Friday, November 30, 2012

Press Release (Revised) 12-11-30 SCE: Don't Gamble Our Future On Probabilities & Un-Verified Data


Dear Readers,

Here are two press releases related to today's NRC meeting regarding San Onofre Nuclear Waste Generating Station, which has been closed since January and should never reopen.

The "DAB" Safety Team's report (I am a small portion of the DAB team) is attached (below, bottom). Ray Lutz's Citizen's Oversight press release is also below (top).

There are rumors that the NRC would like SCE to give up and stop trying to restart San Onofre. Ain't gonna happen. San Onofre's owners were just given over 5 billion dollars in rate hikes over the next few years by the CPUC; they're rolling in dough to fix San Onofre at a leisurely pace. Current plans are to start SanO Unit 2 at 70% power for six months starting February 2nd, which is interesting because that would mean it would be purposefully shut down right smack in the middle of the summer, when it's supposedly needed the most!

What kind of planning is THAT? Sounds propagandistic to me!

We'll find out what happens tonight at the NRC hearing. (I'll be listening to the web cast, if the NRC's technology works.)

Ace Hoffman
Carlsbad, CA

San Onofre Safety Press Release about tonight's meeting:

NRC video link:


From: Ray Lutz <>
Subject: [ShutSanOnofre] Press Rel: NRC Mtg 6pm;
Press Conf. 4pm. TODAY on San Onofre



PUBLIC to NRC: No Restart! Shut Down San Onofre!

TODAY: Edison will propose to restart Unit 2 before failure is understood


Event: NRC Public Meeting

Date/Time: Friday, November 30, 2012 / 6-9 p.m.

Location: The Hills Hotel, 25205 La Paz Rd, Laguna Hills CA

Event: Press Conference by Coalition to Decommission San Onofre

Date/Time: Friday, November 30, 2012 / 4 p.m.

Location: Outside the Hills Hotel, 25205 La Paz Rd, Laguna Hills CA

November 30, 2012 (SAN ONOFRE, CA) ­ A coalition of community advocacy groups opposed to the restart of the defective San Onofre Nuclear Power Plant will attend the public meeting rescheduled by the U.S. Nuclear Regulatory Commission (NRC) to consider Southern California Edison's plan to restart the defective nuclear reactor Unit 2 at San Onofre.

This will follows the March to Decommission San Onofre, led by four Buddhist Monks from the Dana Point Harbor parking lot this morning to the pier. The original plans to go by the San Onofre plant were scuttled when high levels of radiation were measured near the replaced steam generator on the road.

Our Coalition stands by our Core Message delivered at the NRC's public meeting in Dana Point on October 9, 2012:

NO RESTART! of the defective nuclear reactor Unit 2 at the San Onofre Nuclear Power Plant.

We demand a full License Amendment and Hearing and process, including evidentiary hearings with sworn testimony and cross-examination which include experts independent of the NRC, Edison and the nuclear power industry. Of course will all the facts on the table, this will likely mean there will be no restart attempted.

This public meeting tonight is NOT a substitute for this process. Given how we got to this point and the serious loss of faith by the public in the NRC and Edison as a result, we can see no reason why all five NRC Commissioners would not want this as well.

NRC proceedings regarding San Onofre should be conducted in the area most impacted by the decisions of these proceedings and should accommodate the more than 1,000 concerned citizens who are expected to attend ­ as they have consistently shown this year.

A growing number of Southern California City Councils have added their voice to our call for an adjudicated License Amendment and hearing process prior to restart of the crippled San Onofre Nuclear Power Plant in defense of their residents and businesses, including:

Del Mar



Laguna Beach

Mission Viejo

Santa Monica, and

Solana Beach.

The cities of San Clemente and Vista have joined in Senators Boxer's and Feinstein's call for the NRC to modify its policies and procedures in light of the Fukushima meltdowns, to further protect their residents and businesses.

