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 Legacy (SOL Part 1, 2 and 3)

The DAB Safety Team released three Media Alerts today!

Together they describe (in technical detail) the current situation at San Onofre, along with what SCE, their experts and other public nuclear watchdogs are now saying about all the NRC RESTART QUESTIONS they have been told to answer:

1. SONGS Unit 2 Fluid Elastic Instability, Thermal-Hydraulic Modeling, Enlightening Dr. Pettigrew, Concerned/Frustrated NRC Commissioners and Main Steam Break (28 Pages)

snip:

The following paper shows that the entire NRC Regulatory Process is underfunded, broken and needs additional funding, oversight and extensive overhaul to ensure public safety.

2. SCE’s Dismal and Unconvincing Performance before NRC Commissioners (13 Pages)

snip:

The presentation by SCE, Mitsubishi and other experts to the NRC was very disappointing and disturbing to 8.4 million Southern Californians.  The presentation did not address U.S. Sen. Barbara Boxer and Congressman Edward J. Markey’s concerns expressed on February 6, 2013 in her letter to NRC Chairman McFarlane, “Southern California Edison was aware of problems with replacement steam generators at its San Onofre nuclear power plant but chose not to make fixes.

3. Unit 2 Retainer Bars Integrity Unproven and Unsafe During a MSLB  (12 Pages)

snip:

The structural integrity of SONGS degraded retainer bar system to withstand combined loads that result from postulated accident conditions events has not been demonstrated.

Unsafe NRC Computer Model Requires Investigation

Snip from:

Press Release 13-01-22 ATHOS Validity Questioned, Qualifying Investigation Required

The validity of the ATHOS T/H computer model for San Onofre Unit 2 at Main Steam Line Break  conditions requires that the NRC Office of Nuclear Reactor Regulations complete a Qualifying Investigation to assure steam generator tube integrity before any restart decision is made.

PROBLEM STATEMENT: The computer thermal-hydraulic models cannot account for all the mechanical factors and extremely narrow tube-to-tube clearance differences, which would very likely contribute to catastrophic tube-to-tube wear (fluid elastic instability) in San Onofre Unit 2.  In light of the 8 tube failures of Unit 3 at Main Stream Line Break testing conditions, fluid elastic instability can cause cascading tube leakages/ruptures in Unit 2 even at 70% power due to Steam Generator pressure and temperature changes caused by, for example, a main steam line break, earthquake, loss of offsite power, stuck main steam safety valve and/or other operational transients.  The cascading tube failures would “pop like popcorn” (as described by nuclear expert Arnie Gundersen) and cause excessive offsite radiation exposures.  Operator Action as claimed by Edison to re-pressurize the steam generators is not feasible to stop a major nuclear accident in Unit 2 in the first 15 minutes of a Main Stream Line Break,  stuck open SG safety valve, earthquake, steam generator tube ruptures and other operational transients during the preposed 5-month trial TEST PERIOD.

INVESTIGATION REQUEST: The DAB Safety Team seeks to assist the NRR by requesting a Qualifying Investigation, as noted above and by providing additional information, as noted below.

For much more read  DAB Safety Team Documents     “Media Alert 13-01-22 Faulty Modeling And Unreasonable Operator Actions Make San Onofre Restart Unsafe”, “Emergency Preparedness at San Onofre”, “Managing Control Room Safety” and Press Release: “TEST: Viability of Operator Actions to Prevent Offsite Radiation Releases 

=====

Some useful nuclear phrases:

Normal operational conditions

Normal operational conditions mean that the nuclear power plant is operated according to the Technical Specifications and operational procedures. These also include tests, plant start-up and shutdown, maintenance and refueling.

Anticipated operational transient

An anticipated operational transient means a deviation from normal operational conditions, which is milder than an accident and which can be expected to occur once or several times over a period of a hundred operating years.

 Unanticipated operational transient

An unanticipated operational transient means a deviation from normal operational conditions, which is not proceduralized and Plant Operator does not recognize that condition.   A good example are the so called SONGS Unit 3 false alarm from loose parts vibration monitoring system for which there is no explanation from SCE, NRC or Westinghouse.  Another example would be a leakage from a pump pumping radioactive fluid without any area radiation monitors to warn the operators of the leakage.

