I just sent this to the facilitator for the upcoming NRC meeting on Monday....
To: "Richard Daniel, Facilitator" <Richard.Daniel@nrc.gov>
[Regarding the upcoming hearing on San Onofre] my main concern is not so much that a "root cause" has been discovered or even that the trail [is laid out] of how such significant changes were purposefully slipped past the Nuclear Regulatory commission (see attached comments documenting this by Ray Lutz, a local engineer who will be appearing at the hearing on Monday). Mr. Lutz's concerns about procedural breakdown are significant not only to the NRC's method of operation, but to any highly-regulated industry. With regulation tends to come a willingness not to see what is NOT in the regulations, or not brought to one's attention through the normal regulatory channels. The standard answer from the NRC to this citizen has always been "we'll get back to you" -- and that's the end of it.
My main concern is not the "root cause" because I believe it's going to be that the upper area of the steam generators do not have enough water and have too much steam, proportionately, because of a redesign of a plate which blocks more water than the old design did, as the water/steam mixture rises inside the massive steam generators. The water acted to dampen vibration in the old design, hence in the new design, the thin, closely-packed tubes clang into each other. This concept was presented by Arnie Gundersen along with a concern about vibration in the base plate, which I believe may also be a contributing factor. If it has turned out to be something else entirely, that will be of some interest, and I will be interested to see the evidence which supports any alternative theories.
However, my concern is entirely going forward and thus, I refer to such problems as tsunami dangers brought on by underwater landslides, caused by earthquakes in the nearby vicinity of the reactors (within a few hundred miles, for example). The San Andreas fault is approximately 99% certain to have a tremendous rupture in the next few decades. Many of the other faults in the area are expected to reawaken after that event, too -- and new ones will be discovered, no doubt. I find this chilling.
There is virtually indisputable geological evidence of massive tsunami events in THIS coast's past; probably caused by underwater landslides somewhere. Add to that the "unexpected" size of the earthquake in the most earthquake-studied area of the world last year -- that led to the tsunami and triple reactor meltdown in Japan, and I see no reason to wait for another earthquake study -- even if it's getting $64 million in funding (of our money) and will take half a decade or more to complete, it's going to be so thorough. Can we afford to wait? Could Japan? Expert scientists can already dispute the entire effort, if it's findings are anything different that what I have just described as a possible worst case scenario: Events far larger than SanO can possibly survive. That's what we risk if the "root cause" is found and fixed, and the reactors are returned to service. Frankly I'd rather the NRC NOT find the root cause, if that's what it takes to keep the reactors closed! We were promised, however, that at least the root cause would be determined. (I would say the root cause was greed on the part of San Onofre's operators, and that is still present and cannot be accounted for.)
The 2004 earthquake/tsunami combo that killed about a quarter of a million people, and the fact that the tsunami was caused by an undersea landslide made such events prominent in the news. A reactor thousands of miles across the Indian Ocean in India was in fact, damaged by that event, but because it survived, and because none were close enough to be destroyed, the obvious threat was ignored. Come 2011, the price of ignoring the threat fell due for Japan. Perhaps the day after restarting San Onofre, the price of ignoring history will fall due for California.
These are not irrelevant to the steam generator issue by any means, because the steam generator issue causes the local population to bleed money into Southern California Edison's coffers and risk catastrophic meltdowns in return. It is a bad investment ON TOP OF a bad investment! So it won't merely take making the steam generators work better to fix the problem.
As a noted early pioneer of nuclear reactor design noted later in life: "The most intolerable reactor of all may be one which comes successfully to the end of its planned life having produced mountains of radioactive waste for which there is no disposal safe from earthquake damage or sabotage." (The late Dr. A. Stanley Thompson, nuclear physicist.)
So there is no way to exclude the rest of the world's problems from the steam generator decision. To replace them with PERFECT steam generators would still be hazardous to our health and we don't want them.
That said, I would still like some technical questions answered regarding the steam generators, and have included 18 of them below. Arnie Gundersen, who was involved in the basic design of steam generators within the nuclear industry and whom you already are aware will be attending Monday's hearing, has already seen the list of questions, and suggested one of them himself. (I'll leave it to the team to guess which one. :~} )
I hope that written answers can be provided to me in addition to any comments that might be made at the hearing. I appreciate the continued professionalism of the many NRC inspectors and officials I have dealt with over the ~two decades that I have been attending hearings regarding San Onofre and other nuclear issues. I look forward to hearing from you.
May the whole truth win...
1) Which tubes needed to be plugged? Were they all in one area, inner, outer, or scattered?
2) Have any changes been made to the design of the SGs to allow the units to work, other than plugging tubes?
3) How many tubes were plugged?
4) What are the primary and secondary coolant loop pressures, flow rates, and temperatures that SCE proposes to run at, given that the power outputs are "50% to 80%" of normal. For 50%, what are the numbers, and for 80%, what are the numbers? (Normal is about 1200 PSI in the secondary loop and 2200 PSI in the primary loop, for example.)
5) What vibration sensors, temperature sensors, and other sensors have been added to ensure that problems are being found, and what vibration sensors, temperatures sensors, and other sensors were in place before?
