Thursday, January 17, 2013

Media Alert 13-01-17 Allegation – NRC Violating Presidential Directive and the Public Trust

Media Alert 13-01-17


Allegation – NRC Violating Presidential Directive and the Public Trust

Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261

 

San Onofre Unit 2 Restart Decision by NRC Imminent – SCE's PR Machine Is Capable Of Overcoming ALL Hurdles, Except Good Science And Safety


The DAB Safety Team has transmitted the following Allegation to "The United States Department of Justice", "Office of the Chairman of the NRC" and "The United States Senate Committee on Environment and Public Work."  A printed copy of this Allegation will be mailed directly to The White House.


The United States Department of Justice website http://www.justice.gov/open/ states, "The Department of Justice is committed to achieving the President's goal of making this the most transparent Administration in history.  In the Memorandum on Transparency and Open Government, issued on January 21, 2009, the President instructed the Director of the Office of Management and Budget to issue an Open Government Directive.  The Open Government Directive directs executive departments and agencies to take specific actions to implement the principles of transparency, participation, and collaboration set forth in the President's Memorandum." 


Albert Einstein described insanity as: Doing the same thing over and over again and expecting different results. The DAB Safety Team has challenged previously in their published DAB Safety Team Documents, that Southern California Edison's controversial plan to restart San Onofre Unit 2 as a "Bogus and dangerous SCE experiment."  According to SONGS Anonymous Insiders, SCE's Engineers were under the false impression that Unit 3 Anti-vibration Structure was built better than Unit 2.  Therefore, SCE Engineers were operating Unit 3 at lower steam pressures than Unit 2 in a test mode to generate more thermal megawatts and thereby more electricity. To add to Arnie Gundersen's and John Large's Technical Affidavits, DAB Safety Team's investigation reveals that in the process of this "money-hungry experiment", lower steam pressures in combination with other unapproved and unanalyzed design changes destroyed Unit 3 due to fluid elasticity instability. SCE and NRC AIT Team both blamed Unit 3 FEI on botched up MHI Computer Modeling and insufficient tube-to-AVB gaps. AREVA, Westinghouse, John Large and DAB Safety Team findings dispute these statements. NRC Augmented Inspection Team and NRR Panel have swept DAB Safety Team Findings consistently under the rug, in what must be now labeled as a Gov't cover-up!


The DAB Safety Team reaffirms, that a formal NRC 50.90 licensing review with public input is now required, before any decision to restart Unit 2 by the NRC is considered.  The DAB Safety Team's published position is in full agreement with the Friends of Earth's Nuclear Experts' Public statements, "Edison's experimental plan to restart a badly broken reactor and see what happens is unacceptable.  Edison simply cannot prove that if they operate San Onofre under the terms of their restart plan, more steam generator tubes will not fail. This reckless plan would risk the lives and livelihoods of millions of Southern Californians. Edison's defective steam generators are simply too damaged to meet the terms of San Onofre's current operating license. Edison played fast and loose by making radical design changes and ducking the rules. The result was the most rapid breakdown of such replacement steam generators in the history of the U.S. nuclear industry. If Edison had followed the rules, an NRC license review would have found these glaring defects, and the lives and livelihoods of millions of people would not have been put at risk nor would hundreds of millions of dollars have been squandered."



The NRC keeps issuing both controversial and conflicting press statements that a decision to allow the restart of Unit 2 could come as early as March 2013.  According to SONGS anonymous insiders, Edison officials have announced in internal SONGS Staff Meetings that a restart decision is imminent in March despite the huge public outcry about safety problems by SCE.  Press reports as of January 14, 2013 state, "Small steps are being taken to prepare for possibly restarting the troubled San Onofre nuclear power plant, even as its future remains clouded with uncertainty, officials said Monday. Nuclear Regulatory Commission senior inspector Greg Warnick said Monday that the agency is beginning to prepare a detailed plan of what would need to be done to bring the plant safely back to service." (SOURCE: CBS Los Angeles, Associated Press)


NRC's enforcement history, drama and pre-rehearsed tough questions, press reports, casual relationship and/or protection of SCE officials and utility biased public meetings are just old and cheap regulatory tricks that are now being used to protect the NRC's own public image and to fool the public into believing that the NRC is really concerned about public safety regarding SCE's Restart Plan.  The Justice Department & NRR Officials need to set up a legal/technical taskforce to publically question Edison's design and MHI Engineer's listed below under oath regarding their: (1) Understanding of their legal obligations under the 10 CFR 50.59 Process, (2) Understanding of problems with the original steam generators, (3) Critical questioning and professional/investigative skills, (4) Efforts made in industry and academic benchmarking to identify and resolve problems with the original steam generators and, (5) What part did they play in the preparation of design specifications, fabrication, computer modeling, mock-up testing, anti-vibration bar structure, and research required to prevent the adverse effects of fluid elasticity and flow-induced random vibrations in these unique San Onofre Combustion Engineering replacement generators.


The following names of SCE/MHI Engineers have been obtained from public websites


·      Design & Performance Specifications SO23-617-1

1.    Originator – James Chan (SCE)

2.    Independent Review Engineer – Jun Gaor (SCE)

3.    First Line Supervisor – David Calhoun (SCE)

4.    Second Line Supervisor  – Craig Herberts (SCE)

5.    Procurement Engineering Tom Pierno (SCE)

6.    Nuclear Oversight & Assessment Bill Kotekkasko (SCE)



·      Challenges and Rewards of Innovative Design of Replacement Steam Generators

1.    Boguslaw J. Olech, Steam Generator Expert (SCE)

2.    Tomoyuki Inoue, Steam Generator Expert  (MHI)



·      Export of High-performance & High-quality Components

1.    Yasuhiro Kutomi, Nuclear Energy System Headquarters (MHI)

2.    Takaya Kusakabe, Kobe Shipyard & Machinery Works (MHI)

3.    Yoshinori Takata, Kobe Shipyard & Machinery Works (MHI)

4.    Toshiyuki Mizutani, Kobe Shipyard & Machinery Works (MHI)

5.    Chikara Kurimura, Kobe Shipyard & Machinery Works (MHI)

6.    Seiji Asada, Kobe Shipyard & Machinery Works (MHI)



Any NRC decision to grant a restart of Unit 2 without a formal 50.90 licensing review along with public participation will be seen as an invitation to risk a Fukushima-type disaster happening in Southern California. 


Media Alert 13-01-17
Allegation - NRC Violating President's Directive And the Public Trust is posted on the web at this link: DAB Safety Team Documents.

###

The DAB Safety Team: Don, Ace and a BATTERY of safety-conscious San Onofre insiders plus industry experts from around the world who wish to remain anonymous.  These volunteers assist the DAB Safety Team by sharing knowledge, opinions and insight but are not responsible for the contents of the DAB Safety Team's reports.  We continue to work together as a Safety Team to prepare additional: DAB Safety Team Documents, which explain in detail why a SONGS restart is unsafe at any power level without a Full/Thorough/Transparent NRC 50.90 License Amendment and Evidentiary Public Hearings.  For more information from The DAB Safety Team, please visit the link above.

Our Mission: To prevent a Trillion Dollar Eco-Disaster like Fukushima, from happening in the USA.

Copyright January 17, 2013 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team. The contents cannot be altered without the Written Permission of the DAB Safety Team Leader and/or the DAB Safety Team's Attorney

Tuesday, January 15, 2013

Don't look at the sun, you'll get spots in your eyes...

January 15th, 2013

Dear Readers,

A coronal mass ejection is heading our way right now. It will get here over the next day or so. It is expected to have only minor, momentary effects on communications.

It could be worse.

