Exhibit G-3, Volume 2, Comments Received at Public Meetings, DCISC 18th Annual Report - July 1, 2007 thru June 30, 2008
This exhibit provides summaries of comments received by the DCISC from members of the public at public meetings. The full text of the meeting minutes can be found in Exhibits B.3, B.6, and B.9.
October 24 & 25, 2007 Public Meeting
There were no comments from members of the public at the October 24 & 25, 2007 DCISC Public Meeting.
January 23 & 24, 2008 Public Meeting
There were no comments from members of the public at the October 24 & 25, 2007 DCISC Public Meeting.
June 25 & 26, 2008 Public Meeting
Mr. Paul Allen, retired from the San Luis Obispo Air Pollution Control District in 2006, after 29 years in an emergency response capacity with that District including involvement with DCPP, had an issue relating to the accuracy of the Meteorological Information and Dose Assessment System (MIDAS) dispersion model for the path of a plume of radioactivity in the event of a release by DCPP: the MIDAS system being used by DCPP was inadequate beyond a distance of approximately five miles from the plant. This issue has been reviewed previously with PG&E.
The MIDAS version used by DCPP for the last twenty years is designed for a single data input, the data input point being the plant itself. PG&E is the only nuclear utility using a MIDAS single input model. Air flow characteristics in the San Luis Obispo area are complicated, but tracer studies done in 1986 were excellent.
He provided a written report prior to making his remarks to the Committee. A copy of that report was also provided to PG&E’s representatives present.
A 1997 report had determined that the data provided by MIDAS was inadequate in that Doppler detection devices previously used in the local area were no longer useful due to obsolescence. Monitors used in the Emergency Operation Facility to display the path of a plume would likely be inaccurate due to MIDAS’ inadequacies. Field monitoring personnel could also be placed at risk due to MIDAS inadequacy. He was concerned about a loss of institutional knowledge about MIDAS due to retirements of both PG&E and Air District personnel.
Fixing MIDAS might involve purchasing a different version of MIDAS with multi input capabilities and maintaining off site monitoring facilities. This would enhance public safety and PG&E could do a better job with a more capable MIDAS.
Mr. Allen was with the Air District when letters and reports were exchanged with PG&E following drills and exercises which were coordinated with the County Office of Emergency Services, but the issue was not raised with the Nuclear Regulatory Commission (NRC). Mr. Allen would defer to PG&E meteorologists concerning the adequacy of the former Doppler sites, including the PG&E Community Center on Ontario Road which was an important site in the past when the Doppler systems were functioning. The 1986 Tracer Study was performed by a nuclear laboratory in Idaho Falls and some data might be available from that source. The Chair thanked Mr. Allen for an excellent expression of his concerns and stated the Committee would take a look at the issues and come to a conclusion. [Subsequently, the DCISC scheduled a review of this issue at its August 27-28, 2008 Fact-finding Meeting at DCPP and at its October 7-8, 2008 Public Meeting.]
[The following is a review of PG&E’s response to a letter from member of the public Gary Talley regarding a sunken ship off the coast and possible oil leakage effect on DCPP operations.
Mr. Bryan Cunningham, DCPP Environmental Operations Supervisor, reviewed the statistics and construction information for the Union Oil tanker, S.S. Montebello, built in 1921 as a shelter deck tanker of riveted steel construction with 9 liquid cargo holds and a length of 457 feet, a beam of 58 feet and a gross tonnage of 8,272. The Montebello was sunk by a torpedo from a Japanese submarine on December 23, 1941, approximately 6 miles off the coast at Cambria, California in approximately 900 feet of water. In 1996, the wreck was discovered and inspected by submersibles and photographs and video footage of the condition of the ship was obtained. In response to a question from Dr. Rossin, Mr. Cunningham stated that no inspection has been conducted of the interior of the wreck.
