Docket ID: NRC-2013-0271 As fires burn near San Onofre, I'm so glad it's closed permanently!

Dear Readers,

Five or six miles to the south of me, and two or three miles to the north of me, and 15 miles inland (east) of me, brush/forest/house fires are burning. Another fire has been burning very near the permanently-closed San Onofre Nuclear (Waste) Generating Station, about 20 miles north of where I live. And it's only May 15th! At this rate, what will be left to burn by the fall, the peak of southern California's fire season?

So I think this is an excellent moment to THANK EVERYONE once again -- including Southern California Edison's employees who, after all, actually made the decision -- for shutting that awful plant down!

Now that the reactors are NOT OPERATING, we can all breath a sigh of smoke-filled relief that there wasn't a complete "Station Black-Out" (SBO, a loss of offsite power and backup generation capability) at San Onofre during its 45 years of operation. We know how SBOs worked out for TEPCO at Fukushima: Three ongoing meltdowns. It wouldn't have been any better here (and it might have been worse -- much worse).

This is also a good time to point out that if the spent fuel dry casks are in a fire for too long, it could result in a breach of containment, a serious accident the Nuclear Regulatory Commission has no plans for (because they claim it is too unlikely to have to protect against).

The concrete pad, parking lot, etc.. presumably protect the dry casks from anything that could get close... presumably being the keyword there. One unlikely -- but not impossible -- scenario being, for example, a tornado dropping a gasoline truck from the highway onto the dry cask farm. That might not go so well for San Onofre, and I'll bet hundreds of fuel trucks -- and rail cars loaded with all sorts of combustibles -- and chemicals -- go by every day. Tornados aren't too likely here, but not impossible.

There are now approximately 2,000 dry casks in America (about 50 at San Onofre, with more than 100 to come), and there will be about 10,000 dry casks around the country within a few years, just from what is currently in spent fuel pools. On average, about 10 tons more spent fuel nuclear waste is being made every day. The NRC has decided that there is no significant safety difference between fuel in spent fuel pools and fuel in dry casks -- even an overcrowded spent fuel pool or a decades-old dry cask. According to the NRC, all spent fuel pools are equally safe regardless of spent fuel assembly packing density, because additional neutron shields and chemicals in the pool water are used to balance the safety element.

For dry casks, safety factors can be improved several ways, such as by using "cans" to isolate those spent fuel assemblies which have damaged fuel rods. Also by packing old fuel with new fuel, and "high burn-up" fuel with low burn-up fuel, so that the total heat load is within specified parameters. There are regulations for the minimum thicknesses of stainless steel canisters, cement outer packs and so on. These regulations are set to protect the fuel against "reasonably foreseeable" accident scenarios -- but not against ALL accident scenarios. That would be impossible. For that, mitigation comes in the form of odds -- those accidents are deemed to be very unlikely. An asteroid. A large nearby earthquake. A large tsunami. A terrorist attack.

It takes a lot of guesswork to set those standards, especially when many of them are "generic" and assumed to be as accurate for a nuclear power plant in New York as for California, or anywhere else in America.

In any case, the NRC does not consider ANY accident that will result in a large release (greater than, say, 0.01% or less of the total fuel load (or even only a millionth of the total fuel load)) to be a "credible" or "design basis" accident.

Emptying the spent fuel pools into "temporary" (for who-knows-how-many decades) dry casks is risky. When finally transporting them (somewhere), the longer we wait, the more of a nightmare moving them will be, due to the ever-present embrittlement issues. All parts of the casks are going to crumble as time goes by: The cement, the "stainless" steel, the fuel assemblies, the Zirconium alloy cladding, and the hot, radioactive, still-fracturing, still-decaying fuel elements themselves. Spent fuel is stored at about 75 locations around the country. About 15 of them do not have operating reactors.

The "obvious" solution is to consolidate the waste somewhere desolate and safe (no earthquakes, no volcanoes, no tornadoes, no tsunamis, no floods or water seepage, no rodents, no terrorists, no commercial airliners overflying them... go ahead: name that place. Dry cask storage is an abomination of the promise to remove the waste, a promise made by every pro-nuker ever. There is no such place and never will be -- so of course it's time to shut down ALL the reactors permanently.

But instead, even California could actually allow new reactors if a "permanent" national repository is opened somewhere. Even if that repository won't be taking all our current waste for several decades after opening (which, itself, will probably take decades).

The fight to stop nuclear power isn't won, but San Onofre is permanently closed, and that's a big step in the right direction for southern California.

