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.

Sincerely,

Ace Hoffman
Concerned Citizen
Carlsbad, CA

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

3/26/2013

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:
=======================================

Topic:
"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
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Carlsbad, CA
Email: ace [at] acehoffman.org

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

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

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
3/26/2013

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 Torgen Johnson, Ace Hoffman and others talk about San Onofre:
=======================================

Topic:
"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
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Carlsbad, CA
Email: ace [at] acehoffman.org

-----------------------------------------e.com/">www.animatedsoftware.com
************************************************

San Onofre 2 years after Fukushima: A video retrospective of a movement...

A Land Without SONGS, a 24-minute documentary, is currently the lead item on the USTC360 You Tube Channel home page):
http://www.youtube.com/user/USTC360

Direct URL for A Land Without SONGS:
http://youtu.be/bQ116Rj_waA

I'm quite amazed to see this wonderful little video, which aired last weekend and is now available on You Tube.

Zora and the other little girls are so precious, and it's just amazing to watch them try to stop San Onofre. It's their future. As Lyn Hicks says, it doesn't matter much for Lyn, in her mid-80s, or even for me, in my mid 50s. But it matters greatly for the children, in their mid-teens, and for their future. And they're trying to do something about it. We should all try to help the children win the fight against San Onofre.

Practically everyone interviewed (except the professor; I don't know him) in the video is a friend of mine (or family)! All of them are trying desperately to get San Onofre decommissioned. Fukushima woke a lot of people up. And they CAN'T go back to sleep. As Zora puts it her dad, "It's too late [for that] now!"

And my, those orange-shirt people are living large at other's expense! That's obvious. And a report out today in the LA Times shows that for the last three years for which data is available (2008 - 2011), California added MORE jobs EACH year in the green energy technology sector than are employed at San Onofre. These people could all find useful work elsewhere, their skills are transferable and they can learn new skills, as they would continuously do if they stayed at the plant, we're told. Let them learn green!

Many thanks to everyone in this video, everyone involved in producing it, everyone who views it, and most of all, everyone who passes the URL around for others to view it!

Let's get this plant decommissioned and spend our money on something useful!

Yours,

Ace Hoffman
Carlsbad, CA

The author is a computer programmer, independent researcher, author, gadfly, activist (gulp!), humorist (when it works), cancer survivor and mountainbiker.

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

Ace Hoffman
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Carlsbad, CA
Email: ace [at] acehoffman.org

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

NO RESTART! NO WAY! Short technical explanation of why San Onofre should not be restarted!!!

I realize the document below, which was left at the NRG BLOG web site this morning by a friend of mine, is fairly technical, so I've added a GLOSSARY at the bottom to help out.

But nevertheless I highly recommend reading it (it's fairly short) and discussing it with as many people as possible in (and especially out of) the movement to shut San Onofre. It is the most succinct technical analysis I've seen to date on why it is unsafe to restart San Onofre Unit 2, even at 70% power.

Ace Hoffman
Carlsbad, CA

(Note #1: Minor corrections to the version posted at the NRC BLOG have been made to the version below. Please refer to my animation for additional parts placements: http://goo.gl/CRlQl and to yesterday's newsletter for additional discussion: http://goo.gl/q33yL )

(Note #2: Another important point, courtesy Donna Gilmore, http://SanOnofreSafety.org "If the NRC approves restart, Edison will be able to run the plant longer than 5 months. The Confirmatory Action Letter (CAL) gives Edison the discretion to make that decision after the 5 month test period ends. The NRC has refused to modify the CAL to require NRC approval after the 5 month test.")

==================================================
Subject: US NRC Blog
==================================================

FROM: HelpAllHurtNeverBaba
DATE: March 19, 2013 at 1:12 am
NRC STATUS: Your comment is awaiting moderation.

Sincere Thanks to Mr. Victor Dricks, Mr. Cale Young, Mr. Ryan Lantz, Mr. Randy Hall and entire NRC Staff. Thanks to NRC posting this blog

San Onofre NRC/SCE/MHI/ Public Education Series by HAHN BABA­ Statement of facts unless proven wrong otherwise ……… Southern California Edison Submits Operational Assessment Requested by NRC NRR RAI 32 ­ Putting Production/Profits over Safety

1. BACKGROUND: ROSEMEAD, Calif., March 18, 2013 — A new technical evaluation of San Onofre Nuclear Generating Station Unit 2 demonstrates that the Unit 2 steam generators could be operated safely at 100 percent power and reinforces Southern California Edison's (SCE) more conservative plan to begin operating Unit 2 at 70 percent power for five months. SCE submitted the operational assessment of potential Unit 2 steam generator tube wear to the Nuclear Regulatory Commission in response to NRC questions. The new evaluation determined Unit 2 could operate at full power for 11 months with full tube integrity. The assessment was performed by Intertek APTECH of Sunnyvale, CA, and supplements Intertek's earlier assessment of Unit 2 operation at 70 percent power. Intertek performs operational assessments relating to steam generators for many nuclear power plants around the U.S. "This evaluation confirms the structural integrity of the Unit 2 steam generators at 100 percent power, as requested by the NRC," said Pete Dietrich, SCE senior vice president and chief nuclear officer. "While we have no intent to restart Unit 2 at full power, this demonstrates the amount of safety margin we have built into our analyses. We welcome this additional safety analysis but remain steadfast in our commitment to restart Unit 2 at only 70 percent power."

