SCE is now in Violation of
10 CFR 50, Appendix A, GDC 14, 15, 30 and 32 Requirements... And cannot be allowed to restart Unit 2 at ANY power level!
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| Decommission San Onofre |
SCE is
desperately trying to justify the restart of Unit 2 based on conflicting,
confusing and erroneous Operational Assessments prepared by Westinghouse,
AREVA, Intertek and MHI with Inscrutable
(Undecipherable) Data and under-conservative computer models, which are not
applicable to 100% Steam Voiding caused by a Main Steam Line Break and
sub-cooled feed water flashing conditions due to Steam generator
depressurization. The nominal tube wall thickness “flaw” of 28% of
these tubes is projected to be > 31% during the 5 month trial restart of Unit 2
based on untested data, that may be applicable to other plants, but not to
SONGS. Based on the history of the catastrophic and unprecedented failure
of eight Unit 3 SG E-088 tubes, Unit
2 SG design deficiencies and incomplete tube inspections, these flaws can
exceed the 35% plugging limit at any time prior to the end of 5 months trial
period due to any abnormal plant operations or transients [e.g., loss of
offsite power, adverse local thermal-hydraulic conditions (like high Steam
voids of > 99.6% due to narrow tube pitch to tube diameter ratio, low tube
clearances), etc.], all of which are beyond the control of the operator. Hence, the Public and the Regulators will never know, until it is too late, when Unit 2 again
will be operating in violation of the Technical Specifications Limit.
Unit 2’s Restart Effort is just an unapproved and desperate experiment, which
is not permitted by law. The only legal option SCE has is to apply for a
thorough NRC 10 CFR 50.90 License Amendment, along with transparent and trial-like public hearings. Anything less, would be a regulatory failure
by the NRC, to protect public safety and a violation of the authority
and the privileges granted by the President and Congress of the United States.
à
Read the complete Press Release + 12-11-19
Here is the latest data on not only why SONGS cannot be allowed to be restarted at any power level, but why the NRC must stop living in denial and accept the fact that cascading multiple SG tube failures can happen at any time, which can easily lead to a major loss of reactor coolant (Think Fukushima) and or large radioactive releases.
ReplyDeleteBecause of the SG eight tubes that failed in-situ testing at SONGS, basic SG safety now requires that every SG tube in the US fleet needs to be inspected using advanced technology ASAP, before we have one or more nuclear incidents/accidents which our Country can ill afford! I urge you to pass this information along to the U. S. Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board Panel because it is applicable to the safety of all US Steam Generators.
I trust the NRC will fully appreciate the work that went into the 42 page SONGS MSLB Analysis technical version listed above.