ML20059M229

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OEDO-20-00053 2.206 Petition - Flooding Likely to Create Radioactive Geysers at SONGS
ML20059M229
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 02/25/2020
From: Chris Bajwa
NRC/NMSS/DFM/CTCFB
To: Langley C
Public Watchdogs
Bajwa C
Shared Package
ML20036E926 List:
References
2.206, OEDO-20-00053
Download: ML20059M229 (3)


Text

From: Bajwa, Chris To: Charles Langley Cc: Buckberg, Perry; Hamdan, Latif; Williams, Kevin; Carpenter, Robert

Subject:

RE: Re: Response to Immediate Action Requests in Public Watchdogs 2.206 Petition Date: Tuesday, February 25, 2020 12:45:00 PM Mr. Langley, Good morning. This e-mail acknowledges the receipt of your e-mail, below, dated February 16, 2020, and to inform you that the staff will consider your e-mail in the evaluation of the requests in your petition.

Best Regards, Chris Bajwa Division of Fuel Management (DFM)

Containment, Thermal, Chemical and Fire Protection Branch (CTCFPB)

Office of Nuclear Material Safety and Safeguards (NMSS)

  • T4-A60 l ( 301-415-5341 lFAX 301-415-0020 Chris.Bajwa@nrc.gov From: Charles Langley <langley@publicwatchdogs.org>

Sent: Sunday, February 16, 2020 6:14 PM To: Bajwa, Chris <Chris.Bajwa@nrc.gov>

Cc: Buckberg, Perry <Perry.Buckberg@nrc.gov>; Hamdan, Latif <Latif.Hamdan@nrc.gov>; Williams, Kevin <Kevin.Williams@nrc.gov>; Carpenter, Robert <Robert.Carpenter@nrc.gov>

Subject:

[External_Sender] Re: Response to Immediate Action Requests in Public Watchdogs 2.206 Petition

Dear Chris Bajwa:

I am responding to your email to me dated Feb 14, 2020 copied below.

We respectfully disagree with your decision as we are unable to verify the accuracy of your statements. We have reviewed (ML18192B094) and copied herein sections "4.6.2.4 Burial Under Debris" and "4.6.2.5 Flood -------PROPRIETARY INFORMATION WITHHELD IN ACCORDANCE WITH 10 CFR 2.390 Section 4.6.2.4 does not consider any debris generated by flooding as postulated in our petition and Section 4.6.2.5 Flood has been withheld "WITHHELD IN ACCORDANCE WITH 10 CFR 2.390 It is difficult to envision how the withholding this flood information could meet the criteria of 10 CFR 2.390 that states a document may not be withheld:

"in the absence of an NRC determination of a compelling reason for nondisclosure after a balancing of the interests of the person or agency urging nondisclosure and the public interest in disclosure

We believe the public interest is best served by the release of the ISFSI flood information and can not envision any "compelling reason for nondisclosure after a balancing of the interests of the person or agency urging nondisclosure and the public interest in disclosure Please provide as basis (compelling reason) for withholding this vital information.

We also believe that Edison's flood analysis referenced in our 2.206 petition, dated August 26, 2013, (ML13240A130), justifies immediate actions dictated by MD 8.11 Sections II.B.1 and III.B.1.

To further reinforce the immediate need for this information we have filed a FOIA request (FOIA-2020-000098) for the flood analysis.

Sincerely, Charles Langley, Executive Director Public Watchdogs (858) 384-2139 www.publicwatchdogs.org 7867 Convoy Court, Suite 302, San Diego CA 92111 On Fri, Feb 14, 2020 at 11:40 AM Bajwa, Chris <Chris.Bajwa@nrc.gov> wrote:

Mr. Langley, Good afternoon. You submitted a petition, on behalf of Public Watchdogs, requesting action under 10 C.F.R. 2.206 that included, among other requests, that the NRC order the San Onofre Nuclear Generating Station (SONGS) licensee, Southern California Edison (SCE) to immediately suspend decommissioning operations at SONGS and that the NRC order the SCE to take immediate actions to preclude flooding of the Independent Spent Fuel Installation (ISFSI) at the site. The justification provided in your petition for these immediate action requests was an assertion that the SONGS ISFSI is operating in an unanalyzed condition, because some of the potential consequences of flooding of the ISFSI have not been considered.

The NRC staff reviewed these immediate action requests and has concluded, in accordance with Sections II.B.1 and III.B.1 of Management Directive (MD) 8.11, that the requests do not warrant immediate action. The NRC staff has determined that the scenario, described in the petition, of an earthquake and tsunami leading to the submersion under water or covering by debris of the ISFSI at SONGS, while possible, would not lead to the specific consequences presented in the petition.

The effects of inundation of the SONGS ISFSI with floodwater or burial by debris and,

specifically, the reactions of the spent fuel canisters to such conditions, are evaluated in the Final Safety Analysis Report (FSAR) for the Holtec HI-STORM UMAX dry cask storage system (ML18192B094). The NRC staff has reviewed the FSAR for the UMAX system and found that the system meets all applicable NRC regulations.

As such, the NRC staff has determined that the decommissioning activities at SONGS do not constitute an immediate threat to public health and safety.

Consistent with the 2.206 process, the Staff is proceeding with its evaluation of whether the petition you submitted meets the MD 8.11 acceptance criteria for review. We will contact you once the Staff has made that initial determination.

If you have any questions regarding this e-mail, please feel free to contact me at Chris.Bajwa@nrc.gov.

Best regards, Chris Bajwa Division of Fuel Management (DFM)

Containment, Thermal, Chemical and Fire Protection Branch (CTCFPB)

Office of Nuclear Material Safety and Safeguards (NMSS)

  • T4-A60 l ( 301-415-5341 lFAX 301-415-0020 Chris.Bajwa@nrc.gov