On November 8, 2012, the five Nuclear Regulatory Commissioners ruled on petitions filed by Friends of the Earth in June of this year calling for the foregoing. Specifically, the Commission:

Referred to the Atomic Safety & Licensing Board (ASLB) whether the current Confirmatory Action Letter (CAL) process is a de facto license amendment process, requiring an adjudicatory public hearing;

Referred to the Executive Director of Operations (EDO) whether Edison should have sought a license amendment, with attendant adjudicatory hearings, when it installed the defective steam generators in 2010-11;

Offered to reconsider convening an adjudicatory hearing if the ASLB denies FoE's request;

Offered to reconsider staying the restart of the idled reactors if restart becomes "imminent" before the completion of the processes ordered above.

The Coalition to Decommission San Onofre is comprised of community-based, grassroots organizations in San Diego and Orange Counties concerned for the safety of 8.5 million residents living within 50 miles of the crippled San Onofre Nuclear Power Plant, and for the economy of Southern California. We continue to hold the five members of the Nuclear Regulatory Commission accountable.

Additional Key Information:

Southern California Edison wants to restart one of their broken nuclear reactors without fixing it first.1 The plant has been off-line since 1/31/2012 due to radiation leaks and excessive tube wear in newly replaced steam generators2 that are the worst in the nation. See Tubes Plugged Chart3 and Fairewinds Associates report: San Onofre's Steam Generators: Significantly Worse than all Others Nationwide.4 The NRC says design changes in these steam generators are flawed,5 making the reactors unsafe.

California has excess power without California's unreliable nuclear power plants, even during peak summer months, according to California government documents6. And the California ISO's electricity grid Transmission Plan7 says there will be no grid stability concerns with San Onofre shut down.


Citizens' Oversight: Ray Lutz / / 619-820-5321

Peace Resource Center of San Diego: Carol Jahnkow / / 760-390-0775

Residents Organizing for a Safe Environment: Gene Stone / / 949-233-7724

San Clemente Green: Gary Headrick / / 949-218-4051









Ray Lutz
Citizens' Oversight

ShutSanOnofre mailing list
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The DAB Safety Team: November 30, 2012
Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261 
Don't Gamble Our Future On Probabilities & Un-Verified Data
SCE erroneous claims about Westinghouse and AREVA Operational Analysis (OA) as being Deterministic Analysis are misleading, confusing and controversial.  These OA’s are Actually Possibilistic Analysis, (PA) which is nothing more than Profitganda, the use of phony "feel good" information to sell an idea, product or concept to the masses.
Safety analysis can be characterized as Probabilistic, Deterministic or a combination of both known as Possibilistic Analysis.  Deterministic Analysis Definition: Analysis of a deterministic problem, without taking the probabilities of different event sequences into account. [Source:]
1.      Attachment 6 - Steam Generator Operational Assessment- 3.6 Summary of All OAs  - The OAs (See Table 3-1) summarized in Sections 3.1 and 3.2 conclude the SIPC and AILPC are satisfied.

Table 3-1: Edison OA Approach and Results Comparison

OA Description

OA for Degradation
Mechanisms Other
Than TTW

TTW OA With No
Effective AVB

Probabilistic OA
Prepared for TTW

Deterministic TTW

Attachment 6 Appendix
Appendix A
Appendix B
Appendix C
Intertek APTECH
Appendix D
Edison Claim
DAB Safety Team Analysis


Possibilistic (Alarming)

