Halting Holtec – A Challenge for Nuclear Safety Advocates

“The age of nuclear energy is coming to an end. The age of radioactive waste is just beginning.”  Gordon EdwardsCanadian Coalition for Nuclear Responsibility

Once again, the Nuclear Regulatory Commission’s ever-compliant rubber stamp has come down with a hollow thud in favor of the industry it purportedly regulates.  The NRC announced May 21 that it “has determined that fuel loading can be safely resumed at the San Onofre Nuclear Generating Station.“

The transfer of of 3.6 million pounds of highly radioactive spent nuclear (SNF) fuel had been halted since last August at the San Onofre independent spent fuel storage installation (ISFSI), operated by Southern California Edison and designed by Holtec International. 

Today’s NRC announcement came as no surprise to many observers who have been suspecting for weeks that the regulator and its two supposed regulatees – Edison and Holtec – had been going through the motions of regulatory rigor while working to come up with a rationalization for the forgone conclusion that the project would eventually be given the go-ahead.

Last month, the Nuclear Regulatory Commission (NRC), in an unprecedented move, fined Southern California Edison $116,000 for failing to report the near drop of an 54 ton canister of radioactive waste. A ‘slap-on-the-wrist,’ given Edison’s millions in profits, the penalty did not reference the discovery that an ill-designed Holtec canister loading system has been discovered to damage the canisters and make them more subject to speedy degradation. At the time the NRC did not green-light further loading operations until serious questions raised by the incident had been resolved.  Apparently they have been, but no details are yet available.

Critics have long been pointing out that locating a dump for tons of waste, lethal for millions of years, in a densely populated area, adjacent to I-5 and the LA-to-San Diego rail corridor, just above a popular surfing beach, in an earthquake and tsunami zone, inches above the water table, and yards from the rising sea doesn’t seem to make a lot of sense from a public safety standpoint.

The near drop incident last August, revealed by a whistleblower, has drawn further attention to the many defects in the Holtec-designed and manufactured facility.  It has been discovered that the stainless steel canisters, only five-eighths inches thick, are being gouged as they are lowered into the site’s concrete silos.  Southern California Edison admitted to the NRC the damage runs the entire length of the canister walls. Experts have warned that the  gouging makes the thin-walled canisters even more susceptible to corrosion-induced cracking in the salty sea air, risking release of their deadly contents into the environment and even of hydrogen explosions.

Furthermore, critics point out, these thin-walled canisters are welded shut and cannot be inspected, maintained, monitored or repaired, as NRC regulations require.

Systems analyst Donna Gilmore is the founder of SanOnofreSafety.org, and a leading critic of the Holtec system.  She explains her concerns this way in a recent email:

“The root cause of the canister wall damage is the lack of a precision downloading system for the canisters. Holtec’s NRC license requires no contact between the canister and the interior of the holes. The NRC admits Holtec is out of compliance with their license, but refuses to cite Holtec for this violation.

“NRC staff said the scraping of the stainless steel thin canister walls against a protruding carbon steel canister guide ring also deposits carbon on the canisters, creating galvanic corrosion. The above ground Holtec system has long vertical carbon steel canister guide channels, creating similar problems.

“Once canisters are scraped or corroded they start cracking. The NRC said once a crack starts it can grow through the wall in 16 years. In hotter canisters, crack growth rate can double for every 10 degree increase in temperature.

“Each canister holds roughly the radioactivity of a Chernobyl nuclear disaster, so this is a critical issue people need to know about. Unless these thin-wall canisters (only 1/2″ to 5/8″ thick) are replaced with thick-wall bolted lid metal casks – the standard in most of the world except the U.S. – none of us are safe. Thick-wall casks are 10″ to 19.75” thick. Thick-wall casks survived the 2011 Fukushima 9.0 earthquake and tsunami.

“U.S. companies choose thin canisters due to short-term cost savings. These thin-wall pressure vessels can explode, yet have no pressure monitoring or pressure relief valves. The NRC gives many exemptions to ASME N3 Nuclear Pressure Vessel standards (a scandal in and of itself).

