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San Onofre Highway 5M 6.7 Quake San Onofre USGS prob.
From SanOnofreSafety:
Action Alert: Coastal Commission meeting Tuesday, October 6, 2015 12:00 p.m, Long Beach. Commission to vote on whether to approve installation of experimental unproven Holtec UMAX underground nuclear waste storage system at San Onofre. Please attend. This may be your only opportunity to speak against this.

Email your comments prior to meeting to Joseph.Street@coastal.ca.gov
Coastal Application 9-15-0228, Southern California Edison Company, Construct and operate an Independent Spent Fuel Storage Installation (ISFSI) to store spent nuclear fuel from SONGS Units 2 and 3.
” More info here: http://sanonofresafety.org
Dry Storage of Spent Nuclear Fuel Problems and Solutions", by Donna Gilmore SanOnofreSafety.org, May 17, 2015 , p. 6
One curie is 37 billion becquerels, i.e. 37 billion radioactive shots (disintegrations) per second.
San Onofre Cesium 137 vs. Chernobyl by Donna Gilmore SanOnofreSafety Images from “Dry Storage of Spent Nuclear Fuel Problems and Solutions by Donna Gilmore of SanOnofreSafety.org, May 17, 2015
See: https://miningawareness.wordpress.com/2015/05/20/spent-nuclear-fuel-dry-cask-storage-sos/

Holtec ABOVE ground nuclear reactor dry casks at Diablo Canyon. Proposed dry casks system is for underground.
Holtec casks Diablo Dec. 26 2005 or 2006
US NRC or DOE photo, ca 2005-06

From: Donna Gilmore Date: 10/2/2015 2:25 PM

To California Coastal Commissioners and staff.

An additional comment is regarding the very short warranty for the Holtec system. Even though Holtec and SCE claim the system will last 60 to 100 years, the Holtec warranty is for only 10 years for the underground structure and only 25 years for the thin 5/8″ thick steel welded canisters (MPC-37). Also, Edison is considering having Holtec load the existing Areva thin canisters into the Holtec system. The Holtec warranty is only two years for these canisters. The below linked Holtec warranty was provided to me by Edison as part of the CPUC Unit 2 and 3 Decommissioning proceedings. https://sanonofresafety.files.wordpress.com/2013/06/sce-dr-response-w-attachment-to-a-14-12-007-gilmore-sce-001-follow-up-2-q-09-q-12.pdf

On 10/1/2015 6:02 PM, Donna Gilmore wrote:

To the California Coastal Commissioners and staff:

I recommend the Coastal Commission deny the application for this experimental unproven Holtec spent fuel dry storage system (Application 9-15-0228). This is a very important issue to rush through the approval process with so little time for the public to review the staff’s recommendations and related material. However, even with the short review time, I have a number of reasons the proposed system by Southern California Edison (SCE) must be rejected.

The proposed Holtec UMAX underground dry storage system is an experimental unproven system. It cannot be inspected, repaired, maintained, or monitored and does not meet current Coastal Act requirements. The staff’s “Approval with conditions” contains conditions that are unlikely to be met. The serious staff concerns that required these conditions demonstrates the inadequacy of this SCE proposed system. It is likely this system will be at our coast for decades, if not longer, as staff has indicated. There is adequate evidence to show that this experimental Holtec system will likely not meet Coastal Commission short term or long term storage and transport requirements. To assume the system can or will be relocated, as the staff suggests, is not a reasonable assumption, based on known evidence. These high capacity (37 fuel assembly) canisters with high burnup fuel may need to cool in dry storage for over 45 years before they are cool enough to transport. (See slide 10 of this Department of Energy presentation. http://www.nwtrb.gov/meetings/2013/april/boyle.pdf). The NRC has not approved this system in the configuration proposed by SCE and Holtec.

Additional comments and references below.

The report states SCE expects the service life of the ISFSI and casks to be at least 100 years and no major repairs are anticipated within 60 or 100 years. This is an unsubstantiated claim. (Staff Report page 37). Please have SCE provide technical references for those statements. Are these Holtec technical documents submitted to the NRC? The NRC is only certifying the system for 20 years and is not considering degradation or other aging management issues that might occur after 20 years. The NRC doesn’t consider claims by Holtec about those 60 and 100 years as anything the NRC has validated or approved (according to their Sept 2015 UMAX amendment 1 certification approval document). The staff report references email document “SCE 2015b.” Please forward a copy of this document. http://www.gpo.gov/fdsys/pkg/FR-2015-09-08/pdf/2015-22053.pdf

