ML20189A115
| ML20189A115 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/24/2020 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| CSBajwa NMSS/DFM/CTCF 415.5341 | |
| Shared Package | |
| ML20036E926 | List: |
| References | |
| NRC-0941 | |
| Download: ML20189A115 (40) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Petition to Suspend Decommissioning Operations at the San Onofre Nuclear Generating Station Docket Number:
(n/a)
Location:
teleconference Date:
Wednesday, June 24, 2020 Work Order No.:
NRC-0941 Pages 1-39 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
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3 PETITION REVIEW BOARD 4
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5 RE: PETITION TO SUSPEND DECOMMISSIONING OPERATIONS 6
AT THE SAN ONOFRE NUCLEAR GENERATING STATION DUE TO 7
OPERATION OF THE INDEPENDENT SPENT FUEL STORAGE 8
INSTALLATION IN AN UNANALYZED CONDITION.
9
+ + + + +
10 PETITIONER: PUBLIC WATCHDOGS 11
+ + + + +
12 WEDNESDAY 13 JUNE 24, 2020 14
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15 The meeting convened via teleconference 16 at 3:00 p.m. EDT, Kevin Williams, Petition Review 17 Board Chair, presiding.
18 19 PETITION REVIEW BOARD (PRB) MEMBERS PRESENT 20 KEVIN WILLIAMS, Office of Nuclear Material 21 Safety and Safeguards; Chair 22 STEPHANIE ANDERSON, Region IV 23 PERRY BUCKBERG, Office of Nuclear Reactor 24 Regulation 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 ROBERT CARPENTER, Office of the General Counsel 1
MARLAYNA DOELL, Office of Nuclear Material 2
Safety and Safeguards 3
DARRELL DUNN, Office of Nuclear Material Safety 4
and Safeguards 5
LATIF HAMDAN, Office of Nuclear Material Safety 6
and Safeguards 7
NATREON JORDAN, Office of Nuclear Reactor 8
Regulation 9
JON WOODFIELD, Office of Nuclear Material Safety 10 and Safeguards 11 NRC STAFF PRESENT 12 CHRIS BAJWA, Office of Nuclear Material Safety 13 and Safeguards 14 WILLIAM ALLEN, Office of Nuclear Material Safety 15 and Safeguards 16 ANDREW AVERBACH, Office of the General Counsel 17 ANDREW BARTO, Office of Nuclear Material Safety 18 and Safeguards 19 YEN-JU CHEN, Office of Nuclear Material Safety 20 and Safeguards 21 YOIRA DIAZ-SANABRIA, Office of Nuclear Material 22 Safety and Safeguards 23 SUE GARCIA, Office of Nuclear Material Safety 24 and Safeguards 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 CHRISTIAN JACOBS, Office of Nuclear Material 1
Safety and Safeguards 2
ANDREA KOCK, Office of Nuclear Material Safety 3
and Safeguards 4
JOHN McKIRGAN, Office of Nuclear Material Safety 5
and Safeguards 6
CHRISTOPHER REGAN, Office of Nuclear Material 7
Safety and Safeguards 8
AMY SNYDER, Office of Nuclear Material Safety 9
and Safeguards 10 JOHN WISE, Office of Nuclear Material Safety 11 and Safeguards 12 13 ALSO PRESENT 14 NINA BABIARZ, Public Watchdogs 15 FATON BACAJ, Sempra Energy 16 ALBERT BATES, Southern California Edison 17 DOUG BAUDER, Southern California Edison 18 VINCE BILOVSKY, Southern California Edison 19 PAUL BLANCH, Public Watchdogs 20 DEREK BRICE, Southern California Edison 21 DONNA GILMORE, San Onofre Safety 22 RANDALL GRANAAS, Southern California Edison 23 CARLYN GREENE, UxC 24 GARY JENKINS 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 C.D. LADD 1
CHARLES LANGLEY, Public Watchdogs 2
SERGE LaRONDELLE 3
MARK MORGAN, Southern California Edison 4
JERRY STEPHENSON, Southern California Edison 5
ALLEN TRIAL 6
KALENE WALKER 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 CONTENTS 1
Welcome and Introductions............
6 2
PRB Chairman's Introductions
.......... 11 3
Petitioner's Presentation............ 15 4
Closing Remarks................. 38 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 P-R-O-C-E-E-D-I-N-G-S 1
3:13 p.m.
2 MR. BAJWA: I apologize for the delay and 3
the technical issues. Again, just to mute your phones 4
on the system you can do star 6, or you can use an 5
alternative method if your phone has a specific mute 6
capability.
7 We are on tap here. I have multiple 8
windows going at once. If I sound at any point in 9
time distracted, I apologize for that. It's because 10 I'm monitoring a couple of different things at once so 11 I'm having to multi-task here.
12 Anyway, my name is Chris Bajwa. I'm a 13 senior mechanical engineer in the Division of Fuel 14 Management here at NRC. I would like to welcome you 15 and thank all of you for attending this meeting.
