ML20141H814

Responds to to M Fields Requesting That NRC Provide Info That Could Assist Recipient in Addressing Radiological Issues at Songs.Encl 1 Addresses Radiological Monitoring at SONGS Which Pertain to Water Quality

ML20141H814
Person / Time
Site:	San Onofre
Issue date:	07/31/1997
From:	Mendonca M NRC (Affiliation Not Assigned)
To:	Robertus J CALIFORNIA, STATE OF
References
NUDOCS 9708010195
Download: ML20141H814 (5)

Text

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Mr. John H. flobertus July 31, 1997 San Diego Regional Water Quality Control Board 9771 Clairemont Mesa Blvd., Suite A San Diego, CA 92124

Dear Mr. Robertus:

I am responding to the letter you sent to Mel Fields of the U.S. Nuclear Regulatory Commission (NRC) on June 9, 1997. In your letter, you requested that the NRC provide information that could assist you in addressing radiological issues at the San Onofre Nuclear Generating Station (SONGS) brought to the attention of the Regional Water Quality Control Board on May 21, 1997, by Ms. Patricia Borchmann. Enclosure 1 addresses radiological monitoring at SONGS which pertains to water quality.

Ms. Borchmann's letter also contained questions related to the seismic design of the SONGS units, emergency planning and response issues, and several issues unique to SONGS Unit 1. The seismic design issue referred to by Ms. Borchmann is the subject of a current petition pursuant to Section 2.206 of Title 10 of the Code of Federal Reaulations_. The NRC's review of this petition is nearing completion, and we expect to issue our decision in the near future. In a letter dated November 22, 1996 (Enclosure 2), the NRC concluded that insufficient evidence was provided by the petitioner to warrant any immediate action. With respect to emergency planning, Ms. Borchmann has written letters directly to the NRC (June 23, June 28, and July 11, 1997) which address, among other things, emergency planning at the SONGS site. We will include your organization on distribution for our responses to Ms. Borchmann, if requested.

Please contact Mel Fields of the NRC if you wish to be included in this distribution. Enclosure 3 addresses the issues unique to SONGS Unit 1.

I trust this information responds to your request.

Sincerely, Original signed by:

Marvin M. Mendonca, Acting Director Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation

Enclosures:

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As stated DISTRIBUTION: 31 Docket Filest50-206' 361 and 362

, MSlosson MFields g PUBLIC (w/ incoming) SWeiss EHylton PDND r/f MMendonca BSweeney SCollins SBajwa Region IV I)

FMiraglia EHylton(w/ incoming) WBateman RZimn erman TMartin WTravers NRR Mail Room (YT#097010 w/ incoming) (012-G18)

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4 Mr. John H. Robertus July 31, 1997

, San Diego Regional Water Quality Control Board 9771 Clairemont Mesa Blvd., Suite A San Diego, CA 92124

Dear Mr. Robertus:

I am responding to the letter you sent to Mel Fields of the U.S. Nuclear Regulatory Commission (NRC) on June 9,1997. In your letter, you requested that the NRC provide information that could assist you in addressing radiological issues at the San Onofre Nuclear Generating Station (SONGS) brought to the attention of the Regional Water Quality Control Board on May 21, 1997, by Ms. Patricia Borchmann. Enclosure 1 addresses radiological monitoring at SONGS which pertains to water quality.

Ms. Borchmann's letter also contained questions related to the seismic design of the SONGS units, emergency planning and response issues, and several issues unique to SONGS Unit 1. The seisaic design issue referred to by Ms. Borchmann is the subject of a current petition pursught to Section 2.206 of Title 10 of the Code of Federal Reaulations. The NRCMfeview of this petition is . earing completion, and we expect to issue our de%fsion in the near future. In a letter dated November 22, 1996 (Enclosure 2), the NRC concluded that insufficient evidence was provided by the petitioner to warrant any immediate action. With respect to emergency planning, Ms. Borchmann has written letters directly to the NRC (June 23, June 28, and July 11, 1997) which address, among other things, emergency planning at the SONGS site. We will include your organization on distribution for our resp.onses to Ms. Borchmann, if requested.

Please contact Mel Fields of the NRC if you wish to be included in this distribution. Enclosure 3 addresses the issues unique to SONGS Unit 1.

I trust this information responds to your request.

