ML20217D571
| ML20217D571 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/23/1997 |
| From: | Borchmann P AFFILIATION NOT ASSIGNED |
| To: | Fields M NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20217D560 | List: |
| References | |
| 2.206, NUDOCS 9710060006 | |
| Download: ML20217D571 (5) | |
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b Patricia Borchmann 176 Walker Way Vista, CA 92083 June 23, 1997 Mel Fields Project Manager
.US Nuclear. Regulatory-Commission Documents Control Desk l
Washington DC 20555 DEMAND THAT NRC EXTEND THE CURRENT UNIT i SONGS' OUTAGE UNTIL ALL OUTSTANDING PUBLIC SAFETY CONCERNS ARE FULLY RESOLVED A.
Seriour f. laws in the BONGS Raergency Evacuation Plans for l
both san raego and orange county exist.
Based on only a superficial analysis, a few critical flaws were previously identified in my 5-21-97 letter, which'wes previously transitted l
to your a ttention, by John H. Robertus, Executive Officer of l
Regional 'fater Quality Control Board (by letter dated 6-9-97).
To assist you in your response, some additional information is submitted about deficiencies which were previously identified, including:
1.
Evacuation and Traffic Capacity Analysis underestimated the actual number of vehicles projected to be used during nn emergency event, resulting in an overestimated traffic systen capacity assumption.
Although the Emergency Plank for both
-counties were adopted by NRC, based on their acceptance by FEMA, Plans are fundamentally flawed.
The evacuation time line studies by SONGS are also flawed.
Ant. lysis of all studies were based on the flawed assumption that only one vehicle per household would be used during an evacuaticn following an emergency event at SONGS.
This is not a realistic assumption.
Many more= vehicles would be used during a real emergency event evacuation.
With so many parents working _ jobs at separate locations, with children attending various schools or attending after school daycare or 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 consolidate family members in one carpool.
2.
Even under event worst case scenario assumptions such as flooding, the current analysis assumes there would be no lane closures.
Not true, as found during the 1994 flooding and mud closures in Laguna Beach, following-fires in 1993.
3.
Obvious deficiency of.a lO-mile Evacuation Zone, or Low Population Zone (LPZ),'especially following TMI and Chernobyl.
9710060006 970922 PDR ADOCK 05000361 G
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Based on recent receipt of new information, a series of other B..
l swicus technical deficiencies are identified below:
i 1.
Undersised Pressuriser l
ABB-CEE subsequently increased pressurizer size in plants following SONGS in order to obtain an acceptable FSAR Accident i
. Analysis outcome.
The absence of the same standard at SONGS
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l implies a deficiency.
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SONGS Mismanagement in Loss of Coolant Accident Dese Calculations Doses of remedy treatment substances to populations exposed to l
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 i
because the actual figures of the extent of exposed population l
are disputed, no one even really knows how many people might be
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affected in the first place, and of those, how many might be allergic to remedy treatment substances, and if so, how those l
affected might be treated.
Also equally absurd, is the NRC's reply from William H. Bateman in a 12-20-96 letter to Glen Mills about NRC's failure to discipline SONGS following a 5 year period when SONGS' leak i
detections system at spent fuel pools went unmonitored, during a
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period when pools were determined to have leaked.
In the 12-20-96 reply letter from NRC Director William H.
l Bateman, an excerpt includes facts which supposedly "....
obviated the need for further NRC expenditure of NRC funds to independently reperform associated dose calculations."
NRC subsequently admitted that its investigation resulted ir. a 3
calculated post LOCA :PZ thyroid inhalation dose that was 51.9%
l higher than reported in the USAR (Updated Safety Analysis Report) l prepared by Licensee (SONGS).
5.Durationofstorage
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l Contrary to it's current use, the spent fuel pools at SONGS Unit I were never designed for permanent storage of spent fuel pools i
onsite.
Both the pool and fuel assemblies were intended for temporary onsite storage with fuel. assemblies moved offsite, after cooldown, but before the assemblies and pool would'begin to
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show signs of degradation.
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Volume SONGS Units ~2 & 3 may be a larger problem than Unit 1; ben uselof p
use of high density racks to store more spent fuel assemblies in the same volume of space.
Use of the high density racks increases the probability of accidental criticality as the metal i
experiences degradation _and breaks up in a seismic event.
l The amount of spent fuel onsite, and amounts to be accumulated in f
.the future is far greater than anticipated during design and constrution at SONGS.
SONGS now proposes longer times (greater 5:
burn up) between refuelings, meaning greater fission product l
accumulations in spent fuel assemblies discharged from the 4
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t reactor.
