Gary Headrick was unable to attend tonight's meeting due to an emergency eye surgery and asked me to take his place. I am glad to have this opportunity to participate in your panel discussion to consider the CEP's performance for the past three years and to give constructive criticism and make suggestions for where to go from here. I do this on behalf of San Clemente Green and others who share our justifiable concerns.
Looking back, it is important to remember that Edison had a terrible safety record and the worst work environment in the nation when they were still operating. An astonishing NRC survey found that 25% of SONGS employees feared retaliation for reporting safety concerns to management. Just imagine how many did not want to admit that in the survey.
This caused employees to reach out to San Clemente Green in 2010, but their explicit warnings were ignored by Edison and the NRC as well as our own city council who opted to "leave it to the experts". The predictions that a failed steam generator might leak radiation into the environment actually took place two years later.
We were fortunate that Unit 3 was shut down before the situation could escalate into a major disaster. For that we are deeply grateful to those heroic employees who managed to control that emergency situation as well as they did. We got lucky the same way those at Three Mile Island did years before.
See entire letter here
Edison and the NRC still choose to ignore recent warnings from someone working there now. This person claims that $80 M has changed hands in negotiations between dry cask makers, Holtec and Areva, for no apparent reason. But far more important is the fact that damaged fuel assemblies may have been loaded into dry casks without "canning" them first with an extra layer of protection, as required by the NRC. However, the Nuclear Regulatory Commission quickly dismissed this by responding, "In summary, the NRC has determined that the information does not describe an impropriety or inadequacy associated with NRC-regulated activities. Therefore, the NRC plans no further action regarding that information."
Our greatest fear is that we are on a path leading to a situation that has no way of escaping or protecting our property and loved ones from contamination. Adding to our anxiety is the realization that we can't rely on any of the organizations that are supposed to be looking out for our own well being. Dry cask containers may become untouchable as they begin leaking millions of curies just from the first of many microscopic cracks to come. An earthquake might drain an overcrowded spent fuel pool and spew out clouds of radiation in a zirconium fire that can't be extinguished by water. Terrorists might cause even worse damage if you can imagine that. And yet, the CEP is going along with a plan that even ordinary folks can see doesn't hold water, let alone radiation.
This is the questionable plan as it is being executed today...
The NRC has arbitrarily determined that temporary nuclear waste storage systems are now capable of handling this volatile material not just for twenty years, but sixty years, maybe one hundred years or more if that is what it takes to find a better place to take it. They have also approved dismantling the safety net protecting our communities simply because the plant is no longer operational. The onsite fire department specializing in nuclear facilities has been discharged. Spent fuel pools that offer the only remediation for reloading a damaged container will be destroyed after the last fuel assembly has been removed from the pools.
The Coastal Commission has "conditionally" approved burying nuclear waste one hundred feet from the rising ocean, allowing
a twenty year grace period to prove that it is actually safe to do so. They were somehow convinced that new technology would become available in the future, just like the promise that a permanent nuclear waste repository would be available long before now. And Edison has the perfect out if something does go terribly wrong. They can always turn around and blame the Department of Energy for not picking up the waste when they should have.
Edison has selected Holtec as the contractor, with the NRC's blessings, even after their CEO admitted that their containers can be expected to crack, but can't be repaired. He lied to the CEP and the public when he vehemently denied being fined and debarred for bribery charges. But Edison is still going with Holtec anyway, while the CEP remains silently compliant. Are these really the standards that we should be willing to accept when we are dealing with 89 times more radiation than was released in the Chernobyl accident?
Where has the CEP gone wrong?
To put it bluntly, you have been doing a lot of talking but not much listening to anyone else but Edison or their vendors and consultants. The big questions that are often ignored are; What if they are wrong again? What would the consequences be and how would they react in the worst case scenario? The plan that the CEP is going along with only works if Edison can predict the future accurately. The most recent proof of that not being the case is the failed steam generator replacement project which led to the shutdown. How can this body whose primary guiding principle is public safety even consider a plan that relies on technology that has yet to be invented, tested and proven?
While the CEP is not a decision making body, Edison likes to say that "the Community Engagement Panel and a number of community stakeholders have aligned to support their proposals ". That is because "engagement" has largely been a one way street and you don't seem to be listening to our legitimate concerns. There could be far better options that may not favor Edison's objectives, but need to be considered for the sake of ALL.
Our request is to allow independent, unbiased experts to critique Edison's plan by making presentations and taking questions from the panel and the community at large. There are some very well qualified professionals in this field who might think it is a bad idea to bury nuclear waste inches above the rising water table, one hundred feet from the waves, in an earthquake/tsunami zone using containers that are known to develop cracks in a marine environment. It is incumbent on all of us to keep this nuclear waste under the safest conditions possible for as long as it takes to be moved to a better location. We can and must do better than this, with so much at stake.
Potential candidates for independent experts
(you can email me other suggestions)
Representative from the Nuclear Waste Technical Review Board
Gregory Jaczko - Former head of the NRC during Fukushima accident
Peter Bradford - Former NRC Commissioner during the Three Mile Island crisis
Arnie Gunderson - Nuclear engineering consultant for the past 40 years
Daniel Hirsch - Director of Nuclear Policy Programs at UC Santa Cruz
Potential questions to be answered by independent experts
(you can email me other suggestions)
What does the worst case scenario look like if we reach "criticality" (an uncontrollable nuclear reaction), in pools, dry casks or in transportation?
Would it be possible to evacuate millions of people or shelter in place in the event of a nuclear accident?
Is there any reason that the purchased and approved Areva canisters could not have been used to relieve the dangerously overcrowded pools for the past three years?
Why wasn't it a priority for Edison to put nuclear waste into dry storage before decommissioning when it was possible to make us much safer all this time?
If existing thick cask storage containers are not suitable for San Onofre due to size and weight constraints, is it worth considering designing smaller ones that contain fewer fuel assemblies but can be monitored, repairable and transportable by conventional modes of transportation that might travel inconspicuously like the military does frequently?
Wouldn't the cost of doing everything necessary to prevent a nuclear disaster at San Onofre be reasonable when compared to the billions of dollars being spent at the Hanford site or the trillions of dollars Japan is having to spend in futile efforts to clean up Fukushima?
Would there be reparations for those of us who might lose everything?
