Date: Mon, 16 Apr 2007 13:10:05 -0700

From: "Russell 'Ace' Hoffman" <>
Subject: When complacency is treason

To: California Energy Commission, "Chairwoman Hancock" <>
Date: April 16th, 2007
Re: Additional comments about "temporary" Dry Cask Storage for Nuclear Waste

To Whom It May Concern, C.E.C.,

I received a terrifying overseas phone call last week.  The caller, a patriotic American citizen and nuclear whistleblower, and I talked for about 45 minutes.

We talked of crimes no less than treason.  And deaths no less than millions.

If we could give that crime a name, we might call it Negligence.  Gross Negligence.

Oscar Shirani, the afore-mentioned whistleblower, explained that things are actually MUCH WORSE than I had described in my letter to the C.E.C. last week (shown below).  A terrorist is loose in our midst.  Call it what you will.

One way the terrorist in our midst might strike is against nuclear power plants' dry cask storage systems.

Dry casks are considered -- by the authorities -- to be "robust" (that is, "safe") temporary storage for nuclear fuel.  They are massive, heavy, and complex, but they cannot last forever -- they will degrade over time.

But how fast?  That depends, in part, on how well the dry casks are made.  And for that, one turns to standards and regulations.

There are rules and specifications for just about everything related to dry casks.  The alloy content of the steel that is used must meet very exact specifications.  The mix of the concrete is tested constantly -- every truckload is tested as it is poured, for instance.  The methods and procedures for every little step are very carefully laid out.

There are also rules for welding (and there are lots of welds in ANY dry cask system).  There are rules for checking the welds.  Rules for doing the paperwork for the welding.  Even rules for checking the paperwork for the welding.  And hierarchies of inspectors inspecting other inspectors.  Or at least, that's how it's supposed to work.

What all this has to do with terrorism (and treason) is this:

A dry cask is only as good as its components and its welds, which can only be ascertained by inspections and accompanying paperwork, which is only as good as it is HONEST.

Oscar Shirani has PROOF that the nuclear industry, including dry cask manufacturer HOLTEC, has been falsifying records (paperwork) on dry cask construction projects for YEARS.

Not one dry cask ANYWHERE should be considered safe -- and there are now hundreds, with new ones being added somewhere around the country every couple of days.

When Mr. Shirani took his complaint to the Nuclear Regulatory Commission in 2004, the person with whom he filed the complaint was FORCED TO RESIGN within a week of accepting Shirani's complaint!  Mr. Shirani has gotten the run-around from the NRC ever since.

What does it matter?

If a dry cask's inner structure is not properly built, we don't need a terrorist to fly an airplane into it to cause a global catastrophe and a trillion-dollar loss of life and property.

You have to look at the actual welds to know how bad the problem is.  But the NRC won't do it -- and doesn't even have competent staff on hand who would know what to look for!  Oscar Shirani has given sworn testimony and yet the NRC has concluded simply that the paperwork looks good to them, when Oscar knows for certain that the very same paperwork is UTTERLY FALSE.

The inspections are falsified, the review of the paperwork which the NRC did was haphazard.  And that's Standard Operating Procedure for the Nuclear Regulatory Commission regarding ALL their "Independent Spent Fuel Storage Installations."  That means that dry casks made by companies OTHER THAN HOLTEC are at least as risky as the HOLTEC casks Mr. Shirani complained about specifically.

In 2002, the Davis-Besse nuclear reactor nearly melted down due to a corrosion problem.  Evidence recently released indicates the rate of corrosion was much faster -- weeks instead of years -- than originally believed.  So what?

So maybe we don't have years or decades to find out if dry cask storage is safe.  A tiny bit of water vapor locked inside the dry cask, for example, can eat away at the structure, and result in a catastrophic failure.  And the NRC doesn't understand, and doesn't want to look into the problem.

This is presumably because, without dry cask storage, the nuclear industry would have to shut down IMMEDIATELY.  Even "immediately" might not be soon enough to save us from catastrophe, though.  There is not enough room in the spent fuel pools to hold the contents of the dangerously-constructed dry casks even if we construct newer, safer casks which are actually built to specifications.  And, NO temporary dry cask solution is as safe as a very deep pool, although NEITHER solution is really safe -- just degrees of more, or less, but always extreme, danger.

We are all living on borrowed time, unless we start dealing with THIS situation, and the thousands of other "behind the eight ball" situations the nuclear option has given humanity.

There is no such thing as a nuclear alarmist anymore.  Anyone who cares to investigate the situation can see for themselves that the nuclear industry is corrupt, incompetent, undemocratic, illegal, immoral, extremely dangerous, and ONLY exists through tricks of the legal system, such as not allowing state governments to consider nuclear safety issues.  Such ILLEGAL loopholes have NEVER been properly challenged in court, and yet EVERY STATE AGENCY gives up its MORAL RESPONSIBILITIES by obeying these illegal laws.

We cannot wait for a tragedy to drive us towards a sane policy about nuclear energy.  We have to behave responsibly without that terrible impetus.  We need to immediately stop making MORE nuclear waste.  Nothing else make sense.


