Saturday, August 13, 2016

Types of Ionizing Radiation and the EPA's new proposed "emergency" standards...

This is a brief overview of the four types of ionizing radiation, followed by a discussion of the EPA's proposed new rules for "emergency" radiation limits after an accidental release of radioactive materials.

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What is radiation and why is it harmful?
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There are four types of ionizing radiation: Alpha, Beta, Neutron and Gamma (and x-ray, which is a lower-energy emission than gamma rays, and thus less damaging, but otherwise identical to gamma ray emissions).

There are 20 levels or "weighting factors" of radiation damage from various emissions, depending on energy levels of the emission and type of emission/penetration capabilities (alpha, beta, neutron and gamma/x-ray each penetrate differently).

Beta particles, gamma rays and x-rays are all classified as level 1 -- the least damaging for a given energy level. Alpha particles are level 20 -- the most damaging. Neutrons are classified at level 5, 10, or 20 depending on their energy level. Interestingly, the highest level of damage from neutrons is neither at the highest or lowest energy level, but in what might be called the middle energy level (100 keV to 2 MeV).

Additional classifications of radiation damage depends on what, if anything, the radioactive isotope "targets" (bone, thyroid, etc.). All such classifications are generally based on damage to an adult healthy (white) male.

Most biological damage from radiation is probably due to the creation of "free radicals" in the body: Free radicals are molecules which become electrically unbalanced ("charged"). A radioactive emission can knock an electron out of its orbit around a nucleus. The unbalanced atom will then grab an electron from something else, which may then do the same thing to something else, and so on through lower and lower electron bonding energy levels. If a DNA strand is involved, such events can permanently mutate that DNA strand. RNA can also be damaged, which might cause a cell to start producing a poison instead of a useful protein. If the damage simply causes cell death that's usually not so bad unless it's a heart or brain cell, which are not replaced during a lifetime. Most other cells in the body have limited lifespans anyway and die (self-destruct might be a better word) with various average life spans. Intestinal lining cells, for example, only live a few days, taste bud cells live about two weeks. However, if the damage causes either rapid (or slowed) cell division it can be much more dangerous.

A radioactive isotope is not the same thing as a radioactive emission. A radioactive isotope has a "half-life." A half-life is the amount of time it takes for half of a given quantity of a given type of isotope to decay. A radioactive emission is ejected from a radioactive isotope at the moment of decay. Different radioactive isotopes decay with different radioactive emissions, and those emissions have different energy levels. There is no way to predict what the precise energy level will be, nor when the emission will occur, or what direction it will take as it leaves the radioactive isotope. Many types of radioactive decays result in another radioactive isotope being created from the original isotope. Sometimes as many as 20 different elements are created and then altered again, before a stable isotope (such as lead) is reached.

For alpha and beta particles, the emission lasts only until the particle (alpha or beta) slows down from about 98% of the speed of light for alpha particles, and 99.7% for beta particles at the moment of emission, to "terrestrial" speeds. This takes very little time: on the order of a billionth of a second (give or take a few orders of magnitude).

After they slow down, alpha particles become helium atoms, but initially without their electron shells. They will grab other atom's electrons very quickly, though, since most atoms hold their outermost electrons much less tightly than helium atoms hold theirs.

Beta particles become electrons when they slow down.

What slows alpha and beta particles down (and does the damage to biological systems) is their interactions with electrons, atomic nuclei, and/or molecules. Alpha and beta particles are "charged" particles and only have to be near another charged particle to have an effect, and to be effected by other charged sub-atomic particles. Alpha particles are thousands of times larger than beta particles, and twice as strongly charged (in the opposite direction: Positive instead of negative).

Whereas alpha particles "blunderbuss" into electrons, atoms and molecules, beta particles are so small and travel so fast that when they are initially ejected that they pass by other electrons, atoms and molecules so fast that they don't have time to do much damage. It's when they slow down a bit, having passed thousands of charged particles at nearly the speed of light (each charged particle they pass acts as a little brake) that beta particles can do the most damage. For this reason, the nuclear industry's oft-repeated claim that "low energy beta particles" such as from tritium aren't very damaging is utterly false!

Gamma and x-ray emissions are neutrally charged and don't slow down; instead their energy is dissipated by one of three methods: 1) Crashing into an electron and knocking it out of its orbit (this can make the electron a beta particle). The gamma ray disappears. This is known as the photoelectric effect. 2) At higher energy levels, a lower-energy gamma ray or x-ray might also be produced. This is known as the Compton effect. 3) At very high energy levels, gamma rays can also produce a positron when it collides with an electron. This is known as electron-positron pair production.

