US NRC: Impact of Environmental Conditions on Nuclear Waste Dry Storage, Comment Deadline May 4, 2015, 11.59 pm ET

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[Updated 29 Apr; Intro updated 30 Apr; further update later on 30 Apr or 1 May.]
This NUREG looks like a hoax. It does not live up to its title, nor to its scope. One interesting point made, but not evaluated, is that peak cladding temperature (PCT) increases 14.4F for every 10F ambient temperature. The only thing which the NUREG evaluates is low level wind, and it doesn’t do a proper job of that.
Holtec Dry Casks Grand Gulf Miss
Holtec Dry Casks of spent nuclear fuel sweltering on pavement in the Mississippi sun, on the river, with ultra-high humidity. The US NRC allows Holtec and others to pretend that the temperature is only 100F (38C).

Impact of Variation in Environmental Conditions on the Thermal Performance of Dry Storage Casks”, NUREG, US NRC comment deadline MAY 4th-Nuclear Waste Dry Cask Storage Temperature, etc.!documentDetail;D=NRC-2014-0273-0001 ID: NRC-2014-0273-0001
Holtec casks Diablo Dec. 26 2005 or 2006
Dry Casks at Diablo Canyon in California. NRC visit…

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Judge permits Uranium Mining Near Grand Canyon: No Tribal Consult, No Environmental Update; Appeal Expected

The Colorado River is a source of drinking water for Southern Californians.

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D_3516 Prehistoric granaries about Nankoweap in Marble Canyon, Grand Canyon National Park. Mark Lellouch, NPS

The nuclear fuel chain destroys the environment and kills from the start, with uranium mining, to the finish, with long-lived, deadly, nuclear waste. Why does the US government refuse to protect America’s National Forests and water supply? Why does it fail to uphold its obligations to the American Indians?Especially at the behest of foreign mining companies? Why must Americans fight foreign companies in court, and even fight Congressmen, to protect the land and water?
Boating down the Colorado River Below Havasu Creek in Grand Canyon National Park, by Mark Lellouch NPS
Boating down the Colorado River Below Havasu Creek in Grand Canyon National Part, by Mark Lellouch, NPS
Grand Canyon NPS
Grand Canyon, National Park Service (NPS)

Press Release from the Center for Biological Diversity:
April 8, 2015

Federal Judge OKs Uranium Mining Next to Grand Canyon National Park

Decision Allows Mining Without Tribal Consultation or Update Decades-old Environmental Review

PHOENIX, Ariz.— U.S. District…

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Childhood Cancer Near Nuclear Power Stations

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Another US NRC deadline is upon us for 24 March 2015: The following article by Dr. Ian Fairlie should prove helpful for the question about embryo-fetal exposure to radiation, dose assessment, and more. Dr. Fairlie has a degree in radiation biology and his doctoral studies concerned the radiological hazards of nuclear fuel reprocessing. [1] His research was instrumental in shutting down Quebec’s nuclear power station. His 2014 article, related to the one below, is discussed here: Commentary: childhood cancer near nuclear power stations Ian Fairlie © 2009 Fairlie; licensee BioMed Central Ltd.  p. 1Commentary: childhood cancer near nuclear power stations Ian Fairlie © 2009 Fairlie; licensee BioMed Central Ltd. , p. 2Commentary: childhood cancer near nuclear power stations Ian Fairlie © 2009 Fairlie; licensee BioMed Central Ltd. , p. 3Commentary: childhood cancer near nuclear power stations Ian Fairlie © 2009 Fairlie; licensee BioMed Central Ltd. , p. 4Commentary: childhood cancer near nuclear power stations Ian Fairlie © 2009 Fairlie; licensee BioMed Central Ltd. , p. 5Commentary: childhood cancer near nuclear power stations Ian Fairlie © 2009 Fairlie; licensee BioMed Central Ltd. , p. 6Commentary: childhood cancer near nuclear power stations Ian Fairlie © 2009 Fairlie; licensee BioMed Central Ltd.. p. 7Commentary: childhood cancer near nuclear power stations Ian Fairlie © 2009 Fairlie; licensee BioMed Central Ltd. , p. 8 Commentary: childhood cancer near nuclear power stations Ian Fairlie © 2009 Fairlie; licensee BioMed Central Ltd. , p. 9Commentary: childhood cancer near nuclear power stations Ian Fairlie © 2009 Fairlie; licensee BioMed Central Ltd. , p. 10Commentary: childhood cancer near nuclear power stations Ian Fairlie © 2009 Fairlie; licensee BioMed Central Ltd. , p. 11Commentary: childhood cancer near nuclear power stations Ian Fairlie © 2009 Fairlie; licensee BioMed Central Ltd. , p. 12 Highlight-Underline added. Original document here:

Note that many nuclear reactors do “Batch releases” of radionuclides into the air, and/or water, multiple times per year and not only when the fuel is changed. That is, some reactors leak constantly and some hold back the leaks until some of the short-lived radionuclides have become less radioactive or non-radioactive. Then they release the remaining longer and long-lived radionuclides all at once as “effluent”. Dilution…

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10/21/2015 Laguna Woods City Council approves San Onofre nuclear waste resolution

Laguna Woods City Council adopted San Onofre Resolution 15-02 regarding concerns about continued storage of 1,609 metric tons of highly radioactive spent nuclear fuel at San Onofre.  It states that while waste remains on-site “…it must be stored in a manner that is as safe as possible including, but not limited to, that it is inspectable, transportable, and includes continuous, real-time monitoring information that is made available to the public…” and

“…that the proper storage and disposition of spent nuclear fuel must be a consideration in the decommissioning process and that the decommissioning plan must not be considered complete until those issues are resolved…”

See Laguna Woods Resolution 15-02 SONGS Storage and Spent Nuclear Fuel, January 21, 2015.


Holtec HI-STORM UMAX air flow around thin walled canister

Community members spoke about significant and urgent issues concerning Southern California Edison’s plan to spend almost $1.3 billion for a Holtec UMAX canister system that cannot be inspected or adequately maintained.

A similar Holtec canister at Diablo Canyon has conditions for cracking after only two years of use due to salt in the marine environment, yet Edison is ignoring this and other critical issues. See Reasons to buy thick nuclear waste dry storage casks and myths about nuclear waste storage.

The Laguna Woods resolution along with a letter from the Mayor will be sent to state and federal regulators and elected officials urging them to join immediately in efforts set forth in this resolution. The resolution was adopted at the January 21, 2015 City Council Meeting.

The California Public Utilities Commission (CPUC) has not approved funds for the Holtec UMAX canister system. A pre-conference hearing on the CPUC San Onofre decommissioning proceeding (A1412007) will be held at the CPUC in San Francisco on March 2nd at 2:00 pm.  This January 9, 2015 response to Edison’s San Onofre Decommissioning Plan and Costs was submitted to the CPUC, expressing numerous concerns with Edison’s plans.

The Nuclear Regulatory Commission (NRC) has not approved the Holtec UMAX canister system Edison selected. Here are public comments submitted regarding why the Holtec UMAX system should not be approved by the NRC.

Edison has not considered the impact of on-site indefinite storage and the NRC has not completed their assessment of regulatory changes needed after the NRC August 26, 2014 decision allowing on-site indefinite storage. Here are San Onofre Safety comments submitted to the NRC regarding the San Onofre decommissioning plan and costs.

Most of the U.S. uses thin canister designs, such as Holtec. Most of the rest of the world uses thick casks that do not have the thin canister problems.  The NRC Division of Spent Fuel Management has chosen to weaken dry storage standards rather than raise them, in spite of the new requirement of indefinite on-site storage.  Learn more at

Reasons To Buy Thick Casks

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Radioactive Reindeer

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Reindeer pulling sleigh, Russia
Reindeer Pulling Sleigh Photo by Elen Schurova via wikimedia.

