By John Stang
The Nuclear Regulatory Commission this week formally rejected an advocacy organization’s latest petition to halt decommissioning of the retired San Onofre Nuclear Generating Station. (SONGS) in California.
On Feb. 5, San Diego-based Public Watchdogs submitted a 2.206 petition to the NRC that provided a long list of reasons that decommissioning at SONGS must stop due to unanswered questions about 123 canisters of spent nuclear fuel stored next to the Pacific Ocean. A 2.206 petition is a bureaucratic avenue for outside groups to request enforcement action by the federal agency.
The Petition Review Board has determined the issues raised in the organization’s filing have been previously addressed by the agency, according to a letter Tuesday to Public Watchdogs Executive Director Charles Langley from Kevin Williams, director of the NRC’s Division of Materials Safety, Security, State, and Tribal Programs.
“The NRC staff remains confident that there is reasonable assurance that public health and safety is protected and that measures are in place to ensure that fuel is stored in accordance with the requirements of the SONGS license and with the certificate of compliance for the Holtec UMAX system and that other licensing requirements are maintained,” Williams wrote.
Public Watchdogs has the option of filing a lawsuit addressing the rejected arguments in federal court.
“The NRC either mischaracterized or misunderstood or our 2.206 Petition to Revoke. We are evaluating the situation and weighing our options. We may choose to give the NRC an opportunity to correct its mistakes before we take this issue to the next level,” Langley wrote in an email to RadWaste Monitor.
SONGS majority owner Southern California Edison (SCE) retired reactor Units 2 and 3 in 2013 after they were equipped with faulty steam generators. Decommissioning of the two reactors is underway, a $4.4 billion job managed by SONGS Decommissioning Solutions. Disassembly and removal operations for buildings, reactor domes, and other structures recently began. SONGS Unit 1 closed in 1992 and has been largely decommissioned.
Critics of Southern California Edison have steadily contended that the spent fuel storage pad — now holding 3.5 million pounds of fuel — could be at risk of being flooded by rising sea water due to global warming or being inundated by a tsunami. The pad is 108 feet from the ocean and 18 feet above sea level. Also, critics are generally suspicious of Edison’s and its contractors’ abilities to carry out the decommissioning.
Mishaps in moving the fuel to the pad have increased local concerns about keeping highly radioactive material in a seismically active, densely populated region along the Pacific coast. Most notable was an August 2018 incident in which one used-fuel canister was left at risk of dropping nearly 20 feet into its storage slot. That event led to a nearly yearlong halt to the project while SCE and fuel-offload contractor Holtec International made improvements to their processes, and also drew a $116,000 NRC fine of the utility for violation of nuclear safety rules.
Last year, Public Watchdogs and Oceansiders Against San Onofre Corruption submitted separate 2.206 petitions on SONGS. Public Watchdogs sought an immediate halt to decommissioning of the reactors, saying the NRC had breached federal law and its own rules by not conducting further environmental review before allowing the work to proceed. Oceansiders’ petition asks the federal regulator to revoke a 2015 California Coastal Commission permit allowing for expansion of SONGS’ dry storage pad to hold the used fuel from Units 2 and 3.
In December 2019, the NRC told both groups that previous environmental impact studies by the agency on SONGS’ decommissioning covered all the pertinent issues and that new assessments would not cover any additional ground. Public Watchdogs’ efforts to revive those particular issues have been unsuccessful.
Last February, Public Watchdogs filed an additional 2.206 petition that said flooding from the Pacific Ocean could cause SONGS’ spent fuel dry storage site — 18 feet above sea level and 108 feet from the ocean — to “erupt with deadly radioactive steam geysers.”.
The specific mechanism for that to happen would involve water flowing between the walls of the vertical apertures used for storage and the canisters that contain the spent fuel assemblies, Public Watchdogs said. If the water seeps into the canisters themselves, a criticality — an uncontrolled burst of radioactivity — could occur, the petition says. The exteriors of the canisters are 452 degrees Fahrenheit, so the introduction of cold ocean water would convert into steam, which could be radioactive and erupt like a geyser, the press release contends.
Public Watchdogs wants decommissioning activities stopped, including movement of the spent fuel to dry storage. Since the offload of fuel from the two reactors was completed late this summer, that issue is now moot. Among other requested actions in the petition are preparation of countermeasures against flooding and revoking exemptions on emergency preparedness requirements from 2015.
Following the initial filing, the NRC informed Public Watchdogs in April that the Petition Review Board had made an initial determination against taking the petition for review. That was followed by a June teleconference in which Langley presented additional data to make the case for a review. He supplemented that with a July email.
Williams’ Tuesday letter said all of public Watchdog’s concerns have been addressed in earlier studies by the NRC and Southern California Edison.
In the letter, the NRC said the flooding scenarios have been studied. The conclusions — relayed to Public Watchdogs last February — are that used-fuel casks would remind intact, with the fuel being kept safe if flooding occurred. The possibilities of breaches and corrosion were analyzed, and found to be unlikely in a flooding scenario, the agency said.
The letter added: “Total stresses for the combined loads of normal, off-normal, accident, and natural phenomena events are acceptable and are found to be within limits of applicable codes, standards, and specifications.”
