Sunday, October 28, 2012

Surfing from San Onofre to Fukushima...

10/28/2012

Dear Readers,

At a Nuclear Regulatory Commission (NRC) meeting about San Onofre held in Dana Point, California on October 9th, 2012, it was the unionists who tried to crowd out our shut-down message. To entice them to do so, Southern California Edison (SCE) had offered workers all-you-can-eat dinners in the plant parking lot, free tee shirts, bus transport to and from the meeting, and best of all, but tacitly, a chance to be thought of as a team player.

The busses arrived noisily during our press conference, which had to be held outside the entrance to the hotel because they wouldn't let the press trucks on the property for the live feeds.

The NRC PR person wasn't any more cooperative: We had set up a literature table at the entrance to the auditorium, but he tried to move us inside because the NRC needed both tables. "No" I said, and gave them one of them.

When we came back from the press conference, the hall was filled with union members, many of whom had taken literature from the table we had insisted on keeping. We'd wished we had brought more literature!

The unionists were loud sometimes, but polite, and as the night wore on, we got louder, because while they rode back on their busses, which ran back and forth all evening, a much greater percentage of activists chose to stay all the way through.

At a California Public Utilities Commission hearing in Irvine last Thursday (October 25th, 2012), we were out-maneuvered by the local Chambers of Commerce. What enticed them to come was the thousands of dollars (of ratepayer money) Edison gives local CoCs each year, so their chapter presidents will speak well of SCE at times like this. They served up Edison's line dutifully, one after another. Nevertheless we "won the day" with a 5-0 unanimous vote authorizing the go-ahead with an investigation into San Onofre's steam generator problems.

But the public comment period at the CPUC hearing, like at the NRC meeting, was a travesty. The CPUC promised to probably, maybe, possibly give us (the ratepayers) back every penny since January 31st, 2012 if SCE can't get the plant up and running again. That's more than half a billion dollars, but don't hold your fossil-fuel-and-Fukushima-poisoned breath waiting for it.

The CPUC was required by law to begin the investigation within a few weeks anyway, and they emphasized that it would be "thorough," but few of us were given a chance to speak about what it should cover, although dozens of people had driven or carpooled to Irvine thinking they would have a chance to tell the CPUC how they feel. It turned out our input wasn't welcome and the decision seemed to be a foregone conclusion.

The local Chambers of Commerce conspired both to use up the public comment period and to give themselves a bad name -- with CPUC Chairman Michael Peavey's help, who didn't seem to notice the loaded dice. At the very least, he could have told them to stop repeating each other, and certainly would have told us that, if we had droned on in the same fashion.

Instead, Peavey started the meeting late and let this, that, and the other thing prevent him from hearing the citizens. Very few of us had spoken amidst the unionists and Chamber of Commerce people, who all professed their love for San Onofre's supposedly "safe, reliable, affordable energy" as if -- as Gene Stone pointed out in the press conference afterwards -- they had all got the same memo with the talking points they were supposed to emphasize.

The rules for public comment had stated not to do things like that, and also said that spokespersons for organizations of people present could get extra time (that is, more than one minute). But suddenly chairman and former SCE president Michael Peavey had heard enough, and announced the last three speakers. And that would have been that, but Gary Headrick stood up, and with the crowd behind him, forced the issue and was granted three full minutes, which he used to read our group's statement. (It was a team effort all the way: His wife Laurie had already "snuck" in some comments with the Chamber of Commerce people, representing a CoC herself (a green one).)

Another small victory for our side was that the very first public speaker had been Martha Sullivan, who worked at the CPUC for 20 years, until 1998, and was speaking for the Del Mar City Council (that's why she got to speak first). It was a brilliant move on her part. She had tried several times to educate us about how the CPUC operates, to varying degrees of success. When she kicked off the public comment period, we thought things were going to go pretty well, but those CoC people just kept prattling on and on and on.... I stopped videotaping, but wish I hadn't, just so I could demonstrate the repetitiveness of their claims. I'm certain that none of them are familiar with the technical details of what's gone wrong at San Onofre -- they only know that it's "off." They aren't aware of the history of the steam generator replacement project, or of San Onofre's lingering problems with its workforce, or the used reactor core storage hazards, or that children are far more likely to be harmed by radiation than adults -- they just had a basic script to read. The Chamber of Commerce folks know that Southern California Edison contributes millions of dollars (of rate payer money) to local CoC's, as well as to children's cancer hospitals, local nature preserves and so on -- anything that looks like community caring. The media gets millions in advertising dollars from SCE -- but not if they run a lot of negative pieces. Then that dries up.