16 The purpose of today's meeting is to 17 provide petitioner in this case, Public Watchdogs, an 18 opportunity to address the NRC Petition Review Board 19 for the petition that was submitted on February 5th of 20 2020 regarding the petition to suspend all the 21 decommissioning activities at SONG to an unanalyzed 22 condition related to flooding at the SONG ISFSI.
23 I already introduced myself. The chairman 24 for the Petition Review Board is Kevin Williams.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 Kevin is the Deputy Director in the Division of 1
Material Safety, Security, State, and Tribal Programs 2
in the Office of Nuclear Material Safety and 3
Safeguards.
4 This is a Category 1 meeting so the public 5
is invited to observe the meeting. Obviously we're 6
doing this remotely and observe is used in this case 7
by phone and Skype. We'll have an opportunity to 8
communicate with me after the business portion but 9
before the meeting is adjourned.
10 As part of the Petition Review Board's 11 review of this petition, Public Watchdogs has 12 specifically requested this opportunity to address the 13 PRB.
14 We were scheduled to start at 3:00.
15 Obviously we're starting a little late because we had 16 some technical difficulties. After these introductory 17 remarks we will give Public Watchdogs the agreed-to 18 amount of time to address the Board followed by a 19 brief question and answer phase.
20 A couple of housekeeping items. This 21 meeting is being recorded by the NRC Ops Center and it 22 will be transcribed by the court reporter. I would 23 like to give an opportunity for the court reporter to 24 let us know that they're on and that they have what 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 they need to record the transcription for the meeting.
1 Because the transcription will be taken 2
and it will be made publicly available, I would like 3
to emphasize that anyone who speaks on the line needs 4
to speak clearly and loudly and slowly if possible to 5
make sure that the court reporter can accurately 6
transcribe the meeting. If you have anything that you 7
would like to say, please also first state your name 8
for the record. If you have an organization that 9
you're with, that would also be helpful.
10 I think I mentioned this, that if you need 11 to mute your phone through the system and you do not 12 have a mute button, you can use the key star followed 13 by 6. Then in order to unmute your phone, which you 14 don't want to forget to do if you'd like to speak, you 15 do star and 6 again.
16 I would like to do some introductions over 17 the phone. We have a number of participants, over 30 18 currently, logged into the meeting. I think what I'd 19 like to do is have the members of the Petition Review 20 Board introduce themselves giving your name and your 21 position. Then, after that, NRC participants. Then 22 next we will have the people from the petitioners, 23 Public Watchdogs introduce themselves.
24 Finally, we have a number of members of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 the public who are also on this call. It is not 1
required for members of the public to introduce 2
themselves. However, if they are on the phone and 3
they wish to do so, they can do that.
4 First we'll start with the PRB members.
5 I would ask those members to quickly unmute themselves 6
and introduce themselves.
7 (Music playing.)
8 MR. BAJWA: Okay. It appears to be gone.
9 All right. Let's stay muted and I will go ahead and 10 go to the list that I have of the PRB members.
11 Stephanie Anderson from NRC. I have Perry 12 Buckberg, also NRC. Rob Carpenter, Marlayna Doell.
13 I have Darrell Dunn. I have Latif Hamdan. I have 14 Nate Jordan. I have Kevin Williams who is our PRB 15 Chair, as I mentioned. And I have Jon Woodfield. If 16 I missed anyone from the PRB, could you please unmute 17 yourself and introduce yourself.
18 Hearing no one, I would like to --
19 Charles, if you could introduce yourself and anyone 20 who is representing Public Watchdogs.
21 MR. LANGLEY: Yes, this is Charles 22 Langley. I'm the Executive Director of Public 23 Watchdogs. I'm here today to present with our subject 24 matter expert and engineer Paul Blanch.
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10 MR. BAJWA: Okay. Thank you, Charles.
1 Are there any other members of the public 2
who would like to introduce themselves? If you could 3
unmute yourselves one at a time and introduce 4
yourself.
5 MS. GILMORE: Donna Gilmore, San Onofre 6
Safety.
7 MS. GREENE: Carlyn Greene, UxC.
8 MR. BAJWA: Okay. Thank you for that.
9 The agenda for today's meeting after this 10 introduction we'll have --
11 MR. BATES: Excuse me.
12 MR. BAJWA: Yes.
13 MR. BATES: Chris, hi. This is Al Bates.
14 I'm with Southern California Edison. I'm the 15 regulatory manager of San Onofre, the licensee. With 16 me today I have Mark Morgan who is the Senior Nuclear 17 Regulatory Affairs engineer, as well as Derek Brice 18 who is our Chief Legal Counsel for SONGS 19 decommissioning. Thank you.
20 MR. BAJWA: Okay. Thank you. I think I 21 left off with Perry.
22 Perry, did you introduce yourself or did 23 I mention you before?
24 MR. BUCKBERG: You did mention me before.
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11 Thanks, Chris.
1 MR. BAJWA: Okay. Didn't want to leave 2
you out.
3 All right. So any other introductions 4
before we move on? Okay. Hearing none, as I 5
mentioned, the agenda for today's meeting is to 6
provide the petitioner an opportunity to provide any 7
information to the PRB for the PRB to consider in its 8
review of the petition that's been submitted.
