ML14246A562
| ML14246A562 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/02/2014 |
| From: | Magda M Public Commenter |
| To: | Macfarlane A, Michael Orenak, Thomas Wengert NRC/Chairman, Plant Licensing Branch IV |
| Shared Package | |
| ML14246A564 | List: |
| References | |
| LTR-14-0500 | |
| Download: ML14246A562 (5) | |
Text
Joosten, Sandy From:
Sent:
To:
Subject:
Attachments:
Dear NRC Representatives,
Marni Magda <marnimagda@gmail.com>
Tuesday, September 02, 2014 5:26 PM Wengert, Thomas; Orenak, Michael; CHAIRMAN Resource Please deny SCE request for change of decommissioning Trust funds from Spent fuel management August 28 2014 CEP concerns after the meeting about the PSDAR DCE EIE.docx Please find attached my response to the SCE PSDAR, DCE, and EIE draft plans for Decommissioning SONGS.
They are seriously flawed. I ask in the name of the 8.4 million people who live in and love Southern California that you deny the use of the SONGS Trust Fund for any purpose other than management of spent nuclear fuel until the fuel is removed from the SONGS reactor site. I am not a scientist, but I have listened carefully at all of your and SCE meetings on Songs since March 2011. Please make my attached letter part of the public record on concerns about the Decommissioning of SONGS.
Best Regards, Marni Magda 949 230 9181 marnimagda@gmail.com 1
August 28, 2014 Response after the CEP Meeting about the PSDAR DCE and EIE Submitted by Marni Magda marnimagda@gmail.com The CEP and the public have serious concerns about the current SCE drafts of the Post Shut Down Action Report (PSDAR), the Decommissioning Cost Estimate (DCE), and the Environmental Impact Evaluation (EIE) presented at the CEP Meeting August 28, 2014.
(The fourth critical document, Irradiated Fuel Management Plan (IFMP), is not yet a public document.
The owners are going over it still.)
The timelines and Trust Fund Expenditures for Decommissioning SONGS are in reverse order for insuring the public safety.
SCE plans to remove everything on the SONGS site except the spent fuel within twenty years. They have asked the NRC to approve Trust Fund money be diverted from its primary purpose, spent fuel management which currently could only be used on spent fuel management. Three billion dollars is set to be used to clear the land of everything except the dangerous fuel. That means not just the reactor domes, but removal of all protection including security fences, rail road spurs, parking lots, the seawall and pedestrian walkway will all be gone by 2032. Only one billion dollars will be used to manage the 1632 tons of deadly fuel that by NRC regulation may be abandoned on site at San Onofre until 2073 unless "non-generic" problems are identified. SCE's DCE has $7665 per year set aside for the fuel inspection and security of the spent fuel dry storage, but only until 2049. The ISFSI pad for the 150 nuclear fuel canisters needs to be built away from the ocean and 8.4 million people with a defense in depth building surrounding it as other countries have done, with security surveillance and railroad tracks for moving the nuclear waste as soon as the DOE has a place for it. The $4 billion in the ratepayers Trust Fund must be used for safety of the spent fuel until 2073, not the cosmetics of a green bluff in a military base with no traces of SONGS except the deadly fuel abandoned there. SCE hopes the DOE will remove the spent fuel so the ISFSI pad can be removed. There is zero money in the budget after 2052 to inspect, fix, or guard the deadly canisters and the DOE has until 2073 to take it.
The 50 dry storage canisters now at San Onofre on a cement, above ground pad are only guaranteed for twenty years. SCE is set to purchase the same type for the 100 canisters that will hold the remaining high burn up spent nuclear fuel that is currently in the spent fuel cooling pools. The Nuclear Regulatory Commission NRC admits salt water corrosion could cause dangerous cracks in the 5/Sth inch stainless steel canisters within 30 years.
There is great concern on the CEP and the public in attendance over the speed of SCE decisions about the dry canisters that will be used to store the spent fuel in San Onofre possibly until 2073. The spent fuel pools that are not "defense in depth" protected are a reason to begin as soon as possible to move the fuel to dry storage. However, SCE has only two companies bidding on dry storage canisters and both vendors propose 5/8th inch stainless steel canisters with no inspection possible of interior radiation heating once the canister is sealed. Both vendors plan a minimal covering of the dry storage area that will not protect against decades of salt water corrosion. SCE wants to decide on the canisters contract
by September 2014. They need to open the bidding to competing systems from other vendors. The NRC needs to work to help this be possible.
The first stainless steel canisters were used for dry storage in the United States in 1989. Therefore, the time to test the canisters has been small considering they need to last for thousands of years. The Navy has "final deposit" transportable casks for monitored retrievable storage (MRS). The public deserves that the Trust Fund money is used to buy the best canisters that exist. The canisters SCE plans to buy will be certified only for 20 years and don't fill this vital need.
On site at San Onofre today are 50 dry storage canisters of the type SCE plans to purchase. They have been filled with Unit 1 spent nuclear fuel for 10 years. They will come up for recertification in 2023.
Tom Palmisano of SCE admitted no canister has been pulled out of its cement casing for inspection since they were stored in the cement casing. He admitted that the cement beehive like holding system for the canisters is cracking in places at San Onofre. This is the system SCE plans to use when it abandons 150 dangerous nuclear canisters on a cement pad on top of the old Unit I substructure in 2032, with all other structures removed. There will be no building surrounding the fuel for safety and no rail road or any road to assist in removal by the DOE or in case to catastrophe. SCE shows 2048 as the date the DOE will remove the fuel. No funds remain after that in case of accidents, crumbling cement or salt corroded canisters that may crack within 30 years under such conditions. Tom Palmisano said the owners are working on an aging fuel management inspection plan, but none are indicated in the current drafts of the PSDAR, DCE or EIE.