2. Facts to Dispute/Refute SCE Claim

A. San Onofre Unit 3 operation @100 Power ­ 11 Months- SONGS Unit 3 Failed In-situ Wear Data ­ Unit 3 SG 3E088 (www.nrc.gov). The following tube wear data is based on a result of actual tube degradation in SONGS Unit 3 SG 3E088 caused by fluid elastic instability.

Row 106 Column 78, 100 percent through wall wear, length of wear ­ 29 inches
Row 102 Column 78, 99 percent through wall wear, length of wear ­ 23 inches
Row 104 Column 78, 99 percent through wall wear, length of wear ­ 27 inches
Row 100 Column 80, 81 percent through wall wear, length of wear ­ 28 inches
Row 107, Column 77, 80 percent through wall wear, length of wear ­ 34 inches
Row 101, Column 81, 78 percent through wall wear, length of wear ­ 26 inches
Row 98, Column 80, 72 percent through wall wear, length of wear ­ 29 inches
Row 99, Column 81, 72 percent through wall wear, length of wear ­ 27 inches

B. Mitsubishi Root Cause Document UES-20120254, Rev 0, page 13 of 64, Item 1, "Tube to Tube Wear due to in-plane FEI" states," Tube to tube wear was found in the U-bend region, located between AVBs, in the free span. Many of the tubes exhibiting tube to tube wear also exhibited wear at the AVBs and TSPs, in particular at the top tube support plate. For tubes with wear at the top tube support plate, it is considered that the entire tube, including its straight region, is vibrating. Tube to tube wear occurs when there is tube in-plane motion (vibration) with a displacement (amplitude) greater than the distance between the tubes in the adjacent rows, resulting in tube-to-tube contact. Some of the tubes with tube-tube wear did not experience large amplitude vibration but were impacted by tubes that did experience large amplitude vibration. Also the two tubes in Unit 2 with tube-to-tube wear had different wear characteristics than the Unit 3 tube-to-tube wear."

C. Based on Dr. Pettigrew's Research and other papers published between 2006 -2011 on fluid elastic instability experimental data, "The high dry steam velocities differ in the in-plane and out-of-plane directions. For the SONGS RSG tube geometry, based on experimental data, it is conservatively estimated that the high dry steam velocities for in-plane FEI are at least 200 % of the high dry steam velocities for out-of-plane FEI."

D. The SONGS Unit 2 SG tube wear rates calculated by AREVA, Westinghouse and Intertek Operational Assessments and Work Rates are based on the results of out-of-plane velocities, which are under conservative based on FEI Observations in SONGS 3 and Dr. Pettigrew's Research acknowledged by MHI and NRC Chairman and Commissioners.

E. Deterministic Analysis ­ Uniform Linear Tube-to Tube Wear Rate in Unit 2 based on Unit 3 Benchmarking = 100%/11 months = 9%/month, consistent with item D and Actual Observations in SONGS 3

F. Westinghouse in SONGS Unit 2 Return to Service Report, Attachment 6, Appendix D, (www.songs.community.com), page 91 states, "Table 3-2. Wear Projection Results for Active Tubes with Limiting AVB Wear Indications" shows the following active tubes in Unit 2 SG 3E089 with the following data:

Row 119 Column 89, 28 percent ECT reported through wall wear,
Row 121 Column 91, 28 percent ECT reported through wall wear
Row 131 Column 91, 21 percent ECT reported through wall wear
Row 129 Column 93, 22 percent ECT reported through wall wear
Row 126 Column 90, 21 percent ECT reported through wall wear

G. Calculate SG 3E089 tube rupture time @ 9% wear/month for 100% Tube wear @ full power operation

Row 119 Column 89, 28 percent wall wear + 72 % in 8 months = 100 % wear = Tube Rupture
Row 121 Column 91, 28 percent wall wear + 72 % in 8 months = 100 % wear = Tube Rupture
Row 131 Column 91, 21 percent wall wear + 81 % in 9 months = 101 % wear = Tube Rupture
Row 129 Column 93, 22 percent wall wear + 81 % in 9 months = 102 % wear = Tube Rupture
Row 126 Column 90, 21 percent wall wear + 81 % in 9 months = 102 % wear = Tube Rupture

H. Intertek APTECH Operational Assessment referenced in item 1 above, page I-iv states, "Two OA analysis cases were evaluated based on the sizing techniques used to define the Unit 3 TTW depths. Case 1 evaluated the situation where voltage based sizing for Eddy Current Testing Examination Sheet (ETSS) 27902.2 was used to establish the TTW depth distributions and the correlated wear rate with wear index. The results for Case 1 indicate that the Structural Integrity Performance Criteria (SIPC) margin requirements are satisfied for an inspection interval length of 0.94 years (11.5 Months) at 100% power level. For Case 2, where the TTW depths were resized by AREVA using a more realistic calibration standard, the SIPC margins will be met for an inspection interval length of 1.04 years at 100% power level. The plan for Unit 2 is to operate for an inspection interval of 5 months at a 70% power to provide additional margin to the industry requirements for tube integrity. Tube burst at 3xNOPD (Normal Operating Pressure Differential) is the limiting requirement for inspection interval length. Therefore, the accident-induced leakage requirements will be satisfied provided that burst margins at 3xNOPD are maintained during the inspection interval.

