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

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

Stanford engineer Jacobson: U.S. can attain all renewable energy by 2050

Post revised 7/28/2014 to reference Mark Jacobson’s California study, A roadmap for repowering California for all purposes with wind, water, and sunlight, June 2014.

This study presents a roadmap for converting California’s all-purpose (electricity, transportation, heating/cooling, and industry) energy infrastructure to one derived entirely from wind, water, and sunlight (WWS) generating electricity and electrolytic hydrogen. California’s available WWS resources are first evaluated. The plan contemplates all new energy from WWS by 2020, 80 to 85% of existing energy converted by 2030, and 100% by 2050. Electrification plus modest efficiency measures may reduce California’s end-use power demand ~44% and stabilize energy prices since WWS fuel costs are zero. Several methods discussed should help generation to match demand. A complete conversion in California by 2050 is estimated to create ~220,000 more 40-year jobs than lost, eliminate ~12,500 (3800 to 23,200) state air-pollution premature mortalities/yr, avoid $103 (31 to 232) billion/yr in health costs, representing 4.9 (1.5 to 11.2)% of California’s 2012 gross domestic product, and reduce California’s 2050 global climate cost contribution by $48 billion/yr. The California air-pollution health plus global climate cost benefits from eliminating California emissions could equal the $1.1 trillion installation cost of 603 GW of new power needed for a 100% all-purpose WWS system within ~7 (4 to 14) years.

Stanford engineer, Mark Z. Jacobson, is confident in U.S. ability to attain all-renewable energy by 2050. Jacobson is professor of civil and environmental engineering and senior fellow with the Stanford Woods Institute for the Environment On October 9th, Jacobson discussed his plan on the Late Show with David Letterman. Jacobson’s studies show the feasibility of converting global, national and state energy infrastructures to all-renewable sources.

“There’s no technological or economic limitation to solving these problems,” said Jacobson, who is director of Stanford’s Atmosphere/Energy Program and a senior fellow with the Precourt Institute for Energy. “It’s a social and political issue, primarily.”

Jacobson and his co-authors have published studies on how to switch to all solar, wind and water energy sources for the world, the United States, New York state and California. They have plans to do studies for all 50 U.S. states.

The plans show the way to a sustainable, inexpensive and reliable energy supply that could create local jobs and save billions of dollars in pollution-related health costs. They outline paths to fulfilling all transportation, electric power, industry, and heating and cooling energy needs with renewable energy by 2050.

To do this, they calculate the number of new devices and jobs created, land and ocean areas required, and policies needed for infrastructure changes. Jacobson expressed confidence in America’s ability to rise to the occasion. “In World War II, the U.S. produced 330,000 aircraft within five years just because it was necessary.”

Mark Jacobson: Clean Energy Solutions

Jacobson Plants to power California

The following map shows spacing and footprint areas required to repower California for all purposes in 2030.

The dots do not indicate the actual location of energy farms. For wind, the small red dot in the middle is footprint on the ground (not to scale) and the green or blue is space between turbines. For others, footprint and spacing are the same. For rooftop PV, the dot represents the rooftop area needed. Source: Evaluating the Technical and Economic Feasibility of Repowering California for all Purposes with Wind, Water, and Sunlight, Mark Z. Jacobson, Ph.D, et al. May 22, 2013

Jacobson Area To Power All of California

. April 16, 2013 Mark Jacobson presents his findings on the technical feasibility of a 100% renewable energy world by 2050.  Pathways to 100% Renewable Energy Conference at Fort Mason in San Francisco.  

