I have been pressing Tom Palmisano for answers to questions we posed for quite some time now. I just got a response from him which is not surprisingly inadequate. I'm sharing this with you to get your feedback directly so that I can organize a response to Tom that covers all of these concerns. I will identify who each of the comments are coming from in a consolidated response rather than several individual emails. Please don't contact him (or others) directly so we can keep this thread better organised. I'll continue to copy you on this conversation as it grows. Hopefully other independent experts we trust will weigh in also.
Forwarded message ----------
From: Tom Palmisano
Date: Wed, Jun 28, 2017 at 8:16 PM
Subject: Re: (External):Follow up on discussions
To: Gary Headrick < email@example.com
Cc: "Driscoll, Neal" < firstname.lastname@example.org
>, "David G. Victor" < email@example.com
>, "Dan Stetson (NE)" < firstname.lastname@example.org
>, Manuel Camargo < Manuel.Camargo@sce.com
I apologize for the delay in responding to your email.
First, let me reiterate our invitation to host you on site for a tour and discussions. Your questions in the email warrant a more detailed discussion rather than a short response in an email. I’ll provide some responses below, however, I urge you to come to the site for a tour and discussion. Please look at your calendar for some time later in July or August when we can accommodate you.
Some specific responses to your comments:
Comment from your email: The matter of understanding the reliability of welded canisters cannot be overstated. This is not about the other study examining condition of the fuel from bolted casks, but the condition of the unwelded canister itself. This is critical to our understanding just how much time we may have left before there may be a leaking canister in our midst. It's not long, if Donna Gilmore's research is accurate. Why must this take so long to get preliminary results? We don't have years to find out, because by then, it may be too late.
Response: I appreciate your concern and Donna’s viewpoints. The material shared previously is related to an EPRI and NRC study about how high burnup fuel will potentially be affected while in a dry storage canister. This is important confirmatory research, however, as you recognize this is not about the canister performance it is about the fuel rod performance. The industry and the NRC has high confidence in canister performance during the currently licensed periods. The NRC also has requirements which must be met during subsequent licensing periods for the canisters to monitor their performance. The NRC refers to these as “Aging Management Plans” for renewing the license for the canisters beyond the initial 20 year license. We have commissioned a study by MPR associates to summarize the current experience with dry fuel storage canisters and the related aging issues. We expect to discuss this at the 3rd
quarter CEP meeting. I think this will provide some answers on expected canister reliability. We will also be discussing our current work to develop the inspection capability for the canisters in that CEP meeting.
The following is some information on the current and future canister system for SONGS:
There are a number of intervals the address the life span of spent fuel canisters at SONGS, as follows:
- Service life: 100 years
- Design Life: 60 years
- Warranty: NUHOMS 10 years, UMAX 30 years
- NRC license renewal: intial license is for 20 years; license renewal is in 20 or 40 year increments.
Service Life is based on nominal expected environmental conditions and represents a best estimate of canister life time including any planned maintenance. Design Life is based on the canister being exposed to the assumed worst case environmental conditions and represents the shortest expected canister life time. NRC license renewal period is typically 20 years for most dry used fuel storage systems (when licenses are renewed after the first 20 years, the NRC typically reviews site specific inspection results to provide added assurance that the dry used fuel storage equipment is operating as expected).
Comment from your email: At the last CEP meeting, you stated that we don't need to be concerned about criticality events because they have been eliminated by design, or something to that effect. Could you please clarify and indicate if there are any provisions on site to deal with a criticality event?
Response: First, let me elaborate on how we prevent an inadvertent criticality event in the spent fuel pool or the dry cask canisters.
In SONGS Units 2/3 spent fuel pools, criticality is prevented by maintaining physical separation of fuel assemblies with the spent fuel racks, utilizing administrative control of fuel placement within the spent fuel racks, and ensuring sufficient soluble neutron absorbers in the cooling water. The racks were also built with neutron absorbing material in the rack structure. Spent fuel parameters are continuously monitored. Since the spent fuel is in the fuel subject to the controls described, and we are not adding additional fuel to the pools, there is no plausible way for a criticality event to occur.
