Tuesday, January 29, 2013

The CPUC attempts to narrow the focus of their investigation... we try to broaden it...


Dear Readers,

Yesterday the Commissioner and Administrative Law Judge in the California Public Utilities Commission's investigation ("OII") into San Onofre's steam generator problems released a "Scoping Memo" designed to define (and RESTRICT) the extent of the investigation into the problem. If the memo stands as the definition of scope, it will be strictly limited to little more than figuring out who will pay to rebuild and restart San Onofre. There is no provision for looking at the "big picture" of whether there is any sense in replacing or repairing the broken reactors.

This is a travesty and people need to demand the CPUC OII include a much broader look at the issues. I have taken the first section of the scoping memo ("background") and responded below.


Ace Hoffman
Carlsbad, CA


(1) Comments on CPUC's OII "scoping memo"
(2) Quotes from the CPUC OII January 28, 2013 scoping memo
(3) A brief history of the current steam generator problem at San Onofre
(4) Press release regarding the scoping memo from Woman's Energy Matters
(5) Statement regarding the scoping memo from Michael J. Aguirre, Esq.
(6) One-year commemoration of the near-destruction of Southern California planned
(7) Contact information for the author of this newsletter

(1) Comments on CPUC's OII "scoping memo":

The scope of the California Public Utilities Commission's investigation into San Onofre should not be limited in any way. The fact is, that as of January 31, 2012, California has experienced far safer and more reliable electricity service than ever before. The mood of the citizens has also improved as they live with less FUD (Fear, Uncertainty, and Doubt). These advantages should be reflected in more just and reasonable rates for the ratepayers. The increase in safety and satisfaction is in precise response and proportion to the San Onofre Nuclear [Waste] Generating Station (SONWGS) being offline.

Specifically, the operations there over the past few decades, that have led to sudden and/or prolonged power outages, and a constant threat of meltdown, have ceased, and this is a good thing.

Specifically, the dangerous safety violations that have led to whistleblower revelations that have terrified the citizenry because of their safety significance (including retaliatory practices by management, cover-up of fraudulent work practices (such as skipping fire watch rounds), etc.) have been reduced in significance due to the involuntary shut-down of the reactor site.

Specifically, the underhanded practices of the operator, such as misleading local city officials in secret meetings after the citizens have spoken to those cities, and such as targeting any cities the citizens speak to, in a game of whack-a-mole rather than open dialog, honest debate, in-depth discussions, and any reasonable attempt to reach a mutual understand among all the parties.

And specifically, the immoral conduct of Southern California Edison's spokespeople to claim that the nuclear spent fuel waste problem is solvable by government and is not their problem. For approximately 30 years the public were assured by SCE's spokespersons that Yucca Mountain was the solution, so there was no need to discuss the "waste problem" at all and it was dismissed as a non-issue. Then it was the Private Fuel Storage facility in Utah, for a couple of years, that was going to solve the waste problem locally by putting it off on a small but well-paid Goshute Indian tribe. That didn't work out either, and now the public is being told the solution will be the Blue Ribbon Commission's "interim storage facility" whatever, whenever and wherever it is. But even that will be decades in the future if it ever happens at all.

Meanwhile, deadly DRY CASK STORAGE piles up on the coast, now totaling over 40 individual enormous deadly casks, with nearly a hundred more to go, just to get caught up with the current load of highly radioactive used nuclear reactors on site at the present time.

These practices are related part-and-parcel to the extended outages at SONWGS Units #2 and #3: The dangers from SCE's mistakes, cover-ups, lies, falsifications, misrepresentations and other forms of negligence subsides over time as the fuel cools both thermally and radiologically. This outage is GOOD for Southern California: It should not stop. The units should not be restarted.

The root cause of the outage is greed: SCE tried to design new steam generators that would generate the same OR MORE steam within the same size steam generators, using heat transfer tubes with 10% lower heat transfer capabilities. The advantage of the new alloy 690 supposedly was that it was more ductile, stronger, and longer-lasting than the old alloy 600. These all may well be true, when the steam generators are properly designed. Indeed, Edison claimed that a 60-year life was expected, although the CPUC only wanted them to show cost-effectiveness for 18 years (which was only possible by dint of SCE being allowed to exclude numerous cost factors from their calculations, including but not limited to such events as the current outage).