Sun spots are associated with increased numbers -- and sizes -- of solar flares and coronal mass ejections (CMEs). Such events have been tracked as much as possible with available technology since 1755. It's known that there is an 11-year cycle, and 2013 is expected to be a peak year, although not all events occur during peak years. Most, but not all, solar events emanate from near the sun's equator.

The largest two events in history are more than 100 years apart: Quebec in 1989, and the "Granddaddy" of them all, the Carrington event, in 1859. That event caused widespread fires and sparks, especially at the terminus of long telegraph wires. But a lot has changed since then.

The Quebec incident blew out several large transformers as well as other equipment at hydroelectric dams and substations over a large area. Another CME event is believed to have damaged a transformer at the Salem nuclear power plant, although it can be difficult to tell what damaged something: Was it poor maintenance, old age, loose connections, poor original design... sabotage... or a power surge that may or may not have even happened? Few transformers at nuclear power plants are designed to withstand Geomagnetic Disturbances (GMDs) and to make matters worse, even if they were, most are 30 to 40 years old, and are at the ends of their lives. Many utilities are failing to replace their old generators as they await relicensing decisions -- and CMEs.

CMEs are massive and violent. They are comprised of protons and helium atoms being hurled out at tremendous speed. If they stream out in our direction, they'll take anywhere from 15 to about 40 hours to travel the 93 million miles to reach earth, at an average speed of between about two and six million miles per hour. When they get here, they can wipe out transformers and other things connected to the power grid -- after destroying satellites in space first.

The blackout following the Quebec disturbance lasted about three days. But much larger disturbances, and much longer blackouts, are possible, which can -- not that it's likely, but it can -- wipe out the planet, thanks to the nuclear power industry.

Nuclear power plants cannot survive a "Station Black Out" (SBO) condition for long, especially when everything else has been shut down, such as oil refineries, hospitals, other power sources, communications and transmission lines. There are no "manual" pumps for cooling the reactors. If the Emergency Diesel Generators get fried, if the batteries get frizzed, if the off-site power is lost, then it's just a matter of minutes, or perhaps a few hours, before meltdown. Then the spent fuel pools start to boil dry a few days later.

The longer a transmission line is, and/or the higher its voltage, the more susceptible it is to the electromagnetic disturbances that result from the "electrojet currents" that spread across the earth's surface. These usually are the strongest at the north pole, but a visible "Northern Lights" effect has been observed as far south as the Caribbean.

The entire electric industry is largely unprepared for this type of event, due to the costs involved. Retrofitting circuits with shunts for the extra power loads is expensive and time-consuming. Figuring out which transmission lines are most susceptible is no small challenge either. And then, during the time between when astronomers declare that a solar event is occurring, such as right now, and when it gets here, figuring out what to shut down or take off line can be difficult to assess in real time.

Obviously, taking the nuclear power plants offline makes intrinsic sense, but one can hardly expect all ~440 commercial (plus research and military) reactors to simply take heed and stop making their million dollars per day, stop doing their research or heading for the enemy just on the "off chance" that the solar event will, in fact, hit us with all it's got.

After all, Quebec 1989 didn't cause any meltdowns, and nor did the Salem event. For the nuclear industry, a miss like that is often used to prove the success of a plan. All it really proves is the industry got lucky -- again. The nuclear industry's entire existence is based on "careful" calculations of the odds against various events: Hundred year floods, thousand year earthquakes, and so on. They used to base their "safety culture" on something else, known as "Defense in Depth." But "DID" didn't work for large, rare events that could not be engineered against: Too-big earthquakes, too-tall tsunamis. So they admitted those events were: "beyond design basis" and then simply asserted they were too rare to worry about.

Since then, such "rare" events have taken out three nuclear reactors in Japan, one in Russia, and several partially melted down in the United States and elsewhere, as well.

Were these all such rare events that "no one" could have foreseen them? Or is the nuclear industry turning a blind eye to solar flares this year, just like in 2011 when they ignored Fukushima, 2002 when they ignored Davis-Besse, 1986 when they ignored Chernobyl, 1979 when they ignored Three Mile Island, and on and on?

Time will tell.

Ace Hoffman, Carlsbad, California USA (images added 2025)


Upcoming events:
Tomorrow: Wednesday, January 16th, 2013:
Ace Hoffman will be speaking about San Onofre to the LA Green Party at their monthly meeting: Location: The Peace Center - 8124 West Third St. (near Fairfax @ Crescent Heights Blvd). Time: 7:00 pm. Contact: Kamran Ghasri <kghasri@gmail.com>
NRC MEETING TO DISCUSS ACTIVITIES RELATED TO LESSONS LEARNED FROM FUKUSHIMA
scheduled for Wednesday, January 16, 2013 9:00 a.m. - 11:30 a.m., EDT

Interested members of the public can participate in this meeting via a toll-free audio teleconference. Please dial in using toll free number: 888-323-9730, pass code 50556.

Use the website to get more information following an NRC press release. This is the link to this Jan.16 meeting.
http://www.nrc.gov/public-involve/public-meetings/index.cfm?action=search.detail&MeetingCode=20130011




Ace Hoffman
Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Email: ace [at] acehoffman.org
Founder & Owner, The Animated Software Company



Saturday, January 5, 2013

The familiar becomes invisible: The Battle Against San Onofre...

January 4th, 2013

Dear Readers,

People travel past the San Onofre Nuclear (Waste) Generating Station, its twin domes sticking sharply into the skyline between San Diego and Los Angeles, about a million times every week. But who really notices it?

Nestled tightly between I-5 and the railroad on one side and the ocean on the other, it's been on the front page of the local papers dozens of times since it sprung a leak and had to shut down nearly a year ago. But its current problems have become "old news" -- even while the ratepayers continue to pay $60 million a month for nothing. And even though we obviously don't need it -- the lights stayed on all year.

"Do you have a defining moment, something different, something new?" a popular local radio reporter asks an independent SanO safety team spokesperson. The team had sent out (another) press release, describing the latest problem SCE is facing (a strongly-worded letter from, of all places, the Office of Nuclear Reactor Regulations at the Nuclear Regulatory Commission). The reporter couldn't see that San Onofre's spiraling continuum into oblivion is still a BIG story. She could report something about it every day, like a riot or a war. It's a war against humanity -- all of humanity, but especially everyone local. It's a war to prevent a Fukushima-level event here. And while most people remain oblivious, other people have learned about the danger and are actively opposing ANY restart of the crippled reactor. They need your help.

The die was cast for the battle against San Onofre that's now occurring when the control rods were pulled out for the first time in the early 1980s (and earlier, for the already-retired Unit 1). From that moment on, millions of deaths in the community became possible, and a catastrophe becomes more and more probable as time goes on. The debt to the future long ago became unpayable. Atoms were split for profit, the radioactive fission fragments, plutonium and other crud that was produced along the way was ignored.

Either San Onofre will kill us or we will kill it -- it's a fight to the death. Yet most people, even after Fukushima's warning (or Chernobyl's) still aren't paying attention.

300,000 people around Fukushima are still in "temporary housing" nearly two years after the nuclear accident. It wasn't the tsunami that displaced all those people -- it was the radiation. They won't be able to go home for many generations. The "decontamination" procedures going on in Japan are criminally negligent and often make things worse -- contaminating rivers, for instance, in order to clean up land areas. And burning the radioactive debris is utterly irresponsible, but they do it 24 hours a day now in Japan. They even haul radioactive debris miles away from Fukushima just to burn it somewhere else.

In most cases, radioactive contamination cannot be effectively cleaned up at all. Trying to do so, at best, merely harms the workers who do the work, and at worst, stirs up the debris and leaves it in a worse place. What's happening in Japan is a tragedy. We don't want that here.

