ML20248J595

Informs of Disagreement W/Many Conclusions in Ltr from Mm Mendonca to Jh Robertus.Believes That Refs 1 & 2 Show Lack of Attention to Detail & Lack of Questioning Attitude Required to Protect Public Health & Safety

ML20248J595
Person / Time
Site:	San Onofre
Issue date:	08/29/1997
From:	Mills G AFFILIATION NOT ASSIGNED
To:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM)
Shared Package
ML20198R944	List: ML20198R939 ML20248J595
References
2.206, NUDOCS 9711130404
Download: ML20248J595 (6)

Text

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Mail: P,0, Box 3393, Mission Viejo, CA 92690 Phone #: 714 768-0585 FAX: 714-458-6455 E Mail: tuillsglen@msn.com August 29,1997 The lionorable Shirley Jackson Chairperson _ .

U.S Nuclear Regulatory Commission Washington, D.C. 20555-0001 Reference 1: Letter dated July 31,1997, from Marvin M. Mendonca, U.S. Nuclear Regulatory Commission to John 11. Robertus, San Diego Regional Water Quality Control Board.

Reference 2: Letter dated February 28,1995, from Richard M. Rosenblum, Southern California Edison Company to Glen R. Mills (copy enclosed).

Dear Chairperson Jackson:

We have reviewed Reference 1 and disagree with many of the conclusions. The purpose of this letter is to state a opposing view on some of the issues. More comments may follow later as our investigation continues and more information on Ms. Patricia Borchmann's 2.2% petition is obtained.

Enclosure 1 of Reference 1 plays down the threat to public health and safety of tritium 1 release from San Onofre Nuclear Generating Station (SONGS) owned and operated by Southem California Edison (SCE). When tritium unites with carbon in the human body, plants and animals, it becomes organically bound and can remain in the human body much longer than expected. Also as tritium makes it way up the food chain it will 1

become more concentrated. We believe that human beings can receive chronic exposure to organically bound tritium through the ingestion of plant and animals exposed in the efiluent pathway in addition to direct uptake through inhalation, absorption and drinking fluids (tritiated water). Tritium is carcinogenic, mutagenic and teratogenic. When tritium deposits its radioactivity in the human body, it creates at least one lesion in the cell which must be repaired within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to prevent permanent damage. If not repaired within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, when tbe cell disides it will be carcinogenic. Some researchers believe that there is a threshold below which the cell mechanism for repair is not activated in the body, Consequently low levels of chronic radiation exposure (as is expected from SONGS) can accumulate in the human body without the cell repair system being activated. Tritium results in the formation of a helium ion when it releases its radioactivity into the cell.

9711' 0404 971024 PDR OCF 05000206 H PDR

, 7 Consequently the compound to which the tritium was bound acquires a positive charge, becomes chemically active, and can attach itself to a ring of a protein precursor that makes up the chromosomal strands in DNA. The final result is DNA damage and mutations, in Enclosure 3 of Reference I the Nuclear Regulatory Commission (NRC) fails to reveal some important information: SONGS failed to monitor the spent fuel pool leak detection W system from the early 1980's through mid 1980's and as a result the system overflowed I and spilled into the area outside the spent fuel pool. The NRC took no enforcement

, g p4p r action against San Onofre as a result of this failure. No one knows for certain the extent of an underground plume moving toward the beach as a result of the failure for years to monitoi the leak detection system. '3ince SONGS was allowed to extend its property line onto a public beach (to the mean high water line) for all practical purposes SONGS can discharge onto the beach and into the ocean and still claim the area of contamination was within the SONGS's property line. As happened on at least one occasion, SONGS can contaminate a public beach and not be held accountable. It can be easily conceived that during strong storm activity when the water action extends beyond the mean high water line, SONGS could discharge radioactive waste into the beach and never be cited since the diluting action of the storm would destroy all evidence (below 10 CFR 20 limits). We believe that the current radiological environmental monitoring is not adequate to detect Nomdf such discharges. These comments also apply to the possibility of a underground 3 g ) y g ()

radioactive plume moving toward the beach as a result ofleakage from Unit I spent fuel pool.

SONGS has refused to perform :, oil core drilling in the area to learn the truth. It has

, kYY promised to clean the area up during decommissioning. By that time the full impat >f deregulation will be in effect and the unplanned / unexpected cost of any cleanup ' J be charged to the taxpayers.

Although any radioactive contamination in the wea of the beach maybe relatively low when discovered, no one can be certain of the initial contamination level before decay and dilution. Further, even for low contamination levels, various processes exist in nature and animal / plant metabolism to selectively collect and reconcentrate specific radioactive nuclides. Once reconcentrated again in the human body the nuclides have great potential for doing damage. New research data from scientists studying animals living around -

Chernobyl accident site show the acceleration of gene mutation rates by factors of 100's above that which was expected.

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Note the following statement in the last paragraph of Enclosure 3 of Reference 1: "With recpect to the specific concern that the ' plastic has never been tested for resistance to (AU radioactive decay', the question is moot since neither the licensee nor the NRC credits blM9g the plastic to prevent leakage". However if you read Reference 2 SONGS claims credit

- for controlling leakage into and out of the pool with the rubber membrane. Vice

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President Richard Rosenblum incorrectly tefers to a " rubber membrane". The so called  !