However, even assuming alloy 690 is "better" than alloy 600 in many ways, the disadvantage of a lower heat transfer coefficient apparently was not properly accounted for by SCE in their desire for maintaining or even increasing the steam productivity of the replacement units. SCE apparently forgot basic thermodynamic and hydraulics principles. Then they apparently forgot basic engineering principles of having independent eyes check their work, of benchmarking their assumptions against industry standards, and of reviewing the historic record for what is known about the subject (the subject being "Fluid Elastic Instability" which was first recognized as a potential problem in nuclear reactor steam generators in the 1970s). SCE worked hard, but only at hiding their efforts from the public view: They did this by calling all the dozens of significant changes to the steam generators "like for like" because the outer shells of the steam generators were to be the exact same dimensions. But inside those shells numerous vital changes were being made.

In short, SCE attempted to put a sports car engine in the family sedan, and ran into a wall when they first stepped on the accelerator. Luckily, damage was mainly to their pride, and to the ratepayer's wallets. A catastrophic cascade of tube ruptures was avoided, but only by the narrowest of margins, as proven by the 8 tube failures during subsequent pressure testing.

The proper scope of this proceeding is by its very nature massive: The lives of 8.5 millions Southern Californians are at stake. Billions of dollars in what could be green energy investments might be poured into the rat-hole that is San Onofre Nuclear Waste Generating Station if a poor decision is made in this proceeding.

Respectfully submitted,

Ace Hoffman
Carlsbad, CA

(2) Quotes from the CPUC OII January 28, 2013 scoping memo:

Quotes from CPUC's OII Scoping Memo, 1/28/3013:

From: "Background":

"On November 1, 2012, the Commission issued this Order Instituting Investigation (OII). The Commission will investigate the ongoing shutdown of nuclear generation at the San Onofre Nuclear Generating Station (SONGS), and the resulting effects on the provision of safe and reliable electric service at just and reasonable rates. Specifically, this investigation will consolidate and consider issues raised by the operations, practices, and conduct of Southern California Edison Company (SCE) and San Diego Gas & Electric Company (SDG&E) related to and following the extended outages of SONGS Units #2 and #3. The Commission will examine the causes of the outages, the utilities' responses, and the future operation of the SONGS units as part of a review of SCE's actions, and to assess what costs, if any, are appropriate for recovery from ratepayers."


From: "Scope of the Proceeding":

"This is an evolving OII and some key facts (e.g., third party cost recovery, future actions by Nuclear Regulatory Commission (NRC), and repair/replacement options for the steam generators) have yet to be determined."

Note that "repair/replace" should read "repair/replace/retire" but instead the "retire" option has been ignored.

"Nature and effects of the steam generator failures in order to assess the reasonableness of SCE's consequential actions and expenditures (e.g., was it reasonable to remove fuel from unit #3)."

Note that the example of questioning the logic of removing the fuel from Unit #3 implies, once again, a desire to restart even that most-broken of reactors!

"Issues related to the future operation of SONGS as a reliability source shall be considered in the Long-Term Procurement Planning (LTPP) proceeding, Rulemaking (R.) 12-03-014."

This is yet another way of removing as many issues as possible from the OII even though the OII is supposed to figure out if the SGRP was "cost-effective" or not. "Cost-effective," by definition, should consider ALL the costs!


(3) A brief history of the current steam generator problem at San Onofre:

The first reference I recall to a "cascade" of tube failures was by David Lochbaum, director of the nuclear safety project for Union of Concerned Scientists, possibly as early as February 2012.

Lochbaum formerly worked in the industry and is a trained nuclear engineer. His immediate response to the event was that such leaks are not unusual in newly-installed steam generators (Feb 1, 2012, voiceofoc.org) but after it was established that Fluid Elastic Instability was the likely culprit in unit three (a type of vibration which gets worse and worse once it starts, and tube failure becomes virtually inevitable), he was noting that "Serious leaks also can drain cooling water from a reactor." (KQED, March 16, 2012)

Within a few weeks or at most a couple of months, Arnie Gundersen also was making the claim of a potential cascade of tube failures. Gundersen was also a nuclear industry expert, in fact, an expert on steam generators specifically. In a video available on YouTube (and which I was cameraman for part of), Gundersen described the effect, saying the tubes would "pop like popcorn... pop, pop, pop."

