Letter Writing Campaign to Coastal Commission Chair

Citizens Oversight (2017-05-23) Ray Lutz

This Page: https://copswiki.org/Common/M1768
More Info: Stop Nuke Dump

Use the following as a template for your file to stay on message, but also feel free to CUSTOMIZE to your own experience! Best not to have identical letters from everyone.

Send to staff member in charge of the project and he will send to commission accordingly. His name is Joseph Street and you can email him at Joseph.Street@coastal.ca.gov

Dayna Bochco
Chairperson
California Coastal Commission
45 Freemont Street #2000
San Francisco, Ca 94105

Email to: c/o Joseph.Street@coastal.ca.gov

Re: San Onofre Decommissioning

Greetings: We are writing to ask you to change your approach in issuing a Coastal Permit to Southern California Edison (SCE) for the decommissioning of the San Onofre nuclear power plant, including the October 2015 permit for the new Independent Spent Fuel Storage Installation (ISFSI).

You were raised in San Diego. You are an attorney. However, your analysis of the ISFSI permit showed no regard for your city and was void of any lawyer like analysis. Contrary to Commission group-think the Commission's hands were not tied. Further planting 3,600,000 lbs of spent nuclear fuel on the edge of the beach in a new ISFSI was a gross violation of the Coastal Act on its face.

The Commission evaluation of the ISFSI project was flawed and deficient. You did not employ an independent expert to advise the Commission on whether there were other spent fuel storage sites. You did not use an expert to determine the feasibility of a relocation transportation plan. You did not retain an expert to determine how long the spent fuel could be safely stored in the pools.

You did not do adequate legal research. If you had, you would have learned the Commission had broad jurisdiction to deny the permit e.g. on “cost grounds.” See Pac. Gas & Elec. Co. v. State Energy Res. Conservation & Dev. Comm'n, (U.S. 1983) 461 U.S. 190. Did you even read this case?

You did not ask the staff if it used an expert to see if there were other storage sites. You did not ask if the staff used an expert to development a relocation transportation plan. You did not ask the staff for a clear legal analysis of the scope of the Commission’s jurisdiction. You went on SCE guided tour and finished up as follows: what it did to determine if there were other sites

MS. BOCHCO: Okay. Um, all right. Well, I think that's all my questions. Well, thank you very much. [R.T. 81-86]

When you came to San Diego on 10 May 2017, interested parties attempted to engage you in a constructive conversation about these issues. After you arbitrarily limited public discussion of San Onofre decommissioning to 8 minutes you then ignored the speakers you allowed to speak.

We demand the Coastal Commission open up to public scrutiny and public involvement the process the Commission is now using to consider the permits needed to decommission the San Onofre nuclear power plant.

Thank You,

Some Actual Letters Written

Henry Hawthorn -- mechanical engineer with 42 years of design and management experience

Please acknowledge receipt and forward to Chairperson Bocho

Ms. Dayna Bochco
Chairperson
California Coastal Commission
45 Freemont Street #2000
San Francisco, CA 94105

Emailed c/o Joseph.Street@coastal.ca.gov

Re: San Onofre Decommissioning and Waste Storage

Dear Ms. Bochco,

Out of grave concern, I am writing to ask you to change your approach in issuing a Coastal Permit to Southern California Edison (SCE) for the decommissioning of the San Onofre nuclear power plant, including the October 2015 permit for the new Independent Spent Fuel Storage Installation (ISFSI). The analysis of the ISFSI permit shows no regard for Southern California beaches, the ocean and the 8.4 million people that will be affected when, not if, an accident occurs. Storing 3.6 million pounds of spent, highly radioactive, nuclear fuel 100 feet from the ocean is irresponsible and not at all in keeping with what the California Coastal Commission is supposed to stand for.

The Commission’s evaluation of the ISFSI project is flawed and deficient.

