ML13325A055
| ML13325A055 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/10/1981 |
| From: | Mcmullin B, Nader R, James Smith AFFILIATION NOT ASSIGNED, CENTER FOR PROGRESSIVE LAW |
| To: | Bradford P, Gilinshy V, Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML13308A734 | List: |
| References | |
| NUDOCS 8112080123 | |
| Download: ML13325A055 (5) | |
Text
OU.S.
Nuclear Regulatory Commission 1717 H Street, N.W., 11th Floor Washington, D.C.
20555 Nunzio J. Palladino, Chairman Victor Gilinsky, Commissioner Peter A. Bradford, Commissioner John A. Ahearne, Commissioner July 10, 1981 Gentlemen:
It has been over a year and a half since the Kemeny and Rogovin Commissions published their sharp criticism of the Nuclear Regulatory
.Commission's (NRC) approach to regulating nuclear power. Investigating the accident at Three Mile Island, both groups concluded that the NRC's attitude of promoting nuclear energy and protecting the nuclear industry had had a negative impact on public safety.
Despite these strong indictments, however, the NRC has returned to the same "business as usual" attitude that characterized its pre-TMI behavior. Perhaps nowhere is this attitude more obvious than in the case of the San Onofre atomic facility, to which I would like to call your attention.
The San Onofre Nuclear Generating Station (SONGS) is situated in a seismically volatile and densely populated area of Southern California, making it among the most ill-conceived and dangerous nuclear power plants in America. Yet, the NRC's Atomic Safety and Licensing. Board (ASLB) contiuJes to push ahead in its efforts to license San Onofre Units II and III, while ignoring the extremely serious safety issues surrounding the continued operation of Unit I:
- 1) San Onofre Unit 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.
- 2) The Newport-Ingelwood Fault, only four miles offshore, is capable of a 7.5 magnitude earthquake, according to the U.S. Geological Survey. A 7.5 magnitude quake is ten times greater than the 6.5 magnitude quake that San Onofre Units II and III are theoretically capable of withstanding. By comparison, Unit I is designed only to withstand a 5.0 magnitude seismic event!
- 3) Half the population of California would be affected by a serious accident at San Onofre. 10-12 million people live within 100 miles of the plant..
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- 4) No workable or demonstrated evacuation plan exists for even the immediate 10 miles surrounding the plant.
Typically, 25,000 people populate the San Onofre State Beach during the summer months. These people would be stranded in the event of a serious accident, because the only evacuation road passes right by the plant.
- 5) A June review by the Federal Emergency Management Agency (FEMA) concluded that the demonstration of the evacuation.
planning is "woefully inadequate." By the NRC's own reckoning (NUREG-0490) a meltdown accident at San Onofre could cause up to 130,000 acute deaths, and another 300,000 latent fatalities. Property damages, according to Science Applications, Inc., could be as high as $180 billion.
New seismic information, unavailable in 1969 when Unit I was licensed, underscores the gravity of the situation.
In 1980, a new fault zone, the Christianitos Zone of Deformation (CZD) was discovered and mapped by the U.S.
Geological Survey at the request of the NRC. Traces of both this fault and the Newport-Ingelwood fault pass precipitously close to the plant. Had this information been known in 1969, it is doubtful that the AEC could or would have licensed'the Unit I reactor.
Furthermore, the Unit I reactor is plagued with very serious safety problems. In operation over 13 years, it was shut down in April, 1980 due to severe leakage and corrosion in its steam generators. Pacific Gas and Electric claims that the damage has been corrected through the use of an un precedented plugging and sleeving process, but even the NRC admits that the
$67 million operation was "highly experimental." This means that Unit I is not only externally incapable of withstanding a serious quake produced by the Newport-Ingelwood fault, but that internally it is highly susceptible to any -major ground motion. These conditions, in such a densely populated area, are -harly intolerable.
It is time for the NRC to live up to its legal, as well as moral, re sponsibility, which is quite simply to regulate nuclear power in order to protect public health and safety. The circumstances that led to the licensing of Unit I in 1969 are no longer applicable today. New seismic dangers have been uncovered, the population has grown at an astounding rate, and the reactor's equipment is deteriorating. An operating license, once issued, is not an inalienable right that cannot be revoked. Instead, it is like a driver's license, which is granted by the NRC under certain con ditions, and is subject to periodic review and possible revocation.
I urgently request that the commissioners initiate a license review for San Onofre Nuclear Generating Station Unit I, and that, until such time as a review has been completed, operation of Unit I be suspended. Over 1,500 concerned residents of Southern California have petitioned the Director of Nuclear Reactor Regulation of the NRC between 1979-1980 to initiate proceedings pursuant to 10 CFR 2.202 and 10 CFR 55.40 for the purpose of suspending or revoking the operating license for.the San Onofre Nuclear Generating Station Unit I. They have not, as yet, received a reply.
,.I1y 10, 1981 Given the gravity of the issues surrounding.the facility in question and in accordance with the petitioners, I respectfully request prompt action be taken to address these crucial matters. Failure by the NRC to take action will not only confirm the widespread suspicion that the agency has failed to correct its mistakes of the past, but more importantly, will en danger the security of millions of people living in Southern California.