More information and the Solutions Project

. TED Debate: Does the world need nuclear energy? Jacobson vs. Brand

Posted in Energy Options, Video | Tagged , , , , , , , , , | 1 Comment

10/19/2013 San Clemente Symposium: Decommissioning San Onofre and the dangers of high burnup fuel

The Coalition to Decommission San Onofre and the Sierra Club Angeles Chapter organized this San Clemente community symposium with world renowned nuclear experts to discuss San Onofre decommissioning, nuclear waste issues and radiation dangers. Below are handouts, presentations and video highlights from the symposium.  For more information on these issues, go to

High Burnup Handout
Worst Safety Record Handout
Dr. Donald Mosier presentation
Dr. Marvin Resnikoff presentation
Dr. Arjun Makhijani presentation

Video highlights from press conference and symposium

Medical reference for cancer risk from mammogram: Breast Cancer and the Environment: A Life Course Approach (2012), Institute of Medicine of the National Academies. Authors: Committee on Breast Cancer and the Environment: The Scientific Evidence, Research Methodology, and Future Directions; Institute of Medicine. Appendix F contains information on the mammogram (xray) cancer risks referenced in Dr. Mosier’s presentation as well as the current NRC nuclear worker occupational radiation dose limits. The NRC webpage for occupational dose limits is

More videos to be added.

Date: Saturday, October 19, 2013 
Time: 1:30 p.m. to 5:30 p.m. PDT
Press Conference1:00 p.m.
Location: 1201 Puerta Del Sol, 1st floor, San Clemente, CA 92673 
Cost & Parking: Free.

San Onofre nuclear reactors are permanently shut down. However, we are still at risk for a nuclear disaster from the tons of highly radioactive nuclear waste. This waste sits along our coastline and will remain there for the foreseeable future. 

In June, environmental activists won a big victory when the troubled San Onofre nuclear plant ceased operations permanently. The current dispute over defective technology between Southern California Edison and Mitsubishi confirms how necessary this outcome was.

Environmental and citizen groups had only a short time to celebrate averting the risk posed by continued operation of the plant. Almost immediately it became clear that this site, wedged between Interstate 5 and the Pacific shoreline, poses a huge challenge of radioactive nuclear waste stored at the plant.

Much of the waste is a higher radioactive form of spent fuel known as “high burnup fuel,” stored in densities far higher than original design specifications and more unstable than lower burnup fuel.

San Onofre’s use of high burnup fuel puts us at greater risk for a nuclear disaster. The Nuclear Regulatory Commission has not approved a transport method for high burnup fuel and says there is insufficient data to support storing it in dry casks for more than 20 years.” Donna Gilmore, See details at

Large uncertainties persist about where the waste will ultimately be stored and for how long. Billions of dollars of taxpayer and ratepayer money will be required to resolve these uncertainties. The issues involved in “decommissioning” San Onofre were secondary during the shutdown debate but now they loom large.

The Saturday Community Symposium in San Clemente will include these nationally regarded experts.

Dr. Arjun Makhijani

Dr. Arjun Makhijani, President of the Institute for Energy and Environmental Research — an expert on Hardened On Site Storage of nuclear waste and long-term management of high-level waste. He holds a Ph.D. in engineering (specialization: nuclear fusion) from the University of California at Berkeley. He has produced many studies and articles on nuclear fuel cycle related issues, including weapons production, testing, and nuclear waste, over the past twenty years. He is the principal author of the first study ever done (completed in 1971) on energy conservation potential in the U.S. economy. Most recently, Dr, Makhijani has authored Carbon-Free and Nuclear-Free: A Roadmap for U.S. Energy Policy (IEER Press), the first analysis of a transition to a U.S. economy based completely on renewable energy, without any use of fossil fuels or nuclear power. He is the principal editor of Nuclear Wastelands and the principal author of Mending the Ozone Hole, both published by MIT Press.

Dr. Marvin Resnikoff

Dr. Marvin Resnikoff, Senior Associate at Radioactive Waste Management Associates — an international consultant on radioactive waste issues. A nuclear physicist and a graduate of the University of Michigan, Dr. Resnikoff has worked on radioactive issues since his first project at West Valley, New York in 1974. Throughout his career, he has assisted public interest groups and state and local governments across the U.S. in order to identify and create solutions for radioactive waste storage and transportation issues. His recent research focus has been on the risk of transporting and storing radioactive waste and the health impact of radioactive waste from oil and uranium production. He has studied NORM issues for the past 20 years and more recently, NORM in Marcellus shale. Dr. Resnikoff has also co-authored four books on radioactive issues, including Deadly Defense and Danger Below, regarding contamination at DOE facilities. In June 2000, he was appointed by DOE secretary Bill Richardson to a Blue Ribbon Panel on Alternatives to Incineration.

