ML20023B698
| ML20023B698 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/14/1983 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Raynard Wharton SAN DIEGO STATE UNIV., SAN DIEGO, CA |
| Shared Package | |
| ML20023A459 | List: |
| References | |
| FOIA-82-611 NUDOCS 8305060073 | |
| Download: ML20023B698 (3) | |
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WASHINGTON, D. C. 20555 q.26 March 14, 1983 Docket No. 50-206 Mr. Richard J. Wharton University of San Diego Legal Clinics Alcala Park IN RESPONSE REFER San Diego, CA 92110 TO F01A-82-611
Dear Mr. Wharton:
This is in further response to your letter dated December 14,1982 in which you requested, pursuant to the Freedom of Information Act, documents pertaining to current efforts by the NRL to upgrade San Onofre Nuclear Generating Station Unit 1 in order to render it more " earthquake resistant".
Documents 1 through 4, which were attachments to document 10, and documents 5 through 7, which were attached to document 8 are enclosed.
You will be billed for the reproduction charges at the completion of this request.
Documents 8 and 9 contain advice, opinions and recommendations of the Office of Policy Evaluation Staff and are being withheld from public disclosure pursuant to Exemption (5) of the Freedom of Information Act (5 U.S.C. 552(b)(5)) and 10 CFR 9.5(a)(5) of the Commission's regulations.
These documents were prepared to assist the Commission in the then-ongoing deliberation as to whether the Commission should review the Director's Denials, DD-81-19 and DD-81-20.
Release of these documents would impede future communication between the staff the the Commission.
These documents contain no reasonably segregable factual portions.
Document 10 contains the legal advice, analysis, and recommendations of the Office of the General Counsel in the then-ongoing deliberation regarding whether the Commission should review the two Director's Denials, DD-81-19 and DD-81-20.
This document contains no factual information not already contained in the San Onofre docket and is being withheld pursuant to Exemption (5) of the Freedom of Information Act (5 U.S.C. 552(b)(5)) and 10 CFR 9.5(a)(5) of the Commission's regulations.
Release of this document would not be in the public interest because it would impede the future flow of advice from the Office of the General Counsel to the Commissioners.
Pursuant to 10 CFR 9.15 of the Commission's regulations, it has been i
determined that the information withheld is exempt from production or disclosure and that its production or disclosure is contrary to the public interest.
The person responsible for the denial of documents 8 and 9 is Mr. Jack E. Zerbe, Director, Office of Policy Evaluation.
The person responsible for the denial of document 10 is Mr. James A. Fitzgerald, Assistant General Counsel.
8305060073 830314 PDR FOIA WHARTON82-611 PDR
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7 Mr. Richard J. Wharton.
This denial'may be appealed to the Commission within 30 days from the receipt of this letter.
Any such appeal must be in writing, addressed to the Secretary of the Comm!ssion, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and should clearly state on-the envelope and in the letter that it is an " Appeal from an Initial F01 A Decision."
The NRC has not completed its review of the remaining documents subject to your request. We will respond as soon as that review is completed.
Sin erely, J. M. Felton, Director Division of Rules and Records Office of Administration
Enclosures:
As stated s
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Re: F01A-82-611 APPENDIX 1.
Director's Denial DD-81-19 2.
Director's Denial DD-81-20.
3.
11/14/79 Petition Under 10 CFR 2.206 from California Citizens.
4.
7/10/81 Letter to the Commissioners from Ralph Nader.
5.
3/2/82 Memo to Forrest J. Remick from H. R. Denton; San Onofre Unit 1 -
Steam Line Break and Seismic Upgrade (2 pages).
6.
4/2/82 Letter to R. Dietch from D. G. Eisenhut; San Onofre Unit.1 -
System Response and Structural Concerns.
7.
4/8/82 Memo to Forrest J. Remick from H. R. Denton; San Onofre Unit 1 -
Status of Steam Line Break and Seismic Upgrade Issues.
8.
4/9/82 Memo to the Commissioners from F. J. Remick. (Withiteld, Exemption 5).
9, 2/25/82 Memo to the Commissioners from F. J. Remick; Director's Denials of 2.206 Relief (Withheld, Exemption 5).
10.
2/16/82 Memo to the Commissioners from M. Malsch; SECY-82-63, " Director's Denials of 2/206 Relief (In the Matter of Southern California Edison Company)"
(7 pages) (Withheld, Exemption 5).
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w University of San Diego Legal Clinica FREEDOM OF INFORMATION ACT REQUEST December 14, 1982 FREEDOM OF INFORMATI ACT REQUEST
'k h l l Mr. Joseph M.
Felton Director, Division of Rules and Records E
U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Felton:
Pursuant to the authority vested in the public under the Free-dom of Inforn ation Act, 5 U.S.C.
552, we are requesting access to your copies of, any and all non privileged information pertaining to current efforts by the t!RC to upgrade San Onofre Nuclear Generating Station Unit 1 ISan Diego, CA] in order to render it more " earth-quake resistant" than at present.
More specifically, we are interested in all information con-cerning the actual date construction operations for the seismic upgrading began as well as the estimated date such construction will be completed.
Also requested at this time is any and all information available to the NRC concerning the total estimated cost of the up-grading process.
We are also interested in an outline of the procedures to be implemented in the actual construction or alterations utilized in the seismic upgrading.
If no " outline", per se, is available, please furnish us with all notes, reports, investigative files and other re-i search whereby we might determine the actual effect this seismic upgrading will have on current plant design.
We also hereby request l
any and all information regarding the expected or estimated future l
life of the plant.
That is how long is the plant expected to con-tinue to generate power and what is the estimated total electric I
l power to be generated in the future by San Onofre Unit 1.
f This information is being requested because it directly con-cerns the safety of each member of the puolic who currently resides in Southern California.
Presumably, the seismic upgrading program l
is designed for the protection and safety of the public in the event I
of a major earthquake which might potentially damage the plant.
Since the public has a direct interest in all steps taken on its behalf, the information requested is highly relevant.
i The code provisions under which we request disclosure of this information makes allowance for your agency to segregate any material from disclosure which is deemed privileged, if the relevant informa-tion requested, might still be adequately disseminated to the requestor.
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Alcala Park, San Diego, California 92110 714/293-4532 j
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,, Mr. Joseph M.
Felton December 14, 1982 Page.two Furthermore, even if you determine some of the requested information to be privileged, you are free to disclose it i. you find that the benefit to the public outweighs the harms of disclosure.
If you chose to deny all or any part of this request, please specify.the exemption under which you believe such refusal to be justified.
We also request you inform us of any procedures available to us under the law for appealing any adverse determination in this regard.
If there are any fees n ecessary for copying or searching for the records, please supply the records without informing us of the costs if the fees do not exceed $200.
If you have any questions with regards to this request, please do not hesitate to contact me.
Thank you for your time and consid-eration in allowing our organization, and the public at large to better understand the process by which you render the decisions that affect our daily lives.
Very truly yours, Richard J. Wha ton cw/RJW i
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00-81-19 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 0FFICE OF NUCLEAR REACTOR REGULATION HAROLD R. DENTON, DIRECTOR In-the Matter of
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SOUTHERN CALIFORNIA EDISON COMPANY
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Docket No. 50-206
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(San Onofre Nuclear Generating
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Station, Unit 1)
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DIRECTOR'S DECISION UNDER 10 CFR SECTION 2.206 i
a By essentially identical petitions received since November 1979 (44 FR 75535, December 20,1979), approximately 1560 residents of California request-ed that the Nuclear Regulatory Commission's (NRC) Director, Office'of Nuclear Reactor Regulation, suspend or revoke the operating license for the San Onofre Nuclear Generating Station, Unit 1.
By letter dated July 10, 1981, Mr. Ralph Nader also requested that operation of San Onofre Unit 1 be suspended pending completion of a " license review" for the facility.
The petitions and,lir. Nader's letter have been considered under 10 CF'R 2.206 of the Commission's regulations However, we have responded to Mr. Nader's request in a separate decision under 10 CFR 2.206.
The asserted bases for the request by the' petitioners are that San Onofre Unit 1 is not designed to withstand possible ground motion from earthquakes that may occur and that evacuation plans are inadequate to cope with a poten-tial accident at the site. The licensee responded to the petition in a filing i
dated January 23, 1980. Also, in an updated version of the petition distribu-ted by the Alliance for Survival in 1980, the petitioners expressed additional 94-tesOG406 811116 PDR ADOCK 05000206 C
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seismic concerns in light of the Livermore earthquake of January 1980. The updated petition also pointed out that the Rogovin Report to the Nuclear Regulatory Commission on the Three Mile Island accident reconnended that old reactors near major cities be shut down until realistic evacuation plans are available for use.
I have reviewed the information submitted by the petitioners and other relevant information bearing on the issues addressed in the original and updated petitions. For the reasons set forth below, the petitioners' request that the operating license for San Onofre Nuclear Generating Station Unit 1 be suspended or revoked is denied.
I.
With respect to the issues of the seismic capability of San Onofre Unit 1 the petitioners assert that:
(1) San Onofre Unit 1 is not designed to with-stand possible ground motions from earthquakes on the Newport-Inglewood and Christianitos (sic) faults and their branches which pass close to the reactor, (2) these ground motions could break cooling water pipes, cause a loss-of-coolant
' accident and lead to a meltdown of the fuel rods, (3) the addition of a concrete shell to the reactor dome and other modifications are inadequate to ensure against damages from possible ground motions during a maximum possible earthquake, (4) new and relevant information regarding ground motion potential was unavail-able when the Atomic Energy Commission (AEC)* approved.the design criteria for
- The NRC's predecessor
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e Unit 1 and these criteria were based on inadequate data on measurements for ground motions close to the source of the earthquakes, and (5) The Livermore earthquake of January 1980 made seismic focusing an issue relevant to San Onofre's earthquake hazards.
The San Onofre Unit 1 was licensed by the AEC on March 27, 1967.
In the origina1' seismic design, all components, systems and structures which were designated as important to the nuclear safety of the plant were designated Seismic Category A.
The design basis used for Seismic Category A was what in today's terminology would be consistent with a 0.25g Housner Spectrum defined Operating Basis Earthquake (OBE) and a 0.5g Housner defined Safe Shutdown Earthquake. (SSE).
Specifically, structures, systems and components associated with the reactor coolant system, baron injection and residual heat removal were designed as Seismic Category A.
Safety injection system components were also designed as Seismic Category A., The Turbine Building extensichs were designated Seismic Category B and. designed to a 0.29 static criteria.
l Since the original plant was constructed, various structures and systems i
have been added to the plant. These new items were designed to higher seismic levels.
Specifigally, the sphere enclosure building and the diesel generator and its associated structures, system and components were designed to a 0.67g modified Newmark response spectrum.
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In 1973, Southern California Edison Company (SCE) (the licensee) initia-ted a program to reevaluate and modify as necessary the capability of San Onofre Unit 1 to withstand seismic events. The criterion for this program was
the 0.67g Housner response spectrum. The first phase of this program consisted of reevaluating (1) systems to prevent a design basis accident, including the main reactor coolant loop, Nuclear Steam Supply System (NSSS) components and the reactor building and (2) the major structure in mitigating a design basis accident, the containment. Based upon its reanalyses, the licensee concluded for the containment sphere, the reactor building and structural steel framing that these structures have resistance capacities in excess of those required to meet 0.67g Housner Spectra. As a result, modifications were not necessary.
While we have not completed our review of these reanalyses, our preliminary review indicates that these results appear reasonable and are consistent with results from audit analyses performed by NRC of similar structures at other Systematic Evaluation Program (SE.P) plants. However, additional restraints were required for several of the larger NSSS components which were base sup-ported. The'se modifications were implemented during an outage in 1976-1977.
Following initiation of the SEP in 1978, subsequent phases of the seismic
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reevaluation program were incorporated into the SEP. This program is proceeding l
l in three phases:
(1) reevaluation of balance-of-plant structures; (2) re-evaluation of piping and mechanical equipment required to shut down the plant; and (3) reevaluation of piping and mechanical equipment required to mitigate l
accidents. The earthquake input being used for this program is the 0.67g Housner response spectrum.
I Portions.of the Turbine Building Complex were originally designed as Category B structures (0.2g Static) yet they contained systems and components necessary for safe shutdown and accident mitigation, i.e., Category A systems and conponents. As discussed in our attached Safety Evaluation Report (SER) m
two parts of the Turbine Building Coglex (the North Extension and West Heater Platform) require upgrading on a priority basis. The licensee has agreed to imple-ment appropriate modifications to these stnJctures to increase their capacity to 4
resist earthquakes or to shut down the plant if modifications are not coglete by June 1,1982.
In the interim the staff concludes that the North Turbine Building Extension, based upon recent modifications to upper ' column to girder connections, has the capability to resist earthquakes of about 0.4g Housner.
The NRC staff issued' letters dated August 4,1980 and April 24,1981 to SCE requesting details of the seismic reevaluation program including the scope of review, the evaluation criteria, the schedule for completion and justification for continued operation in the interim until completion of the seismic reevalua-tion program. The licensee respondecfby letters dated September 24, 1980 February 23 April 24, July 7, August 11 September 28, October 5,1981 and October 19, 1981.
In addition, on June 1,through June 3,1981 the NRC met with SCE at San Onofre Unit 1 to review the seismic analyses program for the auxiliary feedwater system.
The NRC staff has evaluated the licensee's responses and has prepared a Safety Evaluation Report of the Interim Seismic Adequacy for San Onofre Unit 1.
This report addresses the licensee's conclusion that continued operation is acceptable in the interim until the seismic reevaluation, and any necessary upgrading, is complete. A copy of the Safety Evaluation Report of the Interim Seismic Adequacy for San Onofre Unit 1 is attached to this decision and is hereby incorporated by reference.
The response to the petitioner's allegations (issues 1, 4 and 5) concerning the ground motions from the maximum earthquake on the Newport-Inglewood and Cristianitos faults, new information on ground mot' ions, and near field effects are as follows:
The geologic and seismologic investigations and reviews for the San Onofre,
Nuclear Generating Station (SONGS) sita are among the most extensive ever con-ducted for nuclear power plants. This effort has included seismologic and geologic studies of Southern California and Baja California in general and specific studies j
related to the imediate site vicinity. See NUREG-0712, " Safety Evaluation Report for San Onofre Units 2 and 3".
2 The Offshore Zone of Deformation (0ZD) is about 8 km from the SONGS site at its closest approach to the site. The maximum earthquake on the OID was deter-mined from hist'oric data and instrumentally recorded seismicity and from fault parameters, including slip rate, fault length, and fault area. The vibratory ground motion at the site due to the occurrence of the maximum earthquake on the OZD was determined by the use of empirical methods, theoretical models, and an examination of recent recordings of strong ground motion from earthquakes.
The seismic record in the Southern California region extends back to the 18th century. From 1932 to the present a relatively complete listing of instru-mentally determined earthquakes is available.
Listing of earthquakes of Richter Magnitude 5 or greater within 320 km of the site and all listed earthquakes within 80 km of the site, for which instrumental records are available, were reviewed. The spatial density of these events varies with location. The
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i vicinity of th'e SONGS site (within approximately 30 km)' appears to be one of relatively low seismicity.
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T.he areas of Southern California which might be characterized as seismical-ly active are the San Jacinto, San Fernando, White Wolf, and Imperial Valley faults. These faults are in the range of 80 km to 240 km from the SONGS site at their closest approach and, therefore, are considered to present no signifi-cant seismic challenge to the plants.
The Newport-Inglewood Fault is approximately 35 km northwest of the SONGS site at its closest approach to the site. As a conservatism in estimating the maximum earthquake to be expected on the OID, the staff considers the Newport-Inglewood fault, the Southcoast Offshore Zone of Deformation and the Rose Canyon fault as one continuous zone of deformation.
The licensee and the NRC staff have spent several years conducting exhaustive i
investigations and reviews of the geology and seismology of southern California and particularly the SONGS region to determine the proper earthquake parameters.
For safe-shutdown, the Category A systems, components and structures at SONGS Unit 1 are designed to a Housner s,pectrum anchored at zero period by an acceleration of 0.5g.
This design significantly exceeds the ground motion expected from a magnitude 5 earthquake at a distance of 8 km.
In addition, San Onofre Unit 1 is presently being backfitted to increase its margin of safety with respect to an Ms (surface wave magnitude) = 7 earthquake on the 0ZD.
Although not identified as the Cristianitos Zone of Deformation (CZD), a feature aligned along the CZD known as Fault E, which is not part of the present day mapped Cristianitos Fault, was identified and mapped in 1971 by Marine Advisors Associates, consultants to the Southern California Edison Company. The fault was removed from their 1972 maps because further interpretation did not sub-stantiate a continuous fault, but rather a discontinuous zone of deformation.
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A detailed investigation was made in 1980 by, Southern California Edison at the request of the NRC, assisted by the U. S. Geological Survey (USGS), to determine the offshore extent of the Cristianitos Fault and to determine whether it is structurally related to the_ Offshore Zone of Deformation (0ZD) of whkch the Newport-Inglewood fault is a part. The closely spaced, high resolution seismic reflection profiles taken offshore of the SONGS site revealed a zone of discon-tinuous, en-echelon faults and folds which were collectively referred to as the CZD. The CZD is not seen in the sea cliff exposure along its projected trend.
Also, a Pleistocene erosion platform, which is believed to be 40,000 to 80,000 years old, can be seen in the seismic reflection profiles to overlie, undisturbed, the CZD'.
Since this wouTd indicate that the CZD has not moved for at least that period of time, it is considered to be noncapable and does not present a hazard to the SONGS site.
(See NUREG-0712,'Section 2.5.1.12).
With respect to issues (2) and (3) concerning breakage of water pipes and damage from an earthquake, the petition failed to state specifically the basis for the allegations of the inadequacy of the Unit 1 facilities.
To address issues l
(2) and (3), the staff has examined information regarding the possible effects of seismic events on plant structures and safety systems.
In its letter dated August 11, 1981, the licensee enclosed a summary of the performance of steel-
, framed structures in six past earthquakes dating frca 1952 through 1979 and including the largest recor'ded earthquake in modern times. The licensee noted that, in general, the steel framed structures reviewed were designed for 0.lg or 0.2g static (the turbine building extensions are steel framed structures designed for 0.2g static) and experienced two to three times the design accelera-tion level without significant damage.
In the large number of structures reviewed, which had experienced severe ground motion, no plastic collapse or other gross structural failure was found.
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. Our basis for allowing continued operation of the San Onofre Unit 1 facility, pending completion of the seismic reevaluation program, is described in detail in Section III " Seismic Resistance of Structures, Systems and Corponents".Section IV, " Seismic Reevaluation Program", and Section V,
" Conclusion", of the attached Safety Evaluation Report.
As discussed in the Safety Evaluation Report, significant seismic upgrading of the San Onofre Unit 1 facility is underway, much has been acconplished and more is scheduled.
