Clear & Present Dangers AND Opportunities at Diablo Canyon

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An EON Interview with Mothers for Peace Spokeswoman Linda Seeley

Why are they trying to start up old reactors that are already shut down and build SMRs on the sites that are already down? I know it’s the weapons. It’s the revamping of our nuclear weapons system. – Linda Seeley

By Mary Beth Brangan and James Heddle

[Editors’ Note: The San Luis Obispo Mothers for Peace was organized in 1969 and has been steadfastly advocating for local and national nuclear safety ever since.]

Linda Seeley – EON photo

The Current State of Play – A Slim Window of Opportunity

Heddle: So give us the current state of play. How does the situation shake out now? What should informed and vigilant citizens be aware of here?

Seeley: We have several different things going on at Diablo Canyon right now. Number one, at this very moment, the unit one reactor is offline for refueling. It’s a planned outage. And in this particular very precious amount of time that we have right now until they want to start it up again, Mothers for Peace has filed a petition at the Nuclear Regulatory Commission, which they rejected offhand, by the way. And we knew that they would do that because that’s what they always do. But we had to do it anyway to establish paper trail, if that’s what you want to call it.


If there were, God forbid, say an earthquake or an error by one of the control room people or several of them, or a cascade of events or an unanticipated attack or any number of different things that could happen at a highly complicated nuclear power plant, and if, God forbid, they had to turn the unit one reactor off quickly, the way they do it is by pouring water, cold water into the reactor vessel to make it shut down.

But unfortunately, the unit one reactor vessel is brittle. And it’s just like if you had a steaming, hot boiling cup of water and you pour ice into it, it cracks. And the same thing could happen to the unit one reactor vessel. And there is no backup safety system for that. If it cracked and shattered like that, it would be literally a worldwide catastrophe on the level of Fukushima. And we are completely unprepared to deal with it. There is no way to deal with it.

The NRC and PG&E say, “No, it’s fine. The reactor vessel is fine.” And so what happened is that several years ago, we found a document that was actually related to the Palisades plant in Michigan, and they had a community meeting. And at that community meeting the NRC listed the various reactor vessels that were embrittled, and on that list was the Diablo Canyon unit one.

We tried to explore that, but we’re not technical, we’re not trained as scientists, as material scientists. But we had a community member here who’s also a member of the Diablo Canyon Decommissioning panel, who is an engineer, not a nuclear engineer, but he started looking after I mentioned at the decommissioning panel that we thought that the unit one reactor vessel was brittle. He started investigating and he started reading all of these papers that were technical and indecipherable to a normal person. And he read 4,000 pages of material over a period of about a year.

And he became very alarmed, and he came to me and he said, this is bad. We need to figure this out because it looks like the reactor vessel of unit one really is going to fail if they must shut it down in an emergency.

So, Mothers for Peace had kind of a miracle in a way because we had been looking for a materials engineer. All the materials engineers work for the nuclear industry, and you can’t hire them because if they work for you, they’re kaput. They can’t work anymore.

So, Michael Keagan out in Michigan sent us a notice about this reactor, or two reactors, I think it was, in Belgium that were embrittled and went offline. And I sent for a report about it, and I started reading this report and it was like, wow, that sounds really like unit one at Diablo Canyon.

And so, we checked the author and it turned out to be a very highly esteemed material scientist. His name is Digby McDonald. He’s elderly. He’s a faculty member at UC Berkeley, and he’s written over a thousand papers. He was nominated for the Nobel Prize in chemistry. This year, he’s nominated for the Enrico Fermi prize. He is a brilliant man, and he agreed to work for Mothers for Peace. We still don’t know why. He was interested. For him, it was a matter of intellectual curiosity. Why are these people yelling about embrittlement? And he had already worked on embrittlement in Belgium and had written a report about it and found that they were embrittled, those reactors. They’re down now.

And so, we started sending him information about it. It took him a while to understand the gravity of the problem, because he is not anti-nuclear. He is pro- nuclear, and he doesn’t want the nuclear industry to get a bad name by allowing a dangerous equipment to be used. So, he started reading through all the documents just as our community panel member had done, and he was aghast, frankly, at what had happened.