Most of San Onofre is not visible from the highway. Only the top portions of the twin domes can be seen -- peculiar-looking things. Distinctive. Perky.

Massive additional structures exist between, behind, and near those domes, but those structures are difficult to see from the highway. And reportedly, they're building a new 20-foot wall around the entire structure -- to become more invisible, of course.

There are two extremely deadly spent fuel pools, and dozens of also-dangerous spent fuel dry storage casks (which are relatively new, they started adding those last decade). There are four massive emergency diesel generators (two per reactor, located above any expected tsunami level). Each is as large as a locomotive, and has two weeks' worth of fuel, but the fuel is stored below grade.

There are backup batteries, which are only good for a few hours, and backup water systems to flood the reactors in an emergency, but there's only about a million gallons of water and it can go through that in a minute. Also, there is a huge transmission switchyard, and huge tanks filled with various chemicals to treat the coolant system water, and many, many miles of pipes and cables going every which way.

It's all rusting in the salty air, just like every set of stairs along the coast, just like every metal fitting at every pier. But at San Onofre, it's hidden from public view. You can't get tour of the facility. Not since 9-11, and even before that, access was very limited for the public.

The largest pipes at nuclear reactors have names, like Main Steam Line, Outflow, and Intake. The Pacific Ocean is called "the ultimate heat sink" by reactor operators, because if anything goes wrong, they'll dump the heat into the ocean as much as possible. And the radioactivity. The ocean floor (and everything that feeds along it) around Fukushima is heavily poisoned with radioactive debris.

Very few of the tens of thousand of people who drive by San Onofre every day think about any of this, or what can go wrong -- but they should! They should think about it day and night until it's gone -- decommissioned, demolished, returned to pristine beach.

Like we were promised.

Sometimes you can see San Onofre steaming slightly. Sometimes it steams a lot, as it dumps (slightly radioactive) heat into the environment after a sudden shutdown. But the last time THAT happened was almost a year ago, and both reactors have been shut down ever since. With luck, and some activism in the community we can say good riddance to San Onofre forever.

But most people still ignore this danger in their midst. Driving by it, San Onofre seems benign, even friendly. Even when it's spewing poisons that can kill a person in minutes, it can still LOOK just as benign -- the hydrogen explosions at Fukushima don't have to occur for there to be a disaster unfolding at a nuclear power plant. And the poisons it spews are odorless, colorless, and tasteless even in lethal quantities.

Sometimes a huge part of the plant might be seen being moved in or out of San Onofre with massive cranes. They even have their own 200-wheel truck just for hauling away old steam generators. The only problem is, they've got a lot more old steam generators than they expected.

Floodlit at night, flocked with birds at sunset on the north dome (why only the north dome?), the peculiarly-shaped pair of reactors sits idle, not quite out of sight, but totally out of mind. The familiar becomes invisible.

Meetings with the Nuclear Regulatory Commission come and go... and come, and go. Webinars. Panels. Class 1 meetings. Class 3 meetings. Meetings in Washington. Meetings here. We were told there would be "at least" two NRC hearings AFTER the "root cause" of the current problems had been found. Instead, the plant operators are talking about restarting the plant in just two months, not only without those two hearings AFTER the root cause had been determined, but without even determining the root cause of the problem!

The steam generator tubes vibrated until they ruptured, and radiation leaked. Why? What was different about Unit 3 that caused it to fail in less than a year, when Unit 2 hummed along -- albeit, not nicely -- for 22 months, all the way to its first refueling outage after the replacement steam generators had been put in?

That question has not been answered.

But nor have a thousand other questions, starting with, "What will we do with the waste?" When the reactors are operating it piles up at the rate of more than a ton a week: That's what ends up in the spent fuel pools and dry casks, because we have nowhere else to put it. The federal government promised to take it (and burden someone else with it) but they have not been able to do that. One smart nuclear scientist (which is not as redundant as it sounds) in Japan asks, "Would you build a house without a toilet?" but that's exactly what we've done at San Onofre. "Even the nicest mansion would become uninhabitable if there is no toilet" he adds. San Onofre has no toilet. The nuclear industry has no place for the waste.

Get involved. Get this plant closed. It's your future that is at stake! It's your children, your lives!

Right now, more than ever, the NRC needs to hear from local citizens. More than ever the California Public Utilities Commission needs to hear from you. People who have been watching the plant for the past year (or longer) need your help, and you CAN change your future, and prevent Southern California's own Fukushima.

Next time you drive by San Onofre, remind yourself how much you like to live here. Ask yourself if you want to breath clean air without poisons in it, like tritium or cesium or radioactive iodine. Ask yourself if you need to live at all -- because San Onofre can kill by the millions the moment they restart it.

Ask yourself these questions, then choose to demand San Onofre be shuttered once and for all. Don't expect anyone else's voice to matter. We need yours.

Sincerely,

Ace Hoffman
Carlsbad, CA

==================================================
Upcoming events:
==================================================

Sunday, January 6th, 2013, 2:00 pm:

Ace Hoffman (possibly with Special Guest Harvey Wasserman if he can fight traffic from a KPFK interview to get there in time) at OC Greens monthly meeting

Talking about San Onofre's problems (this event will be filmed)

Where:
Irvine Ranch Water District Headquarters Community Room
15600 Sand Canyon Avenue Irvine, California 92618-3102
(Use of the facility does not represent endorsement by the IRWD)

If you plan to attend please RSVP to Ron Rodarte:
Ron Rodarte <highwayron@gmail.com>

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

Tuesday, January 8th, 2013:

Press conference at CPUC (hearing at 10am, press conference around noon)

Call for San Onofre shutdown; Nuclear-Free New Year

Where:
Front steps of the CPUC, 505 Van Ness Ave. San Francisco, California

If you plan to attend please RSVP Steve Zeltzer:
Steve Zeltzer <lvpsf@igc.org>

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

Wednesday, January 9th, 2013:

Ilene Proctor Presents #55 in the Great Mind Series:
An exciting evening with Harvey Wasserman (Ace will also be there...)

NO NUKES IS GOOD NUKES
Critical Meeting to Keep San Onofre Shut

Time: 7:30 PM to 9:00 PM

Join Hostess Lila Garrett
Address available with RSVP

RSVP A Must: ilenepr@sbcglobal.net

Fee: $20, $15 for PDLA Members

NO NUKES!!! SAN ONOFRE'S CRITICAL SHUT-DOWN MOMENT---

The two remaining reactors at San Onofre---Units 2 & 3---have been shut for almost a year. This is our critical moment to close them forever. Core technical problems have compromised steam generators that must never be allowed to operate again. Because financial issues are at stake, this is a rare moment where state agencies---especially the California Public Utilities Commission---can make the difference. Time is short but our power in this situation is unprecedented. The permanent closure of these reactors would make southern California a vastly safer place, with major economic opportunities for the Solartopian shift to renewables, efficiency and conservation, revolutionizing the regional economy. This is a truly unique moment in our history----let's act now to make the most of it!!


Life-long peace/No Nukes/social justice/election protection activist Harvey Wasserman edits www.nukefree.org and has been fighting for a Solartopian future since 1973. In 1984 he was arrested at the Diablo Canyon nuclear plant and is now focussing his efforts on shutting America's remaining 104 reactors---including San Onofre Units 2 & 3--- and ushering in a era free of atomic power. He has authored and co-authored a dozen books and helped coin the terms "No Nukes" and "Solartopia". He has served as senior advisor to Greenpeace USA and the Nuclear Information & Resources Service. He has spoken to scores of rallies, citizen groups, media outlets and school groups, and in 1994 addressed 350,000 semi-conscious rock fans at Woodstock 2. He is overjoyed to find himself in southern California in January, where his new grandson is about to turn one year old.

