ML20140H760
| ML20140H760 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/09/1997 |
| From: | Robertus J CALIFORNIA, STATE OF |
| To: | Fields M NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20140H766 | List: |
| References | |
| NUDOCS 9706180445 | |
| Download: ML20140H760 (10) | |
Text
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l l ' Jun6 9, 1997 Mr. Mel Fields
, . Project Manager CaFEPA US Nuclear Regulatory Commission p,,, ,;3,,,
Documents Control Desk g,y,,,,,,
i Sa Diego Washington, DC 20555 Regl=1 Water j Qu:lity Control i Bo:rd
Dear Mr. Fields:
9771 Clairemont Mesa RADIOACTIVITY AND SEISMIC CONCERNS AT SAN ONOFRE NUCLEAR Blvd, Suite A S n Diego, CA 92124 GENERATING STATION (SONGS)
F 19h 5-6972 Enclosed for your review is a copy of material submitted by Ms. Patricia Borchmann to the Regional Board at their May 21, 1997, meeting. I understand that Ms. Borchmann is concerned about reports of migration of radioactive substances at SONGS, and is concerned about a Petition by Mr. Stephen Dwyer, a se:smologist, regarding seismic safety at SONGS. I believe the concerns expressed by Ms. Borchmann are subject to your jurisdiction.
The Regional Board's jurisdictional authority over l radioactivity and seismic safety are limited. However, the Regional Board is a State regulatory agency with the responsibility for protecting the quality of ground waters and surface waters within its area of jurisdiction. The Regional Board has been given authority under State Law to require submission of information, establish regulations, direct action and levy penalties and/or bring' legal action when necessary to protect water quality. We regulate the discharge of wastes from SONGS through the issuance of a National Pollutant Discharge Elimination System (NPDES) permit. That permit implements state water quality standards and the federal Clean Water Act requirements.
Any information you could provide us regarding Ms.
Borchmann's concerns or any potential threat to water quality would be greatly appreciated. i l
If you have any questions, please contact Mr. Paul J.
Richter of my staff at (619) 627-3929.
Respectfully, h
'4{ b 0003 I \ l HN H. ROBERTUS '
Executive Officer ,
Enclosure cc: Ms. Patricia Borchmann Ms. Catherine Kuhlmann, USEPA Region 9 (w/ enclosure)
Ms. MaryJane Johnson, SONGS (w/ enclosure)
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. f Rec >rledPaper Our mission is to preserve and enhance the quality of Cahfornia's water resources, and i W ensure their proper allocation and efficient usefor the benefit ofpresent andfuture gentrations.
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[E4h' b y Y kh{h Patricia Borchmann
. 176 Walker Way i Vista, CA 92083 May 21, 1997 g0)19/-[42T'hb I State of California hh 4U~bU Regional Water Quality Control Board San Diego Region j 9771 Clairemont Mesa Boulevard, Suite A i San Diego, CA 92124-1331 j RE: Oral Communicatio'n - ENQCB Board Meeting May 21, 1997 Request Resolution of Support for following, either in l portions deemed appropriate, or in their entirety: l 1
- 1. Initiate independent testing and monitoring of conditions at l SONGS, to verify if reliable, but unconfirmed reports of offsite l l surface and subsurface migration of radioactive substances have l been released beyond the containment structure and fuel cooling ponds, (including tritium and borate crystals), OR:
l 2. Insist that the NRC and FEMA do their duty, and conduct an l updated, independent test program to replace the current obsolete
! seismic data, or even evaluate more relevant updated seismic data ;
from the Northridge quake, which was conveniently overlooked in the analysis. However, NRC and FEMA continue reliance on previously flawed assumptions and the continuance of the status quo. An updated study should serve not only SONGS, and the l public interest, by either disproving the unconfirmed release of radioactive substances from SONGS either occurrad, or continueF i to occur, or if so,to apply immediate remediation measures.
