ML20036E999
| ML20036E999 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/05/2020 |
| From: | Public Watchdogs |
| To: | NRC/EDO |
| Bajwa C | |
| Shared Package | |
| ML20036E926 | List: |
| References | |
| 2.206, OEDO-20-00053 | |
| Download: ML20036E999 (14) | |
Text
FOR IMMEDIATE RELEASE: For background, or interviews with subject matter experts,
Contact:
Charles Langley (858) 752-4600 or langley@publicwatchdogs.org NEW: Flooding likely to create radioactive geysers at SONGS Legal filing to NRC warns of deadly radioactive geysers at failed San Onofre Nuclear Generating Station (SONGS)
Dateline, February 5, 2020, San Diego --Today, Public Watchdogs announced that it filed a 2.206 Petition with the Nuclear Regulatory Commission (NRC) to revoke Southern California Edisons ability to bury deadly nuclear waste at the site of the failed nuclear power plant. The hot, radioactive spent nuclear fuel, which can reach temperatures as high as 750°F, is deadly for at least 250,000 years.
The hot nuclear waste is being stored by Edison in thin-walled (5/8 thick) stainless steel canisters.
Once the waste is canned, it is lowered into a concrete reinforced carbon steel silo located in an earthen berm, 108 feet from the beach at San Onofre State Beach Park.
According to the report, if the superheated silos are flooded, they will erupt with deadly radio-active steam geysers. The phenomena has been dubbed The Yellowstone Effect, because the geysers are likely to mimic the action of the famous Old Faithful geyser at Yellowstone National Park. According to Edisons own documents, the beachfront nuclear waste storage facility is subject to flooding and bluff collapse.
The exterior temperature of the thin-walled canisters average 452°F, while the surface of the silos that hold them are at least 350°F, well above the boiling point of water (212°F).
In the event of flooding, cold ocean water will flash to steam once it enters the superheated silos, ejecting a deadly blast of radioactive steam from the outlet vents at the top of the below-ground silos.
According to Paul Blanch, a Public Watchdogs subject matter expert, If the site is flooded, the integrity of the 5/8 thick canisters may be compromised by pressure and thermal shock. We expect the phenomenon to occur whenever water floods the silos.
The Yellowstone Effect is an unanalyzed condition which requires the NRC to halt all movement of deadly spent nuclear fuel at the failed SONGS facility until the threat has been properly assessed says Charles Langley, Public Watchdogs Executive Director.
Click here for a copy of the petition.
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7867Convoy Court, Suite 302, San Diego, CA 92111 (858) 384-2139 The Yellowstone Effect could cause massive radioactive steam geysers similar to the Old Faithful geyser on the beach at San Onofre.
1 February 4, 2020 Ms. Margaret Doane Executive Director for Operations U.S. Nuclear Regulatory Commission (NRC)
Washington, DC 20555-0001 margaret.doane@nrc.gov Re: San Onofre Units #2 and #3 are operating in an unanalyzed condition 10 CFR 2.206 Petition Regarding Potential Violations of Regulations Docket Nos. 50-361 and 50-362 License Nos. NPF-10 and NPF-15
Dear Ms. Doane:
Pursuant to 10 CFR 2.2061, Petitioner hereby submits this Petition to immediately suspend decommissioning operations at San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 on the grounds that the present ISFSI is operating in an unanalyzed condition2 and will continue to operate in this condition3 until immediate actions are imposed to resolve this condition. Additional requests for immediate actions are also included under Requested Actions.
This petition identifies possibly the most significant man made engineering disaster of the century, exceeding such disasters as Chernobyl, Fukushima, Bhopal, Exxon Valdez, and the Deepwater Horizon oil expulsion.
Public Watchdogs submits this 2.206 Petition generated in conjunction with Paul Blanch PE, Energy Consultant, a Public Watchdogs Subject Matter Expert. This petition is filed on the grounds that the Independent Spent Fuel Storage Installation (ISFSI) presents an unanalyzed risk and imminent threat leaving the public at large vulnerable to a radioactive release and permanent dislocation from their residences and livelihood.
Public Watchdogs filed Freedom Of Information Act (FOIA) request no. 2020 -
0000134 for the identification of the Current Licensing Basis. The FOIA was submitted to NRC on January 27, 2020. At this time, it is not clear to the Petitioner as to what comprises the Current Licensing Basis defined in 10 CFR 54.3.
7867 Convoy Court, San Diego, CA 92111 www.publicwatchdogs.org (858) 384-2139
2 10 CFR § 72.92 Design basis external natural events4 clearly requires the licensee to identify and assess the impact of natural phenomena that may exist or that can occur in the region of a proposed site. Such factors must be identified and assessed according to their potential effects on the safe operation of the ISFSI or Monitored Retrievable Storage.