Sincerely, Ralph Nader cc:
Gov. Jerry Brown
r-.ST FOR ITNST3TULON OF PROCD11N1 GS TO REVOKE OPER'-.TING LICENSE, 10 CFR42.206 TO:
Director of Nuclear Reactor Regulation W~nited States Nuclear Regulatory Conmission a concerned and interested resident of,outhern Cal fozia,. who ray be adversely affected by the unit' s continued crerating, I,.
request the Director of Nuclear Reactor Regulation to iniiiate a proceeding pursuant to 10 CFR 2.202 and 10 CFR 55.40 for the purpose of suspending ar revoking the operating license for the San Onofre Nuclear Generating Station Unit One.
New and relevant information is new available on potential ground notions at the site in the event of an earthquake, and this information would have warranted the Co-mission to have refused to grant a license on the original application.
Furthernore, the plant is 1ccated midway between Los Angeles and San Diego, one of the nost densely populated and fastest grcwing areas in the country.
Unit I is not designed to withstand possible ground notions from earthquakes on the Newport-Inglewood and Christianitos faults and their-branches which pass close to the reactor.
These ground notions could break cooling water pipes, cause a loss of coolant accident, and lead to a mltdcun of the fuel rods.
The addition of a concrete shell to the reactor dome and other nodifications are inadequate to insure against damages frcm -possible ground notions during a aximum possible earthquake.
The new and relevant information regarding ground notion potential was unavailable when the AEC approved the design criteria of Unit I or later when the NRC approved structural changes to.the unit.
Seismic design criteria for Unit I was based on inadequate data on surements of ground notions close to the source -of the earthquakes.
Recent Cinrnia earthquakes near Santa Barbara in August, 1978, near San Jose in August, 1979, anW Inperial Valley in October, 1979, have revealed new and relevant information about ground niotions that was not available to the NRC for determining seismic design criteria for Unit I.
The Livermore earthquake of January. 1980 made seismic focussing an issue relevant to San Onofre' s earthquake hazards.
Because population growth near the San Onofre plant has been nore rapid and ex tensive than could have been anticipated during the licensing of Unit-I, there are no acequate evacuation plans for the area's residents in the event of a loss-of coolant accident.
Approximately nine million people live in the area that could be affected by the accidental release of radioactive gases frcn Unit I.
The State and local govern rents are not prepared to evacuate the population within the short tihe between the accident and the spread of radioactive gases.
The Rogovin report to the NRC on Three Mile-Island accident reccommended that old reactors near major cities (like San Onofre) should be shutdown until Evacuation Plans are realistic.
For the above rgasons, and theassociated risks to the health and safety of the people of Southern California, it is inperative that you take action to suspend or revoke the cperating license for San Onofre Nuclear -Generating Station Unit I.
Signed on this date,
.1980
/
(signature)
(mailig addres's)
(city, state, zip code)
REQUST FOR INSTITUTIO OF PROCEEDNGS TO REVOKE OPERATIG LICENSE, 10 CFR 2.206 q O: Director of Nuclear Reactor Regulation United States Nuclear Regulatory Corrmission As a concerned and interested resident of Southern California, who ray be adversely affected by the unit's continued operating, I i Frre S
, request the Director of Nuclear Reactor Regulation to initiate a roceeding pursuant to 10 CFR 2.202 and 10 CFR 55.40 for the purpose of suspending or revoking the operating license for the San Onofre Nuclear Generating Station Unit One.
New and relevant information is now available on potential ground motions at the site in the event of an earthquake, and this inforration would have warranted the Commission to have refused to grant a license on the original application.
Furthermore, the plant is located midway between Los Angeles and San Diego, one of the most densely populated and fastest growing areas in the country.
Unit I is not designed to withstand possible ground rrotion~s from earthquakes on the Newport-Inglewood and Christianitos faults and their branches which pass close to the reactor.
These ground motions could break cooling water pipes, cause a loss of coolant accident, and lead to a meltdown of the fuel rods.
The addition of a concrete shell to the reactor dome and other modifications are inadequate to insure against damages from possible ground motions during a maximun possible earthquake.
The new and relevant. information regarding ground motion potential was unavailable when the AEC approved the design criteria of Unit I or later when the.NRC approved structural changes to the unit.
Seismic design criteria for Unit I was based on inadequate data on measurements of ground motions close to the source of the earthquakes.
Recent California earthquakes near Santa Barbara in August, 1978, near San Jose in August, 1979, S
and in Imprerial Valley in October, 1979, have revealed new and relevant information about gccund motions thiat.ws not available to the NRC for determi. sing-seismic design criteria for Unit I.
Because population growth near the San Onofre plant has been more rapid and ex tensive than could have been anticipated during the licensing of Unit I, there are no adequate evacuation plans for the area's residents in the event of a loss of coolant accident.
Approxixrately nine million people live in the area that could be affected by the accidental release of radioactive gases from Unit I.
The State and local govern ments are not prepared to evacuate the population within the short te between the accident and the spread of radioactive gases.
When the AEC issued the construction permnit in March of 1964, it was imossible to know the population of the region whould increase so rapidly.
For the above reasons, and the associated risks to the health and safety of the people of Southern California, it is imperative that you take action to suspend or revoke the cperating license for San Onofre Nuclear Generating Station Unit I.
Signed on this date,
, 1979.
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