- 3. A Petition to NRC was filed in October 1996, by seismologist / geologist Stephan Dwyer (his Introduction to Report is attached). I understand that although this petition has not been resolved, the petition will expire at the end of May 1997, in a mere 10 days, unless intervention occurs. I request RWQCB adopt of Resolution to support the extension of the Petition, and j
direct NRC & FEMA to conduct updated testing and analysis !
l necessary to reevaluate seismic risk, risk areas, evacuation zones, emergency planning documents at Federal, State, County, and Local jurisdiction levels, based on most recent available seismic data, update the circulation / traffic analysis, and determine the actual limits of a " safe" evacuation zone, determine necessary evacuation zone routes, feasibility, under l
worst case scenario conditions.
l B. REASON FOR REQUEST
- 1. Upon review of the Emergency Management Plans for both San Diego and Orange County, it appears there are at least a few
- ,j obvious fundamental flaws, which are a basis of my past challenge i
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to the plants' renewal license: Adequacy of emergency evacuation !
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g a) Flaw #1 - Circulation / traffic analysis assumes no more than one (1) vehicle per household will be used during an emergency evacuation. .
b) Flaw #2 - Road capacity - Even though the analysis is supposed to assume worst case scenario conditions such as flooding, the circulation capacity analysis assumes there will be i no lane closures during flooding conditions. Based on ,
conditions during the flooding in Laguna in 1994 following fires, l the assuption of no lane closures is fundamentally flawed. i 2
i It is almost certain that an independent updated seismic study, i i
and evacuation analysis would prompt recognition of the need for l substantial upgrades in the current estimates for manpower under ,
the various Mutual Aid Agreements and EOC mandatory training for I public employees working in agencies.
l C. BACKGROUND l My name is Patricia Borchmann. I am here as a concerned citzen l of Vista, California, (approximately 22 miles from San Onofre).
I understand that RWQCB's authority in the area of water quality in this case is limited; apparently the SONGS permit specifies that water quality issues which would ordinarily be within the scope of your Board are deferred to NRC. According to staff member Paul Richter (Staff Engineer), the most this Board could do would be is adopt a Resolution of Support of causes they determine appropriate. -
l l My bottom line, unless some immediate intervention occurs,the emergency petition filed with NRC will expire at the end of May 1997. I implore the RWQCB Board members either take action to initiate your own independent study of unconfirmed release of radioactive substances, and their surface and subsurface l migration, including but not limited to tritium and borate crystals, or demand NRC & FEMA to do their duty and do so.
Releases are believed to be directly related to seismic events, also unnoted by NRC, but supported by attached Introduction filed in the 10/96 Emergency Petition filed with NRC, due to expire 5-31-97.
Government employees in public agencies are typically trained that public health and safety has always been, and will always be the highest imperative.
Based on information from experts both in the seismic field, and specialists in effects of radioactive substances, I am honestly very skeptical of this critical paradigm (public safety being the
, highest imperative). It is likely to be maybe really the scau l
of the century, and the next century, who will inherit this dilemma, unless constructive action is taken immediately.
My skepticism is based partially on these very recent unconfirmed reports on issues of water quality, underestimated seismic risk and how unealistic the current emergency response plans adopted by NRC, based on FEMA;s acceptance of local / regional plans really are.
I challenged not only feasibility within the current 10-mile evacuation zone, much less the feasibility of a larger zone - an extent at least great enough to protect the public, but a distance which has not-been fully understood, or determined, even following the Cherynobl nuclear disaster, or even the Northridge seismic events.
Given the current apparent unresolved water quality and public risk issues & assessment, a. Responsible or Trustee agency having indirect authority, may make recommendations to NRC issues within this Agency's purview, such as water quality. Therefore, I implore this RWQCB Board take immediate action adopting a resolution of support to NRC to implement seismic and water quality studies, and perform followup, if determined necessary by updated studies.
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l l SEISMIC RISKS AT SAN ONOFRE l NUCLEAR GENERATING STATION INTRODUCTION The Emergency Petition for an emergency shutdown of San Onofre Nuclear Generating Station (SONGS) has been pending for several months. It has now been split into two seperate requests . One is for the removal of all Spent ,
Fuel out of the Southern California Seismic Zone. The other is for the I temporary shutdown of the Unit 2 & 3 Reactors till such time that a complete reviewand reanalysis of the seismic risks of all systems is completed. .-
l '.The Design Basis Event for Units 2 & 3 is only 0.679's. At the time of l
construction this was just sufficiently above the range of g forces of 30 l earthquakes prior to 1979. In the years following construction a number of I
quakes have occured that indicate that this original group of quakes was l_ not statistically relavant. The wide range of quakes accross S. CA, fault types, damage, accelerations and offsets has led to numerous revisions of not only S. CA geology but also the fundamental assumptions of seismology.