The staff also agrees with the licensee's April 28, 1980 basis for continued operation for those structures, systems and components which were originally designed to meet a 0.5g Housner Spectra as ground motion input.
However, not all safety related structures and systems were designed to this level of ground motion.
In partic'ular two critical areas of the Turbine Building complex (North Extension and West Heater Platform), several masonry walls and the Auxiliary Feedwater System are in this category.
It is the NRC'.s judg-ment that the inherent seismic capability of the AFW system and the additional water supply that bypasses the normal suction piping provide an adequate basis for continued operation during the seismic reanalysis and upgrading of the Auxiliary Feedwater System. Based on our review to date, we consider the.
masonry walls have adequate seismic resistance, although spalling and rebar overstraining may be expected to occur at levels somewhat below the 0.67g Housner Spectra used by the licensee in his analyses. Our evaluation of the North Turbine Building Extension and the West Feedwater Heater Platform indicate an inherent capacity to withstand seismic events in excess of the original design (0.2g Static). The staff estimates that the North Turbine Building Extension would have the capacity to withstand an carthquake input level of 0.4g Housner.
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e.
'The staff has concluded that certain modifications to (1) the North Turbine Building Extension and (2) the West Feedwater Heater Platform are necessary in the near term to increase the capability of certain plant structures to resist earthquakes at SONGS 1 to assure that continued operation of the facility is not inimical to the health and safety of the public.
For the reasons discussed in Section II.B., Near-Term Seismic Hazard, of the attached Safety Evaluation Report the probability is low that ground motion at the reactor site greater than that characterized by 0.4g Housner Spectrum would be exceeded. Therefore, considering the plant's ability to resist strong ground motion.
as discussed in Section III of the attached Safety Evaluation Report. Seismic Resistance of Structures. Systems and Components, and considering the icw probability of the ground motion discussed above until June 1.1982; the staff concludes that short term operation of San Onofre Unit 1* during the seismic reevaluation of the facility and.the implementation of any modification shown to be necessary as a result of seismic reanalysis is acceptable under the following conditions:
(1)
Structural upgrading of the North Turbine Building Extension and West Heater Platform by adding diagonal steel bracing is to be coglete'd by June 1.1982, or the facility is to be shutdown. until such upgrading is cogleted; (2)
Results of seismic analysis of structures are submitted for NRC review by January 31, 1982, and for all other items on the schedule specified in the licensee's November 3,1981 letter; (3) Any modifications shown to be necessary as a result of the seismic analysis which are not implemented by January 1 1983, are justified on a case-by-case basis with a schedule i
for implementation; and (4)
Prior to upgrading of the North Turbine Building Extension and West Heater Platform, either the gantry crane is to be parked at the extreme south limit of travel or the reactor is to be shut down during periods when crane movement is required.
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II.
With respect to the issue of the evacuation plans for San Onofre Unit 1 the petitioners assert:
(1) because the population growth near San Onofre
' Unit 1 plant has been more rapid and extensive than could have been antici-pated during the licensing of Unit 1, there are no adequate evacuation plans for the area's residents in~ the event of a loss of coolant accident; (2) there are about nine million people that live in the area that could be affected by
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accidental release of radioactive gases from Unit 1; (3) the State and local governments are not prepared to evacuate the population within the short time between the accident and the spread of radioactive gases; (4) when the AEC issued the construction permit in March 1964, it was impossible to know that the population would increase so rapidly; and (5) the Rogovin Report to the NRC on the Three Mile Island accident recomended that older reactors near major cities (like San Onofre 1) should be shutdown until realistic evacuation plans are developed.
Presently, the licensee has in place an NRC approved (October 1976) emergency plan for San Onofre Unit 1, which includes planning provisions for both onsite and offsite and, contrary to the petitioners contentions 1 and 4, accounts for population growth since the issuance of the construction permit for Unit 1 in 1964. A new proposed regulation was published in the Federal Register (44 FR 7516) on December 19, 1979, to clarify, expand, and further upgrade NRC's emergency planning regulations in 10. CFR Part 50, Appendix E.
Af ter public coments were received, a new regulation was issued with an effective date of November 3,1980.
In compliance with this regulation, the licensee submitted an updated emergency plan for NRC review in January 1981.
v-g
In. addition, contrary to petition contention 3, the licensee submitted to the Federal Emergency Management Agency (FEMA), with copies to NRC, emergency plans for Orange and San Diego Counties, the cities of San Clemente 'and San Juan Capistrano, the U. S, Marine Corps at Camp Pendleton, and the California State Department of Parks and Recreation.
The new regulations require 10 mile radius emergency planning zones around nuclear power plants. The 10 mile radius area is referred to as the plume exposure pathway Emergency Planning Zone (EPZ) and applies to potential airborne exposure. Within the EPZ the resident population estimates are approximately 80,000 in 1980 and 98,000 in 1990 contrary to petitioners' contention 2.
Its size is based on a conclusion that it is unlik ly that any protective actions would be required beyond the plume exposure pathway EPZ, even for most core-melt accidents.
In addition, for worst-case core-melt accidents, acute fatalities would not be expected outside 10 miles.
The detailed planning basis for this EPZ is described in the NRC/ FEMA Report, NUREG-0396, EPA 520/1-78-016,
" Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants".
The planning basis is also described in NUIREG-0654/ FEMA-REP-1,
" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."
A report by Science Applications, Inc. (SAI) was done for the California legislature and is the basis for a recomendation by the California Office of Emergency Services (C0ES) for extended emergency planning zones larger than the 10 mile EPZ. The risk study performed for the State of California is similar in many respects to those studies that were the basis for NUREG-0396, but one of the most important differences was the COES assumption that no
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prot'ective actions would be taken offsite for seven days for those individuals in local areas of high radiation after cloud passage. The staff believes that a more realistic exposure time is considerably shorter and that correspond-ingly smaller planning distances should result from use of the COES Methodology.
The staff, however, has no objection to offsite authorities laying explicit plans for distances farther than 10 miles if those authorities choose to expend resources for this purpose. The NRC's conclusion is that evacuation plans for the population beyond the 10 mile EPZ are not required and that evacuation plans within the 10 mile EPZ are adequate.
An emergency exercise was enacted May 13,.1981 to demonstrate the Emergency Plan at SONGS. This exercise was witnessed by the NRC and FEMA and in a June 3, 1981 memorandum from FEMA to the NRC, FEMA states, in part, that:
"A joint exercise was conducted on May 13, 1981, to evaluate the offsite capabilities of the State and local jurisdictions to respond to a nuclear emergency at the San Onofre station. The exercise reflected a general overall state of preparedness to implement general emergency plans."
In an enclosure to that memorandum, it 'is further stated that:
"On May 13,1981, FEMA Region IX with support from FEMA head-quarters, Regions VIII and X, and the RAC conducted an evalua-tion of the offsite capabilities of the local and State juris-dictions to respond to a nuclear emergency at SONGS. The evaluation preparation, conduct, and subsequent critique process, closely followed guidance provided by FEMA National Program Office.
The finding *, of that evaluation reflected a general overall pre-paredness to implement their plans and to respond to the scenario from an operational standpoint, but significant shortfalls were observed in the ability to conduct radiological response opera-tions. Further, the critical areas of ingestion pathway sampling and analysis, as well as Reentry and Recovery operations were not observed due to the restricted nature of the scenario.
Comuni-cations, EOF facility, and general coordination were also considered to be weak and needed further address through training and drill efforts.~ The evacuation portion of the exercise was considered I
adequate but was felt'it did not totally test the evacuation requirement and, therefore, refelected a need for further study, drill and exercise."..."A range of protective actions has been
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. developed for the plume exposure pathw'ay EPZ for both' emergency workers and the public. Guidelines for the choice of protective actions during an emergency are developed and in place. Pro-tective actions for the ingestion exposure pathway EPZ, approp-riate to the locale, are generally developed. Further develop-ment and testing of these guidelines is reconnended, but do not impose an impediment to the total response capability."
In summary, FEMA found the state and local government emergency response plans " minimally adequate", but found the offsite capability for implementation inadequate pending taking of corrective actions.
In a letter dated June 26, 1981, to the NRC, SCE stated that a series of meetings had been held with FEMA and with all local jurisdictions to develop a plan of action for the continuing development of emergency preparedness. The. plan and its schedule for imple-mentation are described in Appendix A.
FEMA, in a July 14, 1981 memo from R.
Jaske to B, Grimes of the NRC, states-that they have confirmed with FEMA Region IX that SCE',s letter of June 26, 1981, represent agreed positions concerning FEMA's major concerns, what needs to be done to correct them, and SCE's proposed actions to assist in correcting them. The NRC staff has reviewed the corrective action proposed.by the licensee to address the FEMA determinations and concluded that when completed these actions will adequately resolve the expressed concerns.
l Accordingly, in an October 26, 1981 letter the NRC advised SCE that the deft-ciencies identified by FEMA' must be resolved and SCE nust clearly demonstrate that the deficiencies have been corrected before the staff can complete its assessment of the overall state of emergency preparedness with respect to Unit 1.
SCE forwarded to FEMA a letter dated October 15, 1981, showing the completion of all items identified earlier. FEMA is reviewing this' letter and expects to make i
a final determination in mid November,1981.
In view of the NRC staff's previous i
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. evaluation of the current emergency plan, the present efforts to further upgrade the emergency preparedness at San Onofre, and the schedule to meet FEMA's concerns in the near-term, there is no unacceptable risk to the health and safety to the public that would justify an order. to shut down San Onofre Unit 1.
1 III.
On the basis of the foregoing, I have determined that no adequate basis exists for ordering the suspension or revocation of the operating license for the San Onofre Nuclear Generating Station Unit 1.
Consequently, the petitioners' request is denied.
~
A copy of this decision will be filed with the Secretary for the Commission's review in accordance with 10 CFR 2.206(c). As provided in this regulation, the decision will become the final action of the Commission twenty-five (25) days after issuance, unless the Commission, on its own motion, institutes review of the decision within that time.
MNl
' Harold R. Denton, Director Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland, this 16th day of Novembsr,1981
Attachment:
1.
Appendix A - Corrective Actions Required to Address FEMA Determinations of 6/3/81 2.
Safety Evaluation Report of the Interim Adequacy for San Onofre Unit 1
i 1
APPENDIX A i
CORRECTIVE ACTIONS REQUIRED TO ADDRESS FEMA DETERMINATIONS OF JUNE 3, 1981*'
l l
FEMA CONCERNS FEMA RECOMMENDATION RESPONSE **
FEMA Region IX Evaluation of_ Plans and Capabilities "Most Critical Concern" 1.
The assessment and Develop a multi-jurisdic-Continue to install the Health Physics Computer which monitoring of actual tional response capability will provide a prompt conservative assessment of the offsite radiological to assure adequate coverage actual radiological consequences of an accident. This consequences of a radio-of plume pathway and stan-will be operational to a limited degree by fuel load i
logical emergency condition dardized procedures which with full operation expected by July 1982.
Further through methods, systems allow flexibility in develop standard radiological monitoring procedures j
and equipment is considered response.
(50P's) for the local jurisdictions and the Offsite to be weak and in need of Dose Assessment Center (00AC) by August 1981.
SCE F
improvement to abet minimum additionally.will assess the local jurisdictions' i
~
criteria.
current qquipment against their needs and identify any deficiancies noted. SCE will provide staffing l
to assume a role of leadership in this function.
SCE will provide training programs for personnel involved in use of the 50P's.
' " Serious Concern" 2.
The interim - EOF shows a Until the permanent EOF is SCE will develop SOP's to make current EOF operations lack of clear operating completed, the int'erim EOF clearer and more manageable along the lines of the procedures, fragmentation should be relocated to a current planning arrangements. -Limited physical of the facility, lack.of single location separate improvements of the present facilities will be management direction com-from the San Clemente EOC identified and accomplished.
munications, size of the*
and staffed with management, facility, and is a signifi-communicators and other cant impedance to the San support personnel necessary Clemente EOC operation.
for EOF operations.
t
- The schedule for these actions is identified in pages A-4 and A -5.
e 5
g.
31.
FEMA CONCERNS FEMA RECOMMENDATION RESPONSES
" Major Concerns" 3.
A need to clarify monitor-Develop a joint standard-(See item [1] above.) SCE will develop standardized' ing and assessment duties
.ized multi-jurisdictional procedures for the five involved counties to obtain for both plume and inges-response team.
i samples, conduct analyses, and take necessary pro-l tion pathways as they tective actions for the ingestion pathway emergency l
pertain to State OES, planning zone consistent with the State Radiological j
State Radiological llealth llealth proposed ingestion pathway procedures.
Develop i
and local jurisdiction.
an integrated radiological response team to be directed
)
by the Offsite Dose Assessment Center (00AC) to conduct I
field monitoring.
4.
Means to provide early Install sirens and provide SCE will proceed with current plans for siren installation.
notification and clear warning dissemination SCE will develop 50P's for public notification via the instructions to the public capacity to remote areas Emergency Broadcast System (E85) and local stations within the plume exposure where public address identified in the plans.
SCE will develop 50P's for 1
[, pathway EPZ have not been systems from surface or coordination and decisionmaking in use of sirens.
l installed or tested.
airborne vehicle is required.
a 5.
Adequate emergency facili-SCE provide response equip-Agreements have been made between SCE and local < agencies i
ties and equipment to ment which was promised to that specific equipment. will be ordered'by the local
, support the emergehcy the local jurisdictions, risdictions and billed to SCE.
Equipment procurement response have not been including sirens and addt-ss begun and is continuing.
SCE will follow up with
- provided.
tional communications report on status of equipment received or on order.
equipment.
SCE will review equipment needs and status of equipment procure.aent' activities.
6.
Radiological emergency SCE, in conjunction with the (See items [1] and [3] above.) SCE will develop and response training has State of California, should implement a program of training in the critical areas essentially not been develop the necessary train-of radiation monitoring and assessment, communications, provided to those who ing to meet the identified decisionmaking and coordination regarding protective may be called upon to needs in the local actions, etc.
assist in an emergency.
jurisdictions.
l l
g O
FEMA CONCERNS FEMA RECOMMENDATION RESPONSES
~
" Sufficient Concern to Remain a 11ajor Issue" 7.
SCE has not made informa-Disseminate ~ advance public SCE will proceed with the public education program that tion available about how information.
includes an emergency response brochure and radiation the public would be notified.
information brochure mailer, preparation and. distribution or what the publig's initial of flyers and posters, new ads, community meetings, etc.
actions should be in an emergency.
n 6
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a s
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D g
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a O
e SUM 4ARY OF PLANNED ACTION SCHEDULE Items (a) through (h):
1.
Develop 30P's covering the following topics:
Ist draft - 7/15/81 a.
Operation of the Offsite Dose Assessment Final draft - 9/1/81 Center (ODAC)
Implement - 10/1/81~
b.
Radiation surveys by field monitoring teams c.
Emergency Communications
' d.
Use of the s.iren alerting system and public notificatipn e.
Coordination relating to protective actions ~
f.
Acquisition, display and use of meteorological data g.
Operation af the EOF Item (1):
h.
Ingestion pathway monitoring 1st draft - 9/15/81 Final draft - 11/1/81 i.
Existing 50P's covering other plan elements Implement - 12/1/81 2.
Obtain equipment required to carry out radiation monitoring functions
~
a.
Survey types and quantities of equipment 7/15/81
~
~
actually in place b.
Initiate procurement of equipment shortages,
8/1/81 3.
Develop additional communications capabili.ty a.
Expand interagency phone network to include 7/15/81 CHP b.
Provide speaker monitors at EOC's
~ 7/15/81 l
c.
Provide teletype message system network 10/15/81 between all principal centers d.
Provide additional communication circuits 10/15/81 l
l A-4 e
l
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a'.
/
SCHEDULE ~
4.
Make physical improvements to th'e EOF a.
Identify possible improvements ",',',
9/1/81'
' ~ -.-
2-'-
b.
Obtain agree.ments to make improvements 9/1/81.
c.
Construct improvements 10/15/81
~'
5.
Install Sirens 50% by 7/1/81 e
90% by 9/1/81 100% by 10/15/81 6.
Accomplish training in use of new and existing procedures, fac.ilities, and equipment a.
Develop training program (long and short term)
'7/15/81 b.
Develop training material (short term prograin) 9/1/81 Conduct tiaining and drills (short term program) 9/1/81 through c.
10/15/81 d.
Implement long term training program 11/1/81 through.
2/1/82 7.
Public Information Program
- Ongoing,
' Initial program complete 9/1/81 J
e i
n
=
t A-5 e
SCHEDULE ~
4.
Make physical improvements to th'e EOF Identify possible improvements ",,
9/1/81'
~' '
a.
b.
Obtain agreements to make improvements
. 9/U81 c.
Construct improvemer.ts 10/15/81
- ~
5.
Install Sirens 50% by 7/1/81 90% by 9/1/81 100% by 10/15/81
~
6.
Accomplish training in use of new and existing procedures, fac.ilities, and equipment a.
Develop training program (long and short term)
'7/15/81 b.
Develop training material (short term progra')
9/1/81 s
c.
Conduct training and drills (short term program) 9/1/81 through 10/15/81 d.
Implement long term training program 11/1/81 througit 2/1/82
-7.
Public Information Program
- Ongoing,
~ Initial program complete 9/1/81 4
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a f rituq[o UNITED 5TATES g
E NUCLEAR REGULATORY COMMISSION e
a oE WASHINGTON, D. C. 20555
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November 16, 1981 Docket No. 50-206 LS05-81-11-022 LETTER TO CALIFORNIA RESIDENTS
SUBJECT:
DIRECTOR'S DECISION UNDER 10 CFR 2.206 (DD-81-19)
SOUTHERN CALIFORNIA EDISON COMPANY (SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 1)
This is in response to peritions raceived by the Nuclear Regulatory Commission since November 1979 request ng that the Director of Nuclear Reactor Regulation i
suspend or revoke the operatii.: ifcense for the San Onofre Nuclear Generating Station, Unit 1.
The petitions allege that San Onofre Nuclear Generating Station, Unit 1 is not designed to withstand possible ground motions from earthquakes that may occur and that evacuation plans are inadequate to cope with a potential accident at the site. Moreover, in an updated version of the petition distributed by the Alliance for survival in 1980, the petitioners expressed additional seismic concerns in light of the Livennore earthquake of January 1980. The updated petition also pointed out that the Rogovin Report to the Nuclear Regulatory l
Commission on the Three Mile Island accident recommended that old reactors near major cities be shutdown until realistic evacuation plans are available for use.
l By letter dated July 10, 1981, Mr. Ralph Nader also requested that operation of San Onofre Unit 1 be suspended pending completion of a " license review" for the facility.
