Tuesday, March 26, 2013

Re: Query re SoCal Public Meeting on San Onofre Restart

To: Jason Paige <Jason.Paige@nrc.gov> (and other officials...)

Date: 3/26/2013

Dear Mr. Paige, other NRC staffmembers, Commission Chairperson Macfarlane,

You could have saved Californians close to a billion dollars by now if you had told Southern California Edison a year ago that the test results from the 8 tube ruptures during main steam line break testing clearly indicate the design of the steam generators is faulty, and permission will not be granted for restart.

If SCE had then chosen to decommission the plant, that is.

(Of course, you could have done that in 2004 when you first saw the designs, and saved us at least another billion.)

You could save us 68 million dollars this month if you were to make that same decision now instead of next month.

And, again, assuming SCE starts to decommission San Onofre. And that's the logical choice, especially in light of no one having any confidence in the waste confidence decisions now being considered at the federal level. That's a hot potato, for sure.

You could save us a meltdown if you decide not let SCE restart San Onofre. Or that decision could be the "root cause" of the world's first meltdown of a Pressurized Water Reactor. (I mean, forgetting about Three Mile Island and its partial fuel melt, of course. They got very, very lucky that time in Pennsylvania.)

I am frankly amazed that the NRC is acting as though SCE has even begun to prove their case for restart -- at ANY power level. At the very least, the 26 questions from the December 26th, 2012 NRC letter to Pete Dietrich, CNO of SCE, have not been satisfactorily answered any more than the 32+16 additional follow-up Requests for Additional Information have been properly resolved. At the last public NRC meeting on San Onofre nearly every answer from SCE was "we are considering several possibilities" or "we're looking into it" or "we'll let the 'experts' from MHI, AREVA, and so on answer that one" (and those answers were no more satisfactory than SCE's).

Dr. Pettigrew, an invited expert at the meeting, when asked what studies need to be done, practically threw up his arms as he declared it would take thousands of sensors at $70,000 each to study the Fluid Elastic Instability questions raised by San Onofre. Such research hasn't even begun because of the cost -- about one month of ratepayer subsidies for the inoperable plant. But despite the lack of research, we do know what really happened in identical steam generators in Unit 3, and there is NO WAY that Unit 2 is different enough to be safe from FEI during a Main Steam Line Break. Or any time. San Onofre is the "Galloping Gertie" of the nuclear fleet. (See the animation at my blog for the various ways SanO can shake itself a part.)

Furthermore, if you look at some of the reasons SCE thinks the original steam generator replacement was a "like for like" substitution, you'll see that an increase in risk in one area (for example, containment dome over-pressurization accidents) was merely offset by a second change in another area (for example, calculated likelihood of such a containment dome pressurization event).

I'm not saying such "logic" isn't permissible -- I'm saying it represents TWO major design changes, not ZERO design changes: Was the first calculation done right? Was the second done right? Was the comparison done right? Even as little as a fraction of 1% change in these sorts of values should be more than enough to trigger a public license review. FEI might be completely absent at 99.5% dry steam, yet have set in catastrophically at 99.6%. And the cause of the difference in percentage might be a fraction of a percent difference in flow rates in the primary loop. The circulation ratios, pressures, temperatures, and many other factors all affect the onset of FEI. No one can prove San Onofre can be operated safely because the design is faulty. The only significant difference between Unit 2 and Unit 3 is that Unit 2 hasn't failed yet, but one tube was 90% of the way there when Unit 3 failed and the problems were discovered. The truth is, we should never have had a leak in Unit 3, because Unit 2's enormous wear problems should have triggered an immediate shutdown of Unit 3 before January 31, 2012! Or have we all forgotten that fact?

NRC has asked SCE a lot of good questions. SCE's answers thus far have been evasive, inadequate, equivocal, indeterminate, and utterly unpersuasive. And now you want to let them restart Unit 2 without a public hearing, without questioning under oath by independent experts (that means, independent of the failed regulatory agency AND the influencing industry)? Please don't. We've had enough. We want our money back, actually -- or at least we want SCE to be told Unit 2 is no more likely to get a restart "okay" than Unit 3 is, which means not at all unless some magical, new, untested third set of replacement steam generators passes muster with the experts, the public, the Public Utilities Commission which will force us to fund it, as well as NRC experts who let slip the first set of changes but will presumably be more attentive next time.


Ace Hoffman
Concerned Citizen
Carlsbad, CA

Subject: If there are brown-outs or blackouts this summer, we will have no one to blame but Southern California Edison


Dear Readers,

The statement below was written by a long-time (>10 years) highly educated and very technical San Onofre employee who left the company last summer. It is an excellent description of the technical problems at San Onofre. I do not understand why ratepayers in California are still paying about $68 million/month for the upkeep of San Onofre. At the time the steam generator replacement project was approved in 2004, the Public Utilities Commission concluded that operation with only one reactor would not be cost-effective. The reason the SGRP was approved at all was because SCE claimed that doing so would save ratepayers about a billion dollars over the coming two decades. They were wrong: Instead, we've ALREADY spent about TWO billion dollars on the replacement project itself and 14 months of operations and maintenance costs with ZERO output from the reactors -- AND the lights have stayed on.