I. Deterministic Analysis results shown in item G shows that all the five tubes can rupture in 9 months or less than shown by Intertek in Probabilistic Analysis of 11 months. This Probabilistic Analysis does not meet the intent of NRR RAI 32, in which SCE promised to provide an OA that includes an evaluation of steam generator TTW for operation up to the RTP.

CONCLUSIONS: SCE is once again trying to circumvent and gaming the NRC RAI #32, just like avoiding 10 CFR 50.90 for the Brand New $570 Million RSGs . MHI Anti-vibration bar structure, designed for out-of plane vibrations, is incapable of preventing the adverse effects of tube-to-tube wear or fluid elastic instability (high dry steam) at 100% power operation or main steam line break. We saw the destruction of SONGS Unit 3 RSGs due to tube-to-tube wear or fluid elastic instability (high dry steam) at 100% power operation or Main Steam Line Break Testing. According to the analysis of Unit 2 Plant Operational Data/Procedures and Westinghouse Operational Assessment, fluid elastic instability (high dry steam, high fluid velocities, in-plane vibrations) conditions did not occur in Unit 2. Therefore, this insufficient contact tube-to-AVB forces in Unit 3 causing the FEI is based on hideous data and unreliable MHI Computer Modeling once again. Taking credit for double contact tube-to-AVB forces (Better supports), which prevented in-plane vibrations or Tube-to-tube wear in Unit 2 by NRC Region IV AIT Team/SCE/MHI directly contradicts and conflicts with statements made by Dr. Pettigrew, Westinghouse, AREVA, John Large and inconsistent with Unit 2 Operational data. This analysis by SCE does not meet the intent of Federal Regulations, NRC Steam Generator Tube Structural Integrity Criteria, SONGS NRC Approved Technical Specifications, NRC Reasonable Assurance Criteria, NRC Chairman's Standards and SCE's Overriding Obligation for Public Safety. A Lot More to Come… Thanks NRC Staff… HAHN BABA

======================================================
Glossary for above:
======================================================

AIT: Augmented Inspection Team (of the NRC)
AVB: Anti-Vibration Bar
AREVA: French nuclear state-owned corporation
CAL: Confirmatory Action Letter (sent from the NRC to SCE)
CFR: Code of Federal Regulations
ECT: Eddy Current Testing
ETSS: Eddy Current Testing Examination Sheet (27902.2)
FEI: Fluid Elastic Instability
MHI: Mitsubishi Heavy Industries
NOPD: Normal Operating Pressure Differential
NRC: Nuclear Regulatory Commission
NRR: Nuclear Reactor Research division of NRC
OA: Operational Assessment
RAI: Request for Additional Information
RSG: Replacement Steam Generator
RTP: Reactor Thermal Pressure (standard thermal pressure)
SCE: Southern California Edison
SG: Steam Generator (for example, SG 3E089 and SG 3E088 are Unit 3)
SIPC: Structural Integrity Performance Criteria
SONGS: San Onofre Nuclear [Waste] Generating Station
TSP: Tube Support Plate
TTW: Tube-to-Tube Wear


======================================================
Contact information for the author of this newsletter:
======================================================

The original author of the above statement which was left at the NRC web site wishes to remain anonymous, but he can be contacted through Ace Hoffman.

SCE says San Onofre can be operated safely. Facts say otherwise.

SCE's plan to run San Onofre at 70% power for five months, submitted to the Nuclear Regulatory Commission last October, is based on faulty assumptions which defy logic.

And yet, incredulously, today SCE announced that they believe they could run Unit 2 at 100% power for 11 months without going over the 35% tube wear limit on ANY of the nearly 20,000 tubes inside the two "new" steam generators in Unit 2!

Some of those tubes inside those steam generators are already worn more than 20% of their thinner-than-a-dime thickness. None have been inspected with the most thorough equipment available, which can detect stress corrosion cracking, not just tube wall wear.

Yet SCE is sure that they can run Unit 2 without causing "high void fractions" in the steam/water mixture, and without causing excessive turbulence, which was about as bad as anything the industry had ever seen in Unit 2 as well as in Unit 3, which no one is about to try to claim can be restarted.

And presumably, SCE is claiming they could run at 100% power for 11 months without an unreasonable risk of another tube rupture like what happened January 31st, 2012, which shut down the two reactors.

However, SCE has yet to prove their case for restart, and these are just additional speculative claims to confuse and inappropriately reassure the public that restart is safe, and to prod the NRC into a favorable and inappropriate decision. San Onofre cannot be safely restarted. Period. It CAN'T be proven safe, because it's already been proven unsafe. Real-world experience and test results top the fanciest mathematical equations and computer software programs.

