Shocking letter from 2004 shows SoCalEd was concerned all along about ... profits!

If I ever actually hear that San Onofre Nuclear [Waste] Generating Station is being decommissioned, I'll start to believe that we'll soon be left with only the spent nuclear fuel problem to deal with.

I haven't heard anything like that, but we definitely got one step closer to decommissioning today. Senator Barbara Boxer was calling SoCal Edison's statements "gobbledygook." Dave Freeman, former head of the federal Tennessee Valley Authority and senior advisor to Friends of the Earth says: "The San Onofre restart plan is now deader than a doornail. It's over." Damon Moglen, climate and energy director for FOE says: "The restart of San Onofre reactors is now off the table."

I hope the FOE experts are right, but nobody can be sure until the decommissioning begins, and even if they are right, we still have a pile of deadly nuclear waste to deal with. It's "just" not getting any bigger right now and if there's no restart, it won't get any bigger ever again. Also, as it ages, the spent nuclear fuel becomes somewhat easier to handle, although it will remain very difficult and dangerous to deal with for hundreds of thousands of years.

SoCalEdison had always planned to walk away from the problem of what to do with the waste. It was always just a question of when they would walk away from the mess they had made.

It's still possible that somewhere at SCE, some Vice President is writing a letter just like the one uncovered today from November 30th, 2004, which clearly says the steam generators are obviously not going to be "like-for-like." It also clearly states that performance is as critical as timing -- the replacement steam generators were expected to perform at 106% of their original reactor thermal power capabilities, which they are now licensed for. The letter also makes it clear that the RSGs must be designed and delivered on time. To do so, a lot of corners were cut.

Without decommissioning, "no restart" appears to mean "no restart unless the steam generators are rebuilt." That is approximately a five-year process that may or may not have even begun, but if it has begun, it could not have gotten very far, in part because the design of steam generators for pressurized water reactors with only two steam generators is very difficult -- it seriously is! Three steam generators, or four, is a much more common and workable arrangement. They didn't even get close to getting San Onofre's unique steam generators designed right the first time, or the second, and unit three is trashed, and unit two is seriously damaged, but not as seriously as unit three is. (Unit 1 has already been decommissioned.)

All the recent government actions against SCE will amount to nothing but a few years' delay (at most) without decommissioning. Without decommissioning, the plant is expected to reopen eventually. But, under current federal law, if San Onofre is "decommissioned" (which means dismantled), then its license is abandoned.

Currently, San Onofre Unit two can be restarted in a matter of days, if permission is granted by the NRC. The uranium-235 enriched fuel is fully loaded, the coolant loops have been sealed and resealed, and pressure tested and retested. Control room operators are ready to withdraw the control rods and resume operation.

It may sound like we're close to a breakthrough because a letter was made public from nearly ten years ago, from a guy who resigned eight years ago and has "no comment" now when reporters asked. And it's good to hear a Senator condemn SCE's apparent utter disregard for the safety and welfare of the 8.7 million citizens who live within 50 miles of the plant, and the tens of millions more who live just beyond that artificial marker. But I don't hear Ted Craver saying "we are starting the decommissioning process of both units, effective immediately."

To have SanO finally decommssioned would mean we would still have to figure out what to do with the waste that was already created, which is no easy task. But pretending that the waste problem can wait has been our biggest mistake so far.

Meanwhile, the engineering quicksand continues to drag Edison under. One of their main reasons for assuring the public that Unit 2 is different from Unit 3, and that because of those differences Unit 2 won't suffer from fluid elastic instability like Unit 3 did, is the claim that Unit 2 has twice the contact forces of Unit 3 in the u-bend region where the steam generator tubes are butted up against the anti-vibration-bars. The problem with that claim is that industry experts -- hired by SCE -- have stated that 10 to 30 times the contact force is necessary, not just double. How many nails does SanO's coffin need?

Decommission San Onofre NOW. Green jobs for all.

Ace Hoffman
Carlsbad, CA

The 2004 letter:

http://www.epw.senate.gov/public/index.cfm?FuseAction=Files.View&FileStore_id=ccfadddd-50a3-4947-8a49-45e54e9dd2a4

Preparing the dry cask storage site at San Onofre.

============================================

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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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Edison's sneaky plan to restart San Onofre Unit 2... and then Unit 3...

As of today, Southern California Edison still has every intention of restarting San Onofre Nuclear "Waste" Generating Station. Nothing has changed that desire. It seems they will take any risk in order to restart the reactor, and even having to pay for this entire steam generator fiasco from their own pockets won't stop them (though that appears unlikely).

A fully adjudicated license amendment proceeding with sworn testimony, expert witnesses, and cross-examination won't stop them. Even if it takes five years, they'll wait -- even if it takes ten. All these delaying tactics are aimed at either the inevitable -- decommissioning -- or the impossible -- continuous operation ad infinitum. If it re-opens, it will be impossible to keep it open forever, since the entire plant has degraded, sitting by the sea decade after decade. There will be other problems, there will be license renewal procedures, there will be other major parts replaced. There will inevitably be more emergency shut-downs after something "unexpected" goes wrong. But they want to restart it anyway.

San Onofre's spent fuel storage plans are to just keep growing the dry cask farm. That's it -- that's their whole plan. To leave the most dangerous material on earth -- spent nuclear fuel rods -- in the most dangerous location on earth (in a mega-earthquake and mega-tsunami zone).

Here is a perfect place to stop the spiral of madness, and cease risking disaster and piling up waste. But instead, all we get are delays. The Nuclear Regulatory Commission has all but said there will be no restart again this summer, but at the same time "okay to restart" seems to always be on the tip of their tongue. Why?

