San Onofre Cancer Report by Joe Mangano Published

Joe Mangano The Radiation and Public Health Project  
P.O. Box 1260 Ocean City NJ 08226 

Click here for the RADIOACTIVE EMISSIONS AND HEALTH HAZARDS FROM THE SAN ONOFRE NUCLEAR REACTORS IN CALIFORNIA PDF 

Everyone and especially those with small children should consider making a donation to Joe Mangano's* The Radiation and Public Health Project for publishing his San Onofre Cancer Report at no cost, as a public service.

Note: This study comes long before similar studies being done by the NRC which will take years to complete, yet the nuclear industry group already claims that they "won't provide any meaningful data" (see below).

After reading Joe Mangano's study, you can decide for yourself.

* Joseph J. Mangano, MPH, MBA, is Director, Secretary, and the Executive Director of the Radiation and Public Health Project.

Mr. Mangano is a public health administrator and researcher who has studied the connection between low-dose radiation exposure and subsequent risk of diseases such as cancer and damage to newborns.

He has published numerous articles and letters in medical and other journals in addition to books, including Low Level Radiation and Immune System Disorders: An Atomic Era Legacy. There he examines the connection between radiation exposure and current widespread health problems.

For comparison:

CANCER RISKS STUDIED NEAR 7 US NUCLEAR SITES

By STEPHEN SINGER

— Oct. 24 2:03 PM EDT

You are here

http://bigstory.ap.org/article/cancer-risks-studied-near-7-us-nuclear-sites

HARTFORD, Conn. (AP) — Federal regulators say a pilot study of cancer risks posed to residents near seven nuclear power sites in the United States will update 22-year-old data, but an industry group says the study won't come up with anything new.

The Nuclear Regulatory Commission says it will study cancer types in infants and the general population near six nuclear power plants and a nuclear-fuel plant for the Navy. The $2 million study is expected to begin in the next three months and continue at least into 2014.

The Nuclear Energy Institute, an industry group, opposes the study, saying it won't likely provide any meaningful data.

The sites are in California, Connecticut, Illinois, Michigan, New Jersey and Tennessee.

Related articles

• NRC Public Meeting On the Process To Decommission San Onofre
• San Diego Gas & Electric wants to recover San Onofre investment
• Group links Palisades to death rates; company disputes report
• Decades later, Baby Tooth Survey legacy lives on
• Calls for US seafood testing after revelations of Fukushima radiation leaks
• How to support the "Nuclear Waste Symposium"

NRC: The Good, The Bad and the Ugly

NRC: The Good, The Bad and the Ugly

... and why it is unsafe To restart San Onofre

A GOOD NRC enforcement example:

Davis-Besse Nuclear Power Station is a nuclear power plant in Oak Harbor, Ohio. On March 5, 2002, maintenance workers discovered that corrosion had eaten a football-sized hole into the reactor vessel head of the Davis-Besse plant. Corrosion had been clogging the plant’s filters for months, requiring repeated filter replacement, but the cause was not investigated until after a worker leaned against a control rod drive mechanism, and it toppled over. Although the corrosion did not lead to an accident, this was considered to be a serious nuclear safety incident. Some observers have criticized the NRC’s Commission work as an example of regulatory capture [See Note 1] and the NRC has been accused of doing an inadequate job by the Union of Concerned Scientists.  The Nuclear Regulatory Commission kept Davis-Besse shut down until March 2004, so that FirstEnergy was able to perform all the necessary maintenance for safe operations. The NRC imposed its largest fine ever—more than $5 million—against FirstEnergy for the actions that led to the corrosion. The company paid an additional $28 million in fines under a settlement with the U.S. Department of Justice. The NRC closely monitored FENOC’s response and concluded in September 2009 that FENOC met the conditions of the 2004 order. From 2004 through 2009 the NRC reviewed 20 independent assessments conducted at the plant and verified the independent assessors’ credentials. The agency also conducted its own inspections and reviewed FENOC’s reactor vessel inspections conducted in early 2005. NRC inspectors paid particular attention to the order’s focus on safety culture and safety conscious work environment to ensure there were no new signs of weakness. The NRC task force concluded that the corrosion, occurred for several reasons:

·    NRC, Davis-Besse and the nuclear industry failed to adequately review, assess, and follow up on relevant operating experience at other nuclear power plants;

·    Davis-Besse failed to ensure that plant safety issues received appropriate attention; and

·    NRC failed to integrate available information in assessing Davis-Besse’s safety performance.

