SCE Cited For Major Nuclear Related Safety Violation At San Onofre

Get SCE Out of San Onofre

Background: NRC Spent Fuel Pool Cooling Requirements:

“Each licensee shall develop and implement guidance and strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire ….”

The San Onofre spent fuel cooling fire protection plan in the event of a large fire and/or explosion hinges on the expertise and staffing of the on-sight San Onofre Fire Department.

Since the San Onofre Fire Department and Emergency Planning Personnel Staffing was reduced to a skeleton crew without prior approval from the NRC after a full and proper evaluation, the existing fire plan is now outdated and unrealistic in event of a large fire or explosion.

A Spent Fuel Pool Cooling Accident, in case of a large fire or explosion without adequate and demonstrated mitigation measures is a MAJOR Nuclear Safety Concern for all the millions of Southern Californians living within the 10 Mile Emergency Protection Zone.  Remember Fukushima's triple meltdowns occurred because of a failure to keep their reactors cool after the big earth quake and tsunami which occurred on 03/11/11.

Last Friday, the NRC cited SCE, the operator of San Onofre's nuclear power plant for violating NRC rules by failing to get approval before eliminating 39 emergency-response jobs after the plant closed last year.

Historically, NRC Region IV has had the habit of citing Southern California Edison with only low level violations, even if the violations were actually severe violations.  This cozy relationship was a contributing factor in the radioactive leak that resulted in the early decommissioning of San Onofre Units 2 & 3 and the loss of billions of dollars to SoCal ratepayers that could have been prevented, if the NRC had enforced the Federal Regulations as written.  This type of safety enforcement is not good for Californians or the NRC.  Now a serious review/investigation and proper action/fines are required by the NRC and its Commissioners, to assure Nuclear Safety is maintained at San Onofre and all the other US Nuclear Power Plants.

The question the NRC should ask is, "Knowing that the SPENT FUEL POOLS MUST STILL BE KEPT COOL 24/7 no matter what, if a major earth quake occurred tonight, would San Onofre Fire Dept.'s skeleton crew be able to guarantee US that they could prevent a nuclear accident from occurring, especially since the 39 emergency-response positions that were illegally eliminated, probably cost ratepayers much less than even one still employed highly paid nuclear manager who would be home sleeping?  

The question that the CPUC should ask is, "If SEC is really interested in safety as they keep telling us, what is the reasonableness of continually cutting corners on those that actually insure our safety, while at the same time retaining other highly paid nuclear Staff?

Related articles

• San Onofre Nuclear Plant Hit With Violation
• San Onofre nuclear plant hit with violation
• San Onofre nuclear plant hit with violation
• Nation's nuclear waste a deepening concern
• Customers would get $1.4 billion in refunds in San Onofre deal

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

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.)

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

NRC Violating Presidential Directive and the Public Trust

SCE’s PR Machine Is Capable Of Overcoming ALL Hurdles,

Except Good Science And Safety

Albert Einstein also described INSANITY as

Doing the same thing over and over again and expecting different results. 

The DAB Safety Team has challenged previously in their published DAB Safety Team Documents, that Southern California Edison’s controversial plan to restart San Onofre Unit 2 as a “Bogus and dangerous SCE experiment.”  

According to SONGS Anonymous Insiders, SCE’s Engineers were under the false impression that Unit 3 Anti-vibration Structure was built better than Unit 2.  Therefore, SCE Engineers were operating Unit 3 at lower steam pressures than Unit 2 in a test mode to generate more thermal megawatts and thereby generate more electricity.

 To add to Arnie Gundersen’s and John Large’s Technical Affidavits, DAB Safety Team’s investigation reveals that in the process of this “money-hungry experiment”, lower steam pressures in combination with other unapproved and unanalyzed design changes destroyed Unit 3 due to Fluid Elasticity Instability (FEI). SCE and NRC AIT Team both blamed Unit 3 FEI on botched up MHI Computer Modeling and insufficient tube-to-AVB gaps. AREVA, Westinghouse, John Large and the DAB Safety Team findings dispute these statements. The NRC Augmented Inspection Team and the NRR Panel have swept the DAB Safety Team Findings consistently under the rug, in what must be now labeled as a Gov’t cover-up!

The NRC keeps issuing both controversial and conflicting press statements that a decision to allow the restart of Unit 2 could come as early as March 2013.  According to SONGS anonymous insiders, Edison officials have announced in internal SONGS Staff Meetings that a restart decision is imminent in March despite the huge public outcry about safety problems by SCE.  Press reports as of January 14, 2013 state, “Small steps are being taken to prepare for possibly restarting the troubled San Onofre nuclear power plant, even as its future remains clouded with uncertainty, officials said Monday. Nuclear Regulatory Commission senior inspector Greg Warnick said Monday that the agency is beginning to prepare a detailed plan of what would need to be done to bring the plant safely back to service.” (SOURCE: CBS Los Angeles, Associated Press)

NRC’s enforcement history, drama and pre-rehearsed tough questions, press reports, casual relationship and/or protection of SCE officials and utility biased public meetings are just old and cheap regulatory tricks that are now being used to protect the NRC’s own public image and to fool the public into believing that the NRC is really concerned about public safety regarding SCE’s Restart Plan.  The Justice Department & NRR Officials need to set up a legal/technical taskforce to publically question Edison’s design and MHI Engineer’s listed below under oath regarding their:

1. Understanding of their legal obligations under the 10 CFR 50.59 Process,
2. Understanding of problems with the original steam generators,
3. Critical questioning and professional/investigative skills,
4. Efforts made in industry and academic benchmarking to identify and resolve problems with the original steam generators
5. What part did they play in the preparation of design specifications, fabrication, computer modeling, mock-up testing, anti-vibration bar structure, and research required to prevent the adverse effects of fluid elasticity and flow-induced random vibrations in these unique San Onofre Combustion Engineering replacement generators.

Any NRC decision to grant a restart of Unit 2 without a formal 50.90 licensing review along with public participation will be seen as an invitation to risk a Fukushima-type disaster happening in Southern California. 

Read More:  Allegation - NRC Violating President’s Directive And the Public Trust is posted on the web at this link: DAB Safety Team Documents.

Copyright January 17, 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