In Response to Your Letters: Proposed Restart of SONGS Unit 2

Over the past two weeks, the NRC has received a number of phone calls and emails from the local community and other concerned members of the public to voice their opinion regarding the proposed restart of San Onofre Nuclear Generating Station (SONGS) Unit 2. Thank you for expressing your concerns. We value your input and understand how important these issues are. We are continually working to enhance our engagement with the public.

While we cannot respond to each person individually, the NRC would like to assure you that your concerns are being heard and that we are approaching the issue of restarting SONGS very carefully. We are committed to learning what happened at the plant before considering any restart options.

On October 4, the NRC received a letter from Southern California Edison indicating that they have addressed issues raised by the NRC in a Confirmatory Action Letter. At the same time, the NRC also received a proposed action plan that recommends restarting Unit 2 at the San Onofre plant for an initial five-month period at reduced power. This restart would be followed by additional inspection.

The NRC will analyze Southern California Edison’s determination of the causes of the steam generator tube degradation and actions to prevent future degradation before making any decision on the proposed restart plan of Unit 2. The NRC will take as much time as is required to complete its inspection and analysis preceding any decisions about restarting Unit 2. Restart of SONGS will not be permitted until the agency’s thorough review is completed and the facility is safe to operate. The Commission is also considering a petition for hearing and request for a stay of any authorization for restart until the conclusion of the hearing.

The NRC will continue to provide opportunities for the public to be involved and informed. For updates on the San Onofre plant go the NRC web site.

Allison Macfarlane
NRC Chairman

Author: Moderator

Public Affairs Officer for the U.S. Nuclear Regulatory Commission

39 thoughts on “In Response to Your Letters: Proposed Restart of SONGS Unit 2”

  1. The results of Thermal-Hydraulic Computer models can vary as much as 200% depending the operational inputs and results of mock-up data. Some of these models simulate two-phase steam-water mixture sg side conditions using Homogeneous Equilibrium Models rather than hetrogeneous dispersion models. Computer simulations do not control the actual plant operating conditions. It is highly concievable that high localized vapor fractions, steam flows and velocities, Mitisubishi’s flowering effect, narrow tube pitch to tube diameter ratio caused insufficient contact forces between tubes and AVBs and fluid elastic instability in the SONGS Uniit 3 RSGs Tube-Bundle Centrallized region 20 inches above the 7th support plate in the Z direction. Use NRC’s Branch Chief advice reference earlier to find answer to all these questions. Insanity is repeating the same thing over and over again and expecting different results. NRC has been provided a unique opportunity and trust by Ratepayers and Taxpayers to ensure public safety and transparency and not violate this public trust by offering biased and favorable opinions for a INPO 4 Plant with the Worst Safety and Retaliation Record. NRC needs to be reminded that US Federal Government Promotes Human Rights, Democratic Institutions and Workers Respect throughout the World. NRC needs to become a Model Agency and follow Goverments’s Policies and Examples.

  2. NRC needs to use the advice of a NRC Branch Chief with MIT Intelligence and sixth sense [read and reread in between the lines and use a critical questioning and investigative attitude} and then independentely check the SONGS 2 & 3 Operational records to understand why SONGS Unit 2 suffered less damage than unit 3 in-the in-plane direction (e.g., Unit 2 were Operating at Higher Secondary Pressure, Void Fraction was @ 96%, Reactor thermal power was less. May be because of these factors, there was no localized superheat, fluid elastic instability, higher than normal steam velocities in the Central Region of the U-Tube Bundle 20 inches above the 7th TSP. This was the region of high wear in unit 3]. Unit 2 degraded RSGs with hundreds of plugged tubes, narrow tube pitch to tube diameter ratio, low clearances between U-Bends (0.050 inches, design = 0.25 inches), Active Tubes with 28% TTW, only 8 % vidsual inspection of the RSGs, will rupture and leak like a sieve due to 100% void fraction caused by a Main steam Line break Accident. Operational assessments prepared by three independent experts lack clarity and a clear conclusion. Lots of assumptions used without valid engineering and operational basis due to Time Pressure and Lack of Critical questioning and Investigative attitude..

