ML20138G561

Discusses Emergency Petition for Emergency Shutdown of San Onofre Nuclear Generating Station

ML20138G561
Person / Time
Site:	San Onofre
Issue date:	03/24/1997
From:	Dwyer S AFFILIATION NOT ASSIGNED
To:	Fields M NRC
Shared Package
ML20138G450	List: ML20138G444 ML20138G471 ML20138G561 ML20138G609 ML20138G641
References
2.206, NUDOCS 9705060330
Download: ML20138G561 (3)

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{- From: stephen dwyer <smd@wdc. net >

i To: WND2.WNP3(mbf1) l- Date: 3/24/97 7:44pm q

Subject:

Seismic Risks At SONGS Introduction Draft SEISMIC RISKS AT SAN ONOFRE NUCLEAR GENERATING STATION j INTRODUCTION

! The Emergency Peti +5n for an emergency shutdown of San Onofre Nuclear 1

Generating Station (60NGS) has been pending for several months. It has how been split into e two seperate requests.

One is for the removal of all Spent Fuel out of the Southern Califomia Seismic Zone. The other is for the temporary shutdown of the Unit 2 & 3 1 l Reactors till such time that a complete review and reanalysis of the seismic risks of all systems i- is completed.

i The Design Basis Event for Units 2 & 3 is only 0.67g's. At the time of construction this was just sufficiently above the range of g forces of 30 earthquakes prior to 1979. In the years following construction a number of quakes have occured that indicate that this original group of quakes was not statistically relavant. The wide range of quakes accross S. CA, fault types, damage, 4 accelerations and offsets has led to numerous revisions of not only S. CA geology but also the fundamental assumptions of seismology.

The increasing uncertainties of the situation and the science itself have been hotly debated.

The retrofitting of all kinds of structures, many previously thought to be among the most resistant, has been widespread.

Previously known problem structures have been undergoing retrofitting for years. Retrofitting of emergency facilities to withstand over M8.0 quakes has been ongoing. But no retrofitting of San Onofre, the most important structure in S. CA, has been undertaken or even planned Instead, a lenghty report purporting to be " State of the art" has been finally released. All data and information have been so carefully manipulated to i

" prove" that SONGS still meets all original design basis event criteria.

Fault by fault is dismissed for one " reason" or another, formulas are defended while the true nature of the uncertainties involved in the parameters are understated, graphs are manipulated to show that acceleration attenuations are within bounds, g forces are not able to exceed the DBE, vertical g forces are neglected and shown in reduced scale on the last page, the DBE is ommitted entirely from the report making graphical comparissons difficult or impossible, the relationship to anything at SONGS is entirely ommitted, only a simple probablistic calculations are included, no deterministic calculations are discussed , let alone shown, no computer analyses of any structural dynamics or 3-D modelling is presented, no sequential dynamic ,

analyses are presented, the significant advances in offshore geology are dismissed as nothing '

to be concerned about even though they show numerous intersecting folds and faults and complex geometric relationships that were not known at the time of construction, but are now known to be related to similar geology that has caused major damage, the complete and incredible omission of any serious discussion or analyses of the Northridge Quake, a blind thrust previously unknown and unmapped, which caused 20 billion dollars damage and destroyed major structures 20 miles away, especially noticable was any discussion of the fact that the Northridge Quake g forces exceeded 1.8 g's, almost 3 times the DBE of SONGS, the fact that the Northridge Quake was only a M6.6, it had the highest g forces ever recorded, the downplaying of the San Andreas Fault as a significant risk factor was 9705060330 970501 PDR ADOCK 05000206 H PDR

j '. . l l l io just to incredible to believe, the most dangerous section of fault in the world appeared to be no i

more risk than any other susidiary fault in S. CA. The true effects of a major quake on the S.

! San Andreas are totally unknown, but even with a probabalistic approach, it must be able to  :

l generate a quake much bigger than anything ever experienced in CA. 200 or more years of energy buildup at a rate of 25 to 35 or more mm per year means several tens of feet offset f

along a great distance and depth of fault. The g forces, ground waves and especially duration l of shaking could be enough to destroy anything ever built by man over all of S. CA.

i l l The numerous deficiencies in this report are a desperate attempt to cover-up the danger and l l maintain a status-quo that is long out of touch with reality.

Their are so many earthquake faults,and probably many more yet to be found, that to say that none of them could damage SONGS is simply absurd. There are so many uncertainties j involved in the analysis that the risks are not possible to calculate by a probabalistic approach. 1 A much more sophisticated analysis wil be needed. But in the mean time, there are no logical arguments for storing hundreds of thousands of pounds of dangerous Spent Fuel anywhere in l S. CA, let alone in an old Spent Fuel Pool at the beach. Millions of people are needlessly put i at risk from this fuel. Why? There are no good answers, only flimsy excuses from a

stonewalling management at SCE trymg its best to delay the enevitable just to generate a i smal! rate of retum to stock and bond holders. Why did they have the seismic report done by a

! distant consulting firm? Was it because no local firms would touch this problem because they knew that the numerous faults are too unpredictable and dangerous and the results would not

be favorable to SCE? Its clear why the j Northridge Quake was ommitted.

Update: Woodward & Clyde have put forth some answers to NRC queations 3-14-97, but it is only more of the same cover up. See following letter of rebuttal.

Three years after the Northridge Quake and still no updated seismic report.

This is a violation of the requirement to keep all reports affecting safety analysis completely up to date. SCE has been hoping that no one would notice this. glaring deficiency for as long as

possible. SONGS should have been shut down the day of the Northridge Quake pending a

complete analysis, and not put online till it had been finally re-approved. Operating SONGS

! without this information is operating completely blind.

l if the Spent Fuel Pools are so well designed, then why can' t they build some in Nevada in or near the Test Site, and remove them asap. If the design isn't relly that perfect. then all the

!_ more reason to move the Spent Fuel to an udated _ version or new technique. Because this is an emergency situation, the luxury of endless debate about nuclear storage must be set aside and action taken in as best as currently possible manner. Action must be taken without further delay because mill;ons of lives are at stake. If a big quake, and large aftershocks, forces people to live outdoors they will extremely vunerable to fallout from a disaster at SONGS. No ,

escape and nowhere to hide. Its almost unimaginable what could happen, and apparently rnost  !

people prefer not to think about this very real possibility. Its up to the govemment to reduce this risk and resolve this situation before an irreparable tragedy ends S. CA civilization permanently. S. Califomians could concievably rebuild from a great quake but not if everything is radioactive. This risk is simply not something that any govemment agency c':n " License" and force citizens to take. Costs of this project should be paid by the govemment up front, but ultimately SCE should bear the costs in an amortized way.

Marine Corps trucks could be mobilized for this operation to transport the fuel in a secure way.

Highway Patrol could manage the traffic along the route. At 40,000 pounds per truck, a dozen 1

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or so loads would be all that is required to move the fuel. It would not take long once the new site was ready. This could be accomplished by the end of the year. This can be done in an

orderly and safe manner without any long study, debate or delay.Once the fuel is in Nevada, we can continue to study ways to solve the waste problem in a safe way with many years available. Time has run outfor the current staus-quo at SONGS and emergency action must be taken.

Sincerely, i Stephen Dwyer

Geologist smd@wdc. net i

) CC: WND2.WNP3(whb) 1  ;

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