Not Collecting Coupons

And here’s what had happened. According to the rules of the NRC, you’re supposed to remove a thing called a coupon out of the interior of a reactor vessel once every 10 years and test it and that coupon is made of the same stuff that’s inside the reactor vessel. The coupons are different. Not all of them are made of the same stuff. The stuff that’s really … Well, it’s all important, but the most vulnerable is the metal that’s made of the weld material inside, because where the welds are, that’s where it’s most vulnerable. So, they had the weld material from unit one back in 2002. They sent it for analysis at a lab, came back, “Oh wow, this reactor vessel is going to not be safe after about 2023, 2024.” So, in all their wisdom, guess what PG&E did? They said, “That’s not valid. We’re going to use a different test.” So, they got some samples from a different reactor vessel, and they used that test. It was very similar to this unit one reactor vessel. So why not use that?

Brangan: Wait, was this a reactor vessel that was at the same location?

Seeley: No, it was a reactor vessel from I think Michigan. It wasn’t even from the same location. It was not subjected to the same conditions. Then they used mathematical equations to prove that the reactor vessel was fine. They have not removed a capsule from the unit one reactor vessel since 2002, even though according to the rules, they’re supposed to do it every 10 years.

Right now, that reactor is down for maintenance and refueling, and Mothers for Peace in our petition to the NRC said, “Hey, you need to order them to take a capsule out and test it and get the results back before you can turn that back on.”

Heddle: That’s according to law, is it? Regulation?

Seeley: The NRC’s own regulations. But the problem with the NRC is if you make the regulations, you can also bend the regulations. I think that’s their motto. Regulations were meant to be changed or made easier for the industry because that’s what they do.

Heddle: Or granted an exception?
Seeley: Grant all the exceptions, yeah.

No Ultrasonic Inspection of the Reactor Vessel

Seeley: And then there’s also another issue, it’s called the ultrasonic inspection of the belt line. The belt line is the part of the interior of the reactor vessel that is under the most heat, stress, and neutron bombardment; it’s the most vulnerable part of the vessel. And so, every 10 years, they’re supposed to inspect the interior of that with ultrasound. That has not happened for 15 years. That’s the other part of our demands on this petition – inspect it, get the results back, let the public know.

Mothers for Peace, if it turns out that that reactor vessel is hunky-dory, well, phew, yay, we would be very happy about that. But we know that it isn’t and we want to get those results back.

Seismic Thrust Faults

Seeley: There’s another part that’s worrisome too, which is the seismic issue at

Diablo Canyon.

In our filings with the California Public Utilities Commission, we decided that it would be wise for us to hire an expert witness, a seismologist, to review all the literature that’s available about the seismic conditions at Diablo Canyon. And he is again, highly respected. His name is Peter Bird. He’s from UCLA, very highly respected seismologist.

And he reviewed of all the history of Diablo Canyon seismic inspections or analysis, and by the way, he’s one of the authors of the prior level three seismic hazard analysis, so he knows about Diablo. What he says is that during the past 10 years since they did any seismic studies at Diablo Canyon, the technology has changed a lot, and there’s a lot more available to analyze what we already know. There are a lot more tools available to analyze. And he says that there’s a very good likelihood that the fault line that runs right under the plant is called a thrust fault, meaning that instead of moving sideways, it moves up and down if it goes off.

And if you have one that moves up and down, the ground motion is a lot bigger than it would be with a lateral fault, and it goes right under the plant. And so, he is requesting, and Mothers for Peace is requesting a level three seismic hazard analysis. The NRC is the one that orders that. They could order it for Diablo Canyon for this license extension. They won’t.

“Fool Me Once…” Overextension – Will Duped Legislators Respond?

Seeley: This is a complicated thing we’ve got going here. Right now, I think the future of Diablo Canyon rests in our state legislature. They’re the ones who were duped into voting for extending the life of it back in August of 2022. A lot of those legislators who were duped are now regretting their choice.

Brangan: How do you know that?

Seeley: We’ve talked to them privately and others have talked to them privately, and they understand that we don’t need Diablo Canyon. I can’t attribute with certainty any motivation to Gavin Newsom. Maybe he sincerely believes that we need Diablo Canyon to keep the lights on, but I don’t think so, and that’s my personal opinion.