  3. Has NRC Checked the SONGS Operational Records and Calculations to independentl verify that SONGS Unit 3 RSGS tubes did not leak because SONGS Unit 3 RSGS were producing more thermal power than 3438 MWe allowed by their specifications

  4. It seems by the language, that NRC has already pre-determined that SORE will start up again. It seems like a “just a matter of time” and all the public “engagement” is only for the purpose of showing an open ear, although the hands are already in action.

  5. Hydrogen could have come from several places such as the main generator. The generator is cooled with hydrogen (common for large generators like those used in nuclear power plants). Hydrogen leaks from this system are not uncommon. I spent about 3 days last outage working on a plan to identify and repair hydrogen leaks.

    This is NOT hydrogen from the reactor, and any attempt to call it such is simply incorrect. Additionally such hydrogen leaks are somewhat common and are seen fairly often in the industry.

  6. Reply: The NRC already has binding legal authority to prevent San Onofre from restarting; the reactors will remain shut down until the agency is convinced that available information supports restarting Unit 2; Southern California Edison has yet to submit a plan to restart Unit 3.

    Several groups have asked for a formal proceeding, or hearing, to offer legal arguments against SCE’s plan to restart Unit 2 before the NRC makes a decision on acceptability of restart. Under the current regulatory framework, a formal hearing is not required for the NRC to make a restart decision. The Commission is currently considering its decision on the groups’ request.

  7. It’s a shame the things that happened in the 70s, it really is. Some of the ways nuclear plants were maintained and operated was imply appalling, and it really kept up with most plants until the 90s (and some plants into the 2000s….there may even be a few still like that, but in all my experiences working in nuclear I haven’t seen them). I’ve had nothing but good experiences when it comes to safety concerns being communicated, well understood, and appropriately handled, but these are only the experiences of one person at a few plants.

  8. This isnt unique to SONGS. In about 2007 plants started making the change to the surveillance frequency control program (SFCP). SFCP uses NRC required/approved methodologies and requires a license amendment to implement, but once in place allows the program requirements combined with risk analysis and existing plant data to modify surveillance frequencies.

    This has many improvements for the plant, the NRC, and the health and safety of the public. For the plant, license amendments take over a year, and if a change is required, especially if it is a change to correct a non-conservatism, the frequency change is required to stay open that long. It not only counts against plant performance indicators, but it also makes it difficult to increase frequency if it is required due to changing plant designs or conditions. Additionally, the ability to use risk, data, and codes to modify and in some cases reduce the frequency of surveillances is a big cost savings. License amendments are usually over $100k, and for little changes (such as changing an instrument to a digital one which is more stable, and does not require calibration or testing on a 90 day basis anymore), it was making it hard to justify upgrading components. It also saves on costs of doing the test, and reduces wear on the plant and equipment. This also overlaps with public health and safety benefits. Many components in the plant, especially valves that are typically ‘hot’ like the RCIC isolation valves or recirc pump valves in a BWR, are known for passing surveillance testing successfully, but the thermal cycle on the equipment increases the change of a failure happening on the NEXT attempt to test the equipment. Thermal binding and packing leaks are NOT indicative of a good safety culture, and for valves which have low risk from a risk analysis standpoint, combined with a high frequency and confidence of passing tests, it makes just makes sense from a risk AND equipment perspective to only operate these in certain plant conditions (like cold shut down), where you can actually verify the functionality of the device without impacting the operational life or increasing the risk of a critical/safety component failure while the plant is online (and believe me, hot cycling isolation valves or systems is one way to greatly wear at your safety components). For the NRC, this reduces a lot of overhead because only surveillance changes that are outside of the program scope now come in as license amendments.

    tl;dr SONGS is doing something which has been established in the industry for a number of years and has significant financial and safety/risk improvements.

  9. My suggestion is to not hold your breath for either the independent earthquake studies or the evac drill being modeled…

    The NRC serves US but “in its own way”…

  10. Great Post… Salute!
    Perhaps you can post a link for that info, I’m sure many would be interested in reading more!

