Update 10-14-12, SCE’s Replacement Steam Generator $680 Million Debacle

The DAB Safety Team’s - Update 10-14-12,  SCE’s Replacement Steam Generator $680 Million Debacle

1.   If SCE’s and MHI’s Engineers had used all the following guidelines, they would have prevented the

Replacement Steam Generators (RSG’s) catastrophic failures and they would not be in financial trouble with the SONGS Union Workers, the NRC, the Public, the News Media and their Ratepayers:

• ·       Human Performance Tools, along with the NRC Branch Chief and the World’s Foremost Expert’s sage advice of “read between the lines', ‘use critical questioning & an investigative attitude', 'solid teamwork & alignment, and ‘read the academic papers on eliminating fluid elastic instability and flow-induced vibrations in nuclear power plant components.”
•  ·       Benchmarked the design details of Palo Verde and other CE RSGs design details in order to eliminate any potential fluid elastic instability and or flow-induced vibrations experienced in the SONGS CE Original Steam Generators (OSGs), so that they would not occur in their new RSG’s.

  2.  SCE should have embraced rather than bypassed the FULL NRC Licensing Amendment Process.

• ·       SCE “Sweet Talked” the NRC into accepting the results of Inadequate Industry Benchmarking and the Defective 10 CFR 50.59 Evaluation and thus avoided the thorough and lengthy scrutiny of FULL NRC 10 CFR 50.90 Licensing Amendment Process.
•  ·       Note, the lack of strict oversight by Region IV NRC Staff as required by NRC Reactor Oversight Process, was a critical flaw that enabled the debacle.

WHAT IS NEEDED to prevent the adverse consequence of a Main Steam Line Break outside Containment and the resulting nuclear radiological disaster in Southern California, if SCE’s Degraded Unit 2 is allowed to restart at 70% power for an operations trial period of 5 months as an, “Unapproved Experiment”, as SCE and 3 out of 4 Nuclear Energy Institute Qualified “US Nuclear Plant Designers” are recommending?

1.   Submittal of a NRC 10 CFR 50.90 Licensing Amendment Application for SONGS Unit 2 Restart Plan by SCE.

2.   A thorough review of SONGS Unit 2 Restart Plan Return to Service Report by Region IV NRC Staff, NRC Chairman and Commissioners, U.S. Senate Committee on Environment & Public Works, and independent verification/ by the NRC Offices of Nuclear Reactor Regulations, Nuclear Regulatory Research¹ and the Union of Concerned Scientists.

3.   Sworn testimony by all parties responsible for the preparation of SONGS Unit 2 Restart Plan Return to Service Report to insure that public safety and health will not be compromised in case of a nuclear Accident caused by a Design Bases Earthquake/Main Steam Line Break due to multiple tube leaks or ruptures or combination thereof.

4.   Investigation of SONGS Safety Violations and Worker Discrimination, Retaliation, Intimidation and Harassment by an Independent Federal Commission appointed by the President or the Supreme Court of the United States.  This is required to guarantee public acceptance of the results these investigations by the people of Southern California.

5.    Return of the 1.2 Billion Dollars that the ratepayers have “fronted” SCE to date, with interest.

6.    A Financial Bond Guarantee by Southern California Edison to cover the Financial Ruin of Southern California’s economy in case of any nuclear Incident/Accident.

_____________________________________________________

¹Dr. Joram Hopenfeld, a retired engineer from the Office of Nuclear Regulatory Research, sharply criticized NRC officials for downplaying the dangers of degraded steam tubes in  December 1999, three months before the Indian Point accident, and said, “To be credible, risk-informed regulation mandates statistically valid and scrutable data, competent insights of accident scenarios and their consequences, and of accident prevention strategies, as well as meaningful public involvement. In reality, the staff examines accident scenarios and their consequences in a superficial manner; accident prevention is apparently dictated primarily by financial considerations, and the public is being excluded from meaningful participation in the NRC deliberation process’, ‘The nuclear industry and the NRC have a poor track record of controlling steam generator tube degradation.” The NRC's Advisory Committee on Reactor Safeguards (ACRS) issued a report in February 2001 and substantiated many of Dr. Hopenfeld's concerns.