Is it really because some mathematical calculation of the flow rate of the fluid across the U-tubes suggests a maximum of 22 to 35 feet per second (even though it might really be 50)? It's not like it has been measured and verified, only calculated from numerous approximated factors. But supposedly it's the technical crux of the problem, or at least one of the technical cruxes. But is the real problem an inherent push to restart? Yes.

Edison CEO Ted Craver made no promises that they would decommission SanO at the end of the year if the NRC didn't approve a restart: He only said it was a possibility. Nuclear war tomorrow is a possibility too. So is sunshine.

It was clear at the California Public Utilities Commission's hearing last week (which included fully adjudicated sworn testimony with expert witnesses and cross-examination, but very little sunshine) that SoCalEdison is ready to restart Unit 2 virtually tomorrow. Nuclear fuel has been fully loaded into the reactor, the reactor pressure vessel is bolted down tight, the pumps and control mechanisms have all been tested... and their calculations say it'll work.

They just need the NRC's permission.

Last week, during the CPUC's investigation into the San Onofre outage, SCE officials made it clear that they are still going full-tilt towards restart, even if it takes five years and requires replacing all four steam generators. They are doing this with public money and no shame. They have never for an instant planned to do anything else.

The reason?

It's because they have transmission lines capable of carrying 2,340 megawatts of pure gold -- profit -- which would be rendered virtually useless if SanO is not restarted.

San Onofre itself isn't especially valuable comparatively - its two licensed units are already 30 years old, and Unit 1 has been demolished (its spent fuel remains on site). It would cost close to $20 billion each to replace San Onofre's aging reactors with new units, and the opposition would be powerful against such an idea, including the economists. Ratepayers would be furious. Even before the leak that shut Unit 3 and prevented the restart of Unit 2 (so far), Edison would have had a tough time selling San Onofre to anyone. Even Michael Peevey says now, no one would buy it. Mr. Peevey would buy it out of our own pocket if he could.

But the transmission lines? Those are very valuable, not only for their transmission capabilities but also as land rights-of-way. SCE would NEVER want to sell those -- as long as there's something to feed them: Massive generators at their starting terminus. Solar rooftops are of no help to SCE in maintaining the value of those transmission lines.

Unit 3 rattled itself to death a year ago last January but is believed (by some) to be repairable eventually, and Unit 2 nearly did the same, but they operated Unit 2 at a higher pressure and lower reactor coolant flow rate than Unit 3. Consequently, Unit 3 fell apart, but Unit 2 maybe didn't, at least not as much.

At the top of the U-tubes, where the "U" is, Unit 2 had more water mixed in with the steam than Unit 3, and lower fluid velocities, and thus, less vibration. A mixture of other operating conditions were slightly different between the two units, and the proposed steps to "fix" the problem asserts that the planned operating regime ensures that Unit 2 will not be operated at anything like the conditions that Unit 3 was operated at.

There are numerous problems with this approach. First of all, there is the "Main Steam Line Break" accident scenario, in which the piping from one of the steam generators breaks off for some reason (perhaps an earthquake), This causes a sudden and complete drop in pressure inside the steam generators (but outside the U-tubes). This, in turn, causes essentially the same conditions that existed in Unit 3 which shook it apart, known as Fluid Elastic Instability. The tubes rock back and forth in unison, and the vibrations continue -- and accelerate -- until the tubes hit something or break off.

But that's not the only worry with Unit 2. Additionally, the vibration damage is already quite extensive, as indicated by the wear amounts of each tube. But the tubes aren't just damaged from wear. Wear from one part rubbing against another part is visible, detectable, and measurable. (When they saw all the wear in Unit 2 after its January 9th, 2012 shutdown, one has to ask why then didn't immediately shut down Unit 3.) The steam generator U-tubes in Unit 2 are also damaged from fatigue. Fatigue wear is much harder to detect than thinned tube walls resulting from the tubes rubbing against other tubes and against support structures. Fatigue can cause circumferential cracks to form at "hinge points" such as the topmost Tube Support Plate (TSP), which takes the most lateral forces from the tubes, especially during in-plane fluid elastic instability.

The early stages of fatigue damage can be very difficult to detect. Perhaps more troublesome is that a microscopic, virtually undetectable crack can blossom circumferentially, completely severing a ruptured tube in fractions of a second. The fluttering from FEI might coincide with both a main steam line break and an earthquake or aftershock. All three might put force on the tube at once, but Edison has not included FEI in its calculations of tube stresses that might occur during the five-month "test" of San Onofre at 70% power. It's just one of many things that don't add up. Perhaps it's one of the reasons the NRC hasn't let SCE restart SanO yet, but we'll probably never know, because so much information is "redacted" as "proprietary."

Another Edison claim is that the "anti-vibration bars" at the top of the U-tubes in Unit 2 have double the contact force of the AVBs in Unit 3, and this both prevented FEI and will continue to prevent FEI from occurring in the future. There are several problems with this claim, the first one being, that such a contact force MAY be good at stalling or preventing FEI for a while, but once it is overcome (and it can be if the forces are significant enough (such as during a main steam line break)) it's not nearly enough contact force to stop FEI from running wild. That would require contact forces 30 times greater than what Unit 3 had, and 15 times greater than what Unit 2 has.

