ML20134H455

Ack Receipt of Requesting That NRC Shutdown SONGS as Soon as Possible Pending Complete Review of New Seismic Risk

ML20134H455
Person / Time
Site:	San Onofre
Issue date:	02/06/1997
From:	Miraglia F NRC (Affiliation Not Assigned)
To:	Dwyer S, Sanregret R AFFILIATION NOT ASSIGNED
References
NUDOCS 9702110308
Download: ML20134H455 (3)

Text

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k UNITED STATES p

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NUCLEAR REGULATORY COMMISSION I

WASHINGTON, D.C. 3000H001 k..... f 8

I February 6, 1997 l

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Mr. Stephen Dwyer c/o Robert Sanregret, Esq.

17621 Irvine Blvd. #100 Tustin, CA 92780 1

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Dear Mr. Dwyer:

i This letter acknowledges receipt of your December 10, 1996, letter, in which j

you supplement your September 22, 1996, request that the Nuclear Regulatory l

Cosunission (NRC) shut down the San Onofre Nuclear Generating Station (SONGS)

"as soon as possible" pending a complete review of the "new seismic risk." On November 22, 1996, the Acting Director of the Office of Nuclear Reactor i

Regulation issued a letter denying your request for inrsediate action, but i

indicated that the staff will evaluate the matters raised in the petition j

within a reasonable time pursuant to 10 CFR 2.206.

l Your December 10, 1996, letter enclosed a brief paper on the " Uncertainties of Seismic Risk Modeling," and you indicate that additional information 4

supporting your assertion that a new seismic risk exists at the SONGS site i

will be submitted to the staff in the near future. Since you imply in your

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December 10, 1996, letter that there is significantly more information that i

you plan to present to the staff in support of your petition, we are

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temporarily suspending our review of your petition until such time as you have i

provided all the infomation you wish to be considered in the staff's final i

decision regarding your petition. As a point of information, the 2.206 petition process is not iterative in nature, rather the process is designed so that the appropriate office director issues a decision on your petition and, if warranted, the NRC takes appropriate action after an evaluation of all the supporting information.

In that light, it is incumbent upon you to submit all the information you desire the NRC to evaluate in support of your petition.

You also expressed a concern in your December 10, 1996, letter that the staff's denial of your immediate request to shut down the SONGS units did not afford you an opportunity to provide information supporting your petition.

In order to provide you with a timely response to your request for immediate action, the staff could not delay our response until additional information was provided by you. However, our denial of your request for immediate action does not preclude the possibility of granting such a request based on further evaluation by the staff and/or based on additional infomation provided by you i

j on this issue.

Enclosed for your information is a pamphlet on the 10 CFR

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j 2.206 petition process.

9702110308 970206 PDR ADOCK 05000206 P

PDR lloggg

Mr. Stephen Dwyer February 6, 1997 Please let us know your schedule for submitting all the information you intend to provide to support your petition. This will allow the staff to schedule the necessary staff resources to promptly evaluate this information.

i Sincerely, Original Signed h Frank J. Miraglia 3

Frank J. Miraglia, Acting Director

~0ffice of Nuclear Reactor Regulation

Enclosure:

Public Petition Process (NUREG/BR-0200) cc w/o enc 1:

See next page

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DISTRIBUTION:

sDocket File;(w/ incoming);~

i PUBLIC (w/ incoming)' ~

PDIV-2 Reading

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EDO Reading ED0-96778 HThompson JBlaha JDyer, Region IV JLieberman, OE FMiraglia/AThadani RZimmerman BSheron TTMartin JRoe EGAI WBateman MFields EPeyton OPA OCA JGoldberg, OGC j

KPerkins, Region IV/WCF0 THarris NRR Mail Room (ED0-96778)

DOCUMENT NAME: DWYER.2ND jf 0FC PDIV-2]PM PDIV-2/LA OGC

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NAME MFhs:ye EfeN

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DATE 2/ k' /97 2/\\ /97 2/ 4 /97 2/5I/97 2/ /97 3

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MSklA)D NAME RZimr[ma'n hkaglia DATE 2/d/97 L h/(n/97 0FFICIAL RECORD COPY

Mr. Stephen Dwyer February 6, 1997 cc w/o enc 1:

Mr. R. W. Krieger, Vice President Resident Inspector / San Onofre NPS Southern California Edison Company c/o U.S. Nuclear Regulatory Commission San Onofre Nuclear Generating Station Post Office Box 4329 P. O. Box 128 San Clemente, California 92674 San Clemente, California 92674-0128 Mayor Chairman, Board of Supervisors City of San Clemente County of San Diego 100 Avenida Presidio 1600 Pacific Highway, Room 335 San Clemente, California 9267P.

