ML050740393

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SONGS Ltr to H. Pellar - Request to Shut Down SONGS Generating Station
ML050740393
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 03/17/2005
From: Gramm R
NRC/NRR/DLPM/LPD4
To: Pellar H
- No Known Affiliation
Pham B M/NRR/DLPM/PD-2,415-8450
Shared Package
ML050730496 List:
References
+KBR1SISP20050331, G20050149, LTR-05-0108, TAC MC6292, TAC MC6293
Download: ML050740393 (4)


Text

March 17, 2005 Mrs. Harriet Pellar 7224 Spoonbill Lane Carlsbad, CA 92009-5016

SUBJECT:

REQUEST TO SHUT DOWN SAN ONOFRE NUCLEAR GENERATING STATION (SONGS)

Dear Mrs. Pellar:

I am responding on behalf of the U.S. Nuclear Regulatory Commission (NRC) to your letter to Congressman Randy Duke Cunningham dated January 16, 2005, which was forwarded to our agency for response. In your letter, you expressed concerns regarding SONGS with an attached article written by Mr. Russell Hoffman. In his article, Mr. Hoffman had various concerns and complaints regarding the safety and security at SONGS, the nuclear industry in general, and renewable energy. I am writing to respond to your specific concerns regarding nuclear safety and security at SONGS and its impact on health and safety of the public, as they are within the purview of the NRCs regulatory role.

The safety and security of U.S. nuclear power plants like SONGS are ensured through the regulatory licensing and ongoing oversight process, and documented in the guidelines and criteria established in Title 10 of the Code of Federal Regulations (10 CFR).

The NRC grants licenses to applicants only after obtaining assurance that their facilities satisfy the applicable regulations of 10 CFR; we ensure that changes to the licenses are made in accordance with regulations and perform frequent inspections to ensure facilities are operated and maintained in accordance with the regulations. In performing our licensing reviews and inspections, we compare implementing procedures, design documents, and installed equipment against criteria which are based on the regulations. If, in the course of our inspections, we identify a concern with compliance with a regulation, we assess the safety significance and require that the licensee take prompt corrective action to bring the plant back into compliance.

Nuclear power plants like SONGS are required to undergo the NRCs thorough review process prior to licensing where, per regulations, safety analyses are required to be documented and maintained in the Updated Final Safety Analyses Report. As part of the plants licensing basis, these reports address the safety systems and components that Mr. Hoffman brought forth as concerns in his article. Safety issues like potential radiation and effluent release, structural integrity, and material degradation are all specifically addressed in the requirements of 10 CFR.

Releases of radioactive material are required to be monitored, controlled, and maintained below established regulatory limits. Licensees are required to implement monitoring programs to perform examinations of piping pressure boundary material and to detect potential failures.

These are all areas that the NRC evaluates per the NRCs Standard Review Plan for licenses.

Mrs. Pellar Once licensed, licensees like Southern California Edison are required to operate their plants in compliance with NRC-approved Technical Specifications (TSs), which form the basis and standard of our inspection programs. Any alteration plans by the licensee like the potential future replacement of steam generators for both units, if they impact compliance to the TSs, are required to be submitted for NRC review and approval, and are publicly available for comments via the Federal Register.

In addition to nuclear safety, the NRC also establishes high standards for effective security programs at nuclear power plants, as required by and described in 10 CFR Part 73. Since the agencys inception, we have required enhanced protection of licensed facilities against sabotage or attack. Security has been an important part of the NRC's regulatory activities, with defense-in-depth as the guiding design and operating principle. NRC regulations ensure that nuclear power plants are among the most hardened and secure industrial facilities in our nation.