9 It was agreed that an hour would be 10 provided to the petitioner for this presentation.
11 After that presentation, we'll enter a brief question 12 and answer phase where either the licensee may ask the 13 PRB questions related to the issues raised in the 14 petition and/or the petitioner and the licensee may 15 ask the PRB questions related to the 2.206 petition 16 process in general.
17 At this time I would like to turn it over 18 to the PRB Chair Kevin Williams for some opening 19 remarks.
20 CHAIR WILLIAMS: Okay. I just want to 21 verify that you can hear me.
22 MR. BAJWA: Loud and clear.
23 CHAIR WILLIAMS: Okay, good. Thank you.
24 So welcome to this meeting regarding the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 2.206 petition submitted by Public Watchdogs. I would 1
like to first share some background on our process.
2 Section 2.206 of Title 10 of the Code of Federal 3
Regulations describes the petition process.
4 The primary mechanism for the public to 5
request enforcement action by the NRC in a public 6
process. This process permits anyone to petition NRC 7
to take enforcement type action related to NRC 8
licensee or licensed activity.
9 Depending on the results of its 10 evaluation, NRC could modify, suspend, or revoke any 11 NRC issued license or take any other appropriate 12 enforcement action. The NRC staff guidance for the 13 disposition of 2.206 petition request is Management 14 Directive 8.11 which is publicly available.
15 The purpose of today's meeting is to give 16 Public Watchdogs an opportunity to provide any 17 relevant additional explanation and support for the 18 petition after having received the PRB's initial 19 assessment.
20 This meeting is not a hearing, nor is it 21 an opportunity for Public Watchdogs or other members 22 of the public to question or examine the PRB on the 23 merits or the issues presented in the petition 24 request. No decisions regarding the merits of this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 petition will be made at this meeting.
1 Following the meeting the PRB will conduct 2
its internal deliberation. The outcome of this 3
internal meeting will be provided to Public Watchdogs 4
in a letter. The PRB typically consist of a chairman, 5
usually a manager at the senior executive service 6
level at the NRC.
7 It has a petition manager and a PRB 8
coordinator. Other members of the Board are 9
determined by the NRC staff based on the content of 10 the information in the petition request.
11 The members have already introduced 12 themselves. As described in our process, the NRC 13 staff may ask clarifying questions in order to better 14 understand Public Watchdogs' presentation and to reach 15 a reasonable decision on whether or not to accept 16 Public Watchdogs' request for review under the 2.206 17 process.
18 I would like to summarize the scope of the 19 petition under consideration and the NRC activities to 20 date. On February 5, 2020 Public Watchdogs submitted 21 a petition to the NRC under 2.206 regarding concerns 22 about decommission activities at SONGS.
23 The petition requested that the NRC order 24 Southern California Edison to (1) immediately halt 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 decommissioning activities at SONGS, (2) report to the 1
NRC that SONGS ISFSI is operating in an unanalyzed 2
condition, take immediate action to preclude flooding 3
of the SONGS ISFSI, and (3) suspend all fuel transfer 4
actions from the spent fuel pools to the ISFSI at 5
SONGS, among other requests.
6 On April 20, 2020 the petition manager 7
contacted Public Watchdogs to inform them of the PRB's 8
initial assessment that the petition does not meet 9
management directive 8.11, Section 3.c.1 criteria for 10 petition evaluation because NRC staff had continued to 11 carefully regulate the licensee's decommissioning 12 activities at SONGS including through its review of 13 the fuel storage facility design inspection 14 encompassing the physical facility as well as the 15 licensee's operation performance and appropriate 16 enforcement action.
17 The primary safety concerns stated in the 18 petition was the unanalyzed risk and imminent threat 19 or the effects of inundation of the SONGS ISFSI with 20 floodwater or burial by debris that would result in 21 rupture of multiple casks due to thermal shock with 22 results of leaving the public at large vulnerable to 23 a radioactive release and permanent dislocation from 24 their residences and livelihood.
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15 The effects of the inundation of the SONGS 1
ISFSI floodwater or burial by debris, and specifically 2
the impact of such conditions on the spent fuel 3
canisters, have been evaluated and addressed in the 4
final safety analysis report for Holtec HI-STORM UMAX 5
dry cask storage system. That is found at ADAMS ML 6
No. 18192B094.
7 The NRC staff reviewed the SR for the UMAX 8
system and found that the system meets all applicable 9
NRC regulations. The petition manager offered Public 10 Watchdogs the opportunity to address the PRB to 11 clarify or supplement the petition in response to this 12 assessment and Public Watchdogs requested to address 13 the PRB in this form.
14 As a reminder for all participants, please 15 identify yourself if you make any remarks as this will 16 help us in the preparation of the meeting transcript 17 that will be made publicly available. Thank you.
18 Public Watchdogs, I will now turn over the 19 meeting to you to provide additional information for 20 PRB consideration as part of the petition. At this 21 moment we've allotted 60 minutes for your 22 presentation.
23 MR. LANGLEY: Thank you, Mr. Williams, and 24 Chris Bajwa. This is Charles Langley of Public 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 Watchdogs.