  11. RE: “philosophical biases and wild nightmares.” Perhaps you are thinking of how the Japanese Gov’t. is treating it’s Nuclear Refugees which are still living in refugee camps and are now paying for their Bento boxed food over a year and a half after Fukushima which will be a Trillion Dollar Eco-Disaster WITH NO END IN SIGHT!

    I suggest that you don’t talk down to those that are really concerned that something similar does not happen in the USA!

  12. Latest:
    FOR IMMEDIATE RELEASE: October 22, 2012

    CONTACT: Damon Moglen, Friends of the Earth
    John Large, Large and Associates

    SAN ONOFRE: Hydrogen gas leak from crippled reactor exposes danger of restart
    Friends of the Earth: Edison must immediately say if leak is radioactive
    WASHINGTON, Oct. 22 – A reactor at the crippled San Onofre nuclear power plant is leaking hydrogen gas into the environment, according to the U.S. Nuclear Regulatory Commission. Although it is not yet known if the leaking gas is radioactive, Friends of Earth said the latest trouble at San Onofre is strong evidence that the plant is not safe to restart.

    According to an NRC bulletin issued Sunday, an unknown quantity of hydrogen gas is leaking from Reactor 2, which like Reactor 3 has been closed since a leak of radioactive steam in January and the discovery of severely damaged steam generators. The NRC did not say what caused the leak.

    “There are critical questions that Edison must answer immediately,” said Damon Moglen, energy and climate director at Friends of the Earth. “Is the leaking hydrogen radioactive? And was the leak caused by heating up the plant’s steam generators in advance preparation for restart? Edison keeps saying safety is its priority, but it’s clear that the San Onofre reactors are not safe to operate.“

    Both the California Emergency Management Agency and San Diego Department of Environmental Health were notified of the leak Sunday morning.

    Earlier this month, Edison filed a plan to restart Reactor 2 at 70 percent power and run it for five months to see whether it is safe to restart permanently. The NRC says it will take months to decide whether to allow restart.

    This past weekend, Edison was conducting tests that include bringing the reactor to normal operating pressure and temperature, using offsite electrical power. The steam generators will be hot and pressurized. The leak is likely to persist for some days, as the only way to stop such a leak is to depressurize and lower the temperature of the reactor and its coolant system. This is a delicate operation that must follow rigid safety rules to avoid further damage to the reactors.

    “This has all the signs of a bungled and hurried preparation to bring San Onofre Unit 2 back to power,” said John Large, a London-based nuclear consultant. “Depending on the extent of damage to the reactor this could be a further setback to Edison’s plans for an early restart.”


  13. NRC, in a nutshell, let fact and prudent engineering rule your decision over fear, philosophical biases and wild nightmares.

    James Greenidge
    Queens NY

  14. Great Question we need answered ASAP, since SCE IS NOW RE-PRESURIZING its damaged RSG, with radioactive core coolant as we speak! NOW, a MLS rupture could spell nuclear disaster!

  15. The Safety Design Ethos of Nuclear Industry
    “In his excellent book “The First Nuclear Era”, Weinberg relates a discussion he in 1972 with Rep. Chet Holifield, which left him “speechless” after Holifield warned him “Alvin, if you are concerned about the safety of reactors, then I think it may be time for you to leave nuclear energy”. Weinberg succinctly states “I had never been fired before.” (Source: Morgan, “The Angry Genie”, pp 72.

    A bit less dramatic than Holifield’s threat (chair of the Congressional Nuclear something or other bullshit sessions in Washington) to John Gofman. Holifield threatened “to get Golfman.

    Later, Gofman survived the threat, though he lost his funding. He, along with Carl Morgan, took part in the legal case resultant from Karen Silkwood being run off the road in her Honda enroute to giving key documents to her union. The documents related to proof of faulty plutonium fuel rods.


