ML20119A047
| ML20119A047 | |
| Person / Time | |
|---|---|
| Issue date: | 04/20/2020 |
| From: | Chris Bajwa NRC/NMSS/DFM/CTCFB |
| To: | Langley C Public Watchdogs |
| Bajwa C | |
| References | |
| Download: ML20119A047 (2) | |
Text
From: Bajwa, Chris To: Charles Langley Cc: Buckberg, Perry; Hamdan, Latif; Williams, Kevin; Carpenter, Robert Bcc: Averbach, Andrew; Regan, Christopher; Kock, Andrea; Diaz Sanabria, Yoira
Subject:
Petition Review Board Initial Assessment of Public Watchdogs 2.206 Petition dated 02/05/2020 Date: Monday, April 20, 2020 1:32:00 PM
Dear Mr. Langley,
Good morning.
The Petition Review Board (PRB) has completed its initial assessment of the petition you submitted on behalf of Public Watchdogs on February 5, 2020. The petition requested that the U.S. Nuclear Regulatory Commission (NRC) take action under Title 10 of the Code of Federal Regulations (10 CFR), Section 2.206, and included, among other requests, ordering NRC licensee Southern California Edison (SCE) to immediately suspend decommissioning operations at San Onofre Nuclear Generating Station (SONGS) and take immediate actions to preclude flooding of the Independent Spent Fuel Storage Installation (ISFSI) at the site.
The PRB performed its initial assessment to determine whether the petition meets the applicable acceptance criteria in NRCs Management Directive MD 8.11, Review Process for 10 CFR 2.206 Petitions, and its associated Directive Handbook DH 8.11,Section III.C.1. As you will recall, the portion of the petition requesting that the NRC direct the California Coastal Commission with respect to its approval of the removal of spent fuel pools at SONGS was screened out of the 2.206 petition process consistent with the DH 8.11 Section II.A.2(d)(vi) screening criterion. Based on its initial assessment, the PRB has determined that the issues raised in the petition, that remained after screening, have previously been evaluated/considered in NRC staff licensing reviews and none of the provisions of DH 8.11,Section III.C.1(b)(ii) apply. Accordingly, and as discussed further below, our initial assessment is to not accept the petition for review.
The primary safety concern stated in your petition is the unanalyzed risk and imminent threat of the effects of inundation of the SONGS ISFSI with floodwater or burial by debris that would result in rupture of multiple casks due to thermal shock with the result of leaving the public at large vulnerable to a radioactive release and permanent dislocation from their residences and livelihood. The effects of inundation of the SONGS ISFSI with floodwater or burial by debris and, specifically, the impact of such conditions on the spent fuel canisters, have been evaluated and addressed in the Final Safety Analysis Report (FSAR) for the Holtec HI-STORM UMAX dry cask storage system (ML18192B094). The NRC staff reviewed the FSAR for the UMAX system and found that the system meets all applicable NRC regulations.
In order for a radioactive release that exceeds regulatory safety standards to occur, a breach of a spent fuel canister at the SONGS ISFSI would need to occur. The storage canisters used in the UMAX storage system at the SONGS ISFSI are manufactured from austenitic stainless steels, which are not susceptible to pressurized thermal shock; therefore, the canisters would remain intact for the accident events postulated in the petition. The response of spent fuel canisters to accident conditions has been evaluated and addressed in the FSAR. The NRC staff reviewed the FSAR for the UMAX system and found that the system meets all applicable NRC regulations for both structural and thermal
aspects of the storage system design. In the NRC safety evaluation report (SER) for the UMAX Storage System (Amendment 0, ML15093A510) the staff concluded that:
The applicant has met the requirements of 10 CFR Part 72.236(b). The SSCs ITS*
are designed to accommodate the combined loads of normal or off-normal operating conditions and accidents or natural phenomena events with an adequate margin of safety. Stresses at various locations of the cask for various design loads are determined by analysis. Total stresses for the combined loads of normal, off-normal, accident, and natural phenomena events are acceptable and are found to be within limits of applicable codes, standards, and specifications.
- SSCs ITS = structures, systems, and components important to safety In addition, NRC inspectors reviewed the SCE 72.212 report evaluating the UMAX storage system design and approved the UMAX design for use at the SONGS ISFSI, as documented in NRC inspection report 07200041/2017-001 (ML18200A400). The NRC staff remains confident that there is reasonable assurance that the public health and safety is protected and that measures have been established to ensure that fuel is stored in accordance with the requirements of the SONGS license and with the certificate of compliance for the Holtec UMAX system and that other licensing requirements are maintained.
In accordance with MD 8.11, we offer you the opportunity to clarify or supplement the petition in a public meeting with the PRB. If you decide to take advantage of this opportunity, the meeting with the PRB would be conducted consistent with the format described in MD 8.11 Section III.F (in part - you may provide any relevant additional explanation and support for your request either in person or via another agreed-upon arrangement). Please note, however, that an in-person meeting may not be possible in the next few weeks. The PRB will consider your statements and information presented at the meeting, along with the original petition, in making its final determination on whether to accept the petition for review according to the criteria in MD 8.11,Section III.C.1. Please indicate by April 30, 2020, whether you wish to have this public meeting before we close the petition.
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