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“Historically, the Commission has chosen to generically address continued storage, and this approach was validated for appropriate circumstances by the D.C. Circuit Court of Appeals in the same decision that vacated and remanded the 2010 Waste Confidence Decision and rule,” said the NRC in the June 24 report. “Although the environmental impacts of spent nuclear fuel storage during the licensed life for operation may be site specific, the impacts of continued storage may be assessed generically because… changes in the environment around spent nuclear fuel storage facilities are sufficiently gradual and predictable to be addressed generically.”

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America’s weather and geology vary at its 100 nuclear reactor sites in 31 states, creating different dangers. These varied threats could affect spent fuel pools in diverse and potentially disastrous ways.

Diablo Canyon Power PlantThe San Onofre Nuclear Generating Station and the Diablo Canyon Power Plant 250 miles up the Southern California coast have earthquakes as the major environmental threat. Dozens of nuclear reactors and their spent fuel pools stretching across the tornado belt of the Midwest and the hurricane country of the South face entirely different sets of challenges.

Yet the Nuclear Regulatory Commission judges all plants the same to determine if their spent fuel pools could remain safe stuffed with rods for 60 to 100 years after decommissioning of the reactor. The power plants would be approaching 60 years old themselves when the clock would start ticking on 60 more years of storage. The NRC says that there is almost no chance of a SFP fire in the scenarios it envisioned with the rods left in the pools for 120 years or more.

NRC released the 584-page Waste Confidence Generic Environmental Impact Statement Draft Report for Comment (3.88 MB) in August by its Waste Confidence Directorate, Office of Nuclear Material Safety and Safeguards. A blizzard of information and numbers come to a fairly uniform conclusion: nothing bad will ever happen to SFPs so they can all be treated generically as the same.

The draft report calls 60 years of continued storage after reactor closure its “short-term timeframe.” And far from expediting the transfer of vulnerable rod assemblies in the SPFs to dry casks, the commission says it’s not even necessary; “[I]t is feasible to safely store spent nuclear fuel in spent fuel pools in the short-term timeframe and in dry casks during the short-term, long-term, and indefinite timeframes.”

It helps when nature cooperates which is an assumption buried in the report that disregards statistics and common sense entirely. “Changes in the environment around spent nuclear fuel storage facilities are sufficiently gradual and predictable to be addressed generically.”

The NRC’s report, which will take public comments until November 27, has caused considerable outrage in the environmental and nuclear watchdog community. That was evident at an August 22 meeting of the NRC discussing the issue where the nearly unanimous commenters advocated that the SPFs be emptied to at least a lower density.

“No spent fuel pool is protected by containment or is required to have independent redundant cooling,” said Washington D.C. attorney Diane Curran in her August 1 comments submitted to the NRC. Curran represents an environmental coalition of dozens of groups, including Beyond Nuclear, addressing the issue. “They were meant for short-term cooling (~5 years) and weren’t intended to for multi-decade storage of 4-5 times more spent fuel than their original designs. Pools are not only vulnerable to accidents – as witnessed by the Fukushima accident – but they are prime terrorist targets.”

Curran and others including Dr. Gordon Thompson pointed out that the staff who wrote the NRC report actually recommend against transferring hot rods out of the SFPs into dry cask storage. They also questioned the scientific integrity of a study that would only consider a complete drainage of a SFP versus a partial drainage, which is actually worse.

SONGS Sung BlueIndeed, if a spent fuel pool loses water enough to where the fuel assemblies are exposed to each other in air, they could catch alight with an unforgettable, and unstoppable, fire. The only hope of preventing that, short of successfully refilling the pool and keeping it that way, is to let it drain completely so at least air could circulate better cooling the exposed rods.

“[T]he Study ignores the impacts of aging and the potential for an attack on a pool and/or adjacent reactor to initiate a pool fire,” Curran commented. “Vulnerability of spent fuel storage pools to terrorist attack is perhaps the greatest risk of all.”

More scientific skullduggery came out this summer also courtesy of the Nuclear Regulatory Commission. A June 2013 NRC study about a Fukushima-style Mark I boiling water reactor at the Peach Bottom nuclear power station in Pennsylvania looked at that plant’s ability to prevent a huge earthquake from destroying one of its reactor’s spent fuel pools.

