ML14364A013
| ML14364A013 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/02/2014 |
| From: | Stetson D T Ocean Institute |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 79FR61668 00012, NRC-2014-0223 | |
| Download: ML14364A013 (3) | |
Text
As of: December 24, 2014Received:
December 22, 2014PUBLIC SUBMISSIONenng_ost PUBLC S BMISIONTracking No. ljy-8g7a-4ks2 Comments Due: December 22, 201Submission Type: WebDocket: NRC-2014-0223 Southern California Edison Company; San Onofre Nuclear Generating
- Station, Units 2 and 3Comment On: NRC-2014-0223-0001 Southern California Edison Company; San Onofre Nuclear Generating
- Station, Units 2 and 3; Post-Shutdown Decommissioning Activities Report .j4Document:
NRC-2014-0223-DRAFT-0008 Comment on FR Doc # 2014-24356 Submitter Information Name: Daniel StetsonGeneral CommentSee attached file(s)Attachments StetsonInputonPSDAR_EIE_DCE F1017)I-.>.-'L~)m--SUNSI Review CompleteTemplate
= ADM -013E-RIDS= ADM-03Add= T OCEAN INSTITUTE EXPERIENCE IS THE TEACHERSeptember 2, 2014From: Daniel StetsonTo: SCE, CEP Chairman David Victor & MembersRE: Input on Draft PSDAR, EIE and DCE ReportsThank you for the opportunity to. review and provide input on these drafts.Draft Post-Shutdown DecommissioningsActivities ReportAs it is certain that the spent fuel will be stored on site in canisters for the foreseeable future, it is imperative that they be stored and maintained to the highest safety levelpossible.
The two identified potential canister suppliers, Areva Trans Nuclear and HoltecInternational, continue to improve the design of their:products.
In a recent press release,Holtec describes that. they are going to a "double wall. construction" for a facility in.Ukraine."Like Ukraine's national
- facility, Holtec's HI-STORM ventilated system is the designated
.technology for the Skull Valley (Utah) site; however, for added safety, the welded multi-purpose canisters employed at the CSFSF (Central SSpent Fuel Storage Facility-inUkraine) site will be of a double wall construction, just like its sister facility for storingChernobyl's spent fuel, located a few kilometers away.".How much "added safety" does this provide?
Regardless of the supplier, does it makesense to utilize a canister with double wall construction for SONGS?After the Alaskan oil spill there was federal and state legislation that required every shipto have a detailed Emergency Preparedness Plan. In the case of a spill, regardless ofthe vessel's location along the US coast, the ship was required to have a plan that'included every single required resource necessary to respond, clean up the spill andaddress potential environmental damage. As such, resources were established alongthe coast and are being maintained in case of a spill emergency.
The Gulf spilldemonstrated that, even :with this type of protection in place, we can never be tooprepared.
SONGS should develop and have in place a "worst case scenario" emergency response plan. Removing the cooling pools, seawall and train rails appearto significantly reduce safety resources for protection and response.
As theDecommissioning Cost Analysis Report states, "Maintaining the spent fuel pool for anextended duration following cessation of operations prevents termination of the Part 50license...."
Is this, however, the safest course of action?24200 DANA POINT HARBOR DRIVE. DANA POINT, CALIFORNIA 92629TEL: 949.496.2274
- FAX: 949.496.4296
- WEB: WWW.OCEAN-INSTITUTE.ORG Draft Environmental Impact Evaluation ReportThe EIE is incomplete as it does not include an analysis of the ocean impact, primarily the removal of the intake and exhaust conduits.
A study of the conduits and thesurrounding aquatic biology should be undertaken right away. Should eel grass or otherprotected species.
be found in the area, a case can be made for leaving the conduits inplace. 'If chemical, nuclear or other contaminants are found, the conduits obviously need to be removed.
If contaminants and protected species are both found, the conduitsstill need to be removed and a mitigation plan developed.
None of this can take place,however, until the underwater area is surveyed and the evaluation criteria established.
Draft Decommissioning Cost Analysis ReportGiven the parameters of how this report was prepared and our own lack of experience in this area, it seems impossible to properly evaluate and comment upon its findings.
As such, independent, outside expert peer review is recommended to confirm itsfindings.
Sinc ly,Da iel T. StettsonPresident
& CEO