Copyright October 14, 2012 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team.

ACTION ALERT "DEMAND ADJUDICATED EVIDENTIARY HEARING"

The Nuclear Regulatory Commission is headed by five Commissioners appointed by the President and confirmed by the Senate for five-year terms. One of them is designated by the President to be the Chairman and official spokesperson of the Commission. Find out more about the Commissioners:http://www.nrc.gov/about-nrc/organization/commfuncdesc.html

We NOW need to take our Core Message to all five Commissioners, based on NRC Regional Administrator Elmo Collins' statement in the NRC Public Mtg last night that requests for an adjudicated evidentiary hearing from panel and audience members were heard loud and clear. And that, while by policy, the NRC does not have a hearing requirement in place, a decision on if and when such a hearing will happen is up to the five-member NRC board.

Chairman Allison M. Macfarlane: Tel: 301-415-1750 E-Mail: Chairman@nrc.gov

Commissioner Kristine L. Svinicki: Tel: 301-415-1855 E-Mail:CMRSVINICKI@nrc.gov
(She is on Facebook, too: Kristine Svinicki -- you can Message her w/o being Friends.)

Commissioner George Apostolakis: Tel: 301-415-1810 E-Mail: CMRAPOSTOLAKIS@nrc.gov

Commissioner William D. Magwood: Tel: 301-415-8420 E-Mail: CMRMAGWOOD@nrc.gov

Commissioner William C. Ostendorff: Tel: 301-415-1800 E-Mail: CMROSTENDORFF@nrc.gov

Our Core Message: "We oppose Edison's proposed re-start of the defective Unit 2 at San Onofre and demand a full, transparent Adjudicatory Hearing and License Amendment process, including evidentiary hearings with sworn testimony and cross-examination which include experts independent of the NRC, Edison and the nuclear power industry. This public meeting is NOT a proxy nor a substitute for this process. Given how we got to this point and the serious loss of faith by the public in the NRC and Edison as a result, we can see no reason why all five NRC commissioners would not want this as well."

For maximum transparency and public engagement, we want this Adjudicatory Hearing to be held IN Southern California, at a venue that is fully accessible to the public, with ample, free parking and public transit service. NOT at a posh, private resort that limited access by the media and the public at the NRC's public meeting at the St. Regis Monarch Bay Resort in Dana Point on October 9, 2012, for which $24,000 was outrageously paid.

Gene Stone
Residents Organized For a Safe Environment (ROSE)

Nuclear Regulatory Commission Public Meeting Tonight

The Nuclear Regulatory Commission (NRC) has scheduled a Category 3 Meeting Tonight, October 9, 2012, from 6 p.m. to 9:30 p.m. at the St. Regis Monarch Beach Resort, 1 Monarch Beach Resort, Dana Point CA. 92629.

Get there at 5pm to let your voice be heard!

The San Onofre Nukes are mirror images of one another. 
To shutdown one & startup the other, is suicidal.

SCE's Restart PR Campaign Backfires in MV!

SCE's RESTART PR campaign is now in full swing, please tell your friends to find out what SanO insiders are saying about all the technical issues AGAINST RESTARTING SanO, before they attend the NRC Dana Pt. meeting on 10-09-12.

The complete 6 page PR memo can be viewed online http://be.rtgit.com/DABSANO  along with many other of the DAB Safety Team's "Papers", like "DAB Safety's Initial Response to SCE's Restart Plan", so please bookmark it as MORE information will be posted to keep you in the know.

Remember:

       Any SCE restart is nothing but a $1.2 Billion Get out of Jail Free Card for them!

Just SAY N☢ To Any Restart TESTING, SoCal cannot afford a Trillion Dollar Eco-Disaster like Fukushima!