But we know that Diablo Canyon, if there were an accident there, that it would completely ruin the economy of California. I mean, that’s the thing they’re the most interested in, I think. For us, it would totally ruin our lives, and it would ruin our food, and it would ruin the ocean, and it would ruin our rivers and streams, and it would ruin the animals, and it would ruin the whole entire ecosystem. And it would be like the most ridiculous tragedy that ever happened for no good reason, because of the egos of some corporate managers or Gavin Newsom. I don’t know. But it would be a tremendous tragedy.

And when you think that we don’t need it, and yet we’re putting two and a half billion dollars into keeping it open and it’s dangerous, why on earth would we pursue such a path? It is insanity to do that.

And so that’s what people can do. People can call their own state legislators and they can say, “Look, this has gone too far. This is a ridiculous situation that we’re in.” There are off ramps. They’re called ‘off ramps’ to SB 846, the law that made Diablo Canyon stay online.

And by the way, this law says that they’ll extend the life of Diablo Canyon for five years. Don’t believe that for a second. PG&E is applying for a 20-year license extension.

Extension Means More Nuclear Waste Stored On-Site

Seeley: With this possible extension of the license at Diablo Canyon, there’s a whole other issue that they haven’t addressed at all, which is the storage of the nuclear waste. Right now, we have 58 casks that are on these pads that are like the size of two football fields. Okay? The casks are each about, I think about 24 feet tall and about 20 feet in diameter. The canister inside the caskets is five eighths inch thick, stainless steel.

Seeley: Each cask that’s there of the 58 holds about the equivalent amount of radiation as was released at Chernobyl. It’s shocking when you think about it. Now what they’re doing at Diablo Canyon is filling the spent fuel pools. They’re packing them very, very tightly. If they continue to operate, there won’t be enough space because they only have space on these pads for 131 casks, and they will fill that.

They were planning on the plant shutting down in 40 years, so they have enough space for that amount of waste. It’s like a parking lot that holds X number of cars. They only have X number of spaces for the nuclear waste when at the end of 2024 and 2025, those waste lots will be full. Okay. Imagine, if you will, huge parking lots. Instead of being filled with cars, they’re filled with casks of radioactive waste.

They are sitting on a bluff above the Pacific Ocean. Okay? They are visible to any aircraft that might come over there. I don’t even want to talk about the possibilities of what could happen there. So, at the end of 2025 they will be filled, but they want to continue operating. So, what are they planning on doing with the new waste that they will be making? Well, PG&E says they will keep it in the spent fuel pools for 20 more years because then they will have a place to move it to, they say, which is completely insane as we know, because there is no place to move it to.

The terrain around Diablo Canyon, it’s jagged. There is no flat land there. To make flat land there, you have to blow up a mountain. So, if they want to put a new pad in to make room for new spent fuel, they must blow up a mountain and flatten it out and get down to the bedrock, because you can’t store and spent nuclear fuel on anything but bedrock. Of course, the bedrock could crack in an earthquake, but who’s looking at that? Nobody. So that’s our situation with the spent fuel. It’s insane.

A Timebomb In Place

Seeley: That’s another generation with it sitting on the coastline with six and a half million pounds of nuclear waste that’s stored out in the open. And a lot of it in the spent fuel pools to generate electricity that we don’t need on 13 earthquake faults. What could possibly go wrong with a nuclear vessel that will crack if you try to shut it down fast? I mean, it’s the height of insanity and absurdity, and yet we’re living with it. And if things, God forbid, go wrong, we’ll pay the price forever. So, it’s not worth it.

Successful Litigation Despite Regulatory Capture

Seeley: But I want to talk about our other lawsuit that we have going in the Ninth Circuit Court. In 2022 the state passed the law to keep it open for another five years. There’s a rule at the Nuclear Regulatory Commission called the Timely Renewal Rule.

What it says is that if a nuclear power plant wants to continue operating beyond its 40-year license, that they must apply for that license extension at least five years before the old license runs out. And the reason for that is… When you think about a nuclear power plant running for 40 years, well, think about your car, okay? I had a Volkswagen 40 years ago. I would no more get in that Volkswagen today and drive it down the freeway at 80 miles an hour than I would jump out of an airplane without a parachute. We have two nuclear reactors that are approaching 40 years old. They want to continue operating for 20 more years.

The NRC says, “Well, wait. We need to go through all these problems, all the wear and tear, all of the parts that need to be replaced, all that stuff. We need to review that. And that takes a long time. That takes five years to do that.”

