There’s a long way to go on San Onofre restart review

sanoGiven the interest in the NRC’s San Onofre-related meeting in Maryland next week, it’s a good time to step back and see where things stand in reviewing the plant’s restart request.

Of course, the San Onofre nuclear power plant has been safely shut down for almost a year now, after the plant discovered unexpectedly advanced wear in its steam generators. In March of this year the NRC told Southern California Edison the plant will remain safely shut down until the utility does several things to show an appropriate response to what’s caused the wear.

A vital part of SCE’s response is a detailed plan on safely restarting the plant in light of the steam generator wear. SCE delivered that restart plan about two months ago, and the NRC’s experts have begun reviewing the plan and have repeatedly discussed the situation publicly in meetings near the plant.

It’s important to remember the NRC’s review will take many months to complete — we’re still in the early stages of that process. That brings us to next week’s meeting.

The staff, as part of their usual process, isn’t accepting SCE’s plan at face value. The staff has provided additional technical questions on Nov. 30 and Dec. 10 for the utility to answer; the meeting allows a public, open discussion of both the staff’s understanding of the plan and their new questions. While SCE might need to discuss some information in a non-public part of the meeting, all the staff’s questions will be part of the public session.

The NRC wants to be perfectly clear here – this is only one step in a long process, and a final decision on whether San Onofre can restart is months away.

Each year, the NRC’s well-established review process includes having hundreds of this sort of public meeting on a variety of highly technical matters at agency headquarters. It’s not possible to bring all these meetings to the communities near the plants in question, but the staff is making sure a webcast and phone line are available for this meeting so that people near San Onofre can observe the review process in action and ask the NRC staff questions.

The NRC expects to hold at least one more meeting near the plant and there will be additional opportunities for input prior to any final restart decision.

Scott Burnell
Public Affairs Officer

Author: Moderator

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

42 thoughts on “There’s a long way to go on San Onofre restart review”

  1. Fantastic commentary . I was enlightened by the points , Does someone know where I might locate a fillable CA Edison Company Claim Form version to use ?

  2. The key qestions are
    MHI fatigue stress calculations are significantly flawed tube to AVB contact forces calculations test data computer simulations quarter model statistical calculations ECT and VIsual Inspection results Dings and Dent Analysis are significantly flawed SCE Tube Inspections are significantly flawed SCE FSAR 50.59 50.92 are significantly flawed Unit 2 operation

    @70% power can cause a nuclear meltdown due to cracked tubes during AOO and MSLB SCE Root Cause Stinks Wake up NRC Listen to ASLB JH AG JL HAHN Baby

  3. Sure!

    Hey you guys in Japan! Guess what! The worst mother nature threw at three old nuclear inadequately protected reactors happened — and your worst nightmares didn’t! Not even your smallest! Three chances to do Doomsday just fizzled out! Not one injury shy of a sunburn! Yep! Wasn’t nuclear reactors but the gross overreaction of misinformed jittery officials needlessly pushing you out of your homes! Take that to the bank before you sign up for the everyday health-impacting pollution and occasional fatal accidents of fossil fuels!! You’re a strong people! Get back up on the FUD horse that threw you and tame it with lessons and education! This last election and your bold rational PM was a good step proving that fear doesn’t rule your reason! Go nuclear!!

    And may prayers go out to you all for the tens thousands of souls lost by the REAL disaster maker there!

    Think they heard me!

    James Greenidge

  4. In response to the question about the meeting: The meeting facilitator repeatedly noted the meeting discussion, as well as the comments, were limited to the staff’s requests for additional information. The facilitator gave callers an opportunity to speak to the meeting’s topic, and if they were unable to do so the next caller was given an opportunity to ask a question. At that point the Verizon operator would queue up the next caller, and previous callers were always able to rejoin the queue. At the end of the meeting the facilitator asked for additional callers and neither Mr. Lutz nor anyone else had rejoined the queue. As the facilitator pointed out during the meeting, the staff will entertain any additional questions submitted using the NRC meeting feedback form.

    Scott Burnell

  5. I watched the Dec 18th meeting and was troubled that Ray Lutz seemed to be cut off during the public comment period. I called afterwards and he confirmed that he did not leave the NRC public meeting call voluntarily and was not allowed to ask his final question. Shame on who ever made the decision to cut him off. Was it the facillatator who made that decision?