“The Nuclear Waste Technical Review Board December 2017 report to Congress raises concerns of hydrogen gas explosions in these canisters. The residual water in the canisters becomes radiated and results in buildup of hydrogen gas.

“The gouged canister walls reduces the maximum pressure rating of these thin canisters, creating the perfect storm for a disaster. Ironically, Holtec calls their system “HI-STORM”.

“How many ‘Chernobyl disaster can’ explosions can we afford?” Gilmore asks. “There are almost 3000 thin-wall canisters in the U.S. Yet the NRC has no current plan in place to prevent or stop major radioactive releases or explosions.”

Wet or Dry, Risks Abound

After the narrowly averted planetary disaster of a fire in the spent fuel pool at Fukushima Daiichi’s #4 reactor, concerns rose about the fuel ‘stranded’ in over-packed pools in the US.

Increased over-packing of fuel assemblies in cooling pools, their dependence on off-site power sources, plus increasing the vulnerability of the grid to extreme weather events and resulting fire risks in the pools are serious concerns.

Since the use of ‘high burn-up fuel’ by utilities for over a decade, fuel has remained in the reactor cores longer, resulting in far higher thermal temperatures and intensified radioactivity when the rods come out. 

NRC staff has therefore recommended giving the fuel longer time to cool in the pools before transfer to dry casks, and longer cooling time in the dry casks before transport.

Accelerated fuel transfer and transport ignores such recommendations.  But NRC higher-ups appear to have a pattern of disregarding the recommendations of their expert staff people in favor of political power considerations.

Nuclear safety advocates themselves are divided on the issue of the speed with which the radioactive fuel rod bundles can be safely transferred from cooling pools into dry casks. The pools are filled with constantly circulating borated water, which dissipates the high heat and moderates the radioactivity as the isotopes in the fuel rods decay.

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Cooling pools have several levels of redundant, fail-safe systems all of which must fail simultaneously, and for some period of time, in order for water to boil or drain away, and the uncovered fuel to ignite in contact with oxygen. This is called ‘defense in depth.’

Currently, most U.S. pools are packed with spent fuel bundles well beyond their designed capacities. Those in the Get-It-Out-Of-The-Pools-Fast camp point to the pools’ dependence either on outside electrical power, or on diesel-powered back-up generators, their vulnerability to sabotage or terrorist attack, and the fact that the pools, unlike the reactor itself, are not within a containment structure.

The Let-It-Cool-Longer advocates point out that the thermally hotter and more radioactive the fuel bundles are when transferred from pool to dry cask, the more impact they have on the integrity of the containers into which they’re loaded – in this case, 5-eights inch Holtec ‘Hi-Storm’ stainless steel canisters which are purged of water, welded shut and back-filled with pressurized helium.

The incentive for utilities and decommissioning contractors to empty the pools ASAP is that the pools can then be demolished, which in turn triggers the release of the millions-to-billions of dollars worth of Decommissioning Trust Funds. These have been accumulating over the operating life of the plants from monthly payments from utility customers. Demolition of the pools also triggers reduction of expenses for first-responders, security personnel, and evacuation provisions.

Who Gets the Decommissioning Funds?

Former NRC Chair Gregory Jaczko described the current situation this way in a recent May 13 Congressional Briefing:

“Given the fact that you have these large decommissioning funds,” he said, “and given the fact that you have communities very interested in earlier decommissioning, what’s happening now is you have companies that are coming in and offering to buy the reactors from the plant operators in order to decommission them. And the idea behind that is they know there is this very large fund and, if they can decommission for less than what is in that fund, then essentially they can make a very nice profit.”

“However,” Jaczko went on to explain, “there are some challenges with that.”

One is, he said, “can the cleanup actually be done for less money than exists in these decommissioning finds?” While he believes existing funds can cover the actual cleanup costs, he is “not sure they are sufficient to cover the cost of the cleanup and the very nice leftover benefit for the company that does the decommissioning.”