After Gary Headrick spoke, we could see a staff member say something to Peavey, who then announced that there would be one more speaker.

It would be young Zora, 13, had come all the way in from Idyllwild with her father to speak. As I was setting up the camera at the beginning of the meeting, she handed me a note with what she intended to say. (I had met her in August.) One of her friends had spoken at the Nuclear Regulatory Commission hearing two weeks earlier while Zora and another friend stood by her in support. This time Zora was alone at the podium, and stole the show. Here is a link to her marvelous minute in Irvine:, along with Gary's presentation, the CPUC decision, and the press conference activists held afterwards:

http://youtu.be/NxhK6K2442s

Sincerely,

Ace Hoffman
Carlsbad, CA

==============================================
Subject: Re: surfing Irvine today
==============================================

To: cathy iwane

Hi Cathy,

Funny, I thought I was the lucky one, standing next to YOU! Of course actually your husband's the lucky one, managing to surf all day yesterday --- good for him! Looking at the maps of debris, it looks like, if he's far enough south of Fukushima, the waters come up from the south to him, so theoretically he's safe.... a surfer got killed by a shark on this coast this week (Redondo Beach I think?) so there's hazards everywhere.... :~}

Zora sure stole the day yesterday!!

Thanks!

Ace


At 10:32 PM 10/25/2012 -0700, Cathy wrote:
>I was so proud to be standing next to Ace for an hour and a half, with not even a nose bleed seat, because I also had to drop my 7th grader off at school in Solana Beach to get to Irvine by 8:45. Not only am I happy to be surrounded by movers and shakers making waves (the apathy in Japan until March, 2012 was too much to bear for me along with food issues and the hush-hush party-line of the government and schools). But more, I had chills beholding the brave Zora, the 13 year old girl from Idyllwild, who set the record straight about the nuclear waste and economic waste of it all. So for me, the day glow-glo green signs complementing a lovely slice of the semblance of democracy to be had at Irvine City Hall today, was enough for me to telephone my husband back in Japan, after the unanimous vote for OII into SanO....at his time, 4:30am.
>
>But that was okay because the swell in southwest Japan is blessing him of late and he was getting up anyway....to go surf, while he still can. Who knows about the waters of our home next year? For this year, my 50 year old husband cannot live without it.....even if those waters were tainted, even slightly radioactive. This is the bittersweet part of 3/11. Some of us on this planet depend on the natural currents that Mother earth provides for our balance, our sanity, in a sometimes crazy world.
>
>My husband and daddy of his 2 girls, now in California, surfed to his heart's content today.
>
>Thanks to all of you.
>
>Cathy Iwane in Solana Beach
>
>
>From: Beverly Findlay-Kaneko
>To: Jerry Collamer ; SCG- Team <decommission@sanonofre.com>
>Sent: Thursday, October 25, 2012 8:05 PM
>Subject: Re: surfing Irvine today
>
>Would have liked to have seen the day-glo green signs. I was in the overflow room with the other moms who had kids to drop off at school and couldn't make it early enough to even get a nosebleed seat, or a high enough place on the roster to speak. We did perk up when we heard Gary persist off camera until he got a chance to represent all of us. Bravo! Lots of applause in our room for all of "our" people!
>
>Beverly in HB
>
>
>--- On Fri, 26/10/12, Jerry Collamer <jcollamer@att.net> wrote:
>
>From: Jerry Collamer
>Subject: surfing Irvine today
>Date: Friday, 26 October, 2012, 10:00 AM
>
>Ed and I planned to go surfing this a.m. -
>Thursday, Oct. 25th 2011.
>
>Thinking better of it, we drove north to
>surf Irvine's CPUC's Come to Jesus
>meeting held in Irvine's sumptuous
>council chamber; to sit, and clap, and
>cheer, and hold up signs Gary handed
>out seconds before the meeting started.
>
>Sign reads: Cut our Losses Not a Penny
>More to Edison. Pretty much says it all.
>
>Ed and I were up in he cheap seats -
>the nosebleed section. Albeit a comfy
>nosebleed section.
>
>Ace, with camera and tripod was
>positioned right above us, elbow to
>elbow in a long line of video cameras
>recording away.
>
>Mr. Peevey, CPUC's head guy on
>the dais made it clear, time was of
>the essence: 2-minutes per speaker,
>shrunk to 1-minute per speaker as
>the time-clock wound down to 10:30:
>our side's bewitching hour -
>
>but Gary had yet to speak.
>Not holding back, Gary announced
>as much to the dais,
>
>"What about me? I represent the
>multitudes not here, that would be
>here, if not for it being 10:30 on a
>workday."
>
>Chairman Peevey, facing the packed
>bleachers (aka reality), asked the room,
>
>"Who here, does Gary represent?"
>
>The bleachers turned instant day-glow
>green in Gary-signs. It was obvious.
>
>Mr. Peevey to Gary,
>
>"You have 3-minutes."
>
>Long story short: surfing Irvine went
>well today, thanks to all of you.
>
>You make this old surfer proud, to be
>in your brave, informed, active presence.
>
>You are the best, of the very best.
>
>Thank you,
>
>j