CaptD

p.s. Kudos to Joe for the SCE PR Restart Pitch Info!

San Onofre Nuke Restart Cancelled

The Nukes at San Onofre are mirror images of each another.
To shutdown one, and startup the other, is suicidal. 

If you look at the charts released by Southern California Edison (SCE) today, showing the tube wear in the replacement steam generators in San Onofre Units 2 and 3, nearly every chart looks identical from one unit to the other in location, shape, and so forth, if not in amplitude: Unit 3 had more of everything, but its clear that the basic design was bad. It apparently wasn't a manufacturing or operating error that caused the problem, and it can't be fixed without completely redesigning the steam generators, and that will take several years.

While that's undoubtedly what they plan to do for unit three, and while the two reactor's steam generator designs are virtually identical, we're nevertheless told they're utterly different -- as long as Unit 2 is operated at 70% power for not more than about eight months.

SCE has chosen five months as the maximum operating time without further inspection. They'll know their plan is a failure if/when a tube ruptures. It's the only way to tell.

After eight months, the estimated risk probability (which steadily increases as long as the plant is running) gets too high. It's very literally a calculated risk. SCE feels that limiting themselves to five months is "conservative" and "safe."

Is it? One activist put it this way: "Their safety plan is simply to watch more carefully for radioactive leaks!"

Tell SCE no!

And while you're at it, ask for your portion of the 1.2 billion dollar + interest rebate they owe all their rate payers! (that's the $671 million we are paying for the replacement steam generators, plus an additional $65 million per month that rate payers are paying SCE and SDG&E for nothing, while the reactor units are out of commission.)

SCE plan to run at 70% power means 70% output power to the grid. What the actual pressure differences, temperature differences, flow rate differences, etc. will be is (hopefully) buried in the minutia SCE published today as part of their restart plan (I haven't found it yet, though), but it will be >70%, that's for sure! And what's to stop them from exceeding the 70% figure? SCE says power will be limited "administratively", which means an "administrative" decision can be made to increase the power to 71% -- or 100%. It could even be done by accident, or by a hot-shot control-room operator who thinks it's safe and wants to prove it! That's basically what happened in Chernobyl: The operators ran unauthorized safety "tests". This whole operation is an unauthorized safety test. The people do not authorize it!

Plus, Edison might also be tempted to exceed that 70% power level during a "Flex Alert" emergency in order to protect "grid stability" since SanO is considered "baseline" power (and SCE would get well-paid for doing it).

Will Fluid Elastic Instability (FEI) occur during a Main Steam Line Break (MSLB), perhaps because one of the new sensors they plan to add to detect leaks pops out because it wasn't installed properly by Curly, Moe, and Larry, the work crew at SanO? (And of course, they were afraid to report that they couldn't fit it in right, because of ongoing worker intimidation at the plant!)

These already-worn-out steam generator tubes could vibrate excessively during a variety of "unusual events". How does an "administrative limit" guarantee anything?

And what about the ever-present possibility of unintended "power excursions" inside the reactor? These are one of the most-feared (and least understood) potential events in a nuclear plant! How can SanO possibly guarantee that a power excursion won't require more than 70% heat removal through the steam generators?

What if controls rods fail to drop because of an earthquake that also causes a MSLB?

Earthquakes are not a chance or random occurrence for SanO: They are an inevitability. And I mean big ones! It's just a question of when, not IF, which is yet another reason not to allow a restart of SanO when it is not in 100% perfect working condition -- or ever.

The extra "N-16 sensors" they plan to add, prove that they realize they are still battling the POSSIBILITY of FEI and they don't know if their solutions will work. So in fact, they are experimenting with our lives and our communities, and putting our future at stake. Furthermore their decision to add these sensors proves that pressurized water reactors around the country probably also need to SHUT-DOWN to add these sensors as well. The USA cannot afford a Trillion Dollar Eco-Disaster like Fukushima, especially in Southern California!