1 Mr. Bajwa, are you able to -- it looks 2
like you're loading our presentation right now. While 3
that's going, I would like to talk about something 4
that I think is kind of pertinent and germane to what 5
we're going to be talking about today.
6 That is that yesterday a 7.4 Richter scale 7
earthquake shook the west coast of Mexico in a town 8
called Oaxaca. The earthquake triggered a tsunami 9
alert for the pacific coastline for Central America.
10 Now, tsunamis which could easily slug the 11 independent spent fuel installation, or ISFSI at San 12 Onofre, are caused by blind thrust earthquake faults.
13 SONGS is located fewer than two miles away from 14 something called the Oceanside blind thrust. This 15 earthquake fault has been extensively documented by 16 more than 30 peer-reviewed geological studies.
17 A few years ago Southern California Edison 18 commissioned a $12 million study to "prove" that there 19 is no blind thrust fault system off the coast of San 20 Onofre and that it would be impossible for an 21 earthquake to exceed the structural limits of the 22 SONGS ISFSI.
23 Yesterday's tsunami merits special 24 attention because at 7.4 on the Richter scale it could 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 have easily caused serious damage to the SONGS ISFSI 1
if it had occurred off the coast of California.
2 Now to get back to the presentation. I'll 3
just introduce myself. Again, I'm Charles Langley.
4 In terms of my background, I have 24 years of 5
experience as a public advocate regulating California 6
IOUs, or industrial-owned utilities. I got my start 7
in this field in 1996 as a public advocate for UCAN, 8
the Utility Consumers Action Network.
9 Then in 2016 I founded Public Watchdogs, 10 a 501(c)(3) public benefit charity to protect 11 electricity ratepayers from the California Public 12 Utilities Commission and to represent Californians 13 before a regulatory body such as the Nuclear 14 Regulatory Commission.
15 Next slide, please. What we are here to 16 talk about today is what we believe is an unanalyzed 17 flood condition. The San Onofre Nuclear Generating 18 Station, SONGS, has a history of flooding. Today we 19 intend to prove that this history represents an 20 unanalyzed or under-analyzed condition that must be 21 addressed by the NRC immediately.
22 Next slide, please. Severe floods from 23 rain. The site has a history of flooding.
24 Previous slide, please. According to the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 NRC Event Report dated January 22, 2010 even the high 1
ground on the Mesa has been subject to severe flooding 2
according to the Event Report No. 45634. According to 3
this report, on January 18, 2010 the access road to 4
the SONGS Mesa facility was flooded by rain blocking 5
the vehicle access to the San Onofre Emergency 6
Operations Facility.
7 According to the report, in the event of 8
an emergency of San Onofre, Southern California Edison 9
would have had to direct emergency responders to 10 travel to the alternate Emergency Operations Facility 11 located 30 miles away in Irvine.
12 Two days later on January 20th the access 13 road to the SONGS Mesa was again flooded. Again, San 14 Onofre Emergency Operations was inaccessible to 15 vehicles and emergency responders who were directed to 16 travel the 30 miles to Irvine.
17 Next slide, please. This is a tsunami 18 inundation map. It shows Northern -- excuse me, 19 Southern Orange County and Northern San Diego County.
20 That line down the middle of the map is the border 21 between the two counties.
22 Go to the next slide, please. San Onofre 23 is located near that border. That little notch in 24 there is a close-up of where San Onofre is located.
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19 This is the tsunami inundation map from the California 1
Geological Information Services.
2 It shows that this little notch in here, 3
this divot, is where the San Onofre Nuclear Generating 4
Station ISFSI is located including the domes and all 5
the outbuildings. Most of the facility is located 6
within this tsunami inundation zone meaning, of 7
course, that if there was a tsunami, this facility and 8
the ISFSI, the spent nuclear fuel dump, would be 9
inundated.
10 Next slide, please. One thing I'd like to 11 talk about is the vocabulary that's been used in some 12 of Edison's rebuttals to concerns that we've expressed 13 about SONGS.
14 Next slide, please. In its rebuttal, 15 Edison encountered public concerns by stating, "The 16 outside shell of the warmest spent fuel storage 17 canister on site is approximately 225 degrees 18 Fahrenheit, not an average of 452 degree Fahrenheit."
19 We looked everywhere to find what was 20 being defined as the outside shell and nowhere in any 21 of the Holtec documents relevant to the MPC-37, which 22 is the brand of canister used at Holtec, is there a 23 reference to an outside shell.
24 Next slide, please. Okay. So what we're 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 looking at is a cutaway of a Holtec multi-purpose 1
canister and this isn't the canister at San Onofre.
2 It's MPC-100, I believe, inside a concrete overpass.
3 It's the only reference, if you look at this red 4
circle, where we can find reference to an outer shell, 5
an outside shell.
6 We, therefore, advise the NRC to carefully 7
examine any claims that Edison is making regarding the 8
temperature of various components of the MPC-37 9
because it appears that between Holtec and Edison the 10 definition of the different parts and components of 11 these vertical ventilation modules, canisters, fault 12 systems, whatever you want to call them, are kind of 13 slippery and flexible.