6) How frequently will the reactors be shut down for additional inspections?
7) What if a rupture/leak occurs before the first inspection? Will the "experiment" with our lives be ended once and for all at that point?
8) What is the amount of wear on those tubes that have shown wear?
9) Even if thousands of tubes have been plugged, they are still vibrating and are still worn. How can it possibly be safe to operate the reactor with so many weakened tubes?
10) Given that these were new and most of the reactor is 30 or more years old and rusted out and decrepit, why not just give up?
11) What % of the wear was caused by tube-to-tube interactions and what % was caused by tube-to-support interactions? How much damage was near the bends of the U-shaped tubes?
12) Could the additional vibration of the tubes throughout the structure also cause additional wear at the base of each tube -- their sole place of firm attachment? Has this been examined or even considered? The vibration could help work the crud that naturally gathers there work deeper into and between the metals. Would this wear show up right away or will we find out later when tubes start to pop out of their holes?
13) Will operating at reduced pressures, temperatures, and/or flow rates actually cause an increase in metal-damaging deposits not only at the base of each tube but throughout the system, as the "natural flush" that they had been designed to operate with would no longer be occurring?
14) Will SanO be required to shut down immediately upon detecting a leak in the steam generator tubes, or will they be allowed to continue to operate, as long as the leak rate from the primary loop to the secondary loop remains below the normal daily limit for all Pressurized Water Reactors (which I think is about 85 gallons a day)? Will they be given a stricter limit than usual in light of their pressure test failures and actual failures thus far? Or will they be given a more relaxed limit, instead?!?!
15) Considering the increased risk, what is the advantage of letting SanO operators continue to run the plant even after they know they have a leaky situation? (I presume the "advantage" is that very small leaks tend to self-seal with crud; that's why they are allowed to run with continual leaks; it's only the "growing" ones they really worry about, but would like this confirmed.)
16) Given that SanO only as two SGs per reactor, instead of the usual three or four like in most other PWR reactors, the importance of having operational SGs is much greater than at other reactors, because when one fails, there is only one left for heat removal. The new SGs are clearly improperly designed, and to the effect that there are only two, the entire design is clearly faulty and should be abandoned. Why not abandon an obviously-inferior design?
17) The ISO, FERC, SDG&E and SCE have all said we should NOT expect blackouts even in the worst summer days just because SanO is down. Even if we do have any, it's better than having meltdowns -- which might well happen if SanO is brought back online with faulty steam generators. Why generate more nuclear waste and risk catastrophic failure?
18) Why did Edison plug 1300 tubes when their ultrasonic/ eddy current tests indicated that only 12 needed to be plugged?
Attachment: Press release concerning Monday's hearing sent to me by Ray Lutz, the main author
Citizens' Oversight Projects (COPS)
Ray Lutz / RayLutz@CitizensOversight.org / 619-820-5321
Residents Organizing for a Safe Environment (ROSE)
Gene Stone / email@example.com / 949-233-7724
Peace Resource Center of San Diego
Carol Jahnkow / firstname.lastname@example.org / 760-390-0775
FOR IMMEDIATE RELEASE
Activists Demand Nuke Plant Closure at NRC Public Meeting
Nuclear Regulatory Commission to Release investigation findings on San Onofre June 18 in San Juan Capistrano
Ratepayers Demand that Edison CEO Craver Shutter Troubled Plant
June 14, 2012 (SAN JUAN CAPISTRANO) The public will rally and sponsor a press conference in opposition to continued operation of the San Onofre nuclear plant on Monday, June 18, at 5pm prior to the 6pm public meeting scheduled by the Nuclear Regulatory Commission (NRC) at the San Juan Capistrano Community Center at 25925 Camino Del Avion, San Juan Capistrano, California.
After months of investigation, the Nuclear Regulatory Commission will hold its first public meeting after the emergency shut down of the San Onofre Nuclear Generating Station on January 31, 2012, and after their official investigation into the steam generator failures.
"Unfortunately, the NRC wants to limit valuable public input by withholding their report until they announce it at the meeting, making it difficult to the public to formulate questions on this technically complex issue," said electrical engineer Ray Lutz, National Coordinator for Citizens' Oversight Projects. "This is the first public meeting where the public will have a chance to speak and ask questions. It's too bad they're making this like a pop-quiz instead of a take-home test."
Activists are concerned that the NRC will deliver a token report on what occurred, followed by a "we'll have to study your report" response by the utility. NRC Chair Gregory Jaczko, the sole dissenting voice on the commission, recently announced his resignation, signaling that the commission would likely turn into a rubber stamp for utility wishes.
Edison Chair Theodore F. Craver, Jr. admitted that it really was his decision alone to decommission the plant, and that it would be the most difficult decision of his career. The reality is that the decision to decommission could be made immediately, regardless of NRC processing and inquiries. Continuing the effort to restart the plant will either mean that NRC will look the other way and allow the unsafe plant to restart at reduced power, ignoring the fact that experts agree that this will likely only exacerbate the rattling steam generators, or spending a great deal of money to replace the steam generators once again, with no guarantee that these will work either.