We have responded to Mr. Nader's request in a separate decision under 10 CFR 2.206.
l l
The petitions have been considered under the provisions of 10 CFR 2.206 of the l
Commission's regulations. This office has detennined, for the reasons set forth I
in the enclosed Decision, not to issue an order suspending or revoking License No. DPR-13, which authorizes Southern California Edison to operate San Onofre Nuclear Generating Station, Unit 1.
The Decision includes a recent staff report regarding the seismic capability of San Onofre Nuclear Generating Station, Unit 1.
A copy of this detennination will be placed in the Commission's Public Document Room at 1717 H Street, N. W., Washington, D. C.
20555 and at the Mission Viejo Branch Library, 24851 Chrisanta Drive, Mission Viejo, California.
The <fecision will also be filed with the Secretary of the Commission for its review in accordance with 10 CFR 2.206(c) of the Commission's regulations. As provided for by this regulation, the decision will constitute the final action l
l of the Commission twenty-five (25) days after the date of issua'nce of the decision unless the Commission, on its own motion, institutes a review of the decision within that time.
8112000098 81T116~
PDR ADOCK 05000206 G
PDR e
A.'
I*
2-A copy of the Notice of Issuance of the Director's Decision, which is being filed with the Office of the Federal Register for publication, is also enclosed.
Sincerely.
N Harold Denton, Director Office of Nuclear Reactor Regulation
Enclosures:
1.
Director's Decision 2.
Notice of Issuance cc: See next page
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.c California Residents ovember 16, 1981 cc w/ enclosures:
Charles R. Kocher, Esq., Assistant
/
Mr. R. Dietch, Vice President General Counsel Nuclear Engineering and Operations James Beoletto, Esquire Southern Californ.ia Edison Company Southern Califbrnia Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Post Office Box 800 Rosemead, California 91770 Rosemead, California 91770 David R. Pigott, Esq.,
The Honorable Jerry Brown Orrick, Herrington & Sutcliffe Covernor of the State of California 600 Montgomery Street State Capitol San Francisco, California 94111 Sacramento, California 95814 Harry B. Stoehr San Diego Gas & Electric Corpany P. O. Box 1831 a
San Diego, California 92112 Resident Inspector /Sa'n Onofre NPS c/o U. S'. NRC P. O. Box 4329 San Clemente, California 92672 Mission Viejo Branch Library 24851 Chrisanta Drive Mission Viejo, California 92676 May'or City of San Clemente San Clemente, California 92672 Chai'rman Board of Supervisors County of San Diego San Diego, California 92101 California Departnent of Health ATTH:
Chief Environmental l
Radiation Control Unit i
Radiological Health Section 714 P Street, Room 498 Sacramento, California 95814 U. S. Environmental Protection Agency Region IX Office ATTH: Regional Radiation Representative 215 Freement Street San Francisco, California 94111 6
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UNITED STAT 25 8
NUCLEAR REGULATORY COMMISSION n
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,o OFFICE OF NUCLEAR REACTOR REGULATION SAFETY EVALUATION REPORT SAN ONOFRE UNIT 1 INTERIM SEISMIC ADEQUACY DOCKET NO. 50-206 l
l Dated: November 16, 1981
+
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PDR l
SAFETY EVALUATION REPORT SAN ONOFRE UNIT 1 INTERIM SEI5MIC ADEQUACY DOCKET NO. 50-206 I.
INTRODUCTION In accordance with 10 CFR 50.54(f) of the Commission's regulations, letters were issued on August 4,1980 'and April 24, 1981 to Southern California Edison Company requesting that the licensee:
1.
submit details of a seismic reevaluation program plan address-ing the scope of review, evaluation criteria and a schedule for completion; and 2.
provide justification for continued operation in the interim until the program is ccmplete.
In its response to both letters the licensee referenced its April 28, 1980 submittal (Reference 1) as its basis for. continued operation in the interim until the program is complete.
On June 1 through June 3,198L the NRC and its consultants met with Southern California Edison (SCE) and their consultants relative to NRC sponsored seismic analyses of the San Onofre Unit 1 auxiliary feedwater system. At this meeting SCE provided drawings of prelim-inary modifications required to upgrade the four Turbine Building Extension structures and masonry walls to a level of earthquake re-sistance consistent with 0.67g Housner Spectra as input.
Based upon the extent of these proposed modifications, and the potential consequences on plant safety of structural failure of either the North Turbine Building Extension or the West Feedwater Heater Platform, our de-tailed review of the seismic resistance of these structures was expedited.
In their July 7,1981 letter, the licensee connitted to upgrade the North i
Turbine Building Extension and West Feedwater Heater Platform, if possible, during the outage following six effective full power months of operation or at the next extended outage after completion of detailed design of these modifications.
In an August 11, 1981 letter the licensee committed to complete these modifications by June 1,1982. Subsequently, they com-mitted that should the modifications not be complete, they would shut down the facility until the modifications are' complete. The licensee also pro-vided a detailed evaluation of these Turbine Building structures to support continued operation until June 1, 1982.
l
. II.
Seismic Hazard Considerations A.
Geology and Seismology The geologic and seismologic investigations and reviews f'r o
the San Onofre Nuclear Generating Station (SONGS) site are among the most extensive ever conducted for nuclear power plants.
This included seismologic and geologic studies of Southern California and Baja California in general and specific studies related to the immediate site vicinity.
The Offshore Zone of Deformation (0ZD) is about 8 km from the SONGS site at its closest approach to the site. The maximum earthquake on the OZD was determined from historic data and instrumentally recovered seismic activity and from fault para-meters, including slip rate, fault length and fault area.
The vibratory ground motion at the site due to the occurrence of the maximum earthquake on the 0ZD was determined by the use i
of empirical methods, theoretical models and an examination of recent recordings of strong ground motion from earthquakes.
The seismic record in the Southern California region extends back to the 18th century. From 1932 to the present a relatively complete listing of instrumentally determined earthquakes is.
available. Listings of earthquakes of Richter Magnitude 5 or greater within 320 kilometers of the site and all listed earth-quakes within 80 kilometers of the site, for which instrumental records are available, were reviewed. The spatial density of these events varies with location. The vicinity of the SONGS site (within approximately 30 km) appears to be one of rela-tively low seismicity.
l l
Based upon its evaluation for the SONGS Units 2 and 3 the staff concluded that an appropriate representation of the maximum I
earthquake on the OZD to be used in determining the safe shutdown earthquake (SSE) at SONGS is Magnitude, Ms = 7.0.
The SONGS Units 2 and 3 design actually exceeds a conservative represen-tation of the ground motion expected from an Ms = 7.0 earthquake at a distance of 8 km.
The NRC by letter dated August 4,1980 directed the licensee to conduct a seismic reevaluation of San Onofre Unit 1 using 0.67g Housner Spectra as the appropriate free field ground motion for the Safe Shutdown Earthquake (SSE). Based upon our continuing review of the final free field ground motion, the level will be no less than 0.67g Housner Spectra and no greater than-0.67g Modified Newmark-Hall Spectra. The design bases for San Onofre
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, Units 2 and 3 are the 0.679 Modified Newmark-Hall Spectra.
The range between the two spectra is narrowly centered about 0.67g at very short periods (approximately less than 0.05 sec.)
and diverge to a larger extent as the period increases. The basis for the conservatism of the'0.67g Modified Newmark-Hall Spectra is contained in the NRC's Safety Evaluation Report (SER) on Geology and Seismology for San Onofre Units 2 and 3, NUREG-0712 (Reference 2).
Our evaluation contained in Reference 2 addresses the seismic hazard at the San Onofre site.
The NRC letter dated March 15, 1981 confirned our earlier direc-tion to the licensee to proceed with the seismic reanalysis of San Onofre Unit 1 using the 0.67g Housner Spectra pending NRC approval of the final spectra.
If the appropriate ground motion for reanalysis is not the 0.67g Housner Spectra, the staff will evaluate the margins that exist in the structures, systems and components to determine if additional reanalysis using a higher spectra shape is necessary. The licensee has agreed in a letter dated May 11, 1981 to continue reanalysis effort using the 0.67g Housner Spectra.
The staff expects to reach a final decision on the San Onofre Unit 1 spectra reanalysis following the Atomic Safety and Licensing Board's Partial Initial Decision on San Onofre Units 2 and 3 with respect to geology and seismology issues.
B.
Near Term Seismic Hazard l
The staff has considered probabilistic estimates of earthquake occurrence and ground motions exceedance at and in the vicinity of the San Onofre site. These include:
1.
" Development of Instrumental Response Spectra with Equal Probability of Exceedance for Unit 1," Woodward-Clyde Con-sultants, April 18, 1980 - Submitted to NRC by letter dated April 28,1980.
l 2.
A survey of probabilistic estimates of earthquake occurrence l
and ground motion exceedance at and in the vicinity of the l
San Onofre site presented to ACRS by the staff on January l
31, 1981.
e
,n
3.
" Probability of Exceedance of 0.5g Housner Response Spectrum,"
submitted to NRC by letter dated October 19, 1981.
In addition, the staff has also utilized the extensive review of theoretical and empirical studies regarding earthquake ground motion at the San Onofre site conducted for the San Onofre Units 2 and 3 Operating License and summarized in the Safety Evaluation i
Report (NUREG-0712). Examination of the above with respect to the ground motion level defined by the Housner Spectra in the period i-range of 0.5 to 0.6 seconds at 4% damping indicate the following:
a.
Estimates of the probability of exceeding this level of ground motion at or in the vicinity of the San Onofre site in a period of 8 months range from approximately 7 X 10-3 to l
1 X 10-4 The most detailed of 'these estimates were con-l ducted by Woodward-Clyde Consultants for the site. The most recent study which takes into account new data and/or weighting procedures yields the lowest astimates (3 X 10-4 to 1 X 10-4 ).
b.
The Safe Shutdown Earthquas= v2;q) for the San Onofre site as found in the staff Safety E55%:aTion Report for Units 2 and 3 is a magnitude-7.0 occurring on the offshore zone of defor-mation (0ZD) approximately 8 kilometers from the site.
Estimates of the probability of this event are of the order of 10-J to 10-4 for this period. Our examination of the various techniques used to estimate the ground motion deter-ministically at the site from such an event indicate that the referenced level of ground motion is at about the median (50%)
level that could be expected from such an earthquake.
Although absolute estimates of probability with respect to earth-quake hazard cannot be made with great accuracy, it is the staff's judgement, based on the above, that the chance of exceeding the 0.4g Housner Spectrum at periods of 0.5 to 0.6 seconds at 4%
damping during an 8 month period is low.
III. Seismic Resistance of Structures, Systems and Components 3
A.
Containment Sphere and Reactor Building The containment sphere and the reactor building were originally designed using the Housner Spectra with 0.25g and 0.5g horizontal acceleration for the Operating Basis Earthquake (OBE) and the Safe Shutdown Earthquake (SSE) respectively.
e d
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d 1 In its Seismic Backfit Project, as discussed in Reference 3, the licensee performed a seismic reevaluation for certain structures (containment sphere and reactor building),' piping (the primary reactor coolant system), and components (steam generators, reactor coolant pumps, pressurizer, and reactor vessel).
The analyses were performed using 0.67g Housner Spectra. The containment sphere, the reactor building and the primary reactor i
coolant system are three subsystems considered in the system analysis. Each system model included the dynamic characteristics
.of all major subsystems in a coupled time history analysis. The effect of soil-structure interaction was included. The models ased in these analyses were three dimensional, and torsional ef-fects were automatically included.
The response spectrum method in conjunction with a three-dimension-
< ~
al finite element model was used for the seismic reevaluation of i
containment sphere, foundation and the reactor building. The multi-directional components of the earthquake and the modal responses were combined in accordance with Regulatory Guide 1.92.
Based upon their reanalyses, the licensee concluded for the con-tainment sphere, the reactor building and structural steel framing that these structures have resistance capacities in excess of those requir.ed to meet 0.67g Housner Spectra. As a result, modifications were not necessary. While we have not completed our review 'of these reanalyses, our preliminary review indicates that these results appear reasonable and are consistent with results from audit analyses performed by NRC for structures of other SEP plants.
B.
Standby Power Addition Project and Sphere Enclosure Project The Standby Power Addition' Project (including the Diesel Generator Building) and the Sphere Enclosure Project (including the Sphere Enclosure Building) were designed based on the 0.67g Design Spectra developed for San Onofre Units 2 and 3 (Reference 2). The design criteria and procedures used for these two structures are the same as those used for SONGS Units 2 and 3 which have been evaluated and accepted by the NRC staff. These projects were approved by the NRC in Amendment No. 25 to Provisional Operating License No. DPR-13 (Reference 5).
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C.
Reactor Auxiliary Building, Fuel Storage Building, Control Building For these three buildings, with the exception of masonry walls, the Housner Response Spectra scaled to 0.5g for the SSE and 0.25g for the OBE were used in the simplified dynamic analysis for the original design. The vertical spectra were 2/3 of the hori-zontal spectra. The stress components were combined by absolute addition for the vertical and horizontal direction.
Design margins of at least 2 to failure typically exist in well built suJctures as a result of design code allowables,. seismic design conservatisms and inherent seismic resistance. Therefore, 34% increase in input motion. 0.679 vs. 0.5g Housner Spectra, should be accommodated safely by these structures, although modifications may be required to restore design margins for the higher seismic input.
Evaluations of masonry walls in the facility considering the 0.67g Housner Spectra are proceeding. The licensee's analysis to date indicates that masonry walls are capable of resisting this level of motion without collapse.
D.
Turbine Building Structures The Turbine Building structures consist of five separate free-standing structures, connected by common foundation elements.
These structures are:
- 1) The Turbine Pedestal;
- 2) The North Turbine Building Extension; l
- 3) The South Turbine Building Extension; l
- 4) The East Feedwater Heater Platform; and
- 5) The West Feedwater Heater Platform.
The turbine pedestal consists of massive concrete slabs and columns and its initial seismic design basis was 0.5g Housner Spectra.
The remaining turbine building structures were designed to a 0.2g horizontal static coefficient. These structures consist of post-tensioned concrete slabs supported by steel fram-ing. The columns are welded to the beams supporting the slabs and attached to the concrete foundation elements using embedded anchor bolts. Some reinforced concrete block masonry walls exist in each structure.
7-During meetings and a site visit in early June 1981 the licensee identified the following preliminary modifications to the Turbine Building structures to provide resistance to the 0.679 Housner Spectra seismic input. The modifications include the addition of substantial lateral bracing from floor to ceiling -
in both the North-South and East-West directions for both the North and South Turbine Building Extensions and both Feedwater Heater Platforms to increase their lateral resistance to seis-mic motions and to prevent possible impact with the Turbine Pedestal.
1.
System Considerations The failure of any, or all, of the following structures could adversely affect safety systems:
l North Turbine Building Extension.
Earthquake induced collapse of this structure would impair the function of safety related systems, including the main steam lines and their isolation valves (i.e. the tu.bine stop valves),
the feedwate'r and auxiliary feedwater ( AFW) system lines, Emer-gency Core Cooling System (ECCS) lines, cables for instrumenta-tion and controls required for decay heat removal, and the power supply cables for the charging pumps, thereby eliminating all methods for providing water to remove reactor decay heat.
West Feedwater Heater Platform.
Collapse of this structure, induced by an earthquake, would irpair the function of safety related systems, including the AFW pumps, instrument air compressors, and steam and feed-water lines. All methods for providing water to the steam generators to remove decay heat would be eliminated. An alter-nate method for cooling of the core using primary system feed and bleed is possible and is discussed below.
East Feedwater Heater Platform Collapse of this structurt, induced by an earthquake, would impair the function of safety related systems, including the feedwater and ECCS systems. The break of the feedwater system is postulated at the Feedwater Heater. Check valves are O
O
8-installed upstream of the heater on the three feedwater lines go-ing to each steam generator. Therefore, a path for decay re-moval using the auxiliary feedwater system is available. The alternate method for cooling the core using primary system feed and bleed is also available. Therefore, the consequences of collapse of this platform are less severe than those of the West platform.
South Turbi.a Building Extension Collapse of this structure, induced by an ecrthquake, would im-pair the function of safety related systems including the renote Safe Shutdown Panel, loss of electrical power for ECCS loop C, loss of one loop of ECCS for recirculation mode, loss of off-site power and possible loss of the condensato storage tank or piping. However, an alternate suction suction path for auxil-iary feedwater would be available with operator action using the fire water system. The consequences of collapse of this structure are the least severe and would not prevent removal of reactor decay heat.
Alternate Method of Decay Hiat Removal In their August 11, 1981 submittal the licensee discussed an alternate method of decay heat removal, tsing primary system feed and bleed, which can be initiated by the operator from the control room.
The charging pumps, taking suction on the refuel-ing water storage tank (RWST), would be used to deliver water to the primary system through the long-term post-accident recircu-lation flowpath. The pressurizer power-operated relief valves would be opened to rejact heat to the primary containment.
After sufficient water is in the sump the recirculation heat exchanger would be used to remove the decay heat to the ultimate heat sink.
The equipmer.t needed to implement the above means of decay heat removal are separate from and independent of a postulated failure of the west feedwater heater platform. The equipment can be powered from on-site power sources. Backup nitrogen supplies are available and may be needed to operate pneumatic components if the instrument air system is impaired.
l The licensee has calculated that a delay of 30 minutes before the alternate decay heat removal system is operational would not result in uncovering of the core. The calculations also showed that the alternate method has sufficient capacity to remove the decay heat load.
_ As discussed in the licensee submittal of September 28, 1981, plant operating procedures were developed in response to post-TMI Bulletins and Orders for natural circulation cooling, for inadequate core cooling and for PORY operation.
Primary feed and bleed using these procedures is a scenario that is covered in operator training.
Although the staff has not reviewed the licensee calculations in detail, this alternate decay heat removal method would be available for coolir:g should the West Feecwater Heater Platform be damaged by a large earthquake.
2.
Inherent Seismic Resistance The licensee performed a detailed analysis to establish the structural capacity of the North Turbine Building Extension, the West Feedwater Heater Platform and masonry walls in the Turbine Building. These results were reviewed during a meeting with the staff on July 30, 1981. A simplified (ynamic analysis of the entire Turbine Bulding considering soil structure interaction (SSI) was performed to determine the fundamental vibrational modes and mode shapes for the North Turbine Building Extension and the West
(
Feedwater Heater Platform. Jo determining the capacity of the structures, accelerations from the 4% damped 0.5g Housner Spectrum was used in a static analysis. Total force response in any one direction was obtained by combining 100 percent of the maximum response due to one earthquake component with 40 percent of the maximum response due to the other two earthquake components.
During the meeting, the staff requested the licensee to verify by inspection that the welded connections were installed as designed and to evaluate the capacity of the column to girder connections.
The results of the licensee's analyses and evaluations are contained in their August 11,1981 submittal. The results indicate that:
- 1) the welded connections were installed in accordance with the original design;
- 2) the connections are adequate up to the onset of yield in the columns; and i
- 3) the connections would exceed their elastic limit at significant-
~
ly less than the full moment capacity that could be developed by the column.
