An Open Forum Now Available

The NRC welcomes comments on the topics we’re blogging about. But we realize there are other topics you might want to talk about. This post serves as the Open Forum section of the NRC Blog. You may post comments here on any topic relevant to the role and mission of the NRC. Comments here are still moderated and must adhere to the Comment Guidelines. If we determine a comment on another post is more appropriate here, we’ll move it over. This post will stay open for comments and not be subject to the 30-day comment period of other posts. You can always find this post by clicking on the Open Forum category on the side bar.

Holly Harrington
NRC Blog Moderator

Author: Moderator

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

385 thoughts on “An Open Forum Now Available”

  2. I have an “off the wall” question related to contaminated objects. Is there somewhere I can go to have an article tested to see whether or not it is contaminated by radiation? Thanks

  4. totally agree. Moving to facebook at this time is very suspicious, almost like someone wants the easy ability to not just censor, but collect data on the “troublemakers”

  5. Thank you for the response Mr. Moderator. I think though that you are making a mistake by essentially giving up your NRC Blog site & going w FB. FB is rightfully under a microscope right now. They clearly have put profit above principle…allowing personal user data to be compromised & for the outright censorship of those who offer opinions contrary to their own liberal viewpoint.

  6. Please feel free to continue to use the Open Forum section on this platform for comments, and check out our Facebook page for current content.

    Moderator

  7. Is the open forum all that is left of the NRC Blog site?! The NRC has not posted a thing there for a long time. The stories there are so old I cannot even leave a comment there. One of my favorite pastimes was jumping on deceptive NRC propaganda. You have proven to me that you really do not want citizen input. The public & public safety simply are not the priority in the NRC anymore!!

  8. those fees are paid by the rate payers, who have no choice in the matter. tax funded or rate payer funded, rest assured, it is OUR money paying your salaries and we insist that you have our wishes for safety and health as your prime objective. We think you fail at many levels.

  11. I have an “off the wall” question related to contaminated objects. Is there somewhere I can go to have an article tested to see whether or not it is contaminated by radiation? I have a wooden object that was obtained in Hiroshima in 1947, and it occurred to me that this may have been present in that city when the bomb went off. If so, and if it received radiation contamination, I wonder whether or not 70+ years out it might have dangerous levels of contamination. I am absolutely unfamiliar with the half-life of nuclear radiation and its potential dangers. Any thoughts?

  12. The NRC’s open forum policy shows a commitment to caring about our citizens. It’s one of the great examples of open government forums that make this country great. Thank you for the opportunity. There are few government entities as important as the NRC in this global environment.

  13. Congress entrusted the NRC with providing reasonable assurance that public health and safety will be protected. The NRC’s 42-month goal for completing design certification reviews is based on a high-quality application with sufficient information to show that the proposed design meets the necessary safety requirements. Some of these requirements, such as safely controlling the reactor and ensuring core cooling, remain the same regardless of the reactor core’s size. The NuScale approach relies on first-of-a-kind components and technologies to perform important safety functions. The NRC review therefore focuses on the detailed analyses that demonstrate the design will perform its safety functions. The NRC review of these safety issues is progressing as efficiently and effectively as possible.

    Moderator

  14. The NRC goal for a large water reactor is to provide a license in 39 months. So, why is the NuScale 50MWe, i.e. very low source, passive natural circulation primary circuit, passive cooling swimming pool long term decay heat removal design not 12 to 24 months? It CERTAINLY does NOT make sense to take 46-60 months as currently planned. In other words, why isn’t the license review for NuScale almost complete?

    Taking unresponsibly long unnecessarily economically increases the cost of nuclear making nuclear less economically competitive with MUCH more dangerous energy forms. Risk needs to be compared to other energy form production risks, since no one from the public has yet been killed by commercial nuclear power. The risk of Nuclear is far, far, far lower than other power production risks. So taking longer to license nuclear vs coal and natural gas plants is unwarrented.

  17. This is great. This leads to transparency on the part USNRC, that means they are dead serious on their job.

  18. With record amounts of rainfall on the east coast how did nuclear power plants there fare? Nuclear plants don’t fare well with too little or too much water. I am surprised I did not see a post from the NRC about how they were sending additional NRC inspectors to these plants in advance as you have done before previous adverse weather events. As if additional regulators makes a nuclear plant safer. (:-)

  19. Thanks for your comment. We are in the process of evaluating all of our social media tools to make sure we are using them in the most effective ways.

    NRC Moderator

  20. Has your blog changed in the Trump era? I sense it has gotten a lot quieter.

  21. You received the automatic notification from WordPress, per, presumably, your request to follow the Open Forum comments.

    Moderator

  22. Thank you NRC for alerting me by email that the comment by ‘Anonymous’ was moved to this open forum. You not only alerted me but provided the entire text of Anonymous’ comment. Has this always been your practice? I thought your past practice was to just move a comment to the open forum without any notice being sent to blog participants. I really like what you are doing now, perhaps what you have always been doing, as it demonstrates an important characteristic of an open & transparent agency willing to listen even to differing points of view. A very healthy thing in my opinion.

  23. SHUT PILGRIM! Having a tin roof over over-packed fuel rods elevated into the skies which are fly-over terrain for Boston’s Logan Airport as well as being flown over daily by commercial & private planes WITH NOP AIR SPACE SECURITY IS INSANE….We either die by negligent maintance, flooding from Cape Cod Bay, boats being loaded with explosives & sent unmanned into the plant,or that unprotected air space being usedas target practice by some nutcase….we on Cape Cod HAVE NO ESCAPE!!! Neither does Boston & the hundreds of miles surrounding the plant…SHUT PILGRIM NOW!! NRC DO YOUR JOB!!! WE ARE SHOWING UP ON JAN 31!! BE READY FOR SERIOUS QUESTIONS!!!

    Lillia Frantin
    LilliaFrantinStudio@msn.com

    Note: Moved by the Moderator to adhere with blog comment guidelines.

  26. As a taxpayer-funded federal agency I hope the NRC staff is shrinking as more & more nuclear power plants shutdown permanently, most prematurely since they simply no longer can compete with cheaper natural gas-fired generating plants. How many jobs at the NRC have been eliminated and how many more reductions in staff are anticipated? As payroll is a significant part of the agency’s budget, how much has the NRC annual fiscal budget been reduced as a result? Has the NRC instituted a hiring freeze to help effect these staffing reductions?

  27. The NRC has robust training and qualification programs that include many hours of formal training, individual study activities and on-the-job training prior to performing regulatory functions; even then, supervisors and senior regulatory personnel provide coaching and mentoring throughout a staff member’s career.

    Jennifer Golder
    Chief Learning Officer
    Office of the Chief Human Capital Officer

  28. I seem to notice that the current NRC staffing is comprised of many young smart people but that actual hands on experience in the areas they are regulating may be very low. The NRC should initiate ways to get hands on experience to their regulators. The standard 1 or 2 week cram training course along with a accompaniments and study does not really prepare NRC staff to adequately regulate many of our highly technical and complex licensees!

    Anonymous

    Note: Moved by the moderator to adhere to blog comment guidelines

  29. NRC regulations have stipulations in terms of adequate lighting but do not specify a source.

    Moderator

  30. What does NRC rules and regulations with regards to LED lightings in and outside installation for all existing NPP?

    arogado1244@hotmail.com

    Note: Moved by the moderator to adhere to blog comment guidelines

  31. So the “average” American is qualified to be an NRC Commissioner? Someone who communicates on an 8th grade level, can’t set the clock on a microwave, and hangs on every word of clan Kardashian? Will you be sitting on the selection board, or should we just leave it to the California delegation to the United States Senate?

  32. It is our practice to try and keep comments on the blog post to which they are submitted rather than moving them to Open Forum. Sometimes the comments stray quite a bit, but are part of a thread of comments, so we keep them as part of the thread. In this case, we did not see a connection to the topic of the blog post on public meeting facilitators. If you wish to resubmit the comment with a bit more context or relationship to the blog content, we would be happy to review that comment and, if possible, approve it.

    Moderator

  33. So how is the guy’s comment who brought up the disturbances in public meetings in the closing days of Vermont Yankee relevant to the post. It sounds like there is two set of rules for which ideology you favor.
    It was rude and unprofessional you didn’t notify me of the change.
    So what are the real reasons for the change out of the people who run public meeting? How did VY play in this change?
    This blog isn’t even following the philosophy of improving public communications stated below in this ?
    “The purpose of the program is to help make meetings and outreach more effective, inclusive and fair, and to increase NRC’s capacity to collaborate and solve problems with both internal and external stakeholders.”
    How come you didn’t enter my comment on the post and ask me to explain why its relevant.

  34. Per the blog comment guidelines, the comment was moved to Open Forum as there was no connection to the subject of the post under which it was submitted, specifically the NRC’s new meeting facilitators and public meeting statement.

    Moderator

  35. It seems the moderator is oblivious to the contextuality of the first post, about why there was so much dissent surrounding the shutdown of VY.

  36. One must remember, the lying by Entergy got candidate Shumlin elected to be governor. The exiting Republican governor could no longer trust Entergy either. The NRC’s rules by which carry the public credibility was insufficient. A majority of the region’s population could no longer trust VY. The national polls show a startling decline in public credibility of the nuclear industry. We see events at these plants through the captured NRC, lackeys for the nuclear industry…not through the standards of a reasonable man. The nuclear industry (NRC’s) rules are increasing accepting mediocracy as the highest standards. We shocked the world by electing president elect Trump. Fundimentally this election cycle was about making government work for the regular person. We should get some NRC commissioners in there who could advocate for the regular people who were troubled by the closing years of VY. We need some regular people as NRC commissioners.

    Mike Mulligan
    Hinsdale, NH

    Note: Moved by the moderator

  37. Nuclear Power is Sustainable & That’s What Counts!
    Nuclear power meets all the criteria for a renewable energy source but one currently. Most reactors in operation use more fuel than they produce. However fast neutron reactors (FNRs) produce more fuel than they consume. In fact a FNR not only gets much better mileage, getting 60 times the amount of energy from uranium, it also produces even more abundant thorium as a fuel. In a FNR, thorium produces U-233 which is fissile just like the U-235 we get from the ground.
    Even with our current power reactors uranium is abundant and uranium is even available from sea water at costs which would have little impact on electricity prices.
    Of course if FNR technology is used, or thorium becomes a nuclear fuel, the supply is almost limitless.
    Therefore regardless of the various definitions of ‘renewable’, nuclear power meets every reasonable criteria for sustainability, which is the prime concern.
    It is very appropriate, in my opinion, to include non-polluting nuclear power as an important part of our energy future. It deserves to be on an equal footing with any renewable energy source.

  38. NUCLEAR POWER OPTION DYING DESPITE COMMON GROUND
    An article I read recently said that Trump and Clinton seem to have at least a sliver of common ground when it comes to science and energy issues.
    “Nuclear power must be an integral part of energy independence for America,” Trump responded to one question, calling nuclear “a valuable source of energy.”
    Clinton wrote that the climate challenges are “too important to limit the tools available in this fight” and that nuclear power “is one of those tools.”
    Despite that rare agreement on anything in our polarized political system, I believe it is too late to do the right thing. Our U.S. Nuclear Regulatory Commission is becoming the Nuclear Retirement Commission. While other countries consider nuclear power an important part of their pollution-free energy futures, America is not leading the world in yet another important area.

  39. The NRC continuously monitors international events that may have an impact on nuclear safety and security. The NRC’s International Programs staff have been in contact with Japanese officials since the April 14 earthquake in southwestern Japan, who confirmed that no abnormalities have been detected at nuclear power plants in the area.

    Eric Stahl, Public Affairs

  40. The comment posted (by Ricardo) above is an exact Copy/Paste of the Open Forum comment I posted in March of 2011, immediately following the Fukushima/Daiichi earthquake. As far as I can tell, the conditions and events associated with the Japanese earthquake (Kumamoto/Mashiki) this week are not similar to the earthquake that occurred in 2011. [Moderator note: Some verbiage removed here to adhere to NRC blog comment guidelines.] My condolences to the victims of Thursday’s earthquake.

  41. Is the NRC staff following the recent news from the earthquake in Japan? Can you post some reliable technical information regarding the impact of the earthquake on Japanes nuclear facilities? What is the significance of the evacuations that have been ordered due to “failure of backup generators”?

  42. drbill, a cursory reading of your resume indicates that you’re of such a character as to ostensibly be above the fray here. I mean, what does it contribute to the discussion to engage in such pejorative speculation before an inspection team is even convened? It comes off as nothing more than an attempt to pre-condition the team because you have no confidence in their ability to assess the situation. Either that, or you’re just flinging red meat to the less educated denizens of this blog.

  43. • Extent of Intellectual Corruption

    An inescapable fact is that lack of competence, integrity, compliance, and/or transparency at any level of an organization has never been shown to have been confined to that level. Moral pathogens propagate.

    drbillcorcoran

    Comment moved here by moderator.

  44. Thank you for your comments regarding safety relief valves (SRVs) used at the Hope Creek nuclear power plant. As we noted in our earlier correspondence to you, the SRVs in question would have been able to perform their function, despite the problem associated with setpoint drift. We would also remind you that even with the higher lift setpoints, the increase in mechanical stresses on the plant’s torus (the large reservoir of water located at the base of the reactor building that can be used for cooling purposes) and piping attached to the torus would have remained within acceptable limits based on the applicable safety codes. That said, we will continue to monitor and inspect work by Hope Creek’s owner, PSEG, to resolve this issue. The results of those reviews will be made public in upcoming NRC inspection reports.

    Neil Sheehan

  45. ‘NRC letter to Mike Mulligan, re Hope Creek-Results of two stage relief Target Rock safety relief valves’

    https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML15365A341

    See, this is the problem…words have meaning.

    Letter: “In the particular case of Hope Creek, PSEG has taken steps to improve SRV performance, specifically the installation of ion beam implanted platinum or Stellite 21 pilot valve disks, but with limited success to date.”

    ***How about a NRC blog entry on Hope Creek’s SRV problems and these Target Rock SRV valves.

    If the utilities actually participated on the NRC blog, it would be much less one sided.

    I could make the case Mr. Bower’s letter doesn’t accurately represent current conditions in the nuclear industry or even at Hope Creek.

    This last two SRV setpoint accuracy LERs speaks of a drastic increase in setpoint unreliability. Is setpoint inaccuracy…habitually crossing a required tech spec safety shutdown adverse to quality? You know, habitually and knowingly violating a tech spec shutdown. The reliability of setpoint accuracy is increasingly in drastic decline and the most current report is horrific with 10 of 14 SRV failing testing. On two SRV going inop the plant is required to be shutdown within 24 hours. The wording in tech specs is absolutely clear. Severity one percent of the of the fourteen reliefs in the most current grossly crossed tech specs limits requiring a immediate shutdown and the NRC thinks this is insignificant. I got proof (H SRV) do not fail late in the cycle, they fail very early cycle, unlike Mr. Bower with his opinion. I’ll bet you right now two SRVs are inop and the plant is required to be shutdown to repair the valves. The NRC for their own interest is trying to persuade us following plant licensing and Tech Specs is voluntary…violating licensing and Tech Specs can only lead to less than a insignificant plant event or accident. I say change tech specs, don’t keep corrupting your staff with your silly interpretations of tech specs and safety.

    THURSDAY, OCTOBER 29, 2015: ‘Fifteen Years of Data on Hope Creek’s 2 Stage SRVs’

    http://steamshovel2002.blogspot.com/2015/10/fifteen-years-of-data-on-hope-creeks-2.html

    ***Licensee Event Report 2015-004-01

    10 of 14 failed tech specs testing

    ***Licensee Event Report 2013-007-00

    5 failed

    It is just the opposite of how Mr. Bower portrays the scientific facts; problems and setpoint unreliability has drastically increased of the last fifteen years. Mr. Bower picks grossly outdate reports and stale selective facts to bolster an agency agenda. The SRV problems threatens a tremendous amount of grid electricity.

    The plants are “not” required to publically report all SRV leaks, abnormal tailpipe temperatures and other problems with these valves. Who knows what is really going under the sheets? Personally, with the metal plating of the seat and valve, they put this cheap plating on the seat as a scam. It is fraud and corruption of an enormous magnitude. I could make the case that the SRV plating made the problem worst and nobody wants to record the scientific facts because it would cross a agency political agenda. They put plating on core cooling valves in order to cover-up problems with the valve..to just create a merge …this fraud is beyond explanation.

    This is groups and organization ‘normalization of devience’. It is a severe group or organization mental illness. A problem shows up in a component…the group keeps make excuses about the problem instead of fixing it. It is a very dangerous organizational mental disease because the group can’t see what they are doing is wrong. The Hope Creek SRV problems is “Normalization of Devience” on steroids. It is a addiction to making excuses and operating with crappy safety equipment…

    What the Pilgrim events shows us with their SRV problem over many years since 2010, the NRC drastically doesn’t keep current with anomalies and emergent problems with the SRV valves. The agency waits until these safety valves fail, the valves failed before too, and never documented and reported…the valves fail in a Blizzard and LOOP when the community is most vulnerable. Then shockingly the NRC finds a Mount Everest size pile of troublesome documents with the new valve problems everyone had downplayed and hidden from public view?

    Could we find a unknown mount Everest size list of problems like the agency covered up in Pilgrim with Hope Creek? Sadly it is not uncommon and I have been in the middle of it many time before. We could either deal with it painfully across the NRC’s blog or wait till a plant embarrasses the hell out of us all in plant trip, in a blizzard plus a LOOP, with gross multitudes of unexspected equipment problems showing up and cascading into a special inspection leading to permanent plant shutdowns. It is always your choice? This is what happens when you all don’t stay ahead of the ball.

    Hey, what ever happened to Jessie Roberson?

    Mike Mulligan
    Hinsdale, NH

  46. Your organization opened an opportunity to discuss nuclear energy with policies and practices of what is allowed and what is not allowed as far as blogging. I followed your instructions and your organization refused to post my blog.

  47. About Thanksgiving, which was yesterday, the topic is food. Every day we consume nuclear materials in our food and beverages. My mission in life is to stop the use of nuclear energy completely. The use and abuse of nuclear energy after WWII, the splitting of the atom and the continuance of the practice creates green house gases, Pretty soon we will all be hanging in a wax museum because of the use of peace time nuclear clean energy. We could blame Hitler, but he is long gone, and nuclear energy is supposed to be used now and in the future for good purposes. The level of heat needed to split the atom drives us into violation of sustainable existence, and even so, no one protests the splitting of the atom and the extreme high heat needed to do so.

  48. Veterans of Rickover’s Navy Nuclear Propulsion Program are the best. Rickover made our nuclear navy the best in the world. The biggest mistake in our nuclear history was allowing civilians to own & operate land-based reactors. Mistakes in the nuclear navy end up safely in Davey Jones locker. Mistakes w land-based reactors end up in our laps!

  51. What does the average full time equivalent cost at the NRC per year? probably 230,000 just guessing. I mean the gross cost, not the employees wage. Budget/number of employees is a fairly good way to do this. thank you.

  52. Submitted on 2015/10/23 at 2:31 am
    Thanks to the NRC for providing this forum, it is obvious that many outside the NRC are not only “informed” but have issues with the “wonderful” job the NRC is doing. Hopefully the NRC will reconsider the Radiation Study and start helping everyone better understand the risks of being near or downwind from a nuclear reactor!
    Since developing better communications with the public is a major goal of the NRC, I expect to see much more discussion by NRC professionals with those making comments, since this will led to more understanding by everyone, since so many cannot afford to travel to Rockville Pike to ask questions in person.
    I would suggest that the NRC also enable Blog topics be posted by those outside the NRC, so that the public can help the NRC answer those questions that are of top priority!
    If I could post a topic, this is the one that I would choose:
    Since San Onofre proved that more than one steam generator tube can fail at a time, why does the NRC (still) deny considering multiple (or cascade of) steam generator tube failures?
    Arnie Gundersen said, “Eight replacement steam generator tubes failed their pressure tests in 2012 and more than 1,000 others have been plugged. Therefore, a review of the evidence makes it clear that the San Onofre Replacement Steam Generator tube damage discovered in 2012 was so severe and extensive that both reactors [Uint 2 and Unit 3] have been operating in violation of their NRC FSAR license design basis as defined in their Technical Specifications. The Main Steam Line Break with radiological leakage through the steam generator tubes is one of the bounding conditions in emergency plan evaluation and the extent of steam generator tube failures directly impacts the FSAR analysis. The Replacement Steam Generator (RSG) modifications at San Onofre increased both the likelihood of equipment failure and the radiological consequence of such failure and therefore directly affect the FSAR Current Design Basis.”
    Dr. Joram Hopenfeld, who retired from the NRC staff, raised the following concerns about the integrity of
    steam generator tube ruptures to NRC for years. These concerns were ignored until an accident occurred in 2000 at Indian Point 2. The NRC asked its Advisory Committee on Reactor Safeguards (ACRS) to evaluate the decade-old concerns. The ACRS issued a report in February 2001. The ACRS substantiated many of Dr. Hopenfeld’s concerns. For example, the ACRS concluded: “The techniques used to look for cracked steam generator tubes are not nearly so reliable for determining the depth of a crack, and in particular, whether a crack penetrates through 40% of the tube wall thickness. Note: NRC’s regulations do not allow a nuclear plant to start up with any steam generator tube cracked more than 40 percent of its wall thickness, but the methods used to inspect the tubes for cracks cannot reliably determine the depth of cracks. The NRC staff acknowledged that there would be some possibility that cracks of objectionable depth might be overlooked and left in the steam generator for an additional operating cycle! The design of the present generation of nuclear plants was based upon the
    assumption that steam generator tubes maintained their original strength during design basis accidents, but SONGS has proven that assumption to be false, because the failures at SONGS Unit 3, where not one but eight tubes failed and thousands of other tubes were damaged, has demonstrated that those assumptions are no longer valid for RSG’s. A design basis steam line break accident, which assumes that the tubes are in their “as received” condition could result in not only a single tube rupture, but it could also quickly lead to a multi-tube leakage if the tubes are aged, not well designed and or contain fatigue cracks. In the first case, the consequences to the public are minor, while in the second case they would be catastrophic. The level of risk of operating degraded steam generators such as those at SONGS Unit 2 is patently unacceptable.”
    Add to the above that Unit 2 (which was shut down for a scheduled refueling) had a SG tube that had 90% wear and the operator (SCE) never even had a clue that there was “unprecedented” tube wear in both Unit 2 and Unit 3’s almost new RSGs. It was later discovered, after the tube leak on 01/31//12, that Unit 2 and Unit 3 had more tube wear than the rest of the US nuclear fleet combined!

    Click to access steamgeneratortubesplugged1.pdf

    If Unit 3 had not leaked when it did, then both units would have been put back into service with possible catastrophic consequences, yet the NRC still fails to consider multiple SG tube failures. What will it take for the NRC to change its position?

    CaptD

    Comment moved here by moderator.

  53. Interesting article at this link:
    http://www.news-gazette.com/opinion/columns/2015-10-20/jim-nowlan-where-store-nuclear-waste.html
    It is about all that highly radioactive waste piling up in 38 states of this country, with a lot of it in Illinois. None of it is in Nevada because Harry Reid cut a deal with Obama. Yucca Mountain in NV was determined to be the safest spot for a permanent site in the US for it. But we must not let safety get in the way of politics!
    Also the author talked to three different people about the safety of having all this s….stuff stored near highly populated areas of the US. As expected, he got three different answers. Interestlingly he did not talk to the folks who just might have the most expertise on the subject, the NRC. It would have be useless to do so though. The NRC has no position at all on the subject. The NRC says it is a national policy issue and therefore, like Pilate of old, they have washed their hands of it. I guess the NRC’s stated mission of protecting public health & safety is just something they put on their paperwork?!

  54. Premature Rejection

    Nuclear utilities in this country are opting out (rejecting) their nuclear power plants left and right!
    The Premature Shutdown of US Nuclear Plants

    As older nuclear power plants in the US are shutdown early due to not being economically viable in today’s energy market and/or due to having significant safety and regulatory issues, how much is the US NRC downsizing as well?

    For example, Entergy, the owner and operator of the Pilgrim Nuclear Power Plant near Boston, just announced that they would be terminating operation of Pilgrim by 2019 or earlier due to economic and regulatory issues. Over 600 Entergy employees there will be losing their jobs. How many NRC employees will lose their jobs also as a result of Pilgrim’s shutdown?

  55. ” NRC, FERC Commissioners to Discuss Grid Reliability, Reactor Issues Oct. 21 in Washington, D.C.”

    Why not put this up on the NRC blog and let us publically comment on it.?

    I liked somebody to talk about breaker and line unreliability problems around nuclear power plants. The trends. Has the market conditions led to a dilution of responsibility in nuclear plant switchyards and their surrounding transmissions systems?

    The idea the nuclear plant switchyards are becoming the no-man-lands in the electric transmission system. Dominion’s at Millstone dual plant trip and 10 crf 50:59 boondoggle makes the case or “Abbott and Costello who’s electrical engineer on first”. Everyone half owns the switchyards…thus responsibility and accountability is diluted. The not Indian Point owned breaker failure that caused a plant trip and not proper maintenance done on it. The grossly obsolete breaker.

    And Pilgrim’s issues of wanting to give their nuclear plant switchyard to a grid contractor. Don’t even get me talking about Pilgrim…

    Mike Mulligan
    Hinsdale, NH
    http://steamshovel2002.blogspot.com/

  56. With the hurricane not impacting the U.S., inspectors did not need to be pre-positioned at sites over the weekend. The heavy rain did not affect any safety systems or offsite power in our Region I or Region II plants.

    Moderator

  57. With record amounts of rainfall on the east coast how did nuclear power plants there fare? Nuclear plants don’t fare well with too little or too much water. I am surprised I did not see a post from the NRC about how they were sending additional NRC inspectors to these plants in advance as you have done before previous adverse weather events. As if additional regulators makes a nuclear plant safer. (:-)

  58. Has anyone found positive indications of another site of naturally occurring fission like the reactors at Oklo, Gabon in 1972 ?

  59. The NRC Resident Inspectors at Pilgrim have not changed recently. There is a new NRC Project Manager for the plant, but that is not unusual. It is a routine movement of personnel to maintain fresh perspectives.

    Neil Sheehan

  62. Why was the NRC inspector for the Pilgrim plant which is on the verge of shutdown just changed? That is fairly suspicious.

  64. If You Can’t Identify Errors…
    If you can’t (or won’t) identify errors, how can you learn from them?
    “An error doesn’t become a mistake until you refuse to correct it.”
    Orlando A. Battista
    I am afraid the nuclear industry and the NRC are not learning from their errors and the errors of others in the global nuclear industry.
    Examples:
    • Since Fukushima did not happen in our backyard the US nuclear industry lobbied the NRC hard for ways to only help “mitigate” an accident here not to “prevent” one in the first place. The NRC bought into this strategy as they were convinced that taking such preventative measures would just be too costly for the industry. Thank God these same minds were not at work after the US nuclear disaster at Three Mile Island (TMI). No doubt US nuclear plants were made safer after both prevention and mitigation measures were instituted after TMI in 1979.
    • An important accident mitigation feature now required on all Japanese nuclear plants after Fukushima was dismissed by the US NRC as just not being worth the cost to implement here. This despite the fact that dozens of identical nuclear units like those damaged at Fukushima are operating today in the US.
    • The most serious near-miss nuclear event since Fukushima occurred just last May at the Indian Point Nuclear Station near New York City. Even before investigating this event the NRC concluded that this near-miss was not all that safety significant. I guess flood waters getting anywhere they shouldn’t be in a US nuclear plant is just not the same as flood waters getting into a Japanese nuclear facility.
    Why can’t (or worse yet, won’t) the nuclear industry & today’s NRC take a hard look at their own operations to at least identify areas for improvement?!
    I guess that only our nation’s public health and safety is at risk.
    I am afraid that the viability of the US nuclear industry is job one at the new NRC.

  65. It’s Even Worse than I Thought at the NRC
    1. Does how a problem is worded, formatted, or structured make it potentially more serious to the NRC?
    2. Have computers replaced common safety sense at the NRC?
    3. Is the nuclear industry and the NRC becoming more and more tone-deaf to real serious nuclear issues and events?
    I believe the answer is unfortunately yes to all of the above. It is particularly of concern to me since the NRC’s prime mission is supposed to be public health and safety. Let’s take these questions one at a time:
    1. Does how a problem is worded make it potentially more serious to the NRC?
    Answer: Yes.

    Recently I submitted several concerns to the NRC Executive Secretary, the NRC ACRS Liaison, and the NRC Blog site. These concerns were all worded differently but contained the same message. Namely that the NRC failed to thoroughly investigate a near-miss accident at the Indian Point Nuclear Station near New York City. There were several serious safety issues there that were not even discussed let alone cited as violations by the NRC in their special inspection report. But in my latest communication on these same issues I formatted my concerns in NRC “techo-speak”. That is I wrote them just as I believed the NRC should have written these issues up as cited violations of NRC requirements. I was then promptly notified that these apparent violations had been referred to the NRC’s Allegations Division for further review. I was told that if the NRC allegations group decided that they were in fact “allegations” my communication would not be posted on the public NRC Blog site but rather these “allegations” would be handled in a confidential way (translation: secret manner). If the scrubbing of these apparent violations resulted in nothing that constituted an allegation my post would then be made public on the blog. I thought my previous communications to the NRC were quite clear but until I attempted to talk their language they just didn’t seem to get it!

    2. Have computers replaced common safety sense at the NRC?
    Answer: Yes.

    There is a heavy reliance placed on so-called PRA (Probabilistic Risk Analyses) at the NRC. Every single potential problem identified by the NRC at any US nuclear plant is scrubbed by NRC risk analyst experts using these involved analyses with what critics call, “analyses fraught with many assumptions and large uncertainties”. Even before the NRC responded to investigate this Indian Point near-miss, these experts determined through their expert computer analysis that this event was one of the least serious from a set of three possible investigative response options. This type of investigation then only required a team of four NRC inspectors. My concern is how can the NRC conclude potential safety significance ahead of time without knowing all the facts?! And if the PRA folks pencil-whip (I mean analyze) this event as only worthy of the lowest possible investigative response, may that not bias the investigators to perhaps not really look as hard at this event as they otherwise would?!

    And finally,

    3. Is the nuclear industry and the NRC becoming more and more tone-deaf to real serious nuclear issues and events?
    Answer: Yes

    There have been water-intrusion events not only at US nuclear plants over the years but nuclear plants around the globe as well. When flood waters (either from a tsunami or dam break or hurricane rains or from equipment that fails inside a nuclear plant) get into a nuclear plant where they never should be, it is a very serious problem! Even with the painful memories of Japan’s Fukushima still well in our minds this flooding in a vital electrical nerve center of Indian Point was not treated seriously enough in my opinion! In their required report to the NRC, well after this near-miss, Entergy did not even mention this flooding. Even more important this allowed Entergy to be completely silent with regard to any corrective action measures taken and/or planned to prevent a similar event in the future. Also Entergy failed to declare a proper emergency classification as a result of this plant internal flooding. If a proper and higher emergency classification would have been declared many additional resources would have been called out to respond and be at the ready if safety conditions had deteriorated even farther.

    I believe that Entergy failed to properly put public safety first and withheld vital information from the public on this event. Also the NRC failed to properly investigate one of the most safety-significant events since the nuclear plant flooding disaster in Japan.

  67. I’d like to know why the San Operator of Onofre got the OK from NRC Region IV for a 50.59 instead of a 50.90 when they replaced the 4 steam generators that were so different that they bragged about it in a nuclear trade magazine:

    SCE Caused A Nuclear Near-Miss At San Onofre

    The San Onofre Replacement Steam Generator (RSG) Project was designed by a team of both MHI and SCE engineers with SCE having the final say and it was their licensed CA Engineers that put their “chop” on them, which means that SCE “designed” them, the rest is finger pointing. In fact SCE told MHI that everything about the project was to be approved by them first and that HMI was not to talk to anybody including the NRC without getting the OK from SCE.

    This was done in order to get the RSG’s built quickly without a full NRC 50.90 review which would have included a public review process.. By using the NRC 50.59 process (aka Like-For-Like) SCE told the NRC and everyone else that it was going to be an identical exchange, so no technical reviews were required. We now know this was false and can even point out a nuclear industry trade article where SCE’s engineer and a MHI engineer bragged about all the changes they made, anyone of which should have required a full 50.90 review. NRC Region IV that OK’d this 50.59 replacement got all kinds of egg on their face and it pointed out that their NRC inspectors were too cozy with SCE, since the RSG failed soon after being installed, thanks to both their faulty unproven design and also how they were being operated by SCE!

    Improving like-for-like RSGs

    Click to access col-nrc-tech-paper.pdf

    The operation of these RSG’s outside their NRC approved specifications will be THE KEY issue that will convince everyone that their failure is completely SCE fault (since ratepayers had nothing to do with their operation) and everyone knows what operating “over the red line means”!

    Another reason why SCE must turn over their operational records is that the data will prove that SCE’s operators were “experimenting” by adjusting the operational parameters in an attempt to figure out how to get the RSG to work without them causing internal “noises”. In fact the 9,747 steam generator tubes tightly packed inside each of the RSG were striking each other and/or their supports as the tubes vibrated, causing “tube wear”. This was very dangerous because if one or more tubes failed the high pressure radioactive reactor core coolant inside them would “flash” to steam and escape into the atmosphere! The NRC still assumes that not more than a single tube can fail at a time, which San Onofre proved is an invalid assumption since after the entire RSG system was shut down, a number of tubes failed in situ (in-place) testing. Until the “root cause” of San Onofre is determined other US steam generator may also be at risk, since a “cascade” of tube failures could easily vent so much of the reactor coolant, so fast from the reactor core, that it could cause a meltdown of the reactor!

    Having followed this closely since 01/31/12, I can say that we were very, very lucky to not have had a nuclear incident and/or even a nuclear accident at San Onofre despite all the “feel good” talk from SCE. If the “leak” had occurred during a large earthquake along with some other things, while both Unit 2 and Unit 3 were online, we could have had a SoCal Fukushima, which would have easily exceeded the Trillion Dollar Eco-Disaster Japan is now dealing with!

    * The new hashtag that will allow you to keep up to date on the ongoing investigation into the multi-billion $ SCE-CPUC ripoff.

    CaptD
    Note: Moved by the moderator

  68. STEAMER
    My wife, a retired middle school teacher came up with an enhanced STEM, it is called STEAMER. S=Science, T=Technology=Engineering, A=Arts, M=Math, E=English, and R=Reading. So this is STEM on steroids! Adding Arts, English, and Reading is very important. A common language in America is critical to bringing our nation together. No one would argue that reading is not essential too. And Arts bring an appreciation for the beauty in this world.
    I know the NRC may not like the STEAMER acronym. A steamer mentality in the nuclear industry means placing production and profits ahead of nuclear safety. Of course the NRC has been tough on utilities that have exhibited such a dangerous mentality. Unfortunately, the NRC itself has put the viability of the nuclear industry above public safety on numerous occasions. It is tough though for the NRC to really be tough on the nuclear industry. The NRC does not want to do anything to harm the industry it “regulates”. Just like a Remora on a shark sucks off the shark for its livelihood but certainly does not want to do any real harm its host!

  69. Revolving Door Not Unique to the NRC
    Senator Elizabeth Warren said, “Anyone running for President, anyone who wants the power…should say loud and clear: ‘We don’t run this country for Wall Street and mega-corporations. We run it for the people.’ She said the next president needs to halt the revolving door between those working in finance and at government agencies that regulate Wall Street.
    The NRC has company. There is a rotating door between government agencies and Wall Street that is analogous to the rotating door between the NRC and the nuclear industry.
    I say, “We don’t run this country for big nuclear corporations. We run it for the people.” A cozy, symbiotic relationship between regulator and regulated puts the public in the back of the bus!

  70. Nuke Power Plant Life Extensions
    Three-quarters of all US nuclear plants have applied for and subsequently received life extensions from the NRC. The NRC has only denied those life extensions which have not been requested by the nuclear industry. Now most aging nukes can operate 60 years instead of 40 years. There is talk now in the industry of extending those lives to 80 years, called “life after 60”.
    The NRC, though, did require applicants for these life extensions to identify safety improvements at their plants. The NRC wanted the industry to take every reasonable step to lower nuclear plant risks if these plants were to be operated beyond their original design life. But look what happened.
    Plant owners seeking license renewal identified numerous cost-beneficial safety updates by performing so-called Severe Accident Mitigating Alternative (SAMA) evaluations. Incredibly, the NRC did not require that owners implement these risk-reducing measures.
    Furthermore, the NRC does not even currently require that plant owners pursuing subsequent license renewal go through the charade of using SAMA evaluations to identify risk-reducing measures that don’t have to be taken.
    Our NRC is falling down on its purported sole mission of protecting the health and safety of the public. This is just one of the examples.

  71. The first nuclear reactor will be build in Turkey. I hope NRC share their experience with the TAEK too. (turkish institute of nuclear program).

    info@dmdtercume.com

    Note: Moved by the moderator

  72. Behavior Modification Approaches Contrasted
    Approach Recommended With Kids:
    Rewarding good behavior so that you get more good behavior is the way to create the kind of kid you want. Ideally, you reward the good behavior so you never have to deal with the bad.
    NRC Approach with the Nuclear Industry:
    Expect and assume perfect flawless behavior and then you never have to reward or even recognize it. Just expect it and the nuclear industry will be the kind of nuclear industry “kid” you want.
    Approach Recommended With Kids:
    However, as we don’t live in an ideal world with ideal kids reacting to ideal situations, rewarding good behavior may not be enough. Bottom line, every kid misbehaves and that behavior must be dealt with immediately.
    NRC Approach with the Nuclear Industry:
    Sparing the rod doesn’t spoil the nuclear industry. After all their hearts are always in the right place. They are professionals and would never put profits or production ahead of safety. Besides nuclear power is so inherently safe some rules can be relaxed and even some innocent misbehavior ignored. Immediate action to correct aberrant behavior is just never justified.
    Approach Recommended With Kids:
    Even if it isn’t convenient, bad behavior can’t be ignored and the correction can’t be put off. Stop, get the child’s attention, communicate what you expected and implement the appropriate consequences.
    NRC Approach with the Nuclear Industry:
    No such thing as nuclear industry bad behavior it is just behavior that trends “away from goodness”. Just prior to the Challenger space shuttle disaster the engineers said that weather was colder than ever tested and trended “away from goodness,” and that the brittle booster seals had never been tested under those conditions. However their managers ordered them to “take off their engineering hats and put on management hats.” The engineers were challenged to prove it was NOT safe to launch, and they had no data to do so.
    In addition it takes a lot of time to analyze “away from goodness” events to see if something untoward has really happened. The NRC may take months or even years to determine this but they will have all the analyses they need to completely support any action taken. The NRC will not act like the old NRC and take a conservative approach to safety to protect the public in the interim pending further review. No, today’s NRC will not act until all this modern-day, time-consuming, complicated, and painstaking analyses, fraught with large uncertainties and questionable assumptions, is completed.
    Today’s NRC even made a comparison of their approach to nuclear safety compared to the old NRC’s approach. When citing the old program of reactor oversight, today’s NRC said the old way was characterized by “very conservative judgments governed by the rules and regulations”. (Author’s note: Sounds like the old NRC if in doubt would “error” on the side of reactor and public safety. Is this really a bad thing?!)
    In addition nuclear industry folks come from the same DNA as the NRC. One day a person works with the industry and the next with the NRC and vice versa. How can we fault our brother or sister?!
    Approach Recommended With Kids:
    Even rewarding good behavior can backfire. If the parent is not consistent or in control, the child will learn to manipulate the situation to his or her advantage. This will also develop if you allow the child to negotiate with you, which places the child in control.
    NRC Approach with the Nuclear Industry:
    Everything is negotiable, laws, rules, policies, requirements, etc.
    Requests for regulatory relief are always granted. Requests to extend action due dates are also always considered favorably.
    Instead of making more unnecessary rules the NRC encourages the industry to come up with its own initiatives to resolve safety issues. The NRC knows that without rulemaking these industry initiatives are not enforceable but trusts the industry to do the right thing anyway.
    Conclusion: No wonder the nuclear industry has grown up to be what it is! But the real tragedy is that public safety takes a back seat to ensuring the viability of the nuclear industry.

  73. Another Unholy Marriage?
    There are in fact good and bad marriages just like there are good and bad people. There are even holy and unholy alliances and marriages. Examples of unholy marriages include:
    • Religion & Politics
    • Capitalism & the Internet
    • War & Disney-I had to look this one up; it is pretending to go about life here at home like a Walt Disney fantasy while everywhere else in the world our country is at war.
    Based on bitter experience I think a marriage between those who regulate and those they regulate is unholy.
    In this unholy marriage between the nuclear industry and the NRC:
    • One hand washes the other.
    • As much business as possible is conducted in secret.
    • The needs of these nuclear bedfellows outweigh the needs of anyone else including the public.
    • Both parties share the belief that nuclear power is inherently safe and overregulated and that major problems or severe accidents just can’t happen here. After all nuclear power in the US hasn’t traumatized millions of people in this country for over 35 years.
    • That business can always be conducted in a non-adversarial manner. Everything on the table (including cumbersome and old reactor safety criterion and rules) can be negotiated in good faith and even relaxed between these parties.
    • Rulemaking is unnecessary to ensure safety.
    • Punishment for bad industry safety behavior is just not necessary. Civil penalties for wrongdoing are just old school ineffective punishments and are therefore rarely utilized today.
    • Any proposed enforcement action by the NRC can be appealed and even negotiated in secret with the nuclear industry. This process is called Alternate Dispute Resolution (ADR) and is the NRC’s equivalent to plea bargaining by a defendant charged with a crime. Incredibly, one of the stated goals of the NRC in its ADR program is to “improve relations” with the nuclear power plant “defendant”.
    I could go on but this marriage is one of convenience for the NRC and the nuclear industry. I think it is not only an unholy marriage but one made in hell.
    Finally, down deep both of these marriage partners know that nuclear technology is fraught with danger and uncertainty. It must be hard for either party to sleep well at night at times. And that’s why they like this alliance, this marriage.
    “Marriage is good for those who are afraid to sleep alone at night”. St. Jerome

  74. Yet Another Nuclear Power Plant Front Group
    Yes, the nuclear industry is truly on the ropes. A sure sign of it is the establishment of yet another pro-nuclear front group, “Nuclear Matters”. Why yet another one?! The nuke industry already has the:
    • Nuclear Energy Institute (NEI)
    • Clean and Safe Energy Coalition (CASEnergy)-created over a handful of years ago by NEI.
    • Nuclear Regulatory Commission (NRC) itself-this “regulator” long ago was “captured” by the industry it is supposed to regulate. The NRC public relations group regularly publishes premier pro-nuclear stuff-stuff that any nuke utility’s PR group would be proud of.
    “Nuclear Matters” is the new pro-nuke front group on the block. Although nothing is mentioned about its sponsor in the full-page newspaper ads this group pays for, Nuclear Matters is totally funded by our country’s largest nuclear plant owner, Exelon.
    Exelon’s US nuclear fleet includes 23 reactors at 14 different sites. As pointed out in the article at this link,
    http://www.huffingtonpost.com/elliott-negin/nuclear-giant-exelon-laun_b_5428994.html
    the nuclear industry is in dire straits. This is so “Mainly because of cheap natural gas and dampened electricity demand due to energy efficiency programs and a sluggish economy. The most vulnerable plants are in states with deregulated electricity markets, such as Illinois. Unlike regulated utilities, which are guaranteed an annual rate of return, these “merchant” plants sell power on the wholesale market and are being underpriced by their competition.”
    Furthermore the article states, “The (Nuclear Matters) website also lists some of the commonly cited reasons for the industry’s current plight, but, echoing Exelon, also blames federal and state policies that support wind and solar power, which it claims “distorts” electricity markets. Not only is that a dubious assertion, it’s especially ironic given the nuclear industry would not be economically viable without more than 50 years of federal subsidies, many of which continue to this day.”
    US nuclear plants pose a great risk to public safety. That they are in economic trouble and that some may be forced from service as a result is a blessing. Nuke plants, no matter how poor their safety performance is, will certainly not be regulated out of business by their lax regulatory industry bedfellow, the NRC. The nuclear industry is so invested in these old nuclear plants (with our money) that they just cannot let go. Kind of like a person coming into contact with a live electrical circuit. You may be shocked to beat hell but you just can’t let go!

  75. The Faint Signals
    A true leader and a fine person has retired. He worked for an electric utility in the Midwest for over 40 years. I had the pleasure of knowing him and working with him for many of those years. He was a civilian “mustang”, rising through the ranks from a nuclear plant test engineer to eventually become the utility’s President and CEO. Along the way he held positions as reactor engineer, operations manager and even nuclear plant manager. He earned an Atomic Energy Commission (AEC) senior reactor operator’s license. He also served as the utility’s Chief Nuclear Officer for several years.
    I have not known a more capable or conscientious fellow.
    A handful of years after becoming this utility’s CEO, unprecedented river flooding occurred at the utility’s nuclear plant extending a scheduled refueling outage. Regulatory concerns then kept the nuclear plant out of service for a couple of years.
    Taking ownership this CEO led his utility in not only restoring this nuclear plant to service but of also making it one of the safest nuclear plants in the world.
    Upon retirement and true to his typical professional form, this utility leader said of those nuclear plant problems, “The lesson learned there was to pay attention to the faint signals. There were faint signals that there were things we needed to work on.”
    With nuclear technology heeding those faint signals is so very important. If faint signals can slip by a top-notch utility organization and a leader like him they can slip by anyone!
    That is why we need to continue to listen to the voice of another conscientious nuclear power expert, the late Admiral Hyman G. Rickover. He said decades ago,
    “The whole reactor game hangs on a much more slender thread than most people are aware. There are a lot of things that can go wrong and it requires eternal vigilance.”

  76. Reactor Pressure Vessels Coming & Going
    I tried to include a picture of a used reactor pressure vessel (RPV) making a barge trip as well, but I could not get it pasted in. The used RPV was covered in pretty blue and appears to be a pretty benign package on its barge. Contrast that pic to this NRC-provided throwback pic of a new reactor pressure vessel heading to a site to the used RPV that is heading to a disposal site. The package on the Columbia River was the sealed and shielded reactor pressure vessel from the defunct Trojan Nuclear Power Plant, which ceased operation after 17 years. By disposing of the reactor pressure vessel in one piece the contractor said he saved 19 million dollars. For some reason the total cost for disposal was not mentioned?! This package contained two million curies of radioactivity, and that amount does not include the radioactive fuel that was removed before the reactor pressure vessel was shipped. To get a feel for just how much radioactivity this two million curies is, I offer a couple of comparisons…
    • The Curie-Meter-Rem Rule-this rule estimates the radiation dose rate one meter from a one-curie radiation source. At one meter from a one curie radiation source the dose rate is one Rem per hour. So after only five hours a radiation worker would receive his maximum allowable yearly dose of radiation or 5 Rem. So even one curie is a huge amount of radioactivity.
    • The Los Alamos Lab offsite radioactivity recovery project recently celebrated a milestone. Since 1999 they have recovered more than one million curies of radioactivity from 38,000 radioactive sources from 1,100 different locations in the fifty states.
    The radioactivity on this single barge is two times the amount of radioactivity recovered in over 15 years by the lab’s recovery project!
    Guess where this barge discharged its radioactive cargo? In a shallow land fill grave on the Washington state Hanford Reservation. The land fill that it is said,”…poses unique problems due to its close proximity to the Columbia River.”
    Such is another chapter in our nuclear power plant legacy series.

  77. Nuclear Power Predator?

    I admit I have been downright critical, even somewhat of a predator, regarding the nuclear power industry and, in my view, its lax regulator the Nuclear Regulatory Commission (NRC). I have tried to be constructive in my criticism but I am sure I have not been on many occasions. Speaking up is the only way I have to try and make the powers that be really put public safety first. It is, however, like tugging on superman’s cape or spitting into the wind. I may be a verbal predator but I feel the nuclear industry has been preying on the public for decades.

    No other industry on the planet has alarmed or endangered folks as much as this one.

    No other industry has made vast areas of our planet uninhabitable. An eighteen-mile exclusion zone still exists at Chernobyl after nearly 30 years. Ironically, an eighteen-mile exclusion zone has existed at Fukushima for over 5 years.

    No other federal agency is allowed by federal law to cloak so much of its business in secrecy. A confidential classification is used by all federal agencies. But a decades old Atomic Energy Act allows the NRC and the nuclear industry to add a special and unique additional security classification, so-called safeguards information. This has allowed the NRC to cloak literally tens of thousands of additional pieces of information in secrecy. Of course the real trouble with this secrecy is that fewer people can, in any way, question what is actually going on in the industry or in the NRC. Also this additional secrecy tells us just how much the founding fathers actually respected and even feared this energy source.

    No other industry has a “regulator” that depends on those it regulates for its very survival. This has allowed the nuclear industry to “capture” the NRC. The NRC will therefore do nothing to in any way make the nuclear industry less competitive or to threaten its very existence.

    Who is therefore the real predator?!

  78. “Don’t get me wrong—I love nuclear energy! It’s just that I prefer fusion to fission. And it just so happens that there’s an enormous fusion reactor safely banked a few million miles from us. It delivers more than we could ever use in just about 8 minutes. And it’s wireless!”

    — William McDonough

  79. “Eight years involved with the nuclear industry have taught me that when nothing can possibly go wrong and every avenue has been covered, then is the time to buy a house on the next continent.”
    — Terry Prachett

  80. Take the Public off the Hook First

    The troubled Pilgrim Nuclear Power Plant has been allowed to operate for years while the owner Entergy continues to try and figure out ways to improve the reliability of the station’s electrical switchyard and high voltage transmission lines. Meanwhile loss of offsite power events continue to occur which have challenged plant reactor operators and plant safety equipment. Recently even the NRC cited Entergy with nine violations as a result of the last loss of offsite power event at Pilgrim. In addition to citing persistent equipment problems at the plant, the NRC found a number of operator errors which aggravated the situation.

    There are three ingredients necessary to cause a serious reactor accident…

    1.An initiating event

    2.Equipment failure &

    3.Operator error

    All three were present in 1979 and caused the accident at Three Mile Island. All three were present recently at Pilgrim. Thank God we dodged the bullet a few months ago.

    It’s high time the NRC stopped firing warning shots at Energy over the persistent problems at Pilgrim. They should adopt the policy of a gun owner who is running out of ammo. “Due to a shortage of ammunition, warning shots will no longer be fired”.

    Seriously though, it is high time that Pilgrim be shut down until Entergy can actually make appropriate changes to its electrical grid. This would protect the public and also provide Entergy with a real incentive to actually take long overdue corrective action to solve this persistent problem.

    Take the public off the hook, not Entergy and its Pilgrim plant!

  81. Correction-The NRC is Not Digging Their Own Grave
    The NRC is not digging their own grave they are digging ours!
    I am sorry I missed this important point in my last communication. Repeat problems at nuclear facilities are threatening not just the nuke industry and the NRC but the public as well.
    The public is allowing and even paying the NRC and the nuke industry to put our very lives and property in jeopardy. Through our taxes and our utility bills we are contributing to our own potential demise.
    To not learn from history can be troublesome. To not learn from nuclear operating experience can be devastating.
    If nuclear utilities cannot afford to properly maintain and even improve their plants they should do the honorable thing and get out of the business. Unfortunately, they have so much of our money invested in them it is hard, I am sure, for any nuke plant owner to ever think of letting them go. It is akin to inadvertently coming into contact with a live electric wire, although it shocks the hell out of you, you just can’t let go.

  82. The Indian Point Unit #3 (IP3) Nuclear Power Plant Near Miss Accident May 9, 2015, Should Never Have Happened
    Two years prior to this flooding incident at IP3, an extensive flooding walk down of all flood penetration pathways was conducted by Entergy and IP3. Entergy submitted the results of this flooding walk down to the NRC November 27, 2012.
    Like walk downs required at other US nuclear power plants, these walk downs were conducted in response to lessons learned from the Fukushima flooding disaster in 2010.
    The IP3 flooding walk down report noted the following:
    “…a total of 65 walk down packages of features credited for flood protection” were included in the flooding walk downs.
    The IP3 submittal concluded, “Based on the operability determinations, none of the conditions observed during the walk downs were determined to pose a risk to the safe operation of the plant.”
    Yet, two years after these flooding walk downs, a serious water intrusion event occurs at IP3.
    Brings into question the adequacy of all such flooding walk downs at our US nuclear power plants.

  83. Nuclear Power Plant Flooding-Apparently Just Too Difficult a Problem for the US Nuclear Industry and the NRC to Solve
    I know it’s too long a title. But it seems it has taken way too long for our nuclear industry to get their arms around this critical nuclear safety issue, namely external and internal plant flooding. While I think they have the capacity, I do not think the industry has the will to do so.
    Back in 2010, a year before the tsunami and flooding at Fukushima, the International Atomic Energy Agency (IAEA) published a report on nuclear plant operating experience. Their report contains two sections devoted to operating experience with common cause and flooding in nuclear power plants. Quite a list of nuclear power plant flooding vulnerabilities is included.
    Where has our industry and the NRC been?! In spite of our own flooding operational experience over the years and the problems with it around the world, Indian Point #3 has a near-miss accident involving flooding?!
    Is this problem just too big for us to wrestle to the ground?! It better not be. Or else the public is one day going to be down for the count!

  84. Too Much Water in the Wrong Place…
    Recently, in New York City’s backyard, Indian Point Nuclear Power Station Unit #3 (IP#) experienced a near-miss nuclear accident. Too much water in the wrong place nearly resulted in too little water in the right place.
    Nuclear power plants are designed to prevent water intrusion events. However, there have been a number of cases where water has become an unwelcome guest in some of our nuclear plants. This incident at IP#3 was by far the worst as it threatened vital electrical switchgear. This could have resulted in the loss of all station AC and DC power. Exactly what did happen at Fukushima a few years ago.
    At IP#3 a water deluge system operated, apparently as designed, to quench a fire on the main transformer. The main transformer is located outside. But this deluge water somehow got into the plant’s electrical switchgear room. Makes one wonder if water from a heavy rain storm would have caused the same outcome (or worse)!
    Of course losing all on-site power (including emergency power) quickly results in too little water in the right place. Fuel in the reactor can no longer be cooled. A major nuclear accident is well underway.
    The NRC seems to be already downplaying the significance of this event. They are only using a three-person team to investigate the incident. This is the lowest level of investigative response in the NRC’s tool box. They must know that this has to be one of the worst near-miss reactor accidents at any nuclear plant on record.
    Time to level with the public NRC!
    Unfortunately, there is a long history of water intrusion events at our nuclear power plants. The NRC has issued many warnings to the nuclear industry about this potential hazard. Why then does it still occur?!
    Is there a similar problem at this site with its nuclear neighbor, IP#2? Seems obvious that there still may be similar vulnerabilities elsewhere in the US nuclear fleet as well.
    High time for the NRC to step up to the plate in the interest of public safety.

  85. I Want the Old NRC Back
    The old NRC certainly had their flaws back then but you had no doubt whose side they were on. They put public safety first. Today’s NRC has the back of the nuclear industry not the public.
    We can thank the old NRC, though, for contributing to the worst US nuclear plant accident ever at Three Mile Island (TMI) in 1979. However, the post-TMI NRC was a no-nonsense regulator for a long time.
    Today, sad to say, that old no-nonsense regulator is long gone.
    That good old NRC always…
    • Took a conservative approach to safety…placing public safety first.
    Comment: Unlike today’s NRC, when the old NRC was faced with doubt or uncertainty they would “error” on the side of public safety.
    Sidebar: This is much like the EPA today. If they error they overregulate not under regulate. They practice the 3 Cs…”Come Clean & Comply or Close” (maybe that should be the 4 Cs). Keep in mind what we are talking about here. Nuclear power plants have been & are potentially the most hazardous human endeavor that has ever existed on planet Earth (right alongside nuke weapons). We need a real tough regulator to help ensure this dangerous nuclear genie does not come out of the bottle yet again!
    • Took prompt conservative action when reactor safety was involved without being paralyzed by analyses.
    Comment: Today’s NRC waits on protracted nerdy risk assessment analyses before taking any action whatsoever. These risk analyses contain huge uncertainties and scads of assumptions. They are, however, an NRC nerd’s job security. But to rely so much on them is foolhardy as they are biased & rationalize real safety issues. Note: “Man is not a rational animal. He is a rationalizing animal” Robert Heinlein. After all the investments in nuclear plant safety improvements since TMI (& there were many), I believe there is a pro-nuclear bias at the NRC. The mind-set there is that US nuclear power is inherently safe and even overregulated. The “It-Can’t-Happen-Here” mentality is still at work in the agency even though this premise has been proved wrong time and time again. This “too safe to ever be really concerned” attitude of course can’t help but bias any analysis toward an industry-favorable outcome.
    • Strived to make nuclear power safer.
    Comment: Today’s NRC strives instead to please the nuclear industry. The old NRC required that measures be taken to help prevent nuclear plant events and accidents. Today’s NRC accepts nuclear industry initiatives to improve safety instead of issuing new NRC regulatory requirements. While that sounds good, the industry knows full well that the NRC cannot enforce compliance with such initiatives because they are not federal requirements. Those industry initiatives are also the cheapest ones the industry thinks they can get by with. After all, the NRC and the nuclear industry would not want to do anything to further degrade the long-lost nuclear power competitive edge in the marketplace. The most recent glaring example of downright kowtowing by the NRC to the industry (it is supposed to regulate), involves of all things measures to prevent a Fukushima-type accident from occurring in this country. The NRC is allowing the nuke industry to only mitigate the consequences of such an accident in this country when it occurs?! The old NRC, thankfully and appropriately, required both extensive measures to prevent another TMI-type accident and measures to mitigate it in the unlikely event it still occurred. When I think that the new NRC cannot stoop any lower, they do! Today’s NRC has been “captured” by the nuclear industry. And, unfortunately, we all may soon be required to pay a huge “ransom” because of it.
    • Called a spade a “_______” shovel. With today’s NRC PC talk and techno-speak, nothing ever sounds serious or even understandable.
    Comment: Level with us; be straight with us. Don’t promote in any way the nuclear industry. Otherwise you will continue to be perceived as nothing more than a nuclear industry lap dog.
    • Utilized all the tools in their regulatory enforcement tool box.
    Comment: Over the years our new NRC has issued far fewer civil penalties to nuclear plant operators. Why is that?
    Certainly not because nuclear plant regulatory compliance has improved. Dave Lochbaum identifies nuclear power plant “chronic underperformers” using NRC data in an article he wrote in “All Things Nuclear” on April 21, 2015.
    No, the real reason for fewer civil penalties is that the NRC has, for the most part, chosen to leave this enforcement tool in the box.
    Just look up “NRC significant enforcement actions” on the net. There are many escalated enforcement actions involving nuclear power plants listed, but it is rare to see a civil penalty issued as a result. The new NRC has also made more use of mediation sessions with licensees called Alternate Dispute Resolutions (ADRs). Sort of a nuclear “plea bargaining” session, the details of which are kept from the public. Perhaps the NRC feels that a large civil penalty is just penalizing the utility ratepayer as these nuke plant owners simply pass it on in their customer utility bills.
    It is ironic that regularly the NRC adjusts, for inflation, the maximum amount it can assess in penalties (now up to $140k per violation per day) when they rarely even issue a penalty. In the rare cases they do issue a civil penalty, the amount they actually fine a utility is a very small fraction of the allowed maximum. For nuke utilities this is treated as a minor cost of doing business.
    The real impact though of a civil penalty is that it hits the offending utility right in its PR gut and attracts much media attention. Civil penalties should be used more, especially when dealing with those chronic nuclear plant underperformers. Unfortunately, some nuclear utilities will only respond to a regulatory 2×4.
    Finally, the NRC should not allow nuke power plants, assessed a penalty, to just pass it on to their customers. Make the CEO or the CNO (Chief Nuclear Officer) of the offending utility personally pony up the money. Or, even better, make the utility’s stockholders pay it.

  86. Strike Three-the Public is Out!

    Just like a 100 mph fast ball, the NRC and the nuclear industry have smoked another major issue right past the public. And now they brag about it! According to this stilted account we can all sit back and relax; a Fukushima-type disaster can never happen in this country. The NRC and the nuclear industry have come up with, and partially implemented, “mitigation” strategies. What?! Not “prevention” strategies but only “mitigation” strategies?!

    Thankfully, a Three Mile Island-type accident has not happened again in this country. And that is so because we accepted only “mitigation” strategies after that accident in 1979?! No, it is because we figured out many ways to “prevent” another TMI accident.

    Recall how after the terrible Chernobyl accident in the Ukraine in 1986 our nuclear industry said such an accident could not happen here. I still believe they made the right call then, as that Soviet-designed reactor was inherently unsafe and had no robust containment structure around it to help prevent the release of radioactivity.

    The Fukushima reactors in Japan are carbon copies of many of the reactors operating here. Instead of doing the right thing, nothing regarding “prevention” of a Fukushima-type accident here is even being considered. This simply defies logic in my opinion. This proves to me that the NRC has caved to the nuclear industry.

    This is like a defendant being found guilty of a capital crime and being released. No one has had the audacity to lie and say that a Fukushima-type accident cannot occur here in the US. In fact they have admitted that it can happen here. The only sentence for pleading “no contest” is that WHEN an accident occurs here we expect you to do a better job of “mitigating” its consequences.

    It would be akin to having the EPA say that WHEN you have a devastating oil spill, you only have to have suitable cleanup equipment available. Although I have had heartburn with some of the overreach and overkill of the EPA, they always seem to “error” on the side of protecting the public.

    The EPA, however, does not have the handicap the NRC has. The EPA will not enforce its way out of existence. In doing the right thing, however, the NRC may harm the very host that sustains them.

    I have lost hope in the NRC. As they are configured they will never, ever be able to put public safety ahead of preserving the viability of an unforgiving and dangerous method of producing electricity.

  87. Just wondering NRC, where is your earth day post?! You know the one about nuke plants saving the world?! Oh, I forgot about nuke plant pollution; high level radioactive waste; not to mention the people that have been killed, maimed, and traumatized by nuclear power. Please forget I even mentioned earth day.

