ML13144A005
| ML13144A005 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/15/2013 |
| From: | Krom B City of Irvine, CA |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 78FR22576 00257, NRC-2013-0070 | |
| Download: ML13144A005 (4) | |
Text
Page 1 of 1 RULES AND DIRECTIVES BRANCH IJSNRC 2013 MAY 17 AN 9:09 PUBLIC SUBMISSION As of: May 17, 2013 Received: May 15, 2013 Status: Pending Post Tracking No. ljx-85cj-ucl 8 Comments Due: May 16, 2013 Submission Type: Web Docket: NRC-2013-0070 RECEIVED Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Comment On: NRC-2013-0070-0001 Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination; San Onofre Nuclear Generating Station, Unit 2
(ý/O,.3 Document: NRC-2013-0070-DRAFT-0159 7
5-7(
Comment on FR Doc # 2013-08888 Submitter Information Name: Beth Krom Address:
PO Box 19575 Irvine, CA, 92623 Government Agency Type: Local Government Agency: City of Irvine General Comment See attached file(s)
Attachments Beth Krom Comments on NRC-2013-0070 SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 Add= B. Benney (bjb) https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectId=09000064812e5f65&for...
05/17/2013
Bocth Krorn, (,ouncihriurner cityofirVil e~of (
ff
)
'f I o9,621 5
9
>49 46Y May 14, 2013 Brian Benney, Senior Project Manager SONGS Project Branch Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Docket ID NRC-2013-0070
Dear Mr. Benney:
As a public official in the City of Irvine, I am writing to express serious concerns regarding the proposed restart of one of the severely damaged San Onofre nuclear reactors. San Onofre is located between Orange County and San Diego, and given the potential for a major nuclear accident at San Onofre, there exists a significant risk to the millions of people throughout Southern California, including my constituents. For this reason, every precaution must be taken prior to restarting either of these identical damaged reactors. It is imperative that any decisions regarding the proposed restart of either San Onofre reactor be made with maximum deliberation and meaningful opportunity for input from the public, and that proper processes are upheld.
I recently learned that Southern California Edison, operator of the San Onofre reactors, has proposed to experiment with restart of the Unit 2 reactor for five months at reduced power, despite the fact that significant uncertainties remain. I am told the analyses submitted by Edison's own consultants to justify this restart plan not only conflict with one another regarding the cause of the wear, but do not provide assurance that another accident may not occur within months of restart. To restart a severely damaged nuclear reactor when the cause of the damage is uncertain, the time until another accident unclear, and the basis for the restart is reliant upon an assumption that this critical equipment will progressively destroy itself - even during reduced power operation -
puts the lives and livelihoods of my constituents at unacceptable risk.
I am further troubled that Edison chose to submit to the Nuclear Regulatory Commission a request for a license amendment that would relax the rules regarding the integrity of the degraded steam generator tubes -the very issue that led to the unexpected shut down of the reactors. This license amendment request ignores the multiple safety issues that must be addressed in a comprehensive license amendment process prior to any approval for restart of San Onofre reactor unit 2. These include:
144 T I ý ), 1ý I, ýi ( A,( A ý, ) I TJ I f I
May 14, 2013 Docket ID NRC-2013-0070 regarding steam generator tube integrity, the fact that future degradation and damage is predicted even by Edison's own experts, and the possible consequences for reactor safety; a the potential consequences of operating damaged unrepaired steam generators for other vital key safety functions of the San Onofre reactor, including reactor emergency core cooling systems; 4 the increased risk of accident, including release of significant radiation into the environment of Southern California, and the consequences for human health, including radiation dose rates, and the ability of emergency services to manage such a crisis;
- the earthquake risk to the degraded steam generators, including their ability to retain integrity in the event of a seismic event, and the consequences of an accident and release of radioactivity to the environment.
Edison has further asked the NRC to determine that this amendment involves "no significant hazards consideration." Before the NRC allows any proposed changes to San Onofre's operating license, the public deserves the safety questions to be fully addressed in a transparent hearing that allows testimony by local communities and third party experts. I hope you agree.
I am concerned that NRC staff has already issued a preliminary finding of no significant hazards consideration, with a final determination to be made some time in the next 5-6 weeks. I don't understand how such a finding would be justified if it is based on incomplete, contradictory safety analyses by Edison and would allow the restart of the Unit 2 reactor before any hearing was held. The public process should be neither side stepped or compromised. That the NRC is currently considering issuing a final determination of "no significant hazard consideration" suggests a complete disregard for the safety concerns of millions of people in Southern California, including the citizens I represent.
I have been advised that several nuclear experts have raised serious questions about the safety of Edison's proposed license amendment. These questions should be fully and formally examined and subjected to robust adjudicatory hearings. In addition, all on-going investigations that are directly related to the replacement of the San Onofre steam generators and in particular their design, and root cause of the severe wear must be completed. In this, I agree with the views expressed on these issues by Senator Barbara Boxer. There is no compelling reason to take major safety risks to help return an aging, heavily damaged nuclear reactor located in a seismic zone to 70% capacity.
Our lights in Southern California have stayed on for over a year without San Onofre, and the state has plans in place to ensure this continues.
May 14, 2013 Docket ID NRC-2013-0070 Edison's license amendment request and the NRC's proposal would deprive the public of an opportunity for a hearing before the NRC decides whether to issue the license amendment by issuing a "no significant hazards consideration" determination. This is unacceptable.
In closing, I ask that the process set forth for the protection of the health and safety of the public in all matters related to the operation of San Onofre not be abridged in any way, and I wish to express my full support for the submission of Friends of the Earth to this license amendment request, including their opposition to the NRC's determination of a no significant hazard consideration.
Thank you for your consideration.
Beth Krom City Councilmember City of Irvine cc:Senator Barbara Boxer Senator Diane Feinstein Governor Edmund G. Brown NRC Chairman Alison Macfarlane NRC Commissioner Kristine L. Svinicki NRC Commissioner George Apostokalis NRC Commissioner William D. Magwood IV NRC Commissioner William C. Ostendorff Eric Leeds, Director, NRC Office of Nuclear Reactor Regulation Michele Evans, Director, NRC Division of Operating Reactor Licensing Cindy Bladey, Chief, Rules, Announcements and Directives Branch