14 We would just like to state that when they 15 specify what a temperature is, you need to be very 16 specific in determining what part of the system 17 they're talking about because right now we're not very 18 clear on that.
19 Next slide, please. We would also like to 20 point out what we believe is a faulty assumption. In 21 its public response Southern California Edison said, 22 "The water would enter the inlets of the vertical 23 ventilated module lids and flow down the annular 24 region between the cavity enclosure container and the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 divider shell."
1 In other words, they're saying the 2
canister inside the silo that holds them would be 3
filled up with water. Now, what's interesting is that 4
Edison has actually argued that flooding things with 5
water will actually improve the cooling capacity of 6
the canisters. Let me say that again.
7 Edison has argued that flooding the 8
canisters will actually improve the cooling capacity 9
of the canisters. This is what they say. It would be 10 more akin to heating a pot of water for spaghetti.
11 Plus, the temperature of the canister's surface would 12 begin cooling immediately since water is a better 13 conductor of heat than air.
14 We respectfully submit that this is a 15 false assumption. The reason is that tsunamis rarely 16 consist of pure sparkling ocean water. A more likely 17 scenario is tons of semi-liquid mud, rock, and 18 biological debris completely blocking the convection 19 cooling function of the canisters.
20 In fact, it's entirely likely that ISFSI 21 could be covered under many, many feet of mud and 22 rock. In fact, as Mr. Blanch will explain later, 23 convection cooling could also be hampered by other 24 factors.
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22 Next slide, please. Now, this is my last 1
slide. I would just like to observe that the NRC has 2
a history of ignoring flood risks at nuclear reactors.
3 I know this is a new Nuclear Regulatory 4
Commission but I would just like to observe that in 5
2012 an NRC employee named Richard Perkins with NRC's 6
Division of Risk Analysis wrote to the Office of 7
Inspector General that the NRC was intentionally 8
classifying, in other words keeping secret, flooding 9
analyses at US nuclear reactor sites by claiming that 10 these analyses were "sensitive security information in 11 an effort to conceal the information from the public."
12 In the case of SONGS, similar flood 13 information is being withheld on the grounds that 14 disclosure threatens the intellectual property of 15 Holtec International, the vendor of the system used at 16 SONGS. Now, when public safety is at stake, the 17 public's right to know the facts must not be 18 subordinated to the protection of corporate process.
19 One hundred and six years ago Supreme 20 Court Justice Louis Brandeis wrote that the people 21 have a right to know how the people's business is 22 being conducted. Sunlight, he said, is the best 23 disinfectant and electric light the most efficient 24 policeman.
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23 For years San Onofre has provided us with 1
reliable electric light but now the people have a 2
right to know how the public's money, more than $4 3
billion of it, is being spent on nuclear cleanup.
4 I thank the Petition Review Board for 5
listening to my arguments today and I now turn you 6
over to our engineer Paul Blanch for the remainder of 7
this presentation. Thank you.
8 MR. BLANCH: Okay. This is Paul Blanch.
9 I want to thank you, Charles and thank you, Chris. I 10 just want to clarify one thing that Charles said to 11 make sure we're all on the same page. That is that I 12 don't disagree with Edison.
13 If the VVM is totally covered with water 14 there will be proper heat removal as long as there's 15 no obstruction and it's totally covered and remains 16 covered up to 125 feet of water, I don't have a 17 problem as far as cooling goes, but that won't occur.
18 Again, I want to thank members of the 19 Petition Review Board for listening to me. I have 20 additional information, new information, that I've 21 come upon that I deem to be very, very significant.
22 I'm on slide 1 which is just the title slide. Now I'd 23 like to go to slide 2.
24 We've all -- all the NRC PRB members have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 introduced themselves and I have two questions. It 1
was mentioned at the beginning that there is a member 2
from the Senior Executive Service. Could you please 3
identify who that member is?
4 MR. WILLIAMS: Kevin Williams.
5 MR. BLANCH: Kevin Williams is SES?
6 MR. WILLIAMS: Yes.
7 MR. BLANCH: Okay. Do we have any 8
professional engineers from the NRC?
9 MR. BAJWA: Yes. This is Chris Bajwa. I 10 am a professional engineer registered in the state of 11 Maryland.
12 MR. BLANCH: Okay. How about reactor 13 operator authorization licensed power operator. Okay.
14 All right. My professional background is I am a 15 professional engineer. I am an authorized reactor 16 power operator from the United States Navy. I have a 17 degree in electrical engineering. I've worked in the 18 nuclear industry for well over 50 years on regulatory 19 and safety issues. I think I'm well respected by most 20 of the people within the NRC.
21 All of my following slides are in 22 accordance with Management Directive 8.11. I'm 23 following the guidance there. Just to confirm that 24 we're all on common ground, again on slide 2 I mention 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 the documents that I'm using as a reference which is 1
UMAX Revision 5 and NUREG 1536 which is the standard 2
review plan.
3 I'm also referencing now, it might not be 4
on your slide, 10 CFR 72.128(a)(4) and (5). What this 5
says is you must demonstrate that you have a heat 6
removal capability, have testability and reliability 7
consistent with its importance to safety.
