues and does not require a concrete overpack/cask.

The original CASTOR V/21 is almost 15″ thick as opposed to the 1/2″ to 5/8″ stainless steel canisters.  The newer model CASTOR V/19 is almost 20″ thick. There are other ductile cast iron canister brands that are used in other countries. However, the U.S. emphasis on cost rather than longer term safety discourages competition from better quality casks vendors. With new U.S. needs for longer term onsite and interim dry cask storage, this should change.

Forged Steel Casks (AREVA TN Series)

TN24CaskFamilyNov2010ArevaAreva makes thick walled forged steel casks (TN series), which were approved for limited use years ago by the NRC. The TN cask is much thicker than the stainless steel canisters and doesn’t require a cement overpack/cask.  Its specifications are not as robust as the CASTOR, but better than the Areva NUHOMS system that Edison may procure.

Fukushima Daiichi and Germany use some TN casks. Germany mainly uses the CASTOR casks.

Enclose Casks in Buildings

CASTOR Droste BAM2013Both Japan and Germany enclose their casks in buildings for protection from the environment and other external forces.

This is something Edison should consider.

 Action Needed

No dry cask solution is even close to perfect, but we need to buy ourselves as much time as possible. Given the issues with stress corrosion cracking, concrete degradation, lack of monitoring, and lack of external inspection of stainless steel canisters, we can do better.

Spent fuel pools are dangerous. However, the spent fuel needs to cool in the pools for a number of years, so we have time to do a better job selecting a dry cask storage system. Edison’s artificial deadline of June 2019 to have all canisters loaded should not be the driving factor for the future of California.

The NRC does not proactively research dry storage system designs. They only respond to vendor requests for licensing. Vendors will only do this if they think they have a customer lined up for their product. California needs to be that customer.

Edison should reopen the bidding to include vendors with other cask technology. Edison’s Community Engagement Panel (CEP) had a presentation from Areva, but from no other dry cask storage vendors. Edison only solicited bids from three canister system manufacturers who all have the problems mentioned in this document.

Edison requested the NRC approve the NUHOMS 32PTH2 canister – it was not licensed when they decided to use it. That license amendment (Docket No. 72-1029, Certificate of Compliance No. 1029 Amendment No. 3) may be approved in August.  However, the CPUC should not approve funding for this canister system.

Edison has not shared with us the documents they used to solicit bids (Request for Proposal), so we have no idea what the requirements are in that bid package.  That would be useful information and the public should have access to this information.

If you have questions about sources for any information, contact Donna Gilmore. There are also detailed references on the website.  A link to the NRC July and August presentations as well as other documents discussed here are included below.

Donna Gilmore                                                                                       
dgilmore at                                             
Gene Stone
Residents Organized for a Safe Environment
Member, SONGS Community Engagement Panel
genston at


High Burnup Fuel

High Burnup Nuclear Fuel −Pushing the Safety Envelope, M. Resnikoff, D. Gilmore, Jan 2014
Letter from Chairman Macfarlane regarding high burnup fuel, May 2, 2014
Response from Donna Gilmore to NRC regarding May 2, 2014 request for NRC high burnup fuel technical basis, June 25, 2014

NRC Presentations and documents

NRC Meeting to Obtain Stakeholder Input on Potential Changes to Guidance for Renewal of Spent Fuel Dry Cask Storage System Licenses and Certificates of Compliance, July 14th/15th, 2014 (includes slide presentations)
Chloride-Induced Stress Corrosion Cracking Tests and Example Aging Management Program, Darrell S. Dunn, NRC/NMSS/SFST, Public Meeting with NEI on Chloride Induced Stress Corrosion Cracking Regulatory Issue Resolution Protocol, August 5, 2014
NRC Information Notice 2012-20: Potential Chloride-Induced Stress Corrosion Cracking of Austenitic Stainless Steel and Maintenance of Dry Cask Storage System Canisters. November 14, 2012

CASTOR Dry Casks (Ductile cast iron cask technology)

CASTOR V/21 NRC Certificate of Compliance and Safety Analysis Report, August 17, 1990
CASTOR brochure (includes the CASTOR V/19 and other ductile cast iron casks).
GNS’ [CASTOR] experience in the long-term storage at dry interim storage facilities in Ahaus and Gorleben, IAEA Vienna, May 20, 2014
Spent Fuel Storage and Transportation Experience, Idaho National Engineering Laboratory (GNS Castor V/21, Transnuclear TN-24P, Westinghouse MC-10, NAC S-100-C), 1987
BAM test results for CASTOR transport containers
Fracture Mechanics Based Design for Radioactive Material Transport Packagings, Historical Review, Sandia SAND98-0764 UC-804, April 1998
GNS CASTOR Presentation, June 09-11, 2010, Varna, Bulgaria (slide 18: CASTOR V/19, V52)

Areva TN Series Casks (forged steel cask technology)

TN-24 NRC Certificate of Compliance and Safety Analysis Report, November 4, 1993
AREVA Innovation in the Design of the Used Fuel Storage System, CRIEPI Tokyo, November 15-17, 2010 (includes information on TN 24 casks)
AREVA Dual Purpose Casks in Operation, AREVA TN Experience, Vienna, May 19-21, 2014

 NUHOMS 32PTH2 and San Onofre Decommissioning Plans

NRC Certificate of Compliance for Spent Fuel Storage Casks, COC 1029, Docket 72-1029, Amendment 3, Model No. Standardized Advanced NUHOMS®-24PT1, 24PT4, and 32PTH2,  expires 02/05/2023 (pending NRC approval as of 8/20/2014)
Comments on Direct Rule re List of Approved Storage Casks (79 Fed. Reg. 21,121 (April 15, 2014), Request for Rescission of the Direct Rule, and Request for Publication of a New and Revised Notice of  Proposed Rulemaking, Docket No. 13-0271, Diane Curran, on behalf of 20 environmental organizations and individuals.
February 10, 2012 letter from Edison to NRC: Support for NRC Review of Transnuclear Inc. Application for Amendment 3 to the Standardized Advanced NUHOMS® Certificate of Compliance No. 1029, San Onofre Nuclear Generating Station, Units 2 and 3 and Independent Spent Fuel Storage Installation Docket Nos. 50-36, 50-362 and 72041
Update on Decommissioning Plans, Tom Palmisano, Vice President & Chief Nuclear Officer, August 12, 2014 presentation to CA Senate Energy, Utilities and Communications Committee, Chairman Alex Padilla

 Community Engagement Panel Correspondence

High Burnup Fuel and Dry Cask Storage Issues, July 17, 2014 letter to CEP Chairman David Victor from Donna Gilmore, San Onofre Safety
David Victor testimony to NRC Commissioners, July 15, 2014

Additional references at

Nuclear Waste
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3/25/2014 San Clemente: San Onofre decommissioning CEP meeting

San Onofre’s Tom Palmisano will brief the community on decommission planning/activities at the first Southern California Edison Community Engagement Panel (CEP) meeting on Tuesday, March 25, 2014.