• rubber membrane" is a waterproof membrane 40 mils thick known as Amercoat ,

Corporation NOB LOCK in accordance with specification BSO 2576.  !

l We believe References 1 and 2 show a lack of attention to detail and a lack of a questioning attitude required to protect public health and safety. Therefore we will be ,

reviewing all submittals conceming Ms. Borchmann's 2.206 petition and hope to make  :

more comments at a later date.

Sincerely, A R9Vl b Glen R. Mills

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Southem Califomia Edison Company 23 PAnat n Stet ti miCuano ,a mo s t ,e s t v he ts6ta=0 8 m,.........

February 28,1995 W Mr. Glen R. Mills 27681 Duranzo Mission Viejo, CA 92692

Dear Mr. Mills:

This letter responds to the questions you raised in your letters to John Bryson of September,1994 and January,1995, in your September 26,1994, letter you expressed some concerns about the consequences of placing spent fuel dry storage casks in the reservoir area and expressed your opinion that SONGS should be shutdown because of environmental and safety questions.

The United States Department of Energy (DOE), is responsible for taking charge of the spent fuel from all three reactors at San Onofre starting in 1998 and funding for the disposal is provided by a fee on each KWH of electricity generated. However, it is probable that the DOE will not be able to meet its obligations in this area, and under most operating scenarios, additional storage of some sort will be needed if the units are to operate after about 2004. Consequently, Edison is investigating a wide variety of options to provide additional, interim storage capacity for the SONGS fuel.

Arnong the options being considered is the en-site storage of spent fuelin " dry casks.* Such a system is successfully in use at several facilities in the United States.

Should dry cask storage be selected, severallocations on site are under consideration, including the area currently occupied by the reservoir at Unit 1. Any site selected will comply with Nuclear Regulatory Commission standards. The NRC standards include requirements for shielding the casks, limitations on the dose at the Owner Controlled Area boundary, and an evaluation of the impact on the public health and safety of the option chosen. I cannot be more specific in discussing either the options or the licensing and permitting processes that would accompany each option, since there are several significant variables (such as the ability of the DOE to meets its obligations, the amount of fuel generated, etc.) and we are discussing actions that may not take place for several years. Edison has a strong commitment to plant safety and to the health and safety of those who use the land adjacent to our facility; and would neither propose nor construct any facility that did not meet or exceed applicable requirements.

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r.bnwy a. ms in your letter of January 26,1995, you expressed a concern about leakage from the Unit 1 Spent Fuel Pool to the environment and the possibility that hot fuel padicles may also have been released.

The pressure boundary of the Unit i spent fuel poolis a stainless steelliner. Leakage of this boundary was considered in the design and leakage detection wells are provided to detect and remove leakage. Leakage of water into or out of the concrete structure of the poolis controlled by a rubber rnembrane on the outside of the concrete, which extends up to 12 feet above plant elevation zero Consequently, as .

long as the leakage wells are kept pumped down below 12 feet, leakage of spent fuel pool water through the stainless eteel liner or leakage of ground water through the rubber membrane is detected and collected and no release to the soil beneath the pool will occur.

However, for a period of time from roughly 19821986, periodic pump down of the well is not documented and it is possible that leakage of some pool water to the soll beneath the spent fuel pool may have occurred, but it is highly unlikely that a hot fuel particle leaked through about four feet of concrete and into the soil. The decommissioning plan for San Onofre Unit 1 anticipates that some of the soil beneath plant structures may be found to be contaminated and provides for the disposal of that soil with the rest of the material from the plant.

Edison conducts periodic monitoring of the beach sand and ground water in the vicinity of the plant. No beach send contamination or ground water contamination attributable to plant oparation has been detected; nor have hot fuel partLles been found. Ukewise, periodic surveys of the dose rate adjacent to the Owner Controlled Area along the beach and in other areas are performed and the dose rates found are consistent with the applicable Federal Regulations. Consequently, either on the basis of the design and operation of the Unit 1 Spent Fuel Pool or as confirmed by environmental sampling plan, the public health and safety and the safety of those who use the beach adjacent to the plant has not been impacted by the Unit 1 Spent Fuel Pool.

While Edison is performing a more detailed analysis of the Unit 1 Spent Fuel Pool leakage in the 1982 86 time frame, no significent impac*, beyond the possible need for additional soll remCval at the time of decommissioning, is expected.

In your letters you also recommend shutdown of SONGS because of environmental, safety, and cost issues and because the power is not needed. Edison will continue to operate the units only if it can be done safely and in an environmentally responsible

,vay. SONGS is a needed, important, and an economical contributor to Edison's diverse sources of electric generation for its customers. The recent draft settlement with the Division of Ratepayer Advocacy of the California Public Utility Commission forms a prudent and mutually beneficial basis for the continued operation of the facility.

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I trust this information is responsive to your concerns.

Sincerely, /

$ /6f b A cc: J. E. Bryson H. B. Ray I

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