8 Certainly cooling heat removal of 100 to 9
150,000 BTUs per hour is important to safety. If we 10 lose that capability, we will have major problems.
11 Next slide, please. Okay. If we get 12 flooding through whatever means, and whether it's 13 permanent or long-term flooding or short-term flooding 14 we have a disaster on our hands. When water enters 15 above the vents at San Onofre, each of the 72 vertical 16 ventilator modules that store the nuclear waste will 17 be flooded to above the outlet vents.
18 Once this flooding occurs, there is no 19 known means discussed in the final safety analysis 20 report, NRC documents, or Holtec documents to recover 21 from this event and restore cooling. Once the flood 22 waters recede below the inlet vents, we have lost all 23 cooling on all VVM modules.
24 Next slide, please. This is a reiteration 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 of what was in the original.206 that flooding is a 1
design basis event. This is supported by the Standard 2
Review Plan 5(e), 10 CFR 72. Then I want to say that 3
if flooding occurs, damage to the vertical ventilator 4
modules may be unrecoverable in the short term and 5
possibly in the long term.
6 I show a picture of the area. This is a 7
photograph supplied by Edison which shows the area 8
that will be flooded in the event of a tsunami and a 9
tropical storm. There might be possibly other events.
10 Next slide, please. Now there is new 11 information that I have. Flooding, of course, is a 12 design basis event. That's just repetition of what I 13 said before. Water from the tsunami or storm will be 14 above inlet and outlet vents.
15 Once the water recedes from the event, 16 most water will flash to steam and be expelled. This 17 phenomena may be repetitive with waves and surges. We 18 don't know how long that last and how frequently it 19 occurs. However, once the water recedes, subcooled 20 water will remain in the VVM blocking all cooling.
21 I'll get into a little more detail as to why I believe 22 that is the case.
23 When the water remains in the bottom of 24 the VVM, all passive cooling flow will terminate in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 every one of the units, or a common mode failure. The 1
MPC structural integrity has not been analyzed due to 2
rapid cooling, rapid heat-up.
3 Next slide, please. I'm on slide 6. The 4
fuel and the VVM temperatures and pressures are not 5
analyzed beyond 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> from the reference document.
6 It's assumed in the document at 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> somehow it 7
magically ends.
8 The recovery from this event, the flooding 9
event, is briefly discussed and includes removal of 10 the MPC, multi-purpose canister, from the VVM and to 11 remove obstructions by washing and vacuuming if 12 required. Again, this has to be done 72 or 73 times.
13 The other thing that's not discussed in 14 any of the reference documents are the radiation 15 levels that exist around these modules when they are 16 removed when they're cleaning them, so on and so 17 forth.
18 Next
- slide, please.
Flooding 19 considerations from NUREG 1536, which is what the NRC 20 is supposed to use when they are reviewing the 21 applicant's final safety analysis report, says -- and 22 we can all read it together -- the SAR should 23 establish a design basis flood condition. I think we 24 already have it. It's somewhere above the outlet 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 vents.
1 If the SAR establishes parameters for 2
design-basis flood, all of the potential flood water 3
byproducts should be recognized. What they mean there 4
is debris and salt and water and so on and so forth.
5 Serious flood consequences can involve 6
things such as blockage of the vent ports by water and 7
silting the air passages. Other potentially effects 8
include scouring below the foundations and severe 9
temperature gradients resulting from rapid cooling 10 from immersion.
11 Next slide, please. So we go the FSAR and 12 we look for the analysis of what happens with the 13 flood. I took a picture of the page. I forget 14 exactly what page it is but it's from the applicable 15 FSAR.
It says Section 4.6.2.5 Flood.
16 It says proprietary information withheld 17 in accordance with 10 CFR 2.390. We added text has 18 been redacted, for some reason by, NRC Holtec. This 19 is what Charles referred to is you cannot hide 20 information that impacts the public from view by the 21 public.
22 If there is something that is truly 23 proprietary, we can arrange for handling of that. If 24 it needs redaction, we can handle that. We need a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 complete flood analysis.
1 Next slide, please. This is from Oregon 2
State. It says if not controlled, the extremely rapid 3
cool-down rates to which the hot MPC and internal MPO 4
cladding could be subjected to during reflooding and 5
the MPC cavity could result in uncontrolled thermal 6
stresses and failure of structural limbers. Again, 7
another issue that needs to be addressed.
8 Next slide, please. Now, this is a Holtec 9
slide and I can't identify exactly where it came from 10 except that I know it's a Holtec slide and it looks 11 reasonably accurate projecting an axial temperature of 12 the Holtec multi-purpose canister.
13 If we follow the red line, we can see that 14 it goes up almost 370 degrees centigrade up four 15 meters from the bottom of the canister. The 16 interesting part is if we look at the temperatures 17 down one meter and below for the red line, or for any 18 of the lines, we can see that the temperature is in 19 the vicinity -- this is the wall temperature of the 20 Holtec -- it's a low temperature.
21 It's somewhere around 100 to 150 degrees 22 F, 50 degrees C. We can see that sub-cooled water 23 could exist up until it reaches 212 degrees which 24 might be over a meter from the bottom of the VVM.
