What’s up with the #SCECEP

In my opinion, I’m very concerned about the way the SCE/CEP was set up and the direction the leadership of SCE/CEP is now taking us. Instead of taking the neutral position and uncovering and observing the evidence as presented they consistently and obviously put a positive spin on it. Everything is fine and SCE is doing the best job possible.

1. We must ask ourselves does this repeated positive spin serve the public interest? In my opinion No.
2. Is this Community Engagement Panel doing the best job possible to protect the safety of our communities and California? In my opinion we are not.
3. Can or will the SCE/CEP make the changes necessary in its charter to become an effective and strong safety advocate for the decommissioning and safe storage of nuclear waste at San Onofre that the people of California deserve until such time as the DOE takes possession of this long-term problem? In my opinion that is still up in the air.

To this point SCE’s attempt to be inclusive and transparent clearly has it’s limits. While asking me and others to bring up the safety concerns of the local citizens, SCE and the SCE/CEP leadership has then glossed over them, seeing these concerns only to be checked off their list one by one. Example; Tim Brown told the CA Senate Energy, Utilities and Communications Committee on Aug 12, 2014 that local concerns have be heard and addressed. Implying some sort of conclusion or satisfaction by all with SCE’s predestined decommissioning plan. Link for Senate hearing http://youtu.be/_q6YulhHpcU?t=1h2m9s starting time for Tim Brown 1:02:10 to 1:17:45. Nothing of course could be further from the truth for many in our local communities. SCE, Inclusiveness is not just a tool to be used on the “Yellow Brick Road to decommissioning”, we are not in the Land of Oz after all. We are however in the backyards of over 8.4 million Californians.   SCE and its CEP leadership now have a consistent record of spinning information to fit the SCE agenda. For example, regarding “defense in depth”, the chairman, after being concerned at first at the lack of defense in depth for dry cask long-term storage, concluded after his ‘”careful research”, that citizen activists had not asked about ” defense in depth” for waste storage before and that the nuclear industry and the NRC has done a poor job in defining  and getting the word out about “defense in depth” for nuclear waste and dry cask storage. Citing “defense in depth” as cladding on fuel rods, ceramics on the fuel pellets , even the 5/8″ thickness of the canister itself and concrete overpack of the casks as if these were “defense in depth” that were unspoken of in the past. And he was right they were not spoken of in the past as “defense in depth” because they were not considered nor should we consider them today as “defense in depth”. While these have some small measure of defense, they are not in anyway sufficient or adequate for long-term storage of nuclear waste within a heavily populated area like Southern California, and everyone in this nuclear industry knows the calculated risk they are betting on with California’s future.

David Victor’s report Safety of Long-term storage in casks: Issues For San Onofre Dec 9, 2014 does have some items we do agree on:  “It  is  likely  that  spent  fuel  will  be  stored  in  dry  casks  at  the  San  Onofre  nuclear   site  for  very  long  periods  of  time—most  likely  well  beyond  the  20-­‐year  period  for   initial  licensing  of  the  casks.” page 2 of report. “Some  elements  of  what  will  be  needed  for  “defense  in  depth”  are  not  yet  fully   in  existence—for  example,  actual  equipment  that  would  allow  removal  of  fuel  from   a  cask  without  an  onsite  pool  has  been  designed  and  a  prototype  was  demonstrated   in  the  1990s,  but  no  such  full  scale  commercial  system  currently  exists.  Similarly,   full-­‐blown  procedures  for  repairing  all  forms  of  cask  cracking  are  not  yet  fully   certified” page 4 of report. Other than these items there is not much here other than “pro nuclear industry spin.” Read full report at:https://docs.google.com/document/d/13DurWxC8l3l_VCNEGXz5bg0V4FJteepR7LVuUjPz4Xk/edit?usp=sharing

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My full statement to the NRC, Oct 27, 2014

I'd like to thank the NRC for hearing our comments today. I'am happy to see many friends here today that will speak for the safety of CA.

I must say, I no longer believe that SCE is considering doing the state of the art decommissioning that they promised us at the first Community Engagement Panel meeting. Nor do I believe that the NRC will demand or require that of them! But a more standard approach to decommissioning.

The NRC should have to be more proactive with its approach to SCEs PSDAR? The fact that the NRC does not approve or disapprove this minimalist approach to the safe storage of nuclear waste is very disappointing & alarming. Going forward with a plan that uses canisters that were designed for short-term storage does not make sense.

What would make sense to me is if the NRC would take an active regulatory role forcing & working with the industry to improve the design of the dry cask canisters and set in place a real & effective system of defense in depth, a aging management plan, for long-term storage of nuclear waste and a real method of inspection and monitoring of these improved canisters.

Thank you for listening to the people who will speak to you today for the safety of California's 8.4 million people, it's children & environment and the economy of SoCal.