In SONGS Dry Cask Storage Systems, criticality is similarly prevented by maintaining physical separation within the DSC fuel storage basket that utilizes neutron absorbing materials between the cells, utilizing detailed storage loading patterns, and ensuring sufficient soluble neutron absorbers are in the cooling water as the DSC is loaded with spent fuel in the spent fuel pool. DSC critical parameters (temperature) are also continuously monitored. By following these precautions, there is no plausible way for a criticality event to occur.
These types of controls and design features have been used at SONGS and other commercial nuclear plants for years and are proven techniques.
If one were to postulate a hypothetical “what if” question about if an inadvertent criticality would occur, we would detect it by rising radiation levels and we would add soluble neutron poison to the water in the spent fuel pool or dry storage canister to top the reaction. I emphasize this is a very hypothetical question for an event which is not plausible given the design features and controls I described.
I’d be happy to discuss this in more detail when you visit the site.
Comment from your email: I've made what seemed to be a reasonable request from Neal Driscoll about vertical and horizontal movement at SONGS in both a 7.0 quake and a 7.4. He indicated that this information was not readily available, but would ask you about getting that for me. I'm surprised there is nothing you can provide immediately, since Edison has determined that the spent fuel pools would survive a 7.4 quake. Please send any technical documents to support that claim and also authorize Neal to provide me with the specific information I requested. Hopefully there is an animation that could be generated by the updated 3d model. If not, I can generate my own if I just know how much the site could move in any direction and duration for these two scenarios
Response: We’ve discussed the seismic design criteria for SONGS several times in CEP meetings. Your request of Neal Driscoll to provide information on the vertical and horizontal movement at SONGS is not part of his scope of work and I’m not going to authorize him to perform work outside of his scope. I am attaching some NRC documents related to the original seismic design bases for SONGS 2&3 and links to some later NRC information. As we have discussed at CEP meetings, the seismic response of the site structures is analyzed in terms of peak ground acceleration. That acceleration is then used to analyze the response of the various buildings to ensure they meet their design criteria. It is not as simple as saying the building moves “x” amount in the horizontal direction and “y” amount in the vertical direction. This needs to be a more detailed discussion than a simple email response and I would be glad to have our engineers provide briefing during a site visit to explain how the site response to a seismic event is analyzed
Please see the following references for your information:
Included here are three sets of publicly available materials that document the seismic design basis for the San Onofre site, including the spent fuel pools that remain in operation today. These are:
- iii. U. S. Nuclear Regulatory Commission, Safety Evaluation Report (Geology and Seismology) related to the operation of San Onofre Nuclear Generating Station, Units 2 and 3, dated December 1980. See attached cover letter and report. This is publically available material, although we haven’t found a direct online link to the pdf file. It can be ordered through the NRC for a nominal fee but the material is provided here for your convenience. This material establishes the original design basis for San Onofre as a magnitude 7.0 earthquake on the Newport-Inglewood/Rose Canyon (NI-RC) fault. The NRC Safety Evaluation Report includes reference in Section 220.127.116.11 that the staff approved the design basis of 0.67g for San Onofre as being “appropriately conservative.”
- iv. SCE Response to the Request for Information, SONGS 2&3 – Seismic Design Basis Assessment, dated September 24, 2002 (NRC letter Response, https://www.nrc.gov/docs/ML0225/ML022540100.pdf), (Report, https://www.nrc.gov/docs/ML0201/ML020100338.html). This second set of material was developed in response to the postulated Oceanside Blind Thrust Fault (OBT) that was raised as an issue during the California Coastal Commission hearing for the first ISFSI construction at San Onofre. The report evaluated the purported OBT (including the possibility of a magnitude 7.5 earthquake along the fault) using a hazard/probabilistic methodology. The NRC concluded in a letter to Patricia Borchmann dated September 27, 2002, that “the NRC staff concurs with SCE’s assessment that the postulated blind thrust faults do not appreciably change the seismic risk at SONGS.” Recall that the more recent research by the Scripps Institution of Oceanography found that the OBT does not exist, but rather the subject faults are strike-slip in nature.