  6. Some parts of the commission have gone out of the way to include the public lately. Good for them. But it was clear from the Dec. 18 meeting on the potential restart that others are comfortable with industry only and see the public–many of whom have spent an enormous amount of time in self-education–as unworthy. Make an attempt to mingle a little more, hey.

  7. What name calling? I always call it like it lays, and you sound a beaver eagerly lining up bullets for a firing squad. You keep ignoring the fact that this SONGS defect was discovered by engineers long before failure, not after one. Give their inspection and pro perspectives some credit — and I’m pretty sure they want to fix it right for themselves, pride, career and families, far more than you do. What Fukushima showed was that even a older non-updated plant — even if incompetently run and unprepared — could weather about the worst mother nature could do outside an asteroid strike (should I be giving you any ideas?) without tweaking one life. I wish oil and gas and air travel incidents were so resilient — and forgiving! You also willfully ignore that the “thousand year event” hadn’t injured anyone or damaged outside the related buildings while fossil fuel incidents without the help of nature almost occasionally put away scores of people and demolish neighborhoods without any squawk from the greens — who also diss mentions of historic millions of fossil fuel aliments too numerous and obvious to be documented while you have to hunt far and wide for any nuclear ones. I call that royal hypocrisy, especially when it’s a phobia intent on fanning a clueless hysteria into driving the rest of us into a dirtier CO2 future and a continuation of past fossil aliments. Yet you want to condemn an entire power source based on a “what might happen” that didn’t even in its rare worst days? I don’t know what’s gotten to you to want to banish nuclear energy so fervently with “ifs” “maybes” and speculations for ammo, unless you’re making bucks like Arnie and Helen are or out to avenge Hiroshima souls, but if not, you ought heed what FDR said about fear. It makes for a bad obsession.

    James Greenidge
    Queens NY

  8. In response to the follow-up question:

    Southern California Edison bears the responsibility for demonstrating it properly replaced the steam generators using the “50.59” portion of the NRC’s rules, regardless of how “like-for-like” the new generators were. The Friends of the Earth petition argues the utility failed to follow the 50.59 rules. The Commission’s Order says on page 4: “the NRC staff is already evaluating whether these SCE actions required a license amendment. We therefore deny Friends of the Earth’s request and refer this portion of Friends of the Earth’s petition to the EDO for consideration as a petition under 10 C.F.R. § 2.206.” This means the staff’s review is ongoing; the NRC will only have an answer on its own determination when the staff completes the 2.206 process.

    Scott Burnell

  9. Actually….when you evaluate the accident scenario, are the offsite consequences worse or better? Steam generator tube failure was already assumed in plant analysis. So given this new information, is the radiation release to both the public and to the operators within the previous limit of acceptability? If it is, then there is no more than a minimal increase in an accident.

    Now there is a caveat to that. If this change causes a drastic increase in the probability of the accident, the criteria for acceptable radiation release may change, and that’s a large part of what SONGS needs to address before the NRC should allow restart.

    The fact that components are degraded does not necessarily on its own mean the consequence or risk of the accident is worse.

  10. Call it what you want, but the important thing is the actual technical, scientific, and engineering basis. Just because they have more damage does not mean they cannot be operated in a safe manner, and that is what the extensive evaluations that SONGS is doing is about.

    Have you read the SONGS documents which are posted on the front page of

  11. Fire watch rounds != ECCS. Fire watch is a compensatory action which involves verifying a fire does not exist and does not mean your ECCS is inoperable.

    Also “a safety battery”, what are we talking about here? The entire DC power system, which has dozens of massive batteries? A single emergency power light? A UPS for a device? There’s no context, and it also does not mean ECCS is inoperable, on the contrary it would imply that ECCS was still OPERABLE, because all ECCS systems (with the exception of BWR HPCI systems) function on AC electrical power. A battery is DC power, therefore not related.

    As for 50.59, that is used for DESIGN CHANGES. The fact that the actual delivered product is not conforming to plant design does not mean the DESIGN is wrong, it means the part is a non-conforming part. The DESIGN for the station is still correct, but the installed part is not right, and as such it needs to be evaluated for use as is. Use-as-is evaluations DO require 50.59, but JUST BECAUSE SOMETHING IS DIFFERENT DOES NOT MEAN YOU NEED A LICENSE AMENDMENT. If you can show that the non-conforming part does not result in more than a minimal increase of the risk of an accident, and does not require a tech.spec. change (which the use-as-is likely would not), then you do not need a 50.59. Changing parts does not immediately mean you need to do a license amendment. In fact, you can even change parts of your safety analysis report, your plant procedures, major programs, and sometimes even major equipment, without a license amendment or in most cases without even a full 50.59 evaluation.