Ace Hoffman
Carlsbad, CA

Who is Oscar Shirani?

Oscar Shirani is a US Citizen with Iranian background. He has lived in and has been educated in the USA for 32 years (more than 2/3 of his life).  He has received many awards from ASME, Exelon, and other technical societies.  Mr. Shirani has taught many engineering and quality assurance courses nationwide to engineers around the world in ASME, NUPIC (Nuclear Users Procurement Issues Committees (nationwide and international nuclear utilities)), DSQG (Dry Casks Storage Quality Groups), 27 nuclear utilities, etc..

Mr. Shirani has been requested by many organizations to teach them engineering and audit techniques. He was nicknamed "Shut them down Shirani" by Exelon and some NUPIC members when he put out the Stop Work Order against General Electric Nuclear Energy (GENE), San Jose, CA in 1997 for the first time ever.  GE has been the largest manufacturer and designer of Boiling Water Reactors (BWRs) in the world.  GE had to re-train more than 600 engineers and revise more than 700 procedures in two years according to their own statements to resolve Shirani's Stop Work Order.  But, it took Exelon two weeks to lift the Stop Work Order and conduct business as usual with GE despite the existing Stop Work Order.  It means regulations are nothing except garbage, because GE and Exelon did not want to obey the regulations.

Exelon immediately hired the General Manager of GE, David Helwig, who was responsible for GE's failure that caused the Stop Work Order.  Helwig, immediately upon his arrival to Exelon, fired all four of Shirani's bosses who signed his Stop Work Order.  Exelon removed Shirani from Quality Assurance Group to a production department so that he would not have any power of issuing another Stop Work Order.  Shirani was assigned to the GE Audit as a team leader and he was a company man and "a technical super-star" for Exelon plants.  He wrote many technical papers for Exelon and defended its nuclear plants from being shutdown by the NRC during a 7 year time frame and troubles with its reactors which were on the NRC's watch list.  Prior to the GENE Stop Work Order, Shirani was highly respected by ComEd/Exelon and received many awards.

All Shirani's heroism came to a halt when Helwig arrived at Exelon. Shirani was "living like in a hell" with the overbearing presence of Helwig.  Shirani was not only denied at least three promotional opportunities, he was also demoted in January 2000.

The chairman of NUPIC Group, knowing Shirani's reputation in the nuclear industry, requested Shirani lead a nationwide audit of Holtec dry casks, to find the root cause of all its design and fabrication issues.  Exelon was reluctant to let Shirani lead this audit, but was forced to accept.

On the first day of the audit, June 19, 2000, Shirani had a private meeting with his Quality Control (QC) resident inspector at the Holtec manufacturing facility in Pittsburgh, PA and announced: "Things are not going well" and showed his disappointment with the NRC's audit results which were conducted by NRC six months prior to this audit.  Exelon called Shirani and forced him to leave the audit and fly to Philadelphia, PA to interview for a VP position in a non-related experience to Shirani's on June 20, 2000 at 6:00 AM.  (All these tickets should be on record.)

When Shirani returned to Pittsburgh, PA on Wednesday, June 21, 2000, he found out that the audit was called off by Exelon and other utilities who were participating in this audit under Shirani's leadership.  Two welding experts that Shirani had brought with him, Paul MaCuba and Peter Cerve, were given different assignments by Exelon.  Shirani had to extend the audit for another three days and reported the absence of all other auditors as Part Time Auditors who left the audit.

Exelon took out the Design Checklist of the audit report and indicated NOT APPLICABLE (N/A) with all the code violations in design.

Shirani was denied the opportunity to perform any follow-up of the 9 deficiency reports (199 pages).  Finally, Shirani blew the whistle 5 months later in the Doubletree Hotel in Downers Grove, IL, in the presence of 100 nuclear utility members and NRC staff, Dr. Ross Landsman.

Shirani's career came to a halt in 2000 when he wrote the Audit report of Dry Cask Storage against Holtec and spoke publicly in front of NRC's Landsman.  Exelon falsified the audit report on the same day by saying: "All the findings discovered during the audit of dry cask storage have been resolved by the audit team during the audit."

Instead of being criminally prosecuted by the NRC for the falsification of Shirani's audit report, Exelon got off the hook and the Department of Labor also dropped Shirani's case to save the faulty dry casks and to save the NRC from losing face.

Oscar Shirani's Quality Control Inspector, Tony Frazier, who shared many of the audit information with Shirani and was reporting to him for a year, got fired one month after the audit was done.

The NRC's Dr. Landsman warned his superiors at the NRC to protect Shirani before he got fired, but Landsman was ignored.  When Exelon took Shirani to finance after he spoke to Dr. Landsman, two days later Landsman called Shirani and told him: "Exelon tricked you to go to finance, because you spoke with me in front of all the utility members, and I admire your courage, etc.."

On the second day of Shirani's work in Finance, Dr. Landsman wrote to his managers to warn Exelon and to protect Shirani from any retaliation, but NRC did not respond to Landsman. Shirani was fired and the NRC did not protect him.

