From: "Russell 'Ace' Hoffman" <>

Date: Tue, 13 Jun 2006 12:24:50 -0700
Subject: Re: Dry Cask Storage Versus Wet Pool Storage Versus Shutting
  the Reactors Down (etc.)

To: "Barbara Byron" <>

June 13th, 2006

Dear Ms Byron,

Thank you for your email (shown below in its entirety).

I stand by my comments 100%, including my assessment of your own
relevant technical knowledge, and the idea that you do not consider
me a human being, do not feel my ideas have any relevance in the real
world, and that you have -- diligently -- failed to consider my
presentations and comments, year after year after year, to the
extreme danger and detriment of the citizens of California.

I hope that your letter signifies a change in policy for the State of
California, whom you represent to me on these issues.

Regarding the quote you included in your response, the NAS made
numerous assumptions regarding manners of dispersal which negate
their conclusions.  Those assumptions are not reflective of the real world.

The total amount of spent fuel in dry casks versus the total amount
in spent fuel pools is the question one must ask first, which you
have skipped (your NAS quote goes straight to which one is bigger,
not asking how many of each there are, or may be).  There are a
limited number of spent fuel pools and nobody expects to build more
(unless they build more reactors), but we can keep building dry casks
ad nauseam (pun intended), because they are much more cost-effective
for the utility.  A well-built new spent fuel pool would probably
cost BILLIONS of dollars, or close to it.

By the way, spent fuel pools above nuclear reactors, as with most
Boiling Water Reactors, are inherently dangerous, and every one of
those reactors should be shut down immediately and permanently for
that reason alone.  California's four Pressurized Water Reactors
should be shut down immediately too, but not because the spent fuel
pools are above the reactors.  Rather, one good reason is because the
Spent Fuel Pools are NOT inside the containment domes, and thus NOT
protected very well from airplane strikes (have you checked the
thickness of their roofs lately, in light of the "new" terrorism
threats, as well as the STRUCTURAL INTEGRITY of those buildings after
all these years sitting in the rust-inducing salty, irradiated air?).

Of course, if California's reactors's spent fuel pools or dry casks
were INSIDE the reactor containment dome, I doubt anyone would think
it was safe to also operate the reactor!  Well, that works out
conveniently, since there is no reason to operate the reactors,
anyway.  Certainly not for electricity, which can be obtained other
ways, as your own agency's reports on increases in energy production
in the state over the past five years have proven incontrovertibly.

Regarding your quote's assertion about how far the contents would
spread and how much damage would be done, the amount of fuel in the
release scenarios in any estimation by the NAS, the NRC, the DOE, or
the CEC is invariably a tiny, tiny fraction of ONE dry cask or ONE
spent fuel pool -- say, 0.07% or less --  thus, the quote's "total
inventory" point is irrelevant and obfuscating.  To talk about a
release of several tons of fission products from a dry cask AS IF
that is a scenario the NAS has actually considered is
preposterous.  Releases of such magnitude are considered either
IMPOSSIBLE, or so unlikely as to make it unnecessary to calculate
their consequences.

Such arrogance sank the Titanic and doomed two space shuttles, so far.

The cut-off point for Federal Nuclear Government Work is generally
when "they" think something has a likelihood of less than one in one
million, sometimes one in ten million.  But who decides what those
Las Vegas odds are?  Pro-nuclear, biased "scientists" with plenty of
"wriggle room" for "fudge factors," that's who!  Ever hear of the
book How to Lie With Statistics?  It's the bible of the nuclear industry.

Your quote -- you -- speak of TOTAL INVENTORIES while,
mathematically, only acknowledging FRACTIONAL RELEASES.

Furthermore, the damage done by radionuclides in minute quantities --
after a dispersal has become part of the "global background radiation
burden" -- is a matter of serious and significant debate.  Or to put
it bluntly, that same NAS doesn't keep up to date with the current
literature -- the scientific theories and statistical data -- and nor
does the C.E.C., let alone the "Health Physics" community.  Low level
radiation is far more hazardous than the pro-nuclear industry
assumes.  California leads the way on understanding the hazards of
second-hand ("low-level") cigarette smoke.  We should be as
enlightened about LLR.