While the Petitioners were able to access ML13240A130, dated August 26, 2013, we were unable to locate any analysis within the Current Licensing Basis. If there was such an analysis, it appears that it is nonpublic.
Further, Public Watchdogs asserts that the provisions of 10 CFR 1005 remain applicable. However, this cannot be known until a final response to FOIA 2020-0000134 is received.
The Holtec Final Safety Analysis Report (FSAR) and Holtecs Certifications of Compliance dated May, 2019, clearly discusses a flooding event and states that a site-specific analysis will be submitted by the Licensee. In response to our request to the NRCs Public Document Room, the NRC staff responded to an email on December 9, 2019, stating they could not locate an analysis from Edison.
After an extensive search of NRC records, an Edison document dated August 26, 2013, was located and reviewed. The document was (ML13240A130) and included a Request for Relaxation of Commission Order Number(s)6 This document was provided to the NRC by Southern California Edison in response to NRC Order EA-12-049 and EA-12-051. It clearly illustrates that the top of the Independent Spent Fuel Storage Installation (ISFSI) will be submerged and possibly covered by collapsed bluffs and debris. This condition has never been analyzed by Edison for the Dry Cask Storage System (DCSS). Therefore, it may result in the 72 canisters in the DCSS expelling water and radiation as long as water is present. The corrosive effect of salt water from the Pacific Ocean will need to be evaluated7.
10 CFR 50.72(a)(3)(ii)(B) (if applicable) requires a four or eight-hour report to the NRC if The nuclear power plant being in an unanalyzed condition that significantly degrades plant safety. One would logically conclude that the ISFSI is part of the nuclear power plant and that the requirements of 10 CFR 50.72 are applicable. However, without a clearly defined Current Licensing Basis, this safety issue remains in question.
Further 10 CFR § 72.75 - Reporting requirements for specific events and conditions clearly requires:
(b) Non-emergency notifications: Four-hour reports. Each licensee shall notify the NRC as soon as possible but not later than four hours after the discovery of any of the following events or conditions involving spent fuel, HLW, or reactor-related GTCC waste:
3 (1) An action taken in an emergency that departs from a condition or a technical specification contained in a license or certificate of compliance issued under this part when the action is immediately needed to protect the public health and safety, and no action consistent with license or certificate of compliance conditions or technical specifications that can provide adequate or equivalent protection is immediately apparent.
(2) Any event or situation related to the health and safety of the public or onsite personnel, or protection of the environment, for which a news release is planned or notification to other Government agencies has been or will be made. Such an event may include an onsite fatality or inadvertent release of radioactively contaminated materials.
The licensee has failed to report these unanalyzed conditions to the NRC, the State of California and the general public.
Description of unanalyzed condition:
The HI-STORM 100 FSAR, NONPROPRIETARY Revision 18 May 16, 2019 clearly states on page 50/2088:
2.V.2.(b)(3)(f) "10CFR Part 72 identifies several other natural phenomena events (including seiche, tsunami, and hurricane) that should be addressed for spent fuel storage."
And In accordance with NUREG-1536, 2.V.(b)(3)(f), if seiche, tsunami, and hurricane are not addressed in the SAR and they prove to be applicable to the site, a safety analysis is required prior to approval for use of the DCSS under either a site specific, or general license.
The intent of these words is crystal clear: a safety analysis is required prior to approval for use of the Dry Cask Storage System (DCSS) under either a site specific, or general license.
Further, NUREG 2214 clearly states that in order to maintain compliance with NRC safety rules, the Licensee must have a Corrective Action Program, or CAP to handle extreme natural phenomena such as flooding:
8The approved design bases9 have adequately addressed the occurrence of extreme natural phenomena, such as heavy snowstorm or flooding. The QA program ensures that corrective actions are completed within the specific-or general-licensees CAP in the event of extreme natural phenomena.
We have filed FOIA 2020-000098 for this flooding analysis however the FOIA Office responded to our subject matter expert, Mr. Blanch, by stating it would cost about $1000 to see an analysis that should be readily available as part of the NRCs Current Licensing Basis database.
4 On August 26, 2013, San Onofre submitted its flood analysis to the NRC in response to NRC Order Number EA-12-049.10 Page 32 of 53 of this response (ML13240A130) clearly shows the ISFSI area may be FLOODED BY TSUNAMI AND TROPICAL STORM as shown below. This appears to be an unaddressed Design Basis Event (DBE).