Don Mosier

Dr. Donald Mosier, member of Department of Immunology, Scripps Research Institute, and Del Mar City Council member — an expert on the public health effects of radiation.  He graduated medical school at the University of Chicago, where he obtained his Ph.D. in 1969 and his M.D. with honors in 1971. Following post-doctoral training in London and Boston, Don received a commission in the U.S. Public Health Service and fulfilled his service obligation at the National Institutes of Health in Bethesda, MD. In 1978, he accepted academic positions at The Institute for Cancer Research and the University of Pennsylvania in Philadelphia. In 1985, became the Division Head at The Medical Biology Institute in La Jolla. In 1992, Don moved to the Department of Immunology at The Scripps Research Institute, where he is a Professor.

The immediate goal of the symposium is to assure that “best practices” are applied to make the decommissioning of San Onofre as safe as possible and minimize both short and long-term risk to Southern California residents.

The ultimate goal of the symposium is to rejuvenate the national dialog about how the U.S. manages nuclear waste, including the safest on-site and remote storage options.

Co-sponsors of the symposium include the Sierra Club Angeles Chapter and the Coalition to Decommission San Onofre. The Coalition includes the Peace Resource Center of San Diego, San Clemente Green, Women Occupy San Diego, Citizens Oversight Project,, and Residents Organized for a Safe Environment (ROSE).

Posted in Action Alert, Events, NRC, nuclear power, Nuclear Waste, SDG&E, Southern California Edison, Video | Tagged , , , , , , , , , , , , , , | 1 Comment

10/8 and 10/9/2013 NYC and Boston: Fukushima Lessons

See videos of New York, Boston and San Diego Fukushima Lessons seminars:

World renown leaders and experts discuss ongoing lessons from the Fukushima Daiichi nuclear catastrophe and the future of nuclear power.

The Fukushima Nuclear Accident - Ongoing Lessons
New York City Seminar Tuesday, October 8th
9:00 AM – 1:00 PM EST (6:00 AM – 10:00 AM PST)
92nd Street Y, 1395 Lexington Avenue, New York, NY 10128 (Theresa L. Kaufmann Concert Hall)
Boston Seminar Wednesday, October 9th
10:00 AM – 2:00 PM EST (7:00 AM – 11:00 AM PST)
Massachusetts State House, 24 Beacon Street, Boston, MA 02133 (Gardner Auditorium)


Ralph Nader, political activist, author, lecturer, and attorney, was recently added to the New York panel discussion which will address the lessons to be learned from the Fukushima Daiichi nuclear accident and the concerns regarding Indian Point Nuclear Power Station.

Additional speakers on the panel include former Japanese Prime Minister, Naoto Kan; former Chairman of the U.S. Nuclear Regulatory Commission (NRC), Dr. Gregory Jaczko; former NRC Commissioner Peter Bradford; and world renown nuclear engineer, Arnie Gundersen.

They will share their perspectives on nuclear safety for the city’s respective power plant and the future of nuclear power. The panel in New York will be moderated by the President of Riverkeeper, Paul Gallay and in Boston by WGBH’s Sean Corcoran.

NRC  Probabilistic Risk Analysis Fairewinds 2013-06-04

Probabilistic Risk Assessment (PRA- pray for short)
— Arnie Gundersen

The panels discuss concerns regarding Indian Point Nuclear Power Plant, now operating with an expired license in Buchanan, New York and Pilgrim Nuclear Generating Station in Plymouth, Massachusetts. There are multiple concerns regarding both plants’ overcrowded storage of spent nuclear fuel rods.  Indian Point contains almost three times the amount of radioactive material in its spent fuel pools as Fukushima Daiichi. U.S. citizens are now questioning the safety of the Indian Point and Pilgrim nuclear power plants.

Pilgrim’s crowded storage pools are currently holding up to three times more spent fuel rods than they were designed to handle and can potentially be more dangerous than the nuclear reactors themselves. Earlier this year, a plant manager at Indian Point falsified test data on generator emissions due to high levels of particulate pollution which would cause the plant to close.