And as to the fission product inventories specifically, there are
hundreds of isotopes of the full spectrum of elements in the Periodic
Table in each spent fuel rod, and some of them are being released
constantly from the fuel rods, and the public needs to be thoroughly
and totally protected from these "irradiations" -- and told about
them.  Any place where dry casks are stored, there cannot be
people.  So when you talk about spreading them out, you are talking
about stealing hundreds, then thousands, then tens of thousands of
acres from Californians.

And that's without an accident!

Some of the radioactive spent fuel byproducts are radioactive for
mere days, which of course means if they get out they are an
immediate concern.  Others last for thousands of years and will seep
around the planet over time even if they don't disperse very far in
the original accident.

Of course, all the NAS scenarios you religiously believe in assume a
miraculous cleanup can occur, even though real-life experience with
radioactive spills SELDOM results in a successful COLLECTION of the
waste:  Most of the time, the waste is DISPERSED and this is
considered the same as a true CLEAN-UP.  But due to the health hazard
at ATOMIC LEVELS from nuclear fission products, dispersal only makes
identification of CULPRITS difficult if not impossible. It spreads
the deaths out over time and distance, but IT DOES NOT SAVE LIVES.

In any dry cask, a significant percentage of the original fuel load
(Uranium-235) hasn't yet been split (that's why some people want to
reprocess the stuff), and the reactions still continue -- hence all
that decay heat, which, while several orders of magnitude less than
the moment the fuel is removed from the reactor, is still a
significant chemical and physical process -- including that it is
destroying (irradiating) the zirconium cladding you mentioned, as
well as the steel and concrete which the dry cask containers are
built out of.  They can't last forever, and they won't, but we have
no backup plan in place for if they start failing earlier than your
esteemed scientists -- who have been wrong so many times before --
expect.  (Steam Generators were supposed to last, too.)

Fission products continue to be created constantly by the spent fuel,
albeit at a lower rate (from about three to six orders of magnitude
lower) than when the fuel was in the reactor.  Some of the
radioactive isotopes with especially long half-lives are actually
still increasing and will be for, perhaps (depending on the exact mix
of any particular dry cask), centuries or even millennia to come.

You cannot determine the health hazard of a radioactive substance
from its half-life alone.  You must also determine how it interacts
with the environment and with the human body, and how ITS
"radioactive daughter products" (if any) react, and THEIR daughter
products, and so on.  Of course, the NAS knows it all, I am to assume
from your letter!  Despite that fact that it was 50 years AFTER the
dawn of the nuclear age that the scientific community actually agreed
that there is no minimum threshold, no safe dose, of radiation!  And
even that "agreement" has not been fully accepted, and the exact
details of the various mechanisms for damage are still largely
unknown, but hey, that's science, isn't it?  Imprecise.

It is your legal responsibility to assume the worst, in all cases
where legitimate scientific ambiguity exists.  The nuclear industry
has always assumed that things would work out in their favor, and
hasn't been right once yet.

Let me remind you that terrorism with nuclear weapons is not out of
the question.  Not impossible.  Not even "unlikely."  In fact, it's
probably inevitable sooner or later that a nuclear weapon will be
used against a civilian target.  That could obliterate all your
"little" dry casks -- the whole farm around Diablo Canyon or San
Onofre.   Even a "tiny" nuclear blast could open them all.  The NAS
didn't happen to mention that, did they?

One tsunami could ALSO destroy the whole farm, too.  Have you
forgotten Bande Ache?

Please see my addition comments immediately below.