************************************************
** Ace Hoffman,
** POB 1936, Carlsbad CA 92018
************************************************

Wednesday, October 24, 2012

Msg left @ NRC Blog; Precious kid puts NRC official on the spot

10/24/2012

Dear Readers,

The following message was left on the NRC's "Public Blog" this morning (Wednesday) in response to the NRC's posted comments about flooding upgrades (shown immediately below). Also, links to two great moments during the recent NRC public meeting, Gary Headrick letting the cat out of the bag about "Mode 3 testing" and a high school girl from Idyllwild, California asking about the elephant in the livingroom. She's priceless!

Ace Hoffman
Carlsbad, CA

=============================
Message left at NRC "Public Blog":
=============================

Rubber donuts?

Okay, seriously: Rubber donuts were used at Fort Calhoun, and that was nearly a complete failure when a truck driver backed into one and tore it. Is that what's being "temporarily" used at Oconee? And let's see, what could be being kept secret about dams upstream from nuclear reactors... oh yeah, I know! If someone blows up a dam, and then the floodwaters inundate a nuke, or the lake is the emergency backup for the nuke so they drain the lake then destroy the reactor so it needs emergency backup.... hey, if I can think of these things so can anyone else, so maybe, if these are serious threats (like tsunamis are -- did the NRC miss that in their analysis that was started "well before" Fukushima?) -- since these are all unstoppable, unavoidable, and obvious ("clear and present") dangers, shouldn't those reactors that are under such threats be "retired" (along with the rest, because the fuel build-up is an unsolvable, not just an unsolved, problem, and the risk of meltdown is much higher than NRC calculations and predictions admit, since they ignore so many perfectly-plausible accident scenarios, such as greater-than-design-basis earthquakes)?

The biggest problem with the nuclear industry these days is that it can't seem to exit the scene gracefully. It's outpriced if proper safety features are required, but if they are NOT required... well, "scientists" should all take a warning from the seismologists convicted of manslaughter in Italy a few days ago: The nuclear industry is no place for games, lies, or under-achievers. If the truth hurts -- and it does -- suck up to it and admit it. Help these plants all close down before the public is hurt, before the truth -- and the radiation -- gets out, and before thousands of square miles of valuable real estate somewhere in America is lost for a thousand generations.

