Ominous facts from Admiral Len Hering regarding San Onofre Nuclear Generating Station (SONGS)

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Aug 29, 2021, 8:00:05 PM8/29/21
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Subject: [Conscom] Ominous facts from Admiral Len Hering regarding San Onofre Nuclear Generating Station (SONGS)

Mismanagement by the NRC and Edison 


The dismal facts explained:  
 
 
Here is material on Edison’s canister safety at San Onofre
 
Problem #1. Edison contracted the cheapest bid.  Holtec manufactured and delivered casks to San Onofre that contained loose parts. It made a last-minute design change of substituting different parts with shims. This was an unapproved change. Upon delivery loose shims were found in the bottom, but loading proceeded. These casks are supposed to be inspected at the factory after completion to assure no loose parts are present. The required inspections were never done. During shipping loose parts could cause damage to fuel assemblies from shocks and vibrations.
 
Problem #2 Holtec failed to provide correct training and materials to its workers and failed to develop an adequate procedure for the loading of the canisters into its UMAX system. Workers were trained on a different model that had a 1-inch total clearance for the entire circumference of the canister. Holtec neglected to inform workers about the installation of a new piece of equipment that resulted in a clearance of just ¼ inch. The most serious problem was a potential load-drop incident, which was never supposed to occur if proper procedures were followed. Workers could not visualize what they were doing. As a result, they were exposed to excessive radiation. Significant damage occurred to 29 canisters from scratching and gouging during insertion of the canister. As a result, it is likely that these canisters will suffer from more rapid corrosion as they age. In addition to the millions of dollars spent on these now damaged canisters, the same system, the Holtec UMAX system, will be used at the planned CIS facility in New Mexico if it is ever constructed. NRC issued multiple severe violations to the utility, Southern California Edison. However, NRC did not require a fix to this Holtec engineering design problem, and thus it is more likely that the same problem will occur at the New Mexico CIS facility, if approved. Increased inspections and repackaging will likely be necessary, but a DTS is not planned to be constructed. [See 2018 NRC Special Inspection Report.]  
 
 
If fuel damage is known, the damaged fuel is placed in cans with screening on either end. The screening only keeps solid pieces of the fuel pellets within the can, so the can is not a barrier to fission gases. The Holtec MPC-37 canister allows the loading of 12 cans for damaged fuel. Damaged-fuel cans do not provide a barrier. Thus, the only containment is the canister itself. Other countries require placement of damaged fuel in a sealed container, called a quiver. The US does not use this precaution. This situation allows for a serious radioactive release to occur if the canister is damaged.
 
Dry Storage of SNF poses unique technical problems for the long term that have not been solved
 
There are no available methods for detecting cracks or other defects in the sealed 5/8-inch-thick stainless-steel canister inside the vented thick concrete cask. Even an intact canister emits a constant stream of dangerous neutrons and gamma radiation. The outer cask shields workers and any living things in proximity from injury. Outer casks must be ventilated to prevent heat buildup and subsequent damage to the spent fuel assemblies, so they do not serve as containment, only shielding. Visual inspection is impossible because of the high radiation dose without the concrete shielding of the cask. Efforts to develop camera systems that can navigate the small open space between canister and cask and function in that hostile environment have been unsuccessful.
 
Current CIS plans do not include a shielded facility where the canister could be safely removed from the outer cask to remotely inspect the canister for any defects. Such facilities with radiation shielding are called Hot Cells or Dry Transfer Systems (DTS). Plans also do not include the capability of transferring the fuel assemblies out of a damaged canister into a new one.
      
Microscopic cracks in the canisters can release radiation so radiation monitoring is essential. Unfortunately, even if cracks are found, there are no current methods available to repair these cracks in stainless steel canisters loaded with SNF. They cannot be re-welded. The only current approach is to transfer the canister into a larger container.
 
These problems exist at every dry storage site today, while some sites, such as those near saltwater, are more likely to experience more corrosion as the equipment ages.
 
 
NRC never developed specific regulations for CIS facilities. Instead NRC merely adopted the regulations used for dry storage at reactors around the country. Thousands of concrete casks would be placed on a concrete pad on the land surface in the absence of any protection from violent attacks. While hundreds of citizen groups throughout the country have supported HOSS (hardened on-site dry storage) at ISFSIs since 2006, nuclear regulators have not adopted these sensible recommendations to protect SNF storage from terrorist attacks.  Other countries use reinforced concrete buildings as their hardened protection for dry storage casks.
 
Problems with High Burnup Fuel
 
Shorter licensing periods of 20 years were established for HBF.  The GEIS notes:  “Although NRC regulations for dry cask storage allow for a licensing period of up to 40 years for both initial and renewed licenses, licensing periods approved for storage casks for high-burnup fuel have been limited to 20 years due to the more limited data available for high-burnup fuel.”  [See GEIS, App. B, p.16]
 
 
 
 
1. The canister would have to be entirely replaced, because Holtec canisters are too large to put inside of another cask.
"An oft-repeated solution to a leaking or damaged cask is to simply put it in a larger container. While this may be possible in some situations, the Holtec UMAX 37 PWR is unique in terms of its very large size, making the current availability of a larger container impossible."
 
2.  Canisters at San Onofre arrived damaged: "Holtec manufactured and delivered casks to San Onofre that contained loose parts. It made a last-minute design change of substituting different parts with shims. This was an unapproved change. Upon delivery loose shims were found in the bottom, but loading proceeded. These casks are supposed to be inspected at the factory after completion to assure no loose parts are present. The required inspections were never done. During shipping loose parts could cause damage to fuel assemblies from shocks and vibrations."
 
3. Damage occurred to cannisters at San Onofre when loading them into the UMAX system compromising their integrity. "Significant damage occurred to 29 canisters from scratching and gouging during insertion of the canister. As a result, it is likely that these canisters will suffer from more rapid corrosion as they age...NRC issued multiple severe violations to the utility, Southern California Edison. However, NRC did not require a fix to this Holtec engineering design problem, and thus it is more likely that the same problem will occur" in the future. 
 
4. The Holtec system allows for damaged fuel to be loaded into cannisters: "The Holtec MPC-37 canister allows the loading of 12 cans for damaged fuel. Damaged-fuel cans do not provide a barrier. Thus, the only containment is the canister itself. Other countries require placement of damaged fuel in a sealed container, called a quiver. The US does not use this precaution. This situation allows for a serious radioactive release to occur if the canister is damaged."
 
5. Current Canisters may not be safe with high burnup fuel (HBF). "reassurance of safe storage applies only to low-burnup fuel (LBF).  NRC provides reassurance about the continued safe storage of SNF for a period up to 80 years (40 year license and 40 year renewal). However, that assurance is qualified as only applying to LBF. [See GEIS, App. B, p.19] Currently federal agencies are allowing mixed loads of LBF and HBF."
 
6. No canisters were damaged in the Fukushima earthquake and Tsunami, but they were sturdier thick-walled cannisters. "It is important to note that Fukushima employed thick-walled, ductile steel  storage casks with bolted, removable lids, used in European countries, not the thin-walled canisters in common use at US dry-storage sites." There is no assurance that the thin-walled Holtec canisters would fare as well. 
 
7. Transferring the waste to better, thicker casks would require a hot cell (or dry transfer storage facility) which does not currently exist at San Onofre.
 
Without a doubt advocating for better, thicker casks is a great idea. But the cost from a hot cell and transfer to smaller, but thicker casks would cost hundreds of millions of dollars. So it would be a nontrivial proposal from an economic standpoint.
 
 
 
 
 


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