ML13144A016
| ML13144A016 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/14/2013 |
| From: | Agran L City of Irvine, CA |
| To: | Macfarlane A Rules, Announcements, and Directives Branch, NRC/Chairman |
| References | |
| 78FR22576 00268, NRC-2013-0070 | |
| Download: ML13144A016 (4) | |
Text
Page 1 of 1 1RULES AND DIRECTIVES BRANCH
-ilU As of: May 17, 2013 Received: May 15, 2013 Status: PendingPost PUBLIC SUBM ISSION 201 MAY 17 AN 9.
23 Tracking No. ljx-85cm-j6cc Comments Due: May 16, 2013 Submission Type: Web Docket: NRC-2013-0070 RFC F I\\/F D Application and Amendment to Facility Operating License*InvooVng 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
'q Document: NRC-2013-0070-DRAFT-0 173
-7 Comment on FR Doc # 2013-08888 0
Submitter Information Name: Larry Agran Address:
One Civic Center Plaza P.O. Box 19575 Irvine, CA, 92623-9575 Organization: City of Irvine Government Agency Type: Local General Comment See attached file(s)
Attachments Comments to Docket ID 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?objectld=09000064812e6eb 1 &for...
05/17/2013
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Allison McFarlane Chairman U.S. Nuclear Regulatory Commission Mail Stop O-16G4 Washington, DC 20555-0001 RE: Docket ID NRC-2013-0070 May 14, 2013
Dear Chairman Macfarlane:
In my capacity as an elected representative of the City of Irvine, I wish to express serious concerns regarding the proposed restart of the severely darnaged San Onofre Nuclear Generating Station's (San Onofre) nuclear reactors. In addition, I fully support and agree with the submission made by the Friends of the Earth to Edison's License Amendment Request, including Friends of the Earth's opposition to the Nuclear Regulatory Commission's (NRC) "no significant hazards consideration" determination.
Irvine is a city with more than 225,000 pennanent residents and a daytime population of nearly 400,000. Irvine is also only 22 miles away from San Onofre, which is well within the suggested 50-mile evacuation zone should a major nuclear accident occur at the site.
Needless to say, with the livelihoods of so many who live and work within Irvine at risk, the ongoing safety proceedings concerning the use of San Onofre are of substantial interest. And given the far reaching consequences of a major nuclear accident, every precaution must be taken prior to restarting either of the damaged reactors, not only for Irvine, but for the nearly 10 million people in Orange, Los Angeles, San Diego and Inland Empire Counties who also live within 50 miles of San Onofre.
Based on the proceedings and evidence presented to date - and the fact that Southern California's energy needs will continue to be met without San Onofre - there seems to be no compelling reason for the NRC to allow Edison to take major safety risks in order to restart an aging, decrepit, and heavily damaged nuclear reactor. At the very least, it is imperative that the public be given a meaningful opportunity to provide input before any decision regarding the proposed restart of either reactor at San Onofre is made.
Despite the well documented and ongoing problems at the San Onofre Nuclear Generating Station, Southern California Edison - the operator of the San Onofre Nuclear facility -- has proposed to restart the Unit 2 reactor for five months at reduced power. Yet, I have learned that significant uncertainties concerning the safety of the facility remain.
The analyses submitted by Edison's own consultants in support of this restart plan contradict one another regarding the cause of thie wear, and indicate that another accident may occur within months. Accordingly, it is unacceptable to put the lives of my constituents at risk when:
(1) the cause of the damage to the facility remains uncertain; (2) the basis for the restart is reliant upon an assumption that this critical equipment will progressively destroy itself; (3) it is unclear whether further degradation of the steam generator tubes will impact the emergency core cooling system; and (4) it is unclear whether the facility, and steam generator tubes in particular, will be able to withstand a significant seismic event.
Considering these and other issues, it is troubling that Edison chose to submit a request for a narrow license amendment to the NRC that would relax the rules regarding the integrity of the degraded steam generator tubes, because that is the very issue that led to the unexpected shutdown of the reactors in the first place. This narrow License Amendment Request by Edison ignores the multiple safety issues that can only be addressed in a comprehensive license amendment process prior to any approval to restart the San Onofre reactor.
In addition, it is my understanding that the NRC has already issued a preliminary finding of"no significant hazards consideration," with a final determination to be made some time in the next 5 or 6 weeks. And should the NRC grant a no significant hazard consideration, any public hearing on the merits of the license amendment request will be held after the license amendment has been granted - essentially rendering the subsequent hearing meaningless. In light of the fact that several nuclear experts have raised serious questions about the safety of Edison's proposed License Amendment, a formal hearing process is absolutely necessary to examine the remaining concerns. It is inexplicable how the NRC could have made a preliminary determination based on Edison's own incomplete and contradictory safety analyses.
Finally, all ongoing investigations that are directly related to the replacement of the San Onofie steam generators, in particular the design of the system and cause of the severe wear, must be completed. In this regard, I agree with the views expressed by Senator Barbara Boxer.
In sum, Edison's requests for a narrow License Amendment Request and "no significant hazard consideration" should be rejected. My constituents and the rest of those who call Southern California home deserve the protections afforded by a fair and rigorous hearing that this issue warrants.
Sincerely, La" n
Cty C Incilmny ber City f h-Vinle CC: Senator Barbara Boxer Senator Diane Feinstein Governor Edmund G. Brown 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