Car Air Filters Fukushima Radiation Fairewinds2013-06-04

Arnie Gundersen 6-4-2013 San Diego presentation

In the event of a catastrophe like the Fukushima Daiichi nuclear accident, these plants would threaten millions. A nuclear disaster at Indian Point would threaten the entire population of New York City and the outlying metropolitan area. A crisis at Pilgrim poses similar danger to millions within 50 miles of the Plymouth plant including Boston, Cape Cod and surrounding areas.

Ralph Nader has opposed nuclear power since the 1970s and he later founded the Critical Mass Energy Project. Nader was recently named by The Atlantic as one of the 100 most influential figures in American history; one of only four living people to be so honored. He has launched two major presidential campaigns and founded or organized more than a hundred civic organizations.

Tokyo: Fukushima radiation particles - Gundersen

140 miles from Fukushima!

Former Japanese Prime Minister Kan was in office in March 2011 when an earthquake and tsunami triggered the catastrophe at the Fukushima Daiichi nuclear plant. He was confronted by three reactor meltdowns and a nuclear crisis that continues to this day.  Dr. Gregory Jaczko was the Chairman of the NRC during that time. In 2012, Jaczko cast the lone dissenting vote on plans to build the first new nuclear power plant in the U.S. in more than 30 years.

Earlier this year on June 4, 2013, Jaczko, Bradford and Gundersen were joined by Japan’s former Prime Minister, Naoto Kan, where they spoke in San Diego about their concerns regarding the safety of the San Onofre nuclear power plant. The plant was closed permanently a few days after the presentation. See details and video of the San Diego event.

Indian Point is a three-unit nuclear power station located in Buchanan, New York, 25 miles outside New York City. Potential risk of a nuclear crisis at Indian Point would pose a danger to millions in the New York area. The technology at the plant is 40 years old, and the containment domes were not designed to hold 100 tons of melting uranium in event of an accident and meltdown. Both Chernobyl and Fukushima are examples of accidents in outdated nuclear reactors.

Pilgrim Nuclear Generating Station is located in Plymouth, MA, 40 miles outside Boston. Last summer, Jaczko and the community presented legal appeals and environmental warnings to shut down Pilgrim. However, the NRC renewed the 40-year-old nuclear plant’s license for another 20 years despite these oppositions. A nuclear crisis at Pilgrim would pose a danger to millions of people who live within 50 miles of Pilgrim, including those in the city of Boston.

New York Event Facebook page:
More information:

Please donate. These conferences depend completely on the kindness of others. 100% of your donation goes to support direct costs, not administrative costs. Event organizers work pro bono and none of the speakers received honorariums. Expenses included board and flights for the speakers, including Naoto Kan’s team from Japan.  Tax deductible donations can be made to the Samuel Lawrence Foundation.   The Samuel Lawrence Foundation is privileged to sponsor this collection of international leaders and thanks you for your generous support.  Checks can be addressed to:

Samuel Lawrence Foundation Education Fund
Drawer F, Del Mar, CA 92014
Or donate securely through Paypal at
Direct inquiries to
Posted in Events, Fukushima, nuclear power | Tagged , , , , , , , , , , , , , , | Leave a comment

10/01/2013 San Diego: CPUC hearing on San Onofre costs

The California Public Utilities Commission (CPUC) is holding its first Public Participation Hearing (PPH) in San Diego on how much the captive ratepayers of Southern California Edison (SCE) and San Diego Gas and Electric (SDG&E) should pay for the defective San Onofre Power Plant. Please attend, even if you can only attend part of the session.

SCE and SDG&E customers pay about 50% more than the customers of the two largest California municipal electric utilities. Now SCE and SDG&E want us to pay for Edison’s defective nuclear reactor boondoggle. Enough is enough!  (Click for “Compare Rates and Edison Liability” Handout)

Ratepayers’ message to SCE & SDG&E:  YOU BREAK IT, YOU BUY IT!

