So Cal Edison In Violation And Cannot Be Allowed To Restart San Onofre Unit 2

SCE is now in Violation of 10 CFR 50, Appendix A, GDC 14, 15, 30 and 32 Requirements... And cannot be allowed to restart Unit 2 at ANY power level!

Decommission San Onofre

SONGS is required to inspect its steam generators (SG’s) and repair or remove from use any tubes found to contain flaws exceeding 35% of the nominal tube wall thickness.  SCE was operating SONGS Unit 3 RSG E-088 for 11 months with eight tubes with flaws ranging from 72-100% in violation of the above law.  Now SCE wants to jeopardize the safety of 8.4 Million Southern Californians by restarting their degraded Unit 2 RSGs with 2 flawed tubes exceeding 28% of their nominal tube wall thickness along with thousands of other fatigue damaged tubes that may have undetected, untested, undiscovered, unmeasured, undocumented and or un-quantified cracks and run it for 5 months!

SCE is desperately trying to justify the restart of Unit 2 based on conflicting, confusing and erroneous Operational Assessments prepared by Westinghouse, AREVA, Intertek and MHI with Inscrutable (Undecipherable) Data and under-conservative computer models, which are not applicable to 100% Steam Voiding caused by a Main Steam Line Break and sub-cooled feed water flashing conditions due to Steam generator depressurization.   The nominal tube wall thickness “flaw” of 28% of these tubes is projected to be > 31% during the 5 month trial restart of Unit 2 based on untested data, that may be applicable to other plants, but not to SONGS.  Based on the history of the catastrophic and unprecedented failure of eight Unit 3 SG E-088 tubes, Unit 2 SG design deficiencies and incomplete tube inspections, these flaws can exceed the 35% plugging limit at any time prior to the end of 5 months trial period due to any abnormal plant operations or transients [e.g., loss of offsite power, adverse local thermal-hydraulic conditions (like high Steam voids of > 99.6% due to narrow tube pitch to tube diameter ratio, low tube clearances), etc.], all of which are beyond the control of the operator.  Hence, the Public and the Regulators will never know, until it is too late, when Unit 2 again will be operating in violation of the Technical Specifications Limit.  Unit 2’s Restart Effort is just an unapproved and desperate experiment, which is not permitted by law.  The only legal option SCE has is to apply for a thorough NRC 10 CFR 50.90 License Amendment, along with transparent and trial-like public hearings.  Anything less, would be a regulatory failure by the NRC, to protect public safety and a violation of the authority and the privileges granted by the President and Congress of the United States.

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 Read the complete Press Release + 12-11-19 

à For additional technical information read The DAB Safety Team’s: SONGS MSLB Analysis

San Onofre's Unsafe Inspections Put SoCal At Risk

San Onofre Unit 2 Replacement Steam Generators Incomplete and Inadequate Tube Inspections

San Diego, CA (November 9, 2012) – The failure of eight Replacement Steam Generator (RSG) tubes (something which has never happened before) plus the structural integrity of thousands of additional damaged tubes in both SONGS Units 2 and 3 RSG’s are now in question and affect the safety of about 8 million Southern Californians.  This design failure, which has been termed by the NRC as “a very serious safety issue” because of the unprecedented tube damage: Unit 3 has 807 tubes plugged and Unit 2 has 510 tubes plugged – which makes them the 2 WORST RSG’s in the history of the entire U.S. Nuclear “Fleet”.  Which means that SCE was operating beyond their Current License Basis (CLB) and Safety Analysis Limits, plus SCE has yet to be penalized by the NRC for these violations, as required by law.  These RSG failures also offers real proof for the very first time, that if a Main Steam Line Break accident had occurred, at least eight RSG tubes would have leaked/ruptured and potentially caused the SONGS Unit 3 reactor to become a nuclear disaster (e.g., like Fukushima, Chernobyl or Three Mile Island) due to the loss of undetermined amount of radioactive core coolant! 

The truth is that San Onofre escaped becoming an International Nuclear Events Scale (INES) Level 7 nuclear disaster by the slightest of margins, unlike Fukushima!

SONGS Reactor Compatibility Experiment (RCE) States, “Visual inspection of the tube sheet primary side of the SG 3E088, with the secondary side pressurized, identified the tube with the leak.  Subsequent Eddy Current Testing (ECT) inspection identified extensive unexpected tube free-span
wear at the leakage location, not typically seen in recirculating SGs, and tube-to-support wear.  A full-length ECT inspection of each tube (100%) in all four SGs using a bobbin coil probe was performed and provided a comprehensive extent of condition evaluation for tube free-span and tube-to-support wear. The bobbin coil probe inspection was supplemented by Rotating Coil (+Point) probe inspection, which provided further confirmation of the extent of condition.  This supplemental rotating probe examination covered the U-bend portion of approximately 1300 tubes in each SG.”  Thousands of Unit 2 Steam generator tubes, Anti-vibration Bars and Tube support Plates have suffered extensive wear and undetermined amount of internal cracking during 22 months from flow-induced random vibrations and/or cyclic fatigue.  In addition, SCE has only performed remote visual inspection of 8% of the tubes in their damaged Unit 2 RSG’s plus this does include inspection of any tube support plates for any visible damage, structural deformation, cracks and/or any other abnormalities. 