6:00 – 9:00 p.m. (Coalition to Decommission San Onofre press conference at 5:00 p.m.)
San Clemente Community Center
100 N. Calle Seville
San Clemente, CA 92672

Meeting Agenda and live webcast:

Please attend this meeting. Southern California communities need to be involved to ensure our safety. Edison has a history of putting profits over safety.  It is up to us to make sure this doesn’t happen with the tons of highly radioactive waste that is unsafely stored near our communities.

There are facts you need to know that Edison doesn’t share.  For example, the following is from a Q&A with San Onofre Site Vice President Tom Palmisano.

Tom PalmisanoQ: Does San Onofre have high burn-up nuclear fuel and, if so, how does that affect the way you store this used fuel?

A: Like many other nuclear plants, San Onofre has taken advantage of improvements in fuel technologies that allow nuclear plants to extract more energy from the fuel by achieving higher burn-up levels. SCE is licensed to use this fuel and store it in the spent fuel pool, and our dry storage canisters are licensed separately to store high burn-up fuel. Once this fuel is removed from the reactor, it is stored in accordance with NRC regulations and in the same manner as San Onofre’s other used fuel — initially in a steel-lined, concrete spent fuel pool and later in dry cask storage.

What Mr. Palmisano doesn’t say: 

    • Higher burnup = higher cladding failureNRC won’t renew dry cask storage for high burnup fuel after the initial 20 years, because of insufficient data that it is safe.
    • Scientific data indicates fuel cladding failure with fuel burnup as low as 30 GWd/MTU.  See U.S. Nuclear Waste Technical Review Board (NWTRB) graph.
    • NRC won’t approve transportation containers for high burnup fuel due to scientific data showing cladding embrittlement with high burnup fuel, making the cladding so fragile it may shatter on transport, release radiation into the environment.
    • San Onofre’s decision to switch to high burnup fuel was made to increase profits at the expense of our safety.
    • Because of the potential problems with high burnup fuel, Maine Yankee nuclear plant chose to treat their high burnup fuel as “damaged fuel” by storing high burnup fuel assemblies into steel “damaged fuel cans” before placing in the dry cask system canister.  This provides a layer of protection if the outer canister fails. The NRC doesn’t require this. The NRC agrees this would be a safety precaution and has considered requiring this.  However, the nuclear industry does not want this required.

Since San Onofre’s nuclear waste will be on-site for decades, if not longer, all fuel assemblies should be treated as damaged fuel and canned before placing in dry storage  when in doubt, always error on the side of safety over profits.

Most high burnup fuel needs to cool in the spent fuel pools at least 15 years before it’s cool enough to move to dry cask storage.  Edison’s Fact Sheet says fuel needs to cool “at least 5 years”.  However, they don’t mention the additional requirements for high burnup fuel. And they don’t mention it’s over twice as radioactive as the lower burnup fuel they initially used.

Edison doesn’t tell you there is no method to fully inspect fuel assemblies for cladding damage.  Existing technology and employee safety concerns allow only a partial inspection.  Therefore, it’s impossible to know if the cladding has failed on all the fuel rods.

Chart SONGS Chernobyl Other Alvarez, Figure 4San Onofre’s spent fuel contains 89 times the amount of radiation (Cesium-137) released from Chernobyl. Therefore, it’s extremely important this waste is stored as safely as possible.

Please attend this meeting and support our safety recommendations:

    • Establish better ways to safely store and transport nuclear waste, especially high burnup fuel, to an acceptable remote location as soon as it is available and safe to do so.
    • Improve instrumentation capabilities to monitor spent fuel pools and dry cask storage.
    • Add a layer of protection to dry cask storage by “canning” spent fuel assemblies in individual containers prior to loading into canisters — handle waste with the expectation that it may become damaged by excessive heat and radiation over time.
    • Reduce the number of spent fuel assemblies from 24 units per cask instead of seeking to increase it to 32 units for the sole purpose of saving money.
    • Transfer adequately cooled fuel assemblies to dry cask storage immediately to free up overcrowded conditions in spent fuel pools, making them more secure.
    • Reinforce structures that protect all forms of radioactive waste and develop unmanned systems to respond to any radiological emergency in case the plant is not accessible.
    • Provide on-site capabilities to handle leaking casks should there be a breach in containment.
    • Make public announcements before the release of tons of pollutants into the ocean which is currently allowed as part of the decontamination process.
    • Provide public access to real-time radiation monitoring data.

The overarching message from our community to Edison:


error on the side of


Sources and additional information:
Handout: Nuclear Waste Recommendations
Report: High Burnup Nuclear Fuel — Pushing the Safety Envelope


Posted in Action Alert, Chernobyl, Events, How to Help, NRC, Nuclear Waste, Press Release, Radiation Monitoring, Southern California Edison | Tagged , , , , , , , , , | Leave a comment

NRC Ignores High Burnup in Spent Fuel Transportation Risk Assessment

The Nuclear Regulatory Commission (NRC) chose to EXCLUDE high burnup spent fuel in their 2014 final report on Spent Fuel Transportation Risk Assessment (NUREG-2125).   However, they claim “..that NRC regulations continue to provide adequate protection of public health and safety during the transportation of Spent Nuclear Fuel.”

NWTRB 2010 Figure 20

Higher burnup = higher oxide thickness = higher cladding failure. NWTRB 2010 p.56

How is this possible with all the unresolved problems of high burnup fuelHow is this possible when the NRC will not approve transportation containers for high burnup fuel due to the risk of shattering of the fragile protective fuel cladding that can even lead to a hydrogen explosion? The NRC should be required to issue an updated report to address the high burnup transport issues.

When the NRC Commissioners were briefed on the draft version of the report, they were given the impression the report addressed high burnup spent fuel.  At a July 11, 2013 NRC briefing, Chairman Macfarlane asked if high burnup spent fuel was addressed in the report. She and the other NRC Commissioners were told  “yes”, even though it is not. This exchange between Macfarlane and Michael Ryan is the only mention of high burnup fuel in the transcript. Page 43 of the transcript of the Commissioners’ meeting with the NRC Advisory Committee on Reactor Safeguards (ACRS), July 11, 2013:

CHAIRMAN MACFARLANE: Okay, good. And did the study address – did it look at transporting and the risks of transporting high burn-up fuel which after long term storage may become embrittled?