The statement “NRC has estimated that at least 30 years would be required for the initiation of stress corrosion cracking in steel fuel storage casks” is no longer valid. (Staff Report Page 37). That statement is in the NRC 8/5/2015 meeting minutes on Stress Corrosion Cracking and Aging Management. The reason NRC said 30 years was because they assumed the canisters would not be cool enough for moisture to deliquesce (dissolve) salt on the canister for at least 30 years. However, at that time they were not aware of the two-year old Diablo Canyon canister that had temperatures low enough for salts to deliquesce. I participated in that and other NRC meetings on stress corrosion cracking in marine environments. http://pbadupws.nrc.gov/docs/ML1425/ML14258A081.pdf https://sanonofresafety.files.wordpress.com/2011/11/diablocanyonscc-2014-10-23.pdf

The Koeberg nuclear plant had a component that leaked from stress corrosion cracks in 17 years. It is located in a similar environment as San Onofre (on-shore winds, moist ocean air, frequent fog). The NRC considers the Koeberg component (a waste water tank) comparable to a stainless steel canister (304L or 316L stainless steel). The Koeberg through-wall crack was 0.61″ thick. About the same thickness as the proposed Holtec canisters (0.625″ thick). San Onofre has also had stress corrosion cracking in stainless steel pipes that the NRC considers comparable to the thin steel canisters, so it’s clear the environmental conditions are present at San Onofre. We do not need to wait 20 years to find this out, so the Coastal Commission should address this in the current application. References: http://pbadupws.nrc.gov/docs/ML1231/ML12319A440.pdf http://pbadupws.nrc.gov/docs/ML1425/ML14258A082.pdf

Existing Areva NUHOMS canisters have been loaded since 2003, so the idea that Edison needs to have an aging management plan in 20 years is not the case. They need an aging management plan for their existing NUHOMS canisters and system. Does the existing NUHOMS canister ISFSI require a separate Coastal Commission renewal permit? Both the existing NUHOMS and proposed Holtec thin canisters are of the same materials (welded 316L stainless steel). We have only 5 years before we meet the Koeberg timeline. This idea we can wait 20 years is not realistic on many levels. To buy products originally designed for 20 years that do not have aging management built into the design is unacceptable. Edison should be required to provide their aging management plan now, so it can be fully evaluated by the Coastal Commission. What we already know is not adequate. This is too important an issue to base approvals on Edison promises of future solutions.

The UMAX system is an experimental unproven system. Over 99 percent of dry storage system in the U.S. and the world are above ground systems. To claim this is typical or a proven U.S. systems is an inaccurate claim. On Staff Report page 11, the footnote states “A small HI-STORM UMAX system…is installed at Humboldt Bay Power Plant”. This is not a UMAX system and has a very different design. The Humboldt Holtec HI-STAR HB system uses 1/2″ thick canisters, but inserted them in thick steel bolted lid cask before placing them in the underground holes. Also, the fuel cooled for 35 years in the pools and was low burnup fuel, so no air vents were needed to cool the thin canister and fuel. In spite of this, water leaked into this system, which Holtec said would not happen. Their solution was to put caulking around the enclosure. https://sanonofresafety.files.wordpress.com/2011/11/ml13151a317.pdf http://pbadupws.nrc.gov/docs/ML0531/ML053140041.pdf

The Holtec UMAX system has not been approved by the NRC for the configuration planned for San Onofre and it has not been approved for the site. The NRC will need a license amendment for the changes in order to properly evaluate for seismic, thermal and other technical requirements. The system is approved for 1/2″ thick canisters, not 5/8″ as proposed. The system is approved for a totally underground system, not the half underground system proposed. The NRC comments in their September 2015 UMAX approval make this clear. I explained this and other items in the letter I sent to staff on September 17, 2015. It appears some of the public comments I have made have not been addressed. Or has Edison or Holtec or the NRC provided you different information ? https://sanonofresafety.files.wordpress.com/2013/06 /ltrtocoastalcommissiondgilmore2015-09-17umax-amend1.pdf http://www.gpo.gov/fdsys/pkg/FR-2015-09-08/pdf/2015-22053.pdf

Aging management of the Holtec system is inadequate. Even the Holtec President, Dr. Singh, says the canisters cannot be repaired. They cannot even find cracks, let alone repair them.

Relying on vendor promises of future solutions to be able to inspect and maintain the system should not be relied upon in Coastal Commission decision making. The Coastal Commission should not make decisions based on “vaporware”. State agencies are not allowed to procure “vaporware” (capabilities that do not exist), so why would the Coastal Commission make such an important decision assuming these most critical issue will be resolved by vendors?