    Changes remove inspection specifications from license, reducing public and NRC review and clouding operator requirements, watchdog group says

    October 20, 2012 (Washington D.C.) — Citizens’ Oversight, an El Cajon-based citizens watchdog group, submitted a formal request[1] to the U.S. Nuclear Regulatory Commission (NRC) regarding a license amendment request[2] by Southern California Edison (SCE) for the San Onofre Nuclear Generating Station (San Onofre).Raymond Lutz, Electrical Engineer and Founder of Citizens Oversight, prepared the petition to intervene based on a review of the proposed changes to the operating license of San Onofre. These changes to the license do not directly reflect on the recent emergency shutdown on January 31, 2012, and furthermore, is not in response to the proposal by SCE to operate San Onofre Unit 2 at a lower power level despite massive and severe damage to the steam generator tubes due to excessive vibration.

    Instead, the proposed license amendment makes a large number of changes throughout the technical specifications of the operating license. Most of these changes are quite similar in nature: they remove explicit requirements for inspections from the operating license and move these to a separate document which is no longer under the control of the NRC, but is under the control of the licensee.

    For example, in the original specifications document, SR states that the operator must “Verify the secondary side water level in the required Steam Generators (SGs) is >50%,” and this must be checked every “12 hours.” The modified license deletes the explicit specification “12 hours” and substitutes “In accordance with the Surveillance Frequency Control Program.” That program allows the licensee to decrease the frequency (i.e. increase the maximum period between inspections) without direct NRC or public review.

    COPS believes these changes unnecessarily obfuscates the specification and puts inappropriate trust in the licensee to keep the inspections at a safe level. They rely on the Surveillance Frequency Control Program (SFCP) which utilizes Probability Risk Assessment (PRA) calculations using a set of preconceived failure modes. Such analyses are subject to well understood knowledge-based failure mechanisms of “overconfidence” and limited failure scenarios known to underestimate the variety of failure mechanisms.

    An argument will be made that the specifications of surveillance frequencies have not changed, since the values of maximum time period between inspections will initially be the same, the fact is that the licensee can vary these periods without any review by NRC or the public thereafter, and there are no “not-to-exceed” values specified in the specification. Furthermore, moving these values to another document obfuscates actions required by the licensee and may induce operator error as workers search for the correct value in multiple documents.

    COPS also objects to the removal of the requirement to have a backup Atmospheric Dump Valve (ADV) from the license specification. Apparently, the plant has violated this requirement for years, and instead of dealing with it with appropriate mitigation measures, SCE proposes that the ADV requirement be deleted from the specification entirely, and suggests that eliminating this required redundancy does not impact safety, which is incorrect.

    COPS also objects to many other changes proposed, including allowed leakage from the steam generators into the atmosphere, the fact that the isolation area around the plant is not enforceable, and numerous specification mistakes.

    To the knowledge of COPS, no other organization is actively objecting to the license amendment request.

    “The changes proposed further obfuscates the operating license and puts more trust in the operators of the plant instead of requiring regulatory agency and public review,” said Raymond Lutz, author of the submission to the NRC. “After the egregious mistakes by Edison in the recent steam generator replacement project, we need to put a stop to further reliance on the good intentions of the operator and maintain our options to provide needed oversight to these dangerous plants.”

    The petition to intervene was filed prior to the deadline on October 17, 2012, and was submitted electronically using the Electronic Information Exchange. The request for hearing and petition to intervene was submitted in response to the publication of the NRC Staff’s “Notice of Opportunity for Hearing,” in the Federal Register at 77 Fed. Reg. 49,463, on August 16, 2012. The request is located in ADAMS and also in the EHD as accession number ML12291B227.

    Citizens’ Oversight is funded by membership dues and donations from the public and appreciates contributions from the public to help defer costs in executing this process. More information can be found at

    [1] – “Review of SONGS License Amendment Request by COPS; Petition to Intervene and Request for a Hearing” —

    [2] – NRC Proceeding San Onofre 50-361 and 50-362-LA, “Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination.” —

  17. Nuclear power can be safe; given the right technology, a robust facility, and the right location. San Onofre meets none of these criteria. The chance of a nuclear incident at San Onofre is not insignificant given the age of its technology and its location on an earthquake-active coast line. A major or even minor nuclear disaster in a densely populated area would politically eliminate nuclear energy production in the U.S. for generations to come, at a moment in history when carbon-free nuclear energy is most needed to combat global warming.

