San Onofre insider says NRC should not allow nuke restart

For the first time, a source from inside the San Onofre nuclear power plant has come forward to warn that restarting the power plant is too dangerous. "There is something grossly wrong," said the inside source, a safety engineer who worked at San Onofre and has 25 years in the nuclear field.

  (See the interview with the inside source from today on 10News at 5 p.m.)

 The source, who requested anonymity, is not alone in concerns over the safety San Onofre Nuclear Generating Station (SONGS).

San Onofre Fukushima USA 

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.


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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

NRR Meeting Request About SONGS Restart Safety

The DAB Safety Team and Other Experts wish to be invited to a Confidential NRR Meeting about SONGS’ severely damaged Replacement Steam Generators and other safety related problems, before any SONGS Unit 2 restart is granted by the NRC.

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Press Release

The DAB Safety Team: December 26, 2012

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

The DAB Safety Team Requests A Special Meeting With The NRR

To Discuss SONGS Steam Generator Safety

In the interest of the Health & Safety of Southern Californians, the DAB Safety Team’s Principal Investigator and Other Experts (Optional) wish to be invited to attend a Closed Door Confidential Meeting, Tuesday February 19, 2013 in Washington D.C., ideally to be held under oath, about SONGS’ severely damaged Replacement Steam Generators and other safety related problems, before any SONGS Unit 2 restart is granted by the NRC.

The following optional observers (OO) and/or participants (P) are encouraged to attend:

·      Senator Barbara Boxer (OO),

·      Senator Diane Feinstein (OO),

·      The Full NRC Commission (OO),

·      Office of Nuclear Reactor Regulations, NRR (P),

·      Atomic Safety Licensing Board Panel, ASLBP (P or O),

·      NRC Augmented Inspection Team, AIT Chief (P or O)

·      Nuclear Advisor, Senate Committee on Environment and Public Works (P or O)

The DAB Safety Team has transmitted the above Request to the Chairman of the NRC, Offices of Nuclear Regulator Regulations, Atomic Safety Licensing Board and the NRC AIT Team Chief.  A list of Potential DAB Safety Team Experts/Attorneys and Agenda will follow pending acceptance of this invitation by the NRR.  Note: The DAB Safety Team is requesting this meeting in accordance with “NRC Public Meetings and Involvement”, which states, “The NRC considers public involvement in, and information about, our activities to be a cornerstone of strong, fair regulation of the nuclear industry.”

This press release will be posted on the web at this link: San Onofre Papers.

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 San Onofre Papers, 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 please visit the link above.

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

Copyright December 26, 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.

SCE: Gambling Our Future On Probabilities & Un-Verified Data

PRESS RELEASE 

The DAB Safety Team: November 30, 2012

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

Don't Gamble Our Future On Probabilities & Un-Verified Data

SCE erroneous claims about Westinghouse and AREVA Operational Analysis (OA) as being Deterministic Analysis are misleading, confusing and controversial.  These OA’s are Actually Possibilistic Analysis, (PA) which is nothing more than Profitganda, the use of phony "feel good" information to sell an idea, product or concept to the masses.

Safety analysis can be characterized as Probabilistic, Deterministic or a combination of both known as Possibilistic Analysis.  Deterministic Analysis Definition: Analysis of a deterministic problem, without taking the probabilities of different event sequences into account. [Source: Businessdictionary.com]

1.     Attachment 6 - Steam Generator Operational Assessment- 3.6 Summary of All OAs  - The OAs (See Table 3-1) summarized in Sections 3.1 and 3.2 conclude the SIPC and AILPC are satisfied.

Table 3-1: Edison OA Approach and Results Comparison

OA Description	OA for Degradation Mechanisms Other Than TTW	TTW OA With No Effective AVB Supports	“Traditional” Probabilistic OA Prepared for TTW	Deterministic TTW OA
Reference Attachment 6 Appendix	Appendix A AREVA	Appendix B AREVA	Appendix C Intertek APTECH	Appendix D Westinghouse
Edison Claim	Probabilistic	Deterministic	Probabilistic	Deterministic
DAB Safety Team Analysis	Probabilistic	Possibilistic (Alarming)	Probabilistic	Possibilistic (Alarming)