SCE and the NRC have determined in their Environmental Impact Evaluation (EIE) that San Onofre has no environmental risks as it is being decommissioned, but that report was completed based upon the guidelines that the DOE was going to take the spent fuel away from the reactor. San Onofre must have a new EIR based upon San Onofre being made a nuclear waste deposit location until 2073.
The EIE states that San Onofre decommissioning has no environmental impacts over "Small" in concern.
It states the site fits (GElS) generic NRC guidelines just the same as all 104 reactors in the US. Nothing is unique about the San Onofre decommissioning concerns. It is the same requirements as decommissioning a reactor in Nebraska. When questioned by the audience who found it hard to believe the report that no area of impact was "Moderate" or "Large," CEP Moderator David Victor said it probably was because the Moderate and Large impacts were settled when the reactors were approved and built and running --this will be about taking it down so there are not new problems.
However, there are significant and potentially catastrophic new problems that must be mitigated. The NRC in 2014 created the new regulation guidelines for its generic nuclear waste for decommissioning US commercial reactors. It allows spent nuclear fuel to remain above ground in dry storage canisters at all 104 reactor sites for 60 years after the nuclear reactors are shut down unless there are specific geographical problems to a location that don't fit a generic NRC shut down. When Units 1, 2 and 3 at San Onofre came on line, the DOE was responsible for taking the spent fuel away from the reactors to a government storage facility. We need a new look at all of the environmental impacts for Songs decommissioning based upon spent nuclear fuel remaining on site until at least 2048 and probably 2073.
Leaving spent fuel on site when a reactor is shut down is a new NRC solution to the problem of not having a place for the DOE to store the spent nuclear fuel since.Yucca Mountain was shut down, ending the hope of a US spent nuclear fuel repository. Abandoning the spent fuel at the reactor site for up to sixty years was never foreseen in 1983 when the units 2 and 3 came on line. This new reality requires new analysis.
Over 8.4 million people now live within a fifty mile range of the planned abandoned spent nuclear fuel which is lethal for tens of thousands of years. The accepted evacuation plan of 40 years ago is a deadly fantasy today. (In case of disaster Laguna residents are to stay in their homes while the closer residents of San Clemente and Dana Point evacuate to Costa Mesa.) The EIE can't have been created based upon the new fact that spent nuclear fuel will now remain in dry storage on site instead of being removed every year by the DOE which was still believed to be the solution when unit 1 was shut down in 1992.
A new EIE must be demanded checking the geological stability ofthe land where the new expanded ISFSI pad will be rest on the old reactor Unit 1 substructure. And though 40 years ago the seismic study may have allowed the reactor of Unit 1, new science demands a closer look at the substructure left 3 feet under grade. Assessment of seismic safety with the discovery in 1999 of the San Joaquin Hills Fault nearby and the big earthquake overdue, make it necessary to seek a new EIE. Besides earthquake zone considerations that make it impossible that San Onofre is a generic decommissioning location include that the site has more deadly firestorms each year due to increased housing developments in the surrounding wilderness scrub, new scientific data predicts rising ocean levels and increased storms with tsunami potential and terrorism is sadly more likely than in 1983. Salt air corrosion makes the current EIE obsolete because of known cracking problems for stainless steel canisters. There will no longer be any "Defense-In-Depth" protection for the spent fuel abandoned on a platform in dry storage canisters.
Amazingly, as this is being written, according the Chairwoman MacFarlane, the NRC is just now working to revise its security regulations on abandoned spent nuclear fuel at reactor sites above ground, allowing less security because without the reactors the risk is reduced.
SCE continues to say it puts public safety before profit, but their decisions continue to refute that idea. A new EIE must be demanded.
Picture San Onofre in 20 years, 2034. All structures and employees will be gone, leaving a grassy knoll above the ocean except for the cement pad holding the 150 deadly spent fuel dry storage canisters that the NRC demands only be inspected every five years by pulling only one canister from all of the reactor sites to see if any damage has happened. And if there is a leak, the nuclear industry has not yet developed a means to fix it.
There is one exception to SCE's fast removal of all structures at SONGS. They petitioned and expect to be allowed be to leave in the ocean the Unit 2 and 3 intake and outtake conduits that were used for cooling in the reactors and the spent fuel. Their reasoning is that Unit 1 pipes remain since it was shut down in 1992. SCE was given permission by the California State Lands Commission to leave them as a less destructive environmental impact than removal. However, Tom Palmisano did admit when asked that the pipes did have radiological discharge during their thirty years of use using over a billion gallons
of ocean per day and discharging it back into the ocean 10 degrees hotter and radioactive. The California State Lands Commission will decide ifthis cost saving plan will be best for the ocean. The Calif. Environmental Quality Act CEQA process will begin in the 4th quarter. The public and the CEP need a clear date for this controversial request to be made to leave the pipes which are 30 years old, 18 feet in diameter, extended over 1200 feet into the ocean. CEP member Garry Brown of Coastkeeper said of the decision to leave the Unit 1 pipes in the ocean that science has come a long way since 1992. No one has tested the pipes for radiation contamination or taken pictures to determine if there is a growing sea.
environment around the pipes in over thirty years. In that time science has advanced. It is essential that San Onofre gets an EIE that reflects the dangers we now understand that were not available 40 years ago when the nuclear industry believed any day a safe alternative use for the deadly spent nuclear fuel would be invented. It still promotes that myth and asks the public to take the risks.
The next CEP meeting will be October 9, 2014 when emergency evacuation will be discussed. CEP member Ted Quinn requested that the meeting include the details of the Spent Nuclear Fuel dry storage protection and inspection planned by SCE and its vendor until 2073.