Wednesday, October 31, 2012

Why San Onofre Cannot Safely Be Restarted

The DAB Safety Team's Press Release 10-29-12

The DAB Safety Team has now published the differences in their damage assessment between San Onofre Replacement Steam Generators (RSG’s) Unit 2 and 3, and on the causes of Failure, due to operational parameter’s, that have not been explicitly identified either by SCE, MHI, their Outside Experts’ or the NRC.

San Diego, CA (Oct. 29, 2012) – The DAB Safety Team has just released their analysis of SCE’s SONGS Unit 2 Return to Service Report which is titled:
Overview - Consequences of a Main Steam Line Break, which describes why San Onofre’s RSG’s cannot be safely restarted even at reduced Power.

Additional Documentation:

Thank You
Don Leichtling
- The DAB Safety Team

SCE’s Problem: The DAB Safety Team has concluded that SONGS Unit 2 RSG's suffered moderate damages compared with the severe damages to Unit 3 RSG's. This is because compared with Unit 3, Unit 2 RSGs were determined operating at Higher Secondary Pressures (30-100 psia) and lower reactor thermal power (Unit 3 - 1186 MWe & Unit 2 - 1183 MWe).  This DAB finding was confirmed based on review of Plant Operational Data, Plant System Descriptions, conversations with several anonymous Plant Personnel, Preliminary Engineering Calculations and review of the NRC AIT Report). 

Two Questions Reporters Might Like To Ask:

1.     Did the Region IV NRC AIT Team ask SONGS Engineers and Shift Managers why were they operating unit 3 at lower secondary pressures and higher reactor thermal power levels compared with Unit 2 RSGs. What drove them to make this change?  Did they seek Operations management approval?  Did they understand the implication of this change?  Do they understand now what they did wrong and will they admit it?

2.     Has the NRC checked the SONGS Operational Records and Calculations to independently verify that SONGS Unit 3 RSG’s tubes did not leak because SONGS Unit 3 RSG’s were producing more thermal power than the 3438 MWt allowed by their Technical Specifications.  Was the Net Reactor Thermal Power of 3438 MWt exceeded at any other time(s) in violation of SONGS Technical Specifications?

Note: For additional information and all the future DAB Safety Team's San Onofre Papers just click, then bookmark their TAB located at top of this great Decommission San Onofre website. 

Sunday, October 28, 2012

CPUC Investigates San Onofre

The California Public Utilities Commission (CPUC) had managed to prevent most of us from speaking, but after listening to one Chamber-of-Commerce speaker after another take up the speaking time to say the same thing -- that San Onofre is "safe, reliable, affordable energy" (it's none of those) Gary Headrick managed to force his way to the podium by dint of having nearly half the audience there to support him. He was followed by an eloquent 13-year old from Idyllwild, Zora.

Those two presentations, the vote, plus our speakers for the press conference afterwards are all presented here.

Speakers: Gary Headrick, Zora, CPUC, Ray Lutz, Gene Stone, Donna Gilmore, Ace Hoffman

Video by @AceHoffman

What Integrity Looks Like 

Wednesday, October 24, 2012

Today San Onofre Siren Test & Mode 3 Testing

Recorded at a Nuclear Regulatory Commission Public Meeting October 9th, 2012

 Note #1: Mode 3 testing was begun approximately one week later. Ongoing Today!

 Note #2: The girl in the blue shirt trying to get called on... never was. This happened to a lot of people that night.

 Video by Ace Hoffman

Monday, October 22, 2012

San Onofre Leaking Hydrogen


"The control room was notified that an unknown quantity of H2 gas (classified as a minor coupling leak [identified with Snoop liquid leak detector]) is currently being released to the air from the Unit 2 Full Flow Hydrogen skid. "The Environmental Protection Group reported the leak to the California Emergency Management Agency (Cal EMA) at 0809 PDT and the San Diego Department of Environmental Health at 0812 PDT lAW [plant] procedure S0123-XV-17.3, 'Spill Contingency Plan'. The Hydrogen Gas leak is currently still in progress. There is no gas collection areas. Maintenance is in the process of taking action to terminate the leak."

The licensee notified the NRC Resident Inspector.

Friday, October 19, 2012

10-18-12 SCE's RSG Testing Update + New NRC Blog Topic

The NRC has just posted this new topic on their blog site:
In Response to Your Letters: Proposed Restart of SONGS Unit 2

by Allison Macfarlane
NRC Chairman

You are encouraged to add your own comments, but be advised that moderation/posting is glacial!