Nitrogen-16 is produced in copious quantities inside the reactor, but its decay is so rapid (seven seconds) that by the time it was detected on January 31st, the leak had already grown significantly. In a very short time, FEI can go from a small leak to a full-on cascading series of tube failures, which would cause a nuclear incident or even a major nuclear accident!

SCE's Ron Litzinger stated this morning (see below): "When implemented, this plan will get San Onofre Unit 2 back to providing reliable and clean energy to Southern Californians."

Ron Litzinger's quote should read: "When implemented, this experimental plan will cause San Onofre Unit 2 to once again create about 250 pounds per day of waste that is so toxic, that the daily amount alone is enough poison, if it gets released, to render all of Southern California permanently uninhabitable within hours -- long before any actual evacuation could have occurred."

He should then have added that when he says San Onofre will be reliable, he means until something else breaks, or an outside triggering event occurs, such as a grid failure, earthquake, tsunami, etc.. And then he could mention that after running for five months at 70% power, and then inspecting the steam generators as quickly and lightly as they can get away with, they'll request to run hotter, for longer.

Also notice their current plan would almost surely put Unit 2 out of commission for inspection right smack during the summer months of 2013, a peak usage time. Are they hoping for blackouts next summer, having missed them this summer despite San Onofre being inoperable since January 31?

San Onofre's replacement steam generators were never reliable, and they won't be now, since they are already damaged. All of San Onofre is old and unreliable.

The safest thing for Southern California is to keep San Onofre shut down forever, especially since we have a 40% power surplus that is safely generated without it!

Via 

Ace Hoffman 

Carlsbad, CA 

California ISO prepares for another potential summer without San Onofre generation

News Release

News Release

For immediate release | September 13, 2012 Media Hotline  888.516.6397

For more information, contact:

Steven Greenlee | sgreenlee@caiso.com Stephanie McCorkle | smccorkle@caiso.com

California ISO prepares for another potential summer without San Onofre generation

FOLSOM, Calif. – The California Independent System Operator Corporation (ISO) is taking steps now to prepare for the summer of 2013 should Southern California remain without the generation from the San Onofre Nuclear Generating Station. ISO experts briefed the Board of Governors at their meeting today on recent analysis of grid needs should the nuclear plant not return to service.

Topping the list of recommended mitigation actions is converting Huntington Beach units 3 and 4 into synchronous condensers. The units were brought back into service this year to fill the void left by the nuclear plant shutdown. As synchronous condensers, the Huntington Beach units do not produce electricity and therefore, no air emissions credits are required.

Instead, the condensers, acting somewhat like spinning flywheels, adjust to grid conditions by providing the voltage support, normally supplied by the nuclear plant, to the local 230 kilovolt switchyard. Megavars, instead of megawatts, would be produced and used to push megawatts through the grid, much like water pressure helps push water through a hose.

Two analyses provide the basis for today’s briefing: The Addendum to the 2013 Local Capacity Technical Analysis and 2012-2013 Preliminary Reliability Results, both available on the ISO website, caiso.com. The analyses also identify adding capacitor banks on Southern California Edison’s electric systems to provide transmission line voltage support. The Board today approved the staff recommendation to designate the Huntington Beach units as reliability must-run for voltage support in 2013. The designation is one step toward providing reliability in southern Orange and the San Diego counties. If it later determined additional resources are necessary for must-run services, ISO management will seek further Board approval of those additional reliability must-run contracts.

The state’s resource adequacy program has greatly reduced the need for must-run designations over the past few years, although the Board did approve extending a contract for the Dynegy Oakland facility through 2013 for 165 MW. The ISO tariff allows must-run designations under very specific circumstances such as making sure areas have enough local capacity available, mitigating local market power or providing voltage support.