MICHAEL RYAN: Yes. It was a wide range of fuels, fuel types, fuel burn-ups that were evaluated.

CHAIRMAN MACFARLANE: And the potential for embrittlement of those –

MICHAEL RYAN: All of that, yes.

CHAIRMAN MACFARLANE: Okay, good. All right. That’s what I  was interested in.

The report actually excludes high burnup spent fuel from evaluation. After making excuses for why they did this, the report makes unsubstantiated assumptions about high burnup spent fuel transport and ignores NRC’s own documents and policy on the transport of high burnup fuel.

Section 6.3 Effect of Transportation of Higher Burnup Spent Nuclear Fuel  [pages 138-139]

At the time the analyses for this report were completed, the maximum burnup for the spent fuel transported in any of the casks was 45 gigawatt days per metric ton uranium (GWD/MTU). Current reactor operations result in spent fuel with burnup levels higher than this. A detailed examination of the effect of the higher burnup levels is outside the scope of this document, but this section provides some general insights on expected changes resulting from transporting these higher burnup spent fuels.”

The regulatory external dose rates must still be met, so there is no effect on incident-free transport or on the results from accidents that do not result in cask damage. The higher burnup fuel will have to be cooled longer before it is transported to meet the cask’s decay heat and dose rate limits and the expected radiation emanating from the fuel should not change substantially (it cannot increase above the regulatory surface dose rates, and the casks studied here are either at that limit or very near to it). Therefore, results from loss of shielding accidents will not change significantly. In all of the accidents that are severe enough to have a release path from the cask, the acceleration level is high enough to fail the cladding of all of the fuel, whether it is high burnup or not. Higher burnup fuel has a rim layer with a higher concentration of radionuclides. This will lead to the rod-to-cask release fraction being higher but will not affect the cask-to-environment release fraction (Table 5-10 gives the release fractions used in this study.). In addition, the isotopic mixture of the higher burnup fuel cooled for a longer period of time will have more transuranic isotopes and less fission product. For example, the inventory of 241Am (Americium-241) goes up from 193 Tetrabecquerels (TBq) at 45 GWD burnup to 1,980 TBq at 60 GWD burnup (5,210 curies (Ci) to 53,400 Ci) and the inventory of 90Sr (strontium-90) drops from 40,400 TBq to 30,600 TBq (1,090,000 Ci to 826,000 Ci). Insufficient data exists to accurately estimate the rod-to-cask release fractions for higher burnup fuel. If the release fractions remain the same, the effect of the change in radionuclide inventory increases the number of A2s released by a factor of 5.9. This increase does not alter the conclusions of this study.

The NRC findings on transporting nuclear spent fuel contains many assumptions, resulting in unsubstantiated conclusions. Here are their findings and conclusions.

6.4 Findings and Conclusion [pages 139-140]

The following findings are reached from this study:

          • The collective doses from routine transportation are very small. Theses doses are about four to five orders of magnitude less than collective background radiation doses. 
          • The routes selected for this study adequately represent the routes for SNF transport, and there was relatively little variation in the risks per kilometer over these routes.
          • Radioactive material would not be released in an accident if the fuel is contained in an inner welded canister inside the cask.
          • Only rail casks without inner welded canisters would release radioactive material and only then in exceptionally severe accidents.
          • If there were an accident during a spent fuel shipment, there is only about a one-in-a-billion chance that the accident would result in a release of radioactive material. 
          • If there were a release of radioactive material in a spent fuel shipment accident, the dose to the MEI would be less than 2 Sv (200 rem) and would not result in an acute lethality.
          • The collective dose risks for the two types of extra-regulatory accident  (accidents involving a release of radioactive material and loss of lead shielding accidents) are negligible compared to the risk from a no-release, no-loss of shielding accident. 
          • The risk of loss of lead shielding from a fire is negligible. 
          • None of the fire accidents investigated in this study resulted in a release of radioactive material.

Based on these findings, this study reconfirms that radiological impacts from spent fuel transportation conducted in compliance with NRC regulations are low. They are, in fact, generally less than previous, already low, estimates. Accordingly, with respect to spent fuel transportation, this study reconfirms the previous NRC conclusion that regulations for transportation of radioactive material are adequate to protect the public against unreasonable risk.

The NRC should be required to complete a revised report considering the implications of high burnup fuel transport.

2012-07-25 NEI High Burnup Slide3

Status of U.S. high burnup fuel (>45 GWd/MTU) in dry cask storage, NEI 7/25/2012

The majority of the fuel in U.S. spent fuel pools is high burnup fuel and over 200 dry casks contain high burnup fuel.  The first high burnup fuel was loaded in 2003 at Maine Yankee. Maine Yankee loaded their high burnup fuel assemblies in “damaged fuel cans” as a safety precaution.  However, they may be the only nuclear plant that has done this.  The NRC will not renew current high burnup 20-year dry cask licenses, due to the instability and unpredictability of high burnup fuel.

High burnup storage and transport problems need to be solved as soon as possible. However, they do not appear to be receiving the priority needed from the NRC, DOE or nuclear industry. And industry profits are currently a factor when developing solutions. The public at risk for dangerous radiation releases from high burnup fuel.  And with no technology to monitor inside dry casks, we won’t know there is a problem until it’s too late.  The NRC is not meeting it’s mission of “protecting people and the environment.”


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San Onofre and High Burnup Nuclear Waste Experiment

San Onofre cask loading into storage bunker

Loading dry storage canister

It’s been two years since San Onofre nuclear reactors were shut down. However, we’re still at risk from the tons of nuclear waste generated by the reactors. A nuclear waste accident could result in permanent evacuation of parts of Southern California and endanger our nation’s food supply, economy, and our health. The plant was shut due to the January 31, 2012 radiation release and unprecedented premature tube wear in the defectively designed replacement steam generators.

Now we learn Southern California Edison chose to switch to a more dangerous “high burnup” uranium fuel that burns longer in the reactor, increasing their profits, but making us less safe. Virtually all U.S. nuclear plants use high burnup fuel, including Diablo Canyon. High burnup fuel is over twice as radioactive and unstable and unpredictable in storage.  

Years to Cool ChartHigh burnup fuel is also much hotter. It requires up to a minimum 20 years cooling in spent fuel pools before it can be transferred to dry storage canisters and casks. The amount of cooling needed depends on how high the burnup is and the percent of Uranium 235 fuel enrichment (up to 5% U-235).

