Thursday, October 22, 2009

Concerns regarding San Onofre's Steam Generator replacement project

To: Nuclear Regulatory Commission Submission (for tonight's hearing in Dana Point, California)
October 22nd, 2009

The most dangerous times for any nuclear power plant are: Initial start-up or during a restart, and during a shut-down, especially an emergency shut-down.

Three Mile Island Unit II, for instance, had been in commercial operation for less than three months when it partially melted down. It was only slightly different from, slightly more powerful than, Unit 1, which, today, was relicensed by the same careless Nuclear Regulatory Commission we seek redress from today as well -- for another 20 years -- until April 19, 2034. Some of Three Mile Island Unit 1's parts will be 60 years old when it is finally "retired" -- irradiated, thermally heated, pressurized, chemically embrittled, and cycled on and off hundreds or even thousands of times.
The Emergency Core Cooling Systems, mandatory for all commercial reactors, have never actually been tested, and many scientists have asserted that their calculations have indicated the ECCSs may not work when needed. Not only that, but several ECCSs, such as Monticello's, were found to be completely inoperative several decades after installation, and would definitely not have worked. Control rods have jammed, fuel rods have been bent, plutonium has escaped... and one reactor, Davis-Besse, nearly corroded all the way through before anyone noticed! Except maybe the filter salesman.

Many of San Onofre's sea-encrusted, rusted, dilapidated parts will be 60 years old, too, if it makes it to retirement age.

And with all the NEW parts they are installing at San Onofre right now -- miles of pipes, dozens of pumps, scores of valves, hundreds of new sensors, drum after drum of electrical cables -- there will be new pressures and fluid flows throughout the system, new control mechanisms, and even relatively new, or completely new, operators. People quite a bit younger than the plant itself, who don't know how hard people fought to stop it in the first place. Who don't know that almost all our fears have ALREADY been realized, from cancers in the community because of the plant, to fraud at the plant, to piling nuclear waste problems, to threats of terrorism. Yes, it was all foreseen.
Right now, one by one, each of San Onofre's two remaining operable reactors are being rebuilt, top to bottom. That is, pieces of them are being replaced, top to bottom (even the fog lights, and certainly the sump pumps). But despite the retrofit, vastly more pieces are never being touched, never even being inspected.

How much inspection can such a small crew as the NRC leaves "on site" really do? There is only one inspector for every couple of hundred workers.

Furthermore, a climate of cover-up still exists at the plant, according to whistleblowers this author has talked to. And no doubt no one from The Shaw Group wants to expose their mistakes, since they are all new at the site and the last group or operators -- Bechtel and their subcontractors -- were fired en masse after about 40 years of running the most dangerous thing on earth, on August 30th, 2009.
During the retrofit -- a different division of Bechtel is doing that work -- the danger is probably a lot less than during an average day the plant is running. Criticality is not occurring at the shut-down reactor. Water isn't screaming through the system at enormous velocities and pressures. Lazy, sleepy operators on mood-altering cardiac beta blockers for health problems due to sitting all day long aren't using inaccurate and faulty instrumentation to monitor the whole thing and stop it from melting down.

So I'm less scared when the plant is shut down than at any other time. But the restart AFTER this major retrofit will be an especially dangerous time.

And then, the continued operation of the plant for 20 more years may well spell doom for SoCal at some point -- for any of a million different reasons. The old welds might start failing, let alone all the new ones that weren't done right, or were done right in Japan or elsewhere in the world, but didn't get shipped properly to America, or broke during installation. And nobody reported anything, because of the climate of cover-up.

During the actual retrofit, at least the reactor that is being refitted is not increasing the quantity of spent fuel with nowhere to put it by an average of 250 pounds per day per reactor, as happens each day the reactor is operating (500 lbs per day for San Onofre altogether, when both reactors are running). That's in addition to the tritium which is released and poorly tracked, and the hundreds of pounds per year of noble gases which are not tracked or stopped in any way at all, and the daily releases of radioactive isotopes of all known elements, in varying quantities, as allowed by ALARA.
All nuclear facilities vent radioactive isotopes to the public. HEPA filters were originally designed in the 1940s for cleaning the air of radioactive particles but they only achieve a 99.97% success rate (by definition). 3 particles in 10,000 may not sound like a lot, and might have been good enough for The Manhattan Project, but when you are releasing billions of billions of particles every day INTO the filters, it means you are letting a lot of children die in your community DESPITE the filters. And HEPA filters don't work for isolating tritium (a lot more H3 could be removed, but not that way) nor do they do anything to stop the release of the noble gases, which flow right through them. The legal limit for releases of tritium each year by each reactor at San Onofre is about one thirtieth of a teaspoon. Tritium is extremely hazardous, and even this seemingly small amount is way, way too much. And besides, whenever they release more than a thirtieth of a teaspoon, the NRC gives them two special dispensations: One not to say anything, and one not to do anything.

So-called "low-level" waste, such as the old steam generators, and the old pumps, pipes, valves, etc., which are being swapped out at the same time as the steam generator replacement project is going on, will be irradiating people, and will get into our children's braces eventually.

No reactor should ever be restarted. Period. Shut them ALL down and dismantle / decommission them. All other choices are folly.

Ace Hoffman
Carlsbad, CA
The author has developed and distributed award-winning educational software for more than 25 years and has customers at over 1000 colleges and universities in over 100 countries. His company web site -- -- gets millions of "hits" every month. Hoffman has studied nuclear power for about 40 years and wrote approximately 1000 blog entries on nuclear issues prior to authoring The Code Killers in 2008 (and several dozen since).


Ace Hoffman
Author, The Code Killers: An Expose
Carlsbad, CA