  88. Nuclear Power is “Green” Power?!
    Some nuclear proponents continue to assert that nuclear power is green power and should be listed right alongside solar, wind, geothermal, low-impact hydro, etc. How terribly wrong and misleading is that?! Nuclear power has left a legacy that no proper President would ever desire. Nuclear power has scarred people and our planet. Nuclear power has left a legacy of high level radioactive waste stored all over this country. No, nuclear power is not “green” power, it is “gangrene” power and needs to be excised!

  89. This is a follow-up to comments I have made relative to a serious Fukushima or Chernobyl-type nuclear power plant accident at one of our NPPs (Nuclear Power Plants). I believe the 10-mile emergency planning zone around our NPPs is woefully inadequate in the event of a serious accident. This concern is greatly amplified as the NRC is not requiring US nuclear plants to make appropriate NPP changes to prevent a similar accident here. The NRC is bowing to industry pressure by allowing the nuclear industry to just figure out better ways to mitigate a similar accident here when it occurs. We all know that public protective measures were needed far beyond the 10-mile radius at both Chernobyl and Fukushima.

    I know that there are many things that must be considered right after a serious NPP accident. Let me offer some inconvenient details of my own…

    The calendars that are sent annually to each family within 10 miles of a NPP contain information on protective measures that may be necessary and relocation centers that will be available to folks that have to (or more likely choose to) evacuate. Relocation centers are situated just outside the 10-mile radius of a NPP in several different directions. These centers would then not only be relatively convenient at least some of them would not be downwind of a potential radioactive release. (Fine as long as the wind doesn’t change direction like it did in Japan). The trouble is these centers, since they are still relatively close to a NPP, may themselves be uninhabitable due to a serious accident at a NPP. Note to Self: Know a safe friendly place to go well outside the 50-mile radius of a damaged NPP.

    I mentioned that literally millions of folks live within harm’s way of nuclear plants. Nuke utilities have the mailing addresses of those folks unfortunate enough to live within 10 miles of a NPP. These addresses would be helpful to authorities to try and track down folks that could not or would not evacuate, PROVIDED, rescue workers could safely enter such areas after an accident. Beyond that, these addresses would be useless. No telling when anyone could return home if ever. The media would be telling folks to call hotline numbers. Many hotlines would have to be set up to handle millions of calls from folks who had to leave their homes, both inside and beyond the 10-mile radius.

    I don’t want to consider this further at this time…too depressing.

    In closing, an old cartoon depicted an NRC inspector telling a nuclear power plant executive about what the inspector thought of the utility’s nuclear accident emergency plan. The NRC inspector said flatly, ‘Run for It’ is not an acceptable emergency plan. ‘Run for it’ is not an acceptable NRC emergency plan either!

  90. Correction:
    My old friend and emergency planner said I misquoted him. I said that he said “Rings of Death”. He said what he really said was “Wheels of Death”.
    Sorry for the misquote?!

  91. Despite evidence to the contrary, the Nuclear Regulatory Commission (NRC) persists in having non-conservative emergency planning zones around US nuclear power plants. These so-called emergency planning zones are 10-mile radius and 50-mile radius circles around nuke plants (many years ago my nuclear emergency planner jokingly called these zones the rings of death). Turns out he was not far off. There is still an 18-mile radius exclusion area around the now entombed Chernobyl nuclear power plant (NPP) even after 29 years. Ironically, there is an evacuation zone around the damaged Fukushima reactors and spent fuel pools in Japan that has an 18-mile radius also. And recall that our NRC recommended that all Americans within 50 miles of Fukushima leave “Dodge” during the nuclear crisis there.

    According to our NRC, only folks within 10 miles of a US NPP would ever have to evacuate, or hunker down in their homes, or take potassium iodide pills in the event of a nuke accident.

    And these folks in the backyard of a nuke plant are the only ones that are mailed every year a cute little calendar that tells them what to do if their next door nuclear neighbor goes ballistic. What these folks should also be sent is a nuclear accident radiation consent form. You know a document like the type you have to sign before undergoing radiation treatment. A medical “CYA” form that holds harmless the irradiator from any liability if things go south.

    One third of all of us in the US live within 50 miles of at least one nuclear power plant-about 120 million folks. There is unfortunately hardly enough NPP accident insurance to even cover the postage that would be required to send accident survivors a claim form.

  92. When I worked in a nuclear power plant a reactor operator I knew was also a volunteer fireman at a nearby small town fire department. He jokingly confided in me that in all his years responding to fire calls he and his volunteer fire-fighting buddies almost always arrived in time to put out the ashes.

    The same could be said for the NRC’s response to the Fukushima accident in Japan. The NRC has asked the nuclear industry to come up with “mitigation” strategies for a Fukushima-type accident in the US. Mind you the NRC is not asking for “prevention” strategies, but just for “fire-fighting” strategies in the event of a similar nuclear accident here. The NRC is, of course, bowing to industry pressures instead of doing the right thing. Doing the right thing would be requiring nuke plants to make substantial changes to prevent a nuclear accident, much like the old NRC required after the Three Mile Island accident in this country. The new NRC does not want to harm the industry that sustains it. In doing the right thing the NRC would cost nuke utilities just too much money.

    But what are the real costs to public safety in so doing?!

    28 years after the Chernobyl accident 1,000 square miles of territory is still an exclusion zone around the entombed reactor there. 1,500 square miles of land, around the crippled reactors and spent fuel pools in Japan, are contaminated. The real costs though were the deaths, injuries, and traumas to those folks living nearby those plants. Yes, even in Japan, there were deaths. Well over 1,000 Japanese have died just from being evacuated from their homes and not being allowed to return. Not knowing when or if they could return to their homes has killed many citizens especially seniors and the disabled. Radioactive contamination is akin to a strike by a neutron bomb. A neutron bomb kills all life but leaves everything else just as it was. And due to the low-level of radioactive contamination with a neutron bomb the conquering aggressor can occupy the land in short order. Not so with A-plant contamination. No structures, material possessions, vehicles, etc. are harmed by radioactive fall-out, but victims of an A-plant accident cannot even return to assess the situation. Even after natural disasters people can return to devastated areas in a relatively short time. A-plant accidents leave lasting scars on people and the environment.

    I am afraid of this new NRC. They have lost sight of their prime directive-to protect the health and safety of the public.

    The NRC, is in effect, allowing the nuclear industry to arrive in time to “put out the ashes”!

  93. Sorry, machine shop operators! You let me know in no uncertain terms that you did not like me comparing you to a lax federal agency. Please accept my apologies.

  94. An funny old machine shop saying is…
    “Beat to Fit”
    “File to Suit” &
    “Paint to Hide”

    It is not funny though when a federal agency applies this saying to its critical mission of protecting the public from the potential hazards of nuclear power plant (NPP) operation.
    The Nuclear Regulatory Commission (NRC) unfortunately, and mainly through default, applies this philosophy to its nuclear plant safety “oversight” activities.

    “Beat to Fit”

    The NRC puts the nuclear industry first, not public safety. They have beat regulations to fit what the industry desires. The NRC has the same dangerous mind-set that the nuclear industry has, namely, that nuclear power is super-safe and over-regulated. Therefore the NRC has even loosened enforcement of its own regulations. Not only that but the NRC has on a number of occasions allowed the nuclear industry to come up with voluntary initiatives to avoid having the NRC either enforce current regulations or develop new ones. Trouble is these voluntary industry initiatives fall short of adequately addressing safety issues and, perhaps even more troubling, the NRC cannot even enforce voluntary licensee actions since they are not the law.

    “File to Suit”

    Gradually the NRC has filed off the sharp edges of their safety regulations. Instead of figuring out ways to improve NPP safety the NRC has relaxed requirements. A number of the lessons learned from the horrible accident at Fukushima in Japan are not being addressed at US nuclear plants. The NRC is even considering allowing the nuke industry to only mitigate and not prevent a similar accident here.

    “Paint to Hide”

    This is probably the worst NRC practice of all. NRC conducts a lot of its business in secret. The NRC even has a secret additional classification beyond “confidential” that no other federal agency has. It is called “Safeguards Information”. With it the NRC can hide literally tens of thousands of additional documents from the public. Furthermore the NRC does not level with the public. They paint over nuclear safety problems and give the public constant reassurances that nuclear is safe when they know different. The NRC, like the old AEC they replaced, are nuclear power proponents not unbiased safety regulators.

    Time for the NRC to “man up” and put public safety first.

  95. Do As I Say, Not As I Do

    The NRC does not do what it tells others to do. ‘Do as I say not as I do’ is the real mantra in play at the NRC. The NRC tells the owners of nuke plants to always put reactor safety first. To always take a conservative approach to safety. But time and again in its history the NRC itself has set a horrible example. Certainly the NRC has been pressured over the years by the nuclear industry to lower and not even enforce safety standards. This pressure has been brought to bear through industry propaganda organizations like the Nuclear Energy Institute (NEI) who line the pockets of politicians to ride roughshod on the NRC. And the NRC has caved to industry pressure time and time again. This spineless agency has all but forgotten that their only mission is to protect public health and safety. It is so bad at the NRC that now a synonym for “inaction” in the dictionary is the Nuclear Regulatory Commission. Inaction is their mode of operation. Only when actual serious events take place do they take any action whatsoever. And even that is quite limited. The NRC harps on the nuclear industry about learning from others bad experiences. But the NRC itself doesn’t learn from others. Examples…

    Recommendations that pertained to the NRC changing its way of doing business after the Three Mile Island accident were totally ignored.

    Known nuclear safety problems were not addressed by the NRC until those, so-called, “never can happen here” problems actually resulted in serious events at our nuclear plants. Anticipated Transients Without Scram (ATWS) and Station Blackout (SBO) events are prime examples.

    The NRC has allowed spent, yet highly radioactive fuel, to pile up at nuclear plants all over this country. We have all noted how spent fuel pools in Japan boiled dry and released huge amounts of radioactivity to the environment. And their pools contained much less spent fuel than the amounts of spent fuel that have been allowed to accumulate in US nuclear plant spent fuel pools.

    Now we are faced with an NRC that is NOT going to focus on PREVENTING a Fukushima accident in this country. The NRC is seriously considering allowing its partner in crime, the nuclear industry, to focus instead on MITIGATING a Fukushima-type accident here after it happens?!

    How in the world can anyone conclude that the NRC is really putting reactor and public safety first with this horrendous safety track record?!

  96. From “The Age of Radiance” by Craig Nelson

    “Global Fission” author Jim Falk: “People have come not only to distrust the safety of technology but also the authority of those who have assured them so confidently that nuclear power is safe. In this sense people distrust the entire nuclear enterprise-not only its technology, but the public and private organizations, the political parties, and those often prestigious scientists who advocate and assist in the development of nuclear power.” With nuclear power calamities we have learned through harrowing experience that you can’t trust the government, you can’t trust the industry, and you can’t trust the critics…or even your own fears. One psychiatrist, Robert DuPont, has spent years studying radiophobia: “On all four counts, nuclear power generates fear. It’s a cataclysmic accident that people are concerned about. It’s controlled,by “them”, the utilities or the government or the sciemtists or whoever it is perceived as the bad guys. It’s unfamiliar to most people, and most people feel they don’t really need nuclear power, that they can get their power from coal or oil or windmills or some other basis.”

    The atomic utility industry and its governmental affiliates have done such a poor job of both educating the general public and managing their crises that they will be driven out of business. Atomic utilities now require state-funded corporate welfare to build their plants, to insure them, and to nationalize them when disaster strikes. How many politicians can afford to bankroll reactors at every stage? How many parents want a burning radioactive pile anywhere near their young children? Unless some, dramatic technological breakthroughs completely rework public opinion, not in your lifetime and probably not in your children’s lifetime but eventually, nuclear power will become so insignificant that it will be essentially meaningless. Certain countries, such as France and parts of the developing world, will continue with nuclear power, and, we need some reactors to make radioisotopes. But otherwise, as politics and as business, nuclear power has stopped making sense.

  97. The Trouble with Secrecy
    The trouble with secrecy and deception by the NRC and our government is that proper precautions are sometimes not taken without pressure from the public and media. Take the potential devastating accident caused by a plane crash into a nuclear plant. Despite the smoke screen set up by an NEI whitewash report, the smart folks at the NRC have probably known about this horrible possibility for a long time. Has what the NRC likes to call, compensatory measures, been taken to lessen the likelihood of a nuclear power plant Armageddon in the US?

    For example,
    • Has the FAA changed air traffic control patterns around airports to vector planes well away from nuke plants?
    • Has the USAF placed fighter jets on alert status so that any deviation from these safer commercial air traffic routes can be quickly detected and responded too?
    • Are no-fly zones still in effect around our nuclear plants?
    • Have these zones been appropriately expanded to take into account this dire threat?
    • What additional actions have the TSA and the Department of Homeland Security taken? For example are aircraft pilots armed? Or better yet have additional Air Marshals been assigned to aircraft? Are Air Marshalls even disguised as airline employees been assigned to the cockpit?
    What other actions by our government have been taken to protect other of our nation’s vital infrastructures?
    For example, what about upstream dams on major waterways? Not long ago the only “protection” afforded our many vital dams was an International warning sign. The warning sign is bright orange and is clearly visible from the air. The sign has words to the effect that targeting a dam is forbidden during a war. And for terrorists targeting an old upstream earthen dam on the Missouri River there is a disaster bonus. Two downstream nuclear plants could be wiped out as well. Also breaching one earthen dam results in the overtopping and breaching of all downstream dams from there. Is it not ironic that nuclear power plants have extensive security systems that make them a so-called “hardened target” to terrorism but that the upstream dams protecting them had virtually no security whatsoever?
    But I am sure the NRC and the government has our backs. The threats they hide from us have I am sure already been secured and rendered benign.
    If you don’t believe that, well, you have not been drinking enough of the NEI kool-aid.

  98. I stand corrected. The nuclear industry only engages in “disinformation” and not propaganda. Propaganda is only used against our enemies. Now I feel much better!

  99. Is the Mushroom Treatment Justified?
    Can the public really expect anything other than the mushroom treatment from the NRC?!
    Is it OK for our government and its agencies to have and keep secrets?
    Is it OK for the nuclear industry and its propaganda mouthpiece the Nuclear Energy Institute (NEI) to not only keep secrets but to intentionally lie and mislead the public about the safety of nuclear power plants?
    Why is the NRC unique among federal agencies in having the power to keep much more information secret?
    Are nuclear hazards so much greater than all other hazards to public health that such additional secrecy is necessary?
    Is secret keeping and lying to the public necessary to keep nuclear plant vulnerabilities from terrorists and other potential enemies of this country?
    Should we be able to depend on the NRC to be the “No-Spin Zone” for all things nuclear?
    Can we depend on the NRC to tell us if the nuclear industry is not giving the public a fair and balanced view of nuclear safety?
    I believe…
    • That the NRC realizes down deep that nuclear power is potentially very dangerous and therefore any and all secrecy and misinformation about it on their part is totally justified.
    • That the true mission of the NRC is to give the illusion that they are regulating the industry while in fact they are promoting the industry.
    • That the NRC inappropriately feels they are “physicians” first and foremost and that their prime purpose is to do “no harm” to the nuclear industry.
    • That the NRC has abused its authority in keeping much more information from the public than other agencies can. In fact the NRC is allowed to go way beyond the “Confidential” category utilized in our government and other agencies. They have classified tens of thousands of additional documents, meetings, & conversations as so-called “Safeguards Information”. Even when this practice has been repeatedly questioned by oversight groups the NRC has not done one thing to address it.
    • That the NRC is very much pro-nuclear.
    • That the NRC will allow the nuclear industry to spin its propaganda without challenge, even though they know it is misleading or even false.
    • That the NRC public relations folks are nearly as good as the NEI and nuclear industry PR folks in giving the best nuclear propaganda that we taxpayers can buy.
    But again what can we expect from an agency that has been “captured” by the folks it is supposed to regulate?!

  100. The NRC has an API available which allows developers to access raw data.
    http://www.nrc.gov/developer.html

    This is usually only useful to computer programmers as the output is in JSON or XML. However, you can use a tool to turn the JSON output into CSV by using https://json-csv.com. This allows you to open the data in a spreadsheet for analyzing. Someone else might find this useful.

  101. The 10-Minute Murderer
    We are five to ten minutes from the start of nuclear plant Armageddon.
    In the NEI report on an aircraft crash into a nuclear plant, the postulated speed of a freshly-fueled jet liner is a little over 300 mph. 300 mph is 5 miles per minute. This speed according to NEI is the most likely controllable speed close to the ground of a hijacked commercial airliner.
    The NEI report then assures us that hitting a spent fuel pool is next to impossible because these pools are very small targets. Furthermore, NEI assures us that a large aircraft could not hit the spent fuel pool at a high enough angle of attack to get at the spent fuel which is under more than 20 feet of water in these pools. In addition these pools are surrounded by massive concrete walls with a steel liner.
    What NEI conveniently overlooks is that it is not necessary to directly hit a spent fuel pool to start nuclear plant Armageddon. A Pentagon-type hit anywhere in the large building surrounding a plant’s containment building, the so-called auxiliary building, will be quite sufficient. A raging fire in the auxiliary building would result. In a relatively short time there would be no way to cool nuclear fuel in the reactor itself or in the spent fuel pool. Nuclear plant Armageddon-the worst imaginable nuclear plant disaster would be underway.
    At five miles per minute, any of our nuclear plants within 50 miles of a large airport can be hit in 10 minutes or less. That is insufficient time for any intervention to take place on the hijacked aircraft-even intervention by heroic passengers.
    NEI, your report is a terrible whitewash! Your report gives us assurance when it should be giving us a stark warning.

  102. The Elephant in the Room
    In late 2002 NEI and EPRI released a report on an aircraft crash into a nuclear power plant. The report is reassuring. The report concludes…
    “Although full analytical details will not be released to the public for security reasons, NEI announced the following general results:
    • For the models representing all types of U.S. containment buildings, no parts of the engine, the fuselage, the wings or the jet fuel entered the containment buildings. The containment structure was not breached, despite some crushing and spalling (chipping of material at the impact point) of the concrete.
    • Evaluation of the models representing both types of used fuel pools determined that the stainless steel pool liner ensures there would be no loss of pool cooling water even though some crushing and cracking of the concrete occurred at the point of impact. Because the used fuel pools were not breached, there would be no release of radioactivity to the environment.
    • For the analyzed dry fuel storage facilities, the steel canister containing the used fuel assemblies was not breached. Because the dry storage structure was not breached, there would be no release of radioactivity to the environment.
    • For the analyzed used fuel transportation container, the container was not breached, so there would be no release of radioactivity to the environment.”

    This report, although reassuring, does not consider the horrible consequences of all that aviation fuel spreading and burning intensely throughout the so-called auxiliary building surrounding the containment building. Recall the deadly fire in the World Trade Center caused by an estimated 90,000 pounds of jet fuel. Did you know that some commercial jet liners can carry over a quarter-million pounds of aviation fuel? So you don’t have an immediate release of radioactivity as the report suggests. In a short time however plant reactor operators will lose control of the reactor itself as safety equipment, power centers, power supplies, and instrumentation and controls will be rendered inoperable by the intense heat of the fire. Plant operators will then be flying blind with no ability to even monitor let alone control the reactor. As a result the reactor core will be uncovered and core melt will follow. There will also be no ability to, in any way, mitigate this China Syndrome event. The containment building itself will be breached and huge amounts of radioactivity released directly to the environment. Also the ability to cool the water in the spent fuel pool will be lost-no power to the cooling pumps or controls. Although it will take longer than reactor core to melt, the spent fuel pool will eventually become a boiling cauldron and the fuel therein will eventually become uncovered and will melt as well.

    Also there will be no way to fight this raging fire in the auxiliary building. Recall the heavy black smoke and the intense heat generated by the fire in the WTC? Manual fire fighting will be impossible. Even any installed fire suppression systems will be rendered inoperable by the airplane crash itself or by the intense heat of the fire.

    The auxiliary building has a lot of open space but there are a number of equipment and cable penetration areas that are individually protected by so-called 3-hour rated fire barriers (doors and penetrations). These of course will be breached by such an intense and long duration fire.
    The good news is that this devastating accident will take a few hours to reach its peak. But just like the towers fell in a short time, this worst case reactor accident will unfortunately take only a short time as well.

    There will be a few hours to try and evacuate people for miles around the stricken plant. It will be next to impossible, however, to evacuate people from around a nuclear plant in the backyard of large cities. Realizing this there would be a likely call for a large number of people to just stay in their homes, so-called in house shelter. Can you imagine what you would do under these horrible circumstances?! Voluntary flight would occur. People would die just from the evacuation process. Many others would die, just like over a 1,000 people have died so far in Japan, from the prospect of never being able to return to their homes. The elderly and the impaired are the ones who suffer the most.

    A terrorist attack by a large commercial jet liner on a nuclear plant would be catastrophic. Don’t let the Nuclear Energy Institute (NEI), the mouthpiece for the nuclear industry, say otherwise. It is truly amazing to me that a million-dollar study by NEI would fail to mention the horrible elephant in the room!

    On second thought, not amazing, but truly negligent!

  103. The NRC and Pharaoh Are Two Peas in a Pod
    Background
    Recall that Bible story in the book of Exodus? Moses pleaded time and time again for Pharaoh to do the right thing and let God’s people go. They were held in involuntary servitude as slaves in Egypt. The Bible says that Pharaoh’s heart was hardened nine times despite ten horrible plagues being brought on Egypt by God. It is said that God hardened Pharaoh’s heart six times and Pharaoh hardened his own heart three times. Finally Pharaoh released the slaves.
    There have been 99 nuclear power plant (NPP) accidents (plagues) in the world. 57 NPP accidents have occurred since the Chernobyl disaster. The worst ones were the Fukushima nuclear disaster (2011); Chernobyl (1986); Three Mile Island accident (1979); and the SL-1 accident (1961). I believe man not God was responsible for these accidents.
    The Comparison
    It took just ten plagues for Pharaoh to finally learn his lesson. Has our nuclear industry and our regulatory agency, the NRC, really learned their lesson?! Does the NRC even have a heart to harden? Despite a number of senior NRC managers visiting the devastation in Japan, the NRC is seriously considering relaxing its safety design criterion for US plants vulnerable to the same events as those that caused the accident in Japan. How can this be?! If the NRC has a heart who is hardening it? Is it the NRC Commissioners appointed by our President? But who may be pulling the string on the Commissioners? Most likely the strings are being pulled by congressional reps and oversight groups that are in the pocket of the nuclear industry. There is a huge lobbying effort that has gone on for decades in support of all things nuclear. Research a few years ago revealed that the nuclear industry’s Nuclear Energy Institute (NEI) gives more money to Congressional reps than all but three groups – AMA, the tobacco industry, and I think the third was AARP.
    How about a few more specifics…
    In 1996, Dr. Shirley Ann Jackson was the NRC’s Chairwoman. She instituted many positive changes. She got rid of a bad Executive Director for Operations, a bad director of the office of Nuclear Reactor Regulation, and replaced all of the regional administrators. In addition to the managerial changes, Chairman Jackson had a simple rule – if a regulation is on the books, we will enforce it or revise it. We will not ignore it. Nine of the nation’s then 104 operating reactors were shut down during all of 1997 because they did not comply with safety regulations. No excuses were allowed – you complied or you shut down until you did. The nuclear industry did not like having to follow the regulations. So, they went to Senator Domenici, head of the Senate’s appropriations committee. On June 4, 1998, his committee threatened to cut the NRC’s budget by 40%. To avoid “drive-by regulation,” the NRC agreed to concessions to placate Senator Domenici. They essentially stopped enforcing the big regulations. Chairman Jackson soon resigned and became president of RPI University.
    In the late 1990s, Dan Berkovitz was nominated as a Commissioner. He had worked on Senator Glenn’s staff. But he’d irked NEI by helping Senator Glenn’s committee conduct a July 1993 hearing on how the NRC handled whistleblowers. In those days, the NRC would promise confidentiality to whistleblowers, and then pick up the phone and call the companies to tell them who ratted. The companies were then able to fire the right messenger rather than having to wipe out a bunch to get the right one. Senator Glenn’s hearing exposed this practice and forced the NRC to change how it conspired to butcher whistleblowers. The industry did not take kindly to it, so they torpedoed Berkovitz’s nomination.

    Are Congressional “gods” still really pulling the strings of the NRC?!

    Moderator Note: Some verbiage removed at the request of the commenter.

  104. The Real NRC Mission
    The stated NRC Mission is “To protect public health and safety, promote the common defense and security, and protect the environment”.
    Nowhere in this mission statement are these actual NRC activities mentioned…
    • Protecting and even promoting the interests of the nuclear power plant industry.
    • Relaxing NRC safety requirements when the nuclear industry says it would just be too costly to do the right thing.
    • Putting avoided costs to the nuclear industry ahead of reactor and public safety.
    • Allowing nuclear power plants to operate in violation of their licensing bases; or their nuclear plant general design criterion; or their original design basis when it is discovered that such design basis is no longer adequate.
    • Allowing nuclear power plants near large and growing population centers to continue operating knowing full well that emergency plans for public protection are suspect and not even considered adequate by local, county, and state emergency planners.
    • Abrogating the NRC leadership role in the world by not improving the safety of existing nuclear power plants and not properly handling high level radioactive wastes.
    • Discrediting and otherwise retaliating against whistleblowers.
    • Conducting a large part of NRC business in secret.
    • Ensuring the survival and growth of the NRC itself.
    Another striking comparison for me is examining how the EPA and the NRC handle noncompliance with their requirements. As you are aware a number of enterprises have had to cease operation when the costs to comply with EPA regulations are just too much to handle. Nuclear power plant owners on the other hand are given a pass by the NRC on meeting NRC requirements that the nuke industry feels will adversely affect their profit margin or their competitiveness in the energy marketplace. But that’s what you get with a regulatory agency that has been “captured” by the industry it is supposed to be regulating?!

  105. Relying on the licensee to look for, report, and correct problems is as it should be. But what if a licensee is negligent in this regard? Can the resident prod the licensee to do the right thing?! For example, the NRC has over the years issued a number of so-called Information Notices regarding recurrent problems with penetration seals associated with flood and fire barriers. These notices however make it very clear that no action by the licensee is “required”. I believe good responsible licensees will pick up the ball on these notices (even though no action is required) and at least check by sampling to see if similar problems may exist in their power plants. But what if, like ANO, they take no action whatsoever?! Can the NRC Resident Inspector require the licensee to check for similar problems? If not then the NRC should issue an NRC Bulletin (or other mechanism) to “require” action on the part of the licensee. Recurring problems in the nuclear industry are totally unacceptable. Not only should such potential generic problems be promptly communicated to other licensees but action should be required to address them.

  106. NRC regulations require licensees to look for, report and correct any conditions that are adverse to quality or safety. The Resident Inspectors are there to ensure the licensees comply with the regulation.

    Division of Inspection and Regional Support
    Office of Nuclear Reactor Regulation

  107. Thank you Ms Moderator. I look forward to your next post on this blog and its status. I also have noted that it seems you have responded to more blog commenters on this site than in the past. I have no problem at all with the NRC telling me to “pound sand” on my comments. But when there is no response at all from you on a comment it scares me that there may be an element of truth in what I am trying to say. Again thanks for the feedback.

  108. To date, this blog has posted more than 4,800 comments. Those that are edited to adhere to blog guidelines are noted as such in the comment itself. One comment was not posted in the past year, with the agreement of the commenter, who resubmitted the comment with language that adhered with the blog guidelines. Duplicate comments, however, are not posted.

    All comments moved to the Open Forum from other posts are all noted as such. A number of comments have been reviewed by the allegations staff, which has delayed their posting, but none have been ultimately ruled as an allegation.

    All comments are reviewed by NRC staff, but the NRC does not respond to every comment or question. We’ll be updating our comment policy in the near future, and will also write a post updating readers on the blog and its status.

    Moderator

  109. NRC Blog Site Utilization Update
    It has been over two years since you updated us on the use by the public of the NRC Blog site. It has been four years since the NRC initiated the blog site.
    Please update the information you last provided January 3, 2013.
    In addition would you include in this update answers to these questions…?
    What % of blog comments were:
    • Edited or deleted because they did not meet your blog comment guidelines?
    • Moved from the NRC Blog site to the NRC Open Forum site because they were deemed to be unrelated to the NRC post under which they were submitted?
    • Determined to be allegations, and therefore not posted at all? And finally,
    • Not acknowledged in any way by NRC blog moderators? Please provide separately the answer to this question for both the NRC Blog site and the NRC Open Forum site.
    I applaud the NRC for establishing forums for dialog with the agency.

  110. The Perfect Serial Killer
    Background Information
    Back in 1939, one of the early nuclear energy pioneers, Leo Szilard, described a new discovery to Albert Einstein, he labeled it uranium fission. As discussed in Craig Nelson’s 2014 book, The Age of Radiance, Einstein, when hearing of fission, was quiet for a moment, then explained, “I hadn’t thought of that at all.” Einstein went on to say that fission would be the first source of energy for human beings that did not derive from the sun. This is still, to this day, over 75 years later, technically true. The sun’s light powers photosynthesis-the original force of coal, oil, and natural gas-and its heat and light together generate solar, while uranium is derived, like all elements, from supernovas, meaning “a” sun but not “the” sun. Therefore it is an alien sun that has made fission possible, as well as all its resulting effects, both good and bad.
    The Killer
    The trouble with this alien atomic energy is that it has given birth to radiation which is, in my opinion, the “perfect serial killer”. Why, you say? Because it is so hard to pin down radiation even as a “person of interest” let alone even a suspect or a killer in a crime.
    Look how hard it has been to pin down tobacco or asbestos or meds as culprits let alone to try and pin down radiation as even an accessory to the murder or maiming of people and animals and their offspring. Even Dr G, the medical examiner in her famous TV show, would not be able to determine radiation as a precise cause of death. Pinning any untoward outcome on radiation is as “difficult as nailing Jell-O to a tree”.
    You just never know with radiation or nuclear reactors. None of our human senses (sight, sound, smell, etc.) help us detect radiation. Radiation is just the atomic version of poisonous carbon monoxide (CO). Radiation can and has been a silent deadly killer. At least if you survive CO poisoning there are no untoward after-effects. The gas is purged from your system. However, radiation and radioactivity stays around like relatives that hang around too long, only much worse. Radiation poisoning has so-called “acute” and “latent” effects i.e. immediate and long-lasting effects. Furthermore the amount of radiation anyone receives can only be estimated. And you must trust others to get that estimate. Even well after radioactive releases have occurred the so-called experts have widely varying estimates as to how much exposure individuals really received. Don’t get me wrong, radiation has many important benefits especially in medicine. However, when it comes to A-bombs and A-plants it is much different. You know very well, when you see the doc for radiation therapy, exactly what the benefits and risks are. And you make the decision whether you will take those risks or not. With A-plants the only choice you have, if you can afford it, is not to live anywhere near one. And that is increasing difficult to do. Using 2010 population data, one in three Americans (or 116,000,000 people) now live within 50 miles of a nuclear power plant. In my opinion, we must do everything we can to make nuclear power plants and their horrible radioactive wastes a nightmare of the past.

  111. An Ounce of Prevention is Worth a Pound of Cure
    This Ben Franklin quote has been forgotten completely by the NRC. Preventing nuclear plant accidents is apparently no longer important to them. They are looking at not “preventing” a Fukushima-type accident in the US but rather of better “mitigating” such an accident when it occurs.
    This is incredible twisted logic and only serves to protect the nuclear industry from having to do the right thing by upgrading nuclear plant designs to prevent such an accident. Just look back at this nation’s near –miss catastrophe at the Three Mile Island (TMI) nuclear site 36 years ago. Would anyone have even considered just looking at mitigating another TMI accident?! Thank God actions were taken back then to not only mitigate such a catastrophe but to prevent it in the first place. If a Fukushima-type accident had occurred in the US, I “garan-damn-tee you” (old Navy speak) giving the nuclear industry a “pass” on doing the right thing would never have been considered.
    It was encouraging to learn that there are a number of NRC personnel who oppose this intended NRC action. But as I understand it, NRC senior management is proceeding anyway. I wonder if these senior managers are the same ones that personally visited the devastation in Japan. As we have heard, most of them provided grim reports on just how bad things were in Japan. All vowed to do EVERYTHING possible to PREVENT such a catastrophe here.
    Yesterday (3/11) marked the fourth anniversary of Fukushima. A lot of good lessons were learned from this horrible accident. The most important lesson learned was that our US nuclear power plants are just as vulnerable to an accident as those in Japan. This is the time for the NRC to make safe even safer. Now is NOT the time to relax safety requirements. This Admiral Rickover quote is still very appropriate…
    “The whole reactor game hangs on a much more slender thread than most people are aware. There are a lot of things that can go wrong and it requires eternal vigilance.”

  112. Instead of making safe even safer at the NRC, we now see just the opposite being seriously considered by the Commissioners.

    Of course I am talking about allowing nuclear power plants to continue to operate with known inadequate design bases. Instead of carte blanche approval shouldn’t the NRC at least run this significant change in regulatory approach through some serious analysis first?! What if the NRC’s own backfit analysis was utilized?! In a way this would be sort of a reverse backfit analysis. How much could this cost the public if the NRC allows such a thing to happen? Normally we think of this backfit analysis being performed to see if the cost of a proposed change does indeed result in a substantial increase in protection to the public. This change will allow for a substantial decrease in public safety and at what cost not only to Fukushima changes but to all future changes that the nuclear industry feels will hit their pocketbook.

  113. Thanks NRC for the prompt informative response on your actions to improve the resident inspector program. Just one related comment…
    Many problems with reactor plant design and maintenance are not easily identified. For example the flood barrier problems at ANO and FCS. I believe the only way the barrier problems at ANO were discovered was in response to an Fukushima-related initiative that actually took apart penetrations in a controlled fashion to verify design requirements. Similar barrier problems were found by the licensee at the FCS a few years earlier. I was concerned that if it had not been the result of a special initiative at ANO similar problems would not have been found there. This concerns me in the fact that our industry operating experience may not be shared in a timely fashion. Also does the resident inspector have the authority to require his/her power plant to at least check by sampling for similar hard to find problems in the plant? Was that done at ANO?

  114. The NRC has taken a number of actions in recent years to improve the efficiency and effectiveness of the resident inspector system. These include:

    • Changing the mandatory resident inspector relocation requirement to seven years from five years. By increasing the time an inspector can stay at a plant, we take advantage of that inspector’s knowledge of the facility, while reducing the need for on-the-job training of a new inspector. Also, the inspectors experience less disruption from having to move their families so often.
    • Each region maintains a resident inspector rotation schedule. This helps avoid gaps in coverage by allowing resident inspectors to position themselves into new assignments.
    • Implementing recommendations from an audit of the resident inspector program by the NRC’s Office of Inspector General, the agency is increasing the bandwidth for Internet connections at all resident inspector offices. This will allow the inspectors faster access to important documents they need to conduct their inspections.
    • The NRC has made an effort to improve the retention of resident inspectors. The more we are able to retain, the less time we spend on training new inspectors and the greater the body of knowledge available for our oversight process.

    Division of Inspection and Regional Support
    Office of Nuclear Reactor Regulation

  115. Please review the article at this link…
    http://allthingsnuclear.org/four-years-after-fukushima-the-nrc-at-a-tipping-point/
    Really feel the NRC is trying to pull a fast one. And if they get by with it public safety will continue to be at risk. Bottom line this will allow the nuclear industry to not incur the costs of bringing nuclear plants into conformance with new design requirements based on the horrible accident at Fukushima in Japan. It will be another case of the tail wagging the dog. Another case of the NRC putting nuclear industry interests ahead of public safety. The NRC Commissioners must not let this happen!

  116. Correction-No the real reason for the lack of clear language at the NRC is perfectly captured by this quote by George Orwell. “The greatest enemy of clear language is insincerity.”

  117. The PC Virus has Infected the NRC
    You would think that a regulatory agency with the critical mission of protecting the public would be the last place where politically-correct (PC) lingo would manifest itself. Yet, sad to say, the PC Virus has even infected the Nuclear Regulatory Commission (NRC). Plain language has never been a strong suit at the NRC but things have gotten progressively worse. Examples…
    NOW…
    • A violation is called a finding.
    • A near-miss accident is called a precursor event.
    • A green color is used to categorize nuclear plant performance even though federal violations are involved.
    What is driving this trend toward techno-speak at the NRC? Perhaps there are just more paralysis-by-analysis folks employed there and more techno-speak just naturally follows? But the more likely reason, I think, is that the NRC likes watering down the wording so it sounds less alarming. Then the NRC can open up more stuff to public scrutiny. The public won’t understand what the stuff really is, but the info is out there, right?! And the bonus is that it will sound a lot better than it actually is. Reminds me of what smashing-the-earth supporters now call “fracking”, you know the process to bleed more natural gas from our planet. They now prefer to use the term “well stimulation”. And the NRC can claim that it is following the President’s call for regulatory transparency and openness, even though the POTUS does not believe that applies to him, his WH, or his self-appointed czars. Strange that our President would do this in spite of the fact he signed into law a couple of years back the so-called Plain Language Law. It just might take the NRC a lot longer to comply than other federal agencies as they have already been badly infected with the PC Virus.
    Finally, I am afraid the NRC is just a step away from adopting these PC terms…
    • Propose strongly instead of demand
    • Non-traditional success instead of failure
    • Alternate answer instead of incorrect
    • Unjust self-esteem reducer instead of criticism
    The PC Virus will be terminal if the NRC follows the White House lead and calls terrorists, misguided criminals.

  118. Correction-I said the “taxpayer” is paying the NRC nearly $200/hour for NRC resident inspector services. Although every US taxpayer helps subsidize the nuclear industry, in this case, however, it is the utility ratepayer that foots the bill. It is becoming kind of one in the same thing though. Based on the 2010 US Census Report, the number of people living within the 10-mile radius emergency planning zone around each of the 100 or so reactor plants in the US, increased by 17% the last decade. Furthermore, if you expand the radius to 50 miles, one in three Americans or 116,000,000 people live within this nuclear neighborhood. So taxpayers are increasingly becoming de facto nuclear utility ratepayers. With the population increases around nuke plants it must be harder and harder for industry emergency planners, the NRC, and FEMA to plan for the safety of people in these emergency planning zones.
    The extreme case, I believe, in this regard, is the Indian Point Nuclear Units in the backyard of New York City. Over 10,000,000 people are now in harm’s way there. But can you believe the NRC Commissioners are seriously considering extending the operating license for these aging and problem-plagued plants?! High time for the NRC to put public safety first and not continue to be in the pocket of the nuclear industry.

  119. So an NRC Inspector’s efficiency is about 28%. And the taxpayer is paying the NRC nearly $200 per hour for the services of these inspectors. (I wonder what the NRC actually pays these inspectors-probably not even 28% of that) After all, $200 per hour amounts to over $400,000 per year. But even so we are getting something out of these inspectors. Unfortunately we can’t say as much for all the NRC folks who aren’t resident inspectors. Around 200 NRC employees are resident inspectors (2 for each nuclear power plant). There are roughly 4000 NRC employees. So around 5% of the NRC staff are resident inspectors.
    Reflecting some more on the 28% efficiency number for resident inspectors. Even a nuclear power plant is only a little over 30% efficient. Yes 70% of the power generated is lost. If a NPP puts out 1500 MW of heat only 500 MW or so actually comes out as electricity. So by this standard can we really expect much more out of these resident inspectors?!
    Put yet another way charitable organizations are often evaluated by the amount of money they receive verses what actually gets to the folks they are trying to help. Highly rated charities give over 90% of what they receive to the folks they are trying to help. In this context the NRC resident inspectors give 28% of their time to ensuring nuclear safety at our NPPs. 72% overhead for resident inspectors seems very high by comparison.
    Ms Moderator, what has been done over the past 15 years to improve the efficiency of our NRC resident inspector program?

  120. Thanks for the prompt response.
    The 2 to 8 hour response time expectation you cite doesn’t seem to be much of an expectation for a “resident” inspector. Why don’t you just say if you get there within 8 hours it is just fine?! This 8 hour response time expectation is in stark contrast to what you expect of your nuclear power plant emergency response personnel. One group is expected to respond within 30 minutes and the other within one hour when an emergency is declared at the plant. I guess though the NRC meets the definition of “resident” I found in the dictionary-“living somewhere on a long-term basis”.
    Also I question the use of the term “inspector” in “resident inspector”. My data point is old but a little over 15 years ago the NRC provided information on just how much time a resident inspector actually spends “inspecting”. The figure was only 28% of his/her time is spent actually “inspecting”. Yes, between training, vacation, etc. the typical resident inspector spent about 28% of the time actually inspecting (preparing for inspections, conducting inspections, and writing up results). I’d just assumed that one would have to spend 50.0001% of the time or more inspecting in order to be labeled an inspector. I was wrong. Perhaps it would be more accurate to say that the NRC has an office at each nuclear power plant that during normal business hours is usually occupied by at least one NRC employee.

  121. Resident inspectors are not required to establish residence within any specific distance of a site, nor is there a specific requirement regarding response time to a site that would reasonably affect the choice of personal residence within these guidelines. “Emergency Response Resource
    Guide,” NUREG 1442, establishes the expected time for an NRC representative to arrive on site in response to an emergency as 2 to 8 hours. The regions should be cognizant of response capability and coordinate appropriately when resident inspectors are away from the site for extended periods.

    The NRC does not maintain a listing of resident inspectors’ home locations inside or outside of the EPZ.

    Moderator

  122. Also would you provide information as to how many of the 200 or so NRC nuclear power plant resident inspectors currently live within 10-miles of their assigned plants? Thanks.

  123. Ms Moderator would you clarify exactly how near the NRC resident inspectors assigned to each US nuclear plant are required to live with respect to their assigned nuclear plant? The info I have found is vague. One NRC document said “NRC resident inspectors live in the area of the nuclear power plant”.
    It seems to me each resident inspector should be required to live within the 10-mile Emergency Planning zone around each nuclear power plant. It would allow the inspectors to respond more quickly to an event at the plant and it would help reassure those who live within that 10-mile zone that the NRC has skin in the game so to speak. It would help reassure the public that the NRC feels the nuclear plant is safe.

  126. A Real CEO Needed at the NRC
    According to the background info below, the Chairman of the Commission is the “principal executive officer” of the NRC. However the NRC EDO, who reports to the Chairman, is the “chief operating and administrative officer”. Neither the Chairman nor the EDO carries the familiar title used in many organizations, “CEO” or “Chief Executive Officer”. I think under the present set-up the head of a committee (in this case the Commission) would be where the buck would stop. That would be like having the Chairman of the Board acting as the CEO as well. This organizational structure confusion existed over 35 years ago and probably was a consideration for a recommendation of the special inquiry report on the Three Mile Island Accident. They recommended that the NRC be formed as a single-administrator agency. The inquiry report also stated that other federal agencies responsible for public health and safety are headed by one single administrator who is the CEO and just like our President, where the buck stops.
    Background Information…Excerpt from OIG-00-E-09, August 31, 2000…
    “Various pieces of legislation and agency guidance indicate that the EDO is to serve as the head of NRC for day-to-day agency operations. First and foremost, the Reorganization Plan No. 1 of 1980 requires the NRC Chairman, as the agency’s “principal executive officer,” to delegate responsibility for the agency’s administrative functioning to the EDO, subject to the Chairman’s direction and supervision. The EDO was to be given responsibility for distribution of business among NRC staff and offices, preparation of the budget estimate for the Commission, the proposed distribution of appropriated funds according to major programs and purposes, and other specific matters. Thus, the Reorganization Plan is interpreted as giving the EDO day-to-day authority for running NRC, as well as specific responsibilities related to the budget.
    This head of the agency role is reflected in the agency’s official position description for the EDO, which states, “The EDO is the chief operating and administrative officer of the Nuclear Regulatory Commission (NRC) and, except as provided by law, regulation, Commission and/or Chairman action, discharges licensing, regulatory and administrative functions of the Nuclear Regulatory Commission.” Furthermore, MD 9.17, Office of the Executive Director for Operations, states that the EDO is the chief operating and administrative officer of the Commission.(4) According to MD 9.17, the EDO is authorized and directed to discharge all regulatory, financial management, and administrative functions of NRC.”

  127. As you see I love to comment on my own stuff. In that way I will probably get it right eventually! (:-) Also if it is impossible to start steaming again to remove reactor decay heat, operators commence “feeding & bleeding” the reactor cooling system. Operators drain coolant from the system intentionally and make-up for the loss by pumping in ambient temperature water to directly cool the nuclear fuel in the reactor. All the feeding and bleeding is contained within the plant by design and therefore no release of the radioactive coolant results.
    Furthermore, (and as it is very hard to predict just high flood waters would reach at the plant in the event of an ice jam or the catastrophic destruction of upstream dams on the river), even if flood waters went beyond the flood elevation design basis at the site and all AC and DC power were lost (highly unlikely), plant operators have pre-staged portable self-powered equipment to provide cooling make-up water. This safety defense in depth (and so-called beyond-design-basis thinking and preparation) is what gives me so much confidence in the safety of not only the Fort Calhoun Station but the entire US nuclear industry as a whole.
    Finally, the nuclear industry has provided and equipped two US nuclear accident response centers in the US. Pumps and power sources and other emergency equipment is pre-staged at these centers ready to ship. Any specific individual equipment (as plants are of different design) needs at each plant are already on record with the emergency response centers. This equipment can be air-lifted to any nuclear power plant within 24 hours or trucked there within 48 hours. You know Paul Revere said “One if by land, two if by sea”. In the nuclear industry now one call does it all and you just say “One if by land, two if by air”.

  128. I am an old school reactor operator, but I think a hint at the answer above (for a PWR reactor) is to..
    -keep steaming if you already are to remove decay heat or to
    -start steaming if you aren’t to remove decay heat.
    Believe there is an emergency procedure that deals with a total loss of the Raw Water System.
    I now have 99.9% confidence that not even a nuclear fuel pellet will be damaged let alone a drop of radiation released to the environment.

  129. God forbid, even if this doomsday scenario involving the Fort Calhoun Station and a river ice jam occurs, I am 99% confident that not a “drop” of radiation will be released to the environment. It has everything to do with the skill and training of nuclear plant operators and with excellent procedures that deal with unthinkable situations. I will let one of those excellent nuclear plant operators provide the details if the spirit moves him or her.

  130. Missouri River Flooding-supplemental information
    Almost two months after the Fort Calhoun Station (FCS) was shutdown in early 2011, and as a result of a special NRC team inspection, the NRC calculated that if the ability to cool the nuclear fuel at the site were lost it would take 37 hours for boiling to occur in the reactor and 80 hours for boiling to occur in the plant’s spent fuel pool. As decay heat generation drops off exponentially after the reactor is shutdown, it is scary to think how little time it would take for boiling to occur in the reactor at FCS if the plant were just shutdown due to flooding on the Missouri River and a loss of cooling occurred?! Boiling of course can then lead to nuclear fuel damage; steam-cladding interaction leading to hydrogen generation; melting; and even vaporization of the core. It is high time to stop cutting it close on nuclear and public safety at this nuclear power plant.

  131. Further comment on OPPD’s (Fort Calhoun Nuclear Station) response to the NRC on potential flooding on the Missouri River contained in its submittal to the NRC dated August 13, 2014.

    OPPD indicates in its response that during cold weather the “typical time to cool down is approximately 3 hours”. Of course this reactor cool down time is predicated on the availability of the systems necessary to achieve that cool down. In the utility’s response this reactor cool down can be conducted well before flood waters adversely affect the site. OPPD in fact estimates that up to 2 days time is available as flood predictions will allow for such lead time. However, and as indicated before, a rapid flooding event on the Missouri River caused by an ice jam downstream of the site during cold weather, will allow for very little if any lead time. Lack of lead time will make it impossible for plant operators to take demanding and time-consuming corrective actions to protect the plant from rapidly losing an entire safety system, the so-called Raw Water System (RWS).
    Under these conditions can the Fort Calhoun Nuclear Station be cooled down within 3 hours?
    Furthermore, and even more importantly, even if a cold shutdown can be achieved in a timely manner, how can a cold shutdown condition be maintained as the RWS acts as the reactor’s ultimate heat sink?
    Without the RWS available (as all four RW pumps are submerged by flood waters) how long until reactor fuel damage occurs due to the complete loss of the ability to remove decay heat from the reactor core?
    The simple fact is that no matter how fast the reactor is cooled down, decay heat must be removed indefinitely from the fuel not only in the reactor itself but in all the used fuel stored in the plant’s on-site spent fuel pool. How is this critical function to be accomplished with the RWS totally inoperable and with no means available to ever restore it?!
    It is high time to not only ensure that this plant is not operated when river conditions could result in ice jams on the Missouri River, but also to ensure that the plant has a proper modification to bring it into compliance with its operating license and the NRC General Design Criteria. Currently if a single active failure occurs (one of six sluice gates fails) a complete loss of a safety system may result due to a flood at the plant.

  132. Here are those references regarding ice jams causing sudden flooding…

    Excerpt from USA Today March 25, 2009
    Evacuation ordered near Missouri River in Bismarck

    “The Army Corps of Engineers cut off water releases Tuesday from North Dakota’s Garrison Dam — a historic move to ease flooding along the Missouri River in Bismarck. The city ordered the evacuation of homes along the river where access roads were under water in the middle of a spring blizzard.
    The river stage in Bismarck has jumped 2 feet since Monday to more than 15 feet, less than half a foot below flood stage, due to ice jams. Releases from Garrison Dam were first cut to a record-low 4,000 cubic feet per second and then ended altogether.”

    Excerpt from The Bismark Tribune March 13, 2014…
    Ice jams causing trouble on lower Little Missouri River

    “Ice jamming on the Little Missouri River north of Marmarth is causing trouble for at least one ranch family who lost corrals and livestock this week.
    Nikki and John Brown, who ranch on the west side of the river between Marmarth and Golva, had two heifers drown and some property destroyed when the river came up during the early morning hours Wednesday.
    Nikki Brown said the river was higher on their property than it was in either the flood of 2009 and 2011, due to a miles-long ice jam downriver. She said the jam finally broke loose Thursday afternoon.”

  133. Achilles Heel at the Fort Calhoun Nuclear Station

    Winter weather can cause problems for power plants located along the Missouri River. I found two instances where ice jams caused rapid upstream flooding on the Missouri River and on the Little Missouri River. Excepts from articles on the flooding are included at the end of this email.

    Last August the owner of the Fort Calhoun Nuclear Station responded to a number of questions from the NRC regarding License Amendment Request (LAR)13-03, Revising Method for Controlling Raw Water Intake Cell Level. The OPPD letter (LIC-14-0092) contained OPPD’s response to those questions.

    Pivotal to OPPD’s response is that they claim to have two days to respond to potential flooding on the Missouri River. This is because considerable time is required for corrective action in case all six sluice gates in the intake structure at the plant cannot be completely closed. All gates must be fully closed and leak tight so that raw water intake cell water level can be properly controlled. If cell level cannot be controlled an entire safety system, the Raw Water System, will be rendered inoperable by flood waters. I have no doubt that under normal weather conditions flooding on the Missouri River can be predicted and two days warning time seems proper. However, in the event of ice jams downstream of the plant on the Missouri River, very little time may be available to implement a large array of procedural actions let alone corrective actions in the event any one of six sluice gates fails to close completely due to ice, sand, silt etc. Please consider this possibility as you review this license amendment.

    Furthermore, and something the NRC has been aware of for a long time, the current design of the plant is such that five sluice gates must be completely closed and the sixth gate throttled to within one inch of its seat to control intake structure cell level. Also the current design and the proposed modification associated with the LAR do not meet the General Design Criteria associated with a single active failure in that the failure of just one of six sluice gates will render an entire safety system inoperable. I strongly feel the plant should not be operated in noncompliance with the GDC. It is particularly important that the plant not be operated if ice jams can reasonably be expected to form on the river. We are into the winter season and both of the events below occurred during the month of March.

    Your prompt attention to this matter would be much appreciated.

  134. Historical Human Reliability problems in the NRC creates excessive risks.

    36 years after the Three Mile Island Accident, has the NRC learned its lessons and implemented those lessons learned as operating practices to protect the public as required by law? Some say no, as indicated by misinformation related to Three Mile Island, Fukushima and the failure to support public safety 100% instead of the nuclear bottom line..

    Links on the regulator’s failure concerning Human Reliability – Research on this topic reflects a 30 year plus problem with Human Reliability within the NRC:
    Dave Lochbaum – http://www.pbs.org/wgbh/pages/frontline/health-science-technology/nuclear-aftershocks/david-lochbaum-the-nrc-is-not-doing-its-job/
    POGO – http://www.pogo.org/our-work/reports/90s/nss-npp-19960901.html
    New York Times – http://www.nytimes.com/2011/05/08/business/energy-environment/08nrc.html?pagewanted=all&_r=0
    AP – “Time after time, officials at the U.S. Nuclear Regulatory Commission have decided that original regulations were too strict, arguing that safety margins could be eased without peril, according to records and interviews.”http://www.ap.org/company/awards/part-i-aging-nukes
    AP – 1987, Lack of Regulatory Zeal: http://www.apnewsarchive.com/1987/Congress-to-Quiz-NRC-on-Whether-It-Lacks-Regulatory-Zeal/id-e7f0cd04482064d66c2e5e973aa69cc9

    This failure is displayed in other areas, such as NRC’s failure to enforce fire regulations at nuclear power plants, Browns Ferry stands out like a “gusher of tritium.” Consultants such as EPRI, INPO and WANO should never be able to keep safety issues secret utilizing a faux proprietary reason to withhold safety defects. This occurs and the NRC supports it.

    After years of study of the NRC, it is apparent that the NRC has snuggled up to the NEI lobbyist and the nuclear industry in an inappropriate “ménage a trois love affair;” NRC, NEI lobbyists and nuclear power operators make up this risky affair. The NRC past Inspector General Investigators have complained about this fact, so have many concerned citizens and nuclear power safety groups.

    In the world of nuclear reliability, these facts reflect a serious Human Reliability failure on the part of our nuclear regulator, the NRC. A failure to offer the best public protection possible not only raises serious questions about the NRC’s responsibility to public protection, it increases risks of a catastrophic nuclear accident.

  135. NUCLEAR POWER PLANT AUTOMATONS?

    Are US nuclear power plants (NPPs) safer today with highly-trained, high school grads running them? Or have we instead created human automatons that will never deviate from established procedures and protocols, even in the event of unforeseen circumstances?!

    Those NRC-licensed operators on watch at Three Mile Island Unit 2 (TMI2) in the very early morning hours 35 years ago, were almost exclusively ex-Navy nuclear reactor operators. Since then almost all commercial NPP reactor operators have been well-trained, high school graduates without any naval reactor experience.

    Before the TMI accident a sizable number of reactor operators were hired by nuclear utilities after their term of service in the Navy as reactor operators. Those ex-Navy nuclear reactor operators were in high demand by utilities who were staffing new and existing commercial NPPs. They were in high demand because their Navy nuclear reactor training and experience was exceptional. The safety record of the US naval nuclear reactors installed on US nuclear-powered submarines and ships was stellar. Only the USS Thresher (a nuclear-powered sub) tragedy in 1963 marred a perfect naval nuclear reactor safety record.*

    By way of background, the Navy nuclear training program emphasized a safety first approach and the importance of the operator’s role in ensuring that safety. By design naval reactors relied more on the operator than in our heavily-automated commercial nuclear reactors. A contributing factor to this difference is that naval reactors are designed to be operated even under adverse circumstances (like war); while commercial reactors are designed to be automatically and safely shutdown when adverse or upset conditions occur. For example, fewer conditions will automatically scram (shutdown) a naval reactor. And if there is, for example, an enemy threat, even those automatic shutdown systems can be completely blocked by the use of a so-called “Battle Short Switch”. This is equivalent to disengaging a firearm’s safety. All you need to do is pull the trigger. In Battle Short only the reactor operator is the safety device. Only the reactor operator can scram the reactor. Furthermore under normal circumstances (without the use of Battle Short) only the operator can hit the “FILL” switch so that makeup pumps can start and provide water to the reactor to keep the nuclear fuel covered and cooled in case of an accident. In a commercial nuclear power plant the “FILL” function is fully automated. The ex-Navy operators at TMI2, inappropriately took action to secure the plant’s “FILL” system after it had automatically started. Inadequate training of these operators was cited as the root cause of the accident at TMI2. It is interesting to note that ex-Navy operators (identically trained) at a sister-NPP, Davis Besse, handled a nearly identical initiating event as that at TMI2, a couple of years earlier, without serious consequence. Davis Besse operators handled that one just fine despite their “inadequate” training.

    So what has changed since TMI. Lots of things. Improved procedures; training; creation of plant-specific full-scope training simulators; prompt sharing of industry operating experience; etc.

    But what about the nature of the folks who are licensed to operate these plants? Now high school graduates are hired by nuclear utilities. They are then wet-nursed (trained) to be reactor operators. They are indoctrinated while they are young and malleable, you know just like raw military recruits. They then can become human automatons that can be depended on to follow specific rigid procedures to the letter. Enough of this flying by the seat of the pants stuff, like deviating from the inadequate, institutionalized training provided at Davis Besse. Nuclear utilities seemingly now want reactor operators to do nothing more than to watch automated nuclear technology do its thing. Operators are to only act as a member of the team and must love so-called “group think”. (You know just like the “group think” that lead to a decision to launch a space shuttle when it was colder than expected one day).

    Furthermore, even these highly-trained nuclear automatons cannot be completely trusted with the industry’s nuclear technology. We must ensure these operators are fit for duty (you know random drug-testing, etc.) We also need to put a degreed shift technical advisor on each reactor operator shift to make sure the licensed reactor operators always keep the big nuclear-safety picture in mind and that operators behave exactly as they are programmed.

    In addition, to make sure these operators toe the line, not one but two NRC resident inspectors need to be assigned to each nuclear plant site. By God, if its possible, the NRC will now “inspect in” quality.

    *The USS Scorpion, also a nuclear-powered sub, was lost in 1968. Although the cause of the Scorpion’s demise was never conclusively determined, it was not believed to be anything related to its nuclear reactor or its operation. On the other hand, an inadequate reactor operating procedure may have contributed to the Thresher disaster.

  136. The NRC Has Failed to Implement Institutional Changes Recommended After the TMI Accident

    In his book “Reactor Accidents”, David Mosey cites “institutional failure” as a critical and often overlooked root cause in nuclear power plant accidents. For example, operator error or inadequate operator training is often cited as the cause of the TMI accident. However, significant institutional failures set these operators up for failure.

    A special and independent inquiry into the TMI accident was authorized by the NRC Commission shortly after the accident. A number of recommendations were made in their 1980 report (NUREG/CR-1250). The lion’s share of those recommendations called for significant changes in the NRC itself. My read is that almost all of these institutional recommendations were not implemented by the Commission. Let me cite several examples:

    Recommendation: The NRC needs to be a single-administrator agency.
    Status: Not implemented even after 34 years.
    Comment: The NRC is still run by committee. The inquiry report noted that the “NRC is virtually the only agency in the federal government headed by a commission”. Agencies responsible for public health and safety have single administrators. Examples include the FAA, FDA, OSHA, and the EPA. This is one that only the US Congress can implement by legislative action.

    Recommendation: An independent reactor safety board needs to be established with its sole focus on the safety of existing US nuclear power plants (NPPs).
    Status: Not implemented.
    Comment: The Advisory Committee on Reactor Safeguards (ACRS) has existed since the early days of commercial nuclear power. They advise on many matters that have absolutely nothing to do with existing NPP safety. I know of no change that was made to the ACRS as a result of the accident at TMI even though the ACRS was aware of similar precursor events at other plants prior to the TMI accident. They are mandated by law to review new license applications for NPPs and they were busy doing that decades ago. But new NPP license applications are few and far between today. Just look at what the ACRS looks at today. They have a dozen or so subcommittees and there was only one that even had the term “operations” in it. There were five subcommittees looking at designs for future nuclear plants though.

    Recommendation: NRC-qualified Engineer Supervisor on each NPP shift.
    Status: Partially Implemented
    Comment: A Shift Technical Advisor has been assigned to each NPP shift. They do not have to be engineers and they can only advise the Shift Supervisor who also does not have to be an engineer either.

    Recommendation: Operator training must be drastically improved.
    Status: Implemented
    Comment: Operator training is much better at US NPPs and training tools and training organizations vastly enhanced.

    Recommendation: The NRC inspection program needs significant improvement.
    Status: Partially Implemented.
    Comment: Additional inspectors were assigned both in the field and in NRC regional offices and NRC headquarters after TMI. Funding limitations later have reduced the NRC staff assigned to oversee existing NPPs. Also the so-called NRC baseline inspection program is flawed. When NPPs have been forced from service due to significant operational events, subsequently many problems are found when both the NRC and the power plant look hard at the plant. These problems were not discovered earlier through NRC inspection efforts. Millions of utility dollars (really these are rate-payer dollars) are paid to the NRC for these inadequate inspections at each nuclear site each and every year.

    Recommendation: Establish a centralized body to analyze and evaluate NPP operational data and provide a mechanism to promptly distribute this information to appropriate licensees.
    Status: Implemented in 1984 and abolished in 1998.
    Comment: The Office for the Analysis and Evaluation of Operational Data (AEOD) was established in 1984. Although AEOD was abolished its functions were spread out to five different NRC offices.

    Although the NRC has a poor track record on implementing significant accident inquiry report recommendations, so does the nuclear industry itself. For example,

    Recommendation: Form a National Operating Company or Consortium.
    Status: Partially Implemented
    Comment: The Institute of Nuclear Power Operation (INPO) was established by the nuclear industry shortly after the TMI accident. INPO evaluates NPPs on a periodic basis and establishes standards of excellence in nuclear operation for the industry. The inquiry report recommended much more than an INPO. Large utilities with large nuclear fleets operate NPPs better than single nuclear plant utilities. They have vastly superior technical and monetary resources. The inquiry report envisioned that the single NPPs belonging to small nuclear utilities could be brought under a large operating company so that all necessary resources to support the complexities of NPP operation could be more easily brought to bear.

    Recommendation: Form an industry-run off-site data center.
    Status: Partially Implemented.
    Comment: Each nuclear power plant now has its own dedicated group to analyze operational data from other plants. Since the NRC has dissolved the AEOD it appears that the industry as a whole has taken one step forward and two steps back.

    In my opinion it is high time to re-look at the inquiry report recommendations. It appears that significant improvements have been made to safety at each NPP, but that necessary institutional changes, involving the NRC and the nuclear industry as a whole, have been all but ignored.

