ML20039B049
| ML20039B049 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/11/1981 |
| From: | Mcclung C FLEMMING, ANDERSON, MCCLUNG & FINCH |
| To: | Bradford P, Gilinsky V, Palladino N NRC COMMISSION (OCM) |
| References | |
| DD-81-19, ISSUANCES-OL, NUDOCS 8112220227 | |
| Download: ML20039B049 (3) | |
Text
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s To: United States of America a
DEe o-Nuclear Regulatory Commissioh
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Nunzio.J. Palladino, Chairman
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Victor.Gilinsky
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Thomas M.
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Re: Director's Decision under 10 CFR 2.206 (DD-81-19) Southern California Edison
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Company (San Onofre Nuclear Ge.nerating Station, Unit 1) dated November 16, 1981 By way of introduction I am one of the attorneys for the emergency planning intervenors in the ongoing licensing proceedings for San Onofre Nuclear Generatinct Stations (SONGS), Units 2 and 3 (docket Nos: 50-3610L and 50-3620L).
The purpose of this letter is to request that the Commission on its own motion institute a review of the director's decision, referenced above, pursuant to 1C CFR 2.206 (c).
The reasons for my request are set forth celow.
The petitioners basically had two grounds for asking the director to review the license and ongoing operation of Unit 1.
The first relates to the fact that Unit I does not meet the seismic safety requirements which are currently in effect (required for the Units 2 and 3 which are being constructed at the site) and secondly that the emergency planning in the area surrounding the plant does not meet current NRC standards.
The Director's decision indicates that the petitioners were correct on their first point.
The systems and components were designed to withstand a 0.5g and the currant shut down standard being used is 0.67g.
The decision states that the p3 licensee has concluded that the containment structure will y
withstand earthquakes up to 0.67g.
This was done according to the Systematic Evaluation Program.
The Director indicates
/g that the Staff has not yet reviewed this re-evaluation but that it has confidence in it because such reviews have been a112220227 PDR ADOCK 0 0
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}4 United States of America Nuclear Regulatory Commission December 11, 1981 Page Two i
borne out at other plants.
I respectfully submit that this confidence may not be justifiable in the light of the new findings in the Diablo Canyon Case.
This.second issue regarding emergency planning is-very important and it overlaps with the seismic safety issue, in light of to the Coimission's recent Memorandum and Order (CLI-18-33) San Onofre Southern California Edison Company (San Onofre Nuclear Generating Station Units 2 and 3.
The Commission declined to allow Atomic Safety and Licensing Board in those hearings to address the question of what i
effect a serious earthquake approaching or beyong a safe shut down earthquake might have on the emergency planning j
of the surrounding jurisdictions.
The Commission indicated-that this type of question was more appropriately addressed in a generic proceeding and that the Federal Emergency k
Management Agency would be consulted on this issue.
The reasons for that order do not apply to the ongang operation j
and retrofitting of Unit 1.
Substantial upgrading of Unit 1 remains to be done to make it seismically safe.
It makes sense that this should be done with an eye on emergency. planning.
The Federal-Emergency Management Agency (FEMA) has no jurisdiction over the site and the seismic upgrading on the site and, therefore, would have nothing to say about the emergency 1
1 planning during an earthquake and how the.sita could be better prepared for such an event.
There are special considerations that exist at SONGS because there are going to be two new reactors operating at the plant and a potentbl accident. at SONGS, with seismic systems which are not qualified, could affect the operation at SONGS 2 and 3 and, therefore, create a serious emergency planning hazard.
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i The Director's decision regarding emergency planning,.
l beginning at page 11, places substantial reliance on the fact
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that plans have been submitted and that FEMA has made a l
review of the plans. -But thcre has been no review of the effect~of an earthquake which may be serious according to the j
NRC's.own standards.
The safe shut down earthquake for SONGS i
2 and 3 cubstantially exceeds the safe shut down design-1 l
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United States of America Nuclear Regulatory Commission December 11, 1981 Page Three earthquake for SONGS 1.
Therefore, the possibility of an earthquake induced radiological emergency at SONGS is much larger than might otherwise be assumed.
What is more the Director indicates that FEMA will soon sign off on the corrective: actions being taken by the applicant and local jurisdictions with respect to the operating plant.
This is not the case FEMA has issued further interim findings, dated December 1, 1981 and it is unable to say that the emergency plan surrounding the offsite jurisdictions are yet adequate.
In conclusion, I would join the numerous California citizens and other concerned individuals in respectfully requesting that the Commission review the Director's decision in tais matt'er and initiate a hearing process into whether or not the SONGS 1 should be allowed to continue to operate.
Specifically the Commission should investigate whether it is seismically qualified ar.d what effect serious earthquakes might have on emergency planning surrounding the plant.
Very truly yours, n
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I Charles E. McClung, Jr.
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