High burnup fuel is so dangerous, the Nuclear Regulatory Commission (NRC) says there is insufficient data to support approval of more than 20 years of dry cask storage of high burnup fuel. And the NRC will not approve transportation containers for high burnup fuel.

Cross Section Fuel Rod Significant Radial Hydride Orientation DE-NE-0000593

Cladding cracks

Numerous scientific reports state high burnup fuel is causing the protective Zirconium metal cladding around the fuel to crack and become brittle. In this more fragile state, the cladding may shatter, which could lead to radiation escaping into the environment. In addition, the Zirconium reacts with the high burnup fuel to create hydrides. If exposed to oxygen, this can result in a hydrogen explosion, similar to Fukushima. The higher the burnup, the more hydrides created.

What is the NRC doing about high burnup fuel problems?

01-14-2013 INMMS Data Gap SlideThe NRC issued a Waste Confidence Generic Environmental Impact Statement (GEIS) claiming all the nuclear waste can stay at every nuclear plant in the nation for hundreds of years with no significant environmental impact. They chose to ignore the information on high burnup fuel and other known waste storage technology “data gaps”. The GEIS is based on unsubstantiated hope. Thousands of people submitted comments disagreeing with the GEIS.

The NRC Commissioners are scheduled to vote on the GEIS in October 2014. Four of the five Commissioners normally vote for industry profits over safety. Chairman Allison Macfarlane is the only one who normally votes for safety over profit, so she is frequently outvoted.

What is the Department of Energy (DOE) and nuclear industry doing about high burnup fuel problems? The DOE contracted with the Electric Power Research Institute (EPRI) for a “Demonstration Project”. It’s a $16 million four-year project that will not solve the probem. 

Vertical Cask System

Vertical Cask System

EPRI plans to put high burnup fuel in a stainless steel container that isn’t even approved for high burnup fuel. Then open the container occasionally to see what happens to the fuel assemblies. In addition, because there is no technology that can monitor what is happening inside dry storage containers, EPRI plans to develop that technology. This project, which may be extended for 10 years, is what the nuclear industry is claiming as their solution to the high burnup problem. Basically, they plan to “demonstrate” that high burnup fuel can be stored with no problems. They expect to use this project as proof to the NRC, in spite of all the scientific studies to the contrary.

What can you do?

Share this information with others. Share it with your local, state and federal elected officials and government regulators. Ask them to support real solutions to the high burnup fuel storage problem. Most of them are not aware of or have been misinformed about this issue. Senator Barbara Boxer is Chairman of the U.S. Senate Committee on Environment & Public Works. This Committee has oversite of the Nuclear Regulatory Commission.

Share the document, “High Burnup Nuclear Fuel, Pushing the Safety Envelope”. It contains more information and technical references.

High Burnup Fuel Recommendations

It is imperative the NRC

  • Stop approval of high burnup fuel (HBF) use.
  • Stop approval of HBF dry cask storage.
  • Make solving high burnup fuel storage problems one of its highest priorities. The DOE EPRI “Demonstration Project” (EPRI High Burn-up Dry Storage Cask Research and Development Project), that the Nuclear Energy Institute is promoting is not a solution. This project only tests HBF in existing cask technology. The TN-32 cask isn’t even approved for HBF. Over ten years after HBF was first produced and stored in dry storage casks, the industry has finally begun to study the consequences. The NRC has been asleep at the switch, allowing this dangerous experiment in the field to proceed.
  • Develop adequate strategies to detect and mitigate unexpected degradation during dry storage. 
  • Absent a comprehensive safety analysis, not approve 32 assembly casks for HBF, such as the NUHOMS® 32PTH2 cask system that San Onofre wants to use.
  • Require all HBF assemblies be containerized in damaged fuel cans prior to loading in dry storage canisters.
  • Require full cask testing, rather than computer simulations and scale models.
  • Reject NRC’s NUREG-2125 Spent Fuel Transportation Risk Assessment as inadequate as it does not address HBF.
  • Reject the NRC’s Waste Confidence Generic Environmental Impact Statement.

Time is of the essence.

  • As of 2012, most fuel in pools for future loading is high burnup and approximately 200 loaded-casks contain HBF.
  • U.S. dry cask storage of HBF (>45 GWd/MTU) started about a decade ago. (GWd/MTU is the number of gigawatt days of energy produced per metric ton of uranium.)
    • Since 2003, Maine Yankee casks contain HBF up to 49.5 GWd/MTU. (Maine Yankee HBF is in damaged fuel cans, due to unknowns with HBF)
    • Since 2005, HB Robinson casks contain HBF up to 56.9 GWd/MTU
    • Since 2006, Oconee casks contain HBF up to 55 GWd/MTU
    • After 2008, many other sites have casks that contain HBF up to 53.8 GWd/MTU, according to the Nuclear Energy Institute.

For more information and references, go to

Posted in Action Alert, How to Help, NRC, Nuclear Waste, Senator Barbara Boxer, Southern California Edison | Tagged , , , , , , , , , , , , , , | Leave a comment

High Burnup Fuel Fact Sheet

High Burnup Nuclear Fuel 

Pushing the Safety Envelope

by Marvin Resnikoff [1] and Donna Gilmore [2]
January 2014
Click to print or download High Burnup Fuel Fact Sheet

As commercial reactor economics have declined, utilities, with the acquiescence of the Nuclear Regulatory Commission (NRC), have burned nuclear fuel longer and crammed more of it into storage containers.  This experiment has unresolved serious safety issues for storage, transportation and disposal of this highly radioactive waste; issues that have been essentially overlooked by nuclear regulators and the general public.

For high burnup fuel (HBF), the cladding surrounding nuclear fuel, is thinner, more brittle, with additional cracks.  In a transportation accident, the cladding could shatter and a large inventory of radioactivity, particularly cesium, could be released.  The NRC should stop use of HBF and make solving HBF storage problems one of its highest priorities.

High Burnup Fuel Problems

Almost all commercial reactors have HBF.  Since the 1990’s almost all spent nuclear fuel (SNF) being loaded into dry casks is HBF.[3]  HBF is low-enriched uranium that has burned in the reactor for more than 45 GWd/MTU (GigaWatt days per Metric Ton of Uranium).[4]  Many Pressurized-Water Reactors have fuel with projected burnup greater than 60 GWd/MTU.[5]

Cross Section Fuel Rod Significant Radial Hydride Orientation DE-NE-0000593

Fig. 1. Cladding cracks

The only issue NRC staff consider is the highest heat within a storage cask, but this ignores the fact that the cladding of HBF is thinner, more brittle, with additional cracks, as shown in Fig. 1.  Longer cooling time will not solve these problems.                                               

Uranium fuel pellets, stacked within long thin tubes called cladding, are struck by neutrons and fission, producing heat.  A collection of these tubes is called a nuclear fuel assembly, shown in Fig. 2.  After 3 to 4 years, extremely radioactive and thermally hot fuel assemblies are removed from the reactor and stored underwater in a fuel pool.  Following a cooling period of 7 to 20 years, 24 to 32 fuel assemblies are removed from the fuel pool and inserted into a fuel canister, which are then pushed into a concrete overpack shown in Fig. 3.  Because of the poor economics of nuclear power, utilities are pushing the limits for how long fuel remains in reactors with dire consequences.