  137. Atlas rockets on a one way trip to the Sun full of toxic waste creating a clean environment and millions of jobs paid for by the corporations just what is wrong with that? It can be done the question is why not?

  138. BOB & WEAVE (B&W)
    As we used to say in the Navy, it may be screwed up if it’s General Electric, but you can be sure if it’s Westinghouse. 
    As Babcock and Wilcox (B&W) is responsible for the accident at Three Mile Island, we can state what B&W really stands for-“Bob & Weave”. B&W has done everything it can to avoid taking any responsibility for the accident. The owner of TMI won an award of 37 million dollars after suing B&W for their role in causing the accident. B&W has perfected the nuclear shuffle though. They should have been brought up on criminal charges for their intentional wrong-doing. Please take a look at the article at this link…http://www.nukeknews.com/index.html
    Furthermore, B&W has so-called once through steam generators (OTSGs) installed at a number of our US nuclear power plants. In my opinion we should have been “once and through” with these OTSGs a long time ago. My opinion is based on actual experience on the B&W power plant simulator located in Lynchburg, VA. The simulator there includes modeling of B&W’s OTSGs. My colleagues and I were appalled at the unforgiving nature of these OTSGs. When feed water flow is interrupted to these OTSGs in a matter of a few minutes they run dry. When they run dry it is like completely covering the front of your car’s radiator while you are driving. The cooling system quickly overheats and engine temperature soars. In a nuclear power plant this causes the reactor cooling system to overheat and pressure in the system soars causing relief valves to lift causing a loss of reactor coolant accident. The fact that these OTSGs run dry so quickly was startling to us compared to the U-tube steam generators (UTSGs) in the nuclear plant we were trained on. Our UTSGs allow much more time (as much as 30 minutes) until dry out if feed water flow is lost. This buys precious time for operators to ensure an alternate feed water system is supplying makeup water to the steam generators. The B&W OTSGs are smaller than UTSGs and therefore carry a lower inventory of water.
    B&W has not learned its lesson and still wants to unload these unforgiving OTSGs to any nuclear plant that needs replacement steam generators.

  139. “I Feel Like a Million Bucks”
    Did you know that the NRC actually places a monetary value on human life? When you use the expression “I feel like a million bucks” you should say according to the NRC, “I feel like 3 million bucks”. Yep, that is the value of your life according to the NRC. I came across an article on the UCS website, allthingsnuclear.org, that I thought was interesting and I thought I would pass along a portion of it…
    “In February 2011, my colleague Ed Lyman wrote a blog post and a letter to the New York Times pointing out that the Nuclear Regulatory Commission (NRC) assigns a MUCH lower value to human life when assessing the costs of accidents than other government agencies. This issue has been raised again in a recent Bloomberg article.
    In his New York Times letter, Ed explained it this way:
    The N.R.C. has been using the same value—$3 million—since 1995. If the agency were to increase that value to the $5 million to $9 million per life that other agencies use, it would have a major effect on nuclear plant license renewals and new reactor approvals. Plant owners would have to add safety features that the N.R.C. now considers too expensive because it low balls the value of the lives that could be saved.
    N.R.C. calculations need to be brought in line with those of other agencies.
    As Ed points out, this matters because the nuclear industry uses this figure to put a monetary value on loss of life from a possible nuclear accident. It then compares that cost to the cost of safety measures intended to prevent such an accident or reduce its consequences, to see if the safety measures are worth installing. Since the NRC allows the nuclear industry to use a value of life that is 2 to 3 times lower than other federal agencies, that lowers the calculated costs of accidents, which means fewer safety measures appear to be justified, and which means the industry doesn’t need to spend money on them.
    The Fukushima disaster, which occurred a few weeks after Ed’s letter was published and is projected to result in several thousand eventual cancer deaths, made it apparent that resolving this discrepancy is not merely an abstract exercise. Yet the NRC has been studying this issue for at least the past three years without making any changes. The NRC staff is supposed to provide a recommendation for the NRC commissioners to consider by the end of this year.
    The NRC is also debating whether it should give greater consideration to “qualitative factors” in cost-benefit analysis, such as the societal impacts of land contamination and evacuations. Currently when the NRC evaluates new reactor safety requirements, it considers only the direct monetary costs of such disasters—like the value of lives lost and condemned land, and the cost of decontamination—and ignores the social costs of a large population of permanently displaced people. Those factors are hard to quantify, but the NRC needs to find a way to take them into account.”
    So the NRC undervalues human life and does not even take into account the societal costs associated with a large population of permanently displaced people. In Japan it is estimated that more people have died just from being permanently displaced by the Fukushima accident than those killed directly by the accident. High time for the NRC to put public safety first. Otherwise the NRC will have to get rid of its motto of “protecting and serving the public” just like the Ferguson police department had to.

  140. Put the Lid Back on Pandora’s Box

    It is high time we put the lid back on Pandora’s Box. It is high time to spot flirting with nuclear power plant Armageddon. TMI was a near miss accident in the US; Chernobyl and Fukushima were nightmare nuclear accidents overseas.

    I love the commercial on TV about the so-called literal genie. A guy asks for bucks and gets them, literally. Over a half-century ago we asked several questions of a similar fickle genie. The wishes then were for a safe, reliable, cheap and pollution-free source of electricity. His answer was nuclear power. We have learned the hard way that the nuclear power we got satisfied none of those wishes.

    Safe-NOT; not only the accidents, but the US nuclear power plant program has had two-thirds of the nuclear mishaps in the world since Chernobyl.

    Reliable-NOT; numerous US nuclear plants shutdown well before their design life; many due to safety, regulatory, and economic-viability concerns.

    Cheap-NOT; remember the rallying cry years ago? Power from these nukes will be “too cheap to meter”?! Fact is nuclear power plants, with their super-high upfront capital costs; their high costs to staff and maintain; their tax-payer subsidized insurance; and the money they must set aside for their eventual decommissioning, simply can’t compete economically with competing sources of power.

    Pollution-free-HARDLY; nuke utilities tout the fact that nuclear plants do not emit greenhouse gases. Instead of airborne pollution the genie gave us dangerous nuclear high-level and low-level nuclear waste with which we have to contend for hundreds of years. Also nuclear accidents have rendered vast areas uninhabitable.

    Let’s put the lid on the nuclear power plant Pandora’s Box. Even Germany has outlawed further use of nuclear power. You know, even that Germany, the country that, historically, only stops committing atrocities when forced to do so by war.

  141. I believe the UK does nuclear a lot better than the US. Their reactors are gas-cooled compared to the water-cooled and moderated designs in the US. Their reactors can be counted to operate safely for their design life. Furthermore, the US is not even in second place, especially when it comes to nuclear mishaps and near-misses. Since the accidents at TMI in ’79 and Chernobyl in ’86, two-thirds of the nuclear mishaps in the world have occurred in the US. This figure may be somewhat skewed because I do not believe other countries, especially non-western ones, have the low reporting threshold that the US nuclear industry has with reporting mishaps. In fact, recall that the only way the world learned of the Russian Chernobyl accident is when we received a call from the then Soviet Union asking us what is the best way to put out a graphite pile fire?! Still, when we operate around 100 power reactors and the rest of the world operates 300, we have nothing to brag about!

  142. The UK operates nuclear power plants (NPPs) much better than the US.
    There are 105 NPPs in the world that are no longer operating that have “fuflilled their purpose” or have been shutdown as they are no longer “economic to run”. 14 of those are in the UK and 19 are in the US. Of those 19 US NPPs, only 9 have operated approimately full term. While in the UK all 14 of their NPPs have run approimately full term. The average operating life of the 19 US NPPs is 23.2 years. The average operating life of those 14 in the UK is 30.9. What are the possible reasons for the significantly better track record in the UK? All the UK reactors are gas-cooled. All the US reactors are either PWRs (13) or BWRs (6). The UK has its own regulatory agency and we have the NRC. The US has experienced a major accident, TMI, while the UK has had two, neither of which was nearly as severe as TMI. Looks like we should emulate the Brits.

  144. A little off topic but can anyone guide me to where I can find the Fire Dynamics Tool? Thank you!

    Note: Moved by the moderator

  145. I will miss you Dan. You brought up a lot of good information. Good luck with your real job. Oh, Dan, I wish I could be 25 again and have all the wisdom and knowledge I now possess.

  146. Your chosen manner of discourse is to set up all these fake strawmen and then to defy anyone to knock them down. I knocked down one or two for you, but I get them impression I could show you a picture of a white dog, and you would argue that it’s really brown…just for the sake of argument. I have a real job, so I’ll leave the knocking down part to my compatriots with the necessary patience.

    You really must learn some stress management techniques, else you’re going to have a stroke before you’re 25. Farewell.

  147. SMITH SYSTEM FOR SAFE REACTOR OPERATION

    The Smith System for safe vehicle operation has been around for a long time. Getting the Big Picture was one of five elements they preached for good defensive driving. I have attempted to use a similar approach for good nuclear power plant “driving”. Here goes…
    • Get the Big Picture-whether you are operating a vehicle or a nuclear power plant, getting the big picture is critical to safe operation. Do not allow yourself to be distracted. No tunnel vision allowed. Use all available information before taking action. As Davy Crockett said, “Be always sure you’re right-then go ahead!”
    • Believe Your Instruments-unless you can prove that an instrument is faulty. This is probably the #1 factor in aircraft pilot error.
    • Keep Your Hands in Your Pockets Until You Have Gotten the Big Picture-not good when you are driving a car, but the best reactor operators keep their hands in their pockets until they get the big picture. This is especially important when a number of alarms are sounding at once in the control room. Operators are trained to focus on key parameters first and foremost to ensure reactor safety. Keeping the reactor core covered and cooled is paramount.
    • Backup Safety Systems-reactor operators backup automatic systems. For example, if the reactor automatically shuts down (i.e. scrams) the operators manually trip the reactor to backup the automatic action. The focus is on ensuring the plant responds just as it should by design.
    • Do No Harm-the #1 rule for physicians and reactor operators. Reactor operators do not override, defeat, or block automatic safety system operation or safety interlocks. An operator’s primary responsibility is to ensure safety systems operate as designed. Only when the dust has settled are safety systems shutdown or reset. And then only in accordance with strict administrative-control procedures. At TMI and at Chernobyl operator action caused harm.
    • Keep Your Edge-Always Ask Yourself What If and Why Questions-a questioning attitude is fundamental to safe reactor operation. Don’t assume, know! “Assume” can make an “ass” out of “u” and “me”!
    • Know Your Teammates and Your Reactor Plant-I know seniority is a factor in job promotions and advancement. But when seniority governs who is on the graveyard shift that is going to far in my opinion. It would be preferred if the most experienced operators were around when almost no one else was. As a minimum, shift crews should be properly balanced with regard to experience. In addition, I see an overwhelming trend toward 12-hour reactor operator shifts. Operators love it because you get more days off between shifts. I have worked 8, 10, and 12-hour shifts and I know it is hard to be at the top of your game the last couple of hours of a twelve. Airline pilots and reactor operators should have the same work-hour restrictions.
    • Stay Clear of Unsafe-At-Any-Speed Reactors or Reactor Owners

    Stay away from any nuclear power plant stuff made by the Russians. You can be sure if it’s Russian-made that public safety is secondary. Russians, though, are top drawer when making anything that kills people. (I would love to own an AK-47). Just think, how wise is it to play Russian roulette?!

    Before signing on with a power company, familiarize yourself with its operating safety and regulatory track-record.

    Stay Clear of Unforgiving Reactor Plant Designs
     Stay away from reactors not surrounded by rotund containment structures.
     Avoid, like the plague, any reactors designed with positive moderator, fuel, or power coefficients. Negative coefficients inherently act to help shutdown a reactor if the moderator or fuel temperature increases. Positive coefficients do the opposite making the situation much worse. The positive fuel temperature coefficient at Chernobyl accelerated the disaster. In fact the rapid power excursion was so severe that if your car was designed like Chernobyl this is what would happen. You are driving down the road at 60 mph. All of a sudden your accelerator pedal sticks to the floorboard. Before you can get your foot off the accelerator and on to the brake you are traveling 10,000 mph!
     No PWR reactors with B&W once-through steam generators-this design simply does not contain enough of an inventory of water to buy precious time for corrective action if a failure occurs.
     Stay Clear of Reactors that do not have a FSS (Full-scale Simulator)-all nuclear power plants, just like commercial jet airliners, should have Full Scope Simulators (FSS). This is the case in the US. There is not a more important training tool than a simulator. The world record for continuous nuclear power plant operation is 2.5 years. It is therefore quite impossible to practice startups and shutdowns on the actual power plant itself. Besides you can only practice abnormal and even accident scenarios on a simulator. A utility’s real commitment to safety has to be questioned if a FSS is not available for training.
    Attention all folks considering a nuclear power plant profession as an operator. Now you know, as the song goes, whether to walk away or run!

  148. All NRC licensees have a defined plant staff necessary to maintain the safety of the plant. The licensee for the plant contains technical specifications that establish minimum on-shift staffing. Licensees have to maintain these minimum levels or take required action to correct the situation in a timely manner. Each site has two or more NRC resident inspectors that monitor the licensee’s performance. At any time that a licensee is not meeting its regulatory requirements, for any reason, the NRC will take necessary regulatory actions to correct the adverse conditions.

    Steve LaVie
    Senior Emergency Preparedness Specialist

  153. Security is all of our concerns, particularly the NRC when dams are upstream from a nuclear plant.

    I realize there are some security problems and solutions which should not and will not be discussed on an open forum such as this. The NRC is concerned about dam problems and their security upstream from nuclear facilities, as evidenced by improvements in the TVA system and in South Carolina; hopefully improvements will continue and the NRC will not continue to harass their personnel for bringing issues such as upstream dam problems forward. .

    Deterrence relating to security issues may be partially accomplished by information placed in the media to inform a potential attacker that dam security upstream from nuclear plants is being improved and the NRC is concerned about this issue.

    Human Reliability and Security, which is an integral part of the regulatory process is important, a low point which I have observed at times on the part of OUR nuclear regulator. That includes NRC Public Relations personnel. Dismissing this valid concern does not facilitate faith in OUR regulator, nor its public relations personnel.

  154. So sorry I made you repeat something you said before. Do you even care about the upstream dams and their security?!

  155. As we’ve said repeatedly in the past, questions regarding the regulation of dams are best directed to the agencies responsible for a particular dam (Army Corps of Engineers, FERC, etc.).
    Scott Burnell

  156. The NRC has a comprehensive security inspection program for US nuclear plants. Is there a similar security inspection program for the vulnerable upstream dams from many of these plants? If not it seems that the dams would be the likely terrorist target not the plants?!

  157. WHAT IF YOU HAD TO PLAN FOR YOUR WORST NIGHTMARE?!

    The Nuclear Regulatory Commission and owners of nuclear plants in Nebraska are doing just that! I am glad they are doing it but I do not believe it should be carried out in secret.
    The nightmare is that old earthen dams on the Missouri River fail at the worst possible time. According to a preliminary NRC calculation made several years ago, the resulting “tsunami” would cause a 46-foot wall of water to surge down the Missouri River basin. Recall the horrendous and unprecedented flooding that occurred just over three years ago in 2011? The flood wall protecting Omaha was almost overrun. Lay on top of that, and at the same time, the destruction of all five major upstream river dams. I say all five dams fail because the failure of the most upstream dam would result in a domino-failure of all dams downstream. When reservoir levels are the highest in these dams the likelihood of dam failure is also at its highest. Also these dams are unprotected from sabotage (they would be a nice target for a returning ISIS fighter formerly from the US). In addition, the dams are not seismically designed in the event of an earthquake. This wall of water would vastly overwhelm the flood protection systems at Fort Calhoun and Cooper Nuclear Stations. At Fort Calhoun the ground elevation is around 1004 feet above sea level. The plant’s design takes into account a flood 10 feet above that, not 46 feet! This flood would take out everything at the plant below the level of the control room. Pumps, emergency diesel generators, station batteries, off-site power supplies all gone! The control room would no longer be a “control” room. It would be in the dark except for flashlights, backup battery-operated lighting, cell phone lighting, and any pocketed cigarette lighters. All AC and DC power including instrumentation and control power would be gone. The good thing about all this is that this wall of water takes one to two days to reach Fort Calhoun and Cooper. It would not travel the speed of an airliner as in an ocean-type tsunami. One to two days to get thousands of people to higher ground. One to two days to prepare the plant for this nuclear nightmare. During this time the plant would be shutdown and cooled down. However, heat still needs to be removed from the nuclear fuel or it heats up and melts. Since all installed equipment at the plant is inoperable, portable equipment must be brought into play. Portable equipment is staged on site and portable equipment can be flown in quickly from one of two emergency response centers in the US. The closest one would probably be the one in Phoenix, AZ. Equipment would be flown to the nearest airport and then transported by helo to the site. With flood waters everywhere, landing with this equipment would be dicey. I do not believe the buildings on the site have roofs capable of handling the loads. They are not designed as helo pads or for heavy equipment loads. This situation and many others have probably already been addressed by the nuclear plant owners.
    I applaud the Commission and the nuclear industry for preparing for their worst nightmare. The problem I have with all this is that this work is being done in secret. Several meetings have been held just between the utilities, the NRC, and a few government representatives in Nebraska and Iowa. They are privy to the detailed results of Missouri River flood analyses done by the Army Corps of Engineers showing just how bad the flooding would be with the failure of these upstream dams. This is something that is need-to-know public information and should therefore no longer be kept secret.

  158. More NRC Secrecy
    Guess currently assigned NRC project managers just can’t handle the work load at the country’s nuclear power plants. Now the NRC needs another project manager for each nuclear plant. The NRC says the additional project managers are needed just to oversee all the work associated with trying to upgrade nuclear power plants to meet earthquake and tsunami concerns from the accident in Japan. This tells me that there must be a lot of work involved to bring the nuclear fleet up to snuff.
    This also makes it easier for the NRC to continue to cloak these issues in secrecy. Already the NRC has had secret meetings with two utilities in NE regarding the massive flooding that would occur if old earthen dams upstream of their nuclear plants failed. What is so disturbing about this secrecy is that folks who live in and around the Missouri River basin have a right to know just how catastrophic such dam failures would be. One Army Corps of Engineers spokesman said it would be one of the worst disasters in US history. Furthermore, these upstream dams are not protected from terrorist attacks like the downstream nuclear plants are. It is high time to drop this cloak of secrecy so the focus can be on protecting these dams and the folks downstream.
    A suggestion: Judging by previous OIG audit reports there are many secret (closed-door) NRC meetings. If the NRC Commissioners are really serious about wanting an open regulatory environment shouldn’t the GAO or the OIG look into whether all these closed-door meetings should in fact have been closed to the public? Also authorizing closed-door meetings should be the direct responsibility of the Commission or at least the EDO. Currently these secret meetings can be called by the meeting organizer or an NRC section chief.

  159. Closed NRC Meetings, AKA secret meetings, are a lot more common-place than I thought. Just use your search engine and the list is pretty long. Such clandestine meetings serve only to
    reinforce the appearance of collusion between nuclear plant licensees and the NRC with respect to licensing and to severely damage public trust and confidence in the NRC as a fair and impartial arbiter
    of fact. The closed door meetings also call into question another stated principle of good
    regulation – independence. If NRC has to resort to secret meetings with a prospective
    licensee to review matters that are directly related to licensing, it is difficult to see how
    independent the NRC is in its approach to regulation. The NRC Commissioner’s Chairwoman gives lip service to NRC openness and transparency but where the rubber meets the road things are quite different.

  160. NRC-identified Violations Just Aren’t a Big Deal Anymore

    As one would expect, the NRC is very good at citing self-revealing findings that nuclear power plants identify and report to them. Unfortunately, those are, for the most part, the only ones the NRC “finds”.

    When the NRC does find a problem on its own, it is now typically
    “swept under the rug”.

    In the old days anything the NRC found amiss by their inspection
    efforts was a big deal. Please keep in mind that when an NRC
    inspector identifies a problem it means that the plant licensee
    has failed to find it first. That means that many nuclear plant
    personnel have failed to identify it. Among those personnel are the
    workers themselves, their supervisors and managers, and safety
    groups such as QC, QA, and various independent safety review
    groups.

    Instead of treating all these violations seriously, the NRC now assigns
    a safety-significance color code to them and “trends” them. Almost
    all color-coded violations are “Green”, the least significant from a
    safety standpoint. Green to a licensee means “Go”, I am doing just
    fine. Is it any wonder then, that when a plant has a very
    serious incident and the NRC finally pays attention, many more
    problems are discovered.

    The regulatory system is flawed and as a result NRC-identified
    problems are really no big deal anymore.

  161. The Evacuation Process Itself Kills People

    The owner of the Indian Point nuclear plants and the NRC claim that over 300,000 people within 10 miles of the plants can be safely evacuated in the event of serious accident at IP 1 &/or 2. (By the way over 21 million people live within 50 miles of these plants.)
    However there is no such thing as a safe evacuation.

    A survey in Japan has found that “more people have now died because of the Fukushima evacuation process than were killed in the region by the 2011 Japanese earthquake and tsunami which caused the displacement.” Some 300,000 people evacuated their homes. The deaths relating to this displacement-around 1,600-have surpassed the number killed in the region in the original disaster.
    The causes of death have included fatigue due to conditions in evacuation centers, exhaustion from relocating, and illness from hospital closures. The survey also said a number of suicides had been attributed to the ordeal. A Red Cross representative said the conditions faced by those displaced is made worse by them not knowing when they can return. A lot of the people suffering are the older generation and they need a lot of support to make it through with as little ill effect as possible.

    Although a number of senior NRC people have visited Japan (at taxpayer expense) to see the damage first hand, they never have mentioned this horrible aspect of accident there.

    If an accident occurs at IP, evacuation should be considered as a last resort. It will, however, be difficult for those in harm’s way to be content with in-house shelter instead of evacuation.

    Also it is a travesty that the owner of IP would be asking for a license extension on these plants and that the NRC would even be seriously considering such a request. In addition to these plants being in the backyard of NYC, they have an atrocious track record. Radioactive tritium is currently leaking from the plants. The IP units are the most susceptible to earthquake damage of any nuclear plant in the US. IP is number one on any terrorist hit list since such an act would make 9/11 pale in significance.
    Time for the NRC to really put public safety first.

  162. Nice article, it is great pleasure for me to finally find million worth info online, I am honestly surprised to encounter a blog that is not full of the usual garbage, bless you.

  163. > Public Pit Bull Off-Base
    > I have failed miserably in really getting the big picture. I have really been trying to put the bite on the NRC because I think I know something about nuclear power. If I really had the interests of the public at large in mind I would have recognized that the NRC has done far more to address the threat of terrorism than our government itself or any other of its federal agencies. Consider this excerpt from a 2006 US Department of State document on a National Strategy for Combating Terrorism? It says, ” Defend potential targets of attack. Our enemies are opportunistic, exploiting vulnerabilities and seeking alternatives to those targets with increased security measures. The targeting trend since at least September 11 has been away from hardened sites with formidable security (like nuclear power plants) and toward sites which are not always well secured. Specific targets vary, but they tend to be symbolic and are often selected because they will produce mass casualties, economic damage, or both.
    > Among our most important defensive efforts is the protection of critical infrastructures and key resources – sectors such as dams, energy, food and agriculture, water, telecommunications, public health, etc. These are systems and assets are so vital that their destruction or incapacitation would have a debilitating effect on the security of our Nation.”
    > The NRC has participated as they have noted on the Interagency Committee on Dam Safety. Other members include the Army Corps of Engineers, the Department of Homeland Security (which I believe has the lead), FEMA, the Bureau of Land Management, and FERC (Federal Energy Regulatory Commission). The NRC has set the example for everyone else when it comes to protecting our vital infrastructure from terrorist attack. The NRC however cannot force other government agencies to take terrorism as seriously as they do. The NRC can make recommendations, which I am sure they have, but to make other agencies or our government’s administration do the right thing, well, that would be like trying to push on a rope!
    > Furthermore, the NRC has taken action to protect downstream nuclear plants from a major upstream dam failure. It would terribly ironic if our nuke plants survived while mass civilian casualties and property damage occur because these same dams are virtually unprotected.
    > Consider this…
    > If one of the earthen dams on the Missouri River were to fail under the pressure of heavy spring rains and the melting snowpack, (let alone from terrorist attack), it would cause a domino effect resulting in failure of the downstream earthen dams causing them to be overrun and cave under pressure.
    > “There would be a flood like you’ve never seen,” said a Corps spokesman. He warned of the possibility of “chest-high” flooding in cities that would be the most epic man-made disaster in the history of the United States.”

    > It is high time these vital parts of our infrastructure are properly maintained and protected.

    Posted by the Moderator on behalf of Rich

  164. I need some exemption or licensing information on old dentistry equipment. Ritter Dental Company Tri Dent Model C. The spitoon and attached sinl are radioactive (matrixed in the material or glazing). i need any information validating the fact that these were manufatured rthis way ,bearing Uranium of Thorium in the manufacturing of this product.

  166. Garry you have inspired me! I was growing tired of knocking my head against a regulatory stone wall. The NRC is one of the best federal agencies I know at regulatory stonewalling. Stonewall Jackson would have been mighty proud of them! Trouble is that like Stonewall you run the risk of being accidentally “shot” by one of your own men. It is hard for any agency with thousands of conscientious professionals to abide inappropriate behavior for long on the part of their leadership. Foot dragging and stonewalling are characteristics of a very troubled organization. The NRC needs to be more like the EPA and not be beholden to and in the pocket of those they regulate. I have changed my blog name so I can help re-kindle a passion for trying to in some small way improve public safety by insisting on accountability in our government and it’s agencies. Thanks for your blog and keep up the good work!

  168. The NRC seems to be moving to protect the negligent actions of corporations and government regulatory failures, not national security. We are seeing this problem unfold before our eyes as to unnecessary secrecy pertaining to the amount of highly radioactive spent fuel contained in defective fuel pools, particularly in the GE Mark 1 reactors. Now the unnecessary secrecy extends to decaying, defective dams.

    Rich, you ask: “How in the hell can we get this cat back in the bag?” I think, citizens have a responsibility to be educated. Educated citizens are supposed to elect public officials who are not self serving and who support the people, not multi-national corporations. Until the people of our great nation realize that it is us, the individual citizen, who are the owners of our Constitution and not the corporation, nothing will change and our nation will continue to slide into that which protects corporate interests before the health and welfare of the citizen.

  169. Thanks for the feedback and I appreciate the fact that one has to be careful with specifics since some of this info may still be classified as confidential.
    However, Mr. Moderator, could you be a little more specific in your answers?
    For example, you state that the NRC participates in interagency dam coordination. As a result of your participation has action been taken to better secure these vital upstream dams? Have NRC concerns been adequately addressed by other agencies? Has all relevant information that the NRC possesses been provided to other agencies? It has been a very long time since concerns with dam failure were first raised. Please tell me that significant actions have been taken to “harden” these vulnerable dams. Is the level of security provided at these dams equivalent to that provided at each nuclear plant site? If not it seems the target of choice for terrorism would be these vulnerable dams. To the best of your knowledge have agencies responsible for dam security actually communicated necessary security alerts to dam operators?

    I also appreciate the reminder that there are a number of formal ways to raise concerns. I believe that each of these formal ways passes through different parts of the Commission. Would you provide information on how to register formal concerns about the NRC with entities outside the NRC? I am thinking about Congressional Committees and the Government Accountability Office for starters.

    You also stated Mr. Moderator that this blog is not a formal way of raising concerns. I understand that. But this blog I believe is certainly an informal way of raising concerns. This blog is one of the best things the NRC has done to enhance regulatory transparency. I know you do not mean to imply that this blog should be reserved for anything but concerns. Again thanks for this blog and for “pushing back” on my “informal” concerns.

  170. 1. Yes. As we mentioned in a previous response, the NRC has long participated in interagency dam coordination and the U.S. Army Corps of Engineers’ emergency plans for Missouri River dams are available to local and state agencies (https://public-blog.nrc-gateway.gov/2012/08/01/an-open-forum-now-available/comment-page-16/#comment-338173).
    2. The NRC is responsible for ensuring the security of U.S. nuclear power plants, but we regularly consult with the other federal agencies responsible for dam security. These include the Corps of Engineers, Federal Energy Regulatory Commission and the Bureau of Land Management. The Department of Homeland Security also has a role as a part of its critical national infrastructure programs.
    3. The categories in the memo you reference are out of date. U.S. nuclear power plants are conducting their flooding re-analyses according to the schedule the NRC announced in May 2012 (http://pbadupws.nrc.gov/docs/ML1213/ML12132A330.pdf). The analyses account for all flooding scenarios at a given site.
    4. The Corps of Engineers is responsible for sharing its work and has appropriately done so.
    5. The NRC continues to review those plant flooding re-analyses that have been submitted, and if necessary the agency will discuss its work in the context of interagency dam safety coordination.
    6. The federal agencies responsible for dam security will communicate any necessary alerts to dam operators.

    The NRC is devoting significant efforts to this important area of flooding analyses and flood protection.

    We should note the NRC has a number of formal ways you can raise concerns. (The blog is not one of them.) Formal concerns regarding any specific plant can be submitted using the NRC’s process for Allegations (http://www.nrc.gov/about-nrc/regulatory/allegations/safety-concern.html) or petitions for enforcement action (http://www.nrc.gov/about-nrc/regulatory/enforcement/petition.html). Formal concerns about NRC staff actions can be submitted to the NRC Inspector General (http://www.nrc.gov/insp-gen.html).

    Scott Burnell

  171. It’s a Dam Shame
    More on that declassified internal NRC memo on potential dam failures that can be found at Accession Number ML101900305.pdf in the NRC Adams System.
    There are established procedures for classifying and in turn, in rare cases, declassifying information. I am quite sure the NRC has a policy or procedure that provides guidance in this area.
    First of all a little on classifying information. It is good to put a seal on information that may aid and abet an enemy. However caution must be exercised as cloaking an issue in secrecy may result in an issue not getting the attention it really deserves. There are fewer folks asking the tough questions. Like when will this get resolved; is there anything that should be done in the way of compensatory measures or any interim action that should be taken; and is this resolution timely considering its potential impact on safety or security.
    Then there is the rare instance when something is declassified. We continue to hear about stuff that’s become automatically declassified after decades. Declassification is a serious matter and needs to be handled carefully. First and foremost all parties that could be impacted by such declassification must be consulted. Not just to concur but also to take measures they see fit in advance of such disclosure.
    I hope the NRC has documentation that demonstrates that all affected parties were contacted before this “damming” info was released. I am afraid the NRC unilaterally classified and then declassified this info without reaching out to those that could be impacted. I am thinking in particular of the Army Corps of Engineers, FEMA, and the Department of Homeland Security.
    It is a “dam” shame the way the NRC has handled this entire matter. Enough said in a serious vein.

    Now I would like to do a little tongue in cheek.
    First of all the NRC’s new policy on declassification will be after 100 years and then only with the permission of the President and the Pope.
    Now, pretend that you are an NRC official that just learned of this declassified memo.
    What might they say or think?
    “Who in the hell declassified this memo?
    Who knew about this?
    Why wasn’t I consulted?
    What a stupid thing to do!
    How in the hell can we get this cat back in the bag?
    I know our superiors stress regulatory transparency but we all know that is just talk. They deal in a fantasy world while we have to function where the rubber meets the road! Now everyone will be on our case. I just do not need this crap!”

    I will not conclude with meaningless cliches like the only way two people can keep a secret is if one of them is dead! Or with, be sure your sin will find you out.
    I will conclude by saying that the NRC has breached the public trust on this matter. That will be hard to restore.

  172. Nuclear Plant Safety Threat Due to Upstream Dam Failure
    A declassified internal NRC memo can be found at Accession Number
    ML101900305.pdf in the NRC Adams System. It is an internal NRC memo on a generic issue involving potential dam failures. This memo noted a “higher than expected potential for both the external flooding hazard due to a dam failure and it’s associated consequences to the public health and safety of the environment.”
    The memo lists twelve nuclear power plants as having a “HIGH” qualitative assessment of dam hazard vulnerabilities. The memo includes a number of references to this dam failure threat dating back to 1984. This memo is dated 07/19/2010 which interestingly is just a little less than a year before the great MIssouri River flood in 2011. This memo was not added to the ADAMS database until just a few months ago (12/05/2013).
    I conclude from this memo the following:
    1. That the NRC has been aware of this threat to public health and safety for a long time.
    2. That this information has been treated inconsistently as “Security-Related”. First it was security-related, then it was apparently declassified.
    3. That a number of nuclear power plants are in the “HIGH” threat category.
    I have a number of questions for the Commission:
    1. Has the dam failure information the NRC has had for years been shared with entities that have a profound need to know e.g. FEMA, the Army Corps of Engineers, the Department of Homeland Security, and State, County, and Local emergency preparedness personnel?
    2. Has the NRC taken any interagency action to ensure security at these critical upstream dams has been improved?
    3. Have those nuclear power plants in the “HIGH” risk category completed external flood re-analyses considering the complete instantaneous destruction of one or more upstream dams?
    4. Has the NRC shared the recent results of the Army Corps of Engineers dam failure analyses?
    5. Has the NRC shared the results of any nuclear power plant flood re-analyses?
    6. Have security alerts been sent to high risk dam operators via the Army Corps of Engineers advising them of the high risk of dam sabotage?
    There are of course many more questions that can and should be asked by perhaps appropriate investigative agencies. Is this the standard of behavior that we should expect from our government and it’s agencies?

  173. SAY IT AIN’T SO JOE!
    You are really scaring me NRC. Please come out and tell me there is not a shrewd of truth in what I am saying about the vulnerability of major upstream US dams to terrorist attack. Tell me that downstream nuclear plants are not in grave danger if a dam fails and that that there would be no mass casualties as a result. Tell me that security at these dams has been drastically improved. Tell me that these downstream nuclear plants will survive even if hit by a huge tsunami wave. Tell me that the beyond design basis accident considerations since Fukushima implemented at these plants will allow them to withstand such an event even if flood waters greatly exceed that for which the plants are currently designed. Tell me that you have advised other entities with a need to know of the confidential information you have regarding dam failure consequences so they can improve their response plans for such a catastrophic although unlikely event. Tell me that you are not falling on your sword to protect and preserve the nuclear industry. Tell me, NRC Commissioners, that you are not falling on your sword to protect the President who appointed you or other federal agencies that have failed to put public safety first.
    I sincerely hope that the NRC is “rope a doping” me and will come out strongly and forcefully to stomp on my allegations. But please do not remain silent you are scaring the hell out of me.

  174. The NRC has long been an active participant in the Interagency Committee on Dam Safety (http://www.fema.gov/national-dam-safety-review-board-and-icods ). The committee’s other members include the Army Corps of Engineers, FEMA, the Bureau of Land Management and the Federal Energy Regulatory Commission. The committee’s regular discussions include relevant updates on the potential effects of dam failures. For example, the Corps’ emergency action plans for Missouri River dams are already incorporated into FEMA and state/local emergency planning. All U.S. nuclear power plants have closely examined their flooding protections and have taken appropriate steps to correct any deficiencies. The plants’ flooding re-analysis will help determine what additional steps could be needed to enhance flood protection. The NRC already coordinates emergency planning with plants and their state and local counterparts to ensure the public will be protected from a nuclear plant accident regardless of its cause.

    Scott Burnell

  175. I am sorry Mr. Moderator but the NRC has put itself in an untenable position regarding flooding on the Missouri River. The NRC has had for some time information that a dam break on the Missouri River would be catastrophic for the Fort Calhoun and Cooper Nuclear Stations located downstream. Much more importantly an upstream dam break would cause massive civilian casualties and huge loss of property. Yet you and you alone have kept this information not only from the public but from other organizations with a profound need to know. Examples include FEMA, the Department of Homeland Security, and State, County, and local emergency response personnel. You are also aware of recent information from the Army Corps of Engineers regarding the impact of an upstream dam failure. Just guessing, but if this information took you off the hook you are not letting on. So I presume this data also supports the notion that such a dam failure would be catastrophic. Additionally and even worse NRC, you have to the best of my knowledge, taken absolutely no action to protect the public from such a disaster. The affected plants stay in operation and the upstream dams remain extremely unprotected, terrorist targets. If this is not unethical, inappropriate and downright dangerous behavior on the part of a federal agency responsible for public safety, I do not know what is! It is never too late even for you NRC to do the right thing!

  176. NRC to “Sandbag” Army Corps of Engineers this week
    The NRC’s Scott Burnell, a moderator on the NRC’s Open Forum Blog site, noted that, in effect, the NRC will sandbag the Army Corps of Engineers at an NRC-scheduled public meeting later this week.
    This meeting was called by the NRC to discuss a flood analysis study extension request submitted by two nuclear plants located downstream from earthen dams on the Missouri River.
    At this meeting if anyone brings up dam failure data recently submitted by the Corps to these nuke plants and the NRC, the NRC will pass the buck to the Corps because the Corps provided this information confidentially.
    This dam failure data is no doubt “damming”info or it would not be confidential.
    The NRC had previously calculated that a 46- foot tsunami would engulf these nuke plants if an upstream dam would fail. Of course the NRC subsequently struck this information from the public record saying they would not want terrorists to have the data.
    I do not know if the NRC has told the Corps about their intentions to sandbag them or even if the Corps has been invited to the meeting. The old NRC I knew would say the buck stops with them.
    Rich Andrews

  177. I do not like your answer as I believe emergency preparedness personnel deserve this information as well as the public. A dam failure is not just an Army Corps of Engineers issue. I believe the NRC could get the Corps to change their mind if the NRC really believed in regulatory transparency.

  178. If the Fort Calhoun and/or Cooper plants need to support their extension request by referencing information that another agency has determined is not publicly available, that discussion will be closed to the public. The NRC is committed to being open and will hold as much of the discussions publically as we are able to, now and throughout the flooding reevaluation process.

    Scott Burnell

  179. Security Measures Out of Whack
    12,000 dams in the US are classified as high hazard potential from a dam safety perspective. However, only a very small percentage of high-hazard dams represent a potential for causing mass casualties. I could not find a list of the high-hazard dams that represent a potential for causing mass casualties, but I suspect that the earthen dams on the Missouri River upstream of two nuclear power plants are included.
    All nuclear plants are hardened sites with respect to terrorist attack. There are more armed response personnel at these sites than there are nuke plant operators. There are extensive security measures mandated by the Nuclear Regulatory Commission. They include fences, intrusion detection systems, grenade nets, all manner of weapons, well, you get the picture.
    But there are no such mandated security measures in place for vulnerable upstream dams.
    The Department of Homeland Security has released a guideline handbook on security measures for dams but it has no regulatory requirements whatsoever. So why would terrorists attack a hardened nuke plant site when they could take out an unprotected upstream dam? The terrorists would not only cause a Fukushima-type accident at the downstream nuke plants but cause mass casualties and property damage as well. It is high time we get our security priorities straight!

  180. What is Good for the Goose is not Good for the Gander

    The old Atomic Energy Commission and even the early Nuclear Regulatory Commission that I was familiar with always stressed a conservative approach to safety. That is why I am so shocked to see them not abide by that fundamental principle today. Case in point is disregarding public safety in the event of a catastrophic dam break on the Missouri River.
    The NRC has known for several years that such a dam break would result in a Fukushima type event for two downstream nuclear plants. This flood event would greatly exceed the flood elevation for which these plants are designed to withstand. Yet the NRC has keep quiet about this information and much more recent confirming information from the Corps of Engineers. If one of their nuclear plants had such a callus disregard for their license conditions the NRC would be all over them for not putting safety first. Our nuclear industry regulator has failed in its primary mission of protecting the public. The NRC has a steamer mentality, they really will not do anything that would cause a nuke plant to be shutdown. Instead they will work with these nuke plants to pencil-whip this problem away. All the while cloaking this problem under the confidential safeguards information classification. Additionally the NRC will take no conservative safety action until this problem is conveniently swept under the rug. They will not even have these plants shutdown or will they take action to protect these vulnerable upstream dams from terrorist attack in the interim. What is good for the nuclear industry gander in this case is not good for the regulatory goose. Is it any wonder though when the NRC exists only if nuclear power exists! Although the EPA is in my opinion out of control at least it is not beholden to the parties it regulates. What else is the NRC keeping from the public so as to not endanger the viability of nuclear power?

  181. Why does the NRC want to have a public meeting when you cannot talk about the elephant in the room?
    In response to a request from two nuclear power plants for an extension of time to complete a flood reanalysis, the NRC has arranged for a “public” meeting early next month. The NRC however stated in announcing the meeting that part of it would involve sensitive, not for public consumption, information and therefore the “public” meeting would become a private one between the nuclear plants and the NRC.
    Just why would secrecy and privacy be needed?
    I think keeping this information from the public is wrong.
    First a little background.
    The flooding reanalysis required by the NRC is predicated on the failure of an earthen dam upstream of these nuclear plants. A tsunami type event would result which years ago the NRC calculated would result in a wall of water rushing down the Missouri River basin five stories high. Recently the Army Corps of Engineers sent confidential data to these power plants via the NRC that predicted the likely result of a dam failure on these plants. Now these plants want an extension of time to complete their analysis.
    Emergency planners have known for decades that dams can be used as a weapon of mass destruction. Why then is it necessary for the NRC to classify this info as confidential just because it involves downstream nuke plants? Terrorists could easily destroy these unprotected dams using an aircraft; an IED; or a suitcase nuclear weapon.
    So NRC, why hold a public meeting if the public cannot really participate? Why not just keep this little secret between you and the nuclear plant licensees? The public doesn’t really have a need to know anyway right?! Makes you wonder what other things the NRC knows about that may threaten public safety and a nuclear plant’s viability that the public will never know about. How can an agency whose very existence depends on the nuclear industry ever put public safety first?!

  182. Time to Lift the Veil of Secrecy
    Destructive tsunamis can occur in other places than our oceans and seas. They can occur on rivers downstream of dams. If a dam fails a river tsunami can occur.
    Recently two nuclear plants located downstream of earthen dams on the Missouri River asked the NRC for an extension of time to file updated flood analyses. The NRC has scheduled an early May public meeting to discuss their request. Although this is a “public” meeting the NRC indicated that portions of the meeting will be closed to the public. Why the secrecy?
    Could it be that the consequences of dam failure on the Missouri River could lead to a flood that would greatly exceed that for which these nuclear plants are currently designed to withstand?
    A short time ago these same nuclear plants were provided confidential information from the Army Corps of Engineers. The Corps provided data that predicted flood elevations at these plants if an upstream dam failed.
    If indeed this data revealed flood elevations at these plants that exceed the design basis flood elevation at these nuke sites, these plants must be placed in a cold shutdown condition until the formal flood analyses are completed.
    I believe the NRC realizes the significance of this situation by calling for such a meeting. It is time for the blanket of secrecy to be lifted. Dam failure on the Missouri River is not just a nuclear plant problem. Local, county, and state emergency planners also need this information.
    Time for the industry and the NRC to come clean!

  183. Garry is spot on. Instead of bragging about NRC or industry achievements the NRC should be talking openly about their regulatory and the nuclear industry’s shortcomings. Leave the propaganda to DOE and NEI. To read this NRC drivel you would think that everything is just perfect and things could not be better. We need a regulator not an industry cheerleader.
    How about posting blogs that attempt to answer hard questions. How about these for starters…
    • How can the NRC improve its regulatory effectiveness?
    • Why is the NRC baseline inspection program so often found to be inadequate?
    • Why has it become necessary for nuclear plant after nuclear plant to be placed under an enhanced NRC inspection program?
    • How can the NRC performance indicator program be improved so that deteriorating plant performance can be identified before actual significant operational events occur at the plant?
    • Is the NRC doing everything it can to resolve the high level waste problem in the US?
    • What steps are being taken to make the NRC inspection program more proactive and less reactive?
    • Has the NRC done everything reasonably possible to protect nuclear power plants from terrorist attack? Do these efforts include protecting upstream dams from terrorist attack?
    • Should affected nuclear plants be allowed to operate while awaiting the results of significant safety studies? For example, pending earthquake and tsunami-type reviews.

    How about addressing real issues for a change?!

  184. Thank you for reposting my Science 101 post in its proper place, The NRC’s job is a tough one and most certainly very necessary and all to often not appreciated..

    Your blogs are appreciated, they stimulate important discussion and the public has the opportunity to communicate their concerns, ask questions, discuss opinions and facts, including the art of communicating agreement and disagreements.

    This public venue is a communications tool, and it is part of your “face” as our regulator. Moderation at times is necessary, but it must be fair.

  185. You are correct. The original comment was related to the original post for which it was intended. We will make it appear there as well as here. We apologize.

    Moderator

  186. It is unfortunate that the NRC supports propaganda and moves blog postings which challenge their position.

    NRC, your job is to protect the public, not deceive them, not propagandize science, nor move postings around because they do not fit into your or the NEI’s propaganda model.

    Your job is regulation to protect the public. If you wish to educate the public that is great. When you utilize analogies in your Science 101 blog of a warm light bulb, cosmic and earth’s processes, equate the comparisons to ionizing radiation, which in the presentation downplays the threat of ionizing radiation; you are presenting a “maskirovka” of sorts. Particularly when you leave postings which support nuclear power and are off topic, but remove those who challenge you and the process of your mission as it relates to education.

    It is not your mission to act as if you are the NEI or the DOE. It is those folks mission to support nuclear power, not yours. Never downplay the risk presented by ionizing radiation – never deceive the public!

    You are a public entity whose sole purpose is to protect the public via your regulatory function; it is not your mission to protect nor support the nuclear power industry.

  187. This post was moved from the Science 101 blog. Here it is out of context, there it was not. Spreading nuclear waste in our atmosphere is about science, bad science and propaganda, and the ridiculousness of some nuclear physicists who will say anything and run any scam to support nuclear power. Unfortunately, this is a reflection on the NRC and their regulatory policies of which propaganda is not part of the NRC’s mission.

  188. Garry Morgan gmorg50@hotmail.com
    Submitted on 2014/02/26 at 2:55 pm | In reply to George Rublein.
    There is evidence that the supporters of the Radiation Hormesis theory are delusional. I distinctly remember a so called scientist recommending we disperse radioactive waste across our atmosphere as a solution to our gigantic and growing nuclear trash/waste problems. By doing this it would cure us from all of our sicknesses, according to the so called scientific reasoning.
    Moved by Moderator

    There are several medical studies which have demonstrated that low levels of ionizing radiation are harmful, particularly to women and children.

    Of course radiation levels are being reconsidered, since hundreds of billions of dollars are riding on the insanity of the aftermath of Fukushma.

  189. richard123456columbia
    richardperrycolumbia@shaw.ca
    I have a huge problem with any evaluation when a accident is considered, in the near future a Carington event like the one in the 1800’s will happen. This was presented to the American government a few years ago and I have not seen a reply. This event has the likely hood of causing over a hundred plants going into melt down at the same time. How in the hell can these plants be built if an accident is considered. If it happens it will cause a surges on the power lines lasting for some time, this surge will jump over fuses and weld contacts on switches, relays and breakers before they can open. How will this be prevented or the gaining control of the plant shut down?

    Moved by NRC Moderator

  190. CaptD
    captddd@gmail.com
    I suggest that it would also be most helpful to video tape them so that others can “listen to the Pro’s” tell their stories in which they could share their knowledge. Most people talk better than they write, especially about technical matters.

    The most important area of knowledge that NRC needs to document ASAP is Fluid Elastic Instability (FEI), since San Onofre’s NPP replacement steam generator (RSG) debacle has clearly pointed out that while many at the NRC claim to have expert knowledge about FEI, very few if any really do, which places us all at risk. NRC employees don’t like to admit that they don’t really understand FEI, the specific factors that lead up to it and/or how FEI can cause cascading steam generator tube damage inside operating steam generators that cannot be detected until after the damage is done, which could then lead to a catastrophic loss of reactor core coolant!

    Case In Point:
    San Onofre NPP Unit 2 was operating with a SG tube that had 95% wear, when the safety limitation is 35%, yet the Utility Operator SCE never had a clue that this tube was close to failure, until it was inspected during a scheduled refueling, which luckily happened to also occur at the same time that Unit 3’s almost new RSG developed a radioactive leak on 01/31/12. Later NRC investigations found more damaged SG tubes at San Onofre Unit 2 and Unit 3, than in all of the rest of the US nuclear fleet combined!

    Chart:

    Click to access steamgeneratortubespluggedbyageandsanonofresteamgeneratorproblems2012-11-03.pdf

    The NRC has chosen to “look the other way” instead of immediately revising their Beyond Design Basis (BDB) belief that only a single SG tube can fail at any one time for any reason at any NPP, a belief that both San Onofre’s almost new RSG have proven is no longer factual, despite the fact that even ex-NRC scientists have warned the NRC about this issue previously, yet no Regulatory changes have been made. Adding to the problems at San Onofre, are the many conflicting industry and academic expert opinions/explanations of exactly what occurred at San Onofre.

    Many have urged the Chairman of the NRC to direct that San Onofre’s investigations be fast tracked and made public because of its safety implications, but it turns out that even Senator Boxer is having trouble getting complete documentation from the NRC about San Onofre’s operation Each day that the NRC continues to stretch out its FEI investigations hoping this problem will just go away, is yet another day that all other NPP’s may be operating in a potentially unsafe manner!

    Moved by NRC Moderator

  191. Thank you Moderator.
    I just raised what I think is a violation of federal regulations to the Executive Secretary of the Commission. Thought I would post it here also.

    The Fort Calhoun Nuclear Station is Being Operated in Violation of Appendix A to 10 Part 50—General Design Criteria for Nuclear Power Plants

    Paraphrasing these NRC regulations, a nuclear plant must be designed to protect itself against natural phenomena including floods. The design must also concurrently allow for the failure of a single component such that it’s failure does not result in the loss of a safety system to perform its intended safety functions. My concern centers on this requirement and addresses a single active failure that results in a common-mode failure of an entire safety system.
    The Fort Calhoun Station was recently forced to shutdown and cool down due to the failure of a single component, just one intake structure sluice gate of six installed at the plant.
    As a result of this failure the plant declared all four safety- related raw water pumps inoperable. As I understand the design, the failure of any of these sluice gates to close, or to be nearly throttled shut, will result in flood waters covering and rendering inoperable the raw pumps in the event of a design basis flood event at the site.
    Furthermore, these sluice gates have been notoriously unreliable. Most recently one of them had ice blockage. In the past these sluice gates have been prevented from fully closing by debris, sand, and silt. Once closed they most often leak by. These gates are not leak tested periodically as are similar safety-related components in the plant in accordance with the plant’s Inservice Inspection Program. To the credit of the plant staff these sluice gates are cycled periodically to check their operational status. However, this does not ensure that all six gates will operate when needed during a severe flood event, and in fact the General Design Criterion requires that one of these gates be presumed to be inoperable. Unfortunately, since the raw water pumps are an essential system to provide an ultimate heat sink for the reactor and fuel in the spent fuel, the plant must be immediately shutdown and maintained in a cold shutdown condition until the plant design is appropriately changed to meet federal requirements.

  193. Mr/Ms Moderator,
    Would you help me find or provide a link to the NRC annual assessment letters for the Fort Calhoun Station? I was able to find an assessment letter on ADAMS that covered 2009, but was unable to find later assessment letters. I am looking for the NRC annual assessment letters for the Fort Calhoun Station that cover 2010, 2011, and 2012.
    Thank you.

  194. The pumps were never forced out of service. Equipment can be administratively declared “inoperable” for Tech Spec purposes and still be operating.

  195. A “Green Board” Should Be Required for Nuke Plant Restart
    I previously talked about the NRC performance indicator program and how I thought it was seriously flawed.
    Case in point was the last plant that was placed on an enhanced NRC inspection program. It had the same set of performance indicator colors it had when it was placed on the troubled plant list as it had when it was allowed to restart by the Commission a couple of years later. Shouldn’t all performance indicators be in the “Green” for go when a plant is allowed to restart? A nuclear plant would not restart if there were a bunch of alarm windows lit showing on the control room panels. Same should be the case for regulatory performance windows.

  196. NRC Inspection Findings Performance Indicator Summary Ineffective
    Did you know that the latest nuclear power plant to be placed under the NRC’s Enhanced Inspection Program had the same set of performance indicators when it was placed under the program that it had when the NRC allowed the plant to restart last month?!
    In the 4th Quarter of 2011 (the plant was placed under 0350 enhanced inspection 12/13/11) the NRC ROP Inspection Findings Summary showed 1-Red, 1-Yellow, 4-Green, 1-No Finding, inspection finding windows. When the NRC allowed the plant to restart last month these performance indicators were exactly the same color except that one window, the security window, was worse than before, so-called Greater Than Green. The color codes are kind of like a traffic light but with an extra White light. Green is good to go, White is worse (no white lights for this plant), Yellow is worse yet, and Red is the worst from a nuclear safety standpoint. Doesn’t this situation tell even the layman that something is terribly wrong with the NRC performance indicator program?!

  197. Are there any plans for an international role to decommission Fukushima?

    If Japan lacks a decommissioning expert (according to this NPR article http://www.npr.org/templates/story/story.php?storyId=251162961) and yet the U.S. NRC has “10 people devoted to decommissioning including four project managers, four health physicists, and a hydro-geologist. It says it has the equivalent of more than 200 years of experience in decommissioning and has overseen the termination of 11 power reactors and 13 research reactors”

    Why haven’t we (and other countries who are experienced in decommissioning) stepped in to help?

    I am just a concerned mother and I have nothing against nuclear power, but I just want to know what we are doing to protect the U.S. and the rest of the world from the worst nuclear disaster in history?

    I appreciate any information you can share. Thank you

  198. A Cursed Nuclear Power Plant?
    I am not the superstitious type but even I am beginning to believe in curses. Trouble is I don’t know who is responsible for this curse or how it can be undone.
    Case in point the Fort Calhoun Nuclear Power Station.
    Consider this sequence of events:
    Fall 2010: The NRC finds the only significant problem through their inspection efforts at the plant in 16 years, an inadequate flood protection barrier.
    Late Fall 2010-Early 2011: As a result of the NRC finding, personnel at the plant find many other flood protection inadequacies and work very hard to correct them.
    Spring 2011: After the plant is shutdown for a scheduled refueling outage an historic and unprecedented Missouri River flood occurs which tests the plant’s flood protection measures to the limit.
    Later during the flood: a machine operator accidentally damages an inflatable rubber berm that surrounds the plant causing more flooding.
    Later yet in 2011: A fire in vital electrical switchgear renders a “redundant” power supply inoperable causing a temporary loss of all cooling to radioactive spent fuel in the plant’s spent fuel pool.
    Late 2011: The NRC finally decides that the plant is in trouble and declares it a “troubled plant” subject to “enhanced” NRC inspection.
    Late 2011-December of last year (2013): Under increased pressure from the NRC the plant finds and corrects many program, process, equipment, and management problems at the plant, many of which were long-standing and very serious.
    Dec 2013: At long last Fort Calhoun is allowed to restart by the Commission.
    Mid Dec 2013: The plant reaches 100% full power.
    Early January 2014: Mother Nature strikes again. In what has been termed the Midwest’s “Polar Vortex”, ice buildup in the plant’s intake structure renders all four safety related raw water pumps out of service. The plant responds promptly by shutting down and cooling down the plant.
    Curses! Foiled Again!

  199. When NRC inspectors find a problem it should always be considered a big deal
    Why? Because when an NRC finds a problem it is probably the tip of an iceberg of problems.
    When the NRC finds a problem that means the nuclear power plant operator has failed to find it first. The nuclear plant safety net has been breached.
    The nuclear plant safety net includes all the folks who have failed to identify the problem in the first place. They include:
    • The plant workers themselves
    • Their supervisors and managers
    • The plant Quality Control Group
    • The plant’s Corrective Action Program
    • The independent Quality Assurance Group
    • The Utility Safety Oversight Groups
    • INPO-the Institute of Nuclear Power Operations
    When the NRC finds a problem it should therefore be a big deal but I do not think it is consistently treated that way by the NRC or by some plant licensees. Furthermore, I do not believe that it is the fault of the NRC inspectors themselves.
    I think it is the NRC regulatory framework and structure that is seriously flawed. And that is the fault of NRC management.

    Even though I am a retired old-timer in the nuclear business I have tried to keep up to speed with what is going on with our nation’s nuclear power plants. In the old days problems identified by NRC inspectors seemed to always be a big deal. And I think today that in the best-run and managed nuclear plants that is still the case. In these best plants even potential problems or even NRC inspector voiced concerns are jumped on by these plants and wrestled to the ground. However, changes to the regulatory process over the years have, in my opinion, diminished the significance of real problems identified by NRC inspectors. In the old days a violation was a violation and the nuclear power plant operator had to respond in writing to any such violation. Today there are minor violations, non-cited violations, and cited violations. Minor violations and non-cited violations require no formal response from the licensee. Only cited violations require a written response. Furthermore, minor violations can be omitted in NRC plant inspection reports. I reviewed the regulatory track record of one plant that was recently placed on the NRC “troubled plant” list.
    Over a 16-year period there were only 10 cited violations. Of these 10 only two were violations identified by the NRC. The other 8 were self-revealing violations due to equipment malfunctions and in one case a fire. The key here is that after the plant was placed on the enhanced NRC inspection program due to a couple of those significant violations, the licensee was forced to take a hard look at their operation. In so doing they found many problems with equipment, programs, processes, and management that were not, for the most part, previously identified by the NRC. In hindsight looking at some of the detailed NRC inspection reports some problems were identified by NRC inspectors but were buried in the inspection reports as concerns, and minor or non-cited violations. The bottom line is that some plants jump on NRC concerns and some obviously need regulatory arm-twisting. Plant after plant has been determined to be a “troubled plant” and I believe part of the problem is that the current NRC regulatory framework is flawed.

  200. What about all Nuclear reactors being vulnerable to really big earth quakes?

    RE: when Fukushima’s reactors began to fail after a massive tsunami in 2011.

    The huge earth quake that preceded the 2011 tsunami, started the meltdown process at Fukushima, when major power lines collapsed, the tsunami then made things much worse! To leave the earthquake out of the above statement is not only inaccurate, but points out that even now, with the multiple meltdowns at Fukushima still leaking radioactive pollution, the NRC is promoting a pro industry myth. These statements seek to shift the publics attention away from big earth quakes to tsunami’s, since to the public, the threat of big tsunami’s is (SO FAR) much less in the USA, where everyone knows that a big earth quake can strike anywhere at any time.

    This is why I say:

    Nature can destroy any land based nuclear reactor, any place anytime 24/7/365!

    Captddd@hotmail.com

    Note: Moved by the moderator

  204. The NRC provided technical assistance to the U.S. Department of State during development of guidance to avoid travel within 50 miles of the Fukushima Dai-ichi site in the immediate aftermath of the accident there. That guidance expired in October 2011. Existing travel alerts for Japan are available on the U.S. Embassy in Tokyo’s website — http://japan.usembassy.gov/e/acs/tacs-warden.html .

  206. Jeff,

    Just a few of my thoughts from your brief description:

    Any idea how big was the steam leak? It’s source? How long had it been leaking, and how fast was it increasing? Could the leak be isolated, and if so with what plant conditions? Was the room full of trip hazards, head-knockers, making an inspection difficult, if not impossible?

    >140 deg F is too high to enter without an air-fed steam suit. Having worn one of these suits in the past, they may allow some visual inspection, but are cumbersome when attempting local, manual leak isolation, much less repairs. Such a room entry, if needed at all instead of leak isolation, would raise questions about the need for: 1) two entrants in steam suits with air supplied breathing and with full communication to an entry control team; 2) a rescue team, suited-up and ready to assist; 3) a thorough pre-job brief; 4) an ability to remotely isolate the leak, if needed during the entry; 5) a specific entry objective – no free-lancing.

  208. When does a room with an active steam leak become an IDLH? What culture allows a manager to lable people as “pussycats” so to speak, when they don’t want to enter such a room because the temperature is 140-160 degrees F, steam has engulfed the room such that visibility is only about 4 feet above the floor and breathing is impossible while standing?

  209. If you had a valid personnel safety concern at a US Nuke plant, would you take that concern to OSHA or the NRC?

  210. The U.S. Nuclear Regulatory Commission does not have regulatory authority over nuclear plants outside the U.S., nor do we have responsibility for monitoring the world’s oceans or fisheries. However, the U.S. Food and Drug Administration and the U.S. National Oceanic and Atmospheric Administration do have responsibilities in this area. Here are some links that might be useful:

    http://www.accessdata.fda.gov/cms_ia/importalert_621.html

    Click to access UCM073204.pdf

    Moderator

  211. fukushima is still melting down; 300 tons of radioactive sea water spewing daily heading in our direction. what is USNRC doing about this besides nothing?

  212. If taken properly, potassium iodide (KI) will help reduce the dose of radiation to the thyroid gland from radioactive iodines, and reduce the risk of thyroid cancer. The Food and Drug Administration has issued guidance on the dosage and effectiveness of potassium iodide. The NRC has supplied KI tablets to states requesting it for the population within the 10-mile emergency planning zone to be used in accordance with state emergency plans. If radioactive iodine is taken into the body after consumption of potassium iodide, it will be rapidly excreted from the body. If you have questions or are concerned about taking KI please check with your doctor and follow his or her advice.

    Links for more information: http://www.nrc.gov/about-nrc/emerg-preparedness/about-emerg-preparedness/potassium-iodide-use.html and http://www.nrc.gov/about-nrc/emerg-preparedness/about-emerg-preparedness/potassium-iodide.html

    Patricia Milligan

  214. 68.8.158.39 Submitted on 2013/06/07 at 8:24 pm
    ☢ Seminar About Fukushima’s effect on Japan, USA and the World

    – Jun 6, 2013 – 8:50
    Recent Seminar in San Diego, CA (in English & Japanese) about Fukushima, Lessons Learned for California and the rest of US…

    Lessons for California from Gregory Jaczko, Former Chairman of the Nuclear Regulatory Commission

    + Former Japanese PM Kan and two others…

    http://www.copswiki.org/Common/M1359

    Captddd@gmail.com

    Note: Moved by the moderator

  216. I don’t know to whom you sent the document or what kind of comment you were seeking, so I can’t answer the question. However, if it was related to energy policy in general or issues of the “energy mix” in this country, the Department of Energy would be the correct place to submit the powerpoint.