  18. I appreciate the NRC posting the SONGS restart plan right on the front page of the website. The 1200ish page long document details very clearly all of the mechanisms which caused tube wear and plans to correct the tube wear. It also contains very clear data which shows how tube wear can be minimized. I hope concerned members of the public at least review the summary of the plan to understand the engineering principles involved with the restart plan.

  19. I am very concerned. I don’t trust that their recommendations for restart are based on anything past profits. This is an old reactor with serious mechanical issues that have not been addressed. This is earthquake country and this reactor is in close proximity to 8 million of us who could not possibly “get out of here” on the 405. San Onofre was built prior to the discovery of many additional fault lines and to a standard that no longer exists. Even if this plant were up to the same quality standard as when it was built, it would not withstand a 7.0, which is likely. And…’s is in the midst of 8million folks who can’t escape it’s aftermath. Needs to be looked at seriously for shut down.

  20. I am concerned as a resident and homeowner in this area. I am worried about the condition of this aging and cobbled reactor in optimal conditions. I want to see a detailed and unbiased analysis of what would occur, or what could occur in the event of earthquakes at X fault lines at X magnitude. This reactor was built to a standard that is much lower than the risks today and long before several of our known faults were identified. I would also like to see a simulation of the evacuation plan of these 8 million folks getting on the 405 directly after an earthquake. Sounds like a scary situation! Shut her down until you can assure the public of the safety under ALL foreseeable conditions.

  21. The 2007 Working Group on California Earthquake Probabilities (WGCEP 2007), a multi-disciplinary collaboration of scientists and engineers has produced the Uniform California Earthquake Fracture Forecast, a study organized by the Southern California Earthquake Center, the U.S. Geological Survey and the California Geological Survey with major support from the California Earthquake Authority. The three-year study forecasts a 37% probability for a magnitude 7.5 or greater earthquake to occur in Southern California in the next 30 years. Such an earthquake would be of a much geater magnitude than what San Onofre Nuclear Generating Station (SONGS) was designed to resist when it was built over 30 years ago.

    Given the potentially catastrophic outcome of the plant’s failure due to an earthquake to an entire region and to millions of people, SONGS’ seismic safety should be the first thing to be determined in considering the plant’s reopening. If the plant, its support and safety systems and its storage of thousands of tons of radioactive waste are not seismically safe to resist earthquakes of the magnitudes predicted, the plant should be decommissioned immediately. Any studies, tests and posiible repairs of the steam generators are irrelevant and a waste of critical time and millions of dollars.

    Ricardo Nicol, San Clemente

  22. Allison Macfarlane says “…moderation/posting is glacial…” I have one short question for Ms. Macfarlane: Do you understand just how glacially-global will be the effects of all these vented radionucleides on “our” DNA. DNA damage is not merely glacial, it is forever!

  23. Dear Chairwoman Macfarlane,

    Can you please elaborate on these two sentences above: “Restart of SONGS will not be permitted until the agency’s thorough review is completed and the facility is safe to operate. The Commission is also considering a petition for hearing and request for a stay of any authorization for restart until the conclusion of the hearing.”

    I don’t follow why the NRC might also need a stay of any authorization for restart if in the previous sentence there is a clear assertion that restart “will not be permitted” until…?

    Does that indicate that there may be a procedure by which the operator could restart without explicit NRC permission, and therefor the NRC might need added legal measures to prevent that?

    Does that indicate that the NRC is reserving the right to permit restart of San Onofre without any hearings?

    Thank you in advance for any help you could provide to clarify this to a local resident (who isn’t versed in the important refinements of the highly customized language of your industry).