More recently, John Large, distinguished nuclear engineer in England, and also, like Gundersen, contracted by FOE to look into the San Onofre issues, similarly postulated multiple-tube failures were possible if Unit 2 is restarted, due to the degraded condition of so many of the tubes, the inexactness of the tube wall measuring devices, the inexactness of the predictions of future tube failure (in part due to the poor quality of the measurements), the randomness of some of the vibration problems, and the like.

Additionally, the DAB Safety Team, which also has experts on it or associated with it (some of whom were formerly or are currently employed by SCE (and also includes myself, who has never worked there)), agrees with these assessments.

Several problems are all working against SanO.

One is that while the experts all agree that Fluid Elastic Instability occurred in Unit 3, there is disagreement as to whether it occurred in Unit 2 (for what it's worth, I think not). All agree that the design of SanO's steam generators has no "in-plane" support to prevent FEI in the in-plane direction (that means along the length of the u-bends).

Some of SCE's hired outside industry experts believe that friction forces from the out-of-plane supports has been and will be sufficient to prevent FEI in Unit 2. Other experts disagree with this assessment, including some of SCE's own hired outside industry experts.

In any event, the eight tubes that failed pressure testing point to a second problem: Let's say Unit 2 won't suffer FEI at 70% power -- for 5 months or at all. But what if there is a main steam line break, with a main steam line isolation valve failure? That is known as a "design basis accident" which means the utility is expected to prove it has a workable plan to handle such an event. Experts I've talked to do not believe SCE can possibly make that claim -- there would likely be a large radiation release resulting from loss of coolant, with possible core damage. The wear rates in Unit 2 were too high, even without FEI -- just from flow induced vibration. (FIV is a chaotic (random) vibration, FEI is rhythmic and coordinated -- the tubes all sway together in unison.)

Lastly, San Onofre exposed a generic problem for Pressurized Water Reactors (that is, reactors that use steam generators) everywhere: Multiple tube failures are possible. They can result from FEI or from any leak if unchecked, because one pinhole can expand over a period of an hour or so (I forget the average time frame this can happen but it's pretty short) and then it can snap off and hit another tube, causing multiple tube complete ruptures. Of the eight tubes in Unit 3 that failed pressure testing, three of them failed below main steam line break pressure differences expected between the inside of the tubes and the outside. So that's a second route to multiple tube failures, though perhaps not exactly a "cascade" effect of one tube ripping apart and slamming into another -- though it could initiate that effect, too.

NRC regulations do not currently appear to accept the concept of multiple tube failures. Once considered impossible because the reactor would be shut down first, it's now clear that there was at least one instance where a cascade of tube failures was possible -- San Onofre. San Onofre has proven conclusively to the industry that it can happen, although fortunately it did not occur here last January.

No one can say exactly how close to such an event we actually came. No one can truthfully say for certainly that can't happen here. It almost did.

Ace Hoffman
Carlsbad, CA

(4) Press release regarding the scoping memo from Woman's Energy Matters:

For immediate release January 29, 2013

Contact: Barbara George, Exec. Dir. Women's Energy Matters 415-755-3147


Parties to the California Public Utilities Commission's (CPUC)
investigation of the San Onofre nuclear generating station outage are
crying foul over ongoing procedural delays and a narrow Scoping Memo
issued Tues. Jan. 28th. Women's Energy Matters, the Coalition to
Decommission San Onofre, United Public Workers For Action and Michael
Aguirre charge that both seem designed to force southern California
customers to pay even higher rates in the next couple of years to fund
Edison's reckless plan to restart one of its severely damaged reactors —
instead of getting immediate refunds for the year the nuclear plant has
been offline. Parties ask CPUC to stop paying for these lemons now, and
plan for permanent replacement resources instead.

The Memo would put off refunds until 2014 or even 2015, although
SoCalEdison and SDG&E collected $57m a month in 2012 as if SONGS were
operating. It seems to have deleted any review of 2012 costs for
replacement power (promised in the original Order), or most importantly,
a review of SCE's mismanagement of the Steam Generator Replacement
Project, which appears to effectively deny refunds for any of the $700
million spent on it since 2006.