    I’d be happy to talk more about how 50.59 actually works. I’ve written a number of 50.59 evaluations and have had extensive training in this area.

  12. James

    Forget the name calling, these facts are nuclear engineer reviewed, “not shut-em-all-down talk”!

    San Onofre had 8 RSG tubes that failed in-situ testing, that is (also) something that never happened before in the entire US nuclear fleet, many NRC professionals have warned about a “cascade” of tube failures yet the NRC has glossed over that accident scenario as something that could not occur, that is until now! San Onofre will now cause the entire Industry to take another HARD look at just what could happen if FEI or other beyond basis event happens with or without a large Earthquake and or tsunami causing a major loss of core coolant…

    Fukushima proved that Nature can destroy any land based nuclear reactor, any place anytime 24/7/365! Remember a once in a thousand year event can happen tomorrow as easy as it can happen in 999 years, and the USA cannot afford a Trillion Dollar Eco-Disaster at any time!

    Read the Big Number 1 [condensed version (13 pages) or technical version (36 Pages)] 12-10-04 and the Big Number 1 Attachment Notes – Updated 12-10-29 which are all posted here along with the rest of the San Onofre Papers:

  13. nuclear guy says:
    “Also can you please link where San Onofre did not have “properly connected” ECCS systems???”

    First hit on google search. You can do your own research next time.

    “San Onofre’s safety problems began drawing attention in 2007. A fire prevention specialist responsible for hourly patrols around the plant had deliberately falsified inspection records for years. In 2008, a safety battery was discovered to have been disconnected for four years.”

    I understand those batteries are required for proper start of backup generators, required for plant cooling in a disaster.

    The proof that 50.59 was not respected is in the pudding. The new generators failed with only 5% of their advertised life. Therefore, they were different. QED.

  14. Joffan The inspections that were done with low tech instrumentation and all tubes have not been visually inspected and especially the insides have not been inspected for fatigue cracking which is most important since they have already been over stressed… The manufacturer even advised SCE to plug all tubes that have wear… and that has not been done…

  15. Because “minimal increase” is not more SG tube, less tube to tube clearances, taller tube heights and no in-plane support just to name some of the changes, all of which doomed the $680 million dollar RSG to failure!

    Nice try….

  16. Nuclear guy is living in nuclear denial*, SONGS NEW in-house designed RSG have more damage that the REST OF THE US NUCLEAR FLEET COMBINED, plus 8 tubes failed in-situ testing in Unit 3, something that even the NRC says is unprecedented and a major safety concern, yet you say no big deal… and that does not address the tube in Unit 2 with 90 wear that was still in service.
    Ha Ha Ha

    Better read some of those San Onofre Papers and find out what is really going on at SONGS!


  17. Revised Notice of 12/18/12 Meeting with Southern California Edison to Discuss its Response to NRC’s Confirmatory Action Letter and Return to Service Report for San Onofre Nuclear Generating Station, Unit 2 (TAC No. ME9727).
    Meeting Date & Time
    01:00PM –

    Click to access ML12347A066.pdf

    SCE is going to get grilled by the NRR and the NES, I can’t wait…

  18. So what I’m hearing is you have no proof that the 50.59 rule was improperly applied?

    The size of the change does not matter to 50.59. 50.59 only cares if there is more than a minimal increase in an accident. It’s not a matter of “hindsight”.

  19. Don’t get paid to post anywhere.

    Also the failure of ECCS and the heat removal system was not due to the earthquake but instead due to the loss of electrical power. It’s a big difference, as the electrical systems could have been protected from flooding and werent. ECCS pumps are designed to survive earthquake conditions and are actually tested for it. They have to be in order to be classified as safety related.

    Also can you please link where San Onofre did not have “properly connected” ECCS systems???

  20. Mr. Brunell,
    Thanks for your reply.


    After reviewing the November 8, 2012 Memorandum and Order to which you linked I found no specific instruction from the Commission to NRC staff to consider whether or not Southern California Edison’s replacement steam generators are LIKE-FOR-LIKE replacements of the original SONGS Unit 2 and Unit 3 steam generators. I would appreciate clarification.