The cost of a mistake by a supplier to a subcontractor to a manufacturer in Japan of a product installed (by subcontractors of subcontractors) in a reactor in the United States might be a trillion dollars. This is not rocket science. It's far more dangerous, but corners are cut, liberties are taken, and the 1% (if that) which NRC officials could possibly watch is a show put on for your benefit -- even the logs are faked. The consequences of failure because someone didn't do their job, let fake electronic parts slip through in a supposedly "mil-spec" system, are "unfathomable," "unthinkable," and sure: "unlikely." But "unlikely" becomes "inevitable" if you keep making the same mistake over and over and over. Relicensing 40 to 60 year old plants for an additional 20 years? Unfathomable. Every reactor is a "Model T" and the "4th Gen" reactors are Model A's, at best. Computerizing them to avoid operator errors invites Stuxnet-like attacks from outside, inside, or by accident (a kid plays with his dad's computer and downloads a virus...).

The efficiency that was needed to make nuclear power financially viable just isn't there anymore, with other energy sources, including renewables, getting cheaper all the time and nuclear costs going up and up and up, and the waste problem -- the effect of ionizing radiation on everything -- will forever remain the legacy of our inaction today. For either cost, technological, or safety reasons -- usually all three -- we can't find a place to bury it, we can't rocket it to the sun, dump it at sea, drop it safely into a subduction zone, neutralize it, transmute it, or leave it where it is. So why keep making more of it?

Please do not allow the nuclear industry to continue to manufacture (through fission, neutron activation, gamma irradiation, etc.) monumental quantities of highly radioactive poison for which there is no sane, safe solution for containment or disposal.

Sincerely,

Ace Hoffman
Carlsbad, CA

=============================================
The above was in response to this statement by the NRC:
=============================================
URL:
<http://public-blog.nrc-gateway.gov/2012/10/24/nrc-continues-to-take-action-on-flooding-issues/>http://public-blog.nrc-gateway.gov/2012/10/24/nrc-continues-to-take-action-on-flooding-issues/

NRC Continues to Take Action on Flooding Issues

Posted by Moderator on October 24, 2012

Flooding is one of many natural hazards that U.S. nuclear power plants must withstand in order to safely shut down and protect the public. Well before last year's accident at Fukushima, the NRC was hard at work ensuring U.S. plants have robust flood protection measures in place, and now we're focused on having the plants update their flooding analyses.

We've devoted significant efforts at two sites – Oconee in South Carolina and Fort Calhoun in Nebraska – to oversee those sites' work in addressing flooding issues noted by our resident inspectors at the sites. The Fort Calhoun improvements paid off last summer, when the plant safely rode out severe flooding along the Missouri River.

The effort at Oconee, focused on dams upstream of the plant, has been underway for several years. Today, all the information available to the NRC leaves us satisfied that the plant's owner, Duke, has put appropriate temporary flood-related features in place to ensure the public's safety in case of flooding at Oconee. We're monitoring additional work Duke has under way to further enhance Oconee's permanent flood protection.

The experience at those two plants, however, led us to take a broader look at upstream dams to see if anything else needed to be done. That work was largely completed when Fukushima occurred, and the upstream dam analysis played a role in the NRC requiring every U.S. plant to perform a comprehensive reanalysis of all potential flooding sources. The screening analysis did not evaluate the changes at Oconee or Fort Calhoun; instead it answered the question of whether there were possible improvements at other plants.

The NRC has to keep some of that upstream dam information out of public view for several reasons. For one thing, we must coordinate the use of dam-specific information with our federal partners at the Army Corps of Engineers, the Federal Energy Regulatory Commission and the Department of Homeland Security. Other plant-specific information in the analysis also falls into security categories that are withheld from public release.

Two NRC staffers, one of whom worked on the analysis, have offered their opinions that more information should have been made available. They submitted their concerns to the NRC's independent Inspector General, which is one method the staff has to formally disagree with an agency decision. While the IG does its work, the NRC can only comment on the analysis currently available on our website.

Scott Burnell
Public Affairs Officer

###

==============================================
Videos from NRC public meeting, October 9th, 2012:
==============================================

Gary Headrick, asking about "Mode 3" operation at SanO:
http://youtu.be/REdPu2TaodQ

Precious high school girl from Idyllwild asks NRC official about the "toxic waste". The official has no answer. (That's me yelling "that's what we want to know!" and a few other things in the background, then Barbara George, from WEM, speaks up and says, "Then quit making the waste NOW! Shut them all down NOW!"):
http://youtu.be/Q7mAoX31vOU

-------------------------------------------------------------


************************************************

Tuesday, October 9, 2012

Three independent groups of experts tell Edison/NRC: DON'T RESTART SAN ONOFRE UNIT 2!

