ML13095A092

LTR-13-0262 - Coalition to Decommission San Onofre Ltr. Re Concerning of Safety of 8.5 Million Residents Living within 50 Miles of Defective San Onofre Nuclear Reactors, and the Economy of Southern California

ML13095A092
Person / Time
Site:	San Onofre
Issue date:	04/01/2013
From:	Gilmore D, Headrick G, Jahnkow C, Lutz R, Sullivan M, Vanthillo G Citizens Oversight, Earthkeepers San Diego, Peace Resource Center of San Diego, San Clemente Green, San Onofre Safety, Women Occupy San Diego
To:	Boxer B, Waxman H NRC/EDO, US HR, Comm on Energy & Commerce, US SEN, Comm on Environment & Public Works
References
LTR-13-0262
Download: ML13095A092 (2)

Text

Apr.01.2013 12:08 PM Apply Liberally Enterpris 2589475S08 PAGE. 1/ 2

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THE COALITION TO DECOMMISSION SAN ONOFRE The Honorable Barbara Boxer Chairman, Committee on Environmnent and Public Works -r United States Senate c -- o' Washington, D.C. 20510 6 1.j kiv Via Fax to: 202/224-1273 I OC_

OW The Honorable Henry Waxman Ranking Member, Committee on Energy and Commerce United States House of Representatives 2322 Rayburn House Office Building Washington, D.C. 20515 Via Fax io: (202) 225-4099 April 1, 2013

Dear Chairman Boxer and Ranking Member Waxinan:

in San The Coalition to Decommission San Onofre is comprised of community-based, grassroots organizations safety of 8.5 million residents living within 50 miles of the Diego and Orange Counties concerned for the defective Sar Onofre nuclear reactors, and for the economy of Southern California, These organizations include: Citizens Oversight, Earthkeepers San Diego, the Peace Resource Center of San Diego, San Clemente Green, SanOnofreSafety.org, and Women Occupy San Diego.

Today, wejoin with national, regional and California statewide organizations In asking for your of Its leadership to stop Southern California Edison's latest attempt to circumvent public scrutiny mismanagement of the defective San Onofre nuclear reactors.

nuclear We are deeply appreciative of your attention and leadership to date on issues related to the San Onofre we are very skeptical about reactors. Like many other organizations and individuals in Southern California, the Edison's recent announcement that they are considering a voluntary license amendment request. On organizations, local elected bodies surface, this seems to be exactly what we and other community-based and officials have requested. HOWEVER, we see It as no more than another end run around federal their regulations in order to expedite restart of their defective reactor, Specificaljy, Edison has indicated license amendment, similar to a intention to apply for a "No Significant Hazard Consideration" (NSHC) for this This is nothing more finding of"No Significant Impact" under the National Environmental Policy Act (NEPA).

than another regulatory loophole that Edison is attempting to slip through, Wc understand that an NSHC role and finding for this proposed license amendment would effectively strip the public of a meaningful under necessary independent experts in a formal license amendment hearing that we are guaranteed it federal law, and which we have demanded. If the NRC acquiesces to Edison's demand for such a finding, more than a dog and pony show; it could is unassailable - meaning any hearing that takes place would be no take place after the license amendment has been granted and would have no impact on the license amendment increase whatsoever - even if independent experts demonstrate that the amendment does pose more than a minor in the risk of an accident.

to get Unit 2 Edison President Ronald Litzinger said recently, "We want to do every responsible thing we can do to review the technical up and running safely before the summer heat hits our region. While the NRC continues the best materials we've submitted, we're considering a request for a license amendment so that we can pursue he refers are in-path to safe restart while avoiding unnecessary delays." The "unnecessary delays" to which regulations.

depth technical inquiries into the veracity of Edison's claims of safety and compliance with federal running by Edison is asking NRC staff to move the process for restart forward, so that they can be up and Its summer - during peak demand when profits are greatest - before the NRC has even completed technical review. How "res-ponsible" is THAT?