Despite this new announcement -- a "trial balloon" in the political sense -- SCE still plans to only run the Unit 2 reactor for 5 months at 70% power... but by doing this, they are obfuscating the dangers, making it sound like additional wear is the only problem, followed by a single tube rupture at some point if things go wrong. This is not the case. In fact, the main worry is that the wear that has occurred is more than they realize because their inspections are inadequate, coupled with concern that a main steam line break (coupled with the failure of an accompanying isolation valve to close) could lead to "fluid elastic instability" and a multiple-tube rupture, as illustrated in my animation available online here:

http://www.acehoffman.blogspot.com/2013/02/new-animation-shows-what-could-happen.html

Click the triangles in the upper left to go to various screens; and click on MSLB when a steam generator is on the screen to see the event I am referring to. It might only take a couple of seconds or minutes, and happens whether the reactor is SCRAMed successfully or not. The steam line breaks, the water in the steam generator almost instantly turns to steam, it rushes out the top of the steam generator, the u-tubes start fluttering, and .... they break away in clusters.

Last year, eight tubes ruptured during "MSLB" testing, three of those did so below the pressure differential that an actual main steam line break would incur. The requirements include a margin of error of about 180%, and the other 5 tubes failed that part of the test. Only about 1.5% of all the tubes were pressure tested -- the ones that were going to be taken out of service anyway because they were located in areas of highest wear and thus, it's presumed, the areas of highest heat and highest fluid velocities as well. (And highest void fractions.)

San Onofre has no answer for the problem indicated by those test results. However, lucky for them, the Nuclear Regulatory Commission has deemed a multi-tube rupture scenario "not credible" as stated at the last NRC hearing, February 12, 2013 at the Church of the God Loving Beach People. But under oath, with experts cross-examining the NRC's own experts or San Onofre's, I don't think they would be able to deny this is a real and reasonable possibility. Not only is it a possibility, but a main steam line break is probably about ten times more likely than a severe earthquake (one cause of a main steam line break might be an earthquake, but it's not the only possible cause. Rust is another.).

Experts not tied to the nuclear industry (anymore...) believe a cascading tube rupture scenario, such as that depicted by the main steam line break animation, is plausible.

And although it's not guaranteed to cause a meltdown all by itself -- there are a few backup systems that might still work -- it would bring SoCal frighteningly close to our own Fukushima. A main steam line break can produce sonic-level sound vibrations, inhibiting communication. The loss of numerous sensors and controls is very likely to accompany such an event. The operators in the control room might need some time to figure out what happened: They might not have that time. But what if they try to isolate the WRONG steam generator, for example? What if the break is inside the containment dome and the burst pressures are exceeded because, unknowingly or covered-up, the dome cut to insert the steam generators didn't go as well as they thought it had, like at Crystal River in Florida? The engineers thought they had closed that one up pretty good too, and then cracks developed...

If a meltdown occurs, the containment area may not be enterable, as in the case of Fukushima, for years or even decades or centuries. And, like at Fukushima, our children will be most affected, our crops, our land will be lost, and no one will compensate us for the loss. It will be no different for hundreds of thousands of people around the plant, maybe millions. And Fukushima wasn't even as bad as it could be, not by two orders of magnitude at least: The cores did not fully explode vaporize in a massive steam explosion, for instance.... at least, not yet. But all of multiple core's noble gasses were released, their full loads of cesium and strontium... and some plutonium and uranium, but the majority of the plutonium and uranium is still inside the reactor buildings somewhere, at this time. Things could have been a lot worse there, and could be a lot worse than that here.

And even if there is no main steam line break, there are still a multitude of other problems. First of all, and perhaps most importantly, SCE's plan for restart has always depended on FRICTION FORCES to prevent "in-plane" vibration of the tubes inside the steam generators. Vibration in other directions has always been taken care of by having supports that the tubes butt up against, and it was assumed by the nuclear industry that if you solve the out-of-plane vibration problems, you will also have solved any in-plane vibration problems.

However, San Onofre Unit 3 proved that "rule-of-thumb" to be incorrect. and the industry needs to amend its thinking.

Another Achilles' Heal of the industry is the waste problem. Not mentioning it (as SCE never does) doesn't make it go away. In fact nothing makes it go away. The federal government will continue to break its promise to remove the waste from near the reactor, because there is no place to put the waste -- no national repository -- and we are many decades away from having such a place, if ever. So the less waste that sits here on our coast, exposed and dangerous as it sits there, its containers rusting in the sea breeze, its contents in constant need of attention and protection (and inert gasses under pressure), the better. It all costs money for tens of thousands of years, and the more radioactive trash there is, the greater the cost, the larger the land that's needed to store it, and the greater the risk.

Let's hope the CPUC will stop wasting the ratepayer's money on the hopes of restarting a fault reactor based on a faulty premise -- on a fault line. Let's hope the NRC will flat-out refuse to allow SCE to restart. Let's hope SCE gives up this foolish plan. And, since hoping won't change anything, let's decommission San Onofre starting right now. It's the only way forward for society.

