SCE Cited For Major Nuclear Related Safety Violation At San Onofre

Get SCE Out of San Onofre

Background: NRC Spent Fuel Pool Cooling Requirements:

“Each licensee shall develop and implement guidance and strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire ….”

The San Onofre spent fuel cooling fire protection plan in the event of a large fire and/or explosion hinges on the expertise and staffing of the on-sight San Onofre Fire Department.

Since the San Onofre Fire Department and Emergency Planning Personnel Staffing was reduced to a skeleton crew without prior approval from the NRC after a full and proper evaluation, the existing fire plan is now outdated and unrealistic in event of a large fire or explosion.

A Spent Fuel Pool Cooling Accident, in case of a large fire or explosion without adequate and demonstrated mitigation measures is a MAJOR Nuclear Safety Concern for all the millions of Southern Californians living within the 10 Mile Emergency Protection Zone.  Remember Fukushima's triple meltdowns occurred because of a failure to keep their reactors cool after the big earth quake and tsunami which occurred on 03/11/11.

Last Friday, the NRC cited SCE, the operator of San Onofre's nuclear power plant for violating NRC rules by failing to get approval before eliminating 39 emergency-response jobs after the plant closed last year.

Historically, NRC Region IV has had the habit of citing Southern California Edison with only low level violations, even if the violations were actually severe violations.  This cozy relationship was a contributing factor in the radioactive leak that resulted in the early decommissioning of San Onofre Units 2 & 3 and the loss of billions of dollars to SoCal ratepayers that could have been prevented, if the NRC had enforced the Federal Regulations as written.  This type of safety enforcement is not good for Californians or the NRC.  Now a serious review/investigation and proper action/fines are required by the NRC and its Commissioners, to assure Nuclear Safety is maintained at San Onofre and all the other US Nuclear Power Plants.

The question the NRC should ask is, "Knowing that the SPENT FUEL POOLS MUST STILL BE KEPT COOL 24/7 no matter what, if a major earth quake occurred tonight, would San Onofre Fire Dept.'s skeleton crew be able to guarantee US that they could prevent a nuclear accident from occurring, especially since the 39 emergency-response positions that were illegally eliminated, probably cost ratepayers much less than even one still employed highly paid nuclear manager who would be home sleeping?  

The question that the CPUC should ask is, "If SEC is really interested in safety as they keep telling us, what is the reasonableness of continually cutting corners on those that actually insure our safety, while at the same time retaining other highly paid nuclear Staff?

Related articles

• San Onofre Nuclear Plant Hit With Violation
• San Onofre nuclear plant hit with violation
• San Onofre nuclear plant hit with violation
• Nation's nuclear waste a deepening concern
• Customers would get $1.4 billion in refunds in San Onofre deal

SCE’s Technical Ability To Perform Safe Restart Questioned

SCE’s misleading and embarrassing technical presentation at their NRC public meeting when explaining fluid elastic instability in SONGS Unit 2, creates doubts about Edison’s ability to perform a safe restart of their damaged “Radiation Steaming Crucibles” aka Replacement Steam Generators (RSG's).

==============================================================

After spending almost a year, wasting hundreds of millions of dollars of rate payer’s money and hiring World’s Best Experts, Southern California Edison brought out SONGS Senior Vice President of Engineering, Tom Palmisano, on November 30, 2012 (Friday night) to give an intense technical presentation and a dazzling performance in a bid to convince the regulators they should be able to restart Unit 2 at the plant. However, Palmisano failed miserably to convince the DAB Safety Team, NRC Region IV Panel and the Public/Technical Experts, that Southern Californians will be safe from the effects of a potential nuclear radiological accident by the restart of Unit 2’s “Sick and Unsafe” Steam Generators by operating them at 70% power for a trial period of 5 months.  When questioned by NRC Panel Members, the unprepared and uncomfortable Palmisano tasked with convincing the NRC, the Public and the News Media that Unit 2 is safe for restart “stumbled several times during the presentation”, then in response to the panel members questions for further technical details said sometimes irritatingly, “I will get back to you” and then finally “hesitantly” admitted, “SCE and MHI analysis are still not yet complete and will continue for several months for a detailed analysis and investigation to this problem.” 

