Statement and Questions for the NRC Sept 26, 2013

Questions from the Coalition to Decommission San Onofre for the NRC September 26, 2013 Decommission public meeting

We are here today in the hope that the Nuclear Regulatory Commission (NRC) will make San Onofre the “Flagship Project” for a safe-and-sane cleanup of America’s effort at decommissioning our old and dangerous nuclear fleet and its highly radioactive nuclear
waste problems. The original Manhattan Project brought us to where we are now; it’s time for the same kind of resources and energy to be put into a project to rid of us this dangerous radioactive waste.

To this end the Coalition to Decommission San Onofre is forming a true citizens’ oversight committee to watch out for the health and safety of all Californians, and workers at the plant during the decommissioning process. Our second goal is to watch out over the cost of decommissioning so the citizens and ratepayers of California are not gouged during the process.

1. Is the NRC willing to recognize and give us, The Coalition to Decommission San Onofre, official status? Will the public have an opportunity to review and comment on significant decommissioning plans, including planned expenditures?
2. High burnup has been used at San Onofre since 1996 we were told by the NRC recently. But we cannot find a public notice of that from the NRC or SCE. Even the union and other workers I have talked with were not aware of its use. Was a notice ever given to the public and workers? Were workers made aware that this high burnup fuel is more than twice as radioactive?
a. High burnup fuel is hotter and “between 2 and 158 times more radioactive”, requiring the waste to be cooled on-site in spent fuel pools for at least 12-15 years (rather than 5 years).
http://www.greenpeace.org/canada/Global/canada/report/2010/5/nuclear/GP_REACTOR_FUEL_REPORT_MAY2010.pdf
Does the NRC agree with these statement? If not how much more radioactive would the NRC say high burnup is? Edison reported to the CPUC they must keep some of their fuel in the spent fuel pools for at least 12 more years. SCE SONGS 2 & 3 Early
Decommissioning Scenario – CPUC Supplemental Testimony, July, 22, 2013

http://sanonofresafety.files.wordpress.com/2013/06/nucleardecomcosttri2012_test_sce_20130722_282046.pdf

b. How does the high burn up fuel affect the decommissioning process at San Onofre? What specific problems does this higher radioactive fuel present for waste storage in fuel pools and dry cask storage at San Onofre and just how much longer will this radiation last? How will Decommissioning be impacted by the current
onsite storage of the Spent Fuel?
c. We understand the NRC staff is worried about short and long-term waste storage in dry cask of high burnup fuel, and has initiated a new study to determine if it can safely be stored in dry casks? Is this report complete? Will it be released public and when? One of your concerns is that there is no way to monitor what’s occurring inside the dry casks. How does the NRC propose to monitor the highly radioactive material inside of the dry casks? How many casks will be required to safely store all the high burnup fuel that is on site in both the spent fuel pools and dry casks at San Onofre? How much high burn up fuel is on site in fuel pools and dry cask at San Onofre?

d. We know that MOX fuel was used in Unit 1 and removed from San Onofre to the GE Morris facility in Illinois. How and when was that done and under what permit was that done? If MOX fuel was transported away, can other high burnup fuel be moved from the site in the same way to the same place?
http://www.uxc.com/products/pdf/STF164.pdf
http://web.ornl.gov/~webworks/cpr/rpt/106763_.pdf
3. Will the NRC allow the resale of non-radioactive equipment and secondary side components (e.g., the Turbines, MSR’S, heat exchangers, condensers, intake pumps, intake piping, outfall piping, all associated piping and electrical components? Since some of these
are almost new (Turbines $90 million, Canister $50 million, Heat Exchangers $20 Million) will they be sold and where will the proceeds go?
4. We would like to know if there can be public announcements when any “allowable” toxic waste is to be released into the environment. We would also like to know, in general and
relative terms that everyone can understand, what the upper limits are for releasing radiation and toxic chemicals into the environment during the decommissioning process. When were those limits established and what would trigger a process to reevaluate those limits?
5. The NRC has not approved a transport dry storage cask nor even short-term dry cask
storage (over 20 years) for high burnup fuel. Will the NRC continue to allow high burnup fuel use even though they do NOT have an approved safe solution to store or transport this waste — even short-term? References: Dr. Robert E. Einziger’s 3/13/13 conference session on Storage and Transportation of High Burnup Fuel where he states the NRC has “insufficient data to support a licensing position” to extend high burnup dry cask storage over the initial 20 years currently approved. See his presentation (slide 7) on Status of NRC Research on High Burnup Fuel Issues, Regulatory Information Conference session on Storage and transportation of High Burnup Fuel.
http://www.nrc.gov/public-involve/conference-symposia/ric/past/2013/docs/abstracts/einziger-rev-2-onsite-w24-hv.pdf
Hear Dr. Einziger’s audio of the March 13, 2013 conference session on Storage and Transportation of High Burnup Fuel. Dr. Einziger’s presentation starts at 39:50 minutes. http://www.nrc.gov/public-involve/conference symposia/ric/past/2013/docs/audio/w24.mp3
High burnup fuel is more difficult to store and transport. In addition, there is no transport cask design approved to store high burnup fuel. See GAO-12-797 August 2012 SPENT NUCLEAR FUEL: Accumulating Quantities at Commercial Reactors Present Storage and Other Challenges http://ml12046a013.pdf/ . Other source documents at http://sanonofresafety.org/nuclear-waste/ The NRC currently licenses dry cask storage for high burnup for only 20 years.

Current expiration date 2/5/2023. See
http://pbadupws.nrc.gov/docs/ML0515/ML051520016.html and
http://pbadupws.nrc.gov/docs/ML0515/ML051520118.pdf
http://pbadupws.nrc.gov/docs/ML0515/ML051520118.pdf
6. What are the reasons San Onofre has the highest percentage of damaged fuel assemblies? How many of these are high burnup? What is the impact of this to decommissioning in terms of safety, timeline and cost?
7. What is the status of Southern California Edison’s request to the NRC for approval to upgrade from 24 fuel assembly casks to the NUHOMS® 32PTH2 [32 fuel assembly] dry cask system, with an estimated install date of September 2014? The higher number of fuel assemblies brings higher risk of radiation releases, especially for high burnup fuel. High burnup fuel is hotter and more radioactive and therefore takes more space within a store.
Since it’s safer to reduce the number of assemblies, rather than increasing the number of assemblies, why does the NRC approve 32 assembly casks? Reference: SCE Request to replace Dry Cask Storage System to NUHOMS® 32PTH2, February 10, 2012
http://pbadupws.nrc.gov/docs/ML1204/ML12046A013.pdf
8. Is removing the spent fuel pool considered part of the decommissioning process? If so, how can dry casks be transported without use of a spent fuel pool in cases where that may
be needed? What vulnerabilities are there in San Onofre’s spent fuel pools? What improvements could be made to improve safety? Will any of them be made? If so, when? If not, why not?

We feel these questions should be answered in the NRC opening statement:
1. What level of on-site staffing will NRC provide during the decommissioning process, and in which areas of technical expertise and oversight?
2. How do the waste confidence hearings affect the probability and timing at San Onofre for shipment of nuclear waste to remote interim or permanent storage?

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About residentsorganizedforasafeenvironment

Vision for ROSE Working for the good of the Mother Earth. To provide a safe and clean planet for our children and grandchildren, and the seven generations to come. Working to support Ethically Sound Environmental decisions for the future. We hold the power of our vision in our own hands.
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