10/9/2012

Dear Readers,

It is to the nuclear industry's great advantage that their failures are odorless, colorless, tasteless -- in short, utterly undetectable to the human sense organs except in very high (and very poisonous) doses, when radiation first gives you a metallic taste in your mouth much like adrenalin might give you, then, at higher doses, skin burns, nausea, vomiting, organ deterioration, and death. And you might get all the rest without getting the metallic taste in your mouth. Lower doses cause cancer, heart disease, lowered IQs, and, of course, thyroid problems: 40% of Japanese children living near the crippled -- and still spewing -- Fukushima reactors now have thyroid problems, a harbinger of cancers in the community in the coming years.

You need sophisticated equipment to detect radiation -- equipment which, fortunately, has come down to the $150 price range, while increasing in sensitivity significantly too. Scintillators, which can tell you the energy level of the radiation as well as what type (alpha, beta, gamma) -- and thus can determine what isotope is emitting the deadly particles and rays -- are also coming out in similar price ranges.

I suppose it could be said to be an exciting time to detect radiation, thanks to Fukushima, Chernobyl, and a thousand other events.

But monitoring radioactive releases doesn't save lives nearly as well as not having the releases in the first place. San Onofre Unit 2 is in bad shape and should not be restarted in any case, but especially because of the problems it has right now.

BASIC REACTOR FACTS:

Nuclear reactors heat water to create steam to turn a turbine to spin a generator to produce electricity. There are two types of commercial nuclear power plants in the United States. About 2/3rds of the 104 U.S. power reactors are Pressurized Water Reactors (PWRs), which have three coolant loops, and the rest are the Fukushima-style Boiling Water Reactors (BWRs), which have only two coolant loops. San Onofre Nuclear Generating Station's reactors are both PWRs.

In both types of reactors, assemblies of zirconium tubes filled with uranium oxide pellets the size of a pinkie-finger bone heat recirculating water in the primary loop. That water is very radioactive, mostly with short-lived isotopes but also with "fuel fleas" of plutonium and uranium and other "transuranic" elements which have broken off of the ceramic pellets and escaped the zirconium cladding. Fission products, which are the resultant parts of splitting each atom, have also leached into the primary loop. Fission products are nearly always radioactive, and biologically active, too. Although most of the radioactivity in the primary loop is from the short-lived isotopes, with half-lives measured in seconds, plutonium's half-life (the time it takes for half of a substance to decay) is 24,000 years. (Half of what is left will decay in the next 24,000 years, and so on for about 10 to 20 half-lives, until it's all decayed.)

Water is pressurized to ~1200 psi in a BWR, which is low enough so that it turns to steam directly in the reactor core. The steam is piped to a turbine in another building.

In San Onofre and other PWRs, the water is pressurized to ~2200 psi, so that it does not boil as it loops through the system repeatedly -- it just goes up and down in temperature. A second loop of recirculating water is flashed to steam by touching the other side of thin tubes which carry the pressurized water on the inside. Thousands of these tubes are bundled together inside of school-bus-sized containers known as Steam Generators (SGs).

In both types of reactors, the steam exits the containment area, spins the turbines, and then is condensed back to water by the second loop in BWR designs, and the third loop in PWR designs. The last loop might be lake, river, or ocean (salt) water. Salt water is, of course, particularly corrosive.

There are various disadvantages unique to each design. The BWR design places highly radioactive water outside the containment area, pretty much defeating the purpose of the containment in the first place. The PWR's most unique disadvantage is the SGs, which have proven to be troublesome throughout the nuclear industry.