You may now check this meeting off your list as another NRC public relations meeting where the public was heard but not listen too! We expect & need more than that from the NRC.

Gene Stone, ROSE, SCE/CEP Member

San Onofre Priorities: On-Site Safety, Off-Site Storage

June 7 marks the first anniversary of Southern California Edison’s decision to permanently close the troubled San Onofre nuclear plant near San Clemente. Gene Stone of Residents Organized for a Safe Environment (ROSE) summed it up this way: “We are safer – but we are not yet safe.”

There are two crucial matters: the quality of storage technology on-site at San Onofre, and the prospects for long-term storage at a remote site.

The accuracy of Stone’s words was confirmed at a May 6 workshop on managing nuclear fuel waste. Tom Palmisano, senior nuclear officer for Edison, reported that cooling pools at San Onofre currently hold 2668 spent fuel assemblies including 1115 “high burn-up,” a fuel type that is hotter both thermally and radioactively than conventional fuel.

Spent fuel from Unit 1 is already in dry casks holding 24 assemblies each. Removal of Unit 2 and Unit 3 fuel from pools will require 100 more 32-unit casks. This will triple the footprint of the concrete storage structure, from today’s 200 x 400 feet to an ultimate 400 x 600 feet.

Experts are unanimous that fuel pool hazards are far greater than dry cask storage and the intent is to complete transfer in 5 to 7 years. At that point the focus shifts to long-term safety of casks.

A lively debate at the May 6 workshop pitted Marvin Resnikoff of Radioactive Waste Management Associates against Michael McMahon from cask manufacturer AREVA and Drew Barto, lead on spent fuel storage and transportation for the U.S. Nuclear Regulatory Commission (NRC).

Resnikoff reviewed the performance hazards and risks in cask safety for long-term on-site storage and off-site transport. McMahon and Barto countered with advances in design technology that they say provide a robust and secure storage system even for high burn-up fuel. Through this exchange of sharply differing views, the workshop added value by throwing the spotlight on key technical issues in specific ways that can be debated to a point of resolution. Nuclear safety advocates will be watching the outcome closely.

The other major contribution of the workshop was to confirm a striking degree of unanimity regarding the need to revitalize the process for locating and developing sites for long-term remote storage. Gains in on-site safety promised by technology advances did not diminish the consensus that spent fuel waste should be removed from San Onofre at the earlier possible opportunity.

In part this reflects the unusually exposed nature of the San Onofre site. But sentiment runs deeper. Per Peterson, a member of the NRC’s Blue Ribbon Commission, expressed a feeling little short of dismay at the national failure to identify and develop remote storage. Edison said it is committed to this outcome as the fully satisfactory solution. Members of the expert panel as well as the Citizens Engagement Panel (CEP) that hosted the event made it clear that indefinite on-site storage remains unacceptable.

Message to the NRC: San Onofre may be the test case where all parties are urging a better way than the grotesque and inappropriate land-use outcome of constructing a nuclear waste mausoleum at San Onofre or at any other closed nuclear plant.

Dr. David Victor of UC San Diego chairs the CEP, which organized the workshop. He summed up the discussion this way: “We have an obligation to make the long-term storage of fuel as safe as possible and practical. We need a strategy for federal action on consolidated storage and ultimate repositories. Toward that end, we should articulate what we as a community need—and carry through with the Governor and Congress to assure they give priority to what is most important.”

Enter Senator Barbara Boxer and colleagues Sanders and Markey. On May 16 they introduced Senate bills S. 2324, 2325 and 2326, which would:
• Require the NRC to cease its current practice of issuing exemptions to emergency response and security requirements for spent fuel at closed nuclear reactors, unless all fuel storage at the site is in dry casks.
• Ensure that host states and communities have a meaningful role in shaping decommissioning plans for retired nuclear plants.
• Require for the first time that the NRC to explicitly and publicly approve or reject each proposed decommissioning plan.
• Ensure operator compliance with the NRC requirement that spent nuclear fuel be removed from pools and placed into dry cask storage within 7 years after the decommissioning plan is submitted to the NRC.
• Provide funding to help reactor licensees implement plans for decommissioning nuclear plants.
• Expand the emergency planning zone for non-compliant reactor operators to 50 miles.

The Boxer-Sanders-Markey bills are classic legislative oversight. They close safety-related loopholes and provide a more accountable and participatory process for affected area residents.
These sensible steps do not in themselves deal with on-site storage design technology or remote site development. But they are in the spirit of comprehensive nuclear waste management, which remains one of America’s largest environmental challenges.

By Gleen Pascall
Sierra Club

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.

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Southern California Edison Announces Plans to Retire San Onofre Nuclear Generating Station!