The many layers of protection offered by robust plant design features, sophisticated surveillance equipment, physical security protective features, professional security forces, and access authorization requirements provide an effective deterrence against potential safety or security problems related to terrorist activities that could target equipment vital to nuclear safety. Since the terrorist attacks of September 2001, the NRC has sought to ensure the continued protection of the nations nuclear power plants, working in close coordination with the Federal Bureau of Investigation, the Department of Homeland Security, the Federal Aviation Administration, the Department of Defense, State and local authorities, and other intelligence and law enforcement agencies, as well as NRC licensees. NRC coordination with these agencies remains ongoing. Although there have been no credible threats against the nations nuclear power plants, the NRC has taken a number of steps to improve the already high level of security at the nuclear power plants, including more training for security guards and requiring additional guards at the plants. These actions include issuing: (1) Orders formalizing certain security enhancements, security force fitness-for-duty and training improvements, and Design Basis Threat (DBT) revisions, (2) more than 60 advisories to licensees to describe threat conditions or recommend additional measures, and (3) an NRC Threat Advisory and Protective Measures System, consistent with the Homeland Security Advisory System, to rapidly respond to changes in the national threat environment. The revised DBT includes changes in the adversary characteristics that the NRC considered appropriate for inclusion in the current threat environment. These and other actions make nuclear power plants even better protected than what had been the best protected commercial facilities prior to the attacks on September 11, 2001.

I hope the contents of this letter have adequately addressed your concerns regarding safety and security at SONGS, as pointed out in your letter to Congressman Cunningham. We thank you for taking the time to bring forth these concerns to the NRC.

Sincerely,

/RA/

Robert A. Gramm, Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Mrs. Pellar Once licensed, licensees like Southern California Edison are required to operate their plants in compliance with NRC-approved Technical Specifications (TSs), which form the basis and standard of our inspection programs. Any alteration plans by the licensee like the potential future replacement of steam generators for both units, if they impact compliance to the TSs, are required to be submitted for NRC review and approval, and are publicly available for comments via the Federal Register.

In addition to nuclear safety, the NRC also establishes high standards for effective security programs at nuclear power plants, as required by and described in 10 CFR Part 73. Since the agencys inception, we have required enhanced protection of licensed facilities against sabotage or attack. Security has been an important part of the NRC's regulatory activities, with defense-in-depth as the guiding design and operating principle. NRC regulations ensure that nuclear power plants are among the most hardened and secure industrial facilities in our nation.

The many layers of protection offered by robust plant design features, sophisticated surveillance equipment, physical security protective features, professional security forces, and access authorization requirements provide an effective deterrence against potential safety or security problems related to terrorist activities that could target equipment vital to nuclear safety. Since the terrorist attacks of September 2001, the NRC has sought to ensure the continued protection of the nations nuclear power plants, working in close coordination with the Federal Bureau of Investigation, the Department of Homeland Security, the Federal Aviation Administration, the Department of Defense, State and local authorities, and other intelligence and law enforcement agencies, as well as NRC licensees. NRC coordination with these agencies remains ongoing. Although there have been no credible threats against the nations nuclear power plants, the NRC has taken a number of steps to improve the already high level of security at the nuclear power plants, including more training for security guards and requiring additional guards at the plants. These actions include issuing: (1) Orders formalizing certain security enhancements, security force fitness-for-duty and training improvements, and Design Basis Threat (DBT) revisions, (2) more than 60 advisories to licensees to describe threat conditions or recommend additional measures, and (3) an NRC Threat Advisory and Protective Measures System, consistent with the Homeland Security Advisory System, to rapidly respond to changes in the national threat environment. The revised DBT includes changes in the adversary characteristics that the NRC considered appropriate for inclusion in the current threat environment. These and other actions make nuclear power plants even better protected than what had been the best protected commercial facilities prior to the attacks on September 11, 2001.

I hope the contents of this letter have adequately addressed your concerns regarding safety and security at SONGS, as pointed out in your letter to Congressman Cunningham. We thank you for taking the time to bring forth these concerns to the NRC.

Sincerely,

/RA/

Robert A. Gramm, Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation DISTRIBUTION: See next page Incoming: ML050660228 PKG. ML050730496 Response No.: ML050740393 NRR-106 OFFICE PDIV-2/PM PDIV-2/LA PDIV-2/SC PDIV-2/PD NAME BPham DBaxley RGramm HBerkow DATE 3/16/05 3/16/05 3/17/05 3/17/05 File Location: E:\Filenet\ML050740393.wpd OFFICIAL RECORD COPY

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