Here are the high burnup fuel issues:

  • HBF is dangerously unpredictable and unstable in storage – even short-term.
  • HBF is over twice as radioactive and over twice as hot. The higher the burnup rate and the higher the uranium enrichment, the more radioactive, hotter and unstable fuel and cladding become.  Fig. 4 shows the increase of heat output of fuel assemblies as a function of burnup.
  • HBF requires a minimum of 7 to 20+ years of cooling in spent fuel pools before storage in dry casks. The years of cooling depends on the burnup rate, percent of uranium enrichment and other factors as defined in the dry cask system’s technical specifications.[6] Lower burnup fuel requires a minimum of 5 years. See Fig. 5.
  • HBF requires more storage space between fuel assemblies due to the higher heat, higher radioactivity, and instability,[7] yet the NRC approves high density of fuel assemblies in fuel pools and dry casks systems. San Onofre requested use of a new dry cask system that crowds 32 fuel assemblies into the same space that currently holds 24.[8]  Absent a comprehensive safety analysis, the NRC should NOT approve the NUHOMS® 32PTH2 cask system for HBF, but is considering doing so this year. The NUHOMS system consists of a welded canister that holds 24 or 32 fuel assemblies; the canister slips inside a concrete storage overpack, shown in Fig.3.  Diablo Canyon now uses a HOLTEC 32 fuel assembly cask system.
  • No transportation casks for HBF have been approved by the NRC,[9] so even if a waste repository were available, HBF could not be relocated.
  • HBF nuclear fuel is approved for only 20 years storage in dry casks, based on faulty assumptions about how HBF reacts in the first 20 years of storage.[10]
  • There is insufficient data to approve HBF in dry casks for over 20 years, per Dr. Robert Einziger, Senior Materials Scientist, NRC Division of Spent Fuel Storage and Transportation.[11]  Experimental data show fuel with burnup as low as 30 GWd/MTU have signs of premature failure.[12]  As was done at Maine Yankee,[13] all HBF assemblies should be containerized in damaged fuel cans for dry storage.
  • The NRC has no adequate strategies to detect and mitigate unexpected degradation of HBF during dry storage.[141516]
  • HBF has major implications for pool storage before movement to dry storage.  The NUHOMS 32 assembly cask requires up to 20 years and longer if HBF is to be transported. As seen in Fig. 4, HBF would require more than 30 years in storage before it could be transported.  This has major ramifications for decommissioning reactors. Essentially, reactors cannot be immediately dismantled after ceasing operation. SAFSTOR[17] is the only option. The reactor license must be retained for this period.  A longer time is required before HBF can be removed from the reactor site. In addition, the current high spent fuel pool densities present an even greater risk due to inclusion of HBF assemblies.

HBF has major implications for disposal in a repository.  If DOE intends to open NUHOMS and HOLTEC canisters and repackage HBF for disposal, major problems may arise.  Because the cladding is brittle and has cracks, it may be damaged during transportation and storage.  Each HBF assembly may have to be containerized before storage, similar to damaged fuel assemblies.

HBF has major implications for transportation.  Transportation issues have not been well examined by NRC in NUREG-2125, the latest transportation risk assessment, a 509 page report with numerous references.[18]  But NUREG-2125 does not investigate transportation of HBF, a major oversight, as is discussed below.

NRC Transportation Accident Analysis

Public input on NUREG-2125 was unwisely curtailed at 60 days.  The report was sold to the Commissioners by NRC Staff as a way to gather input from stakeholders, but in practice, this did not meaningfully happen.  NRC staff required 7 years to produce this report, yet the State of Nevada’s request for an additional 30 days review was denied.  NUREG-2125 should have been critically reviewed.

NUREG-2125 is essentially a transportation risk analysis. As the critique by the State of Nevada[19] shows, the NRC picked and chose which of its reports to include as references.  Important accident sequences were not included.  Here are just 3 examples of many, some of which are discussed in footnote 19.

  • Transportation casks have impact limiters at each end.  Therefore, the most vulnerable position is a side impact, where the impact limiters are avoided, the so-called backbreaker accident.  The references not chosen by NRC discuss this accident.  NUREG-2125 does discuss a side impact by a train at a RR crossing.  If the train sill directly impacts a transportation cask, the forces and accelerations can be great enough to stretch the bolt lids and leave an opening to the cask interior.  But cited references do not include the 1-ton impact limiters at each end, which would increase the bending.  For HBF, 140 g forces, a 60 mph side impact, would easily shatter the brittle cladding.  HBF has over twice the cesium inventory.
  • There are serious unanswered questions about long duration, high temperature fires and effect on cask and fuel cladding.  Casks have neutron shielding on the outside, generally boronated plastic, within a thin metal cylinder.  Fuel would heat up with this plastic blanket, except for the fact that metal brackets that hold the thin outer metal cylinder in place are heat conductors.  But in a fire accident, these metal conductors can serve as heat inputs to the cask.  This is not correctly modeled by cask manufacturers.
  • The State of Nevada has been asking for some time for full cask testing.  These double layer casks, a canister within a transportation overpack, should be fully physically tested.  Instead cask manufacturers rely on computer simulations and scale models.  It is important to benchmark these computer models.  Examples of failures by manufacturers to properly evaluate effectiveness can be found in the fire insulation failures throughout the US nuclear fleet due to inaccurate manufacture qualifications.

NRC Security Analysis

Finally, malevolent events should be seriously examined.  We do not have confidence this has been done.  Anti-tank weapons such as the Russian Kornet, or French Milan, can easily penetrate 1 meter of metal.  For transportation, the concern is about events that include entrance and exit holes.  This is of particular concern with HBF, with large Cesium inventories and suspect fuel cladding.

