ML13141A150

Comment (218) of Patricia Borchmann Opposing Action That Could Lead to a Restart of the San Onofre Nuclear Power Plant

ML13141A150
Person / Time
Site:	San Onofre
Issue date:	05/03/2013
From:	Borchmann P - No Known Affiliation
To:	Bladey C K Rules, Announcements, and Directives Branch
References
78FR22576 00218, NRC-2013-0070
Download: ML13141A150 (2)

Text

May 3, 2013 Ms Cindy Bladey U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 171

Dear Ms Bladey,

T]The comments that follow are regarding Docket ID NRC20130070.

We ask that the Nuclear Regulatory Commission (NRC) take no action FiV)could lead to a restart of the San Onofre nuclear power plant befor"-the Commission completes a comprehensive investigation and provides'-'

full opportunity for public participation and independent expert testimony.

't-.-o U)C/3 Southern California Edison (SCE) is attempting to shortcut the license review process by calling on the NRC to make a fast-track restart decision.

We and other environmental groups have joined with U.S.Senator Boxer and U.S. Representative Markey in urging the NRC not to follow such a course.We were deeply disturbed when on April 10 the NRC staff disregarded wll _J5 SJ5 numerous statements of concern and announced a "preliminary finding" that a San Onofre restart at 70% power posed no significant safety risk.We join a wide range of concerned citizens and public officials in believing that a full and transparent review of the failed San Onofre generators is essential before the NRC considers any potential restart at either partial or full power of the failed generator.

We support Senator Boxer, Chair of the Environment and Public Works Committee, who stated on April 10, 2013: "The NRC staff proposal, which could pave the way for the restart of the San Onofre nuclear power plant before the investigations of the crippled plant are completed, is dangerous and premature." Given the recent failure of tubes that carry radioactive water, speeding restart of San Onofre through a so-called "license amendment" that shortcuts procedures is totally inappropriate.

SCE's request to weaken its license requirements was made despite evidence showing that there could be a significant hazard from the operation of the deficient steam generators.

Given the troubled history and current condition of the plant and the raised level of public concern, the public deserves a full SITE SPECIFIC review by the NRC of conditions at San Onofre before it considers a restart of either failed generator.

I support the call by the Sierra Club for the NRC to block any restart of the failed San Onofre generators at this time, and to conduct a SITE SPECIFIC, comprehensive, evidentiary and open review process.The "DAB Safety Team" prepared an analysis of "Emergency Preparedness at San Onofre (dated April 2012). DAB Findings (p.2): "During the audit of 1Q12 DEP Objective Analysis Files and review of the April Emergency Planning Drill Results, it was discovered that adverse, and declining Drills/Exercise Performance (DEP) Indicator Trends are continuing (at SONGS), despite a Super Expensive Emergency Preparedness Management Reorganization, Change Management and Enhanced Shift Managers/Operations Crew Training." Extent of Conditions and Impact: (p.2 , 3)"With both SONGS units in shutdown due to leaks in Steam Generator tubes, SONGS Senior Management attention is focused on resolving this problem, and seeking NRC's permission to restart the units. With SONGS under NRC, INPO, SONGS Nuclear Oversight Board, Public and Media scruitny, Station cannot afford the luxury of dealing with adverse performance and publicity in Emergency Preparedness caused by declining SONGS Drill/Exercise Performance (DEP) indicator metric." E 0.0i 094)"A review (p.4) indicates that corrective actions (planned or completed) to date have addressed individual performance and technical issues in a piecemeal manner. Broader organization and technical issues designed to prevent DEP classification failures by Shift Managers/STA/Operations Crew have not been systematically addressed.

There has been a continuing decline since 2006 in which SONGS performance has been consistently in the fourth quartile.

Actions taken to date have not solved the performance issues.""This is a condition adverse to quality, a chronic problem that has persisted for more than 5 years. It is a major impact and challenges the safe reliable operation of the plant or personnel safety and reflects adverse organization and human performance behaviors.

This is a OPS/EP/NOD finding that warrants immediate actions on part of the SLT, and a Signficance Level I NN and a Root Cause Evaluation.(S0123-XV-50.CAP-2)." DAB Safety Team Conclusions on Emergency Preparedness (p.4).: "Improved Emergency Performance was observed in July 2012.However, this is cyclic, and unpredictable performance improvement, because SONGS Senior Leadership does not own the SONGS Emergency Prepared Program despite years of championing by Institute of Nuclear power Operations and SONGS Nuclear Oversight Board ..........

Last six years Emergency Preparedness Audits between 2006 and 2011 have been Adequate.

Out of the 4 Emergency Plan Drills conducted between April 2012 and August 2011, 3 have been ADEQUATE, and 1 has been UNSATISFACTORY.

SONGS SVP/CNO Pete Deitrich often publicly states with full confidence: "Public Safety is our Number One Priority and an Overriding Public Obligation".

Maybe he does not know the weakness of his own organization, or the RWO Leaders paint a rosy picture to him. According to insiders, one of the Best Shift Managers said, "I do not want to put my license on the line, and risk public lives, by Restarting Unit 2 "As-is". One of the Old and Long Time Plant Operators says, "These SONGS Managers are running this place like a 'Nazi Concentration Camp.SONGS has a long way to become an INPO 1 Plant and achieve"Edison's Vision" of Excellence in Regulatory Compliance, Fiscal Discipline, Plant Operations, and Emergency Preparedness.

All the Trainings, Six-week Leadership Academy, Be Here Now, Facilitative and Open Leadership and Crucial Conversations are a waste of Ratepayers funds, SONGS Workers and EIX Shareholders Money. Maybe it is time, EIX Chairman starts seriously thinking of retiring/firing the existing Senior Leadership Team w/700 SONGS employees in October. The Chairman will be well off by hiring a new Leadership Team which has the ability, training, and foresight to solve the SONGS chronic emergency preparedness, other safety, fire, maintenance and worker retaliation problems.

This way, EIX/SCE Management and Board of Directors can start the recovery phase of regaining the severely damaged and lost public trust by creating a safe, open and transparent environment for ALL parties.The history of SONGS Performance on Emergency Drills reflects repeated significant deficiencies over 5 years, with little improvement.

Thank you for your attention to these concerns.patricia borchmann escondido, CA 92026