These results confirmed that the welded column to girder connections were the limiting element in the original design of these structures.
The licensee has also performed a detailed inelastic analysis of the masonry walls using an input of 0.67g Housner. The analysis results indicate that displacements up to 10" at midspan could occur but the wall would not collapse. The staff has not completed its review but believes thrt, although degradation (spalling and potential limited overstraining of rebar) cnuld occur, collapse is not likely.
For analyses of the North Turbine Building Extension and West Feedwater Heater Platform Structures, the licensee assumed a ground motion amplification factor of 1.4 (based upon their calculated fre-quencies and a 4% damped Housner Spectrum). The onset of structural yielding was predicted to occur at approximately.0.3g to 0.4g Housner Spectrum for the North Turbine Building Extension and for both East and West Feedwater Heater Platforms. The South Turbine Building Ex-tension would yield at a lower value.
At the onset of ductile behavior,'significant redistributions of loads in the members will begin to take place. Since the original column to girder connections could not develop the full plastic moment capacity of the columns, the licensee upgraded the strength of the connections on column lines B and D of the North Turbine Building Extension (a total of 5 of 8 such connections). These connections have been modified such that the full plastic moment capability of the columns can be developed. Considering that girder capacities are in excess of the column capacities and assuming that the column l
to foundation anchorages (i.e., bottom connections) are adequate, the top connections for columns line B and D are sufficient to allow some limited ductility for the North Turbine Building Extension.
Column line B provides primary resistance to North-South motion, there-fore without considering restraint from adjacent structures (given the several inch gap that exists between the Enclosure Building and North Turbine Building Extension), these modified connections should be adequate to develop ductile behavior.
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The adequacy of the column to foundation anchorages in the North Turbine Building Extension is a key factor in the strength of the structure to resist earthquakes. Previous licensee analysis indicated anchor bolt capacities in the range of 0.39g to 0.48g Housner. These results indicated capacities in excess of the original top connections. Additional analysis considering 'the effects of column imbedment in the floor was presented to the staff on October 16, 1981, and is contained in the licensee's submittal dated Octobe'r 19, 1981. Recognizing the limitations of using elastic analysis to predict ductile behavior and other uncertainties in the licensee's analysis'of the anchor bolt capacities, the staff believes that the capacity of the structure to resist North-South ground motion is about 0.4g Housner Spectrum.
Column lines A and'D provide the primary resistance of the North Turbine Building Extension to East-West motion. Only column line D is being modified. However, substantial restraint to the half of the structure supported by column line A is provided by the approximate 1 1/2 inch gap between it and the top of the spent fuel pool on the west side and the operating deck of the Control Building on the east side. Therefore, considering (1) the unmodified column line A connections should remain elastic up to a displacement of about 1 1/2 in., at which point the gaps would close and the restraint from the adjacent structure would be realized; and (2) the ductile behavior of column line D to resist seismic motions including any torsion which may result from the impacts with the adjoining structures, the staff concludes the seismic resistance capability of the struc-ture in the East-West direction should be comparable to that of the North-South direction.
i The staff estimates that the East and West Feedwater Heater Platforms are likely to have the capability to resist earthquake input in the range of 0.3 to 0.4g Housner. The performance of the North Turbine Building Extension based upon the recent modification of the top connections and considering the displacenent constraints offered by.
the adjacent structures is likely to have the capability to resist l
earthquake input of about 0.4g Housner. The South Turbine Building l
Extension would be expected to fail at an earthquake level less than that for the East or West Feedwater Platform due to the substantial added load that it must carry due to the crane which is normally positioned over the South Turbine Building Extension.
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, E.
Safety Related Mechanical Equipment The original design of the safety related piping was based on the ANSI B31.1 code for power piping using the Housner Spectrum (0.5% damping) scaled to 0.25g which resulted in response accelerations of 1:0g and 0.679 for horizontal and vertical components respectively (Refer-ence 4). The original design basis for all equipment (mechanical and electrical) initially classified as safety related was 0.5g Housner Spectra with 1% and 2% damping ratios.
In its Seismic Backfit Project (as discussed in Reference 3), the li-censee performed a seismic neevaluation for certain structures (con-tainment sphere and reactor building), piping (the primary reactor coolant system), and components (steam generators,. reactor coolant pumps, pressurizer, and reactor vessel). The aralyses were performed using 0.67g Housner Spectra. The containment sphere, the reactor building and the primary reactor coolant system are three sub-system models considered in the analysis. For example, the system model for the coolant loops included a detailed model of the reactor coolant system, with simplified models representing other components, systems and structures (containment sphere and reactor building). The sim-plified models were developed from more detailed models. The analy-sis included the dynamic characteristics of all major subsystems in the coupled time history analysis.
The analysis of the reactor coolant system was based on the direct application of ground motion input to the complete closed system model. Based upon the results of this analysis some support modifi-cations were made for large NSSS equipment (i.e., steam generators and pressurizer, etc.) to resist overturning and to accomodate large thermal expansion. We have not yet completed our review of these reanalyses. Attached branch piping was not included in this reevalua-tion, but was initially designed considering a 0.5g Housner Spectra.
l The equipment in the Standby Power Addition Project was designed for the same seismic input as San Onofre Units 2 and 3.
The design basis l
was 0.67g Modified Newmark-Hall Spectra (Reference 2). The piping and mechanical equipment were designed (Reference 11) in accordance I
with the applicable sections of the ASME B&PV Code and are acceptable.
The auxiliary feedwater ( AFW) system was not originally designated as a safety related system. Therefore, the system was originally l
l e
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D
. designed to resist a 0.2g static horizontal acceleration. New dis-charge piping and portions of the steam supply piping to the steam driven AFW pump have been installed and were upgraded in their sels-mic design to 0.67g Housner Spectra. However, other portions of the AFW system (e.g., the supply piping to the AFW pumps and the condensate storage tank) have not been and are not presently being upgraded. The seismic design basis for the portions of the system which have not been upgraded is a 0.2g static horizontal acceleration.
On November 24 and 25,1980, the NRC staff conducted a site visit and a walk-down of the SONGS 1 auxiliary feedwater (AFW) system.
Based on our observations of the existing AFW system, the NRC Staff concluded that some inherent seismic resistance capability was pro-vided in the initial design and construction for much of the system.
Piping, cable trays, equipment and components were generally pro--
vided with lateral support.
Three areas of concern were identified which required remedial act-ions prior to the resumption of power operation of SONGS 1.
The first concern was the Station No.1 battery racks. While the exist-ing racks provided for some degree of lateral seismic load resist-ance and are redundant to the much more substantial No. 2 battery racks, the configuration.did not appear to have a level of integ-rity commensurate with the importance of the batteries to plant safety. These racks appeared less capable of continued integrity following a seismic event when compared to the No. 2 battery racks which were installed to the seismic design criteria specified for their diesel generator installation. Therefore, we required that the existing No.1 battery racks be re-evaluated using the current SSE specified criteria, and modified accordingly.
The second concern was the suction piping to the AFW pumps, which consists of a single header from the condensate storage tank to the pumps. The header has some lateral support. However, the conden-sate storage tank was not qualified to the initial or current SONGS l
1 seismic criteria for safety related systems. The tank is not anc-chored at its base.
It merely rests on the ground. Also, the permanent alternate wate'r supply is through the tank. There is a capability to install a hose from a seismically qualified water source to the AFW pump suction and bypass the condensate storage tank. We required that a hose be installed and kept attached to m.
. the appropriate connections to facilitate its use if it became necessary to do so.
The third concern was with the main instrumentation and control panels in the control room. These are supported c.t the bottom by a concrete channel and at the top by steel knee braces anchored to the concrete ceiling with expa'sion anchors. The requirements n
of IE Bulletin 79-02 (the concrete expansion anchor and Lase plate issues) had not been applied to these anchor bolts and base plates.
We st3ted that conformance with the IE Bulletin requirements for f ac-tors of safety, considering base plate flexibility, must be assured for the original design of these panels. Also, some bolts and screws were missing in these panels. We required that the licensee inspect all screws, bolts and nuts in the panel for their presence and integ-i ty. Missing fastening devices were to be replaced.
These three actions were completed by the licensee prior to their re-star;t in June 1981.
Based upon the detailed walk-downs of the SONGS 1 AFW system, the AFW system possesses an adequate degree of seismic resistance and redun-dancy to permit plant operation during the near term seismic reevalua-tion and upgrading of this system required of all operating PWRs by NRR Generic Letter dated February 10, 1981.
However, this conclusion is contingent upon the structural integrity of the North Turbine Building Extension, the West Feedwater Heater Platform and any masonry walls whose f ailure could impair the function of the AFW system.
F.
Anchorage and Support of Class IE Electrical Equipment In response to the NRC's letters of January 1 and July 28, 1980, on tie-down of safety related electrical equipment, the licensee con-ducted a walk-through visual inspection of the plant and made a pre-liminary assessment of the,aJequacy of equipment tie down. The licensee surveyed approximately fif ty-nine items and found that ap-proximately two-thirds were adequately secured. Based on the re-sults of these preliminary assessments, interim modifications were completed for the remaining items in July and August 1980.
-1 5-Following completion of these interim modifications, detailed anal-yses were performed on the anchorages of all identified items.
These analyses were divided into two phases. The first phase irclud-ed all equipment at grade elevation for which response spectra were available (the 0.67g Housner Spectra). The results of these analysts confirmed the adequacy of the preliminary assessments and the interim modifications with five exceptions. The five items were the battery racks, the Uninterruptable Power Supply battery rack, the High Volt-age control board, the SkVa inverter and the battery chargers.
The second phase of the program included all equipment located in the control room. The analysis of the anchorage of safety related elec-trical equipment in the control room is based on the estimated ficar response spectra with a peak floor acceleration of 2.0g.
From the results of the analyses, additional modifications were found to be required for process control racks R1 through R7, R10 and R11, the nuclear instrumentation system, radiation monitoring system, vital bus assembly, and containment system actuation system logic Train A cabinets.
All modifications identified by the licensee to be necessary to resolve 4
all electrical equipment, anchorage have been implemented. Our review of the adequacy of these modifications is continuing.
IV. Seismic Reevaluation Program In accordance with 10 CFR 50.54(f) of the Commission's regulations, a letter was issued on August 4,1980 to Southern California Edison Company requesting that the licensee:
1 1.
submit details of a seismic reevaluation program plan addressing j.
the scope of review, evaluation criteria and a schedule for completion; and l
2.
provide justification for continued operation in the interim un-til the program is complete.
. It was noted in our letter that the proposed program plans and schedule for an expanded program should include an evaluation of the following:
1.
the remainder of the reactor coolant pressare boundary (i.e., all.
attached piping /equipmeret),
2.
safety related mechanical and electricci equipment to bring the plant to cold shutdown, and 3.
safety related mechanical and electrical systems required to mit-igate the consequences of an accident.
In its response to this letter the licensee referenced its April 28, 1980 submittal (Reference 1) as its basis for continued operation in the interim until the program is complete. The program scope and schedule in this sub-mittal needed to be modified to include the reevaluation of piping and mechanical / electrical equipment.
Subsequently, several meetings were held between the licensee and the NRC Staff to discuss the seismic reevaluation program scope and schedule.
The licensee partially responded in a letter submitted on February 23, 1981, entitled " Balance of Plant Structures Seismic Reevaluation Criteria." This document provides a detailed description of the methodology and criteria to be used in seismic reevaluation of each of the plant strutures included in the program, with the exception of the upgraded projects previously dis-cussed which include the Reactor Building, Steel Containment Sphere, Sphere Enclosure Building, and Diesel Generator Building.
A follow-up to the 10 CFR 50.54(f) letter was sent to the licensee on April 24, 1981 requesting the information on the complete scope and schedule for the reevaluation program.
In response to our April 24, 1981 letter, the licensee submitted a description of complete program scope and schedule on July 7, 1981.
D
17-i SCE has committed to complete the balance-of-plant structures and I
masonry wall evaluations by January 1982. SCE also proposed that any modifications be evaluated to determine if they would be impacted by other SEP topic evaluations and therefore should be deferred to the SEP integrated safety assessment. By May 1, 1982, SCE is scheduled to have reevaluated the remainder of the primary coolant pressure boundary and all structures and mechanical systems required to bring the plant to a safe shutdown. Accident mitigating systems will be completed by November 1982.
V.
Conclusion t
As discussed in the above evaluation, significant seismic upgrading of the San Onofre Unit 1 facility is underway, much has been accomplished and more is scheduled. The staff also agrees with the licensee's April 28,1980 basis for continued operation for those structures, systems and components which were. originally designed to meet a 0.5g Housner Spectra as ground motion input.
However, not all safety related structures and systems were designed to this level of ground motion.
In particular two critical areas of the Turbine Building complex (North and West Extensions), several masonry walls and the Auxiliary Feedwater system are in this category.
It is the NRC's judgment that the inherent seismic capability of the AFW system and the ad-ditional water supply that bypasses the normal suction piping provide an adequate basis for continued operation during the seismic reanalysis and i
upgrading of the Auxiliary Feedwater System. Based on our review to date, we consider the masonry walls have adequate seismic resistance, although spalling and rebar overstraining may be expected to occur at levels some-what below the 0.67g Housner Spectra used by the licensee in his analyses.
3 Our evaluation of the North Turbine Building Extension and the West Feedwater Heater Platform indicate an inherent capacity to withstand seismic ' events in 2
excess of the original design (0.2g Static). As discussed in Section III.A.4, the staff estimates that the North Turbine Building Extension would have the capacity to withstand an earthquake input level of 0.4g Housner.
The staff has concluded that certain modifications to (1) the North Turbine' Building Extension and (2) the West Feedwater Heater Platform are necessary in the near term to increase the capability of certain plant structures to resist earthquakes at SONGS 1 to assure that continued operation of the facility is' not inimical to the health and safety of the public.
l a
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. For the reasons discussed in Section II.B., Near-Term Seismic Hazard, the probability is low that ground motion at the reactor site greater than that characterized by 0.4g Housner Spectrum would be exceeded.
Therefore, considering the plant's ability to resist strong. ground motion, as discussed in Section III, Seismic Resistance of Structures, Systems and Components, and considering the low probability of the ground motion discussed above until June 1,1982; the staff concludes that short term operation of San Onofre Unit I during the seismic re-evaluation of tne facility and the implementation of any modification shown to be necessary as a result of seismic reanalysis is acceptable under the fcllowing conditions:
(1) Structural upgrading of the North Turbine Building Extension and West Heater Platform by adding diagonal steel bracing is to be completed by June 1,1982 or the facility is to be shut down until such upgrading is completed; (2) Results of seismic analysis of structures are to be submitted for NRC review by January 31, 1982 and for all other items on the schedule specified in the licensee's November 3,1981 letter; (3) Any modifications shown to be necessary as a result of the seismic analysis which are not implemented by January 1,1983 are to be justified on a case by case basis with a schedule for implementation; and (4) Prior to upgrading of the North Turbine Building Extension and West Heater Platform, either the gantry crane is to be parked at the extreme south limit of travel or the reactor is to be shut down during periods when crane movement is required.
i l
O
,m
O REFERENCES 1.
" Seismic Reevaluation Program," San Onofre Nuclear Generating Station, Unit 1, April 28,1980.
2.
Safety Evaluation Report (SER) on Geology and Seismology for San Onofre Nuclear Generating Station Units 2 and 3, NUREG-0712, December 1980.
3.
" Seismic Reevaluation and Modification," San Onofre Nuclear Generating Station, Unit 1, April 29,1977.
4.
" Seismic Design Bases and Criteria for San Onofre Nuclear Generating Station Unit 1," Docket Summary, prepared by Lawrence Livermore National Laboratory, August 1979.
5.
" Safety Evaluation by the Office of Nucletr Reactor Regulation Supporting Amendment No. 25 to Provisional Operating License No. DPR-13," San Onofre Nuclear Generating Station, Unit 1 April 1,1977.
4 F
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9
. ' ' I, '.
Y-00-81-20 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION HAROLD R. DENTON, DIRECTOR In the Matter of
)
)
SOUTHERN CALIFORNIA EDISON COMPANY
)
Docket No. 50-206
)
(San Onofre fluclear Generating
)
Station, Unit 1)
)
DIRECTOR'S DECISION UNDER 10 CFR 2.206 I
By letter dated July 10, 1981, Ralph Nader requested that the Nuclear Regula-tory Commission (NRC) suspend the operating license for the San Onofre Nuclear Generating Station Unit 1 until a license review has been completed.
His request is similar to the requests made in petitions received since November 1979 (44 FR 75535, December 20,1979) from approximately 1560 residents of California which also have been considered under 10 CFR 2.206 of the Commission's regulations.
The asserted bases, in summary form, for the request by Mr. Nader were that:
(1) San Onofre Unit I has been identified as having the highest probability I
of a meltdown of any California reactor.
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i, (2) San Onofre Unit 1 is designed to withstand a 5.0 magnitude seismic event, yet the Newport-Inglewood Fault 4 miles offshore is capable of a 7.5 magni-tude earthquake.
(3) Half of the population of California would be affected by a serious acci-dent at San Onofre.
(4) No workable or demonstrated evacuation plan exists for the immediate 10 miles surrounding the plant.
(5) A review by the Federal. Emergency Management Agency concluded that the demonstration of the evacuation planning is " woefully inadequate." The NRC's own analysis (NUREG-04907 states that a meltdown accident at San Onofre could cause up to 130,000 acute deaths and 300,000 latent fatalities.
In addition,'Mr. Nader asserts that new seismic information underscores the gravity of the situation at San,Onofre and that Unit 1 is externally and inter-nally susceptible to any major ground motion.
The issue of seismic capabilities of the San Onofre Nuclear Generating Station Unit 1 and the adequacy of the evacuation plans are discussed in a separate decision (DD-81-19) in response to the petition by approximately 1560 Southern California residents.
That decision is hereby incorporated by reference.
This decision responds to the additional allegations made by Mr. Nader, paragraph by paragraph, in the following discussion.
~ 4
II Mr. Nader asserts in pr.ragraph three, item 1 of his July 10, 1981 letter that:
" 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 Cali-fornia Office of Emergency Services."
The staff has performed a brief review of the Executive Summary of the lengthy report.
The report does not directly state that, but instead refers to the comparative probabilities of accident occurrences per year for each of the scenarios examined.
As'an example, Scenario 1 is containment failure by
" energetic missile produced by steam explosion" and includes the assumption that containment sprays do not operate.
The probability of this event is-5 x 10 7 per year for San Onofre Unit 1.
This is approximately a factor of ten times the probability of occurrence of this scenario at the WASH-1400 plant (Surry) and the factor of 10 difference is generally carried throughout the remainder of the accident sequences studied.