A BAD NRC enforcement example:

At San Onofre by Region IV and the NRC: The papers shown below have been obtained from Public Domain written by Dr. Joram Hopenfeld and a former SONGS Employee based on his investigation of the steam generator issues, review of the plant data and discussions with several Key SONGS Insiders. These papers confirm that Southern California Edison wants to restart unsafe Unit 2 nuclear reactor at 70% power under false pretenses, just for profits, and as an unapproved risky experiment by subverting the NRC and Federal regulatory process.  The true Root Cause (See Note 2) of the unprecedented tube-to-tube wear in Unit 3 has NOT been officially established, as required by NRC Confirmatory Letter Action 1 for restarting the defectively designed and degraded Unit 2.  NRC has not even completed their review of Unit 2 Return to Service Reports, nor have they finished Special Unit 2 Tube Inspections, nor have they (publicly?) reviewed SCE’s Response to NRC’s Requests for Additional Information (RAIs).
NOTE: NO FINES ARE MENTIONED - WHY?

An UGLY NRC enforcement example?:

Now, SCE wants the NRC to approve a new shady License Amendment, undermining public safety and they want it done without the involvement of Public Safety Experts, Attorneys and/or Citizens/Ratepayers.  After the review of the Mitsubishi Root Cause Evaluation and the Draft SCE License Amendment, it is crystal clear that the NRC needs to follow the example of their own enforcement at David Besse together with the lessons learned from Fukushima, when it comes to NOT approving this new Shady License Amendment for restarting San Onofre Unit 2’s defectively designed and degraded replacement steam generators.  In light of the unanticipated/unprecedented tube leakage at San Onofre Unit 3, the health and safety, along with the economic concerns/objections of 8.4 million Southern Californians’ MUST OVERRIDE and PREVENT the restarting of Unit 2 at ANY power level.  In a Democratic Society, truth must prevail over profit motivations, misleading propaganda of electricity service disruption and/or projected probabilistic temporary inconveniences to the public based on phony data, because America cannot afford a trillion dollar nuclear eco-disaster!

Our Safety must override SCE's profits and prevent them from restarting Unit 2.

Notes:

1: Regulatory capture occurs when a regulatory agency, created to act in the public interest, instead advances the commercial or special concerns of interest groups that dominate the industry or sector it is charged with regulating.  Regulatory capture is a form of government failure, as it can act as an encouragement for firms to produce negative externalities. The agencies are called "captured agencies".

2. Human performance errors resulting from the negative safety culture of production (profits) goals overriding public safety obligations.


=======================================================================
Additional Information:

The full DAB Safety Team's Media Alert 5 Parts:

https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=15V8BD4YK0MjwUV6gPZt6ILS_lP7CpClzgnZentLfx8U

The complete five (5) part presentation, see the eight (8) titles listed below:

Part 1, First Part  https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=1GcDuO0NvUdBBRVqCinM3Gr9bhmsJDCIbOg65rwdtjBY

Part 1, Second Part https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=1v_UcRLUlwmhtVDbftGcROPkF-cujiGa_-qjUJ7i2WIM

Part 1, Third Part https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=1yCOQ_diw8Qix1qG3j7MC6F2VfcqMoFOidxjJdIBpba0

Part 1, Fourth Part https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1

Part 2 https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?
pli=1&docId=1wkyTGWUy0pIXjBXc91JWr6_ACB3d-AIQbuVVZtDRZvI

Part 3 https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=16VmGtq9oYGS2-bpR4nBt9d-YB21E2xrjFpIJoxFJ4s4

Part 4 https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=0BweZ3c0aFXcFMC1BNlpMeDQyM2M

Part 5 https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=0BweZ3c0aFXcFX2gxRDFCRW9CVzg

San Onofre Unit 2 Retainer Bars Could Cause Massive ☢ Leakage

In an accident like a main steam line break at San Onofre, the badly designed retainers bars in Unit 2 could actually make things much worse by causing more damage to any of the 9,727 already fatigued tubes in each of its steam generators which could lead to additional leakage of highly radioactive reactor core coolant and/or cause a nuclear incident or worse a nuclear accident like Fukushima!