Both designs run the risk of a fire of the zirconium cladding, releasing the fission products and resulting in a meltdown of the fuel (as apparently happened in Fukushima), or even a fire of the fuel itself (releasing everything -- the worst of the worst and far worse than Chernobyl OR Fukushima was). There are many other possible failure scenarios known as "Design Basis Accidents," which they have to plan for, and "Beyond Design Basis Accidents," which they don't have to plan for because they're considered too rare to bother about, and which are usually unstoppable if they do occur (asteroid impacts, or greater-than-DBA earthquakes are two examples of BDBAs).

SAN ONOFRE'S STEAM GENERATORS:

There are 9,737 tubes inside each of the four failing SGs at San Onofre. Each is shaped like an upside-down U. The tubes are about 4/100ths of a inch in wall thickness and about the diameter of an average adult finger. Primary coolant flows through the inside of the tubes. Secondary coolant rises along the outside of the tubes and picks up heat through them, and turns to steam. At the top of the U, it was still supposed to be mostly water, which dampens vibrations of the tubes pretty well, but it turned out to be mostly steam, which doesn't. The tubes banged into each other.

San Onofre's replacement SGs were highly modified from the original design, and no wonder: The original SGs had performed very poorly, wearing out several decades early. When forcing the rate payers to pay for the new steam generators a few years ago, it was said they would last 60 to 80 years or more, because they would be made with the new alloy "690", instead of the old alloy "600".

Across the nation, everybody's switching over, we were told.

The NRC accepted the new SGs as "like for like" replacements for the old ones, thus avoiding a costly and delaying -- and possibly damaging -- public inquiry into the whole affair. Neither the NRC nor SCE, nor the SG manufacturer in Japan, Mitsubishi Heavy Industries, bothered to do a thorough, careful, critical analysis of the new SGs' ability to perform as intended. Mockups and scale models were not made. Instead, computer programs were fed various parameters of the new design, but they returned invalid values, which were not cross-checked in any meaningful way.

The "hydrodynamic" calculations are too complex to be done by hand, they have to be done by computer, and even the computer models are crude estimations of the actual flow patterns of all the millions of gallons of pressurized hot water, "cold" water, and steam.

EDISON'S PROPOSAL TO RESTART:

This evening (October 9th, 2012) in Dana Point there is to be a special NRC public meeting about the problems with the steam generators. Edison has asked the NRC for permission to restart San Onofre Nuclear Reactor Unit 2 at 70% power.

The NRC has already stated they will need "months" to review Edison's restart proposal, but the NRC hasn't said whether it will hold full evidentiary hearings regarding the botched steam generator replacement project. Unit 2's two new replacement steam generators, which are not even two years old, have more wear than was expected to be seen in the 40- to 60-year extended life of the plant. Unit 3 is in even worse shape and there are no plans to restart it at the present time.

WHAT WENT WRONG AT SAN ONOFRE:

We were promised better steam generators and what we got was Fluid Elastic Instability (FEI). FEI is a synchronized swaying of these huge bundles of heat exchanger tubes in unison until something breaks. A single tube in Unit 3 ruptured on January 31st, 2012, spewing hundreds of gallons of radioactive water out from the primary (hottest, most pressurized side) to the secondary side, where it flashed to steam, went through the turbines, and was condensed, at which point radioactive noble gases were released and detected.

That was just one leak in one tube, but thousands of tubes were damaged and in subsequent pressure testing of selected tubes, 8 more burst, some at pressures below what they are required to handle, and all eight of them at less than 3 times the normal operating pressure. That is unacceptable even to the NRC. More than 800 tubes were plugged in Unit 3 while Edison attempted to convince the experts that Unit 3 was just "settling in" (their term). SCE's attempts to restart Unit 3 fell on deaf ears even among San Onofre's staunchest supporters -- the NRC. (Unit 1 was closed in 1992 for a variety of reasons.)

The replacement SGs at San Onofre suffered significant premature wear damage not just from FEI, but also from a more common -- but never THIS severe in any other reactor in the country -- problem known as Flow Induced Turbulence (FIT). Unlike FEI, FIT becomes chaotic, but also has damaged thousands of tube in the SGs of both reactors at San Onofre.