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Apr.01.2013 12:08 PM Apply Liberally Enterpris 8589475808 PAGE. 2/ 2 San Onofre hasn't been "the largest source of baseload generation and voltage support in the region," as Edison repeatedly claims, for 14 months and counting, and the CA Independent System Operator (ISO) says we'll do just fine without it for the second Southern California summer upcoming. For example, voltage support will be provided by retrofitting the retired, Edison-owned Huntington Beach power plant as a "synchronous condenser" -- thankfully, CA officials and the Federal Energy Regulatory Commission pushed through obstruction and this wise plan is being carried out for operation in June.

Per the CA Energy Commission, despite increased population and more appliances consuming power in homes and businesses, energy efficiency standards have helped keep per capita electricity consumption in California flat for the past 30 years. California's per capita electricity consumption has remained constant at approximately 7,000 kilowatt-hours/year (kWh) for the last 30 years due in large part to strict standards for homes and appliances. The rest of the U.S. has increased 40 percent (to roughly 12,000 kWh/year per person). And there is even more savings to be gained through additional advances in energy efficiency as well as conservation by users, Not to mention the boom in rooftop solar installations, with San Diego County leading the statc.

Edison needs to stop with the Chicken Little routine - the sky Is NOTfalling. The 21st CenturyL&just moving forward A rubberstamp finding of no significant hazard by the NRC would be wholly inappropriate for restarting a nuclear reactor that has two of the most damaged and defective steam generators in the history of the US nuclear industry -- the other two being in its twin reactor, Son Onofre Unit 3, which Edison admits are experiencing a globally unique tube damage phenomenon. This request on the part of Edison. is indicative of a corporate culture that sets aside safety concerns in the interest of expediency and profits - a culture that was clearly demonstrated by the revelations in the recently released MHI documents that showed they did just that when originally designing these defective replacement steam generators. Their desire to gamble on safety in order to rush forward for greatest profits placed the lives and livelihoods of the 8.5 million people living near these reactors at signIficant and unacceptable risk. Edison must not be allowed to do so again.

Lastly, the NRC has announced that a meeting between the NRC and Edison to discuss the license amendment and NSHC is to be held April 3 in Rockville, MD. it is fundamentally unacceptable to have this meeting to discuss such a critical issue on the opposite coast from the communities most impacted. The meeting ought to be held in Southern California where our neighbors and we can participate.

In sum, we respectfully request that in your critical oversight capacity, you ensure that the right of citizens to a full. adjudicatory public hearing required for a thorough license amendment process is upheld, that the NRC reject Edison's NSHC request, and that the upcoming meeting to address Edison's license amendment request take place in Southern California.

Sincerely, TIE eUBLITIOI TS 1180 lSl1BA III O lOlE Citizens Oversight: Ray Lutz, !A.)*..,! cn()Vcrsh'i.org / 619-820-5321

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Earthkeepers San Diego: Grace Van Thillo, grL(ac*),carthliak.ntL, /

Peace Resource Center of San Diego: Carol Jahnkow, ýjtr)U.ahnA.W_ i!:. cen, / 760-390-0775 San Clemente Green: Gary Headrick, gay(tt in.cennesreen,org / 949-218-4051 SanOnofreSafety.org: Donna Gilmore, donnaghI, ,gma/,oen / 949-204-7794 Women Occupy San Diego: Martha Sullivan, ni.ribu*/*,1,.iyuna. uvt. / 858-945-6273 Cc: Senator Diane Jelnsteln, via Fax to: (202) 228-3954 Allison M. Macfarlane.Chair of the U.S. Nuclear Regulatory Commission, 0ia Fax to: 301/415-3504 R. William Borchardt, ,'xecutive Directorfor Operations,NRC, via Fax to: 301/415-2162 Eric Leeds , Director,NuclearReactor Regulation, NRC, via Far to: 3011/415-8333 Arthur Howell, ReglonalAdmlnlsrrator,Region IV,NRC, via Fax wo: 617/200-1122 Daniel Dorman. Co-Chair.SONGS Oversight Panel.NRC, via 1ax to: 301/415-8333 2