In fact, that's how much contact force Mitsubishi's proposed "long-term fix" that was announced last week has -- 30 Newtons of contact force instead of one or two. The problem is, those extra AVBs (at the 45 and 135 degree angles) will only be for SOME of the tubes, but in a main steam line break accident condition, ALL of the tubes may be experiencing fluid elastic instability, even the damaged tubes that have been taken out of service.

There are more extensive fixes to San Onofre's steam generators that can be applied, but those fixes require completely rebuilding the steam generators, which will take five years and surely will require an open public licensing amendment proceeding. Edison is willing to take the time and wait it out. They own two licensed reactors. They have transmission lines that need to be fed in order to make a profit. Solar power rooftops can replace the power from San Onofre, but they cannot replace the profit.

At some point, Mitsubishi will probably announce that they are willing to pay all or most of the design and manufacturing costs for the replacement steam generators. It's just a business decision, having nothing to do with making SoCal ratepayers happy, but it will make the CPUC jump for joy. They'll do it because their reputation as steam generator manufacturers is at stake. They sold us very poorly designed units! The announcement of free replacements will probably come just when the activists are almost winning on monetary grounds at the CPUC, if that ever happens. MHI (or a subcontractor) may already have started fabricating them, somewhere in Japan.

While waiting for these new steam generators to be built and delivered, naturally, Edison wants to run the plant and just hope they don't have any big problems like a main steam line break. Running the plant is impossible with Unit 3 because of damage that has already been incurred, but is that true of Unit 2, too? For more than a year Edison has claimed to be on the cusp of proving Unit 2's extensive and unprecedented damage is controllable, and that's the key word. Tube wear will continue under ANY restart plan, but not so fast at 70% power output as at 100% power output. After five months they'll shut the reactor down and take a look. If their predictions are correct, they plan to add new anti-vibration bars at 45 degrees and 135 degrees and try again. My guess is that second "test" will also be for only a few months (perhaps seven or ten), and at a slightly higher power level. Edison has already been asking for the right to turn up the dial as much as they want after the first test run at 70%, if things look alright. They don't want to have to come back to the NRC to ask for permission to add more power after each test run.

But from an engineering point of view, so what if the test works? Surviving operating conditions does NOT prove that Unit 2's damaged and defective steam generator tubes can survive transient events.

At some point, SCE plans to run Unit 2 at 100% until the new steam generators are manufactured and ready to be installed. Probably nothing can completely arrest the wear at operating conditions, so any fix is temporary. Unit 3 cannot be restarted without steam generator replacement because of the amount of wear and the numbers of tubes that are worn. However, SCE has no intention of closing the plant and doesn't care what it costs the ratepayers during the extended outage.

That is why, if we don't want there to be a catastrophic accident, we need to demand immediate decommissioning of San Onofre Nuclear Waste Generating Station. Decommission means dismantle. It means make restart impossible. It means take away SCE's license to operate a nuclear power plant.

Decommission now. Solar and wind power forever.

Now is the time for southern California to switch to safe solar power!

Ace Hoffman
Carlsbad, California

A week at the California Public Utilities Commission investigation into San Onofre's steam generator failures...

May 19th, 2013

Dear Readers,

Last week, the fight against San Onofre took a significant, if obscure, legal step forward at the state level. Witnesses were sworn in and testimony was taken for the California Public Utilities Commission's investigation (known as an "OII") into the failure of San Onofre's replacement steam generator project.

The first day, the proceedings were not webcast. One of the people in the audience had set up a camera but was told to put away his equipment. He argued a bit and then complied, but while in his seat again (instead of at the back of the room), the state police (not the city police) came and quietly spoke to him. I learned later that they asked him to go outside and talk to them. He asked, were they making a request, or giving him a legal order? They said they were making a request. The audience member declined to accompany them, saying he was busy listening to the proceeding.

At that point, I felt an enormous amount of pressure to turn off the audio recorder I was secretly using myself (someone had cajoled me into turning it on), since I was sitting almost directly behind where the would-be cameraman was sitting!

Just kidding, of course.

In reality, I was too scared to turn it off at that point.

Shortly thereafter, however, pressure from the public caused the CPUC to record the rest of the event and webcast it. Power (and information) to the people! The room was much less full after that.

The only conversation that was allowed was between those seated at the two rows of tables in the front and the judges or commissioner. When someone is on the witness stand, and when allowed, the people at the front tables talk with the witness, and ask them questions.

On the left side of the room (from the audience's perspective) were more than half a dozen groups of activists and "advocates," some with two people at the table, some with one. TURN, A4NR, CDSO, WEM, WBA, the DRA (Division of Ratepayer Advocates) and someone representing "interested parties" were all present. All did a splendid job. The advocates, as they were called, sometimes put different people at the table and changed positions now and then.

On the right was one person from SDG&E and four lawyers from SCE and their law firms. For most of the proceeding, only the head SCE lawyer, Henry Weisman, spoke for that side.

Facing the tables were two Administrative Law Judges (ALJs) and a commissioner the first day, but the commissioner left after that. Hopefully he watched the proceedings on the Internet. The witness stand was empty at first, then occupied one by one with a variety of people, mostly from SCE.

I spoke out from the audience once, which you're not supposed to do, but they had to admit I had a good reason. I complained that the lawyer for SCE was not using his microphone properly and could barely be heard. That was Thursday, as I recall, your honor.

You could only officially address the judges. Attorneys for the "advocates" could not talk directly to the attorneys for SCE and SDG&E, and the audience could not speak at all.