Ace Hoffman
Carlsbad, CA

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The following was left by an acquaintance of mine at the NRC Blog site today:
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Sincere Thanks to Mr. Victor Dricks, Mr. Cale Young, Mr. Ryan Lantz, Mr. Randy Hall and entire NRC Staff. Thanks to NRC posting this blog

As a part of San Onofre Public Awareness and SCE/MHI Lessons Learnt Series, Brilliant NRC Staff should summarize for the benefit of General Public an Unbiased Gap Analysis on San Onofre Degradation before Unit 2 restart based on the plant data and a review of following reports:
1. NRC AIT and follow up reports
2. SCE Root Cause Analysis Evaluations (Safety Short Cuts and Avoidance of 10 CFR 50.90)
3. Westinghouse Operational Assessment
4. AREVA Operational Assessment
5. MHI Root Cause Analysis & Technical Reports (Safety Short Cuts and Avoidance of 10 CFR 50.90)
6. SCE Enclosure 2 and Remaining Operational Assessments
7. Internationally Known Chartered Engineer and Nuclear Scientist John Large Technical ASLB Paper
8. Internationally Known Nuclear Engineer Arnie Gundersen's Technical Papers
9. Professor Daniel Hirsch's Report
10. Mitsubishi AVB Testing for San Onofre RSG Repairs
11. Dr. Pettigrew's and other research papers published between 2016 and 2011 on FEI & FIRV
12. SONGS Special Tube Inspections & Insider Reports
13. NUREG 1841- Comparison of CE Replacement Generators with San Onofre
14. SCE Response to NRR RAI's
15. Fluid Elastic Instability, AVB Contact Forces and risks of Design Bases Accidents at 70% reduced power, Accuracy of Thermal-Hydraulic Computer Modeling and Reliability of SCE Operator Actions
16. Analysis of San Onofre Units 2 & 3 Operational Data and its impact on Units 2 & 3 Cause Root Cause Evaluations and how it relates to Fluid Elastic Instability, Flow-induced Vibrations, Mitsubishi Flowering Effect and AVB Contact Forces
17. SCE's Compliance with NRC CAL and NRC Justification of SCE 10CFR 50.59 and Assurance to 8.4 Million Southern Californians based on Scientific Facts and Operating Experience

Thanks…. HAHN BABA

====================================================
Contact information for the author of this newsletter:

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Ace Hoffman
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Carlsbad, CA
Email: ace [at] acehoffman.org

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The flawed logic behind restarting San Onofre in light of Fukushima...

3/10/2013

As we approach the two-year anniversary of the Fukushima nuclear disaster (tomorrow, March 11, 2013), dozens of other nuclear commemorations now fill the year: Three Mile Island later this month, Chernobyl next month, Hiroshima/Nagaski in August, and then there's Bikini, the highly polluted Nevada Test Site, Sellafield, Mayak, Hanford... and North Korea again earlier this month (they've set off their 3rd nuclear device).

The list of incidents involving massive releases of nuclear materials from industrial and military sources grows longer every year.

After so many nuclear disasters, why is there STILL no public monitored radiation system in place, nor any public health surveys being done regularly, instead of "just" forecasted for the future? There's an unofficial history of misery, starting with the uranium miners, the bomb victims, the bomb test "downwinders," "Chernobyl heart" and "thyroid necklace" children, and now Fukushima thyroid cases abound... yet nobody counts.

So far, San Onofre doesn't belong on any list of major nuclear accidents. Let's keep it that way. However, they carted away more than 50 truckloads of tritium-laced beach soil after pulling apart the old Unit 1 reactor and finding it had been leaking who-knows-how-much for who-knows-how-long. Big surprise? Not really: Nuclear power plants leak like sieves. Tritium (a radioactive form of hydrogen) leaks have been reported at most nuclear power plants in the country (and probably went unreported at the rest, just as San Onofre's leaks had gone unreported (and supposedly undiscovered) for many years). The regulatory authorities rely on the utilities to provide the information -- there is no independent monitoring.

In fact, small daily releases and occasional larger "accidental" releases are normal operating procedure for all nuclear power plants. Permissible amounts are "As Low As Reasonably Achievable" ("ALARA") which is defined as what they can achieve and still operate, which is to say: still make a profit. It is not what is actually safe, since no amount is safe. The entire nuclear industry still calculates the hazards from any release based on a "reference man," a mythical being who is 100 or 1000 times less susceptible to radiation damage than a "reference fetus" would be, and somewhere in-between for a "reference child." A adult "reference woman" is also more susceptible to radiation's damaging effects, and not to mention, if she's pregnant, damage to her fetus and even her fetus's eggs! Instead of worrying about any of that, the nuclear industry uses the "lowest common denominator" to minimize their liability, in addition to minimizing it with the Price-Anderson Limited Liability Act, which has been copied all over the world, and which practically lets nuclear utilities get away scott-free after any accident. They might destroy their entire state, and leave hundreds of thousands of people homeless, and cause thousands of cancers over the coming years, and yet stay happily in business (and not go to jail)!

Southern California Edison and the rest of the nuclear industry refuse to face the reality of the situation they are creating (and then walking away from with their pockets full of their ratepayer's money). Radioactive waste is so hazardous, that it must remain isolated from human beings and all other living things for thousands of generations. How can this be done? No one knows how to do it or where to store it.

So, it just sits there on our coast. Ceramic pellets of fuel which have had a small fraction of their uranium atoms split. Those split atoms now comprise two (usually two) unstable fragments of the original atom's nucleus, each about half the size of the original atom's nucleus, and each with too many neutrons in its core. The two new elements are also destined to decay, usually again and again, perhaps a dozen times or more, changing what element they are and their chemical properties each time, and releasing an elementary particle or beam, such as an alpha or beta particle traveling near the speed of light, and/or a gamma ray or xray traveling AT the speed of light.