Sincerely, original signed by:

Marvin M. Mendonca, Acting Director Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation

Enclosures:

As stated DISlRIBUTION:

Docket Files 50-206, 361 and 362 MSlosson MFields PUBLIC (w/ incoming) SWeiss EHylton PDND r/f MMendonca BSweeney SCollins SBajwa Region IV FMiraglia EHylton(w/ incoming) WBateman RZimmerman TMartin WTravers l NRR Mail Room (YT* ")7010 w/ incoming) (012-G18)

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A p ug g 0 4 UNITED STATES y j NUCLEAR REGULATORY COMMISSION

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Mr. John H. Robertus San Diego Regional Water Quality Control Board 9771 Clairemont Mesa Blvd., Suite A San Diego, CA 92124

Dear Mr. Robertus:

I am responding to tha letter you sent to Mel Fields of the U.S. Nuclear Regulatory Commission (NRC) on June 9,1997. In your letter, you requested ,

l that the NRC provide information that could assist you in addressing  !

radiological issues at the San Onofre Nuclear Generating Station (SONGS)  !

l brought to the attention of the Regional Water Quality Control Board on i l May 21, 1997, by Ms. Patricia Borchmann. Enclosure 1 addresses radiological monitoring at SONGS which pertains to water quality, J l j Ms. Borchmann's letter also contained questions related to the seismic design  !

of the SONGS units, emergency planning and response issues, and several issues l unique to SONGS Unit 1. The seismic design issue referred to by Ms. Borchmann l is the subject of a current petition pursuant to Section 2.206 of Title 10 of j the Code of Federal Reaulations. The NRC's review of this petition is nearing completion, and we expect to issue our decision in the near future. In a letter dated November 22,1996 (Enclosure 2), the NRC concluded that insufficient evidence was provided by the petitioner to warrant any immediate action. With respect to emergency planning, Ms. Borchmann has written letters directly to the NRC (June 23, June 28, and July 11, 1997) which address, among other things, emergency planning at the SONGS site. We will include your organization on distribution for our responses to Ms. Borchmann, if requested.

Please contact Mel Fields of the NRC if you wish to be included in this distribution. Enclosure 3 addresses the issues unique to SONGS Unit 1.

I trust this information responds to your request.

Sincerely, l L /~ --. -

! Marvin M. Mendonca, Acting Director l Non-Power Reactors and Decommissioning l Project Directorate Division of Reactor Program Management 1 Office of Nuclear Reactor Regulation

Enclosures:

i As stated

ENCLOSURE 1

SUBJECT:

RADIOLOGICAL MONITORING AT NUCLEAR POWER PLANTS The NRC requires each of its licensed nuclear power plants to monitor radioactive effluents and to conduct an environmental monitoring program. For the release of radioactive effluents, the NRC imposes separate requirements for airborne and waterborne effluent releases. These requirements, contained in 10 CFR Part 50.36a of our regulations, are structured to maintain doses to members of the public associated with all radioactive effluent releases to levels that are as low as is reasonably achievable (ALARA). The requirements contain design objectives for off-site doses to the maximally exposed member of the public living near the nuclear power plant. These design objectives, which are per reactor unit, are 3 millirem per year from waterborne releases and 5 millirem per year from airborne releases. These values are a small fraction of the 100 millirem annual limit in 10 CFR Part 20 for members of the public from exposure to NRC licensed facilities.

The NRC recognizes that the discharge of radioactive materials (including Tritium) from routine plant operations may result in environmental impacts.

These impacts can be on man, animals, plants, and sea life. During the licensing of a plant, NRC conducts a thorough review of these impacts and issues a Final Environmental Statement (FES) in accordance with the National Environmental Policy Act, which identifies the potential impact of the operation of the plant on the environment. In the FES for SONGS Unit 1, the

'NRC estimated that 8000 curies of Tritium would be released annually. In the FES for SONGS Units 2 and 3, the NRC estimated that a total of 2000 curies of Tritium would be released annually (1000 curies per unit). Thus, the NRC evaluated the impact to members of the public and the environment based on the l operation of all three units releasing an annual total of up to 10,000 curies of Tritium. This compares to an average value of 2200 curies currently being released from all three San Onofre units in a year.  !

