ML13144A012
| ML13144A012 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/15/2013 |
| From: | Zahn P - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 78FR22576 00264, NRC-2013-0070 | |
| Download: ML13144A012 (4) | |
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,RULES AND DIRECTIVES BRANCH USNRC As of: May 17, 2013 Received: May 15, 201 Status: PendingPost PUBLIC SUBM ISSIONo* MAY 17 AM 9: 2 1 Tracking No. ljx-85cl-Comments Due: May Submission Type: Wel 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
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Document: NRC-2013-0070-DRAFT-0167 Comment on FR Doc # 2013-08888
-T(Wcý0/3 7 2 57 7ý Submitter Information Name: Peter Zahn Address:
P.O. Box 662 Solana Beach, CA, 92075 General Comment See attached file(s)
Attachments Public Comment letter on License Amendment-Benney SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 Add= B. Benney (bjb) https://www. fdms.gov/fdms-web-agency/component/contentstreamer?obj ectld=09000064812e6d9e&for...
05/17/2013
Peter Zahn P.O. Box 662 Solana Beach, CA 92075 May 15, 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 M/lr. Benney:
I am a City CouLcilmember in Solana Beach. California, writing to express my personal views.
My family and I live about 30 miles from the severely damaged San Onofre nuclear reactors.
We. along with many others in our community, are worried about our safety in the event either of the two reactors is restarted.
Given the massive impact to life and property if there is a major accident, we insist on a transparent process that affords substantial public input prior to any restart.
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. However, significant uncertainties remain. The analyses submitted by Edison's own consultants to purportedly support 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 family and fellow residents at enormous 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 liccnse amendment request unfortunately ignores the multiple safety issues that should be addressed in a comprehensive license amendment process prior to any approval lor restart of San Onofre reactor unit 2. These include:
Mr. Brian Benney May 15, 2013 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; 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;
" 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.
The Atomic Energy Act, which governs the NRC and these issues, guarantees the public the right to a full adjudicatory hearing during licensing proceedings. The no significant hazard determination is to be only used for routine license amendments. It would be wholly inappropriate for the NRC to make such a determination in this case -which then circumvents the required thorough process --given the issues outlined above and the unique and severe damage in San Onofre's nearly brand new replacement steam generators.
.1 understand the 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 am deeply concerned about this proposed determination, because it would, based on, incomplete, contradictory safety analyses by Edison, allow the restart of the Unit 2 reactor before any hearing was held. Thus the hearing would be rendered essentially meaningless. That the NRC is currently considering issuing a final determination of "no significant hazard consideration" is to disregard the safety concerns of millions of people in Southern California, including the citizens I represent.
Several experts have raised serious questions about the safety of Edison's proposed license amendment. These questions should be Fully and fbrmally 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. On this point, 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.
I understand that we will have reduced energy capacity in Southern California, but I am encouraged by recent moves to fill in at least a part of'the shortfall from other sources. Public safety must remain the paramount consideration.
Mr. Brian Benney May 15, 2013 Edison's license amendment request and the NRC's proposal would deprive the public opportunity for a hearing before the NRC decides whether to issue the license amendment by issuing a "no significant hazards consideration" determination. The NRC should rebuff these actions.
Finally., I would like to associate myself and express my full support Ibr and agreement with the submission of Friends of the Earth to this license amendment request, including their opposition to the NRC's determination of a no signi licant hazurd consideration.
Sincerely.
Peter Zahn 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 NR.C Commissioner William C. Ostendorff Eric Leeds. Director, NRC Office of Nuclear Reactor Regulation Michele Evans, Director, NRC Division of Operating Reactor Licensing Cindy BladeyI, Chief. Rules, Announcements and Directives Branch