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30 This is important as far as blockage of flow.
1 Next slide, please. This is -- I've 2
annotated the data from the FSAR that shows a typical 3
cast installation maximum temperature after 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> 4
of flow blockage. I got these numbers from the 5
following slide which is slide 12. Going back to 6
this, it shows some pretty significant temperatures 7
here. Fuel cladding of 964 degrees, fuel basket 936 8
degrees.
9 Those are beyond the limits but, again, I 10 want everyone to remember this is only after 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />.
11 This could persist most likely for more than 32 days 12 or 32 weeks. We don't know the consequences. The 13 water has not been demonstrated to be able to be 14 removed. It could be tested but, for some reason, it 15 hasn't been tested.
16 Next slide which is slide 12. The 17 temperatures I annotated on a previous slide were 18 taken from this Table 4.6.7.
19 Next slide. The maximum temperatures 20 reached after 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> of complete blockage. Again, 21 this is a direct quote. "Short-term operations 22 including, but are not limited, to the MPC drying and 23 onsite transport. The 1,058 degrees F temperature 24 limit applies to MPCs containing all moderate burn-up 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 fuel."
1 This last sentence is important and maybe 2
Donna -- not now but Donna might take an interest in 3
this. "The limit for MPCs containing one or more high 4
burn-up fuel assemblies is 752 degrees F." We've 5
already seen the 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> of blockage that brings it 6
up to 964 degrees F. We've got another problem that 7
the temperatures with a flood will certainly exceed 8
the design temperatures for a high burn-up fuel.
9
- Summary, issues, conclusions, and 10 questions. These are pretty much statements.
11 Flooding of the ISFSI has not been analyzed, at least 12 an analysis that we have seen as a member of the 13 public. Flood analysis, if existing, has been 14 withheld on that redacted page.
15 Flooding above the vents will halt all 16 cooling for all VVMs. This is a serious problem.
17 This is a problem I recently recognized. Steam 18 initially when the tsunami or flood recedes will be 19 produced and will be expelled as steam until the water 20 reaches the saturated conditions for whatever 21 temperature the MPC is at. Sub-cool sea water will 22 block all cooling with no possible recovery. Flow 23 blockage has only been analyzed for 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />.
24 Next slide. Structural impact of multiple 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 rapid temperature changes has not been analyzed.
1 Impact of residual salts and other contaminates and 2
flood byproducts non-analyzed. Common mode failure 3
has not been considered or discussed. Radiological 4
impact has not been address.
5 NUREG 1536 says all of the potential 6
effects of flood water and ravine flood byproducts 7
could be recognized. Not done. There are no 8
emergency plans that I've seen which are discussed in 9
the FSAR for the recovery of the 72 or 73 flooded 10 vertical modules.
11 In conclusion, I want to thank the 12 Petition Review Board for listening to me and my 13 perspective pertaining to this major safety issue and 14 request the NRC bring the AFSE into regulatory 15 compliance. That means the capability to withstand 16 and recovery from a blood which is a design-basis 17 event. Again, I want to thank you for listening to 18 me.
19 I'm turning it back to you, Chris.
20 CHAIR WILLIAMS: Public Watchdogs, thank 21 you for taking the time to provide the NRC staff 22 clarifying information on the petition you submitted.
23 As stated at the opening, we will now enter the 24 question and answer phase of the meeting. At this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 time does the PRB have any questions for the 1
petitioner?
2 Hearing none, if present, does the 3
licensee have any questions for the PRB related to the 4
issues raised in the petition?
5 MR. BATES: This is Al Bates, Southern 6
California Edison. We do not have any questions.
7 CHAIR WILLIAMS: Thank you, Al.
8 Does the petitioner or licensee have any 9
questions about the 2.206 petition process?
10 MR. BLANCH: Speaking for the petitioner 11 this is Paul. I would like to know why the flood 12 analysis has been redacted and withheld.
13 CHAIR WILLIAMS: Well, that's a question 14 that's outside of the scope of this process. The 15 question that we're having is do you have any 16 questions about the 2.206 petition process.
17 MR. BLANCH: I don't. Charles, do you?
18 MR. LANGLEY: This is Charles Langley.
19 thank you for going through this process, Mr.
20 Williams. I'm wondering if you can tell me what 21 happens next and what is the expected time frame for 22 a response from the NRC?
23 MR. WILLIAMS: So what happens next is 24 we'll review the additional information that you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 provided. We will also review the transcript from 1
this recorded meeting. We, being the PRB, will re-2 engage and discuss the additional information and make 3
a determination of whether there's any new information 4
that would warrant a change to our current assessment 5
in terms of where the PRB initial assessment came out.
6 If there is a change, we will address that 7
in our wrap-up. If there is not a change, then we 8
will convey to Public Watchdogs the outcome of the 9
petition.
10 MR. BLANCH: This is Paul Blanch. I would 11 like to make one comment. I think most of you have 12 seen the recent Inspector General's report. I think 13 it was16-024. I believe one of the findings was to 14 encourage more of a dialogue between the petitioners 15 and the PRB. I would like to reinforce this.