Shirani is currently working outside the USA to feed his family, because he has been out of work and could not find any job for three years. He had sent more than 40 resumes to the Nuclear Regulatory Commission for various positions, but did not even get one interview.

But the public has been endorsing and loving Shirani, and call him an "AMERICAN NATIONAL HERO." Read his stuff by Googling OSCAR SHIRANI.


Prior comments for the C.E.C. (included here for ease-of-reference):

April 10th, 2007

Dear Readers,

Some Californians want to start building nukes again.  The rest of us have to stop them.

Years ago, Californians passed a law specifically prohibiting utility companies from building new nuclear power plants in the state until the "high-level nuclear waste problem" is solved.

The waste problem is NOT solved, not even close.  And the four nukes we have are old and undergoing major rebuilding just so they can make MORE nuclear waste for another twenty or thirty years -- or more.  The cost?  Billions of dollars per reactor.

And, while large and expensive parts such as steam condensers, miles of cabling, and hundreds of pumps are being replaced, thousands of old and rusted parts are NOT being replaced.  These practically new (and thus ILLEGAL) nukes are the same old, tired designs.  Many CRITICAL safety components are the same old rusted garbage they've been replacing when it fails for years -- if the failure is obvious.  A lot of times, they don't notice until they need it.

The spirit of the law is being violated as we speak, and now they want to take the law away completely!

Yucca Mountain, the permanent nuclear waste storage facility located in Nevada and planned for the past 20 years or so -- is just a typical "drive it down the road and dump it on Native American Indian land" solution.  It is NOT a technological marvel.  It's nearly completely stalled anyway, and rightly so.  It's a boondoggle.

Solving the nuclear waste problem is a PHYSICAL IMPOSSIBILITY, not a mere technicality, not a complex engineering hurdle, not a bureaucratic fumble.  They are not just short on funds.  Nor are they short on "great minds" who have worked on the problem all their professional lives.

Nor are they short on things they've already tried which have already failed.  For example, new studies show that glass vitrification of low-level nuclear waste is probably going to be about 1% as durable as expected.  ONE PERCENT!

The problem with the nuclear waste problem is that it's "intractable" -- and NO scientist has ANY PLAN which is workable.  That's because when you get right down to the science of the matter, there is NO physical barrier which can be built which will keep radiation out (or in).  There is no safe place to put it.  There isn't even a transportation method safe enough to get all the waste safely to this mythical safe storage location.  It's not just DIFFICULT, it's IMPOSSIBLE.  It has taken decades to ADMIT utter failure and most politicians don't admit it yet.  But solving the nuclear waste problem has, in fact, been an UTTER FAILURE.

The solution is NOT to change the law!  That's no way to admit defeat!  The solution is to stop creating MORE nuclear waste.  Period.

Instead, now that the Spent Fuel Pools are packed like sardines, nuclear waste is being off-loaded into "dry casks" at the nuke plant locations.  These casks are NOT designed to be permanent, but they cannot be moved.  (To move the fuel later, a dangerous repacking operation will have to be done.)  And these dry casks will, over the life of the radioactive waste they contain, have to be replaced HUNDREDS of times -- a cost not calculated by the utilities, since EACH CASK is supposed to last several decades, maybe as much as a hundred years -- and the utilities are not required to calculate the costs of ANYTHING further out than a few decades.

They don't know what condition the fuel rods will be when the casks are opened (there are no remote monitoring cameras inside the casks), but I doubt anyone at Southern California Edison or Pacific Gas & Electric really cares -- they figure they'll be retired, if not long dead, when the quap starts to leak.

In the meantime, the spent fuel casks are vulnerable both to terrorism and to the hazards of mother nature.  Airplanes can fall on them by accident as well as on purpose.  The ensuing unquenchable fire will probably cause secondary meltdowns at the reactors they are near, since no one will be able to come close enough, and survive long enough, to shut the reactors down safely.

New dry casks are needed every couple of WEEKS in California, just to hold newly created waste from the four nuclear power plants we've already got.  And now they want to build more nuclear power plants!

But in order to do so, the law in California must be amended.   If it is, THOUSANDS of dry casks will be needed, and EACH ONE will be an environmental catastrophe just waiting to get out.  EACH ONE will be able to destroy tens of thousands of square miles of property, and kill millions.

With a corrupt, nuke-crazy federal government promising to hand out TENS OF BILLIONS OF DOLLARS in funding to any community crazy enough to want to build a nuclear power plant, naturally, somebody wants the money.

Oppose AB-719 like your life depended on it.  Because it might.


Ace Hoffman
Carlsbad, CA

Send your comments (including, if you like, this letter) TODAY to:

"Chairwoman Hancock" <>

Comments are apparently needed "yesterday, if not sooner."  There will be a California Energy Commission meeting on AB 719 next Monday, April 16th, 2007 in Sacramento.  Comments may also be faxed to the C.E.C. at: (916) 319 2192.