Neutrons are electrically neutral (hence the name). This neutral charge allows them to interact more directly with the nucleus of an atom and/or with electrons, since they are neither repelled nor attracted to other (charged) sub-atomic particles. Neutrons usually decay into a proton, an electron and an "electron anti-neutrino." The half-life of a free neutron is about 10 minutes.

Nuclear reactors depend on neutron emissions to operate: The neutrons split other atoms, giving off more neutrons in a "chain reaction." In a light water reactor such as all American reactors (both Pressurized Water Reactors and Boiling Water Reactors) the neutrons are slowed with normal ("light") water which acts as a moderator. The reason reactors use a moderator is because at higher speeds the neutrons won't split ("fission") other atoms.

Only a few isotopes of a few types of atoms can be fissioned, including several isotopes of Uranium and Plutonium. Although Thorium cannot be split, Th-232 can absorb a neutron, then the Th-232 transmutes, first becoming Protactinium-233 by beta emission, then the Pa--233 transmutes (also by beta decay) into a fissile isotope of Uranium, U-233.

Spent fuel also emits neutrons, and special "neutron absorbers" are placed around the spent fuel to prevent the neutrons from getting out. If the spent fuel assemblies are crushed together (for example, by an earthquake, terrorist bomb or airplane strike) and water or some other moderator is present to slow the neutrons down, a "criticality event" becomes possible -- an uncontrolled chain reaction, producing enormous amounts of heat and fission products in a few thousands or even millionths of a second.

Neutrons are very damaging to biological systems but fortunately, isolated radioactive particles in the environment do not emit neutrons.

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Setting permissible levels of radiation:
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The EPA's proposed changes are specifically for accidental releases, so that at worst (so to speak) only the immediate area needs to be evacuated. This is to aid the nuclear industry so that it can keep operating with barely a blip. Any reasonable person looking at the future of nuclear power can see that A) A meltdown somewhere in America is practically inevitable sooner or later, and B) A major accidental released at, say, Indian Point would require long-term evacuation of New York City, whereas with the new limits, they probably would not evacuate NYC at all, even after a full-blown meltdown (or two) at Indian Point.

There are worse accidents possible than even a meltdown, however: A fire hot enough to burn the uranium dioxide fuel pellets, for example. Such an event at Indian Point would almost surely require the permanent evacuation of New York City and the surrounding area of lower New York state, as well as all of Connecticut and New Jersey, perhaps an even larger area.

These proposed new EPA guidelines do nothing to protect the citizens of NYC, and will be responsible for a plague of cancers in the decades after an accident. Radiation levels equivalent to 250 chest x-rays per year will be permissible during the period after an accident. Granted, moving all those millions of people to "temporary" shelters would also be hazardous to their health, especially their mental well-being, which is probably the underlying justification for the EPA's new rulings.

Of course, no careful studies of "hot spots" after an accident will be done -- they never are done after a radioactive release -- so individual dose assays will be impossible, and there will be no follow-up of individuals as they move around the country to get away from the depressed local area -- again, there never are such studies. If ANY government research is done later, it will be of the "healthy survivors," not the miscarriages, stillbirths, and non-fatal ailments such as inflammation, lowered IQs, deformities, etc.. They might study lung cancer deaths, but that would be about it, and those studies would probably be done in the first couple of years, long before most lung cancer deaths would even appear.

Ace Hoffman
Carlsbad, CA

-----------------------------------------
Ace Hoffman, computer programmer,
author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Subscribe to my free newsletter today!
Email: ace [at] acehoffman.org

Please conserve resources: Do not print this email unless absolutely necessary.

Note: This communication may have been intercepted in secret, without permission, and in violation of our right to privacy by the National Security Agency or some other agency or private contractor.
-----------------------------------------

Sunday, July 31, 2016

Before moving the waste to an "interim" storage site, neutralize it (as much as possible)

To: consentbasedsiting@hq.doe.gov

July 29th, 2016

To Whom It May Concern, Department of Energy

The idea that future generations, 500,000 years or more from now, can "consent" to having nuclear waste placed in their midst is ludicrous. And at the rate we are generating nuclear waste (about 10 tons per day in the U.S.A.; 50 tons per day globally) there isn't enough space on this planet to store all the waste that already exists, let alone what will be produced over the next few decades, centuries, and millennia.