EDISON'S RESTART PLAN:

Edison wants the NRC to see Unit 2 as having completely different problems from Unit 3, even though Unit 2's SGs are identical in every way possible to those in Unit 3, and even though they are showing the same sorts of wear patterns, just not as severely. More than 500 tubes have been plugged in Unit 2 "as a precautionary measure" according to Edison. Two tubes in Unit 2's SGs -- and hundreds in Unit 3's SGs -- had "tube-to-tube" damage, which should never occur at all and almost surely indicates FEI in addition to FIT.

Edison claims that they can safely run Unit 2 for five months at 70% power and then take a look to see how much wear occurred. Although it's likely there won't be much additional wear, it's also possible that FEI will still set in, and it's ALSO possible that, since the "70%" figure is purely administrative, it will be exceeded. And a run-away power excursion might cause the operators to feel they have no choice but to run at full heat-removal capacity, despite the plan to run at 70% power.

And besides that, there is little evidence that FEI is necessarily less likely at 70% power, and in addition, other problems which have plagued the nuclear industry, such as crud buildup, are much more likely to occur at the lower power setting.

It's not a sound plan -- it's a desperate measure by Edison to stay in the nuclear energy business instead of being forced to allow renewable energy systems to hook up to the grid without excessive fees or delays. It's a plan to keep Edison from going out of business to be replaced by citizen-owned local utilities. It's a plan that puts Southern Californians at grave risk for corporate profits. There are better jobs in the renewable energy sector for the employees. Nobody needs San Onofre to restart.

OUTSIDE (AND INSIDE) EXPERTS HAVE EXAMINED THE ISSUE:

Three groups of outside experts have each reached the same conclusion about San Onofre Unit 2: DO NOT RESTART IT.

Arnie Gundersen is a former nuclear industry engineer. With his wife, also a former nuclear industry executive, and other experts, Arnie's team, Fairewinds Associates, concluded that it would not be safe to restart Unit 2.

Dan Hirsch, founder of Committee to Bridge the Gap, with his own team of experts and students, researched every other steam generator system at PWR reactors across America and concluded the same thing -- that San Onofre is worse than anywhere else and should not be restarted.

And another independent team that was formed around a San Onofre employee who left the company this past August reviewed Arnie Gundersen's and Dan Hirsch's reports, as well as numerous other technical reports from all over the world, and also reached the same conclusion -- that restarting San Onofre Unit 2 is unsafe. (I am associated with this third group as a concerned citizen.)

The NRC says they'll take "months" to decide if Edison's restart plan is logical, which has taken Edison more than nine months to deliver since the shutdown. But the plan is utter folly and the NRC should be able to see that as easily as the independent experts have seen it. This is a no-brainer: Keep San Onofre shut forever. It's not worth the risk.

Ace Hoffman
Carlsbad, CA

============================

Three Fairewinds Associates reports on San Onofre steam generators (July 2012, May 2012, April 2012):

http://fairewinds.org/content/san-onofre%E2%80%99s-steam-generators-significantly-worse-all-others-nationwide

http://fairewinds.org/content/san-onofre%E2%80%99s-steam-generator-failures-could-have-been-prevented

http://fairewinds.org/content/san-onofre-cascading-steam-generator-failures-created-edison

Videos and much more about the San Onofre steam generators available at the Fairewinds Associates web site:

http://fairewinds.org/

Committee to Bridge the Gap press release on San Onofre steam generators:
http://committeetobridgethegap.org/wp-content/uploads/2012/09/CBG-SONGStubes5.pdf

Committee to Bridge the Gap report on SanO:
http://www.committeetobridgethegap.org/pdf/CBG-SanOnofreReport.pdf

Dan Hirsch of Committee to Bridge the Gap speaks about the steam generator report at Del Mar city council:
http://www.youtube.com/watch?v=Rh6aZ5gwoGo

DAB safety team's collection of reports:
https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit

-----------------------------------------
Ace Hoffman, computer programmer,
author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Phone: (760) 720-7261
Address: PO Box 1936, Carlsbad, CA 92018
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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:
>
>http://www.SONGScommunity.com/
>
>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 www.SONGScommunity.com. 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 www.SONGScommunity.com, or follow us on Twitter atwww.twitter.com/SCE_SONGS, and on www.facebook.com/sce.
>
>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.
>


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