    Moderator

  217. A few month ago I emailed a power point doc (Going Green All The Way). I also gave a copy to president Obama and President Clinton. I have been wondering if there have been any coments on that document?.

    pribas@msn.com

    Note: Moved by the Moderator

  218. In most cases, the slides are posted on the meeting notice page on the website. But sometimes there can be a delay if slides are being revised at the last minute or being delayed in some way for posting to ADAMS (a requirement). And if we have non-NRC staff providing slides, we need time to process those. So, yes, we agree with you, and it’s something we’re working toward. You can also reach out to the contact person listed on the meeting notice the day before, if the slides are not posted.

    Holly Harrington

  219. I am a frequent participant in NRC public meetings via teleconferences and/or webcast and I applaud the NRC for making these meetings remotely accessible. It’s an invaluable time and money saver.

    Unfortunately, in many of these open public meetings (not all), only those who attend in person are provided a copy of the meeting slides with which to follow along and refer during the meeting. In these cases, the meeting flow, usefulness, and efficiency tends to be greatly reduced. To be clear, I’m not talking about closed meetings or meetings where SGI/SUNSI or proprietary information is discussed.

    As a matter of policy, and in the interest of fairness and meeting efficiency, a copy (or e- copy) of the meeting presentations should be provided to ALL participants, no later than the start time of the public meeting. Thank you.

  220. Submitted on 2013/05/14 at 2:23 pm

    Who’s brilliant idea was it to build a nuclear reactor on the beach in one of the most seismically active areas of the country. Liquifaction? San Onofre, CA is Fukushima waiting to happen. How? Why? It doesn’t take a genius to see this reactor should never have been built, never mind not restarted at any capacity. Edison can take the hit on this one. They aren’t broke.

    macphillips1@gmail.com

    Note: Moved by moderator

  221. Greetings!

    I’m no ad-man and don’t go around promoting blogs, and the following isn’t that case. If nuclear energy is to get a fair shake in the court of public opinion then it needs to be viewed free of tainted, biased, FUD, and often pernicious assertions divorced from fact or study. Rod Adams has vented anti-nuclear activists whose credential pretenses and outright lies has caused great grievous injury to the public perception and acceptance of nuclear power. Two such excellent and long overdue ventings can be viewed here:

    http://atomicinsights.com/2013/04/was-gundersen-a-licensed-reactor-operator-and-senior-vp-nuclear-licensee.html#comments

    I hope more blogs step up to the plate to debunk and expose anti-nuclear zealots and organizations. Nuclear blogs ought have a persona notorious headliner on these types to tip off a clueless web surfer. I implore all nuclear advocates join me, even redundantly, to embedding this above address on as many nuclear sites as possible for a heads-up on the same page on our common unscrupulous nemesis who is almost literally getting away with mass murder in league an unchallenging often sympathetic media. Doing so is not strutting a blog; you are doing a public good by enlightenment for the irresponsible pro-fossil actions of anti-nuclears has cost the health and lives of real-life non-specutalated tens of millions of people worldwide.

    James Greenidge
    Queens NY

    Note: Moved by the moderator

  222. The NRC has repeatedly examined the potential impact of solar flares and continues to conclude U.S. nuclear power plants can safely shut down if a major flare affects the U.S. electrical grid. Both the NRC and the Federal Energy Regulatory Commission (which oversees the grid) continue to examine ways the grid and power plants can better withstand a severe solar flare impact. Late last year, the NRC announced its decision on a public petition regarding solar flares. For more information on the subject, please see: https://public-blog.nrc-gateway.gov/2011/10/31/keeping-u-s-reactors-safe-from-power-pulses/ and http://pbadupws.nrc.gov/docs/ML1235/ML12353A410.pdf .

    Scott Burnell

  223. To admin–I scanned the 1700 comments, and I am somewhat shocked, unless I missed something, that no one mentioned the issue of a large scale power loss due to a Carrington type event, that would, say knockout half the united states, with obvious large scale disruption of society and supply chains, and could lead to dozens of nuke plants or their spent fuel pool melting down.

    This seems odd, since the odds of such an event (especially these next few years) seem to be much greater than 1%. and our great new eye on the Sun doesn’t make this long tailed cat anymore comfortable in a room full of rocking chairs and surprise space rocks.

    freshenergy@hushmail.com

    Note: Moved by the moderator

  224. Thanks to Mr. Matthew Mitchell, Chief, Projects Management Branch, Japan Lessons-Learned Directorate for posting this blog. San Onofre Billion Dollar Debacle SCE/MHI/NRC Fukushima Lessons Learnt and Public Awareness Series – HAHN BABA

    SCE 10CFR 50. 92 (No Significant Hazards Consideration Analysis) License Amendment for San Onofre Nuclear Plant – SCE has to provide NO answer to one of the following 3 questions:
    (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or
    (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or
    (3) Involve a significant reduction in a margin of safety.

    It appears from a review of all the NRC Regulations and NRC Staff reports/ correspondence that NRC/Industry/NEI/EPRI purposely does not believe in the Ex-NRC Highly Educated, Brilliant Researcher, Eminent Scientist, Public Safety Expert [NAME REDACTED] theory, actual observations and concerns of cracked tubes, cascading tube leaks/ruptures caused by steam line breaks at several power plants (SONGS Unit 2 Scenario -100% void fractions resulting in uncovery of the tube bundle, jet impingement loads on tubes caused by flashing feedwater and stored energy in SG, loose metallic objects and parts of of broken tubes cutting other tubes, 36 U-bends with clearances of 0.05 inches, failure of retainer bars due to FEI velocities causing collapse of Anti-vibration bar bundle and rupturing other pressurized tubes, resonance vibrations and re-pressurization of SG resulting in loss of more coolant, etc.) and operator errors even after what happened with SCE/MHI designed Magical out-of-plane anti-FEI vibration bar bundle in SONGS 3, then the readymade cookbook SCE answers based on knowledge of SONGS 50.59/FSAR Culture are as follows

    1) Yes, Operating SONGS Unit 2 between 70-95% power involves more than a minimal increase per SONGS 50.59 Cookbook, but does NOT Really Involve a significant increase in the probability or consequences of an accident previously evaluated;
    (2) Operating SONGS Unit 2 between 70-95% power does NOT Really create the possibility of a new or different kind of accident from any accident previously evaluated; and
    (3) Yes, Operating SONGS Unit 2 between 70-95% power involves more than a minimal increase, but does NOT Really involve a significant reduction in a margin of safety.

    Then the question is if SCE is so sure of its 50.59 readymade cookbook answers like the Replacement Steam Generator 50.59 Evaluation Conservative NO Answers, why does not SCE want to apply for a License Amendment to operate Unit 2 at 95% power and afraid to go through a questioning public hearing. If SCE applies for a License Amendment to operate Unit 2 at 95% power and goes through a satisfactory public hearing, it makes good economic and public relations sense for SCE. Satisfying the concerned public in a democratic country like USA is key to the future of SCE, NRC, MHI and Nuclear Industry and intentionally avoiding the worried and restless public is an admission of guilt, negligence of duty, and is an indication of SCE using money and political clout to subvert the NRC regulatory process and violation of Federal Regulations. NRC has very brilliant and dedicated safety staff and I hope they do not get trapped and tainted like the Japanese regulators with Fukushima….Very Strong Rumors on the street from several sources that some elected and appointed officials with authority over Senator Barbara Boxer and Dr. Macfarlane are adamant and pushing restart of Unit 2 despite very strong objections from public, technical experts, scientists, Ex-NRC Chiefs, Friends of the Earth, Media and several Safety Organizations. In the End, Southern Californians need safe, reliable, well managed/maintained nuclear plants free of worker retaliation, discrimination and harassment for expressing nuclear safety concerns and Not a Fukushima in their Backyards.

    Note: Moved by the moderator

  225. Considering the fact that no storage site for radioactive waste that will render it safe for thousands of years has yet been found and created, what is the rationale for creating more?

    Take the case of the San Onofre Nuclear Generating Station: tons of radioactive waste have been accumulating beside the coastal route linking Orange and San Diego Counties for 40 years. It’s situated adjacent to three earthquake faults on the shore of the Pacific Ocean in a tsunami zone. Population in the 50-mile radius of that plant has grown to more than eight million since it was built.

    This ageing facility (owned and operated by Southern California Edison) has been down since Jan. 31, 2012 due to malfunctioning tubes and design flaws. In that time, no more radioactive waste has been created. There have been no power outages in the huge population area it served. This power plant has never supplied more than a small percentage of the total electricity needed by the ever-growing communities within a 50-mile radius of the plant.

    It is irrational to start up San Onofre again so it can continue to produce over 500 pounds of radioactive waste daily, risking the lives and properties of millions of people for a small boost of electric power they’ve proved they don’t even miss. Instead, the urgent priority must be to solve the safe storage of radioactive waste far from population centers for thousands of years. Until that can be done, it is irresponsible and dangerous to continue creating more radioactive waste.

    melkernahan@gmail.com

    Note: Moved by the moderator

  226. Tsunamis like the one that devastated Fukushima are caused by earthquakes along “subduction zones,” where the force of the earth’s movement shoves one tectonic plate under another rather than the more common horizontal movement of two plates rubbing against each other. The only subduction zone along the U.S. West Coast is the Cascadia zone, stretching from northernmost California and along the Oregon and Washington coasts and northwards to British Columbia. The NRC is confident that Diablo Canyon and San Onofre are adequately protected against likely tsunamis that are possible from the seismic conditions of their region.

    For info on spent fuel management and storage, including inventory information, we recommend the U.S. Fourth National Report for the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management, available on the Department of Energy’s website at this address:

    Click to access 4th_US%20_Nat%20_Report%20%2009-21-11%20(2).pdf

    Dave McIntyre

  227. Diane March 26, 2013 at 4:40 pm (Edit)
    Along the same lines….Kim, can you please comment regarding Diablo Canyon’s storage & also about the danger of tsunamis and/or earthquakes coming from the 13 faults around it? Thanks!

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  228. Please contact the Office of the Inspector General directly for information on this issue. You can reach them at: 1-800-233-3497.

    Moderator

  229. please get me your OIG ‘s decision regarding my criminal complaint re Pilgrim Nuclear

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  231. Can we get an update on how our nuclear facilities faired during Storm Saturn? What about the Pilgrim plant, which operates on a General Electric Mark I (same equipment as Fukushima). Their license would have expired in 2012 if you hadn’t given them such a generous 20 year extension (which was vehemently opposed by Pilgrim Watch).

    What about the Oyster Creek plant (oldest plant in the country)? The national weather service has a flood warning in effect until friday.

    What about the various other facilities in the D.C. area as well as the ones in the midwest? Are they all safe?

    The taxpayers are anxious.

    -Keith
    keithsbrooks@gmail.com

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  232. Summarizing John Large’s Technical Affadavit, Westinghouse and AREVA OAs and Dr. Michel Pettigrew’s (World’s Number 1 FEI Expert hired by SCE) Testimony in Front of NRC Chairman and Commissioners

    Tube Wear Rates – Predicting the In-Service Period:

    1. John Large States,”SCE presents the findings of its commissioned OAs in a positive light, claiming that at 70% power the restarted Unit 2 plant will maintain RSG tube integrity for 16 to 18 months of continuous running, that is considerably longer than the proposed 150 day inspection interval. However, closer study of the OAs reveals that the reasoning behind important aspects of the deterioration period for the AVB effectiveness in Unit 2 is flawed, being overly dependent upon a number of uncertainties. Some account of these uncertainties has been taken by AREVA in revising the TTW time-to-burst period down to 2.5 months which is well below the 150 days inspection interval but, without much justification, it determines and front-ends the time-to burst with a further 3.5 month AVB wear-in period, thereby delaying the onset of TTW and the unacceptable level of risk of tube burst to about 1 month longer than the proposed inspection period. There is little confidence in the outcome of the AREVA and Westinghouse OAs projection of the time period through which the Unit 2 nuclear plant could be reliably expected to operate without a) incurring a tube failure or b) running at a greater risk of a tube failure occurring. This is primarily because: (i) it is generally accepted that Unit 2 is following along the same path of deterioration as Unit 3 (AVB wear and loss of effectiveness preceding TTW), although the reasons why it lags so much behind are not at all understood by SCE and, indeed, subject to disagreement between the AREVA and Westinghouse; (ii) moreover, the pattern of AVB breakdown is not clear from the more advanced TTW degradation of Unit 3, thus the Westinghouse extrapolation to Unit 2 is not robust – again, there is disagreement between the OAs on this; so, it follows,
    iii) there is very little justification in adding to the time-to-burst for Unit 2 tubes a 3.5 month AVB wear-in period, this is particularly so because so there is no certainty of just where Unit 2 is presently at along the path towards TTW wear. In account of these uncertainties, together with the uniqueness of the in-plane FEI in the SONGS RSGs, restarting Unit 2 to continuous running, even at 70%, will incur great deal of change, test and experiment.

    TTW Tube Performance during Design Basis Accidents (DBA): The tube structural integrity performance is unpredictable when subject to additional forces during and following certain design basis accidents. From the OAs it is not clear that this important nuclear safety prerequisite has been adequately reviewed and included in the SCE response to the CAL.

    Final Safety Analysis Report: SONGS Technical Specification assumes that for normal operation the DBA event is limited to the burst of a single tube and that for all other design basis incidents (SSE, LOCA, etc) all tubes are required to maintain structural integrity throughout and following the incident.

    The conditions, uncertainties and risks that will accompany the proposed restart and continuous running of Unit 2 significantly depart from those incorporated in the unrevised FSAR, particularly: (i) since there are no means of monitoring tube wall thinning whilst the plant is in service, the risk of tube burst is wholly dependent upon the accuracy and reliability of SCE’s, (a) Outage 16 inspection results obtained indirectly, using remote inference techniques, to predict the extant tube wear and, importantly, the condition and contact forces of many thousands of AVB-to-tube locations when in the cold and unpressurized state, and projecting these to the hot, pressurized service operational state; and , (b) using the data predictions of i)a) are drawn from uncertain and empirically unsound bases, to seed models of AVB-to-tube contact characteristics and tube motion, in order to determine the tube wall wear rate, tube wall thinning and, hence, the risk of tube rupture; (ii) certain of the wear patterns and tube thinning seem to be unique and have not, been experienced in operational SGs elsewhere, so the rate(s) of tube wall thinning adopted by AREVA and Westinghouse OAs are largely hypothetical; and (iii) prediction of FEI activity, the placement and effectiveness of the preventatively plugged tube buffer zones in delaying the advancement of TTW are founded on a great deal of uncertainty; (iv) there is disagreement over the extent of other (non-FEI) fluid excitation sources, particularly at the TSP and AVB contact points. With such uncertainties prevalent, RSG tube integrity cannot be assured throughout the inspection interval proposed by SCE, thus previous studies and analyses contained within the present version of the FSAR would be invalid for the restart and continuous running of Unit 2.”

    2. Westinghouse states, “FASTVIB incorporates the analytical approaches that were largely defined by the work of H.J. Connors at the Westinghouse Research Laboratories. Verification and qualification of this methodology for steam generator applications includes not only the analytical comparisons in configuration control files, but also many comparisons with results from tests and operating steam generators. These include comparisons with a 49-tube test model of the inlet region in water flow, a quarter-scale model of the U-bend tested in air, a .01 power scale Model F steam generator (MB-2), cantilever tube air flow tests, and operating Model 51 and Model F steam generators. Work rates are scaled from baseline mechanical shaker test trends using inputs from qualified thermal-hydraulic and FIV analyses such as ATHOS/VGUB and FASTVIB. Evaluating any other geometry, including tube row and AVB location, and any other flow field, requires adjustment of experimentally determined workrates using parameters appropriate to the configuration of interest. In this case, work rates for the SONGS steam generators were determined using scaling factors derived from analyses. This is done using an equation that is a function of tube frequency, secondary fluid density, effective velocity of the fluid for the limiting vibration mode, fluid elastic excitation ratio, effective tube span length, and tube/AVB clearance. The wear projection process applied here is very time consuming due to the trial and error involved in obtaining a match for the inspection results, often for three different AVB wear indications in a given tube. Therefore, the uncertainty evaluation is based on the following analysis applied to one tube. In this evaluation, the method uncertainty (standard deviation of growth) is determined as a fraction of the mean estimated growth of an AVB wear indication. This allows estimation of them growth uncertainty from the estimated growth by applying this ratio.”

    3. AREVA states, “Since stability at 70% power does not depend on any effective in-plane supports, detailed probabilistic calculations are only relevant to the demonstration of margin and conservatism. A maximum stability ratio of 0.75 will be maintained for 8 months at 70% power with a probability of 0.95 at 50% confidence. A conservative probabilistic analysis demonstrates substantial margin for the planned 5 month operating interval. Additionally, defense in depth measures in terms of preventive tube plugging with wire cable stabilizers in plugged tubes, provides for maintenance of tube integrity under the extreme assumption that instability at 70% power begins immediately upon restart. The minimum estimate for time to violate structural and leakage integrity requirements in an unplugged tube is 6 months based on instability zone expansion from higher risk plugged tubes out to an unplugged tube and then wear of the unplugged tube.”

    4. Dr. Pettigrew states, “We’ve been trying to model these phenomena for quite a number of years, and guess we’ve made some progress, but so far we haven’t been able to predict what we have seen in the lab, you know, within plus or minus 10, 20 percent, and we’re out by a factor of 50 percent or more. And it’s particularly difficult in two- phase flow, because in two-phase flow, you have an extra parameter, which is void fraction or steam quality, if you like. And then you’ve got also to talk about flow regime. What kind of flow regime exists inside the tube bundle? Okay, so very little work has been done on that, because it’s very difficult to do, for one thing, and in cross-flow in particular. you’ve got also to talk about flow regime. What kind of flow regime exists inside the tube bundle? Okay, so very little work has been done on that, because it’s very difficult to do, for one thing, and in cross-flow in particular. So you — we’ve made an attempt at looking at the tail of this with – experimentally to start with, and we’ve built test sections with tubes about twice the size of steam generators so that we can look at the detail of what’s happening as the flow goes through the tube bundle. And this was revealing actually. What you find is that the flow tends to create a path between the tube, which you could represent by a series of 60-degree elbows. And you find that the void fraction distribution across that gap — we took 19 measurement points across the gap at every millimeter. And what you find is that the void fraction distribution goes from being high on one tube and low on the other tube, and the next tube is the other way around. So there’s a tremendous mixing taking place in the tube bundle, and if you’re looking at the mixture of the flow, it’s really quite a fine flow. Now, between — now I’m talking about the flow going between the tube, but between — so the — an upstream and downstream tube, if you like. Then there’s a region here of more stagnant flow and more — lower void fraction tends to be mostly liquid. So what’s happening is that the flow on one end is streaming between the tube and the tube bundle, and in between, between upstream and downstream tube, there’s an accumulation of liquid there and some cyclic activities as well, which, again, is something that we were not expecting. We were expecting random turbulence excitation to be quite broad banded, and what we found is that there is some periodicity in this two-phase, flow end tube bundle Well, okay, I divide this thing in two. First of all, you go from the flow and then you calculate the response of the structure. And once you’ve got the response of the structure, then you calculate the wear that will take place the — if the structure responds to that level. Okay? So are two different things here. There is vibration, and there is vibration damage. So this work rate, you can calculate it and estimate it. And the wear damage, the wear volume damage according to our chart, the theory — so the wear volume is really the product of a wear coefficient times a work rate. Okay? The wear coefficient, this you have to obtain experimentally. There is a limited amount, not greatly, because you have to do those tests at high temperature and high pressure –so it means in a pressure vessel. If you 1 do things in a pressure vessel, it gets very costly and very complicated, and to go and try to measure inside those — what you need, you need to measure the contact forces and the sliding distance. We’re talking about measuring microns at 300 degrees C, measuring fraction of newtons at 300 degrees C. You need something like $80,000 worth of transducer just for one such test facility. So — but to answer your question, there is some data available. Some come from the EPRI program, and some have come from Westinghouse, because they have asked us to do that work for them.”

    5.Conclusions: The benchmarking evaluation (Using interpolation of conventional Westinghouse Model 51 and Model F steam generators test results) used by Westinghouse for projecting Unit 2 wear rates (Westinghouse Appendix D, Table 3-2. Wear Projection Results for Active Tubes with Limiting AVB Wear Indications) using Unit 3 tube wear rates does not fit the definition of Deterministic Analysis as claimed by SCE in Attachment 6. The wear rate calculations are based on Westinghouse ATHOS Computer Models, scale up of Model 51/F results and other non-conservative methodology, which are not Deterministic. Westinghouse ATHOS thermal-hydraulic results show that Unit 2 had a gap velocity of 28 feet/sec and void fraction of 99.6%, but did not suffer FEI based on ECT Inspection Results. AREVA’s contact force calculations do not fit the definition of Deterministic Analysis as claimed by SCE in Attachment 6. These OAs are contradicting, confusing, inconclusive, smoking mirrors and full of holes. Trying to help NRC. Please pass it on to the SONGS NRC San Onofre Special Panel. Thanks for posting this blog.

    helpallcqiascnp@yahoo.com

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  233. RE: Tubes in the San Onofre year-old, poorly designed, 65-foot tall, 640-ton steam generator. Actually it was one tube (as far as we know) that started to leak that caused the shutdown because what was leaking was radioactive core coolant which was first only monitored but then the “leak” started increasing in volume so fast that Edison had no choice but to shut the reactor down. Later upon further inspection and testing, not 1 but 8 tubes failed in-situ testing (done in place under controlled conditions) which is something that has NEVER happened before in the history of the entire US Nuclear “fleet”. Even the NRC called that a serious safety concern and they are now, A YEAR LATER, still trying completely understand how that occurred. It is also is important to note that during this same period after Jan. 31, 2012, Unit 2 just happened to be shutdown for refueling and when they inspected it, one of its tubes had 90% wall wear which is well above the 35% safety standard, yet Edison had no idea it was even damaged!

    More on why these tubes are so important here: Nuclear Power Plant Basics https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=0BweZ3c0aFXcFZDZJZWdESWJMYms

    snip:

    Important Note: While each of the steam generator’s 9,700+ tubes is about the size of a penny, each with a wall thickness thinner than a dime (0.043 inches) to help transfer heat, but they also serve as a vitally important boundary between the HOT radioactive coolant circulating inside the tubing which MUST remain separated from the non-radioactive water/steam mixture which circulates outside the tubing. A leak, crack or worse, a complete failure of one or more of any of the tubes inside the steam generator would allow highly radioactive, very hot, pressured coolant to mix directly into the non-radioactive water/steam mixture which would then immediately escape into the environment. Additionally, should a main steam line break (MSLB) or any other similar problems occur, the rapid loss of core coolant that is needed to constantly cool the radioactive fuel rods in the reactor could lead to a catastrophic meltdown of the entire radioactive reactor core.

    More on that here: Nuclear Power Plant Basics

    https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=0BweZ3c0aFXcFZDZJZWdESWJMYms

    captddd@gmail.com

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  234. To help readers learn more about how Steam Generators (SG) can “fail” here is a link to an amazing accurate animation that was done to illustrate San Onofre’s Replacement Steam Generators (RSG) problems (which included MULTIPLE SG tube failures) and the animation even illustrates a Main Steam Line Break (MSLB): http://www.acehoffman.org/sano/SanOnofreRSGsbyAceHoffman.swf
    Note: By scrolling over the animation a large number of additional animations can be viewed!

    At San Onofre, it was one SG tube (as far as we know) that started to leak that caused their shutdown because what was leaking was radioactive core coolant which was first only monitored but then started increasing in volume so fast that Edison had no choice but to shut the reactor down.

    Later upon further inspection and testing, not one but 8 tubes failed in-situ testing (done in place under controlled conditions) which is something that has never happened before in the history of the entire US Nuclear “fleet”. Even the NRC called that a serious safety concern and they are still trying completely understand how that occurred. It is also is import to note that during this same period after Jan. 31, 2012, Unit 2 was also shutdown (for refueling). When they inspected its SG’s, one of its tubes had 90% wall wear which is well above the 35% safety standard and Edison did not even know it!

    More on that here: Nuclear Power Plant Basics https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=0BweZ3c0aFXcFZDZJZWdESWJMYms

    Important Note: The steam generator’s tubing wall thickness is thinner than a dime (0.043 inches) to help transfer heat, but it also serves as a vitally important boundary between the radioactive coolant circulating inside the tubing which must remain separated from the non-radioactive water/steam mixture which circulates outside the tubing. A leak, crack or worse, a complete failure of one or more of any of the tubes inside the steam generator would allow highly radioactive coolant to mix directly into the non-radioactive water/steam mixture which would then escape into the environment. Additionally, should a Main Steam Line Break or other similar problems occur, the rapid loss of core coolant that is needed to constantly cool the radioactive fuel rods in the reactor could lead to a catastrophic meltdown of the entire radioactive reactor core.

    This MSLB event is also mentioned in previous ACRS reports (see our Response to NRR RAI -32 – Technical, page 49). https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=0BweZ3c0aFXcFX05DMWxKNmZXUTA

    captddd@gmail.comCaptD0

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  235. MHI reactor design is dangerous for US Public. Is Not San Onofre Enough. Edison wrote a defective 50.59 evaluation and design specification and MHI designed and built radiation steaming crucibles specified by SCE without thinking, NRC Region IV is siding with SCE and beating MHI is not good, Americans wants to hear the facts and not this Loose Cause of Loose Supports. Now Pete Dietrich is also becoming the $ 2 million/year paid SCE FEI Expert and Media Persons with Safety Sermons without really knowing the details of the plant and design and what Caused Real FEI in Unit 3 and What is Conservative FEI In Unit 2. By protecting his henchman, he will be out of job like Ross Ridenoure, Ted Kramer has limits of putting with Inept Managers, Pete, Enjoy while you can, or fire the henchman and look for the true cause, This will help NRC Region IV. It is never too late to admit and correct the mistakes. Ted, NRC and Public will be happy if you spilled SCE Mistakes and Did NOT Preach Safety Sermons. Pete, you have zero credibility with the public. Please Keep NRC Out of the SCE Guilt Games, NRC have other plants to attend to. Ted Kramer is not impressed with your actions

    helpallcqiascnp@yahoo.com

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  236. San Onofre Unit 2 Steam Generators are not Safe at any Power and do not meet the NRC Licensed Conditions for Operation to RTP and Design Basis Accident Conditions. SCE and NRC are just playing Cat and Mouse Games and wasting Ratepayers/Taxpayers money, time and causing unneeded anxieties and worries for Public, Politicians, Workers, Labor Unions, Contractors, Ted Craver and Michael Peevey. If SCE wants to produce safe, dependable and profitable power, they should return $1 Billion to Rate Payers and pay another 1 Billion Dollars to Westinghouse (The Most Advanced, Sophisticated, Skilled and Dependable US Nuclear Plant Designer & Manufacturer) to remove the defective generators and build new replacement generators like Palo Verde Nuclear Generating Station. MHI, AREVA & SCE cannot fix these Sick Fukushima Radiation Steaming Crucibles.

    helpallcqiascnp@yahoo.com

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  237. Special Public Education Series – San Onofre Dangerous Steam Generators
    Thanks To DAB Safety Team and NRC Moderat
    NUCLEAR INDUSTRY LESSONS LEARNT: People need safe, reliable, economical, well managed and well-maintained nuclear power plants and safety-conscious work environment. Nuclear Power plants workers should be free of retaliation (For expressing nuclear safety concerns), discrimination, harassment, intimidation, favoritism and should come to work happy and go back home safe and happy. This is America and NOT North Korean, Cuba, China or Iran?>

    USNRC Briefing on Palo Verde Nuclear Generating Station – Some Great Lessons Learned – A Must Read
    One of the big questions asked, “How does a management team that was responsible for taking Palo Verde to one of the highest nuclear performance levels in the country and sustaining it for a decade allow it to fall into Column 4 (Lowest NRC Rating for a Nuclear Power Plant, That is where San Onofre should be Today, but they are in NRC Column1 (highest Performance?”
    The following is the Palo Verde Management’s perspective of historical performance:
    Our high plant performance combined with high performance assessments, although positive at the time, contributed to complacency and an environment that camouflaged our growing weakness in personal
    One of the big questions asked, “How does a management team that was responsible for taking Palo Verde to one of the highest nuclear performance levels in the country and sustaining it for a decade allow it to fall into Column 4?”
    The following is the Palo Verde Management’s perspective of historical performance: accountability
    and a higher tolerance for incomplete root cause analysis; encouraged an attitude of pride, reduced our focus on continuous improvement and established a mind set that we were good enough to handle all issues as they occurred.
    Next, we relied too heavily on historical and lagging performance indicators. We were not as attentive as we should have been to qualitative factors and non-metric supported indications. These more subtle qualitative signals were not given the weight we give to our numerical metrics and as with the other things I’ll describe today show we were too focused on the past.
    When our workload increased, we got defensive. But our historically high production over an extended period, we have become unfamiliar with high levels of emergent work. As a result, our bench strength was overestimated and we did not perform to our own standards.
    We rationalized that we were too good for low performance and our outages were not symptomatic of larger issues. Accountability declined in part due to this rationalization.
    This was compounded by our high reliance on teams. Previous assessment reports had heralded our strong team structure while identifying the risks of over reliance. Encouraged by our performance, we under-appreciated the warning.
    With higher workloads and declining personal accountability, dysfunctional teams developed and our ability to realign them was not timely and more difficult than we had expected.
    Turnover rates in our work force have always been low. Seen as positive, we did not fully appreciate the familiarity affect this had on individuals who became reluctant to challenge or criticize their friends. We became overly dependent on each other versus strengthening the process and when combined with group oriented performance awards, individual accountability declined.
    Also, for the first time, the attitude changes that come with thinking about retirement became a factor. We had studied and built plans to deal with the number of retirements, but we underappreciated the personal effects on individuals who are not yet retiring, but starting to focus for the first time on their future personal retirement plan instead of solely on a plant business plan and their participation in it.
    This environment also produced an internal, not an external, industry oriented perspective. People came to see us. We were the example. Industry visits were rationalized to our performance instead of being used to learn from others. We had not kept up with the advancements in the industry.
    Finally, and probably the most importantly, our communication models had evolved over time and did not cover the information we needed to hear. We had institutionalized our communications and narrowed them to a point where we spent too much time on historical performance data. This was not intentional, but we let single points of communication develop which reduced our ability to see many of the things I’ve outlined today.
    Additionally, our oversight structure was not organized correctly and when combined with our medium of communication, cultural issues were not fully appreciated.
    Obviously, these are just some of the lessons we’ve learned; however, they are the major cultural factors which contributed to our leadership’s inability to identify and correct our decline in performance. We have relearned the very important fact that high nuclear performance is more a function of people than technology.

    helpallcqiascnp@yahoo.com
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  238. Special Public Awareness Series – San Onofre Nuclear Generating Station (SONGS)
    COURTSEY OF DAB SAFETY TEAM….Thanks to NRC for Posting This Blog
    Thanks… HelpAllHurtNeverBaba
    helpallcqiascnp@yahoo.com
    Media Alert 13-01-28
    Allegation – NRC AIT Report Incomplete, Inconclusive, Inconsistent and Unacceptable
    Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261
    SONGS UNIT 3 RSG REAL ROOT CAUSE: Lack of “Critical Questioning & Investigative Attitude” by SCE, MHI and NRC Region IV and AIT Team.

    The DAB Safety Team has transmitted the following Allegation to “Office of the Chairman of the NRC” and “The United States Senate Committee on Environment and Public Work.”

    It is the DAB Safety Team’s goal to help educate both the NRC and the Public by providing unbiased, logical and factual information in order to help assess the real dangers of any San Onofre Unit 2 restart. According to Press Reports and San Onofre Insiders, Unit 2 permission for restart by the NRC is imminent yet the REAL Root Cause for the $1 Billion destruction of Units 2 and 3 RSGs (Including equipment cost and expenses) has not yet even been determined. The Public does not know the status of SCE’s ongoing cause evaluations, SCE’s response to 32 NRR’s RAI’s and NRC’s Special San Onofre Inspections. We like to remind NRC San Onofre Special Panel, what NRC Chairman Macfarlane said during her recent Fukushima Trip, “Regulators may need to be ‘buffered’ from political winds, but they need to be fully subjected to the pressure of scientific and engineering truth and cannot be allowed to make decisions or order actions that are ‘independent’ of facts.” The NRC rush to a faulty judgment cannot be allowed to compromise Public Safety just to please SCE, as this conflicts with President Obama’s Policy, the new NRC Chairman’s Standards and the advice of NRC retired Branch Chiefs who have also spoken out.

    A NRC Branch Chief gifted with MIT Intelligence, Intuition and a Sixth Sense, told an anonymous participant at an Industry Conference, “Sir, to resolve any complex technical problem and understand unclear regulations, you have to, ‘Read and reread in between the lines’, use, ‘Critical questioning and an investigative attitude’ and ‘Solid teamwork & alignment.”

    SONGS UNIT 3 RSG ROOT CAUSE: It appears that Complacent SCE and Inexperienced MHI Engineers did not perform proper academic research and industry bench marking about the potential adverse consequences of the reduction of original CE steam generator pressures from 900 psi to say, 800 psi on fluid elastic instability and flow-induced vibrations. These lower secondary steam operating pressure (800-833 psia) are the primary cause for shortening the life of SONGS Original Combustion Engineering Generators due to increased tube wear and plugging caused by flow-induced random vibrations and destruction of SONGS Unit 3 Replacement Steam Generators due to flow-induced random vibrations, Mitsubishi flowering effects and steam voids or steam dry-outs (AKA fluid elastic instability). In addition, SCE Engineers prepared defective 10 CFR 50.59 Evaluation and design specifications, which were not challenged by MHI, and adequately reviewed by NRC Region IV. MHI at the direction of SCE Engineers made numerous untested and unanalyzed design changes to the steam generators under the pretense of “like for like”, and Elmo Collins said, “The guts of the machinery look …. Different.”

    Therefore the SONGS UNIT 3 RSG REAL ROOT CAUSE: Lack of “Critical Questioning & Investigative Attitude” by SCE, MHI and NRC Region IV and AIT Team.

    • Lessons Learnt: MHI, AIT, DAB Safety Team together with other World Nuclear and SG Experts / Manufacturers agree that, “Lower secondary steam operating pressures (800-833 psi) are severe and can easily cause SG flow-induced random vibrations and fluid elastic instability.” At lower secondary steam operating pressures (800-833 psi), the utility can generate more thermal megawatts out of the SG and hence add more power to the grid and thereby make more money for SCE/EIX Officers and shareholders. These lower secondary steam operating pressures (800-833 psi) were the primary cause for shortening the life of SONGS Original Combustion Engineering Steam Generators. The real lesson learnt is that ALL parties must follow the NRC Chairman’s advice, pay attention to their work and always ensure that public safety is THE overriding obligation for the regulators, licensee, its vendors and contractors. NRC “Reasonable Assurance” for the protection of adequate health and safety of the public from postulated radiological accidents cannot be compromised at any time during the design, operation, fabrication, testing, surveillance, maintenance and inspection of a nuclear power plant. SCE and its offsite response organizations need to demonstrate; (1) Feasibility of an Operator Action during a postulated main steam line break with multiple Unit 2 steam generator tube ruptures, (2) They can effectively implement emergency plans and procedures with zero Drills/Exercise Performance indicator failures during a Fully Staffed NRC/FEMA evaluated exercise prior to any Unit 2 Restart.

    • Comments about the NRC Augmented Inspection Team San Onofre Report
    NOTE: We highly recommend that NRC Augmented Inspection Team and NRC San Onofre Special Review Panel thoroughly review SONGS Unit 2 Return to Service MHI, AREVA, Westinghouse, DAB Safety Team and John Large Reports, then carefully examine the operational differences between Unit 2 and 3 and then update the NRC AIT report with a FACTUAL Root cause for FEI in Unit 3 and NO FEI in Unit 2. NRC San Onofre Special Review Panel also needs to review the SONGS Unit 2 Restart Reports (done by SCE, Westinghouse, AREVA and MHI), SCE Unit 3 Root Cause Evaluation, NRC AIT Report, ATHOS Modeling Results and Unit 2 Operational Data and then arrive: (1) At a unanimous, clear and concise conclusion whether FEI occurred in Unit 2 or not, and (2) Provide a GAP ANALYSIS (The scientific, technical and engineering reasons why all these reports are so different) prior the February 12, 2013 NRC Public Meeting.
    The AIT inspection concluded that: (1) SCE was adequately pursuing the causes of the unexpected steam generator tube-to-tube degradation. In an effort to identify the causes, SCE retained a significant number of outside industry experts, consultants, and steam generator manufacturers, including Westinghouse and AREVA to perform thermal-hydraulic and flow induced vibration modeling and analysis; (2) The combination of unpredicted, adverse thermal hydraulic conditions and insufficient contact forces in the upper tube bundle caused a phenomenon called “fluid-elastic instability” which was a significant contributor to the tube to tube wear resulting in the tube leak. The team concluded that the differences in severity of the tube-to-tube wear between Unit 2 and Unit 3 may be related to changes to the manufacturing/fabrication of the tubes and other components which may have resulted in increased clearances between the anti-vibration bars and the tubes; (3) Due to modeling errors, the replacement generators were not designed with adequate thermal hydraulic margin to preclude the onset of fluid-elastic instability. Unless changes are made to the operation or configuration of the steam generators, high fluid velocities and high void fractions in localized regions in the u-bend will continue to cause excessive and accelerated tube wear that could result in tube leakage and/or tube rupture; (4) The thermal hydraulic phenomena contributing to the fluid-elastic instability is present in both Unit 2 and 3 steam generators; (5) Based on the updated final safety analysis report description of the original steam generators, the steam generators’ major design changes were appropriately reviewed in accordance with the 10 CFR 50.59 requirements.
    So based on a review of the AIT Report and World’s Experts, the three potential causes, which were significant contributors to the “fluid-elastic instability” in SONGS Unit 3 and the tube-to-tube wear resulting in the tube leak are as follows:
    A. Insufficient contact tube-to AVB forces and differences in manufacturing or fabrication of the tubes and other components between Units 2 & 3
    B. Due to modeling errors, the SONGS replacement generators were not designed with adequate thermal hydraulic margin to preclude the onset of fluid-elastic instability.
    C. Differences between Unit 2 and Unit 3’s Operational Factors
    A. Let us now examine that whether insufficient contact tube-to AVB forces in the Unit 3 upper tube bundle caused “fluid-elastic instability” which was a significant contributor to the tube-to-tube wear resulting in the tube leak.
    A.1- MHI states, “By design, U-bend support in the in-plane direction was not provided for the SONGS SG’s”. In the design stage, MHI considered that the tube U-bend support in the out-of-plane direction designed for “zero” tube-to-AVB gap in hot condition was sufficient to prevent the tube from becoming fluid-elastic unstable during operation based on the MHI experiences and contemporary practice. MHI postulated that a “zero” gap in the hot condition does not necessarily ensure that the support is active and that contact force between the tube and the AVB is required for the support to be considered active. The most likely cause of the observed tube-to-tube wear is multiple consecutive AVB supports becoming inactive during operation. This is attributed to redistribution of the tube-to-AVB-gaps under the fluid hydrodynamic pressure exerted on the tubes during operation. This phenomenon is called by MHI, “tube bundle flowering” and is postulated to result in a spreading of the tube U-bends in the out-of-plane direction to varying degrees based on their location in the tube bundle (the hydrodynamic pressure varies within the U bend). This tube U-bend spreading causes an increase of the tube-to-AVB gap sizes and decrease of tube-to-AVB contact forces rendering the AVB supports inactive and potentially significantly contributing to tube FEI. Observations Common to BOTH Unit-2 and Unit-3: The AVBs, end caps, and retainer bars were manufactured according to the design. It was confirmed that there were no significant gaps between the AVBs and tubes, which might have contributed to excessive tube vibration because the AVBs appear to be virtually in contact with tubes. MHI states, “The higher than typical void fraction is a result of a very large and tightly packed tube bundle, particularly in the U-bend, with high heat flux in the hot leg side. Because this high void fraction is a potentially major cause of the tube FEI, and consequently unexpected tube wear (as it affects both the flow velocity and the damping factors) the correlation between the void fraction (steam quality) and the number of
    tubes with wear in a given void fraction region was investigated. From this investigation, a
    strong correlation between the void fraction (steam quality) and the percentage of tubes with
    the Type 1 (tube-to-tube) and Type 2 (tube-to-AVB) wear was identified. The correlation between flow velocity and the number of tubes with wear was also investigated. The results show that when the flow velocity is high, the percentage of tubes with wear increases, even though this correlation is not as strong as that between the void fraction (steam quality) and the percentage of tubes with wear.”
    A.2 – AREVA states, “At 100% power, the thermal-hydraulic conditions in the U-bend region of the SONGS replacement steam generators exceeded the past successful operational envelope for U-bend nuclear steam generators based on presently available data. The primary source of tube-to-AVB contact forces is the restraint provided by the retaining bars and bridges, reacting against the component dimensional dispersion of the tubes and AVBs. Contact forces are available for both cold and hot conditions. Contact forces significantly increase at normal operating temperature and pressure due to diametric expansion of the tubes and thermal growth of the AVBs. After fluid elastic instability develops, the amplitude of in-plane motion continuously increases and the forces needed to prevent in-plane motion at any given AVB location become relatively large. Hence shortly after instability occurs, U-bends begin to swing in Mode 1 and overcome hindrance at any AVB location.”
    A.3 – Westinghouse states, “Test data shows that the onset of in-plane (IP) vibration requires much higher velocities than the onset of out-of-plane (OP) fluid-elastic excitation. Hence, a tube that may vibrate in-plane (IP) would definitely be unstable OP. A small AVB gap that would be considered active in the OP mode would also be active in the IP mode because the small gap will prevent significant in-plane motion due to lack of clearance (gap) for the combined OP and IP motions. Thus, a contact force is not required to prevent significant IP motion. Manufacturing Considerations: There are several potential manufacturing considerations associated with review of the design drawings based on Westinghouse experience. The first two are related to increased proximity potential that is likely associated with the ECT evidence for proximity. Two others are associated with the AVB configuration and the additional orthogonal support structure that can interact with the first two during manufacturing. Another relates to AVB fabrication tolerances. These potential issues include: (1) The smaller nominal in-plane spacing between large radius U-bend tubes than comparable Westinghouse experience, (2) The much larger relative shrinkage of two sides (cold leg and hot leg) of each tube that can occur within the tubesheet drilling tolerances. Differences in axial shrinkage of tube legs can change the shape of the U-bends and reduce in-plane clearances between tubes from what was installed prior to hydraulic expansion, (3) The potential for the ends of the lateral sets of AVBs (designated as side narrow and side wide on the Design Anti-Vibration Bar Assembly Drawing that are attached to the AVB support structure on the sides of the tube bundle to become displaced from their intended positions during lower shell assembly rotation, (4) The potential for the 13 orthogonal bridge structure segments that are welded to the ends of AVB end cap extensions to produce reactions inside the bundle due to weld shrinkage and added weight during bundle rotation, and (5) Control of AVB fabrication tolerances sufficient to avoid undesirable interactions within the bundle. If AVBs are not flat with no twist in the unrestrained state they can tend to spread tube columns and introduce unexpected gaps greater than nominal inside the bundle away from the fixed weld spacing. The weight of the additional support structure after installation could accentuate any of the above potential issues. There is insufficient evidence to conclude that any of the listed potential issues are directly responsible for the unexpected tube wear, but these issues could all lead to unexpected tube/AVB fit-up conditions that would support the amplitude limited fluid-elastic vibration mechanism. None were extensively treated in the SCE root cause evaluation.”
    A.4 – John Large, Internationally Known Scientist and Chartered Nuclear Engineer from London says about the SONGS Unit 2 Replacement Steam Generators (RSGs) AVB Structure, “It impossible to reliably predict the effectiveness of the many thousands of AVB contact points for when the tube bundle is in a hot, pressurized operational state. The combination of the omission of the in-plane AVB restraints, the unique in-plane activity levels of the SONGS RSGs, together the very demanding interpretation of the remote probe data from the cold and depressurized tube inspection, render forecasting the wear of the tubes and many thousands of restraint components when in hot and pressurized service very challenging indeed. Phasing of AVB-TSP Wear -v- TTW: I reason that, overall, the tube wear process comprises two distinct phases: First, the AVB (and TSP) -to-tube contact points wear with the result that whatever level of effectiveness is in play declines. Then, with the U-bend free-span sections increased by loss of intermediate AVB restraint(s), the individual tubes in the U-bend region are rendered very susceptible to FEI induced motion and TTW. Whereas the OAs commissioned by SCE broadly agree that the wear mechanics comprises two phases, there are strong differences over the cause of the first phase comprising in-plane AVB wear: AREVA claim this is caused by in-plane FEI whereas, the contrary, Mitsubishi (and Westinghouse) favor random perturbations in the fluid flow regime to be the tube motion excitation cause. Put simply: i) if AREVA is correct then reducing the reactor power to 70% will eliminate FEI, AVB effectiveness will cease to decline further and TTW will be arrested; however, to the contrary, ii) if Mitsubishi is right then, even at the 70% power level, the AVB restraint effectiveness will continue to decline thereby freeing up longer free-span tube sections that are more susceptible to TTW; or that iii) the assertion of neither party is wholly or partly correct. I find that the AVB assembly, which features strongly in the onset of TTW, is clearly designed to cope only with out-of-plane tube motion since there is little designed-in resistance to movement in the in-plane direction – because of this, it is just chance (a virtually random combination of manufacturing variations, expansion andpressurization, etc) that determines the in-plane effectiveness of the AVBs.”
    A.5 – SCE claims, “The facts identified in this analysis indicate that even though the Unit 3 tube bundle components (tubes and AVBs) might have been fabricated and assembled better, the tube “to” AVB gaps built gaps might have been in fact larger in the Unit 3 RSGs as suggested by the ECT results. Based on this, it cannot be ruled out that the tube-to-AVB gaps are larger and more uniform in the Unit 3 RSGs than the Unit 2 RSG’s. This might have resulted in reduction of the tube-to-AVB contact force and consequently in multiple consecutive AVB supports being inactive. Inactive tube support might have resulted in “tube-to-tube” wear.
    A.6 – DAB Safety Team Conclusions: SONGS Unit 3 RSG’s were operating outside SONGS Technical Specification Limits for Reactor Thermal Power and Current Licensing Basis for Design Basis Accident Conditions. Let us summarize what these experts are saying: (1) AREVA is saying, “After fluid elastic instability develops, the amplitude of in-plane motion continuously increases and the forces needed to prevent in-plane motion at any given AVB location become relatively large. Hence shortly after instability occurs, U-bends begin to swing in Mode 1 and overcome hindrance at any AVB location”, (2) Westinghouse is saying, “A small AVB gap that would be considered active in the OP mode would also be active in the IP mode because the small gap will prevent significant in-plane motion due to lack of clearance (gap) for the combined OP and IP motions. Thus, a contact force is not required to prevent significant IP motion”, (3) MHI is saying, “High steam flows and cross-flow velocities combined with narrow tube pitch-to-diameter ratio caused elastic deformation of the U-tube bundle from the beginning of the Unit 3 cycle, which initiated the process of tube-to-AVB wear and insufficient contact forces between tubes and AVBs. Tube bundle distortion is considered a major contributing cause to the mechanism of tube-to-tube/AVB/TSP wear seen in the Unit 3 SG’s. After 11 months of wear, contact forces were virtually eliminated between the tube and AVBs in the areas of highest wear of Unit 3 tubes as confirmed by ECT and visual inspections. According to MHI Technical Document, the RSG Anti-bar Vibration Structures were only designed for out-of plane vibrations and not in-plane vibrations”, (4) John Large is saying, “Its impossible to reliably predict the effectiveness of the many thousands of AVB contact points for when the tube bundle is in a hot, pressurized operational state.” In essence, all the three NEI qualified, “U.S. Nuclear Plant Designers” are saying: (a) Firstly, these AVB structures are not designed to prevent in-plane vibrations, (b) Secondly, once fluid elastic instability develops, the AVB is not strong enough to prevent large in-plane amplitude of tubes, (c) Thirdly, excessive fluid-induced random vibrations and fluid hydrodynamic pressures (Mitsubishi Flowering Effect) cause the loss of tube-AVB contact forces and increase the tube-to-AVB gaps and the onset of fluid elastic instability develops, and (d) Lastly, tube-to-AVB gaps and contact forces are irrelevant to prevent fluid elastic instability from progressing and causing tube-to-tube and tube-to-AVB wear. Therefore, based on a review of MHI, AREVA and Westinghouse excerpts shown above, it is concluded, that FEI, flow-induced random vibrations and MHI Flowering effect redistributed the tube-to-AVB gaps in Unit 3 RSG’s as measured by SCE. Westinghouse even goes this far to state, “None of the MHI manufacturing issues were extensively treated in the SCE root cause evaluation.” Hence, It is concluded that the NRC and SCE claims that insufficient contact forces in Unit 3 Tube-to-AVB Gaps ALONE caused tube “to” tube wear are misleading, erroneous and designed to put the blame on MHI for purposes of making SCE look good in the public’s eyes and for collecting insurance money from MHI’s so-called “manufacturing defects”.
    B. Let us now examine the effects of modeling errors, that the SONGS replacement generators were not designed with adequate thermal hydraulic margin to preclude the onset of fluid-elastic instability.
    B.1 – NRC AIT Report states, “The ATHOS thermal-hydraulic model predicts bulk fluid behavior based on first principals and empirical correlations and as a result, it is not able to evaluate mechanical, fabrication, or structural material differences or other phenomena that may be unique to each steam generator. Therefore this analysis cannot account for these mechanical factors and differences which could very likely also be contributing to the tube degradation.”
    B.2 – Ivan Cotton states, “Fluid elastic instability is one of the most damaging types of instabilities encountered in heat exchangers and steam generators and can impose a severe economic penalty on the power and chemical industries. At present our understanding of the mechanisms leading to fluid-elastic instability is very limited and more experiments are needed to more fully delineate the conditions for the onset of fluid-elastic instability.” Such experimentation should only be done in a sealed lab, NOT our environment with the lives of eight million local residents at stake in the outcome!
    B.3 – Ishihara, Kunihiko and Kitayama state, “Tube vibrations become large as tube thickness/diameter ratio (T/D) increases and tube length/diameter ratio (L/D) decreases, and the tube vibrations strongly depend on the dynamic characteristics of tubes such as the natural frequency and the damping ability.” In the case of SanO’s replacement SGs, the tubes, especially in the U-bend region, were too close together, poorly restrained, poorly damped, along with too much heat flux and an inappropriate pressure-to-flow ratio, along with other causes which resulted in FEI and FIV.
    B.4 – Fairewind states, “Realistically, the 3-D steam analysis is not accurate enough to apply to such important safety related determinations. To make such mathematical risk 3-D analysis, a very large margin of error must be applied, and that has not been done. For example, if the 3-D steam analysis determines that plugging 100 tubes is a solution, then plugging ten times that number might be the appropriate solution due to the mathematical errors in the 3-D analysis being applied by Edison and Mitsubishi. Edison has taken many of its mathematical/computer models as “gospel” rather than accepting their wide margins of error, which directly affect safety, which is precisely what got them in trouble in the first place. It should have been obvious to Edison that MHI FIT-III has not been benchmarked, and had not been previously used in licensing procedures showing that the use of FIT-III might have an adverse effect on the FSAR safety analysis thus necessitating the entire license amendment review and public hearing process. As noted by the AIT, Edison approved the use of FIT-III code even though the code was not benchmarked, nor identified as acceptable in the FSAR. Consequently, Edison operated San Onofre without knowing the uncertainties in the Replacement Steam Generators’ performance characteristics. Predicted liquid levels, pressure drops, vibrations, and temperatures at both Units 2 and 3 were all subject to unknown uncertainties during both normal and abnormal operations. In my opinion, by approving the use of an un-benchmarked and untested design tool like FIT-III, Edison did not did not meet the requirements expected from a nuclear licensee.
    Use of an un-benchmarked computer code that is not included in the FSAR protocol demands a formal FSAR license amendment process including the requisite public hearings.”

    B.5 – Mitra, V.K. Dhir, I. Catton state, “Flow induced vibrations in heat exchanger tubes have led to numerous accidents and economic losses in the past. Efforts have been made to systematically study the cause of these vibrations and develop remedial design criteria for their avoidance. Instability was clearly seen in single phase and two-phase flow and the critical flow velocity was found to be proportional to tube mass. It is also found that nucleate boiling on the tube surface is also found to have a stabilizing effect on fluid-elastic instability.”

    B.6 – John Large, says “Factual Issues v) & vi) – SONGS SG Comparison to Other Operating SGs: I identify a number of issues with the representation of Figures 4-3 and 5-1 of the AREVA Tube-to-Tube Report, including: i) it is not exactly clear which properties are being represented on the spider diagram for comparison with the other operational SGs; even so ii) since it is most unlikely that AREVA has undertaken a comprehensive (ATHOS) simulation of each of the five nominated SGs, the comparisons drawn are likely to be between aggregate or bulk flows within the entire tube bundle of each SG; iii) as acknowledged by AREVA, the SONGS RSGs are dominated by in-plane flow regimes whereas all other SGs are characterized by out-of-plane flow regimes; and iv) none of the comparative SGs has been identified. In other words, unless the spider diagrams of Figure 4-3 and 5-1 somehow, and I cannot reason how, are making a direct comparison of the complex two-phase fluid cross-flow situation in the SONGS and other five comparative plant steam generators, then these figures only provide the bases of a somewhat meaningless comparisons.”
    B.7 – SCE states that SONGS Unit 3 Damage (FEI) was caused due to outdated MHI Thermal-Hydraulic Computer Models. According to NRC AIT Report, SONGS did not specify the value of FEI in its Design and Performance Specifications SO23-617-1. Academic Researchers have discussed and warned about the adverse effects of fluid elastic instability (tube-to-tube wear) in nuclear steam generators since the 1970’s. Westinghouse and Combustion Engineering (CE) have designed CE replacement steam generators (RSGs) to prevent the adverse effects of fluid elastic instability since 2000’s (e.g., PVNGS).
    B.8 – The NRC AIT Report dated November 9, 2012 states, “the FIT-III thermal-hydraulic model was still in-progress at the time of the inspection and no final conclusions were reached for the cause of the non-conservative flow velocities, which were used as inputs in the tube vibration analysis and resulted in non-conservative stability ratios. Since the licensee had not completed the cause evaluation for this unresolved item, the inspectors were not able to make a final determination of whether a performance deficiency or violation of NRC requirements occurred. The inspectors were informed that Mitsubishi was performing an evaluation of the potential factors that contributed to the low flow velocities in FIT-III relative to the velocities calculated by the ATHOS model developed after the tube leak event in Unit 3. This evaluation was included in Document SO23-617-1-M1530, Revision 1, which also intended to demonstrate the validity of FIT-III results for the original tube vibration analysis. This evaluation was still being finalized and not yet approved by Edison. The licensee and Mitsubishi continued to evaluate this unresolved item and no final conclusions were reached at the time of the inspection. The NRC is continuing to perform independent reviews of existing information, and will conduct additional reviews as new information becomes available.” In another related finding, NRC inspectors stated, “SCE Engineers did not meet Procedure SO123-XXIV-37.8.26 requirements to ensure the design of the retainer bar was adequate with respect to the certified design specification. Specifically, the licensee failed to ensure that there was sufficient analytical effort in the design methodology of the anti-vibration bar assembly to support the conclusion that tube wear would not occur, as a result of contact with the retainer bars due to flow-induced vibration. The inspectors determined that the requirements for flow-induced vibration in the certified design specification, along with the expectations in Procedure SO123-XXIV-37.8.26, provided sufficient information to reasonably foresee the inadequate design of the retainer bars during the review and approval of design Calculations SO23-617-1-C749 and SO23-617-1-C157, including the associated design drawings provided by Mitsubishi.”
    B.9 – Arnie Gundersen states, “Not only is Mitsubishi unfamiliar with the tightly packed CE design, but Edison’s engineers added so many untested variables to the new fabrication that this new design had a significantly increased risk of failure. As a result of the very tight pitch to diameter ratios used in the original CE steam generators, Mitsubishi fabricated a broached plate design that allows almost no water to reach the top of the steam generator.
The maximum quality of the water/steam mixture at the top of the steam generator in the U-Bend region should be approximately 40 to 50 percent, i.e. half water and half steam. With the Mitsubishi design the top of the U-tubes are almost dry in some regions. Without liquid in the mixture, there is no damping against vibration, and therefore a severe fluid-elastic instability developed.

Because of the Edison/Mitsubishi steam generator changes, the top of the new steam generator is starved for water therefore making tube vibration inevitable. Furthermore, the problem appears to be exacerbated by Mitsubishi’s three-dimensional thermal-hydraulic analysis determining how the steam and water mix at the top of the tubes that has been benchmarked against the Westinghouse design but not the original CE design.

The real problem in the replacement steam generators at San Onofre is that too much steam and too little water is causing the tubes to vibrate violently in the U-bend region. The tubes are quickly wearing themselves thin enough to completely fail pressure testing. Even if the new tubes are actively not leaking or have not ruptured, the tubes in the Mitsubishi fabrication are at risk of bursting in a main steam line accident scenario and spewing radiation into the air.”
    B.10 – Comment on Limitations of ATHOS thermal-hydraulic Models: The ATHOS thermal-hydraulic model predicts bulk fluid behavior based on first principals and empirical correlations and as a result, it is not able to evaluate mechanical, fabrication, or structural material differences or other phenomena that may be unique to each steam generator. Furthermore, the combination of the omission of the in-plane AVB restraints, the unique in-plane activity levels of the SONGS RSGs, together with the very demanding interpretation of the remote probe data from the cold and depressurized tube inspection, render forecasting the wear of the tubes and many thousands of restraint components when in hot and pressurized service very challenging indeed. ATHOS thermal-hydraulic Models used for 70% power have not been benchmarked, and tested against SONGS Unit 2 RSG degraded tube bundles performance for several cycles of depressurized/pressurized operation. Hence, ATHOS analyses cannot accurately predict the behavior of pressurized degraded SG tube bundles and their interaction with their anti-vibration bar support structure, which could very likely contribute to unknown amounts of tube-to-tube wear and/or AVB degradation in Unit 2, at 70% or 100% power during a main steam line break accident resulting in a cascade of multiple steam generator tube ruptures.
    B.11 – Conclusions on Modeling Errors: The NRC AIT Report dated November 9, 2012 states, “the FIT-III thermal-hydraulic model was still in-progress at the time of the inspection and no final conclusions were reached for the cause of the non-conservative flow velocities, which were used as inputs in the tube vibration analysis and resulted in non-conservative stability ratios. Since the licensee had not completed the cause evaluation for this unresolved item, the inspectors were not able to make a final determination of whether a performance deficiency or violation of NRC requirements occurred. SCE and MHI are both negligent because they did a very poor job of Industry and Academic Research benchmarking regarding the applicability of thermal-hydraulic computer models during the redesign of San Onofre’s original CE SGs. SCE is negligent because they did not check the results of MHI’s outdated Thermal-Hydraulic Computer Models to meet their specification and procedure requirements. This does not meet the NRC Chairman’s Standards. Therefore, it is concluded that SCE claims as stated above are not factual. SCE engineers did not check the work of MHI with a critical and questioning attitude and did not meet the San Onofre Design Procedures, 10CFR50, Appendix B, Quality assurance Standards and or NRC Regulations. NRC AIT Team jumped the boat by putting all the blame on MHI in July 2012 and now they are retreating in November 2012 by stating with a sunken face, “The inspectors were not able to make a final determination of whether a performance deficiency or violation of NRC requirements occurred.”

    C. Let us now examine the other differences between Unit 2 and Unit 3’s Operational Factors, which were significant contributors to the “fluid-elastic instability” in San Onofre Unit 3 and the tube-to-tube wear resulting in the tube leak.
    C.1 – Adverse Design/Operational Factors responsible for Fluid Elastic Instability: Low steam generator pressures (SONGS RSGs range 800-850 psi, the primary cause of the onset of severe vibrations) allow the onset of FEI, whereby U-tube bundle tubes start vibrating with very large amplitudes in the in-plane directions. Extremely hot and vibrating tubes need a little amount of water (aka damping, 1.5% water, steam-water mixture vapor Fraction 99.5%). Without the water, the extremely hot and vibrating tubes cannot dissipate their energy. In effect, one unstable tube drives its neighbor to instability through repeated violent impact events which causes tube leakage, tube failures at MSLB test conditions and/or unprecedented tube-tube wear, Tube-to-AVB/Tube Support Plates wear, as we saw in San Onofre Unit 3. So in review, due to narrow tube pitch to tube diameter, tube natural frequency, low tube clearances, in certain portions of the RSGs U-tubes bundle, fluid velocities exceed the critical velocities due to extremely high steam flows (100% power conditions). These high fluid velocities cause U-tubes to vibrate with very large amplitudes in the in-plane direction and literally hit other tubes with repeated and violent impacts. Due to lower secondary steam operating pressures (required to generate more heat, electricity and profits) and excessive pressure drops due to high flows and velocities, steam saturation temperature drops. This lowering of steam saturation temperature combined with high heat flux in the hot leg side of the U-tube bundle causes steam dry-outs to form (Vapor fraction >99%), known as “NO Effective Thin Tube Film Damping.” Thin film damping refers to the tendency of the steam inside the generators to create a thin film of water between the RSG tubes and the support structures and each other. That film is enough to help keep the tubes from vibrating with large amplitudes, hitting other tubes violently, and to protect the Anti-Vibration Bar support structures and maintain the tube-to-AVB gaps and contact forces. These adverse conditions in Unit 2 at 70% power operation (RTP) with the present defective design and degraded RSGs, known as fluid elastic instability (Tube-to-Tube Wear, or TTW) can lead to rapid U-tube failure from fatigue or tube-to-tube wear in Unit 2 due to a main steam line break as seen in Unit 3’s RSG’s. In summary, FEI is a phenomenon where due to San Onofre RSGs design intended for high steam flows causes the tubes to vibrate with increasingly larger amplitudes due to the fluid effective flow velocity exceeding its specific limit (critical velocity) for a given tube and its supporting conditions and a given thermal hydraulic environment. This occurs when the amount of energy imparted on the tube by the fluid is greater than the amount of energy that the tube can dissipate back to the fluid and to the supports. The lack of Nucleate boiling on the tube surface or absence of water is found to have a destabilizing effect on fluid-elastic stability.
    C.2 – Unit 2 FEI Conflicting Operational Data
    • NRC AIT Report SG Secondary U2/3 Pressure Range 833 – 942 psi
    • SCE RCE SG Secondary U2/3 Pressure – 833 psi
    • RCE Team Anonymous Member – Unit 2 SG Secondary Pressure 863 psi
    • SONGS SG System Description Unit 2 SG Pressure Range 892 – 942 psi
    • Westinghouse OA SG Secondary U2/3 Pressure ~ 838 psi, Void Fraction 99.55%
    • SCE Enclosure 2, MHI ATHOS results – U2/3 Void Fraction 99.6%
    • SCE Enclosure 2, Independent Expert results – ATHOS U2/3 Void Fraction 99.4%
    • DAB Safety Team SG Secondary U2 Pressure 863 -942 psi, Void Fraction 96-98%
    • SONGS Plant Daily Briefing Unit 3 Electrical Generation – 1186 MWe
    • SONGS Plant Daily Briefing Unit 2 Electrical Generation – 1183 MWe

    C.3 – Unit 2 FEI Conclusions
    C.3.1 – NRC AIT Report – Operational Differences between U2/3 – The result of the independent NRC thermal-hydraulic analysis indicated that differences in the actual operation between units and/or individual steam generators had an insignificant impact on the results and in fact, the team did not identify any changes in steam velocities or void fractions that could attribute to the differences in tube wear between the units or steam generators.