Another of his concerns is that the companies offering cleanup services “are not necessarily large electric power companies that are very well capitalized companies that have a lot of resources.”

The finals issue – which Jaczko notes often gets forgotten – “is that these funds which were originally set aside by the ratepayers… the people who bought electricity. They weren’t set aside by the companies themselves. They were charged the ratepayers for this money. Originally those funds, if there was any left over at decommissioning, were intended to they go back to the people who paid that money… the ratepayers.”

“So, Jaczko concluded, “there is a real policy question that people need to think about as we go forward.”


Questioning Holtec

Back at San Onofre,  Keep-the-Pool-and-Cool-Longer advocates are arguing that Holtec’s dry storage system does not match the defense-in-depth protection of pools, or even of the thick-wall cask systems used elsewhere in the world. They point out that if a canister is damaged, the only way the fuel can be re-packaged is either in a pool or in a so-called ‘hot cell’ or ‘dry cell,’ which is a secure building in which the radioactive materials are remotely handled robotically.

The only US hot cell large enough to do this would have been the Idaho Test Area North (TAN) Hot Cell facility, which was destroyed in 2007. No hot cells are planned and no funding is currently allocated for hot cells.

Some advocate moving the ISFSI further inland, out of the immediate earthquake and tsunami zone into a so-called ‘hardened on-site storage (HOSS)’ structure, surrounded by the sprawling Camp Pendleton Marine Base. Still, there are those who point out that, unless the thin Holtec canister are replaced by thick-walled casks, the fuel might not even be able to be safely moved even that far.

Pool, or No Pool? That is the Question.

If the pools are prematurely destroyed, and there is no hot cell, there is no way to deal with a damaged canister or damaged fuel. 

Holtec’s CEO Kris Singh has long-ago admitted that there is no way to repair a damaged canister.  Keep-the-Pools advocates assert that, without pools or robotically operated ‘hot cells,’ repair of damaged canisters or fuel bundles is impossible.

But, even if there is a pool available, Edison’s Tom Palmisano identified a further complication in a public 2018 meeting in response to a question about four possibly damaged canisters already loaded at SONGS.

Meeting Chair David Victor asked, “So, people are going to want to know about these four canisters. Why not take eight or 10 days and move them back into the pool, and unload them and reload them? Help us understand….”

Palmisano responded, “Yeah. Let me address this ’cause I faced this issue back in the mid-90s at the Palisades Nuclear Plant with a loaded canister that had a potential weld defect and got into this very discussion.

“Nobody has unloaded a commercial canister either a bolted cask or a welded cask or canister. Okay?

“It is possible.   What you’d do is basically have a mechanism either to do it in a fuel pool or do it in a dry transfer facility [ a robotically operated hot cell ]. It’s possible either way.

“You’d take the canister back in and the first thing you’d do, [is] reconnect the valves and find a way to purge the helium and refill it slowly with water. The biggest technical issue that we’ve looked at in the industry over the many years, not just related to SONGS, is the thermal transient to actually reintroduce water into a, let’s say a canister with hot fuel, 2 – 300 degrees C, and the thermal transient that you put the fuel through. OK?

“So, once you get it re flooded, cooled down, you’ll then … grind out the weld, take the lid off, that’s just mechanics. That’s doable.

“The real challenge as we would understand it today – and nobody has had to do it yet – is the re-flood. It’s certainly technically possible. What I would tell you – I was back in Washington with the NRC last week – if you would just brainstorm this it would probably be a two to three year project to develop the techniques, pilot the techniques. The NRC would want to have explicit approval on this because of the radiological hazards.”

Victor interposed, “To the workers.”

Palmisano paused, then added, “Uh, yeah…to the workers”- the apparent intended implication, ‘but not to the surrounding population.’

What Palmisano is describing is the possibility that the extreme difference between the heat of the fuel and the temperature of the water might cause a steam explosion in the already damaged canister, in which case the ‘radiological hazards’ might well affect more than ‘just the workers.’

