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

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.

SCE's Restart PR Campaign Backfires in MV!

SCE's RESTART PR campaign is now in full swing, please tell your friends to find out what SanO insiders are saying about all the technical issues AGAINST RESTARTING SanO, before they attend the NRC Dana Pt. meeting on 10-09-12.

The complete 6 page PR memo can be viewed online http://be.rtgit.com/DABSANO  along with many other of the DAB Safety Team's "Papers", like "DAB Safety's Initial Response to SCE's Restart Plan", so please bookmark it as MORE information will be posted to keep you in the know.

Remember:

       Any SCE restart is nothing but a $1.2 Billion Get out of Jail Free Card for them!

Just SAY N☢ To Any Restart TESTING, SoCal cannot afford a Trillion Dollar Eco-Disaster like Fukushima!

CaptD

p.s. Kudos to Joe for the SCE PR Restart Pitch Info!

California ISO prepares for another potential summer without San Onofre generation

News Release

News Release

For immediate release | September 13, 2012 Media Hotline  888.516.6397

For more information, contact:

Steven Greenlee | sgreenlee@caiso.com Stephanie McCorkle | smccorkle@caiso.com

California ISO prepares for another potential summer without San Onofre generation

FOLSOM, Calif. – The California Independent System Operator Corporation (ISO) is taking steps now to prepare for the summer of 2013 should Southern California remain without the generation from the San Onofre Nuclear Generating Station. ISO experts briefed the Board of Governors at their meeting today on recent analysis of grid needs should the nuclear plant not return to service.

Topping the list of recommended mitigation actions is converting Huntington Beach units 3 and 4 into synchronous condensers. The units were brought back into service this year to fill the void left by the nuclear plant shutdown. As synchronous condensers, the Huntington Beach units do not produce electricity and therefore, no air emissions credits are required.

Instead, the condensers, acting somewhat like spinning flywheels, adjust to grid conditions by providing the voltage support, normally supplied by the nuclear plant, to the local 230 kilovolt switchyard. Megavars, instead of megawatts, would be produced and used to push megawatts through the grid, much like water pressure helps push water through a hose.

Two analyses provide the basis for today’s briefing: The Addendum to the 2013 Local Capacity Technical Analysis and 2012-2013 Preliminary Reliability Results, both available on the ISO website, caiso.com. The analyses also identify adding capacitor banks on Southern California Edison’s electric systems to provide transmission line voltage support. The Board today approved the staff recommendation to designate the Huntington Beach units as reliability must-run for voltage support in 2013. The designation is one step toward providing reliability in southern Orange and the San Diego counties. If it later determined additional resources are necessary for must-run services, ISO management will seek further Board approval of those additional reliability must-run contracts.

The state’s resource adequacy program has greatly reduced the need for must-run designations over the past few years, although the Board did approve extending a contract for the Dynegy Oakland facility through 2013 for 165 MW. The ISO tariff allows must-run designations under very specific circumstances such as making sure areas have enough local capacity available, mitigating local market power or providing voltage support.

Link: http://is.gd/eyetRe

The Number 1 US Nuclear Safety Concern ==> San Onofre's Replacement Steam Generators

The DAB Safety Team is thankful to numerous anonymous concerned SONGS Workers, who have provided factual information in the interest of the Public Safety to us so that we could arrive at these “Reasonable Conclusions” regarding SONGS Replacement Steam Generators Degradation.  We acknowledge Fairewinds Energy Association, Professor Daniel Hirsch, Friends of the Earth, San Clemente Green, Media, News Papers and the SD Reader, whose material has contributed to the successful completion of this document.

NOTE: These Preliminary Conclusions are subject to change upon receipt of Southern California Edison's (SCE) SONGS Unit 2 Restart Plan and Mitsubishi Heavy Industries (MHI) Root Cause Evaluation.

 

If SONGS Unit 2 is allowed to operate at reduced power, an Un-isolable main steam line break accident can occur at any time, due to a postulated design basis earthquake and/or any other associated failure.  Due to this event, the depressurization of the steam generator caused by the steam line break coupled with the excessive vibrations due high differential pressure (> 2250 psi), high reactor coolant water temperature inside the tubes, the compact space between the SONGS U-Tube Bundle and the moisture separators (compared with other Mitsubishi Steam Generators) and the steam over-pressurization would cause the elastic deformation (NRC AIT Report, Mitsubishi Preliminary Cause Evaluation) of the taller U-tube bundle due to increased U-tube bundle height, high localized steam-voids or dry-outs (two-phase mist region, almost devoid of water in undefined central portion of the U-tube bundle above the 7^th support plate) and narrow-pitch/tube diameter ratio.  This unanalyzed and rare phenomena not experienced in the Steam Generators operating history, in turn, would cause the onset of fluid elastic instability conditions due to the 100% localized steam voids in the central portion of U-Tube bundle above the 7th Support Plate.  The fluid elastic instability conditions would result in further lowering the already low in-plane tube clearances (Attributed to unanalyzed effects because of addition of more tubes to achieve more thermal MWt out of the SGs). The combination of these factors along with a poorly designed anti-vibration support structure [low damping capability of the support structure (i.e., the tube support plates, the tube-sheet, and the anti-vibration bars)] would result in excessive and violent vibrations, cause tubes to hit each other in the in-plane direction, result in leaking tubes, which would cause high-pressure primary sub-cooled water jets.  These high-pressure jets would cut holes into other already worn tubes and create undetermined number of cascading tube ruptures.

The cumulative effects of the above conditions along with the unanalyzed effects of plugged and staked tubes would rupture other damaged, plugged, staked and worn tubes.  The amount of leaking reactor coolant through these ruptured tube cuts is beyond the analyzed limits of a SONGS UFSAR Analysis [Three combined independent events loads (DBE + MSLB + LOCA)] that would be released via the blowing radioactive steam carrying Un-partitioned reactor coolant from the Un-isolated steam generator into the environment.  This uncontrolled radiological accident would release significant amounts of radiation, which could adversely affect the health and safety of all Southern Californian residents plus the transient population within the 10-mile Emergency Planning Zone.   We believe that this scenario can also progress into a nuclear meltdown of the reactor due to potential errors by plant operators unable to diagnose and control rapidly changing plant conditions due to the confusion caused by the non-user friendly and complex, abnormal, emergency operating and emergency plan implementing procedures.  

This scenario is a departure from a method of evaluation described in the UFSAR used in establishing the SONGS design bases or in the safety analyses and requires a NRC 50.90 License Amendment before SONGS Unit 2 or 3 can be allowed to restart.  A permission by NRC for SONGS restart of either Unit 2 or 3 without the 50.90 License Amendment would be construed as: (1) Repeat violation of NRC 50.90 License Amendment Process by SCE, (2) Violation of SCE’s Overriding Obligation to protect the health and safety of Southern Californians from radiological accidents, and (3) Inconsistent with the NRC's long history of commitment, transparency, participation, and collaboration with the public's oversight of Nuclear Reactor regulatory activities.

-- The DAB Safety Team

Do You Live In The San Onofre Fallout Zone?