Radioactive Leaks and ruptures can happen without notice:

Allegation/Violations

The NRC has decided in AIT follow-up report dated 11/09/2012, “Item 3. “(Closed) Unresolved Item 05000362/2012007-03, ‘Evaluation of Retainer Bars Vibration during the Original Design of the Replacement Steam Generators” as a non-cited violation in accordance with Section 2.3.2 of the NRC’s Enforcement Policy.”  However, as shown below, SCE/MHI’s failure to verify the adequacy of the retainer bar design as required by SCE/MHI’s procedures have resulted in plugging of several hundred tubes in the brand new replacement generators. This has resulted in these violations:

1. Failure to meet NRC Chairman Standards on Nuclear Safety by SCE,
2. Failure to meet Senator Boxer’s Committee on Environment and Public Works
(EPW) Standards on Nuclear Safety by SCE,
3. Failure to enforce SCE Edison Contract Document instructions to MHI by SCE,
4. Failure to meet SONGS Technical Specifications by SCE,
5. Failure to meet general design criteria (GDC) in Appendix A, “General Design
Criteria for Nuclear Power Plants,” to 10 CFR Part 50, “Domestic
Licensing of Production and Utilization Facilities GDC 14, “Reactor
Coolant Pressure Boundary” by SCE/MHI,
6. Failure to demonstrate that Unit 2 retainer bars will maintain tube bundle
geometry at 70% power due to fluid elastic instability during a main line
steam break (MSLB) design basis event, and
7. SCE/MHI took shortcuts by avoiding the 10 CFR 50.90 License Amendment
Process under the false pretense of “like for a like” replacement steam
generator.  SCE added 377 more tubes, increased the average length of the
heated tubes and changed the thermal-hydraulic operation of the RSGs without

proper safety analysis and inadequate 10CFR 50.59 Evaluation.

This intentional action to produce more thermal megawatts out of the

RSGs compromised safety at SONGS Unit 2 due to the failure of 90

percent through wall thickness of a tube by the inadequate design of the

r

etainer bar.

Recommended Actions:

NRC San Onofre Special Panel is requested to resolve the above listed Allegations and/or Violations within 30 days of receipt of this email and prior to granting SCE’s permission to do any restart "testing" of Unit 2. Answer all allegations factually, don't just void them.
 
See Full Document: Media Alert: San Onofre Retainer Bar Problems

San Diego screening of MOVIE: "311: Surviving Japan"

WE HAVE THIS weekend to pre-sell just 6 seats to make this screening happen in San Diego! No excuses on the weekend, just DO it: You will NOT be charged until the event is confirmed. ($12 per ticket)http://www.tugg.com/titles/311-surviving-japan?location=global&state=upcoming

Please join us for the 2nd Anniversary of the Fukushima nuclear disaaster!

San Diego screening of "311: Surviving Japan" on Monday, March 11, 2013, the 2nd Anniversary of the Fukushima nuclear disaster (7:30p). PLEASE RESERVE YOUR TICKET(S) ONLINE ASAP TO ENSURE THE FILM IS SCREENED HERE: http://www.tugg.com/titles/311-surviving-japan?location=global&state=upcoming You will NOT be charged until the event is confirmed. ($12 per ticket).  We must sell 50 tickets in advance ASAP for this film to be a go at the theater!

Where:

AMC Fashion Valley 18

7037 Friars Rd, San Diego, California 92108

YOU MUST RESERVE YOUR SEAT ONLINE NOW!  There will be no "walk up" tickets sold.

We will do a "Light Brigade" action along the busy Friars Road entrance to the Fashion Valley Mall from 6-7p, holding lighted letter signs spelling out "No More Fukushimas". Please emailmarthasullivan@mac.com to volunteer as a "Holder of the Light."

We will also do Flyering inside the Mall during the same period before the screening: 6-7p, with a special guest for the occasion. Please email marthasullivan@mac.com to volunteer for the Info Crew.

Here is a brief description of the film: "Inside story of 2011 Japanese Tsunami relief & Fukushima nuclear disaster. A critical look at how the authorities handled the nuclear crisis and Tsunami relief by an American who volunteered in the clean-up. It is in short, a documentary of the devastating events in Japan and 6 months of the after-math that followed. It features true stories from those affected by the disaster, the government and even TEPCO. It highlights the struggle in dealing with: The Tsunami clean-up, Government response to the disaster, radiation plus the future of nuclear power after the accident." (90 minutes long, plus speaker.)