Transporting all that waste represents yet another hazard that the public should have a right to consent -- or not -- to, but who in their right mind will want hundreds or even thousands of shipments of nuclear waste going through their community -- especially since there is zero likelihood that those communities will be reimbursed for the risk they take of having their neighborhoods permanently contaminated if there is an accident along the way?

And speaking of reimbursement, how far into the future does the DOE expect to compensate a community for taking the waste for "interim" storage? America has tried for more than 50 years to find a permanent repository, and Yucca Mountain was a scientific failure, not just a political one. There were groundwater seepage issues, rainwater leakage issues, volcanic activity nearby, earthquakes, and metallurgical issues that could not be dealt with for the time frames necessary to store the waste.

The Yucca Mountain project was strongly opposed in Nevada, and no other community in the country has ever stepped up to willingly become a permanent nuclear waste repository -- and only a few locations could even be considered because of the incredible difficulty -- no, impossibility -- in predicting how the earth will behave for the many millennia the waste will remain toxic. And all locations are susceptible to asteroid impacts and earthquakes, so really there is no safe place for nuclear waste.

And everybody knows it.

There are two broad categories of radioactive hazards in spent nuclear fuel. One is the fissionable isotopes, and the other is the fission products themselves.

Regarding the fissionable isotopes, there are two main concerns. One is the proliferation risk that the waste will be stolen, the fissionable isotopes isolated (possibly by a newly-developed laser separation process, which does not require hundreds of centrifuges and massive industrial installations to accomplish). A nuclear bomb can then be made from the enriched product of the separation process.

The other problem with the fissionable isotopes is that if nothing is done about the Uranium-235 and Plutonium-239 in the spent fuel, the proliferation risk will continue for thousands of years, since the half-life of U-235 is about 700 million years, and the half life of Pu-239 is about 24,100 years. But something CAN be done: Using a laser which is emitting photons in the 10 to 15 MeV range, these two isotopes can be safely fissioned in a controlled manner, while the spent fuel is still in the fuel rods.

Although such lasers do not currently exist, there is little doubt they could be developed, and there is no doubt the process would work because the breakdown of these isotopes has been proven with other methods such as with a linear accelerator. The process does not even take very long and can produce waste energy which can be harnessed to mitigate some or all of the cost.

By eliminating these two isotopes using the method described above, which has a patent pending filed by Peter M. Livingston, a scientist who witnessed a number of bomb tests at the Nevada Test Site and has studied the problem for many years, the two greatest difficulties with spent fuel are almost completely eliminated: The long term storage problem, and the proliferation risk.

What is left are the fission products. Most of these have half-lives of three decades or less (there are a few, which I call the ignoble seven, with half-lives of many millennia or even a million years or more, but these are present in only trace amounts).

Within about six centuries, almost all of the fission products will have decayed to stable elements. Thus, the longest that an interim OR permanent waste repository would need to be carefully monitored would be about 600 years. Granted, that's no piece of cake, considering our nation is only about 240 years old and most of our buildings, roads, dams, bridges and other infrastructure, much of which is well under 50 years old, is already crumbling -- but it's much more manageable than 500,000 years, a length of time so enormous that nobody can predict the consequences of trying to store hazardous waste that long.

Below is a link to Peter Livingston's patent for a process to neutralize the fissionable isotopes in spent fuel.

Under no circumstances should this suggestion encourage the production of more nuclear waste. During reactor operation, nothing is more dangerous than a superheated 150-ton pile of super-critical nuclear fuel, and when the fuel is first removed from the reactor, the remaining short-lived fission products keep the fuel assemblies so thermally hot that a spent fuel fire could occur at any time unless the fuel is safely stored deep under water. Such an event would be catastrophic, as we have seen in Chernobyl, Fukushima, Three Mile Island and elsewhere. A spent fuel pool or dry cask storage facility fire could be worse than all of those events combined. Dry casks and spent fuel pools are subject to risks from airplane strikes, earthquakes, tsunamis, terrorism, and even just manufacturing errors.