However, the probabi'lity of the eventi is only one of a number of significant parameters with regard to implications of impact of an accident upon the health and safety of the public.
What is equally important in the study is the predicted consequences of.the events under consideration.
Table 3-1 of the study's Executive Summary shows that expected downwind whole body doses from the accident scenarios are less at San Onofre 1 than at any other California plant except Humboldt Bay (which is shut down).
Table 3-2 of the Executive Summary shows that l'ess than 0.1 early fatalities are expected from the three worst scenarios at San Onofre 1, using 1975 population figures and assuming no emergency protective actions.
This information is consistent with the NRC staff's studies discussed below.
' ~
The Executive Summary also states that "there is roughly a 50 percent probabil-ity that a release at... San Onofre...would be blown completely or partially in the direction of the Pacific Ocean." Two conclusions of tne report-are partic-ularly germane:
"1.
The probabilities of occurrence of accidents at a nuclear power plant in California that threaten the health and safety of people residing near the site' are generally lower than compa-rable values in WASH-1400 and are on the order of one chance in a million per year of reactor operation.
2.
While the probability of serious hypothetical accidents is very low, the consequences can bc substantia if effective evacua-tion and interdiction measures are not taken.
The consequences for nuclear power plants in California are generally somewhat less than those reported in WASH-1400."
The NRC staff has recently completid conservative studies.
These studies show that, under severe accident conditions, including contaf ament failure (although not by vessel steam explosion), an accident at San Onofre 1 would not have nearly the ' consequences purported by Mr. Nader, who referenced conservative assumptions for San Onofre 2/3 from a supplement to draft NUREG-0490.
The final NUREG-0490 is the Final Environmental Statement for Units 2 and 3 and was not intended to address Unit 1.
Unit ~1 has a smaller radioactive material inventory than Unit 2 or 3 and consequences would, therefore, be less.
l Tables 1 and 2 of Appendix 8 are a summary of calculated consequences of vari-ous accident sequences at San Onofre 1, using the actual power level of 1347 MWt and assuming evacuation to 10 miles (Table 1) and 20 miles (Table 2).
The l
l assumptions for the Siting Source Terms (SST) 1, 2, and 3 are presented in Table 3 of Appendix A, where the type of accident and nature of. containment leakage are explained.
The consequences of SST-4 and SST-5 sequences are less
~.. _ _.
severe than those of SST-1, -2, and -3 and therefore the -4 and -5 sequences are not included.
The various evacuation scenarios usad in the studies are presented in Table 4 of Appendix A.
There are several assumptions that must be highlighted.
They are:
(1) con-tainment failure is assumed to occur in 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for the SST-1 scenario, the worst-case accident considered in the study; (2) population densities and dis-tributions utilized are from 1970 census data which is a nonconservative factor by perhaps as much as 30%; 1980 census data are not available in ccmputerized form and the 30% nonconservatism is insignificant when compared ;o other conser-vatisms and nonconservatisms in the analysis; (3) meteorological assumptions were gleaned from regional meteorology, since continuous sampling was avail-able over longer periods.
However,' the site-specific wind rose was used.
Although the use of regional meteorology may appear to be ncnconservative and there is uncertainty associated with the use of any one year's data, the NRC's studies have shown that accident consequences are relatively inse~nsitive to regional meteorology; (4) peak and probibility of peak values were derived from conservative assumptions involving dispersion of the radioactive cloud; and (5) evacuation is considered only out to 10 miles for Table 1, but peak values are generated conservatively from radioactive cloud deposition at a population center outside 10 miles.
Examination of Table l'shows how overstated the values of the supplement to draft NUREG-0490 are as quoted by Mr. Nader in his assertions regarding San m
Onofre Unit 1.'
The ongoing NRC Siting Analysis study has provided some idea of the risk of operation of San Onofre 1.
That risk is not as significant as Mr. Nader implies.
~
Table 1 presents results based upon an assumed evacuation to 10 miles but using the conservative radioactive cloud deposition beyond 10 miles, as ncted in assumption (5) above.
Table 2 utilizes the same conservative deposition assump-tion but includes evacuation to 20 miles.
However, as noted below (response to paragraph 3 items 3, 4, and 5), the NRC requires only an evacuation plan to 10 miles because studies show that a plan beyond 30 miles is not generally necessary.
Table 2 has been incinded here only to show the conservatisni of the assumptions that were included in Table 1.
For the very low probability accidents having the potential for causing radiation exposure above the thres-hold for acute fatality at distances beyond 16 km (10 mi), it would be realis-tic to expect that authorities would evacuate persons at all distances at which such exposures might occur.
The NRC staff is satisfied, based on their review of accident scenarios that there are no special or unique features about San Onofre Unit 1 that would warrant spe'cial or additional engineered safety features.
Mr. Nader asserts in paragraph three, item 2, of his letter:
"The Newport-Inglewood Fault, only four miles offshore, is capable l
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 l
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."
The geologic and seismologic investigations and reviews for the San Onofre Nuclear Generating Station (SONGS) site are among the most extensive ever con-ducted for nuclear power plants.
This included seismologic and geologic studies of Southern California and Baja California in general and specific studies related to the immediate site vicinity.
~
The Offshore Zone of Deformation (0ZD) is about 8 km from the SONGS site at its closest approach to the site.
The maximum earthquake on the OZD was deter-mined from historic data and instrumentally recorded seismic activity and from fault parameters, including slip rate, fault length, and fault area.
The vibra-tory ground motion at the site due to the occurrence of the maximum earthquake on the OZD was determined by the use of empirical mathods, theoretical models, and an examination of recent recordings of strong ground motion from earthquakes.
The seismic record in t.he Southern California region extends back to the 18th century.
From 1932 to the present a relatively complete listing of instrumen-tally determined earthquakes is available.
Listings of earthquakes of Richter Magnitude 5 or greater within 320 km of the site and all listed earthquakes within 80 km of the site, for which' instrumental records are available, were reviewed. The spatial density of these events varies with location. The vicinity of the SONGS site (within approximately 30 km) appears to be one of relatively low seismicity.
The areas of. Southern California which might be characterized as seismically active are the San Jacinto, San Fernando, White Wolf, and Imperial Valley faults.
These faults are in the range of 80 km to 240 km from the SONGS site at tneir closest approach and, therefore, are considered to present no seismic cha11enge to the plants.
Based upon its evaluation for the SONGS Units 2 and 3 in NUREG-0712, the staff concluded that an appropriate representation of the maximum earthquake on the OZD to be used in determining the safe shutdown earthquake (SSE) at SONGS is M, (surfaco wave magnitude) = 7.0.
The SONGS Units 2 and 3 design actually
~ -~
exceeds a conservative representation of the ground motion expected from an M, = 7.0 earthquake at a distance of 8 km.
The Newport-Inglewood Fault is approximately 35 km northwest of the SONGS site at its closest approach to the site.
As a conservatism in estimating the maxi-mum earthquake to be expected on the OZD, the staff considers the Newport-Inglewood fault, the Southcoast Offshore Zone of Deformation and the Rose Canyon fault as one continuous zone of deformation.
Mr. Nader's allegations on San Onofre Unit No.1 describe the Newport-Inglewood fault as being 4 miles offshore (it is approximately 35 km from the site) and as "being capable of a 7.5 magnitude earthquake, according to the U.S. Geological Survey." This char-acterization is based on the U.S. Geological Survcy Open-File Report (OFR)81-115, " Scenarios of Possible Earthquakes Affecting Major California Pnpula-tion Centers, with Estimates of Intensity and Ground Shaking." The context in which 0FR-81-115 was written must be understood.
The Preface of 0FR 81-115.
follows:
"Following the President's trip to review the destruction caused by the eruption of Mount St. Helens on May 18, 1980, he directed that an immediate assessment be undertaken of the consequences of, and l
state of preparedness for, a major earthquake in California.
The l
review was conducted by an ad hoc committee of the National Security Council chaired by Frank Press, the President's Science Advisor.
This report was compiled by the staff of the U.S. Geological Survey Office of Earthquake Studies for use by government agencies in estimating casualties, economic losses, and overall disaster pre-paredness.
The basic charge to the Office of Earthquake Studies i
was to develop scenarios of credible earthquake that would severely l
affect major California population centers, to estimate intensities for these events, and to indicate the approximate level of strong ground motion in the affected regions.
This report presents esti-mates of ground motion based on current data and methods and is thought to be accurate.
Nevertheless, the information in this report was prepared in an extremely short period of time, solely for the purposes of the National Security Council review.
This report should not be taken to represent either a comprehensive *
~
statement of earthquake hazard throughout California, or a defini-tive statement regarding the effects of any specific earthquake."1 In contrast to 0FR 81-115 which was " prepared in an extremely short' period of time" and "should not be taken to represent either a comprehensive statement of earthquake trazard throughout California or a definitive statement regarding the effect of any specific earthquake," the SONGS applicants and the NRC staff have spent severtl years conducting exhaustive investigations and reviews of the geology and seismology of southern California'and particularly the SONGS region to determine the proper earthquake parameters.
Mr. Nader misrepresents the design of SONGS Units 2 and 3 in that he states the San Onofre Units 2 and 3 are only capable of withstanding a 6.5 magnitude earthquake.
SONGS Units 2 and 3 ar'e designed for a site-specific spectrum with a zero period anchor of 0.67g acceleration.
This ground motion exceeds a con-servative. representation of the ground motion expected at the site from an occurrence of an M = 7.0 earthquake on the OZO at a distance of 8 km.
s Mr. Nader's allegations also understate the design of SONGS Unit 1 in stating that Unit 1 is designed to withstand a 5.0 magnitude seismic event.
The SONGS Unit 1 design basis earthquake is a Housner spectrum anchored at zero period by an acceleration of 0.5g.
This design significantly exceeds the ground motion expected frem a magnitude 5 earthquake at a distance of 8 km.
Details l
lIn his testimony in the operating lice'nse proceeding for SONGS 2 and 3, James F.
Devine, Assistant Director for Engineering Geology, USGS, reiterated that this i
report was not intended as.a detailed report on the seismicity of the San Onofre site.
See Transcript at 5328-31, 5408, 5429-31 (Occket Nos. 50-361 and 50-362, l
July 28, 1981).
Moreover, the report was not admitted as evidence of seismicity in the area.
Transcript at 5444-47 (July 29, 1981).
-g-
of the seismic capacity and program for upgrading SONGS Unit 1 are found in the response to the petitions by approximately 1560 Southern California resi-dents.
The response is an enc 1csure to the transmittal letter for this decision.
Mr. Nader asserts in paragraph three, items 3, 4, and 5 of his letter:-
"(3) Half the population of California woulc be affected by a serious accident at San Onofre.
10-12 million people live within 100 miles of the plant.
(4) No workable or demonstrated evacuation olan exists for evec 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.,
dould be as high as $180 billion."
Presently, the licensee has in place an NRC-approved (October 1976) emergency plan for San Onofre Unit 1, which includes planning provisions for both onsite and offsite and accounts for population growth since the issuance of the con-struction permit for Unit 1 in 1964.
A new proposed regulation was published in the Federal Register (44 FR 7516) on December 19, 1979, to clarify, expand, and further upgrade NRC's emergency planning regulations in 10 CFR Part 50, Appendix E.
After public comments were received, a new regulation was issued with an effective date of November 3, 1980.
In compliance with this regula-tion, the licensee submitted an updGted emergency plan for NRC review in January 1981.
In addition, the licensee submitted to the Federal Emergency Management Agency (FEMA), with copies to NRC, emergency plans for Orange and -
.s San Diego Counties, the cities of San Clemente and San Juan Capistrano, the U.S. Marine Corps at Camp Pendleton, and the California State Department of Parks and Recreation.
The new regulation requires 10 mile radius emergency planning zones around nuclear power, plants.
The 10-mile radius area is referred ta as the plume exposure pathway Emergency Planning Zone (EPZ) and applies to potential air-borne exposure.
Its sire is based on a conclusion that it is unlikely that
~
any protective actions would be required beyond the pluma exposure pathway EPZ, given for most core-melt accidents.
In addition, for worst-case core-melt acci-dents, acute fatalities would not be expected outside 10 miles.
The detailed planning basis for this EPZ is described in the NRC/ EPA Report, NUREG-0396, EPA 520/178-016, " Planning Basis for the Development of State and Local Govern-ment Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants." The planning basis is also described in NUREG-0654/ FEMA-REP-1,
" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."
A report by Science Applications, Inc. (SAI) was done for the California legisla-ture and is the basis for a recommendation by the California Office of Emergency Services (COES) for extended emergency planning zones larger than the l'0-mile EPZ.
The risk s.tudy performed for the State of California is similar in many respects to those studies that were the basis for NUREG-0396, but one of the most important differences was the COES. assumption that no protective actions would be taken offsite for seven days for those individuals in local areas of high radiation after cloud passage.
The NRC staff believes that a more realis-tic exposure time is considerably shorter and that correspondingly smaller
~ -
~
planning distances should result from use of the COES methodology.
The staff, however, has no objection to offsite authorities laying explicit plans for dis-tances farther than 10 miles if those authorities choose to expend resources for this purpose.
The staff's conclusion is that evacuation plans for the pop-ulation beyond the 10-mile EPZ are not required and that evacuation plans with-in the 10 mile EPZ are adequate.
An analysis was prepared for the Southern California Edison Company by Wilbur Smith Associates, Traffic Engineers, entitled, " Analysis of Time Require-ment to Evacuate Transient and Permanent Population From Various Areas Within the Plume Exposure Pathway Emergency Planning Zone, July 1981." This analysis, which considers the beach visitors, the number of cars and the routes, concludes that the evacuation time estimate f5r the general population of transient and permanent residents on a summer weekend is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for a radius of 2 miles from the plant, and 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for a radius of 5 miles from the plant.
The California State Department of Parks and Recreation has a revised " Nuclear Power Plant Emergency Response Plan for the San Onofre, San Clemente, and Doheny State Park and Beach Areas, December 1980" whica details the evacuation routes and traffic control points.
The Southern California Edison Company has installed sirens within the 10 mile emergency planning zone including all the beach areas.
The
~ sirens would be activated in the event of an accident at the plant that required people to take protective measures such as shelter or evacuation.
With the traffic control, people to the north of the plant would only be allowed l
l to evacuate to the north, and people south of the plant would be required to evacuate to the south; therefore, it would not be necessary for evacuees to l
pass by the plant.
I I
L
.f r
.c A'n emergency exercise was enacted May 13, 1981, to demonstrate the Emergency Plan at SONGS.
This exercise was witnessed by the NRC and FEMA and in a June 3, 1981 memorandum from FEMA to the NRC, FEMA states, in 'part, that:
"A joint exercise was conducted on May 13, 1981, to evaluate the off-site capabilities of the State and local. jurisdictions to respond to a nuclear emergency at the San Onofre station.
The exer-cise reflected a general overall state of preparedness to implement general emergency plans."
In an enclosure to that memorandum (at pages 2 and 6), it is further stated that:
"On May 13, 1981, FEMA Region IX with support from FEMA headquarters, Regions VIII and X, and the RAC [ Regional-Assistance Committee]
conducted an evaluation of the offsite capabilities of the local, and State, jurisdictions to respond to a nuclear emergency at SONGS.
The evaluation preparation, conduct, and subsequent critique processy closely followed guidance provided by FEMA National program office.
The findings of that evaluation reflected a general overall prepared-ness to implement their plans and to respond to the scenario from an operational standpoint, but significant shortfalls were observed in the ability to conduct radiological response operations.
- Further, the critical areas of ingestian pathway sampling and analysis, as well as Reentry and Recovery operations were not observed due to the restricted nature of the scenario.
Communications, EOF facilityi and general coordination were also* considered to be weak and need further address through training and drill efforts.
The evacuation portion of the exercise was considered adaquate but was felt it did i
not totally test the evacuation requirement, and therefore, reflected a need for further study, drill, and exercise....
I A range of protective actions has been developed for the plume exposure pathway EPZ for both emergency workers and the public.
Guidelines for the choice of protective actions during an emergency I
are developed and'in place.
Protective actions for the ingestion exposure pathway EPZ, appropriate to the locale, are generally developed.
Further development and testing of these guidelines is recommended, but~do not impose an impediment to the total response capability."
i In summary, FEMA found the State and local government emergency response plans
" minimally adequate," but found the offsite capability for implementation inade-quate pending taking of corrective action.
In a letter dated June 26, 1981,
/
c' to the NRC, the Southern California Edison Company (SCE) stated that a series q of meetings had been held with FEMA and with all local jurisdictions to develop a plan'of action for the continuing development of emergency preparedness.
The plan and its schedule for implementation are described in Appendix B.
FEMA in a July 14, 1981 memo from R. Jaske to B. Grimes of the NRC states that they have confirmed with FEMA Region IX that SCE's letter of June 26 represents agreed positions concerning FEMA's major concerns, what needs to be done to correct them, and SCE's proposed actions to assist in correcting them.
The NRC staff has reviewed the corrective action proposed by the licensee to address the FEMA determinations and concluded that when completed these actions will adeqdately resolve the expressed concerns.
Accordingly, in an October 26, 1981 s
letter the NRC advised SCE that the deficiencies identified i
by FEMA must be r'esolved and SCE mu'st clearly demonstrate that the deficien-cies have been corrected before the staff can complete its assessment of the over-all stata of emergency preparedness with respect to Unit 1.
SCE stated in a letter to FEMA dated October 15, 1981, that they have completed all of the items of concern identified in the June 26 letter.
FEMA is reviewing the October 15, 1981 letter and is expected to make a final determination on the adequacy of l
these actions in mid-November 1981.
In view of the NRC staff's previous evalua-tion of the current emergency plan, the present efforts to further upgrade the emergency preparedness at San Onofre, and the schedule to meet FEMA's concerns l
in the near-term, there is no unacceptable risk to the health and safety to
\\
the public that would justify an order to shut down San Onofre Unit 1.
l Mr. Nader quotes the values of acute fatalities (130,000) and latent fatalities (300,000) from a supp1'ement to the Draft Environmental Statement (DES) for San Onofre Units 2 and 3.
The calculations did not apply 'to Unit 1.
In addition,
I the Final Environmental Statement for Units 2 and 3 (NUREG-0490) states that for serious accidents with the low probability of 10 s, the values of acute fatalities is 30,000 and latent cancers for 80 km/ total is 12,000/24,000.
For the very low probability accidents having the potential for causing radia-tion exposure above the threshold for acute fatality at distances beyond 16 km (10 mi), it would be reasonable to expect that authorities would evacuate per-sons at all distances at which such exposures might occur, even though planning for such a contingency is not required.
Acute fatality consequences would therefore reasonably be expected to be very much less than the numbers shown.
See Appendix A, Tables 1 and 2.
Mr. Nader quotes a " property dama'ge" value of $180 billion from a Science Appli-cations, Incorporated study.