Palmisano declared with his face beaming that tube-to-tube wear was caused “Most Likely” by in-plane vibrations (fluid elastic instability) in Unit 2 Steam Generator E-089 (U2SGE089).  Two affected tubes in U2SGE089 with 14% wear depth were plugged and they preventatively plugged 321 tubes to conservatively add to the safety margin.  It is astonishing and alarming to note that SCE’s Vice-President contradicted the World’s Leading and Pioneering Nuclear Plant Designer, Westinghouse Operational Assessment, which concluded, “ In-plane vibrations (fluid elastic) instability did not occur in U2SGE089 in two affected tubes.  The tube-to-tube wear is most likely a result of out-of-plane vibrations (flow-induced random vibrations) of the two tubes in close proximity to the level of contact during operation.”

The DAB Safety Team perception is that Palmisano is either pretending or really does not understand the Westinghouse Operational Assessment’s conclusions regarding the adverse effects of fluid elastic instability and flow-induced random vibrations, which caused the January 31, 2012, radioactive leak in one of the SONGS Unit 3’s brand new 680 million dollar replacement steam generators (RSG’s) reverse-engineered by the inexperienced SCE in-house engineers and manufactured at the direction of complacent Mitsubishi Heavy Industries.  Southern Californians were very lucky, because a potentially serious nuclear accident in progress was stopped by an emergency shut down. When tested later, in March 2012, eight (8) steam generator tubes (wear range 72-100%, length of wear 23-34 inches) in the newly replaced San Onofre Unit 3 RSGs E-088 failed “in-situ” pressure testing and therefore were plugged, after only 11 months of operation.  After that, several hundred Alloy 690 Thermally Treated tubes were also plugged due to tube-to-tube wear. SCE did not disclose intentionally to the public that one Unit 2 tube had also experienced a 90% through wall wear due to a MHI Manufacturing retainer bar defect.  Southern Californians were once again very lucky that a serious nuclear accident was prevented by a planned refueling shut down. SONGS RSG’s now have more damaged and/or plugged tubes than all the rest of the US reactor fleet combined. Based on analysis of NRC AIT Report and SONGS Procedures, Operational Data, Plant Daily Briefing Sheets, Engineering Calculations and conversations with Plant Personnel, the DAB Safety Team disagrees with SCE and confirms Westinghouse Operational Assessment conclusions that fluid elastic instability did not occur in Unit 2 Steam Generator E-089.  The DAB Safety Team discussions with two of the NRC Panel Members gives us the perception that the NRC panel Members disagree amongst themselves and also with SCE on the effect of operational parameters on fluid elastic instability in Unit 2 Steam Generator E-089.

The inexperienced and complacent SCE Engineers in a rush to make profits for SCE Officers and Shareholders ignored: (a) CPUC advice on applying to NRC for increased plugging limit to extend the life of Original Steam Generators, and (b) SDG&E opposition to the wisdom and viability of the RSG Project.  Although SCE was a shareholder in PVNGSs, the SCE Engineers due to time pressure and complacency did a very poor job of Benchmarking, (a) Especially of PVNGS on the new fabrication techniques and design to prevent the adverse effects of fluid elastic instability (FEI) and flow-induced turbulent and random vibrations (FIRV), and (b) Did not keep up with the research of World’s Foremost Expert and other academic scholars to prevent the adverse effects of FEI and FIRV, prepared a defective 10 CFR 50.59 Evaluation and made numerous untested and unanalyzed design changes under the pretense of like-for-like to avoid lengthy and evidentiary public hearings and thorough NRC 50.90 Amendment. If Edison had informed the NRC that the new steam generators were not like-for-like, the more thorough NRC licensing review process would have hopefully identified the design problems before the steam generators were manufactured. The unauthorized and untested design changes made by SCE Engineers to extract more heat and make more money for SCE shareholders from the RSG’s (1729 MWt) compared with the OSG’s (1705 MWt) destroyed the brand new 680 million RSG’s. [Please see DAB Safety Team Papers, “The Big Number 1 Attachment Notes”  & “SONGS Insider Secret)

Based on a review of MHI, AREVA and Westinghouse documents, the DAB Safety Team concludes that FEI and MHI Flowering effect redistributed the tube-to-AVB gaps in Unit 3 RSGs.  It is the DAB Safety team’s strong perception that SCE claims that insufficient contact forces in Unit 3 Tube-to-AVB Gaps “ALONE” caused tube to tube wear are misleading, erroneous, egregious, and designed to put the blame on MHI for purposes of making SCE look good in the public eye so they can collect insurance money for their own design defects.