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

January 14th, 2013 (afternoon; exact time and place TBD):
A "private" one-hour meeting with NRC Chairman Allison Macfarlane:
Presumably there is at least one spot available for this event since I was kindly offered a seat but won't be there. If you wish to attend please RSVP Gene Stone:

Gene Stone <genston@sbcglobal.net>

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

==================================================
From NIRS (accompanied the awesome Nuclear Monitor #755):
==================================================

Nuclear Monitor #755 is a special issue on radiation issues. We hope you find it useful.

We are currently searching for a new editor for the Nuclear Monitor. This position is based at the World Information Service on Energy office in Amsterdam. If you, or someone you know, is interested in this position, please contact wiseamster@antenna.nl

Until a new editor is found, we expect to publish the Nuclear Monitor monthly rather than biweekly. The attached issue is your December issue, which has been delayed due to a December power surge in NIRS� office which fried the computer and software used to produce the Monitor (and which has now been replaced).

We have updated our Monitor subscription list; welcome to the hundreds of new subscribers from November and December who have now been added!

Michael Mariotte
NIRS

==================================================
Contact information for Ace Hoffman:

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

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

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

Thursday, January 3, 2013

Press Release: 13-01-03 TEN Unresolved Items, Requires NRR Investigation

Press Release (Condensed Version)


The DAB Safety Team: January 3, 2013

Media Contact:
Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261


The Unsatisfactory Status Of The NRC Region IV Augmented Inspection Team Report Which Contains TEN Unresolved Items, Requires Additional NRR Investigation And Resolution.




The DAB Safety Team has transmitted the following to the Chairman of the NRC, Offices of Nuclear Regulator Regulations, Atomic Safety Licensing Board and NRC AIT Team Chief.

The NRC AIT Report (ADAMS Accession Number ML2012007) identified ten unresolved items in July 2012 that warranted additional follow-up:  (1) adequacy of the post trip/transient procedure; (2) evaluation and disposition of the Unit 3 loose parts monitor alarms; (3) design of retainer bar; (4) control of original design dimensions; (5) evaluation of and controls for divider plate repair; (6) atmospheric controls of Unit 3 steam generators during shipment; (7) no tube bundle support used during shipping; (8) evaluation and disposition of accelerometer readings during shipping; (9) adequacy of Mitsubishi's thermal-hydraulic model; and (10) change of methodologies associated with 10 CFR 50.59 review.  Consistent with existing NRC inspection processes, these unresolved issues will be inspected and dispositioned during follow-up inspection efforts to determine if there are any violations of regulatory requirements.


DAB SAFETY Team Comments. re: NRC AIT Report: It has been almost six months since the issuance of the original report and since that time the NRC AIT has completed several follow-up inspections at SONGS.  However, the NRC AIT has not publicly updated its report on the results of follow-up inspections to resolve the above items and determination of violations of regulatory requirements by SCE. These concerns were expressed to the NRC Region IV Staff and AIT at the November 30, 2012 Public Meeting.  Several Environmental, Public and even Pro-Nuclear Groups have repeatedly and publicly stated to the NRC, Atomic Licensing Board and Office of Nuclear Reactor Regulations: "When it comes to SCE's mistakes and public policy, NRC Region IV is asleep at the wheel."  NRC Chairman has stressed the need for "Independent Regulators" during her recent Fukushima trip. Therefore, these items should be added to the NRR list for resolution.  Especially, items (2), (3), (9) and (10) should be resolved as soon as possible.  In addition, the NRR should made public SCE's FSAR analysis showing the effect of a Main Steam Line Break for Unit 2 operation up to Reactor Thermal Power on Steam Generator Tube Ruptures (for one (1), four (4), eight (8) or an ever increasing number (a cascade aka Hopenfeld Effect) of tube rupture/failures) in accordance with President Barack Obama, Senator Barbara Boxer and the NRC Chairman's Open Government Initiative, as these documents directly affect public safety, they must no longer be considered SCE's "privileged documents" after their SONGS Replacement Generators $680 Million Debacle.

The complete version of  Press Release + 13-01-03 TEN Unresolved Items, Requires NRR Investigation will be posted on the web at this link: DAB Safety Team Documents.



###


The DAB Safety Team: Don, Ace and a BATTERY of safety-conscious San Onofre insiders plus industry experts from around the world who wish to remain anonymous.  These volunteers assist the DAB Safety Team by sharing knowledge, opinions and insight but are not responsible for the contents of the DAB Safety Team's reports.  We continue to work together as a Safety Team to prepare additional : DAB Safety Team Documents, which explain in detail why a SONGS restart is unsafe at any power level without a Full/Thorough/Transparent NRC 50.90 License Amendment and Evidentiary Public Hearings.  For more information from The DAB Safety Team, please visit the link above.

Our Mission:
To prevent a Trillion Dollar Eco-Disaster like Fukushima, from happening in the USA.

Copyright (c) 2013 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team. The contents cannot be altered without the Written Permission of the DAB Safety Team Leader and/or the DAB Safety Team's Attorney

Wednesday, January 2, 2013

Waste Confidence: Out of sight, out of mind... out of options...

Re: Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation

Document ID: NRC-2012-0246-0001 Document Type: Proposed Rule
Docket ID: NRC-2012-0246 RIN: 3150-AJ20

To make a comment about the above document (must be done by midnight EST 1/2/2013):
http://www.regulations.gov/#!submitComment;D=NRC-2012-0246-0001


1/2/2013

Dear Readers,

At a recent Nuclear Regulatory Commission webinar/hearing on "Waste Confidence," or what to do about the growing mountain of radioactive used reactor cores, people on both sides actually agreed on SOMETHING. I didn't like the term "Waste Confidence" and the pro-nuker didn't like it either.

Other than that, there was little to agree on. The pro-nuker preferred to call it "spent fuel confidence." I, on the other hand, didn't like the word "confidence" since there's nothing that warrants ANY confidence in this discussion, whatsoever. "Waste Failure" would be more appropriate. Or "Waste Impasse" might be even better. Or better yet: "The Intractable, Unsolvable, Filthy, Disgusting Mess We've Made" but I guess that would just be too accurate to a group where a "rapid disassembly" is the term for a core explosion that spews radioactive crud for miles around.

But one way or another, it's obvious that "Waste Confidence" is a misnomer from start to finish.

The NRC officials stressed that in their 30 years, they have not overseen a major accident at a nuclear facility, during transport, or at a waste storage facility such as a spent fuel pool or dry cask storage farm.

Of course, TEPCO and the Japanese nuclear regulators made the same claim of confidence and historic precedent. Then Fukushima happened.

The NRC's confidence is wholly out of proportion to their "success" thus far: There HAVE been accidents, there HAVE been releases, and most importantly, there have been CLOSE CALLS where only good luck (aka the Grace of God) saved us. A fire nearly took out Browns Ferry, and TMI did NOT become a Fukushima or Chernobyl, but could have. And Davis-Besse in 2002 was fractions of fractions of an inch from a catastrophic hole in the reactor pressure vessel head. San Onofre's Unit 2 pressure vessel head (and many others around the nation) was replaced during the last outage as a direct result of increased inspections following the Davis-Besse incident. SanO's Unit 3 was due for a head replacement when it blew a tube in one of its new steam generators.

Japan had been lucky many times before, as small accidents did not become global catastrophes: Monju, 1995, Tokai, 1997 & 1999, Mihama, 2004, and Kashiwazaki-Kariwa, 2007 to name a few. But as every smart gambler knows (that's everyone who doesn't gamble with their lives), luck runs out sooner or later. On March 11th, 2011, luck ran out for Japan.

