ML20178A248

Public Watchdogs 10 CFR 2.206 Petition - E-mail from Public Watchdogs with Presentations for June 24th Public Meeting with the NRC

ML20178A248
Person / Time
Site:	San Onofre
Issue date:	06/24/2020
From:	Public Watchdogs
To:	Office of Nuclear Material Safety and Safeguards
CSBajwa NMSS/DFM/CTCF 415.5341
Shared Package
ML20178A247	List: ML20178A248 ML20178A249
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2.206
Download: ML20178A248 (10)

Text

• Charles Langley

• Executive Director of Public Watchdogs

• 24 years experience as a Public Advocate regulating California IOUs

Unanalyzed Flood Condition The San Onofre Nuclear Generating Station (SONGS) has a history of Flooding.

Today we intend to prove that this history represents an unanalyzed or under-analyzed condition that must be addressed by the NRC immediately.

Severe floods from rain

• According to an NRC Event Report dated January 22, 2010, even the high ground on the Mesa has been subject to severe flooding according to Event Report Number 45634 (Source: https://bit.ly/3esXmhl)

According to the report, On January 18, 2010 the access road to the SONGS MESA facility was flooded by rain blocking vehicle access to the San Onofre Emergency Operations Facility. According to the report, in the event of an emergency at San Onofre, Southern California Edison would direct emergency responders to travel to the alternate Emergency Operations Facility located 30 miles away in Irvine.

Two days later on January 20, the access road to the SONGS MESA was again flooded. Again, the San Onofre Emergency Operations Facility was inaccessible to vehicles and emergency responders were directed to travel 30 miles to Irvine.

Tsunami Inundation Map Close up of SONGS Where ISFSI is located

Nomenclature

• In its public rebuttal to Public Watchdogs concerns about flooding risks at SONGS, Southern California Edison has used terminology that needs to be refined.

Inconsistent terminology In its rebuttal, Edison countered Public Watchdogs concerns by stating:

"... the outside shell of the warmest spent fuel storage canister on site is approximately 225°f., not an average of 452°f.

Yet nowhere in any of the Holtec documents relevant to the MPC-37s in use at SONGS is there a reference to an outside shell

Example of Outside Shell?

The only example of an outside shell that we could find in Holtec schematics was this illustration of an outer shell, which is actually the exterior of the concrete overpack on a Hi-Storm 100 canister. We therefore advise the NRC to carefully examine the claims made by Edison regarding temperatures of various MPC-37 components.

Source: Figure 1.13A: HI-STORM 100S OVERPACK CROSS SECTIONAL ELEVATION VIEW, HI-STORM 100 FSAR, NONPROPRIETARY, Revision 18, May 16, 2019 at https://bit.ly/31c0Fpk

Faulty Assumptions In its public response*, Edison stated The water would enter the inlets of the vertical ventilated module lids and flow down the annular region between the cavity enclosure container and the divider shell. Edison has argued that flooding will actually improve the cooling capacity of the canisters.

Edison also stated It would be more akin to heating a pot of water for spaghetti .Plus, the temperature of the canister surface would begin cooling immediately, since water is a better conductor of heat than air This is a false assumption: Tsunamis rarely consist of pure sparkling saltwater. A more likely scenario is tons of semi-liquid mud, rock, and biological debris completely blocking the convection cooling function of the canisters. In fact, as Mr. Blanch will explain, convection cooling could be hampered by other factors.

• See Statement from Southern California Edison re Public Watchdogs News Release Feb. 4, 2020 FINAL at https://bit.ly/2B2L3tD

A history of ignoring flood risks at NRC In 2012, NRC employee Richard Perkins with the NRCs Division of Risk Analysis wrote to the Office of Inspector General that the NRC was intentionally classifying flooding analyses at U.S. nuclear reactor sites by claiming that it was sensitive, security information in an effort to conceal the information from the public.

In the case of SONGS, similar flood information is being withheld on the grounds that disclosure threatens the intellectual property of Holtec International, the vendor of the system used at SONGS.

106 years ago, Supreme Court Justice Louis Brandeis wrote that the people have a right to know how the peoples business is being conducted. Sunlight he said, is the best disinfectant, and electric light the most efficient policeman.

For years, San Onofre provided us with reliable electric light, but now, the people have a right to know how the publics money - more than

$4 billion of it, is being spent on nuclear clean-up.

I thank you for listening, and turn you over to our Engineer, Paul Blanch, for the remainder of this presentation.

Source: http://big.assets.huffingtonpost.com/igletter.pdf