  24. It is morally, ethically and financially irresponsible to be producing nuclear waste when we have no way of safely disposing it. Are we really going to leave this mess for OUR children to clean up? When nuclear power was developed, before I was born, that is what the solution was: We will leave it for the future generations to figure out. Well, we still haven’t figured it out and I WILL NOT leave it for my children to solve. We are lucky that we have made it as far as we have. Nuclear power was and is a bad idea. Let’s admit it and move on while we still can. ENOUGH IS ENOUGH. Do the right thing. DECOMMISSION NOW.

  25. Salute
    I could not have said it better myself!

    I predict that the public’s perception of the NRC will be defined by how fast the NRC makes the decision to decommission San Onofre!

  26. Good Idea, why Region IV puts up with San Onofre’s worst in the USA record is a question that needs answering!

  27. Sorry for using the wrong reply button!

    Region IV NRC needs to step up its enforcement so that none of its reactors are never again the worst in the USA, like San Onofre is and has been for far too long!

  28. I really enjoyed your book despite the fact that it could happen all to easily in SoCal!
    I even got the free kindle update yesterday!

  29. Great Comment Salute!
    Looking forward to shaking your hand at the fully transparent adjudicatory hearing…

  30. I live within 17 miles of the defective Southern California Edison Nuclear Generation Station. If this plant is reopened as the ” experiment ” Edison is calling for, and a disaster happen –fmost certainly I would lose my home, potentially my life..and the lives of my family. There is a population of 8 plus million people within 50 miles of this defective plant. They are in harms way if, and when Edison’s ” experiment” fails. The nation would also lose its largest port at Long Beach/San Pedro . The nation would be crippled.

    I have attended the last seven years of NRC reviews/meeting over Edison’s Nuclear plant. Consistently Edison has/have failed to perform in an acceptable manner. This resulted in the issuance of the “Chilling Effect Letter ” iby the NRC. Edison has a track record of falsification of health and safety records.
    Edison can not be trusted—decommission the plant before a national disaster occurs.

  31. In 1975 I lived in the San Onofre area. As a college educated person with a science degree I was concerned about the safety of the plant. I was so concerned that I wrote a fiction novel predicting what I thought could happen in the event of an earthquake – fuel rods being jammed into a fixed position, meltdown of the nuclear fuel, failure of the surrounding people being able to evacuate, lack of knowledge as to what paths to follow, radiation exposure, etc. And guess what – the Fukushima nuclear disaster proved my predictions correct. Don’t you think it is strange that someone could so foresee what was going to pass that it was accurately predicted over 35 years ago? And the type of plant design that Fukushima has exists here in the United States – where we do have earthquakes. Now the nuclear plants are 35 years older. It is just a matter of time until this happens again in the United States. Barbara Billig, author of “The Nuclear Catastrophe”, a fiction novel of survival.

  32. Dear NRC Chairman Macfarlane, NRC Commissioners, and NRC Staff:

    The decision to restart the badly damaged nuclear reactor Unit #2 at San Onofre is far too important to be decided at the staff level. This crucial decision needs to come before an administrative law judge in a fully transparent adjudicatory hearing. This hearing needs to be part of a thorough license amendment process due to the obvious physical and operational differences between the original steam generators and the rapidly failed replacement steam generators. The experiment of restarting and running a damaged nuclear reactor unit in the middle of 8.4 million unsuspecting and poorly informed people, could negatively impact far more than Edison’s facility and that is the crux of the public’s outrage.
    The public does not trust the NRC’s decision making structure and does not believe your risk assessment models are based on the reality we are seeing unfold at Fukushima, or on the reality of medical evidence regarding negative public health impacts of radioactive fallout. The public sees the NRC as a captured regulatory agency that functions as an extension of the nuclear industry with little regard for public safety and no regard for our homes and businesses that could be caught downwind of a radioactive plume.
    The surrounding communities are not economic externalities as the NRC and the industry would like to believe, and as the NRC has reinforced with the Price Anderson Act. The ridiculously small and inadequate 10-mile EPZ around the power plant illustrates clearly that public safety is not your priority. Ironically, we the public are the ones who pay for the power plant and the plant’s improvements as ratepayers and taxpayers, yet our well-being is of little concern to Edison or the NRC. Only a poorly regulated investor owned utility monopoly can exist with this business credo. In a competitive business environment Edison would have been driven into bankrupt years ago by more innovative energy companies promoting safer energy options. We need you, the NRC to regulate this facility propertly.
    Ultimately this entire steam generator fiasco will be paid for with ratepayer money, or taxpayer money if there is a nuclear accident, so ratepayers and taxpayers should in principle have a say in this critical restart decision. The public is demanding an adjudicatory hearing and full license amendment process with independent experts testifying and cross examining Edison’s experts under oath, to address the current crisis at San Onofre.
    Southern California Edison should not be allowed to risk the homes and businesses worth thousands of times more than the power plant (ironically owned by Edison’s own ratepayers) in the five surrounding counties, by restarting a dangerous facility that the region does not need. This defies common sense and good business sense. Granting approval for restart would illustrate terrible NRC policy to risk an accident no matter how small or large, at a time when the nuclear industry’s reputation is heavily tarnished by the recent nuclear disaster in Fukushima.
    We urge you to use your common sense, the lessons of Fukushima, your knowledge of the many safety issues at San Onofre, and the considerable amount of independent expert reports, whistleblower concerns, and widespread public outrage, in order to deny the restart of damaged nuclear reactor Unit #2 upwind of the 8th largest economy in the world.