Nuclear waste storage is a huge unsolved problem in every nuclear country. Although France, Japan and several other countries reprocess spent fuel, they have had numerous incidents at their facilities and numerous releases of radiological materials into the environment. In addition to being dirty, reprocessing is energy-intensive and expensive. For these and other reasons, such as proliferation issues, we do not reprocess spent fuel in America, and don't expect to.

Instead, we just hold onto it. What else can we do? There's nowhere to put it because all the options we've explored as a country haven't worked out: Dumping the waste at sea was banned decades ago, rocketing it into outer space is not only prohibitively expensive, but even the most modern rockets have an alarming failure rate -- and that is unlikely to improve, not just because the debris field in near earth orbit is getting more and more crowded, but because fraudulent electronics parts have been turning up everywhere -- including in military and aerospace applications.

We looked into placing the waste deep in the earth, but the earth is too unpredictable. Yucca Mountain is often called a political failure, but actually: There are earthquakes there! And not to mention water seepage from above, a vast and precious water table underneath, and insect/vermin infestation issues too. And it was on sacred Indian land. Is there one square foot of land on this earth which is NOT sacred to us all?

We've considered "vitrifying" the waste but the main problem there has been cracking of the once-solid vitrified materials, cause by gas molecules created by the decay of the radioactive isotopes.

Transmutation, another proposed solution, has never been proven successful on a large-scale basis and most transmutation schemes require an additional nuclear reactor to produce the neutron flux needed to transmute the unstable fission products to ones with very short half-lives. And can it be done cleanly? And thoroughly? It's not even on the table as a research project at the NRC.

What we can do with the used reactor cores is to let them be. Of course, that introduces a wide variety of other problems, all of which we now have: Finding locations, hardening the sites against potential terrorism threats, and hoping that nothing goes wrong due to metal fatigue, overheating, criticality events, airplanes crashing into the facility, earthquakes, tsunamis, and more.

It's been said that the dry casks survived the earthquakes and tsunami at Fukushima, therefore we should be using more dry casks. It's true they survived, and they survived in North Anna recently when an earthquake moved them several inches on their beds, but none tipped over.

However it's NOT true that dry casks can survive anything mother nature (and human nature) can throw at them! They could be in the wrong place at the wrong time, and that's why we need to limit how many of them there are. But the only way to do that is, of course, to shut down the reactors. That way, the fuel can be allowed to cool enough to move it from the spent fuel pools to the dry casks. If the reactors are operating, there will always be fuel in the pools and in the reactor. The "hot" fuel is extremely dangerous; the longer it is out

And even if they do everything perfectly for the next 100,000 years -- a long shot bet, indeed -- they will not be a quarter of the way towards "solving" the problem of what to actually DO with the waste. Letting it sit is a recipe for letting something bad happen to it.

The only reasonable and logical solution is to stop making more. But this "Waste Confidence" decision isn't based on reason or logic. It's based on keeping the reactors OPERATING for the next hundred years -- some reactors will be nearly 150 years old by then! But that's the plan: The NRC assumes that the storage casks will be properly manufactured and loaded. The NRC assumes that they will be properly guarded. The NRC assumes that Homeland Security will prevent all significant acts of terrorism against the facilities, and the security guards at the site with their pea-shooters will prevent the rest. The NRC assumes that the deadly fuel rods within the casks were not damaged during their 5 years in the reactor, or the 5 to 25 years in the spent fuel pool, or during transfer into the casks.

The NRC further assumes that approximately three "interim storage facilities" will open across the country during the next century to "temporarily" hold the waste until a "permanent geologic repository" is established -- something just like Yucca Mountain, but feasible. The NRC assumes that transporting the fuel to these facilities will always be done safely -- well over 100,000 trips will be required around the country just for the existing fuel, with an average trip distance of close to 1000 miles (more if less than three interim facilities are established). 90% of the American population will be within 50 miles of a transportation route -- and 50 miles might still be too close, if something goes wrong during the transport of the fuel.

The most insidious evil in this "Waste Confidence" process is that the NRC assumes that what they need to do is create regulations that allow the reactors to continue to operate. It does not occur to them what is obvious to so many others: There IS no solution to the waste problem, because ionizing radiation destroys any container you put it in. It escapes with tenacious capability and remains hazardous for many eons. It renders anything near it radioactive and poisonous as well. It kills in microscopic quantities. It maims and sickens whom it does not kill. And we have no safe place to store it. And there are clean alternatives for electricity generation. So why not just stop making more of this waste altogether? The NRC, most of all, should be able to see that that's the only solution to the waste confidence problem: Limit the size of the problem.

If we stopped now, then at most we would need ONE interim storage facility where three were planned by the end of the century. If we stopped now, then in 88 years, in 2100, the youngest fuel would be 88 years old and far safer if an airplane hits it, if a terrorist launches a missile at it, or if it simply degrades and falls apart. Fresh, hot fuel is so dicey, and for what? To keep the fat cat shareholders who own the reactors rich? Certainly not to keep the lights on -- that could be more easily accomplished through safe, green alternatives!

So why are we burdening our future generations with an ever-growing, unsolvable problem?

Ace Hoffman, Carlsbad, California USA


Subject: Re: fuel rod temps

At 12:57 PM 12/31/2012 -0800, an Orange County reporter asked:
>Hey Ace,
>I'm interest in heat. The maximum fuel temperature in a PWR reactor is about 650 degrees C ( 1,202 F). How hot is a fuel rod or fuel rod assembly when it goes into the cooling pool and when it comes out of the pool? How hot does it remain in the dry cask?



Hi,

Answers: Extremely hot, very hot, and just plain hot, hot , hot.

Wikipedia says: "About 1 hour after shutdown, the decay heat will be about 1.5% of the previous core power. After a day, the decay heat falls to 0.4%, and after a week it will be 0.2%."

The document linked to below has this sentence (on page 46): "In-reactor, the pellet temperature can be as high as 1,700°C at the center of the pellet, decreasing to about 400°C (the regulatory guidance limit) at its rim or outer boundary."

On page 76 it says this about dry cask storage: "In general, cladding temperatures are expected to drop from about 400ºC to 100ºC over the first 10 years (assuming 30 GWd/MTU burnup, 5 year cooled fuel), with the temperature remaining at about 100ºC for the next 90 years."

The residual radiation produces the heat, of course.

The document also talks about all the many ways the fuel gets deformed in the reactor: Thermal stress, swelling from built-up fission products within, stress corrosion cracking, etc.. It mentions that the fuel rods are pressurized with helium when they are manufactured and then as they are used in the reactor, gaseous fission products increase the pressure even more, up to about 600 psi or more (page 49.) Later (page 59), it says that in the pool, "The internal rod pressure at room temperature is typically 3–7 MPa (440-1,000 psi)." I presume by "room temperature" they mean the temperature of the circulating water in the pool, which, they say, is about 40 degrees C (page 60). Poor water chemistry can cause additional fuel degradation.

Regarding the long-term: "Whereas used-fuel design flaws for reactor performance can be discovered by studying fuel failures in-reactor, there is a small chance that design flaws for very long-term dry-storage and transport performance will not be discovered for decades or longer." (page 52.)

The temperature of the fuel cladding in the dry casks can be as high as 350 degrees C (page 61). The NRC has suggested limits of from 400 to 570 degrees C, but I guess they're not sure where to set the limit so they haven't.

There are a lot of "unknowns" in dry cask storage, but there can be no doubt it's dangerous and we want as little of it as possible in SoCal!!