With respect to Ms. Borchmann's concern regarding Tritium, the staff has reviewed the licensee's effluent release data since initial operation. To date, approximately 50,000 curies of Tritium have been released into the environment. Also, based on average releases over the past ten years, the staff projects that an additional amount of approximately 34,000 curies will be released if normal operation continues to the expiration date in the licenses for SONGS Units 2 and 3. The production of Tritium will stop once power operation ceases. As such, the amount of Tritium released during decommissioning and disposal of. the spent fuel will be insignificant compared to that released during power operation.

It should be noted that the total number of curies released by the plant does not by itself represent a meaningful representation of the impact to members of the public or the environment. It is also helpful to recall that Tritium forms naturally in the environment due to the action of cosnic rays. The power plant data must be put into perspective based on what assumptions the NRC used in the evaluation and licensing of the plants and on the calculated doses resulting from the radioactive releases.

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To compare the requirements for operation to actual experience, for the year 1991, the NRC performed an independent evaluation of the doses to the hypothetical maximally exposed member of the public from all gaseous and liquid effluents (including 2,375 curies of Tritium) from all three San Onofre units. The annual doses were estimated to be 0.0042 millirem to the whole body from airborne releases and 0.0078 millirem to the whole body from liquid releases. These doses are well below the ALARA design objectives the plant is required to meet. To understand better the significance of these dose estimates, a comparison to the estimated doses from natural background is useful. The National Council on Radiation Protection and Measurements performed a comprehensive review of sources of natural background radiation doses received by the population of the United States, which shows the average annual exposure to be approximately 300 millirem. After natural background radiation, the next largest component of human exposure to radiati;. comes from medical procedures such as those involving x-ray examinations and nuclear medicine, which results in an annual exposure of approximately 53 millirem.

All other sources (ita.iuu'.ng nuclear power plants) are much smaller in magnitude. Thus, the off-site doses from the normal operation of nuclear power plants are significantly lower than the doses from commonplace activities.

The environmental monitoring program conducted at the SONGS site is designed to assess the impact of the release of radioactive material into the environment. The environmental monitoring program requires samples of air, l drinking water, ocean water, shoreline sediment (beach sand), milk, fish, and local food crops from areas near and far away from the facility to be analyzed for radioactive material. The licensee is required to report the results of this extensive monitoring to the NRC on an annual basis.

A review was performed of the licensee's most current published radiological environmental operating report (1996). The result of this report shows that I no detectable amounts of Tritium were found in any of the environmental l samples analyzed for Tritium (ocean water, drinking water, shoreline sediment, I ocean bottom sediment, non-migratory marine species, soil and kelp analysis, I and local crops). Only naturally occurring material was detected. This data I shows that while Tritium is released from the three units, it has a negligible l impact on the public and the environment. l As part of the checks and balances to ensure the safe operation of nuclear power plants, the NRC conducts routine inspections of the licensee's effluent and environmental monitoring program to verify compliance with the regulations and the conditions of its license. No significant problems have been identified at the San Onofre site.

In conclusion, the NRC has considered the impact of the discharge of l radioactive materials released into the environment during the licensing of l' the three San Onofre units, and during the continued operation of the units.

We find that the operation of the nuclear units at the San Onofre site have a negligible impact on the public and the environment.

f'; ENCIDSURE 2 l .. M*%

i- p '4 UNITED STATES j'

g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30eeHo01

%, . . . . . ,o# November 22, 1996 i

i Mr. Stephen Dwyer j c/o Robert Sanregret, Esq.

i. 17621 Irvine Blvd. #100 i Tustin, CA 92780 i s

Dear Mr. Dwyer:

i 3

.This letter acknowledges receipt of your request, dated September 22, 1996,

that the U.S. Nuclear Regulatory Commission (NRC) shut down the San Onofre l Nuclear Generating Station (SONGS) "as soon as possible" pending a complete

review of the "new seismic risk." Since' SONGS, Unit 1, was permanently shut

down on November 30, 1992, your request will be considered as referencing SONGS, Units 2 and 3. As a basis for this requested relief, you assert that a design criterion for the plants, which was "0.75 G's acceleration," is s " fatally flawed" on the basis of the new information gathered at the Landers and Northridge. quakes. You assert (1) that the accelerations recorded at.

Northridge exceeded "1.8 G's and it was only a Richter 7+ quake," (2) that there were horizontal offsets of up to 20 feet in the Landers' quake, and (3) that the Northridge fault was a " Blind Thrust and not mapped or assessed."