Today, as our cities are ablaze again, the power is staying on (at least so far...). If San Onofre were still operating, the fire burning near SanO could have caused them to SCRAM the reactors (drop the control rods) when offsite power was lost or even if the power lines were merely threatened.  No matter how often the NRC repeats the line that a SCRAM is a routine operation -- it is anything but routine. It's more like landing a jumbo jet on an aircraft carrier.

Pilots have a saying: There are no bad flights, only bad landings -- unless the plane goes up to 41,000 feet and the pilot (or somebody) cuts off the forced air so the oxygen masks drop, then 15 or 20 minutes later the oxygen is used up, and some time thereafter, the lifeless, empty-fueled jet gently touches down gear up into the ocean, fills with water, disappears under the waves, and leaves no trace.

Alternatively it could crash into San Onofre's dry casks while the plane is still loaded with fuel. Even with the plant closed, this is a very real threat. Brush fires even a few miles away could also drop hot embers all over the power plant. Removing the waste is the only thing that will free southern California from the yoke of nuclear nightmares.

But removing the waste isn't going to happen for a very long time, so we need to do everything we can to make sure it is stored as safely as possible and in such a way that it CAN be removed -- if there ever is a better place to put it (someone mentioned the Aleutian Islands recently. Obviously, someone who doesn't live in Alaska!).

Instead, the current plan is to pack the fuel into dry fuel canisters which hold a whopping 32 fuel assemblies each. Half of those assemblies can be already damaged when they are loaded into the dry cask canister. All spent fuel should be treated as potentially damaged, requiring storing each fuel assembly in "fuel cans" to reduce the possibility of a criticality event.

The NRC and the nuclear industry -- and many anti-nuclear activists -- are in a rush to put nuclear waste into dry casks. But a lot of safety factors had to be compromised to allow long term storage of spent nuclear fuel on site in the first place. Let's think this through. There are undoubtedly better materials that the dry cask canisters could be made with -- but they are much more expensive.  Perhaps it is better to leave the waste in the pools while waiting for a national consolidation of our nuclear waste sites (consolidation is only reasonable after CLOSING a reactor site).

Ace Hoffman
Carlsbad, CA

-------------------------------------------------------------
From: "Gene Stone" <genston@sbcglobal.net>
Subject: Comments needed by May 15, act now
To: "ROSE" <rosenewsandactionalerts ...snip... decommission@sanonofre.com>
Cc: "C.A.N." <coalitionagainstnukes-list@lists.riseup.net>

Southern California Edison plans to upgrade to NUHOMS® 32PTH2 dry cask system to store their highly radioactive nuclear waste. This means storing 32 nuclear fuel assemblies in a space original designed for 24 fuel assemblies.. The higher number of fuel assemblies brings higher risk of radiation releases, especially for the hotter and more radioactive high burnup fuel. This is a brand new design that the NRC approved. However, the NRC is accepting public comments until May 15, 2014. If they get enough significant comments they said it may delay approval.

Submit comments at this Federal Register link. Refer to Docket ID NRC-2013-0271 in any correspondence to the NRC about this.

http://www.regulations.gov/#!documentDetail;D=NRC-2013-0271-0001

The NRC should not lower safety standards by approving this new canister.

From Donna Gilmore and Gene Stone. We know it is late so please act now.

Gene Stone
Residents Organized For a Safe Environment (ROSE)
949-233-7724, On twitter @gene_stone
http://residentsorganizedforasafeenvironment.wordpress.com/
http://partofthearth.blogspot.com/


-----------------------------------------
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

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.
-----------------------------------------

From: "Joe Holtzman"
To: "Ace Hoffman"

Ace

Is there room in the containment dome to store any of this garbage ?

Joe

In matters of style, swim with the current;
In matters of principle, stand like a rock.

Thomas Jefferson

Comment added 8:45 pm PST:

Hi Joe,

I've thought about it [before] and realized that there's probably room for only a small portion of it.  The casks are pretty big.

And I don't think the floor is very even, and probably not all of it could take the weight, though probably some could.

They could probably put a new pool there, but I doubt even two of those could hold all the waste, and many people object to spent fuel pool storage anyway of course -- but it might be the right idea anyway.  However, I don't think there's room for more than single-digits of casks inside the domes, and they'll have about 150 casks to worry about when they're done.  Or rather, we'll have them to worry about, and our children will, and their children.  Thank goodness there is only a limited supply.  Other communities will have an endless quantity of these dastardly things!