Well, the NRC granted an exemption a couple of times to nuclear plants down to three years prior to that. Outrageous, right? How could they go through all that paperwork, review, etc. in only three years? But they did it.

But now at Diablo Canyon, PG&E’s application for relicensing Diablo Canyon is going to be submitted to the NRC 10 months and two days before the expiration of unit one and 20 months before the expiration of unit two. That is unheard of!

So, Mothers for Peace filed an objection to that, a petition with the NRC. The NRC rejected it, which we expected. So, then what did we do? We filed it with the Ninth Circuit Court of Appeals, and that’s where it is right now. We’ll be having a hearing on that in the Ninth Circuit Court. I think it’s in early January if I’m not mistaken. Our lawyer just filed a reply brief on Thursday to PG&E’s and the NRC’s lame, I must say, explanation of why they actually don’t need to have five years or even three years before their license runs out. So basically, if they prevail, we will have Unit one being given a green light to operate without a license with this unchecked cracked reactor vessel. What could possibly go wrong? It’s insane!

We have racked up huge bills with our expert witnesses, but we needed to do it in order to be able to have a solid case at the CPUC. We have a tremendously excellent lawyer at the CPUC. And the CPUC is going to make the decision about whether Diablo Canyon can continue to operate. We know the NRC will say the CPUC can’t, but the CPUC could say no.

The CPUC, the California Public Utilities Commission, are the ones that make the prudent decisions about whether or not our California rate payers’ and taxpayers’ money is worth putting into a certain project.

And this particular project is horrendously expensive because number one, back in 2016 when they decided to shut down Diablo Canyon and came to a deal, the state of California labor unions, environmental groups, et cetera, made a deal.

Okay, we’re going to shut down Diablo Canyon at the end of its license term in unit one, 2024. Unit two, 2025. Okay, so we’re going to do that.

In the meantime, now we’re in almost 2024 now, right? Back then in 2016, you have an old Volkswagen, you are going to put it in the used car lot pretty soon. Well, you do not spend a lot of money on putting repairs into it. You try to limp along until you get rid of it. That’s what they’ve been doing for the past six years, seven years now They have all this undone maintenance that they are trying madly right now to catch up on to get ready to relicense the plant. So, they’re sinking tons of money into it.

Of course, they got a whole bunch of money from the state, and they’re getting the money from the feds, so they’re flush. And for any capital projects where they put build something or do something significant, not just maintenance, that does not come out of PG&E’s pocketbook. That comes out of the rate payer’s pocketbook with a guaranteed 10% return rate for the investors who are invested in the utility. This is like a gravy pot for PG&E. They are loving it.

They’re also getting all these bonuses for the workers out at Diablo Canyon – 25% per year bonus to their salary. And they’ve been getting that since 2016. And they are continuing to get that. Now they are well paid, let me tell you.

Heddle: But that was premised on the idea that it was going to fade out and they were going to lose their job.

Seeley: That’s right. But now, no. The reason they were getting a 25% bonus was to keep them working there so they didn’t quit and go somewhere else until the plant shut down. So now with the plants not going to shut down, supposedly, unless Mothers for Peace prevails, they’re going to continue to get this 25% bonus. I mean, talk about a money trap. It is the biggest money trap that ever existed in this county, I’ll tell you.

Brangan: I am so surprised you could challenge an NRC decision in federal court.

Seeley: Yeah, we’ve done it before and won. We won back in 2010, I think. When they were building the spent fuel facility, the dry cask storage, we filed a lawsuit about a dry cask storage facility, and our contention was that it was vulnerable to terrorist attack, and then it needed to be guarded better with HOSS, Hardened On- Site Storage. Right. And we won that case that it is vulnerable to terrorist attack in the Ninth Circuit Court – the Ninth Circuit court ruled in our favor.

And then what did the NRC do? Squat. Nothing. They didn’t change their rulings at all because they said, “Well, the possibility of a terrorist attack, we have done the analysis on it, and it is so remote that we don’t even need to take that under consideration in our ruling.” Isn’t that something? They’re a captive agency. It is amazing. And the longer I work in this, the more I understand that. I used to hear the term captive agency and think, huh? What exactly does that mean? What it means is they are under the absolute control of the industry that they are supposed to be regulating. That does not work.