SCE Violated Federal Reg.’s And the Public Trust

Nuclear Experts Agree, San Onofre’s Replacement Steam Generators Are Unsafe

Summation: Based upon our ongoing review of evaluations, engineering analyses, inspections, technical and operational assessment reports prepared by the NRC’s Augmented Inspection Team, MHI, SCE, Westinghouse, AREVA, Professor Daniel Hirsch, industry experts and knowledgeable whistle blowers, along with the recent affidavits prepared by Arnie Gundersen and John Large, we reaffirm the following statements which have been previously substantiated in numerous DAB Safety Team Documents:

1. The DAB Safety Team has been saying for months for a long time that SCE and MHI Engineers did a very poor job in their review of Academic Research Papers and Industry Comparisons about how to prevent the adverse effects of fluid elastic instability in the design of San Onofre's replacement steam generators because the original Combustion Engineering designed steam generators did not experience the adverse effects of fluid elastic instability. Nuclear Expert, John Large statesA, “I have little confidence in the outcome of AREVA’s projection of the time period through which the U2 nuclear plant could be reliably expected to operate without incurring a tube failure or running at a greater risk of a tube failure occurring. ... In my opinion, simply sweeping the fluid elastic instability issue under the carpet on the basis ... it will not reoccur at 70% power is not only disingenuous but foolhardy.” TheNRC chairman has publicly stated, “SCE is responsible for the work of its vendor and its contractor.” DAB Safety Team alleges that SCE actions are in violation of the Federal Regulations, its CPUC Charter, the NRC Chairman Standards and even its own advertised charter of “Overriding Obligations to Shareholders and Public Safety.”


2. Accidents involving steam generator depressurization (main steam line break), station blackout and other anticipated transient events causing steam generators over-pressurization can occur at any time over the full range of normal operating conditions up to Reactor Thermal Power (3438 MWs). Therefore BY DESIGN, these replacement steam generators are NOT capable of protecting their already worn and cracked tubes from radioactive leakages and/or ruptures caused by the above.

3. In Unit 2, these already fatigued, cracked, and heavily degraded tubes can snap, leak and/or rupture at the tube sheet, tube support plate or the unsupported anti-vibration bars mid and free spans during these postulated adverse accident conditions. John Large statesA, “For the MSLB event very high, two-phase fluid cross-flow velocities would be expected to instantaneously develop in the U-bend region, triggering vigorous FEI that could, particularly if the AVB restraints are ineffective, promote violent tube to tube clashing and the potential for a multiple tube failure event.”

4. It is ABSOLUTELY CLEAR, that San Onofre Unit 2 replacement steam generators will likely experience single to multiple tube-to-tube failures (e.g., San Onofre Unit 3, Mihama Unit 2, North Anna, Indian Point 2 and Craus, France, etc.) during these postulated adverse licensed conditions at any power level up to 100% Power (Licensed Reactor Thermal Power of 3438 MWTs).


5. The proposed Defense-in-Depth instrumentation, along with unreliable and unproven operator actions to detect multiple tube leaks/ruptures and/or to re-pressurize the steam generators during these postulated adverse licensed conditions as claimed by Edison are not practical to stop a major nuclear accident from progressing and causing a Unit 2 meltdown.

6. There are conflicting, contradicting, ambiguous and confusing findings between the experts in the Unit 2 Operational Assessments: Such conflicting disagreements over the cause of Tube To Tube Wear reflects poorly on the depth of understanding of this crucially important FEI issue by SCE, each of these SCE consultants and the designer/manufacturer of the Replacement steam generators. The DAB Safety Team’s findings contradict the SCE and all the three NEI qualified, “US Nuclear Plant Designers” findings about Unit 2 FEI (See, Overview – Consequences of a Main Steam Line Break).

7. The DAB Safety Team Comments about SCE 10 CFR 50.59 Safety Evaluation for RSGs: The Big Number 1 Attachment Notes shows the comparison between San Onofre and Palo Verde's Replacement Steam Generator design parameters. Palo Verde has the largest CE RSGs in the world (~ 800 Tons each) and SONGS Replacement Steam Generators are the second largest CE Replacement Steam Generators in the world (~ 620 Tons each). John Large statesA, “In my opinion, the changes, tests and experiments (CTE) inherent in the SCE proposal to restart Unit 2: (a) involve a significant increase in the probability or consequences of an accident previously evaluated; (b) create the possibility of a new or different kind of accident previously evaluated; and (c) involve a significant reduction in a margin of safety. Arnie Gundersen statesB, “It is my professional opinion that Edison should have applied for the 50.59 process so that the FSAR license amendment evaluation and public hearings would have occurred six years ago, prior to creating an accident scenario and facing losses that by the end of this process will easily total more than $1 Billion.” Therefore, the DAB Safety Team concludes that SCE claims as stated are not factual. SCE did not meet the 10CFR50, Appendix B, Quality assurance Standards and has violated the NRC 10 CFR 50.90 Regulations.