If SONGS has a times.between refuelinga,pending request to NRC to allow longer I suggest the agency reject the request
-outright, or proceed cautiously, with objective analysis independent of Licensee SONGS.
5.
Condition of Plastic Membrane Under Spent Puel Pool A 40-mil thick waterproof membrane was installed under the Spent Fuel Pool (SFP) bottom slab and on pool walls-below grade.
The sembrane's condition is not known.
The membrane had seams which had to be welded together.
SCE assumes the membrane still adequately performs itr original function of containing leaks from the pool.
Epoxy repairs to the pool performed in the past would fail during a r,sismic event due to the brittle nature of epoxy as it ages.
6.
Failure to Monitor Leak Letection Bysten Recent earthquakes (Landers and Horthridge) 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 seismic activity, discovered later, but never reevaluated, or ever-determined what extent of seismic retrofit would be required for Units 2 & 3.
Unit I was shut down due to the economic analysis which showed costs for seismic retrofit exceeded's point of diminishing returns.
SONGS' seismic design assumptions and criteria are also correspondingly flawed 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 fEiled 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 l
dotection system, and does not include requirements for j
monitoring SFP leaks.
The NRC still hasn't gotten around to writing the regulatory requirements and procedures for the FSAR material.
7.
Conditioned nasponser Nasked by Rffacts from Camp Pendleton:
As a citizen of nerth 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 reduces 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 ariving in radioactive areas, as drivers listen to their preferred-tapes or personal CD's.
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Industry's total reliance on implementation of an unrealistic j
ssNs-(systemmatic Emergency Management) model during an emergency event at SONGS, which will not function as designed.
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As pointed out in his March 30, 1997 letter Ilast exhibit of enclosed material);
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"The success of dealing with a major accident is dependent 1
on the full cooperation of all individuals designated with responsibility.
It is possible to imagine a nuclear accident emergency at SONGS so severe that some individuals may choose to l
walk away from the site and abandon their responsibilities.
i During the THI reactor emergency in late 1970's we heard of at i
least one individual who in fact ran away from the scene and i
failed to perform his emergency duties.
What assurance is there that in the most-threatening nuclear accident, individuals will chooce to remain on duty and not run away?
Unlike a military organization SONGS employs civilian personnel who cannot be forced to perform their dutias, especially under nuclear accident conditions which might affect their health and safety.
We have i
heard stories of Russians using capital punishment on those who i
would not risk their health and safety at chernobyl.
A free l
society such as oura cannot use such tactics.
The more severe j_
the accident, the greater the need for personnel, but the less likely they will htay around and help."
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l For all the above reasons, I demand that N2C extend the current i
Unit 3 fuel outage until all concerns and issues raised here, and i
those within the scope and depth of enclosed material, and all i
other material submitted by Glen R. Mills have been fully resolved.
l Please confirm if this letter can be treated as a formal i
Petition, pursuant to 10 CFR Ch.1, Section 2.206, and if not, why j
not?
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I would say it is about time NRC got around to doing your duty.
Remember, your duty is to work in the public's interest, not the nuclear industry's interest.
NRC's past responses have been disingeuous, unresponsive, and j
patronizing, it best.
Meetings with Glen Mi!)s to resolve his concerns about issues in his material over several years have j
been reported where NRC staff engaged in intimidating tactics, j
This pattern was recently identified in a GAO audit, prepared for j
a Congressional subcommittee, which affirmed NRC's performance reflects 6 culture which tolerates and accepts conditions which jeopardize public health and safety.
Since this subject is so timely, I'm sending a copy to my Congressman, and circulated to 1
other members, the President, and Vice President, who will also i
await your reply.
Since I-cannot afford duplication costs of all j
the anclosed technical material-from Glen Mille, copy recipients i
will receive copy of this letter only, with request that you i
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i (NRC) duplicate all enclosed material from Glen Mills-to be distributed under separate cover.
A proof for authenticity and i
completeness prior to duplication'is roguested.
i Thank you for your prompt, responsive reply.
Another " blow it off" response will not be accepted.
"We the Peoplea deserve that i
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. ;* found unsafe, close it; with costs absorbed by shareholders, not ratepayers or local residents forced to put l
up with living at risk, without a net, under a knowingly deficient plant & spent fuel pool design.
This has caused substantial wental distress for not only myself and my partner, l
but also Glen Mills & his many professional colleapes, about the l
countless others, who although they may not be similarly-distressed, they do not even knew of the conditions they are j
exposed to, by if.ving near SONGS.