Heddle: Regulatory capture.
Seeley: Right.
Brangan: It’s because they get paid by the industry.

Seeley: Right. 80% of their budget comes straight from the industry. And that was the deal that Congress made, which is insane. It should be independently funded by the taxpayers, and it should be an agency that actually regulates. This is the most toxic substance in the whole history of the world here that they’re dealing with and trying to regulate. And well, if they regulate it, they’ll lose their jobs because they’ll shut down the nuclear plants. But don’t get me started.

Diablo’s Surplus Power Blocks Renewables

Seeley: Then there’s another issue, which is the fact that we don’t need Diablo Canyon to make enough electricity to keep our lights on. And that … I mean, this was sold to us or to the legislators by Gavin Newsom as the reason for keeping Diablo going, “Oh, if we don’t have Diablo Canyon, we’ll have blackouts.”

No, we won’t. The battery storage is coming on so strong right now, the solar – no matter … they’re trying to squelch it. But the solar and the wind and the hydro storage and all of the different flexible sources of electricity are there. And all Diablo Canyon does is prevent renewables from coming online. It’s a behemoth. It’s a dinosaur. We don’t want it. We don’t need it. And the reason … I mean, I don’t know exactly why they want to keep all these nuclear plants going the Department of Energy, especially having granted $1.1 billion to PG&E to keep this monstrosity going along with our $1.4 billion from the state of California. I mean, that’s quite a gift to PG&E.

Diablo Canyon is sitting there with these transmission wires that can be used for offshore wind. I know that’s controversial, but they’re planning on putting in 40 miles offshore giant wind turbines. And if those come online, they would, I think it’s 14,000 megawatts that they’re planning on putting online, which is four … No, seven times as much as Diablo Canyon produces. Diablo Canyon is 2200 megawatts. Wow. I never even thought about that. But they’ve got the transmission lines at Diablo Canyon to carry that power. And if it’s all clogged up with nuclear, it can’t be used for anything else, including solar. And then we have a lot of battery storage coming online right now, a tremendous amount in California. And even though the governor is fighting community choice energy, along with the utilities, community choice energy is going to prevail.

And in community choice, we use renewable energy. And this lie about nuclear power being a solution to a climate change because it’s carbon free, that is one of the most ridiculous arguments that I’ve ever heard in my life.

The Myth of ‘Emissions Free’ and ‘Carbon Free’ Nuclear Power

When you look at the nuclear fuel chain from the beginning, from mining and milling and enrichment and transportation and all that, just with the uranium. And then you get to the building with hundreds of millions of tons of cement and pipes and electrical wires and all that stuff – all that is horribly intensive with carbon. And then for a while, it doesn’t produce a lot of carbon, although it does produce radioactive carbon called Carbon 14, and it produces radioactive isotopes that go into that are in the steam that come out of it, and it heats the water because of the oceans and the rivers that it’s next to.

So, it contributes to warming because nuclear power is hot. It’s 5,000 degrees. That’s hot. And if you have something boiling at 5,000 degrees for 40 years, don’t tell me it hasn’t contributed to global warming. Right? And then you get to the point where you’ve got to tear the thing down and you have to haul out everything that’s been there, all the cement, all the wires. And the bonus is, it’s all contaminated with radiation! So, you have to find a place to put it, and there’s nowhere to put it. It’s insane. That’s all I have to say.

Why the Frenzied Push for Zombie Reactors and Unproven New Nukes?

Heddle: So finally, why do you think this orchestrated campaign for revival of

nuclear energy enthusiasm is going on?

Seeley: I think it’s about the weapons. I think it’s about the plutonium, because that’s where they get the plutonium from the nuclear plants and they need it to make more nuclear weapons and the depleted uranium bullets or shells, those horrible things, and they want to enhance our nuclear weapons. I think they’ve dedicated over a trillion dollars to revamping our nuclear weapons in this country, which is like, I don’t know. It’s enough to make you want to puke to think about the real motivation for this.

Brangan: There’s a connection between weapons and energy? Seeley: They started it.
Brangan: The commercial energy production?

Seeley: Well, yeah. That’s why they started commercial energy production. They started commercial energy production for the purpose of being able to harvest the plutonium and the highly enriched uranium, and I don’t know what other materials out of nuclear power plants in order to create this horrendous arsenal of nuclear weapons that they now want to enhance. They want to make the strategic nuclear weapons and the small nuclear weapons that will only contaminate 20,000 people instead of a million people. But you get enough of them, you can contaminate the entire world. It’s outright evil. Unfortunately, the Biden administration is 100% behind it.