San Diego, California 92101 Mr. Harold B. Ray Alan R. Watts, Esq.

Executive Vice President Woodruff, Spradlin & Smart Southern California Edison Company 701 S. Parker St. No. 7000 P.O. Box 128 Orange, California 92668-4702 San Clemente, California 92674-0128 Mr. Sherwin Harris Resource Project Manager Public Utilities Department City of Riverside 3900 Main Street Riverside, California 92522 Dr. Harvey Collins, Chief Division of Drinking Water and Environmental Management California Department of Health Services P. O. Box 942732 Sacramento, California 94234-7320 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mr. Terry Winter Manager, Power Operations San Diego Gas & Electric Company P.O. Box 1831 San Diego, California 92112-4150 Mr. Steve Hsu Radiologic Health Branch State Department of Health Services 1

Post Office Box 942732 Sacramento, California 94234 l

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12/11/96 13:02 O

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8 Dec.10,1996 Dr. Shisiey Jackson and Frank J. Miraglia, Jr., Ading Director OfRce Of Nuclear Reactor Regulation U. S. Nuclear ReQulatory Commission Washington D. C. 20555-0001

Dear Dr. Jackson and Mr. Miraglia,

i:

I have finally recieved your letter of Nov. 22,1996 in which Mr. Miraglia denied my request that the SONGS be immediately shut down pendin0 a more thorough review of the seismic risks.

i i was told that there would be a pettion process during which I assumed that I would be able to present information and data. I now assume that the request for a shutdown is separate from the pattion process and that is why your dental was issued first. I think that you should have at least let me submit something before this decision was made.

Mr. Miraglia then used some other SCE data to substantiate his denial and hasty conclusions.

He stated that there is insufficient evidence to warrant immediate action, but I have not had the chance to submit any evidence yet! He also stated that he will evaluate my allegations, but I have not even had the chance to submit any yet! Even if my request is to separated into two parts, an emergency part and a lengthier petMion process, it should be made clearer to whom and when information is to be submitted.

I have endosed a brief paper on the* Uncertainties of Seismic Risk Modellin0". This is only the beginning of what will be presented. I will also submit an outline of the material to be presented soon.

May I make corrections or additions to the Notice that is being pubkshed in the Federal ReOlster?

1 No information was included about this part of the process either.

If these procedural misunderstandings and tactics are typical of your handling of emergency and other requests, I pray they improve before we procede, if they are indicative of a systematic administrative problem, then not only is S. Califomia in danger, but the rest of the country.

Since this is an emergency sMuation, pisase call or e-malf to facilitate with these procedural matters. Lots use regular mail for documents.

Sinceroty, Yh Stephen Dwyer, Geo ogist clo Robert A. Sanregret Esq.

i 17621 frvine Blvd. #100 Tustin, CA 92780 0 14) 731-1335 914) 7313745 Fx smdewdc. net e4c.. b e4r4.m4y N kers

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12 11/96 15:es O

P.02 Uncertainty Factors Affecting Setemic Risk Modelling in 80. California The followin0 list is an outline of the.10 major uncertatinties in current seismic risk analysis TNs list was taken from a recent paper by M.D. Petersen, et al, (Seismic Hazard Analysis, AEG,1-2096). Their conclusion that the entire Los Angeles, Ventura and Oran0e Counties are high hazard areas. Acceleradons of 0.4g (pga),1.0g (0.3-sec SA), and 0.50(1-sec SA) can occur nearly everywhere. Higher accelerations occur near all of the known fault zones Similar figures

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could be calculated for other areas in 8. Califomia, such as San Die 00, W. Riverside, San l

Bemardino and imperial Co's.

They also condude that even though these calculations are based on a broad consensus of cummt adentific opinion, numerous uncertalnues exist in assumpuons about most of the key parameters. The models are always being updated with each event. TNs is charaderistic of the history of the adence. 40 years ago, we didn't even know that the San Andreas Fault had offsets of over 350 miles! Yes, we have come a long way towards understanding the spectacular geology and tectonics of S. Califomia, but there are still a lot of thin 0s we need to know to make certain critical decisions on ma}or construction projects, past and present. We need to 1

continuality upgrade the calculations because the awareness of the seismic risks is so dramatically increased with ead event.