    C.3.2 – SCE Unit 2 Restart Report Enclosure 2 Conclusions – Because of the similarities in design between the Unit 2 and 3 RSGs, it was concluded that FEI in the in-plane direction was also the cause of the TTW in Unit 2.
    C.3.3 – SCE U2 FEI SONGS RCE Team Anonymous Member Conclusions – FEI did not occur in Unit 2
    C.3.4 – Westinghouse OA Conclusions: (a) An evaluation of the tube-to-tube wear reported in two tubes in SG 2E089 showed that, most likely, the wear did not result from in-plane vibration of the tubes since all available eddy current data clearly support the analytical results that in-plane vibration could not have occurred in these tubes, and (b) Operational data – Westinghouse ATHOS Model shows no operational differences in Units 2 & 3 (void fraction ~99.6%) and then Westinghouse says in (a) above that FEI did not occur in Unit 2. Westinghouse is contradicting its own statement.

    C.3.5 – AREVA OA Conclusions – Based on the extremely comprehensive evaluation of both Units, supplemented by thermal hydraulic and FIV analysis, assuming, a priori, that TTW via in-plane fluid-elastic instability cannot develop in Unit 2 would be inappropriate.
    C.3.6 – John Large States, “I note here that there are three clear conflicts of findings between the OAs: From AREVA that AVB-to-tube and TTW result from in-plane FEI, contrasted to Westinghouse that there is no in-plane FEI but most probably it was out-of-plane FEI, and from MHI that certain AVB-to-tube wear results in the absence of in-plane FEI from just turbulent flow. My opinion is that such conflicting disagreement over the cause of TTW reflects poorly on the depth of understanding of the crucially important FEI issue by each of these SCE consultants and the designer/manufacturer of the RSGs.”

    C.3.7 – DAB Safety Team Conclusions – Due to higher SG pressure (Range 863 – 942 psi) and lower thermal megawatts as compared to Unit 3, FEI did not occur in Unit 2. This is consistent with the position of RCE Team Anonymous Member. The NRC AIT Report, SCE, Westinghouse, MHI, SCE chosen “Independent” Experts and AREVA conclusions on Unit 2 FEI are inconsistent, confusing and inconclusive. The NRC AIT Report, SCE and AREVA conclusions on Unit 2 FEI are unacceptable.

    C.3.8 – The NRC San Onofre Special Review Panel should direct other branches within the NRC (NRC-RES and/or the ACRS) to review the above data without any prior “turf” bias and present their findings to the public for review and comment prior to any restart decision being made by the NRC.

    Dangers of SAN ONOFRE Unit 2 Restart
    1 – Chairman Allison Macfarlane said Unit 2 would not be permitted to restart unless the NRC has reasonable assurance it can be operated safely. Let us examine that scenario below and determine whether NRC can have that reasonable assurance or not:
    2 – Let us examine what John Large says, “There is no account of the changes that have been made in the evaluation of the tube structural and leakage integrity, that is from the stage of predicting those tubes at risk of TTW and other forms of wear, the tube thinning wear rates, through to the nature of the tube failure being unique to the type and extent of the wear pattern and tube thinning; and the methods of deducing, mainly by unproven inference, from the probe inspection results particularly to determine the in-plane AVB effectiveness, includes unacceptably large elements of test and experimentation that are inconsistent with the analyses and descriptions of the FSAR. I provide a number of explicit examples where I consider that the circumstances and risks accompanying the proposed restart of Unit 2 will result in unacceptable levels of test and experiment.” What he is saying is that these degraded tube bundles cannot prevent multiple tube ruptures from fluid elastic instability as we saw by the failure of 8 tubes in Unit 3 RSGs under Main Steam Line Break (MSLB) test conditions.
    3 – Let us examine what Arnie Gundersen says, “Eight replacement steam generator tubes failed their pressure tests in 2012 and more than 1,000 others have been plugged. Therefore, a review of the evidence makes it clear that the San Onofre Replacement Steam Generator tube damage discovered in 2012 was so severe and extensive that both reactors have been operating in violation of their NRC FSAR license design basis as defined in their Technical Specifications. The Main Steam Line Break with radiological leakage through the steam generator tubes is one of the bounding conditions in emergency plan evaluation and the extent of steam generator tube failures directly impacts the FSAR analysis. The Replacement Steam Generator (RSG) modifications at San Onofre increased both the likelihood of equipment failure and the radiological consequence of such failure and therefore directly affect the FSAR Current Design Basis.”
    4 – Unit 2 Main Steam Line Break (MSLB) Scenario: The most severe design basis accident to meet the San Onofre Unit 2 TS 5.5.2.11.b.1 steam generator structural integrity is a MSLB at the first weld outside containment. This assumption minimizes the flow resistance between the break and the affected SG and maximizes the mass & energy (M&E) release. The analyses focus on M&E releases at licensed Rated Thermal Power (RTP or 100% Power). The outside containment case includes the assumption that the main steam isolation valve (MSIV) in the steam line with the least flow resistance fails to close following the main steam isolation signal (MSIS). This assumption maximizes the M&E release during a MSLB outside of the containment. Super-heating within the SG initiates upon U-tube uncovery as specified in the NRC Information Notice 84-90. The turbine stop valves are assumed to close instantaneously at the time of the reactor trip. This assumption is conservative for a MSLB event because the entire steam inventory at the time of reactor trip is assumed to be forced out the break in 300 seconds (5 minutes). No Operator action outside Control Room can be assumed, if it takes less than 30 minutes. Westinghouse states, “it should be understood that there is more mass of secondary coolant in the steam generator at no load than at full power. Therefore, no load is the worst case for steam line break analyses.”
    The depressurization of the non-isolable steam generator would result in 100% void fractions in the degraded Unit 2 U-Tube bundle due to instant flashing of the sub-cooled 440 degrees Fahrenheit feedwater into steam. This condition of ZERO Water in the steam generators would cause fluid elastic instability (FEI), flow-induced random vibrations and excessive hydrodynamic pressures (Mitsubishi Flowering Effect). The force of the flashing steam would create high-energy jets, lifting loose parts and debris present in the steam generator, which would do additional damage by cutting holes into the already degraded tubes and creating additional loading (See Note 1 below) on the tube support plates (TSPs) due to heavy build-up of deposits on trefoil/quadrifoil-shaped holes from SG blowdown and crack the high cycle fatigued U-bend tubes not supported by Anti-Vibration Bars (AVB). These cumulative adverse conditions in all likelihood would result in a massive cascading of RSG’s tube failures (tubes would excessively rattle or vibrate, hitting other tubes with violent impacts) due to extremely low tube-to-tube clearances and no effective or non-existent in-plane anti-vibration bar support protection system. This jackhammering effect would involve hundreds of degraded active SG tubes along with all the inactive (plugged /unstabilized) tubes causing a catastrophic amount of simultaneous tube leaks/ruptures. Under this adverse scenario, approximately 60 tons of very hot high-pressure radioactive reactor coolant would leak into the secondary system. The release of this amount of radioactive primary coolant, along with an additional approximately 200 tons of steam in the first five to fifteen minutes from a broken steam line would EXCEED the SONGS NRC approved offsite radiological release doses safety margins based on assumption of a single tube rupture in the SONGS FSAR. So, in essence, these RSG’s are like loaded guns, or a Fukushima-type nuclear accident, waiting to happen. Any failure under these conditions would allow significant amounts of radiation to escape to the atmosphere and a major Loss of Coolant Accident (LOCA) could easily result causing much wider radiological consequences and even a potential nuclear meltdown of the reactor.
    SCE states, “A MSLB alone does not generate sufficient differential pressure to cause tube rupture. The differential pressure across the SG tubes necessary to cause a rupture will not occur if operators (See Note 2 below) prevent RCS re-pressurization in accordance with Emergency Operating Instructions.” SCE’s suggested DID Actions and proven unreliable operator actions to detect a leak and/or to re-pressurize the steam generators as claimed by Edison are not practical to stop a major nuclear accident from occurring in Unit 2 in the first 5-15 minutes of a MSLB during the proposed 5-month trial period.
    NOTES:
    1. Plugging of the at-risk tubes is not a satisfactory solution because it is the retainer bar that vibrates via random fluid flow processes at sub FEI critical velocity levels – these are likely to continue in play or, indeed, exacerbate at the proposed U2 restart at 70% power, leading to through-tube abrasion, the detachment of tube fragments, lodging at other unplugged and in-service tube localities, resulting in the so-called ‘foreign object’ tube wear. This additional loading would exceed: (1) the safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials, and (2) significantly affect burst or collapse pressures determined and assessed in combination with the loads due to a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.
    2. SCE’s suggested “defense-in-depth” actions are insufficient to stop multiple tube ruptures due to the short duration of a main steam line beak event. Human performance weaknesses, such as mis-diagnoses, substantial delays in isolating the faulted steam generator, communication errors and delayed initiation of the residual heat removal system, have been identified in past events at SONGS and other US Nuclear Power Plants. The events also involved unnecessary radiation releases, lack of RCS subcooled margin, excessive RCS cooldown rates, and overfilling the SG because of human or procedural problems.

    CONCLUSIONS: Until the NRC can determine that San Onofre is 100% safe to operate at its approved rated power, granting any Unit 2 Restart testing is unacceptable, because if a nuclear accident occurred during testing who would be held liable, the Nuclear Utilities, the Insurance Carriers, the Federal Government, the State of California, the CPUC, the NRC Commissioners, NRC Region IV, EIX/SCE Shareholders & Employees or just the millions of affected southern Californians? The DAB Safety Team believes that once the true amount of existing tube fatigue and all other associated damage is quantified, anything short of a total SG rebuild and/or SG replacement will be unacceptable prior to any restart being authorized by the NRC.
    Special Comments about San Onofre
    1. San Onofre is rated by the Institute of Nuclear Operations (INPO) as an INPO 4 Plant (The Worst Nuclear Plant Rating) and it should also should be rated in NRC Region IV Response Column V (Worst rating) and not in the NRC Response Column I (Best Nuclear Plant Rating).
    2. San Onofre is the worst nuclear plant in the country with the worst safety record, worst retaliation record, an INPO 4 rating and it is a mockery to place it in NRC Response Column I. NRC Region IV by listing San Onofre in NRC Response Column I, is putting its credibility on line and is displaying clear trends of collusion with SCE. It would be informative to learn who made the decision on San Onofre’s current ranking and why…
    efinitions of NRC Response Columns [Source: NRC Inspection Manual Chapter 0305]
    Column I – All Assessment Inputs (Performance Indicators (PIs) and Inspection Findings) Green; Cornerstone Objectives Fully Met
    Column II – One or Two White Inputs (in different cornerstones) in a Strategic Performance Area; Cornerstone Objectives Fully Met.
    Column III – One Degraded Cornerstone (2 White Inputs or 1 Yellow Input) or any 3 White Inputs in a Strategic Performance Area; Cornerstone Objectives Met with Moderate Degradation inSafety Performance
    Column IV – Repetitive Degraded Cornerstone, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or 1 Red Input; Cornerstone Objectives Met with Longstanding Issues or Significant Degradation in Safety Performance
    Column V. Overall Unacceptable Performance; Plants Not Permitted to Operate Within this Band, Unacceptable Margin to SafetyLicensed Activities

    ###
    Definitions, Abbreviations and Acronyms
    • 10 CFR 50.59 Safety Evaluation – Section 50.59 of Title 10 of the Code of Federal Regulations (10 CFR 50.59) defines the conditions under which reactor licensees may make changes to their facilities or make changes to procedures or to conduct tests or experiments without prior NRC approval. In general, such changes, tests, or experiments may be carried out unless they would involve a change to the technical specifications or an unreviewed safety question (as defined in 50.59(a)(2)). [Source: World Wide Web]
    • AIT: NRC’s Augmented Inspection Team
    • AREVA: Nuclear engineering firm owned by French Atomic Energy Commission
    • Arnold “Arnie” Gundersen is chief engineer of energy consulting company Fairewinds Associates and a former nuclear power industry executive, and who has questioned the safety of the Westinghouse AP1000, a proposed third-generation nuclear reactor. Gundersen has also expressed concerns about the operation of the Vermont Yankee Nuclear Power Plant. He served as an expert witness in the investigation of the Three Mile Island accident. Source: World Wide Web]
    • ATHOS is a three-dimensional computational fluid dynamics (CFD) code for analyzing steam generator (SG) thermal-hydraulic (TH) performance characteristics [Source: Westinghouse OA]
    • AVB: Anti Vibration Bar
    • CFR: Code of Federal Regulations
    • CPUC: California Public Utilities Commission
    • DBA: Design Basis Accident
    • ECT: Eddy Current Testing
    • EIX – Edison International
    • EPRI: Electric Power Research Institute
    • FEI: Fluid Elastic Instability is a phenomenon where the tubes vibrate with increasingly larger amplitudes due to the fluid effective flow velocity exceeding its specific limit (critical velocity) for a given tube and its supporting conditions and a given thermal hydraulic environment. This occurs when the amount of energy imparted on the tube by the fluid is greater than the amount of energy that the tube can dissipate back to the fluid and to the supports, because of lack of squeeze film damping, nucleate boiling or presence of localized regions in U-Tube bundles with high vapor fractions (e.g., >99.6%, steam voids, steam dry-outs, etc.) [Source: MHI/DAB]
    • FIRV: Flow-Induced Random Vibrations is a phenomenon where the tubes vibrate due to forces created by turbulent flow as a result of fluid velocity and density fluctuations. Vibration amplitudes due to random vibration are generally small (smaller than those due to tube fluid-elastic instability). [Source: MHI]
    • FSAR: Final Safety Analysis Report
    • FSM: Fluid elastic Stability Margin
    • FWLB: Feed-Water Line Break
    • John Large is a Chartered Engineer, a Consulting Engineer, a Fellow of the Institution of Mechanical Engineers, Graduate Member of the Institution of Civil Engineers and Fellow of the Royal Society of Arts. [World Wide Web]
    • LOCA: Loss Of Coolant Accident
    • MHI: Mitsubishi Heavy Industry
    • MSIV: Main Steam (line) Isolation Valve
    • MSLB: Main Steam Line Break
    • MWt: Mega-Watts Thermal
    • NOPD: Normal Operating Pressure Differential
    • NRC: Nuclear Regulatory Commission
    • NRC Reasonable Assurance is the recognition that “adequate protective measures can and will be taken in the event of a radiological emergency.” Reasonable assurance is based on licensees complying with NRC regulations and guidance, as well as licensees and offsite response organizations demonstrating that they can effectively implement emergency plans and procedures during periodic evaluated exercises. [Source: http://www.nrc.gov]
    • NRC San Onofre Special Review Panel – The NRC has established a special panel to coordinate the agency’s evaluation of Southern California Edison Co.’s proposed plan for restarting its Unit 2 reactor and ensuring that the root causes of problems with the plant’s steam generators are identified, and addressed. [Source: US NRC Blog]
    • NRR: NRC’s Office of Nuclear Reactor Regulations
    • OD: Outer Diameter
    • P/D: Pitch to Diameter ratio
    • OSG: Original Steam Generator
    • RCE: Root Cause Evaluation
    • RCPB: Reactor Coolant Pressure Boundary
    • RCS: Reactor Coolant System
    • RSG: Replacement Steam Generator
    • RWST: Refueling Water Storage Tank
    • SCE: Southern California Edison
    • SG: Steam Generator
    • SGTR: Steam Generator Tube Rupture
    • SM: Stability Ratio
    • SONGS: San Onofre Nuclear (Waste) Generating Station (alternate abbreviation: SONWGS)
    • TSP: Tube Support Plate
    • TTS: Top-of-Tube Sheet
    • TTW: Tube-to-Tube Wear
    • TW: Tube Wear
    • Westinghouse – Westinghouse Electric Company provides fuel, services, technology, plant design, and equipment for the commercial nuclear electric power industry.

    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 28, 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

  239. Special Public Awareness Series – Comparison of 2 Nuclear Power Plants in NRC Region IV
    San Onofre Nuclear Generating Station (SONGS) versus Palo Verde Nuclear Generating Station (PVNGS) – Part 2 – Original Combustion Engineering Steam Generators
    Challenges and Rewards of Innovative Design of Replacement Steam Generators
    Boguslaw J. Olech (Southern California Edison Co.), Tomoyuki Inoue (Mitsubishi Heavy Industries Ltd.)

    This paper describes major challenges associated with, and rewards resulting from, an innovative/improved design of the Replacement Steam Generators (RSGs) for the San Onofre Nuclear Generating Station (SONGS). The SONGS is a two-reactor Pressurized Water Reactor (PWR) Nuclear Power Plant (NPP) located in California, USA. The SONGS is majority owned and operated by Southern California Edison Company (Edison). The SONGS consists of twin plants (Units 2 and 3) rated at 3358 MWt (~1180 MWe) each. SONGS Unit 2 began commercial operation in 1983 and Unit 3 in 1984. The plants were originally equipped with CE Model 3340 recirculating steam generators. The Original Steam Generators (OSGs) employed heat transfer tubing made of Alloy 600 Mill Annealed (MA) and the carbon steel egg-crate type tube supports. The OSGs were designed for a 40-year service life. The main function of steam generators in PWR power plants is to transfer heat from the reactor core and in doing so produce steam. The steam, in turn, drives the main turbine/electric generator to produce electricity. Within the steam generator pressure vessel, a bundle of U-tubes, typically made of nickel-based alloy, provides surface area required for heat transfer from the primary to secendory coolant. The primary coolant flows through the tubes and causes the secondary coolant, which is in contact with the exterior surface of the tubes to boil, generating wet saturated steam. After passing through the moisture separators and steam dryers, essentially dry, saturated steam leaves the steam generator on its way to the high-pressure turbine. Over the years of operation of the PWR plants, it became evident that the steam generator tubes, made predominantly of Alloy 600, were susceptible to primary water stress corrosion cracking (PWSSC). This corrosion mechanism was resulting in tube degradation necessitating plugging large numbers of tubes after each inspection of the tubing. In addition, the SONGS OSG design has shown to be susceptible to tube through-wall wear and severe corrosion of the tube supports. It became evident that the OSG would have to be replaced much sooner than stipulated by their design service life. Continuing to operate with highly degraded steam generators can involve substantial economic risks from forced outages, extended refueling outages, as well as the direct costs of inspections and repairs. To address these risks, and consistent with industry experience, Edison has set a 21.4% plugging level as the technical end-of-life of the SONGS OSGs. The worst case forecast indicated that this plugging level could be reached by approximately 2012. SCE adjusted the DEI forecasts (SCE increased the probability that the units would exceed the plugging limit) to include subjective components to account for changes in industry experience, and NRC guidance and requirements. (Decision Application 04-02-026 p. 27). All the considerations mentioned above prompted Edison to make a conservative decision to replace the SONGS OSGs in both Units prior to that date. The contract for design, fabrication and delivery of the RSGs was awarded to Mitsubishi Heavy Industries Ltd. (MHI). As specified, the RSGs were supposed to be a replacement in-kind for the OSGs in terms of form, fit and function. At the same time, however, the RSG specification included many new requirements derived from both industry and SONGS operating experience, and the requirement to use the best and most suitable materials of construction. These requirements were aimed at improving the RSG longevity, reliability, performance and maintainability. Also, the specification called for very tight fabrication tolerances of the components and sub-assemblies, especially the tubesheet and the tube U-bend support structure. In addition, SONGS steam generators are one of the largest in the industry, which called for innovative design solutions and improved fabrication processes when working on the RSGs. Conceivably, the MHI and Edison project teams faced many tough challenges throughout the entire project in the design, manufacturing and QC areas, when striving to meet the specification requirements. Both teams jointly tackled all these challenges in an effective and timely manner. At the end, MHI delivered the RSGs which incorporated all the latest improvements found throughout the industry, as well as innovative solutions specific to the SONGS RSGs. In Unit 2, the RSGs were installed and tested in 2009/10 and in Unit 3 in 2010/11. The RSG post-installation test results met or exceeded the test acceptance criteria for all specified test parameters, thus properly rewarding the effort put into their fabrication.

    OBJECTIVE: To investigate the potential of Edison decision in 2001 to uprate the power in 2001 in San Onofre Original Combustion Engineering Steam Generators (OSGs) had any adverse effect on the increase in OSGs tube plugging Limit, and (1) Whether this decision inadvertently shortened the life of original CE steam generators, (2) Created the urgency to install new replacement steam generators (RSGs), and (3) The above factors have any impact on 2005 CPCU steam generators replacement (SGRP) decision, which states, “ If the SGRP cost exceeds $680 million, or the Commission later finds that it has reason to believe the costs may be unreasonable regardless of the amount, the entire SGRP cost shall be subject to a reasonableness review.”

    BACKGROUND:

    1. On March 14, 1993, while operating at 98-percent power, Palo Verde 2 experienced a steam generator tube rupture (SGTR) causing a primary-to-secondary leakage rate of approximately 908 liters per minute (lpm) [240 gallons per minute (gpm). The steam-tube cracking become so serious in Palo Verde Unit 2 that APS could operate it only for six months, at 86 percent of power, before shutting down to check the tubes. The unit was designed to operate at full power for 18 months between routine refueling shutdowns. [Source: Phoenix News Times, June 1, 1994, “Secrets of the Palo Verde Inn”]. Palo Verde Unit 2 had the same Combustion Engineering steam generators, with similar problems as San Onofre original Combustion Engineering steam generators described below.

    2. According to the Press Reports in 2004, “Each of San Onofre’s reactor domes has two generators, and each generator has about 9,350 tubes that are cracking, forcing crews to plug them up for safety’s sake. Under federal regulations, if 21.4 percent or more of the tubes are filled, the plant can be ordered to shut down. San Onofre’s generators are about halfway toward that tube-plugging limit. There is a 25 percent probability that the generators in Unit 2 will reach the federal limit by 2010 and a 15 percent probability that those inside Unit 3 will do the same by 2017. Source: http://www.cfece.org/GreenNuclear.htm%5D.”

    3. In “CPCU SGRP Decision 05-12-040 December 15, 2005”, SCE stated, “That there is a 25% probability that the Unit 2 steam generators will not be able to operate beyond RFO 16. It also says that there is a 15% probability that the Unit 3 steam generators will not be able to operate beyond RFO 16. SCE argues that it would be irresponsible to wait beyond RFO 16 to perform the SGRP because the probability of an unplanned shutdown would be too great.” In the above referenced document, the Utility Reform Network (TURN) stated, “SCE has not justified why its estimated 25% probability of shutdown in RFO 16 justifies performing the SGRP at that time. TURN points out that other utilities have requested and received higher plugging limits from the NRC.8 TURN, therefore argues that SCE has not addressed this possibility. TURN also states that due to the uncertainty in the steam generator tube degradation forecast, the tube plugging limit, and the point at which the probability of shutdown justifies that the SGRP be performed, it is possible that SONGS could operate until at least one or two RFOs later. TURN, therefore, recommends that such a possibility should be modeled.” In the above referenced document, SDG&E states, “Based on steam generator tube degradation forecasts prepared by Dominion Engineering, Inc. (DEI) for SCE, that there is a 67% probability that Unit 2 will operate until RFO 17 in 2011 and a 56% probability that Unit 3 will continue to operate until RFO 20 in 2016. Therefore, SDG&E recommends that the SGRP, if it is to be performed, be delayed by at least one RFO for Unit 2, and up to three RFOs for Unit 3. In the interim, the replacement steam generators would be stored.”

    4. DAB Safety Team, NRC Augmented Inspection Team and MHI has established beyond shadow of doubt that lower steam pressures are more severe for tube vibrations. Also, by operating steam generators at lower steam pressures, more thermal megawatts (more electric megawatts, more profits) can be produced. DAB Safety Team and other experts have further established that besides all other untested and unanalyzed design changes, lower steam pressures (~ 833 psi) and high thermal megawatts caused fluid elastic instability (Steam dry-outs, vapor fraction) in Unit 3. The fluid elastic instability in Unit 3 caused tube-tube wear in almost 400 tubes, one tube leak and failure of 8 tubes at main steam line break test conditions. Due to lower steam pressures (See Note Below), which increases the fluid velocities and thereby increases tube excitation which also causes tube vibration, Unit 3 also experienced increased flow-induced random vibrations, which caused extensive tube-to-AVB/TSP wear. Due to higher pressures, lower thermal megawatts, Unit 2 did not suffer fluid elastic instability, but suffered comparatively lower flow induced vibrations, which caused limited tube-to-AVB/TSP wear.

    NOTE: Lower steam pressures increase the reactor thermal power, increase heat flux in the hot leg and lower steam saturation temperatures. The net effect is increase in the steam content, or vapor fraction and gap velocities of the steam water mixture in the upper portions of the u-tube bundle and tube supports. This phenomena, increases tube excitation and tube vibrations. Reduction in steam pressure also increases the differential pressure between the inside of the tubes and secondary side of the steam generator, which in turn, also increase the tube excitation and tube vibrations. The cumulative effect is increased: (1) wear of the tubes and tube supports, (2) tube plugging and, (3) probability of tube rupture.

    5. In the Original 2001 Power Uprate Application (NRC ADAMS Accession Number ML010950020), “Proposed Change Number NPF-10115-514 Increase in Reactor Power to 3438 MWt San Onofre Nuclear Generating Station Units 2 and 3”, SCE stated “ By the above reference Southern California Edison (SCE) submitted Amendment Application Numbers 207 and 192 to the facility operating licenses for the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3, respectively, to increase the licensed reactor thermal power level to 3438 MWt. At 100% power operation, steam generator pressures typically vary between 800 psia and 815 psia, compared to the original nominal design operating pressure of 900 psia. Wear at tube support structures is a known degradation mechanism at SONGS. At SONGS, rapid wear was observed on tubes surrounding the stay cylinder in the center of the steam generator during the first cycle of operation. Many tubes in the most susceptible region around the stay cylinder have been preventively plugged. The first preventive plugging was done after 0.7 EFPY of operation. The preventively plugged region was expanded during the Cycle 3 outage. Typical active wear in CE designed steam generators has occurred at the support structures in the upper bundle region of the steam generator. These supports consist of diagonal straps (frequently called bat wings) and vertical strap supports. This currently active wear mechanism is influenced by both flow velocities and tube to support gap wear. The variable influenced by the proposed uprate is the inner bundle flow velocities. The hydrodynamic stability of a steam generator is characterized by the damping factor. A negative value of this parameter indicates a stable unit, i.e., small perturbations of steam pressure or circulation ratio will diminish rather than grow in amplitude. The damping factors remain highly negative, at a level comparable to the current design, for all cases. Thus, the steam generators remain hydrodynamically stable for all uprate cases.Based on a projected increase of 2.3% in the secondary side fluid velocity, normal operation flow induced vibration analysis is impacted by the velocity increase. Current analysis considered that tubes with more than one consecutive inactive eggcrate were staked and plugged, and two nonconsecutive inactive eggcrates are acceptable. The Stability Ratio (SR) is defined as: SR = Veff/Vcr, where, Veff= effective velocity, Vcr = critical velocity; and Values of SR 2%) in thermal and electrical megawatts as a result of operational changes,
    3.Tube Plugging Records between 1984 –2001 and 2001-2010 to perform trending on tube plugging rates in original steam generators,
    4.Original Combustion Engineering Steam Generator Design Specifications as developed by Bechtel Power Corporation or Combustion Engineering. Lessons Learnt: Common: SCE owns 78.2% of SONGS and 15.8% of PVNGS and both plants are licensed by NRC Region IV.
    To NRC Moderator: Special Thanks for posting this blog…. HAHN Baba

  240. Special Public Awareness Series – San Onofre Nuclear Generating Station (SONGS) Unit 2 Restart
    Part 4 – Comments about the NRC Augmented Inspection Team San Onofre Report
    Courtesy of DAB Safety Team
    The DAB Safety Team’s goal is to help both the NRC and the Public by providing unbiased, logical and factual information in order to help assess the real dangers of any San Onofre Unit 2 restart. According to Press Reports and San Onofre Insiders, Unit 2 permission for restart by the NRC is imminent yet the REAL Root Cause for the $1 Billion destruction of Units 2 and 3 RSGs (Including equipment cost and expenses) has not even been determined. Public does not know the status of SCE, MHI updated and ongoing cause evaluations, SCE’s response to 32 NRR’s RAI’s and NRC’s Special San Onofre Inspections. The NRC rushing to a faulty judgment cannot be allowed to compromise Public Safety just to please profit-motivated SCE, as this conflicts with President Obama’s Policy, the new NRC Chairman’s Standards and the advice of NRC retired Branch Chief’s who have also spoken out.

    NOTE: We highly recommend that NRC Augmented Inspection Team and NRC San Onofre Special Review Panel thoroughly review SONGS Unit 2 Return to Service MHI, AREVA, Westinghouse, DAB Safety Team and John Large Reports, then carefully examine the operational differences between Unit 2 and 3 and then update the NRC AIT report with a FACTUAL Root cause for FEI in Unit 3 and NO FEI in Unit 2. NRC San Onofre Special Review Pane also needs to review the SONGS Unit 2 Restart Reports (done by SCE, Westinghouse, AREVA and MHI), SCE Unit 3 Root Cause Evaluation, NRC AIT Report, ATHOS Modeling Results and Unit 2 Operational Data and then arrive: (1) At an unanimous, clear and concise conclusion whether FEI occurred in Unit 2 or not, and (2) Provide a GAP ANALYSIS (The scientific, technical and engineering reasons why all these reports are so different) prior the February 12, 2013 NRC Public Meeting

    The AIT inspection concluded that: (1) SCE was adequately pursuing the causes of the unexpected steam generator tube-to-tube degradation. In an effort to identify the causes, SCE retained a significant number of outside industry experts, consultants, and steam generator manufacturers, including Westinghouse and AREVA to perform thermal-hydraulic and flow induced vibration modeling and analysis; (2) The combination of unpredicted, adverse thermal hydraulic conditions and insufficient contact forces in the upper tube bundle caused a phenomenon called “fluid-elastic instability” which was a significant contributor to the tube to tube wear resulting in the tube leak. The team concluded that the differences in severity of the tube-to-tube wear between Unit 2 and Unit 3 may be related to the changes to the manufacturing/fabrication of the tubes and other components which may have resulted in increased clearance between the anti-vibration bars and the tubes; (3) Due to modeling errors, the SONGS replacement generators were not designed with adequate thermal hydraulic margin to preclude the onset of fluid-elastic instability. Unless changes are made to the operation or configuration of the steam generators, high fluid velocities and high void fractions in localized regions in the u-bend will continue to cause excessive tube wear and accelerated wear that could result in tube leakage and/or tube rupture; (4) The thermal hydraulic phenomena contributing to the fluid-elastic instability is present in both Unit 2 and 3 steam generators; (5) Based on the updated final safety analysis report description of the original steam generators, the steam generators major design changes were appropriately reviewed in accordance with the 10 CFR 50.59 requirements.
    So based on a review of the AIT Report and World’s Experts, the three potential causes, which were significant contributors to the “fluid-elastic instability” in SONGS Unit 3 and the tube-to-tube wear resulting in the tube leak are as follows:
    A. Insufficient contact tube-to AVB forces and differences in manufacturing or fabrication of the tubes and other components between Units 2 & 3
    B. Due to modeling errors, the SONGS replacement generators were not designed with adequate thermal hydraulic margin to preclude the onset of fluid-elastic instability.
    C. Differences between Unit 2 and Unit 3’s Operational Factors

    A. Let us now examine that whether insufficient contact tube-to AVB forces in the Unit 3 upper tube bundle caused “fluid-elastic instability” which was a significant contributor to the tube-to-tube wear resulting in the tube leak.
    A.1- MHI states, “By design, U-bend support in the in-plane direction was not provided for the SONGS SG’s”. In the design stage, MHI considered that the tube U-bend support in the out-of-plane direction designed for “zero” tube-to-AVB gap in hot condition was sufficient to prevent the tube from becoming fluid-elastic unstable during operation based on the MHI experiences and contemporary practice. MHI postulated that a “zero” gap in the hot condition does not necessarily ensure that the support is active and that contact force between the tube and the AVB is required for the support to be considered active. The most likely cause of the observed tube-to-tube wear is multiple consecutive AVB supports becoming inactive during operation. This is attributed to redistribution of the tube-to-AVB-gaps under the fluid hydrodynamic pressure exerted on the tubes during operation. This phenomenon is called by MHI, “tube bundle flowering” and is postulated to result in a spreading of the tube U-bends in the out-of-plane direction to varying degrees based on their location in the tube bundle (the hydrodynamic pressure varies within the U bend). This tube U-bend spreading causes an increase of the tube-to-AVB gap sizes and decrease of tube-to-AVB contact forces rendering the AVB supports inactive and potentially significantly contributing to tube FEI. Observations Common to BOTH Unit-2 and Unit-3: The AVBs, end caps, and retainer bars were manufactured according to the design. It was confirmed that there were no significant gaps between the AVBs and tubes, which might have contributed to excessive tube vibration because the AVBs appear to be virtually in contact with tubes. MHI states, “The higher than typical void fraction is a result of a very large and tightly packed tube bundle, particularly in the U-bend, with high heat flux in the hot leg side. Because this high void fraction is a potentially major cause of the tube FEI, and consequently unexpected tube wear (as it affects both the flow velocity and the damping factors).”
    A.2 – AREVA states, “At 100% power, the thermal-hydraulic conditions in the U-bend region of the SONGS replacement steam generators exceeded the past successful operational envelope for U-bend nuclear steam generators based on presently available data. The primary source of tube-to-AVB contact forces is the restraint provided by the retaining bars and bridges, reacting against the component dimensional dispersion of the tubes and AVBs. Contact forces are available for both cold and hot conditions. Contact forces significantly increase at normal operating temperature and pressure due to diametric expansion of the tubes and thermal growth of the AVBs. After fluid elastic instability develops, the amplitude of in-plane motion continuously increases and the forces needed to prevent in-plane motion at any given AVB location become relatively large. Hence shortly after instability occurs, U-bends begin to swing in Mode 1 and overcome hindrance at any AVB location.”
    A.3 – Westinghouse states, “Test data shows that the onset of in-plane (IP) vibration requires much higher velocities than the onset of out-of-plane (OP) fluid-elastic excitation. Hence, a tube that may vibrate in-plane (IP) would definitely be unstable OP. A small AVB gap that would be considered active in the OP mode would also be active in the IP mode because the small gap will prevent significant in-plane motion due to lack of clearance (gap) for the combined OP and IP motions. Thus, a contact force is not required to prevent significant IP motion. Manufacturing Considerations: There are several potential manufacturing considerations associated with review of the design drawings based on Westinghouse experience. The first two are related to increased proximity potential that is likely associated with the ECT evidence for proximity. Two others are associated with the AVB configuration and the additional orthogonal support structure that can interact with the first two during manufacturing. Another relates to AVB fabrication tolerances. These potential issues include: (1) The smaller nominal in-plane spacing between large radius U-bend tubes than comparable Westinghouse experience, (2) The much larger relative shrinkage of two sides (cold leg and hot leg) of each tube that can occur within the tubesheet drilling tolerances. Differences in axial shrinkage of tube legs can change the shape of the U-bends and reduce in-plane clearances between tubes from what was installed prior to hydraulic expansion, (3) The potential for the ends of the lateral sets of AVBs (designated as side narrow and side wide on the Design Anti-Vibration Bar Assembly Drawing that are attached to the AVB support structure on the sides of the tube bundle to become displaced from their intended positions during lower shell assembly rotation, (4) The potential for the 13 orthogonal bridge structure segments that are welded to the ends of AVB end cap extensions to produce reactions inside the bundle due to weld shrinkage and added weight during bundle rotation, and (5) Control of AVB fabrication tolerances sufficient to avoid undesirable interactions within the bundle. If AVBs are not flat with no twist in the unrestrained state they can tend to spread tube columns and introduce unexpected gaps greater than nominal inside the bundle away from the fixed weld spacing. The weight of the additional support structure after installation could accentuate any of the above potential issues. There is insufficient evidence to conclude that any of the listed potential issues are directly responsible for the unexpected tube wear, but these issues could all lead to unexpected tube/AVB fit-up conditions that would support the amplitude limited fluid-elastic vibration mechanism. None were extensively treated in the SCE root cause evaluation.”
    A.4 – John Large, Internationally Known Scientist and Chartered Nuclear Engineer from London says about the SONGS Unit 2 Replacement Steam Generators (RSGs) AVB Structure, “It impossible to reliably predict the effectiveness of the many thousands of AVB contact points for when the tube bundle is in a hot, pressurized operational state. The combination of the omission of the in-plane AVB restraints, the unique in-plane activity levels of the SONGS RSGs, together the very demanding interpretation of the remote probe data from the cold and depressurized tube inspection, render forecasting the wear of the tubes and many thousands of restraint components when in hot and pressurized service very challenging indeed.”
    A.5 – Conclusions: SONGS Unit 3 RSG’s were operating outside SONGS Technical Specification Limits for Reactor Thermal Power and Current Licensing Basis for Design Basis Accident Conditions. MHI states that high steam flows and cross-flow velocities combined with narrow tube pitch-to-diameter ratio caused elastic deformation of the U-tube bundle from the beginning of the Unit 3 cycle, which initiated the process of tube-to-AVB wear and insufficient contact forces between tubes and AVBs. Tube bundle distortion is considered a major contributing cause to the mechanism of tube-to-tube/AVB/TSP wear seen in the Unit 3 SG’s. After 11 months of wear, contact forces were virtually eliminated between the tube and AVBs in the areas of highest area of Unit 3 wear as confirmed by ECT and visual inspections. According to MHI Technical Document, RSG Anti-bar Vibration Structure was only designed to sustain the adverse effects in the out-of plane vibrations and not in-plane vibrations. Therefore, based on a review of MHI, AREVA and Westinghouse excerpts shown below, it is concluded, that FEI and MHI Flowering effect redistributed the tube-to-AVB gaps in Unit 3 RSG’s. It is concluded that NRC and SCE claims that insufficient contact forces in Unit 3 Tube-to-AVB Gaps ALONE caused tube “to” tube wear are misleading, erroneous and designed to put the blame on MHI for purposes of making SCE look good in the public’s eyes and for collecting insurance money from MHI’s manufacturing so called defects.

    B. Let us now examine of effects of modeling errors, that the SONGS replacement generators were not designed with adequate thermal hydraulic margin to preclude the onset of fluid-elastic instability.
    B.1 – NRC AIT Report states, “The ATHOS thermal-hydraulic model predicts bulk fluid behavior based on first principals and empirical correlations and as a result, it is not able to evaluate mechanical, fabrication, or structural material differences or other phenomena that may be unique to each steam generator. Therefore this analysis cannot account for these mechanical factors and differences which could very likely also be contributing to the tube degradation.”
    B.2 – Ivan Cotton states, “Fluid elastic instability is one of the most damaging types of instabilities encountered in heat exchangers and steam generators and can impose a severe economic penalty on the power and chemical industries. At present our understanding of the mechanisms leading to fluid-elastic instability is very limited and more experiments are needed to more fully delineate the conditions for the onset of fluid-elastic instability.” Such experimentation should only be done in a sealed lab, NOT our environment with the lives of eight million local residents at stake in the outcome!
    B.3 – Ishihara, Kunihiko and Kitayama state, “Tube vibrations become large as tube thickness/diameter ratio (T/D) increases and tube length/diameter ratio (L/D) decreases, and the tube vibrations strongly depend on the dynamic characteristics of tubes such as the natural frequency and the damping ability.”
    B.4 – Fairewinde states, “Realistically, the 3-D steam analysis is not accurate enough to apply to such important safety related determinations. To make such mathematical risk 3-D analysis, a very large margin of error must be applied, and that has not been done. For example, if the 3-D steam analysis determines that plugging 100 tubes is a solution, then plugging ten times that number might be the appropriate solution due to the mathematical errors in the 3-D analysis being applied by Edison and Mitsubishi.”
    B.5 – Mitra, V.K. Dhir, I. Catton state, “ Flow induced vibrations in heat exchanger tubes have led to numerous accidents and economic losses in the past. Efforts have been made to systematically study the cause of these vibrations and develop remedial design criteria for their avoidance. Instability was clearly seen in single phase and two-phase flow and the critical flow velocity was found to be proportional to tube mass. It is also found that nucleate boiling on the tube surface is also found to have a stabilizing effect on fluid-elastic instability.
    B.6 – SCE states that SONGS Unit 3 Damage (FEI) was caused due to outdated MHI Thermal-Hydraulic Computer Models. According to NRC AIT Report, SONGS did not specify the value of FEI in its Design and Performance Specifications SO23-617-1. Academic Researchers have discussed and warned about the adverse effects of fluid elastic instability (tube-to-tube wear) in nuclear steam generators since 1970’s. Westinghouse and Combustion Engineering (CE) have designed CE engineering replacement steam generators (RSGs) to prevent the adverse effects of fluid elastic instability since 2000’s (e.g., PVNGS).
    B.7 – The NRC AIT Report dated November 9, 2012 states, “the FIT-III thermal-hydraulic model was still in-progress at the time of the inspection and no final conclusions were reached for the cause of the non-conservative flow velocities, which were used as inputs in the tube vibration analysis and resulted in non-conservative stability ratios. Since the licensee had not completed the cause evaluation for this unresolved item, the inspectors were not able to make a final determination of whether a performance deficiency or violation of NRC requirements occurred. The inspectors were informed that Mitsubishi was performing an evaluation of the potential factors that contributed to the low flow velocities in FIT-III relative to the velocities calculated by the ATHOS model developed after the tube leak event in Unit 3. This evaluation was included in Document SO23-617-1-M1530, Revision 1, which also intended to demonstrate the validity of FIT-III results for the original tube vibration analysis. This evaluation was still being finalized and not yet approved by Edison. The licensee and Mitsubishi continued to evaluate this unresolved item and no final conclusions were reached at the time of the inspection. The NRC is continuing to perform independent reviews of existing information, and will conduct additional reviews as new information becomes available. In another related finding, NRC inspectors stated, “SCE Engineers did not meet Procedure SO123-XXIV-37.8.26 requirements to ensure the design of the retainer bar was adequate with respect to the certified design specification. Specifically, the licensee failed to ensure that there was sufficient analytical effort in the design methodology of the anti-vibration bar assembly to support the conclusion that tube wear would not occur, as a result of contact with the retainer bars due to flow-induced vibration. The inspectors determined that the requirements for flow-induced vibration in the certified design specification, along with the expectations in Procedure SO123-XXIV-37.8.26, provided sufficient information to reasonably foresee the inadequate design of the retainer bars during the review and approval of design Calculations SO23-617-1-C749 and SO23-617-1-C157, including the associated design drawings provided by Mitsubishi.”
    B.8 – Arnie Gundersen states, “Not only is Mitsubishi unfamiliar with the tightly packed CE design, but Edison’s engineers added so many untested variables to the new fabrication that this new design had a significantly increased risk of failure. As a result of the very tight pitch to diameter ratios used in the original CE steam generators, Mitsubishi fabricated a broached plate design that allows almost no water to reach the top of the steam generator.

The maximum quality of the water/steam mixture at the top of the steam generator in the U-Bend region should be approximately 40 to 50 percent, i.e. half water and half steam. With the Mitsubishi design the top of the U-tubes are almost dry in some regions. Without liquid in the mixture, there is no damping against vibration, and therefore a severe fluid-elastic instability developed.

Because of the Edison/Mitsubishi steam generator changes, the top of the new steam generator is starved for water therefore making tube vibration inevitable. Furthermore, the problem appears to be exacerbated by Mitsubishi’s three-dimensional thermal-hydraulic analysis determining how the steam and water mix at the top of the tubes that has been benchmarked against the Westinghouse design but not the original CE design.

The real problem in the replacement steam generators at San Onofre is that too much steam and too little water is causing the tubes to vibrate violently in the U-bend region. The tubes are quickly wearing themselves thin enough to completely fail pressure testing. Even if the new tubes are actively not leaking or have not ruptured, the tubes in the Mitsubishi fabrication are at risk of bursting in a main steam line accident scenario and spewing radiation into the air.”
    B.9 – Comment on Limitations of ATHOS thermal-hydraulic Models: The ATHOS thermal-hydraulic model predicts bulk fluid behavior based on first principals and empirical correlations and as a result, it is not able to evaluate mechanical, fabrication, or structural material differences or other phenomena that may be unique to each steam generator. Furthermore, the combination of the omission of the in-plane AVB restraints, the unique in-plane activity levels of the SONGS RSGs, together with the very demanding interpretation of the remote probe data from the cold and depressurized tube inspection, render forecasting the wear of the tubes and many thousands of restraint components when in hot and pressurized service very challenging indeed. ATHOS thermal-hydraulic Models used for 70% power have not been benchmarked, and tested against SONGS Unit 2 RSG degraded tube bundles performance for several cycles of depressurized/pressurized operation. Hence, ATHOS analyses cannot accurately predict the behavior of pressurized degraded bundle and anti-vibration bar support structure, which could very likely contribute to the tube-to-tube wear and AVB degradation at the Unit 2, 70% power and main steam line break with multiple steam generator tube ruptures.
    B.10 – Conclusions on Modeling Errors: SCE and MHI are both negligent because they did a very poor job of Industry and Academic Research benchmarking regarding the applicability of thermal-hydraulic computer models during the redesign of SONGS original CE SGs. SCE is negligent because they did not check the results of MHI’s outdated Thermal-Hydraulic Computer Models to meet their specification and procedure requirements. This does not meet the NRC Chairman’s Standards. Therefore, it is concluded that SCE claims as stated above are not factual. SCE engineers did not check the work of MHI with a critical and questioning attitude and did not meet the 10CFR50, Appendix B, Quality assurance Standards and or NRC Regulations.

    C. Let us now examine the other differences between Unit 2 and Unit 3’s Operational Factors, which were significant contributors to the “fluid-elastic instability” in SONGS Unit 3 and the tube-to-tube wear resulting in the tube leak.
    C.1 – Adverse Design/Operational Factors responsible for Fluid Elastic Instability: Low steam generator pressures (SONGS RSGs range 800-850 psi, the primary cause of the onset of severe vibrations) cause at the onset of FEI, whereby U-tube bundle tubes start vibrating with very large amplitudes in the in-plane directions. Extremely hot and vibrating tubes need a little amount of water (aka damping, 1.5% water, steam-water mixture vapor Fraction 99.5%). When this happens, the extremely hot and vibrating tubes cannot dissipate their energy and return to their original in-plane design position. In effect, one unstable tube drives its neighbor to instability through repeated violent and turbulent impact events which causes tube leakage, tube failures at MSLB test conditions and or unprecedented tube-tube wear, Tube-to-AVB/Tube Support Plates wear, as we saw in SONGS Unit 3. So in review, due to narrow tube pitch to tube diameter, tube frequency, low tube clearances, in certain portions of the RSGs U-tubes bundle, fluid velocities exceed the critical velocities due to extremely high steam flows (100% SONGS power conditions outside the industry NORM). These high fluid velocities cause U-tubes to vibrate with very large amplitudes in the in-plane direction and literally hit other the tubes with repeated and violent impacts. Due to lower steam operating pressures (required to generate more heat, electricity and profits) and excessive pressure drops due to high flows and velocities, steam saturation temperature drops. This lowering of steam temperature combined with high heat flux in the hot leg side of the U-tube bundle causes steam dry-outs to form (Vapor fraction >99%), known as “NO Effective Thin Tube Film Damping.” Thin film damping refers to the tendency of the steam inside the generators to create a thin film of water between the RSG tubes and the support structures. That film is enough to help keep the tubes from vibrating with large amplitudes, hitting other tubes violently, and protect the Anti-Vibration Bar support structures and maintain the tube-to-AVB gaps and contact forces. These adverse conditions in SONGS at 70% power operation (RTP) with the present defective design and degraded of RSGs known as fluid elastic instability (Tube-to-Tube Wear, or TTW) can lead to rapid U-tubes failure from fatigue or tube-to-tube wear in Unit 2 due to a main steam line break as seen in SONGS Unit 3 RSG’s. In summary, FEI is a phenomenon where due to SONGS RSGs design intended for high steam flows causes the tubes to vibrate with increasingly larger amplitudes due to the fluid effective flow velocity exceeding its specific limit (critical velocity) for a given tube and its supporting conditions and a given thermal hydraulic environment. This occurs when the amount of energy imparted on the tube by the fluid is greater than the amount of energy that the tube can dissipate back to the fluid and to the supports. The lack of Nucleate boiling on the tube surface or absence of water is found to have a destabilizing effect on fluid-elastic stability.
    C.2 – Unit 2 FEI Conflicting Operational Data
    NRC AIT Report SG Secondary U2/3 Pressure Range 833 – 942 psi
    SCE RCE SG Secondary U2/3 Pressure – 833 psi
    RCE Team Anonymous Member – Unit 2 SG Secondary Pressure 863 psi
    SONGS SG System Description Unit 2 SG Pressure Range 892 – 942 psi
    Westinghouse OA SG Secondary U2/3 Pressure ~ 838 psi
    DAB Safety Team SG Secondary U2 Pressure Range 863 -942 psi
    SONGS Plant Daily Briefing Unit 3 Electrical Generation – 1186 MWe
    SONGS Plant Daily Briefing Unit 2 Electrical Generation – 1183 MWe
    C.3 – Unit 2 FEI Conclusions
    C.3.1 – NRC AIT Report – Operational Differences between U2/3 – The result of the independent NRC thermal-hydraulic analysis indicated that differences in the actual operation between units and/or individual steam generators had an insignificant impact on the results and in fact, the team did not identify any changes in steam velocities or void fractions that could attribute to the differences in tube wear between the units or steam generators.
    C.3.2 – SCE Unit 2 Restart Report Enclosure 2 Conclusions – Because of the similarities in design between the Unit 2 and 3 RSGs, it was concluded that FEI in the in-plane direction was also the cause of the TTW in Unit 2.
    C.3.3 – SCE U2 FEI SONGS RCE Team Member Conclusions – FEI did not occur in Unit 2
    C.3.4 – Westinghouse OA Conclusions: (a) An evaluation of the tube-to-tube wear reported in two tubes in SG 2E089 showed that, most likely, the wear did not result from in-plane vibration of the tubes since all available eddy current data clearly support the analytical results that in-plane vibration could not have occurred in these tubes, and (b) Operational data – ATHOS Model shows no differences in Units 2 & 3
    C.3.5 – AREVA OA Conclusions – Based on the extremely comprehensive evaluation of both Units, supplemented by thermal hydraulic and FIV analysis, assuming, a priori, that TTW via in-plane fluid-elastic instability cannot develop in Unit 2 would be inappropriate.
    C.3.6 – DAB Safety Team Conclusions – Due to higher SG pressure (Range 863 – 942 psi) and lower thermal megawatts compared to Unit 3, FEI did not occur in Unit 2. This is consistent with the position of RCE Team Anonymous Member. NRC AIT Report, SCE, Westinghouse and AREVA conclusions on Unit 2 FEI are inconsistent, confusing and inconclusive.
    C.3.7 – DAB Safety Team Request: NRC San Onofre Special Panel investigation required.
    To be continued.. Part 4 – Original SONGS Combustion Engineering Steam Generators

  241. Special Public Awareness Series – San Onofre Nuclear Generating Station (SONGS) Unit 2 Restart
    Part 3 – Steam Line Break Mihama No. 3, Japan, 2004

    On Monday, 9 August 2004 a fatal accident happened at the Mihama No. 3 nuclear power station in Fukui prefecture, Japan. The plant is owned and run by Kansai Electric Power Corporation (KEPCO), the major power utility in Western Japan. Four workers were scalded to death by superheated steam, seven other workers were injured.

    The accident happened when the reactor was about to undergo routine maintenance. The accident was caused by a bursting steam pipe in the non-radioactive part of the reactor. In 27 years of operation that 56 cm diameter pipe had not once been checked for corrosion, let alone replaced. By the time it burst, its walls had worn down from an initial 10 mm of carbon steel to a mere 1.4 mm. Regulations required the pipes to be replaced when the walls were eroded to a thickness of 4.7 mm. Nine months before the accident a subcontractor company had alerted the operators to the need for inspections, but the warning was ignored.

    Between 1998 and 2003, KEPCO replaced carbon steel steam pipes in two other power stations, Takahama Nuclear Power Plant No. 3 and Oi Nuclear Power Plant No. 1, with stainless steel pipes. Inspections had revealed that the original pipes had worn so thin they would not have lasted another two years.

    The Mihama No. 3 reactor, which started commercial operations in 1976, is of the pressurized water (PWR) design used by most Western countries (USA, Germany, France). High pressure water is used to carry heat from the reactor core to a heat exchanger, where its heat turns water of a secondary cooling cycle into steam, which then drives power turbines. The steam is condensated and fed back into the heat exchanger. Because of the heat exchanger separating the two cooling cycles, water in the secondary cycle and the steam turbines are not radioactively contaminated.

    There are 15 nuclear power stations in Fukui prefectures, almost one third of the 47 in all of Japan. Plans to switch some of them to the use of mixed oxide (MOX) fuel have met political resistance, as there a questions about both the safety and economic viability of this type of fuel.

    The accident raises renewed serious questions about the safety culture of Japanese Nuclear Power Plant operators and the legal framework that surrounds them. Existing regulations did not explicitly require the company to check the secondary cooling cycle steam pipes of nuclear power stations. By contrast, every car needs to undergo comprehensive safety checks every two years. In 1995, a serious accident forced a shutdown in the Monju Fast Breeder Reactor, also in Fukui prefecture. That accident was also caused by a broken cooling pipe. The operators then tried to conceal evidence to cover up the magnitude of the accident.

    To be continued.. Part 4 – Fundamentals of Fluid Elastic Instability

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  242. Special Public Awareness Series – San Onofre Nuclear Generating Station (SONGS) Unit 2 Restart
    Part 2 – Mihama Nuclear Accident, Japan 1991, MHI SG – Lessons Learnt

    On February 9th, 1991, a heat transfer tube (SG tube) in a steam generator of the No.2 pressurized water reactor at the Mihama nuclear power station of the Kansai Electric Power Company broke off during a rated output operation. As a result, about 55 tons of primary cooling water leaked out from the SG tube into the secondary cooling loop, and the reactor was scrammed by operation of the ECCS (Emergency Core Cooling System). The amount of steam released from the main steam relief valve to atmosphere was about 1.3 tons. The amounts of radioactive rare gas and iodine discharged to the atmosphere were about 2.3E10 and 3.4E8 becquerels, respectively. This accident was the first disaster in Japan that resulted in actuation of the ECCS due to leakage of primary coolant in the steam generator. Therefore, the accident caused social concern with nuclear reactors.

    The international nuclear events scale (INES) is defined by the IAEA to assure coherent reporting of nuclear accident by different official authorities. The INES is characterized from level one to level seven. The level number increases with the scale of the accident. For example, level one is a minor event, and level seven is major accident. The scale of the accident in 1979 resulting in the loss of coolant that occurred in Three Mile Island was ranked level five by the IAEA. The accident reported here was ranked level three.

    The failure of the SG tube was caused by fretting fatigue resulting from contact of the SG tube with the supporting plate for the SG tubes, because the AVB, which functions to prevent flow-induced vibration, was not inserted deep enough onto the SG tubes in the steam generator. After seven seconds, the ECCS was automatically operated, and coolant water was flooded into the reactor by a high pressure injection pump. However, one main steam isolation valve and one pressurizer relief valve could not be operated by remote control. Therefore, the valve operation was carried out manually. Moreover, the steam generator of the No.2 pressurized water reactor was also replaced with a new one, because many of the SG tubes were removed from the generator for failure analysis.

    Lessons Learnt: Ignorance, Insufficient Knowledge, Poor Understanding, Production, Hardware Production, Production of Machinery and Equipment, Heat Exchanger, SG tube, Supporting Plate, AVB, Installation, Regular Operation, Nonobservance of Procedure, Error of Mounting Position, Lack of Insert Depth, Failure, Fracture/Damage, Flow-induced Vibration, Fretting Fatigue, Failure of SG tube, Usage, Maintenance/Repair, Inspection, Lack of Inspection, Failure, Large-Scale Damage, Leakage of Coolant
    To be continued.. Part 3 – Stream Line Break Mihama No. 3, Japan, 2004

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  243. Special Public Awareness Series – Comparison of 2 Nuclear Power Plants in NRC Region IV
    San Onofre Nuclear Generating Station (SONGS) versus Palo Verde Nuclear Generating Station (PVNGS) – Part 1 – Plant Description
    1. PVNGS is a nuclear power plant located in Tonopah, Arizona, about 45 miles (80 km) west of central Phoenix. It is the largest nuclear generation facility in the United States, averaging over 3.3 gigawatts (GW) of electrical power production in 2008 to serve approximately 4 million people. Arizona Public Service (APS) owns 29.1% of the station and operates the facility. Other owners include Salt River Project (17.5%), El Paso Electric Co. (15.8%), Southern California Edison (15.8%), PNM Resources (10.2%), Southern California Public Power Authority (5.9%), and the Los Angeles Dept. of Water & Power (5.7%). The plant is located in NRC Region IV.
    2. SONGS is a nuclear power plant located on the Pacific coast of California, in the northwestern corner of San Diego County, south of San Clemente. The facility is operated by Southern California Edison. Edison International, parent of SCE, holds 78.2% ownership in the plant; San Diego Gas & Electric Company, 20%; and the City of Riverside Utilities Department, 1.8%. The plant is located in Nuclear Regulatory Commission Region IV. The plant’s two reactors (Units 2 and 3) have been shut down since January 2012 due to premature wear found on tubes in steam generators, which apparently contributed to the accidental release of radioactive steam. The plant is located in NRC Region IV.
    Common: SCE owns 78.2% of SONGS and 15.8% of PVNGS and both plants are licensed by NRC Region IV.
    To be continued.. Part 2 – Original Combustion Engineering Steam Generators

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  245. Examples of “Friendly Sleepy Eyes” and “Watchful Open Eyes.” End Result – Ruined San Onofre Generators, $1Billion Down the Drain, and … & Running Palo Verde Generators for 10 years.
    San Onofre increased the total number of tubes by 377, but increased the length of each of the 9727 tubes by more than 7.2 inches, making it equivalent addition of ~ 11% tubes. SCE I…. and W… avoided the 50.90 License Amendment under the “Friendly Sleepy Eyes” of NRC Region IV.
    Palo Verde may be added tubes and also increased the length of each tube (equivalent addition of ~ 10% tubes + Tubes for Power Uprate) to its replacement generators by making the generators taller Wisely via 50.90 License Amendment under the “Watchful Open Eyes” of NRR.

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  246. The federal Nuclear Regulatory Commission began formally flagging nuclear safety concerns at the SONGS Federal Nuclear Prison in 2008, citing its failures to provide adequate instructions to employees, weaknesses in ensuring oversight and problems quickly addressing safety issues. Edison replaced its top nuclear official in 2010, part of a management shakeup that improved operations. Still, San Onofre’s on-site employees have made more allegations of wrongdoing in 2012 than at any other nuclear plant in the country. NRC reported zero violations in July 2012 and Pete Dietrich is very proud of his achievements. Looks like The NRC Resident Inspectors at San Onofre do not read Anonymous Notifications Nuclear Safety Concerns (Fire, Cyber Security Violations, Steam Generator Mistakes, Inhuman Attendance Policy, etc.) which are being reported by employees, who have been insulted, harassed, intimidated, discriminated and retaliated by SCE Management Senior Leaders/Managers Agents specially trained at Six-week Leadership Academy Course. Because of these Ruthless and Inefficient SCE Management Money- Hungry Senior Leaders/Managers Agents, SONGS is still an INPO 4 Plant and EIX Management is rewarding these people with Millions of Dollars in Salaries/Bonuses paid by the Poor Ratepayers. People do not understand why some NRC Region IV folks have been protecting these guilty SONGS folks for years? Some thing is grossly wrong about the conduct of some NRC Region IV folks, which needs to be investigated and fixed by NRC Chairman.

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  247. One of the well-known SONGS Shift Managers told SCE Management that he was not going to put his “License on the line” by operating a “Defectively Designed and Inoperable Unit 2” with bogus and unproven compensatory measures. Several other Shift Managers have retired rather than work for SONGS’ Profit-Motivated and Retaliating Management. The Operator Union has warned the SCE Management that with the proposed operator reductions, it will not be safe to restart Unit 2.

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  248. Text based on information from DAB Safety Team San Onofre Papers
    Fluid Elastic Instability is a very controversial and complex phenomenon, which has been around since 1966. To understand the concept of FEI in a two-phase heterogeneous steam water mixture in a Nuclear Steam Generators, Researchers and Steam Generator Designers/Manufacturers are still struggling. FEI can be caused by a combination of low steam generator pressures, low steam saturation temperatures, low tube clearances, high steam flows, high fluid velocities, improperly designed floating anti-vibration structures, no-in plane supports, potential of corrosion products clogging the TSP holes, lack of mixing baffles in the steam generator lower section, narrow tube pitch to tube diameter, low tube wall thickness to diameter ratio, high tube length to tube diameter ratio, tube frequency, resonance vibration, reactor coolant pump pressure pulses and other several unknown factors. The bottom line of FEI is the absence of water film on these tubes AKA localized steam voids. SONGS MHI RSGs suffer from most of these problems. On top of these problems, these “defectively designed and degraded generators” have thousands of damaged tubes. Therefore, these generators known as radiation steam crucibles cannot meet the 10 CFR Part 50 Appendix A, General Design Criteria 14 and SONGS Unit 2 Technical Specifications structural integrity performance criterion in TS 5.5.2.11.b.1.