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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 towithstand over MB.O 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 perporting to be " State of the art" has been finally released. All data and information have been so carefully manipulated to
" 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 toanything 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 structuraldynamics 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 j
( serious I discussion or analyses of the Northridge Quake, a blind thrust previously I unknown and unmapped, which caused 20 billion dollars damage and destroyed ma,jor 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 I the DBE of SONGS, the fact that the Northridge Quake was only a M6.6, it had the highest g orces ever recorded, the downplaying of the San 'dreas " salt as 1
a significint risk factor was just to incredible to believe, the most '
dangerous section of fault in the world appeared to be no more risk than any other susidiary fault in S. CA. The true effects of a major quake on the S. I San Andreas are totally unknown, but even with a probabalistic approach, it must be able to 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 along a great distance of fault. 1 The g forces, ground waves and especially duration of shaking could be ;
enough to destroy anything ever built by man over all of S. CA. !
The numerous' deficiencies in this report are a desperate attempt to cover-up the danger and 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 involved in the analysis that the risks are not possible to calculate by a probabalistic approach. A much more sophisticated analysis wil be i needed. But in the mean time, there are no logical arguments for storing hundreds of thousands of pounds of dangerous Spent Fuel anywhere in S. CA,
let alone in an old Spent Fuel Pool at the beach. Millions of people are 06 needlessly put at risk from this fuel. Why? There are no good answers, only flimsy excuses from a stonewalling management at SCE trying its best to delay the enevitable just to generate a small rate of return to stock and bond holders. Why dfd they have the seismic report done by a distant consulting I
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 l results would not be favorable to SCE? Its clear why the Northridge Quake was ommitted.
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.
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 i action taken in as best as currently possible manner. Action must be taken without further delay because millions 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 most people prefer not to think about this very real possibility. Its up to the government to reduce ;
this risk and resolve this situation before an irreparable tragedy ends S. ;
CA civilization permanently. S. Californians could concievably rebuild from i a great quake but not if everything is radioactive. This risk is simply not )
something that any government agency can " License" and force citizens to i take. Costs of this project should be paid by the government up front, but ultimately SCE should bear the costs in an ;
amortized way. l i
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 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 c2n be done in an orderly and safe l 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 out for the current staus-quo at SONGS and emergency action must be taken.
Stephen Dwyer i
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From: PAUL BLANCH <PMBLANCHDIX.NETCOM.COM>
To: " DAVE LOCHBAUM" <dlochbaum@ucsusa.ucsusa.org>,
j " ROSEMARY" < ROE @AFR-OLT.COM), " PAUL GUNTER" <pguntereigc.apc.org>,
- " JIM RICCIO" <JRICCIO@MINDSPRING.COM), "JON BLOCK" <JONB@SOVER. NET)
Subject:
Re: TRITIUM IN THE SAND ,
Sent: 1/31/97 7:21 PM Received: 1/31/97 6:34 PM From: stephen dwyer, smd@wdc. net To: PAUL BLANCH, PMBLANCH@ix.netcom.com CC: GLEN MILLS, MILLSGLEN@msn.com
Dear Paul and Glen,
I think that the excuses they have given reguaring the SFP's at SONGS are pretty weak. Since the pool was cracked, from seismic event (s) I think,
! the structural integrety is compromised and greater damage could be expected next quake. The lack of monitoring the monitor well(s) is an incredible failure to even care about safety. The plastic has never been tested for resistance to radioactive decay, which could be similar to ultraviolet decay. Most plastics fail and 30 years is long enough for that to happen. The fact that the groundwater is higher than the monitor well is only partially safe. The hydraulic gradient may be ok but the osmotic gradient between the salty pool water and the fresh ground water is out not in. This could explain the mystery (Borate) crystals outside the walls. Diffusion is an unstoppable process.
The fact that the sand at the beach was centaminated shows that its leaking substantial amounts of radiation out, even as the water levels remain as planned.
A part of and symptom of the enevitable entropy of the entire plant.
Unfortunately, the entropy seems to have set in the hearts and minds of those
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who are responsible.
l I find it an incredible insult that they seem to think that just because this pollution is not going towards any water wells, but only towards our state beach, its somehow ok and of no concern.
