ML20138G609
| ML20138G609 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/26/1997 |
| From: | Dwyer S AFFILIATION NOT ASSIGNED |
| To: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20138G450 | List: |
| References | |
| 2.206, NUDOCS 9705060343 | |
| Download: ML20138G609 (3) | |
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e.
9 From:
stephen dwyer <smd@wdc. net >
To:
WND1.WNP2(Chairman)
Date:
3/26/97 6:36pm
Subject:
Seismic Risks @ SONGS Intro Draft Mar. 2d,1997 Honorable Shirley Jackson, Chairman Nuclear Regulatory Commission Washington, D.C.
Re: Emergency Petition 2.206 for SONGS / Seismic Risks SEISMIC RISKS AT SAN ONOFRE NUCLEAR GENERATING STATION i
INTRODUCTION The Emergency Petition for an emergency shutdown of San Onofre Nuclear Generating Station (SONGS) has been pending for several months. It has now been split into 4
two seperate requests.
One is for the removal of all Spent Fuel out of the Southem Califomia Seismic Zone. The other is for the temporary shutdown of the Unit 2 & 3 i
Reactors till such time that a complete review and reanalysis of the seismic risks of all systems is completed.
The Design Basis Event for Units 2 & 3 is only 0.67g's. At the time of construction this was just sufficiently above the range of g forces of 30 earthquakes prior to 1979. In the years following construction a number of quakes have occured that indicate that this original group of quakes was not statistically relavant. The wide range of quakes accross S. CA, fault types, damage, accelerations and offsets has led to numerous revisions of not only S. CA geology but also the funcamental assumptions of seismology.
The weasing uncertainties of the situation and the science itself have been hotly debated.
The retrofitting of all kinds of structures, many previously thought to be among the most resistant, has been widespread.
Previously known problem structures have been undergoing retrofitting for years. Retrofitting of emergency facilities to withstand over M8.0 quakes has been ongoing. But no retrofitting of i
San Onofrr, the most important structure in S. C/, has been undertaken or even planned.
instead, a ienghty report purporting to be " State of the art" has beers finally relaased. All data and information have been carefully manipulated to
" prove" that SONGS still meets all original design basis event criteria.
Fault by fault is dismissed for one " reason" or another, formulas are defended while the true nature of the uncertainties involved in the parameters are understated, graphs are manipulated to show thet acceleration attenuations are within bounds, g forces are not able to exceed the DBE, vertical g forces are neglected and shown in reduced scale on the last page, the DBE is ommitted entirely from the report making graphical comparissons difficult or impossible, the relationship to anything at SONGS is entirely ommitted, only a simple probablistic calculations are included, no deterministic calculations are discussed, let alone shown, no computer analyses of any structural dynamics or 3-D modellinc is presented, no sequential dynamic analyses are presented, the significant advances in offshore geology are dismissed as nothing to be concemed about even though they show numerous intersecting folds and faults and complex geometric relationships that were not known at the time of construction, but are now 9705060343 970501 PDR ADOCK 05000206 H
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. known to be related to similar geology that has caused major damage, the complete and j
incredible omission of any serious discussion or analyses of the Northridge Quake, a blind thrust previously unknown and unmapped, which caused 20 billion dollars damage and destroyed major structures 20 miles away, especially noticable was any discussion of the fact that the Northridge Quake g forces exceeded 1.8 g's, almost 3 times the DBE of SONGS, the fact that the Northridge Quake was only a M6.6, it had the highest g forces ever recorded, the downplaying of the San Andreas Fault as a significant risk factor was just to incredible to j
believe, the most dangerous section of fault in the world was made to appear to be no more l
risk than any other susidiary fault in S. CA. The true effects of a major quake on the S.
San Andreas are totally unknown, but even with a probabalistic approach, it must be able to generate a quake much bigger than anything ever experienced in CA. 200 or more years of l
energy buildup at a rate of 25 to 35 or more mm per year means several tens of feet offset l
along a great distance and depth of fault. The g ferces, ground waves and especially duration l
of shaking could be enough to destroy anything ever built by man over all of S. CA, The numerous deficiencies in this report are a desperate attempt to cover-up the danger and maintain a status-quo that is long out of touch with reality.
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Their are so many earthquake faults,and probably many more yet to be found, that to say that l
none of them could damage SONGS is simply absurd. There are so many uncertainties l
involved in the analysis that the risks are not possible to calculate by a probabalistic approach.
l A much more sophisticated analysis wil be needed. But in the mean time, there are no logical l
arguments for storing hundreds of thousands of pounds of dangerous Spent Fuel anywhere in S. CA, let alone in an old Spent Fuel Pool at the beach. Millions of people are needlessly put j
at risk from this fuel. Why? There are no good answers, only flimsy excuses from a stonewalling management at SCE trying its best to delay the enevitable just to generate a 3
small rate of retum to stock and bond holders. Why did they have the seismic report done by a j
distant consulting firm? Was it because no local firms would touch this problem because they knew that the numerous faults are too unpredictable and dangerous and the results would not i
be favorable to SCE7 Its clear why the Northridge Quake was ommitted.
Update: Woodward & Clyde have put forth some answers to NRC questions 3-14-97, but it is only more of the same cover up. See following letter of rebuttal.
Three years after the Northridge Quake and still no updated seismic report.
This is a violation of the requirement to keep all reports affecting safety analysis completely up to date. SCE has been hoping that no one would notice this glaring deficiency for as long as possible. SONGS should have been shut down the day of the Northridge Quake pending a complete ana!ysis, and not put online tillit had been finally re-approved. Ope ating SONGS without this information is operating completely blind.
If the Spent Fuel Pools are so well designed, then why can' t they build some in Nevada in or near the Test Site, and remove them asap. If the design isn't relly that perfect, then all the more reason to move the Spent Fuel to an udated version or new technique. Because this is an emergency situation, the luxury of endess debate about nuclear storage must be set aside and action taken in as best as currently possible manner. Action must be taken without further delay because millions of lives are at stake. If a big quake, and large aftershocks, forces people to live outdoors they will extremely vunerable to fallout from a disaster at SONGS. No escape and nowhere to hide. Its almost unimaginable what could happen, and apparently most people prefer not to think about this very real possibility. Its up to the govemment to reduce this risk and resolve this situation before an irreparable tragedy ends S. CA civilization permanently. S. Califomians could concievably rebuild from a great quake but not if everything
a.
M is radioactive. This risk is simply not something that any govemment agency can " License" and force citizens to take. Costs of this project should be paid by the govemment up front, but ultimately SCE should bear the costs in an amortized way.
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Marine Corps trucks could be mobilized for this operation to transport the fuelin a secure way.
Highway Patrol could manage the traffic along the route. At 40,000 pounds per truck, a few i
dozen or so loads would be all that is required to move the fuel. It would not take long once the new site v>ss ready. This could be accomplished by the end of the year. This can be done in an orderly and safe manner without any long study, debate or delay.
i Update: Due to the tremendous public resistance to moving waste recently in Germany, we need to come up with a much better plan. One that includes public education, mass media presentation of the true situation and resons why this must be done, debate and a vote. It will probably take shutting down at least a portion of S. CA for a day, a " Nuclear Holiday" with support from the mejority and a positive plan for a new future, not the status-quo, l
cover-up and confrontation.
Once the fuelis in Nevada, we can continue to stL.dy ways to solve the waste problem in a safe way with many years available. Time has run out for the current staus-quo at SONGS and emergency action must be taken.
Most Sincerely, Stephen Dwyer Geologist, petitioner smd@wdc. net (714)731-1335 1
l (714) 731-3745 fax i
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