ML14008A021
| ML14008A021 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/17/2013 |
| From: | Gibson B City of San Luis Obispo, CA, Board of Supervisors |
| To: | Macfarlane A NRC/Chairman |
| Wittick S | |
| Shared Package | |
| ML14008A022 | List: |
| References | |
| G20140036, LTR-14-0012 | |
| Download: ML14008A021 (5) | |
Text
BOARD OF SUPERVISORS 1055 MONTEREY, ROOM D430
- SAN LUIS OBISPO, CALIFORNIA 93408-1003
- 805.781.5450 FRANK R. MECHAM, Supervisor District One BRUCE GIBSON, Supervisor District Two ADAM HILL, Supervisor District Three CAREN RAY, Supervisor District Four DEBBIE ARNOLD, Supervisor District Five December 17, 2013 The Honorable Allison Macfarlane, Chair U.S. Nuclear Regulatory Commission Mail Stop 0-16G4 Washington, DC 20555-0001 chairman@nrc.gov- email RE: Waste Confidence Rule and Diablo Canyon Power Plant
Dear Chairperson Macfarlane:
Attached please find comments from the San Luis Obispo County Board of Supervisors submitted directly to your staff regarding the update of the NRC's Waste Confidence Rule. We are, of course, particularly interested in issues regarding spent nuclear fuel now stored in our county at the Diablo Canyon Power Plant (DCPP). In summary, our comments are these:
The Waste Confidence Rule should require that safety margins for spent fuel storage pools and dry cask storage mitigate risks associated with the widest reasonable range of accidents, natural disasters, and security threats.
The safety margins for natural disasters should explicitly consider earthquake seismic threats to storage facilities.
The GElS does not appear to explicitly consider seismic risks in the analysis assumptions of potential impacts (Sec 1.8.3)
The NRC should require that spent fuel be transferred from wet (pool) storage to dry cask storage on the most accelerated time schedule possible.
The NRC should redouble efforts with other federal agencies and Congress to develop a permanent spent fuel repository.
In the aftermath of the Fukushima disaster, our Board has considered a number of issues regarding DCPP, a facility that has long had major impacts on San Luis Obispo County. DCPP is a major component of our local economy and generates considerable tax revenue supporting both our schools and local government. At the same time, this nuclear power plant is sited in a tectonically active area and subject
to considerable risk from earthquake ground motion. As you know, the earthquake risk to the plant in general is under active study through a process convened by the California Public Utilities Commission.
The storage of spent fuel at DCPP is an ongoing concern for us. In particular, spent fuel pools are potentially vulnerable to natural disasters, human-caused accidents, and sabotage. The spent fuel pools at DCPP have also been reconfigured, and now contain more than twice the number of fuel assemblies that they were originally designed to hold. While we are assured by PG&E that risks of this configuration are completely mitigated, but we believe this issue is worthy of extensive review.
We further understand that the pools at DCPP are now storing spent 11 high burn-up" fuel assemblies -
material possibly not considered in the original design. We would request a thorough examination of the thermal and mechanical consequences of high burn-up fuel being present in spent fuel pools.
DCPP also has a facility for dry cask storage of spent fuel, which is generally agreed to be the preferred means of spent fuel storage. Testimony before our Board has suggested that the loading of dry casks at DCPP is not occurring as fast as it could. Given the extra density of spent fuel in the pools and the risks specific to OCPP, we would request that the NRC require the transfer of fuel from the pools to dry casks to be conducted in the most timely manner possible.
Finally, as you are certainly aware, a nationwide solution for permanent spent fuel storage has been delayed for far too long. The permits for DCPP did not imagine that the indefinite storage of spent fuel onsite- and such storage is an obvious added risk to residents of this county. We would again urge the NRC to accelerate work with other federal agencies and Congress to advance a permanent solution.
Our Board appreciates the opportunity to comment on your Waste Confidence Rule update and trust that your Commission will require all nuclear plant operators to handle spent fuel in a manner most protective of the residents of the communities where these plants are located. Thank you.
