Webinar on safety risks at the failed San Onofre Nuclear Generating Station (SONGS) draws huge crowd

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On Tuesday, April 23 at 5:30 Pacific Time, Charles Langley of Public Watchdogs, Gary Headrick of San Clemente Green, keynote speaker Paul Blanch, and Cathy Iwane, a Fukushima evacuee, were featured in a 90-minute Webinar by producer Doug Wood of Grassrootsinfo.org . The presentation focused on the nuclear radiation risks at the failed San Onofre Nuclear Generating Station (SONGS), and was broken into five brief presentations on a different aspect of safety.

Source page for these videos
Part One – Charles Langley, Public Watchdogs
Part Two, Paul Blanch
Part Three, Cathy Iwane
Part Four, Paul Blanch
Part Five, Gary Headrick, San Clemente Green
Part Six, Panel Discussion, Questions and Answers

Get the video from Grassrootsinfo here.

Paul Blanch’s presentation notes from Part One are shown below:

Expert Witness, Nuclear Power, Whistleblower

Paul Blanch

Presentation Script

Potential Flooding

Part One, Presentation by Paul Blanch

Slide 1:

Thank you and good evening.

As a nuclear engineer with over fifty years of experience, I would say that the San Onofre Nuclear Station (SONGS) is probably the most dangerous nuclear power plant site in the USA. I am saying this as a lifetime advocate of safe nuclear power. The Nuclear Regulatory Commission’s (NRC) mission is to “Protect the Public and the Environment.” This mission is allegedly accomplished by compliance and enforcement of the Federal Regulations.

I have been a qualified Reactor Operator, Instructor of reactor theory and operations, and a qualified nuclear electrician, and more than four years of formal nuclear education. Additionally, I received a BS degree in engineering and was a professional engineer (PE) in the State of California. I have participated in many Nuclear Decommissioning Boards (DOB) in the Northeast US.

Slide 2:

The NRC’s Office of the Inspector General (OIG) has issued at least three investigative reports validating my interactions with the NRC. All of these OIG reports substantiated my contentions that the NRC provided false information to me and to the public. The NRC continues this practice and we have been meeting with the OIG on an ongoing basis about the issues we will be discussing today. These OIG reports can be located on the NRC’s website.

I will be citing specific regulations from the Federal Code of Federal Regulations (CFR) but will not burden the audience with specific and confusing terms such as 10 CFR 72.122(l) etc. as these can be all found on the NRC’s website or Google.

Slide 3:

Now, the Nuclear Regulatory Commission, or the “NRC” has a responsibility and a mission to protect the “public and the environment.” But I’m sorry to say, that’s not happening here, and everyone in Southern California needs to know that, and know what the problems are. That’s my goal here tonight.

Slide 4:

So the question before us tonight is: How can we make San Onofre decommissioning safer? We will never make it completely safe. But there are things we can do to make it safer than it is now. And it’s critical that we do that before it’s too late.

Slide 5:

This photo is taken from the South of the plant.

The major issues we’ll be talking about tonight are:

  • The potential flooding of San Onofre during a tsunami or major weather event and the unaddressed issue of potential “Criticality”, a clear requirement of the regulations
  • The failures of political communication after the Fukushima accident and the transparency of failures of the NRC, Southern California Edison or “Edison” and Holtec about the true dangers at San Onofre
  • The retrievability of the spent fuel
    • The potential consequences should the NRC continue to ignore its regulations and Congressional mandate.

Slide 6:

Here are some pictures demonstrating the proximity of San Onofre to the ocean, and the very likely possibility that in a severe storm or a tsunami, the area where the spent fuel is currently located, could become submerged in salt water. Keep in mind, the facility is in an earthquake zone, so the idea of a tsunami is not that remote. The wall that you see there is the only thing protecting the spent fuel containment area. This wall will not even protect against wave actions. One can also view the San Onofre one-foot-thick “sea wall.”

Slide 7:

This photo taken last month in the Canary Islands is designed to protect a small harbor and small city. It is about 12 feet thick at to top and 50 feet at the bottom. This is also similar to the sea wall at Fukushima, which unfortunately did not consider the potential magnitude of historic tsunamis.