Your request that the Comission immediately shut down the SONGS units is denied. The ground motion detected at the SONGS site during these two earthquakes was below the 0.05g reporting limit in place at the time of those earthquakes and had no effect on SONGS structures and components. In addition, you have not provided evidence in your request to support your assertion that these two earthquakes have invalidated the seismic design of the SONGS units. Tae Northridge and Landers earthquakes occurred in areas where the tectonics is different than in the SONGS area. Because of the differences in geology and tectonics between the source regions of the Landers and Northridge earthquakes and the SONGS site area, earthquakes of those types are not contributors to the seismic hazard at the SONGS site and do not contribute to the seismic design criteria for the SONGS units, which are discussed more fully below.

Before licensing SONGS (and all nuclear power plants) the NRC reviewed the design of the facility including its ability to safely withstand the effects of natural phenomena such as earthquakes. The SONGS site had undergone geologic and seismic investigations and review prior to issuance of the construction perinits, including surveys performed by the applicant, the United States Geological Survey, the California Division of Mines and Geology, and the National Oceanic and Atmospheric Administration. The findings of these investigations were reviewed extensively by the staff and were litigated extensively in proceedings concerning the issuance of the construction permits and operating licenses for SONGS Units 2 and 3. The seismic design of the plants is based on the assumed occurrence of a magnitude 7 earthquake on the

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Mr. Stephen Dwyer November 22, 1996 Offshore Zone of Deformation (0ZD), a fault zone approximately 8 kilometers (5 miles) from the site, at its closest approach. This assumed event is larger than earthquakes known to have occurred on the OZD, and the resulting ground motion estimate is larger than that which could reasonably be expected

at the plant site from other seismic sources. Southern California Edison (SCE

. or the licensee) has recently completed a probabilistic seismic hazard l assessment which confirms the conservatism of the seismic design of the plant (SCE letter dated December 15, 1995, entitled, " Response to Generic Letter 88-20, Supplement 4, Individual Plant Examination of External Events").

Accordingly, there is insufficient evidence to conclude'that there is a substantial public health and safety hazard warranting the immediate action

you request. The Comission staff will, however, evaluate the matters that

. you have alleged.

Your request has been referred to me pursuant to 10 CFR 2.206 of the

Commission's regulations. As provided by Section 2.206, action will be taken on your request within a reasonable time. I have enclosed for your l information a copy of the notice that is being filed with the Office of the

Federal Register for publication.

j Sincerely, '

j Original Signed By Frank J. Miraglia, Jr., Acting Director

Office of Nuclear Reactor Regulation 1 J

Enclosure:

Notice ec w/ encl: See next page I

. - = . . - _ . . . _ _ . - - .- . .. - _ .

1 Mr. Stephen Dwyer November 22, 1996 cc w/ enc 1:

. Mr. R. W. Krieger, Vice President Resident Inspector / San Onofre NPS

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Southern California Edison Company c/o U.S. Nuclear Regulatory Commiission San Onofre Nuclear Generating Station Post Office Box 4329 P. O. Box 128 San Clemente, California 92674 San Clemente, California 92674-0128 Mayor i Chairman, Board of Supervisors City of San Clemente  ;

j County of San Diego 100 Avenida Presidio

1600 Pacific Highway, Room 335 San Clemente,ECalifornia 92672 i '

San Diego, California 92101 ,

cc w/ incoming:

4 Alan R. Watts, Esq. Mr. Harold B. Ray Rourke & Woodruff Executive Vice President 701 S. Parker St. No. 7000 Southern California Edison Company Orange, California 92668-4702

P.O. Box 128 l 1

San Clemente, California 92674-0128 '

Mr. Sherwin Harris i

Resource Project Manager  ;

Public Utilities Department  !

City of Riverside ,

3900 Main Street  !

Riverside, California 92522 Dr. Harvey Collins, Chief

Division of Drinking Water and

and Environmental Management California Department of Health Services P. O. Box 942732 i

Sacramento, California 94234-7320 i Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavilion 611 Ryan Plaza Drive, Suite 400 i Arlington, Texas 76011-8064 Mr. Terry Winter i Manager, Power Operations San Diego Gas & Electric Company

. P.O. Box 1831 l San Diego, California 92112-4150 Mr. Steve Hsu Radiologic Health Branch State Department of Health Services

, Post Office Box 942732 Sacramento, California 94234

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7590-01 UNITED STATES NUCLEAR REGULATORY COMMISSION SOUTHERN CALIFORNIA EDISDN COMPANY. ET AL.