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BRucE GIBSON Chair, Board of Supervisors San Luis Obispo County
BOARD OF SUPERVISORS 1055 MONTEREY, ROOM D430
- SAN LUIS OBISPO, CALIFORNIA 93408-1003
- 805.781.5450 FRANK R. MECHAM, Supervisor District One BRUCE GIBSON, Supervisor District Two ADAM HILL, Supervisor District Three CAREN RAY, Supervisor District Four DEBBIE ARNOLD, Supervisor District Five December 17, 2013 Secretary, US Nuclear Regulatory Commission Washington, DC 20555-0001 (301) 415-1101- fax ATTN: Rulemakings and Adjudications Staff RE: Docket ID NRC-2012-0246/Comments on Waste Confidence Rule Update and Generic Environmental Impact Statement (GElS)
For your record:
The San Luis Obispo County Board of Supervisors appreciates the opportunity to comment on the upcoming update of the NRC's Waste Confidence Rule and the associated GElS. Our comments are informed by the location ofthe Diablo Canyon Power Plant in our county. This facility is sited in a tectonically-active region of the Pacific Coast and thus potentially subject to significant ground shaking from large-magnitude earthquakes.
In summary, our comments are these:
The Waste Confidence Rule should require that safety margins for spent fuel storage pools and dry cask storage mitigate risks associated with the widest reasonable range of accidents, natural disasters, and security threats.
The safety margins for natural disasters should explicitly consider earthquake seismic threats to storage facilities.
The GElS does not appear to explicitly consider seismic risks in the analysis assumptions of potentia I impacts (Sec 1.8.3)
The NRC should require that spent fuel be transferred from wet (pool) storage to dry cask storage on the most accelerated time schedule possible.
The NRC should redouble efforts with other federal agencies and Congress to develop a permanent spent fuel repository.
In the aftermath of the Fukushima disaster, our Board has considered a number of issues regarding DCPP, a facility that has long had major impacts on San Luis Obispo County. DCPP is a major component of our local economy and generates considerable tax revenue supporting both our schools and local government. At the same time, this nuClear power plant is sited in a tectonically active area and subject to considerable risk from earthquake ground motion. As you may know, the earthquake risk to the plant in general is under active study through a process convened by the California Public Utilities Commission.
The storage of spent fuel at DCPP is an ongoing concern for us. In particular, spent fuel pools are potentially vulnerable to natural disasters, human-caused accidents, and sabotage. The spent fuel pools at DCPP have also been reconfigured; and now contain more than twice the number of fuel assemblies that they were originally designed to hold. While we are assured by PG&E that risks of this configuration are completely mitigated, but we believe this issue is worthy of extensive review.
We further understand that the pools at DCPP are now storing spent "high burn-up" fuel assemblies -
material possibly not considered in the original design. We would request a thorough examination of the thermal and mechanical consequences of high burn-up fuel being present in spent fuel pools.
DCPP also has a facility for dry cask storage of spent fuel, which is generally agreed to be the preferred means of spent fuel storage. Testimony before our Board has suggested that the loading of dry casks at OCPP is not occurring as fast as it could. Given the extra density of spent fuel in the pools and the risks specific to DCPP, we would request that the NRC require the transfer of fuel from the pools to dry casks to be conducted in the most timely manner possible.
Finally, as you are certainly aware, a nationwide solution for permanent spent fuel storage has been delayed for far too long. The permits for DCPP did not imagine that the indefinite storage of spent fuel onsite- and such storage is an obvious added risk to residents of this county. We would again urge the NRC to accelerate work with other federal agencies and Congress to advance a permanent solution.
Our Board appreciates the opportunity to comment on your Waste Confidence Rule update and trust that your Commission will require all nuclear plant operators to handle spent fuel in a manner most protective of the residents of the communities where these plants are located.
Thank you.
Sincerely, ( l"i
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\0 v"4..A fi Uc~~v-BRUCE GIBSON Chair, Board of Supervisors San Luis Obispo County
jC)OC)-z-Board of Supervisors San Luis Obispo County County Government Center, Room D430.
San Luis Obispo, CA 93408 RETURN SERVICE REQUESTED The Honorable Allison Macfarlane, Chair U.S. Nuclear Regulatory Commission Mail Stop 0-16G4 Washington, DC 20555-0001 I<>~:U*iSt*iP 20555 ,,,,,,,,,,II" 'I*"''''''''' I,,,,,,, II., . ,,,,,,,,,.I I