All communications must be with the judge, except after the judge swears in a witness. Then, the lawyer or advocate sponsoring that witness asks the witness to affirm that the exhibits they are associated with in the proceedings are in fact accurate to the best of their knowledge. Then they turn over the witness to be "cross-examined." Then there is usually some rebuttal testimony, but not very much. Sometimes rebuttal testimony is preceded by one of the judges asking additional questions after the advocates are finished with theirs.

It seemed to me that the advocates had an overwhelming case against SCE and SDG&E. Time and again our arguments were objected to by the SCE lead lawyer, and time and again the objection was sustained -- but many other objections were overruled (meaning the witness had to answer the question) or questions were not objected to at all.

Every so often, someone would have to search for a document, and one of the judges would declare the hearing to be "off the record" for a moment. This would give the court reporters a little break, from maybe 10 seconds to a couple of minutes. The court reporters would rotate through several in the pool, usually changing during a break. There were two short breaks and a long lunch break each day.

Everyone tried to get the job completed in a week. No one wanted to be accused of forcing everyone to stay longer, in the most friendly city in the world with the biggest variety of the best food, dozens of museums and other attractions, and a million other things to do. The reason why we should all try to wrap it up in a week was purportedly to save the ratepayer money, since rooms were quoted during the hearing (by someone from SCE, "off the record") as costing $400 per night, and I guess SCE was planning to bill the ratepayers.

My room was free since I stayed with a friend. Sometimes I had to pay for parking. I'm supposed to submit a record of the hours I spent working on the case as an "expert," having worked with several of the groups. A line of questioning by one of the advocates was based on my suggestions, which in turn, were mainly based on the "DAB Safety Team" reports and the documents those reports are based on.

The courtroom "drama" comprised about a dozen witnesses, mostly from SCE, who testified to the extremely complex financial arrangements of the company. Deeper and deeper into the rabbit hole we crawled. I tweeted perhaps 40 times during the week, mostly the first couple of days. The rest of the time I sketched various people in the room, mostly witnesses, on my smartphone.

A foundation was being laid for later phases of the investigation, and the basic question of this phase, "who should pick up the tab for the money spent in 2012?" was clearly being shown to be: "Not the ratepayer." That only leaves SCE, SDG&E, and their shareholders, minus whatever can be gotten out of Mitsubishi Heavy Industries, who was not represented in the room.

MHI's liability is apparently limited to about $160 million dollars, a pittance compared to the tens of billions that will be lost in "guaranteed" income to Edison if San Onofre is shut down permanently, and a small fraction of the billions that was lost already due to the failure of the new components. At sums like these, the hotel costs of an extra week of hearings seems trivial to this writer, but so be it. Everyone stayed late the last day, everyone who was allowed to speak had spoken, and all agreed that we were done.

Some of SCE's witnesses were notoriously difficult to pin down on anything. Mr. Perez was a master at evasive answers; it took two days to get through him. "I don't know" was the most common response to a question to him, other than hearing an objection from SCE's lead attorney.

However, a different witness, Mr. Palmisano, Vice-President of Nuclear Engineering at SoCalEdison, was much more cooperative. He didn't give ground: He believes the plant can be safely restarted. But he spoke the truth as he saw it, and that was much appreciated and admired by all. Mr. Palmisano was also willing to try to explain the engineering basis for his opinions. His testimony was very refreshing, especially in comparison to those who came before and after him. However, when trying to understand the exact engineering principles, one eventually gets to a point where the necessary numbers are "redacted" in the testimony. This became a bit of an issue when an unredacted version of a document, from a popular web site on the Internet, was presented. As far as I know the unredacted version was not allowed to be admitted as evidence.

Later, another witness was cornered into admitting that YES, a Fukushima type of accident (in terms of the consequences, if not the exact events) could happen here. This seemed like a key moment, along with when the same witness, who was in charge of various features of SCE's outreach to the community, and their evacuation planning and so forth, did not know what major cities are inside the various radiation ingestion zones around the plant.

There aren't expected to be any rulings in this case for a long time, perhaps years. There are three more "phases" of the CPUC investigation, and aspects such as whether or not SCE committed fraud in any of their claims about the steam generators isn't scheduled to come up until phase three, possibly in 2014.

It was a grueling week, but I believe at the end, the advocates had presented a strong case for not restarting San Onofre: It's too risky, it's not economical, and its energy is replaceable with clean energy alternatives. Ratepayers should not be charged for this fiasco.

Meanwhile, however, Edison announced a possible "long-term fix" for running Unit Two at 100% power again for an additional 40 years -- assuming their "test" (running for five months at 70% power) works out as planned. The long-term plan involves adding more "anti-vibration bars" which they say will provide about 15 times more force against certain types of vibration such as "random vibration." Will the plan work?

It might reduce the vibration significantly. But, because the flow rates are not being changed much, it probably won't actually stop the vibration completely. Nor will it stop the forces on the tubes themselves that caused the vibration in the first place, but it could put those forces against microscopic cracks that might have already formed.

So it might work, but I wouldn't bet the farm.

Ted Craver and Pete Dietrich, however (neither of whom were called at the hearing) would bet YOUR farm, though!

Sincerely,

Ace Hoffman
Carlsbad, CA

Drawings by Ace Hoffman on a Samsung Note II

Southern California Edison pleads hardship to the NRC, but plea is really a rush to restart...

Nuclear power used to be a status symbol. It used to imply: "This country is civilized. It is at peace with its neighbors. It is friendly and efficient. It is clean -- it reduces fossil fuel use!".

It was all hogwash, but that's the tarnished thinking that got the U.S. and 30 other countries into this mess, with no way out. Keeping going is just plain stupid, but that's what we've been doing so far.