Slide 8:

This photo from the owners of the plant, “Edison” shows the area that would be flooded in the event of a major weather event. As you can see, the area which is clearly marked is exactly where the spent fuel is presently being stored. So everyone knows this is a problem. The Storage Facility may be flooded at an ever-increasing frequency. Edison submitted this photo under oath to the NRC in 2013 and it has never been supplemented or withdrawn,

Slide 9:

Now the NRC has decided that the possibility of a flood at San Onofre is not credible, so they don’t have to plan for flooding. The NRC’s documentation, actually says “flooding is excluded as an initiating event” in spite of Edison’s own analysis. And Holtec, the company subcontracted to Edison to decommission San Onofre, is classifying its analysis of flood potential as “proprietary information.”

How can information, critical to the safety of millions of people be classified as “proprietary?” It appears that Edison is hiding and withholding vital information.

Slide 10:

Let me talk for a few minutes about the way the spent fuel is currently being stored and cooled at San Onofre, and why it could be a major problem in the event of a flood. This canister containment device is designed to keep the spent fuel cool. Here’s how it is designed to function

These 5/8-inch thick canisters, each containing more radioactive material than that released from either Fukushima or Chernobyl are located about 108 feet from the Pacific Ocean.

During normal operation, the airflow enters the top as shown by the blue arrows, and proceeds down the outside of the divider shell. From there, it passes through small passages estimated to be about 4 inches in height at the bottom, and due to the heat, rises and discharges, the heated air, thus cooling the canisters. The normal temperature on the outside of the canister is greater than 500°F. I expect the discharged air to be a few hundred degrees.

I have described the operation of the cask and cooling design during normal operations. It may function well in a dry, salt-free environment, however, at San Onofre, the life expectancy is limited and only carries a 25 years warranty.

There is a probability, as acknowledged by Edison andHoltec, that flooding may occur under storm conditions, and also due to the effect of a tsunami. Either of these events will result in the flooding of these vertical modules (VVM). In this event, water, and debris will inundate these modules filling all cooling paths and module voids.

Should this occur, Pacific seawater with, about 3% salt, will flood all voids in these modules. As clearly stated by the NRC and Holtec, the water will actually assist with canister cooling. When the water recedes, the seawater will rapidly boil off due to the heat of the spent fuel and the latent heat of the Vertical Ventilation Modules (VVM). In a few hours or minutes, all water will be boiled off leaving a few hundred pounds of solidified salts and other debris at the bottom of the modules.

This salt will totally inhibit all cooling to the spent fuel. Edison states they can remove this blockage, but thisstatement is false, especially for 73 canisters. Edison has not acknowledged having procedures or equipment in place remove blockages within 24 hours as required by the legally binding Technical Specifications (TS). This is not trivial and a very expensive endeavor. Nor has the NRC required such equipment or training for these procedures.The loss of canister heat removal has been analyzed by Holtec and the NRC however it assumes cooling will be restored within 24 hours, which cannot possibly be accomplished for even one canister.

The loss of heat removal for greater than 24 hours has never been analyzed and will result in exceeding fuel and canister design limits with unknown radiological consequences. It is also possible the materials designed to prevent criticality could be damaged.

Slide 11: The NRC has developed what they call a “Probabilistic Risk Assessment of a Dry Cask Storage System at a Nuclear Plant”. In this report, they project a dose of 360 millirems (mr) of radiation to the public extending out to 1 mile away. The maximum allowable dose to the public is 100 millirems, so we have a problem. And it means that everyone within the 1-mile radius would have to be relocated in a flooding event, just as they were at Fukushima.

Now the NRC hasn’t done, or hasn’t made public, any analysis of the exposure to the public beyond one mile. This is another reason why we need a site-specific analysis for a flooded and potentially breached spent fuel canister. The NRC has determined that such a breach is “not

credible,” but we believe it is very credible and requires a revised Emergency Evacuation Plan. And the time to develop that plan is now, not once we have an emergency on our hands.

Slide 12. Inadvertent Criticality

No commercial reactor in the world has ever experienced this type of event but it occurred at a military reactor (SL-1 in Idaho) in 1961 resulting in immediate fatalities and land still uninhabitable today.

September 1965 I commenced my first day at Admiral Rickover’s Navy Nuclear Power School. At that time I hardly knew the difference between a neutron and a crouton. On this first day, we were all gathered to view a classified video on the Army’s inadvertent criticality accident at the SL-1, which occurred in an Idaho desert. This accident produced a peak pressure of 10,000 psi and resulted in 3 immediate fatalities and an unspecified number of latent deaths. The amount of contaminated land has never been published, to my knowledge. We all understood the message!

This video can now be viewed on Google.

Our instructor that day reminded us that we are not dealing with a cookie factory but a dangerous system if not understood, maintained, and operated in accordance with approved procedures, the results can be catastrophic.