In 2003, the Monterey Bay National Marine Sanctuary Shipwreck Monitoring and Site Characterization Program performed a hull integrity assessment of the Montebello. The general condition of the wreck indicates the torpedo struck a forward compartment which was dry at the time of the impact. The Montebello’s cargo holds and 90 of its hull remain intact. The bow of the vessel impacted and is buried in the sea floor and the hull is fractured at the forward torpedo zone impact. The stern section of the vessel settled upright and flat on its keel. The wreck has now been partially covered by fishing nets.
Oil leaks were not detected during the 1996 or 2003 inspections, nor was evidence of seepage found in the surrounding wreck site. Colonies of beggiatoa bacteria, which are hydrocarbon decomposers, were not detected. The ship’s structural steel will continue to decompose due to prolonged exposure to seawater.
The Montebello was carrying a cargo of 73,571 barrels, or 3,089,982 gallons, of ‘Santa Maria’ crude oil when it was sunk in approximately 8 individual cargo holds with 8,174.5 barrels in each. This oil would be very viscous at room temperature, in a semi solid state, and would have required heating in order to freely flow into a tanker’s cargo hold. The specific gravity of the oil is 0.923, which would make the oil float upon the surface of the water if released. The lower specific gravity of gasoline is 0.72 and of diesel oil 0.85 would make them float better than crude oil. Due to the cold ocean temperature at the wreck site, it is expected the oil would be in a semi-solid or solid state at present.
The expected consequences in the event of a hull/cargo breach as follows:
Oil should initially remain relatively intact within the wreck in a semi-solid or sold state around 30-40ΕF temperature range.
Hydrocarbon decomposing bacteria will quickly colonize and degrade oil within the hull and the surrounding wreck site.
Emulsification will likely occur at the seawater/oil interface and result in seepage or chronic release with heavier hydrocarbon components sinking and lighter components likely reaching the surface, possibly causing localized water toxicity at the wreck site.
An acute, sudden release of a large volume of oil from the cargo of the Montebello is not expected as individual cargo hold integrity is likely nor are the individual cargo holds likely degrading at a uniform rate.
In the unlikely event of a substantial acute liquid-oil release, in the most common current and wind conditions for the area the oil would likely migrate toward and make a landfall along Estero Bay, north of DCPP. The California current offshore in the vicinity of the wreck generally sets to the south or southeast, while the prevailing winds blow from the northwest, turning inland along the coast. The oil would likely be more driven by wind and travel faster than by the current. The lighter the winds, the more oil would likely be driven out to sea. In conditions which would direct the oil past Point Buchon, also to the north of DCPP, those same conditions would favor a bypass of DCPP. In the unlikely event the oil release reached the area of DCPP, it would have taken several days to reach the plant, giving DCPP time to prepare and respond appropriately. Such response would include requesting direct assistance from marine oil spill response and containment resources from the Long Beach or San Francisco Bay regions. The DCPP staff would have time to plan for the possibility of a power reduction to significantly reduce the plant’s ocean cooling water requirements. Were the Intake Structure, which faces away from the area from which the Montebello’s oil would originate, directly threatened, all four main seawater circulators could be stopped thereby reducing cooling water flow by 98.7 and eliminating the majority of current into the Intake Cove; floating surface oil would be blocked by the Intake Structure curtain wall which extends 7.75 feet below mean sea level; and the heavier petroleum components suspended in water would generally congeal into globules of seawater and be captured by plant screening systems. It would be possible to deploy booms across the Intake Structure or the Intake Cove and these methods could be used in the event of an oil spill caused by an accident to a tanker offshore, although vessels generally remain 15-20 miles off the coast when transiting this section of the California coast.
The Montebello wreck is relatively intact on the sea floor, with its remaining cargo of heavy crude oil expected to be solid of semi solid at the deep ocean temperature. An acute release of liquid-oil from the wreck is not expected, although eventually hull or cargo hold deterioration can result in seepage. In the unlikely event of a substantial oil release, the oil slick is expected to migrate toward Estero Bay or, should conditions permit, past Point Buchon, thereby in either event bypassing DCPP. Should the oil approach DCPP, mitigation measures are available. The state would likely take quick action before any oil actually reached the beaches.
