NRC-2012-0192, Comment (1) of Ray Lutz, on Behalf of Citizens Oversight Projects (Cops), on NRC-2012-0192-0001, Southern California Edison, San Onofre Nuclear Generating Station, Units 2 & 3, Application and Amendment to Facility Operating License In

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Comment (1) of Ray Lutz, on Behalf of Citizens Oversight Projects (Cops), on NRC-2012-0192-0001, Southern California Edison, San Onofre Nuclear Generating Station, Units 2 & 3, Application and Amendment to Facility Operating License Involvi
ML12264A587
Person / Time
Site: San Onofre  
Issue date: 09/17/2012
From: Lutz R
Citizens Organized to Protect Our Parrish
To:
Rulemaking, Directives, and Editing Branch
References
77FR49463 00001, NRC-2012-0192-0001
Download: ML12264A587 (11)
v • d • e


Text

Page 1 of 2 As of: September 19, 2012 Received: September 17, 2012 PUBLIC SUBMISSION Status: Pending Post PUBLI SUBM SSIONTracking No. 8111I ad8e Comments Due: September 17, 2012 Submission Type: Web Docket: NRC-2012-0192 Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Comment On: NRC-2012-0192-0001 Southern California Edison, San Onofre Nuclear Generating Station, Units 2 and 3; Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Document: NRC-2012-0192-DRAFT-0001

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Comment on FR Doc # 2012-20114 X1/X

-/

4i3 Submitter Information TE Name: Ray Lutz Address:

T-1L-771 Jamacha Rd# 148 El Cajon, CA, 92020 C)

Submitter's Representative: Ray Lutz Organization: Citizens Oversight Projects (COPS)

-0 Government Agency: Public General Comment The primary change to the license is to move surveillance frequencies from the license document to a document under the control of the operator. This change would only be entertained if it were a desire to decrease the frequency of surveillance to save money. COPS objects to these changes for the following reasons.

We see two categories of surveillances:

(1) Critical operational parameters to allow the reactor to continue to operate safely and detect a failure, and (2) Tests of backup and safety equipment not necessary for the normal operation of the plant but standing ready in case of emergency.

It is our observation that Category (1) surveillance frequencies are far too low (infrequent) to allow operators to detect a developing failure at the plant.

EX: checking leakage from the steam generators every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is ridiculously infrequent. A leak can progress quickly within only a matter of hours during a SGTR, and if the operator waits for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to detect that failure, the plant will certainly be experiencing a LOCA.

httpsý/www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=09000064.

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Page 2 of 2 COPS says:

--> Classify all surveillances according to whether they are in class 1 or 2.

--> Increase substantially the surveillance frequencies in Class 1 to reflect the need to detect rapid deterioration in a SGTR, for example. These should NOT be moved to the Surveillance Frequency program.

--> CLASS 2 surveillances must Include minimum frequencies (or maximal time intervals between inspections) in the license document to insure that the licensee adheres to a reasonable limits for inspections of parameters in CLASS 2.

https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=09000064...

09/19/2012

Page 1 of 1 As of: September 19, 2012 Received: September 17, 2012 PUBLIC SUBMISSIONreng_rost PUBLC S

BMISIONTracking No. 8111 lad90 Comments Due: September 17, 2012 Submission Type: Web Docket: NRC-2012-0192 Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Comment On: NRC-2012-0192-0001 Southern California Edison, San Onofre Nuclear Generating Station, Units 2 and 3; Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Document: NRC-2012-0192-DRAFT-0002 Comment on FR Doc # 2012-20114 Submitter Information IE!

71C Name: Ray Lutz Q

Address:

-F-I 771 Jamacha Rd #148 El Cajon, CA, 92020

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Submitter's Representative: Ray Lutz FI--

Organization: Citizens Oversight Projects (COPS) c,-

Government Agency: Public General Comment Vol 7 (Chapter 3.4 Reactor Coolant System (RCS)) - ML11251A100 ON Page 99, the proposed change is to reduce SG level from 25% to 20%. this significantly reduces the level for reactor trip. Proposal under consideration is to change 25% to 20% in two places here.

This is the reverse of most changes that go from 25% to 50%, and may be a mistake. Perhaps 20%

should be 50%.

The text is:

Each OPERABLE loop consists of two RCPs providing forced flow for heat transport to an SG that is OPERABLE. SG, and hence RCS loop, OPERABILITY with regard to SG water level is ensured by the Reactor Protection System (RPS) in MODES I and 2. A reactor trip places the plant in MODE 3 if any SG level is ≤ [25]% as sensed by the RPS. The minimum water level to declare the SG OPERABLE is [25]%.

--- > This proposed change is a reduction of the level of water in the steam generator to allow the reactor to run. COPS objects to this loosening of licensee requirement and puts the plant in severe danger.

https://www. fdms.gov/fdms-web-agency/component/contentstreamer?objectld=09000064...