Ace Hoffman
Carlsbad, CA

Nuclear Terrorism against dry casks, nuclear power excursions, and
related issues:

Subject: How Cheney and friends use the complexities of nuclear power
to pocket billions of dollars and destroy the planet

May, 2006

It's taken more than 30 years, and well over 3,000 interviews
(hundreds in person, thousands over the phone, and thousands more by
email), but here's what I've learned:

Nuclear power is really, really complicated.

Duh?  Duh, you say?  Are you a nuclear engineer?  If so, what portion
of the whole puzzle did YOU study?  I'll find an expert who's just as good.

And if not, then please just step aside for the moment and watch the
Biggies battle it out.  Watch the pro-nuke "experts" dance from one
reason to another to prove their point.  That is, watch them give up
on one reason we simply MUST have nukes only to argue something
different, that you had already argued with them before.  This is
what they do.  Circular arguments, with many steps (remember, nukes
are complicated, right?).

I did a couple of animation of nuclear power plants last year.  They
are extremely accurate depictions (see URLs, below), and even several
pro-nuclear sources have described them as "excellent" and asked to
use them to describe nuclear power to the public, to university students.

Okay, that doesn't make me a nuclear scientist, but if you find me a
pro-nuclear scientist and give me his arguments, I'll find another
scientist who'se credentials are just as good to go over my answer if
I need to, but I'll answer every one of his arguments.   I've done it
before and I'll do it again -- I'll let them argue for 50 pages and
dozens of letters if it takes them that long to circulate around to
their previous arguments (repeat themselves) or, as is MORE LIKELY,
they end up arguing both sides of a coin, which show's they are being
merely argumentative, which is not the same as debate.

For example, most pro-nukers can be induced to argue FOR wind power
within 10 pages of "debate" (utter gibberish on their part, mind
you).  No matter if they started out saying it couldn't
work.  Eventually you can always dance them around to admitting that
renewables COULD work, if only.

If only this, if only that.  If only they weren't so ugly.  If only
they didn't kill birds.  If only they didn't put a lake where a
canyon or a flood plain used to be.  If only, if only, if only.

Then, when you turn the conversation to the specific, unique, and
INTRACTABLE problems of nuclear power and say, "these are so much
more serious than ANY of the arguments against renewable energy," the
cycle starts to repeat itself, as they argue that wind power could
never replace nuclear power because of this, and that, and so
on.  It's all hogwash.

The latest voodoo reason to support nuclear power is fear of global
warming.  Not that global warming isn't a problem -- it's just that
nuclear isn't the solution.

It would take every issue of every week of this newsletter to
describe all the problems nuclear power presents, but in this guest
editorial, I'd like to concentrate on some immediate problems
California (and many other states and countries around the world) are facing.

First and foremost is the continued accumulation of ever-increasing
mountains of nuclear waste -- so called "High Level Radioactive
Waste,"  which is also known as "Spent Fuel," a term the nuclear
industry likes, because it sounds so harmless.  Well, it isn't
harmless and worse, it cannot be safely contained for long periods
with defying the laws of physics, which say that a radioactive
breakdown is strong enough to break ANY chemical bond -- and not just
any chemical bond, but thousands of them at once.

By operating nuclear power plants, we are creating enormous problems
for future generations.   So-called "experts" STILL, after 50 years
of knowing better, write about the possible creation of containment
systems that will not break down, will not become radioactive
themselves, will not fail, no matter how many years they are required to last.

Other pro-nuke "experts" STILL, after 50 years of knowing better,
talk about "rocketing the waste to the sun."  Really, it's not been
forgotten, and I'm talking about by so-called "rocket
scientists."  REAL "rocket scientists" who obviously are not
statisticians, for statistically, after 50 years, we know that that
method could not possibly reliably loft all 77,000 tons (or whatever
the exact correct value is; one hear's so many different numbers) of
high level radioactive waste out to space.  It's preposterous.

Still other "highly qualified experts" (I don't know WHO does the
qualifying, but they get articles in high places so someone must)
think that dumping the waste in tectonic subduction zones deep in the
oceans is the answer.  They're wrong on several counts, and their
numbers are few, but they're out there.

