ML20216J410

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Partially Deleted Ltr,Submitting Suppl to 970623 Petition Ltr Re Issues Raised,Concerning Unit 3 Fuel Outage & Public Safety
ML20216J410
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 06/28/1997
From: Borchmann P
AFFILIATION NOT ASSIGNED
To: Bateman W
NRC (Affiliation Not Assigned)
References
2.206, NUDOCS 9709170276
Download: ML20216J410 (3)


Text

,

b^l.NQ Patricio Borchmann 7

176 Walker Way 6

Vista, CA92083 June 28, 1997 William Bateman Project Directorate IV-2 Division of Reactor Projects III/IV

' office of Nuclear Regulatory commission Washington DC 20555-0001 JUtt Petition under 10 CTR 2.106, and Demand that MRC R'rtend current Unit 3 Tuel Outage Until All Outstanding Publio Bafety Concerns are fully Resolved

Dear Mr. Bateman,

Yesterday in our two phone conversations, you confirmed receipt only yesterdey of my 6-23-97 letter, and that your Legal counsel was frantically evaluating it's content to determine if it can be treated as a Petition under 2.206.

In our discussion you indicated that unless some new information was presented, NRC is likely to reject the Petition, since NRC has already spent substantial time c resources in previous analysis and reponses to many concerns about public safety at SONGS.

Since you indicated Unit 3 is currently anticipated to go back online an early as next week, there is, as you know, great urgency to resolve this matter.

As we discussed, I felt the Petition did raise a number of new issues of substance, and we also discussed some additional concerns which were not specifically identified in the Petition.

One concarn we discussed included the need for an updated traffic capacity analysis and evacuation time line study, to evaluate capacity and levels of service on I-5 at vit de la valle" exit.at 4 peak hour during summer when both Del Mar Pair and Del 9(ar Race

/ Track are both operating.

If you were familiar with this area, you would already know that a large section of I-5, for several miles from this exit already operate.at gridlock during such conditions. It takes hours, with speeds less than 10 mph to pass through an approximate 1-2 mile section of I-5 in this area.

If that's normal, under non-emergency conditions, just imagine if an emergency event SONGS occurred, necessitating an immediate evacuation?

I do not believe it is feasible even in a 10 mile evacuation zone, and an evacuation zone limited to only 10 miles is sorely inadequate..

Although you noted NRC responses to concerns are felt to have been thorough, and based on soun a thodology, I noted NRC's responses reflect a tendency to fragment issues, and thereby by dsolating responses to issues, NRC f ails to interactively or comprehensively address the big. picture in l

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t; tale Th3 pettcra of fregne:t tica la problenmatia, Cnd thio io brought up cacific311y to challcnga WRC'o rolo in finding reasons to dismiss the 2.206 Petition, and in working harder to '

fustify it's disnissal, than your marwfated role to protect public Malth a safety.,

You suggested I submit an immediate supplement to my 6-23-97 Petition letter to support my position.

I welcome this opportunity to do so.

1.

How can NRC continue to accept an evacuation zone limited-to only 10 alles, when you already know genetic mutations caused by DNA damage were found 120 miles from Chernoby1?

If an evacuation zone of 120 miles from SONGS were applied, you would be evacuating populations north of Los Angeles, to south of the US border, to th.7 Mojave & Anza Borrego deserts to the east.

What about people who live in Orange County who commute to work in San Diego County, or vice versa?

Would that be feasible?

Don't think so.

2.

Technological arrogance is what got us in this mess in the first place.

When Units 1, 2 & 3 were constructed, it was known then there was no safe disposal systen for spent fuel, but it was presumptiously assumed that technology would develop a safe solution in time, which was perhaps the most fatally flawed assumption of all.

This disposal problem does not warrant, however, a careless and underanalyzed disposal system at either Ward Valley or Yucca Mountain in Arizona.

Mater table levels at Yucca Mountain were recently found to have crisen dramatically according to a recent newspaper article.

There is more reason to shut down SONGS Units 2 & 3 and fully decommission Unit 1, than to proceed with any underanalyzed disposal plans which have the potential to irreversibly contaminats public drinking water supplies with radioactive waste for this, and many future generations.

3.

Licensee SONGS and SCE care more about their profit margin and bottom line than the very real risks to public safety caused by their plant.

This became very apparent at the recent Coastal Commission hearings on SCE's propsal to amend permit to reduce mitigation requirements, offsetting damages to marine resources caused by SONGS.

I was theral I attended the Coastal Commission hearings.

I observed all the consultants, attorneys, and SCE staff members, and can only imagine how much money they spent on an effort which was appropriately rejected by Coastal commission.

The money would have kan better spent performing actual mitigation.

4.

If there is no problem at SONGS, why did SCE recently find it necessary to dramatically increase their liability insurance to cover a nuclear disaster event?

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D n to tho immediccy cnd licited dur0ticn fcr thic cmall t: indow cf cpportunity to cupplccont ty 6-23-97 Petiticn, I d3 n3t h Vo time to add anything further at this point.

Please forward this new material to your Legal counsel, to entble then to make an informed decision in their determination on whether my 2.206 Petition is valid.

Since the post office closes at noon on Saturdays, unfortunately, I find myself out of time.

Thank 1rou.for discussing my concerns with me yesterday, and accept:.ng my phone calls.

You noted you appreciated my having confirmed my interest in this case is as an aftseted citizen of Vista.

However, as an employee of a public agency, I explained my concern & reservations do also extend to the workplace, since the Mutual Aid Agreements under the SENS (Standardized Emergency Management systen) would require me to perform at an Emergency operatAons Center, and I would violate terms of those agreements if I chose to evacuate, myself.

It is not fair for SONGS to continue operating with their huge profit under current ratepayer structure, while dismissing valid concerns about public safety, and reliance on a flawed evacuation plan which exposes me and countless others to an ugly way to die, especially when I know all your safety plans, redundancy safety features are so flawed.

It shows nothing but callous disregard for human life, and I have nothing but contempt for the Licensee, or NRC, unless you reject their party line about safety.

I urge you to do the right thing.

Sincerely, JWW_

Patricia Borchmann O

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