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Sunday, September 29, 2013

San Onofre Decommissioning Meeting

Full credit to Roger Johnson, who attended the San Onofre meeting and made these great interpretations of what was said and unsaid.     

I am storing this on my site for ease of reference and this will be helpful in preparing comments for NRC meetings.

The upcoming NRC meetings open to public are here, 8 of them


NRC Public Meeting on Decommissioning, 2013-09-26

Citizens Oversight  (2013-09-26) This Page:
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About 7 minutes were omitted at the beginning of Part 1 and 3 minutes at the beginning of Part 2 which were facilitator remarks about logistics.

Part 1

Includes presentations by NRC staff and first questions from the public

Part 2

More questions. Don't miss statements by Peter Dietrich of Southern California Edison near the end, regarding the fact that they are not planning to return the site as "greenfield" level.

Summary by Roger Johnson

Notes on the NRC public meeting at the Costa Omni Resort in Carlsbad, Thursday Sept. 26 6-9 PM
This was a typical NRC meeting: a moderator, 4 featured speakers (one who made 2 presentations), and a dozen other NRC officials who occupied the entire center section of the front row (a number of them gave extensive comments during the public question phase). The NRC once again chose a plush resort and a huge banquet room which probably seated over 1000. The NRC claims to have selected this distant site because they could not find anything suitable in Orange County. Some said they wanted the meeting at this distant site to reduce public attendance. The AC was cranked up making the room frigid (perhaps 60 degrees) and uncomfortable. I am guessing that there were about 200 in attendance, perhaps 75 when the evening ended. Although this was a good crowd, it appeared small in this huge room. The NRC said they expected more, but perhaps they were delighted at a smaller crowd which they could interpret as a lack of public interest. The meeting reminded me of one of the 18 grievances against King George written into the Declaration of Independence, namely that inconvenient meetings were called by the Crown in distant and cold places in order to suppress attendance.

The NRC had a table in the lobby full of NRC documents about decommissioning. One color pamphlet is called the Decommissioning Process. There are before and after aerial photos on the cover (and inside) showing nuclear power plants before and after they were demolished. The “after” photos show a green field. The NRC now uses the term Greenfield to mean site restoration. They also made it a verb: Greenfielding. This term was used often during the evening apparently in a public relations/marketing effort to make it appear that former highly radioactive sites could be made pristine. Before the meeting started, the NRC had a slide show showing other before and after photos. One disturbing series of photos showed the Maine Yankee containment domes being blown up, reduced to rubble, and then planted over. The photos remind me of the contaminated and bulldozed town of Uravan, Colorado which is now a "Greenfield." One wonders why they would show that unless they planned to do the same thing at San Onofre.

The meeting began with happy talk and rules by the moderator, and the first half of the meeting was monopolized by the speakers and their power point presentations. As usual, the focus was on the bureaucratic procedures of the NRC rather than on the substance of decommissioning.

 Few details were given other than lengthy lists of NRC rulings which had to be followed in a particular order. During the public questions phase, speakers gave lengthy answers and often passed the microphone back and forth so that many NRC officials could respond to the same question.

The net result was that time ran out and many in the audience could never get recognized.

I was sitting in the second row center and waved my hand for an hour and was ignored the entire evening.

The first speaker was Larry Camper who boasted that the NRC decommissioning team had 300 years of cumulative experience in decommissioning. They have decommissioned 50 materials sites, 13 research reactors, 11 nuclear power plants (NPP), about 80 in total. He made it clear that the licensee (Edison) had the right to choose whether to decommission the site for unrestricted use (for any purpose) or restricted use (still partly contaminated).

He said that all decommissionings so far have been unrestricted. He said their goal was to end up with contamination levels no higher than 25 mrem AND as low as reasonably achievable (ALARA). This was scary and unclear but not questioned. All their technospeak may boil down to the fact that they have a procedure which says that they don’t have to do what is safe, they only have to do whatever is practical and easy to achieve (for them)..

The second speaker was Bruce Watson who went into many of the rulings such as 10 CFRPart 20 Subpart? E He says that Edison will have 60 years to complete the process, up to 50 in SAFSTOR and 10 in DECOM. The radioactive waste has to be reduced only by 90%, not 100%. He made the incredible statement that they liked to go slow and stretch out the process in order to allow the decommissioning trust funds to remain invested so that interest would compound and generate more money over time.
Edison will produce a PSDAR report about costs and environmental impacts. This plan must be submitted, but it does not require any approval by the NRC. A final License Termination Plan LTP must be approved by the NRC. Edison has until June 7, 2015 to submit their plan but Edison says it hopes to submit it earlier.

