Thursday, October 4, 2012

Southern California Edison (SCE) announces risky restart plan for San Onofre Unit 2

October 4th, 2012

Dear Readers,

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!

Ace Hoffman
Carlsbad, CA

At 09:10 AM 10/4/2012 -0400, Ulrich, Kendra @ FOE wrote:
>From: shaun burnie
>Sent: Thursday, October 04, 2012 8:57 AM
>Dear All - Edison release and documentation just posted:
>Press release
>Southern California Edison Submits Response to Confirmatory Action Letter and Unit 2 Restart Plans to Nuclear Regulatory Commission
>Posted October 4, 2012 - 5:30 a.m. PDT
>Media Contact: Media Relations (626) 302-2255
>Investor Relations: Scott Cunningham, (626) 302-2540
>ROSEMEAD, Calif. (Oct. 4, 2012) ­ Southern California Edison (SCE) has submitted its response to the Nuclear Regulatory Commission's (NRC) Confirmatory Action Letter, along with its restart plan for Unit 2 of its San Onofre Nuclear Generating Station. The response, the restart plan and supporting analyses can be read at The unit cannot be restarted until all plans have been approved by the NRC.
>"Safety is our top priority, and after conducting more than 170,000 inspections to understand and prevent the problem, and confirming the corrective actions we have taken to solve the problem with the top experts from around the world, we have concluded that Unit 2 at San Onofre can be operated safely and within industry norms," said Ron Litzinger, president of SCE. "When implemented, this plan will get San Onofre Unit 2 back to providing reliable and clean energy to Southern Californians."
>The response and restart plans are being submitted simultaneously to provide the NRC with all the relevant information needed to evaluate the full spectrum of repairs, corrective actions and additional safety measures proposed for restart and safe operations at the plant. Unit 3 will remain offline while the utility continues to study the potential solutions that are unique to that unit.
>The response to the NRC covers the causes of the tube wear, repairs and corrective actions required for the Unit 2 steam generators, actions to prevent the extensive tube-to-tube wear observed in Unit 3, and inspection and safe operation protocols.
>· SCE determined the tube-to-tube wear in the Unit 3 steam generators was caused by a phenomenon called fluid elastic instability, a combination of high-steam velocity and low-moisture conditions in specific locations of the tube bundles and ineffective tube supports in the same locations.
>· The high-steam velocity and low-moisture conditions existed in Unit 2 and hence Unit 2 was susceptible to the same vibration-causing environment. However, of the almost 20,000 tubes in Unit 2, all except two are known to have been effectively supported throughout its 21-month operating period.
>· SCE will operate Unit 2 at 70 percent power, which will prevent the vibration-causing environment by decreasing steam velocity and increasing moisture content. The 70 percent power level will result in steam velocities and moisture content consistent with those that the industry has successfully operated under for many years.
>· SCE has chosen a conservative operating period of five months. SCE will shut down Unit 2 after five months for inspection of the steam generator tubes to ensure the continued structural integrity of the tubes, to measure tube wear and to confirm that the solutions are working. The five-month operating period affords an additional safety margin beyond the analysis provided by the independent experts.
>· SCE has plugged six tubes in Unit 2 indicating wear with greater than 35 percent through wall depth and preventively plugged more than 500 other tubes. Steam generators are built with an allowance of extra tubes so that tubes may be taken out of service for a variety of reasons, including wear, and only 2.6 percent of the total tubes in Unit 2 have been plugged.
>The restart plan covers the above repairs, corrective actions and operating parameters, and also includes additional monitoring, detection and response activities. Three independent experts in steam generators have performed analyses that validate the safety of the restart and operations plans.
>Proposed additional monitoring, detection and response activities include:
>· Installation of early warning monitors that can detect extremely small tube leaks faster;
>· Enhanced sensitivity of vibration monitors;
>· Additional monitoring and analysis systems; and
>· Enhanced operator training to respond to extremely small tube leaks.
>SCE anticipates discussing its Confirmatory Action Letter response with the NRC in a public format.
>Unit 2 was taken out of service Jan. 9, 2012, for a planned outage. Unit 3 was safely taken offline Jan. 31, 2012, after station operators detected a small leak in a steam generator tube. Unit 3 remains safely shut down for continued inspections, analysis and testing.
>For updates, please visit, or follow us on Twitter, and on
>The San Onofre plant is jointly owned by SCE (78.21 percent), San Diego Gas & Electric (20 percent) and the city of Riverside (1.79 percent).
>About Southern California Edison
>An Edison International (NYSE:EIX) company, Southern California Edison is one of the nation's largest electric utilities, serving a population of nearly 14 million via 4.9 million customer accounts in a 50,000-square-mile service area within Central, Coastal and Southern California.

Ace Hoffman, computer programmer,
author, The Code Killers:
An Expose of the Nuclear Industry
Free download:
Phone: (760) 720-7261
Address: PO Box 1936, Carlsbad, CA 92018
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