The Chernobyl accident is an obvious example of how human failures when dealing with a modern technical system can have global consequences and also be a potential threat to what we like to think of as the unspoiled wilderness of the Arctic.” (Ahman, 1995)

Reindeer are particularly at risk from nuclear fallout because Reindeer love to eat lichens, and lichens are excellent absorbers of radiation. The, 26 April, 1986, Chernobyl disaster is well-documented to have scattered radioactive caesium 137 (cesium 137), with a half life of about 30 years over Europe. This is very bad, as caesium is very similar to potassium and hence can be taken up by human and animal body as well. Potassium is one of the most important, and perhaps the most important element in the body, as it is necessary for…

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10/27/2014 Carlsbad: NRC San Onofre Decommissioning meeting

PRESS RELEASE                                                                            FOR IMMEDIATE RELEASE

 Media Contact:  Donna Gilmore,
Updated 2/22/2015 with this link to Official Transcript of 10/27/2014 NRC San Onofre Decommissioning meeting
San Onofre’s Decommissioning Plan is not what it’s cracked up to be
Are the nuclear waste dry storage canisters at San Onofre cracking?
No one knows, but Edison wants to buy more of these inferior canisters.

NUHOMS 32PTH canisterOctober 27, 2014 (Carlsbad, CA) – The Nuclear Regulatory Commission (NRC) should not approve Southern California Edison’s San Onofre Decommissioning Plan.[1]  Edison plans to use dry storage canisters designed for temporary short term storage for long-term indefinite storage. The mission has completely changed but the canisters have not. The thin steel canisters Edison is proposing are vulnerable to cracking within a few years and there is no way to know if they have cracks and the cracks cannot be repaired. Canisters with cracks cannot be stored or moved safely.

The NRC has scheduled a public meeting today from 6:00 p.m. to 9:00 p.m., to receive public comments on this plan. Meeting location is the Omni La Costa, Poinsettia Ballroom, 2100 Costa Del Mar Road in Carlsbad.

The NRC recently approved leaving the tons of highly radioactive nuclear waste at San Onofre and all other nuclear plants in the nation for 60 years (short-term), 100 years (long-term) and indefinitely. Edison’s plan does not address this new reality.

A 2014 partial surface inspection of a two year old Diablo Canyon nuclear waste dry storage canister found conditions for stress corrosion cracks – a low enough temperature for ocean salts to corrode and crack the ½” thick stainless steel canister.[2] The NRC originally said it would be at least 30 years before cracking might occur.[3]    Now both the NRC and Edison know better, but have not addressed this issue.

The NRC has not revised its spent fuel dry cask storage system requirements or its aging management plan given the above new realities. They plan to revise it in 2015.

Edison’s plan does not address many major issues. The ratepayers could be set up for another billion dollar boondoggle similar to the steam generator boondoggle where metal tubes failed within one year in a system that was supposed to last 40 years.  We’re facing similar problems with Edison’s decommissioning plan.  However, the consequences could be much worse. The NRC needs to do their job and not approve Edison’s plan.

No technology exists to inspect or repair the thin steel canisters Edison wants to procure. Not even the outside of these thin 5/8” thick canisters can be inspected.

Cracked canisters must be replaced. Edison has allocated no money to replace cracked canisters and these welded canisters were not designed to be opened. Instead, Edison wants to eliminate the spent fuel pools even though this is the only on-site method to transfer fuel into another canister.

No seismic rating for cracked canisters exists. The NRC proposes allowing up to a 75% crack before canisters must be taken out of service. However, cracked canisters have not been evaluated for earthquake conditions. And cracked canisters are not approved for transport.

It is unknown if existing San Onofre canisters are cracked, yet Edison wants to buy more of this same inferior technology and they have no money allocated to replace the existing canisters with better technology, over the many decades they plan to leave them on our coastline.

