Monday, December 3, 2012

[SDCPJ] Citizens Oversight Intervention Hearing w/ NRC, Wednesday, December 5, 2012

On Wednesday, December 5, there will be a Pre-hearing proceeding on San Onofre License Amendment Intervention by Citizens Oversight (COPS) before the Atomic Safety and Licensing Board Panel in its Rockville Hearing Room, located on the third floor of Two White Flint North, 11555 Rockville Pike, Rockville, Maryland. Ray Lutz, representing COPS, will be participating by teleconference at an NRC-scheduled room in downtown San Diego. Hearing length less than three hours. 

IN SAN DIEGO:  PRESS CONFERENCE by Ray Lutz at 9:00 a.m., with 10:00 a.m. Webcast Viewing avai
lable, at the World Resources SimCenter, 10883rd Ave., SD 92101 near San Diego City Hall. Ray will also be available after the hearing for questions at the WRSC (allowing for transit time from the teleconference room in Little Italy). (NOTE: free parking at Horton Plaza w/ validation begins at 9:30a, if you enter before 9:30a you get only 30 minutes free parking and it doesn't require validation.) 

Raymond Lutz, Electrical Engineer and Founder of Citizens Oversight, prepared the petition to intervene based on a review of the proposed changes to the operating license of San Onofre. The proposed changes to the license do not directly reflect on the recent emergency shutdown on January 31, 2012, and furthermore, is not in response to the proposal by SCE to operate San Onofre Unit 2 at a lower power level despite massive and severe damage to the steam generator tubes due to excessive vibration.

Instead, the proposed license amendment makes a large number of changes throughout the technical specifications of the operating license. Most of these changes are quite similar in nature: they remove explicit requirements for inspections from the operating license and move these to a separate document which is no longer under the control of the NRC, but is under the control of the licensee, and therefore, it can be changed "at will" by SCE without any notice to the public, opportunity to intervene or request a hearing.

Citizens Oversight believes these changes unnecessarily obfuscate the specification and puts inappropriate trust in the licensee to keep the inspections at a safe level. They rely on the Surveillance Frequency Control Program (SFCP) which utilizes Probability Risk Assessment (PRA) calculations using a set of preconceived failure modes. Such analyses are subject to well understood knowledge-based failure mechanisms of "overconfidence" and limited failure scenarios known to underestimate the variety of failure mechanisms.

An argument will be made by SCE attorneys that the specifications of surveillance frequencies have not changed, since the values of maximum time period between inspections will initially be the same. But under the proposed changes, the licensee can vary these periods without any review by NRC or the public thereafter, and there are no "not-to-exceed" values specified in the specification. Furthermore, moving these values to another document obfuscates actions required by the licensee and may induce operator error as workers search for the correct value in multiple documents.

COPS also objects to many other changes proposed, including allowed leakage from the steam generators into the atmosphere, the fact that the isolation area around the plant is not enforceable, and numerous specification mistakes.

To the knowledge of COPS, no other organization is actively objecting to the license amendment request.

COPS requested that the event be held near San Onofre, but they refused to hold it so that local residents can attend, although the proceeding will be open to the public in Maryland, and SCE attorneys and NRC staff will be attending in person. COPS representatives will be attending the meeting using a video- conferencing link with details to be determined, and although the NRC is not accommodating participation by the public, COPS is grateful to the World Resources SimCenter for working with us to set up a viewing room nearby, as well as hosting the Press Conference before, and Q&A after.
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