Southern California Edison Announces Plans to Retire San Onofre Nuclear Generating Station

San Onofre RIP

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ACTION ALERT DEMAND ACTION NOW

ACTION ALERT, WRITE OR CALL NRC COMMISSION AND DEMAND THEY TAKE LEGAL ACTION AGAINST SCE EXECUTIVES WHO LIED TO THE NRC. ITEM 2 DEMAND THE SCHEDULING OF THE ADJUDICATED PUBLIC HEARING.

Email address and Phone #’s of the NRC commission below.
Chairman@nrc.gov Tel: 301-415-1750
CMRSVINICKI@nrc.gov Tel: 301-415-1855
CMRAPOSTOLAKIS@nrc.gov Tel: 301-415-1810
CMRMAGWOOD@nrc.gov Tel: 301-415-8420
CMROSTENDORFF@nrc.gov Tel: 301-415-1800

http://www.washingtonpost.com/business/ap-exclusive-calif-sen-boxer-wants-justice-dept-probe-on-troubled-san-onofre-nuclear-plant/2013/05/28/5aaf8d48-c77e-11e2-9cd9-3b9a22a4000a_story.html

AP Exclusive: Calif Sen Boxer wants Justice Dept probe on troubled San Onofre nuclear plant

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Why fatigue damage will stop the NRC from allowing Unit 2 to restart

FATIGUE DAMAGE TO SONGS STEAM GENERATORS

J. Hopenfeld 

Provided to the “DAB Safety Team” as additional explanation of the fatigue damage to SONGS steam generators which was discussed in a report by the author and was submitted to the California Public Utility Commission on March 29, 2013

Note: Links to these documents are listed below 

SCE/MHI made a mistake in their stress analysis, which directly impacts the safety of restarting Unit 2.  When the error is corrected, the result clearly shows that Unit 2 has already used up its allowed fatigue life and is not fit for service any longer.  This means that if Unit 2 is restarted at any power level an abrupt pressure change such as inadvertent closing or opening of a valve or a steam line break could lead to a sudden tube ruptures.   The ASME code and NRC regulations do not permit safety components to operate when their fatigue life has been exhausted.

The source of MHI’s error resulted from how they calculated the increase in the local stress at geometrical discontinuities  (notches), which are formed when two metal surfaces come in contact during vibration.  Since the worn surfaces of the tubes inside the steam generators cannot be seen, MHI made two key assumptions, which are inconsistent with the observation that both the tube and the supporting bar are worn into each other.  First, MHI assumed that the ASME endurance limit could be applied directly to the notched tube surfaces.  Since it is commonly known that surface roughness significantly reduces fatigue life and since the ASME data is for smooth polished surfaces, this assumption would underestimate the amount of fatigue damage.  Second, when using the Peterson chart, MHI assumed unrealistically large fillet radius and consequently derived a low concentration stress factor.  Large radii would decrease the local stress and cause the tube to fail at a higher stress thereby increasing its fatigue life.  Only by using these two, arbitrary non-conservative, assumptions was MHI able to conclude that Unit 2 did not suffer any fatigue damage.

As depicted in the MHI drawings the support bar and the tube form a sharp discontinuity at the contacting surface, therefore the appropriate geometry for calculating the stress concentration is an abrupt geometry change (very small radii), not a large radius shoulder fillet that was assumed by MHI.  When a correction is made to account for the sharp notch, the corrected stress indicates  (see Figure 1 below) that the tubes have used up their fatigue life during the first cycle of operation.  Structures with sharp notches can fail catastrophically when subjected to high cycle vibrations.  (MHI redacted their assumption so the exact value of the radius they used is unknown.)

 The loss of fatigue life is a major defect in the tube material; NRC regulations 10CFR50, Appendix B, Criterion 16 specify that for a licensee to maintain his operating license, such non-conformance must be promptly identified and corrected.   The licensee must assure that “corrective action (is) taken to preclude repetition.  NRC’s General Design Criteria 4 and 10CFR50 Appendix A also specify that steam generator tubes must be able to “ accommodate the effects of loss of coolant accidents “ The fact that the NRC has not already raised these issues in any of their  “Requests for Additional Information, RAIs” indicates that the NRC would be ignoring its own regulations if it allows SCE to restart Unit 2.

 In Summary: The SCE request for approval to operate Unit 2 at 70 % power for 150 days provided no explanation for the selection of this inspection interval.  The absence of such explanation and the absence of an indication of the actions that would follow demonstrate the unreliability of SCE entire assessment of restarting Unit 2.  Edison did not specify pass/fail criteria for the tubes during the outage inspection.  Given the fact that fatigue damage does not lend itself to detection, SCE request is unacceptable and should be rejected. 

  

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

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

Which includes both Dr. Hopenfeld's CPUC documents as Parts 4 & 5:

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

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