====== 10/18/12 RESTART NEWS UPDATE =====

Information Concerning SCE's Ongoing RSG  Restart Testing At SanO:
I saw this info and I've had this email conversation with NRC Region IV about it:

(I saw this on Oct. 17, 2012 and sent it to the NRC)

I saw this posted on Twitter today and wanted to forward it to you, in the hope that it is not factual, because if it is, then the NRC has more problems at San Onofre than just damaged and leaking SG tubes...

This was posted on Facebook:
"ACTION ALERT! San Onofre Nuke Plant could Re-Start Within 10 Days!
From a whistle-blower at San Onofre nuclear plant in Southern California: "We are working on Unit 2, bringing it up from Mode 5 to 4 and are preparing to go from Mode 4 to 3 by the weekend of October 20th. Southern California Edison (SCE) brought in the auxiliary boiler (which runs off of oil), and assigned 12 hour shifts. SCE are making damn sure that no steam leaves the domes for fear the public will catch on. I can’t believe how audacious they are, but for all practical purposes, they are going to restart Unit 2—which still is highly radioactive—without the NRC thoroughly reviewing Edison’s application that was just submitted. Their motivation is to see if they fixed the new reactor head which leaked profusely the first time they tried it. They don’t want anything holding them back from actually restarting when they get the green light from the NRC. The NRC’s Confirmatory Action Letter allows them to take it up to Mode 3 because the reactor is not “critical”, (fission reaction is on hold). They are trying to beat the clock before time runs out on them and the CPUC (California Public Utility Commission) sticks Edison with the cost of the outage instead of the ratepayers.” -M

Question: Has the NRC approved this new TESTING, (as it was my understanding that there would be no restarting until the NRC decided it was safe to do so)?   You should be able to confirm the validity of the above with a simple phone call to the resident inspector at San Onofre...

Hopefully Mr. Elmo Collins will honor his quote, "We don't experiment with safety"...

I look forward to your timely response, as I want to give the NRC a chance to comment before publishing the above.


I got this reply on Oct. 18, 2012:

Southern California Edison is permitted, by their license, and by the Confirmatory Action Letter issued March 27, 2012, to heat up and pressurize Unit 2 to normal operating pressure and temperature.  This heat up is being done using offsite electrical power.  This is NOT starting up the plant.  The safety concern with Unit 2 steam generators is the excessive vibration that occurs during high steam flow conditions in the steam generator, which may result in unexpected and rapid steam generator tube wear.  This cannot occur in the condition the plant is being taken to.  The steam generators will be hot, and pressurized, but there is no heat generation from the reactor, and the heat generation from the auxiliary boiler and reactor coolant (electric) pumps is very small and cannot produce enough energy to cause vibration in the steam generator tubes.  

The NRC has no concern with the structural integrity of the Unit 2 steam generator tubes today, in their current reactor shutdown condition.  The NRC is currently evaluating Southern California Edison’s proposal to restart the reactor.  This proposal states that Unit 2 can be operated, meaning it can start the reactor to produce the large amount of heat and steam flow for 70% of normal full power operation.  This amount of steam flow must be shown to not result in additional unexpected and excessive tube wear, or the NRC will not allow the reactor to be restarted. 

The reactor has not been, and will not be started up until NRC has granted permission.  The “testing” that is being referred to is normal testing that is allowed by the current license at San Onofre.  The “testing” that Mr. Collins was referring to is any test or experiment that is not currently an approved procedure and is outside the safety analysis as described in the facility Updated Final Safety Analysis Report.  As an example, the NRC would not allow the reactor to be restarted, producing the large amount of heat and steam flow, so that the licensee could monitor tube vibration to ‘see’ if excessive vibration is occurring – that would be a “test”.  The licensee must prove, with reasonable assurance, before starting the reactor, that excessive vibration will NOT occur.

Victor Dricks
Public Affairs Officer
U.S. Nuclear Regulatory Commission / Region IV


So I sent this reply yesterday:

Question 1 – Is the pressurized and hot reactor coolant (Any Amount) being circulated through SG 2E-089 under these test conditions?
Question 2 – Does the NRC postulate a MSLB outside containment under these test conditions?
Question 3 – If the answer to Question 1 and 2 is yes, does NRC postulate > 99.6 % steam voiding in the U-Tube Bundle?