Edisons response to NRC Order EA-12-049 and EA-12-051 is a part of the Current Licensing Basis.
From Edisons own submittal under oath, executed on August 26, 2013 under penalty of perjury, the area of the ISFSI may be submerged by an unspecified level of seawater during a tropical storm or tsunami resulting in potential rupture of all 72 spent fuel storage casks. This event is likely to result in rupture of multiple casks and the release of millions of curies of long-lived radioactive isotopes.
The impact of the thermal shock of cold water from the Pacific Ocean immersing the 452-degree Fahrenheit multipurpose canister (MPC) is unanalyzed and void of regulatory scrutiny. It is possible that this thermal shock could challenge the only boundary between millions of curies, the environment, and millions of people. In addition, potential criticality as discussed in 10 CFR 72.124 has not been addressed.
5 This event would likely result in an Old Faithful geyser type event continuing as long as water and debris remains above the inlet vents.
Old Faithful, Yellowstone National Park The latest Google Earth Satellite image (below) clearly shows the ISFSI in an area vulnerable to floods, tsunamis and tropical storms.
The Petioner would like to assume that Edisons analysis was conducted by qualified personnel under Edisons Quality Assurance program as specified in 10 CFR 50 Appendix B, but the fact remains that there is a high probability that the ISFSI will be inundated by seawater, sand, rubble, or other debris at any time.
6 Potential Consequences of ISFSI flooding A thorough analysis of the risks, probability, and consequences of this event is beyond the scope of this document. However, because the ISFSI is operating in an unanalyzed condition, it is imperative that the NRC order the Licensee to investigate and provide the site-specific analysis required of Holtecs Certificate of Compliance.
The possible consequences of flooding above and inside the ISFSI canisters are highly predictable. Such flooding could precipitate the total rupture of the canisters, the release of millions of curies of long-lived radioactive isotopes, and potential criticality.
Below is a depiction of one of the 70 plus HI-STORM MPC-37 (DSCC) casks that are being interred inside the below-ground canister enclosure cavity at the SONGS ISFSI.
The canisters are almost totally below grade and designed to allow ambient air to enter the silo through convection cooling. An estimated 125,000 BTUs per hour is conducted upward and re-discharged (unmonitored for radiation) to the environment through the outlet vents. The amount of residual heat contained in
7 each of the canister enclosure cavities, or below-ground silos, is estimated to be in excess of 10 Million BTUs, or the equivalent of about 4,000 pounds of TNT.
The radiation levels outside the multipurpose canister (MPC) are in excess of one million RADs per hour (1,000 RADs is a fatal dose for most humans). The radiant heat from the surface is sufficient to burn paper and hair, melt lead, or deep fry a Thanksgiving turkey.
As shown in the illustration below, and on the previous page, the gap between the carbon steel enclosure cavity and the hot, radioactive canister is narrow, precluding easy repair or inspection.
When the storm surge predicted by Edisons analysis occurs, seawater and debris will come in contact with the inlet and outlet vents and immerse the fuel canisters in saltwater. The cold seawater will immediately come in contact with the sizzling hot wall of the canister and flash to steam.11 It is possible that the vents may also clog with sand, mud, or other debris, completely preventing the convection cooling function of the canister enclosure cavity.
8 Areas of concern and the consequences:
Canister integrity and possible rupture due to thermal shock. 12 Criticality 13 14 due to the introduction of sea water into the fuel. According to the Holtec Final Safety Analysis Report of May 2019, criticality may occur with the introduction of non-neutron absorbing water (water without boron).
Salt water inundation. Sea water, with its unknown composition, may introduce additional unanalyzed nuclear interactions due to neutron and gamma flux and possible criticality.
Potential overpressure due to steam formation has not been considered.
No means to detect water level that may accumulate due to condensation or external flooding events.
Inability to retrieve damaged canisters: Canister deformation15 and radiation levels may prevent removal of the MPC-37s. Each canister contains about the same amount of long-lived radiation isotopes that were released from Chernobyl in 1986.16 Potential landslides: The location of ISFSI below the bluffs and the possibility of multiple Bluff Collapses17 from the cliffs near the ISFSI may result in the incapability of the system to remove heat generated from the spent fuel. Landslides could result in overpressure and expulsion of the systems capability to remove heat generated from the spent fuel resulting in overpressure and expulsion of millions of curies of radioactive isotopes.18 Lack of Emergency Planning: Should this event occur with significant releases from one or more casks, there are no procedures in place to ever reduce the expulsion of millions of curies of deadly radiation.19 Long term and irreversible corrosion of the entire system due to saltwater exposure creating a fertile ground for chloride-induced stress corrosion cracking.