High Burnup Fuel Recommendations

It is imperative the NRC

  • Stop approval of high burnup fuel (HBF) use.
  • Stop approval of HBF dry cask storage.
  • Make solving high burnup fuel storage problems one of its highest priorities.   The DOE EPRI “Demonstration Project” (EPRI High Burn-up Dry Storage Cask Research and Development Project),[20] that NEI is promoting[21] is not a solution. This project only tests HBF in existing cask technology (TN-32).  The TN-32 cask isn’t even approved for HBF.[22]  Over ten years after HBF was first produced and stored in dry storage casks, the industry has finally begun to study the consequences.  The NRC has been asleep at the switch, allowing this dangerous experiment in the field to proceed.
  • Develop adequate strategies to detect and mitigate unexpected degradation during dry storage.
  • Absent a comprehensive safety analysis, not approve 32 assembly casks for HBF, such as the NUHOMS® 32PTH2 cask system.
  • Require all HBF assemblies be containerized in damaged fuel cans for dry storage.
  • Require full cask testing, rather than computer simulations and scale models.
  • Reject NUREG-2125 Spent Fuel Transportation Risk Assessment as inadequate as it does not address HBF.

Time is of the essence.

  • As of 2012, most fuel in pools for future loading is high burnup and approximately 200 loaded-casks contain HBF.[23]
  • Dry cask storage of HBF in the U.S. started about a decade ago:
    • Since 2003, Maine Yankee casks contain HBF up to 49.5 GWd/MTU. (Maine Yankee HBF is in damaged fuel cans, due to unknowns with HBF)
    • Since 2005, HB Robinson casks contain HBF up to 56.9 GWd/MTU
    • Since 2006, Oconee casks contain HBF up to 55 GWd/MTU
    • After 2008, many other sites have casks that contain HBF up to 53.8 GWd/MTU, according to the Nuclear Energy Institute.[24]
Reactor Fuel Assembly

Fig. 2. Reactor Fuel Assembly


Fig. 3. NUHOMS canister fits inside a concrete overpack

Fig. 3. NUHOMS canister fits inside a concrete overpack


Cooling Requirements By Fuel Burnup

Fig. 4. Power Output with Time as a Function of Fuel Burnup [25]

Years to Cool Chart

Fig. 5. Power Output with Time as a Function of Fuel Burnup [25]



[3] DOE EPRI High Burn-up Dry Storage Cask Research and Development Project: Draft Test Plan, Contract No.: DE-NE-0000593, September 13, 2013, Page 2-1

[4] GAO-12-797 SPENT NUCLEAR FUEL Accumulating Quantities at Commercial Reactors Present Storage & Other Challenges, August 2012, Low-enriched uranium = up to 5% of U-235. GWd/MTU is the amount of electricity produced (gigawatt-days) per metric ton of uranium.

[5] Savannah River National Laboratory, “Inventory and Description of Commercial Reactor Fuels within the United States,” SRNL-STI-2011-00228, March 31, 2011

[6] CoC No. 1029 Technical Specifications for Advanced NUHOMS® System Operating Controls and Limits, Appendix A Tables 2-9 to 2-16

[7] RWMA Marvin Resnikoff, PhD: The Hazards of Generation III Reactor Fuel Wastes, May 2010

[8] Edison request for NUHOMS® 32PTH2

[9] SFPO Interim Staff Guidance 11, Rev 3 Cladding Considerations for the Transportation and Storage of Spent Fuel 11/17/2003

[10] NWTRB Douglas B. Rigby, PhD: The NRC approved the initial 20 year dry cask storage based on assumptions. However, no information was found on inspections conducted on HBFs to confirm the predictions that were made. U.S. Nuclear Waste Technical Review Board, December 2010 report,

[11] NRC R. E. Einziger, PhD: insufficient data to support licensing dry casks for >20 years, March 13, 2013

[12] DOE FCRD-NFST-2013-000132, Fuel Cycle Research & Development-Nuclear Fuel Storage and Transportation-2013-000132, Rev. 1, June 15, 2013

[13] Maine Yankee Atomic Power Company’s Response to the NRC’s Request for Comments Regarding Retrievability, Cladding Integrity and Safe Handling of Spent Fuel at an Independent Spent Fuel Storage Installation and During Transportation (Docket ID NRC-2013-0004), March 18, 2013

[14] Fancy New Lids for Nuclear Waste Casks, As Contents Get Hotter, Jeff McMahon, May 2, 2013

[15] NRC 10 CFR Part 72: [Docket No. PRM-72-4]: Prairie Island Coalition; Denial of Petition for Rulemaking, Federal Register, v. 66, no. 25 (February 6, 2001): p. 9058.  FR Doc No: 01-3025

[16] NRC Acceptance Review of Renewal Application to Materials License No. SNM-2506 for Prairie Island Independent Spent Fuel Storage Installation – Supplemental Information Needed (TAC NO. L24592)

[17] Under SAFSTOR, which utilities refer to as “deferred dismantling,” a nuclear facility is maintained and monitored in a condition that allows the radioactivity to decay; afterwards, it is dismantled and the property decontaminated…

[18] Office of Nuclear Materials Safety and Safeguards, Nuclear Regulatory Commission, “Spent Fuel Transportation Risk Assessment, NUREG-2125, May 2012

[19] Memo from Marvin Resnikoff to Bob Halstead, 7/18/2013, “NUREG-2125 Review”

[20] DOE EPRI High Burn-up Dry Storage Cask Research and Development Project: Draft Test Plan, Contract No.: DE-NE-0000593, September 13, 2013, Page 2-1,

[21] NEI High Burn-up Used Nuclear Fuel Extended Storage and Transportation Demo, Rod McCullum, INL High Burn-up Used Fuel Demonstration Workshop, August 22-23, 2012

[22] TN-32 Generic Technical Specifications

[23] Storage of High Burn-up Fuel, Nuclear Energy Institute (NEI), Marc Nichol, July 25, 2012 NRC Public Meeting, Slide 3,

[24] DOE EPRI High Burn-up Dry Storage Cask Research and Development Project: Draft Test Plan, Contract No.: DE-NE-0000593, September 13, 2013, Page 2-1

[25] Data from Characteristics for the Representative Commercial Spent Fuel Assembly for Preclosure Normal Operation, Bechtel SAIC Co., May 2007, OOO-PSA-MGRO-OO700-000-00A, Table 3. Thermal Power (Watts) per PWR Fuel Assembly with 4.0% U-235

[26] Data from Characteristics for the Representative Commercial Spent Fuel Assembly for Preclosure Normal Operation, Bechtel SAIC Co., May 2007, OOO-PSA-MGRO-OO700-000-00A, Table 3. Thermal Power (Watts) per PWR Fuel Assembly with 4.0% U-235 

Learn more at

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12/17/2013 San Clemente City Council Meeting – San Onofre nuclear waste

San Clemente City Council unanimously passed Resolution 13-53 regarding the urgency of removing the dangerous nuclear waste from San Onofre, based on geographic conditions and dense population. The resolution was submitted as a comment to the NRC Waste Confidence Generic Environment Impact Statement (GEIS). The NRC GEIS concludes it is safe to store the tons of nuclear waste at all nuclear plants indefinitely.