09/19/2012

Page 1 of 1 As of: September 19, 2012 Received: September 17, 2012 PUBLIC SUBMISSION j Status: PendingPost PUBLC S BMISIONTracking No. 8111 ad92 Comments Due: September 17, 2012 Submission Type: Web Docket: NRC-2012-0192 Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Comment On: NRC-2012-0192-0001 Southern California Edison, San Onofre Nuclear Generating Station, Units 2 and 3; Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Document: NRC-2012-0192-DRAFT-0003 Comment on FR Doc # 2012-20114 Submitter Information Name: Ray Lutz FT 1/--

Address:

r 771 Jamacha Rd. #148 El Cajon, CA, 92020 Submitter's Representative: Ray Lutz Organization: Citizens Oversight Projects (COPS)

Government Agency: Public General Comment COPS is concerned that that the surveillance frequency is too infrequent for checking the status of critical operational measurements to account for the rapid response needed in a real failure event.

---> We assert that this spec (operator much check leakage rate every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) is far too lax because the leakage can progress from a small leak to a major SGTR in only an hour or two. The SONGS steam generator leak started at a 75 gpd rate and within one hour had increased to 104 gpd. Waiting 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> would allow this to progress to a full SGTR and perhaps LOCA.

--- > Waiting for this leak to progress to 150 gal/day rate is far too lax to detect a dangerous operating condition in the plant.

https://www.fdms.gov/fdms-web-agency/componentlcontentstreamer?objectId=09000064...

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Page 1 of 2 As of: September 19, 2012 Received: September 17, 2012 PUBLIC SUBMISSIONeng_ost PUBLC S BMISIONTracking No. 8111 ad94 Comments Due: September 17, 201 Submission Type: Web Docket: NRC-2012-0192 Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Comment On: NRC-2012-0192-0001 Southern California Edison, San Onofre Nuclear Generating Station, Units 2 and 3; Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Document: NRC-2012-0192-DRAFT-0004 Comment on FR Doc # 2012-20114 2

Submitter Information Name: Ray Lutz Address:

771 Jamaca Rd #148 El Cajon, CA, 92020 Submitter's Representative: Ray Lutz Organization: Citizens Oversight Projects (COPS)

Government Agency: Public

IJ 1-77 r77

-C/

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CA) 1ým General Comment The operational license has a severe internal inconsistency. On one hand, it says there can be no pressure boundary leakage at all, due to material degradation.

From Technical Specification:

No pressure boundary LEAKAGE is allowed, being indicative of material deterioration.

LEAKAGE of this type is unacceptable as the leak itself could cause further deterioration, resulting in higher LEAKAGE. Violation of this LCO could result in continued degradation of the RCPB. LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE.

Definition from 10CFR 50.2 (definitions)

  • Reactor coolant pressure boundary* means all those pressure-containing components of boiling and pressurized water-cooled nuclear power reactors, such as pressure vessels, piping, pumps, and valves, which are:

(1) Part of the reactor coolant system...

https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=09000064...

09/19/2012

Page 2 of 2 But then, it allows significant leakage to occur, up to 150 gallons per day through any one SG, and they have to check for this.

--- > The definition of pressure boundary or the technical specification regarding leakage must be revised to achieve internal consistency. Now, the document is inconsistent because it first says no leakage is allowed, and then it allows leakage of up to 150 gal/day which is then released into the environment.

https://www. fdms.gov/fdms-web-agency/component/contentstreamer?obj ectld=09000064... 09/19/2012

Page 1 of 2 As of: September 19, 2012 Received: September 17, 2012 PUBLIC SUBMISSION I~Status: PendingPost PUBLC S BMISIONTracking No. 8111 add6 Comments Due: September 17, 2012 Submission Type: Web Docket: NRC-2012-0192 Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Comment On: NRC-2012-0192-0001 Southern California Edison, San Onofre Nuclear Generating Station, Units 2 and 3; Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Document: NRC-2012-0192-DRAFT-0005 Comment on FR Doc # 2012-20114 Submitter Information Name: Ray Lutz Address:

771 Jamacha Rd #148 El Cajon, CA, 92020 L

  • Submitter's Representative: Ray Lutz

=C Organization: Citizens Oversight Projects (COPS)

Government Agency: Public C/:)

General Comment

  • Attachment I Vol 10 (Chapter 3.7 Plant Systems) - ML11251A103, Page 99 - ADV -

Atmospheric Dump Valve - The ISTS LCO 3.7.4 is being changed from "Two ADV lines shall be OPERABLE" to "One ADV line per required steam generator shall be OPERABLE." The ISTS is written such that there are two ADV lines per SG. SONGS has just one ADV line per SG and in MODE 4 SONGS could have one SG being utilized for heat removal. If the LCO required two ADV lines to be OPERABLE, SONGS would be in an ACTION unnecessarily. Therefore, the LCO was changed to require one ADV line per required steam generator. Also, due to SONGS just having one ADV line per steam generator, the Completion Time for ACTION A was changed from 7 days to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. These changes are also consistent with the SONGS Units 2 and 3 CTS.