One problem I've thought about with putting them in the domes is that the casks aren't really as strong as they look from the outside.  Another problem is they might crumble from old age sooner than expected, and we wouldn't want pieces of them falling on the dry casks (or on a new spent fuel pool, for that matter).

I do actually believe that with enough money to buy things like "nickel-based alloys" or something else no one wants to "splurge" for, there's a possibility the spent fuel can be far more safely contained -- but still by no means "good enough" by any standard, just several orders of magnitude better.  Something that is akin to the pyramids, but high-tech.  And no-fly rules, and anti-aircraft installations, and anti-ballistic nuclear missile -- hardened... okay, of course that can't be done.  But even using better alloys would probably bankrupt every nuke operator if they had to allow for that sort of cost (didn't one go bankrupt in Texas this week?).  I'm not advocating it because I want to see them go bankrupt, of course -- I'm advocating it simply to save my planet!  The nuclear industry's coming bankruptcy is an inevitable consequence of being in the wrong business, one that is not sustainable.

Hydride formation never sleeps; What do they have to do to make the dry casks safer?

5/6/2014

Dear Readers,

The zirconium cladding which encloses the fuel pellets that were used at San Onofre (and every other light water nuclear reactor in America) will continue to degrade even after the fuel rods are crammed into their "dry casks", which are then welded and/or bolted shut and -- if the nuclear industry has its way -- forgotten about (until something goes wrong).

The loss of cladding integrity is a serious failure the nuclear industry needs to face, because a permanent solution to the waste problem is NOT on the horizon, but the fuel cladding degradation is very much on the horizon, and the horizon is getting closer every day.

The cladding may NOT degrade "gracefully," meaning, we may not see the failure coming, and won't be able to do anything about it until it happens. The nature of brittle-failure is that once a crack grows past a certain size it becomes dangerous. That size is unknown without lots and lots of testing, and each rod will behave differently. As the cracks form, stresses change throughout the rods.

Failure of even ONE rod among the hundreds of thousands of fuel rods can lead to a cascade effect and would be a significant environmental problem on its own. That cask would have to be resubmerged, opened, and the damaged fuel rod(s) "canned." "Canning is a process which isolates each fuel assembly (of approximately 150 fuel rods). But "canning" requires taking up additional space inside the dry cask. It also changes the thermal properties, and costs additional money to implement. Normally only fuel that is already obviously damaged in some way gets "canned." Without canning, fuel accumulations due to failed fuel rods have a greater potential to form a critical quantity. Also, any radioactive releases that would have been kept in the can will escape into the rest of the dry cask and possibly out the cask's vents (yes, these casks have vents). A radioactive release inside the dry cask will also make handling that fuel in the future more difficult.

We could see, several decades down the road or maybe tomorrow, that all the fuel that seemed fine is now starting to crack. Failure rates can increase exponentially because small cracks are both harmless and invisible to the naked eye (not that you could get a naked eye close to a spent fuel rod without dying long before you got close). Over long periods of time, temperature has an enormous effect on fuel cladding integrity. With dense packing and mixing high burnup fuel with low burnup fuel, the average temperature of the oldest fuel will be significantly higher than it otherwise could be if the high burnup fuel were kept in the spent fuel pools longer and/or packed less densely.

Cracks tend to grow at roughly the same rate under the same conditions, so the fuel that is in the dry casks the longest is normally the fuel that is the most worrisome. However, some damage also is done in the pools and some occurs in the reactor during operation so the exact state of each fuel rod cannot be decided without very careful non-destructive testing and accurate estimating of the heat loads during operation and while inside the pools and the dry casks. Southern California Edison does not want to do ANY of this sort of testing. They just want to accept dry cask industry estimates as fact.

It appears that the reason Edison set up the Citizens advisory committee (known as the C.E.P.) is so that a few hand-picked elected officials and others, including one activist (Gene Stone of R.O.S.E.) among 18 members, will have a hand in rejecting expensive solutions to the problem, and will keep demanding someone, somehow, move the waste away from SoCal "as soon as possible." It is a hollow demand. There will never be, on this earth, a safe place to store nuclear waste (nor is there a safe or cost-effective way to get it into outer space, beyond earth's debris field). There will never be an energy efficient (and safe) way to neutralize all of the nuclear waste, even if some portion of it can be reused or reprocessed or fed into a breeder reactor or transmuted or anything. These problems are terminal and are not going away.

Stopping nuclear power is the #1 thing everyone should do.