As the warm season approaches, once again we are being warned about the possibility of blackouts, and once again no effort has been made to replace San Onofre's output with vastly more efficient solar rooftop panels, wind turbines, demand response, and other clean solutions. The complete replacement of San Onofre's electrical output could have been accomplished already. In fact, after the energy crises of the early 2000s, MORE capacity was added in California in a single 14-month period than San Onofre and Diablo Canyon combined could produce!

So if there are brown-outs or blackouts this summer, we will have no one to blame but Southern California Edison. They don't need a CPUC decision to do the right thing. They can decide for themselves, and for the sake of their customers, to decommission San Onofre, and should do so immediately.

But instead, SCE wants to restart Unit 2 at 70% power, which will be just as dangerous in many ways as running at 100% power (see below), and will not be "cost-effective" even without trying to account for the cost of storing more and more spent fuel virtually forever, let alone, trying to account for the cost of potential, foreseeable, catastrophic accidents.

And not only does SCE want to restart, they want to do it without ANY additional public hearings until AFTER the restart! They're having a special meeting with the NRC next Wednesday (4/3/2013) in Maryland just to discuss how to avoid public scrutiny! (The meeting will start at 10 am Pacific time and be webcast on the NRC web site. A phone-in line will also be provided. Call 888-677-3916 and use passcode 2670631. )

Unit 3 (the one that sprung a leak January 31, 2012) cannot be restarted without installing all-new steam generators of an all-new and untested design at a cost of several billion MORE dollars and several years' additional delay. Why bother? Why aren't we already 14 months into decommissioning San Onofre?

California used to be THE leader in renewable energy technology. It's time we were again.

Ace Hoffman
Concerned Citizen
Carlsbad, CA

Shown below:
(1) The following was written a few days ago by a former San Onofre employee
(2) Invitation: Come hear Torgen Johnson, Ace Hoffman and others talk about San Onofre
(3) Contact information for the author of this newsletter

(1) The following was written a few days ago by a former San Onofre employee:

The basic fundamental problem is that in all the Mitsubishi San Onofre replacement steam generators, the anti-vibration bars and tube support structures are NOT designed for prevention of excessive tube vibrations from the high dry steam (fluid elastic instability).

That is what happened in Unit 3.

Patches of high dry steam in 4% of the area of Unit 3 U-tube bundle in replacement steam generators caused one tube to leak, 8 tubes to fail under main steam line break testing conditions and destroyed almost 400 tubes and that was the end of the life of the Unit 3 replacement steam generators. NRC called it a very serious safety situation, which has never happened in a US Nuclear Plant.

At the most one tube has leaked at US Nuclear Power plant in the last 30 years, and that is the end of story, but not at San Onofre.

According to NRC and Federal Rules, all the steam generators, no matter whether you operate at 0%, 50%, 70% or 100% power, have to be designed against very low probability of a tube leak due to vibrations during any power level and especially caused by high dry steam conditions during a Main Steam Line break accident. During such an accident, in Unit 2 at 70% power, 100% steam generator will be full of 100% dry steam. Many tubes like Unit 3, can break and leak in Unit 2 in minutes, nobody exactly knows. In 5-15 minutes, 60 tons of radio active coolant can escape into the environment with steam and San Onofre operators cannot do any thing to stop it. Who can predict the end result, Three Mile Island, Fukushima, Chernobyl, Mihama..... The point is even running at 70% power, SCE cannot guarantee public safety because an accident can happen at any time. This is just an effort on SCE's part to stay in the rate base, make money and hoping nothing happens until Mitsubishi can rebuild these steam generators in 5 years. But meanwhile, Unit 2 is the same as Unit 3 and the same old players SCE and MHI, playing the same old games risking public safety instead of ensuring public safety.


(2) Invitation: Come hear Ace Hoffman and others talk about San Onofre:

"From Three Mile Island to San Onofre: Re-igniting a 'No Nukes' Consciousness"

When: TOMORROW! (Wednesday, 3/27/2013) from 7:00 pm to 9:00 pm. Doors open at 6:30, refreshments available

Where: Friends Meeting Hall, 1440 Harvard St Santa Monica CA (south of SM Blvd -- park in back)

Cost: Free (a hat will be passed to cover the room cost)

For more information visit: ActivistSupportCircle.org or call: 310-399-1000
or email: Jerry Rubin <jerrypeaceactivistrubin (at) earthlink.net>

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

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
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