Glass vitrification is another dream, but the construction delays in
the Hanford, Washington nuclear facility to try it might put the lid
on the idea.  It was a bad idea to begin with, but so is leaving that
waste the way it currently is stored, in leaky tanks.

Which brings us to San Onofre and Diablo Canyon.  They are creating
so-called "High Level Radioactive Waste" at the rate of about a ton
every two days for the four reactors.  There is now approximately ten
million pounds of the HLRW stuff and it isn't being rocketed to the
sun (thank goodness) or anything -- it's "just" sitting there.

About five years after it is removed from the reactor, spent fuel can
be removed from a pool where it is stored deep underwater, and placed
in "dry casks."   This transfer itself is a very dangerous
operation.  Every step -- and every added step -- is dangerous.  By
not having a long-term solution, we are adding lots of steps, every
one of which carries an added grave risk.

These dry casks are massive things, but not so massive that a
terrorist cannot break them open.  Not so massive that an earthquake,
tsunami, or other natural disaster cannot harm them, although the
utility will claim otherwise -- it's a lie.  It's an engineering
impossibility at the price / performance ratio they must work under
to do what they claim they are doing AT A PROFIT.  How so?  A couple
of inches of steel and a few feet of concrete just aren't enough to
guarantee the job.

And if a dry cask catches fire, it could easily be as bad as a
meltdown of the nuclear reactor itself -- perhaps worse.  Each dry
cask holds about 1/4 of a full reactor's load of fuel, and if they
catch fire, they cannot be put out with water -- it takes flooding
them with noble gases, but no one can get close enough to do it (they
won't live long enough to get close, if they try) and the casks are
not being stored in pits where such a thing would even be possible,
AND there is no automated delivery system for such a calamity, nor
are there stores of such chemicals on site.

What does the nuclear industry and the Nuclear Regulatory Commission
do instead?

They assume such a thing simply cannot happen.  Really -- that's what
they do.  That's the fantasy-land they operate under.  Their idea of
a "worst-case scenario" very specifically does NOT include more than
perhaps 0.01% percent of the fuel burning or escaping in any way, if
that.  Zero Point Zero One Percent.

These "what-if" accident scenarios are utterly unrealistic.  In
reality, a dry cask fire can cause widespread death and destruction,
just like a nuclear plant.  Furthermore, by storing the dry casks so
close to the nuclear reactors, IF a reactor accident occurs, both the
spent fuel pools and the dry storage casks are vulnerable to
secondary failures,.  For example, some explosive accidents can throw
the lid of the reactor half a mile into the air.  The lid weighs
about 20,000 pounds.   If it lands in the spent fuel pool or on a dry
storage cask, it would cause a secondary release of radiation that
might be bigger than the first.

Of course, the Nuclear Regulatory Commission has a way around
this.  They simply deny that such accidents are possible.  They do
this by designating such explosive deconstruction as being "outside
the design-basis accident."

In other words, the NRC simply refuses to admit that things can go
that wrong.  They believe, instead, that the safety systems and
backup systems will work as designed, even though experience has
shown that to be a baseless assumption.

For example, the Monticello nuclear reactor had its main safety
system UNAVAILABLE for nearly 30 years -- since the plant was
constructed until just a few years ago -- because 32 shipping bolts
were not removed from eight humongous bellows, when parts were
installed at the plant during its original construction.

And after that, the system was never tested or inspected.  This is
just one of many, many indications that the NRC is a lap-dog
regulatory agency and the industry it regulates is dangerously
incapable of meeting the incredibly high standards required by nuclear power.