There are numerous cleaner, cheaper, more manageable methods for generating electricity -- even for propulsion on aircraft carriers and submarines. With some 600 military bases around the globe, our aircraft can already quickly reach any point on the planet without the need of aircraft carriers at all, and for stealth operation, a nuclear submarine has to shut off its nuclear reactor anyway, and operate on batteries. Both ships and subs normally have to stay with a large fleet of non-nuclear ships such as landing craft transporters, oilers, mine sweepers, frigates, destroyers, etc.. And even though they are considered "robust," a nuclear reactor on board a ship or sub can melt down, causing a catastrophic release of radiation which will spread throughout the oceans. This has probably already happened, although the evidence is impossible to accurately obtain, but more than half a dozen nuclear subs have been lost at sea, including two U.S. submarines, and in all cases, the exact cause of the catastrophe has not been positively ascertained.

Iran doesn't need nuclear power, China doesn't need nuclear power, Russia doesn't need nuclear power. Most people in Japan probably wish they never had nuclear power. Nobody else needs it, and we certainly don't need it.

The Department of Energy has been unable to solve the problem of nuclear waste, despite more than half a century and tens of billions of dollars of prior effort. This is because nuclear radiation destroys any molecular or chemical bond in the universe. DoE made a hollow promise to take back the nuclear waste from commercial reactors, a promise they have never kept and are now paying hundreds of millions of dollars per reactor for. It is time to eliminate that promise because nuclear waste cannot be safely kept -- and eliminating that promise would IMMEDIATELY cause the shut down all remaining commercial reactors. That would be a good thing.

No community will ever want nuclear waste. No consent can ever be given by people as yet unborn. No one can predict the consequences of storing anything anywhere for 500,000 years.

Ace Hoffman
Carlsbad, CA

URL for Dr. Peter M. Livingston's patent application for reducing the storage time of spent nuclear fuel: http://goo.gl/7ro0tZ (goes to the USPTO).




-----------------------------------------
Ace Hoffman, computer programmer,
author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman

Please conserve resources: Do not print this email unless absolutely necessary.

Note: This communication may have been intercepted in secret, without permission, and in violation of our right to privacy by the National Security Agency or some other agency or private contractor.
-----------------------------------------

Saturday, July 9, 2016

Nuclear security, neutralizing nuclear waste, storing SanO's waste at Palo Verde NPP

Last week (June 30th, 2016) I gave a 75-minute presentation on "consent-based siting" of nuclear waste, covering the basics of nuclear reactors and the various problems of used reactor core assemblies. I've posted that presentation online here:

https://youtu.be/i1k2G9sdDnk

(Note one correction: The half-life of Uranium-235 is about 700,000,000 years.)

Below is a discussion of security at nuclear power plants, a plan for neutralizing the waste (also discussed in the presentation), and a look at the possibility of moving the spent fuel at San Onofre, a closed nuclear power plant, to Palo Verde Nuclear Power Plant, which is scheduled to remain open for another 20 years. Also included are comments on moving the waste to PVNPP from Tom Palmisano, Vice President of Decommissioning and Chief Nuclear Officer San Onofre Nuclear Generating Station.

Ace Hoffman
Carlsbad, CA

Items shown below:
(1) Security at nuclear facilities
(2) A plan for neutralizing the U-235 and Pu-239 in nuclear waste
(3) Moving nuclear waste to an "interim" storage facility at Palo Verde
(4) Contact information for Ace Hoffman

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(1) Security at nuclear facilities:
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We talked briefly about security at nuclear facilities and you said you thought they were "very secure" locations.

I beg to differ:

The shooter at the Orlando nightclub was a security guard for the firm that "protects" 90% of America's nuclear power plants.

At a nuclear reactor in India, the head of security there turned on his fellow guards a few years ago, killing three. Fortunately he was acting alone and did not continue the attack to the facility itself.

This week in Dallas, Texas, a single shooter was able to kill five police officers and wound seven more before being subdued. The attacker claimed to have planted bombs throughout that city. And it comes as no surprise, considering the "skill" of the attacker, that he has been identified as a trained U.S. military veteran with experience in Afghanistan, and in the reserves.

If there is any better proof that security at our nuclear facilities is inadequate (the exact number is "classified" but is well known to be between three and five guards at any one time), one need only look at Baghdad, where one car bomb killed over 200 people in an instant. Or Beirut in 1983, when one truck bomb killed 241 American servicemen and women, along with over 60 others (mostly French troops).

More than 20 suicidal terrorists were involved in the 9-11 tragedy.

Most of the "iron coffins" (lookout posts) at San Onofre are unmanned at any one time. Security guards patrolling the spent fuel carry only sidearms and generally walk alone, and only periodically cover any one area.