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-361. 50-362. AND 50-206

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RECEIPT OF PETITION FOR DIRECTOR'S DECISION UNDER 10 CFR 2.206 i

Notice is hereby given that by request dated September 22, 1996, Stephen 1

Dwyer (Petitionor) requested that the U.S. Nuclear Regulatory Commission  !

1 (Commission) shut down the San Onofre Nuclear Generating Station "as soon as j possible" pending a complete review of the "new seismic risk." This request is being considered as a Petition under 10 CFR 2.206.

As a basis for the request, the Petition asserts that a design criterion for the plant, which was "0.75 G's acceleration," is " fatally flawed" on the l basis of the new information gathered at the Landers and Northridge quakes.

The Petitioner asserts (1) that the accelerations recorded at Northridge exceeded "1.8 G's and it was only a Richter 7+ quake," (2) that there were horizontal offsets of up to 20 feet in the Landers quake, and (3) that the Northridge fault was a " Blind Thrust and not mapped or assessed."

The request is being treated pursuant to 10 CFR 2.206 of the Commission's regulations. By letter dated November 22, 1996 Petitioner's request that the Commission immediately shut down San Onofre Nuclear Generating Station was denied. As provided by Section 2.206, appropriate action will be taken on this request within a reasonable time.

Als!!1bOM 3 77

A copy of the Petition is available for inspection in the Commission's Public Document Room at 2120 L Street, NW, Washington, DC 20555-0001.

Dated at Rockville, Maryland this 22nd day of November 1996.

FOR THE NUCLEAR REGULATORY COPMISSION C

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Frank 4-JIiragl . , A@ g Dir:: tor Office %f Nuclea eactor Mgulation i

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O ENCLOSURE 3 RESPONSE TO ELECTRONIC MAIL REGARDING SAN ON0FRE NUCLEAR GENERATING STATION, UNIT 1 This paper discusses several electronic messages provided by Ms. Borchmann that discuss the San Onofre Nuclear Generating Station, Unit 1 (SONGS 1).

Based on our review, we determined that the above messages contain or imply safety concerns regarding SONGS 1.

From those messages, we identified three concerns which are addressed below:

i Concern 1. The SONGS 1 spent fuel pool "was cracked, from seismic event (s)...," and the structural integrity was comprised.

Answer:

The NRC staff is unaware of cracks in the spent fuel pool due to seismic activity. The staff is also unaware of any seismic events that would have caused cracking.

Concern 2. A " monitor well" is located in the sand, between the spent fuel pool and the Pacific Ocean. This well is one of the primary fission barriers. NRC has reported the existence of tritium in the " monitor well." Therefore, the spent fuel pol is apparently leaking into the ground.

Answer:

Attached are three figures of the fuel storage building and monitoring well that show the location of the spent fuel pool leak detection well. The detection well is not an environmental or groundwater monitoring well, it is simply the receptacle in which leakage between the pool's stainless steel liner and its concrete structure may be collected.

The spent fuel pool is constructed of reinforced concrete and lined with stainless steel. The liner is attached to the concrete by welding to embedded plates and structural angles. In order to monitor leakage passing through the liner, there is a leak chase system that is connected to a 12 inch diameter vertical pipe that serves as the leak detection well. The leak chase system consists of several 1 inch square channels that connect to a 2 inch square perimeter channel. These perimeter channels are connected through a trench drain to the leakage detection well that is located outside the building north wall. The well extends down below the bottom of the pool to collect water leakage from any portion of the pool liner.

The licensee has determined through monitoring the level of the water in the well on a weekly basis that the leakage is about 5 gallons / week. The licensee has taken steps to prevent the possibility of leakage out to the environment by keeping the leak detection system drained below the lowest groundwater elevation. The water that is collected is periodically pumped from the monitor well to a collection receptacle and processed as radiological liquid waste. Consequently, the collected water is monitored leakage that is radiologically controlled and not an unmonitored release to the environment.

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Concern 3. The " plastic has never been tested for resistance to radioactive decay, which could be similar to ultraviolet decay."