Both San Onofre AND Diablo Canyon -- all four of California's aging
nuclear power plants -- are, for all intents and purposes, being
completely rebuilt as we speak. By dividing the work up into pieces
the full cost -- well over a billion dollars PER PLANT and probably
two or three -- is made to appear in media reports as much smaller
amounts, and the work is made to appear as little more than
accelerated maintenance -- a seemingly good thing, eh? Well, it's a
bunch of bull. What's going on is a complete rebuild ALMOST from the
ground up, but a piece at a time. There are so many old wiring
systems and parts in those plants, though, that no one that works
there knows how the system really works -- I guarantee it (and I know
quite a few employees and ex-employees at the plant, by the way).

Here are some of the parts that have recently been replaced or
probably will be soon, in one or more reactors at San Onofre alone:
Steam generators, "heaters" (about 30 per reactor), reactor pressure
vessel heads, one main rotor (there is one per reactor) had to be
rebuilt after the fire in 2001. Hundreds of pumps, wiring systems,
feedback loops and circuit boards (these are humongous things that
have to be put in place with forklifts and cranes, nothing like a
household circuit at all!).

Yet, in the end, to call these reactors "like new" or even "newly
refurbished" would be inappropriate, because, try as they might,
there are still hundreds of systems which are corroding in place in
the radioactive and salty, smog-filled environment in which these
reactors sit. The parts replacement projects are mostly being done on
a "when it fails, replace it" basis, rather than on a
preventive-maintenance schedule.

And what of the NRC? The industry is "self-regulated" -- they only do
paperwork audits, 99% of the time that they do ANY audit at all.

In California, the operation of our nuclear power plants continues,
decade after decade, in opposition to the things Californians love.
We do not love the risk from earthquakes, tsunamis, riots, or
anything else, we live here IN SPITE of these risks. But risks are
cumulative, and the added burden of nuclear power is a risk that has
been foisted on the citizens of this state -- and on the planet --
through immoral and undemocratic manipulation of public opinion for
the past half century.

For example: Let's take a quick look at tritium: Tritium is a
radioactive isotope of hydrogen, with one proton and two neutrons in
its nucleus. When it undergoes radioactive decay, it releases a beta
particle -- which is just a very high-speed electron -- from the
nucleus. As this happens, one of the neutrons (the one that ejected
the electron) becomes a proton instead, and the atom becomes, not a
very heavy hydrogen atom like it was, but a light helium atom.
(Normal helium has two protons and two neutrons in its nucleus.
Helium from tritium has two protons and ONE neutron in its nucleus.)

Too technical? Sure, and the nuclear industry is counting on that. So
I'll try to refrain for the rest of this commentary.

Tritium is produced at -- and released into the environment from --
all nuclear power plants. Federal regulations are lax on tritium,
because it would cost the nuclear industry billions, or shut them
down, if they showed proper concern for tritium's hazards.

Pro-nukers -- health physicists, specifically, the specialists who
should know better -- will tell you (and have told me) that tritium's
beta particle is relatively harmless, because it is a "low-energy"
beta particle, as beta particles go.  In fact, they might add, in low
doses it might even be good for you.

But find a BETTER expert to talk to (they do exist), and you'll learn
that beta particles, when they are ejected from the nucleus of an
atom (oh, here we go again!), "dump" all that excess energy that they
get ejected with at "the end of their track." At the beginning of the
track, the beta particle is traveling TOO FAST (a significant
fraction of the speed of light) to be near another atom long enough
to have much influence, but as the beta particle slows down, it stays
in the vicinity of each atom it passes long enough to have a
significant effect -- long enough to cause ionizing radiation damage.

Now, of course, this IS certainly too technical for the average
Californian -- I've been studying it for more than 30 years and it's
hard for me, too. And thus we are frozen out of the discussion,
accused of being emotional and unaware of the facts, or being just
another California "whacko environmentalist."

But there ARE experts who will back up what I've just written
regarding tritium, and we need to start listening to them.  Indeed,
across the country there seems to be a renewed interest in the damage
lowly little tritium can do. Tritium leaks have been found at several
nuclear plants and local residents, despite official propaganda from
the Feds, are scared.