2.  AREVA Attachment 6 – Appendix B: SONGS U2C17 - Steam Generator Operational Assessment for Tube-to-Tube Wear – page 20 - 4.2 - Operational Assessment Strategy: The nominal distance between extrados and intrados locations of neighboring U-bends in the same plane ranges from 0.25 inches to 0.325 inches due to the tube indexing. There are 36 U-bends in Unit 2 SG E-088 and 34 in SG E-089 with a separation less than or equal to 0.050 inches (Design 0.25 inches, Arkansans Nuclear One Unit 2 0.35-0.50 inches).  The U-bends with the smaller separation distances are much better candidates for wear by rubbing yet do not exhibit TTW.  Contact forces, as deteriorated by tube wear at support locations over time, will be calculated using advanced computational techniques. This will be combined with calculations of stability ratios to develop the probability of the onset of in-plane fluid-elastic instability (an alarming statement because a Main Steam Line Break (MSLB) accident has no time line), both as a function of operating power level and operating time. The operating power and operating time will be adjusted to provide a probability of occurrence of instability 0.05. This probability is based on considerations and requirements described in the EPRI SG Integrity Assessment Guidelines. Without the development of TTW, the Structural Integrity Performance Criteria, SIPC, is automatically satisfied to a probability greater than 0.95.

DAB Safety team Comment:  This is claimed to be a Deterministic OA but is using Probabilities. This is projecting possibilities using probabilities.  Hence this is an (Alarming) Possibilistic OA and not a Deterministic OA as claimed by SCE.

 3. Westinghouse Attachment 6 – Appendix D: Operational Assessment of Wear Indications In the U-bend Region of San Onofre Unit 2 Replacement Steam Generators, Page 5, Section 1- Introduction: For the SONGS application, the resulting wear distribution after a cycle of operation is known, or can be inferred from existing ECT data, but for any given tube, there are many parameters that resulted in the wear distribution that are unknown.  It can be assumed that the tube and AVB surfaces will not have significant run-in effects for the first cycle of operation, but even this assumption involves a potential error of several hundred percent. Most importantly, the tube/AVB geometry is expected to be different than the original design intent, but all that can be inferred with the available information is the minimum length of the dominant tube vibration span. In the largest sense, the answer (wear distribution) is known, but the inputs are unknown.

Foot Note 4, Page 101: Westinghouse does not have access to the assembly procedures. The 0.12 to 0.14 dimensions are anecdotal without verification.  NOTE: Anecdotal: Based on personal observation, case study reports, or random investigations rather than systematic scientific evaluation. [Source: dictionary.reference.com]

Foot Note 5, Page 102: Westinghouse does not have access to final manufacturing or inspection details, but anecdotal input indicates that six-pound weights were allowed and used during AVB inspection for consistency with AVB drawing tolerances.

DAB Safety team Comment:  When you start using the words unknown, assumed, inputs are unknown, anecdotal without verification and this assumption involves a potential error of several hundred percent, then this Deterministic OA is using unknown Probabilities and un-validated (Alarming) Possibilities. Hence this is a Possibilistic OA and not a Deterministic OA as claimed by Edison.

4. Enclosure 2 San Onofre Nuclear Generating Station Unit 2 Return to Service Report -Section 5.2.2 Probabilistic Risk Assessment: The differential pressure across the SG tubes necessary to cause a rupture will not occur if operators prevent RCS re-pressurization in accordance with Emergency Operating Instructions.

The DAB Safety Team Comment:  Do Southern Californians really want to live at the mercy of SCE’s plant operators, who will be put in the very difficult position of operating defective steam generators that already have thousands of damaged tubes, just so SCE can profit (See SONGS Union Leader's letter that the SONGS workforce thinks a restart is not safe)?  Even an Ex-Plant Shift Manager said, “He was not going to put his license on line and risk public lives because SCE Management wants to make money by restarting a defective reactor.”  The question is, how bad do these steam generators have to be before the NRC tells SCE to pulls the plug? 

The DAB Safety Team believes that SCE’s own data proves beyond a doubt, that these already heavily damaged replacement steam generators (RSG) should never be restarted.

Guessing On Nuclear Safety Caused A Trillion Dollar Radioactive Eco-Disaster At Fukushima!

Copyright November 30, 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.