    Courtesy of DAB Safety Team
    After wasting hundreds of millions of dollars, SCE has already used all the World’s Experts to demonstrate safe operation of Unit 2 at 70% power. Therefore, ,SCE has to Use Unknown Canadian, Russian, Chinese, Korean and Indian Steam Generator and Fluid Elasticity Experts to help develop a New Tube-To-Tube (TTW) Operational Assessment at 100% power, which will be ACCEPTABLE to The NRR. If that does not happen, NRR has to take pity at SCE and change SCE License to operate Unit 2 at 70% power. But, SCE still cannot demonstrate compliance at 70% power with: (1) 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”, and (2) SONGS Unit 2 Technical Specifications structural integrity performance criterion in TS 5.5.2.11.b.1. NRR has very smart engineers, who know the answer but are waiting for MHI Cause Analysis and Testing to be completed. It is CRYSTAL clear that SONGS Unit 2 RSGs will continue to experience Tube-to-Tube Wear (TTW) just like Unit 3 under accident conditions at any power because of the following:
    1. Fluid Elastic Instability (FEI or TTW) will continue to travel through the buffer zone of plugged/stabilized tubes and the plugged vibrating tubes will cause TTW in both active and inactive pressurized tubes.
    2. SONGS RSG’s U-Tube bundle and Anti-vibration Bar Structures were not properly designed to prevent the formation of highly localized steam dry-outs and retain structural integrity during a design basis MSLB in accordance with Modified SONGS Unit 2 Technical Specifications tube structural integrity criteria (which applies over the full range of normal operating conditions (including startup, operation in the 70% licensed power range, hot standby, and cool down and all anticipated transients included in the design specification) and design basis accidents)
    3. The improperly designed and degraded Unit 2 RSGs, if operated, will cause tube leak/ruptures (e.g., SONGS Unit 3, Mihama Unit 2, North Anna, Indian Point 2 and Craus, France, etc.) under potential Main Steam Line Break (MSLB) Conditions. Any number of the Unit 2 fatigued and already heavily degraded tubes can snap, leak and/or rupture at the tube sheet, tube support plate or the unsupported anti-vibration bars mid and free spans due to undetected microscopic and macroscopic cracks and corrosion products locked to the TSP during MSLB and other accident conditions. Between 2004 and 2006, three primary-to-secondary leaks occurred at the Cruas NPP: unit 1 in February 2004 and unit 4 in November 2005 and February 2006. The three leaks were all the result of a circumferential crack in the tube at the location where the tube passes through the uppermost tube support plate (TSP #8). The results of in situ examination initiated by the Cruas NPP operator showed that the flow holes of the uppermost Tube Support Plates (TSPs) were partially or completely blocked by corrosion products. This phenomenon is referred to as TSP “clogging-up” and it was considered potentially generic for EDF NPP fleet. For the Cruas leakages, it was established that the association of TSP clogging-up and the specificity of the Cruas steam generator (central area in the tube bundle where no tubes are installed) were responsible for a significant increase in the velocity of the secondary fluid in the tube bundle central area. In case of SONGS, this statement is true throughout the U-Tube Bundle because of Narrow Tube Pitch to Tube Diameter Ratio.
    4. The proposed Defense-in-Depth instrumentation, along with proven unreliable operator actions to detect a leak and to re-pressurize the steam generators during MSLB conditions as claimed by Edison are not practical to stop a major nuclear accident from occurring in Unit 2 during a MSLB
    5. With 500 plugged tubes in Unit 2 RSGs and 36 U-bends in Unit 2 SG E-088 and 34 in SG E-089 with a separation less than or equal to 0.050 inches, localized steam flows, fluid velocities and void fractions in these U-bends are projected to be higher in Unit 2 at 100% power level than predicted by the Westinghouse ATHOS Thermal-Hydraulic Computer Model. NOTE: The ATHOS thermal-hydraulic model predicts bulk fluid behavior based on first principals and empirical correlations and as a result, it is not able to evaluate mechanical, fabrication, or structural material differences or other phenomena that may be unique to each steam generator. Therefore, ATHOS thermal-hydraulic model cannot account for these mechanical factors and/or differences, which could also be contributing to additional tube degradation/failures.

    HelpAllHurtNeverBaba
    helpallcqiascnp@yahoo.com

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  249. NRC, MHI and SCE are wasting efforts, time and rate/taxpayers money to re-design anti-vibration bars that may be used as a long-term repair of both Unit 2 and Unit 3 San Onofre Nuclear Generating Station (SONGS) steam generators. The reasons are as follows:

    A. NRC is a regulating and inspection agency for ensuring public safety from licensed nuclear power plant activities, licensees, vendor and contractors. NRC mission is not to act as a steam generator expert and direct the activities of Inexperienced SCE/ Complacent MHI Engineers in the design, fabrication and testing of replacement parts for the “Defectively Designed and Degraded” SONGS Combustion Engineering (CE) replacement steam generators.

    B. SCE and MHI Engineers have failed miserably in their original attempts to duplicate original CE replacement generators under the pretense of a “like for like” exchange, wasted $1Billion Dollars of Ratepayers Money and almost caused a Fukushima Type Nuclear accident In Southern California Backyard.

    C. What did the designer (Edison) and manufacturer (MHI) proudly proclaim to the public about these “Innovative Replacement Steam Generators”?
    • Mike Wharton, Edison Manager of the steam-generator replacement project said, “The new steam generators are designed to last longer. They are designed for 40 years. We expect we’ll actually be able to get 60 years out of them … better materials, better design. You learn over the course of years what works well and what doesn’t, and you try to build it into the next generation.” [December 24th, 2009 Source: OC Register.]
    • Pete Dietrich, SONGS Chief Nuclear Officer said in Jan 10 2012, ”The plant’s largest components — steam generators — are just two years old and represent the safest, most efficient 21st century machinery.” [Source: Market Watch]
    • Ross Ridenoure, Southern California Edison senior vice president and chief nuclear officer, said, “ The installation is “a major milestone in the station’s history. We’re committed to making sure it’s done right.” [Source: January 28th, 2009, LA Times]
    • John R. Fielder, Edison President said, “New steam generators are cheaper for ratepayers than building new power plants or buying power on the open market.” [Source: LA Times, December 16th, 2005]
    • Mitsubishi Heavy Industries, Ltd., manufacturer of these RSGs stated in December 2006, “There is no standard design for a replacement SG because the specifications and plant requirements vary among customers. By applying the following latest advanced technologies to all SGs, improvements were made which cope with all past problems such as tube corrosion, vibration and wear, fatigue, and water hammer, and products which satisfy customers’ advanced demands for heat transfer capability and moisture content are being supplied. (1) Tube material of high nickel alloy TT690 with excellent corrosion resistance, (2) Outstanding tube support plate design, tube expansion technology in tube sheets, (3) Tube support structure at U-bends with high support function. The tube support structure at a U-bend is a unique design with reduced flow resistance increasing the number of support points. Together with excellent assembly technology during manufacturing, high reliability against vibration and wear of heat transfer tubes is achieved, and (4) MHI has developed a small, high-performance moisture separator by optimizing the geometry of the parts based on extensive field pressure tests. As a result, replacement SGs corresponding to power up-rating and/or advanced moisture requirements can be designed. Source: Mitsubishi Heavy Industries, Ltd., Technical Review Vol. 43 No. 4 (Dec. 2006).
    • Ei Kadokami, the deputy manager of Mitsubishi Heavy Industries in an article in the March-April 2009 Edition of the Nuclear Plant Journal explained some of the changes and expectations in MHI steam generators, “Tube P/D (pitch/outer diameter) is narrower than others so that the tube bundle and the Steam Generator itself are smaller, which is the first feature. The second feature MHI would like to emphasize is that MHI has not experienced any significant degradation in recent design. Alloy 690 is used for almost all steam generators and has high resistance against corrosion, but some steam generators fabricated by other manufacturers have wear caused by tube vibration in the U bend region. No tube wear has been experienced in recent MHI steam generators because not only AVB and TSP are designed to have enough margin against fretting wear but also the manufacturing procedure is appropriate to control gaps between the tube and AVB. Nuclear Plant Journal, Plant Maintenance & Plant Life Extension Issue, March-April 2009 volume 27 No. 2, ISSN: 0892-2055”
    • Boguslaw J. Olech (Retired from Southern California Edison) and Tomoyuki Inoue (Mitsubishi Heavy Industries Ltd.) in an International Engineer Magazine wrote, “The contract for design, fabrication and delivery of the RSGs was awarded to Mitsubishi Heavy Industries Ltd. (MHI). As specified, the RSGs were supposed to be a replacement in-kind for the OSGs in terms of form, fit and function. At the same time, however, the RSG specification included many new requirements derived from both industry and SONGS operating experience, and the requirement to use the best and most suitable materials of construction. Both teams jointly tackled all these challenges in an effective and timely manner. At the end, MHI delivered the RSGs, which incorporated all the latest improvements found throughout the industry, as well as innovative solutions specific to the SONGS RSGs. In Unit 2, the RSGs were installed and tested in 2009/10 and in Unit 3 in 2010/11. The RSG post-installation test results met or exceeded the test acceptance criteria for all specified test parameters, thus properly rewarding the effort put into their fabrication.”

    D. The Southern California Edison Company (SCE) filed an application (Application Number A.04-02-026) with the California Public Utilities Commission (CPUC) on February 27, 2004 for the San Onofre Nuclear Generating Station (SONGS) Steam Generator Replacement Project (Proposed Project). SCE’s stated objectives for the Proposed Project was to “Extend useful life of steam generators, and to ensure continued supply of low-cost power.” On May 15-19, 2006, Richard McIntyre and Greg Galletti of the USNRC Office of Nuclear Reactor Regulation USNRR, Division of Engineering (DE) traveled with an inspection team to observe the performance of a Nuclear Procurement Issues Committee (NUPIC) joint utility audit conducted at the Mitsubishi Heavy Industries facilities (MHI) in Kobe, Japan. The purpose of the Quality and Vendor Branch observation of this SCE led NUPIC joint utility audit was to ensure the audit process remains an acceptable alternative to the NRC vendor inspection/audit program.The staff observed how documents were selected for review and the adequacy of the review, interviews conducted of MHI technical personnel, and observed on-going work and testing activities in MHI’s manufacturing facility. This also included observation of both fabrication activities and several calibration and NDE activities including ultrasonic inspection of a tube support plate, and magnetic particle inspection of selected steam generator components. The reported noted that the NRC staff concluded that the “ NUPIC audit team performed a sound, thorough, performance-based review of the audited areas.”
    E. Design, fabrication and testing of Combustion Engineering (CE) replacement steam generators is not a moneymaking experiment to play with innocent public lives and a “Child’s Play.” Experts like Westinghouse/Combustion Engineering and their fabricators should perform this difficult and highly skillful task. These parties have proven experience in the design, fabrication, testing and safety design bases of Combustion Engineering (CE) steam generators for the last 50 years.

    HelpAllHurtNeverBaba
    helpallcqiascnp@yahoo.com

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  250. San Onofre Unit 2 Steam Generators are not Safe at any Power and do not meet the NRC Licensed Conditions for Operation to RTP and Design Basis Accident Conditions. SCE and NRC are just playing Cat and Mouse Games and wasting Ratepayers money, time and causing unneeded anxieties and worries. If SCE wants to produce safe, dependable and profitable power, they should return $1 Billion to Rate Payers and pay another 1 Billion Dollars to Westinghouse (The Most Advanced, Sophisticated, Skilled and Dependable US Nuclear Plant Designer & Manufacturer) to remove the defective generators and build new replacement generators like Palo Verde Nuclear Generating Station.
    MHI, AREVA & SCE cannot fix these 21st Century Safest but Sick Fukushima Radiation Steaming Crucibles.

    HelpAllHurtNeverBaba
    helpallcqiascnp@yahoo.com

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  251. 13-01-04 Supplemental NRR Version to DAB Press Release + 12-12-31
    The DAB Safety Team: January 4, 2013
    Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261
    SCE CANNOT PROVIDE AN OPERATIONAL TUBE-TO-TUBE WEAR (TTW) Unit 2 ASSESSMENT ACCEPTABLE TO THE NRR FOR OPERATION UP TO THE RTP
    NRC Office of Nuclear Reactor Regulation asked in a letter dated December 26, 2012 to Edison the following questions during review of SONGS Unit 2 to Service Report: (1) Under SONGS Unit 2 Technical Specifications structural integrity performance criterion 5.5.2.11.b.1, the plant is required to ensure that generator tubes retain “structural integrity” during “the full range of normal operating conditions,” including if the plant is running at full power, and (2) NRC wanted Edison to demonstrate that Unit 2 could meet that threshold, or explain how generator tubes would interact with each other if the plant is operating at maximum capacity?
    DAB Safety Team Conclusions: Based on the analysis of NRC AIT, MHI, SCE, Westinghouse and AREVA Reports, it is clear that SONGS Unit 2 RSGs will continue to experience Tube-to-Tube Wear (TTW) just like Unit 3 for operation up to 100% Power, or Licensed Reactor Thermal Power of 3438 MWTs because of the following:
    •Fluid Elastic Instability (FEI or TTW) will continue to travel through the buffer zone of plugged tubes and plugged vibrating tubes will cause TTW in the active pressurized tubes.

    •SONGS RSG’s U-Tube bundle and Anti-vibration Bar Structures were not designed to prevent the formation of highly localized steam dry-outs and/or retain structural integrity during a design basis MSLB in accordance with SONGS Unit 2 Technical Specifications tube structural integrity criteria (which applies over the full range of normal operating conditions (including startup, operation in the 70% power range, hot standby, and cool down and all anticipated transients included in the design specification) and design basis accidents).

    •The improperly designed and degraded Unit 2 RSGs, if operated, will cause tube leak/ruptures (e.g., SONGS Unit 3, Mihama Unit 2, North Ana, Indian Point 2 and Craus, France, etc.) under potential Main Steam Line Break (MSLB) and other transient conditions.

    •Any number of the Unit 2 fatigued and already heavily degraded tubes can simultaneous snap, leak and/or rupture at the tube sheet, tube support plate or the unsupported anti-vibration bars mid and free spans during MSLB accident conditions because of Tube Bundle Uncovery, 100% localized steam dry-outs (TTW), high-energy jet impingement, debris and loose parts.

    •Finally, the proposed Defense-in-Depth instrumentation, along with proven unreliable operator actions needed to detect a leak and to re-pressurize the steam generators during MSLB conditions as claimed by Edison, are just not practical to stop a major nuclear accident from occurring in Unit 2 during a MSLB during the 5-month trial period.
    Therefore, SCE cannot provide an NEW Operational Assessment ACCEPTABLE to the NRR/NRC, which demonstrates that steam generator Tube-to-Tube Wear (TTW) and Tube Integrity from Reactor start-up, 70% Power and operation up to 100% power would not cause a tube leaks/ruptures in order to comply with: (1) 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, and (2) SONGS Unit 2 Technical Specifications structural integrity performance criterion in TS 5.5.2.11.b.1.

    HelpAllHurtNeverBaba
    helpallcqiascnp@yahoo.com

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  252. PENDING Press Release
    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 Request 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 NRR, 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.”
    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 RSG’s?
    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 time frame and are currently still operating?
    14 – Were the original CE Steam Generators and new replacement generators exact in Thermal Output (MWe) 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 questioning job on their review of the San Onofre Unit 2 Restart Proposal as indicated by their Request for Additional Information #32
    ###
    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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  253. 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: RAI#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 RAI#32(1): 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 RAI#32(2): SCE cannot provide an ACCEPTABLE operational assessment to NRR, 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.”

    I would like to wish the entire NRC Staff and their families a Happy 2013. I would also like to pay a Professional Complement to the NRR Staff for displaying a “Critical Questioning & investigative Attitude” and for performing a comprehensive technical evaluation on the 2003 PVNGS RSGs License Amendment/Power Uprate Application and SONGS Unit 2 Return to Service Report…. Thanks for blogging

    helpallcqiascnp@yahoo.com

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  254. Public Perception of NRC Region IV and Southern California Edison

    Both are violating Federal Regulations and Public Trust
    Both believe in Production over Public Health and Safety
    NRC finds a repeat problem at SONGS, NRC says it is More than a Minor Violation
    SCE says, Problem has been put in the Corrective Action System and has been addressed
    SONGS has the worst Nuclear Safety Violations and Worker Retaliation Record
    NRC says SONGS has Zero Worker retaliation and Nuclear Safety Violations
    NRC SONGS Nuclear Safety Violations data conflicts with its own statements
    SONGS Unit 3 almost missed a Nuclear Accident,
    SCE and NRC say, it was just a Minor Leak
    SONGS Prepared a Defective 10 CFR 50.59 Evaluation for Replacement Steam Generators
    NRC says SONGS played according to the Rules
    Office of Nuclear Reactor Regulation says, Wait a Minute NRC, SONGS broke the Rule
    Citizens say, when it comes to Edison, NRC is sleeping on the Wheel
    NRC and Edison Attorney’s work together to defeat the Public
    NRC Region IV is in non-compliance with President Obama’s Open Government Initiative
    NRC Region IV is in non-compliance with Senator Boxer’s Open Government Initiative
    NRC Region IV is in non-compliance with NRC Chairman and its Own Rules
    Both give the perception of Collusion and Twin Brothers
    Public Meetings are for Edison and NRC, not for the Public
    This is Democratic America and not a Third World Dictator Country
    Edison is paid by the Ratepayers and NRC is paid by the Taxpayers
    Southern Californians have faith in NRC Chairperson and Atomic Safety Licensing Board
    Government will not allow the Sick SONGS Unit 2 Restart without Repairs and License Amendment
    Southern Californians will not allow a Fukushima in their Backyards

    helpallcqiascnp@yahoo.com

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  255. US # 1 Nuclear Safety Concern and San Onofre Watergate – $1 Billion Dollar Ratepayer Rip-off

    SCE’s misleading and embarrassing technical presentation at their NRC public meeting when explaining fluid elastic instability in SONGS Unit 2, creates doubts about Edison’s ability to perform a safe restart of their damaged “As Designed and Defective Radiation Steaming Crucibles.”

    helpallcqiascnp@yahoo.com

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    According to public sources, Pete Dietrich has already announced in internal SONGS staff meetings that Unit 2 will tentatively restart on February 2, 2013. If confirmed, this is stunning news for the public and gives the clear perception of collusion between the NRC and SCE. SCE can go to extent to make money and leave the NRC hanging between the Public Safety and allegiance to SCE. TEPCO’s reported collusion with Japanese Regulators resulted in Fukushima’s catastrophic nuclear accident (a Trillion Dollar Japanese economic, public health & safety radiation nightmare and Eco-Disaster).

    If allowed to restart SONGS Unit 2 by NRC even at 70% power operations for a trial period of 5 months, a steam line break outside containment in Unit 2 and/or any unanticipated operational transients can result in the following scenarios: (1) the depressurization of the steam generators with the failure of a main steam isolation valve to close, or (2) over pressurization of the steam generators with the actuation of a main steam safety valve. Any of these adverse conditions would result in 100% void fractions in the degraded Unit 2 U-Tube bundle due to low tube-to-tube clearances and no in-plane anti-vibration bar protection. This condition of ZERO Water in the steam generators would cause fluid elastic instability (FEI) and flow-induced random vibrations, which in all likelihood would then result in massive cascading SG tube failures, involving hundreds of degraded active SG tubes, along with all the damaged inactive (all the plugged /stabilized) SG tubes. With an undetermined amount of simultaneous tube leaks/ruptures, approximately 60 tons of very hot high-pressure radioactive reactor coolant would leak into the secondary system. The release of this amount of radioactive primary coolant, along with an additional approximately 200 tons of steam in the first five minutes from a broken steam line would EXCEED the SONGS NRC approved safety margins. So, in essence, the RSG’s are loaded guns, or a nuclear accident like Fukushima waiting to happen in Southern Californian backyards. Any failure under these conditions would allow significant amounts of radiation to escape to the atmosphere and a major Loss Of Coolant Accident (LOCA) could easily result causing much wider radiological consequences and even a potential nuclear meltdown of the reactor! Since these events would happen at an extremely fast pace, no credit is assumed in the first 5 minutes of the main steam line break accident for: (1) Enhanced Unit 2 Defense-In-Depth Actions – SCE Restart Plan Enclosure 2, Item 9.0, and (2) The differential pressure across the SG tubes necessary to cause a rupture will not occur if operators prevent RCS re-pressurization in accordance with their Emergency Operating – Enhanced Unit 2 Defense-In-Depth Actions – SCE Restart Plan Enclosure 2, Item 5.2.2. Probabilistic Risk Analysis. SONGS Operating history indicates gives a clear perception that claiming reliance on timely operator action is a well orchestrated and intentional SCE move designed to make profits and to fool/hurt the public. The operator action will not work due to short duration of the initial and devastating event, the radiation/steam environment, communication errors between the control room and field operators due to sonic booms and hissing steam noises (sound-powerd phones, pagers, cell phones and radio’s will not work), darkness, difficult terrain and other unknown equipment failures and contingencies. NRC UNDER ANY CIRCUMSTANCES SHOULD NOT PERMIT SCE TO RESTART UNIT 2 WITHOUT RETUBING or REPLACING THE DEFECTIVE STEAMING RADIATION CRUCIBLES like PVNGS Design by Westinghouse. MHI and AREVA lack that capability.

  256. All comments that meet the comment guidelines of the blog are posted. Some postings may be delayed if the comments need to be reviewed by Allegations staff. Comments that meet the guidelines but do not pertain to the topic of the post under which they are submitted are moved here, to the Open Forum section.

    Blog Moderator

  257. True public officials are fearless and address a public safety or retaliation problem, when reported and do not get afraid and remove the comments from the blog. You can please send me an email not to put any more comments, but these problems should be an eye-opener for NRC officials in line with His Excellency, The President of United States, Senator Barbara Boxer, The Federal Reglations and NRC Rules. I wonder, what is the difference between SCE and NRC? Thanks..

    helpallcqiascnp@yahoo.com

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  258. Coursy of DAB Safety Team FYI – Ms. Maureen Conley & NRC Chairmam and Region IV Staff
    SCE’s misleading and embarrassing technical presentation at their NRC public meeting when explaining fluid elastic instability in SONGS Unit 2, creates doubts about Edison’s ability to perform a safe restart of their damaged “Radiation Steaming Crucibles”.
    Due to high steam flows, high fluid velocities, narrow tube clearances, areas of top of U-tube bundle in a nuclear steam generator have no water, as seen in SONGS 3. When this happens, fluid elastic instability occurs and the thin tubes move with large sprinting amplitudes and hit the neighboring tubes with violent and repeated impacts. Poorly designed nuclear steam generators such as SONGS, have NO in-plane anti-vibration bar supports and water to protect tubes from hitting each other. Therefore, cascading tube ruptures can occur and cause a reactor Meltdown. SONGS Unit 2 “As-designed and Defective Radiation Steaming Crucibles have NO in-plane anti-vibration bar supports, have extremely low tube clearances and many unanticipated operational occurrences and MSLB even at 70% power, can cause the entire u-tube bundle to be devoid of water and cascading tube ruptures. Result is Fukushima In Southern California Backyards.
    After spending almost a year, wasting hundreds of millions of dollars of rate payer’s money and hiring World’s Best Experts, Southern California Edison brought out SONGS Senior Vice President of Engineering, Tom Palmisano, on November 30, 2012 (Friday night) to give an intense technical presentation and a dazzling performance in a bid to convince the regulators they should be able to restart Unit 2 at the plant. However, Palmisano failed miserably to convince the DAB Safety Team, NRC Region IV Panel and the Public/Technical Experts, that Southern Californians will be safe from the effects of a potential nuclear radiological accident by the restart of Unit 2’s “Sick and Unsafe” Steam Generators by operating them at 70% power for a trial period of 5 months. When questioned by NRC Panel Members, the unprepared and uncomfortable Palmisano tasked with convincing the NRC, the Public and the News Media that Unit 2 is safe for restart “stumbled several times during the presentation”, then in response to the panel members questions for further technical details said sometimes irritatingly, “I will get back to you” and then finally “hesitantly” admitted, “SCE and MHI analysis are still not yet complete and will continue for several months for a detailed analysis and investigation to this problem.”
    San Onofre’s “As designed and defective” replacement steam generators (aka radiation steaming crucibles) without replacement or adequate repairs (replacement of tube bundle and anti-vibration supports) are unsafe and fail to meet the Steam Generator Fundamental Tube Integrity Criteria for a Main Steam Line Break Accident and Other Unanticipated Operational transients.
    According to public sources, Pete Dietrich has already announced in internal SONGS staff meetings that Unit 2 will tentatively restart on February 2, 2013. If confirmed, this is stunning news for the public and gives the clear perception of collusion between the NRC and SCE. TEPCO’s reported collusion with Japanese Regulators resulted in Fukushima’s catastrophic nuclear accident (a Trillion Dollar Japanese economic, public health & safety radiation nightmare and Eco-Disaster).
    Copyright – 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 Attorneys.
    helpallcqiascnp@yahoo.com
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  259. Palmisano declared with his face beaming that tube-to-tube wear was caused “Most Likely” by in-plane vibrations (fluid elastic instability) in Unit 2 Steam Generator E-089 (U2SGE089). Two affected tubes in U2SGE089 with 14% wear depth were plugged and they preventatively plugged 321 tubes to conservatively add to the safety margin. It is astonishing and alarming to note that SCE’s Vice-President contradicted the World’s Leading and Pioneering Nuclear Plant Designer, Westinghouse Operational Assessment, which concluded, “ In-plane vibrations (fluid elastic) instability did not occur in U2SGE089 in two affected tubes. The tube-to-tube wear is most likely a result of out-of-plane vibrations (flow-induced random vibrations) of the two tubes in close proximity to the level of contact during operation.”
    The DAB Safety Team perception is that Palmisano is either pretending or really does not understand the Westinghouse Operational Assessment’s conclusions regarding the adverse effects of fluid elastic instability and flow-induced random vibrations, which caused the January 31, 2012, radioactive leak in one of the SONGS Unit 3’s brand new 680 million dollar replacement steam generators (RSG’s) reverse-engineered by the inexperienced SCE in-house engineers and manufactured at the direction of complacent Mitsubishi Heavy Industries. Southern Californians were very lucky, because a potentially serious nuclear accident in progress was stopped by an emergency shut down. 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 RSGs E-088 failed “in-situ” pressure testing and therefore were plugged, after only 11 months of operation. After that, several hundred Alloy 690 Thermally Treated tubes were also plugged due to tube-to-tube wear. SCE did not disclose intentionally to the public that one Unit 2 tube had also experienced a 90% through wall wear due to a MHI Manufacturing retainer bar defect. Southern Californians were once again very lucky that a serious nuclear accident was prevented by a planned refueling shut down. SONGS RSG’s now have more damaged and/or plugged tubes than all the rest of the US reactor fleet combined. Based on analysis of NRC AIT Report and SONGS Procedures, Operational Data, Plant Daily Briefing Sheets, Engineering Calculations and conversations with Plant Personnel, the DAB Safety Team disagrees with SCE and confirms Westinghouse Operational Assessment conclusions that fluid elastic instability did not occur in Unit 2 Steam Generator E-089. The DAB Safety Team discussions with two of the NRC Panel Members gives us the perception that the NRC panel Members disagree amongst themselves and also with SCE on the effect of operational parameters on fluid elastic instability in Unit 2 Steam Generator E-089.
    The NRC Chairman stated that SCE is responsible for the work of its vendors and contractors. The real crux of the problem with the San Onofre Generators, Palmisano said, was the outdated mathematical model Mitsubishi used. There were mistakes in the parameters concerning the arrangement of the heat transfer tubes, Palmisano said. The SCE claims about MHI Thermal-Hydraulic Computer Modeling errors are misleading, erroneous and designed to absolve SCE of all the mistakes and put the blame on MHI for purposes of collecting insurance money for using outdated computer codes and to appear blameless themselves before the public.
    Unit 2 has hundreds of times more bad tubes and a thousand times more indications of wear on those tubes than the typical reactor in the country with a new steam generator, and nearly five times as many plugged tubes as the rest of the replacement steam generators, over a comparable operating period, in the country combined. Therefore, the restart of Unit 2 with thousands of degraded tubes present a formidable challenge to the Safe Restart of Unit 2 by making it highly vulnerable to localized steam dry-outs, 100% void fractions, fluid elastic instability, flow-induced random vibrations and cascading tube ruptures during unanticipated operational occurrences and or Main Steam Line Breaks. SCE is trying to Restart Unit 2’s Degraded RSG’s, which are outside the NORM of the NRC Regulations.
    According to DAB Safety Team conversation with one of the NRC Panel members, Senators Barbara Boxer and Diane Feinstein have told the NRC and are both in favor of Replacement or Adequate Inspections and Repairs of SONGS RSGs with a 50.90 thorough NRC License Amendment Process and Evidentiary Public Hearings.
    According to public sources, Pete Dietrich has already announced in internal SONGS staff meetings that Unit 2 will tentatively restart on February 1, 2013. If confirmed, this is stunning news for the public and gives the clear perception of collusion between NRC and SCE. TEPCO’s reported collusion with Japanese Regulators resulted in Fukushima Catastrophic Nuclear Accident (Trillion Dollar Japanese economic, public health and safety radiation nightmare, worker fatalities and environmental disaster).
    helpallcqiascnp@yahoo.com
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  260. The World’s Foremost Expert and Scholars on Design to prevent FEI and Excessive FlRV
    The World’s Foremost Renowned Professeur Titulaire, Michel J. Pettigrew, Ecole Polytechnique de Montreal, on the subject of fluid elastic instability and turbulence-induced vibration states in a 1970’s paper, “It is concluded that, although there are still areas of uncertainty, most flow-induced vibration problems can be avoided provided that nuclear components are properly analysed at the design stage and that the analyses are supported by adequate testing and development work when required. There has been no case yet where vibration considerations have seriously constrained the designer.” Weaver and Schneider in 1983, examined the flow induced response of heat exchanger U-tubes with flat bar supports. It is worth quoting the first conclusion of their paper: “The effect of flat bar supports with small clearance is to act as apparent nodal points for flow-induced tube response. They not only prevented the out-of-plane mode as expected but also the in-plane modes. No in-plane instabilities were observed, even when the flow velocity was increased to three times that expected to cause instability in the apparently unsupported first in-plane mode.” One Masters Research Student R. Viollette in a research paper published in 2006 states, “Fluid elastic instability is the most important vibration excitation mechanism for heat exchanger, or steam generator type of tube bundles. It is so because of the very high vibrations amplitude that it can induce to the tubes, which can lead to rapid failure by fatigue or wear. Also, unlike vibrations induced by vortex shedding (vortex-induced vibrations), fluid elastic instability is not a self-limiting phenomenon: amplitude of vibrations does continue to increase with velocity past the critical onset of the instability.
    What went wrong with SONGS RSGs Tubes – Worst US Operating Nuclear Fleet Record
    The Inexperienced and Complacent SCE Engineers in a rush to make profits for SCE Officers and Shareholders ignored: (a) CPUC advice on applying to NRC for increased plugging limit to extend the life of Original Steam Generators, and (b) SDG&E opposition to the wisdom and viability of the RSG Project.
    Although SCE was a shareholder in PVNGSs, the SCE Engineers due to time pressure and complacency did a very poor job of Benchmarking, (a) Especially of PVNGS on the new fabrication techniques and design to prevent the adverse effects of FEI and FIRV, and (b) Did not keep up with the research of World’s Foremost Expert and Academic Scholars to prevent the adverse effects of FEI and FIRV.
    Due to time pressure, complacency and a rush to make profits for SCE Officers and Shareholders prepared a defective 10 CFR 50.59 Evaluation and made numerous untested and unanalyzed tested design change under the pretense of like-for-like to avoid lengthy and evidentiary public hearings and thorough NRC 50.90 Amendment.
    NRC Comments: Greg Werner, who headed the federal team, said ‘Changes intended to improve manufacturing were never thoroughly reviewed in the context of the generator design, resulting in weaker support around bundles of tubes that contributed to vibration, he said. The disclosure will rivet new attention on a series of alterations to the equipment design, including the decision to add 400 tubes to each generator and installing V-shaped supports that were intended to minimize tube wear and vibration. The generators were designed to meet a federal test to qualify as “in-kind,” or essentially identical, replacements for the original generators, which would allow them to be installed without prior approval from federal regulators. The agency is reviewing how that was handled. Inside the guts of the machinery, the original steam generators and the replacements “look substantially different,” Collins said [Source: AP News].
    DAB Safety Team agrees with Fairewinds Associates comments: If Edison had informed the NRC that the new steam generators were not like-for-like, the more thorough NRC licensing review process would have likely identified the design problems before the steam generators were manufactured. The unauthorized and untested design changes made by SCE Engineers to extract more juice (heat) and make money for SCE shareholders out of the RSGs (1729 MWt) compared with the OSGs (1705MWt) destroyed in the Brand New 580 million RSGs. [Please see DAB Safety Team Papers, “The Big Number 1 Attachment Notes” & “SONGS Insider Secret)
    What is FEI/FIRV, why it occurred and caused unprecedented tube-to-tube wear in U3 RSGs
    SONGS RSGs are not designed for in-plane protection from FEI. Low Steam Generator Pressures (1 causes the onset of FEI and Excessive FIRVs At the onset of FEI, U-tube bundles tubes vibrate with very large amplitudes in the in-plane directions Extremely hot and vibrating tubes with large need tubes a little amount of water (aka damping, 1.5% water, steam-water mixture vapor Fraction 99.5%). When this happens, the extremely hot and vibrating tubes cannot dissipate their energy and return to their original in-plane design position. So now, one unstable tube drives its neighbor to instability through repeated violent and turbulent impact events and causes tube leakage, tube failures at MSLB test conditions and unprecedented tube-tube wear, Tube- to-AVB/Tube Support Plates wear, as we saw in SONGS Unit 3. At the onset of FEI, U-tube bundles tubes vibrate with very large amplitudes in the in-plane directions
    Erroneous SCE claim that insufficient contact forces in Unit 3 Tube-to-AVB Gaps caused FEI
    MHI states, “By design, U-bend support in the in-plane direction was not provided for the SONGS SGs. In the design stage, MHI considered that the tube U-bend support in the out-of-plane direction designed for “zero” tube-to-AVB gap in hot condition was sufficient to prevent the tube from becoming fluid-elastic unstable during operation based on the MHI experiences and contemporary practice. MHI postulated that a “zero” gap in the hot condition does not necessarily ensure that the support is active and that contact force between the tube and the AVB is required for the support to be considered active. The most likely cause of the observed tube-to-tube wear is multiple consecutive AVB supports becoming inactive during operation. This is attributed to redistribution of the tube-to-AVB-gaps under the fluid hydrodynamic pressure exerted on the tubes during operation. This phenomenon is called by MHI, “tube bundle flowering” and is postulated to result in a spreading of the tube U-bends in the out-of-plane direction to varying degrees based on their location in the tube bundle (the hydrodynamic pressure varies within the U bend). This tube U-bend spreading causes an increase of the tube-to-AVB gap sizes and decrease of tube-to-AVB contact forces rendering the AVB supports inactive and potentially significantly contributing to tube FEI. AREVA states, “At 100% power, the thermal-hydraulic conditions in the U-bend region of the SONGS replacement steam generators exceeded the past successful operational envelope for U-bend nuclear steam generators based on presently available data.” AREVA states, “The primary source of tube-to-AVB contact forces is the restraint provided by the retaining bars and bridges, reacting against the component dimensional dispersion of the tubes and AVBs. Contact forces are available for both cold and hot conditions. Contact forces significantly increase at normal operating temperature and pressure due to diametric expansion of the tubes and thermal growth of the AVBs. After fluid elastic instability develops, the amplitude of in-plane motion continuously increases and the forces needed to prevent in-plane motion at any given AVB location become relatively large. Hence shortly after instability occurs, U-bends begin to swing in Mode 1 and overcome hindrance at any AVB location.” Westinghouse states, “Test data shows that the onset of IP vibration requires much higher velocities than the onset of out-of-plane (OP) fluid-elastic excitation. Hence, a tube that may vibrate in-plane (IP) would definitely be unstable OP. A small AVB gap that would be considered active in the OP mode would also be active in the IP mode because the small gap will prevent significant in-plane motion due to lack of clearance (gap) for the combined OP and IP motions. Thus, a contact force is not required to prevent significant IP motion.” SCE claims, “The facts identified in this analysis indicate that even though the Unit 3 tube bundle components (tubes and AVBs) might have been fabricated and assembled better, the tube “to” AVB gaps” built gaps might have been in fact larger in the Unit 3 RSGs as suggested by the ECT results. Based on this, it cannot be ruled out that the tube” to” AVB gaps are larger and more uniform in the Unit 3RSGs than the Unit 2RSGs. This might have resulted in reduction of the tube” to” AVB contact force and consequently in multiple consecutive AVB supports being inactive. Inactive tube support might have resulted in “tube-to-tube” wear. The DAB Safety Team concludes that SONGS Unit 3 RSGs were operating outside SONGS Technical Specification Limits for Reactor Thermal Power and Current Licensing Basis for Design Basis Accident Conditions. The DAB Safety Team further agrees with MHI that high steam flows and cross-flow velocities combined with narrow tube pitch-to-diameter ratio caused elastic deformation of the U-tube bundle from the beginning of the Unit 3 cycle, which initiated the process of tube-to-AVB wear and insufficient contact forces between tubes and AVBs. Tube bundle distortion is considered a major contributing cause to the mechanism of tube-to-tube/AVB/TSP wear seen in the Unit 3 SGs. After 11 months of wear, contact forces were virtually eliminated between the tube and AVBs in the areas of highest area of Unit 3 wear as confirmed by ECT and visual inspections. Therefore, based on a review of MHI, AREVA and Westinghouse documents, DAB Safety Team concludes that FEI and MHI Flowering effect redistributed the tube-to-AVB gaps in Unit 3 RSGs. It is DAB Safety team strong perception* that the SCE claims that insufficient contact forces in Unit 3 Tube-to-AVB Gaps “ALONE” caused tube” to” tube wear are misleading, erroneous and designed to put the blame on MHI for purposes of making SCE look good in public eyes of collecting insurance money for manufacturing defects.
    Irresponsible SCE claim that SONGS Unit 3 Damage (FEI) was caused due to outdated MHI Thermal-Hydraulic Computer Models
    NRC Chairman stated that SCE is responsible for work of its vendors and contractors. The real crux of the problem with the San Onofre Generators, Palmisano said, was the outdated mathematical model Mitsubishi used. There were mistakes in the parameters concerning the arrangement of the heat transfer tubes, Palmisano said. Mitsubishi typically makes generators with tube arrangements in a different shape than the tube arrangements in the San Onofre generators. Because of this, Mitsubishi engineers had to plug in a different batch of numbers to their equation – numbers that proved to be wrong, Palmisano said. The older formula also included mistaken assumptions about the nature of fluid elastic instability, Palmisano said, leading to a drastic underestimation of the amount of heat and pressure that would run through the tubes, and in turn, leading to the unprecedented vibration. According to NRC, SONGS did not specify the value of FEI in its Design and Performance Specifications SO23-617-1. MHI states, “The major concern with the large U-tube SGs is their propensity for tube wear in the tube bundle U-bend region. Consequently, minimizing tube wear was given the first priority in the SONGS RSG specification, design and fabrication, and the tube support design and fabrication was discussed by MHI and SCE in numerous design review meetings. The major concern with the large U-tube SGs is their propensity for tube wear in the tube bundle U-bend region. A SCE Engineer along with a MHI Technical Specialist claims in a joint paper published in an International Magazine, “SONGS steam generators are one of the largest in the industry, which called for innovative design solutions and improved fabrication processes when working on the RSGs. Conceivably, the MHI and Edison project teams faced many tough challenges throughout the entire project in the design, manufacturing and QC areas, when striving to meet the specification requirements. Both teams jointly tackled all these challenges in an effective and timely manner. At the end, MHI delivered the RSGs, which incorporated all the latest improvements found throughout the industry, as well as innovative solutions specific to the SONGS RSGs. In Unit 2, the RSGs were installed and tested in 2009/10 and in Unit 3 in 2010/11. The RSG post-installation test results met or exceeded the test acceptance criteria for all specified test parameters, thus properly rewarding the effort put into their fabrication.” Therefore, DAB Safety Team concludes that SCE claims as stated above were really not effective. SCE engineers did not check the work of MHI with a critical and questioning attitude and did not meet the 10CFR50, Appendix B, Quality assurance Standards and NRC Regulations. Fluid elastic instability is difficult to model using computer simulations and SCE did not do full-scale modeling of the new steam generator design. They also skipped full-scale hot testing after installing the new steam generators in 2010 and 2011. The SCE claims about MHI Thermal-Hydraulic Computer Modeling errors are misleading, erroneous and designed to put the blame on MHI for purposes of making SCE look good in public eyes of collecting insurance money for manufacturing defects.
    The Final Question – Is Unit 2 Safe at 70% power for 5 month operation
    DAB Safety Team has already answered this question previously in several papers listed on Page 2. DAB Safety Team Expert Panel will issue an unbiased detailed technical response in the near future to the Edison “November 30, 2012 – Public Meeting Presentation with the Nuclear Regulatory Commission Unit 2 Confirmatory Action Letter November 30, 2012” for the benefit of the His Excellency President Barack Obama, Southern Californians, NRC Chairman, NRC Atomic Licensing Board, NRC Staff, Senate Committee on Environment & Public Works, EIX/SCE Management, its vendors, contractors, employees and Union workers. The DAB Safety team will issue the following papers in the near future:
    • Evaluation of SCE Unit 2 Restart November 30 Public Meeting NRC Presentation
    • NRC Poor Public Perception and Future Expectations to meet President Obama’s and Senator Barbara Boxers Open Government Initiative and 100% Transparency to avoid Collusion with SCE to ensure the Safety of 8.4 Southern Californians and a Trillion Dollar ECODISASTER
    • SONGS Profit-Motivated, Production over Safety and Retaliating Senior Leadership Team
    • SONGS Fire Safety, Emergency Preparedness and Cyber Security Concerns
    • SONGS Worker Rights and Anonymous NNs
    The Final Answer – Is Unit 2 Safe at 70% power for 5 month operation – NO
    As DAB Safety Team have shown you (Based on the PVNGS Design and Academic Research Papers dating back 40 years) that higher steam pressures, low reactor thermal power, in-plane FEI protection, prevention of higher fluid velocities and adequate tube clearances are crucial to prevent the formation of localized steam dry-outs or regions of lower steam void fractions (98.5%) and determination of adequate tube clearances are the most fundamental and important design and operational parameters to prevent Fluid Elastic Instability (FEI) and flow-induced random vibrations. Higher steam void fractions also increase the effective steam-water mixture gap velocity, cross-flow fluid velocity, hydrodynamic pressures and decreases the damping capability of the anti-vibration structure.
    SONGS “As-Designed and Defective RSGs (aka Radiation Steaming Crucibles)” have no in-plane design FEI protection, extremely low tube clearances (some as low as 0.050 inches, Industry NORM – 0.35-0.55 inches), thousands of worn and fatigued tubes and a degraded AVB Structure. To save money and time, SCE in their rush to Restart Unit 2, has not inspected thousands of Unit 2 Steam Generator tubes with T/R single-pass array probes, laser-scanned penetrant inspection and ultrasonic detection technologies to accurately determine the depth, extent and location of these internal cracks at the U-bends and tube-support intersections and the clearances between these tubes. Furthermore, SCE has not made use of the world’s best remote video-inspection technology (which is not available in-house to, AREVA, Edison and MHI). In order to cut their costs and save time and choosing not to use this advanced technology using the most accurate remote visual and mechanical inspection techniques, Edison does not want to disclose to the public all the damage to the Unit 2 RSG tube bundles, the AVB structure and tube support plates. Fairewinds states, “A complete chemical analysis of a selection of individual tubes in each of the San Onofre reactors, conducted either by Southern California Edison or an independent outside team of consultants, is the only accurate engineering method available to ascertain if the tube failures are due to metallurgical problems or mechanical wear. If Edison is to accurately determine whether the problems at San Onofre are due to metallurgical insufficiencies or mechanical wear, orthodox engineering methodology requires that San Onofre technicians physically remove (pull) a selection of tubes and examine them. The U shape and long size of these tubes preclude replacement or repair, and therefore the hole from which they are removed must be plugged by welding the hole shut. In order to answer long-term reliability and safety concerns, the metallurgy of the tubes must be compared to the old design and fabrication. Moreover, tubes from both San Onofre Unit 2 and 3 must be removed and thoroughly examined in order to compare any subtle differences in fabrication between the two units.”
    Fairewinde States, “Unfortunately, progress on evaluating the extent of the problems at both San Onofre Units 2 and 3 has been slow, due in part to Edison’s purchase of only one set of the steam generator nozzle dams required for tube inspections. Steam generator nozzle dams prevent reactor water from leaking into the bottom of the steam generators when inspections are taking place. Consequently, when only one set of dams is available, both units cannot be simultaneously inspected. The decision to procure only one set of nozzle dams indicates a penny wise and pound foolish procurement policy that has made it technically impossible for Edison to simultaneously conduct these critical steam generator examinations of both San Onofre Units 2 and 3 without draining both vessels below their nozzles and limiting the movement of nuclear fuel in each reactor. Even though Unit 3 experienced a gross tube leak and Unit 2 did not, it is important to note that these inspections showed that more tubes in Unit 2 were degraded than in Unit 3. It is also important to note that both Unit 2 and Unit 3 were designed and manufactured to the same specifications. Since Unit 2 operated somewhat longer than Unit 3, it is not surprising that Unit 2 should exhibit more degradation than Unit 3 as well.”
    AREVA states, “Based on the extremely comprehensive evaluation of both Units, supplemented by thermal hydraulic and FIV analysis, assuming, a priori, that TTW via in-plane fluid-elastic instability cannot develop in Unit 2 would be inappropriate.” Therefore, all the degrades tubes subject fluid-elastic instability should be plugged, using the MHI Screening Criteria, which would exceed the NRC total plugging limitation and RIGHTFULLY PREVENT ANY RESTART of Unit 2!
    Westinghouse states, “For most of the straight leg section of the tube, the gap velocities at lower power levels and at 100% power are similar. The gap velocities are controlled by the recirculating fluid flow rate, which is relatively constant at all power levels.” Westinghouse is projecting the wear of 2 active tubes in SG 2E089 from 28% to be ~31% by the end of 5 months assuming everything goes as planned, without any transients or MSLB. In light of SONGS Unit 3 Operating experience, and to adequately protect the Public Health & Safety from a potential nuclear accident, the projection of this number based on empirical formulas and data derived from other plants/tests is highly questionable and does not meet the intent of Deterministic Analysis. Furthermore, this number ~31% is too close to the NRC’s plugging limit of 35%.
    According to AREVA and Fairewinds Associates, tube plugging and stabilization is not the solution to the vibration problems. FEI can progress through a buffer zone of plugged tubes to reach pressurized, in-service tubes and cable stabilizers do not substantially improve U-bend in-plane stability. The DAB Safety Team assisted by several SONGS Anonymous Insiders has concluded that SONGS Unit 2 Replacement Steam Generators (RSG) are in worse shape now than certified by the SCE and their three NEI Qualified, “U.S. Nuclear Plant Designers.”
    Professor Dan Hirsch States, “Unit 2 has hundreds of times more bad tubes and a thousand times more indications of wear on those tubes than the typical reactor in the country with a new steam generator, and nearly five times as many plugged tubes as the rest of the replacement steam generators, over a comparable operating period, in the country combined. Therefore, the restart of Unit 2 with thousands of degraded tubes present a formidable challenge to the Safe Restart of Unit 2 by making it highly vulnerable to localized steam dry-outs, 100% void fractions, fluid elastic instability, flow-induced random vibrations and cascading tube ruptures during unanticipated operational occurrences and or Main Steam Line Breaks. SCE is trying to Restart Unit 2’s Degraded RSG’s, which are outside the NORM of the NRC Regulations, which include a limit on operational primary-to-secondary leakage, typically 150 gallons per day, beyond which the plant must be promptly shutdown.
    In conclusion, even at 70% power operations, if a steam line break outside containment were to occur in Unit 2, the depressurization of the steam generators with the failure of a main steam isolation valve to close would result in 100% void fraction in the degraded U-Tube bundle and the straight leg portion between the Tube Support Plates. This condition of ZERO Water in the steam generators due to low tube clearances would cause fluid elastic instability (FEI) and flow-induced random vibrations, which would then result in massive cascading SG tube failures, involving hundreds of degraded active SG tubes, along with all the damaged inactive (all the plugged /stabilized) SG tubes. With an undetermined amount of simultaneous tube leaks/ruptures, approximately 60 tons of very hot high-pressure radioactive reactor coolant would leak into the secondary system. The release of this amount of radioactive primary coolant, along with an additional approximately 200 tons of steam in the first five minutes from a broken steam line would be EXCEED the SONGS NRC approved safety margins. So, in essence, the RSG’s will become loaded guns, or a nuclear accident waiting to happen. Any failure under these conditions, would allow significant amounts of radiation to escape to the atmosphere and a major nuclear accident would easily result causing much wider radiological consequences and even a potential nuclear meltdown of the reactor! Since these events would happen at an extremely fast pace, no credit is assumed in the first 5 minutes of the main steam line break accident for: (1) Enhanced Unit 2 Defense-In-Depth Actions – SCE Restart Plan Enclosure 2, Item 9.0, and (2) The differential pressure across the SG tubes necessary to cause a rupture will not occur if operators prevent RCS re-pressurization in accordance with their Emergency Operating – Enhanced Unit 2 Defense-In-Depth Actions – SCE Restart Plan Enclosure 2, Item 5.2.2 – Probabilistic Risk analysis.
    The Operational Assessments reports prepared by AREVA, and Westinghouse “conflict and contradict” with MHI’s Technical Report and Press Statements, on the causes and extent of degradation pertaining to the SONGS Unit 2 Steam Generator Replacement Generators. The DAB Safety Team Expert Panel and SONGS Concerned Insiders preliminary opinion are that these reports are not comprehensive and fail to arrive at a concise and clear conclusion, because:
    (1) SCE Engineers have either not provided, or they are withholding all the information to these parties because of “The consequences of being Wrong, Terminated or Fired”,
    (2) Due to competing and proprietary interests between the three NEI qualified, “US Nuclear Plant Designers”, these reports have not been openly and candidly discussed,
    (3) Time/Pressure exerted by SCE on these parties to prepare Operational Assessments in order to rush to Restart Unit 2 have led to incomplete conclusions,
    (4) Since nobody really knows, what really happened, all the Parties have a shared interest to “Operate Unit 2 at reduced power as a “Test Lab to conduct Nuclear Experiments “ to determine, “What really went wrong with unit 3, so SCE can determine the Root Cause, corrective actions, repair and test plans to return both units 2 and 3 to full power operations.”
    The Final FIX – Decommission SONGS Units 2/3, or Replace/Repair RSGs with a 50.90 thorough License Amendment Process and Evidentiary Public Hearings. According to DAB Safety Team conversation with one of the NRC Panel members, Senators Barbara Boxer and Diane Feinstein have told the NRC and are both in favor of Replacement or Adequate Inspections and Repairs of SONGS RSGs with a 50.90 thorough NRC License Amendment Process and Evidentiary Public Hearings.
    According to public sources, Pete Dietrich has already announced in internal SONGS staff meetings that Unit 2 will tentatively restart on February 1, 2013. If confirmed, this is stunning news for the public and gives the clear perception of collusion between NRC and SCE. TEPCO’s reported collusion with Japanese Regulators resulted in Fukushima Catastrophic Nuclear Accident (Trillion Dollar Japanese economic, public health and safety radiation nightmare, worker fatalities and environmental disaster).
    Public expects that NRC complies with President Barack Obama, Senator Barbara Boxer and NRC Chairman’s Open Government Initiative by using NRC Branch Chief’s advice and Reactor Oversight Process, when it audits SCE’s Licensing Basis Documents, facility procedures/records, 10 CFR 50.59 Safety Evaluations, Unit 2 Restart Documents and issues/approves Safety Evaluation, License Amendment Applications and Inspection Reports, Responses to Confirmatory Action Letters and other enforcement violations, as appropriate. NRC completes its mission of ensuring public safety with complete public respect, transparency and involvement by issuing all documents, emails, telephone records and holding open and trial-like thorough hearings without any time pressure from SCE, its vendors and contractors.
    helpallcqiascnp@yahoo.com
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  261. Courtesy Of DAB Safety Team
    Poor NRC Presentation Creates Doubts About Edison’s Ability To Perform Technical Restart
    PRESS RELEASE
    The DAB Safety Team: December 6, 2012
    SCE’s misleading and embarrassing technical presentation at their NRC public meeting when explaining fluid elastic instability in SONGS Unit 2, creates doubts about Edison’s ability to perform a safe restart of their damaged “Radiation Steaming Crucibles”.
    After spending almost a year, wasting hundreds of millions of dollars of rate payer’s money and hiring World’s Best Experts, Southern California Edison brought out SONGS Senior Vice President of Engineering, Tom Palmisano, on November 30, 2012 (Friday night) to give an intense technical presentation and a dazzling performance in a bid to convince the regulators they should be able to restart Unit 2 at the plant. However, Palmisano failed miserably to convince the DAB Safety Team, NRC Region IV Panel and the Public/Technical Experts, that Southern Californians will be safe from the effects of a potential nuclear radiological accident by the restart of Unit 2’s “Sick and Unsafe” Steam Generators by operating them at 70% power for a trial period of 5 months. When questioned by NRC Panel Members, the unprepared and uncomfortable Palmisano tasked with convincing the NRC, the Public and the News Media that Unit 2 is safe for restart “stumbled several times during the presentation”, then in response to the panel members questions for further technical details said sometimes irritatingly, “I will get back to you” and then finally “hesitantly” admitted, “SCE and MHI analysis are still not yet complete and will continue for several months for a detailed analysis and investigation to this problem.”
    Palmisano declared with his face beaming that tube-to-tube wear was caused “Most Likely” by in-plane vibrations (fluid elastic instability) in Unit 2 Steam Generator E-089 (U2SGE089). Two affected tubes in U2SGE089 with 14% wear depth were plugged and they preventatively plugged 321 tubes to conservatively add to the safety margin. It is astonishing and alarming to note that SCE’s Vice-President contradicted the World’s Leading and Pioneering Nuclear Plant Designer, Westinghouse Operational Assessment, which concluded, “ In-plane vibrations (fluid elastic) instability did not occur in U2SGE089 in two affected tubes. The tube-to-tube wear is most likely a result of out-of-plane vibrations (flow-induced random vibrations) of the two tubes in close proximity to the level of contact during operation.”
    The DAB Safety Team perception is that Palmisano is either pretending or really does not understand the Westinghouse Operational Assessment’s conclusions regarding the adverse effects of fluid elastic instability and flow-induced random vibrations, which caused the January 31, 2012, radioactive leak in one of the SONGS Unit 3’s brand new 680 million dollar replacement steam generators (RSG’s) reverse-engineered by the inexperienced SCE in-house engineers and manufactured at the direction of complacent Mitsubishi Heavy Industries. Southern Californians were very lucky, because a potentially serious nuclear accident in progress was stopped by an emergency shut down. 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 RSGs E-088 failed “in-situ” pressure testing and therefore were plugged, after only 11 months of operation. After that, several hundred Alloy 690 Thermally Treated tubes were also plugged due to tube-to-tube wear. SCE did not disclose intentionally to the public that one Unit 2 tube had also experienced a 90% through wall wear due to a MHI Manufacturing retainer bar defect. Southern Californians were once again very lucky that a serious nuclear accident was prevented by a planned refueling shut down. SONGS RSG’s now have more damaged and/or plugged tubes than all the rest of the US reactor fleet combined. Based on analysis of NRC AIT Report and SONGS Procedures, Operational Data, Plant Daily Briefing Sheets, Engineering Calculations and conversations with Plant Personnel, the DAB Safety Team disagrees with SCE and confirms Westinghouse Operational Assessment conclusions that fluid elastic instability did not occur in Unit 2 Steam Generator E-089. The DAB Safety Team discussions with two of the NRC Panel Members gives us the perception that the NRC panel Members disagree amongst themselves and also with SCE on the effect of operational parameters on fluid elastic instability in Unit 2 Steam Generator E-089.
    The inexperienced and complacent SCE Engineers in a rush to make profits for SCE Officers and Shareholders ignored: (a) CPUC advice on applying to NRC for increased plugging limit to extend the life of Original Steam Generators, and (b) SDG&E opposition to the wisdom and viability of the RSG Project. Although SCE was a shareholder in PVNGSs, the SCE Engineers due to time pressure and complacency did a very poor job of Benchmarking, (a) Especially of PVNGS on the new fabrication techniques and design to prevent the adverse effects of fluid elastic instability (FEI) and flow-induced turbulent and random vibrations (FIRV), and (b) Did not keep up with the research of World’s Foremost Expert and other academic scholars to prevent the adverse effects of FEI and FIRV, prepared a defective 10 CFR 50.59 Evaluation and made numerous untested and unanalyzed design changes under the pretense of like-for-like to avoid lengthy and evidentiary public hearings and thorough NRC 50.90 Amendment. If Edison had informed the NRC that the new steam generators were not like-for-like, the more thorough NRC licensing review process would have hopefully identified the design problems before the steam generators were manufactured. The unauthorized and untested design changes made by SCE Engineers to extract more heat and make more money for SCE shareholders from the RSG’s (1729 MWt) compared with the OSG’s (1705 MWt) destroyed the brand new 680 million RSG’s. [Please see DAB Safety Team Papers, “The Big Number 1 Attachment Notes” & “SONGS Insider Secret)
    Based on a review of MHI, AREVA and Westinghouse documents, the DAB Safety Team concludes that FEI and MHI Flowering effect redistributed the tube-to-AVB gaps in Unit 3 RSGs. It is the DAB Safety team’s strong perception that SCE claims that insufficient contact forces in Unit 3 Tube-to-AVB Gaps “ALONE” caused tube to tube wear are misleading, erroneous, egregious, and designed to put the blame on MHI for purposes of making SCE look good in the public eye so they can collect insurance money for their own design defects.
    The NRC Chairman stated that SCE is responsible for the work of its vendors and contractors. The real crux of the problem with the San Onofre Generators, Palmisano said, was the outdated mathematical model Mitsubishi used. There were mistakes in the parameters concerning the arrangement of the heat transfer tubes, Palmisano said. MHI States, “Minimizing tube wear was given the first priority in the SONGS RSG specification, design and fabrication, and the tube support design and fabrication was discussed by MHI and SCE in numerous design review meetings.” A SCE Engineer along with a MHI Technical Specialist claims in a joint paper published in an International Magazine, “SONGS steam generators are one of the largest in the industry, which called for innovative design solutions and improved fabrication processes when working on the RSG’s. Conceivably, the MHI and Edison project teams faced many tough challenges throughout the entire project in the design, manufacturing and QC areas, when striving to meet the specification requirements. Both teams jointly tackled all these challenges in an effective and timely manner. At the end, MHI delivered the RSG’s, which incorporated all the latest improvements found throughout the industry, as well as innovative solutions specific to the SONGS RSG’s. In Unit 2, the RSG’s were installed and tested in 2009/10 and in Unit 3 in 2010/11. The RSG post-installation test results met or exceeded the test acceptance criteria for all specified test parameters, thus properly rewarding the effort put into their fabrication.” Therefore, the DAB Safety Team concludes that SCE engineers did not check the work of MHI with a critical and questioning attitude and did not meet the 10CFR50, Appendix B, Quality Assurance Standards, the NRC Chairman’s Expectations and or NRC Regulations. The SCE claims about MHI Thermal-Hydraulic Computer Modeling errors are misleading, erroneous and designed to absolve SCE of all the mistakes and put the blame on MHI for purposes of collecting insurance money for using outdated computer codes and to appear blameless themselves before the public.
    A NRC Branch Chief gifted with MIT Intelligence, Intuition and a Sixth Sense said, “Sir, to resolve any complex technical problem and understand unclear regulations, you have to, ‘Read and reread in between the lines’, use, ‘Critical questioning and an investigative attitude’ and ‘Solid Teamwork & Alignment.” That NRC Chief, if you asked him about the restart of SONGS Unit 2 “As-Designed and Defective RSGs (aka Radiation Steaming Crucibles)” will say, “In Emergency Planning Space, decisions have to be Accurate and Timely. Under-conservative, rushed and profit-motivated analyses based on limited facts, biased and ambiguous operational data, untested deterministic and probabilistic risk analysis, conflicting theories and differing operational assessments of degraded equipment at even reduced power operations for 150 days with conditional monitoring along with unproven and unreliable compensatory and operator actions represent enormous risks to public health and safety, the environment and Southern California’s economy.”
    Unit 2 has hundreds of times more bad tubes and a thousand times more indications of wear on those tubes than any typical reactor in the country with a new steam generator, and nearly five times as many plugged tubes as the rest of the replacement steam generators in the country combined, over a comparable operating period. Therefore, thousands of degraded tubes present a formidable challenge to the Safe Restart of Unit 2 by making it highly vulnerable to localized steam dry-outs, 100% void fractions, fluid elastic instability, flow-induced random vibrations and cascading tube ruptures during unanticipated operational occurrences and/or Main Steam Line Breaks.
    Even at 70% power operations, if a steam line break outside containment were to occur in Unit 2, the depressurization of the steam generators with the failure of a main steam isolation valve to close would result in 100% void fraction in the degraded U-Tube bundle and the straight leg portion between the Tube Support Plates. This condition of ZERO Water in the steam generators due to low tube clearances would cause fluid elastic instability (FEI) and flow-induced random vibrations, which in all likelihood would then result in massive cascading SG tube failures, involving hundreds of degraded active SG tubes, along with all the damaged inactive (all the plugged /stabilized) SG tubes. With an undetermined amount of simultaneous tube leaks/ruptures, approximately 60 tons of very hot high-pressure radioactive reactor coolant would leak into the secondary system. The release of this amount of radioactive primary coolant, along with an additional approximately 200 tons of steam in the first five minutes from a broken steam line would EXCEED the SONGS NRC approved safety margins. So, in essence, the RSG’s are loaded guns, or a nuclear accident waiting to happen. Any failure under these conditions would allow significant amounts of radiation to escape to the atmosphere and a major Loss Of Coolant Accident (LOCA) could easily result causing much wider radiological consequences and even a potential nuclear meltdown of the reactor! Since these events would happen at an extremely fast pace, no credit is assumed in the first 5 minutes of the main steam line break accident for: (1) Enhanced Unit 2 Defense-In-Depth Actions – SCE Restart Plan Enclosure 2, Item 9.0, and (2) The differential pressure across the SG tubes necessary to cause a rupture will not occur if operators prevent RCS re-pressurization in accordance with their Emergency Operating – Enhanced Unit 2 Defense-In-Depth Actions – SCE Restart Plan Enclosure 2, Item 5.2,2, Probabilistic Risk analysis.
    The Final Question – Is Unit 2 Safe At 70% Power For 5 Months Of Operation?
    The Answer Is NO.
    SCE is trying to restart their Unit 2’s degraded RSG’s, which are outside the NORM of the NRC Regulations. The DAB Safety Team has already answered this question previously in their San Onofre Papers posted on the web.
    The DAB Safety Team Expert Panel will issue an unbiased detailed technical response in the near future to Edison’s “November 30, 2012 – Public Meeting Presentation with the Nuclear Regulatory Commission Unit 2 Confirmatory Action Letter November 30, 2012” for the benefit of President Barack Obama, Southern Californians, the NRC Chairman, the NRC Atomic Licensing Board, the NRC Staff, the Senate Committee on Environment & Public Works, EIX/SCE Management, its vendors, contractors, employees and Union workers. The DAB Safety team will issue the following papers in the near future:
    • Evaluation of SCE Unit 2 Restart November 30 Public Meeting NRC Presentation
    • NRC Poor Public Perception and Future Expectations to meet President Obama’s and Senator Barbara Boxers Open Government Initiative and 100% Transparency to avoid Collusion with SCE to ensure the Safety of 8.4 Southern Californians and a Trillion Dollar ECODISASTER
    • SONGS Profit-Motivated, Production over Safety and Retaliating Senior Leadership Team
    • SONGS Fire Safety, Emergency Preparedness and Cyber Security Concerns
    • SONGS Worker Rights and Anonymous NNs
    The Final Fix – Decommission both SONGS Units 2 and 3, or replace them using a 50.90 thorough License Amendment Process and Evidentiary Public Hearings. According to the DAB Safety Team’s conversation with one of the NRC Panel members, Senators Barbara Boxer and Diane Feinstein have told the NRC that both of them are in favor of Replacement or adequate inspections and repairs of SONGS RSG’s along with a 50.90 thorough NRC License Amendment Process and Evidentiary Public Hearings.
    According to public sources, Pete Dietrich has already announced in internal SONGS staff meetings that Unit 2 will tentatively restart on February 2, 2013. If confirmed, this is stunning news for the public and gives the clear perception of collusion between the NRC and SCE. TEPCO’s reported collusion with Japanese Regulators resulted in Fukushima’s catastrophic nuclear accident (a Trillion Dollar Japanese economic, public health & safety radiation nightmare and Eco-Disaster).
    The public expects that the NRC complies with President Barack Obama, Senator Barbara Boxer and the NRC Chairman’s Open Government Initiative by using the NRC Branch Chief’s advice and Reactor Oversight Process, when it audits SCE’s Licensing Basis Documents, facility procedures/records, 10 CFR 50.59 Safety Evaluations, Unit 2 Restart Documents and issues/approves Safety Evaluation, License Amendment Applications and Inspection Reports, Responses to Confirmatory Action Letters and other enforcement violations, as appropriate. The NRC should complete its mission of ensuring public safety with complete public respect, transparency and involvement by issuing all documents, emails, telephone records and holding open and trial-like thorough hearings without any time pressure from SCE, its vendors and contractors.
    The position that San Onofre’s “As designed and defective” replacement steam generators (aka radiation steaming crucibles) without replacement or adequate repairs (replacement of tube bundle and anti-vibration supports) are unsafe and fail to meet the Steam Generator Fundamental Tube Integrity Criteria for a Main Steam Line Break Accident is consistent with the recommendations earlier made on this subject by:
    • Arnie Gundersen and his team of anonymous steam generator experts
    • Professor Dan Hirsch
    • Dale Bridgenbaugh (Retired professional nuclear engineer),
    • Union of Concerned Scientist (David Lochbaum, Director of Safety)
    • The DAB Safety Team Panel’s of several SONGS insiders root cause and operation experts
    • Other anonymous steam generator and thermal-hydraulic experts, and
    • Retired NRC Experts
    Copyright December 5, 2012 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 Attorneys.
    helpallcqiascnp@yahoo.com
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  262. Coming up – Harassment, Retaliation, Discrimination, Intimidation and Insult of a Injured worker by SCE for reporting fire/safety, cyber security and steam generator concerns – This will put every US government agency to shame for protecting worker rights in the most powerful, rich and democratic country in the world.
    E Mail to White House Website
    When a powerful corporation and their attorneys are trying to block all the doors of Government Agencies trying to help the case of a Harassment, Discrimination, Retaliation & intimidation of an Injured Minority Professional Engineer in a Democratic Society led by His Excellency Barack Obama, The Greatest People’s President and the Mightiest Man on Planet Earth, who should this person appeal to for justice. Can You Please help and advise.
    Sincerely
    Good Bless His Excellency and His Family
    helpallcqiascnp@yahoo.com

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  263. US is worried about human right violations in China and Iran, How about human rights retailation for expressing Nuclear Safety Concerns by SCE at San Onofre, Does not look good for NRC? Mystery gets even deeper, because I know it First Hand.. Let me get all my files… Sincerely Help All Hurt Never Baba

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  264. A NRC Branch Chief gifted with MIT Intelligence, Intuition and a Sixth Sense, who is an acquantaince of mine, said to an anonymous participant at an Industry Conference, “Sir, to resolve any complex technical problem and understand unclear regulations, you have to, ‘Read and reread in between the lines’, use, ‘Critical questioning and an investigative attitude’ and ‘Solid Teamwork & Alignment.”
    NRC AIT Report, SCE Cause Evaluation, MHI Technical Document, AREVA and Westinghouse Operational Assessments failed to explain why Unit 2 suffered less damage than Unit 3. Here ia an excerpt from one of the DAB Safety Team Reports, “Damage to SONGS Unit 2 RSGS: The DAB Safety Team Analysis further shows that: (1) Compared with Unit 3, lower secondary side mass flow and reactor thermal power 1729 MWt (0.5% error) per/RSG at 100% power produced higher than normal fluid velocities in the tube bundle region and straight portion of the tube-leg sections in Unit 2 where the Tube-AVB/TSP wear was observed, (2) Secondary side higher pressure (863-942 psi) at 100% power produced lower void fractions < 98.5 in the Unit 2 tube bundle region where no tube-tube wear was observed. Higher (98.5%) than typical (96%) void fraction in Unit 2 is a result of a very large (tall) and tightly packed tube bundle, particularly in the U-bend, with high heat flux in the hot leg side."