The Coastal Commission should demand Edison use a proven system that can be inspected, maintained, have continuous monitoring, is transportable and doesn’t crack. This is the only way to meet Coastal Commission requirements. The NRC is only concerned with 20 years. The Coastal Commission is concerned with longer term requirements. Technology exists to meet both NRC and Coastal Commission requirements.

Rejecting the option of the thick casks, such as the German thick Castor casks (manufactured by Siemplekamp, designed by GNS), with the response “these thick-walled casks are not generally licensed for use at U.S. sites by the NRC” is not sufficient to reject thick casks. (Staff Report page 20). There is also the option of thick metal casks such as the Areva TN-24 and TN-32 casks currently used in the U.S. Southern California Edison knows both the German and Areva thick metal casks have been licenses by the NRC, so there is every reason to believe they would receive a license for San Onofre. Given that these options are proven technologies used in the U.S. and are the main storage technologies used for the majority of the rest of the world for both storage and transportation, thick casks should not be a rejected alternative. This would better meet Coastal Commission requirements for longevity and transport and also meet NRC requirements. Thick casks are approximately 10 to 20 inches thick compared to the proposed thin canisters that are only 5/8th of an inch thick. https://sanonofresafety.files.wordpress.com/2011/11/reasonstobuythickcasks2015-04-16.pdf https://sanonofresafety.files.wordpress.com/2013/06/germanycaskstoragegorlebengns.jpg

There is already evidence for the staff to have sufficient probability that requirements to have canisters transportable and maintainable may not be met with the Holtec UMAX system. Pushing the can down the road another 20 years isn’t going to change that. The only reason no thin canisters have leaked yet is because they have not been in use long enough for cracks to go through the wall of the canister. We are at higher risk of cracks due to our corrosive coastal environment. We are the last location that should be using this inferior technology with materials known to crack from corrosive moist salt air. The NRC does not allow transport of cracking canisters. The underground portion of this system is subject to corrosive ground chemicals and yet cannot be inspected due to lack of technology to inspect this design. http://pbadupws.nrc.gov/docs/ML1432/ML14323A067.pdf

Regarding Edison’s promise of potentially moving the system to higher ground as the coastal environment degrades that would require a major expense and would likely cost over double the existing San Onofre Decommission Plan cost estimates. The cost estimates they submitted to the NRC and CPUC assumes fuel will be picked up at the earliest DOE time frame, even though their documents state these dates are unlikely to be met. They also assume nothing will go wrong with the canisters. They have budgeted about $1.3 billion for spent fuel management and plan to spend it all. They also plan to spend the entire $4+ billion Decommission Trust Fund, so no monies will be available. What is the basis for accepting Edison’s promise? Will ratepayers be required to pay for this? Is their promise and this plan reasonable?

Choosing thick casks meet Coastal Commission requirements for both relocation on-site and transport. Thick casks are transportable. No additional transportation casks are needed. No protective concrete structures would need to be destroyed and rebuilt. No transfer casks are needed. Systems are installed above ground. Thick cask have seals that can be monitored and replaced. Once a thin canister cracks, it is no longer usable and cannot be repaired.

As the staff report clearly indicates there are many uncertainties regarding when or if the Department of Energy will pick up the fuel and many uncertainties about environmental conditions in our future. Therefore, we need to plan now for the best option, not wait for 20 years and hope something magical will change and assume the Holtec system can be relocated or transported. Please protect our coastal resources and do not allow this experimental Holtec UMAX system in our coastal communities. It does not meet current Coastal Act requirements. It is folly to approve a system based on vendor and utility promises of future solutions when we have the facts we need to make better decisions now. Yes. we need an NRC approved system, but one that also meets Coastal Act requirements. Those to items are not mutually exclusive and are obtainable. Edison’s unreasonably short artificial timeline should not be a driving factor for this decision that has long term implications for our Coastal resources.

Thank you,

Donna Gilmore SanOnofreSafety.org 949-204-7794

Additional information and references

Reasons to Buy Thick Casks and Nuclear Storage Myths https://sanonofresafety.files.wordpress.com/2011/11 /reasonstobuythickcasks2015-04-16.pdf SanOnofreSafety.org http://sanonofresafety.org/ Nuclear Waste Storage and Transport http://sanonofresafety.org/nuclear-waste/ Coastal Commission Staff Report http://documents.coastal.ca.gov/reports/2015/10/Tu14a-10-2015.pdf Coastal Commission October 6 Agenda and Location http://www.coastal.ca.gov/mtgcurr.html
Original found here: https://sanonofresafety.files.wordpress.com/2011/11/6-long-beach-coastal-commission-meeting.pdf (Some emphasis added, along with original emphasis).