The city also sent a letter to the NRC requesting an extension of the deadline for GEIS comments to February 28, 2014 and sent letters to cities within 20 miles, asking them to support the same action.


Please attend Tuesday’s 6:00 p.m. San Clemente City Council meeting to support the city taking a more active role in ensuring the safe storage and transport of San Onofre’s tons of nuclear waste.

The City Council will vote on whether to approve Resolution No. 13-53 regarding the City’s position on San Onofre nuclear waste and decommissioning.  It includes concerns about the Nuclear Regulatory Commission’s (NRC) Generic Environmental Impact Statement (GEIS) that makes the outrageous claim it is safe to store nuclear waste at San Onofre (and all other U.S. nuclear plants) for hundreds of years or indefinitely.

The NRC GEIS concludes it’s safe to store nuclear waste on site indefinitely, even though the NRC currently will not approve transportation casks for “high burnup” nuclear waste and will not approve dry cask storage of high burnup nuclear waste for more than 20 years.  

Southern California Edison chose to use high burnup nuclear fuel because it made them more profits, yet it made us less safe, with no containers deemed safe enough to store the waste even short-term (over 20 years).

High Burnup Fuel Clad Hydrides Microscopic View

NRC photo

NRC engineers, such as Dr. Robert E. Einziger, and other experts say high burnup fuel is proving unstable and unpredictable. There is evidence high burnup nuclear fuel waste can cause the protective cladding around the enriched uranium fuel to become brittle, making it fragile and subject to shattering.  If it shatters, it can release dangerous levels of radiation into the environment. The industry has no technology to monitor nuclear waste inside the containers, so by the time they know there is a problem, it may be too late.

Some of the high burnup waste is so hot and radioactive, it can require a minimum of 20 years to cool in spent fuel pools.

Table 2-12 Fuel Cooling Time Table 24PT4-DSCThe years of cooling depend on how long the fuel was burned in the reactor and the level of uranium enrichment. A recent Department of Energy (DOE) report (Table 7) shows San Onofre has high burnup fuel of 68 GWd/MTU (or 67,676 MWd/MTU) with a maximum uranium enrichment of 4.08%. This means the fuel would need to cool a minimum of 20 years.  See Table 2.12 of technical specifications for NUHOMS® 24PT4-DSC. Note: If Edison has a current inventory report that differs from this DOE information, we encourage them to share it with the public. 

See details at

Just showing up at this city council meeting will say a lot! The City Council needs to know how important this issue is to our citizens.

Location:  San Clemente City Hall, 100 Avenida Presidio, San Clemente, CA
Date:          Tuesday, December 17th, 2013
Time:         6:00 p.m. meeting
Arrive early to attend the following events:
4:30 p.m. Press Conference (for the evening TV news) outside chambers
5:00 p.m.  Social gathering/rally outside City Hall chambers, with drinks and holiday treats
12/17/2013 City Council Meeting Agenda
Item 9.B, City’s Position on Various Issues Relating to San Onofre Nuclear Generating Station (SONGS)
High Burnup Executive Summary (revised 1/2/2013)
12-17-2013 San Onofre meeting handout

Special guest speaker:  For 26 years he managed the production of dry casks at San Onofre and now says, “We’ve got to get this waste the hell out of here!”  Storing the waste in an earthquake and tsunami zone is too dangerous.  And the salt air is corroding the metals of the stainless steel nuclear waste storage containers. 

How much waste is at San Onofre?

Chart SONGS Chernobyl Other Alvarez Figure 4

In the 1986 Chernobyl nuclear accident, over 350,000 people were evacuated. An area the size of New Jersey remains contaminated.

San Onofre contains 89 times the amount of radiation (Cesium-137) released from Chernobyl.  See Robert Alvarez June 2013 San Onofre report.


Agenda: 12/17/2013 City Council Meeting Agenda

Agenda Item 9.B. City’s Position on Various Issues Relating to San Onofre Nuclear Generating Station (SONGS) (Pages 9B-1 through 9B-55)

Report from the Public Works Director/City Engineer concerning the City’s position on various issues relating to the pending closure of San Onofre Nuclear Generating Station (SONGS).

Staff Recommendation


2. Authorize staff to send the letters contained in the Administrative Report, dated December 17, 2013, to the Nuclear Regulatory Commission (NRC), our local Legislators, and the Cities of San Juan Capistrano, Oceanside, and Dana Point.

 City Website: Check the San Clemente City Council website for updates and details.

For government and scientific facts about nuclear waste (spent nuclear fuel), including the San Onofre nuclear waste, go to

The public can send comments directly to the NRC about the Waste Confidence GEIS

Comments are due by 12/20/2013. See the NRC Waste Confidence website.  All comments must include Docket ID No. NRC–2012–0246.

E-mail comments to:, citing Docket ID No. NRC–2012–0246
Submit comments online at: using Docket ID No. NRC–2012–0246
Mail comments to: [Note: it's too late to mail comments due to the 12/20/13 deadline]
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
ATTN: Rulemakings and Adjudications Staff
citing Docket ID No. NRC–2012–0246 in your comments
Fax comments to:
U.S. Nuclear Regulatory Commission
301-415-1101, citing Docket ID No. NRC–2012–0246
Posted in Action Alert, City Council, Events, NRC, nuclear power, Nuclear Waste, Southern California Edison | Tagged , , , , , , , , , , , , , , , , , , , , , | Leave a comment

11/18/2013 Carlsbad & 11/20 San Luis Obispo NRC Waste Confidence Meetings

One Day Son All This Will Be YoursPlease attend the Nuclear Regulatory Commission’s (NRC) Monday, November 18th meeting in Carlsbad, California or the November 20th meeting in San Luis Obispo.

It’s our opportunity to comment on the NRC’s outlandish proposal that the tons highly radioactive nuclear reactor plant waste can safely stay in California virtually forever and that they can use a generic environmental impact statement to cover all future licensing of nuclear reactors in the country. To Hot To Handle High Burnup Poster

The NRC did not even consider the critical problem of “high burnup” nuclear fuel waste, which virtually all nuclear reactors are now using.

The NRC will not approve transport or short-term storage of high burnup fuel waste because they have NO CONFIDENCE it is safe.