The third speaker (and 5th speaker) was Dr. Blair Spitzberg whose specialty is fuel safety. He carelessly stated that spent fuel has to go into cooling pools for “several years.” Regular fuel needs to be cooled in pools for 5 years and the Hi Burn fuel that Edison has been using since 1996 requires 12-15 years. It was unclear whether Dr. Spitzberg’s goal was to deceive the public about this crucial issue or to trivialize it (or both). He stated that San Onofre has two types of dry casks which are certified for transport: 24PT1 and 24PT4. They also have another type not yet certified (but Edison has applied for transport certification). This is all mute because there is no where for any of it to go, at least during our lifetime. He said that the exact number of dry casks is secret information but it can be found on (if someone finds these data here please circulate). He said there were 55 cannisters at San Onofre as of Dec., 2012.

Here are 2 more alarming statements Dr. Spitzberg made:

First, he referred to a category called “High Risk Activities” with no explanation. If part of decommissioning involves high risk radiological activities, this should be disclosed to the public as to when they occur and what part of the public takes the risk if something goes wrong.

Second, when talking about contaminated waste, he mentioned that “MOST” contaminated waste is taken out of state, implying that some contaminated waste is taken to other parts of California. Since there are no radioactive contamination waste disposal sites in California, presumably he means that it is dumped in landfills?

Also discussed was Unit #1 which is not completely decommissioned because the reactor vessel remains on site. Attempts were made to barge it through the Panama Canal to a Class C (highly contaminated) site in South Carolina but there was political opposition by the countries involved plus the fact that the barge would move so slowly that it would tie up traffic. Attempts to route it around South America were blocked by Argentina. The “solution” is to leave it at San Onofre for the time being (meaning probably decades) which makes San Onofre a Class C radioactive waste storage facility. The “plan” is to wait until it is time to move reactor vessels (the largest component needing removal) for Units 2 and 3, and then deal with them all at the same time. Since these are too large and too dangerous to ship by truck or rail, they hope that many years from now a solution will someone become apparent. It looks like a long time before #1 will get a LTP.

Some other tidbits about #1 which came up (also in Q and A) include the fact that Edison never removed the large discharge pipe into the ocean. They decided that there would be more radioactive contamination to the ocean by removing it than leaving it there (presumably contaminated), not to mention the fact that doing nothing is always cheaper and easier.

If they knew before they built this pipe that it would be too dangerous ever to remove, why was it ever allowed to be built? This shows the same dangerous strategy of the NRC: build things first without concern for consequences and put off safety considerations as long as possible.

