UPDATE 10/7/15:
The California Coastal Commission will meet Tuesday in Long Beach to hear testimony about the shuttered San Onofre Nuclear Power Station in San Diego County and how to best store spent nuclear fuel. This is the Chapter's stance. If you want to attend, the meeting starts at noon Tuesday at the Long Beach Convention & Entertainment Center. Here's a link to the agenda and other details, including how to live stream the session.
To: California Coastal Commissioners Effie Turnbull-Sanders, Dayna Bochco, Mary Luevano, Wendy Mitchell, Mary Shallenberger and Mark Vargas:
I write in support of the application by Southern California Edison Company to construct and operate an Independent Fuel Storage Installation (ISFSI) for storage of spent nuclear fuel from Units 2 and 3 at the San Onofre Nuclear Power Station in San Diego County.
Those who care about the California coast have two primary concerns regarding spent nuclear fuel at San Onofre. The first concern is to move fuel rods from pools to dry cask storage as rapidly as possible. The second concern is to remove storage casks from the vulnerable San Onofre site at the earliest available opportunity.
Opinion is virtually unanimous that worst-case hazards are far more severe for nuclear waste stored in fuel pools rather than in dry casks. Construction of concrete structures holding steel canisters is an essential part of this transition.
Commission staff has wisely suggested that after 20 years an amendment be required to continue operation of the facility. This is appropriate not only as a checkpoint to determine whether the ISFSI is providing safe storage but is also timely for review of alternatives to on-site storage.
For more than 30 years it has been a matter of national policy – and of Sierra Club policy – that nuclear waste be removed from operating sites and stored at one or more remote long-term repositories. In the interim, no site has been licensed for operation. As a result, spent fuel has remained on-site at all decommissioned commercial nuclear power plants.
Some fear that construction of an ISFSI on-site at San Onofre will simply assure permanent storage there. Yet the ISFSI is essential to support dry storage and closure of spent fuel pools. To reconcile these concerns, we would ask the Commission to note the following additional aspects of project design and operation:
• Dry cask storage should be in canisters that can be transported if the opportunity arises to remove them from San Onofre.
• Transportation connections at San Onofre should be maintained in a condition that enable spent fuel removal by rail or truck.
• Efforts at the state, regional and national level should be encouraged to develop safer, less exposed storage sites to which spent nuclear fuel can be moved from sites such as San Onofre that are subject to multiple risk factors.
• If such options develop, with the active support of Edison, responsible federal agencies should remove the canisters from the ISFSI and transport them to remote storage.
In conclusion, we support the Commission’s authorizing timely construction of an ISFSI at San Onofre to mitigate unnecessary risks related to the extended use of wet storage when dry storage options are available onsite. Every possible threat (earthquakes, tsunamis, hostile acts, operational errors) that might potentially lead to the release of radiation from spent fuel in dry storage onsite is magnified many fold by additional risks arising from the potential loss of electrical power and water supply needed to keep spent fuel fully submerged and protected in pools.
Once power generation operations stop and remaining spent fuel is moved to wet storage, as has occurred at San Onofre, every available caution should be taken by moving the spent fuel to dry storage and ending any use of wet storage as soon as best practices allow.
Thank you for consideration of our thoughts.
Sincerely,
Glenn Pascall, Chair
Sierra Club Task Force on San Onofre
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