At San Onofre, approximately four million pounds of spent nuclear fuel sits on our coastline, waiting to be released in the event of an airplane accident, or even an asteroid. The asteroid which struck Russia recently could have breached these casks. It actually landed in one of Russia's most highly secretive nuclear sites.

We don't want a nuclear catastrophe in Southern California. California is the salad bowl, fruit bowl, nut bowl, and cheese plate to not only much of the United States, but even around the world. Our agriculture would be even bigger if there were more water available -- something nuclear power cannot help with. Nor can nuclear power help with global warming, because it uses vast amounts of fossil fuels to mine the uranium, process it, refine it, mill it, etc., and then more fossil fuel energy to actually build and run the plant, to build replacement parts for it and so forth. (And replacement parts for failed replacement parts, for that matter.)

And then, afterwards, that endless storage problem... does not happen for free. Even if we just consider the necessary security guards (and ignore the scientists working on better solutions, the steel and cement fabricators, etc.), the guards alone will need housing, transportation, weapons, instruction videos, training exercises... for, oh, 100,000 years! This will cost a considerable amount money, and burn a considerable amount of fossil fuel. (A closed nuclear power facility on the east coast estimated their costs for maintaining their spent fuel "farm" at about $10 million per year, ad nauseam.)

So nuclear power cannot possibly help solve the global warming problem in any way, and the smaller the pile of nuclear waste we leave our progeny, the better. It was true 30 to 40 years ago when most of today's obsolete and aging nuclear power plants were commissioned, and it's more true now.

And if all those reasons for not restarting San Onofre were not good enough -- which they most definitely are -- then its own problems, problems unique to San Onofre, should be good enough. San Onofre is not a good investment for society (or for SCE's stockholders).

Look at the facts: In 2004 the old steam generators (two per reactor) were showing significant wear and it was clear they were not going to last until the end of their current 20-year license periods, around 2022/2023. An ever-increasing number of tubes in the original steam generators would have to be plugged each time the reactors were shut down for refueling/maintenance. It was costing a fortune and the plant was delivering less and less steam-generated electricity. Tube wear was apparently accelerated after a 2001 power uprate. The additional energy in the system (increased flow rates, increased heat, etc.) increased the vibration and increased the rate of damage. Sort of like driving a rented car harder than you would your own.

Southern California Edison didn't need to worry about cost of replacing the steam generators earlier because of the increased wear rates because -- perhaps you've guessed it -- the ratepayers, and not SCE, would pay for the new steam generators. This was justified to the California Public Utilities Commission by claiming that, over the next 20 years, the steam generator replacement project would SAVE ratepayers a billion dollars over estimated costs of replacing San Onofre with fossil-fuel power plants. Cheap gas-fired modern turbines were never even considered ­ a properly operating San Onofre (i.e., not melted down, and not impaired by long-term shutdowns such as what has actually happened) was compared to old-style clunkers such as coal plants! Getting rid of San Onofre wasn't compared to wind power alternatives, or solar rooftops, or even plain-old conservation, which STILL offers the potential to completely "replace" San Onofre if properly undertaken. And it would be cheaper. And can't melt down.

The cost of the replacement steam generator project was projected by SCE at about 700 million dollars -- obviously, less than the amount that would supposedly be saved, making it a "cost-effective" replacement project for the ratepayers -- they said.

The CPUC bought the bait -- hook, line, and sinker: Why not? The head of the CPUC was the former head of SCE, and never met a nuclear power plant he didn't like. (He still heads the CPUC and still supports San Onofre in every way possible.)

Then, on January 31, 2012, a hole developed in one area of one of the 9,727 u-tubes in each of the two new replacement steam generators in each of the two operating reactors at San Onofre. Radiation leaked from the primary coolant loop to the secondary coolant loop, and was detected in the turbine building, from where it was vented to the public airspace. Small quantities of highly radioactive Nitrogen-14 and other "hot" elements were released and the reactor -- Unit 3 -- was shut down. The other functional reactor at the time, Unit 2, was already shut down for scheduled maintenance and a reactor pressure vessel head replacement.

(The new RPVH was one of the many smaller jobs which Edison originally had planned to ask for ratepayer funding for along with the steam generator replacement project. However, when the price climbed to around a billion dollars and opposition grew, they dropped the rate hike request by several hundred million dollars and delayed everything except the steam generator replacement, which answered the most vocal activists' claims, who had tried to get the project stopped or delayed based solely on the actual cost of the replacement project alone, instead of looking at the big picture (the spent fuel problem, potential for accidents, etc.). SCE was allowed to charge the ratepayers the reduced total, and move forward with the project.)

Now what? SoCal Edison has effectively given up on Unit 3 due to excessive damage that has already occurred. It can probably be assumed Unit 3 won't reopen unless they replace the steam generators, which they probably don't have the money for -- unless it can be billed to ratepayers, who are complaining vociferously against any mention of it right now. That's good, but as before: Is it enough?