Slide 13: “Federal Regulations for “Criteria for nuclear criticality safety” state in part:

“Spent fuel handling, packaging, transfer, and storage systems must be designed to be maintained subcritical for . . .handling, packaging, transfer and storage conditions and in the nature of the immediate environment under accident conditions.”

An “Inadvertent criticality” is not credible for inland sites but an unaddressed possibility at San Onofre, with unimaginable consequences. Once again, Edison fails to provide any realistic analysis of this event.

In its present analysis, Holtec states that criticality will not occur as long as the water in the canister water level is less than 95%, but fails to discuss total flooding, inferring that total flooding may result in multiple criticalities. We don’t know if this is the water level in the canister or the fuel, that are significantly different.

Holtec also uses a proprietary material (METAMIC TM) to absorb neutrons and prevent criticality. We have no information on this material and its ability to remain functional at temperatures during the loss of cooling and other events that exceed design limits. The required analysis must also consider this event and its consequences.

Slide 14: Thank you for listening and I will now turn the presentation back to Charles.


Slide 1:

Thank you again. This first photo illustrates the power of the Pacific Ocean in the vicinity of San Onofre

This part of my presentation is about the Federal Regulation that requires the Retrievability of the spent fuel at San Onofre.

Slide 2:

Retrievability is one of the most vital aspects of the safe storage of spent fuel in the Storage Facility at San Onofre and other existing Storage Facility Sites.

Regulations in Part 72 on “ Retrievability” state:

“Retrievability. Storage systems must be designed to allow ready retrieval of spent fuel, high-level radioactive waste, and reactor-related GTCC[Greater Than Class C] waste for further processing or disposal.”

And the same Part 72 of the regulation states:

Except as specifically authorized by the Commission in writing, no interpretations of the meaning of the regulations in this part by any officer or employee of the Commission other than a written interpretation by the General Counsel will be recognized as binding on the Commission.”

The regulations clearly define ” Spent Fuel ” as the fuel assemblies within the canisters.

Slide 3: The NRC with the assistance of industry lobbying groups has made every effort to change this regulation and avoid a major financial impact on utilities by a concerted effort to change the interpretation avoiding the long, formal rulemaking process described in Part 2 of the Regulations. Compliance would tens of millions to the decommissioning costs.

In direct conflict with the requirements of the law, the NRC has developed a “workaround.” With full knowledge, the NRC has essentially changed the intent of the Retrievability regulation to allow sites to meet this law by demonstrating that canister storage is acceptable without the ability to ever access the spent fuel, thus saving billions of dollars for the nuclear industry no need for a hot cell or a spent fuel pool. The NRC did all of this behind closed doors however, it was eventually published in the Federal Register which does not meet the requirements for formal rulemaking requirements.

Why should we care about “Retrievability”

The NRC knowingly violated its own regulations

Slide 4: Federal law requires that nuclear waste storage systems be designed to allow ready retrieval of spent fuel and other high-level radioactive waste for further processing or disposal. “Ready retrieval” means you can easily get to the spent fuel and move, inspect, and repair it if necessary. That’s the federal requirement, fuel Retrievability, not cask relocation.

Non-Compliance is not an option but forcing the NRC may take action may require a formal legal challenge.

Retrievability is required because:

Without this capability, we can never inspect, repair or transfer the fuel to a long-term facility. And.

  • It is a Federal Law (Energy Reorganization Act of 1974 and 10 CFR)
  • It may be necessary for transportation from the present location
  • Necessary for fuel inspection and repair
  • Without Retrievability the risk to the public and future
    generations is significantly increased
  • Required for long-term geological disposal
  • Required for possible reprocessing

Slide 5:

Federal Regulations prohibit the NRC from changing or reinterpreting any regulations in 10 CFR 72, but this is nothing new to the NRC

In spite of this, the NRC has made significant changes to the Retrievability regulation and has not provided a “written interpretation by the General Counsel” that I am aware of.

This was done by the issuance of Industry Staff Guidance (ISGs 1, 2, and 3) thus totally changing the intent of the regulation on Retrievability.

Slide 6:

This is a photo of the equipment required to move the canisters at San Onofre. As you can see in this picture, this is not a simple job. It takes extreme effort, time, equipment, personnel, and significant radiological exposure to workers to actually remove one of these canisters from its current location. So in the event of an emergency like a giant storm, there’s essentially no way for these things to be moved in a timely fashion. With encased salts and debris, the canisters may not be able to be removed from the VVM!