How to Profit from the Age of Nuclear Waste

So, some are advocating that the San Onofre storage facility be moved to higher ground in thicker casks housed in more securely hardened structures.  Others are advocating for the waste to be shipped across country to New Mexico to a facility being proposed there by Holtec and a local group of entrepreneurs calling itself the Eddy-Lea Alliance.

Holtec International, a major player in this drama, is a family-owned company, based in Camden, New Jersey.  It has faced allegations of bribery, nepotism, executive incompetence, poor quality control, and has mixed reviews from employees.  True to its name, the company has international ambitions for building small nuclear reactors (SMRs) and to become dominant in the burgeoning global market of radioactive waste management. It is working hard to convince the NRC and members of the public that concerns about its San Onofre ISFSI are over-blown and unfounded. In fact, this brouhaha may represent a serious threat to Holtec’s business model.

Holtec canisters are reportedly installed at three-dozen other reactor sites around the country, including Humboldt Bay in California.  Holtec is in the running, too, for a waste storage facility at the state’s Diablo Canyon nuclear site, scheduled for shutdown in 2025. 

Holtec is also offering to buy four other US phased out nuclear power stations, – Oyster Creek in New Jersey, Pilgrim in Maine, Palisades in Michigan and Indian Point in New York.  As of this writing three of those proposed deals have yet to be closed, but on April 18, 2019, Holtec announced that it has closed the deal with Entergy to acquire the leaking and controversial Indian Point energy center just outside New York City after the last of its three reactors shuts down. That is, pending NRC approval – which given the agency’s industry-compliant pattern – is almost sure to be forthcoming.  Looks like Holtec – with the NRC’s blessing – is on a roll.

As Jaczko explained, the Pot of Gold in the radioactive waste business is that –  – thanks to fees charged to ratepayers over the years, each plant has accumulated hundreds of millions to several billions of dollars in decommissioning trust funds. Who will get to keep the change, ratepayers or vulture capitalists?

With Three Mile Island now scheduled for shutdown by the end of September, will Holtec attempt to buy TMI, as well?

The California – Chernobyl Connection

Holtec and its client Edison would have the public believe that the San Onofre ISFSI is top of the line, up to date and state-of-the-art spent fuel handling.  But that image seems to be contradicted by a recent Holtec press release and accompanying animated video that describe using double walled canisters in contrast to the single walled canisters at San Onofre.

On May 6, 2019, Holtec was “pleased to announce the start of final system-wide trials for Chernobyl’s dry store facility….” In the next two months, Holtec expects to complete “stem-to stern functional demonstrations of the [SF-2] spent fuel handling and storage processes before handing over the facility to Ukraine’s State owned enterprise Chernobyl Nuclear Power Plant (ChNPP).”

The Holtec press release boasts, “Dismembering more than  21,000 RBMK spent fuel assemblies in a special purpose “hotcell,” packaging those fuel assemblies in double walled canisters (DWCs), and transferring them from (open) water-cooled pools into hermetically sealed rugged helium-filled storage systems inside ventilated modules will mark a huge safety milestone for Ukraine.”

Holtec is also building a project called a Central Spent Fuel Storage Facility (CSFSF) for the Ukrainian company Energoatom.  Holtec says the “CSFSF will employ double-confinement DWCs, the world’s first double-walled, double-lid multi-purpose canister system for dry storage of spent nuclear fuel.”

Some may now be asking, “Why isn’t what’s good for Ukraine, also good for California?”  But Donna Gilmore points out that, “It’s still a thin-wall canister system.  Exterior wall is 3/8″ thick.  Interior wall is 1/2″ thick.  Both welded shut.  Still must be stored in Holtec concrete cask with air vents.  Still cannot be inspected, maintained, monitored or repaired inside or out.” 