The 369-page study was called Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor (16.61 MB). The NRC used Peach Bottom as a “reference plant.” It is built on rock along the Susquehanna River in an area that has had a history over the last 50 years of having a peak horizontal acceleration eight times less than SONGS.

Sound science – and common sense – suggests that Peach Bottom and San Onofre can’t be generically lumped in together when it comes to earthquakes and spent fuel pools. The plants’ reactors and spent fuel pools are designed differently with SONGS situated on a dirt bluff in earthquake country. But no matter, as the report came up with conclusions that are alarmingly optimistic.

“This study shows the likelihood of a radiological release from the spent fuel after the analyzed severe earthquake at the reference plant to be about one time in 10 million years or lower,” the report says. “The Office of Nuclear Reactor Regulation’s regulatory analysis for this study indicates that expediting movement of spent fuel from the pool does not provide a substantial safety enhancement for the reference plant.”

Humans didn’t even begin to evolve on their own until five million years ago when we diverged from our last common lineage with chimpanzees. The NRC boldly states that one of the two SFPs at Peach Bottom Power Plant will last over 2,174 times as long as the 4,600 year old pyramids at Giza, Egypt. The figure would be laughable if it weren’t for the fact that the NRC is in charge of “regulating” America’s nuclear reactors and spent fuel pools and actually meant for the report to be taken seriously and save the nuclear industry millions of dollars because they wouldn’t have to do anything about their SFPs.

Dry casks diagrams - Nuclear Regulatory CommissionThe NRC dismissal of the danger of spent fuel rods in pools was in admitted response to a 2002 report that Robert Alvarez published. Alvarez was part of a 2002 Institute for Policy Studies in-depth study of how vulnerable to terrorists were America’s spent fuel pools. It was accepted for publication in the peer-reviewed Science and Global Security journal in January 2003. The study, Reducing the Hazards from Stored Spent Power-Reactor Fuel in the United States, (816 KB) revealed the breadth of the spent fuel rods nuclear waste problem.

“Because of the unavailability of off-site storage for spent power-reactor fuel, the NRC has allowed high-density storage of spent fuel in pools originally designed to hold much smaller inventories,” Alvarez wrote. “To reduce both the consequences and probability of a spent-fuel-pool fire, it is proposed that all spent fuel be transferred from wet to dry storage within five years of discharge. The cost of on-site dry-cask storage for an additional 35,000 tons of older spent fuel is estimated at $3.5–7 billion dollars or 0.03–0.06 cents per kilowatt-hour generated from that fuel.”

Alarmed by the Alvarez report, Congress prompted the National Academy of Sciences to investigate. NAS released its own report in 2006 called “Safety and Security of Commercial Spent Nuclear Fuel Storage.” The NAS, America’s most august scientific body, minced no words describing the dangers.

“A loss‐of‐pool‐coolant event resulting from damage or collapse of the pool could have severe consequences,” the NAS study said. “It is not prudent to dismiss nuclear plants, including spent fuel storage facilities as undesirable targets for terrorists…under some conditions, a terrorist attack that partially or completely drained a spent fuel pool could lead to a propagating zirconium cladding fire and release large quantities of radioactive materials to the environment…Such fires would create thermal plumes that could potentially transport radioactive aerosols hundreds of miles downwind under appropriate atmospheric conditions.”

Not surprisingly, the NRC didn’t agree with either Alvarez or the NAS. “The NRC concluded that the fundamental recommendation of the 2003 Alvarez paper, namely that all spent fuel more than 5 years old be placed in dry casks through an expedited 10-year program costing many billions of dollars, was not justified,” the draft study reads. “[T]he NRC disagreed with some of the conclusions from the National Academies study, including the finding that the NRC might determine that the earlier movement of spent fuel from pools to dry cask storage would be prudent, depending on the outcome of plant-specific vulnerability analysis.”