--- > We object to this design deficiency in the SONGS plant. This points out a design deficiency of SONGS compared with other plants.

Page 101: This part was deleted: "Two ADV lines per steam generator are required to meet single failure assumptions following an event rendering one steam generator unavailable for Reactor Coolant System (RCS) heat removal."

Page 102: "The design must accommodate the single failure of one ADV to open on demand; https://www. fdms.gov/fdms-web-agency/component/contentstreamer?obj ectld=09000064... 09/19/2012

Page 2 of 2 (following deleted:) thus, each steam generator must have at least two ADVs. (end delete)

--- > Since the design must accommodate the single failure of one ADV, how is this accomplished if there is only one ADV per SG??

---> We object to this change to the license which incorrectly allows a single ADV. The requirement for two ADVs should be maintained and SONGS should continue to be in violation of that constraint.

https://www.fdms.gov/fdms-web-agency/component/contentstreamer?obj ectld=09000064... 09/19/2012

Page 1 of 2 As of: September 19, 2012 Received: September 17, 2012 PUBLIC SUBMISSION Status: Pending Post Tracking No. 811 ladd8 Comments Due: September 17, 2012 Submission Type: Web Docket: NRC-2012-0192 Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Comment On: NRC-2012-0192-0001 Southern California Edison, San Onofre Nuclear Generating Station, Units 2 and 3; Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Document: NRC-2012-0192-DRAFT-0006 Comment on FR Doc # 2012-20114 Submitter Information Name: Ray Lutz FF-Address:

771 Jamacha Rd #148

-F-1 El Cajon, CA, 92020

<C" Submitter's Representative: Ray Lutz

-f.

Organization: Citizens Oversight Projects (COPS)

Government Agency: Public: See CitizensOversight.org General Comment INADEQUATE EXCLUSION AREA CONTROL 10 CFR 50.02 (excerpt)

_Exclusion area_ means that area surrounding the reactor, in which the reactor licensee has the authority to determine all activities including exclusion or removal of personnel and property from the area. This area may be traversed by a highway, railroad, or waterway, provided these are not so close to the facility as to interfere with normal operations of the facility and provided appropriate and effective arrangements are made to control traffic on the highway, railroad, or waterway, in case of emergency, to protect the public health and safety. Residence within the exclusion area shall normally be prohibited. In any event, residents shall be subject to ready removal in case of necessity. Activities unrelated to operation of the reactor may be permitted in an exclusion area under appropriate limitations, provided that no significant hazards to the public health and safety will result.

--- > The exclusion zone at San Onofre Nuclear Generating Station includes a freeway and an accessible beach. There are no signs warning people that ingress to the area may subject them to https://www.fdms.gov/fdms-web-agency/component/contentstreamer?obj ectld=09000064... 09/19/20i2

Page 2 of 2 higher than specified radiation in the event of a rapid emergency situation.

---> Contrary to the definition of an exclusion zone, there is no means to stop traffic on the freeway in the event of a SGTR or LOCA, events that can progress within minutes and may require the complete shutdown of the freeway. Licensee should be required to install gates and tum-arounds to allow that traffic be completely stopped on the freeway and rerouted to other roads.

Attachments SanOnofreExclusionZone https://www. fdms.gov/fdms-web-agency/component/contentstreamer?objectld=09000064...

09/19/2012

According to the San Onofre license, there is an exclusion area defined which encompasses a large section of the freeway, the frontage road, and the beach area which is easily accessible to the public. No signs exist informing the public that this is an exclusion area and concern for radiation to the public occurs at the boundary of this area.

The license also says that there must be a way to control traffic on the roads next to the plant but there is no control to this area of the freeway that I have seen. I would think they would have to install lights and gates at the previous overpass so cars can be easily stopped and turned away.

The following is the definition of the "Exclusion area" from 10 CFR 50.2:

Exclusion area means that area surrounding the reactor, in which the reactor licensee has the authority to determine all activities including exclusion or removal of personnel and property from the area. This area may be traversed by a hlth~

r~ilrn~cI or w.*terwav, orovided these are San Onofre Nuclear Generating Station Exclusion Zone hi h[*

milmnV pr vie these...

not so lose to the facility as to interfere with normal onperations of the facility and orovided appropriate and effective arrangements are made to control t,~ffr.,,n tho hinhwnv rqilroid, or waterwav, in case of emeraencyv to orotect the public health and sIaty. Residence within the exclusion area shall normally be prohibited. In any event, residents shall be subject to ready removal in case of necessity.

Activities unrelated to operation of the reactor may be permitted in an exclusion area under appropriate limitations, provided that no significant hazards to the public health and safety will result.

Citizens' Oversight Projects (COPS)

Sept. 17, 2012 V1 (Ray Lutz)

The diagram above is excerpted from the San Onofre operating license, and the map above it is the approximate outline when showns on a satellite map.

See CitizensOversight.org for more information.

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