The methods employed by SONGS using bobbin and rotating coil (+Point) probes to inspect the Unit 2 damaged tubes cannot reliably determine the depth, extent and location of these cracks, so the actual condition of the tubes remains a dangerous unknown!  In a Rush to Restart Unit 2 and cut their costs, Edison has not inspected more than 2000 Unit 2 Steam Generator tubes with T/R single-pass array probes, laser-scanned penetrant inspection and ultrasonic detection technologies to accurately identify and determine the depth, extent and location of these internal cracks at the U-bends and tube-support intersections.  NRC's regulations do not allow SONGS to start up with any steam generator tube cracked more than 35% of its wall thickness. Therefore by not performing these accurate inspections, Edison has not met the performance criteria specified in 10 CFR Part 50, Appendix A, “General Design Criteria for Nuclear Power Plants,” Criterion 14, 15, 30 and 32, which establishes the fundamental regulatory requirements for the integrity of the SG tubes. 

The DAB Safety Team has concluded that SONGS Unit 2 Replacement Steam Generators (RSG) are in worse shape now than certified by SCE and their three NEI Qualified, “U.S. Nuclear Plant Designers.”  The accident scenario of concern consists of two events: (1) a non-isolable secondary system break or rupture that is outside containment; and (2) a coupling of this break with the rupture of, or significantly increased leakage from, affected SG tubes.  Even at 70% power operations, if a steam line break outside containment were to occur in Unit 2, the depressurization of the steam generators with the failure of a main steam isolation valve to close would result in 100% void fraction in the degraded U-Tube bundle and the straight leg portion between the Tube Support Plates.  This condition of ZERO Water in the steam generators would cause fluid elastic instability (FEI) and flow-induced random vibrations, which would then result in massive cascading SG tube failures, involving hundreds of degraded active SG tubes. Fluid elastic instability (FEI) and flow-induced random vibrations can progress through a buffer zone of plugged tubes to reach pressurized, in-service tubes and create additional SG tube failures.  The resulting SG secondary side blow-down could further increase tube leakage due to resonance vibrations within the affected SG tube bundle.  With an undetermined amount of simultaneous tube leaks/ruptures, approximately 60 tons of very hot high-pressure radioactive reactor coolant would leak into the secondary system.  The release of this amount of radioactive primary coolant, along with an additional approximately 200 tons of steam in the first five minutes from a broken steam line would EXCEED the SONGS NRC approved safety margins.  So, in essence, the RSG’s will become loaded guns, or a nuclear accident waiting to happen.  Any failure under these conditions, would allow significant amounts of radiation to escape to the atmosphere and a major nuclear accident would easily result causing much wider radiological consequences and even a potential nuclear meltdown of the reactor!  Since these events would happen at an extremely fast pace, no credit is assumed in the first 5 minutes of the main steam line break accident for: (1) Enhanced Unit 2 Defense-In-Depth Actions - SCE Restart Plan Enclosure 2, Item 9.0, and (2) The differential pressure across the SG tubes necessary to cause a rupture will not occur if operators prevent RCS re-pressurization in accordance with their Emergency Operating Procedures - Enhanced Unit 2 Defense-In-Depth Actions - SCE Restart Plan Enclosure 2, Item 5.2,2, Probabilistic Risk analysis.

In Emergency Planning Space, decisions have to be Accurate and Timely. Under-conservative, rushed and profit-motivated analyses based on limited facts, biased and ambiguous operational data, untested deterministic and probabilistic risk analysis, conflicting theories and differing operational assessments of degraded equipment at even reduced power operations for 150 days with conditional monitoring along with unproven and unreliable compensatory actions represent enormous risks to public safety, the environment and our nation’s economy. 

The NRC must REALLY resolve the concerns stated above as soon as possible. In the interim, the NRC must stop making favorable decisions to SCE (especially when it lacks defensible technical and inspection bases), which affect the lives of millions of Southern Californians."

The above analysis is consistent with the conclusions and reports provided earlier on this subject by:

1.     Fairewinds Associates Internationally Known Nuclear Consultant Arnie Gundersen and his team of Anonymous Industry insiders, who have had lengthy careers in the design, fabrication, and operation of nuclear steam generators.

2.     Professor Daniel Hirsch and Internationally Known Nuclear Consultant Dale Bridenbaugh.

3.     Dr. Joram Hopenfeld, a retired engineer from the Office of Nuclear Regulatory Research and NRC's Advisory Committee on Reactor Safeguards (ACRS) report issued in February 2001, which substantiated many of Dr. Hopenfeld's concerns,

4.     David A. Lochbaum, Director of the Nuclear Safety Project for the Union of Concerned Scientists (UCS).

CPUC: California Public Utilities Commission

DBA: Design Basis Accident

ECT: Eddy Current Testing

FEI: Fluid Elastic Instability

MHI: Mitsubishi Heavy Industry

MSLB: Main Steam Line Break

NRC: Nuclear Regulatory Commission

RCE: Reactor Compatibility Experiment

SCE: Southern California Edison

TTW: Tube-to-Tube Wear

DAB Safety Team

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

Don Leichtling and Ace Hoffman are the spokesmen of the DAB Safety Team, who along with the support of an ever-growing number of SONGS Concerned Insiders and Whistleblowers have prepared the following analysis.

