ML20216J281
| ML20216J281 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/23/1997 |
| From: | Borchmann P AFFILIATION NOT ASSIGNED |
| To: | Fields M NRC |
| References | |
| NUDOCS 9709170220 | |
| Download: ML20216J281 (6) | |
Text
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Patricia Borchmann 176 Walker Way vista, CA 92083 J
June 23, 1997 I
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i Mel Fields l
Project Manager l
.US Muclear Regulatory Commission Documents control Desk
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Washington DC 20555 j
DENAND THAT NRC EXTEND THE CURRENT UNIT 3 SONGS' OUTAGE UMTIL ALL OUTSTANDING PUBLIC SAFETY CONCERNS ARE FULLY RESOLVED
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A.
serious flows in the BONGS Emergency Rvacuation Pleas for both saa Diego and orange county azist.
Based on only a superficial analysis, a few critical flaws were previously i
identified in my 5-21-97 letter, which was previously transitted to your attention, by John H. Robertus, Executive officer of Regional Water Quality Control Board (by letter dated 6-9-97).
some additional information is To assist you in your response,ich were previously identified, submitted about deficiencies wh i
including:
1.
Evacuation and Traffic Capacity Analysis underestimated the actual number of vehicles projected to be used during an i
resulting in an overestimated traffic system emergency event, ion.
Although the Emergency Plans for both capacity assumpt j
counties were adopted by NRC, based on their acceptance by FEMA, Plans are fundamentally flawed.
The evacuation time line studies by SONGS are also finwed.
Analysis of all studies were based on L
the flawed assumption that only one vehicle per household would be used during an evacuation following an energency event at SONGS..This is not a realistic assumption.
Many more vehicles would be used during a real energency event evacuation.
With so many parents working jobs at separate locations, with children attending various schools or attending after school daycare or t
other activities, an event could easily occur where a family needs more than one vehicle to evacuate and there would not be enough time for parents stuck in traffic jams to meet, and j
consolidate fanily members in one carpool.
2.
Even under event worst case scenario assumptions such as t
i.
flooding, the current analysis assumes there would be no lane closures.
Not true, as found during the 1994 flooding and mud 3
closur,es in Laguna Beach, following fires in 1993.
3.
Obvious' deficiency of a 10-mile Evacuation Eone, or Low Population Bone (LPE), especially following TMI and Chernobyl.
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2.
Based on recent receipt ^of new information, a series of other serious technical deficiencies are identified belows 1.
Undersised Pressuriser ABB-CEE subsequently increased pressurizer size in plants following SONGS in order to obtain an acceptable FSAR Accident Analysis outcome.
The absence of the same standard at SONGS implies a deficiency.
2.
SONGS Mismanagement in Inss of Coolant Accident Dose Calculations Doses of remedy treatment substances to populations exposed to radiation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are supposedly critical, however because the actual figures of the extent of exposed population are disputed, no one even really knows how many people might be affected in the first place, and of those, how many might be allergic to remedy treatment substances, and if so, how those affected might be treated.
bsur is the NRc's reply froo William H. Bateman about NRC's failure to d scip ne SONGS follow ng h 5 year period when SONGS' leak detections system at spent fuel pools went unmonitored, during a period when pools were determined to have leaked.
In the 12-20-96 reply letter from NRC Director William H.
Bateman, an excerpt Lncludes facts which supposedly a....
obviated the need for further NRC expenditure of NRC funds to independently reperform associated dost calculations."
NRC subsequently admitted that its investination resulted in a calculated post LOCA PZ thyroid inhalation dose that was 51.9%
higher than reported in the USAR (Updated Safety Analysis Report) prepared by Licensee (SONGS).
b.DurationofStorage Contrary to it's current use, the spent fuel pools at SONGS Unit I were never designed for permanent storage of spent fuel pools onsite.
Both the pool and fuel assemblies were intended fort temporary onsite storage with fuel assemblies moved offsite, after cooldown, but before the assemblies and pool would begin to show signs of degradation.
4.
Volume SONGS Units 2 & 3 may be a larger problem than Unit 1, because of use of high density racks to store more spent fuel asse'ablies in the same volume of space.
Use of the high density racks increases the probability of accidental criticaliti as the metal experiences degradation and breaks up in a seismic event.
The amount of spent fuel onsite, and amounts to be accumulated in the future is far greater than anticipated during design and constrution at SONGS.
SONGS now proposes longer times (greater burn up) between refuelings, meaning greater fission product accumulations in spent fuel assemblies discharged from the W Wf h gm q,g,e agog gg3q
reactor.
If SOHCS has a pending request to NRC to allow longer 4
times between refuelings, I suggest the agency reject the request outright, or proceed cautiously, with objective analysis independent of Licensee SOHGS.
5.
Condition of Plastic Nenbrane Under Spent Fuel Pool A 40-mil thick waterproof membrane was installed under the Spent Fuel Pool (SFP) bottom slab and on pool walls below grade.
The zombrane's condition is not known.
The membrane had seams which had to be welded together.
SCE assumes the membrane still adequately performs its original function of containing leaks from the pool.
Epoxy repairs to the pool performed in the past would fail during a seismic event due to the brittle nature of epoxy as it ages.
6.