This-value is from Table 11-24 A, and is, as in the use of the values for health effects, also for a release from San Onofre Unit 2 or 3.
The value is not appropriate for San Onofre Unit 1 because of the lower inventory of radioactive material in the Unit 1 reactor core.
Mr. Nader asserts in paragraph four 'of his July 10, 1981 letter that:
"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 dis-covered and mapped by the U.S. Geological Survey at the request of' the NRC.
Traces of~both this fault and the Newport-Inglewood 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."
Although not identified as the Cristianitos Zone of Deformation (CZD), a feature aligned along the CZD known as Fault E, which is not part of the present day mapped Cristianitos Fault, was identified and mapped in 1971 by Marine Advisors Associates, consultants to the Southern California Edison Company.
The fault
was removed from their 1972 maps because further interpretation did not substan-tiate a continuous fault, but rather a discontinuous zone of deformation.
A detailed investigation was made in 1980 by Southern California Edison at the request or the NRC,' assisted by the U.S. Geological Survey (USGS), to determine -
the offshore extent of the Cristianitos Fault and to determine whether it is structurally related to the Offshore Zone of Deformation (0ZD) of which the Newport-Inglewood fault is a part.
The closely spaced, high ' resolution seismic reflection profiles taken offshore of the SONGS site revealed a zone of discon-tinuous, en echelon faults and folds which were collectively referred to as the CZD.
The CZD is not seen in the sea cliff exposure along its projected trend. Also, a Pleistocene erosion platform, which is believed to be 40,000 to 80,000 years old, can be seen in the seismic reflection profiles to overlie, undisturbed, the CZD.
Since this would indicate that the CZD has not moved for at least that period of time, it is considered to be noncapable and does not present a hazard to the SONGS site.
(2ee NUREG-0712, Section 2.5.1.12)
In paragraph five Mr. Nader asserts:
"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 (sic) claims that the damage has been co'rrected through the use of an unprecedented plugging and sleeving process, but even the NRC admits that the S67 million operation was
' highly experimental.'
This means that Unit I is not only externally incapable of withstanding a serious quake produced by the Newport-Inglewood fault, but that internally it is highly susceptible to any major ground motion.
These conditions, in such a densely popu-lated area, are clearly intolerable."
The steam generator tube leakage at the time of the April 1980 shutdown was 270 gallons per day.
This was considerably less than the allowable leak rate
limit of 430 gallons per day permitted by the Plant Technical Specifications.
Subsequent inspections revealed the cause of the leakage to be intergranular corrosion attack of the tubing at the top of the tubesheet elevation.
The extent of intergranular co.-rosion attack was found to be general throughout the central reg.fons of the tube bundles where substantial sludge had accumu-lated on the tubesheet.
Approximately 60% of the steam generator tubes needed repair based upon the inspection results.
General industry practice for performing tube repairs has and continues to be the plugging of the affected tubes on both the inlet and outlet sides, thereby effectively removing these tubes from service.
However, the plugging of each of the tubes requiring repair during the April 1980 outage would have resulted in excessive loss of available heat-transfer area.
For this reason, Westing-house' and Southern California Edison developed a sleeving repair technique as an alternative to plugging.' The advantage of sleeving, as opposed to plugging, is that it allows the repaired tubes to remain in service.
Similar sleeve repairs have been performed previously a't other plants (Palisades in 1978 and R. E. Ginna in 1980), but for a much smaller number of tubes.
i I
Sleeve repairs involve the insertion of a smaller diameter tube (i.e., the sleeve) into the tube to be repaired.
The sleeve is inserted until it' spans the affected region of the affected tube, and a sleeve to tube joint is formed at the upper and lower ends.
The San Onofre sleeves were designed to function as the primary pressure boundary, with no credit taken for the remaining strength of the affected tube wall.
Like the original tubing, the sleeves have been designed and analyzed in accordance with Section III of the ASME Boiler and -
Pressure Vessel Code and applicable regulatory guides.
The governing load con-ditions included the differential pressure loadings and differential thermal expansions (between tubes) associated with design, test and faulted (e.g.,
Loss-of-Coolant Accident (LOCA) or Main Steam Line Break (MSLB)] conditions.
Seismically induced loadings are not a governing load condition for steam gen-erator tubing except at the upper support plate and U-bends.
The recent cor-rosion problems and sleeves are located at the tubesheet where the seismic-induced loadings are reported to be very small.2 The structural integrity of
.the tubing at the more limiting upper support plate and U-bend locations has been verified previously by the licensee on the basis of the 0.67 g ground motion earthquake prescribed by the NRC.3 The steam generator repair programs " implemented during the Ap'ril 1980 outage at San Onofre Unit I has been evaluated by the staff and found to be acceptable.4 Southern California Edison has implemented a number of corrective measures to i
retard the rate of further corrosion.
These include the use of secondary side hot and cold water soaks, stricter surveillance and control of the secondary water chemistry, and reduced temperature operation'.
The San Onofre steam gen-erator tubes, including the sleeved tubes, will be inspected at regular inter-vals as required by the Plant Technical Specifications.
San Onofre Unit 1 has a license condition to perform the first such inspection within six effective full power months following restart from the April 1980 outage.s Any additional W estingnouse Report No. SE-SP-40(80), Revision 1, " Steam Generator Repair Report for Southern California Edison San Onofre Unit 1," March 1981.
3 Southern California Edison letter to the staff dated February 14, 1977.
' Safety Evaluation by the Office of Nuclear Reactor Regulation supporting Amendment No. 55 to Provisional Operating License No. DPR-13, Southern California Edison Company, San Onofre Unit 1, Steam Generator Repair Program and Restart, Docket Number 50-206, June 8, 1981.
5See M.
~..
u
corrosion will result in additional repairs and other corrective measures as appropriate.
III On the basis of the foregoing, I have d'etermined that no adequate basis exists for ordering the suspension of the operating license for San Onofre Nuclear Generating Station, Unit 1.
Mr. Nader also requested that the Commission con-duct a " license review" for Unit 1.
The staff has been conducting a compre-hensive review of Unit I under the auspices of the NRC's. Systematic Evaluation Program (SEP).
The SEP is a program begun in 1978 by the NRC to review the licensing basis of older operating facilities, including San Onofre Unit 1, in order to provide:
(1) documentati'on regarding comparison of the facility with current criteria on ~significant safety issues (topics) and a rationale for accept-able departures from these criteria, (2) integrated and balanced decisions with regard to any required backfitting, and (3) a safety assessment suitable for use in considering a conversion of a Provisional Operating License to a Full-Term Operating License where applicable, as for San Onofre Unit 1.
The SEP topic review for San Onofre Unit I was about 72% complete as of September 30, 1981. The draft safety evaluation providing the results of the review is presently targeted for summer 1982.
I believe that the SEP review esse'ntially meets Mr. Nader's concern that the Commission reassess the licensing basis for older plants like San Onofre Unit 1.
However, I have not found that there is a basis to suspend operation at this time during performance of the SEP review.
Consequently, Mr. Nader's request is denied.
l
'19
A copy of this decision will be filed with the Secretary,of the Commission for review in accordance with 10 CFR 2.206(c) of the Commi'ssion's regulations.
As provided in 10 CFR 2.206(c), this decision will constitute the' final action of the Commission twenty-five (25) days after the date of issuance, unless the Commission, on its own motion, institutes thf review of this decision-within that time.
d Harold R. Denton, Director Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this 16 day of November, 1981 Attachments:
Appendices A and B 9
e e
M 9
^E
APPENDIX A 9
The following tables summarize some of the results relating to the calculated consequences of severe accidents postulated at the San Onofre Nuclear Generating Station Unit 1 site.
The calculations were performed as part of ongoing siting studies in support of siting.rulemaking.
The results, shown in Tables 1 and 2, were based on a number of assumptions that were used in the modified version of CRAC code.- The definitions of acci-dents and the evacuation scenarios used in the calculations are shown in Table 3.
For San Onofre 1 site the calculations.used:
(1) closest meteorological station at Sante Marie, California, (2) 1970 census population data, and (3) 1347 MWt power level.
In Table 1 the model assumes evacuation to 10 miles only.
In Table 2 the model assumes evacuation to 20 miles.
In Tables 1 and 2 the Evacuation Scenario 1 is referred to as "best," Scenario 7 (30%, 40%, 30% weighing of Scenario 1, 2, and 3) is referred to as " Summary," and Scenario 5 (which is based on a 24-hour acute dose) is referred to as "No" evacuation.
These scenarios are described in Table 4.
Figures for latent cancer fatalities in the row labeled " Initial" are due to whole body dose from initial exposure, while those labeled " Total" are an A-1 e
integral of latent cancers for all age groups exposed for their remainder of
~
respective lifetimes.
a 9
e eum G
~
A-2 L.
Table 1:
Calculated Consequences of Accidents at San Onofre Unit 1 Using Actual Power Level of 1347 HWL Evacuation Out to 10 Miles SST-1 SST-2 SST-3 Prob.
Prob.
Prob. -
Hean Peak of Peak Hean Peak of Peak Hean Peak of Peak "Suanary"* Evacuation Acute Fatalities 0.0339 126 4.79 x 10 80 0
0 0
0 AcuteInjuries 17.7 22,200 4.79 x 10 30 0
0 0
0 "Best"* Evacuation 3
j" Acute Fatalities 0.0339 126 4.79 x 10 10 0
0 0
0 g
Acute injuries 14.3 22,200 4.79 x 10 10 0
0 0
0 "No"* Evacuation Acute Fatalities 4.64 2,900 7.01 x 10 88 0
0 0
0 Ac.ute Injuries 122 22,200 4.79 x 10 30 0
0 0
0 Latent Cancer Fatalities **
Initial 152 2,260 2.20 x 10 8 6.18 84.2 2.20 x 10.s 0.0371 0.401 2.35 x 10 s Total 1490 14,100 1.52 x 10 8 78.5 872 7.61 x 10 18 0.219 1.66 7.61 x 10 18
- See Table 4.
- 8ased upon " Worst" Evacuation of Table 4.
s O
Table 2:
Calculated Consequences of Accidents at San Onofre Unit 1 Using Actual Power Level of 1347 MWt Evacuation Out to 20 Miles SST-1 Prob.
Mean Peak of Peak "Sumary"* Evacuation Acute Fatalities 0
0 Acute Injuries 2.3 1,700 3.2 x 10 8 "Best"* Evacuation Acute Fatalities 0
0 Acute. Injuries 5.2 x 10 2 270 6.2 x 10 10 "No"* Evacuation Acute Fatalities 4.64 2,900 7.01 x 10 10 Acute Injuries 122 22,200 4.79 x 10 10 Latent Cancer Fatalities"*
Initial 130 2,300 1.5 x 10.a Total 1,100 14,000 9.8 x 10 8
- See Table 4.
~
- Based upon " Worst" Evacuation of. Table 4.
i
[
l l
A-4 m
Table 3:
Assumptions for Siting Analysis Time of Release Warning Release Release Probability Release Duration Time Height Release Category (reactor yr) 1 (br)
(hr)
(hr)
(meters)
Energy SST 1 1 x 10 4 1.5 2
0.5 10 0
SST 2 2 x 10 4 3
2 1
10 0
SST 3 5 x 10 4 1
4 0.5 10 0
SST 4 1 x 10 3 0.5 10 0
SST 5 5 x 10 3 0.5 1
10 0
Acciderit Tyoe Nature of Containment Leakage SST 1 Core Melt Large! Overpressure failure SST 2 Core Melt Large, H2 Explosion or Loss of Isolation SST 3 Core Melt
- 1%/ day SST 4 Gap Release
- 1%/ day SST 5 Gap Release
- 0.1%/ day s
4 A-5
Table 4:
Emergency Response Scenarios D,istance Time before Evacuated Evacuations Rate of Evacuation
("Best")
-1.
Evacuation 10 Miles 1 hr Delay 10 mph 2.
Evacuation 10 Miles 3 hr Delay 10 mph 3.
Evacuation 10 Miles 5 hr Delay 10 mph
~
4.
Sheltering 10 Miles 6'hr Relocation Regional Sheltering Facilities
("No")
5.
No emergency response (24 hr acute dose)
(" Worst")
6.
Evacuation 10 Miles 5 hr Delay 1 mph
(" Summary")
7.
Evacuation summary (30%, 40%, 30% weighting of 1, 2, 3) e a
e t
e e
a A-6
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l APPENDIX B CORRECTIVE ACTIONS REQUIRED 10 ADDRESS FEMA DETERMINATIONS OF JUNE 3, 1981*
l FEMA CONCERNS FEMA RECOMMENDATION RESPONSE **
i FEMA Region IX Evaluation of Plans and Capabilities "Most Critical Concern" 1.
The assessment and
' Develop a multi-jurisdic-Continue to install the Health Physics Computer which monitoring of actual tional response capability will provide a prompt conservative assessment of the offsite radiological to assure adequate coverage actual radiological consequences of an accident. This consequences of a radio-of plume pathway and stan-will be operational to a limited degree by fuel load logical emergency condition dardized procedures which with full operation expected by July 1982.
Further through methods, systems allow flexibility in develop standard radiological monitoring procedures and equipment is considered response.
(50P's) for the local jurisdictions and the Offsite to be weak and in need of 9 Dose Assessment Center (ODAC) by August 1981.
SCE i'
improvement to meet minimum additionally will assess the local jurisdictions' criteria.
current equipment against their needs and identify M
)
any deficiencies noted.
SCE will provide staffing to assume a role of leadership in this function.
SCE will provide training programs for personnel involved in use of the 50P's.
" Serious Concern" 2.
The interim - EOF shows a Until the permanent EOF is
.SCE will develop 50P's to make current EOF operations l
lack of clear operating completed, the interim EOF clearer and more manageable along the lines of the procedures, fragmentation should be relocated to a current planning arrangements.
Limited physical of the facility, lack of single location separate improvements of the present facilities will be 1
management direction com-from the San Clemente'EOC identified and accomplished.
i munications, size of the and staffed with management,
~
facility, and is a signifi-communicators and other cant impedance to the San support personnel necessary Clemente EOC operation.
for EOF operations.
DThe schedule for these actions is identified in pages B-4 and b-5.
l coAs a result of a meeting between FEMA and SCE on June 15, 1981, it is SCE's understanding that the significant concerns addressed in the FEMA Region IX Evaluation of the May 13, 1981 Exercise are covered in these planned actions.
P
FEMA CONCERNS FEMA RECOMMENDATION RESPONSES
" Major Concerns" j
3.
A need to clarify monitor-Develop a joint standard-(See item [1] above.) SCE will develop standardized ing and assessment duties ized multi-jurisdictional procedures for the five involved counties to obtain for both plume and inges-response team.
samples, conduct analyses, and take necessary protec-tion pathways as they tive actions for the ingestion pathway emergency pertain to State OES, planning zone consistent with the State Radiological State Radiological liealth llealth proposed ingestion pathway procedures.
Develop 4
and. local jurisdiction.
an integrated radiological' response team to be directed l
by the Offsite Dose Assessment Center (00AC) to conduct field monitoring.
4.
Means to provide early Install sirens and provide SCE will proceed with current plans for siren installa-notification and clear warning dissemination tion.
SCE will develop 50P's for public notification instructions to the public capacity to remote areas via the Emergency Broadcast System (EBS) and local sta-within the plume exposure where public address tions identified in the plans.
SCE will develop 50P's pathway EPZ have not been
, systems from surface. or
, for coordination and decisionmaking in use of sirens.
' c=
installed or tested.
airborne vehicle is required.
no
.S.
Adequate emergency facill-SCE provide response equip-
. Agreements have been made between SCE and local agencies ties and equipment to ment which was promised to that specific equipment will be ordered by the local support the emergen y the local jurisdictions, jurisdictions and billed to SCE.
Equipment procurement response have not been including sirens and addi-has begun and is continuing.
SCE will follow up with provided.
tional communications report on status of equipment received or on order.
equipment.
SCE will review equipment needs and status of equipment procurement activities.
1 1
I 6.
Radiological emergency SCE, in conjunction with the (Seeitems[1]and[3]above.) SCE will develop and response training has State of. California, should implement a program of training in the critical areas essentially not been develop the necessary train-of radiation monitoring and assessment, communications, provided to those who
.ing to meet'the identified decisionmaking and coordination regarding protective uay be called upon to needs in the local actions, etc.
l assist in an emergency.
jurisdictions.
f I
l l
I t
FEMA CONCERNS FEMA RECOMMENDATION RESPONSES
" Sufficient Concern to Remain a Major Issue"'
7.
SCE has not made informa-Disseminate advance public SCE will proceed with the public education program that tion available about how information.
includes an emergency response brochure and radiation the public would be notified information brochure mailer, preparation and distribu-or what the public's initial tion of flyers and posters, new ads, community meetings, actions should be in an etc.
emergency.
e e
6
+
SUMMARY
OF PLANNED ACTION SCHEDULE Items (a) through (h):
1.
Develop 50P's covering the following topics:
1st draft - 7/15/81 a.
Operation of the Offsite Dose Assessment Final draft - 9/1/81 Center (ODAC)
Implement - 10/1/81 b.
Radiation surveys by field monitoring teams c.
Emergency Communications d.
Use of the siren alerting system and public notification e.
Coordination relating to protective actions f.
Acquisition, display and use of meteorological data g.
Operation of the EOF Item (i):
h.
Ingastion pathway monitoring 1st draft - 9/15/81 Final draft - 11/1/81 1.
Existing SOP's covering other plan elements Implement - 12/1/81 2.
Obtain equipment required to carry out radiation monitoring functions a.
Survey types and quantities of equipment 7/15/81 l
actually in place 1
l b.
Initiate procurement of equipment-shortages 8/1/81 3.
Develop additional communications capability a.
Expand interagency phone network to include 7/15/81 CHP 1
b.
Provide speaker monitors at EOC's 7/15/81 c.
Provide teletype message system network 10/15/81 between all principal centers d.
Provide additional communication circuits 10/15/81 i
~
B-4
SCHEDULE 4.
Make physical improvements to the EOF a.
Identify possible improvements 9/1/81 b.
Obtain agreements to make improvements 9/1/81 c.
Construct improvements 10/15/81
~
5.
Install Sirens 50% by 7/1/81 90% by 9/1/81 100% by 10/15/81 6.
Accomplish training in use of new and existing procedures, facilities, and equipment a.
Develop training program (long and short term) 7/15/81 b.
Develop training material (short term program) 9/1/81 c.
Conduct training and drills (short term program) 9/1/81 through 10/15/81 d.
Implement long term training program 11/1/81through 2/1/82 7.
Public Information' Program
- Ongoing, Initial program complete 9/1/81 6
i 8-5 ~
3 7590-01 UNITED STATES NUCLEAR REGULATORY COMMISSION DOCKET NO. 50-206 SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 1 ISSUANCE OF DIRECTOR'S DECISIONS UNDER 10 CFR 2.206 By petitions received sinc ~e November 1979 (44 FR 75535, December 20, 1979) approximately 1560 California residents have requested that the Nuclear Regulatory Commission's Director of Nuclear Reactor Regulation suspend or revoke the operating license for the San Onofre Nuclear Generating Station, Unit 1.