    What DAB Safety Team is saying that Unit 2 did not experience FEI in 22 months of operators because of higher steam pressures and lower reactor thermal power. According to SONGS Insider Anonymous Operations Staff, SCE Engineers believed that Unit 3 RSGs AVBs were built with better toelerances and closer gaps than Unit 2. SCE Engineers were running to test Unit 3 RSGs at 833 psi and 1739 MWt thermal power for 11 months, but because of low tube clearances in the high region of wear some as small as 0.050 inches and hot high flux, and taller than normal normal tube bundle created higher fluid velocities of 28 feet/second, void fraction of 99.6%, hydrodynamic pressures in excess of 4200 (units ?) and Mitsubishi Flowering Effect, This adverse phenomena in turn created in-plane fluid elastic instability, excessive and violent flow-induced random out-of-plane random vibrations and large amplitudes of low-resonance retainer bars. This whole thing in turn damaged thousands of tubes, tube support plates, created insufficient contact forces between tubes-AVBs and 8 failed tubes at MSLB Conditions. What I am saying is that SCE Engineers are NOT coming out with
    full facts and Telling NRC and others all the details because of the fear being retailiated, fired, insulted or terminated. NRC in order to maintaiin their Charter of Public Safety and be in compliance with His Excellency President Obama, United States Congress and Respected NRC Branch Chief's Policies, need to review these Restart Documents very carefully, with a critical questioning and investigative attitude and interview these engineers (SCE, MHI, AREVA, Westinghouse) under oath with some kind of a protection clause. It is time for NRC to Restore their honor and integrity by working with and not pushing the public, which pays NRC's Bills, Thanks

    helpallcqiascnp@yahoo.com

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  265. Please do not forget that 8 tubes failed in Unit 3 at MSLB test conditions. Power plants spend hundred of million dollars in pipe whip restraints for protection of safety-related equipment from high energy line and main steam line breaks. Steam line breaks have occured at Robinson, Turkey Point and Mihama. MSLB outside the containment at the first weld with MSIV failure to close is a design basis accident, which can occur at any time during normal plant operations. With the depressurization of the faulted steam generator, U-tubes bundle and entire generator will be full of steam causing fluid elastic instability, flow-induced randow vibrations, distortion of the U-Tube bundle due to excessive hydrodynamic vibrations and MHI flowering effect and movement of low frequency retainer bars with large amplitudes. With no-in-plane protection, low tube clearances as low as 0.050 inches, degraded AVBs, distorted TSPs, hundreds of worn, plugged and stabilized tubes will hit each other with much more impact than witnessed in Unit 3 U-tubes with 8 tube failures at MSLB conditions. All it takes couple of tubes to leak or rupture and you will see a repeat of Mihama Unit 2 Accident with only 1 SG tube rupture, a Level 3 Nuclear incident in Japan in 1991. SCE wants to make money and People of SOCAL are not ready to witness a nuclear accident. SG tube integrity criteria call for a low probability of leakage or gross rupture as a design condition, which is not the case with SONGS 2. SCE needs to go through a full 50.90 License amendment and trial like hearing. One small leakage will wipe out SCE politically, finacially and leave a bad public perception for the NRC and rest of the nuclear industry. Rrunning at 70% does not make political, economical or safety sense. If SCE want to run these Defective Radiation Steam Crucibles, they have to give a turn-key contact to Westinghouse to rebuild these sick generators just like palo-verde steam generators with wider tube clearances, support system to prevent fluid elastic instability, flow-induced random vibrations and localized steam dry-out and a 50.90 license amendment process with extensive public hearings. SCE, NRC, AREVA, MHI and Westinghouse have not explained the precise reasons why Unit 2 did not experience fluid elastic instability. SCE know the reasons but do not want to publicly admit it to loose whatever little Credidibility they have.
    That was a good question, it is not a matter of making money but public safety. I know SONGS like the back of my hand including all the management, steam generator design engineers, root cause members, high energy specialists, operations,trainers and shift managers. Some of these people are very nervous and concerned because i talked to them everday as a part of my job. Let us keep talking…. Have a great day Sir– Life is a unique opportunity to serve the Society

    helpallcqiascnp@yahoo.com

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  266. Coutsey Of DAB Safety Team
    Life is a “Unique Opportunity” Provided by “The CREATOR” to serve the Society
    SONGS Anonymous Concerned Worker and Pair of Two Shoes
    This SONGS Long-Time Dedicated Worker wanted to go to an Industry Conference at his own expense and using his vacation. The purpose of his visit was so he could help improve the Company Management’s performance with the new industry information, he received at the Conference.
    His Supervisor’s were not approving his repeated requests for vacation because they were afraid that he may disclose the insider secrets to others at the Conference for the Company’s Lagging and Chronic Worst Safety Record and Management’s Retaliation of Workers for expressing Nuclear Safety Concerns. So this worker went to the One of the Company’s TOP Bosses and told him his concerns and this story,” Sir, when I was in College, I went to visit my father, who was a Top Executive with the Government. My father was on a temporary assignment on a Large Government Farm with thousand of workers reporting to him. My father’s assignment was ending, so we were waiting for a Train to take us back home. But the train tracks were blocked by thousands of Farm Workers. So when I enquired, the Farm Workers said, ’Sir, We do not want this “Kind Officer” to leave because he fought with the Central Government and got us 2 pair of shoes. The Workers said, ’We have been working on this farm all our lives without shoes and our feet get “cut and bleed” from stones and other sharp objects working in the farm. We are thankful that this Officer went, because he went out of his way, put his job on the line and got us these pair of shoes with a “Great Smile” without expecting any, ”Raises, Rewards or Recognition” in Return.”
    So the concerned worker told the TOP Boss, “Sir, I have tripped many times and have hurt my toes. I am very thankful to the Company for providing me a Free ‘Pair of Steel Toed Shoes.’ Now I can perform my job and walk anywhere in the Plant without any fear of hurting “My Toes. I have been working here a long time. I work long hours, including weekends and from home without charging any overtime to the Company. Like my father, I provide these services with a “Great Smile” without expecting any ‘Raises, Rewards or Recognition” in Return.’ Sir, can you please help me and tell these Supervisor’s to approve my Vacation. The end result was ‘No Action’ and the Worker lost his money on Air Line Tickets, was insulted, intimidated and retaliated by his Supervisors because the Worker went to the Top Boss for help against their wishes.”
    SONGS was an INPO Plant 1 in 1998 and a beautiful place to work. The workers were always smiling, relaxed and used to greet each other at lunch and take a walk on the Beach. The workers will often say, “What a Great Place to work, get paid, go home safe and happy to your family.” In 2012, SONGS is an INPO 4 Plant with the Worst Safety, Maintenance and Worker Retaliation Record.” On top of that, SONGS Senior Management Team and Engineers are being accused of wasting 600 Million Dollars of Ratepayers Money on Replacement Steam Generators and telling lies to NRC, CPUC, News Media and Public. Like an Old Plant Operator Says, “The working conditions are chaotic and horrible at SONGS and some of these ‘Money Hungry Tigers’ Senior Management Team Leaders have turned this place into a ‘Federal Nuclear Prison.” NRC, SONGS Employee Concerns and Human Resource Departments are unable to stop these “Money Hungry Tigers’ and ‘Lawless Mob’ from using these “Unlawful Tactics.”
    Copyright October 27, 2012 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 the DAB Safety Team’s Leader and/or DAB Safety Team’s Attorneys.

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  267. PENDING PRESS RELEASE, Subject to Editorial Changes
    The DAB Safety Team: November 28, 2012
    SONGS Insider Secrets: Mystery behind Destruction of SONGS Unit 3 Replacement Steam Generators (RSGs) and limited Damage to Unit 2 RSGs
    Quote No 1: A NRC Branch Chief gifted with MIT Intelligence, Intuition and a Sixth Sense said to an anonymous participant at an Industry Conference, “Sir, to resolve any complex technical problem and understand unclear regulations, you have to, ‘Read and reread in between the lines’, use, ‘Critical questioning and an investigative attitude’ and ‘Solid Teamwork & Alignment.”
    Quote No 2: Insanity: doing the same thing over and over again and expecting different results. Albert Einstein
    Quote No 3: SCE is ultimately responsible for the work done by their vendors and contractors. NRC Chairman Allison Macfarlane
    Quote No 4: Running the reactor at a 30 percent reduction in power may not fix the problems but rather make them worse or shift the damage to another part of the generators. It’s a real gamble to restart either unit without undertaking repairs or replacing the damaged equipment. Arnie Gundersen
    Quote No 5: Both San Onofre units will remain shut down until repairs are made and we and the Nuclear Regulatory Commission are satisfied it is safe to operate. Pete Dietrich
    Quote No 6: AREVA States, “The nominal distance between extrados and intrados locations of neighboring U-bends in the same plane ranges from 0.25 inches to 0.325 inches due to the tube indexing. There are 36 U-bends in Unit 2 SG E-088 and 34 in SG E-089 with a separation less than or equal to 0.050 inches. The U-bends with the smaller separation distances are much better candidates for wear by rubbing yet do not exhibit TTW.” Based on SONGS 3 experience, this behavior can change because of plugged/staked tubes due to shifting of localized steam-dry out regions in the hot leg U-Tube Bundle region of these U-bends with these extremely low clearances. These extremely low clearances can cause very high steam velocities, which can result in fluid elastic instability during the 150-day proposed test operating period even at reduced power levels and higher steam pressures. Nobody has reported another potential accident in Unit 2, which was averted because one tube had experienced a loss of 90% percent of its wall thickness, while the plugging limit is 35%. Fortunately, Unit 2 was shutdown for refueling before the tube had a chance to leak like Unit 3. Too many guesses, probabilities built around thin safety margins and unknown conditions, another potential nuclear accident without MSLB? Production over Safety
    Mystery behind Destruction of SONGS Unit 3 Replacement Steam Generators (RSGs) and limited Damage to Unit 2 RSGs: At lower steam pressures (~ 833 psi), steam-water mixture has a saturation temperature of 5230F and more internal energy (1198.2 Btu/lb.) compared with higher steam pressure (~ 942 psi), steam-water mixture has saturation temperature of 537.50F and less internal energy (1194.7 Btu/lb.). Therefore, you can get more juice (more Megawatts) out of the steam generator at lower steam pressure, if you supply more reactor thermal power to the steam generator tubes from the reactor. Lower steam pressures combined with high reactor thermal power, high steam velocities and narrow tube clearances also promote localized steam dry-out regions (Vapor fraction >99%) in the hot leg side of the U-Tube bundle, which cause fluid elastic instability, flow-induced random and severe vibrations, and excessive hydrodynamic pressures (aka Mitsubishi Flowering Effect). These adverse effects in turn cause excessive tube-to-tube wears leading to cascading tube leakages/ruptures, increased tube clearances and tube-to-AVB gaps, and deformation of anti-vibration bar structure. Tube-tube/AVB wear and deformation (aka Mitsubishi Flowering Effect) of especially a floating anti-vibration bar structure without structural beams and lateral/mid span supports causes redistribution of tube-to-tube/AVB gaps and clearances, when the steam generator reverts back from hot operating to cold conditions. This redistribution of gaps can lead to differences in measurements during steam generator refueling inspections compared with the original manufacturing/design gaps in the cold condition and can lead to wrong projections and misleading conclusions regarding last and future cycles operating conditions.

    The original SONGS CE Model 3410 steam generators (OSGs) were rated for 1705 MWt reactor thermal power. Over the years of operation of the SONGS OSGs, it became evident that the steam generator tubes, made predominantly of Alloy 600, were susceptible to primary water stress corrosion cracking (PWSSC). This corrosion mechanism was resulting in tube degradation necessitating plugging large numbers of tubes after each inspection of the tubing. In addition, the SONGS OSGs design had shown to be susceptible to tube through-wall wear and severe corrosion of the tube supports. Continuing to operate with these highly degraded steam generators involved substantial economic risks from forced outages, extended refueling outages, as well as the direct costs of inspections and repairs. SCE’s bid specification required that the stay cylinder feature of the original steam generators be eliminated to maximize the number of tubes that could be installed in the replacement steam generators and to mitigate past problems with tube wear at tube supports caused by relatively cool water and high flow velocities in the central part of the tube bundle. Mitsubishi employed broached trefoil tube support plates instead of the egg crate supports in the original design. In addition to providing for better control of tube to support plate gaps and easier assembly, the broached tube support plates were intended to address past problems with the egg crate supports by providing less line of contact and faster flow between the tubes and support plates, reducing the potential for deposit buildup and corrosion. Mitsubishi selected a u-bend configuration for the upper part of the tube bundle instead of the square bend design of the original steam generators based on its experience that u-bends were easier to fabricate and support and were easier to inspect.

    The original steam generators installed throughout the domestic fleet of pressurized
    water reactors, including SONGS, experienced widespread corrosion of the tubes and
    tube support plates, stress corrosion cracking of the tubes, and wear at tube supports.
    These problems led to the replacement of nearly all of the original steam generators, in
    most cases well before the end of their design lifetime. For SONGS, the design of the
    replacement steam generators included a number of design changes to correct life
    limiting problems with the original steam generators, based in part on consideration of
    SONGS-specific and industry-wide operating experience. This included use of more
    corrosion resistant materials for the tubing and tube support plates to mitigate corrosion. The tubes in the new Replacement Steam Generators (RSGs) were fabricated with thermally treated Alloy 690, which has superior corrosion resistance. The only drawback the new Alloy 690 has, is that it has a 10% less thermal conductivity/heat transfer rate compared with old tube alloy 600.

    Therefore, to achieve the thermal output of 1729 MWt from the new RSGs as approved by the NRC in 2001 SONGS Power Uprate Application, SCE engineers needed to install 11% more tubes in the new RSGs. By removal of the stay cylinder from the OSGs, there was enough space to add only 4% (377) more tubes. Since there was no room to add the additional 7% tubes, SCE increased the length of each tube in the U-Tube Bundle (Outside the Industry NORM and partially responsible for Mitsubishi Flowering effect) by more than 7 inches to obtain 1729 MWt out of the RSGs. The Unit 2 RSGs were built with bigger tube-to-AVB Gaps and no in-plane protection from vibrations caused by potential fluid elastic instability conditions, because the OSGs did not experience that phenomena.

    Based on information from anonymous SONGS operations and root cause team concerned insiders, a cursory review of plant records (plant procedures, system descriptions and plant daily briefing sheets), engineering calculations performed using SONGS procedures and review of NRC AIT Report, SCE Operators were running Unit 2 RSGs at higher steam pressures (~ 863-942 psi) and lower reactor thermal power (1715-1725 MWt) for almost 22 months with no reported and detected abnormality (6 tubes with 28 to 90 percent wear of the tube wall thickness due to retainer bar vibrations). Because of the short measured lengths of these flaws, only the 90 percent indication was in-situ pressure tested as part of condition monitoring. The affected tube was successfully pressurized to 5300 psi with no leakage (Southern Californians saved from another nuclear accident).

    The Unit 3 SG manufacturing process used more accurate and tighter tolerances, which improved tube-to-AVB alignment such that tubes had more contact forces with AVB’s and provided an effective “zero” tube-to-AVB gap under operating (hot) conditions. According to trusted SONGS operation insiders, SCE Engineers were convinced that Unit 3 RSGs were built better than Unit 2 RSGs in terms of providing in-plane protection due to better control of tube-to-AVB gap. Therefore, SCE Engineers decide to operate Unit 3 RSGs at lower steam pressures (~833 psi) to get more juice (more Megawatts) out of the RSGs by supplying more reactor thermal power (~1729 -1739 MWt) to the RSGs tubes from the Unit 3 reactor. This was unfortunately the biggest miscalculation. What happened next you all know, because of the low steam pressures (~833 psi), combined with low tube clearances (SONGS Design – 0.250 inches, some found as low as 0.050 inches) and no effective in-plane tube support protection, the high reactor power resulted in fluid elastic instability, flow-induced random vibrations, excessive hydrodynamic pressures and localized steam dry-out regions (vapor fraction >99.6%) resulted in destruction of SONGS Unit 3 RSGs (1 tube leak, 8 tubes failures at MSLB conditions, 1800 tubes with tube-to-tube /anti-vibrations bars/support plates wear – unprecedented damage in the history of US Operating Nuclear fleet). Fluid elastic instability and Mitsubishi Flowering Effects increased the tube-to-AVB gaps, decreased tube-to-tube clearances and created lower and insufficient contact forces in Unit 3, which were described inaccurately by NRC and SCE as a MHI manufacturing defect due to political and financial reasons. After 22 months of operation the severity of wear in Unit 2 was determined to be similar to that experienced by Unit 3 after 11 months of operation. The worst case steam generator in Unit 2 had about 2600 wear indications at AVBs compared about 3400 wear indications in Unit 3. Without an effective in-plane support system, these high fluid velocities and localized steam dry-out regions resulted in very large or uncontrolled vibrations (amplitudes) of tubes in the-in-plane direction and caused fluid elastic instability, flow-induced random vibrations, excessive hydrodynamic pressures and increased tube-to-AVB gaps and created insufficient contact forces in Unit 3.

    High steam pressures (~863-933 psi) and lower reactor thermal power (1715-1725 MWt), coupled with low tube clearances and no in-plane tube support design accompanied with high steam flows and velocities caused flow-induced random vibrations and excessive hydrodynamic pressures, which resulted in SONGS Unit 2 RSGs damage (high tube-to-anti-vibrations bars/support plates wear). Since the steam pressures were high, fortunately void fractions were less than 98.5% and no fluid elastic instability occurred in Unit 2, which is consistent with the Westinghouse Finding. NRC, AREVA, Westinghouse, MHI and SCE missed this key operational observation in the NRC AIT Report, SCE Unit 3 Root Cause Evaluation and SCE Unit 2 restart Plan. MHI indirectly alluded to this fact in their technical report but did not say it publicly for reasons unknown to the DAB Safety Team or perhaps being afraid of backlash from SCE and NRC. At least one person working at SONGS discussed this fact about operational differences with other personnel between Units 2 and 3, but nobody listened to him. His findings were intentionally or unintentionally ignored because everybody in SCE was focused on blaming MHI to recover the insurance money and/or absolving themselves of all blame. DAB Safety Team is sure that MHI will pursue this fact during arbitration proceeding to absolve them of this blame and protect their reputation.

    Public Expectations: Public expects that NRC complies with President Barack Obama, Senator Barbara Boxer and NRC Chairman’s Open Government Initiative by using NRC Branch Chief’s advice and Reactor Oversight Process, when it audits SCE’s Licensing Basis Documents, facility procedures/records, 10 CFR 50.59 Safety Evaluations, Unit 2 Restart Documents and issues/approves Safety Evaluation, License Amendment Applications and Inspection Reports, Responses to Confirmatory Action Letters and other enforcement violations, as appropriate. NRC completes its mission of ensuring public safety with complete public respect, transparency and involvement by issuing all documents, emails, telephone records and holding open and trial-like thorough hearings without any time pressure from SCE, its vendors and contractors.
     
    Questions which must be answered by NRC and SCE prior to Unit 2 restart: The questions, which NRC in its 95 page AIT Report the SCE and its vendors in their 1200 page San Onofre Nuclear Generating Station Unit 2 Return to Service Report have not answered completely, convincingly and unanimously are as follows:
    (1) Whether fluid elastic instability occurred, occurred for a limited time or did not occur at all in the SONGS Unit 2 Steam Generator Replacement Generators (RSGs)?
    (2) What was the contribution of fluid elastic instability and “Mitsubishi flowering effect” in increasing the Unit 3 Tube-to-AVB gaps, which were built better than Unit 2 and designed to provide an effective “zero” tube-to-AVB gap under operating (hot) conditions?
    (3) How come the SONGS RSGs were specified, designed and fabricated as comparable replacements on a like-for-like basis for the original steam generators in terms of fit, form and function with numerous untested and unanalyzed design changes under the 10CFR50.59 rule?
    (4) Were these numerous untested and unanalyzed design changes responsible for damage to SONGS RSGs?
    (5) Were SONGS RSGs operating beyond their design basis or Industry NORMs and how did it impact degradation of RSGs?
    (6) Is this the fault of SCE’s in-house design team, their Performance Specifications coupled with their numerous design changes and or the MHI Fabrication/Testing Technology combined with Faulty Thermal-Hydraulic Computer Codes, which caused unprecedented damage to SONGS RSGs?
    (7) Are the Unit 2 RSGs qualified in the “As-designed and Degraded Condition” for a MSLB or other Anticipated Operational transients?

    The DAB Safety Team and the Public expects that SCE and their three NEI Qualified, “US Nuclear Power Plant Designers”, Westinghouse, AREVA and MHI would revise their reports and arrive at a concise and clear answer (meeting the NRC Quality Assurance requirements as stated by NRC Chairman Allison Macfarlane) to these puzzling public safety questions in the Unit 2 Return to Service Report.

    SONGS RSGs Design: Due to unsubstantiated claims, complacency, challenges and rewards of innovative steam generators, time and financial pressures, both inexperienced Southern California Edison (SCE) and Mitsubishi Heavy Industries (MHI) Engineers did a very poor job of Industry Benchmarking and keeping up with the Academic Research Papers on the basic lessons of steam generator design (How to prevent the adverse effects of fluid elastic instability, flow-induced random vibrations, excessive hydrodynamic pressures and preventing localized steam dry-out regions observed in SONGS Units 2 and 3 RSGs with high steam flows to produce more megawatts than the original steam generators (1729 MWt vs. 1705 Mwt). In addition, SCE made numerous untested and unanalyzed design changes under the pretense of 10 CFR 50.59 process (like for like change) and intentionally (Public Perception) avoided the NRC 50.90 License Amendment Process. These factors contributed to the catastrophic failure of such an important piece of equipment vital to the safety of the public and reliable power generation to meet the needs of the Southern Californian Ratepayers, for which they paid 570 million dollars.

    SCE Restart Report for SONGS Unit 2: To address the tube leak and its causes, SCE assembled a technical team from MPR Associates, AREVA, Babcock & Wilcox Canada, PVNGS, EPRI, INPO, Westinghouse, Intertek APTECH and MHI, as well as experienced consultants including former NRC executives and a research scientist. On October 3, 2012, SCE submitted a 1200 page report prepared by these experts (Under the closed Scrutiny, Guidance and Leadership of SCE Managers) to NRC Region IV. The SCE Root Cause Evaluation Report, Operational Assessments reports prepared by SCE, AREVA and Westinghouse, and MHI Technical reports conflict and contradict with each other on the causes and extent of degradation pertaining to the fluid elastic instability in SONGS Unit 2 Steam Generator Replacement Generators (RSGs) and Tube-to-AVB gaps in both Unit 3 and Unit 2 RSG’s. MHI truly states that specific causes that resulted in tubes being susceptible to fluid-elastic excitation are not yet completely known.

    The DAB Safety Team along with the support of an ever-growing number of SONGS Concerned Insiders and Whistleblowers have prepared the above analysis, which is consistent with the conclusions presented in the publicly available reports provided earlier on this subject by:
    • Internationally Known Nuclear Consultant Arnie Gundersen and his team of Anonymous Industry insiders, who had lengthy careers in the design, fabrication, and operation of nuclear steam generators.
    • Professor Daniel Hirsch and Internationally Known Nuclear Consultant Dale Bridenbaugh.
    • Publicly available posted documentation by Dr. Joram Hopenfeld, a retired engineer from the Office of Nuclear Regulatory Research and NRC’s Advisory Committee, and
    • David A. Lochbaum, Director of the Nuclear Safety Project for the Union of Concerned Scientists (UCS).
    Copyright November 28, 2012 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 Attorneys.
     
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  268. SCE erroneous claims about Westinghouse and AREVA Operational Analysis (OA) as Deterministic Analysis are misleading, confusing and controversial. These OAs are Actually Possibilistic Analysis.
    Safety analysis forms a major part of the design and licensing process for nuclear power plants. Safety analysis is carried out to ensure that the various provisions for safety are adequate to maintain the plant parameters within acceptable limits under various postulated conditions including normal operation, anticipated operational occurrences and accidents. Safety analysis can be characterized as Probabilistic, Deterministic or a combination of both known as Possibilistic Analysis. Deterministic Analysis Definition: Analysis of a deterministic problem, without taking the probabilities of different event sequences into account. [Source: Businessdictionary.com]
    EXPERT INVOLVEMENT: Upon discovery of TTW in Unit 3, SCE commissioned the services of industry experts to assist in assessing the cause of this phenomenon. SCE selected experts based upon their previous experience in design, evaluation, tube vibration, testing and causal determinations related to SGs. Members included experts in T/H and SGPs from MPR Associates, AREVA, Babcock & Wilcox Canada, Palo Verde Nuclear Generating Station, EPRI, Institute of Nuclear Power Operations (INPO), Westinghouse, and MHI, as well as experienced consultants including former NRC executives and a research scientist. A series of panel meetings were conducted during which testing and analysis results were presented. The panel members assessed whether the current work by SCE and its partners was sufficient in understanding the TTW phenomenon and whether the corrective actions developed were sufficient to ensure tube integrity in the future.
    1. SCE Enclosure 2: San Onofre Nuclear Generating Station Unit 2 Return to Service Report Page 19 – 5.2.1 – Deterministic Risk Analyses: The SONGS Updated Final Safety Analysis Report (UFSAR) Section 15.10.1.3.1.2 presents the current licensing basis steam line break (SLB) post-trip return-to-power event (post-trip SLB). Based on the actual plant RCS chemistry data, the accident-induced iodine-spiking factor of 500, and the estimated SG tube rupture leakage rate, the calculated dose would have been at least 32 percent lower than the dose consequences reported in the UFSAR for the post-trip SLB event with a concurrent iodine spike. The postulated post-trip SLB with tube rupture and concurrent iodine spike Exclusion Area Boundary, Low Population Zone, and Control Room doses would be less than 0.068 Rem Total Effective Dose Equivalent (TEDE), which is well below the post-trip SLB Control Room limit of 5 Rem TEDE, and the Exclusion Area Boundary and Low Population Zone limit of 2.5 Rem TEDE. The potential for a seismically-induced tube rupture was also evaluated. The analysis determined the equivalent flaw characteristics of the most limiting degraded tube in Unit 3 SG 3E-088 from its in-situ pressure test result. This tube, Row 106 Column 78 (the leaking tube), sustained an in-situ test pressure of 2,874 psi before exceeding leakage limits. This in-situ test pressure, which is slightly more than twice the operating differential pressure on the tube, corresponds to the limiting stress for crack penetration or plastic collapse with large deformation. The combined stresses due to operating differential pressure and seismic forces corresponding to SONGS Design Basis Earthquake (DBE) are lower than this limiting stress and are also less than the allowable stress for the faulted condition (i.e., including DBE) according to the American Society of Mechanical Engineers Code. Therefore, the degraded tube would not have burst under this worst case loading.
    2. Attachment 6 – Appendix B: SONGS U2C17 – SCE Steam Generator Operational Assessment for Tube-to-Tube Wear – Pages 17 and 18 – Section 3.4 – Deterministic TTW OA: A deterministic TTW OA [Appendix-D] was completed for tube wear at AVBs and TTW. Tube-wear projections for in-service tubes confirm the SG performance criteria will be satisfied during the inspection interval. Tube wear projections for plugged tubes confirm that severance will not occur during the inspection interval. Evaluation of TTW of the two tubes in SG 2E-089 concludes the wear did not result from in-plane vibration of the tubes. ECT data demonstrate the tube wear indications at AVBs did not extend beyond the width of the AVBs in Unit 2. Wear extending beyond the width of AVBs was strongly correlated with Unit 3 tubes with TTW. In-plane SRs indicate that the two Unit 2 tubes with TTW are stable at 100% power. Pre-service inspection data indicates these two tubes were in close proximity prior to SG operation. The OA postulates that during operation out-of-plane vibration and/or turbulence caused the two tubes to wear. The potential for in-plane vibration leading to TTW in Unit 2 is evaluated by calculating in-plane SRs. The OA methodology predicts in-plane vibration in Unit 3 and confirms the absence of in-plane vibration in Unit 2. This OA projects the depth of indications to the next inspection using current inspection data. ATHOS results provide the T/H inputs for flow velocity, density, and void fraction along the length of the tube. These conditions are used in the Flow Induced Vibration analysis to generate the SR for out-of-plane and in-plane vibration of the tube for various tube support conditions. The support conditions define whether or not a support location such as an AVB intersection is effective, meaning that the structure provides adequate support with respect to motion of the tube due to vibration. Presence of tube-to-AVB wear indicates an ineffective support. The vibration analysis results and support conditions are used to make wear projections in the next operating cycle. This calculation is based on empirical test results and involves several input assumptions related to tube-to-AVB gap, the AVB twist, and the wear coefficient between the tube and AVB. The expected ranges of these parameters are known from test results, published data and experience. Wear depth projection is made taking into consideration the inspection results at the current outage. After setting the inputs to match the inspection results for a given indication, the wear calculations are extended to determine the projected wear depth at the next inspection.
    3. AREVA Attachment 6 – Appendix B: SONGS U2C17 – Steam Generator Operational Assessment for Tube-to-Tube Wear – page 20 – 4.2 – Operational Assessment Strategy: Contact forces, as deteriorated by tube wear at support locations over time, will be calculated using advanced computational techniques. This will be combined with calculations of stability ratios to develop the probability of the onset of in-plane fluid-elastic instability, both as a function of operating power level and operating time. The operating power and operating time will be adjusted to provide a probability of occurrence of instability 0.05. This probability is based on considerations and requirements described in the EPRI SG Integrity Assessment Guidelines. Without the development of TTW, the Structural Integrity Performance Criteria, SIPC, is automatically satisfied to a probability greater than 0.95.
    4. Westinghouse Attachment 6 – Appendix D: Operational Assessment of Wear Indications In the U-bend Region of San Onofre Unit 2 Replacement Steam Generators, Page 4 – Executive Summary: This evaluation is a supplement to the OA which uses traditional/probabilistic methods. Page 5, Section1- Introduction: Southern California Edison (SCE) is preparing an operational assessment for all of the tube degradation mechanisms in the SGs using traditional and probabilistic methods. This report documents an evaluation using semi-empirical methodology applicable to tube wear resulting from flow-induced vibration. Page 23, 2.5.2 Application to SONGS Steam Generators: The semi-empirical wear calculation methodology developed for design, and based on testing described, was adapted for characterizing the SONGS tube wear experience. It includes projecting expectations for future operation at different power levels. The only change to the structure of the coding was to allow continued operation from an existing conformal tube/AVB wear geometry developed during an earlier time period with a different excitation level for the new time period. Without this change, the highly nonlinear effects of beginning with a fresh tube and AVB depth-volume relationship would have prevented meaningful extrapolation of continued operation of the existing steam generators. Normal design practice involves definition of ranges of potential parameter variables and tube/AVB geometry configurations and then demonstrating that the maximum tube wear consequences are less than a design margin. For the SONGS application, the resulting wear distribution after a cycle of operation is known, or can be inferred from existing ECT data, but for any given tube, there are many parameters that resulted in the wear distribution that are unknown. For example, neither the tube nor the AVB wear coefficient is known except over a range of possibilities for the two materials (Alloy 690 TT tubing and 405 SS AVBs). Whether the inferred tube wear distribution has less wear on the AVB, equal wear on the AVB, or more wear on the AVB markedly affects the combination of other parameters that would produce the same tube wear depth distribution. It can be assumed that the tube and AVB surfaces will not have significant run-in effects for the first cycle of operation, but even this assumption involves a potential error of several hundred percent. Most importantly, the tube/AVB geometry is expected to be different than the original design intent, but all that can be inferred with the available information is the minimum length of the dominant tube vibration span. In the largest sense, the answer (wear distribution) is known, but the inputs are unknown.
    Foot Note 4, Page 101: Westinghouse does not have access to the assembly procedures. The 0.12 to 0.14 dimensions are anecdotal without verification. NOTE: Anecdotal: Based on personal observation, case study reports, or random investigations rather than systematic scientific evaluation. [Source: dictionary.reference.com]
    Foot Note 5, Page 102: Westinghouse does not have access to final manufacturing or inspection details, but anecdotal input indicates that six-pound weights were allowed and used during AVB inspection for consistency with AVB drawing tolerances.
    Copyright November 28, 2012 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 Attorneys
     
    helpallcqiascnp@yahoo.com

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  269. Edison, Westinghouse, MHI, Intertek APTECH and AREVA need to prove to the DAB SAfety Team, Arnie Gundersen, Professor Dan Hirsch, Dr. Joram Hopenfeld, Union of Concerned Scientists and 8 Million Southern Californians that almost 70 U bends with a clearence of 0.005 Inches in SONGS Unit 2 Steam Generators (DesignClearence 0.25 Inches, Westinghouse Plants 0.035-0.50 inches) and 2 Active tubes with 28% wear will not develop fluid elastic instabilty and cause cascading tube leakages /ruptures due to localized steam voids/flashing feedwater during normal 70% power operations, Main Steam Line Break conditions, inadvertent relief valve actuations and Unanticipated Oerational Transients. Edison cannot rely on operator intervention to save the Public (SONGS Emergency Plan DEP Indicator 94% for last 6 years)from massive offsite radiation releases during such an event due to sonic booms, steam/radiation environment, communication errors, difficult access routes, subsequent equipment failures and other unknown contingencies. This is a Public Safety Knowledge Test for these Billion Dollar Players, who have signed and bet their reputation/dollars on this complicated, convoluted, complex and Unsafe SONGS Unit 2 Restart Plan and Unapproved Science Experiment. Thanks
    helpallcqiascnp@yahoo.com

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  270. Westinghouse calculates a void fraction of 99.6% in both Units, but claims, no fluid elastic instability occurred in Unit 2. DAB Safety Team agrees with Westinghouse based on review of plant operational data that no fluid elastic instability occurred in Unit 2. NRC and SCE both claim that Operational Conditions were same in both units, but fluid elastic instability occurred in Unit 3 due to high steam flows, velocities (MHI Computer model under-predicted TH conditions) and manufacturing defects, which created insufficient contact forces between tube-to-AVB Gaps. However, based on a review of AREVA and Westinghouse OAs, DAB Safety Team has concluded that fluid elastic instability and MHI Flowering Effect, and may be manufacturing defects contributed to bigger gaps in Unit 3, but the gaps were redistributed. Therefore, NRC Headquarter Qualified Steam Generator and Thermal-Hydraulic Experts needs to determine the real Root Cause of SONGS SG Degradation. NRC Region IV should not even be holding any discussions with SCE for Restart Of Unit 2, because Southern Californians do not trust their technical ability to make public safety decisions.
    helpallcqiascnp@yahoo.com

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  271. SCE due to its own negligence and greed is wasting time and money of NRC, CPCU, Ratepayers. With Unit 3 a major nuclear accident was fortunately prevented. Unit 2 came close to a nuclear accident. There is a high potential that Defective Unit 2 is going to have a nuclear accident, if restarted without further visual, Time-Array, UT, Laser Morphology Scans and MHI Recommended Repairs/Plugging and reduction of critical work force. The Present inefficient, profit-driven and super-retalitating (Law-less Mob) SCE Management is not capable of running a nuclear power plant. SCE is going to bring shame NRC, CPCU, Westinghouse, AREVA, MHI and its shareholders. The political, nuclear, and financial wisdom is to retube both units ASAP by Westinghouse. Time is money. Southern Calfornians do not want a SCE Created Fukushima and Mihama in their backyards. Public meeting is a complete waste of time and public resources. Listen to DAB Safety Team, Arnir Gundersen, Professor Dan Hirsch, Dr. Joram Hopenfeld, Ace Hoffman, CAPT D and Union of Concerned Sciebtists. A Nuclear Accident is going to Bankrupt SCE and put EIX/SCE out of business.

    helpallcqiascnp@yahoo.com

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  272. Eight tube failures and the structural integrity of thousands of damaged tubes in SONGS Units 2 and 3 Replacement Steam Generators is being persistently questioned by the worried public and has been termed by NRC as a very serious safety issue (Unprecedented damage in the history of U.S. Operating Nuclear Fleet – San Onofre Unit 3: 807 tubes plugged – WORST US record! San Onofre Unit 2: 510 tubes plugged – 2nd WORST US record). . SONGS RSG’s now have more damaged and or plugged tubes than all the rest of the US reactor fleet combined.
    Please do not allow SCE to Gamble on Southern Californians Future On Probabilities & Un-Verified Data – SCE erroneous claims about Westinghouse and AREVA Operational Analysis (OA) as being Deterministic Analysis are misleading, confusing and controversial. These OA’s are Actually Alarming, Confusing, Convoluting, Complex Possibilistic Analysis, (PA) which is nothing more than Profitganda, the use of phony “feel good” information to sell an idea, product or concept to the masses.
    Edison, Westinghouse, MHI, Intertek APTECH and AREVA need to prove to the DAB Safety Team, Arnie Gundersen, Professor Dan Hirsch, Dr. Joram Hopenfeld, Union of Concerned Scientists and 8 Million Southern Californians that almost 70 U bends with a clearance of 0.05 inches in SONGS Unit 2 Steam Generators (Design clearance 0.25 Inches, Westinghouse Plants 0.35-0.50 inches) and 2 Active tubes with 28% wear will not develop fluid elastic instability and cause cascading tube leakages /ruptures due to localized steam voids/feedwater flashing during normal 70% power operations, Main Steam Line Break conditions, inadvertent relief valve actuations and Unanticipated Operational Transients.
    Edison cannot rely on operator intervention to save the Public (SONGS Emergency Plan DEP Indicator 94% for last 6 years) from massive offsite radiation releases during such an event due to sonic booms, steam/radiation environment, communication errors, difficult access routes, subsequent equipment failures and other unknown contingencies. This is a Public Safety Knowledge Test for these Billion Dollar Nuclear Poker Players, who have signed and bet their reputation/dollars on this complicated, convoluted, complex, contradicting and Unsafe SONGS Unit 2 Restart Plan and Unapproved Defective Radiation Steaming Crucibles Science Experiment.
    Westinghouse calculates a void fraction of 99.6% in both Units, but claims, no fluid elastic instability occurred in Unit 2. DAB Safety Team agrees with Westinghouse based on review of plant operational data that no fluid elastic instability occurred in Unit 2. NRC and SCE both claim that Operational Conditions were same in both units, but fluid elastic instability occurred in Unit 3 due to high steam flows, velocities (MHI Computer model under-predicted TH conditions) and manufacturing defects created insufficient contact forces between tube-to-AVB Gaps.
    Based on a review of AREVA and Westinghouse OAs, DAB Safety Team has concluded that fluid elastic instability and MHI Flowering Effect, and may be manufacturing defects created Gaps in Unit 3, but the gaps were redistributed. Therefore, NRC Headquarter Qualified Steam Generator and Thermal-Hydraulic Experts needs to determine the real Root Cause. NRC Region IV should not even be holding any discussions with SCE for Restart Of Unit 2, because Southern Californians do not trust their technical ability to make public safety decisions.
    Thank very much Sir. United States needs safe and reilable, well managed and maintained nuclear power with respect and no “Retaliation” for safety concious plant workers. I hope NRC Steam Generator, Thermal-Hydraulic and Radiation Experts will sharpen their pens and redline every page of these Restart Documents in accordance with NRC Branch Chief gifted with MIT Intelligence, Intuition and a Sixth Sense advice, who said, “To resolve any complex technical problem and understand unclear regulations, you have to, ‘Read and reread in between the lines’, use, ‘Critical questioning and an investigative attitude’ and ‘Solid Teamwork & Alignment.”

    helpallcqiascnp@yahoo.com

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  274. Note: Moved by the moderator

    The Defective Radiation Steaming Nukes at San Onofre are mirror images of each another. One is shutdown due to a Near-Miss Radiological Accident and to give permission by NRC to startup the other damaged one for SCE to make profits is suicidal for the Great People of Southern California. SCE is now in Violation of 10 CFR 50, Appendix A, GDC 14, 15, 30 and 32 and SONGS Technical Specification Requirements and cannot be allowed to Restart Unit 2 Radiation Steaming Crucibles. SONGS Chief Nuclear Officer Pete Dietrich said on January 10, 2012. “The plant’s largest components, steam generators, are just two years old and represent the safest, most efficient 21st century machinery.” [Source: Market Watch]. All the 4 CHEAP & DEFECTIVE Radiation Steaming Crucibles are of the same SCE “Innovative and Challenging Design” fabricated by the Inexperienced Mitsubishi Heavy Industries, who does not possess the knowhow of Westinghouse to build a Combustion Engineering Replacement Steam Generator.
    Many steam generator tube ruptures and steam line break events have occurred in the last 30 years at nuclear power plants throughout the world. In light of the Unit 3 Replacement Steam Generators (RSGs) unprecedented eight tube failures, which happened due to high steam flows, high steam velocities, insufficient contact forces between the Tubes and AVBs, 99.6% localized steam voiding [Result of low steam pressures, narrow tube pitch to tube diameter ratio, low tube clearances, NO design “In-plane Fluid Elastic Instability support protection”, taller Tube Bundle, Mitsubishi Flowering effect] and low frequency retainer bars vibrating with large amplitudes due to random vibrations. Help All Hurt Never Baba agrees with MHI that all the Unit 2 Tubes would be susceptible to the Type 1 (tube-to-tube wear) and Type 4 (Retainer Bar wear) failures/ruptures due to 100% steam voiding of the entire U-Tube Bundle in case of a Main Steam Line Break (MSLB) /MSIV Failure to close or Steam generator over-pressurization followed by lifting of relief Valves. Therefore, to meet the SONGS Technical Specifications and GDC 14 of Appendix A to 10 CFR Part 50 for a MSLB / Unanticipated Operational transients and prevent a nuclear accident and reactor meltdown from cascading tube ruptures in Southern California, all the tubes susceptible to Type 1 and Type 4 wear should be preventatively plugged before Unit 2 Restart. In other words, the Unit 2 RSGs in the “As Designed and Degraded Configuration” cannot be OPERATED at any “Power Levels” due to the “Tube Plugging Limit” and substantial risk of nuclear meltdown. So now the Trillion Dollar Question is would the NRC give Pete Dietrich a Christmas Present in the November 30 Public Meeting and let SCE operate Unit 2 to experiment if 16 Unit 2 tubes can break at MSLB conditions, meltdown the Unit 2 reactor and create Fukushima and Chernobyl in Southern California’s Back Yards? Pete Dietrich better tell Ted Craver and Ron Litzinger to be ready with a $12 Billion Nuclear Liability Insurance Premium for a Trillion Dollar Coverage for a Potential Nuclear Accident in the Making!
    Public perception is very strong that NRC is not following the Doctrine and Charter of His Excellency President Obama, United States Congress and Senate Committee on Environment and Public Works to protect the public from potential nuclear accidents. Please follow the advice of NRC Branch Chief gifted with MIT Intelligence, Intuition and a Sixth Sense, who says, “To resolve any complex technical problem and understand unclear regulations, you have to, ‘Read and reread in between the lines’, use, ‘Critical questioning and an investigative attitude’ and ‘Solid Teamwork & Alignment.” Advice to NRC: Please read the SCE Restart Documents and Operational assessments very thoroughly and critically and do not let SCE sweet talk you into believing that it is safe to Run Unit 2, just like they did with 10 CFR 50.59 for Replacement Steam Generator. This is Democratic America and not a Third world Country, where you can get away with not following regulations or Japan, where TEPCO and Japanese Regulators have ignored safety warnings for years and so many nuclear accidents have happened including Fukushima. If some accident happens in Unit 2, the consequences are very clear. Fukushima, Mihama, Chernobyl, Three Mile Island…. Thanks, just trying to be of help to the Public, NRC and Nuclear Industry…. Sincerely Help All Hurt Never Baba
    helpallcqiascnp@yahoo.com

  275. By putting pressure on NRC, CPUC, NEI, INPO, Westinghouse, AREVA, MHI, News Reporters and Politicians to restart “As Designed and Defective Unit 2 Steam Generators”, SCE is setting a bad example and liability for other Responsible Nuclear Utilities, which are supplying safe and reliable nuclear power for 20% of US electric needs. It is time for SCE to realize that these generators are not qualified for any Design Basis Accidents and Unanticipated Operational Transients. The ultimate nuclear, political and financial wisdom lies in giving a turnkey contract to the NEI Qualified, “World’s Premium US Nuclear Plant Designer and Manufacturer” Westinghouse Electric Company LLC for re-constructing and re-tubing these “Sick Generators” ASAP just like PVNGS Largest and Safest Steam Generators.

    helpallcqiascnp@yahoo.com

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  276. Some words about fluid elasticity and flow-induced vibrations
    High steam flows, low secondary steam generator pressures and narrow tube pitch to tube diameter ratios in a nuclear steam generator create highly localized steam voids in the U-Tube Bundle Region. Nuclear Steam generators tubes with narrow tube pitch to tube diameter ratios, poorly designed tube supports and anti-vibration bars and operated with high steam flows and low secondary steam generator pressures are highly subject to fluid elastic instability and flow-induced random vibrations.
    High Void Fraction increases steam-water mixture fluid normal and cross-flow velocities and decrease tube and Anti-Vibration bar damping resistance.
    High Void Fraction, high normal fluid velocity and decreased tube damping resistance cause fluid elastic instability in the in-plane direction and severe tube-to-tube wear.
    High cross-flow fluid velocity and decreased tube damping resistance generate random vibrations in the in-the out-of-plane direction and cause severe tube-to-AVB wear.
    High local fluid velocity in the horizontal direction in the straight leg section of the tube due to narrow tube pitch to tube diameter ratios generate random vibrations and cause tube to contact the land region of the BEC hole and tube-to-TSP wear.

    DAB Safety Team
    helpallcqiascnp@yahoo.com

    Note: Moved by the moderator

  278. RE: “Generic Communications – What That Means for the Nuclear Power Industry”
    For all the highly intelligent engineers involved in nuclear power, it appears the industry has never spent the money to pre-position tractor-trailer mounted generator units and fuel tank trailers near enough to reactors to serve as backup to the backup. In quake prone areas, they would be positioned where not dependent on bridges. This is an example of why no person or company should be allowed to possess and/or operate something which has the capacity to ruin an area the size of two western states. Human greed and error, and the bottom line, create risk. Further, if a coal-fired plant has an accident, the worst which can happen is a dust or steam explosion, a pile fire, or maybe a coal ash pile avalanche. If a team of well-trained and well-equipped Iranian commandos attacked a coal-fired plant, people would laugh about it. If they went after an NPP or a SFP it would be equivalent to and as destructive as a strategic nuclear hit. The plant security would all be killed at the outset, too. One third or more of Japan is now a radiological control area by US standards. Millions of people there and around the world are going to die early deaths. There’s probably a microscopic particle of plutonium dust from Daichii spent fuel pool number three in at least one of the lungs of everyone reading this. It’s too bad the free energy technologies discovered time and again over the last 100 years could not be utilized by the engineers to change society and the environment for the better. One example, Brown’s gas flame, has the potential to take the radioactivity out of every radioactive substance. It’s not utilized because taking care of nuclear waste is a generational profit source, and because within the technology is free energy. Another weird point: much of the cancer people get nowadays is due to ionizing radiation from isotopes in the food and water they ingest, and the air they breathe. While generating cancer from its activities, the nuclear industry and its owners also prevent cures. Witness vitamin C as a way to eliminate 80% of the risk of cancer from ionizing radiation. The annoucement of this method and its importance was snuffed out, in the news, WORLD WIDE. Within it is the cure for all infectious disease, and probably for cancer, too. So it is a threat to profit, and to a means to reduce the population. Too bad nuclear industry employees don’t care enough about their neighbors to scheme against this industry and then turn their talents loose on making the world a BETTER place to live, where neighbors think of neighbors before they do something which might be bad for them.

  279. CaptD
    captddd@hotmail.com

    How many at the NRC are trained Geologists beside the new Chairwomen?

    This is a very powerful article and one that the Nuclear Industry and the NRC needs to respond to, if they want to regain their credibility; making excuses is N☢ longer acceptable when it could mean the difference between paying for SITE improvements to or the decommissioning of these “at risk” Reactor Complexes and a Trillion Dollar Eco-Disaster, like Fukushima!

    Remember the risk of a once in a thousand year “event” could just as likely happen tomorrow as in a thousand years…

    Reactor at operating power hit by Orphan Tsunami (no local quake). What would be different to 3/11?
    http://wp.me/pDwKM-2OC

    Note: Moved by the moderator

  280. Fred Stender
    freshenergy@hushmail.com

    How about taking some enforcement actions against these plants that lie to NRC about serious things, like SONGS did? That would show a commitment to integrity and respect for the residents of the USA.

    And reduce the plant residence time….any NRC inspector can only stay 3 years, not 7 as is currently allowed, 7 allows way to cozy a relationship to develop especially as most plants are located in small communities and the well paid NRC person, and their actions, which in a regulatory environment could and should when necessary,negatively affect thousands in the community.

    This is an opportunity set up perfectly for failure. 3 years max. The biggest threat to America is the financial monopolies and the nuclear power plants. Treat your NRC position like a military position and be ready to move whenever necessary.

    Note: Moved by the moderator

  281. american2018@gmail.com

    According to the Bible, in the book of John in the New Testament, all things were made through Jesus Christ. This means he is the author of life. He designed, engineered, and wrote the genetic codes of life. Don’t say they happened by chance, information science and probability prove that could not have happened. The nuclear power industry has regular routine releases of radioactive pollution, and periodically has catastrophic releases of enormous amounts of radioactive pollution. This radioactive pollution attacks the very information in the genomes of human and all other life on earth. Disease is being generated which will pass on down through the generations of all living things. Nuclear power is an attack on God’s creation. In case you never noticed this, herein are you informed. “Choose ye who ye shall serve this day….”

    Note: Moved by the moderator

  282. Ultimate Enlightenment, Nuclear Wisdom & Expensive Lessons Learnt: A joint enquiry by the US Departments of Justice and Labor into the dark inner secrets of SONGS Steam Generator Degradation and Safety/Discrimination/Intimidation/Retaliation/Harassment Concerns will not only cure SONGS Problems but will improve safety record at other similar US Nuclear Power Plants. This investigation will help CPCU, NRC, NEI, INPO and other US Agencies responsible for the protection of health and safety of Americans from potential radiological accidents, which can be caused by natural forces, human errors, equipment failures poor training, poor operating procedures and production/profit oriented management, etc. Foreign-owned NEI Qualified,”US Nuclear Manufacturers/Designers” will dominate the Future US Nuclear Energy Market, but NRC, NEI, INPO and other US Agencies need to ensure that their technology is safe, reliable and affordable for the US Public and Rate Payers by using: As a NRC Section Chief of MIT Intelligence says to his dedicated staff, “Before approving any Safety Evaluation and other Licensing Documents/Inspection Reports, Please, “Read and reread in-between the lines’, use a ‘Critical Questioning & Investigative Attitude’ and ‘Solid Teamwork & Alignment’ between NRC Staff, Licensee, Manufacturers and Vendors.” This saying is consistent with the teaching of World’s Foremost Expert on preventing the adverse and expensive effects of Turbulence-induced vibrations and Fluid Elastic Instability in Nuclear Power Plant Components and Heat Exchangers.

    DAB Safety Team Member

    Note: Moved by the moderator

  283. The last paragraph should read:

    As a point of reference, just ONE steam generator tube failed and caused a IAEA level 3 disaster in Japan at their Mihama Unit 2 nuclear reactor in 1991, (See http://is.gd/feYSBl ), and it had 2 holes in May of 2003. A disaster at San Onofre could easily have been EIGHT times worse or MORE!

    CaptD

    Note: Moved by the moderator

  284. Good day! I simply want to give an enormous thumbs up for the good information you will have right here on this post. I will probably be coming back to your blog for more soon.

  285. Why is the Project on Government Oversight, a supposedly nonpartisan watchdog, wading into a partisan controversy and stoking the flames of conflict? If abuse of authority took place by Jaczko, why is POGO whitewashing it?

  286. Actually, if you look into it, I believe you will find that the NRC plays no role in collection of, or disbursement of, funds related to the waste disposal surcharge. Those monies are collected from all of us by the electric utilities and go straight to the U.S. Treasury. DOE is charged with using those funds for building and maintaining a waste disposal site. I am not sure if any of those funds are used by NRC to cover the licensing process for a repository. It’s possible, but it would be a relatively small amount compared to the total cost of building a waste repository. Congress is ultimately responsible for deciding how those funds get spent so you should be directing your question to them, not the NRC.

  287. Zach
    When could the utilities expect to see the NRC to pay back the billions of dollars they have paid to the NRC for a future waste disposal site? They were promised Yucca and didn’t get that. In the country we live in the government should not be allowed to take someone’s money, promise them something, and then back out on the deal. Our country was not pictured to run this way and the government should hold itself to a higher standard. Will Obama step in and do something? Obama first approves two new sites for construction, and now he has appointed a woman who is hugely against Yucca, but they still take their money don’t they?

    Note: Moved by the Moderator

  288. “What is the most effective method of protecting public health and safety?”

    As a long time [30+ year] nuclear power [electrical / I&C] design engineer, I am highly familiar with all the engineered safeguard systems [ESF, reactor SCRAM].

    As someone with an advanced degree in engineering and operations management [with a thesis paper on safety culture management] I am also familiar with the safety risk that is posed by broken human performance safety culture barriers.

    INPO places safety culture in the category of “human performance”. As a former QA assessor, human performance supervisor and INPO coordinator, here is a definition of safety culture from a nuclear safety human performance perspective:

    Safety Culture (Human Performance)
    “A managerial-organizational human performance safety system that requires the application of QA [surveillance, maintenance, quality management] recommended by human performance experts, similar to QA applied to engineered safety systems as recommended by engineering experts.”

    To regulate nuclear safety properly, safety culture needs to be added to the NRC 10CFR50 Appendix B criterion as a QA topic, quality managed by the NPPs and regulated by NRC as a safety related human performance safety system, so that operating organizations will start to dedicate sufficient resources to the quality management and assurance of organizational safety culture.

    The above discusses “how” to manage safety culture. “Where” to manage safety culture is at the 4 safety culture human performance quality barriers [Corcoran 2000]

    These are:

    Worker
    Manager
    Internal Oversight [i.e. “QA Department”]
    External oversight [i.e. “regulators” like NRC, INPO].

    Proper root cause analysis will clearly demonstrate these broken barriers for any accident, such as Fukushima.

    Publications that do these kind of analyses are “Reactor Accidents” by my friend David Mosey and “Hostages of Each Other” by my friend Joe Rees and “Flirting With Disaster” by my aquaintance Mark Gerstein and “Managing the Risk of Organizational Accidents” by James Reason and “Analysis of Significant Operating Events” by INPO.

    All of these point to broken safety culture barriers [not failed engineered safety systems] as the root cause of nearly every major accident. Mosey refers to this as “institutional failures” Rees [and INPO] as “professionalism failures” Gerstein as failures of the “sociotechnical system” Reason as “organizational accident” [when the light shines through the wheel of swiss cheese] INPO identifies safety culture weakness and a causal factor in 70% of SOEs.

    So, the “most effective method of protecting public health and safety” is to not only assure the quality of engineered protective systems [i.e. QA systems] but to also assure the quality of the human performance safety systems [i.e. organizational safety culture].

    Yet when we do accident analysis, we rarely if ever do proper broken barriers analysis, so we never see what is broken in “human performance land” or what actually needs to be addressed and fixed. We can only understand and then see these things, if we study the kind of publications identified above.