Gary Talley, who wrote the letter to the Committee, a resident of Cambria, California, displayed a photograph of the Montebello. Mr. Talley thanked the DCISC for its assessment of this threat and stated it was his opinion nuclear power is safe power but he was concerned by the threat. His past experience was as a safety engineer and that he also has experience as a diving instructor. He was concerned for the entire central coast of California due to the possibility of oil leaking from the Montebello wreck site. He briefly reviewed the effect of the oil leak from the Exxon Valdez spill in Alaska although he acknowledged the volume of oil in that event was much greater than the oil within in Montebello. He stated there was risk to wildlife from the potential oil leak. He noted that the Montebello was constructed some 9 years after the Titanic and shipbuilding techniques were primitive.
‘Hot Tap’ techniques could be used to pump the oil out of the wreck thereby removing the threat. The U.S. Navy has done this before with sunken vessels. He estimated the coast of such a cleanup would be less than the potential losses to tourism, etc. at those locations which could be impacted by an oil release. Mr. Talley stated that 8,000 barrels of oil, if cleaned, could be worth approximately $11.4 million at current oil prices. He plans to try to convince the Navy to work with the National Oceanic and Atmospheric Agency (NOAA) and with the Monterey Bay Marine Sanctuary, elected officials and the DCISC to save the central coast from what he characterized as an ecological time bomb, the danger from which can be measured by the few millimeters remaining of the Montebello’s hull. The Chair thanked Mr. Talley for his letter and his comments.
[The DCISC was satisfied that the safety of DCPP is not threatened by the sunken ship, and this review closes the DCISC investigation of this issue].
Ms. Jill Zamek, with the group San Luis Obispo Mothers for Peace, distributed to the Committee and PG&E and read for the record from a letter to the NRC’s Region IV administrator written by Ms. Morgan Rafferty, also a member of San Luis Obispo Mothers for Peace. The letter contained the following information and allegations: workers perceive raising safety concerns at DCPP carries a high likelihood of retaliation by management including receiving a poor performance evaluation following a worker raising an issue within the DCPP Differing Professional Opinion Program concerning the adequacy of set point methodology for the SGs, thereby creating a chilling effect on workers raising safety concerns; DCPP workers have lost trust and confidence in the fairness and confidentiality of the Employee Concerns Program and believe it to be biased; PG&E is filling supervisory positions, including the director of Quality Assurance position, at DCPP with individuals who do not meet required qualifications and is altering the final safety analysis section text to match the individual’s lesser qualifications; and PG&E is again violating 10 CFR Part 50 Appendix B by failing to promptly correct, for budgetary reasons, known deficiencies concerning reverse rotation of the containment fan cooler units (CFCU) for both units. Ms. ZamEk reported the NRC responded to Ms. Rafferty’s letter on May 8, 2008, and she provided a copy of the NRC letter, and stated an evaluation of the concerns expressed therein should normally be completed within six months. The Chair thanked Ms. ZamEk for her comments.
[The DCISC had previously received this letter and related others from Ms. Rafferty and had reviewed the safety issues regarding the CFCUs a number of times over the last several years, most recently at its April 16-17, 2008 and May 20-22, 2008 Fact-finding Meetings. The Committee’s assessment was presented earlier in the June 25-26, 2008 Public Meeting. The Committee is satisfied that DCPP has appropriately addressed all CFCU safety issues.]
Mr. Roy Cinowalt, a retired pipe fitter, had toured DCPP 16 or 17 years ago. He was exceedingly impressed by what he observed during the morning tour of DCPP including the oversight, the quality of the plant and its personnel and the interest DCPP personnel take in their jobs. He stated certain people and newspapers seem to constantly attack and allege conspiracies without offering reasonable alternatives. Mr. Cinowalt stated he did not agree with that sort of thinking and that many people in the community believe in DCPP and its operation and integrity. The United States should forget about coal and, like France, move toward more nuclear energy. The Chair thanked Mr. Cinowalt for his comments and commented for the record that the DCISC is independent of PG&E and DCPP workers work for PG&E and the DCISC has no authority or control over DCPP’s employees.