By letter dated July 10, 1981, Mr. Ralph Nader also requested that operation of San Onofre Unit 1 be suspended pending completion of a " license-review" for the facility. The petitions and Mr.'Nader's letter have been considered under the provisions of 10 CFR 2.206.
The petitions allege that San Onofre Unit 1 is not designed to withstand possible ground motions from earthquakes that may occur and that evacuation plans are inadequate to cope with a potential accident at the site. Moreover, in an updated petition distributed by the Alliance for Survival in 1980, the petitioners expressed seismic concerns in light of the Livermore earthquake of January 1980. The updated petition also pointed out that the Rogovin Report to the Nuclear Re'gulatory Connission on the Three Mile Island accident recommended that old reactors near major cities be shutdown until evacuation plans are realistic. Mr. Nader requested that operation of San Onofre Unit 1 be suspended until that review is completed.
G1120GG11P 811116 PDR ADOCK 05000206 G
7590-01 2-Upon review of information pertaining to the seismic and evacuation concerns at San Onofre Unit 1 and the information provided by the petitioners and Mr. Nader, the Director of Nuclear Reactor Regulation has determined that suspension or revocation of the operating license for San Onofre Nuclear Generating Station, Unit 1, is not warranted.
Accordingly, the requests of the residan's of California and Mr. Nader have been denied. The reasons for this denial are explained in two
" Director's Decisions" under 10 CFR 2.206 (DD-81-19; and 00-81-20) which are available for public inspection in the Commission's Public Document Room,1717 H Street, N. W., Washington, D. C. and at the Mission Viejo 3 ranch Library, 24851 Chrisanta Drive, Mission Viejo, California.
A copy of the decisions will be filed with the Secretary for the Commission.'s review in accordance with 10 CFR 2.206(c). As provided
-r in this regulation, the decisions will become the final' action of the Commission twenty-five (25) days after issuance, unless the Commission on its own motion institutes review of these decisions within that time.
Dated at Bethesda, Maryland, this 16th day of November,1981.
FOR THE NUCLEAR REGULATORY COMMISSION 4W W w
Harold R. Denton, Director Office of Nuclear Reactor Regulation O
7
.,,,y
-c m--,
II lb @l ID NAftE ID N4ME 1259 Ablitz, by 223 Bassett, Patricia M.
158 Acken, Allison 1099 Battelle, Anthony 745 Adans, Jennifer Crawford 1219 Baube. Fred L.
955 Adams, John 861 Bauman, Nora S.
1130 Adams Tani fiarie 1360 Beal, Norman B.
500
.Adato, Sam 1376 Beals, Charles S.
326 Adelman, Ilene 139 Beard, Jes 271 Ahans, Betny 488 Beechetti, Gina D.
120 Aja, Ronald 1222 Becker, Lynd.
]*
100 Akers, Jon C.
1480 Becket, Nancy 334 Alberts, Gary E.
1330 Beel, ' Carl S.
f 335 Alberts, Lucy Anne 1526 Beeson, Laurie E.
1482 Alderete. Arthur 949 Belanger, Sharon Edna 1
843 Alexander, !!errie Lee 977 Belin, Linda R.
1332 Allen, Francis 1136 Belmonte Elizabeth 280 Almcpist. Deber:h A.
1469 Belmonte, Joseph 175 Altergott, Gary 1470 Belmonte, Patricia 176 Altergott, Linda 1023 Belshin,tiark i
1392 Alton, John 1294 Ben-Horw J. David 567 Altschuler, Joanne 753 Benado, Tony Leon m
1059 bes, Neal 69 Bennett, James 837 Msterdam, John D.
540 Bennett, Jason 996 Mundson, Robert G.
1335 Bensinger, Charles 1001 Anaya, Mona V.
1383 Benson, Lynne 365 Anderson, Cecile H.
~
1277 Beranek David A.
131B Anderson, Mike 1205 Berg, Cathy 1261 Andrasi, Alexander 1241 Berger, Fred A.
1553 Andrelus, James H.
214 Bergman, Evelyn J.
1554 Andrelus. Jim 439 Bernstein, Jean N.
440 Angell, Carol R.
772 Bernstein, !! arc L.
724 Angiulo, Kenneth 849 Berrner, Jill u
157 Arata, Allen 574 Bessolo, John 340 Amstrong, fiary 51 Bestgen Brent 641 Arrivee, Kristen 943 Bevander, Rose 1.
933 Arthur, Jatki 959 Bikle, Nancy J.
875 Arthur, Jill 1273 Bingaman, Kim Michelle 442 Askew, Lori Sue 1271 Binganan, Phyllis 1287 Atkins, Bryan 526 Bisbey, Cary 1368 Audia, Carl John 934 Bishop, Susan 1429 Aulsebrock, Richard 1000 Bittan, Bradley H.
1424 Austin, Kati R.
999 Bittan,tielinda Inez 620 Austin, Mary P.
1088 Bitzer, John filchael ISS Avey, Randel T.
976 Blach, Joyce 970 Awad, Charles M.
1559 Black, Karen Louise 1833 Azelton, Joyce 1372 Blacknan, Patricia A.
1325 Bailey, Janes 145 Blair, Bob 736 Bailey, Steffani 974 Bla1., Randy S.
l 1230 Bakke, Jean C.
674 Blake, Ted I
t 1
972 Balch, Robert T.
527 Blocker, Debbie 597 Baldi, John 528 Blocker Dolphia
~
515 Baldwin, Alison 853 Blutman, Loren ti.
1430 Ballard, Faye 539 Boeheim, Frank l
n 483 Barb, Linda 1084 Bonsack, Paul R.
1516 Barbour, Olivia L.
902 Bort, David H.
565 Barclay, Carolyn 1484 Boruff Barbara 1020 Barkley, Jr., William H.
90 Bothamley, William 427 Barling, Lesley 993 Bottfeld, Susan i
1340 Barnes, John C.
128 Bouguin. David 1344 Barnes, Steven D.
696 Bounakes Elizabeth 1072 Barnett, Juhn F. X.
1203 Bowie, Barbara 841 Barnett, Penelope F.
901 Be man, Dennis 1381 Barnett, Rick 468 Bo man, Robin 973 Barnyt, Bernard 779 Brack, Mark Leslie i
i 193 Barone,flichelle 186 Bradley, Joseph P.
327 Barrows, Daniel H.
1494 Bradley, M.
i 1035 Bartholomew, Valerie 1495 Bradley, H.
[
450 Bartlett, Alice 1149 Bragg, Leslie 1356 Bartolini, George 473 Braida, John Peter l
1355 Bartolini, Joseph 1402 Brain Laurel
[i 552 Basara, Robert M.
677 Brannon, Kathy 164 Bassett Elizabeth 923 Bratter, Adam i
mm
Q NM1C 2
W1E 1517 Brennan, C. J.
137 Chazan, tiene ti.
244 Erenner, Joanne B.
1134 Chlebda, Jim 70 3retz. Elizabeth S.
372 Christian, Linda 356 Bretz, William L.
1073 Christy, Dianna 445 Bricault, Lynda 1245 Church, Kelly Jean 1323 Brivet. Laurent Christophe 673 Ciaccio, John J.
,,,1165 Breach, Jody L.
1358 Cirillo Nellie 652 Brooke, Richard S.
380
'Clabaugh, Sheri 1147 Brown, Gail 1186 Cline, Eddy Robert 1432 Brown, James B.
293 Coffnan, Jennifer
+
d 1187 Brown, Marty 134 Cohen,' Arthur R.
I 1129 Browne, Todd T.
588 Cohen, Donald 143 Brunnett, Christine 889 Cohen, Richard 447 Bruns, Robert 1030 Cohen, Susan C.
000 Brutschy, !!arcy S.
1339 Cohn, David 1
798 Bnatschy, !!ary A.
738 Coit, James 1137 Buettner, Lanny Steven 182 Colburn, Loren 333 Bu111vant, fielante 201 Collan, K.
239 Bullock, Diana Reade 1468 Collins Chalynn 146 Bumatay, Pier R.
776 Collins, Gregory D.
197 Burdige, David 1241 Collins, John L.
l 1528 Burfoot, Nora 371 Collins, Peter 421 Burgess, Fred 1350 Canbe, Pamela I.
35 Burkholder, Nancy 1078 Comerchero, Scott 704 Burns, Robert A. H.
444 Comire, Arlynne 541 Burns, J.D., Robert 1247 Cone, Ronald E.
926 Burrows, Julie 616 Conger, Anita H.
131 Byer, Timothy Grant 542 Connors, Brian 679 Byrne, Nancy S.
1320 Conrad Christopher 1413 Cahumada,'
1228 Conrad, Yim 501 Cain, Patrice 1509 Contreras, Martha Dean 325 Cain, Sandy F.
1083 Conway, Susan E.
932 Caldwell, Karen J.
1146 Cook, Alan ti.
846 Callahan, fiaureen 259 Cook, Bonnie Jr 581 Callison, Dorothy B.
1050 Cook, Diane A.
599 Cambaliza, Deborah 228 Cooley, Will 927 Cooper, Toni 986 Canglis, Paslo p
39 Canpoy, Kenneth 1308 Coppen, Ralph 4
1444 Cana11. Dan 1309 Coppen, Tracy i
215 Cante, Cheryl 965 Corbert Andrew b
572 Canty, Robin L.
15 Corser. Scott 645 Capocefalo, Suzanne 20 Corser. Sust I'
209 Capozziello, D. flichael 307 Corte11 yon, Pamela L.
I 256 Capozziello, Ita rlene 309 Costa, Frank h
533 Caranani, fl.
1450 Coverley, R.
h 275 Cardoza, DeAna L.
1122 Crane, Sheila D.
L.
24 Carlson, Richard 107 Cristal, Laurie 1408 Cannichael, L. B.
106 Cristal, fiel s.
669 Carney, Jane 1285 Crites Jodie 254 Carratu, Michelle 1227 Cronuel, Chris 571 Carratu. Roan 936 Crowley, Barbara J.
1481 Carrera,~ ttanuel 762 Cunningham, Robert A.
I 770 Carriagton, liichael 1102 Curtis, mary A.
(
454 Carroll, Andrea 1272 Cypher, III, Edward P.
[,
1135 Carroll, Joyce it.
66 Dagne, Diane 61 Carroll. Trudy V.
941 Dailey, Edmond J.
1352 Carruthers, Joany Elizabeth 590 Dallaire, Joseph A.
833 Carson, Karen 1231 Dallman, Peter L
1191 Carson, Vance 560 Daly, Peter B.
[
658 Carter, Mary E.
850 Danesi, Tim i
1513 Carvison, Ronald E.
898 Dauer Neva 422 Castelli, Alex 1463 Cavenport, Lynda 131 Cauchen, Lisette 1094 Davidson, Robert 1298 Cauchon, Therese I.
1311 Davis, Barbara t I 1393 Caughie, David 818 Davis, Michael 1006 Caughie, Jill S.
16 Dawson, Corky 298 Caward, Lauri 1534-Dawson, Frank A.
1427 Cemcione, Joseph 413 Day, Kathi 1027 Cery, Robert 7
Day. Marcia 290 Chambers, Kathyrn Ann 887 de la Rosa, Michele 717 Cha se, l'.a ryanne 806 de la Torre, Edward n
R NA!!E R
NAME 803 de Lava 11ade, Celia 17 Fay, Joseph 709 Dean, Ceana D.
18 Fay, Kay L.
761 Dean, Debbie L.
370 Feder, Judson J.
1193 Dean, fiargo 1434 Fef bel,' Eernadette 121 DeBacker. Patrick J.
568 Felber, rtary F.
219 DeGiacomi, Gilbert J.
88 Ferdula, Susan Jo
~
1139 DeGuelle John E.
555 Ferguson, Karen 1475 Deitrick, Donald L.
546 Ferguson,liark D.
918 Del Gaizo, !!ary V.
1443 Fernandez, Jill R.
7 216 Delmonte. Peter J.
82 Fieldman, Anita
- r 586 Denberg, Lisa I.
1329 Fietje' Cindy 1362 Dennison, Lisa 561 Finch. William E.
226 Deva. Irene 868 Findholm, Barbara 419 Ceverter. Tierney 894 Finkelstein, Gerri 1237 Devine, Ron 549 Fisher, Donna 5.
i 1009 Davries Dwayne 824 Fisher, K. C.
1512 DeYoung, David J.
550 Fisher Larry 1
45 Dill, Jimy D.
635 Fisher, Patricia Ann 855 Dill, John 905 Fiske, Joyce 5.
907 Dillon, Lynn 512 Fitzpatrick, Susen M.
461 Dilts. Patricia J.
227 Fitzsinmons. Kevin J.
886 DiPaola, Anthony 882 Fix, Jenses 657 Dobyns, !!ary 991 Flaherty, Vincent R.
373 Dodge, Mark W.
1103 Flanigan, Kelly 1533 Dolinski, Laura 1210 Fleming, Van
+
871 Dollison, Leota M.
1143 Flynn, tiary E.
111 Donnelly, fiark 596 Fogan, Stuart 1283 Dorfman, Idelle 464 Foley, Christine L.
1284 Dorfman, Ken 1045 Foster Todd it.
133 Dorsey, F. Ryan IDS Fox, Betty 160 Dorsey, William 312 Fox, Florence 1324 Doty, Molly A.
313 Fox, Vernon 1131 Doty, William James 1058 France, flichelle Juilla 662 Doughty, Julia A.
1331 France. Ronald-K.
893 Douville, touise ti.
836 Frangoulis, Dianne r
305 Dowell, David A.
397 Frazier, Pam C.
i 1278 Dozier, Patricia 659 Freednan. Nancy l'J38 Drapkowski, Carol 606 Freenon, David A.
726 Drechsel, Panela K.
233 French. Scott W.
324 Drews, !!ichael D.
688 Freund. Michael 796 duBois. Julie 750 Frey, Craig A 794 duBois, Nancy 803 Friedman, Bradley
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1497 Duffen, John M.
1515 Friedcan, !!ildred 1019 Duncan, Douglas B.
125 Fritz, Sandra Lynn 1057 Duncan, Ruthanne 456 Fulton, Kim W.
628 Dye, Jr. _ttorris E.
589 Funk, Jr., Donald A.
706 Eck, Deborah L.
1433 Fuscaldo, Rocco 354 Eddy, William A.
603 Futteman, Robert L.
60 Edinger, Iris 681 Gaber. Claudia 1
615 Edmunds, B.
723 Gabrych. Elizabeth 1159 Ef ting. Charles C.
712 Gaede Robert C.
a 642 Ehlmann. Grace N.
1541 Gallant, Joseph D.
J 963 Ehrenfeld. Rick 848 Gallinger, Karen 1138 Eichert. Rand 643 Galt, Linda G.
978 Eichner, Mauna 200 Gannen, Barbara h
287 Eisek. Burna J. C.
339 Ganz, Sara Lynn 521 Ekhoff. John R.
1373 Garcia, Amando 1379 Elia Anthony G.
285 Garcia. Rebecca 5.
1062 Elkin. Aaron J.
295 Garcia. San F.
1061 El kin. Diane 5.
1125 Gardner, Carl Dennis 1065 Elkin, Lawrence Neal 428 Gargus Suzanne 1367 Ellison, Joy 184 Garland. W. Gary 997 Emley. James 110 Garvey, John it.
1096 Empson. Kimberly R.
890 Gaylord, Christopher 26 Engstrom, Lynn 257 Gekler, Sandra L.
807 Erdman, Linda A.
1025 Gelber David Lawrence 1337 Fagin Eleanor 1208 Genovese. Don 1361 Fanis, Gleason 604 Gentry, Charles a
1189 Famer. Ken 1090 Geman, Gregory W.
1176 Farrell, Jeffrey 8.
5 Gertler. Jeffrey 1451 Farris, David tiichael 1307 Gibney, David s
10 Nfd1E 10 NM1E 211 Gibney, Thomas D.
103 Hamilton, Edythe it.
877 Gibson, Jerry 361 Hamlet. Dana 913 Gilbert, l'.arilyn 896 Hannond, Celeste 914 Gilmore Elizabeth 1036 Hamond, Sean 916 Gilmore, Jennifyr 786 Hanpton, Holly 815 Gilmore, Lesli 1243 Hancock, Barbara L.
1391 Girdner, Eddie J.
1317 Handrvch, Patricia I 1163 Giuliani, Angel H.
1254'
'Hanley, D. Bridget 187 Glaser, Jeffrey 1180 Hanley, Kathi 337 Glass, Gary 1179
.Hanley, Steve D.
+J 431 Glass; Robert D.
213 Hann, Greg S.
'i 946 Glayer, Mark A.
844 Hansen, Brett i
945 Glinos. Dianne 425 Hansen-Nelson, Asta 1168 Glowaty. David A.
519 Hansesty, John 1169 Glowaty, Michael E.
1004 Hardin, James 289 Glusman, Paul 879 Hargrove, Dennis 944 Gnn, Robert 1195 Haman, Susan 1107 Godanis, Brian K.
569 Hamon, Brett 4
1366 Godfrey, Geoffrey A.
395 Hamon, Robert 304 Goff Warren 860 Harris, Barbara 1140 foggin, Anna l'.arte 42 Harris, Christy 75 Goland, Lee 1270 Harris, Craig L.
925 Gold, David 351 Harris, James F.
i 353 Golden, Nancy P.
328 Harris, Linda McConnell l
1535 Golden. Sandra 505 Harris, Michael ld 399 Goldman,Itay 857 Harris, Paula l
1291 Goldman, Steven L.
903 Harrison, Randolph 8 85 Goldwasser. Esther H.
1370 Hartman, Roxane 987 Golnbeff, Anna V.
1502 Hartmon,111chael 1041 Gonzales,' Stephen Isaac 523 Hasir, Helen E.
1310 Gonzalez, Servando 900 Haskell, Bette 1192 Good, Ema Jean 952 Haskell, Carol L.
[
666 Goodwin, Joseph J.
637 Hastings Sharon L.
725 Gottschalk, Craig P.
787 Havill, Valerir
[4 744 Goudy, Daniel J.
1086 Hawn, Leroy A.
1489 Gaulart, Robert A.
1087 Hayduk, Stanley D.
683 Govela, Jessica 663 Hayes, Leone ti.
l 462 Graeme, Jr., James E.
660 Hayes, Lester 1557 Grandy, Willian 1126 Hayhurst, I, Kirk 367 Grant, Shirley A.
960 Haywood, Dawson H.
{
1291 Gray, Ceborah L.
958 Hayacod, Suzanr.e F
1274 Gray, Hichael S.
1518 Hazboun, Rii:hard 284 Greb. Belinda 1336 Healy, Robertine 713 Green Tisha 1034 Heckhaus, Philip Lewis t-251 Greenan, Robert W.