Tallure to Monitor Lenk Detection Systen Recent earthquakes (Landers and Northridge) produced g loadings and horizontal offsets far greater than expected, based on conventional Richter scale ratings, indicating plant design was not built to withstand the extent of actual noismic activity, discovered later, buttnever reevaAuated, or ever determined what ytent of seismic retrofit would be$repired for Units 2 & 3.
Unit I was shut down due to the eco omic analysis which showed costs for seismic retrofit exceeded'a point of diminishing returns.
SONGS' seismic design assumptions and criteria are also correspondingly flawod in an analysis which determined no need to retrofit Units 2 & 3 for seismic safety.
Recent earthquakes have put the entire science of seismology into disarray.
SONGS' failed to monitor the SFP's leak detection system from 1981 to 1986, and NRC failed to discipline SONGS.
NRC's reply was "there are no procedural requirements for monitoring SFP's for leakage, and provided the FSAR in effect at the time does not include a detailed description of the leak detection system, and does not include requirements for monitoring SFP leaks.
The NRC still hasn't gotten around to writing the regulatory requirements and procedures for the FSAR material.
1.
Conditioned Response, Nasked by Rffects from Camp Pendletont As a citizen of north Vista, we have been conditioned to the frequent noises and explosions from Camp Pendleton's training exercises, to maintain our military readiness.
If there were an explosion or emergency event at SONGS, our conditioned response to ignore effects from Camp Pendleton activities reducer, our ability to distinguish a SONGS emergency event from the routine training practices at Camp Pendleton.
Also, unless drivers are tuned in listening to the conventional radio programming, they could be unknowingly driving in.,
radioactive areas, as drivers listen to their preferred tapes or personal CD's.
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2ndustry's total re11ance on implementation of an unrealistic SENS (Systeneatic Jteergency Management) nodel during an energency event at SONGS, which will not function as designed.
As pointed out in his March 30, 1997 letter (last exhibit of enclosed material);
"The success of dealing with a major accident is dependent on the full cooperation of all individuals designated with responsibility.
It is possible to imagine a nuclear accident emergency at SONGO so severe that some individuals may choose to walk away from the site and abandon their responsibilities.
During the THI reactor emergency in late 1970's we heard of at least one individual who in fact ran away from the scene and failed to perform his emergency duties.
What assurance is there that in the most threatening nuclear accident, individuals will choose to remain on duty and not run away?
Unlike a military organization SONGS employs civilian personnel who cannot be forced to perform their duties, especially under nuclear accident conditions which might affect their hnalth and safety.
We have heard stories of Russians using capital punishment on those who would not risk their health and safety at Chernobyl.
A free society such as ours cannot use such tactics.
The more severe the accident, the greater the need for personnel, but the lens likely they will stay around and help."
For all the above reasons, I demand that NRC extend the current Unit 3 fuel outage until all concerns and issues raised here, and those within the scope and de th ne ed material, and all other material submitted have been fully resolved.
Please confirm if this letter can be treated as a formal Petition, pursuant to 10 CFR Ch.1, Section 2.206, and if not, why not?
I would say it is about time NRC got around to doing your duty.
Remember, your duty in to work in the public's interest, not the nuclear industry's interest.
NRC's past responses have been disin suous unresponsive, and patronizing, at best.
Heatings to resolve his concerns about issues in his material over several years have been reported where NRC staff engaged in intimidating tactics.
This pattern was recently identified in a GAo audit. prepared for a Congressional subcommittee, which affirmed NRC's performance reflects a culture which tolerates and accepts conditions which jeopardize public health and safety.
Since this subject is so timely, I'm r-nding a copy to my Congrossman, and circulated to other member the President, and vice President, who will also await your ri j.
Since I cannot afford duplication costs of all the enclosed
.chnical material copy recipients will receive copy of this Ictter only, with request that you
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d (NRC) duplicate all enclosed material to be distributed under separate cover.
A proof for authenticity and cospleteness prior to duplication is requested.
Thank you for your prospt, responsive reply.
Another " blow it off" response will not be accepted.
"We the people" deserve that NRC act on behalf the the public, and apply public safety as the highest human paradigm.
Remember, with SONGS, there is no safe margin for error. If found unsa'e, close it; with costs absorbed J
by shareholders, not ratepayers or 2ocal residents fnrced to put up with living at risk, without a net, under a knowingly deficient plant & spent fuel pool design.
This has caused substantial men distress for not only myself and ay partner, s
but als
& his many profes.:ional colleagues, about the countless o ers, w o although they may not be similarly distressed, they do not even know of the conditions they are exposed to, by living near SONGS.
5 Patricia Borchmann copy:
President Bill Clinton Vice Preside;:r. Al Gore Congressman Congressman J. Biden, Chairperson - GAO Report on NRC State Atterney General Dan Lundgren Executive Director of Operations U.S. Nuclear Regulatory Commission Washington DC 20555 0001 v/ Request for Licensing Actions.10 CTR 2.206 SONGS William Bateman Project Directorate IV-2 Division of Reaction Projects III/IV Office of Nuclear Reactor Regulation Washington DC 20555-0001 Susan Hansch/Melanie Haler California coastal commission Paul Richter, Regional Water Quality Control Board e
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THE CORRESPONDENCE REFERRED TO l
BY PATRICIA BORCHMANN IS WITHHELD FROM THE PUBLIC i
DOCKET TO PROTECT THE PRIVACY OF 1
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