    I’m hoping to understand your reply and would appreciate a YES or NO response to the initial question restated here: At any point in the process did the NRC EVER make a determination that Southern California Edison’s replacement steam generators are LIKE-FOR-LIKE replacements of the original SONGS Unit 2 and Unit 3 steam generators?

    I gather from your reply that the Commission has instructed NRC staff to consider whether Southern California Edison’s replacement steam generators are like-for-like replacements of the original SONGS Unit 2 and Unit 3 steam generators. Is that correct?

    I would like to know whether NRC is revisiting the question after previously determining the RSGs to be like-for-like replacements OR whether no determination was previously made by NRC.

    Thanks in advance for clarification speaking directly to the use of the term LIKE-FOR-LIKE.

    Myla Reson

  21. ” it because the industry is now worried that the tide has turned and such meetings only reveal that the industry in INHERENTLY unsafe.”

    “Inherently unsafe”? After 50 years of operation under different companies worldwide with a score of ultra-rare fatalities — including worst accidents — that can fit in one bus? Are you blind to the tens thousands of certified mortal victims of fossil fuels and certified millions of fossil aliments or do you just have some implacable philosophical beef with the atom? Mister, there are neighborhoods near oil refineries and chem plants who’d happily swap them for a clean quiet nuke down the block. But your pious passion for SONG management to get everything right and safe even exceeds the concern and experience of the engineers on the job, uh? How bloody concerned of you and Lily M. Really, to be a public health and safety advocate who shuns the near nil mortality/damage tally nuclear plants have compared gas and oil facilities makes you an instant hypocrite. The only reason the public has been tepid about U.S. nuclear is because the nuclear industry has been total slackards at public education and FUDites and sympathetic media rushed in to fill the void and poison the perception of power plants which have injured less people in their whole existence than just one year’s tally of just one of its rivals. To deny such facts, yes does make one a FUD-laced hypocrite.

    James Greenidge
    Queens NY

  22. But Edison has not posted the wear maps so we can even look at them. What do they have to hide? Inspecting tubes does not mean they are safe to use. There has been no third party review of their proposals. The steam generators have not been thoroughly tested, they have not even been thoroughly simulated. What makes you think Edison can get it right this time, when they blew it with a bad design, wasting over a billion dollars on their first design? Are you happy that this is how we are now working, with crappy steam generators jury-rigged to get them to work?

    I think we should send a roll of duct tape. They are probably running out.

  23. Yeah, I guess Fukushima proves your point. All the nuclear safety analysis and Probability risk assessments are based on failure scenarios that are within a very small set. How about a mag. 9 earthquake? ECCS may not work. The emergency pumps still have to run, and they were connected improperly at San Onofre for four years. Those pumps also automatically shut down if they start to vibrate. OMG, earthquakes vibrate too, so they pumps may be shut down before they can start to cool the core. THE CORE MUST STILL BE COOLED! Even in “cold shutdown” it puts out the same heat as a 160,000 HP engine.

    Nuclear safety analysis is only worth as much as the assumptions it is based on. And those assumptions may all be wrong.

    Are you employed by the nuke industry, nuclear guy? Are you being paid to post here?

  24. Because Edison has already proven that their ability to evaluate their design is faulty. They spent nearly a billion dollars, all told, on their big steam generator mistakes. These replacement steam generators SHOULD have had a full license amendment, with the hope that it might allow many eyes to look at their design and perhaps this would have revealed that their design did not incorporate any supports against in-plane vibration. The steam generator replacement project was huge, and they modified the design substantially. The claim that they were like-for-like, we now know, was incorrect. Thus, with 20-20 hindsight, we know that a license amendment SHOULD HAVE BEEN required for the steam generator replacement project.

    If you make lots of small changes, you can add up all those minimal increases and you can get a lot. Plus, what is the harm in having more review? Is it because the industry is now worried that the tide has turned and such meetings only reveal that the industry in INHERENTLY unsafe. The mindset you represent is haunted by a common defect: The human mind is constantly too confident that it can get everything right. The failure in design was not due to earthquake or tsunami… it was due to a defect in the design, and a thought that designers can get it right. I’m an engineer, and I have no confidence that with the complexity of these plants, that they can be run safely.

  25. Question for Scott Burnell: [Restated for clarification] Has the NRC ever made the determination that Southern California Edison’s replacement steam generators are like-for-like replacements of the original SONGS Unit 2 and Unit 3 steam generators?