You did not employ an independent expert to advise the Commission on whether there were other spent fuel storage sites. You did not ask staff if they had an expert advise them on alternate sites. You did not use an expert to determine the feasibility of a relocation transportation plan. You did not ask if the staff used an expert to develop a relocation transportation plan. You did not retain an expert to determine how long the spent fuel could be safely stored in the pools. Your failure to take these actions resulted in a storage plan with the following deadly problems and design flaws:

1. Waste that will remain deadly for more than 250,000 years
2. Waste that may never be moved
3. Storage canisters that are too big, too hot and too thin to transport safely
4. No requirements for inspections for almost 20 years
5. Currently no technology is available for inspection
6. Site will be under water at some point in time as seas rise due to climate change
7. High tide and storm surge ocean conditions will flood the site
8. The site is in a tsunami inundation zone
9. The Newport-Inglewood/Rose Canyon earthquake fault is just a few kilometers offshore
10. The site is a ready-made dirty bomb. Terrorists can too easily launch a conventional weapon in to the site from the freeway or ocean

I express these concerns as a mechanical engineer with 42 years of design and management experience. From the successes and failures I have witnessed, three principles have proven to be consistently true. All three apply to every design including those for the storage of nuclear waste.

1. Theoretical designs never exactly match real world experience
2. Design safety factors that are based on estimates and assumptions without real world experience and data and are too often, and likely, flawed
3. Avoid overconfidence in your own design rationale

No design is without risk and the risk must be assessed with what a failure could lead to. If you design a consumer product and it fails to function in the field a person could be injured or the manufacturer could suffer a financial loss. If you design an aircraft component and it fails in flight you could cause the death of hundreds of people. If your design for nuclear waste storage is flawed, if the safety factor assumptions made in the absence of actual experience and data are wrong, and the storage system fails in a location that can harm 8.4 million people and contaminate the ocean the disaster is of inconceivable horror and magnitude.

Do not leave the San Onofre nuclear waste in the hands of those who ran the reactor that, based on complaints to the NRC, had the worst safety record of any reactor in the country. If that is not proof enough of their ineptitude, a press release today reports that there has been a Severity Level IV violation of NRC requirements related to the licensee’s failure to follow a procedure requirement to test the density of the important-to-safety (ITS) grout that was placed under the cavity enclosure containers. There are no doubt other undiscovered design errors, failures to properly test and workmanship flaws. All of this is assurance of a disaster.

Mitigate the danger of a failure by getting the nuclear waste off the beach and in to a lower risk, properly operated, storage location as soon as it can safely be moved. One such site, partially owned by SCE, is the Palo Verde reactor site in the Arizona desert.

Finally, too much of what has transpired so far has been done in what may be illegal secret meetings with no public input. I demand the Coastal Commission provide for public involvement the process the Commission is now using to consider the permits needed to decommission the San Onofre nuclear power plant and storage of spent waste.

Thank You,

Henry Hawthorn

David Haze -- 40+ year resident of San Clemente, California

My name is David Haycraft and I am a 40+ year resident of San Clemente, California. I have now attended several meetings on the topic of decommissioning the San Onofre Nuclear Power Plant (SONGS), and the existing plan to move forward with a “dry caste storage’ plan for the spent nuclear waste (Independent Spent Fuel Storage Installation (ISFSI).

Like many others in the process of “awakening” to this unacceptable plan, I find it absolutely ludicrous that your agency has issued this permit for the ISFSI back in 2015. The information I have seen shows that the California Coastal Commission’s evaluation of the ISFSI project was flawed and deficient. You did not employ an independent expert to advise the Commission on whether there were other spent fuel storage sites. You did not use an expert to determine the feasibility of a relocation transportation plan. You did not retain an expert to determine how long the spent fuel could be safely stored in the pools, and you did not do adequate legal research on the matter.

I can only speak for myself, but the underlying (key word: lying) feeling I get from the granting of this permit is that huge amounts of money, power, and influence have been afforded to the members of the CCC, to allow for this to happen at all. I have seen several examples of how difficult it has been for the public, commercial, and even governmental agencies to get permits for projects that have far less environmental impact than burying 3,600,000 lbs of spent nuclear fuel on the edge of the ocean. This in itself tells me that something is awry at the CCC, and the Commission itself has most likely been corrupted.

My understanding is that the most important thing that can be done in your power is to revoke the existing permit for the ISFSI, and not grant any additional permits to Southern California Edison, until the public is comfortable with a plan for the decommissioning of the plant, and the transfer of the spent fuel elsewhere.

It is my privilege and right as a citizen of this community to demand that the CCC REVOKE THIS PERMIT and NOT GRANT ANY ADDITIONAL PERMITS.

Comments

• Support_Letter_to_CCC_Chair_Bochco.docx: WORD version of the proposed starter letter