Link: http://is.gd/eyetRe

The Number 1 US Nuclear Safety Concern ==> San Onofre's Replacement Steam Generators

The DAB Safety Team is thankful to numerous anonymous concerned SONGS Workers, who have provided factual information in the interest of the Public Safety to us so that we could arrive at these “Reasonable Conclusions” regarding SONGS Replacement Steam Generators Degradation.  We acknowledge Fairewinds Energy Association, Professor Daniel Hirsch, Friends of the Earth, San Clemente Green, Media, News Papers and the SD Reader, whose material has contributed to the successful completion of this document.

NOTE: These Preliminary Conclusions are subject to change upon receipt of Southern California Edison's (SCE) SONGS Unit 2 Restart Plan and Mitsubishi Heavy Industries (MHI) Root Cause Evaluation.

 

If SONGS Unit 2 is allowed to operate at reduced power, an Un-isolable main steam line break accident can occur at any time, due to a postulated design basis earthquake and/or any other associated failure.  Due to this event, the depressurization of the steam generator caused by the steam line break coupled with the excessive vibrations due high differential pressure (> 2250 psi), high reactor coolant water temperature inside the tubes, the compact space between the SONGS U-Tube Bundle and the moisture separators (compared with other Mitsubishi Steam Generators) and the steam over-pressurization would cause the elastic deformation (NRC AIT Report, Mitsubishi Preliminary Cause Evaluation) of the taller U-tube bundle due to increased U-tube bundle height, high localized steam-voids or dry-outs (two-phase mist region, almost devoid of water in undefined central portion of the U-tube bundle above the 7^th support plate) and narrow-pitch/tube diameter ratio.  This unanalyzed and rare phenomena not experienced in the Steam Generators operating history, in turn, would cause the onset of fluid elastic instability conditions due to the 100% localized steam voids in the central portion of U-Tube bundle above the 7th Support Plate.  The fluid elastic instability conditions would result in further lowering the already low in-plane tube clearances (Attributed to unanalyzed effects because of addition of more tubes to achieve more thermal MWt out of the SGs). The combination of these factors along with a poorly designed anti-vibration support structure [low damping capability of the support structure (i.e., the tube support plates, the tube-sheet, and the anti-vibration bars)] would result in excessive and violent vibrations, cause tubes to hit each other in the in-plane direction, result in leaking tubes, which would cause high-pressure primary sub-cooled water jets.  These high-pressure jets would cut holes into other already worn tubes and create undetermined number of cascading tube ruptures.

The cumulative effects of the above conditions along with the unanalyzed effects of plugged and staked tubes would rupture other damaged, plugged, staked and worn tubes.  The amount of leaking reactor coolant through these ruptured tube cuts is beyond the analyzed limits of a SONGS UFSAR Analysis [Three combined independent events loads (DBE + MSLB + LOCA)] that would be released via the blowing radioactive steam carrying Un-partitioned reactor coolant from the Un-isolated steam generator into the environment.  This uncontrolled radiological accident would release significant amounts of radiation, which could adversely affect the health and safety of all Southern Californian residents plus the transient population within the 10-mile Emergency Planning Zone.   We believe that this scenario can also progress into a nuclear meltdown of the reactor due to potential errors by plant operators unable to diagnose and control rapidly changing plant conditions due to the confusion caused by the non-user friendly and complex, abnormal, emergency operating and emergency plan implementing procedures.  

This scenario is a departure from a method of evaluation described in the UFSAR used in establishing the SONGS design bases or in the safety analyses and requires a NRC 50.90 License Amendment before SONGS Unit 2 or 3 can be allowed to restart.  A permission by NRC for SONGS restart of either Unit 2 or 3 without the 50.90 License Amendment would be construed as: (1) Repeat violation of NRC 50.90 License Amendment Process by SCE, (2) Violation of SCE’s Overriding Obligation to protect the health and safety of Southern Californians from radiological accidents, and (3) Inconsistent with the NRC's long history of commitment, transparency, participation, and collaboration with the public's oversight of Nuclear Reactor regulatory activities.

-- The DAB Safety Team

Do You Live In The San Onofre Fallout Zone?