Slide 7:

Holtec produced a “Final Safety Analysis Report” where it discusses the “PROCEDURES FOR UNLOADING THE HI-STORM UMAX SYSTEM IN THE SPENT FUEL POOL”

Apparently, Edison has no concerns the Spent Fuel Pools are planned to be demolished shortly. This conscious decision was approved by the California Coastal Commission (CCC) apparently with no knowledge and total disregard of the federal requirements but will significantly reduce decommissioning expenditures.

This is the most egregious example of Holtec, a subcontractor to Edison, lying to the NRC and the public by stating:

“If the MPC [Multi Purpose Canister] fuel cavity cannot be successfully returned to a safe, analyzed condition, the fuel must be placed in a safe condition in the spent fuel pool. The Completion Time is reasonable based on the time required to re-flood the MPC, cut the MPC lid welds, move the TRANSFER CASK into the spent fuel pool, remove the MPC lid, and remove the spent fuel assemblies in an orderly manner and without challenging personnel.”


Slide 8:

“The HI-Storm 100 system, unloading procedures, describe the general actions necessary to prepare the MPC for unloading . . . Special precautions are outlined to ensure personnel safety during the unloading operations, and prevent the rest of the MPC over pressurization and thermal shock to the storage spent fuel assemblies.” Knowing there won’t be any spent fuel pools within 300 miles of San Onofre.

There are no provisions discussed to prevent thermal shock when the canister is submerged in cold water and the consequence are unknown.

The HI-Storm 100 system canister is nearly identical to the UMAX system

The NRC must take some type of enforcement for these false statements (but they won’t)

Slide 9

This part of the FSAR (Final Safety Analysis Report) clearly requires “all cooling to all canisters must be restored within 24 hours or damage will occur.” We know this to be impossible and there will likely be a major release of radioactive material into the environment that may persist for years.(i.e. Fukushima and Chernobyl)

Slide 10:

This is the cover page from the 671-page UMAX FSAR. This document must be totally revised to address compliance with a potential flooding issue, criticality, and retrievability.

Should this analysis conclude an unacceptable risk to the public, then Edison must consider installing a “Hot Cell” and constructing a hardened structure with thick-walled casks as will be shown in upcoming slides thus demonstrating Regulatory compliance to meet the Federal requirements for Flooding, Retrievability, and Criticality

Slide 11:

We must demand Edison retain the Spent Fuel Pools until a suitable hardened structure is constructed as shown in the following photo.

Slide 12

Where do we go from here?

  • Provide an accurate analysis for Flooding, Retrievability, and Criticality.
  • Provide a hardened (seismic and tsunami resistant) structure with thick wall casks for flood, and tsunami protection, and a terrorist deterrent meeting the Federal Siting Requirements
  • Continue our attempts to reestablish a dialog with the Chairman, Commissioners, Office of Public Affairs, NRC Staff, and NRC’s Inspector General Office
  • Reiterate our numerous requests with the NRC’s technical staff for a public meeting per Commission Policy
  • Update the Final Safety Analysis Report demonstrating compliance with all Federal regulations.
  • Reevaluate Emergency Planning based on realistic accident dose rates
  • Attempt to accelerate the NRC’s Inspector General’s investigation
  • Retain the Spent Fuel Pool and/or install a “Hot Cell” demonstrating regulatory compliance for the short term.

Slide 13:

Self-explanatory. Why does the NRC refuse to enforce its regulations? The answer is that no nuclear plants would be economical if the regulations were enforced.

Slide 14: Nothing will be done without public outcry.

Let your feelings be heard by your elected officials, letters to the news media, and to the Nuclear Regulatory Commission

Slide 15

Concluding Remarks

NRC personnel may also present tonight for this presentation, but we will not be putting them on the spot or asking them any questions at this time.

However, we will provide the opportunity to the NRC and Edison to provide a brief statement.

From my perspective, living 2500 miles from San Onofre, my family and I are “Safe” from this impending disaster. I may have had a different opinion if I were residing in Southern California.

I say this even after sleeping on a Nuclear Submarine for months on end, 100 feet from a “safe Navy nuclear power reactor.”

A special thanks to Doug Wood for his audio-visual expertise. We would not have been able to produce this presentation without his assistance.

We look forward to working toward mutual resolution of these significant safety issues, and re-iterate our invitations to the NRC, EDISON, and the Community Engagement Panel for productive, professional meetings in the near future.”

So these are just a few of the issues we’re facing right now at San Onofre. Thanks for your attention.

I now turn this back to Charles Langley for questions and closing comments.

Thank you for listening.

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