The NRC Chairman stated that SCE is responsible for the work of its vendors and contractors.  The real crux of the problem with the San Onofre Generators, Palmisano said, was the outdated mathematical model Mitsubishi used. There were mistakes in the parameters concerning the arrangement of the heat transfer tubes, Palmisano said. MHI States, “Minimizing tube wear was given the first priority in the SONGS RSG specification, design and fabrication, and the tube support design and fabrication was discussed by MHI and SCE in numerous design review meetings.” A SCE Engineer along with a MHI Technical Specialist claims in a joint paper published in an International Magazine, “SONGS steam generators are one of the largest in the industry, which called for innovative design solutions and improved fabrication processes when working on the RSG’s. Conceivably, the MHI and Edison project teams faced many tough challenges throughout the entire project in the design, manufacturing and QC areas, when striving to meet the specification requirements.  Both teams jointly tackled all these challenges in an effective and timely manner. At the end, MHI delivered the RSG’s, which incorporated all the latest improvements found throughout the industry, as well as innovative solutions specific to the SONGS RSG’s. In Unit 2, the RSG’s were installed and tested in 2009/10 and in Unit 3 in 2010/11. The RSG post-installation test results met or exceeded the test acceptance criteria for all specified test parameters, thus properly rewarding the effort put into their fabrication.”  Therefore, the DAB Safety Team concludes that SCE engineers did not check the work of MHI with a critical and questioning attitude and did not meet the 10CFR50, Appendix B, Quality Assurance Standards, the NRC Chairman’s Expectations and or NRC Regulations.   The SCE claims about MHI Thermal-Hydraulic Computer Modeling errors are misleading, erroneous and designed to absolve SCE of all the mistakes and put the blame on MHI for purposes of collecting insurance money for using outdated computer codes and to appear blameless themselves before the public.

A NRC Branch Chief gifted with MIT Intelligence, Intuition and a Sixth Sense 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." That NRC Chief, if you asked him about the restart of SONGS Unit 2 “As-Designed and Defective RSGs (aka Radiation Steaming Crucibles)” will say, “In Emergency Planning Space, decisions have to be Accurate and Timely. Under-conservative, rushed and profit-motivated analyses based on limited facts, biased and ambiguous operational data, untested deterministic and probabilistic risk analysis, conflicting theories and differing operational assessments of degraded equipment at even reduced power operations for 150 days with conditional monitoring along with unproven and unreliable compensatory and operator actions represent enormous risks to public health and safety, the environment and Southern California’s economy.”

Unit 2 has hundreds of times more bad tubes and a thousand times more indications of wear on those tubes than any typical reactor in the country with a new steam generator, and nearly five times as many plugged tubes as the rest of the replacement steam generators in the country combined, over a comparable operating period. Therefore, thousands of degraded tubes present a formidable challenge to the Safe Restart of Unit 2 by making it highly vulnerable to localized steam dry-outs, 100% void fractions, fluid elastic instability, flow-induced random vibrations and cascading tube ruptures during unanticipated operational occurrences and/or Main Steam Line Breaks. 

Even at 70% power operations, if a steam line break outside containment were to occur in Unit 2, the depressurization of the steam generators with the failure of a main steam isolation valve to close would result in 100% void fraction in the degraded U-Tube bundle and the straight leg portion between the Tube Support Plates.  This condition of ZERO Water in the steam generators due to low tube clearances would cause fluid elastic instability (FEI) and flow-induced random vibrations, which in all likelihood would then result in massive cascading SG tube failures, involving hundreds of degraded active SG tubes, along with all the damaged inactive (all the plugged /stabilized) SG tubes. With an undetermined amount of simultaneous tube leaks/ruptures, approximately 60 tons of very hot high-pressure radioactive reactor coolant would leak into the secondary system. The release of this amount of radioactive primary coolant, along with an additional approximately 200 tons of steam in the first five minutes from a broken steam line would EXCEED the SONGS NRC approved safety margins. So, in essence, the RSG’s are loaded guns, or a nuclear accident waiting to happen. Any failure under these conditions would allow significant amounts of radiation to escape to the atmosphere and a major Loss Of Coolant Accident (LOCA) could easily result causing much wider radiological consequences and even a potential nuclear meltdown of the reactor!  Since these events would happen at an extremely fast pace, no credit is assumed in the first 5 minutes of the main steam line break accident for: (1) Enhanced Unit 2 Defense-In-Depth Actions - SCE Restart Plan Enclosure 2, Item 9.0, and (2) The differential pressure across the SG tubes necessary to cause a rupture will not occur if operators prevent RCS re-pressurization in accordance with their Emergency Operating - Enhanced Unit 2 Defense-In-Depth Actions - SCE Restart Plan Enclosure 2, Item 5.2,2, Probabilistic Risk analysis.