 The public is going to ask ,"What is going on between Region IV and the NRC? People need the answers in a hurry.  Is the NRC more concerned about the Safety of The Public or letting Edison get away with whatever they want to do?  If NRC was strict from the very beginning with Edison, things would not have to come to this.  There is still time.  Here is a quote for your benefit, An anonymous participant in an Industry Conference was asking questions and persistently complaining about complex and unclear NRC regulations.  A NRC Branch Chief said, "Sir, to resolve any complex technical problem and understand unclear regulations, you have to, 'Read and reread in between the lines', use, 'Critical questioning and an investigative attitude' and 'Solid teamwork & alignment'."

I'll update this post, if I get any additional replies

Wednesday, October 17, 2012


The San Francisco-based California Public Utilities Commission on Tuesday published a draft investigation order regarding the idled San Onofre Nuclear Generating Station.

 It will take up the matter at a public meeting Oct. 25 in Irvine. 
                                                   --> Salute to UT's Morgan Lee

COM/MF1/sbf                                     DRAFT                              Agenda ID #11659 


Order Instituting Investigation on the Commission’s Own Motion into the Rates, Operations, Practices, Services and Facilities of Southern California Edison Company and San Diego Gas and Electric Company Associated with the San Onofre Nuclear Generating Station Units 2 and 3.




1. Introduction
We open this investigation to consolidate and consider issues raised by the extended outages of Units 2 and 3 at the San Onofre Nuclear Generating Station (SONGS). This includes determining whether to order the immediate removal effective today of all costs related to SONGS from the rates of Southern California Edison Company (SCE) and San Diego Gas & Electric Company (SDG&E), with placement of those costs in a deferred debit account pending the return of one or both facilities to useful service or other possible action. It also includes considering appropriate rate treatment for all SONGS-related costs in other proceedings.

This investigation will consider the causes of the outages, the utilities’ responses, the future of the SONGS units, and the resulting effects on the provision of safe and reliable electric service at just and reasonable rates. Due to the size, location, ownership structure, and unique nuclear licensing requirements of SONGS, the unexpected outages raise particularly complex issues. These issues come before us in many proceedings. This investigation will consider these issues in a consolidated manner that is efficient for the utilities, parties and the Commission. To facilitate that objective, all costs incurred on and after January 1, 2012 that are associated with SONGS shall be tracked in a memorandum account. SCE and SDG&E shall each, within 30 days of today, file with the Energy Division Director and serve on the service list a Tier 1 advice letter to establish that account, including specified subaccounts.

Tuesday, October 16, 2012

FOE --> San Onofre - Feds Stonewall FOE's Petition For Legal Hearing On Reactor Restart

Posted Oct. 16, 2012,           Salute to FOE!
WASHINGTON, D.C. --  The Nuclear Regulatory Commission’s continued refusal to consider a legally binding hearing on the future of the San Onofre nuclear plant has prompted Friends of the Earth to accuse the agency of failing to protect the public and of failing to follow its own rules and procedures. 
More than three months have passed since Friends of the Earth petitioned the NRC for a legally binding hearing on the future of the crippled plant. In that time, the NRC has failed to even schedule a discussion of the petition. Now that Southern California Edison has submitted a plan to restart one of San Onofre’s reactors, Friends of the Earth is reiterating its request that the NRC begin a license amendment process to determine if San Onofre is safe to operate and is asking for an emergency stay to keep the plant closed in the meantime.
In a letter to the NRC , Friends of the Earth said: “Time is being wasted.” The organization argued that that the Commission is not only ignoring the law but precedent in a strikingly similar case.

In 2002, the Palo Verde nuclear plant in Arizona – partly owned by Edison – replaced two steam generators of similar design to those used at San Onofre. Under NRC rules, when utilities replace major equipment with a revised design that affects the unit’s safe operation, the licensee must obtain a license amendment. Palo Verde’s operators did so.
In contrast, when Edison replaced the steam generators at San Onofre, the utility claimed it was “like for like” – so similar to the units it was replacing that no license amendment was required.  But Edison in fact made major design changes to the new steam generators that caused the equipment to degrade and fail after less than two years of operation.  These errors in design and the steam generators’ failure are now critical to the question as to whether it’s safe to operate either of the San Onofre reactors.
“It cannot be lawful for utilities to pick and choose the process they undergo,” Friends of the Earth wrote to the NRC. Friends of the Earth “seeks only that this Commission enforce its own rules in an even-handed manner. . . .  We submit that, consistent with its decision on the Palo Verde plant, its own regulations, and the Atomic Energy Act, the Commission, not the staff, must decide the point and must grant the petition filed by Friends of the Earth and convene a licensing proceeding to amend formally the license for San Onofre
CONTACT: Damon Moglen, (202) 222-0708 Dave Freeman, (310) 902-2147