- v. GeoPentech, 2010 Probabilistic Seismic Hazard Analysis Report, dated December 2010 (Report, http://www.energy.ca.gov/ab1632/documents/status-reports/SCE/SCE_Evaluation_of_AB1632_Report_Recommendations-appendices.pdf). This third set of reference material captures seismic research performed in 2010. This research postulated a magnitude 7.5 earthquake along the NI-RC fault. Peak ground acceleration is provided, but is only related to annual frequency of exceedence.
> on behalf of Gary Headrick <email@example.com
Thursday, June 15, 2017 at 5:31 PM To:
Tom Palmisano <Tom.Palmisano@sce.com
"Driscoll, Neal" <firstname.lastname@example.org
>, David Victor <email@example.com
>, "Dan Stetson (NE)" <firstname.lastname@example.org
>, Manuel Camargo <Manuel.Camargo@sce.com
(External):Follow up on discussions
I want to speak to you directly about some unfinished business in the hopes of keeping things moving before the next CEP meeting. I don't expect you will be answering all of the questions we submitted back on 2/16/17, but there are these few most important ones that do need to be responded to in writing, since time at meetings is not nearly sufficient.
On March 25, David Victor said in an email to me, "The unweld cask effort is an ongoing research project—what I have is a summary of where they stand, not final results which are years down the road. There is a group of emails that Manuel has on hand for the CEP and one in that pile concerns this matter. When they go to the CEP I will send to you."
The matter of understanding the reliability of welded canisters cannot be overstated. This is not about the other study examining condition of the fuel from bolted casks, but the condition of the unwelded canister itself. This is critical to our understanding just how much time we may have left before there may be a leaking canister in our midst. It's not long, if Donna Gilmore's research is accurate. Why must this take so long to get preliminary results? We don't have years to find out, because by then, it may be too late.
At the last CEP meeting, you stated that we don't need to be concerned about criticality events because they have been eliminated by design, or something to that effect. Could you please clarify and indicate if there are any provisions on site to deal with a criticality event?
I've made what seemed to be a reasonable request from Neal Driscoll about vertical and horizontal movement at SONGS in both a 7.0 quake and a 7.4. He indicated that this information was not readily available, but would ask you about getting that for me. I'm surprised there is nothing you can provide immediately, since Edison has determined that the spent fuel pools would survive a 7.4 quake. Please send any technical documents to support that claim and also authorize Neal to provide me with the specific information I requested. Hopefully there is an animation that could be generated by the updated 3d model. If not, I can generate my own if I just know how much the site could move in any direction and duration for these two scenarios.
Finally, I do appreciate the many invitations I've had to tour the facility and I intend to do that when my schedule allows. It looks like that will be a few weeks from now.
I've attached our original list of questions in case you can address them also, except for the ones that Neal has answered already.
Tom gave you a bunch of double talk. And it's not "my" research or "my view". It's NRC's research and documents that I am sharing.
Regarding the EPRI study, I think he's referring to the EPRI high burnup Demonstration Project. That uses a thick cask, since they cannot open thin canisters without destroying the canister. David Victor probably misspoke if he used the word "canister" instead of cask. Unless you get the number or name of the study we'll never get that straightened out.
What's more important is we don't need that study. The NWTRB said that study won't prove anything and is a waste of money. And there is already actual data in a 2012 NWTRB report describing a study that used actual high burnup fuel. It showed hydride and oxide levels increase dramatically on the cladding starting around 35 GWd/MTU. Remember this chart below you modified to show San Onofre fuel burnup range in yellow?
At the 2016 NRC Nuclear Waste Conference the nuke industry claimed they have no actual data with high burnup fuel from reactors and that's why they need the EPRI demonstration project. When I stated this is not true and referenced the high burnup study discussed in a NWTRB report, it was so quiet you could hear a pin drop. They don't want people to know. They want to continue produce high burnup fuel, in spite of the dangers.
Call me if you want to discuss the rest.