Compare Your Electric Rates 2012-04

CPUC Public Hearing

Tuesday, October 1, 2013
2:00 pm – 5:00 pm and 6:30 pm – 9:30 pm 
Al Bahr Shriners Building
5440 Kearny Mesa Rd.
San Diego, CA 92111
1:00 pm  Press Conference outside building entry by Coalition to Decommission San Onofre (CDSO). Contact: Ray Lutz,, 619/820-5321
Parking is free and shared with the Hampton Inn San Diego-Kearny Mesa Hotel
Telephone: listen-only toll-free phone line at 877-347-9604, passcode 771069
Audio webcast: available in real-time and archived thereafter via audio webcast.

CPUC meeting information:

Members of the public who wish to address the CPUC must sign in at the Public Participation Hearings and will be called upon in the order listed on the sign-in sheet. Community-based organizations and other groups are encouraged to identify one or two speakers to represent the views of the organization’s members. Elected officials attending the PPH are allowed to speak first. If a large number of people sign-up to speak, the ALJ may set a time limit in order to allow everyone a chance to be heard. There will be a CPUC court reporter present to record your comments for the official record.
Public participants may not bring to PPHs signs larger than 8.5 in x 11 in, or signs of any size with supports or handles (wood, metal, etc).
The CPUC opened this multiphase investigation to consolidate and consider issues raised by the extended outages of Units 2 and 3 at SONGS. Generally, the proceeding is focused on any warranted refunds to ratepayers or rate reductions. The Phase 2 Evidentiary Hearings on October 7-11, 2013 will consider the removal from rate base of non-useful capital assets at SONGS. Other phases of the proceeding have or will address other SONGS-related cost issues. These Public Participation Hearings are an opportunity for the CPUC to hear from the public about how the CPUC should adjust rates as a result of the non-operation of SONGS.  Administrative Law Judges Darling and Dudney, along with Commissioner Florio, will represent the CPUC at the meeting in San Diego.

Ratepayers’ message to SCE & SDG&E: YOU BREAK IT, YOU BUY IT!

The Coalition to Decommission San Onofre, a non-profit volunteer grassroots organization representing the interests of the 8.5 million people living within 50 miles of this defunct nuclear power plant (now a highly radioactive nuclear waste dump), recently submitted the following testimony in this investigation:

    • The San Onofre Nuclear Power Plant was not “used and useful” at any time after the emergency shutdown on January 31, 2012. Furthermore, as soon as the Root Cause Analysis had been completed by SCE for both Units 2 and 3 on May 7, 2012, it should have been clear to any reasonable manager that the plant would never run again. The U.S. Nuclear Regulatory Commission (NRC) just published its finding that SCE failed to identify a flawed design for four replacement steam generators, which led to excessive wear to hundreds of tubes that carried radioactive water.  See Page 25 of  this September 20, 2013 NRC Confirmatory Action Letter Response Inspection Report (NRC ML13263A271.pdf), showing SCE’s awareness of the problems in the design stage.
    • The CDSO argued in Phase 1 of this CPUC investigation that SCE did NOT exercise reasonable managerial skill in designing, fabricating, installing and troubleshooting the Steam Generator Replacement Project (SGRP) and related High Pressure Turbine (HPT) project, and Phase 3, the Reasonableness Review of the SGRP, remains to be conducted. Therefore, the CPUC has no basis on which to make the findings proposed by SCE and SDG&E in Phases 1 or 2 of the investigation.
    • The calculation of net investment in fixed assets should be based on the plant without the defectively designed and failed SGRP and systems replaced contingent upon it. As a rough estimate, the base plant value, not including these failed/superfluous systems is about $449 million net investment in the core plant ($1,241 – $768 [SGRP] – $24 [HPT] = $449 million) . The $792 million difference between $1,241 and $449 represents the loss incurred by the failure of the SGRP and should be resolved between SCE and Mitsubishi Heavy Industries, and any insurance, with the rest covered by shareholders (through loss of their equity).
    • Any remaining assets not already fully depreciated should be depreciated at a rate to allow investors to recover their investment, but not enjoy a return on the investment due to the inherent risk involved in such investments. Allowing investors to be risk-free in their investment continues to incentivize monopoly utilities to develop failed projects that run only for a short time, so they can have the entirety of their investment returned plus a return on investment (ROI) and have it returned faster than the normal depreciation schedule. This is an extremely counterproductive regulatory policy which has been fully exposed by the magnitude of this failed SGRP and its consequent costs. The CPUC needs no further reason to recognize this and cease repeating this perverse policy.
    • San Onofre should be removed from the rate base at the earliest date allowed under Public Utilities Code Section 455.5: November 1, 2012; and all activities subsequent to November 1, 2012, considered “decommissioning” as the plant is no longer used and useful. The defectively-designed and failed Steam Generator Replacement Project and related High Pressure Turbine project should be treated as an abandoned plant, and therefore, shareholders should not recover their equity nor any return on their equity investment on them. The Investor-Owned Utilities who are the gatekeepers to our transmission grid and generation resources do NOT need any more help from this Commission. We ratepayers who fund their lavish compensation and can barely support ourselves, our families, and our small businesses, DO. To wit …
Posted in Action Alert, CPUC, Events, nuclear power, Press Release, SDG&E, Southern California Edison, Steam Generator | Tagged , , , , , , , , , | 1 Comment