Sunday, October 14, 2012

Update 10-14-12, SCE’s Replacement Steam Generator $680 Million Debacle

The DAB Safety Team’s - Update 10-14-12,  SCE’s Replacement Steam Generator $680 Million Debacle

1.   If SCE’s and MHI’s Engineers had used all the following guidelines, they would have prevented the
Replacement Steam Generators (RSG’s) catastrophic failures and they would not be in financial trouble with the SONGS Union Workers, the NRC, the Public, the News Media and their Ratepayers:

  • ·       Human Performance Tools, along with the NRC Branch Chief and the World’s Foremost Expert’s sage advice of “read between the lines', ‘use critical questioning & an investigative attitude', 'solid teamwork & alignment, and ‘read the academic papers on eliminating fluid elastic instability and flow-induced vibrations in nuclear power plant components.”
  •  ·       Benchmarked the design details of Palo Verde and other CE RSGs design details in order to eliminate any potential fluid elastic instability and or flow-induced vibrations experienced in the SONGS CE Original Steam Generators (OSGs), so that they would not occur in their new RSG’s.

  2.  SCE should have embraced rather than bypassed the FULL NRC Licensing Amendment Process.

  • ·       SCE “Sweet Talked” the NRC into accepting the results of Inadequate Industry Benchmarking and the Defective 10 CFR 50.59 Evaluation and thus avoided the thorough and lengthy scrutiny of FULL NRC 10 CFR 50.90 Licensing Amendment Process.
  •  ·       Note, the lack of strict oversight by Region IV NRC Staff as required by NRC Reactor Oversight Process, was a critical flaw that enabled the debacle.

WHAT IS NEEDED to prevent the adverse consequence of a Main Steam Line Break outside Containment and the resulting nuclear radiological disaster in Southern California, if SCE’s Degraded Unit 2 is allowed to restart at 70% power for an operations trial period of 5 months as an, “Unapproved Experiment”, as SCE and 3 out of 4 Nuclear Energy Institute Qualified “US Nuclear Plant Designers” are recommending?

1.   Submittal of a NRC 10 CFR 50.90 Licensing Amendment Application for SONGS Unit 2 Restart Plan by SCE.

2.   A thorough review of SONGS Unit 2 Restart Plan Return to Service Report by Region IV NRC Staff, NRC Chairman and Commissioners, U.S. Senate Committee on Environment & Public Works, and independent verification/ by the NRC Offices of Nuclear Reactor Regulations, Nuclear Regulatory Research1 and the Union of Concerned Scientists.

3.   Sworn testimony by all parties responsible for the preparation of SONGS Unit 2 Restart Plan Return to Service Report to insure that public safety and health will not be compromised in case of a nuclear Accident caused by a Design Bases Earthquake/Main Steam Line Break due to multiple tube leaks or ruptures or combination thereof.

4.   Investigation of SONGS Safety Violations and Worker Discrimination, Retaliation, Intimidation and Harassment by an Independent Federal Commission appointed by the President or the Supreme Court of the United States.  This is required to guarantee public acceptance of the results these investigations by the people of Southern California.

5.    Return of the 1.2 Billion Dollars that the ratepayers have “fronted” SCE to date, with interest.

6.    A Financial Bond Guarantee by Southern California Edison to cover the Financial Ruin of Southern California’s economy in case of any nuclear Incident/Accident.

1Dr. Joram Hopenfeld, a retired engineer from the Office of Nuclear Regulatory Research, sharply criticized NRC officials for downplaying the dangers of degraded steam tubes in  December 1999, three months before the Indian Point accident, and said, “To be credible, risk-informed regulation mandates statistically valid and scrutable data, competent insights of accident scenarios and their consequences, and of accident prevention strategies, as well as meaningful public involvement. In reality, the staff examines accident scenarios and their consequences in a superficial manner; accident prevention is apparently dictated primarily by financial considerations, and the public is being excluded from meaningful participation in the NRC deliberation process’, ‘The nuclear industry and the NRC have a poor track record of controlling steam generator tube degradation.” The NRC's Advisory Committee on Reactor Safeguards (ACRS) issued a report in February 2001 and substantiated many of Dr. Hopenfeld's concerns.

Copyright October 14, 2012 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team.