Edison's radical redesign of the steam generators caused structural
failures after less than two years ­ an industry record. SCE falsely
told the Nuclear Regulatory Commission (NRC) and CPUC that the
replacement generators were "like for like," avoiding a "License
Amendment Review" which might have caught problems such as an
error-filled computer simulation.

Friends of the Earth are suing NRC to force a License Amendment Review
for any restart. Edison plans to restart the slightly less damaged Unit
2 as soon as NRC gives the go-ahead (expected in March/April), run it at
70% power for 5 months and then shut down for inspections.

Local residents warn that SCE's plan puts California's economy at risk,
along with more than 8 million people who live within 50 miles of SONGS.
That's the distance from Fukushima Daiichi that the NRC recommended for
Americans to evacuate. SCE's testimony on possible rate reductions
proposed nearly full funding for most operations but hardly anything for
Quality Assurance and whistleblower protection.

The Memo offers a booby prize, agreeing to consider "community outreach
and emergency preparedness." Parties say they intend to fully explore
California's emergency plans for nuclear accidents, which dates back to
the 1980s and involves multiple agencies. They call for expanding the
evacuation zone from the current 10 miles to 50, extensive real-time
radiation monitoring with public reports, and including earthquake
impacts on emergency planning, which NRC rejected back in the 1980s,
claiming "earthquakes are no worse than fog." Prior to any restart,
parties will insist on a real-world emergency drill, to test emergency
plans that are currently only paper exercises conducted every 3 years by
first responders.
Women's Energy Matters (WEM) has been a public interest party
("intervenor") in CPUC cases since 2001. See more information at

For in-depth information about SONGS, see http://sanonofresafety.org

CPUC's Scoping Memo is posted at

Selected quotes:

Broadly stated, the scope of the future Phases of this OII are
envisioned as follows:

• Phase 2 ­ whether any reductions to SCE's rate base and SCE's 2012
revenue requirement are warranted or required due to the extended SONGS
outages… Memo, p. 4. [Note: a decision on Phase 1 would come in August
at the earliest; no date was set for Phase 2 to begin.]

…SCE and SDG&E argue that the Commission may not order refunds of any
expenses related to the SONGS outages … because it would constitute
"impermissible retroactive ratemaking." Even if the Commission were
authorized to make such an order, the utilities contend no refunds could
occur prior to the 2015 GRCs. [GRC = General Rate Case]. Memo, pp. 5-6.
[Note: The Memo asks parties to submit legal briefs on these issues,
indicating that Commission lawyers lack confidence whether refunds are
legal. The question arises: why did the Commission's recent decision on
SCE's 2012 GRC allow SCE & SDG&E to keep collecting SONGS revenues, when
the plant was already out of service and the long-delayed Investigation
was finally about to begin?]

[T]o ensure that review of community outreach is considered in
conjunction with local emergency preparedness activities, this Scoping
Memorandum and Ruling explicitly authorizes review of SCE's actions and
expenditures for community outreach related to the SONGS. p. 10.

Edison's Testimony and other public documents are posted at

The following is an excerpt from SCE's December 15, 2012 Testimony, pp.

The Engineering functional group consists of the Design Engineering,
Plant Engineering,

Nuclear Safety Concerns, and Nuclear Oversight/Assessment divisions. …
Plant Engineers are familiar with the design basis of their assigned
plant systems… [Ed. note - In other words ­ these people might
understand what went wrong with the new steam generator design — so
let's get rid of them]

Nuclear Safety Concerns provides an alternate, confidential mechanism
for SONGS workers to identify conditions related to their personal
safety, the health and safety of the public, or compliance with NRC

Nuclear Oversight and Assessment develops, maintains, and oversees the
Quality Assurance and Performance Improvement programs. It provides
managerial and administrative controls to assure safe operation and
maintenance of SONGS systems required by the NRC… SCE thus
conservatively estimates that it must expend at least 15% of the
GRC-authorized amount for the Engineering group regardless of whether
SONGS is operational, and this 15% of the GRC-authorized amount should
not be subject to refund.