09/26/2013 Carlsbad NRC meeting: Decommissioning San Onofre

Meeting summary
Meeting Transcript

Note 10/27/2014: NRC’s Larry Camper, said a separate meeting will be scheduled regarding high burnup fuel. However, this was never scheduled. Edison plans to store high burnup fuel in a new dry cask that will increase our risks. Learn about these critical issue on this handout:  Core Message to the NRC handout (9/26/2013).

The Nuclear Regulatory Commission (NRC) staff will hold a public meeting in Carlsbad, California, to discuss the decommissioning process for nuclear power reactors, including the San  Onofre Nuclear Power Plant.  Please attend this important meeting. 

Location:  Omni LaCosta Hotel2100 Costa del Mar Road, Carlsbad, CA 92009
Date: Thursday, September 26, 2013
Time: 6-9 p.m. Doors open at 5 p.m. to to accommodate security bag checks.
Parking: Free self-parking available.
La Costa Hotel: 800-854-5000 or 760-438-9111
NRC Contact: John Hickman, FSME 301-415-3017 

One Day Son All This Will Be YoursSan Onofre is shut down, but there are many risks and costs related to the decommissioning process.  For example, California’s San Onofre and Diablo Canyon nuclear power plants use high burnup fuel, making the decommissioning process and storage of the tons of nuclear waste much more dangerous.

  • High burnup fuel results in waste that is hotter and over twice as radioactive, requiring the waste to be cooled on-site in spent fuel pools for at least 12-15 years (rather than 5 years). Water must continuously flow over the nuclear waste in these pools or the waste will overheat resulting in a potential nuclear radiation disaster.San Onofre cask loading into storage bunker
  • The NRC has not approved a transport dry storage cask nor even short term dry cask storage (over 20 years) for high burnup fuel.  
  • The initial NRC high burnup dry cask storage approval (for 20 years) was based on assumptions that are proving incorrect. The high burnup fuel assemblies are showing unpredictable increases in wear on materials and components.
  • Higher fuel burn-up results in increased environmental and human health consequences in the event of an accident resulting in the release of radioactive substances.
  • More information and sources at

Question for the NRC: Why is the NRC continuing to allow high burnup fuel at U.S. nuclear reactors when they don’t have an approved safe solution to store or transport this waste — even short-term?

At this public meeting the NRC will respond to questions about the decommissioning process, but will be unable to answer specific questions concerning Southern California Edison’s plans for decommissioning San Onofre, as that information is not yet available. This is a Category 3 public meeting. The public will have an opportunity to ask questions at the end of the NRC presentations. TELECONFERENCE: Members of the public can listen to this meeting via the following one-way toll-free phone bridge: 1-888-469-2078. Passcode 2185334. The audio stream will be available once the meeting begins.  Questions or comments regarding the decommissioning process for power reactors can be submitted at any time to This meeting will be videotaped and transcribed by the NRC. It will be available on the NRC webpage ( following the meeting. The meeting transcript will be placed in the Agencywide Documents Access and Management System (ADAMS) following the meeting to provide a written account of this meeting. Docket Nos. 50-361 and 50-362. Information associated with NRC’s regulatory oversight of the decommissioning of nuclear facilities is publicly available at Participants from the NRC include:

Larry Camper, Director, Division of Waste Management and Environmental Protection, FSME
Bruce Watson, Chief, Reactor Decommissioning Branch, FSME
Blair Spitzberg, Chief, Repository and Spent Fuel Safety Branch. RIV
Michael Dusaniwskyj, Financial Analyst, Financial Analysis & International Projects Branch. NRR


6:00 p.m. – 6:10p.m. Welcome, agenda and ground rules for Q & A session (Chip Cameron, Facilitator)
6:10p.m. – 6:20 p.m. NRC Decommissioning Overview (Larry Camper)
6:20 p.m. – 6:35 p.m. Reactor Decommissioning Process (Bruce Watson)
6:35 p.m. – 6:45 p.m. Decommissioning Inspection Program (Blair Spitzberg)
6:45 p.m. – 6:50 p.m. Decommissioning Funding (Mike Dusaniwskyj)
6:50 p.m. – 7:00 p.m. Spent Fuel Management (Blair Spitzberg)
7:00 p.m. – 9:00 p.m. Questions and comments from members of the public (Chip Cameron)
9:00 p.m.  Adjourn Enclosure
2013-09-26 NRC meeting announcement and agenda (ML13238A283)
2013-09-26 Handout – Core Message to the NRC from Coalition to Decommission San Onofre

Note: Although not part of this NRC meeting, Southern California Edison submitted written testimony to the California Public Utilities Commission for possible decommissioning scenarios. See SONGS 2 & 3 Early Decommissioning Scenario – CPUC Supplemental Testimony, July, 22, 2013 For an inventory of dry casks stored at San Onofre and Diablo Canyon nuclear power plants, see last pages on the these NRC inspection reports:

For more information, go to

San Onofre Nuclear Spent Fuel Pool

San Onofre transfer pool

Posted in Action Alert, Events, NRC, nuclear power, Nuclear Waste, SDG&E, Southern California Edison | Tagged , , , , , , , , , , | 2 Comments

6/4/2013 San Diego Seminar – Fukushima Daiichi Disaster: Lessons for California

Fukushima Hydrogen Explosion March 2011

This historic seminar is available on video at these locations:

Arnie Gundersen’s slide presentation provided compelling information about radiation from Fukushima and the scientific case as to why it would be a nuclear experiment to restart San Onofre with it’s defective steam generators.  Note: This is a large file, so please be patient while it loads.


Former Japanese Prime Minister Naoto Kan visits San Diego on Tuesday, June 4th, to speak about his experiences in a seminar entitled, “The Fukushima Daiichi Disaster: Ongoing Lessons for California.”

He will be joined by former U.S. Nuclear Regulatory Commission (NRC) Chair Gregory Jaczko, who led the Commission during the Fukushima Daiichi nuclear meltdown. Also included on the panel will be former NRC Commissioner Peter Bradford, world renown nuclear engineer Arnie Gundersen, and Kendra Ulrich from Friends of the Earth.  Prime Minister Kan will be welcomed by San Diego County Supervisor Dave Roberts.

The panel discussion will be open to the public and media. It will be webcast live, worldwide at

Date:  June 4, 2013 8:30 am – 11:30 am (doors open at 8:00 am)
San Diego County Supervisors Chambers
1600 Pacific Highway
San Diego, CA 92101
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Bill Walker  (510) 759-9911
Alex Frank  (703) 276-3264 or
Annie Eddey  (619) 955-5285 x102

Coalition of Concerned Citizens of Southern California, Friends of the Earth in cooperation with Physicians for Social Responsibility, and the Samuel Lawrence Foundation, are honored to welcome Japan’s former Prime Minister Naoto Kan to San Diego to share his perspective on nuclear safety and the future of nuclear power. Kan was in office March, 2011, when an earthquake and tsunami triggered the Fukushima Daiichi nuclear plant catastrophe. He was confronted by three reactor meltdowns and a nuclear crisis that continues today.