    Torgen Johnson

  33. The DAB Safety Team’s – Update 10-14-12, SCE’s Replacement Steam Generator $680 Million Debacle

    1. If SCE’s and MHI’s Engineers had used all the following guidelines, they would have prevented the
    Replacement Steam Generators (RSG’s) catastrophic failures and they would not be in financial trouble with the SONGS Union Workers, the NRC, the Public, the News Media and their Ratepayers:

    • Human Performance Tools, along with the NRC Branch Chief and World’s Foremost Expert’s sage advice of “read between the lines’, ‘use critical questioning & an investigative attitude’, ‘solid teamwork & alignment, and ‘read the academic papers on eliminating fluid elastic instability and flow-induced vibrations in nuclear power plant components.”

    • Benchmarked the design details of Palo Verde and other CE RSGs design details in order to eliminate any potential fluid elastic instability and or flow-induced vibrations experienced in the SONGS CE Original Steam Generators (OSGs), so that they would not occur in their new RSG’s.

    2. SCE should have embraced rather than bypassed the FULL NRC Licensing Amendment Process.

    • SCE “Sweet Talked” NRC in accepting the results of Inadequate Industry Benchmarking and the Defective 10 CFR 50.59 Evaluation and thus avoided the thorough and lengthy scrutiny of FULL NRC 10 CFR 50.90 Licensing Amendment Process.

    • Note, the lack of strict oversight by Region IV NRC Staff as required by NRC Reactor Oversight Process, was a critical flaw that enabled the debacle.

    What is needed to prevent the adverse consequence of a Main Steam Line Break outside Containment and the resulting nuclear radiological disaster in Southern California, if SCE’s Degraded Unit 2 is allowed to restart at 70% power for an operations trial period of 5 months as an, “Unapproved Experiment”, as SCE and 3 out of 4 Nuclear Energy Institute Qualified “US Nuclear Plant Designers” are recommending?

    1. Submittal of a NRC 10 CFR 50.90 Licensing Amendment Application for SONGS Unit 2 Restart Plan by SCE.

    2. A thorough review of SONGS Unit 2 Restart Plan Return to Service Report by Region IV NRC Staff, NRC Chairman and Commissioners, U.S. Senate Committee on Environment & Public Works, and independent verification/ by the NRC Offices of Nuclear Reactor Regulations, Nuclear Regulatory Research1 and the Union of Concerned Scientists.

    3. Sworn testimony by all parties responsible for the preparation of SONGS Unit 2 Restart Plan Return to Service Report to insure that public safety and health will not be compromised in case of a nuclear Accident caused by a Design Bases Earthquake/Main Steam Line Break due to multiple tube leaks or ruptures or combination thereof.