  26. Of course the NRC should not take SCE’s claims without checking them themselves. Japan’s new nuclear regulator was confronted with just such a situation this week. Do they blindly take the operator’s word for it or review it themselves, ask questions and make their own determination? The NRA stated the operators inherent conflict of interest even when the operator employs a expert to work for them requires the regulator to do their own due diligence on the situation.

    This obviously should not be rushed. I big design mistake was made, luckily it was caught before it became a big accident. There should be much more public disclosure. SCE should be compelled to make all of their data and analysis on this public. The trade secrets or security excuse is really not applicable. This is a very old technology, the design of PWR steam generators are well known and MHI’s “design” for the failed units is not a secret anyone wants to rip off, if anything it could make a good textbook of what not to do. 🙂

  27. I’m curious, why is making a change that does not result in more than a minimal increase in the chance of an accident require a license amendment? Is there some basis I’m missing?

  28. “which would drain the reactor core coolant before the control room crew could do anything about it ”

    FYI: ECCS automatically starts and injects into the core within seconds of accident signals being detected. It would completely prevent draining of the core. In fact, your steamline break combined with tube failure, combined with failure of main steam lines to isolate (both inboard and outboard) which are all either expected to never occur, or expected to only occur once in plant life, all of those things would just reduce reactor pressure faster and allow ECCS to inject quicker.

    You really need to do some work on your nuclear safety analysis before you make such claims.

  29. This guy mixes multiple beyond design basis events, most of which are not ever expected to occur once during the life of the plant, let alone occurring simultaneously. Additionally he doesn’t credit many things like ECCS, or most ESFs for the facility, all of which would mitigate even the combination of events he keeps proposing.

  30. Question for the NRC: Has the NRC ever make the determination that Edison’s replacement steam generators are like-for-like replacements of the old steam generators?

  31. “…which would drain the reactor core coolant before the control room crew could do anything about it and cause a nuclear incident or worse a nuclear accident that would destroy the economy of the USA,”
    like Fukushima’s nuclear accident is doing to the Japanese!”

    Wow, Capt! What all the reactors around the world over 50 years I don’t think I ever heard that happening by equipment defect or human error. Of course there’s Fukushima and it took a rare superquake and tsunami to do that — with zero casualties to boot (if only even minor oil and gas accidents were so merciful — like the ones in Tokyo weren’t in the same quake!) Why not let the engineers determine what needs fixing and what the bill is instead of nuke-fear knee-jerk politicians and armchair implacable shut-them-all-down-no matter-how-safe nightmares — er, expertise?

    James Greenidge
    Queens New York

  32. Any restart of this plant with these failing steam generators is completely premature. The changes to the steam generators in Unit 2 to allow it to run, i.e. adding cables to the inside of many tubes to try to get them to stop vibrating, amounts to a change to the design that is beyond the limits imposed by 10 CFR 50.59, and a license amendment should be required by the NRC. Furthermore, the NRC should not allow SCE to claim that failure data is “secret” to avoid embarrassment. Let’s get all the facts on the table and make sure this is done right this time. That means complete openness, and therefore a license amendment process to insure everything is adequately reviewed.

  33. Good News for Southern California (SoCal) because SCE’s poorly redesigned SONGS replacement steam generators (RSG’s) are already heavily damaged and would NEVER survive a main steam line break (MSLB) or other Beyond Basis accident because its SG tubes not only have far more damage than any other RSG’s (except for failed SONGS Unit 3 which will not be used again unless completely rebuilt) in the US nuclear fleet but SCE has yet to fully visually inspect ALL THE RSG tubes with state of the art technology because they will then be forced to plug and or stabilize even more SG tubes which will then exceed the NRC SG tube plugging limitation, making it unable to be restarted!

    It is time for the NRC to demand SCE provide answers of how they would be able to deal with cascading RSG tube failures due to a MSLB and or other Beyond Basis accident, which would drain the reactor core coolant before the control room crew could do anything about it and cause a nuclear incident or worse a nuclear accident that would destroy the economy of the USA, like Fukushima’s nuclear accident is doing to the Japanese!

  34. Ridiculously slow. Reviewing a plan should not take as long as the original planning. It’s not like there are any real safety implications to a restart, especially as proposed. The steam generators have been thoroughly tested and any possible problem tubes dealt with. A short operating cycle will allow more inspection and better understanding. A future steam generator leak would be quickly detected – as it was previously, indeed – and safely responded to.

    The NRC appears to have forgotten its safety mission and branched off into some obstructionist agenda.

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