=====

Accident

An accident means such a deviation from normal operational conditions as is not an anticipated operational transient. There are two classes of accident: postulated accidents and severe accidents. Based on the initiating event, postulated accidents are further divided into two sub-classes whose acceptance criteria are described in Guide YVL 6.2.

Postulated accident

A postulated accident means such a nuclear power plant safety system design-basis event as the nuclear power plant is required to withstand without any serious damage to the fuel and without discharges of radioactive substances so large that, in the plant’s vicinity, extensive measures should be taken to limit the radiation exposure of the population.

Severe accident

OMG................. Talk about SanO Nuclear Denial* “severe accident” is not even listed in the 130 page NRC Collection of Abbreviations, but if you do a computer search for it on the NRC website you find this:

Severe accident

A type of accident that may challenge safety systems at a level much higher than expected.

* http://is.gd/XPjMd0
The illogical belief that Nature cannot destroy any land based nuclear reactor, any place anytime

Dangerous Safety Cover Up At San Onofre

Question 1:  What do steam generator tubes have to do with safety?

Answer: (From Nuclear Power Plant Basics)

Steam generator tubes have walls thinner than a credit card to help transfer heat, but they also MUST serve as a vitally important boundary between the radioactive coolant circulating inside the tubing from the non-radioactive water/steam mixture which circulates outside the tubing in order to prevent a nuclear incident or worse a nuclear accident!  A leak, crack or worse, a complete failure (rupture) of one (or more) of any of these thin tubes inside the steam generator would allow highly radioactive coolant to mix instantly with the non-radioactive water/steam mixture, which would then escape into the environment.  Additionally, should a main steam line break or any number of other similar problems occur, the rapid loss of core coolant that is needed to constantly cool the radioactive fuel rods in the reactor could lead to a catastrophic meltdown of the entire radioactive reactor core, like Fukushima.

Question 2:  How safe are the tubes in the 680 million dollar Unit 2 & 3 replacement steam generators at San Onofre?

Answers:

A.  At the June 18, 2012 NRC Region IV Augmented Inspection Team presentation, the NRC said, “Throughout the US nuclear industry, this is the first time more than one steam generator tube failed pressure testing…. Eight tubes failed. The pressure testing identified that the strength of eight tubes was not adequate and structural integrity might not be maintained during an accident… this is a serious safety issue.” Yet no major violations and/or fines were given, why not?

B.  Later in the November 09, 2012 report, a portion of the NRC Region IV Augmented Inspection Team report stated, “Specifically, the Supplier shall demonstrate that its design will minimize vibration-induced tube wear or fatigue in the tube bend area of the tube bundle."  The licensee did not meet Procedure ... requirements to ensure the design of the retainer bar was adequate with respect to the certified design specification.  Specifically, the licensee failed to ensure that there was sufficient analytical effort in the design methodology of the anti-vibration bar assembly to support the conclusion that tube wear would not occur as a result of contact with the retainer bars due to flow-induced vibration.   Yet again no major violations and/or fines were given, why not?

C.  A single tube in Unit 2 was then discovered with 90% wear, far exceeding its 35% wear safety limitation, that was still in-service until Unit 2 was shut down for a scheduled refueling and Edison never even knew it!  Yet again no major violations and/or fines were given, why not?

Note: Tubes hitting against their retainer bars causing wear problems are just one example of Edison's failure to meet their Certified design specifications.  By not doing this, Edison violated the 10 CFR Part 50, GDC 14 and Steam Generator Tube Structural Integrity Criteria.  In short, the failure of eight (8) steam generator tubes in San Onofre Unit 3 Replacement Steam Generator E-088 during “in-situ” (in place) main steam line break pressure testing should have been characterized as a RED major safety violation of Edison's licensing commitments, instead of a GREEN very minor violation and yet again no major violations and/or fines were given, why not?

Question 3:  Is anyone really enforcing Public Safety at San Onofre?

Answer: Instead of performing the strict enforcement required of an Independent Regulator tasked with ensuring Public Safety, it is the DAB Safety Team’s opinion that NRC Region IV Augmented Inspection Team is helping cover up both Edison's dangerous steam generator tube design and their gross negligence.  Because Region IV's investigation does not meet the NRC Chairman’s Standards, the NRC needs to investigate itself ASAP to find out why no major safety violations and/or large fines have been given out.

Want to read more, Allegation - Dangerous Safety Cover Up At San Onofre will soon be posted on the web at this link: DAB Safety Team Documents.