When "the bomb" and nuclear power plants were first being built, tens of thousands of scientists signed petitions and letters opposing these plans. A number of prominent scientists in the innermost circle opposed the bomb's use right from the start. They tried to send a letter to President Harry Truman, stopping its use on civilians, but the letter was blocked. They probably tried to have Japanese diplomats or at least captured prisoners brought in to witness the "test" in Alamogordo, New Mexico, along with lots of allied reporters (instead of just a very select few) so they could tell their fellow citizens back home what was coming. So everyone knew the consequences of not stopping the war, without actually having to experience them.

Instead the bomb was used, and in their shame, the "Atoms for Peace" program brought forth a new use of nuclear power, for supposedly peaceful purposes, but in reality, many of the times, for making materials for bombs.

Originally built in the 1960s, San Onofre was a symbol of the peaceful use of the atom and originally was a demonstration plant for a new reactor technology called a "Pressurized Water Reactor" ("PWR"). Tens of thousands of protestors tried to stop it -- and many were arrested in peaceful demonstrations -- but to no avail. San Onofre Unit 1 was shut down permanently in 1992 by the utility company because its steam generator tubes were failing. It's time (past time) to permanently close the remaining two reactors, which were built in the early 1980s and are rusted out everywhere.

Now, as before, it is the most knowledgeable of the experts who are opposing nuclear power, and San Onofre's restart in particular.

Now, San Onofre is a symbol of the failure of the same technology that failed at San Onofre in Units 1, 2, and 3 already once before. It's not the same as what failed in Fukushima, which are the older style Boiling Water Reactors. Pressurized Water Reactors have more parts -- an entire extra coolant loop -- than a BWR, and that extra loop operates at much higher pressure. The "extra parts" are the steam generators, which transfer the heat from the primary loop to the secondary loop. So in essence, you have everything that could go wrong in a BWR, PLUS the steam generators. No wonder the only "lesson learned" from Fukushima is that you need bigger vents! There are no safe reactors. It's an engineering fallacy to think there are, or could be.

At San Onofre, both steam generators have thousands of damaged tubes, hundreds of which have been plugged and/or staked, but hundreds more have not been. An unknown number have unknown amounts of fatigue damage, in addition to rubbing wear. Rubbing wear had reached 90% through-wall on one tube in unit 2 and 100% in unit 3. Had Unit 2 been restarted, it would have failed within a month or two. What if both units had failed on the same day, because of a station black out or earthquake? What if the tubes had cascaded into each other? What if the guesstimate of dangers is wrong because it's based on a "reference man" not an infant or at least a child? What if the relative danger is off by an order of magnitude (in other words, what if it's 10 times worse than the official government estimate)? What if it's even worse than that?

San Onofre is a liability to the people of SoCal, and needs to be shut down. The NRC needs to be told by May 16th, 2013 that we don't want them risking Southern California. If we fail to convince the NRC to forbid SCE from restarting the plant, San Onofre Unit 2 could be restarted any time after June 16 (according to the latest schedule), a month after the May 16th deadline for public comment to the NRC.

If the NRC gives permission, and they're clearly heading in that direction, then after June 16th, 2013, SCE can and undoubtedly WILL restart San Onofre. How can we be sure?

How about this: The NRC just granted SCE a waiver on a test they are supposed to run every ten years, letting SCE use an alternative and less realistic "test" instead, so as not to delay a restart that hasn't even been approved yet. It's a pressure test. They've had 8 tubes, which are part of the primary pressure boundary, fail pressure tests, and now they're pleading the time lost to run a pressure test is excessive and unnecessary!

Unit 2 has been offline for nearly a year and a half, and they've known this once-per-decade test was coming up the entire time, yet they couldn't find a slot to run it a few months ago when restart wasn't about to happen?

Oh, that's right. SCE has always thought restart was just around the corner.

What's the real reason restart is imminent now? Now, when nothing's been repaired and the plant is still falling apart at the seams? I don't know: It's not sound engineering principles, it's not the will of the public, and it's not logic. However, if they restart and run successfully, and don't have cascading tube rupture following a main steam line break with an isolation valve failure or some other tragedy, they will have done all the other PWR reactors a valuable service. They will have shown that even the best activists can be beat. Local activists have had national and even international support to get THIS reactor shut down, but we have not succeeded. We have real-world experience showing that the economic hazards are far worse than the Price-Anderson Act can cover. We have engineering evidence that the steam generator tubes are fatigued, worn, bent and weakened. We have real-world experience that the tubes are prone to failure, their predecessors in Units 2 and 3 were, and the tubes in Unit 1 were, too.

We have evidence of fraud by the management in slipping these highly-modified steam generators through as "like for like" changes. We have documented evidence of intimidation and retaliation against workers who complain about safety violations.

We have Fukushima. We have the NRC on record as saying it still can't figure out how to apply any "lessons learned" from Fukushima to San Onofre or any other U.S. nuclear power plant, not even the 23 nearly exactly "like for like" BWR plants which are prone to the same potential catastrophic conditions that doomed the Fukushima reactors.

Yet San Onofre sits in an earthquake zone, in a tsunami inundation zone, in a wildfire zone which can cause another Station Black Out at any time. It's old, it's rusted, and major parts still need replacing, and the replacement parts have failed.

Decommission San Onofre now! Let's move on to green energy. Employ good workers in good jobs.

Tell the NRC: no restart of San Onofre!