2.  AREVA Attachment 6 – Appendix B: SONGS U2C17 - Steam Generator Operational Assessment for Tube-to-Tube Wear – page 20 - 4.2 - Operational Assessment Strategy: The nominal distance between extrados and intrados locations of neighboring U-bends in the same plane ranges from 0.25 inches to 0.325 inches due to the tube indexing. There are 36 U-bends in Unit 2 SG E-088 and 34 in SG E-089 with a separation less than or equal to 0.050 inches (Design 0.25 inches, Arkansans Nuclear One Unit 2 0.35-0.50 inches).  The U-bends with the smaller separation distances are much better candidates for wear by rubbing yet do not exhibit TTW.  Contact forces, as deteriorated by tube wear at support locations over time, will be calculated using advanced computational techniques. This will be combined with calculations of stability ratios to develop the probability of the onset of in-plane fluid-elastic instability (an alarming statement because a Main Steam Line Break (MSLB) accident has no time line), both as a function of operating power level and operating time. The operating power and operating time will be adjusted to provide a probability of occurrence of instability 0.05. This probability is based on considerations and requirements described in the EPRI SG Integrity Assessment Guidelines. Without the development of TTW, the Structural Integrity Performance Criteria, SIPC, is automatically satisfied to a probability greater than 0.95.
DAB Safety team Comment:  This is claimed to be a Deterministic OA but is using Probabilities. This is projecting possibilities using probabilities.  Hence this is an (Alarming)  Possibilistic OA and not a Deterministic OA as claimed by SCE.
 3. Westinghouse Attachment 6 – Appendix D: Operational Assessment of Wear Indications In the U-bend Region of San Onofre Unit 2 Replacement Steam Generators, Page 5, Section 1- Introduction: For the SONGS application, the resulting wear distribution after a cycle of operation is known, or can be inferred from existing ECT data, but for any given tube, there are many parameters that resulted in the wear distribution that are unknown.  It can be assumed that the tube and AVB surfaces will not have significant run-in effects for the first cycle of operation, but even this assumption involves a potential error of several hundred percent. Most importantly, the tube/AVB geometry is expected to be different than the original design intent, but all that can be inferred with the available information is the minimum length of the dominant tube vibration span. In the largest sense, the answer (wear distribution) is known, but the inputs are unknown.
Foot Note 4, Page 101: Westinghouse does not have access to the assembly procedures. The 0.12 to 0.14 dimensions are anecdotal without verification.  NOTE: Anecdotal: Based on personal observation, case study reports, or random investigations rather than systematic scientific evaluation. [Source:]
Foot Note 5, Page 102: Westinghouse does not have access to final manufacturing or inspection details, but anecdotal input indicates that six-pound weights were allowed and used during AVB inspection for consistency with AVB drawing tolerances.
DAB Safety team Comment:  When you start using the words unknown, assumed, inputs are unknown, anecdotal without verification and this assumption involves a potential error of several hundred percent, then this Deterministic OA is using unknown Probabilities and un-validated (Alarming) Possibilities. Hence this is a Possibilistic OA and not a Deterministic OA as claimed by Edison.

4. Enclosure 2 San Onofre Nuclear Generating Station Unit 2 Return to Service Report -Section 5.2.2 Probabilistic Risk Assessment: The differential pressure across the SG tubes necessary to cause a rupture will not occur if operators prevent RCS re-pressurization in accordance with Emergency Operating Instructions.

The DAB Safety Team Comment:  Do Southern Californians really want to live at the mercy of SCE’s plant operators, who will be put in the very difficult position of operating defective steam generators that already have thousands of damaged tubes, just so SCE can profit (See SONGS Union Leader's letter that the SONGS workforce thinks a restart is not safe)?  Even an Ex-Plant Shift Manager said, “He was not going to put his license on line and risk public lives because SCE Management wants to make money by restarting a defective reactor.”  The question is, how bad do these steam generators have to be before the NRC tells SCE to pulls the plug? 
The DAB Safety Team believes that SCE’s own data proves beyond a doubt, that these already heavily damaged replacement steam generators (RSG) should never be restarted.
Guessing On Nuclear Safety Caused A Trillion Dollar Radioactive Eco-Disaster At Fukushima!

Copyright November 30, 2012 by The DAB Safety Team.  All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team. The contents cannot be altered without the Written Permission of the DAB Safety Team

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