When the blackouts of '01 occurred here, the real reason was probably
because three of our four nuclear power plants were "down and out"
and the fourth one dropped out now and then and well. The "powers
that be" in charge of power in California engineered the blackouts to
"prove" that we need all the power, by any means, that we can get.

And now, Southern California Edison (SCE), the operator of San Onofre
Nuclear WASTE Generating Station (called SONGS, not SONWGS,
officially, since the waste is ignored), is running millions of
dollars worth of ads telling Californians that SCE is making major
investments in proven green technologies such as WIND POWER.

Yet at the same time, shills for their nuclear industry, such as
academicians who were invited to speak to the California Energy
Commission last year at rare public hearings (where testimony was NOT
sworn, and much of it WAS useless), tell us that WIND POWER hasn't
got a chance.

Who's lying?

Both are, and solely to make nukes look good. There is NO real effort
to solve our energy problem with renewables, even though it is
perfectly possible to do. Instead, the Bush Administration is pushing
nuclear power like never before, with every trick in the book and
several new ones, such as the Nuclear Regulatory Commission's new
policy to license both the construction AND the operation of a
nuclear power plant at the SAME TIME, so that, after the billions of
dollars and 5 to 10 years of construction, no citizen can oppose the
plant before fuel is finally loaded (as happened at Shoreham on Long
Island, New York, leaving a bitter, bitter taste in the Nuclear Mafia's mouth).

AND they have approved the licensing of new nuclear power plants on
old sites -- even ones where the previous reactors have been
"decommissioned" or perhaps NOT EVEN BUILT! (And "decommissioned, by
the way, is a euphemism for grinding them up into radioactive dust
and spreading them around the globe, and/or hauling them off in
truckloads and trainloads to some waste dump somewhere, except, of
course, for the "spent fuel," which just sits, vulnerable, on our coasts.)

If California continues to insist on self-ignorance about this issue
-- if we are fooled by the fear of global warming into supporting
nuclear power (it's not a solution, as many highly technical articles
by highly qualified experts has shown), we are in for a lot of hurt.

A nuclear disaster would be the worst part of ANY accompanying
earthquake, tsunami, or terrorist act. It would dwarf Katrina and
9-11 combined. It MUST be avoided, but the only way to do that is to
wise up. Will we?

Ace Hoffman
Carlsbad, CA

At 09:49 AM 6/13/2006 -0700, "Barbara Byron" <> wrote:
>The National Academy of Sciences Public Report (2006) Safety and
>Security of Commercial Spent Nuclear Fuel Storage concluded (p. 68) that
>dry cask storage has several potential safety and security advantages
>over pool storage.
>"Less spent fuel is at risk in an accident or attack on a dry storage
>cask than on a spent fuel pool.  An accident or attack on a dry cask
>storage facility would likely affect at most a few casks and put a few
>tens of metric tons of spent fuel at risk.  An accident or attack on a
>spent fuel pool puts the entire inventory of the pool, potentially
>hundreds of metric tons of spent fuel at risk."
>"The potential consequences of an accident or terrorist attack on a dry
>cask storage facility are lower than those for a spent fuel pool.  There
>are several reasons for this difference:
>(1) There is less fuel in a dry cask than in a spent fuel pool and
>therefore less radioactive material available for release,
>(2) Measured on a per-fuel-assembly basis, the inventories of
>radionuclides available for release from a dry cask are lower than those
>from a spent fuel pool because dry casks store older, lower decay-heat
>(3)  Radioactive material releases from a breach in a dry cask would
>occur through mechanical dispersion.  Such releases would be relatively
>small.  Certain types of attacks on spent fuel pools could result in a
>much larger dispersal of spent fuel fragments.  Radioactive material
>releases from a spent fuel pool also could occur as the result of a
>zirconium cladding fire, which would produce radioactive aerosols.  Such
>fires have the potential to release large quantities of radioactive
>material to the environment."

Contact information for "Ace:"