Ace Hoffman
Carlsbad, CA
5/4/2013

For the email addresses of various NRC officials, please see my previous newsletter:
http://acehoffman.blogspot.com/2013/05/attention-san-onofre-activists-now-is.html
Short URL: http://goo.gl/Krcmo

Attachment: Bethann Chambers letter about San Onofre (pdf)

At 04:50 PM 5/4/2013 -0700, Ashok Kumar wrote:

Thanks ACE: Invaluable service always needed for such a calamity to be avoided and the advice must be followed.
Ashok

Thanks, Ashok.  Someone wrote to say that only dozens, if that, were arrested and I modified one sentence to make it more clear that not all the protesters were arrested.  He argued about the "tens of thousands" of protesters, too, but someone had told me 35,000. I just don't remember who.  Maybe they meant to say 3,500?  Well anyway, thousands, if not tens of thousands.

Ace

Attention San Onofre activists: NOW is the time to tell the NRC: "NO RESTART!"

The public has just 16 days to have any serious hope of stopping the restart of the San Onofre Nuclear Waste Generating Station (SanO).

After that, the official "public comment" period for the Nuclear Regulatory Commission's (NRC's) decision to approve (or not) Southern California Edison's (SCE's) restart plan for SanO's Unit 2 reactor will be over, plus if the NRC approves the restart, the Michael Peevey-controlled California Public Utilities Commission (CPUC) isn't standing in SCE's way, and nor is Governor Jerry "Gamma Beams" Brown.

The citizens must now stand up for themselves, as this is their last best chance to keep San Onofre shut down and get it decommissioned. Even though all the other logic of why San Onofre should be shut down is being ignored (as usual), the citizens still have a very good case. But the question has come down to: Is a 70% restart decision safe? (Somehow, the utility apparently believes public opposition will wane after restart. After all we've learned? Not likely!)

After that time, the NRC will make their decision. At some point, there will be a perfunctory final public hearing with perhaps two hours of unsworn testimony filled with barking Chamber-of-Commerce toadies pleading for the cheap energy they claim comes from San Onofre (in reality, it's the most expensive energy source on earth).

SCE will say they know what went wrong in Unit 3, and will promise to operate Unit 2 safely and not to turn the power up past 70%, which they will call their new 100%*.

The NRC staff will say they've reviewed all the data SCE gave them, and based on that data, they believe the restart plan is safe. That means they calculated the odds of an accident based on estimates of damage from rough measurements by imprecise equipment. It means they feel the crap-shoot is worth taking. The NRC will say that they reviewed the proprietary data that neither the public, nor outside experts, are allowed to see.

At that point, a nod of the head from the NRC will let the operators of San Onofre Unit 2 withdraw its control rods and let the nuclear reaction restart.

Unit 2 could start making waste again as early as next month.

Don't let this happen -- contact these people immediately!

"Chair Allison M. Macfarlane" <Chairman@nrc.gov>
"Commissioner Kristine L. Svinicki" <CMRSVINICKI@nrc.gov>
"Commissioner George Apostolakis" <CMRAPOSTOLAKIS@nrc.gov>
"Commissioner William D. Magwood" <CMRMAGWOOD@nrc.gov>
"Commissioner William C. Ostendorff" <CMROSTENDORFF@nrc.gov>

Also cc:
<Thomas.Hipschman@nrc.gov>
<Ryan.Lantz@NRC.gov>
"James Andersen" <james.andersen@nrc.gov>

Federal Register notice of comment period**:
http://goo.gl/dKtHV

With everything that's gone wrong for San Onofre, you would think SCE would just give up at some point. It would be the sensible business decision. That point may be reached soon, but it hasn't been reached yet. However, yesterday SCE hinted at it when their CEO, Ted Craver, told investors that San Onofre might be closed forever if they don't get permission to restart Unit 2 at 70% power (calling it "100% power" as SCE proposes to do only serves to confuse regulators and the public). But don't be fooled -- SCE wants to keep SanO running at almost any cost.

70% power from Unit 2 is 35% of SanO's previous output but comes with 100% of the risk, and at nearly 100% of the cost of running the two remaining reactors (Unit 1 was shut down in the early 1990s for similar problems to what is keeping Units 2 and 3 closed now).

The public's ability to argue against restart is seriously hampered because the most crucial information on which a logical decision could be based has been redacted by SCE and the steam generator manufacturer, Mitsubishi Heavy Industries (MHI). The public is not allowed to know the values of thousands of key data points, making it impossible to check the claims of SCE. The NRC does get to see these data, but cannot explain their reasons for accepting the numbers because they can't release the "proprietary" information that supposedly backs up any claims. The public is left completely in the dark. Even independent experts with decades of work in the nuclear industry and/or with the federal regulators themselves cannot see the unredacted data. But they can "bracket" key values and they have done so, and even while giving SCE the benefit of the doubt, they have concluded that SCE did not properly calculate the risks of restarting San Onofre. But worse than that, SCE has ignored key issues relating to wear and fatigue, they have failed to utilize more effective damage probe equipment, and they have misdiagnosed the root cause of the problems that shut down Unit 3.

In other words, profits still come before truth AND safety in the nuclear industry.

In Pressurized Water Reactors like the ones at San Onofre, inside the containment dome, the reactor heats ­ and irradiates -- highly pressurized primary coolant water to over 600 degrees Fahrenheit -- which would be well above boiling at atmospheric pressure, but it's pressurized to about 2200 pounds per square inch, and so it doesn't boil unless the system springs a leak. In that case, it flashes instantly to steam as it exits the leak. If the pressure drops low enough inside the primary loop, it will start to boil, which can lead to vibration problems in the reactor core -- a much worse place for vibration than even in the steam generators. It can also result in massive radiation releases and meltdowns.