Yours,

Ace


From: http://www.nwtrb.gov/reports/eds_rpt.pdf
This review finds that fuel rods discharged from nuclear power plants are typically in good condition with only a very small percentage of rods having cladding defects. Early references reported that less than 0.04 percent of fuel rods failed, and later plant records indicate that the failure rate has decreased to less than 0.0005 percent for more recently discharged fuel. During preparation for transfer to dry-storage facilities, failed fuel assemblies are loaded into specifically designed compartments of the canisters or metal casks, separate from intact fuel assemblies.

The fuel-drying process is not perfect. After drying, residual water remains in unknown amounts that can affect subsequent internal degradation processes. The vacuum-drying heat cycles can change the nature of the hydrogen in the cladding and stress the fuel.

According to the literature review, the fuel, the dry-storage system components (canister, cask, etc.), and the concrete foundation pad may all degrade during dry storage. Some degradation mechanisms may be active during the early years of dry storage, while different mechanisms may be active at the lower temperatures that would be expected during extended storage.

The most significant potential degradation mechanisms affecting the fuel cladding during extended storage are expected to be those related to hydriding, creep, and stress corrosion cracking.

These mechanisms and their interactions are not well understood......


12/17/2012

Gary wrote:

"Dry cask storage is the first step towards hardened on site storage, HOSS, which I believe is preferred by most experts."

My response:

First of all, there is no room for HOSS at SanO. That's been affirmed many times by "experts."

Second, there are many different versions of hardening dry casks. However, our dry casks have essentially NO hardening against airplane strikes or terrorists. Spent fuel pools are better protected against both, in part by being between the domes. 4 foot thick reinforced cement walls help, too.

Third, there are essentially no "bunkers" for the dry casks. Actually, it's more like a TENT right now!

Fourth, if it's a "step" towards HOSS, then it means additional transfer operations (plural), introducing additional expenses, complications, risks, and exposures.

Fifth, again: If the reactors remain open, or even just in a state where they can be reopened when the political climate changes, then we aren't choosing between dry casks and spent fuel pools, we are choose both, with more and more dry casks forever.

And sixth, there are no "experts" in nuclear waste storage. NOT ONE. There is no solution, only temporary holding places. Seriously: There are no experts in this field. There are no experts at Fukushima. It's a marvelous new science with lots of opportunities: The science of post-accident cleanup is a part of the science of nuclear waste management. It builds on sciences like metallurgy and thermodynamics and many others, such as robotics: all relatively new sciences themselves -- at least, in terms of the learning curve. But we do know that ionizing radiation can destroy any chemical bond known to man (by definition), so, nothing we build will last forever. 300 years is a pipe dream for dry cask storage, and less than 0.001% of the actually storage time needed.

One dry cask contains millions of pellets of fuel. Each pellet contains "countless tens of thousands" of potentially fatal cancer doses which, in the case of the plutonium, can kill over and over with a 25,000 year half life.

Dry casks are exactly what Southern California Edison needs to keep going, since Yucca Mountain is probably dead (and certainly should be). Dry casks are relatively cheap at about a million bucks each -- about 20 times cheaper than an additional spent fuel pool might be, if they could build one today -- and some people think they're effective.

Ray Golden, former spokesperson for SanO and a highly skilled liar, claimed the dry casks would be effective under up to 50 feet of water. Of course, that assumes a tsunami they claim can't happen here. He never said what size airplane they could withstand, because the answer is: A piper cub, that's about it. They are also vulnerable to terrorism.

Shut down is what we are about. We should not be distracted into supporting dry cask storage -- which, by the way, has been reported by whistleblowers to have welding problems right here at SanO, so they might not even be as good as the utility claims (ours are a unique design -- and remember how well that worked out for the SGs!). Other whistleblowers have reported other problems around the country (Google Oscar Shirani).

Dry casks are not needed. A very deep, very many layers-lined spent fuel pool at ground level is a much, much safer alternative, especially if it is multiple pools so not too much fuel is in each one. Too expensive? Nobody said this would be cheap!

A combination of both is something someone suggested to me many months ago. But truly, NONE OF THESE SOLUTIONS ARE ADEQUATE for the task, and that's the main point everyone should remember. And if restart occurs, then we have to restart the clock for 5 more years before all the fuel is cooled enough for dry casks.

I wish some of you had been around when dry casks were first being planned here at San Onofre. Because back then, some activists supported it just as those same activists do today -- because they saw dry casks as the lesser of two evils, the main problem with the other evil being that the pools are too full, not that they are, in and of themselves and properly designed and loaded, more dangerous. Overcrowded pools, it has been argued, are more dangerous. But there is more than one way to not overcrowd the pools. Shutting down is a very good way.

Dry casks aren't the lesser of two evils: They are just another evil, piled three high here at SanO.

Even if you like the idea of hardened, dry storage -- for whatever reason -- what they are doing here at SanO with the crowded dry cask farm is an abomination.

Ace Hoffman, Carlsbad, California USA

My July 2012 ppt presentation on dry casks, called "How to deal with spent fuel fires":
http://animatedsoftware.com/environment/no_nukes/2012/NuclearFuelFires.pdf


Ace Hoffman
Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Email: ace [at] acehoffman.org
Founder & Owner, The Animated Software Company



Press Release + 13-01-02 Supplemental: NRC Region IV AIT Team’s SG Review Requires Another Immediate NRR Investigation

Press Release + 13-01-02 Supplemental To Our Press Release + 12-12-31


The DAB Safety Team: January 2, 2013

Media Contact:
Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261


The NRC AIT Team's Review Of The SONGS Original Steam Generators (OSGs) And Their Replacement Steam Generators (RSGs) Requires Another Immediate NRR Investigation




The DAB Safety Team has transmitted the following to the Chairman of the NRC, Offices of Nuclear Regulator Regulations, Atomic Safety Licensing Board and NRC AIT Team Chief.

NRC Office of Nuclear Reactor Regulation has requested Edison in a December 26, 2012 letter the following additional information (RAI #32): "Please clarify how the information submitted by SCE demonstrates: (1) that the structural integrity performance criterion in TS 5.5.2.11.b.1 is met for operation within current licensed limits up to the licensed Rated Thermal Power (RTP or 100% Power), or (2) provide an operational assessment that includes an evaluation of steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP."


OSGs Design:
The SONGS OSG design had shown to be susceptible to out-of-plane tube through-wall wear and severe corrosion of the tube supports. The maximum Stability Ratio calculated by SCE Engineers in 2001 Power Uprate Application was 0.675 (< 1 so no Fluid Elastic Instability (FEI)).  According to Enclosure 2 of SONGS Unit 2 Return to Service Report, OSGs were operating at 1709 MWt (Reactor Thermal Power or RTP), vapor fraction (96.1%), Interstitial or gap velocity of 22.9 feet/second.


DAB SAFETY Team Comments. re: OSGs Design: The OSGs operated for 28 years, did not experience abnormal tube leak or tube-to tube wear (TTW) for operation up to 1709 RTP. No FEI occurred (stability ratio <1).  Furthermore, the OSG FSAR analyses demonstrated that the offsite radiological release doses due to an OSG tube rupture, main steam line break or an inadvertent opening of an OSG Atmospheric Dump valve with single active failure were at the time, well within the federal 10CFR100 guidelines.


SCE Profit-Motivated RSGs Design Changes: According to Enclosure 2 of SONGS Unit 2 Return to Service Report, the SONGS RSGs RTP specifications were changed to 1729 MWt.  To accommodate this additional 20 MWt, SCE engineers changed the vapor fraction (99.6%), Interstitial or gap velocity of 28.3 feet/second, added 377 additional tubes and increased the length of each tube by more than 7 inches.  NRC AIT Team report states, "SCE Design Specification SO23-617-1 did not address specific criteria for stability ratio and does not mention fluid-elastic instability."  Note: All these changes were made: (1) In a rushed "hush-hush" manner to generate extra profits for SCE and its Shareholders, (2) SCE Engineers prepared a defective 10CFR 50.59 safety evaluation hiding these numerous untested and unanalyzed changes under the pretense of "like for like" between the OSGs and the RSGs. Then they convinced NRC Region IV to review these without a formal NRC 50.90 License Amendment Process and Evidentiary Public Hearings.