The same technique used by the Dallas police this morning to kill the last suspect -- a remote controlled robot carrying a bomb -- can be used by terrorists next time. Not to mention flying drone bombs which can be controlled from more than a mile away with live video on board the drone.

After 9-11 there was a call for permanent anti-aircraft installations around each nuclear facility, which would have numerous problems and was never implemented. "No-fly zones" were also suggested and in some cases may have been implemented, but only for a few weeks and only below 5,000 feet. Problems with adding anti-aircraft installations would include the horrific possibility of shooting down the wrong planes, or of failing to shoot down the attacking plane(s) in the mere seconds it (they) would be in range, as well as either inadequate fields of fire or fields of fire that actually include the facility itself, along with extremely high costs for installation and maintenance of the facility, and continuous training and retraining of the personnel.

According to a National Academy of Sciences study, spent fuel dry cask storage containers cannot survive more than about 20 minutes in a jet fuel fire (the exact length of time and other details are "classified"). Yet the current plan for an "island" of sunken dry cask pods at San Onofre does NOT include a system to allow run-off of jet fuel, which the study suggested is imperative to prevent such a condition. Diablo Canyon's dry cask pad is also not designed for such a catastrophe. In fact, no dry cask facility in America seems to have taken into account the dangers revealed in the NAS study.

There should be no question that the security forces at any U.S. nuclear facility -- including San Onofre -- can be quickly overwhelmed. An estimate by the Blue Ribbon Commission (BRC) of $8 million per year spent per reactor for security is clearly a grossly inadequate amount. The current designs for spent fuel storage are grossly inadequate from a security standpoint, and are not "hardened" in any significant way.

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(2) A plan for neutralizing the U-235 and Pu-239 in nuclear waste:
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Dr. Peter M. Livingston, who has ample experience both in attending U.S. nuclear bomb tests in Nevada and working with radiochemistry issues, is not the first or only scientist to suggest that spent fuel nuclear waste should be neutralized to whatever extent is possible. However, as far as I know he is the only one with a patent (pending) on the subject.

It is well established, through experimentation with linear accelerators, that photons in the 10 to 15 million electron volt (MeV) range are capable of splitting fissile materials: Uranium-235 and Plutonium-239, the "active" ingredients in nuclear fuel. (U-235 is the main fissile isotope in "fresh" fuel (with a small quantity of U-234, which is also fissile), but Pu-239 is produced from U-238 during criticality).

When fuel is removed from the reactor, it is because too many "poisons" have built up in the spent fuel ("poisons" (an industry technical term) are isotopes which are not fissile but which can absorb neutrons and block the chain reaction).

After use in the reactor, there is still "plenty" of fissile material in spent fuel. (Some propose that the fuel can be reprocessed to extract the fissile material, but this is a very dirty and expensive process which yields low-quality fuel that can only be reused approximately twice.)

Fissile isotopes have half-lives of 700 million years (U-235) and 24,100 years (Pu-239). The half-life of Pu-239, as well as its chemical ("heavy-metal") properties, make it extremely hazardous: A few millionths of a gram is sufficient to cause lung cancer in humans.

Both of these isotopes, however, can be broken down by photons in the 10 to 15 MeV range. It is reasonably certain that "table-top" lasers can be manufactured which will output such high-powered photons, making reduction/neutralization of these isotopes highly feasible. This process is described in Dr. Livingston's patent application (URL below).

Designing any type of repository for spent fuel that will last as long as plutonium's half-life, let alone ten to twenty half-lives (the standard measurement for the existence of a radioisotope is 10 to 20 times its half-life) is virtually impossible. The pyramids, for example, are only about 5,000 years old, 1/5 of one half-life of plutonium.

When neutralized, U-235 and Pu-239 produce additional fission products, which are already in abundance in spent fuel (and virtually non-existent in "fresh" nuclear fuel).

Fission products generally have half-lives around 30 years or less (with seven long-lived exceptions which are present in "trace" quantities in spent fuel).

Thus, protecting society from fission products is a much shorter proposition: The United States is just over 240 years old. In that amount of time, most of the fission products would reduce by radioactive decay to less than 1% of their total. Six centuries is enough time for the fission products to reduce to approximately <0.01% of their original total. While six centuries is still far longer than our nation has existed, it is a much more calculable, and manageable, problem.