(5) Statement regarding the scoping memo from Michael J. Aguirre, Esq.:

Contrary to what the PUC news release led the public to believe the PUC issued a "scoping" memorandum today limiting the review of San Onofre issues to those helpful to SCE and hurtful to the public. The scoping memo makes a mockery of the PUC "investigation" because it allows only a very limited review of the issues: (1) assessing the reasonableness of SCE's actions and expenditures after the outage; (2) whether SCE's 2012 expenditures for SONGs was reasonable; (3) the reasonableness of SCE's expenditures for community outreach; and (4) whether SCE should refund any money they were allowed to keep under the General Rate Case issued in December 2012.

Here is what will not be allowed: (1) whether SCE was imprudent and unreasonable in spending $800 million for the 4 new generators to replace the previous generators which tube problems, when the new generators had tube problems worse than those replaced; (2) whether the 4 generators should be taken out of the rate base. The Scoping Order does not address the first question and pushes off the second to some undetermined time in the future. The PUC has mislead the People of California by issuing a news release announcing an investigation while issuing an order that does not permit a reasonable investigation.

It is clear that the PUC has decided to get San Onofre back in operation as soon as possible. The PUC "investigation" is nothing more than a cynical public relations stunt.

Michael J. Aguirre, Esq.

(6) One-year commemoration of the near-destruction of Southern California planned:

NoSanO: 1st Anniversary of the San Onofre Nuclear Shutdown

The 1st Annual NoSanO Anniversary: 1 Year Without San Onofre. Featuring Ed Begley, Jr at 6:30p, Live Music by the Kalama Brothers, and the U.S. Green Chamber of Commerce tells us about The Green Job Market.

One year ago, a radiation leak nearly became a major nuclear disaster. A year without any blackouts proves we don't need to live with the danger. Safe, reliable and sustainable alternatives will provide energy and jobs.
Join us for an enjoyable and informative evening.

$10 Prepaid Admission gets you in the door, plus a Slice of Pizza and a beverage of your choice (wine, beer, soft drink). $15 at the Door. Additional servings: $2.50 per slice / $5.00 beer or wine (other drinks free)

We also have a bus set up from San Diego's Balboa Park (SW corner of Park Blvd & President's Way) with stop at the Oceanside Transit Ctr for only $10 Roundtrip!

Select the SD-O'side Bus Ticket on the Ticket Menu here and also your Pick-Up location (San Diego or Oceanside) from the Drop-down Menu in answer to the Question at Checkout.

Ed Begley, Jr, is an American actor and environmentalist who has appeared in hundreds of films, television shows, and stage performances. He is best known for his role as Dr. Victor Ehrlich, on the television series St. Elsewhere, for which he received six consecutive Emmy Award nominations, and his most recent reality show about green living called Living With Ed on Planet Green with his wife, actress Rachelle Carson-Begley. For more on Ed, see http://www.edbegley.com

The Kalama Brothers: Diverse in their music from Traditional and Contemporary Hawaiian, to Soul and Classic Rock. The magic of their harmonies is something special! They'll fill your hearts with their love and touch your souls with their warmth. http://http://www.kalamabrothers.com

The U.S. Green Chamber of Commerce's goal is to facilitate and support sustainable business practices that spur innovation, job creation, energy efficiency and an overall brighter economic future. The Chamber was established in San Diego in 2009, and has since expanded across the nation with branches in Texas and Florida. http://http://www.usgreenchamber.com

Presented by San Clemente Green, with more info on www. SanOnofreSafety.org


Martha Sullivan posted in North County San Diego Anti-Nuke Working Group

2:25pm Jan 29

Folks, we really need you to COMMIT and Buy your Ticket(s) online -- you'll save $5 and time at the Door, too! And the RT bus from San Diego at $10 is a STEAL -- plus, you'll be wristbanded On the Bus and ready to blow through the Door when you arrive.

Just DO IT: http://www.brownpapertickets.com/event/319537 !
NoSanO: 1st Anniversary of the San Onofre Nuclear Shutdown

(7) Contact information for the author of this newsletter:

** Ace Hoffman,
** POB 1936, Carlsbad CA 92018
** home page: www.animatedsoftware.com