The NRC originally thought high burnup fuel would react the same as lower burnup fuel after it cooled longer in the spent fuel pools.  However, scientific studies have proven this fuel remains unstable, unpredictable, hotter and over twice as radioactive as lower burnup fuel. No one knows how to contain it safely in dry cask storage.

The NRC is claiming in their Draft Waste Confidence Environmental Impact Statement they have confidence all waste can be stored safely in California and the rest of the U.S. indefinitely.

Tell the NRC they need to complete their research on extended storage before completing the Environmental Impact Statement. How can they have confidence when they haven’t even finished their research on storing this dangerous waste?

Carlsbad —  Monday, November 18, 2013 
5 p.m. Press Conference
5 – 7 p.m. Overpass Light Brigade
6 – 7 p.m. NRC Open House (Q&A with NRC Staff)
7 – 10 p.m. NRC Public Comment Meeting
Sheraton Carlsbad Resort and Spa
5480 Grand Pacific Drive
Carlsbad, CA 92008
Facebook Event page – Carlsbad meeting
NRC Meeting Notice – Carlsbad
San Luis Obispo — Wednesday, November 20, 2013
6 – 7 p.m. NRC Open House (Q&A with NRC Staff)
7 – 10 p.m. NRC Public Comment Meeting
Courtyard by Marriott San Luis Obispo
1605 Calle Joaquin Road
San Luis Obispo, CA 93405
NRC Meeting Notice – San Luis Obispo
See Mothers for Peace website for more San Luis Obispo details

These are the two of twelve public meetings being held by the NRC around the country to take comment on the Draft Waste Confidence Generic Environmental Impact Statement report.  See complete schedule and other details at

Stop the Nuclear Waste Con!

The NRC Draft Waste Confidence Generic Environmental Impact Statement and proposed rule are unacceptable. They are based on unsubstantiated hope. The Coalition to Decommission San Onofre (CDSO) and the Sierra Club Angeles Chapter have prepared the following core message to the NRC. Click here for NRC Core Message Handout and suggested signage.

Stop the Nuclear Waste Con: The NRC Draft Waste Confidence Generic Environmental Impact Statement (GEIS) is unacceptable. Much of it appears to be based on unsubstantiated hope and it ignores the unsolved problems of high burnup fuel. The NRC won’t approve short-term storage or transport of high burnup used nuclear fuel because they have no confidence it is safe. The Waste Confidence GEIS needs to address:

HIGH BURNUP FUELToo hot to handle

No short-term storage or transportation solutions for high burnup fuel waste.

      • The NRC and DOE are concerned with the instability of high burnup nuclear waste in both storage and transport, yet the NRC continues approving this dangerous fuel for reactors.
      • The NRC won’t approve high burnup dry cask storage over 20 yearsbecause they have NO CONFIDENCE it can be stored longer without releasing radiation into the environment, even though it must be stored for thousands of years. 
      • The NRC won’t approve transportation of high burnup used fuel because they have NO CONFIDENCE it can be transported without releasing radiation into the environment. 
      • San Onofre’s high burnup used fuel is so hot and radioactive, it requires up to a MINIMUM 20 YEARS cooling in the crowded spent fuel pools, instead of the minimum 5 years for lower burnup fuel.

Generic Environmental Impact StatementNOT acceptable for California

      • California didn’t “sign up” for permanent (100+ years) nuclear waste dumps.
      • California nuclear waste sits in the world’s earthquake “ring of fire”, the same as Fukushima, the most active and dangerous earthquake zone in the world. California’s nuclear waste is surrounded by known active earthquake faults and the USGS says no one has ever predicted a major earthquake.
      • California’s nuclear waste sits along an eroding coastline, in tsunami zones, and is exposed to a highly humid and corrosive coastal environment. NRC’s NUREG/CR-7030 states atmospheric corrosion of sea salt can lead to stress corrosion cracking within 32 and 128 weeks in austenitic [corrosion resistant] stainless steel canisters.
      • It would be impossible to evacuate the millions of people living near California’s waste. Of the 34 million people in California, over 8.5 million reside within 50 miles of San Onofre.
      • A radiological disaster impacts the nation’s and world’s security, economy and food supply.
        • California is the eight ranking economy in the world, virtually tied with Italy and the Russian Federation, and larger than Canada, Australia and Spain.
        • More than 40 percent of containerized imports enter the country through California ports, and nearly 30 percent of the country’s exports depart through them.
        • California produces nearly half of the U.S. grown fruits, nuts and vegetables. California remained the number one state in cash farm receipts in 2011, with its $43.5 billion in revenue representing 11.6 percent of the U.S. total. U. S. consumers regularly purchase several crops produced solely in California.
        • San Onofre is located adjacent to the primary vehicle transportation artery between Los Angeles and San Diego (I-5), and one of the largest military installations (and targets) on the West Coast (Camp Pendleton).

We oppose NRC’s proposed rule that future licensing can be based on the assumption spent fuel can be safely stored above ground virtually forever.

      • In the proposed NRC rule that accompanies the draft GEIS, the NRC proposes to incorporate into every reactor license the Draft GEIS’ conclusion that spent fuel can be safely stored above ground indefinitely. 
      • This proposal would in effect forbid any further public discussion, in individual reactor licensing actions, of the serious question of whether generation of additional spent fuel is justifiable in light of the absence of any means of safe disposal.


As described by the NRC Chairman, Allison Macfarlane, in a recent speech,

“…in June 2012, the D.C. Circuit Court of Appeals vacated the NRC’s 2010 Waste Confidence rule. In the court’s opinion, the Commission’s conclusion that a high-level waste repository would be available ‘when necessary’ lacked an appropriate discussion of the environmental consequences of failing to achieve that objective. The ruling also expressed concern about potential spent fuel pool leaks and fires. In the time since the court issued its decision…NRC staff has been working to revise the Waste Confidence rule and develop a generic environmental impact statement. From the beginning, the Commission made it clear that public involvement must be an essential part of this process. Starting last month, the NRC has been holding a series of public meetings around the country to get important input for our final products.”

NRC Presentation

NRC Poster

Page 1 of posterNRC Storage Time Frames


Page 2 of poster.NRC Waste Confidence Timeframes


NRC Slide Presentation (ML13273A339.pdf)

Submit Written Comments to the NRC by December 20, 2013

Email comments to the NRC at, citing Docket ID No. NRC–2012–0246.  For other ways to submit comments go to

For other sample comments, go to Beyond Nuclear.

Coalition to Decommission San Onofre includes Citizens Oversight, Inc., Peace Resource Center of San Diego, San Clemente Green,, and Women Occupy San Diego. For more information on nuclear waste, go to

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