Perhaps most importantly, U-235 and Pu-239 are both "bomb-making material." Therefore, neutralizing them completely removes the proliferation risk from the spent fuel, as well as the possibility of a criticality event during transport or storage.

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Follow-up comment from Dr. Peter M. Livingston:
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Actually low emittance cathodes have been explored fairly extensively.
Their major utility is providing the electron source for various accelerators, including the CERN device.

Here is an example reference.

https://accelconf.web.cern.ch/accelconf/e08/papers/mozbm01.pdf

I don't think that the low emittance cathode advances have been incorporated into the desktop FEL's design. Stanford had a good design going, but I think the team fell apart when the lead physicist died. It is that design which I recall.

Now I think coupling the idea of this emitter with a device to photofission spent nuclear waste is a matter of publicity to get momentum back behind the FEL design and testing.

As you know, Yucca mountain or its equivalent is 500,000 years. The probability that a cask will fail far sooner seems to be unity.

So I think that arousing public interest in de-activating spent rods by photofission is the way to go now.

Peter

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(3) Moving nuclear waste to an "interim" storage facility at Palo Verde:
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Palo Verde is located in a far safer location than San Onofre. It is not in an earthquake zone, a tsunami zone, or near even 1/10th of the population that San Onofre is located in the midst of. The nearest major city to Palo Verde Nuclear Power Plant is Phoenix, approximately 60 miles away. Southern California Edison is a part-owner of Palo Verde and much of the profit that Arizona Public Service makes from that facility is due to selling power to California.

Transport of nuclear waste -- especially if it has been neutralized first by the Livingston process described above -- is far better than transporting the same waste to, for example Texas or even New Mexico, simply because the total distance is much less -- tens of thousands of miles less, when accounting for the ~150 trips that will have to be made. (Overall risk is a function of the number of trips times distance traveled times quantity (radioactivity) of each load times strength of each container times travel time per trip.)

Below is Tom Palmisano's letter from approximately one year ago to Marni Magda regarding moving the waste to Palo Verde, which was sent to me by Donna Gilmore. Here are my responses to each of his points:

1) ANY solution involving moving the waste will require a new license from the NRC so this point is not significant.

2) ANY solution, according to the Department of Energy (DOE) and before that the Blue Ribbon Commission, will require "incentives." Undoubtedly a for-profit nuclear facility and a community which already has a nuclear waste dump in its midst would be much more willing to accept "incentives" than a community which does not already have nuclear waste and an operating nuclear power plant. It might make the difference between a "profitable" nuclear power facility and one like the dozen or so that have announced closure dates due to unprofitable conditions, or have already closed.

As for the waste being a "significant liability" (Tom Palmisano's words) that is true here too -- but much more so because of the added threats of earthquakes, tsunamis, and the larger population surrounding the waste. Therefore SCE would be significantly reducing its own liability by moving the waste and should be willing to pay handsomely to reduce that liability.

3) The problem of license transfer is no different than it would be for an interim or consolidated storage facility, so this is a straw-man argument when it comes from someone who endorses either of those solutions.

4) Transport issues can be significantly reduced by the Livingston method described above, as well as by building up the rail and/or road infrastructure between San Onofre and Palo Verde. The distance needing structural improvement is far less than for the proposed sites in Texas and New Mexico (neither of which are likely to come to fruition anyway).

5) Who will hold "title" of the fuel is obviously SCE's main concern: They will oppose ANY plan which does not include transfer of title. But to claim that they are more capable than APS in protecting the fuel is another straw-man argument, considering that SCE sub-contracts security, as well as subcontracting the manufacture of the dry storage casks and the spent fuel island itself.

Tom's summary) Tom Palmisano's belief that there is widespread support for an interim or consolidated nuclear waste storage facility anywhere is not supported by facts. If it were, then surely the DOE would have scheduled one of their meetings on the subject in those communities. They did not do so. It must be noted that none of Tom's arguments against storing the waste are based on increased safety of the large population that surrounds San Onofre. Rather, he describes the risk as a "significant liability" to Palo Verde, essentially ignoring the fact that it is an even greater risk where it is.

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Conclusion:
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The main disadvantage to moving the waste to Palo Verde, or to any interim or consolidated storage facility, is that such an action is an "enabler" for other reactors to stay open, since they can then assume that the waste they generate can be moved somewhere eventually. This is a foolhardy, serious and significant problem since each reactor produces approximately 250 pounds of waste per day (according to the nuclear industry's own estimates).