NRC AIT Team review of SCE 10CFR 50.59: The NRC AIT Team stated in its report, "Based on the updated final safety analysis report description of the original steam generators, the team determined that the steam generators major design changes were reviewed in accordance with the 10 CFR 50.59 requirements.  The team determined that no significant differences existed in the design requirements of Unit 2 and Unit 3 replacement steam generators.  Based on the updated final safety analysis report description of the original steam generators, the team determined that the steam generators major design changes were reviewed in accordance with the 10 CFR 50.59 requirements.  The NRR technical specialists reviewed SCE's 10 CFR 50.59 evaluation against 10 CFR 50.59(c)(2)(viii) which requires that licensees obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change if the change would result in a departure from a method of evaluation described in the final safety analysis report (as updated) used in establishing the design bases or in the safety analyses.  The NRR technical specialists found two instances that failed to adequately address whether the change involved a departure of the method of evaluation described in the updated final safety analysis report." (emphasis added)  The changes were as follows:  (a) Reactor Coolant System Structural Integrity - Use of ABAQUS Computer Program instead of ANSYS: SCE's 50.59 evaluation incorrectly determined that using the ABAQUS instead of ANSYS was a change to an element of the method described in the updated final safety analysis report did not constitute changing from a method described in the updated final safety analysis report to another method, and as such, did not mention whether ABAQUS has been approved by the NRC for this application.   (b) Main Steam Line Break Mass-Energy Blowdown Analysis & Tube Wall Thinning Analysis - Use of ANSYS Computer Program instead of STRUDL and ANSYS Computer Programs:  SCE's 50.59 evaluation did not mention whether the method has been approved by NRC for this application.



The DAB Safety Team's Comment's re: SCE RSGs Catastrophic Design Changes:
About a year ago, on January 31, 2012, in SONGS Unit 3, one tube started leaking radioactive coolant in one of brand new replacement steam generators (RSG's) E-088 that was reverse-engineered by SCE and manufactured by a complacent Mitsubishi Heavy Industries (MHI).  The leak started small, but increased enough in a very short period of time to warrant the emergency shutdown of the reactor.  When tested later (in March 2012), eight (8) steam generator tubes (wear range 72-100%, length of wear 23-34 inches) in the newly replaced San Onofre Unit 3 RSG E-088 failed "in-situ" main steam line break pressure testing and therefore were plugged, after only after 11 months of operation, something that had never happened before in the history of the US Nuclear fleet.  Additionally, several hundred of the Alloy 690 Thermally Treated tubes were also plugged due to tube-to-tube wear.  SONGS RSG's now have more damaged and/or plugged tubes than all the rest of the US reactor fleet combined.   Southern Californians were very lucky, because a potentially serious nuclear accident in Unit 3 was narrowly avoided.  This accident could have potentially caused a nuclear meltdown and threatened the health and safety, economy and environment of Southern California. NRC website also states, "The severity of one of the wear indications at a Unit 2 (steam generator tube to*) retainer bar was significant enough (90 percent thru-wall) to warrant in-situ pressure testing. This pressure test confirmed the structural integrity of this tube (there was no leakage)." This means that Southern Californians lucked out again, because Unit 2 just happened to be shutdown for refueling, otherwise, this tube could have also leaked radiation due to any design bases accident or unanticipated transients. Finally, the NRC AIT Team displayed poor judgment in their review of SCE's 10 CFR 50.59 Evaluation and the NRR Specialists wisely questioned the inadequacy SCE's 10 CFR 50.59 Evaluation. The NRR now needs to review the NRC AIT Teams' failure to enforce NRC Regulations and find out what exactly happened to ensure the Public Safety.   * Wording added for clarification


DAB SAFETY Team Comments to NRR RAI#32: By operating the "Defectively Designed and Degraded" Unit 2 Replacement Steam Generators (RSGs) at 100% Reactor Thermal Power:


(1) SCE CANNOT DEMONSTRATE [with all the World's Expert's Assistance - emphasis added] that ALL in-service RSG tubes would retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, cool down and all anticipated transients included in the design specification) and design basis accidents in accordance with SONGS Unit 2 Technical Specifications structural integrity performance criterion in TS 5.5.2.11.b.1.


(2) SCE CANNOT PROVIDE AN ACCEPTABLE OPERATIONAL ASSESSMENT TO THE NRC, which demonstrates that steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP would not cause a tube leak in order to comply with Code of Federal Regulations, 10 CFR Part 50 Appendix A, General Design Criteria 14, "Reactor Coolant Pressure Boundary" shall have "an extremely low probability of abnormal leakage...and gross rupture."

Please See DAB Safety Team Paper Response to NRR RAI #32  - Technical for additional details. This press release will be posted on the web at this link: DAB Safety Team Documents.



###



ABBREVIATIONS AND ACRONYMS:

·      AIT: NRC's Augmented Inspection Team
·       AVB: Anti Vibration Bar
·       CE: Combustion Engineering, builders of SONGS original steam generators
·       CNO: Chief Nuclear Officer
·       DAB: DAB Safety Team
·       FEI: Fluid Elastic Instability
·       MHI: Mitsubishi Heavy Industry
·       MSIV: Main Steam (line) Isolation Valve
·       MSLB: Main Steam Line Break
·       MWt: Mega-Watts Thermal
·       NRC: Nuclear Regulatory Commission
·       NRR: NRC's Office of Nuclear Reactor Regulations
·       PVNGS: Palo Verde Nuclear Generating Station
·       QA: Quality Assurance
·       RAI: Request Additional Information
·       RSG: Replacement Steam Generator
·       RTP: Reactor Thermal Power
·       SCE: Southern California Edison
·       SG: Steam Generator
·       SONGS: San Onofre Nuclear (Waste) Generating Station (alternate abbreviation: SONWGS)
·       TS: Technical Specifications (for operation of a NPP)
·      TTW: Tube-to-Tube Wear

The DAB Safety Team: Don, Ace and a BATTERY of safety-conscious San Onofre insiders plus industry experts from around the world who wish to remain anonymous.  These volunteers assist the DAB Safety Team by sharing knowledge, opinions and insight but are not responsible for the contents of the DAB Safety Team's reports.  We continue to work together as a Safety Team to prepare additional DAB Safety Team Documents, which explain in detail why a SONGS restart is unsafe at any power level without a Full/Thorough/Transparent NRC 50.90 License Amendment and Evidentiary Public Hearings.  For more information from The DAB Safety Team, please visit the link above.

Our Mission: To prevent a Trillion Dollar Eco-Disaster, like Fukushima, from happening in the USA.

Copyright January 1, 2013 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team. The contents cannot be altered without the Written Permission of the DAB Safety Team Leader and/or the DAB Safety Team's Attorney



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

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

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

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

Monday, December 31, 2012

Press Release + 12-12-31 Office of Nuclear Reactor Regulations RAI #32 Request

Press Release (Condensed Version)


The DAB Safety Team: December 31, 2012

Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261



NRR Requests Additional Information on SCE's San Onofre Unit 2 Restart Proposal



The DAB Safety Team has transmitted the following to the Chairman of the NRC, Offices of Nuclear Regulator Regulations (NRR), Atomic Safety Licensing Board and NRC AIT Team Chief. 