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Patricia Borchmann copy:
President Bill Clinton Vice President Al Gore
,l Congressman l
Congressman J. Biden, Chairperson - GAO Report on NRC State Attorney General Dan Lundgren 1
Executive Director of Operations i
U.S. Nuclear Regulatory Commission Washington DC 20555 0001 l
w/ Request for Licensing Actions 20 CTR 2.206 BONGS S
William Bateman Project Directorate IV-2 i
Division of Reaction Projects III/IV office of Nuclear Reactor Regulation j
Washington DC 20555-0001 Susan Hansch/Melanie Haler California coastal l
Commission i
o Paul Richter, Regional Water Quality Control Board i
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v Patricia horchmann 176 Walker Way 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 RRt Petition under 20 CFR 2.206, and De. sand that Enc Rrtend current Unit 3 Fuel Outage until All Dutstanding Public Batety concerns are fully Resolved
Dear Mr. Bateman,
Yesterday in our two phone conversations, you confirmed receipt only yesterday 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 and NRC resources in previous analysis and l
reponses to Glen R. Nills' many concerns abcut public safety at SONGS.
Since you indicated Unit 3 is currently anticipated to go back online as 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 concern we discussed included the need for an aapdated traffic capacity analysis and evacuation time.line study, to evaluate
-capacity and levels of service on I-5 at via de la valle exit.at peak hour during summer when both Del Mar Fair and Del. Mar Race drack 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 through an approximate 1-2 mile section of I-5 in this area. pass If that's normal, under non-emergency conditions, just imagine if an emergency event SONGS occurred, necessitating an immediute evacuation?
I do not believe it is feasible even in a 10 mile evacuation zone, and an evacuation zore limitec1 to only 10 miles is sorely inadequate.,
Although you noted NRC responseu to Glen R. Mills' concerns are felt to have been thorough, and based on sound methodcilogy, I noted NRC's responses reflect a tendency to fragment issues, and thereby by 4solating responses to issues, NRC fails to interactively or comprehensively pddress the tig picture in 1
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e' total.
The pattern of fragmentation is problemmatic, and this is brought up specifically to challenge NRC's role in finding reasons to dismiss the 2.206 Petition, and in working harder to stify it's dismissa2, than your mandated role to protect pub 21c th 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 sono limited to only 10 miles, 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 the Mojave & Anza Borrego deserts to the east.
What l
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 constructad, it was known then there was no safe disposal system 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.
Water table levels at Yucca Mountain were recently found to have risen 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 contaminate public drinking water supplies with radioactive waste for this, and anny 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 the!r plant.
This became very apparent at the recent coastal commission hearings on BCE's proposal to amend permit to reduce altigation requirements, offsetting damages to marine resources caused by SONGS.
I was there; I attended the Coastal commission hearings.
I observed all the consultants, attorneys, and SCE V
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 been better spent performing actual sitigation.
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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t Due to the immediacy and limited duration for this small window of opportur.ity to supplement my 6-23-97 Petition, I do not have l
time to add anything further at this point.
Please forward this new-material to your Legal Counsel, to enable them to make an i
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 you.for discussing my concerns with me yesterday, and accepting my phone calls.
You noted you appreciated my having confirmed my interest in this case is as an affected citizen of Vista.
However, as an employee of a public agency, I explained i
ny concern & reservations do also extend to the workplace, sirce the Mutual Aid Agreements under the SEMS (Standardized Emergency i
Management System) would require me to perform at an Emergency Operations 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 cut 7nt ratepayer j
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 j
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.
j Sincerely, l
lWh-Patricia Borchmann 1
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s Patricia Borchmann 176 Walker Way Vista, CA 92083 July 11, 1997 Hel Fields Project Manager US Nuclear Regulatory Commission Documents Control Desk Washington DC 20555 RE:
2.2026 Petition - Final Supplement
Dear Mr. Ficids,
Thank you for contacting me 7-8-97 at 8:30 am 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 clocure 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?
NRC 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 judgement, and clear deference to the Licensee.
It looks like their profit margin matters more than the public's safety margin again.
3.
In addition to prior comments about analytical' flaws in the r.urrent 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 larger regional basis than your current plans artead.
- 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.
L 6.
NRC's absolute reliance on the " defense in depth" philosophies, redundancy safety systems are no more than mere
" rhetoric", until proven otherwise.
This rhetoric merely mimics the Licensee's party line about public safety.
NRC should demand aore.
7.
Thank you for your message 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 ROquired 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, this will be the final submittal associated with my 2.206 Petition.
Please proceed with formalizing your acknowledgement letter, and conducting the necessary analysis to prepara a Director's decision.
Thank you for your continued courtesy and cooperation in processing'ay 2.206 Petition.
Sin 9erely, 0
PathiciaBorchmann _
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