ML13144A039

Comment (329) of Donald E. Mosier Opposing the No Significant Hazards Consideration for the License Amendment Application from Southern California Edison Proposing the Restart of the San Onofre Unit 2 Station

ML13144A039
Person / Time
Site:	San Onofre
Issue date:	05/02/2013
From:	Mosier D E - No Known Affiliation
To:	Bladey C K Rules, Announcements, and Directives Branch
References
78FR22576 00329, NRC-2013-0070
Download: ML13144A039 (2)

Text

RULES AND DIRECTIVES BRANCH USNqC May2, 2013 2 AY 21 AM 9:31 Cindy Bladey, Chief, Rules, Announcements, and Directives Branch (RADB), Office of Administration, RECFIVED Mail Stop: TWB-05-B01M, U.S. Nuclear Regulatory Commission, e(Washington, DC 20555-0001.

Re: Docket ID NRC-2013-0070

Dear NRC Staff:

I am writing to express my opposition to the "No Significant Hazards Consideration" for the license amendment application from Southern California Edison proposing to restart Unit 2 at SONGS at 70% power. I am a scientist at The Scripps Research Institute in La Jolla, CA, and a trained pathologist with experience in radiation exposure.

I wish to comment on the findings necessary to support the NSHC determination.

1. "involve a significant increase in the probability or consequences of an accident previously evaluated";

The design flaws that led to fluid elastic instability and in-plane tube vibrations in the unit 3 steam generator are also present in unit 2. SCE's own analysis cites a high probability of tube failure if unit 2 were operated at 100% power. The reduction in risk by operating at 70% is unknown.2. "create the possibility of a new or different kind of accident from any accident previously evaluated":

The extent of tube damage in unit 2 is unprecedented given it's short time in operation.

In plane tube vibration is also unprecedented, and tube support plates were not designed to prevent this effect. The probability of cascading tube failure and loss of cooling capacity has to be considered.

3. "involve a significant reduction in a margin of safety"; One tube failure in unit 3 was a significant warning sign. The possibility of multiple tube failures in unit 2 does pose a significant reduction in the margin of safety for the 8.5 million residents within 50 miles of SONGS.We now appreciate that low level radiation doses are more dangerous than thought in the past, and that concentration of cesium and iodine in the food chain followed by human ingestion is a much more dangerous form of exposure than airborne radionuclides encountered shortly after an accident.

For example, cesium levels in fish offshore of Fukushima remain very high (up to 25,000 Bq/kg) up to a year after the March 2011 disaster (1). Thus, any release of significant amounts of radiation from SONGS would have both immediate and long-term consequences, including an increased incidence of cancers associated with radiation exposure such as leukemias and thyroid cancer.SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= B. Benney (bjb) w t," As a research physician who performs studies with human subjects, I am very familiar with the risk:benefit analysis that is used by Institutional Review Boards to evaluate any research involving human subjects.

The risks must be minimal even if the benefits to the population are potentially large. The same criteria should be applied to this request to restart unit 2. The risk of harm to the large local population is not worth the benefit of the 700 mW of energy to be produced.

And the analogy is not flawed, because the restart proposal is an experiment to determine how serious further tube damage will be under the reduced power option, an experiment with an unknown outcome.I urge you to deny the license amendment request and proceed with the ongoing investigation of the faulty steam generator design that led to SONGS suspending operation in January 2012.Yours sincerely, Donald E. Mosier, PhD, MD 1. Buesseler, K.O., 2012. Ecology. Fishing for answers off Fukushima.

Science 338, 480-482.