There are currently approximately 2,500 dry cask storage containers around the country, at approximately 70 sites, with more than 11,000 containers worth of spent fuel in total in existence today, mostly still in spent fuel pools and in the reactors themselves. A new dry cask is needed somewhere in the USA approximately every one to three days.

Pretending that ANY solution other than "stop making more waste" will save America from a catastrophic spent fuel accident or terrorist attack is simply irrational -- even with Dr. Livingston's proposal, and even with interim, consolidated, or permanent storage solutions. This fact should be recognized and verbalized by the Citizen's Engagement Panel of San Onofre.

Yucca Mountain was not just a political boondoggle, it had serious and unresolved technical issues. The Yucca Mountain team of thousands of scientists was free to propose an alternative type of solution but could not find one. (They were not permitted to propose a geologic repository in another location, because all such locations had already been rejected.)

Lastly, it should be noted that, prior to the permanent shut-down of San Onofre, virtually no one here was paying attention to the problem of spent fuel. Now, although that situation has changed significantly, simply moving the waste to make it anyone else's problem, and attempting to transfer "ownership" of the waste to anyone else, including the Federal government, is NOT actually solving the problem. It's just passing the buck. We as a "united nation" MUST do better than that and as de facto owners of one of the largest piles of nuclear waste in the country, it is soCal's duty to attempt to truly solve the problem, not just pass it on to someone else. Anything less does a grave disservice to our children, their children, their children's children, etc. for the foreseeable future.

Ace Hoffman
Carlsbad, CA

URL for Dr. Peter M. Livingston's patent application for reducing the storage time of spent nuclear fuel: http://goo.gl/7ro0tZ (goes to the USPTO).

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Tom Palmisano's letter to Marni Magda:
==============================================

Dear Marni,

Thanks for your email. This is a good question and I appreciate your raising it to me. Let me give you some initial thoughts.


1. SCE is a 15.8% owner of Palo Verde. There are six other owners with varying percentages. Arizona Public Service is the majority owner and operator. They hold the NRC operating license, not SCE.


2. I don't know if the other six owners would be agreeable to storing San Onofre used fuel at the Palo Verde site. Since we are not the sole owner, it would need to be a decision all the owners agreed with. This would represent a significant liability for these other six owners and I doubt that they would be in favor of that.


3. Even if the other owners agreed, we would have to explore who would own and be responsible for the fuel, and who's NRC part 50 license the fuel would be stored under. Palo Verde is licensed to possess and store their nuclear fuel. They are not licensed to possess and store San Onofre's used fuel. Assuming we could transport and store fuel there, we might have to license and build a 50.72 ISFSI to store San Onofre's used fuel.

4. As you are aware, there are a number of transportation issues that need to be resolved no matter where we ship fuel to.

5. From an SCE perspective, our thought with offsite Consolidated Interim Storage is we would want the private party or DOE to take title to the fuel when it leaves SONGS. We would be concerned about maintaining title to the fuel and liability for an offsite location not under our direct control. With the proposed commercial facilities in West Texas and New Mexico, there initial thoughts are they or DOE would take title to the fuel.

My bottom line is I think it is very unlikely we could ever reach an agreement to store used fuel at Palo Verde. I think are best chance of success in the relatively short term is to advocate strongly for the private Consolidated Interim Storage Facilities in West Texas or New Mexico. The respective companies are interested, the local communities are supportive and there appears to be some reasonable level of state and federal support.

I'd be happy to talk to you further about this. Let me know if you'd like to set up a phone call or meeting.

Best Regards,

Tom [Palmisano, VP of Decommissioning and CNO at SCE]

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(4) Contact information for Ace Hoffman:
===========================================


-----------------------------------------
Ace Hoffman, computer programmer,
author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
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Addendum (added 7/9/2016:16:53):

Comment on liability from Donna Gilmore:

"[R]egarding liability.  Edison already has a certain percent of liability at Palo Verde and they are trusting APS to manage that facility, so that should be considered an endorsement or trust in APS.
 
"The way the liability would work is the percent of ownership and liability would go up for Edison, SDG&E and the other owners of San Onofre waste. Anaheim is one of those cities.  They may probably trust APS more than Edison to manage the waste, as may other California cities.

"If we could store the waste in safer containers first, they may be more inclined to take it.  The cost savings would be significant. The transport is the scariest part."

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