"The NRC investigation was limited in scope to avoid the most important issue: the regulatory process which allowed the 'super-charged' steam generators to be installed without NRC approval," Lutz said. "Edison engineers bragged about being able to upgrade the reactors without any such approval, and indeed, it was even the 'major premise' of the project. If the NRC is not going to review this, then it raises a good question: when does this review occur or is this just going to be swept under the rug?"
Even if the steam generators were working like they were supposed to, we now know that the plant is in an earthquake zone, a tsunami inundation zone, and would likely fail in any sort of moderate earthquake. Operators admitted last month that vibration sensors on crucial equipment would improperly shut down that equipment in the event of an earthquake.
San Onofre, designed for a 6.0 quake and upgraded to withstand 7.0, is certainly at risk given the recent 7.5 magnitude quake near Mexicali and the recently discovered fault only yards from the reactor site. That new fault experienced a 3.8 quake just last month.
The underlying agenda of SCE, the plant operator, was to "super-charge" the steam generators, essentially upgrading the plant to produce more power without NRC or approval by the public . SCE Engineers admitted in January that they worked to avoid full NRC review of the changes. In an article in Nuclear Engineering International: "the major premise of the steam generator replacement project was that it would be implemented under the 10CFR50.59 rule, that is, without prior approval by the US Nuclear Regulatory Commission (USNRC)" [2, emphasis added].
On April 25, citizen activists submitted a letter to NRC Chairman Gregory Jaczko detailing requests for action prior to any restart of the reactors at San Onofre . These requests will form the basis for some of the questions and comments from the public. Some of the questions from the public should include:
1. Has the NRC investigation determined the root cause of the steam generator failure?
2. Has the NRC also determined why the design error occurred?
1. Was it due to faulty simulations, faulty testing, or no testing or simulation at all, using the "see if it breaks" approach?
2. Is there a fundamental gap in our understanding of physics that limits our ability to predict this failure?
3. Has the analysis from Mitsubishi Heavy Industries been completed, and if so, what was their conclusion, and can we get a copy of their report?
4. The likely root cause is a mis-design by [SCE] and MHI engineers. What corrective action is planned, if any, to rectify the design errors so that excessive tube degradation will not occur?
5. What assurance do we have that the same engineers can do it right this time? If this occurs, will the NRC approve every step of the way?
6. Indeed, since this design was so problematic, what assurance do we have that other systems that are never tested until a disaster occurs will actually perform as intended?
7. SCE has said they intend to plug some tubes and run the reactor at a lower power, but experts agree that this approach will not reduce the rattling of the tubes but instead may increase it. Has there been an analysis to confirm that such operation will reduce tube degradation or is this just a wild guess by SCE engineers?
8. The inquiry by the NRC was limited in scope and did not include any of the regulatory process that also failed to ensure that such poor designs will ever result. Will there be a separate inquiry by the NRC into such regulatory matters? If not, which agency does that type of review?
9. It is clear now that SCE engineers intended to boost the power output from the plant by modifying the steam generators to generate more steam [1 & 2]. Such a capacity upgrade for a nuclear plant would normally require a re-licensing procedure and it would be paid by the shareholders and not by the ratepayers. Since SCE worked around the law to upgrade this plant in capacity without going through the required procedure:
1. will the operators be fined for violating NRC regulations?
2. will the company be required to charge shareholders for this debacle rather than ratepayers, and undo the improper charge to ratepayers that occurred under the guise that this was just a maintenance and not a capacity upgrade?
3. will the relicensing procedure be activated in ex-post facto fashion so that review by the NRC and the public, as required by law, be respected?
10. What is the status of the investigation into the electrical fire that occurred on April 20, 2012?
11. What is the status of the investigation into the worker who fell into the primary coolant pool in January, 2012?
12. What is the status of the investigation into the vibration sensors on the emergency pumps that had to be disabled because they would improperly shut down the pumps in the event of an earthquake?
13. What steps are being taken to address post-Fukushima concerns at nuclear power plants in the United States, including San Onofre? Will the plants be stress-tested to insure that they will be likely to perform as intended when these disasters occur?
14. Seismic studies costing $64 million have been approved for the vicinity of San Onofre. What will be done with these studies when they are completed? Will the plant be simulation tested to see if it will survive any possible earthquake and/or tsunami?
Event: Rally / Press Conference
Date/Time: Monday June 18, 2012, 5pm.
Location: San Juan Capistrano Community Center
Event: NRC Meeting
Date/Time: Monday June 18, 2012, 6pm.
Location: San Juan Capistrano Community Center
 http://sciencedude.ocregister.com/2012/01/05/powering-up-nuclear-plant-to-boost-output/166317/ -- Powering up: Nuclear plant to boost output -- "The new [steam] generators raised the amount of steam energy produced in the reactors."
 http://www.copswiki.org/Common/M1252 -- "Improving Like-for-like RSGs" from Nuclear Engineering International -- Describes the many changes made to the steam generators to increase the steam energy developed.
 http://www.copswiki.org/Common/M1254 -- "Letter to NRC Chairman Gregory Jaczko Requesting Specific Steps before restarting the San Onofre reactors"
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