Plants are vulnerable to environmental disasters such as tornados, flooding, hurricanes and earthquakes depending on where they’re located. Peach Bottom Power Plant several miles from the Maryland border in Virginia lost 35 of its 97 emergency sirens when Hurricane Sandy roared up the Eastern Seaboard. They went out, ironically, when the plant’s power went down as they had no battery backup, according to the Lancaster New Era.

Due for a $10 million overhaul, the system is currently arrayed in a 10 mile radius of Peach Bottom in four counties in Pennsylvania and Maryland. Counter intuitively the sirens don’t signal an evacuation, rather for the public to just turn on the radio and listen to the emergency broadcasting system.

After all, there’s only a one in 10 million year chance of something going wrong with its reactor pools – pools stuffed with spent nuclear fuel rods packed in a high-density configuration and suspended four stories in the air like the destroyed reactors in Fukushima.

NEXT – PART TWO – San Onofre’s Risky Business

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13 Comments

  1. Please participate in this action to change the waste storage plan at San Onofre…
    http://conta.cc/1SePXmf

  2. Our nuclear waste at SONGS is being handled by liars and thieves. Read more here… http://conta.cc/1WFtEGI

  3. Southern California Edison issued a ‘white paper’ November 4 on its contention Mitsubishi left it, essentially, high and dry when it came to the defective generators that led to SONGS’ shutdown: http://assets.fiercemarkets.com/public/sites/energy/reports/1104songsWhitePaper.pdf

  4. EnviroReporter.com received this notice today from the Nuclear Regulatory Commission:

    No: 13-089 October 28, 2013
    CONTACT: Maureen Conley, 301-415-XXXX

    NRC Extends Public Comment Period for Proposed Rule and Environmental Study
    on Extended Storage of Spent Nuclear Fuel

    The Nuclear Regulatory Commission is extending by three weeks, until December 20, the deadline for public comments on a proposed rule and supporting environmental study on the effects of extended storage of spent nuclear fuel beyond the licensed operating life of commercial reactors.

    The NRC has also rescheduled the five public meetings on extended storage that were postponed due to the government shutdown and will hold an additional teleconference to receive public input on Dec. 9. The rescheduled meetings will be held Nov. 12 in Oak Brook, Ill.; Nov. 18 in Carlsbad, Calif.; Nov. 20 in San Luis Obispo, Calif.; Dec. 2 in Perrysburg, Ohio; and Dec. 4 in Minnetonka, Minn. Additional details about the meetings, including information on how to register, can be found on the NRC website. NRC staff will also host a public status update teleconference on Oct. 30. Details are on the website.

    The proposed rule was published in the Federal Register September 13 for public comment through Nov. 27. Known as “waste confidence,” the proposed rule would replace a similar provision in NRC’s environmental regulations that was vacated last year by the U.S. Court of Appeals for the District of Columbia Circuit. The rule does not authorize extended storage of spent fuel at reactor sites – a separate license is required for that. Rather, waste confidence is a generic finding of the environmental impacts of storing spent fuel for extended periods beyond the licensed operating life of reactors. The draft Waste Confidence Generic Environmental Impact Statement forms the regulatory basis for the proposed rule. The draft statement is available on the NRC’s waste confidence webpage.

    Public comments may be submitted several ways: Online through the federal government’s rulemaking website, http://www.regulations.gov using Docket ID NRC-2012-0246; by e-mail to Rulemaking.Comments@nrc.gov; by fax to 301-415-1101; by mail to Secretary, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001, ATTN: Rulemakings and Adjudications Staff; or by hand delivery to 11555 Rockville Pike, Rockville, Md., between 7:30 a.m. and 4:15 p.m. on federal workdays.

    Comments may also be provided orally or in writing at the public meetings, part of the agency’s extensive public outreach effort on the waste confidence project. All comments will be considered no matter how they are submitted.

  5. Bit of confusion there between National Research Council and Nuclear Regulatory Commission – they should sort it out with the TLA ( Three Letter Acronym ) Commission.
    As to whether a zirconium fire could happen, I’ve run across a lot of blogs assuring everyone that it had already happened. Haven’t seen any retractions yet. Zircalloy’s melting point is over 400 degrees Centigrade higher than the nichrome used in toaster heating elements. Fresh fuel is kept separate for the first few months, and after five years it can be dry casked, ie air cooled.
    Apparently China is planning spent fuel storage which will use it for industrial or space heating, which seems a more practical approach. There’s plenty of other things more worthy of being worried about.