In the May 13 Congressional Briefing, Len Hering, a retired Navy Admiral with a successful career in nuclear materials handling, responded to a reporter’s question on this issue, “We can easily provide you the data to show the difference between a thin wall container and a heavy wall container,” Admiral Hering said.  “The thin wall that Holtec is currently utilizing is a half to five-eighths inch thick. A thick wall container is roughly l0.9 to 18.4 inches thick. The difference in those containers is significant. A thin wall container is welded shut. The thick wall container is bolted shut and has gaskets. You’re able to off-load, on-load, monitor the internals that are required per the Title 10. The thin wall has no capacity to do any of those requirements.”

Hering went on to explain, “Thin wall is not approved for shipment, therefore, we have to figure out what to do with that thin wall container before shipment can occur. It is subjected to a number of things to include corrosion, as you’ve heard, that the thick wall containers we have a completely different capacity to be able to both monitor, maintain and create an environment of inspection that the thin wall container does not allow us.”

Ruling Gives Go Ahead to Holtec New Mexico Project

On May 7, the Atomic Safety Licensing Board (ASLB) of the Nuclear Regulatory Commission (NRC) gave the go-ahead to the NRC’s consideration of a pending license application from Holtec International/Eddy-Lea [Counties] Energy Alliance to store 173,600 metric tons of highly radioactive irradiated nuclear fuel in southeastern New Mexico.  

The 142-page ASLB decision denied all 50 contentions contained in petitions from nearly a dozen organizations opposing the project and requesting a full public evidentiary hearing on its potential impacts. 

Petitioners included Beyond Nuclear, Sierra Club, Don’t Waste Michigan, Alliance for Environmental Strategies; Citizens for Alternatives to Chemical Contamination (MI), Citizens’ Environmental Coalition (NY), San Luis Obispo Mother’s for Peace (CA), Nuclear Energy Information Service (IL), Public Citizen (TX), Nuclear Issues Study Group (NM).  

In an unusual alliance with environmental groups like extractive industry groups the Texas-based Fasken Land and Minerals Ltd. and Georgia-based NAC International Inc. also filed petitions for a hearing, contending that the nuclear waste storage project threatens lucrative fracking operations in the booming Permian Basin.  The project is also widely opposed by Native American Tribes – already victimized by atom bomb testing and uranium mining – as well as ranchers and growers who fear water contamination and the boycotting of their products by suspicious consumers wary of contamination.

The region in which the proposed dump will be located is already known as Nuclear Alley, being home to the failed Waste Isolation Pilot Project(WIPP), the Urenco Nuclear Reprocessing Plant and the Waste Control Specialists (WCS) low-level waste site just across the border in Texas, which is also applying for a high-level waste storage license.

As Navajo spokesperson Leona Morgan pointed out at the congressional briefing, “This idea, to move nuclear waste to the west or to places that will impact Native peoples is nothing new, we’ve dealt with so many issues from the beginning of the Manhattan Project to the testing of the Trinity bomb.”

“As Diné people,” she said, “we’re well known for the impacts our communities have been suffering from the uranium mining. We refer to this as the raping of our Mother Earth. And so, today in New Mexico, we’re dealing with the legacy of not just the mining, but all of these other facilities. And the waste from the uranium still has not been cleaned up.”

The Halt Holtec campaign has held demonstrations and press conference with its inflatable mock nuclear waste transport cask all around the region. EON photo

Opponents cite the likelihood that the Holtec/Eddy-Lea project – a below-grade ISFSI similar to the one at San Onofre, with the same loading problems – could and would be eventually expanded to accommodate all tons of spent fuel from aged reactors across the country as they are decommissioned in coming years, thus making the establishment of a permanent federal deep geological repository less urgent, and making New Mexico the de facto national dump. Should the canisters show damage on arrival, ‘return to sender’ is the stated policy.

Opponents point out that over 200 million U.S. Citizens living along transportation routes would be placed in peril by the thousands of resulting shipments of highly radioactive waste being shipped cross country on the nation’s rickety rails, roads and bridges through major population areas.