Below is a transcript of a nuclear fuel suggestion by a friend of mine, a metallurgist who worked at the International Atomic Energy Agency, PSE&G, Westinghouse, etc.. for many years before a head injury put him on disability several decades ago.

Every suggestion I have heard for improving the storage of spent nuclear fuel costs enormous amounts of money. Earthen berms between each cask would enhance safety, as would thicker cement sarcophaguses, not to mention rebar. Less fuel in each cask enhances safety in some ways, but means there are many more dry casks. Not one of these questions is easy to answer, but the fact is: Southern California Edison's dry cask solutions are notorious. They will be the death of southern California if an airplane strikes them, or a terrorist.

During war, our pilots learn not to line up their airplanes in a row if the enemy is near, for example alongside the runway, because then one enemy fighter plane, in one strafing pass, can destroy an entire row of airplanes (this happened to our land-based bombers at Pearl Harbor). At San Onofre with our dry cask storage system, we have the same situation: Everything all lined up and packed in tight, UNDER MAJOR AIRLINE ROUTES, just a few miles from an open airstrip, and just a few hundred feet from rail, truck and passenger traffic to the tune of hundreds of thousands of trips per day.

To the best of my knowledge, San Onofre's dry cask storage system is the tightest-packed dry cask system anywhere in the country -- but all dry cask "farms" are as compact as possible. This decreases the "target size" for a terrorist but increases the damage if an airplane falls on it accidentally or on purpose. Nuclear waste needs to be stored either underground or under "no fly" zones. San Onofre's nuclear waste is neither.

This is an outrageous situation, but what can be done about it? Move the waste? To where? One activist, Roger Johnson, suggests the Chocolate Mountains military range as a temporary location, on the California border with Arizona. Personally, I do not believe a temporary solution is useful; it just enables the nuclear industry to claim that there is some solution at all! More useful is to point out to Diablo Canyon's local community (and Palo Verde's and others) that storing old nuclear waste isn't any fun, and the less of it, the better. Furthermore, we should make sure it's clear that storing it is going to be a lot more expensive than ANYONE had ever expected, and the cost will go up significantly with each new fuel rod accumulated at the site. Who's going to be paying for our waste to be stored when we are all dead and buried, and even our children, and our children's children, are all gone?

There is no solution but shutdown. Before anyone can properly even think about what to do with the waste, we need to shut down the operating reactors -- the waste production facilities. Prior to shutdown, the waste is a hidden part of the nuclear industry. Now, here in southern California, it's all we have, and we need to do SOMETHING with it.

Nuclear waste problems have been ignored for about 70 years, but now southern Californian residents are forced to grapple with the problem.

Wish us luck.

Ace Hoffman
Carlsbad, CA

=============================================================

What do they have to do to make the dry casks safer?

This is a transcript of metallurgist Ed Siegel's comments from May 4, 2014, with some speako corrections and a few other things (all in brackets) added to enhance the average person's understanding. Some non-relevant comments have not been transcribed.

Ed's solution is much, much more expensive than anything the nuclear industry is planning to do, but would presumably last a lot longer (depending on how many layers are involved) and will do a better job. In the long run, it would be far, far cheaper than to have to repackage early, let alone than having an accident, which could cost in the trillions of dollars and thousands of lives.

I would appreciate hearing from anyone who has any technical comments or suggestions, or inquiries about this transcript.

Ace

==================== Transcript: =====================

There's a phenomenon called DIFFUSIVE-MAGNETO RESISTANCE. I'm one of the developers of it. The discovers are Conyers Herring, died 20 years ago from Bell Labs, back in the '70s -- in the 40s -- back in World War II, when I was discovering who the girls and boys were -- and I'm still not sure.

If you have hydrogen diffusing in steel, ferritic, body-centered cubic steel, it diffuses at 60 meters per second [as fast as a rifle bullet], and it was found that you could contain the hydrogen by magnetizing the steel. Now, earlier someone named Youdelis (University of Windsor) had found that if you took an aluminum-copper junction, and just look at one diffusing into the other, if you put a magnetic field on, it retarded the mobility of the ions.

Plutonium is a lot larger than... what are the wastes, primarily?"

Well, there's plutonium, cesium, strontium...

"Okay, cesium's a heavy alkali metal, plutonium's a very heavy metal, the ionic radia are huge, the masses are huge, if hydrogen's retarded in ferritic steel, then certainly in a ferritic steel, plutonium would be retarded maybe (he pauses for second...) ten thousand times as much.