  6. @John ONeill: The Hiroshima analogy is a unique way to justify nuclear power and in that context true. Unfortunately, it appears that your characterization of the zirconium cladding not burning isn’t in accord with a 2006 National Research Council of the National Academy of Sciences report called Safety and Security of Commercial Spent Nuclear Fuel Storage: Public Report:

    “The first two of these objectives could be compromised by a terrorist attack that partially or completely drains the spent fuel pool.2 The committee will refer to such scenarios as “loss-of-pool-coolant” events. Such events could have several deleterious consequences; Most immediately, ionizing radiation levels in the spent fuel building rise as the water level in the pool falls. Once the water level drops to within a few feet (a meter or so) of the tops of the fuel racks, elevated radiation fields could prevent direct access to the immediate areas around the lip of the spent fuel pool building by workers. This might hamper but would not necessarily prevent the application of mitigative measures, such as deployment of fire hoses to replenish the water in the pool.

    “The ability to remove decay heat from the spent fuel also would be reduced as the water level drops, especially when it drops below the tops of the fuel assemblies. This would cause temperatures in the fuel assemblies to rise, accelerating the oxidation of the zirconium alloy (zircaloy) cladding that encases the uranium oxide pellets. This oxidation reaction can occur in the presence of both air and steam and is strongly exothermic—that is, the reaction releases large quantities of heat, which can further raise cladding temperatures. The steam reaction also generates large quantities of hydrogen…”

    “These oxidation reactions can become locally self-sustaining (i.e., autocatalytic3) at high temperatures (i.e., about a factor of 10 higher than the boiling point of water) if a supply of oxygen and/or steam is available to sustain the reactions. (These reactions will not occur when the spent fuel is under water because heat removal prevents such high temperatures from being reached). The result could be a runaway oxidation reaction—referred to in this report as a zirconium cladding fire—that proceeds as a burn front (e.g., as seen in a forest fire or a fireworks sparkler) along the axis of the fuel rod toward the source of oxidant (i.e., air or steam). The heat released from such fires can be even greater than the decay heat produced in newly discharged spent fuel.

    “As fuel rod temperatures increase, the gas pressure inside the fuel rod increases and eventually can cause the cladding to balloon out and rupture. At higher temperatures (around 1800°C [approximately 3300°F]), zirconium cladding reacts with the uranium oxide fuel to form a complex molten phase containing zirconium-uranium oxide. Beginning with the cladding rupture, these events would result in the release of radioactive fission gases and some of the fuel’s radioactive material in the form of aerosols into the building that houses the spent fuel pool and possibly into the environment. If the heat from one burning assembly is not dissipated, the fire could spread to other spent fuel assemblies in the pool, producing a propagating zirconium cladding fire.

    It catches fire, alright. NRC’s conflicting reports on spent fuel pools safety are none too few. But when it comes to the zirconium cladding, here’s what it concluded in 2001:

    “… it was not feasible, without numerous constraints, to establish a generic decay heat level (and therefore a decay time) beyond which a zirconium fire is physically impossible.”

    Thanks for your comment, John.

  7. The difference between the Hiroshima bomb and spent nuclear fuel is that the bomb was built, with considerable difficulty , to explode; the fuel was designed to disperse heat.
    Nearly twenty thousand Russian warheads have been broken down into fuel and will, in due course, wind up in spent fuel pools in the United States, where they will pose far less risk to humanity than they used to.
    Inside a reactor pressure vessel, zirconium can react exothermicly with water if temperatures get high enough, but in a spent pool, the water is at atmospheric pressure. By the time temperatures have risen over 100 C, all the water will have evaporated, and until then steam will still be carrying heat away from the fuel. Solid zirconium will not burn, as it forms an impermeable oxide layer ( as does aluminium), and the melting point is 1855 Centigrade. Hence the NRC judgement that a spent fuel fire is ‘extremely unlikely.’

