ML20216J291
| ML20216J291 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/11/1997 |
| From: | Borchmann P AFFILIATION NOT ASSIGNED |
| To: | Fields M NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 2.206, NUDOCS 9709170223 | |
| Download: ML20216J291 (2) | |
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Patricia Borchmann i
176 Walker Way Vista, CA 92083 July 11, 1997 Mel Fields Project Manager 4
US Nuclear Regulatory Commission Documents control Desk Washington DC 20555 RE:
2.2026 Petition - Final Supplement
Dear Mr. Fields,
Thank you for contacting me 7-8-97 at 8:30 an as arranged, at my residence.
You and 3 other members of your staff verbally acknowledged my 2.206 Petition, and responded to questions about actions to be taken about issues brought up in the Petition.
Many of these issues were previously brought up both internally within the industry, externally, and also to NRC, many years ago.
However as I understand at this point, NRC has no reason to believe previous analyses and responses warrant substantial editing.
1.
It was noted the scope of the 2.206 Petition was narrowly limited to demand that NRC extend the Unit 3's closure from the current fuel outage.
The Petition's narrow scope was only because my second letter was dated 6-28-97.
I understand Unit 2 was shut down the following day, 6-29-97, but closure was not publicized, or otherwise known til an article dated 7-2-97 in San.
Diego Union Tribune.
I would argue that if the imminent closure of Unit 2 were known when the 6-28-97 Petition letter was filed, the scope of the Petition would have also demanded NRC extend the closure of Unit 2 as well as Unit 3.
This omission, is due only.
to the-industry's failure to promptly disclose conditions, as a product of the operator's secrecy and effort to suppress important information.
2..Upon what basis has NRC determined the absence of hazardous conditions, enabling your agency to return Units 2 & 3 to service, as early as next week, if not earlier?
MRC should at least place Units 2 & 3 on the Watch List, until this Petition reaches the commission's level.
I think NRC's decision to allow Units 2 & 3 to return to full, or.even partial power shows poor t
judgement, and clear deference to the Licensee.
It looks like i
their profit margin matters more than the public's safety margin again.
3.
In addition-to prior comments about analytical flaws in the current seismic, traffic capacity and evacuation plans, updated analysis is also critical to accurately assess existing and
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projected growth, land uses, traffic capacity and levels of service on a inryer regionni basis than your current piens extend.
4.
A 7-10-97 Channel 10 news broadcast reported traffic volumes have doubled in last five (5) years on both I-5 and I-15.
Development patterns in Temecula, Murrieta and other remote communities beyond your study area have already had a far more dramatic effect than anticipated on the traffic capacity of this region's system.
5.
Licensee's (SCE/ SONGS)' historical use of manipulated data, and adjusted analytical modeling techniques, leading to predisposed " acceptable" outcomes should be rejected by NRC, or at least not automatically accepted.
6.
NRC's absolute reliance on the " defense in depth" philosophies, redundancy safety systems are no more than mere "rhetorac", until proven otherwise.
This rhetoric merely mimics the Licensee's party line about public safety.
KRC should demand more.
7.
Thank you for your messege yesterday (7-10-97) on my voice mail at work regarding.NRC's projected, but uncertain time frame for response.
Under best case scenario, I understand NRC's goal is to reach closure on my 2.206 Petition by 180 days following your formal acknowledgement letter.
Time frames for actual reply relies on cooperation by many other agencies (including but not limited to FEMA).
Time frames will also largely depend on whether technical materials by others is released.
In absence of a release by others, I understand NRC will otherwise be required to summarize extensive materials, either already in your possession, or other new internal material, believed to have been previously withheld by Licensee.
Portions of internal SCE dialogue on many of the same issues were previously transmitted in my two previous letters.
I now also have copies which you should already have of Nuclear Safety Concerns brought up internally to SCE, but largely disregarded over a period of several years.
As discussed during our phone conversation on 7-7-97, ion.
this will be the final submittal associated with my 2.206 Petit Please proceed with formalizing your acknowledgement letter, and conducting the nece,ssary analysis to prepare a Director's decision.
Thank you for your continued courtesy and cooperation in processing my 2.206 Petition.
Sin 9erely, 0
Patricia Borchmann
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