    I did a “safety culture broken barrier” analysis on Millstone and Davis Besse in some of my presentations, I discuss the need for NRC to establish and require QA for safety culture in almost all of them.

    One of the more interesting lines in the movie “Avatar” is:”It is difficult to fill a cup that is already full”. Making no progress after a decade of pushing for safety culture QA, in 2010 I stopped trying. I stopped doing presentations and attending NRC INPO and other meetings as a “safety culture expert”.

    However, as an industry I can tell you we are not doing what needs to be done.

    Click to access CollinsSafety_Jul_07.pdf

  289. Please consider this idea as a low cost solution to America’s “long term” radioactive waste storage problem:

    Make use of our Military Testing Bases and or our MOA’s (Military Operation Area’s) out west, which are really huge tracts of land (think tens of thousands of acres) used ONLY by the military and already secured by them 24/7!

    Placing these very large (heavy) concrete casks in a poke-a-dot pattern will allow for at least 50 to 100 years of storage, safe from everything except a War, (in which case every reactor is just as vulnerable) and then revisit the storage problem then; at which time, probably a future solution will allow for an even better lower cost “final solution”…

    Because these casks would be very large and all look alike nobody would know what was in any one of them, which would be yet another level of security for the casks with higher levels of nuclear waste! An ideal outside coating for these casks would be similar to the spray-on “bed liner” used for pickup trucks that not only prevents rusting and or damage for the life of the vehicle but would also seal the casks to prevent leakage of any kind!

    Hopefully these casts would be similar in size to a large shipping container so that existing material handling equipment could be used to load, unload and or move them about without “inventing” a mega hauler vehicle. By keeping the “footprint” of these casks similar to a large 40 foot shipping container, the stacking and or placement of them might also be semi or fully automated which would not only save money but again keep the exact location of any specific cask secret! The monitoring of these casks 24/7/365 could even be done via satellite since these casks are similar in size to rocket launchers which are easily seen from space.

    In another 50 to 100 years, storage technology will be such that, yet another lower cost solution for all this waste will be surely found, and then it can be considered verses continuing to using the above storage plan… Perhaps like lifting it all into space via a space elevator* and then shoving it in an orbit into the SUN.

    BTW: Area 51 (which does not exist officially) already contains huge tracts of land that has already been used as a nuclear testing site, and is off limits to all but a few forever.

    * The Space Elevator (which I have heard the Japanese are now working on) would make lifting heavy items into orbit both safe and cheap…

  290. It is a well known fact that the Japanese ARE INDEED burning huge amounts of radioactive debris! Better recheck your source of information, I bet you will be amazed at both the amount and locations of this “burning”, Here is a quick Google search: http://is.gd/WKNuFa

    One story: Atlantic: Is gov’t trying to contaminate every region of Japan by burning radioactive debris? “If everyone is ‘contaminated,’ then, in a relative sense, no one is”
    http://enenews.com/?p=33602

    + more here:
    See: The Asia-Pacific Journal: Japan Focus – Index to Fukushima papers.
    http://wp.me/pDwKM-2qY
    and
    Global risk of radioactive fallout after major nuclear reactor accidents J. Lelieveld et al http://wp.me/pDwKM-2zz
    and
    International Workshop on Source Term Estimation Methods for Estimating the Atmospheric Radiation Release from the Fukushima Daiichi Nuclear Power Plant
    http://is.gd/A96APk

    RE: “The amounts of radionuclides which have been transported to the United States, either through the atmosphere or ocean, are insignificant with respect to causing adverse human health effects or effects on the environment.

    So, in summary, no, radionuclides released by the Fukushima Dai-ichi event are not having any measureable effect on our weather.”

    Many scientists would seem to have a different viewpoint! Perhaps the term “INSIGNIFICANT” is the key issue…

  291. NRC Response: Your question suggests that there is an ongoing burning of radioactive debris, perhaps from the event or of an intentional man-made nature, at the Fukushima Dai-ichi facility. That is not the case. The three damaged reactor cores, which were the source of prior radionuclide releases, are currently being maintained in a safe, cold shutdown condition and are not actively releasing significant amounts of radionuclides into the atmosphere around the facility. Tokyo Electric Power Company and government of Japan personnel are at the site actively cleaning up damage caused by the event and performing construction activities. These activities may be stirring up small amounts of previously-deposited radionuclides, but they would not go any distance at all before settling out again. So there is no active source for any meaningful ongoing release of radionuclides into the upper atmosphere from the Fukushima Dai-ichi facility.

    Further, with respect to total inventory of radionuclides released during the Fukushima Dai-ichi event, the vast majority were either (1) transported into the ocean through the movement of contaminated water or (2) deposited locally on Japanese soil in the vicinity of the Fukushima Dai-ichi facility. The amounts of radionuclides which have been transported to the United States, either through the atmosphere or ocean, are insignificant with respect to causing adverse human health effects or effects on the environment.

    So, in summary, no, radionuclides released by the Fukushima Dai-ichi event are not having any measureable effect on our weather.

  292. CaptD: Far better to let some other Country squander their financial resources and install safe, clear and PROVEN Solar (of all flavors) instead of funding yet more Nuclear “make work” projects for the Nuclear Industry; that has happened for far to long and is probably going on today in “born black” projects…

    The longer the USA waits to install Solar (of all flavors) the less Global Rare Earth and other required items (like Copper, whose total amount is now expected to last about another 20 years) will be acquired by Countries like China… Then What?

    Note: Moved by the Moderator

  293. Questions for the NRC: Could it be that the radionuclides still being released from the 3/11/11 triple meltdown and all the ongoing Fukushima radioactive debris burning is changing the ionization of our clouds and thereby our weather? Does the NRC have experts in Meteorology on Staff?

    CaptD

    Note: Moved by the Moderator

  294. The ESBWR design completely avoids the circumstances that led to the Chernobyl accident. The issue we’re looking at involves how the steam dryer, a very large metal structure, will vibrate and otherwise respond to the pressures and forces involved when the reactor is operating.playfi

  295. It is time to get off the imports of fossil fuels, save the hundreds of billions now paid for the imports and put them to a better use. As a side effect air pollution would be reduced.

  297. The NRC and DOE spend billions of dollars studying the problem of nuclear waste disposal. Yet not a dollar has been spent investigating these various claims, which have been around for a least forty years. no nuclear

  298. It is time to get off the imports of fossil fuels, save the hundreds of billions now paid for the imports and put them to a better use. As a side effect air pollution would be reduced.

    Moderator Note: Comment moved from another post

  299. Can’t wait until the days of nuclear fusion, as opposed to fission, reactors. Once we’re able to get ITER viable for commercial usage – or rather, a reactor based on ITER’s build – our worries will dwindle to nothingness. Fusions reactors wont be worried about earthquakes or most other natural disasters, with their safety assured by the benign waste products they produce.

    Trevor Michaels

    Moderator Note: Comment moved from another post

  300. The NRC and DOE spend billions of dollars studying the problem of nuclear waste disposal. Yet not a dollar has been spent investigating these various claims, which have been around for a least forty years. no nuclear

    http://www.sewaproyektor.heck.in

  303. Just got my bachelor in EE, and I would like to know much bureaucratic/politic issues typically encountered by a junior engineer.

    I asked because I worked part time on campus, and although I didn’t deal with departmental issues directly, my boss often shared the headaches he had to deal with, usually after meetings.

    Moderator Note: Moved from another post.

  304. Atlas rockets on a one way trip to the Sun full of toxic waste creating a clean environment and millions of jobs paid for by the corporations just what is wrong with that? It can be done the question is why not?

  305. The Department of Energy is responsible for developing a strategy for dealing with high-level waste. To that end, DOE and President Obama initiated a Blue Ribbon Commission on America’s Nuclear Future to “conduct a comprehensive review of policies for managing the back end of the nuclear fuel cycle and recommend a new plan.” From that commission’s value statement: We are investigating a wide range of issues. These include reactor and fuel cycle technologies, options for safe transport and storage of nuclear waste, options for waste disposal, and institutional arrangements for the management of used fuel and high-level wastes. We will also make recommendations regarding the handling of the nuclear waste fund.

    You can learn more at their web site: http://brc.gov/

  306. There are many reports on the Internet that the radioactivity in radioactive waste and spent nuclear fuel can be neutralized by various simple, safe, inexpensive processes. The NRC and DOE spend billions of dollars studying the problem of nuclear waste disposal. Yet not a dollar has been spent investigating these various claims, which have been around for a least forty years.

    WHAT IS YOUR EXCUSE?

    Moderator: Moved from another post

  307. Link to probably the best nuclear safety discussion blog in the world, comprised of 6000+ mostly nuclear experts & professionals, operated / moderated by a woman who is a nuclear regulator in Romania. You can join the group and start a discussion on any nuclear safety subject, and get interesting thoughtful feedback. http://www.linkedin.com/groups?home=&gid=2170900

  309. Where I can find more info about appropriate safety of nuclear power, i want it to share with my country, I am from Peru, please send me the info

    thankyou very much

    Moderator Note: Comment moved from another post

  310. Why is the Project on Government Oversight, a supposedly nonpartisan watchdog, wading into a partisan controversy and stoking the flames of conflict? If abuse of authority took place by Jaczko, why is POGO whitewashing it?

    Moved by the moderator to this topic

  311. This is more than the NRC chairman’s “personality.” His deficiencies as a leader and manager are too severe for him to be entrusted with such an important post, let alone his extreme partisan approach to his job. The NRC should be about science, engineering, and public health not crass politics and crass managerial behavior. Gregory Jaczko is a disaster on all counts and President Obama should be asking for his resignation, too.

    Moved by the moderator to this topic

  312. I am unhappy to hear that four NRC Commissioners have aired to Congress specific instances of abusive conduct by NRC Chair Jazcko, directed at the Commissioners as well as toward NRC staff. (“Leader of Nuclear Agency Hears Litany of Objections” NY Times Dec 14 2011) Apparently thie rcent criticisms were preceded by an Inspector General’s report, which outlined similar misbehavior by Chariman Jazcko.

    I hope to see more about this posted here.

    Moderator Note: Comment moved from another post

  313. It is embarrassing as an NRC employee to see the Commissioners before a Congressional committee discussing their inability to work in some semblance of tolerance, if not harmony, among themselves. The accusations against the Chairman, right or wrong, reflect poorly on all. I believe the Commission owes the NRC staff an apology for its inability to contain these internal squabbles and the need to elevate them to the public level of embarrassment. We are supposed to be a technical, not a political, agency. Yet we have politicians accusing us of acting like politicians!

  314. Hey! Do you use Twitter? I’d like to follow you if that would be okay. I’m definitely enjoying your blog and look forward to new updates.

  315. The NRC logo at the top of the blog page should be clickable to the nrc.gov homepage.
    -Cindy Montogmery

    Comment moved by the moderator

  316. I applaud the NRC for at least initiating this kind of an open discussion. It should however be more public, and it’s too bad such discourse wasn’t available during the time when all these plants were set up in the first place.

  317. The development of uranium-based light-water reactors in the United States was based, at least in part, on the existence of infrastructure for enriching uranium, as well as U.S. Navy experience operating uranium-based reactors. The NRC is aware of Liquid Fluoride Thorium Reactor technology and would be the agency to approve and regulate any civilian reactor design using that technology in the United States.

  318. Just saw a presentation on LFTR. No sensitive intermediate elements, waste has a short half-life, no pressurized containment required, fail-safe consists of plugs that melt upon overheating and allow vessel to drain into smaller vessels, stopping the reaction. A prototype at Oak Ridge was “turned off” every night using this multi-drain system. Research needed for commercial version. AEC wasn’t interested in the 1950s and 1960s. Why? No weapons grade materials are produced in a LFTR; the very characteristic that recommends it today.

  319. Re blog thread on safety culture policy posted last month, to develop the new definition, in Feb 2011 NRC assembled a panel of over a dozen “experts” and held a three day conference. I was the sole member of the public on the panel and I believe the most studied and accomplished in safety culture. I have an extensive bibliography and I have written many papers on the subject including a master’s thesis. I have given a number of industry presentations a couple at the request of NRC and INPO. I was the primary safety culture advisor on an EPRI sponsiored MIT project.

    The NRC invites input from the public, but does the NRC really “listen” the public? As a “member of the public” I felt I was continually treated as a “third class citizen”. INPO and NEI being first class, nuclear industry reps second class, myself third class, even though of the panel members, I was likely the most expert in the subject. The NRC however, had very small ears for what I was saying [or trying very hard to say].

    The result is that the industry got the definition it wanted, not the definition needed [or accurate or proper]. The underlying dynamics may have been similar to finance industry regulation under Greenspan: the regulation the industry liked, but not the regulation needed to properly protect the interests of the public.

    What kind of “core values and behaviors?” the new definition does say. Safety culture is not a “collective commitment by leaders and individuals”. What Schein says is: “leaders create culture”. Safety culture is it is a function of [is created by, is the responsibility of] LEADERSHIP, period. This is a CENTRAL [a sine qua non] point. Without this you fail to identify leadership as responsible for safety culture, and you cannot have effective regulation or effective licensee management of safety culture. This is such an obvious oversight, the only conclusion I reach is that the leaders of industry did not want this responsibility identified.

    Additionally, the phrase “to emphasize safety over competing goals” says nothing. Saying “to emphasize safety over profits” is clearer, but still tells you little about safety culture. Safety culture is an attitude that manages risk. In a HRO, it is a professional leadership attitude that protects people and the environment from the risks of a hazardous process. Like the medical profession, you must invoke the term “professionalism” but leaders of industry do not want regulators ever to hold them responsible for maintaining “professional attitudes”. Politically, they do not like to clearly state that operating nuclear involves managing hazards and risks, but it does. “Nuclear Organizations” are high hazard ventures, operated by HROs, and are all about managing risk. The tool used by NRC that is central for assessing safety [PRA] focuses on assessing and managing risk. All of these including the concept of maintaining stakeholder trust are central to safety culture, but absent from the definition adopted by NRC. The new NRC definition addresses none of the problems with the old INSAG definition. This is because NRC never too the time and never made an effort to clearly understand what those problems were.

    Here is a proper definition of HRO safety culture [such as nuclear, process etc] if NRC had a better understanding of safety culture in Feb 2010, this would have been selected as the new NRC definition:

    HRO Safety Culture

    “In a high hazard industry or venture, professional leadership attitudes that ensure hazardous processes are managed such that risk to people and the environment is maintained as low as reasonably achievable, thereby assuring stakeholder trust.”

  320. The real problem here is that we have a much better alternative to these reactors (LFTR-Liquid Flouride Thorium Reactors) and are not pursuing it as we should be. We made a bad choice 40 years ago and are paying for it now… If we don’t wake up the rest of the world (Russia, China, and India) are going to pass us by. LFTR’s are much safer, cheaper, can be started and stopped easily, produce 1/30th the waste and what waste they do produce is radioactive for much less time, no proliferation danger, etc. A proven technology that we chose not to develop.
    For more info, see http://www.youtube.com/watch?v=WWUeBSoEnRk .

  321. I also agree, that US and other counties are using current technology, but I am not sure that we are very well protected after the Fukushima Daiichi plant recent events.

  322. this comment was moved by the moderator:

    My son is visiting Connecticut for the first time. I have just seen there are nuclear plants all around him. I cannot believe after Japans experience America still has Nuclear power plants operating. The public will have to band together to sue power companies for exposing us with poison then maybe they will shut them down.
    Question there are also 2 closed plants in CT are these also dangerous in other words are there still ponds that need to be kept cool??? Is so that is 4 surrounding my son at present. Thanks America!!

  323. This comment has been moved by the moderator:

    Regarding the issue of fiery steam-cladding reaction it is not clear, why it was moved out to this environment. I hope there will be a regulatory resolution, finally accepting that this process was the key process in all major reactor accidents, like the Fukushima Daiichi Units 1, 2 and 3, Chernobyl 4 and TMI2, even the Paks 2 fuel washing accident.

    [PDF] 2010/11/24-Comment (3) of Aladar Stolmar, on New England …
    … Van, Attached for docketing is a comment on PRM-50-93/50-95 from Aladar
    Stolmar that I received via the regulations.gov website on 11/24/10. …
    pbadupws.nrc.gov/docs/ML1033/ML103340250.pdf – 2010-12-09

    It is a much overdue duty of NRC and IAEA to evaluate the evidence provided by the TMI-2
    accident, Chernobyl-4 accident, Paks-2 incident, and related experiments. Evaluating this
    evidence, one can see that the ignition of the zirconium fire in the steam occurs at a local
    temperature of the fuel cladding of around 1000-1200′C, [[and that a self-feeding with steam due to the precipitation of eroded fuel pellets and zirconia reaction product from the hydrogen stream into the water pool, causes intense evaporation.]]
    There are insignificant differences in the progression of the firestorms that occurred in the TMI-2 reactor severe accident, Paks washing vessel incident, and Chernobyl-4 reactor accident; the later defined only by the amount of zirconium available for the reaction. At the mean time, there are significant similarities in the processes leading to the ignition of the firestorm. In all three of the compared cases, it took several hours of ill-fated actions or in-actions of the operators to cause the ignition condition. Also, there are similarities in the end result of the firestorm; namely, that the extent of the fuel damage is much less than it was predicted from any other severe fuel damage causing scenarios, introduced for explanations. Therefore the fraction of released fission products is significantly less than was anticipated from the fuel melting or a so called “steamexplosion” scenario. Also, the fiery steam-zirconium reaction results in a much higher than anticipated (from any other scenarios) rate of Hydrogen production, which in turn requires a review of containment designs.
    [PDF] 2010/03/24-Comment (3) of Aladar Stolmar, on PRM-50-93 …
    … From: Aladar Stolmar [astolmar@gmail.com] Sent: Wednesday, March 24,
    2010 2:59 AM To: Rulemaking Comments Subject: Docket ID NRC-2009 …
    pbadupws.nrc.gov/docs/ML1008/ML100830501.pdf – 2010-11-26
    Similar destruction and relocation of nuclear reactor fuel was observed in the TMI-2 and Chernobyl-4 severe reactor accidents and in the Paks-2 refueling pond reactor fuel washing accident.
    The similarities in these tests and accidents are the formation of gaseous (steam) bubbles in the upper regions of fuel bundles, the ignition of Zirconium in the steam and generation of Hydrogen and zirconia (ZrO2) reaction products in a very intense fire, essentially in a firestorm. Therefore, the conservative regulation shall mandate that the owners and operators of Nuclear Reactors and Reactor Fuel Handling Facilities shall demonstrate that there will be no dry-out of the fuel bundles in any circumstances. Also, in order to prevent the exposure of the public to the harmful consequences of an accident in a reactor, the housing of the reactor (containment) shall withstand the detonation of the air-Hydrogen mixture with the amount of Hydrogen calculated from the consumption of the entire inventory of Zircaloy in the reactor core or in the entire enclosed in a vessel volume, where such bubble formation is possible.
    There are several reports presenting the same issue as Mark Leyse. The cladding of nuclear fuel made of Zirconium alloy ignites and burns in the steam. The same process can be recognized (and should be recognized) as the common cause of the TMI-2 and Chernobyl-4 reactor severe accidents and the Paks-2 refueling pond accident. And the regulations in 10 CFR 50 series shall mandate to deal with the real issues and real processes.
    [PDF] 2011/06/28 – – NRC Public Blog April 2011 through May 2011
    … comment #652 posted on 2011-04-06 07:31:03 by Aladár Stolmár
    comment #644 posted on 2011-04-04 20:11:31 by duxx …
    pbadupws.nrc.gov/docs/ML1117/ML11179A192.pdf – 2011-06-29

    As I wrote in the comment to US NRC http://pbadupws.nrc.gov/docs/ML1033/ML103340250.pdf
    : „It is a much overdue duty of NRC and IAEA to evaluate the evidence provided by the TMI-2 accident, Chernobyl-4 accident, Paks-2 incident, and related experiments. Evaluating this evidence, one can see that the ignition of the zirconium fire in the steam occurs at a local temperature of the fuel cladding of around 1000-1200′C, [[and that a self-feeding with steam due to the precipitation of eroded fuel pellets and zirconia reaction product from the hydrogen stream into the water pool, causes intense evaporation.]] There are insignificant differences in the progression of the firestorms that occurred in the TMI-2 reactor severe accident, Paks washing vessel incident, and Chernobyl-4 reactor accident; the later defined only by the amount of zirconium available for the reaction. At the mean time, there are significant similarities in the processes leading to the ignition of the firestorm. In all three of the compared cases, it took several hours of ill-fated actions or in-actions of the operators to cause the ignition condition. Also, there are similarities in the end result of the firestorm; namely, that the extent of the fuel damage is much less than it was predicted from any other severe fuel damage causing scenarios, introduced for explanations. Therefore the fraction of released fission products is significantly less than was anticipated from the fuel melting or a so called “steam explosion” scenario. Also, the fiery steam-zirconium reaction results in a much higher than anticipated (from any other scenarios) rate of Hydrogen production, which in turn requires a review of containment designs.” I hope the gentlemen will recognize the same process in the Fukushima Daiichi 1-3 reactors as the leading, key process. I hope we will have a thorough investigation of the fiery steam-zirconium reaction and there will be issued a call for shutting down the 11 still operating Chernobyl type (RBMK) reactors in Russia
    [PDF] 2011/04/08 – – NRC Public Blog February 2011 through March …
    … comment #441 posted on 2011-03-18 13:44:34 by Diesel comment
    #412 posted on 2011-03-17 07:06:13 by Aladár Stolmár …
    pbadupws.nrc.gov/docs/ML1109/ML110980787.pdf – 2011-04-13

    A few of us, nuclear engineers were, are fighting for lifetime for the consideration of real processes in the reactor severe accidents. As I formulated in a comment to US NRC: Consideration of the zirconium-steam reaction and the ignition and intense firestorm in
    nuclear reactor fuel rods is well overdue. Reevaluating the evidence provided by the TMI-2 reactor accident, Chernobyl-4 reactor accident, and Paks Unit 2 fuel washing incident, with consideration of this intense fiery process, will bring us closer to an ultimately safe nuclear power plant design. http://pbadupws.nrc.gov/docs/ML1033/ML103340250.pdf
    Also, I called two years ago for a review: If the hydrogen which is generated in the reactor core from the reaction of the steam (coolant) with the zirconium alloy (or other low neutron absorbing metal cladding and other fuel bundle elements) explodes inside the building surrounding the reactor, this detonation still will not cause a break of the pressure boundary of the containment. Thirty years after the TMI-2 accident and 23 years after the Chernobyl disaster, I feel obligated to formulate this guideline in order to protect the public from further irradiation from the use of nuclear power. The Chernobyl type reactors (RBMK), which are still operating, have to be shut down immediately because they do not satisfy this guideline. Other nuclear reactors operating and future designs shall be reviewed for compliance to this key requirement and the result of such review shall be defining for their future. http://aladar-mychernobyl.blogspot.com/
    Returning to the comment to US NRC http://pbadupws.nrc.gov/docs/ML1033/ML103340250.pdf
    : „It is a much overdue duty of NRC and IAEA to evaluate the evidence provided by the TMI-2 accident, Chernobyl-4 accident, Paks-2 incident, and related experiments. Evaluating this evidence, one can see that the ignition of the zirconium fire in the steam occurs at a local temperature of the fuel cladding of around 1000-1200′C, [[and that a self-feeding with steam due to the precipitation of eroded fuel pellets and zirconia reaction product from the hydrogen stream into the water pool, causes intense evaporation.]] There are insignificant differences in the progression of the firestorms that occurred in the TMI-2 reactor severe accident, Paks washing vessel incident, and Chernobyl-4 reactor accident; the later defined only by the amount of zirconium available for the reaction. At the mean time, there are significant similarities in the
    processes leading to the ignition of the firestorm. In all three of the compared cases, it took several hours of ill-fated actions or inactions of the operators to cause the ignition condition. Also, there are similarities in the end result of the firestorm; namely, that the
    extent of the fuel damage is much less than it was predicted from any other severe fuel damage causing scenarios, introduced for explanations. Therefore the fraction of released fission products is significantly less than was anticipated from the fuel melting or a so called “steam explosion” scenario. Also, the fiery steam-zirconium reaction results in a much higher than anticipated (from any other scenarios) rate of Hydrogen production, which in turn requires a review of containment designs.” I hope You will find useful this information for the background of the Fukushima Daiichi plant recent events.

  324. I agree, NASA, USAF, other countries are using current technology.
    However, if you take a look at the mechanics of lifts, the costs will fall from the current technology on the microscopic cost comparison, stems from the gravitational field of the Earth.

  325. Time and time again have we witnessed a global accident as a result of mother natures swift hand. When will we learn that if we can build it, then it can be destroyed. Nuclear included. Are we not just filling the foundations for total man made destruction of (our) planet..?

  326. Yes there are better and cheaper ways to go about it. But maybe the government has some insight.

  327. I guess that is why it would be a National project. We could do it. The Atlas rocket does not cost as much as the shuttle rockets. It does not have to get to the Sun to burn up its gravity would pull it in. The amount of energy we could produce would far out weigh the cost. All the jobs it would create would be enormous. I guess it is better to have something like Japans radiation rain down on us right?

  328. We have world wide solutions through UN treaties with IAEA to develop and share best practices info on wide spectrum of nuclear power energy. Problems then are with any nations which do not choose to join the treaties.

  329. Each source of energy is limited, and many have dangerous side effects.
    Solar and Wind use technology whose construction is dependent on industrial commodities which the world is running out of, and of course need a volume of weather activity which is not universally available.
    Fossil fuels have carbon cycle implications for climate change and maybe ozone hole.
    Hydro-electric is great on rivers, until earthquake brings down damn, and people downstream inadequate time warning to get out of way of flood. Hydro-electric works for some coastal inlets … get tide power coming and going, but better not mess with ocean going currents essential to other nation’s climates.

  330. I agree, with respect to current technology used by NASA, USAF, other nations.
    However, if you take a look at the mechanics of space elevators, the cost drops from current technology to microscopic cost by comparison, to get anything out of Earth gravity field.
    If the waste container is sent in a direction below the Earth orbit with the Sun, that means it will spiral closer and closer to the Sun, and fall into the Sun, unless it crashes into Venus or Mercury or other stuff in transit.

  331. People periodically bring up the idea of sending waste towards the sun. If you run the calculations, you will find that this method of disposal is simply not practical from a cost standpoint, unless we all want to pay a whole lot more for our electricity.

    First, there are the political ramifications and risks associated with a radioactive rocket that might blow up before getting out of Earth’s atmosphere. Remember the Columbia disaster? Not sure anybody wants highly radioactive material raining down from the skies over land or sea.

    Second, the amount of energy (and hence, fuel) it would take to do this is very large. You have to realize that we are moving in orbit around the sun. That means that any rocket we shoot into space is also moving in orbit around the sun. So shooting something to the sun is not as simple as putting a rocket into space and letting gravity take over. All you succeed in doing is putting that canister of waste in orbit around the sun as well. Orbital mechanics dictates that it takes a change in kinetic energy for a body to go from one orbit to another. To change to a closer orbit around the sun requires you to speed up the spacecraft. The closer you want the craft to get to the Sun’s surface, the more and more kinetic energy you have to add to get there. The fuel it would take to do this is so enormous as to make this method of disposal simply impractical.

  332. WASHINGTON, D.C. — August 11, 2011 — The U.S. Nuclear Regulatory Commission is legally required to slow down reactor licensing and relicensing in order to address major changes urged by the agency’s own experts who have reviewed the Fukushima accident, according to 19 separate legal challenges filed today by a total of 25 public interest groups.

    The groups contend that under federal law, the NRC may not issue or renew a single reactor license until it has either strengthened regulations to protect the public from severe accident risks or until it has made a careful and detailed study of the environmental implications of not doing so. The groups are also pursuing a technical finding from high in the NRC that leads to upgraded safety standards.

    “What we’ve learned in the wake of Japan’s nuclear disaster — and what NRC experts concluded — is that current regulations are fundamentally inadequate. They simply do not provide the level of safety required by laws including the National Environmental Policy Act and the Atomic Energy Act,” said Phillip Musegaas, Hudson Program Director of Riverkeeper, Inc., which today filed a contention document related to the Indian Point reactor in New York State with the NRC. “The law requires regulators to take this information into account before issuing any licenses for reactors. Our filing today is intended to force them to do so.”

  333. Why can we not have a government controlled central waste disposal site from which we charge corporations for deposing nuclear waste on a one way rocket to the Sun? It would create jobs, research, in all parts of the country. Just do it.

  334. Why can’t decay heat be harnessed and used as an energy source to safely power down/cool a nuclear reactor?

    I have been wondering about this since the incidents in Japan. It appeared that the Fukushima nuclear reactors survived the 5th largest recorded earthquake on earth quite well and initiated normal shutdown procedures. It was the fact that the tsunami later damaged the backup power system for cooling, which resulting in a cascade of failures and a meltdown in the reactors. I feel that nuclear energy is a clean source of power and that it can help solve our dependence on imported fossil fuels as well as provide no CO2 emissions. On the other hand, plants should be designed to withstand extreme events, even if they are of a low probability. In the Japan case, ancient stone markers warned of tsunami risk at levels above the Fukushima backup generators.

    As an engineer and a scientist, I hate getting information on important topics through normal news outlets that like to sensationalize and oversimplify stories. I understand that I am not a nuclear engineer so maybe this is a dumb question but I have dealt with lots of disasters including Katrina and know that failures of the power grid over an extended period could result in the loss of backup cooling due to diesel fuel running low and such. It seems something more robust and redundant should be used.

    It is my understanding that the typical reactor will produce between 5-7% of its rated output in decay heat due to the radioactive decay of fission byproducts after shutting down. I understand that the amount of heat generated depends on the length of time the fuel has been in use and undergoing fission so older fuel will have a larger decay heat. I understand the heat generation drops quite rapidly as the short lived isotopes decay but that longer lived isotopes continue to decay and generate heat so that cooling is needed for a very long time (5-10 years) after the spent fuel is removed from service.

    I looked up the operational rating of several nuclear power plants in the U.S. and most tend to range between 1000-1200 MW of power, which is quite a large number. When one of these shuts down, decay heat should be generated in an amount around 50 MW (or more) immediately after shutdown based on the 5-7% heat of operation. 50 MW is an immense amount of power and I would think this would well exceed the rated output of even the largest (or a bank of) diesel generators.

    My question is why this tremendous amount of energy cannot be harnessed and used to generate power that could be used to safety shut down and cool a nuclear reactor. It seems there is plenty of heat to lead to a complete core meltdown and/or fire long after the primary fission reaction is shut down. Why can’t this heat be used to generate power, whether it be electrical or mechanical, in order to run pumps and such to cool the reactor during shutdown? Why couldn’t one of the steam turbines be run to generate power to run the pumps? If the main turbines are too large to run on such a reduced output, could a smaller turbine be used for backup purposes? How about running the pumps directly and mechanically without any electric generation via a turbine meant just for this purpose? I like to keep things simple as there is less to go wrong so a purely mechanical pump might be in order. How about a thermocouple system? I know that radioactive decay is used to power space probes in this manner and such but don’t know how it would work on such a large application. Even if decay heat cannot produce enough power, can it not provide some power and reduce dependence of batteries or diesel? If nothing else, it could reduce the rate at which batteries or diesel are used up and buy time to solve the underlying problem.

    As decay heat drops, potential power generated from it also drops, but so would the cooling requirements. Pumps would not be able to be run at their maximum rating but is this a bad thing after most of the short lived isotopes have decayed? I am not an expert so maybe decay heat can remain dangerous even if it isn’t enought to generate a meaningful amount of power. Is it like my electric stove. Sometimes I turn it off right before the food is done and let it cook with the residual heat. Eventually it cools off to where it can no longer cook but would still be dangerous to touch. I know this is very simple but is it a good comparison?

    If decay heat cannot effectively be used to shut down a nuclear reactor, why can’t the reactor go down to an “idle” mode where it generates just enough power to run the emergency cooling systems? It could be run this way indefinitely and let some of the short-lived isotopes generated during full power operation decay over a period time before reducing power further or shutting down completely once enough short-lived isotopes have decayed. Why is this not done?

    All it takes is one unforeseen disaster to knock out external power at a nuclear plant and it seems this might be a solution or at least part of the solution to the decay heat issue. I have been reading about solar flares and their ability to fry large electrical transformers that are key to large parts of the power grid. I understand that we are entering a very active solar cycle and there is some concern one of these flares could knock out a large part of the grid for an extended period. What would happen to a nuclear plant in such a situation?

  335. As much as nuclear energy proves effective on large scale production, a simple breach could be very catastrophic, solar and wind energy is the only safe way out. Lets embrace safe green energy.

    festow32@gmail.com

    Moved to Open Forum by the moderator

  336. hello this is biomenta from germany. as you know the time nuklear machines end in 2021 but other euopean countries like france buld new machines. the question is, why can’t we find a worldwide solution

    Moved by the Moderator to Open Forum

  337. We tolerate risk in all other technologies for generating energy. In fact we tolerate assured depletion of finite resources, loss of miners/drillers, and release of greenhouse gases. Yet nuclear energy has to prove ahead of time that it is utterly without risk. A scientific approach, were the nation to adopt it, would be to consider the risks of traditional energy production when compared with nuclear power. Unfortunately, the emotional has trumped the rational. That an aging reactor survived a direct hit by a tsunami is a triumph of engineering. If we applied the same expectations to automobile design, we would have to drive Bradley fighting vehicles (and go broke paying for them).

  338. Moved by the Moderator to Open Forum:

    At the heart of the problem is the fact that safety upgrades will impact the bottom lines for a significant portion of the U.S. reactor fleet. Reactor operators face significant capital expenses such as making SNF pools nuclear safety-rated, movement away from high density SNF storage, repair/replacement of degraded piping, hydrogen mitigation measures, etc.. For instance, According to EPRI, the additional per-reactor costs of placing SNF greater than five years of age into dry storage ranges between $573 million (BWRs) to $760 million) (PWRs).

    Plus there is the potential for loss of revenue from the closure of aging reactors, that are no longer economical with these additional expense and/or are under siege by a growing number of states – especially BWR Mark I units, reactors in high-risk siezmic areas, or those too close to major population centers (ie Indian Point).

    This is a big problem for those reactor owners operating in a de-regulated environment, notably Exelon with close ties to Obama, which don’t have a captive rate-base to recover these expenses

  339. I agree with you Kathryn. Why government doesn’t focus on research of environment friendly power resources like solar and wind systems?
    Nuclear reactor incidents can kill us all. Perhaps US can prevent nuclear reactor incidents what about other country with poor standard like North Korea, Iran, or Indonesia?
    If something happen with their reactor its hard to prevent radio active exposure event our location far away from their reactor. In this case, I believe we still have any chance to get radio active exposure.

  341. The plant declared both Unit 1 diesel generators inoperable based on the licensee’s engineering analysis which is not only site specific: it is specific to the type of diesel generators used for Unit 1; their location; and the amount of space and ventilation available to the diesel and associated equipment. In this case, the major concern was not so much the possibility of direct damage to the diesel itself but impact on electrical and other auxiliary equipment located in the diesel room. If, in addition to the heat produced by a running diesel the ambient temperature in the diesel room is unusually high, the auxiliary equipment adjacent to the diesel may overheat and affect its operability. If Unit 1 diesel generators are not available, Unit 2 diesel generators which are of different design could be used to supply power to Unit 1 equipment.

    The NRC is still reviewing this issue for compliance with NRC regulations and design requirements.

  342. NRC,
    I have a question this event notification was from 6-8-2011. It seems to say that the Prairie Island plant’s emergency generators were off line because of excessive outside heat. Am I reading this correctly? If so is this something that affects all nuclear plant backup generators or is it site specific? Thanks

    “BOTH EMERGENCY DIESEL GENERATORS DECLARED INOPERABLE DUE TO EXCESS OUTSIDE AMBIENT AIR TEMPERATURE

    “Outside ambient air temperature exceeded the maximum analytical value for operability for Unit 1 D1 and D2 Diesel Generators at 1349 CDT. The calculated limiting outside air temperature needed for equipment in the D1 and D2 rooms to meet their temperature limits is 100.5?F. Outside ambient temperature exceeded this limiting value and both Unit 1 safeguards diesel generators were declared inoperable at 1349 CDT on 6/7/2011. If outside ambient air temperature is above the maximum analytical value, components within the D1 and D2 diesel rooms may not be able to perform their required functions thus preventing them from fulfilling their safety function needed to mitigate the consequences of an accident (10 CFR 50.72 (b)(3)(v)(D)).

    “Unit 1 is currently in Mode 3, Hot Standby. Ambient outside air temperatures are at or near peak values for the day and expected to decrease approximately 1 to 2 degrees per hour which will restore ambient conditions to less than the maximum analytical value.

    “The NRC Resident Inspector has been notified.”

    The outside air temperature has peaked at 101.4?F which is unusually high for this location and is expected to drop below the 100.5?F limit shortly. The licensee does not anticipate that this condition will be repeated again any time soon.”

  343. Thanks Art and moderator for helping with those links. Yes that’s what I was looking for Art.

  344. Yes, well it was 3 days before serious help could arrive because FEMA prevented people (regular folk you know, not “experts”) from helping their fellows. I don’t think I want the National Guard “protecting” me. These so-called homeland security agencies seem good at taking tax money but not so good on the protection end. I think we need protection FROM them. What did gun confiscation during Katrina have to do with protecting people from flood waters? Let us not forget that levees (thanks to the core of engineers) are blown to flood certain areas so that other “more important” areas are more protected from damage. Who decides? And on what criteria? Who among us is less or more important? I guess that’s left up to the actuaries and the insurance companies.

  347. Nrc,

    Do you have a link to a transcript of the 6-8-2011 meeting with the group Beyond Nuclear where the petition to close the GE mark 1 plants in the US was discussed? Thanks

  348. I share Nancy concerns.
    Remember Katrina – it was 3 days before serious help could arrive, other than Coast Guard helicopters, which were kept very busy. In fact FEMA has some guidelines how many days supplies people should try to have, because of how long until National Guard can get there, so similar thinking is needed for how long a power plant may be without aid, if there is a regional disaster like Japan, causing reduced capacity to respond to individual events among the thousands, and delays to provide aid, due to damage to transportation infrastructure. There can also be disruption to telecommunications, delaying SOS getting out.

    In anticipation of this, critical infrastructure ought to have satellite phone available, in case cell towers and land lines go down. Regional homeland security should know what are critical infrastructure, check in with them when regional disaster, to make sure their needs not neglected. There needs to be availability of helicopters and marine landing craft for search and rescue forces along flooded areas.

    Fukushima plant design has spent pools above containment, and no way to vent hydrogen, leading to holes in roof, radiation escaping, problem managing radioactive water. My understanding is that US design has spent pools closer to ground level, stored longer time period. I sure hope those buildings are earthquake resistant, well protected against flood waters.

  349. I agree with this
    I want to add my concerns about the dangers of station blackout and loss of cooling accident. The disaster in Japan showed everyone that emergency safety protocols must be updated in the US.

  350. Nancy Allen May 22, 2011 at 1:56 pm Your comment is awaiting moderation.
    I want to add my concerns about the dangers of station blackout and loss of cooling accident. The disaster in Japan showed everyone that emergency safety protocols must be updated in the US. The present emergency response cannot be considered adequate to address all events that would cut power to the reactors for an extended period of time. There is a need for power generation other than just back up diesel generators and the 4-8 hour back up batteries. There should be an immediate effort by the NRC to have a power supply available for all natural catastrophic events including large magnitude earthquakes, tsunamis, tornadoes, hurricanes and more. If there is no emergency design criteria that can anticipate and fully prepare for this no new plants should be built and old ones relicensed only if they meet stringent NRC safety regulations with a back up alternative energy supply like wind, solar, geothermal and more.

  351. Reg guide 1.8 outlines the training requirements for SRO’s and will be looked at on a case by case basis. If an individual without a bachelorette degree had a technical background in quality control would they be considered for the instant SRO program if they have three level III’s from the American Society of Nondestructive Testing, a CWI from American Welding Society and over ten years of nuclear experience?

  352. I agree with
    The resulting effects from the earthquake and subsequent tsunami on the power station in Fukushima will in all likelihood result in a statistically insignificant number of casualties of any kind

  354. This comment has been moved to this page by the moderator:

    Hello,

    Recent Congressional correspondence related to Yucca Mountain SER was made publically available through several websites. They included a letter from Chairman Jaczko as well as another letter signed by four Commissioners. Read together, it appears that the Chairman is not following the will of the Commission as a whole in sending policy views to Congress. If true, this is a major breach of existing protocol and calls into question whether the NRC has a Commission or a sole Administrator. What’s really going on? Thank you.

    Here’s a link to one of the stories.

    http://www.nucleartownhall.com/blog/rebellion-at-the-nrc-jaczko-outvoted-4-1-on-release-of-safety-report/

  355. Non sequitur. This is a typically overwrought and hysterical response. The resulting effects from the earthquake and subsequent tsunami on the power station in Fukushima will in all likelihood result in a statistically insignificant number of casualties of any kind. The facilities in Japan performed extremely well considering the magnitude of the event, and the operators and authorities there have responded in a most timely and effective manner. I would suggest that the preceding posters’ angst would be more effectively directed at banning walking outdoors, as the risk of injury and death from that engaging in that activity is exponentially higher.

  356. I’ve done several searches via your NUREG page and the ADAMS interface for NUREG 0408 and other documents applicable to the Mark I containment and Mark I containment short and long term programs from the 1970s and 1980s. Why are these not available?

  357. OK, I wonder who’s bright idea it was to build a nuclear plant on a subduction plate. Even if we survived this catastrophe, what happens down the road when this planet gets into the ring of fire? We might not have a planet left to talk about. Hillary Clinton said on CNN that we didn’t have the foresight to see this catastrophe, but I disagree with that.

  358. Yes, the NRC is following the impact of the earthquake in Japan and the resulting tsunami. Please see our latest blog post outlining NRC actions. However, we cannot speak for the Japanese government on their actions nor on the specifics of their plants.

    Holly Harrington
    Blog Moderator

  359. Is the NRC staff following the recent news from the earthquake in Japan? Can you post some reliable technical information regarding the impact of the earthquake on Japanes nuclear facilities? What is the significance of the evacuations that have been ordered due to “failure of backup generators”?

  360. Thank you for the opportunity to comment. In a few days the NRC will likely give Vermont Yankee another license period. This is the same plant which has had a cooling tower collapse , a two story transformer fire ,unaccounted for missing fuel rods , cracks in the steam dryer and Tritium , Cobalt 60 and Ziinc 55 found in the groundwater test wells nearby and I won’t repeat the earlier post about Strontium 90 in the fish in the nearby river. In a recent NRC report ( 2009 ? ) the estimate for a severe accident was every 1 million hours of man-operations. That works out to every 114 years. I suppose ”severe accident” is a euphemism for a meltdown. Great research guys ! The 4 partial meltdowns we’ve had in the US were all within 15 years of starting operations : Simi Valley , Idaho SL-1 , Enrico Fermi and TMI.
    Your Radioprotection Health Officer , a nice woman who I’ve met , would be interested to know that a health study was done and the 6 towns surrounding Vermont Yankee were found to have a slightly higher incidence of Leukemia in comparison with the rest of the county. Please forward this comment to your chairman. Thanks.

  362. Howdy from Missouri! Just would like to post that NRC.GOV is my home page on my personal home computer. That’s all. Sincerely, Paul Christopher Anzalone

  363. It’s not clear what reviews or reports you’re referring to, but here are some links that might be helpful:

    How the NRC reviews new plant designs: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/new-nuc-plant-des-bg.html

    How the NRC reviews new reactor applications: http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0298/

    How the NRC reviews reactor license renewals: http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0291/

    Moderator

  364. I think it an important step in the right direction to put up this blog site. Collaboration and Communication is essential for projects of the magnitude as energy. Energy project affect everyone and everyone should know how things are going. Thanks.

  365. Thank you for a very informative article, along with interesting comments. It is rather disconcerting to consider all these issues with old and newer reactors, particularly for those of us caring for elderly parents who live far from us but near an older reactor. One more issue for those of us in the Sandwich Generation to have to take into consideration. I appreciate this website to keep us updated and informed.

  366. I have been told by NRC staff that Chairman Jaczko has been directing the staff to take various policy positions in papers being sent to the Commission either for information or for a vote. Recent examples would be the paper on Yucca Mountain and the paper on Waste Confidence which is close to being delivered to the Commission. If this allegation is true, it is quite disturbing. Openness demands that the public know what the professional staff’s views are before the Commission acts. If the staff’s views are modified by the Chairman before policy papers are delivered, how will the public ever know the staff’s real views?

  367. I would like to know more about your review process. Many people are confused about the long periods of time that are invested in providing a report on requests. For instance is their a research team that needs to study the technology being reviewed? Is there a consultation with the professionals about their processes? Your role is a complex one to understand so any information that can explain why some reports can take years and not just months.

    Moderator: This comment has been moved here from a different post.

  368. As of recent, the NRC is becoming more dependant on industry’s ghost stories, basically unsubstantiation stories and events dressed up as fact. They and the industry are increasingly representing a filament or fragments of the facts, partial and incomplete evidence and truth in documents and testimony. The examples I would give is the engineering, design, licensing bases and UFAR of the VY AOG piping radiological containment system. A developing problem is a factual understanding of the technical meaning of environmental LLD…the standards of how long a sample stays in a scintillation counter that gives us a LLD…what is the minimum level of detection of tritium and what constitutes a indication of a radioactive leak? Don’t give me it is 2000 picocuries per liter…Vermont establishes it at 670 to 700 picocuries. Has the NRC in their deeds and actions…in their hearts… been gaming the first emergent indication of a radiological leak at the nuclear plants?

    We are getting a lot engineering ghost stories out of the agency recently…the facts are so thin it is like translucent ghost and just fragments of the truth floating all around us.

    There was a lot of ghost floating around in the part 26 commissioner meeting yesterday, did you see them…in LERs, the ROP and the inspection reports…its like Halloween all time and all year long.

    The NRC is just becoming a “not facts” based agency!

    Mike Mulligan

    Moderator: This comment has been moved here from a different post.

  369. Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
    Title: 10 CFR 2.206 Petition Review Board RE Vermont Yankee
    Thursday, February 3, 2011
    CHAIRMAN QUAY: At this point I would like to turn it over to Mr. Mulligan.
    Mr. Mulligan: Hello. I’ve got to get this on the record. When you first pushed the button when I came on the phone, I heard a snippet of information and the snippet of information was, “Let’s have a little fun.” What was that about?
    CHAIRMAN QUAY: That was me. I was welcoming a new Board member. She hasn’t been here before and I said, “This will be fun for you.” The reason I said that is it’s a new experience. It’s an experience which all of us need to have is interacting and learning how to interact with the public.
    MR. MULLIGAN: Who is this?
    CHAIRMAN QUAY: This is Ted Quay.
    MR. MULLIGAN: Okay.
    CHAIRMAN QUAY: Okay?
    MR. MULLIGAN: Thank you

  371. since you did not include my earlier post it is obvious you are censoring posts you don’t like. NRC is living a culture of corruption. Jaczko must go.

  373. I remember seeing “The China Syndrome” as a kid and it kind of freaked me out. I have always wondered how realistic was that movie in terms of what Jack Lemmon’s character was freaked out about. Forty years later and I do not recall any big snafus, which makes me wonder about the comment above regarding nuclear infrastructure as “aging”. Any insights on this?

  374. The NRC has jurisdiction over all civilian (e.g., non-weapon) uses of nuclear materials in the United States. For example, the NRC regulates a research reactor operated by the Armed Forces Radiobiology Research Institute, while Congress has directed DOE to seek NRC licensing for the Next-Generation Nuclear Plant, a Generation IV project. The White House can designate specific facilities as being under the self-regulation of either the Department of Energy or the Department of Defense. DOE self-regulates a few of its own research reactors under this authority. The NRC, DOE and DOD have been discussing other small modular reactor concepts, some meeting the Generation IV definition. Both DOE and DOD have indicated they will seek NRC licensing for any small modular reactor projects at their respective facilities.

  375. I have read that the American military has more freedom as do research labs. If the military wanted to start developing their own Generation 4 reactor is there any reason they need to consult with the NRC?

    Moderator: This comment has been moved here from a different post.

  376. This is my test drive of the new car.
    If this is the new NRC…it is something?
    This transparency is powerful stuff…having people see events in their near immediacy….having people all see the information at the same time, or at least letting people see indiveguals interpretation of events, not just the bureaucrats’ and licensee interpretation of events.
    …It is transformational.
    Congratulations to the NRC!

  377. Part Two ==> China has grand plans to build enough nuclear power plants to supply 200 gigawatts by 2030, and do it with a modified (Gen-III) Westinghouse AP 1000 design. Now they’ve included TFMSR’s in the plans, which may eliminate the need for the much more expensive Westinghouse LWR’s. Their nuclear capacity is already replacing coal-fired plants amounting to 60 gigawatts since 2006.

    China has 13 nuclear plants in operation today, another 25 under construction, and 200+ more on the drawing boards. They aren’t waiting around to sign any pollution reduction treaties, they’re just *DOING* it! Now they’re siezing the fantastic opportunity to leap straight ahead to Gen-IV designs, such as TFMSR and Liquid Flouride Thorium Reactors (LFTR’s). Please google “Energy From Thorium” and “Thorium Energy Alliance”. I promise you’ll be amazed.

    By the way, the United States is preparing to destroy (i.e., down-blend and bury) one thousand kilograms of Uranium 233 (currently classified as toxic nuclear waste). U233 can be used to produce many beneficial medical and industrial isotopes, and is an ideal “starter” fuel for TFMSR’s. It’s going to cost several hundred million dollars to destroy this valuable stockpile of U233. The United States could proceed with the destruction plans — which would make the Chinese TFMSR success more difficult — or, we could develop our own TFMSR program and beat the Chinese to the patent office. The latter notion gets my vote.

    So here’s a new challenge for the NRC: adopt and adapt regulations to take into account the concept of liquid fueled reactors that can operate at atmospheric pressure and passively shut down in an emergency. The SCRAM process for a liquid fuel reactor will manually or automatically drain the molten core into holding tanks where the fuel solidifies and traps all the radioactive materials. What a concept!

  378. The NRC has a regulatory role related to DOE’s program seeking utilities to use weapons-grade plutonium fuel (MOX) in commercial nuclear reactors. After Duke Energy withdrew from a failed test of MOX fuel in 2008, DOE was left with no utilities which even had interest in MOX. Now, DOE has turned to the TVA and Energy Northwest (Richland, WA), and is attempting to convince them to use weapons-grade MOX, which has never been used on a commercial scale and never even tested in a BWR. But any use in BWRs or PWRs will need a full three cycles of testing, licensed by the NRC, to see if “batch” use of MOX can be licensed by the NRC. As DOE, Energy Northwest (EN) and TVA, which has a MOU with EN (see that in documents linked below) failed to provide information to the public about the interest in MOX by EN, that has been done by Friends of the Earth, in the public interest: “Secret Plan Exposed to Use Surplus Weapons Plutonium in Washington State Nuclear Reactor” – see:
    http://www.foe.org/secret-plan-exposed-use-surplus-weapons-plutonium-washington-state-nuclear-reactor

  379. An issue which the NRC very much needs to address is the matter of the Yucca Mountain Nuclear Waste Repository. NRC Chairman Gregory Jaczko’s actions regarding this matter have been extremely disturbing.

    Last year, the NRC’s Atomic Safety and Licensing Board ruled that the Energy Department does not have the authority to withdraw its application to build the Yucca Mountain site. This decision is now appealed to the full NRC commission of which Gregory Jaczko is the chairman. In what took the ASLB 39 days to decide, the NRC commission is still deciding and has been doing so for over 200 days. It is quite obvious to everyone involved as well as the public that the decision is being delayed for political reasons.

    Of five NRC commissioners, two oppose Yucca mountain (Jaczko and Magwood), two support Yucca mountain (Ostendorff and Svinicki ), and one recused himself from voting (Apostolakis). If the decision on whether to uphold the ASLB decision was made now, the vote would end in a tie meaning the ASLB decision would stand. This scenario is obviously untenable to Gregory Jaczko so he has delayed the commission’s vote for over 200 days. It is worth noting, at this point, that George Apostolakis, the commissioner who recused himself from voting on this issue, did so because he earlier worked on the DOE license application for the Yucca project. Ironically, Gregory Jaczko, who was senate majority leader Harry Reid’s science advisor and who helped Reid frame arguments against Yucca mountain, has NOT recused himself.

    In this blatantly political action, Jaczko has made it clear that he will use any means at his disposal to stop Yucca Mountain from going forward. Jaczko has already delayed a commission ruling for over 200 days and I have no doubt that he will delay further. In fact, I believe he will delay the decision until William Ostendorff’s term as NRC commissioner expires in June of this year. This will give him free reign to decide the matter how he wishes.

    Gregory Jaczko has turned the once apolitical Nuclear Regulatory Commission into a political tool for Harry Reid to exert control over America’s nuclear policy. He refuses to allow a vote to occur to decide the fate of the Yucca Repository until he can control the outcome.
    The NRC has lost credibility and will continue to lose credibility in the eyes of the American people until a decision is made by the commission. Gregory Jaczko is delaying a legal proceeding for political gain and should resign immediately from his position, as he has lost the confidence of the public.

    I also find it abhorrent that on this blog an NRC moderator said “The decision to cancel the Yucca Mountain Project was made by the White House and the Department of Energy, not the NRC.” The decision on whether or not to cancel Yucca Mountain is still in review! Furthermore, the NRC ultimately WILL decide on whether or not the project will go forward or not based on the commission’s ruling.

  380. Since at least 1982, NRC Office of Investigations (OI) personnel at grade levels of GS-12 – 14, and GS-15 have been misclassified as series 1811, “Criminal Investigator.” To be classified in this series, an individual must meet most of the “frontline law enforcement” factors, and have them largely constitute the position duties:

    1. Perform investigations (long-term, complicated reviews);
    2. Investigate individuals suspected of or convicted of violating criminal laws of the United States (employing agency must have criminal investigation authority);
    3. Have the authority to carry weapons;
    4. Have the authority to arrest, seize evidence, give Miranda warnings, and execute search warrants;
    5. Have a “rigorous” position which includes unusual physical hazards due to frequent contacts with criminals and suspected criminals, working for long periods without a break, and being in on-call status 24 hours a day.

    For LEO retirement credit, one must show that the primary duties of the position are the investigation, apprehension, and detention of criminals or suspects. The most important factors, are: 1) frequently pursuing or detaining criminals; 2) an early mandatory retirement age; 3) a youthful maximum entry age; 4) the job is physically demanding requiring a youthful workforce; and 5) exposure to hazard or danger. The factors (above) may also be considered as appropriate.

    OI duties and authorities do not match these criteria, especially since NRC lacks statutory authority for performing criminal investigations. They lack arrest responsibilities, agency authority to carry firearms or other weapons, do not perform undercover work, do not execute search or seizure warrants, do not give Miranda warnings, and are not exposed to hazardous conditions nor inclement weather. Most work takes place in an office setting, and is not “rigorous.” OI investigations do not involve felonies, but violations of the regulations contained in 10 Code of Federal Regulations (Energy). None of their work is “frontline law enforcement work, entailing unusual physical demands and hazards.” In March 2007, the Director of OI admitted that OI personnel have never performed a single arrest. When OI was created, a proposed desk audit of investigative positions to determine the correct job classification was cancelled. OI personnel have indicated that “NRC is the best-kept secret on the 1811 circuit!”

    Letters from the NRC to the Civil Service Commission or Office of Personnel Management (OPM) regarding 1811 classifications and law enforcement retirement contained vague, erroneous, or misleading and false information. These letters indicated high percentages of criminal investigations, or investigations involving “matters of potential criminality covering a wide spectrum of violations.”

    The position of “Investigation Specialist,” later “Investigator,” began with the Atomic Energy Commission (AEC). These positions were series 1810, located in the Division of Compliance, and the investigation reports issued were titled “Compliance Investigations.” These positions were clearly originally established to conduct civil investigations to determine compliance with the regulations found in 10 Code of Federal Regulations (Energy).
    OI investigative personnel actually perform the duties and responsibilities of the series 1801 or 1810 classifications, and meet the 1801 or 1810 position classification guidelines and qualification requirements. Personnel classified in series 1801 or 1810 do not receive early retirement nor availability premium pay. The 1801 series guide, for example, specifically speaks to positions where investigations relate to violations of regulations and criminal matters are referred to another agency for criminal investigation.

    The result of the misclassification is that the NRC has unnecessarily paid OI investigators early retirement and premium pay (Administratively Uncontrollable Overtime [AUO] or “availability pay” of 25% of their salary), amounting to hundreds of thousands of dollars per year, and totaling millions of dollars during the period 1982-2010. The 25% availability pay is included in the OI investigators’ basic pay, and therefore raises the “high three” salary years utilized to determine retirement pay. Also, a more beneficial percentage is used to calculate retirement benefits. A very conservative analysis indicates that the overpayments greatly exceed $700,000 per year (the effect on Thrift Savings Plan agency contributions and retirement benefits of an additional 25% during an employee’s “high three” years was not calculated).

    OI Investigations largely consist of interviews with a court reporter present, and document reviews. Between 7% – 30% of the cases are referred to the Department of Justice (DOJ) for prosecutorial review, but very few are accepted for further investigation, and even fewer result in convictions. In extremely rare cases, the OI investigator may provide assistance to the DOJ in its review or investigation, and may provide testimony in court or before a Grand Jury. In vanishingly rare cases, the investigator may assist in obtaining and executing a search warrant (accompanying the primary law enforcement officers), or collecting physical evidence.

    A chronology of events indicates that NRC senior management was well aware that NRC did not have the authority to conduct criminal investigations, had not given such authority to OI, and that OI did not perform criminal investigations. In the early years, OI did not even directly interface with the DOJ, but passed their investigations to the Office of Inspector and Auditor for referral to DOJ. Of central importance is a memorandum dated October 15, 1982 in which the NRC Deputy General Counsel advised that, lacking statutory authority, NRC personnel should not conduct criminal investigations under any circumstances. Subsequently, numerous submittals were made to OPM, claiming that all OI investigations were criminal investigations.

    Perhaps as importantly, on April 9, 1984, the full NRC Commission received a Briefing on Criminal versus Civil Investigations. A draft document giving OI the authority to conduct criminal investigations was discussed, with the Commission strongly objecting to and directing removal of the term “conduct” and substitution of the word “assist.” Quotes: “we believe that the Commission – and OGC has taken this position in the past – that the Commission does not have independent authority to conduct criminal investigations.” “Yes, our policy is to first serve our civil purpose and then help DOJ.” This briefing led to a commission paper used as guidance in negotiating a Memorandum of Understanding with the Department of Justice.

  381. Public Participation
    Wondering if you will make this a seperate NRC blog issue?
    (The point I make, is public participation fun for the NRC, they don’t take it as a serious business.

    NRC “having fun” over Vermont Yankee 2.206

    So I am on the phone bridge this morning Feb 3, 2011 at 9am, I identify myself to the mechanical voice message system, then I am just kind of waiting around in silence on the phone waiting for them to push the button to join the conference. I assume there are people on the voice bridge, and then there are NRC officials in one or more rooms on a speaker phone device.

    All of a sudden I hear a click, I hear the snippet “and have a little fun”, then I hear the talking of all the NRC officials, then the “welcome to this is a 2.206 petition…”. All the background chatter of the officials stops…then we are off to the races with the 2.206 processes. From this point on everything is recorded in the NRC ops center and it is transcribed for addition into the public record.

    They do the introduction, then they give me the microphone so to speak. I say I got to get this down on the record. I just heard a snippet of “and have a little fun” when I first came into the meeting, when I was connected to the phone bridge…what did you mean by this? It was a male voice talking to a female.

    I am thinking two NRC officials were talking about outside activities, but you never can tell what is behind it. I said to myself too, they just might be talking about have having a little fun with me in the meeting.

    The chairman of the petition board pops up explaining on my phone, “I was introducing a new NRC official to the petition board and I was telling her to have a little fun as she participates and listens to your review board” concerning tritium and root cause analyze issues at Vermont Yankee. I want to force a shutdown of VY and remove the licenses of all the Entergy nuclear plants, or at least get peoples attention…

    Can you imagine a 2.206 petition meeting chairman indoctrinating a new NRC official into the petition process by saying have a little fun with it. Are they all laughing and making faces behind my back as I am stuttering and fumbling my way through my speech. Are they laughing and having a little fun over us all?

    Mike Mulligan

    Moderator: This comment has been moved here from a different post.

  382. The NRC Chairman’s recent actions regarding suspension of Yucca Mountain staff review of the license application is a disgrace to the NRC as an agency. If one person, chairman or not, can stop a licensing proceeding the stability of the NRC licensing process is undermined. NRC’s only job should be nuclear safety — not political favoritism. Not allowing the Commission vote on the Yucca Mountain CAB ruling is nothing short of a coverup. So much for openness in government.

    Joe Ziegler

    Moderator: This comment has been moved here from a different post.

  383. I am concerned about the aging nuclear reactors in the US. Recently there have been multiple incidents — scrams — that indicate less than secure conditions. I believe the public is being kept in the dark about the danger they are in because of the lack of repairs and continued use of aging nuclear reactors. I would like to see them all shut down, and replaced by solar and wind systems.

    Kathryn Barnes

    Moderator: This comment has been moved here from a different post.

  384. When will the NRC be releasing SER, Volume 3? What is the rationale for holding it up and how does this support the commission’s commitment to openness and transparancy?

    Frank

    Moderator: This comment has been moved here from a different post.

  385. Thank you for the opportunity to speak out. The NRC allowed Vermont Yankee to forgo the ASME 10 year welds exam scheduled for 2010 and replace it with their own welds exam while Vermont Yankee has had the same internal radioactive leaks due to old welds in the same area two years running ?!? The Connecticut river now has Strontium 90 found in the fish in proximity to the Vermont Yankee nuclear power plant.
    Strontium 90 which the EPA says on their website causes Leukemia and bone cancer. Strontium 90 which
    has a half-life of 27.8 years and was produced at Vermont Yankee as effluents in 2002 , 2003 and 2004.
    We can collectively thank the NRC for contributing to the health of the American people.

    Peter Van der Does

    Moderator: This comment has been moved here from a different post.

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