  8. @John ONeill

    From what I’ve read and from what Arnie Gundersen has stated is that the Spent Fuel Pool at Reactor 4 in Fukushima contains the equivalent of 1400 Hiroshima bombs.

    Now I don’t know if that’s enough to kill everyone in Japan and the northern hemisphere, but it certainly would make for a very bad day.
    (decades and/or centuries)

    NOT telling people of the long term and short term destructive potential and risks of NUCLEAR WASTE is what’s really harmful.

  9. @John ONeill: We would suggest reading the article again because we never said “spent fuel pools could kill everyone in Japan/ the northern hemisphere.” Especially pay attention to the parts describing the mechanics of a SFP fire and how hot it gets. Spoiler alert: it’s a lot hotter than a blowtorch and even the Nuclear Regulatory Commission knows – and has stated – how deadly it would be.

  10. What the hell kind of cretins would call the closing of a nucler reactor several years after it’s use by date “Premature” ? These reactors were designed to last 40 years and if anything the situation with San Onofre has confirmed this was about right.

  11. To be moved to dry storage, the heat output of spent fuel has to have dropped to the point where air cooling will prevent any damage to it. So if the pools drained, air cooling would continue – better than in a cask, where thick stainless steel walls impede convection.
    Another reason why the NRC assigns a very low probability to radiation release from the pools is the lack of flammability of the rods. Zirconium powder will burn – so will iron powder – but try setting fire to a slab of steel. You can google video of zirconium tube being blowtorched without melting or burning. The uranium oxide which makes up ninety eight percent of the ‘meat’ of the fuel rods won’t burn either – it’s an oxide, you might as well try to burn stone. Telling people that spent fuel pools could kill everyone in Japan/ the northern hemisphere is dishonest and harmful.
    Finally, crediting 300 megawatts of energy savings by customers with avoiding blackouts is a bit rich, when SONGS produced over 2,200 megawatts. As usual when a nuclear plant is shut down, most of the electricity deficit has been made up by burning gas or coal, CO2 emissions included.

  12. One chance in 10 million years for any kind of black swan event at any of 100 nuclear sites! I believe that assertion of extremely remote situational and temporal risk is ludicrous on its face. Are there any insurance companies willing to take this assertion at face value and issue a policy based on this conclusion by the NRC? I think not! They would laugh them right out of their offices! No! They would have them frog-marched out of their offices, and then they would laugh until they could not laugh any more. They would be weeping and shaking their heads in disbelief! I would love to see such a scene enacted for a Hollywood film. It would be an opening scene of the greatest disaster movie every made! “The End of Mankind”

    Bravo, Michael! This article drives home the point. People need to wake up and see the disaster that awaits them, if they do not act responsibly to protect themselves and their future generations. It’s simple, it’s too much risk, for far too long, in too many places.

  13. Michael,
    I am way beyond happy to see your new article about SONGS, as, based on the potential global disaster from removing the 1535 spent fuel rods from the Fukushima reactor #4, I have been very concerned and wondering about the plans for removal of the spent fuel rods from the two closed down reactors at SONGS.
    I know that we were all overjoyed to hear that SONGS was shut down, but that is certainly not the end of this scary nuclear drama, which will continue to go on for many years into the future. Your article clearly details this very frightening prospect, along with both the scientific and political factors involved in the ongoing dangers which will remain, far beyond our lifetimes.
    While Fukushima should have emphasized to our own Governmental nuclear authorities just how incredibly dangerous these spent fuel rods are, the EPA and the NRC, dishearteningly, seem to be just as devoted to downplaying the danger as is the Japanese government. Apparently it is always about MONEY….but it just never seems to be about human lives.
    As a long time Red Cross disaster volunteer, I have been keeping after the Red Cross about making plans for a possible nuclear disaster at SONGS, which could affect millions of people….and which would involve other agencies, such as the Police and Fire departments as well as FEMA.
    I plan to share your article with all of the above agencies,in order to let them know that the SONGS danger is NOT over, and will NOT be over for a great many years to come, and that disaster planning needs to be accomplished NOW!
    Thank you again Michael, for this vitally needed investigation and report, and I will be anxiously looking forward to reading #2.

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