-Answer:

The " plastic" is presumably the Amercoat " Nob-lock" membrane that surrounds the spent fuel pool basemat and walls up to the 12-foot elevation. To address this concern, it is necessary to provide some background information on the membrane. The plant design, as stated in the FSAR, specifies that the purpose of the membrane was to prevent groundwater from coming in contact with the concrete of the spent fuel pool (implicitly for protection during the construction of the pool). The NRC did not credit the membrane as a barrier ,

to prevent spent fuel pool leakage to the environs. We have attached pages '

9.1-5 and 9.1-6 of the FSAR that describe the design function of both the membrane and the channel leak collection system.  ;

With respect to the specific concern that the " plastic has never been tested for resistance to radioactive decay," the question. is moot since neither the licensee nor the NRC credits the plastic to prevent leakage.

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'FROM: ORIGINAL DUE DT: 07/25/97 TICKET NO: 0970106 DOC DT: 06/09/97 NRR RCVD DATE: 06/27/97 J. ROBERTUS, CAL / EPA TO:

M. FIELDS

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FOR SIGNATURE OF : ** YEL **

g{y QJ DESC: ROUTING:

RADIOACTIVITY AND SEISMIC CONCERNS AT SAN ONOFRE COLLINS NUCLEAR GENERATING STATION (SONGS) MIRAGLIA ZIMMERMAN MARTIN TRAVERS BOHRER ASSIGNED TO: CONTACT:

DRPM SLOSSON SPECIAL INSTRUCTIONS OR REMARKS:

DUE TO NRR DIRECTOR'S OFF;CE i h g LL L+ .

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N, ' Junh 9, 1997 g. g Mr. Mal Fields

!- . Project Manager # ,

l CaFEPA US Nuclear Regulatory Commission . fg Peu W son

• Documents Control Desk '" '

l Sam Diego Washington, DC 20555 Regiort Water Qrlity Control

, Bo:rd

Dear Mr. Fields:

9771 Clairemont Mesa RADIOACTIVITY AND SEISMIC CONCERNS AT SAN ONOFRE NUCLEAR Bhd., Suite A San Diego,CA 92124 GENERATING STATION (SONGS) 19)$ -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 seismologist, 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 l and surface waters within its area of jurisdiction. The l 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 I discharge of wastes from SONGS through the issuance of a l National Pollutant Discharge Elimination System (NPDES) l permit. That permit implements state water quality i 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.

If you have any questions, please contact Mr. Paul J.

Richter of my staff at (619) 627-3929.

Respectfully, I$Mw/O ~

HN H. ROBERTUS

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5xecutive Officer Enclosure cc: Ms. Patricia Borchmann Ms. Catherine Kuhlmann, UbEPA Region 9 (w/ enclosure)

Ms. MaryJane Johnson, SONGS (w/ enclosure)

File: 13-0087.02 11111111ll!11EI!!!

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State of California (Do) '1 Regional Water Quality Control Board San Diego Region

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9771 Clairemont Mesa Boulevard, Suite A  !

San Diego, CA 92124-1331 RE: Oral Cnamunication - JNQCB Board Neeting May 21, 1997 Request Jaesolution of support for following, either in I portions deemed appropriate, or in their entirety:

1. Initiate independent testing and monitoring of conditions at

-' SONGS, to verify if reliable, but unconfirmed reports of offsite surface and subsurface migration of radioactive substances have been released beyond the containment structure and fuel cooling ponds, (including tritium.and borate crystals), OR:

2. Insist that the NRC and FEMA. do their duty, and conduct an 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 public interest, by either disproving the unconfirmed release of radioactive substances from SONGS either occurred, or continues to occur, or if so,to apply immediate remediation measures. l 1

3. A Petition to NRC was filed in October 1996, by 9 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  ;

-) direct NRC T FEMA to conduct updated testing and analysis 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 worst case scenario conditions.

B. REASON FOR REQUEST

l. Upon review of the Emergency Management Plans for both San Diego and Orange County, it appears there are at least a few i) obvious fundamental flaws, which are a basis of my past challenge

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to the plants' renewal license: Adequacy of emergency evacuation plans.

a) Flaw #1 - Circulation / traffic analysis assumes no more than one (1) vehicle per household will be used during an emergency evacuation. ,

j b) Flaw #2 - Road capacity - Even though the analysis is supposed to assume worst case scenario conditions such as flooding, the circulation capacity analycis assumes there will be l no lane closures during flooding conditio.ns. Based on  ;

conditions during the flooding in Laguna in 1994 following fires, 1 the assuption of no lane closures is fundamentally flawed.