    4. Investigation of SONGS Safety Violations and Worker Discrimination, Retaliation, Intimidation and Harassment by an Independent Federal Commission appointed by the President or the Supreme Court of the United States. This is required to guarantee public acceptance of the results these investigations by the people of Southern California.

    5. Return of the 1.2 Billion Dollars that the ratepayers have “fronted” SCE to date, with interest.

    6. A Financial Bond Guarantee by Southern California Edison to cover the Financial Ruin of Southern California’s economy in case of any nuclear Incident/Accident.

    1Dr. Joram Hopenfeld, a retired engineer from the Office of Nuclear Regulatory Research, sharply criticized NRC officials for downplaying the dangers of degraded steam tubes in December 1999, three months before the Indian Point accident, and said, “To be credible, risk-informed regulation mandates statistically valid and scrutable data, competent insights of accident scenarios and their consequences, and of accident prevention strategies, as well as meaningful public involvement. In reality, the staff examines accident scenarios and their consequences in a superficial manner; accident prevention is apparently dictated primarily by financial considerations, and the public is being excluded from meaningful participation in the NRC deliberation process’, ‘The nuclear industry and the NRC have a poor track record of controlling steam generator tube degradation.” The NRC’s Advisory Committee on Reactor Safeguards (ACRS) issued a report in February 2001 and substantiated many of Dr. Hopenfeld’s concerns.

    Copyright October 14, 2012 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team.

  34. Since San Onofre has the worst record of Safety Violations, Worker Discrimination, Retaliation, Intimidation and Harassment of any US reactor, I also think it would be smart of the NRC to position some additional inspectors (from different NRC Regions) to augment the NRC on site inspector, that way both SCE and San Onofre would really get inspected, instead of just another PASS…

  35. At some point, the NRC needs to be able to say, “enough is enough” and shut a broken reactor down for good. The economics aren’t there if the waste issue is taken into account, or the accident recovery costs that might be incurred at any time — including the moment SCE raises the power level to the guessed-at supposedly-safe value of 70% of millions of horsepower in heat, pressure, and flow rates… why risk it? I have attended dozens of meetings throughout Southern California regarding these steam generator issues: SCE representatives have ALSO attended dozens of these meetings, and presented their case at many of them. The NRC is NEVER at these meetings. So the NRC doesn’t hear the lame answers the SCE representatives have for mayors, council members, interested outside experts and the public, telling us all simply that the tube supports were machined a little differently in Unit 3, which may or may not be true and may or may not be the real root cause of the problem. And anyway, WHY wasn’t THAT caught earlier? By NRC, MHI, or SCE? How could such a gross error be missed? Then SCE tells us — by petitioning YOU — that it’s worth risking ALL of Southern California to operate San Onofre at 70% power — delivering about 2% of California’s daily energy but risking the entire Golden West’s reputation for being the fruit, nut, and vegetable garden to the world that it is. The public’s opinion has been clearly stated: Permanent closure of San Onofre is what we want. Numerous groups of technical folks have chimed in as well: Operating San Onofre Unit 3 is impossible, and operating Unit 2 at 70% power is risky and the risks greatly exceed the possible benefits even with perfect steam generators. The waste problem has not been solved, and the NRC must understand THAT if they don’t understand any other problem. If the NRC can’t make the determination to shut San Onofre forever, if the CPUC, CCC, CEC, SCE, and DOE all can’t either, then who can? The public! And they have. Do your job, NRC. Shut San Onofre forever.

  36. I’d like to suggest that the NRC Resident Inspector post a daily update of what is being done, so that everyone that is interested in what exactly is happening at San Onofre can stay informed.

    This is especially important now that SCE is re-pressurizing damaged RSG 2E-089 after they have only inspected about 15% of it’s SG tubes for wear and or leakage, despite the technology being available to do so. SCE is now under great financial pressure and Southern California does not need any more radioactive releases from San Onofre, Where Haste Makes Radioactive Waste….

  37. SCE has greatly disrespected the NRC by their lies about a “like for like”. The NRC should not take this direct insult to themselves and the general public. Greed of Corporations can only be influenced by taking their money. Shut them down and keep them down.

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