83 Heifetz, Ruth 11.
L
~
79 Greene, Lou Es 1402 Heinlein, Anna L.
410 Greene, ShTron 1160 Heiser, Judy Ann 6 64 Greghan, S. H.
1473 Held, Robert H.
l' 897 Gregston, Patrick 484 Helquist Paul Roger 1333 Griffith, Linda Louise
'a55 Helsley, Pamela S.
525 Groebel Stephanie 698 Hen, Earl 623 Groode. David 1411 Henderson, Janice C.
611 Groode, Jason D.
612 Henderson,!!ary K.
3 82 Groome. Deborah S.
1200 Hendricks, Nancy L.
381 Groome, Richard H.
1477 Hendrickson, Gloria M.
863 Gross, Helen 283 Hendrix, Joe D.
-e 648 Gross, Phillip C.
22 Henkle, Randy J.
695 Gruber, Jennifer L.
1529 Heman, Anne 1496 Guerrero, Arthur 1530 Herr, Jeff 1092 Guild Dolores 951 Hersch, Lisa J.
865 Guiney, Joe 937 Hersh, Louis R.
1458 Gusesheck, G.
294
.Hess, Catherine 1133 Gustin, Cherly A.
7J2 Hess, Ja:k R.
235 G'atterrez,!!arsha 1417 Hester, Eva E.
792 Gutierrez, Pamela Fairchild 1418 Hester, Luther G.
795 Gutierrez, Victor 1416,
Hester Stephen E.
93 Hahn, Philip A.
592 Hettig Julie 487 Halal, Catherine 1158 Hecann, Eve 740 Halgren, Jeanne 1055 Hidde David 771 Hall, Jeffrey G.
336 Higgins, Georgena Ann 1240 Halley, Jan 467 Higgins, Virginia 11.
L ID EME ID NAME 1522 Higginson, Kathy J.
1154 James, Kathy 928 Highley, Robert G.
478 James Laurie 161 Hil gers, liillie 1446 James, Lynda 995 Hillenbrand Elizabeth A.
716 James, Michelle 1043 Hillstead, Julie Anne 366 James, Nancy R.
23 Hinde, Margery 491 James, Rick 35 Hingel, Richard E.
511 Janeson, Helene A.
j 994 Hinzc, Jonathan A.
647 Jencks, liuriel Estelle 1156 Hochard, Robert R.
238 Jennings, k.ne 322 Hodge, Barbara A.
783 Jennings, Jack R.
,g' 203 Hodgin, Geraldine 1465 Jensen, Kin 3
l 202 Hodgin Richard S.
1550 Jensen, Lars 240 Hodgjr,,n, Tanara Keta 36 Jepson, Patricia E.
a 707 Hoffman, Clarence J.
998 Jergenson, Richard H
1011 Hoffman, Daniel W.
14 Jofr: ann, Anne F.
1010 Hoffman, Dawn 691 Johnson, Holly 1024 Hoffman, Julie 506 Johnson, Mona 99 Hof fman, Sarah E.
122 Johnson, Patricia Anne 595 Hogan, Craig 1440 Johnson, Rondel E.
W[
4 71 Hogan, Edward J.
28 Johnson, 5. H.
1342 Holcomb, Lisa Anne 872 Johnston, Erika Faye 416 Holyic, William 608 Johnston, Tony 450 Holyk, Holly L.
437 Jones David Evan 975 Holzberg, Roger 593 Jones, Kimberly Clary 1067 Hopkins, Beverly 362 Jordan, Jon D.
21 Hopping, Bruce S.
458 Jesephs, William 1536 Horner, Brett 48 Joslyn, Mark 582 Horner, Hark 1501 Jules. Ed 359 Horowitz, Raynond 199 Justice, Jolene 1521 Horton, Judith 1508 Kaizen Donald C.
1123 Horvath. Arthur 1232 Kalem, Rachel 839 Houchen. Evelyn L.
1217 K.ealet, Jeffrey D.
840 Houche1, Nancy L.
378 Kane, Frank 1054 Houdek, Stacy 650 Kaplowitz, Jahrthan 1056 Howard,Jeff 1558 Karnatz, Dana 1150 Hubman, Mi:hael P.
218 Karno Vicki 477 Hudson, James Barry 1207 Katz, Glenn
[
1412 Hufnaghe, Susan Carol 1204 Kaufmann, Sandy p
140 hunphries, Connie 517 Keener, Thomas 127 Hupf, Gayle A.
1161 Kehl, Daniel
.E 125 Hupf, Mark J.
870 Kehoe, Edward k
84 Hurwitz, Elliot P.
692 Keiller Danny L.
332 Husk, Ksateih 1111 Kelch, Patricia Ann 463 Hutcherson, Leslie 1485 Kelley, Ted
'i 983 Hyde, Donald W.
564 Kelly, George Jay 563
' Hyman, 8atry 917 Kelly, Miceal 1268 Ibsen, Kenneth 765 Kelly, Peter 953 Ibsen, Kristine 281 Kelsey, Barbara j.
950 Ikehara, Karen K.
1505 Kelty, Tom 388 illegible), Petitioner (Name 1044 Kemp, Brian T.
389 illegible), Petitioner (Name 43 Kendall, Duncan 493 illegible), Petitioner (Name 8
Kcrby, Connia A.
496 illegible), Petitioner (Name 129 Kern, Jamie H.
610 illegible), Petitioner (Name 1460 Kester, Craig 1483 illegible), Petitioner (Name 1491 Kierulff, Stephen 627 Ireland, Jill K.
867 Killian, Denice h
1109 1saacson,tiichael 737 Kimons, Sandy L.
1375 Isaacson, Michael 980 Kiop, Linda 1374 Isaacson, Rose 266 Kipilman, Jeff 969 Isenberg, Lenny 715 Kirby Thomas A.
326 Iverson, Terry 1442 Kirst, Susan 964 Izenstark, Susan 1194 Klawitter, Kathleen 247 Jackson, Lola 1202 Klier, Mary 962 Jackson, Mary 331 Klitzner, Bernard David 346 Jackson, Therese 1116 Knapp, William C.
1248 Jacobs, Kristen L.
87 Koch, Ronald L.
532 Jacobson, Daniel C.
288 Koeppen Julie 86 Jacobson, James P.
13 Koll, Juri qb 1267 Jacome Terry 310 Kory, Fern f
405 Jaffe, Jacqueline 414 Kory, itichael 3I 72 James Ira ti.
1532 Kraf f t Ellen I
!~
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ID N41E ID N4tE 675 Kreikeneier, Patty A.
1121 Lindell, Andrea 212 Kreis-Gibney, iterrily 805 Linden,!! ark 113 Kreisberg, Daniel 0.
654 Lindgren, John N.
1157 Krouse Colleen 342 Lindsay, Dean 732 Kuhn, itartha 225 Lindstrom, Ken 1113 Kulm, Jana 494 Linstrot, Vandi A.
479
'Linthicum, Fred 1246 Kusel, Lisa Gay
^
730
- Kyrene, 1425 Linzenmeyer, William G.
262 La Fon, Charyol 263 Liotta, Crissina 11.
]
1082 LaBedz, Sandy 95 Lippert, Joanne 5.
543 LaBouff, Joan 719 Lippincott, William H.
1380 Laffoon. Victoria 713 Lippitt, Kathleen H.
1 185 Lageweg, Cor 1551 Liss, Gary 690 Laing, Sally 1504 Litfin, Karen T.
9 317 Lakritz, Brad 6
Litman, David 411 Lambert. Dorte 1242 Liv'emore, William B.
727 Lancaster, Gilliam 252 Logsdon, Lawrence M.
[
1100 Landa Evelyn W.
25 Logsdon, Noma Jo 1101 Landa, Martin Bennett 1251 Loiacono, Joseph C.
'[
1105 Landa, Philip 1249 Lotacono Nancy i
1437 Landreau Doug 1354 Lonbard, Mathew J.
j 888 Landy, Elayne 5.
1301 Lonczak, John F
308 Lane, John 436 Londe. Helen F.
q, 733 Lane, Noel 242 Longnion, Brenda 1400 Langley, Ethel 207 Lopas. Nancy d
1365 Lanier, Adriene I.
457 Lopez, Jean f
672 Lanning, Gayle E.
968 Loughran, Derek l;
1292 Lapin, Ling 237 Loveless, Carole 729 Larisch, Erich W.
852 Lowe, Stuart 8.
l<,-
1542 Larkey, Leah 764 Lumian, David J.
644 Larson, Peter 1386 Lucian, Geraldine 296 Larson, Ray 1385 Lumian, Noman C.
1003 Lathers, Delmar 50 Lusk, Christopher i
j, 624 Lau, Janics L.
1196 Luster, Sandra'
[~
670 Lau,fiaureen Treacy 1445 Luxenberg, Richard i
1250 Laualle, Larry 495 Lyle Isabelle 1471 Lawrence, Daniel A.
577 Lynch, Sidney J.
823 Lawrence, Marie 1544 Lynch, Sidney J.
323 Layver, Paige K.
459
!!achit, Monte t.
261 Lazareck, Jack P.
557 tiack Elizabeth 1 66 Leath, Joelle ti.
148 t'acKenzie., Joseph D.
653 Leddy, Geraldine J.
147
!!ahoney, Bridget 403 ledsinger, Deborah 873
!!aile, Jonathan 1155 Lefler, Steven fi.
1 83 Maitino, John R.
8 343 Leibson, Sandee 579
!!ajure, Allison 5.
i 1075 Leis, Vickt 1305
!!alenda Curt 892 Leisner, Tina 940 Malloy, James P.
27 Lekas, William 5.
880 Maloney, Susan 435 Lenkin, Adele 1525 tiandel, Peter R.
150 Lennard, Alan
' 566 fiandish, Eugene 149 Lennard, Irene 38 Mandt, Carrell 5, 154 Lennard, Paul 636 Manfull, Dorothy 710 Lerager, Elvin H.
40 Mann, Joyce Marie 153 Lesser, Anna 842 Mansfield, Julie A.
I 253 Lester, Judith R.
678 Mapp. Violet 1457 Levario, Barbara 1546 Marchitto, James 700 Levenson, Alan 1255 Marcus, thrtin 5.
992 Levitt, William 210 Fardian, Jayne M.
i 773 Levy, David 827 Marquette, David 1514 Levy, Sylvia,
671 l'arsh, Michael k
509 Lewis, Charles R.
443 ttarston, ;J bert R.
508 Lewis, Jo 1029 ftartin, Brian John 499 Lewis, tiargaret 1476 Martin, Gary E.
f 782 Libertelli, Mark 1357 Martin, Nancy J.
I.
1346 Lickides, Gregory A.
102 tiartinez, Cher 330 Light, Kristin Joy 775.
Martinez, Philip R.
I 1117 Lightfoot. Denise 476 Martone, San 758 Likins, Carol Frances 734 riason, Elisabeth 167 timent, Kristine V.
321 Mason, James 11.
272 Limont, Stacy A.
651 Mason, Jim 30 Lind. Thomas R.
979
!!ason, Morris 5.
l LIy
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1105 tkCaffery, Greg 932
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708 McCauley, Laurel I.
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866 Rubin, Robert 123 Schweizer, Kari F
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625 Rubio, George 1037 Sears, Leigh 769 Ruchames, Donna 685 Seckler, Linda T.
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407 Russell, Betsy 638 Serden Paige L
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1548 Sanders, Michelene 451 Shurtleff, Michael 551 Sanderson III, Garrett 163 Siegel Eric 232 Sandlow, Jeff fi.
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502 kith, Barbara R.
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1142 Szarkowski, Stephanie E.
1316 Snyder, Barbara 802 Takes, John A.
37 Soar, Steven 1363 Tate. Tom 188 Solden, Chris 364 Tatom. Marilee 763 Solovjovs. Juris 1296 Taumuina, Julia Ann S20 Sonazzaro, David 101 Taylor Daniel E.
329 Sottosanto, Gene 98 Taylor Nancy A.
I 222 Southard, Vern 1319 Tedesco, Thomas L.
i 59 Sowden Sandra 514 Tedrich, Jill
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4 U.S. Nuclear Regulatory Comission 1717 H Street, N.W., Ilth Floor Washington, D.C.
20555 Nunzio J. Palladino, Chairman Victor Gilinsky, Comissioner Peter A. Bradford, Comissioner John A. Ahearne, Comissioner July 10, 1981 Gentlemen:
It has been over a year and a half since the Kemeny and Rogovin Comissions 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 w6uld 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 p'lants in America. Yet, the NRC's Atomic Safety and Licensing Board (ASLB) cor.ti.ues to push ahead in its efforts to license San Onofre Units II and III, Mile ignoring the extremely serious safety issues surrounding the continued operation of Unit I:
1)
San Onofre Unit I has beeri 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, eccording 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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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 passesfright by the plant.
- 5) A June review by the Federal Emergency Management Agency.
(FEMA) concluded that the demon'stration of the evacuation.
J 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.
2 New seismic infomation, unavailable in 1969 when Unit I was licensed.
underscores the gravity of the situation.
In 1980, a new fault zone, the i
Christianitos Zone of Defo'rmation (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 licehsed the Unit I reactor.
Furthermore, the Unit I reactor is plagued with very serious safety i
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 l
$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 cny major ground motion. These conditions, in such a densely populated area, are charly 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 l
issued, is not an inalienable right that cannot be r. evoked.
Instead, it L
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 i
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 i
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.
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Given t.he 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.
c Sincerely, A
L Ralph Nader cc: Gov. Jerry Brown G
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ESP FOR D ST3 TUT 3CN OF PIC'EED2%S 'IO REVdKE OPERkTnX; Li'CDOSE,10 CFRN2.'206, 10:
Director of Nuclear Reactor Fogulation United States Nuclear Regulatory Conmission As a concerned and interested resident of youthern'califor;qia,. do pay be adversely'-
ffected by the unit's continued c5 crating, I/_4,A 8.. )t. hw//w, request the n
@irector of Nuclear Reactor Regulatiori to initiate a proceeding pursuant to 10 CFR 2.202 md 10 CFR 55.40 for the purpose of suspending at revcking the operating license for the an Onofre Nuclear Generating Station Unit One.
New and relevant information is ncw available on potential ground notions at the ito in the event of an earthquake, and this information would have warranted the
- ssion to have refused to grant a license on the original application. Furthernore, o plant is lo ated midway between Ics Angeles and San Diego, one of the nost densely z:pulated and fastest grcwing areas in the country.
Unit I is not designed to withstand pcssible ground notions fran earthquakes on tha Newport-Inglewcod and Christianitos faults and their branches which pass close to the reactor.
These ground notions could break cooling water pipes, cause a loss of x61 ant accident, and lead to a meltdcwn of the fuel rods.
The addition of a concrete shell to the reactor dczne and other nodifications are inadequate to insure against Eamages fran pcssible ground notions,during a maxinun possible earthquake. The new
%d relevant infonration regarding ground notion potential was unavailable den :le, tr approved the design criteria of Unit I or later whe.ri the NRC approved structural ihanges to the unit.
Seismic design crite'ria for Unit I was based on inadequate data bn reasure rents of grcund notions close to the source.of the ea. Wakes.
Recent' talifornia earthquakes near Santa Barbara in August,1978, near San Jose in August,1979, hnd in Inperial Valley in 0:tober,1979, have revealed new and relevant information about Wound notions that was not available to the NRC for determining seismic design criteria Tcr Unit I.
The Livermore earthquake of January,1980 made seismic focussing n issue relevant to San Onofre's earthquake hazards.
Because population grcwth near the San Onofre plant has been nore' rapid and ex-sive than could have been anticipated ddring the licensing of Unit-I, there are no a
dequate evacuation plans for the area's residents in the event of a Icss.of coolant
)ccident.
Approximately nine million pecple live in the area that could be affected by the accidental release of radioactive gases frczn Unit I.
The State and 1ccal govern-
'ents are not prepared to evacuate the pcpulation within the short time betseen the hccidentandthespreadofradioactivegases. The Rogovin report to the NRC on
%ree Mile. Island accident - reccommended that old reactors near major cities Ilike San, Onofre) should be shutdown until Evacuation Plans are realistic.
For the above reasons, and the* associated risks to the health and safety of the I
beople of Southern California, it is inperative that you take action to suspend or fevoke the cperating license for San Onofre Nuclear-Generating Station Unit I. /
' Signed on this date', h7.rm 1980 h.G r. [.
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a EDDTJBT IOR INSTITUTIQ4 OF PRCt2 DINGS TO REVOKE OPERATEG LICENSE,10 CFR 2.206 5
10:
Director,of Nuclear Reactor Regulation United States Nuclear Regulatory Ccanission, As a concerned and interested resident of Southern California, who ray be adversely affected by the unit.'s continued cperating, I hWrev L, 5m I4 W request the Director of Nuclear Reactor Regulation to initiate a proceeding pursuant to 10 CFR 2.202 a.nd 10 CFR 55.40 for the purpose of suspe:xiing or revoking the operating license for the San Oncfra Nuclear Generati:v3 Station Unit One.
New and relevant infomation is nos available on potential ground notions at the site in the event of an earthquake, and this infomation would have warranted the i
Ccmnission to have refused to grant a li nse on the original application. Furtherrore, th' plant is 1ccated midway between Ics Angeles and San Diego, one of the nest densely j
e populated and fastest growing areas in the country.
Unit I is not designed to withstand possible ground notions frcm earthquakes on the Necort-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 meltdcwn of the fuel rcds. The addition of a concrete shell to the reactor derne and other nodifications are inadequate to insure against 7 da: rages frcm possible ground notions during a raximum possible earthquake. The new and-relevant. information regarding ground notion potential was unavailable when the AK approved the design criteria of Unit I or later when the NRC approved structural changes to the unit.
Seismic design crite' ia,for Unit I was based en inadequate data r
on neasurerents of ground notions clcse to the source of the earthquakes.
Recent California earthquakes near Santa Barbara in August,1978, ncar San Jose in August,1979, and in Irperial Valley in October,1979,"have revealed new and relevant info =ation about ground notions that Eas not available to the NK for detam.i.'ing sais-ic design criaria fcr Unit I.
Secause population grcuth near the San Onofre plant has been nere 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 less of coolant accident. A'pproximately nine million people live in the area that could be affected by de accidental release of radioactive gases frcm Unit I.
The Stare and lccal govern-ne:its are not prepared to evacuate the population within the shcrt tine between the accident and the spread of radioactive gases. When the AI issued the constru d en perit in.varch of 1964, it was inpassible to know the population of the regien should increase so rapidly.
Fcr the above reasons, and the associated 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 Staticn Un't I.
.j Signed on this date, H-l4-79
, 1979.
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