There was also discussion of a leak of radioactive liquid waste being shipped to Clive, Utah from #1. It was discovered at a truck stop in Utah. Teams went in and patched it up and the NRC claims that no one was hurt. Later I cornered the staff member who said that asked if he meant that the radioactivity didn’t harm anyone during the few days after the accident and he admitted that this is what he meant. I asked how they could possibly know if anyone was harmed since it would take at least 5 years for cancer to appear if someone inhaled radioactivity. He agreed that it was possible and they really don’t know if anyone was harmed even though they make claims to that effect.
Speaker #4 was Michael Dusaniwskyj, an economist. He said there was currently $1.7 billion in trust funds for unit #2 and $1.9 billion for #3. He said that $295 million remained earning interest for Unit 1 of which they expect to spend $206 million. No mention of where the unused $89 million will go. Back to the rate payers who have been paying for this since 1968?
Gene Stone opened the Q&A period with a request for having a citizen group called Coalition to Decommission San Onofre officially be a part of the decommissioning process. The NRC replied briefly that they would think about it.. Another question from this group was whether residents would be warned of any activities which might lead to environmental contamination. The answer was no, residents would not be warned. The NRC bureaucratic answer was that all such activities would be treated exactly the same way as the current procedures for low level radioactive waste disposal. It was asserted that all such waste disposal would be carefully documented and eventually appear in public records. The current procedure is to wait about a year and then make quarterly reports about radioactive waste disposal into the air and ocean. The waste discharges are averaged over 90 day periods. NRC regulations carefully state that these averages must not exceed permissible levels (it is always what is permitted, not what is safe). In this way, a large release on the beginning of a quarter could be averaged with 89 days of no releases and the records would clearly indicate a low permissible average dose. The public will never know before such releases occur and they will also never know the dates and concentrations of releases even a year later. The only way to know is to install real time publically accessible monitoring, a subject which never came up in spite of all the expressed concern for transparency and public safety. Supposedly there will be a lot of radioactive monitoring by Edison and the NRC, but it will all be secret information.
Much of the discussions involved the problems caused by the use of Hi Burn fuel which is much hotter, much more radioactive, and requires about triple the amount of time in cooling pools. The NRC could not answer exactly how decisions were made (and kept from the public) about the switch in fuels. They could not answer questions about the dangers of dry cask storage for this fuel. Dr. Spitzberg admitted that Hi Burn fuel required more time in cooling pools but he did not know how much longer. At one point he said it might be 7 years (half the time that other experts cite). The NRC was quick to blame the Dept. of Energy and national politics for the failure to have any permanent nuclear waste disposal facility. They were happy to talk at length about this problem involving other parties. They maintain that they are blameless and can do nothing about it.
Many people in the audience made articulate statements of concern coupled with questions which were often brushed aside. Some mayors and city council members weighed in. One interesting speaker was Patrick Christman, Assistant Chief of Staff at Camp Pendleton who was involved in environmental protection for the camp. He later told me that the marines were concerned about the radiological dangers but considered themselves mostly observers. He was not aware that San Onofre might be a major target for terrorists, and he was not aware of the newly funded cancer streak study which will be carried out by the National Academy of Sciences in the next 2 years (all of Camp Pendleton will be part of the study).
There was only one pro-nuclear comment from the audience. This came from a representative of the Chamber of Commerce who was outraged that the general public was allowed to weigh in at all. He suggested that the NRC should stop wasting its time listening to the public and make all the decisions on their own. The NRC gave him effusive thanks for his comments. I suppose everyone knows that Edison has contributed heavily to every Chamber of Commerce in most of Southern California.
I was disappointed that there were almost no questions or discussion of the disposal of low level waste (everything that is not the fuel rods). Will they blow up the containment domes as they did in Oregon and Maine (think of all the contaminated particulate blown into the air and settling in the ocean and on our rooftops). Will they bulldoze contamination and let it stay? Will they let everything underground stay, contaminated or not? If Class A waste goes to Clive, Utah, what will be the route for the thousands of trucks? What safety precautions will they take? We assume Class C waste will go to Texas (how?) but what falls into Class B and where will it go? Who makes these classifications and how can they be trusted? Will they try to classify contaminated waste as less than A so it can go into EPA designated hazwaste sites or into landfills? How much of San Onofre will end up at the landfill off Ortega Highway, and how much will somehow end up in the ocean? Will they leave forever the 18 ft diameter 1500 ft long into the ocean? This pipe has been carrying liquid radioactive waste for a third of a century. Will the public be notified on days of “high risk” demolition? They have hazmat suits but we don’t. What about the 3 upwind schools only 2 miles away? What about the surfers?
Two low points stuck out for me. First was the discussion about the safety of the spent fuel pools. The NRC went on and on about how it had a 5/8 inch steel lining, walls 4 feet thick, and a foundation 3 feet thick, and it was way above sea level (19.75 feet to be exact). Therefore it would be impervious to earthquakes and tsunamis. When asked about safety from above, perhaps by terrorist attacks, the question was cut off and never answered. When pressed about drone attacks and terrorism, Bruce Watson dragged out the old study claiming that an airplane could crash into the containment dome and not cause it to collapse. He would not respond to attacks on the fuel pools or dry cask storage and used the NRC line that San Onofre was just as safe as any other nuclear power plant in the country. (Which is true because all of them are unsafe.) I am familiar with the National Academy of Sciences special study about the vulnerability of NPP to terrorism and the research done by Sandia Labs about 9/ll type plane crashes. Privately he admitted that such crashes or missile attacks or any high explosives might lead to catastrophe if they targeted the pools or dry casks (which is why the NRC only takes about containment dome safety). I told them that the Sandia Labs also found that a truck bomb exploding at a NPP perimeter a few hundred feet from a fuel pool would likely cause a catastrophe. He did not know this. But he did know that the fuel pools and openly stored dry casks are about 200 feet from public road Old Pacific Highway and about 300 ft from Interstate 5. Everyone knows that NPP designed in the 1960s were never designed to protect against terrorism. The NRC pretends that no such attacks are likely and it is the Pentagon’s problem, not theirs.
The other low point was the last question from Pete Dietrich, Edison chief nuclear engineer. He complained about the continual reference to “Greenfield” status which suggested that Edison would have to make the site pretty when they leave. When pressed, the NRC said that the site would not have to be returned to a “Greenfield” which pleased the public. They only had to please the US Navy, the owner. The bottom line is that Edison has to do only what is acceptable to the Navy, perhaps what one might find at a military base used as an artillery range. This is a clue as to what we can expect from Edison.

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