It is almost certain that an independent updated seismic study, and evacuation analysis would prompt recognition of the need for substantial upgrades in the current estimates for manpower under the various Mutual Aid Agreenents and EOC mandatory training for public employees working in agencies.

C. BACKGROUND My name is Patricia Borchmann. I am here as a concerned citzen 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. ,

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 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 cubstances, I am honestly very skeptical of this critical paradigm (public safety being the

, highest imperative). It is likely to be maybe really the scam

of the century, and the next century, who will inherit this dilemma, unless constructive action is taken immediately.

v , ,-

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 i indirect authority, may make recommendations to NRC issues within I this Agency's purview, such as water quality. Therefore, I j 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 SEISMIC RISKS AT SAN ONOFRE NUCLEAR GENERATING STATION INTRODUCTION The Emergency Petition for an emergency shutdown of San Onofre Nuclear ggy Generating S({;gion (SONGS) has been pending for several months. It has now been split into two seperate 'equests.

r One is for the removal of all Spent Fuel out of the Southern California seismic Zone. The other is for the 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.

The Design Basis Event for Units 2 & 3 is only 0.679'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, 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 towithstand 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 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 teport 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

( 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 just to igggedible to believe,qgge 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.

San Andreas are totally unknown, but even with a probabalistic approach, it j 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 i per year means several tens of feet offset along a great distance of fault.

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. l 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. I Their are so many earthquake faults, and probably many more yct to be found,

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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, l

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let alone in an old Spent Fuel Pool at the beach. Millions of people are f

9 "- 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 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 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 Deen 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 Puel 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 mannur. 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 a great quake but not if everything is radioactive. This risk is simply not dew something tNND any government agency can " License" and force citi: ens to take. Costs of this project should be paid by the covernment 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 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 l many years available.

Time has run out for the current staus-quo at SONGS and emergency action must be taken.

Stephen Dwyer

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. smdewdc. net f*

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From: PAUL BLANCH <PMBLANCH9IX.NETCOM.COM>

To: " DAVE LOCHBAUM" <dlochbaumeucsusa.ucsusa.org>,

" ROSEMARY" <ROEeAFR-OLT.COM), " PAUL GUNTER" <pgr.ntereigc.apc.org>,

" JIM RICCIO" <JRICCIOeMINDSPRING.COM>, "JON BL'.)CK" <JONBOSOVER. NET > .

Subject:

Re: TRITIUM IN THE SAND Sent: 1/31/97 7:21 PM Received: 1/31/97 6:34 PM From: stephen dwyer, smdewde. net To: PAUL BLANCH, PMBLANCHeix.netcom.com CC: GLEN MILLS, MILLSGLENemsn.com I

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 contaminated shows that its l

leaking substantial amounts of radiation out, even as the water levels remain as planned. l 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  ;

I who are responsible.

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 i

even bring the fluid wastes from Rocky Flats Arsenal to CA to cool the rods etc. :-(

I am especially concerned that on the one hand they say the rods, pins, 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 done safely, even rod by rod or whatever? If so then they don't have that excuse for leaving them at San onofre ,any longer. The risks of leaving them there are greater than the risks of moving them aawy from millions of people and this vital environment to the desert at Nevada Test Site etc.

Sincerely, Steve Dwyer smdtwdc. net you can forward this John:

I have been reading some of the communications with the " Monitor Well" at the SONGS 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

. 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 i

" Defense in Depth?"

From: PAUL BLANCH <PMBLANCH3IX.NETCOM.COM>

To: "JZ" <JAZWOL3aol.com>, "JZ" <JAZ@tTRC . GOV >

Dear John Zwolinski,

The monitor well is really a basement structure under the SFP.

The problems with it include:

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 placed '

under typ. concrete slabs. Radiation decay of this is unknown. ,

3. Something is leaking somewhere, since beach sand was removed to

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white crystals of borates? are showing up on the adjacent soil.

,4. No one seems to monitor or test this either.

p.-,/,, 5. Some new monitoring plans are in progress, what exactly I, don't know.

6. The SFP was cracked (Quake?) and was epoxied up. The structural integrety has declined and it will fail worse next quake or settling.

7. Settling in an adjacent well ( 200 feet deep water well) right there

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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.