The Final Question – Is Unit 2 Safe At 70% Power For 5 Months Of Operation?

The Answer Is NO.  

SCE is trying to restart their Unit 2’s degraded RSG’s, which are outside the NORM of the NRC Regulations.  The DAB Safety Team has already answered this question previously in their San Onofre Papers posted on the web.

The DAB Safety Team Expert Panel will issue an unbiased detailed technical response in the near future to Edison’s “November 30, 2012  - Public Meeting Presentation with the Nuclear Regulatory Commission Unit 2 Confirmatory Action Letter November 30, 2012” for the benefit of President Barack Obama, Southern Californians, the NRC Chairman, the NRC Atomic Licensing Board, the NRC Staff, the Senate Committee on Environment & Public Works, EIX/SCE Management, its vendors, contractors, employees and Union workers. The DAB Safety team will issue the following papers in the near future:

·      Evaluation of SCE Unit 2 Restart November 30 Public Meeting NRC Presentation

·      NRC Poor Public Perception and Future Expectations to meet President Obama’s and Senator Barbara Boxers Open Government Initiative and 100% Transparency to avoid Collusion with SCE to ensure the Safety of 8.4 Southern Californians and a Trillion Dollar ECODISASTER

·      SONGS Profit-Motivated, Production over Safety and Retaliating Senior Leadership Team

·      SONGS Fire Safety, Emergency Preparedness and Cyber Security Concerns

·      SONGS Worker Rights and Anonymous NNs

The Final Fix – Decommission both SONGS Units 2 and 3, or replace them using a 50.90 thorough License Amendment Process and Evidentiary Public Hearings.  According to the DAB Safety Team’s conversation with one of the NRC Panel members, Senators Barbara Boxer and Diane Feinstein have told the NRC that both of them are in favor of Replacement or adequate inspections and repairs of SONGS RSG’s along with a 50.90 thorough NRC License Amendment Process and Evidentiary Public Hearings. 

According to public sources, Pete Dietrich has already announced in internal SONGS staff meetings that Unit 2 will tentatively restart on February 2, 2013.  If confirmed, this is stunning news for the public and gives the clear perception of collusion between the NRC and SCE.  TEPCO’s reported collusion with Japanese Regulators resulted in Fukushima’s catastrophic nuclear accident (a Trillion Dollar Japanese economic, public health & safety radiation nightmare and Eco-Disaster).

The public expects that the NRC complies with President Barack Obama, Senator Barbara Boxer and the NRC Chairman’s Open Government Initiative by using the NRC Branch Chief’s advice and Reactor Oversight Process, when it audits SCE’s Licensing Basis Documents, facility procedures/records, 10 CFR 50.59 Safety Evaluations, Unit 2 Restart Documents and issues/approves Safety Evaluation, License Amendment Applications and Inspection Reports, Responses to Confirmatory Action Letters and other enforcement violations, as appropriate.  The NRC should complete its mission of ensuring public safety with complete public respect, transparency and involvement by issuing all documents, emails, telephone records and holding open and trial-like thorough hearings without any time pressure from SCE, its vendors and contractors.

The position that San Onofre’s “As designed and defective” replacement steam generators (aka radiation steaming crucibles) without replacement or adequate repairs (replacement of tube bundle and anti-vibration supports) are unsafe and fail to meet the Steam Generator Fundamental Tube Integrity Criteria for a Main Steam Line Break Accident is consistent with the recommendations earlier made on this subject by:

·      Arnie Gundersen and his team of anonymous steam generator experts

·      Professor Dan Hirsch

·      Dale Bridgenbaugh (Retired professional nuclear engineer),

·      Union of Concerned Scientist (David Lochbaum, Director of Safety)

·      The DAB Safety Team Panel’s of several SONGS insiders root cause and operation experts

·      Other anonymous steam generator and thermal-hydraulic experts, and

·      Retired NRC Experts 

Copyright December 5, 2012 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team. The contents cannot be altered without the Written Permission of the DAB Safety Team Leader and/or the DAB Safety Team’s Attorneys.


PRESS RELEASE 

The DAB Safety Team: December 6, 2012

Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261 

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

http://public-blog.nrc-gateway.gov/

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)

Sir

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

Best

CaptD

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

”

To read the letter to the NRC: http://libcloud.s3.amazonaws.com/93/23/6/2497/12-10-16_Letter_to_the_NRC.pdf

CONTACT: 
Damon Moglen, (202) 222-0708 
Dave Freeman, (310) 902-2147

Categories: Climate And Energy, News Releases, San Onofre News

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.