Unit 2 on the other hand, might be different. Edison believes Unit 2 can be restarted safely at reduced power output and efficiency. Such thinking is faulty, but nevertheless, Edison applied to the Nuclear Regulatory Commission in October of last year for permission to restart Unit 2 at 70% power output, to see if their theory of what caused the two different types of vibrations in Unit 3 are correct. Everyone admits the shortened time period is an experiment: They'll shut the reactor down afterwards and see how much wear actually occurred. The media refer to it as a test, SCE union workers refer to it as a test, everyone refers to it as a test.

But if you say to the NRC, "DON'T EXPERIMENT WITH THE SAFETY OF 8.7 MILLION PEOPLE!" they get all huffy and offended, and say they WON'T experiment with the safety of 8.7 million people, even though that's exactly what they'll be doing if they allow the restart of that faulty reactor.

San Onofre's Unit 2 steam generators are faulty because they were designed without proper engineering review. Without "critical thinking" or "independent analysis."

In other words, shoddy workmanship and deficient management.

Now, SCE is trying desperately to put all the blame for the failure on Mitsubishi Heavy Industries (the manufacturers of the replacement steam generators), and it's true: MHI made a lot of mistakes. But SCE was responsible for MHI's actions at every stage, according to NRC regulations!

San Onofre is filled with subcontractors and sub-sub-contractors. A few years ago SCE released Bechtel as the main subcontractor and brought in The Shaw Group instead (known to be the smoothest talkers with the best lawyers in the industry. Perhaps SCE had an inkling of the problems they would be facing?). About 40% of the onsite employees at San Onofre are SCE workers, the rest are sub-contractors of some sort or other. Even SCE is, effectively, a subcontractor of [San Diego] Gas & Electric (SDG&E), which does nothing at the plant, yet owns 20% of it, and the city of Riverside, which owns less than 2% and also is not involved in operating the plant.

So who's responsible?

Federal regulations state, NRC commissioners state, and even Southern California Edison itself from time to time states that SCE is responsible for the actions of their contractors, including fabricators of parts, security forces (always subcontracted at every nuclear power facility), soda deliverers, etc.. Everyone.

MHI failed to calculate adequate clearances between tubes in the u-bend region -- some are only a 20th of an inch apart (industry standard is nearly half an inch apart).

MHI failed to calculate the flow rates of the mixture of steam and water as it rises up through the u-tubes: It was too fast, averaging around 28 or 29 feet per second in Unit 3, somewhat slower in Unit 2. (And traveling at double that speed around some of the inner u-tubes.)

MHI failed to properly calculate the circulation ratio of water that falls down from the top of the steam generator where they "dry" the steam and returns for a second (or third...) loop. The circulation ratio should have been well above 3, but it wasn't.

MHI failed to properly calculate the fraction of water-to-steam in the upper portion of the u-tube bundles. They expected the tops of the u-tubes to still have significant amounts of water surrounding them, which provides damping against vibration. Steam is 30 times less dense than water, and so, less able to dampen vibration.

MHI failed to account for the extreme dry-out conditions of the steam, which caused the outer surfaces of the u-tubes to lose the thin layer of water that normally coats them. This thin water layer aids in efficiently transferring heat from the inside of the tubes to the outside, to be carried away from the reactor. Thus, the heat stayed in the tubes longer, and was released later, on the downward, "cold" leg of the steam generator's u-tubes. This created unexpected additional flow in the cold side, additional u-bend flowering effect, additional turbulence in the upper areas of the u-tubes, and additional wear and tear.

MHI failed to perform proper cross-checks of their mathematical models for the above behaviors of the steam generators.

MHI repeatedly reassured SCE that the steam generators were being well-designed and well-manufactured.

MHI warranted their work for the cost of manufacture only, NOT for the cost of replacement power during an outage, NOT for the cost of a meltdown from a catastrophic cascade of tube failures, NOT for the loss of the entire reactor due to faulty steam generator design. JUST for part of the replacement costs of the four steam generators themselves (about $138 million dollars appears to be the maximum recoverable, with about $50 million of that already paid by MHI to SCE).

So is MHI the only entity at fault?

Not by a long shot! SCE was supposedly overseeing the whole operation, and made repeated visits to the Kobe and other MHI factories (and their subcontractors) in Japan, and approved all of MHI's work. In the NRC's own Augmented Inspection Team report (summer, 2012), it states that the possibility of manufacturing defects (which are blamed (or perhaps I should say "credited") for some of the differences in behavior between Units 2 and 3) are not considered in the NRC's assumptions -- that is, the NRC assumes that parts supplied to nuclear reactor operators have been built to design specifications. Now, small differences in manufacturing methods are being blamed for differences in wear between Unit 2 and Unit 3: Namely, the "3 mil gap" between the u-tubes and the tube support plates is more round and tighter-fitting in Unit 3, which led to less water getting through and more wear in Unit 3, they think (but nobody really knows).

The NRC has stated time and again that nuclear power plant operators are responsible for the quality of work of their subcontractors, and MHI was a subcontractor of SCE.

SCE is irresponsible to be saying they were "reassured repeatedly" that MHI's designs were adequate. So what if they we were reassured a thousand times? One might also ask why repeated reassurances were needed! SCE should have done their OWN calculations to determine the adequacy of the new design. They should have opened up those new designs to NRC and public scrutiny so other experts could have reviewed them. SCE's steam generator engineers signed off on the design before construction -- they "put their 'chop' on it," which makes it "legal" in California!