Major radiation releases to the environment. Interpolation is based on NRC studies of the exclusion area (unhabitable) from the event could range from all radiation remaining on site or extending out beyond 50 miles.
No procedures are available to ever recover from this likely event.
9 NRC regulations require that a 2.206 Petition request specify the action requested and set forth the facts that constitute the basis for the request.
Requested Actions:
Institute a proceeding pursuant to 10 CFR 2.202 to modify, suspend, or revoke a license, or for any other action as may be proper, and An immediate halt to decommissioning: The NRC must order SCE to halt all decommissioning activities until the ISFSI is no longer in an unanalyzed condition.
Prompt reporting by Licensee: The NRC must require the Licensee to report SONGS as operating in an unanalyzed condition and to report the unanalyzed condition as required by 10 CFR 50.72, 50.73 and 10 CFR 72.75.
Development of flood and landslide countermeasures: The NRC must order Edison to take immediate actions to preclude flooding of the ISFSI.
Cessation of all fuel transfer activities. Until a viable solution is approved, NRC must suspend all fuel transfer actions from the spent fuel pools to the ISFSI at San Onofre.
Contact California authorities: Inform the California Coastal Commission that it is unacceptable to approve the removal of the Spent Fuel Pools until the NRC approves this removal with a methodology demonstrating the feasibility of safely protecting the public and the environment. Maintaining the two existing spent fuel pools may be the only viable means of recovery from this unanalyzed disaster.
Redefine the Current Licensing Basis. The NRC must clearly identify its Current Licensing Basis per the requirements of 10 CFR 54.3 as requested in NRC FOIA 2020- 0000134.
Reinstate appropriate levels of emergency response capability By rescinding the NRC emergency planning exemptions granted to Edison in 2015. These requirements must be reinstated to protect the public from this high probability event.
Inability to retrieve damaged canisters: Canister deformation20 and radiation levels may prevent removal of the MPC-37s. Each canister
10 contains about the same amount of long-lived radiation isotopes that were released from Chernobyl in 1986.21 We request that this petition be evaluated on a stand-alone basis and not be consolidated with any other petitions that may result in the dilution of the vital nature of this petition.
Based on the NRCs history, more than four hundred eighty 2.206 petitions have been submitted to NRC in the last 25 years, yet fewer than five have been granted.
Over this same period the NRC has received thousands of requests from licensees for changes and exemption. We are not aware of any of these requested changes being denied.
Given the significance of the allegations in this Petition, we are hopeful that the Commission will take the responsible course of action and move quickly to resolve the issues identified in this report.
Once again, we appreciate the NRCs efforts to protect the Public and the Environment however the public urgently needs a copy of the NRCs applicable regulations defined in 10 CFR 54.3, and assurance the NRC will succeed in its stated mission.
Please feel free to contact Public Watchdogs directly should you have any questions.
Sincerely, Charles Langley Executive Director Public Watchdogs (858) 384-2139 Endnotes 1 A 10 CFR 2.206 petition is a vehicle whereby any person can request the NRC to modify, suspend, revoke a licensees permit, or for any other action deemed proper. The request must specify the action requested and set forth the facts that constitute the basis for the request.
2 An unanalyzed condition is one where a condition exists that has not been analyzed by the Licensee and the NRC as specified in 10 CFR 72 below.
11
§ 72.122 Overall requires:
(a) Quality Standards. Structures, systems, and components important to safety must be designed, fabricated, erected, and tested to quality standards commensurate with the importance to safety of the function to be performed.
(b) Protection against environmental conditions and natural phenomena.
(1) Structures, systems, and components important to safety must be designed to accommodate the effects of, and to be compatible with, site characteristics and environmental conditions associated with normal operation, maintenance, and testing of the ISFSI or MRS and to withstand postulated accidents.
(2)
(i) Structures, systems, and components important to safety must be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, lightning, hurricanes, floods, tsunami, and seiches, without impairing their capability to perform their intended design functions. The design bases for these structures, systems, and components must reflect:
(A) Appropriate consideration of the most severe of the natural phenomena reported for the site and surrounding area, with appropriate margins to take into account the limitations of the data and the period of time in which the data have accumulated, and (B) Appropriate combinations of the effects of normal and accident conditions and the effects of natural phenomena.
3 Regulations applicable to San Onofre plants are defined in the Code of Federal Regulations (CFR) and the scope of the applicable regulations is defined in 10 CFR 54.3; and includes the Holtec Final Safety Analysis Report (FSAR) and Holtecs Certifications of Compliance.