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Copyright November 9, 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.

Will the NRC give SCE what it wants, permission to restart unit 2?

Will the NRC give SCE what it wants, permission to restart?

A PUBLIC MEETING NOTICE: San Onofre Nuclear Generating Station DOCKET: 05000361/362 November 16th, 2012 6:00 p.m. – 9:00 p.m. (PDT) LOCATION: Doubletree Guest Suites, Doheny Beach, CA 34402 Pacific Coast Highway Dana Point, CA 92629.

The 8.4 million citizens in the 50 radius of San Onofre should be very worried about the Southern California Edison's plan to restart unit number two at SONGS. SCE will explain in detail their plan of action to restart unit #2 at this meeting. For your information and safety please attend this meeting. Will the NRC give SCE want it wants, which is permission for them to restart without making any repairs to unit #2, with only the addition of a sound listening device to hear if there is a new steam leak?

The NRC has not replied to the public demand for an adjudicated public hearing that was clearly heard and understood by Mr. Collins at the last NRC meeting on San Onofre on October 9, 2012. How long will the public have to wait for an answer? Time is running out, and the NRC's credibility is once again in question. Just what are the NRC alliances? Why is there such a rush to restart this defective steam generator? 

Will the NRC ever respond to the questions submitted by David Lochbaum of the Union of Concerned Scientists?  These question where:

Union of Concerned Scientists has serious concerns about Southern California Edison’s (SCE) restart plans for San Onofre Unit 2. In a 10/12/2012 letter submitted to the Nuclear Regulatory Commission (NRC), David Lochbaum, Director, Nuclear Safety Project, identified the following issues:

1.      Unit 2 replacement steam generator 2SG89 has significantly more wear indications per number of supports than does [Unit 2] replacement steam generator 2SG88. Until the reason for this marked difference between the wear degradation for the Unit 2 replacement steam generators is understood, the operational assessment performed for future operation is suspect. [See graph in Lochbaum letter].

2.      Since all four replacement steam generators came from the same manufacturer, were of the same design, made of the same materials, assembled using the same procedures, and operated under nearly identical conditions in twin reactors, the reason for this marked difference is unclear… [the] explanation is not well documented and therefore appears to be more convenient than factual.

3.      The document states that the owner will “administratively limit Unit 2 to 70% reactor power prior to a mid-cycle” outage to inspect the replacement steam generators. What are the legal consequences if the reactor power were to increase to 75%, 85% or 100% power? The NRC has licensed San Onofre Unit 2 to operate at 100% power. What would legally prevent the owner from restarting Unit 2 and increasing its output to the NRC licensed limit? The NRC’s enforcement program includes sanctions when its regulations are violated, but nothing for broken promises. If the NRC agrees that reactor operation at less than 100 percent power is warranted, it should enforce that reduction with an order or comparable legally-enforceable document.

4.      Table 8-1 of Enclosure 2 and its accompanying text attempt to explain how operating Unit 2 at 70% power will prevent the tube-to-tube wear (TTW) experienced on Unit 3 by comparing it to an anonymous reactor (called Plant A). ..reliance on one suspect data point (Plant A) is hardly solid justification for operation and 70% power being acceptable.

5.      There is no justification in this 80-plus page document for an operating duration of 150 days.

6.      … there are no legal means compelling the plant’s owner to shut down Unit 2 after 150 days of operation at or above 15% power.

7.      ...a temporary nitrogen-16 radiation detection system will be installed prior to the Unit 2 startup. However, there is no commitment to use it after startup, or to keep it in service should it stop functioning. The detection system is proposed as a defense-in-depth measure, but there is no assurance it will be operated.

8.      Attachment 6 to Enclosure 2 has proprietary information redacted. Section 1.4 of Enclosure 2 states that the owner used AREVA, Westinghouse Electric Company LLC, and Intertek/APTECH to review the operational assessment. At least one of these companies manufactures replacement steam generators and would therefore be a competitor to Mitsubishi Heavy Industries (MHI), which made the replacement steam generators for San Onofre. If the owner did not withhold the proprietary information from MHI’s competitors, why withhold it at all? If SCE did withhold the proprietary information from these reviewers, what is the value of their independent, but limited, review?

The question has to be asked should the restart be put on hold until the Academy of Science cancer study is completed, and should real time radiation monitoring be put in place on NRC's or SCE's website prior to a restart? The public needs to see for themselves what is being released when this defective steam generator blows again.

It is clear to ROSE that the rush to restart unit two is on, and the decision by the NRC to let SCE move forward has been made at the highest levels of the NRC.

One last question remains will you stand up for the public’s right to know and for the safety our children deserve?

Gene Stone, ROSE

http://residentsorganizedforasafeenvironment.wordpress.com/