8. The Public expects that the Offices of Nuclear Reactor Regulation (NRR) comply with President Barack Obama, Senator Barbara Boxer and NRC Chairman’s Open Government Initiative. Under no circumstances should the NRR permit SCE to restart unit 2 without replacing the defective replacement steam generators, a full NRC 50.90 Licensing Amendment and transparent trial-like public hearings.
A http://libcloud.s3.amazonaws.com/93/80/a/2680/R3218-Large-AF2-redacted_proprietary.pdf
B http://libcloud.s3.amazonaws.com/93/b5/f/2677/2013_1_11_FOE_Gundersen_Affidavit_reEdisonSanOnofreRSG.pdf

Full Media Alert 13-01-15 Allegation - SCE Violated Federal Reg's And The Public Trust is posted on the web at this link: DAB SafetyTeam Documents.

###
The DAB Safety Team: Don, Ace and a BATTERY of safety-conscious San Onofre insiders plus industry experts from around the world who wish to remain anonymous. These volunteers assist the DAB Safety Team by sharing knowledge, opinions and insight but are not responsible for the contents of the DAB Safety Team's reports. We continue to work together as a Safety Team to prepare additional: DAB Safety Team Documents, which explain in detail why a SONGS restart is unsafe at any power level without a Full/Thorough/Transparent NRC 50.90 License Amendment and Evidentiary Public Hearings. For more information from The DAB Safety Team, please visit the link above.

Our Mission: To prevent a Trillion Dollar Eco-Disaster like Fukushima, from happening in the USA.

Copyright January 14, 2013 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 Attorney

NRC AIT Review Of San Onofre Requires An NRR Investigation

NRC AIT review of SCE 10CFR 50.59: The NRC AIT stated in its report, “Based on the updated final safety analysis report description of the original steam generators, the team determined that the steam generators major design changes were reviewed in accordance with the 10 CFR 50.59 requirements.  The team determined that no significant differences existed in the design requirements of Unit 2 and Unit 3 replacement steam generators.  Based on the updated final safety analysis report description of the original steam generators, the team determined that the steam generators major design changes were reviewed in accordance with the 10 CFR 50.59 requirements.  

Later the NRR technical specialists reviewed SCE’s 10 CFR 50.59 evaluation against 10 CFR 50.59(c)(2)(viii) which requires that licensees obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change if the change would result in a departure from a method of evaluation described in the final safety analysis report (as updated) used in establishing the design bases or in the safety analyses.

The NRR technical specialists found two instances that failed to adequately address whether the change involved a departure of the method of evaluation described in the updated final safety analysis report.” (emphasis added)  The changes were as follows:

• Reactor Coolant System Structural Integrity - Use of ABAQUS Computer Program instead of ANSYS: The SCE’s 50.59 evaluation incorrectly determined that using the ABAQUS instead of ANSYS was a change to an element of the method described in the updated final safety analysis report did not constitute changing from a method described in the updated final safety analysis report to another method, and as such, did not mention whether ABAQUS has been approved by the NRC for this application.

• Main Steam Line Break Mass-Energy Blowdown Analysis & Tube Wall Thinning Analysis – Use of ANSYS Computer Program instead of STRUDL and ANSYS Computer Programs:  SCE’s 50.59 evaluation did not mention whether the method has been approved by NRC for this application. 

The NRR now needs to investigate why the NRC AIT Team displayed poor judgment in their review of SCE’s 10 CFR 50.59 Evaluation, which in effect, let SEC off the hook without even a fine, for making design changes that put all of Southern California at risk, since we came so very close to having a Fukushima-type radioactive nuclear accident in San Onofre less than a year ago!

Link to full Press Release 13-01-07 NRC AIT Review Requires An NRR Investigation

The DAB Safety Team: January 7, 2013    Supplemental To Our Press Release + 12-12-31

Copyright January 1, 2013 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 Attorney