B. Various failure scenarios could occur during big quakes resulting in  !

l unacceptable doses to the public" whatever that means, it doesn't l sound good.

l 9. Osmotic pressure of the concentrated boric solutions is greater than I l the

! fresh water outside therefore it can migrate up the hydraulic gradient.

10. Spent fuel at SONGS 1 SFP is not scheduled to be removed until 1999, j and l final shipments are not sched. until 20131 i

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 j clcser to .

500,000 lbs(correct me if I'm wrong) and will take most of the next l century  :

l I

, to remove. This time frame also includes the time fraoe of the next Bigone on the S. San Andreas Faulti  ;

We are working on this and other seismic analyses at SONGS, but our work l will not be completed soon, due to various delays.

l I don't recommend living around here. .

l Steve Dwyer j smdewdc. net ps Paul, you can forward most of what I send you.

l except our upcoming plans or stategies. 1 l

l At 09:39 PM 2/2/97 -0000, you wrote:

Paul M. Blanch

! Energy Consultant l

135 Hyde Rd.

West Hartford CT 06117 Tel: 860-236-0326 Fax: 860-232-9350 l

l

Subject:

SONGS SEISMIC

Date

Wed, 19 Mar 97 12:36:16 -0000

{ x-sender: PMBLANCHapopd.IX.NETCOM.COM

From

PAUL BLANCH <PMBLANCH9IX.NETCOM.COM>

! . To: " undisclosed-recipients::"

[ ,.

t NUCLEAR REGULATORY COMMISSION

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• \,, AR LINGTON, TEXAS 76011 8064 March 8. 1996

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Ms. Patricia Borchmann

. 176 Walker Way Vista, CA 92083 ,

i

Dear Ms. Borchmann:

I am in receipt of your letter of February 19, 1996, to me in which you raisec concerns regarding tl]e San Onofre Nuclear Generating Station. This letter supplements a brief response sent to you on February 20 by Mr. Mark Hammond, an NRC public affairs officer who works in our Walnut Creek Field Office. I understand that Mr. Hammond also discussed your concerns with you by telephone.

The Nuclear Regulatory Commission's Systematic Assessment of Licensee Performance uses ratings of superior, good and adequate. It does not provide for an inadequate rating. Any plant which the NRC judges inadequate in its overall safety or regulatory performance would not be allowed to operate.

The use of the word " inadequate" in the North County Times in its February 18 article was the newspaper's. It should not be construed as relative to the SALP process.

You also addressed evacuation routes for the San Onofre plant. The evacuation routes for San Onofre are part of a set of emergency response plans developed and maintained principally by the California Office of Emergency Services, Orange County, San Diego County and Southern California Edison Corp. Other federal, state, county and municipal agencies are also involved. The emergency response plans were reviewed and approved by the Federal Emergency Management Agency (FEMA), the lead federal agency in offsite emergency planning and response. Before issuing an operating license for San Onofre Unit 2 in September 1982, and for Unit 3 in September 1983, the NRC reviewed '

and accepted FEMA's assessment.

Reactor licensees are required to conduct studies to estimate the time needed to evacuate the public from the area surrounding each power plant. The results of those studies are incorporated in emergency response plans and are l used by regulatory personnel and emergency planners to assess the ,

effectiveness of prote:tive responses for the public. The time required to evacuate the public from a 10-mile emergency planning radius is estimated by analyzing the available transportation facilities and other relevant  ;

conditions within the radius. Data is collected and assumptions made regarding the transportation facilities, the size and characteristics of the population and other conditions in the planning zone. Guidance in standard approaches to assembling this info'rmation is provided in an NRC publication,

" State of the Art in Time Estimate Studies for Nuclear Power Plants,"

NUREG/CR-4831.

9204190452-970609 3 PDR ADOCK 05000206 D,^

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,, 1 i 6 Ms. Patricia Borchmann ,

'* A broader perspective on emergency planning in general is provided in

" Criteria for Preparation and Evaluation of Radiological Emergency Response i Plans and Preparedness in Support of Nuclear Power Plants," NUREG-0654, a

joint effort of the,NRC and FEMA.

! Should you wish, those documents, as well as the complete set of emergency

response plans for San Onofre, are available at the Local Public Document Room j for San Onofre, Main Library, University of California at Irvine, Irvine, CA 1 (714) 824-7234.

j Sincerely, i

! L. J . Callan j Regional Administrator 1

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