If these SFP's are such great designs for high level waste disposal, then why don't they store all the nuclear wastes this way? Why, we could have thousands of swimming pools at all the beaches along the coast. We could
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even bring the fluid wastes from Rocky Flats Arsenal to CA to cool the i rods etc. :-( {
I am especially concerned that en the one hand they say the rods, pins, i
cladding pellets and racks are stong and safe, and on the other hand, they are so ~ !
unstable and dangerous they cannot be handled or moved at all, anywhere. ']
Have any assemblies been moved to another location anywhere? Can it be j done safely, even rod by rod or whatever? If so then they don't have that f excuse for leaving them at San Onofre juyr longer. The risks of leaving them there are I greater than the risks of m'ving o them aawy from millions of people and f this i vital environment to the desert at Nevada Test Site etc. J t
Sincerely, f Steve Dwyer ,
smd@wdc. net you can forward this I
I John: 1 I have been reading some of the communications with the " Monitor Well" at '
the SONGJ plant. As I understand it, a " monitor well" is located in the sand, between the spent fuel pool and the Pacific Ocean. The water level ;
in the monitor well is maintained below the water table, such that any a water leaking from the SFP will wind up in the well and not in the ocean.
One of the NRC reports indicates the tritium concentration in the well is about half the concentration of the spent fuel pool water. This indicates to me this well is now one of the primary fission barriers and now the NRC is admitting that the spent fuel pool is leaking into the ground.
Have I read this NRC document incorrectly?
If this plant had a Part 72 License, this potential may have been recognized and prevented.
What is the depth of this well and is this what the NRC defines as
" Defense in Depth?" )
From: PAUL BLANCH <PMBLANCH3IX.NETCOM.COM>
To: "JZ" <JAZWOL@aol.com>, "JZ" <JAZ@NRC. GOV >
Dear John Zwolinski,
The monitor well is really a basement structure under the SFP. l I
l The problems with it include:
l 1. Contaminated water was found, after a period of about five years no l one was even looking.
[ 2. This basement is on an old 40 mils plastic liner similar to ones l placed-l under typ. concrete slabs. Radiation decay of this is unknown.
f N 3. Something is leaking somewhere, since beach sand was removed to
\ Hanford and
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i L , white crystals of borates? are showing up on the adjacent soil, p,j '4 . No one seems to monitor or test this either.
4il 5. Some new monitoring plans are in progress, what exactly I, don't know.
j 6. The SFP was cracked (Quake?) and was epoxied up. The structural j j integrety j l
has declined and it will fail worse next quake or settling. !
l 7. Settling in an adjacent well ( 200 feet deep water well) right there was investigated by numerous test holes. Some cavities and bad ground were ;
encountered. No other tests were run, and test holes grouted. This could mean that some unstable areas exist in the sandstone bedrock. These could !
cause )
additional settling during a seismic event, very close to the SFP. l'
- 8. Various failure scenarios could occur during big quakes resulting in
- " unacceptable doses to the public" whatever that means, it doesn't sound good.
l 9. Osmotic pressure of the concentrated boric solutions is greater than i l the l L fresh water outside therefore it can migrate up the hydraulic gradient. l l 10. Spent fuel at SONGS 1 SFP is not scheduled to be removed until 1999, l and
! final shipments are not sched. until 20131 l The total U/Pu is 207 assemblies at 0.371 tons each=76 tons or 155,000lbs!
, The totals for the other SFP is much greater so that totals are
! closer to 500,000 lbs(correct me if I'm wrong) and will take most of the next century
, to remove. This time frame also includes the time frame of the next Bigone on the S. San Andreas Fault!
l We are working on this and other seismic analyses at SONGS, but our work will not be completed soon, due to various delays.
I don't recommend living around here.
l Steve Dwyer smd@wdc. net ps Paul, you can forward most of what I send you, except our upcoming plans or stategies.
At 09:39 PM 2/2/97 -0000, you wrote. 1 l
Paul M. Blanch i Energy Consultant 135 Hyde Rd.
West Hartford CT 06117 ;
Tels 860-236-0326 Fax: 860-232-9350
Subject:
SONGS SEISMIC
- Date
- Wed, 19 Mar 97 12:36:16 -0000
$ x-sender: PMBLANCH@popd. IX .NETCOM . COM
, From: PAUL BLANCH <PMBLANCH@IX.NETCOM.COM>
, 's . . To: " undisclosed-recipients:;"
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