According to Michael J. Keegan, an Intervenor with Don’t Waste Michigan, “The license application to construct and operate a ‘consolidated interim storage facility’ for spent nuclear fuel in New Mexico is a blatant violation of the Nuclear Waste Policy Act (NWPA 1982, Amended 1987).  The entire application is contingent on the Department of Energy taking title to the spent nuclear fuel. This is forbidden by current law, unless it is a Permanent Repository.  Concealed from the Public is the true intent of Holtec International to store high level nuclear waste for 300 years.  This proposal is [for a] permanent high level nuclear waste dump and is again, a blatant violation of NWPA,” Keegan points out.

Holtec counsel Jay Silberg reportedly said during a January hearing that the plan would still be viable if utilities retain title to the waste in the case that the Nuclear Waste Policy Act is not altered – as is now being attempted in Congress – or that a permanent repository at Yucca Mountain or elsewhere is not constructed.

Says Don’t Waste Michigan attorney Terry J. Lodge, “No less than Rick Perry, Secretary of the U.S. Department of Energy, admitted a few weeks ago to a congressional committee that there is a distinct possibility that ‘interim storage’ sites like Holtec could become permanent, de facto spent nuclear fuel repositories for hundreds of years or even forever,”  Lodge adds, “Holtec would have none of the safeguards and protections that were considered during the Yucca Mountain proceeding. If Holtec is allowed to build, there is a grave possibility that New Mexico will become the loser for all ages,”

Mindy Goldstein, a lawyer for Beyond Nuclear comments, “Holtec, Beyond Nuclear, and the NRC all agree that a fundamental provision in the Holtec application violates the Nuclear Waste Policy Act. Today, the Licensing Board decided that the violation did not matter. But, the Board cannot ignore the mandates of federal law.”

Goldstein adds that this is the second time the NRC has issued a decision overruling Beyond Nuclear’s objection to NRC consideration of the unlawful application, and that the group will continue to pursue a federal court appeal it filed on December 27, 2018.

Donna Gilmore comments, “This is another example of the NRC not protecting our safety.  The proposed Holtec New Mexico system is the same Holtec system used at San Onofre.  The NRC knows every canister downloaded into the Holtec storage holes is damaged the entire length of the canister due to the poorly engineered downloading system that lacks precision downloading. In spite of this gouging of thin canister walls (only 5/8″ thick), the NRC refuses to cite Holtec with a Notice of Violation.”

Gilmore concludes, “The NRC told the ASLB they have no problem with Holtec returning leaking canisters back to sender, yet neither the proposed New Mexico Holtec site nor the San Onofre site have a plan to deal with leaking canisters, let alone prevent radioactive leaks or hydrogen gas explosions.  We cannot trust the NRC to protect our safety.  It will be up to each state to stop this madness.”

The opposition groups have vowed to appeal.  San Luis Obispo Mothers for Peace said in a statement, “These Mobile Chernobyls are fast tracked to take to the rail, roads, and waterways. Disregard for the current NWPA law by proceeding as if it does not exist is not acceptable.  This railroad of a ruling by the Atomic Safety and Licensing Board Panel will be appealed to the NRC Commission as prescribed by the Administrative Procedures Act (APA).   Once these remedies have been exhausted appeal to federal courts is then in order.”

San Luis Obispo Mothers for Peace Spokesperson Molly Johnson stated, “The NRC again demonstrates that it has been fully captured by the industry it is charged to regulate. The NRC process is shamelessly designed to prevent the public from participating in decision-making.”

Kevin Kamps, radioactive waste specialist for Beyond Nuclear, speaks for many when he says, “On behalf of our members and supporters in New Mexico, and across the country along the road, rail, and waterway routes in most states, that would be used to haul the high risk, high-level radioactive waste out West, we will appeal today’s bad ruling.”

First in Line?
On Thursday, May 23,  U.S. Rep. Mike Levin, D-San Juan Capistrano, introduced a  congressional bill that would prioritize the removal of nuclear waste from places with high population density and high seismic activity.  It was clearly drafted with San Onofre and Holtec’s proposed New Mexico CIS project in mind. Holtec is on a roll.

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