The panel discussion provides Southern California with an opportunity to learn lessons from the ongoing Fukushima Daiichi disaster while awaiting a decision on the restart of San Diego’s crippled San Onofre nuclear reactors. Kan will discuss his concerns about the inherent dangers posed by nuclear reactors.

former Japanese Prime Minister Naoto KanNaoto Kan, as Japan’s Prime Minister during the beginning of the 2011 Fukushima nuclear disaster, realized there was a chance that people might not be able to live in the capital zone including Tokyo and would have to evacuate. Mr. Kan declared the need for Japan to end its reliance on atomic power and promote renewable sources of energy, such as solar that have long taken a back seat in the resource-poor country’s energy mix. Mr. Kan resigned as Prime Minister in August 2011 and now serves the Democratic Party of Japan to garner support for alternative energy policies.

former U.S. Nuclear Regulatory Commission (NRC) Chair Gregory Jaczko

Former NRC Chair Gregory Jaczko, has emerged as a leading critic of safety at U.S. nuclear power plants. During the Fukushima crisis, Chairman Jaczko recommended that Americans evacuate 50 miles outside Fukushima. In February 2012 Mr. Jaczko cast the lone dissenting vote on plans to build the first new nuclear power plant in more than 30 years when the NRC voted 4-1 to allow Atlanta-based Southern Co. to build and operate two new nuclear power reactors at its existing Vogtle nuclear power plant in Georgia. He cited safety concerns stemming from Japan’s 2011 Fukushima nuclear disaster, stating, “I cannot support issuing this license as if Fukushima never happened.” His pro-safety stance caused much friction with the other commissioners, resulting in his departure from the NRC. He has since been appointed to a post on a Congressional panel overseeing the National Nuclear Security Administration.

Peter A. BradfordPeter A. Bradford is an adjunct professor at the Vermont Law School, a former U.S. NRC Commissioner, and a former utility regulatory commission chair in New York and Maine.  Mr. Bradford was a member of the NRC during the Three Mile Island accident.  He taught at the Yale School of Forestry and Environmental Studies and currently is an Adjunct Professor at Vermont Law School teaching “Nuclear Power and Public Policy”. A member of the China Sustainable Energy Policy Council, he served on a recent panel evaluating the reliability of the Vermont Yankee nuclear power plant, on the European Bank for Reconstruction and Development Panel advising how best to replace the remaining Chernobyl nuclear plants in Ukraine, a panel on the opening of the Mochovce nuclear power plant in Slovakia, and the Keystone Center collaborative on nuclear power and climate change. He is the author of “Fragile Structures: A Story of Oil Refineries, National Securities and the Coast of Maine” and many articles. He is a graduate of Yale University and the Yale Law School and is Vice Chair of the board of The Union of Concerned Scientists.

Arnie Gundersen is chief engineer of the energy consulting company Fairewinds Associates and a former nuclear power industry executive. Fairewinds has developed extensive reports on Fukushima, San Onofre, and other nuclear power plants. Arnie has 40-years of nuclear power engineering experience. He attended Rensselaer Polytechnic Institute (RPI) where he earned his Bachelor Degree cum laude while also becoming the recipient of a prestigious Atomic Energy Commission Fellowship for his Masters Degree in nuclear engineering. Arnie holds a nuclear safety patent, was a licensed reactor operator, and is a former nuclear industry senior vice president. During his nuclear power industry career, Arnie also managed and coordinated projects at 70-nuclear power plants in the US.

Kendra UlrichKendra Ulrich is a nuclear campaigner for Friends of the Earth and Board Member of Beyond Nuclear. She focuses on protecting people and the environment from the threats posed by nuclear energy. Her work is grounded in the basic tenant that all people, both current and future generations, have the intrinsic right to a safe and healthy environment. Prior to joining Friends of the Earth, she spent nearly a decade working on a variety of pollution and energy issues with environmental advocacy organizations. She holds an M.S. in Environmental Studies with a concentration in Advocacy for Social Justice and Sustainability from Antioch University New England.

Torgen Johnson, an urban planner from Solano Beach helped to organize Tuesday’s event. He said speakers were selected because they are authoritative voices with a critical outlook on the industry.  “They’re all independent,” he said. “They’ve taken risks with their own careers to put the public first.”

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