The several disastrous earthquakes we have had in S. Califomia were full of surprises and we were actually very lucky we didn't have greater loss of life. These events are the womings that 4

we should heed before an even greater catastrophy occurs. We must plan for the miti adon of 0

an evert greater than any recently experienced on our local small faults. We must prepare for a Great event on the Southem San Andreas Fault. This event could easily be M=8, and wl!!

probably be much greater than the San Francisco Quake, M=8+.

There are a lot of thin 0s we should do as soon as possible. Some are discussed below.

Ust Of Seismic Analysis Uncertainties

1. How to quantify slip rates and maximum magnitudes along with their uncertainties for all fault sources.

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2. How to locorporate blind thrusts with appropriate weighting.

3. What seismogenlc zone widths to use for various fault zones.

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4. Which magnitude distribuuons are most appropriate for various fautts.

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5. How to inrorporate back round seismicity and which "b" value is most appropriate for 0

exponentially distributed earhtquakes.

6. Whether to use source zones or simple point sources in modellin0 bactoround seismicity.

7. Which alternative segmentation models are viable (includin0 attemauve cascades models for "A' zones).

8. How to incorporate geodetic data directly in the model.

9. Which attenuation relauons are most appropriate and how to model ground motion from large (M >8) earthquakes.

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10. How to resolve the ckscrepancy between the rate of earthquakes in this and other seismic hazard models and the historic earthquake record (especially in the Transverse Ranges).

The quantity and nature of these uncertain 6es means that we can continue to exped new surprises with each event. The proliferauon of monitorino stauons and new computerized i

modellin0 has increased the analysis capability and precision, but has done little to improve the accuracy of the results and the value of the " Prod 6dions". In fed, various other non mathematical models for prediction and mitigadon have a better trad record. The "modet" that I would recommend is one that acknowledges how humble and firnited our sciences are compared to the vast complexities of the mechanisms of Geology. This means that we should not take risks when we know that we roan don't have the knowledge to evaluate them. This "model" has an inherent resped for the tremendous power of earthquakes, and perhaps an inherent wisdom Although the calculations for San Onofre Nudear Generating Stauon were updated in 1995,

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it is my understanding only a "Probetsstic" colouletion was done, beoed on some simple assumed parameters it appraently concludes that the cid calculations made in an earlier solemology era are still relatively valid. Addibonel coloulations of the true maximum event or a ' Deterministic" omiculadon were not done. Additional parameters, assumptione and verlous combinations of these were not modeled and run in a Dynamic, Sequential way. New tecniques could show better what actually could take pleos as the quake event unfolds Not only the structural features, but also the sou, rock, dvil engineering, hardware, plumbin0, electrical and especially human situations need to be evaluated in a Realetic Scenerlo Analysis. I dont believe i

j that anything Ilke this has been done. It should be if we are to approach resNty and get beyond simpustic mathematical calculations Also, the risks should not be taken untM these more sophisticated dynamic scenarios are evaluated Therfore, the plant shouki be temportly shut down pending the results, and not continue " Status Quo" while we debate the need for further 1

studies. This cunent snusuon is nenher scienunc nor aste. The seismic risks to this plant are l

the crosseet of any cumeny operoung pient in the wortd.

l Not only should the plant be temposity shut down, but also the weste storage situation should be dealt with as an *lmmediate Emergency Hazard". The weste should be propered for transport out of the S. Califomia Seismic Zone. I believe that several temporary sites are svellable, j

Almost anypleos is safer then in a pool at the beach! This facility for storing weste was never i

dusigned for the cunent usages and this is totally unacceptable and a vloistion of numerous rules, re0uistions, laws, human ri0 hts and basic common sense. The weste should be shipped as soon as poselbie, to the Nevada Test Site, Palo Verde Plant, or some other site away fmm l

dense population centers, wolor sources and the San Andreas Fault! We need to set the example for other facilities. This operation should be state of the art. If this isnt poselble, then it 3

should be shut down permanently.

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Millions of people are at risk, the Pacific Ocean is at risk and the future of America is at risk.

i This is a crime aGainst Humanity and the Pienet!

I sincerely, st >.

l StephkDwyer smdgwdc. net i

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