16 I've been through a number of 2.206 17 petitions and it always seems a monologue and very 18 rarely a dialogue where we can openly share 19 information and questions between us. I encourage the 20 PRB to establish a formal dialogue with themselves and 21 Public Watchdogs and myself to assure that we're all 22 looking at the same problem.
23 CHAIR WILLIAMS: That is duly noted.
24 Appreciate your comment.
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35 Any other questions about the 2.206 1
petition process from Public Watchdogs?
2 MS. BABIARZ: Yes. this is Nina Babiarz.
3 I do have a question.
4 CHAIR WILLIAMS: Okay.
5 MS. BABIARZ: Considering that we don't 6
know what is in the report that's been suppressed and 7
withheld from the public, and considering the fact 8
that the seismic and tsunami activity has continued up 9
to yesterday, would part of this process be that the 10 NRC in addition to responding to the 2.206 would 11 consider updating that flooding report to a current 12 status. Thank you.
13 CHAIR WILLIAMS: Chris or Rob, did you 14 want to address that at all? Rob Carpenter, are you 15 on?
16 MR. CARPENTER: Kevin, this is Rob. I'm 17 sorry, I'm here. I was having trouble getting my 18 phone off of mute. So let me ask for you to repeat 19 the last part of that question once again just so I 20 make sure I understand.
21 MS. BABIARZ: Yes. Considering that we do 22 not know the contents of the report that has been 23 suppressed from the public's review, and in addition 24 to the response to Public Watchdogs 2.206, would part 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 of that consideration be the NRC hopefully updating 1
considering that the seismic and tsunami activity as 2
recent as yesterday, would you consider updating the 3
report and, as part of updating that report, release 4
it to the public?
5 MR. CARPENTER: I'll address that in two 6
ways. The first is that the seismic and tsunami 7
activity you're referring to is what Mr. Langley was 8
talking about in Mexico?
9 MS. BABIARZ: The constant threat on the 10 west coast including the tsunami inundation zone smack 11 in the middle of the San Onofre site.
12 MR. CARPENTER: Okay. It sounds to me 13 like the question is generally given the possibility 14 of seismic and tsunami activity would we update the 15 analysis.
16 MS. BABIARZ: The probability. The 17 probability. Since we live with it on a 24/7 basis 18 out here the probability.
19 MR. CARPENTER: Okay. So the answer to 20 that question is not -- that is not something that 21 would be part of the 2.206 process. The 2.206 process 22 23 MS. BABIARZ: No, my question was in 24 addition to the 2.206 response to Public Watchdogs, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 and considering that we don't know what was in the 1
report in the first place that's been suppressed, but 2
knowing from this presentation that there is a 3
constant and upgraded seismic and tsunami threat that, 4
of course, either or both would result in flooding, 5
would the NRC consider updating that flooding report 6
to a current status of the current seismic activity 7
threatening this site and then release that updated 8
report to the public?
9 MR. CARPENTER: So I'm of the opinion that 10 question is not about the 2.206 process at all 11 actually.
12 MS. BABIARZ: Well, I guess my question is 13 actually related to the 2.206. From this exercise of 14 2.206 does the NRC consider upgrading the information 15 to a current status to reflect the threat?
16 CHAIR WILLIAMS: This is Kevin. I think 17
-- I allowed this to go forth because what I really 18 wanted to do was get to the crux of your question. I 19 think what we need to try to do is package this more 20 in terms of Public Watchdogs providing additional 21 information in that regard.
22 I
believe that was the intent of 23 mentioning it in the beginning. As we go back and 24 look at the transcript and look at the additional 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 information that was provided, it's something that 1
we'll consider as we're considering the petition.
2 MR. BLANCH: This is Paul Blanch. I have 3
another comment. We know the regulation requires the 4
ability to cool the fuel after a flood. It also 5
requires demonstration and testability and reliability 6
consistent with its importance to safety.
7 As an engineer, this is very testable.
8 One could test an actual module to see if cooling is, 9
in fact, blocked. If Cal, Holtec, or whomever, NRC, 10 can conduct an actual test replicating the impact of 11 the flood and demonstrate that cooling is still 12 adequate, then they should do that. If not, we're all 13 guessing.
14 It's very easy to flood one of those VVM 15 canisters to see what's going to happen. The NRC says 16 nothing is going to happen so there's no danger of 17 damage. I think the NRC, the licensee, and Holtec 18 should consider an actual test to see whether flooding 19 will block cooling as I content. Thank you.
20 CHAIR WILLIAMS: Thank you. If there are 21 any members of the public before I conclude the 22 meeting, do you have any comments regarding the 2.206 23 petition process?
24 Before we close, does the court reporter 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 need any additional information for the meeting 1
transcript? You're good? Thank you.
2 We want to encourage the participants 3
outside the NRC to provide public meeting feedback to 4
the staff via the NRC public meeting website. With 5
that, this meeting is concluded and we will be 6
terminating the phone connection. Thank you for your 7
time and thank you for providing additional 8
information.
9 (Whereupon, the above-entitled matter went 10 off the record at 4:17 p.m.)
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