Heddle: Nuclear weapons and nuclear energy are codependent?

Seeley: You can’t have one without the other. Yeah. Nuclear energy and nuclear weapons are married, and they have taken a vow. They can’t get along without each other. And so, this nuclear energy consortium that is pushing so hard right now, and it’s not only in the US, but also all over the world – they are in it for the weapons. It’s terrifying.

Heddle: So, the Mothers For Peace come full circle, right? You started out opposing the weapons and now you’re back.

Seeley: And we’re back. We’ve come full circle in the Mothers for Peace because we started as an anti-Vietnam War group. And then being posed with this Diablo Canyon plant here, we’ve been focusing for the past 40 years on Diablo Canyon. And now here we are again looking at the world’s situation and understanding even more deeply how connected nuclear weapons and nuclear power are. And we realize, and the anti-weapons people are also realizing what an integral part nuclear power plays in this. And so, we are coming together, and I think what’s happened is that we’ve all been so busy trying to squelch our own fires that we haven’t realized that our fire is dependent on their fire and vice versa. And so, we really have to come together during these next few years to help the public understand how deeply connected these things are.

A Call to Action. What Can Readers Do?

Heddle: So what needs to happen now, and how can people support that happening?

Seeley: Well, they can donate money to us for one thing. We have a donate button on our website at Mothers for Peace really needs donations. We have hired a raft of consultants. I’ll tell you the experts we’ve hired. We have hired our seismic expert. These are all fantastic people, and our materials engineering expert, who has been absolutely a treasure for us. We’ve hired someone who was the head of the Midwest Independence Systems Operator, analogous to California Systems Operator, which analyzes the energy needs, who is articulate and certain about this, that we do not need Diablo Canyon as part of our energy mix. In fact, it hurts our flexible energy supply in California.

We’ve hired experts, and they’re great experts. And we have our attorneys too, who give us a great rate, but it’s still super expensive. So, we have a donate button on our website, and we are grateful for every single donation that we get.

Brangan: Yeah. You’re doing this for everybody.

Seeley: We are. Oh, the other thing about Mothers for Peace is that we’re not paid. We are an all-volunteer organization. We don’t even have an office. And we work because we’re Mothers for Peace, because we want to protect the future generations. And we know that with nuclear power and the nuclear waste that’s produced with nuclear power, that it’s a threat to all the future generations.

Folks need to contact their state senator and their state assemblyman and assemblywoman. I think you should also get in touch with your local government, your city council, your board of supervisors, because we’re all downwind from Diablo Canyon.

And the local officials need to know that their constituents are concerned about this death threat. The government is interconnected, and they have relationships with the local assembly members and local senators too. So, I think that’s a good point of pressure that could be made.

Letters to the editor, those help those inform. Op-eds, there was a fantastic op-ed in the Santa Barbara independent this past week, just brilliant. Our local paper doesn’t tend to run op-eds that are disparaging or questioning PG&E and Diablo Canyon, though they run an occasional letter to the editor to keep it balanced, but you don’t see many op-eds about it.

What people can do is get in touch phone calls and letters to their state representatives, their assembly members, and their state senators – their local representatives, their board of supervisors, their city council. Go to the Mothers for Peace website. It is filled with information. It’s absolutely chock-full

Ed. Note:  A seismic assessment report is now on-track to be completed by January 2024, with details of the findings expected to be available for the public and the NRC around the first quarter of 2024. In a recent California Public Utilities Commission (CPUC) meeting on Diablo Canyon, Linda Seeley raised the following question: “If the seismic assessment report isn’t going to be submitted until the end of the first quarter in 2024, how can we make a rational judgment now about extending the life of Diablo?”
That question still hangs in the air...

James Heddle and Mary Beth Brangan are co-founders of EON – the Ecological Options Network. The EON production SOS – The San Onofry Syndrome: Nuclear Power’s Legacy received its World Premier at the Awareness Film Festival in Los Angeles, CA October 10, 2023, where it won the Grand Jury Award for feature documentary. SOS was directed by Heddle, Brangan and Morgan Peterson, who also served as editor.