There is no early warning monitoring system. We won’t know the canisters have failed until after they leak radiation into the environment. If one fails, they all could fail and yet there is no contingency plan for this possibility.

Castor-V-19 cask

Castor V/19 cask

Edison refuses to allow bidding from vendors with the most widely used dry storage technology in the world (e.g., ~20” thick Castor ductile cast iron casks), even though this technology does not have the problems of the thin canisters. Germany, Japan and other countries use thick casks and house them in reinforced buildings for additional environmental and other external hazards. Edison should do this, too.

The NRC has no aging management plan for stress corrosion cracking or other degradation issues with these canisters – either short-term or long term. And they plan to require inspection of only one canister per facility and only of the exterior surface. The NRC is allowing the industry 5 years to develop technology to inspect the exterior for cracks. However, this will be challenging to accomplish, since the steel canisters provide no protection from gamma and neutron radiation, so must be inspected while inside a concrete overpack or concrete cask. If they do find cracks they still have no way to repair them in.


The NRC needs to revise their NUREG-1927, “Standard Review Plan for Renewal of Spent Fuel Dry Cask Storage System Licenses and Certificates of Compliance” [4] before approving a decommissioning plan for San Onofre.

The NRC needs to revise these standards to reflect the best available dry storage technology in the world and not lowered due to the limitations of current U.S. thin steel canister designs. The NRC must not approve this incomplete and inadequate decommissioning plan until all these issues are resolved.  To do otherwise, risks the future of California and threatens the food supply, health and economy of our nation and our families.

Edison should allow vendors with better cask technology to bid on this project. We need a nuclear waste storage system that can be inspected, repaired, and adequately monitored or ratepayers may be on the hook for millions or billions more than collected in the decommissioning fund. Until adequate funds are assured, the NRC should not approve Edison’s plan.


PDF printable version of press release (revised)


[1] NRC webpage: Plans for Decommissioning of San Onofre Nuclear Generating Station Units 2 and 3
[2] Diablo Canyon: conditions for stress corrosion cracking in 2 years, D. Gilmore, October 2014
[3]  Summary of August 5, 2014 Public Meeting with the Nuclear Energy Institute on Chloride Induced Stress Corrosion Cracking Regulatory Issue Resolution Protocol  
[4] NUREG-1927, Standard Review Plan for Renewal of Spent Fuel Dry Cask Storage System Licenses and Certificates of Compliance, March 2011

Decom Fund Assurance 9-26-2013Slide35

Meeting information from the previous NRC public meeting on San Onofre Decommissioning held September 26, 2013:

Meeting summary
Meeting Transcript
Posted in Action Alert, Events, NRC, Nuclear Waste, Press Release, SDG&E, Southern California Edison | Tagged , , , , , , , , , , , , , , , , , , , | 1 Comment

Battle For The Net

If you woke up tomorrow, and your internet looked like this, what would you do? Imagine all your favorite websites taking forever to load, while you get annoying notifications from your ISP suggesting you switch to one of their approved “Fast Lane” sites.Think about what we would lose: all the weird, alternative, interesting, and enlightening stuff that makes the Internet so much cooler than mainstream Cable TV. What if the only news sites you could reliably connect to were the ones that had deals with companies like Comcast and Verizon?On September 10th, just a few days before the FCC’s comment deadline, public interest organizations are issuing an open, international call for websites and internet users to unite for an “Internet Slowdown” to show the world what the web would be like if Team Cable gets their way and trashes net neutrality. Net neutrality is hard to explain, so our hope is that this action will help SHOW the world what’s really at stake if we lose the open Internet.If you’ve got a website, blog or tumblr, get the code to join the #InternetSlowdown here: else, here’s a quick list of things you can do to help spread the word about the slowdown: Get creative! Don’t let us tell you what to do. See you on the net September 10th!

via Battle For The Net.

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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
Posted in Action Alert, CPUC, How to Help, NRC, Nuclear Waste, PG&E, Press Release, Southern California Edison | Tagged , , , , , , , | 12 Comments

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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