Of course, the NRC is hardly blameless. It is their responsibility to ENSURE that public safety is maintained at nuclear power plants regardless of the cause. To merely mention "safety" at a public hearing other than the NRC is to risk being reminded that "safety" is the authority of the NRC. (Just as, to mention "cost" at an NRC hearing will get you told they don't regulate based on cost, which is utterly untrue.)

The MHI document released by the NRC last Friday makes it clear that avoiding a thorough review of the design changes was one of the requirements SCE gave to MHI for the steam generators. SCE is actually proud of this attempt (successful, so far) at avoidance: Their spokesperson said Friday after the MHI report came out that "triggering" the NRC review process is something nuclear power plant operators are SUPPOSED to try to avoid, because it adds to the expense of making changes safely! Of all the double-talk I've ever heard, that's Orwellian for sure!

SCE and MHI also wrote serious articles in nuclear trade journals "bragging" about how wonderful "their" replacement steam generators were, which were published just about the time the generators failed. And MHI planned to substantially increase their nuclear parts supply business, and is still hoping to do so, somehow. They might even get SCE's business for a third set of steam generators!

Go figure.

Now, SCE wants very badly to restart Unit 2. It took them the better part of a year before they even felt confident enough to go to the NRC to ask for permission to restart at a lowered output level for a five-month period -- the "experiment" that's not an "experiment." It may take the NRC the better part of a year to respond back to SCE, and they've asked some tough additional questions, such as in a December 26, 2012 letter to the Chief Nuclear Officer of SCE, Pete Dietrich, stating that SCE needs to show that the Unit 2 reactor can be safely run at 100% power, not just at 70%. But then again, the NRC might give SCE restart approval next month (April, 2013).

SCE dug into their deep supply of lawyers to respond to the December 26 letter, and told the NRC that the NRC doesn't know how to read their own regulations, and "70% power" is the new "100% power," and so the regulations should allow them to restart, without having to prove they could do so safely at the previous "normal" power output level!

And of course, SCE promises not to turn up the dial past 70%. Swears they won't. But they also squeezed in a comment, in responding to the NRC's letter, that not raising the power level above 70% becomes their choice, not the NRC's, after the five months is up!

And SCE doesn't even promise to do 170,000 inspections like they say they did last time, they only promised to "take a look and see what we find." 170,000 inspections on nearly 40,000 tubes isn't as many per tube as all that: Just over 4 per tube. This is a crucial point: All the original inspections were inadequate: It was only after Unit 3 sprung a leak that Unit 2 was determined to also have very significant wear that prevents it from operating too. Even the post-shutdown tube inspections continue to be inadequate: SCE is NOT using the latest available inspection equipment, they are using cheaper alternatives that return less accurate data.

And on top of all that, the data they are collecting -- the inaccurate data from the cheaper inspection equipment -- is being used to estimate that NOT ONE TUBE will go out of compliance with NRC regulations (35% wear rate) during the five-month test-that's-not-a-test. Some of the tubes that have not been plugged are worn more than 20% already, so it's not even a game of inches -- it's a game -- a gamble -- of small fractions of a millimeter. One tube in Unit 2 was 90% worn -- and this was only found after the other reactor failed and a "closer" (more thorough) inspection was done! There was less than 1/200th of an inch protecting us from a tube rupture in Unit 2 -- the Unit they want to restart -- and they didn't even know it. An additional worry: The inspection system they are using does not examine the insides of the tubing for fatigue cracks (as apposed to "fretting" and other wear on the outside of the tubes that thins the walls substantially) like the state-of-the-art inspection equipment does.

Why isn't Edison using the state-of-the-art inspection equipment? Perhaps because if they "find" too much damage then the steam generator will be unusable since its plugging limitation will be exceeded. You can't see what you don't look for.

Southern California Edison expects the NRC to give it permission to restart San Onofre some time in late April, for operating at 70% power output for five months. During that five months there will be no way to know ahead of time if a rupture is eminent. If the reactor tubes survive the test, and if upon inspection after shutdown, the wear rates are significantly reduced, they will try to operate for longer, at higher heat flows to the turbines, and then inspect, and plug, and inspect, and plug, until the NRC's plugging limit for one of the steam generators is reached. When this happens SCE will try to smooth-talk the CPUC that all this is just part of doing business and the ratepayers need to pay for all-new steam generators a third time, at an additional cost of probably well over a billion dollars.

Meanwhile, alternatives such as wind, wave, solar, etc. have already made the whole idea of nuclear power obsolete. But SCE won't endorse change if it would mean they are not the ones "generating" the electricity, since they want to keep their energy monopoly. As it is now, SCE pays themselves far more for the solar energy they generate than they do for the solar energy "we" generate and put into the grid, which is great for their shareholders, but a rip-off for ratepayers who should get safe energy for the lowest possible price.

We need to decommission San Onofre NOW. We must not allow restart "TESTING" of San Onofre's faulty steam generators at the risk of the health and safety of the 8.7 million people living within 50 miles of the plant, and the tens of millions more who live just a few minutes further away as the wind blows.

Ace Hoffman
Carlsbad, CA

The author has been studying the failures of nuclear power for more than 40 years. It's not getting any better. www.acehoffman.org .

(A cartoon found on FB; artist unknown)