So what you want to do is you want to have alternate layers, a non-spinodally decomposing, no Wigner's disease, low carbon stainless -- nickle-based, too expensive -- followed by around that a ferritic steel -- I don't know which one -- carbon-manganese might work well like for pressure vessels -- and you want to magnetize that parallel to the axis. Then you want ANOTHER layer of the 304 L or whatever, then ANOTHER ferritic steel and at that one you want to magnetize circumferentially -- and I'm the only one and Tony Aaron that knows how to do that -- it's very clever. We're talking about magnetizing it in place. Now if you wound a coil around it you can magnetize it parallel to the axis. But were talking about getting RADIAL magnetic fields in addition to longitudinal magnetic fields.

Tony Aaron came up with a solution which is brilliant, something that goes back to high school science. Tony Aaron's a genius. [Note: Ed later told me what the "trick" is. I don't think it's that hard to figure out...]

So, how many layers do you want? As many as it takes. You've got to estimate the number of years you've got to contain it. If we're talking about 1,000 it might take 100 layers. If you don't like it, then have it for dinner!"

A low number with L -- NOT "360" and definitely L!

-------------------------------------

One last thing: That's also the way to retard things leaking at Hanford, I gave testimony on this at the uh, Washington State Department of Ecology hearing on the future of Hanford, August, 2012, and they redacted it for about a year and they finally put it online, my witness is Janis Udall, a biologist, she went with me [Ed then rattles off her phone number and email address]... And the guy you want to get it from ... is Deder Boohrmann who I believe is the public relations man for the Washington State Department of Ecology, Bellevue, Washington, and they kept it offline because they were playing "CYA"...

-------------------------------------

Lastly, the alternate layers are something like a hydrox cookie... um, if you don't understand the technology of that, the next girl scouts are selling their little mint cookies go buy some and pull them apart and you'll see alternate layers of different flavor[s]. This is what we want, some flavors are magnetized, the other[s] are not. They're not magnetized because they're stainless steel, because stainless steel is non-ferromagnetic it's paramagnetic and the magnetized layers are ferritic steel magnetized in different directions, and that's like the nice white cream between the dark chocolate wafer sides.

-------------------------------------

Clean room contamination.

Typically clean room benches and chairs and sputtering systems and CVD systems, the chassis, like, for example made by Applied Materials, is stainless steel. If it's not 304 L stainless it embrittles over time or when it was heat treated, they didn't, when they formed it, they didn't re-heat treat it. The typical particulates in the air, the most dominant mineral in the earth's atmosphere, on the surface of the earth is plagioclase feldspars, they have a Moh hardness of number 6 1/2, quartz has a Moh hardness of 7. The typical particulates in the air are small quartz particles and small plagioclase feldspar particles. When they hit a surface, if it's soft they just mush down in asperity. If the asperity's brittle they break it off and if you look at the contaminant measurements in semi-conductor and disk drive pad clean rooms, it's EXACTLY the composition of cheap stainless steels with quite a bit of carbon which means they didn't use an L type carbon steel...

That's what the paper's going to be about. The American Vacuum Society. I went to this thing at the Convention Center, at the Town and Country -- they made me the keynote speaker...

[He then comments on a few people, including Bill Gates who's Small Modular Reactors is a terrible idea. "They know nothing about metallurgy up there" and when one fails, they'll all fail because they're all alike. he then suggests I buy some of the spent fuel to get cheaper radiation treatments for my wife, who, as he knows, is undergoing radiation treatments at the current time (she has exactly ONE more treatment to go, tomorrow morning.]

Plutonium's going to diffuse -- a proton is 2000 times heavier than an electron. So hydrogen is 2000 times heavier roughly than an electron. Plutonium is [94], so it's [almost] 100 [times] heavier [than hydrogen] so if this retards hydrogen, certainly it would retard plutonium [which is] real slow [in comparison]. And now, what plutonium's radiation damage does in terms of enhancing it's diffusivity, that's another story. I'm just talking about plutonium diffusing through something, not counting the radiation damage. The radiation damage might enhance the diffusivity because you'll get what are called thermal spikes, radiation damage spikes, so it might scoot along those a little, but they might be sideways, not through. You need multiple layers. Remember: A box of hydrox cookies. In fact, you should say, if you're testifying, "A box of girl scout cookies would be an effective shield around it. But only Hydrox!"

================= Transcribed May 4th - 5th, 2014 ===================


-------------------------------------------------------------------
© Ace Hoffman
www.acehoffman.org
-------------------------------------------------------------------