4 10 CFR § 72.92 Design basis external natural events.
(a) Natural phenomena that may exist or that can occur in the region of a proposed site must be identified and assessed according to their potential effects on the safe operation of the ISFSI or MRS. The important natural phenomena that affect the ISFSI or MRS design must be identified.
(b) Records of the occurrence and severity of those important natural phenomena must be collected for the region and evaluated for reliability, accuracy, and completeness. The applicant shall retain these records until the license is issued.
(c) Appropriate methods must be adopted for evaluating the design basis external natural events based on the characteristics of the region and the current state of knowledge about such events.
5 10 CFR § 100.21 Non-seismic siting criteria.
Applications for site approval for commercial power reactors shall demonstrate that the proposed site meets the following criteria:
(a) Every site must have an exclusion area and a low population zone, as defined in § 100.3; (b) The population center distance, as defined in § 100.3, must be at least one and one-third times the distance from the reactor to the outer boundary of the low population zone. In applying this guide, the boundary of the population center shall be determined upon consideration of population distribution. Political boundaries are not controlling in the application of this guide; (c) Site atmospheric dispersion characteristics must be evaluated, and dispersion parameters established such that:
(1) Radiological effluent release limits associated with normal operation from the type of facility proposed to be located at the site can be met for any individual located offsite; and (2) Radiological dose consequences of postulated accidents shall meet the criteria set forth in § 50.34(a)(1) of this chapter for the type of facility proposed to be located at the site; (d) The physical characteristics of the site, including meteorology, geology, seismology, and hydrology must be evaluated and site characteristics established such that potential threats from such physical characteristics will pose no undue risk to the type of facility proposed to be located at the site; 6 Southern California Edison letter dated August 26, 2013, requesting relaxation of safety rules governing nuclear power plants, re: Docket Nos. 50-361 and 50-362, License Nos. NPF-10 and NPF-15, Request for Relaxation of Commission Order Number EA-12-049, Request for Relaxation of Commission Order Number EA-12-051, And First 6 Month Status Report on Implementation of EA-12-049 and EA-12-051, San Onofre Nuclear Generating Station, Units 2 and 3 at https://www.nrc.gov/docs/ML1324/ML13240A130.pdf 7 It will be impossible to evaluate the integrity of the spent fuel casks without a Spent Fuel Pool
12 8 FOIA 2020-000096 has been requested for the specific analysis 9 Part of the San Onofre CLB 10 This is part of the CLB as defined in 10 CFR 54.3, see NRC letter dated March 12, 2012 Issuance of order to modify licenses with regard to requirements for mitigation strategies for beyond-design-basis external events, NRC Order Number EA-12-049.
Page 32 of 53 https://www.nrc.gov/docs/ML1205/ML12054A735.pdf 11 The outside wall of the Holtec MPC-37 canister is calculated by Holtec to be 4520F, and the carbon steel wall of the silo in excess of 3500F 12 Rapid Cooldown: Most reactor vessels are greater than 6 thick and are limited to a cooldown rate of less than 100 0F per hour. This postulated event would result in a cooldown rate of 1000s of degrees per hour possibly shattering the fuel canister.
13 See A Review of Criticality Accidents, Los Alamos National Laboratory, University of California, Year 2000 Revision at https://www.orau.org/ptp/Library/accidents/la-13638.pdf.
14 Criticality is when the fuel in the casks commences an uncontrolled nuclear reaction producing millions of additional BTUs and short-lived fission products including Iodine 131. This self-sustaining nuclear fission would also provide a motive force expelling short lived and long lived fission products, violating the requirements of 10 CFR 72.124 15 ASME CRTG-Vol.77 16 See Fallout From Chernobyl, Los Angeles Times, September 24, 1986, Thomas Maugh https://www.latimes.com/archives/la-xpm-1986-09-24-mn-8963-story.html.
17 See Bluff collapse as depicted by Edisons own analysis on page 32 of 53 of ML13240A130 at https://www.nrc.gov/docs/ML1324/ML13240A130.pdf 18 NUREG 1864
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13 19 10 CFR 50 Appendix A at https://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-appa.html Criterion 63Monitoring fuel and waste storage. Appropriate systems shall be provided in fuel storage and radioactive waste systems and associated handling areas (1) to detect conditions that may result in loss of residual heat removal capability and excessive radiation levels and (2) to initiate appropriate safety actions.
20 ASME CRTG-Vol.77 21 See Fallout From Chernobyl, Los Angeles Times, September 24, 1986, Thomas Maugh https://www.latimes.com/archives/la-xpm-1986-09-24-mn-8963-story.html.