ML13308A751
| ML13308A751 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/29/1982 |
| From: | Nader R AFFILIATION NOT ASSIGNED |
| To: | Palladino N NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8203110454 | |
| Download: ML13308A751 (4) | |
Text
U.S. Nuclear Regulatory Commission 1717 H Street, N.W., 11th Floor Washington, D.C..20555 Nunzio J. Palladino,,Chairman
-3ohn A. -Ahearne, Commissioner 4MAR021982M' I
Peter A. Bradford, Commissioner gaMM Mal Victor Gilinsky, Commissioner Thomas Roberts, Commissioner ary 29, 1982
Dear Commissioners:
In my July 10 letter to you I raised several questions of safety significance regarding the operation of the San Onofre Nuclear Generating Station I (SONGS) and the licensing of SONGS II and III.
The concerns-expressed in that letter remain, especially in light of the recent accident at the Robert E. Ginna plant Monday, January 25.
My letter to you was treated by NRC Director Harold R. Denton as a show cause petition (10 CFR 2.206) and was denied. I have been informed by NRC Secretary Chilk that the date by which the NRC can act to change the Director's decision on my request to close down San Onofre I and initiate a licensee review is Feburary 5, 1982.
I hope that the issues raised in my initial letter and elaborated upon below will lead you to reverse that decision.
- San Onofre I has been identified as having the highest probability of a meltdown of any reactor in California, according to a study prepared by Science Applications, Inc., for the California Office of Emergency Services.
- San Onofre I has been cited by the NRC as one of 8 reactors thought to be most vulnerable to embrittlement and thermal shock.
- San Onofre I has one of the most severely degraded steam generators in the country and is almost identical to the Ginna plant.
The plant is currently held together by band-aid sleeves in almost 7,000 different places to prevent deteriorated steam tubes from leaking. This measure is at best a temporary one and highly suspect given the seismic activity of the region. There are far more serious accidents that could result from steam tube problems than the one that 6ccurred at Ginna; these include the disabling of the emergency core cooling system (ECCS) in a loss-of coolant-accident, potentially causing a meltdown.
8203110454 820129 PDR ADOCK 05000206 H
FDR
San Onofre/page 2 There exists a major fault only four miles from the San Onofre site known as the Off-Shore Zone of Deformation which is capable of generating an earthquake of at least 7.0.
Testimony presented at the Atomic Safety and Licensing Board hearings last summer and the Safety Evaulation Report indicate that 7.0 is likely to be a conservative figure.
In either case, it is doubtful whether San Onofre I could withstand such an earthquake. In denial of 1,560 citizen petitioners from California, who contested the adequacy of Unit I and II's design, the Cormiission noted that vital components at the plant are not built to the.67g seismic standard required. Unit I is only designed to meet a.5g ground movement and certain plant components are known not to reach even this standard. The NRC has already required the plant to do structural upgrading of its West Heater Platform and North Turbine Building by June 1, 1982.
Furthermore, claims that faults in the region are no longer active need to be reevaluated in light of the swarm of 20 relatively small earthquakes in early November. Additonal studies should be con ducted to see whether current estimates of the seismic volatility of the area underestimate the dangers.
- The operating record of the plant does not demon strate prudent management on the part of the utilities which operate it. This factor should be taken into account in both your consideration of the continued operation of Unit I as well as the licensing of Units II and III.
Specific examples include:
- 1. The July-September 1980 Report to Conqress on Abnormal Occurences (NUREG-0090, Vol. 3, No. 3) charged that deficiencies in equipment maintenance was responsible for the failure of a crucial salt water cooling pump and used a wrong backup pump to take its place. In addition, plant operators failed to shut the plant down as required during this very serious mishap.
- 2. Because of a radiation monitoring error during steam generator repairs in 1980, 66 workers were overexposed to radiation. A fine of $150,000 was subsequentally levied by the Commission.
San Onofre/page 3
- 3. The demonstration of the site's evacuation plan has be found to be "inadequate" by the Federal Emergency Management Agency.
- 4. A test of two crucial valves in the plant's emergency core cooling system (ECCS) on Septem ber 3, 1981 found them to be inoperable; it was subsequentally acknowledged that they had been out of service for an unknown amount of time.
Unit I is now required to shut down every three months to check the valves, thereby compounding the embrittlement problem of the reactor vessel.
- 5. The reactor vessel for San Onofre II was installed 180 degrees backwards and the foulup was not reported to the NRC until 7 months after it occured.
- 6. Sixteen of the utility's 18 trained operators failed the NRC's exam for senior reactor operators.
- 7. Workers have charged that the sleeving repairs to the Unit I's steam generators invol ved shoddy work.
Our own review of the record regarding San Onofre I leads us to believe that if this reactor is allowed to continue to operate, the public health and safety will be held hostage.
It is time that the Commission live up to its moral, let alone legal, obligation to protect the public. As mentioned in my previous letter, a plant's operating license, once issued, is not an inalienable right that cannot be revoked. Rather, it is a license, which is qranted under specific specifications and is subject to review and revocation if those standards are not met.
Similarly, the NRC should not be induced or pressured into licensing a plant that is poorly sited or inadequately designed just because it has been built. SONGS II and III, like Diablo Canyon, should not be started up because of the serious seismic and other problems known to exist there.
It is difficult to understand how the Commission can even consider licensing plants which have steam generator models known to be defective.
While much public and NRC attention has centered on another California plant, Diablo Canyon, the danger posed by the three
-units in San Clemente are comparably threatening. Nearly half the state's population (10 million) live within 100 miles of the site and the earthquake hazard is equally, if not more severe.
San Onof re/page 4 In light of the NRC's suspension of Diablo Canyon's low-power license, and Chairman Palladino's revealing remarks about the industry-wide problem of nuclear construction quality assurance-typified by the misoriented reactor vessel at SONGS II-it appears that at the very least an independent review of the two new-San Onofre plants is warranted.
An independent review must, of course, be done by a firm that is truly independent and has no conflict of interest.
Sincerely, Ralph Nader cc:
Governor Jerry Brown Rep. Jerry Lewis Senator Alan Cranston Rep. Bill Lowery Senator S. 1. Hayakawa Rep. Daniel E. Lungren Rep. Glenn M. Anderson Rep. Robert Matsui Rep. Anthony C. Beilenson Rep. Paul N. McClosky Rep. George E. Brown Jr.
Rep. George Miller Rep. Clair W. Burgener Rep. Norman Y. Mineta Rep. John L. Burton Rep. Carlos J. Moorhead Rep. Phillip Burton Rep. Leon E. Panetta Rep. Eugene A. Chappie Rep. Charles Pashayan, Jr.
Rep. Don H. Clausen Rep. Jerry M. Patterson Rep. Tony Coelho Rep. John H. Rousselot Rep. George E. Danielson Rep. Edward R. Roybal Rep. William E. Dannemeyer Rep. Norman D. Shumway Rep. Ronald V. Dellums Rep. Fortney H. Stark Rep. Julian C. Dixon Rep. William M. Thomas Rep. Robert K. Dornan Rep. Henry A. Waxman Rep. David Dreier Rep. Mervyn M. Dymally Rep. Don Edwards Rep. Vic Fazio Rep. Bobbi Fiedler Rep. Barry M. Goldwater Rep. Wayne Grisham Rep. Augustus F. Hawkins Rep. Duncan L. Hunter Rep. Robert J. Lagomarsino Rep. Tom Lantos