The caustic and radioactive primary coolant flows through thousands of dime-thin tubes inside the steam generators. In fact, the surface area of the u-tubes inside the steam generators comprise about 50% of the total area of the "primary boundary" protecting the public and the environment from the radioactive iodine and other poisons which are normally entrapped in the primary loop. The reactor pressure vessel itself, 8 inches thick of high quality steel (one hopes), is part of the same primary boundary layer as the dime-thin tubes, and operates at the same pressure.

The secondary coolant loop, which flows outside the tubes but inside the steam generators, is at a much lower pressure (more than 1000 psi lower). As it passes by the u-tubes that are carrying the primary coolant inside them, the secondary coolant picks up some of the primary coolant's heat as the two coolant loops race next to each other inside the steam generators. Being cooler and under lower pressure, the secondary coolant loop heats up and turns to steam as it rises past the tubes. At the top of the u-bend it's nearly all steam -- this was part of the problem in Unit 3 -- not enough water for damping. Above the u-bends, the steam runs through a series of swirl vane moisture separators, dryers, and massive pipes until -- with less than 1% water in it -- the steam impinges on the turbine blades which are in a large building outside the containment dome. The turbine spins, generating electricity. After doing the work, the steam is condensed back to water (much of it has already condensed as it impacts the turbine blades multiple times in high- and then low- pressure blade rings). Final condensing is accomplished using a third coolant loop of ocean water (lake water or river water in other reactors, always mixed with dead fish, fish fry, larvae and other large and small sea life). The condensate is then pumped back into the steam generator as "feedwater" to go around again and again and again... if nothing goes wrong.

San Onofre has two closed loops and one open loop with sea water. The primary loop is highly radioactive. The secondary loop should not normally be radioactive at all, but it often is, slightly. This is because some leakage from each loop is "normal" in the parlance of the nuclear industry.

On January 31st, 2012, Unit 3 (which is not under consideration for restart) sprang a leak, which was a pinhole-sized hole. Enough primary coolant was leaking into the secondary coolant side that regulations required the plant to shut down. The size of leak was growing and had they waited, it could have gotten MUCH worse very fast. Subsequent investigation showed that SCE (and all of Southern California) was lucky that day: The u-tube that failed had a two-foot long wear spot coming out on either side of where it had ruptured.  The tube could have easily ripped completely open (like that oil pipe in Arkansas last month), to the point where its entire contents would have leaked into the secondary coolant loop.

Whenever primary coolant leaks, some of it escapes into the environment, because the radioactive noble gases don't condense when the steam is condensed to water. That leakage was what was measured the day Unit 3 shut down and how they knew they had a leak in the first place. The excess radiation was discovered, not surprisingly, in the turbine room, near where the condenser is located.

But things could have gone much worse for several reasons. One reason is that the damaged tube might have broken off and flung itself against other weakened and damaged tubes, causing them to break off in a cascade of tube failures. The tubes on either side of the tube that ruptured were also highly worn and near their breaking point, even without another tube banging into them under extremely high pressure, and then flailing around.

The NRC doesn't have a plan for multiple tube ruptures, let alone cascades of tube ruptures. During subsequent pressure testing of Unit 3's steam generators after the sudden shut-down last year, 8 tubes failed the tests; which is something that has never happen before in the history of the US nuclear "fleet." Three of those (including the one that had previously leaked) failed at below the expected, routine pressures that might occur during normal operating procedures, such as start-up or shutdown, or during what are known as "design basis accidents" which are accidents the owner/operator of the reactor is required to plan for because it's assumed they will occur somewhere sooner or later, and in many cases (such as a main steam line break) have occurred in the past.

In a multiple-tube rupture, there would be little time act, and no books or experts to guide the San Onofre control room operators. By the time they've figured out what's happening, the reactor's fuel will have become uncovered and a partial meltdown would have started. There may be nothing they could have done. If the ruptures occur because of a main steam line break the control room operators will be very, very busy.

It is because of the extreme amount of tube wear that Unit 3 cannot be restarted without a complete redesign of the steam generators and perhaps five years of just sitting there costing money for the ratepayers while the replacement steam generators -- untested in the field and currently nonexistent -- are designed and built.

Unit 2, on the other hand, suffered only one kind of vibration (known as "flow induced vibration" or FIV) and associated wear damage, but supposedly, Unit 2 did not experience the more damaging kind of vibration that Unit 3 was affected by (known as "fluid elastic instability" or FEI).

One reason Unit 2 should not be restarted is that it most certainly CAN suffer FEI. Despite more than a year of study by "experts," the exact reasons Unit 2 did not suffer from FEI are disputed and in any case, are unprovable without restarting the reactor and seeing what happens at various temperatures, pressures, flow rates and other operating conditions.

SCE insists the reasons for the different wear types and rates between Unit 2 and Unit 3 are subtle manufacturing differences between the two steam generators in Unit 2 and the two in Unit 3. They say these differences altered the flow of the secondary loop enough to prevent FEI in Unit 2. However, what if it was something else? Surely if they really knew what it was, they would know how to control it, and would have asked for a full restart at 100% power for the full fuel cycle of about 22 months. Then they would make some profit. Instead they are asking for 70% power for only 5 months, then they promise to do a thorough inspection. Their calculations say that for at least five months, it will be safe to operate. Their calculations also indicate that wear will continue, and that Unit 2 will be pretty well worn out within the five month period if any of their "worst case" scenarios turns out to be the correct one. Those scenarios are, in their opinion, significantly less likely. So that leaves us with two obvious questions: 1) What if their estimates are wrong? and 2) What if their estimates are right but something goes wrong anyway?