NRC Office of Nuclear Reactor Regulation has requested from Edison in a letter dated December 26, 2012, the following additional information (RAI #32): "Please clarify how the information submitted by SCE demonstrates: NRRRAI#32(1) that the structural integrity performance criterion in TS 5.5.2.11.b.1 is met for operation within current licensed limits up to the licensed Rated Thermal Power (RTP or 100% Power), or NRRRAI#32(2) provide an operational assessment that includes an evaluation of steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP."


Answer to NRRRAI#32(1):
As shown in the linked Response to NRR RAI #32  - Technical
, by operating the "Defectively Designed and Degraded" Unit 2 Replacement Steam Generators (RSGs), SCE CANNOT DEMONSTRATE [with all the World's Expert's Assistance - emphasis added] that ALL in-service RSGs tubes would retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, cool down and all anticipated transients included in the design specification) and design basis accidents in accordance with SONGS Unit 2 Technical Specifications structural integrity performance criterion in TS 5.5.2.11.b.1.


Answer to NRRRAI#32(2): As shown in the linked Response to NRR RAI #32  - Technical, SCE CANNOT PROVIDE AN ACCEPTABLE OPERATIONAL ASSESSMENT TO THE NRC, which demonstrates that steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP would not cause a tube leak in order to comply with Code of Federal Regulations, 10 CFR Part 50 Appendix A, General Design Criteria 14, "Reactor Coolant Pressure Boundary—shall have "an extremely low probability of abnormal leakage…and gross rupture."
###

Press Release (Complete Version) + 12-12-31 NRR RAI #32 Request



Snip:


NOTE:
Here are the 14 most important questions that the DAB Safety Team feels must be answered before the NRC, Atomic Safety Licensing Board, NRC Offices of Nuclear Reactor Regulations and Nuclear Regulatory Research can complete their investigation regarding the reasonableness of the actions of SCE with respect to SONGS steam generator replacements and their subsequent safe operation:



1 - According to some Newspaper Comments and Industry Reports in 2004, the going price for each of the four 620 Ton CE Replacement Steam Generator (RSG's) was estimated to be between 175-200 Million Dollars (Per Piece). How did SCE CNO/President in 2004 convince MHI to build such large, complicated, innovative and complex steam generators for 569 million dollars, which is almost 130 million dollars short of the market price and funds approved by CPUC? 

Note: The steam generator project execution began in 2004 after a SCE cost-benefit analysis, which revealed that replacement of major parts and components would save $1bn for Southern California Edison customers during the plant's license period. Instead, the ratepayers have lost $1bn in less than 2 years due to SCE's in-house design team's mistakes.

2 - Since MHI only had experience building Fort Calhoun's tiny RSG's (less than 320 tons), how did the SCE Engineers Technically Qualify MHI for the much larger RSGs?

3 - Which other utilities' QA Programs did SCE use to approve Mitsubishi's quality assurance program? Fort Calhoun? French?  Belgian? Japanese?

4  - Why didn't SCE apply to NRC for increasing the plugging limit for the Original CE Generators, so they would have had more time to think, research and not rush according to the CPUC?

5 - Which Utilities' CE Replacement Generators did SCE benchmark to develop such detailed design and performance specifications or did they just modify the CE Old Generator Specifications with New Industry Information?  Were the SCE engineers, who wrote, checked and approved the new specifications steam generator experts or was another steam generator expert in the background, who directed all the SCE work?

6 - Where did all the claims of challenges, reward, innovations and teamwork between SCE and MHI go wrong?

7 - Were the SCE Engineers sent to Japan to check MHI work and approve documents/test results qualified in that exact field, or they were just in training and/or sightseeing?

8 - Who at SCE made the decision to make all these numerous design changes and determined the changes were "Like for Like" and did not need a Licensing Amendment Process?

9 - Which SCE Engineer(s) provided all these changes, information and documents to which NRC Engineer(s), who then made the decision that it was OK to proceed without a full Licensing Amendment Process?

10 - Which SCE engineer(s) approved/validated the MHI Thermal-Hydraulic FIT-III FIVATS code Inputs and Calculations?

11 - To make up for the 10% heat transfer equivalent by switching from Alloy 600 to Alloy 690, SCE needed to add 935 tubes, but they only added 377 tubes. What happened to the balance of 558 tubes?  Did the SCE Engineers tell MHI to increase the length of 9727 tubes and by how much, to make up for the 558 tubes?

12 – Why didn't the SCE Engineers question/independently verify/validate the MHI benchmarking of the FIT-III thermal-hydraulic model?

13 – Why didn't the SCE engineers contact their counterparts at PVNGS for information/advice, since PVNGS has the largest CE Replacement Generators (800 Tons) in the world, were built in early 2001-2005 and are currently still in operation?

14 - Were the original CE Steam Generators and new replacement generators exact in Thermal Output (MWt) or were there "minor" differences?



Under no circumstances should the NRC Region IV, Offices of Nuclear Reactor Regulation and Nuclear Regulatory Research*, and the NRC Atomic Safety Licensing Board permit SCE to restart unit 2 without re-tubing or replacing the defective replacement steam generators, along with a full NRC 50.90 Licensing Amendment and transparent trial-like public hearings.

* The DAB Safety Team would like to extend a Professional Compliment to the NRR for doing a thorough investigation on their review of the San Onofre Unit 2 Restart Proposal as indicated by their Request for Additional Information #32.



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 ABBREVIATIONS AND ACRONYMS:

·       AIT: NRC's Augmented Inspection Team
·       AREVA: Nuclear engineering firm owned by French Atomic Energy Commission
·       AVB: Anti Vibration Bar
·       CE: Combustion Engineering, builders of SONGS original steam generators
·       CNO: Chief Nuclear Officer
·       CPUC: California Public Utilities Commission
·       DABST: DAB Safety Team
·       FEI: Fluid Elastic Instability
·       MHI: Mitsubishi Heavy Industry
·       MSIV: Main Steam (line) Isolation Valve
·       MSLB: Main Steam Line Break
·       MWt: Mega-Watts Thermal
·       NRC: Nuclear Regulatory Commission
·       NRR: NRC's Office of Nuclear Reactor Regulations
·       PVNGS: Palo Verde Nuclear Generating Station
·       QA: Quality Assurance
·       RAI: Request Additional Information
·       RSG: Replacement Steam Generator
·       RTP: Reactor Thermal Power
·       SCE: Southern California Edison
·       SG: Steam Generator
·       SONGS: San Onofre Nuclear (Waste) Generating Station (alternate abbreviation: SONWGS)
·       TS: Technical Specifications (for operation of a NPP)
·       TTW: Tube-to-Tube Wear



This press release along with DAB Safety Team's Response to NRR RAI #32  - Technical  will be posted on the web at this link: San Onofre Papers.


The DAB Safety Team: Don, Ace and a BATTERY of safety-conscious San Onofre insiders plus industry experts from around the world who wish to remain anonymous.  These volunteers assist the DAB Safety Team by sharing knowledge, opinions and insight but are not responsible for the contents of the DAB Safety Team's reports.  We continue to work together as a Safety Team to prepare additional San Onofre Papers, which explain in detail why a SONGS restart is unsafe at any power level without a Full/Thorough/Transparent NRC 50.90 License Amendment and Evidentiary Public Hearings.  For more information from The DAB Safety Team, please visit the link above.

Our Mission: To prevent a Trillion Dollar Eco-Disaster, like Fukushima, from happening in the USA.

Copyright December 31, 2012: The DAB Safety Team. All rights reserved. This material cannot be published, broadcasted and/or redistributed without crediting the DAB Safety Team. The contents cannot be altered without the Written Permission of the DAB Safety Team Leader and/or the DAB Safety Team's Attorneys.

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