ML13155A056
| ML13155A056 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/15/2013 |
| From: | Heebner L - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 78FR22576 00552, NRC-2013-0070 | |
| Download: ML13155A056 (4) | |
Text
I Jodsten, Sandy From:
Sent:
To:
Subject:
Attachments:
Lesa Heebner [lesaheebnercouncil@me.com]
Wednesday, May 15, 2013 3:46 PM CHAIRMAN Resource; CMRSVINICKI Resource; CMRAPOSTOLAKIS Resource; CMRMAGWOOD Resource; CMROSTENDORFF Resource; DianneFeinstein@feinstein.senate.gov; christhompson@feinstein.senate.gov; Barbara Boxer@boxer.senate. gov; lauraschiller@boxer.senate. gov; governor@gov.ca.gov; Ken Alex; cliff.rechtschaffen@gov.ca.gov RE: Comment letter to NRC on SONGS License Amendment Letter on License AmendmentBenney.doc
- Attached and copied in below is my comment letter to the NRC on the San Onofre License Amendment.
Thank you for your consideration.
Sincerely, Lesa Heebner, Councilmember City of Solana Beach; SANDAG Board member; Vice Chair SANDAG Regional Planning Committee; Vice Chair San Dieguito River Valley Joint Powers Authority 411[b/a'0 3 858 922 3434 cell 7
858 755 7757 office 858 777 3531 fax FOR ALL NON-CITY RELATED ISSUES, PLEASE CONTACT ME AT:
LesaHeebnerl(&me.com FOR ALL CITY-RELATED ISSUES, PLEASE CONTACT ME AT:
LesaHeebnerCounciliiame.com Brian Benney, Senior Project Manager SONGS Project Branch Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission F~
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Washington, DC 20555-0001 RE: Docket ID NRC-2013-0070 SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 Add= B. Benney (bjb) 1
Brian Benney, Senior Project Manager SONGS Project Branch ifi Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation
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Washington, DC 20555-0001
":7 RE: Docket ID NRC-2013-0070 May 15 2013
Dear Mr. Benney:
As a City Councilmember of Solana Beach, I write to express my deep concerns regarding the proposed restart of one of the severely damaged San Onofre nuclear reactors located between Los Angeles and San Diego. Given the potential for a major nuclear accident at San Onofre, which risks causing serious harm to millions of people in Southern California, including my constituents, every precaution must be taken prior to restarting either of these identical damaged reactors. A major accident at San Onofre could have far reaching consequences. It is, therefore, all the more imperative to me 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.
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 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 unfortunately ignores the multiple safety issues that should be addressed in a comprehensive license amendment process prior to any approval for restart of San Onofre reactor unit 2. These include:
,- the fact that future degradation of the integrity of the steam generator tubes is predicted even by Edison's own experts, which carries consequences for reactor safety;
the potential consequences of operating damaged unrepaired steam generators which would impact 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 subsequent 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 would then allow circumvention of 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.
I 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.
I am concerned 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.
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 not take these actions.
- Regards, Lesa Heebner, Council member City of Solana Beach, approximately 30 miles from SONGS 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