SCE's idea of a "worst case" scenario isn't nearly as bad as things can actually get. They are ignoring several problems.

Not only might they be wrong about what prevented FEI in Unit 2, but FEI will still be possible in Unit 2 if there is a main steam line break with accompanying isolation valve failure. If that happens, the secondary coolant in the steam generator will all immediately flash to steam and rush up and out the generator to the environment. As it rushes past the U-tubes, they will be devoid of the damping effects from the water that would normally have been there (that damping effect was missing in Unit 3).

But that's not the only problem. Another serious fallacy in SCE's restart plan is that there is an improper accounting of the fatigue factor from all the vibration that has occurred and can occur in the steam generators.

Fatigue is difficult to inspect for, difficult to model on computers, and impossible to predict accurately as to size, location, or the time or force it will take for something that has been stressed to subsequently fail.

The way a ductile (bendable) piece of metal becomes fatigued is that it can withstand, for example, millions or maybe even hundreds of millions of small stresses, but large stresses introduce the beginnings of microscopic cracks that grow over time until one day, the crack races through the metal and the metal cleaves along the crack. An important question that needs to be answered before any restart is considered at San Onofre is: Have the metal u-tubes inside the steam generators been overly stressed?

SCE claims they have not. Outside experts dispute that claim because their research concludes that the water in the secondary loop (outside the u-tubes) travels at least twice as fast across the tubes as SCE assumes (as the steam rises up the steam generator, it has a horizontal component). The horizontal component is fast enough to bend the tubes out of shape by more than their stress limit.

SCE did 170,000 individual inspections of the 40,000 tubes in units 2 and 3 after the tube rupture in January 2012. But all those inspections (just over 4 per tube) were for external tube wear from rubbing against each other or against tube support plates and other structural components of the steam generators. Fatigue wear was virtually ignored because their calculations assumed the tubes had not been stressed beyond their fatigue limits. Or was it because they didn't want to find what they might have found?

Yesterday another news item about San Onofre came out, about a repair job on a huge pipe in Unit 3 that was leaking. San Diego's 10 News reported -- with photos -- that the pipe leak was being channeled into a container with a combination of broomstick handles, plastic bags, and tape. A whistleblower at the plant says that the entire plant is rusting out, and cited a long fire main as one of the most rusted and dangerous pipes. ***

It's time to decommission San Onofre. There's no reason for SCE or anyone else to wait for NRC approval which should never come anyway. Even if they get approval from the NRC to restart, the plant can only operate at 35% of its previous output which is not enough to make it a significant source of income for SCE. Since they can only operate one unit which must be shut down frequently for extensive inspections to see if it's wearing out extra-quickly, it cannot provide reliable "base load capacity." (Of course, it never actually did provide reliable base-load capacity.) At 70% power, the reactor can still suffer from catastrophic failure caused by station blackouts, fires, earthquakes, tsunamis, sabotage, or a thousand other events. The steam generator problem makes all of these other problems more likely to turn into major catastrophes.

Solar power provides thousands of jobs in Southern California already and can provides thousands more for many years to come. These are good paying union jobs that offer good benefits -- solar panel installation is a profitable business for everyone, including the homeowner.

Let's get California on a true path to clean energy. Demand SCE decommission San Onofre NOW. Don't wait for a "captured" regulatory federal agency to give approval for a broken plant with defective and degraded equipment to experimentally restart at unprofitable power levels just to test their theories of what went wrong. Let's prevent a Fukushima accident in California. Let's stop piling up more nuclear waste with nowhere to put it.

Tell the NRC to tell SCE they will NOT be given permission to restart either of their broken reactors. Then let Ted Craver see the light and turn towards the sun.

Ace Hoffman and friends
Carlsbad, CA
May 1st, 2013

* The technical term: "full range of normal operating conditions" is going to be changed to "normal steady state full power operation" to accomplish this power reduction from 100% to 70%.

** Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination; San Onofre Nuclear Generating Station, Unit 2: https://www.federalregister.gov/articles/2013/04/16/2013-08888/application-and-amendment-to-facility-operating-license-involving-proposed-no-significant-hazards

*** 10 News: Plastic bags, tape, broomsticks fix San Onofre leak:
http://www.10news.com/news/investigations/photograph-picture-given-to-team-10-shows-plastic-bags-tape-broomsticks-used-to-fix-leak-at-san-onofre-043013

###

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** Ace Hoffman
** home page: www.animatedsoftware.com
** Personal home page: www.acehoffman.org
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Follow-up 5/2/2013 on the timing of the NRC's upcoming decision:

I just spoke with Victor Dricks

Dricks says:

1) The NRC will not take any action on Edison's License Amendment application prior to June 17 - and that restart would not occur prior to the NRC's decision on the License Amendment.

2) The next public meeting in Southern California will be for the purpose of discussing the results of the Confirmatory Action Letter (CAL) inspection - and the results of the technical evaluation of Edison's restart plan. The decision on restart WILL NOT be discussed or announced at the next public meeting in SoCal.

3) The NRC expects the meeting to take place sometime in mid-June - they will give the public as much prior notice as possible

I asked how much prior notice they're required to provide - he said 14 days - but they've been having much difficulty finding a venue large enough to accommodate 1,000 people -  if they find a large enough venue they may be forced due to circumstances to shorten the 14 day notice requirement.

Myla

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