Gregory Jaczko Fukushima Lessons for California

You do not have to be against nuclear power,
to be against restarting the San Onofre nuclear power plant. 

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



In this segment the Former Chairman of the Nuclear Regulatory Commission, shares his views on nuclear safety issues in the U.S. in the light of the on-going Fukushima disaster, and his view that San Onofre should not be restarted.

The public forum, held June 4, 2013 in the San Diego City Council chambers, was organized by Torgen Johnson.

In addition to Prime Minister Kan (ably translated by Cathy Iwane) speakers included:
Gregory Jaczko, Former Chairman of the Nuclear Regulatory Commission; Peter A. Bradford, former member of the NRC; and Kendra Ulrich, Friends of the Earth.

Captured by EON and reposted here as a public service.

Gregory Jaczko Fukushima Lessons for California
Nuclear Accidents Do Happen. ~ Gregory Jaczko


Aging Nuke Plants On Fault Lines In Tsunami Hazard Zones = Fukushimas… Any Questions?
PLEASE Turn off a light for Fukushima USA / San Onofre

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Why fatigue damage will stop the NRC from allowing Unit 2 to restart




FATIGUE DAMAGE TO SONGS STEAM GENERATORS

J. Hopenfeld 

Provided to the “DAB Safety Team” as additional explanation of the fatigue damage to SONGS steam generators which was discussed in a report by the author and was submitted to the California Public Utility Commission on March 29, 2013


Note: Links to these documents are listed below 
SCE/MHI made a mistake in their stress analysis, which directly impacts the safety of restarting Unit 2.  When the error is corrected, the result clearly shows that Unit 2 has already used up its allowed fatigue life and is not fit for service any longer.  This means that if Unit 2 is restarted at any power level an abrupt pressure change such as inadvertent closing or opening of a valve or a steam line break could lead to a sudden tube ruptures.   The ASME code and NRC regulations do not permit safety components to operate when their fatigue life has been exhausted.

The source of MHI’s error resulted from how they calculated the increase in the local stress at geometrical discontinuities  (notches), which are formed when two metal surfaces come in contact during vibration.  Since the worn surfaces of the tubes inside the steam generators cannot be seen, MHI made two key assumptions, which are inconsistent with the observation that both the tube and the supporting bar are worn into each other.  First, MHI assumed that the ASME endurance limit could be applied directly to the notched tube surfaces.  Since it is commonly known that surface roughness significantly reduces fatigue life and since the ASME data is for smooth polished surfaces, this assumption would underestimate the amount of fatigue damage.  Second, when using the Peterson chart, MHI assumed unrealistically large fillet radius and consequently derived a low concentration stress factor.  Large radii would decrease the local stress and cause the tube to fail at a higher stress thereby increasing its fatigue life.  Only by using these two, arbitrary non-conservative, assumptions was MHI able to conclude that Unit 2 did not suffer any fatigue damage.

As depicted in the MHI drawings the support bar and the tube form a sharp discontinuity at the contacting surface, therefore the appropriate geometry for calculating the stress concentration is an abrupt geometry change (very small radii), not a large radius shoulder fillet that was assumed by MHI.  When a correction is made to account for the sharp notch, the corrected stress indicates  (see Figure 1 below) that the tubes have used up their fatigue life during the first cycle of operation.  Structures with sharp notches can fail catastrophically when subjected to high cycle vibrations.  (MHI redacted their assumption so the exact value of the radius they used is unknown.)

 The loss of fatigue life is a major defect in the tube material; NRC regulations 10CFR50, Appendix B, Criterion 16 specify that for a licensee to maintain his operating license, such non-conformance must be promptly identified and corrected.   The licensee must assure that “corrective action (is) taken to preclude repetition.  NRC’s General Design Criteria 4 and 10CFR50 Appendix A also specify that steam generator tubes must be able to “ accommodate the effects of loss of coolant accidents “ The fact that the NRC has not already raised these issues in any of their  “Requests for Additional Information, RAIs” indicates that the NRC would be ignoring its own regulations if it allows SCE to restart Unit 2.

 In Summary: The SCE request for approval to operate Unit 2 at 70 % power for 150 days provided no explanation for the selection of this inspection interval.  The absence of such explanation and the absence of an indication of the actions that would follow demonstrate the unreliability of SCE entire assessment of restarting Unit 2.  Edison did not specify pass/fail criteria for the tubes during the outage inspection.  Given the fact that fatigue damage does not lend itself to detection, SCE request is unacceptable and should be rejected. 

  

Aging Nuke Plants On Fault Lines In Tsunami Hazard Zones = Fukushimas… Any Questions?
PLEASE Turn off a light for Fukushima USA / San Onofre

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NRC: The Good, The Bad and the Ugly

NRC: The Good, The Bad and the Ugly

… and why it is unsafe To restart San Onofre



A GOOD NRC enforcement example:


Davis-Besse Nuclear Power Station is a nuclear power plant in Oak Harbor, Ohio. On March 5, 2002, maintenance workers discovered that corrosion had eaten a football-sized hole into the reactor vessel head of the Davis-Besse plant. Corrosion had been clogging the plant’s filters for months, requiring repeated filter replacement, but the cause was not investigated until after a worker leaned against a control rod drive mechanism, and it toppled over. Although the corrosion did not lead to an accident, this was considered to be a serious nuclear safety incident. Some observers have criticized the NRC’s Commission work as an example of regulatory capture [See Note 1] and the NRC has been accused of doing an inadequate job by the Union of Concerned Scientists.  The Nuclear Regulatory Commission kept Davis-Besse shut down until March 2004, so that FirstEnergy was able to perform all the necessary maintenance for safe operations. The NRC imposed its largest fine evermore than $5 million—against FirstEnergy for the actions that led to the corrosion. The company paid an additional $28 million in fines under a settlement with the U.S. Department of Justice. The NRC closely monitored FENOC’s response and concluded in September 2009 that FENOC met the conditions of the 2004 order. From 2004 through 2009 the NRC reviewed 20 independent assessments conducted at the plant and verified the independent assessors’ credentials. The agency also conducted its own inspections and reviewed FENOC’s reactor vessel inspections conducted in early 2005. NRC inspectors paid particular attention to the order’s focus on safety culture and safety conscious work environment to ensure there were no new signs of weakness. The NRC task force concluded that the corrosion, occurred for several reasons:


·    NRC, Davis-Besse and the nuclear industry failed to adequately review, assess, and follow up on relevant operating experience at other nuclear power plants;
·    Davis-Besse failed to ensure that plant safety issues received appropriate attention; and
·    NRC failed to integrate available information in assessing Davis-Besse’s safety performance.



A BAD NRC enforcement example:

At San Onofre by Region IV and the NRC: The papers shown below have been obtained from Public Domain written by Dr. Joram Hopenfeld and a former SONGS Employee based on his investigation of the steam generator issues, review of the plant data and discussions with several Key SONGS Insiders. These papers confirm that Southern California Edison wants to restart unsafe Unit 2 nuclear reactor at 70% power under false pretenses, just for profits, and as an unapproved risky experiment by subverting the NRC and Federal regulatory process.  The true Root Cause (See Note 2) of the unprecedented tube-to-tube wear in Unit 3 has NOT been officially established, as required by NRC Confirmatory Letter Action 1 for restarting the defectively designed and degraded Unit 2.  NRC has not even completed their review of Unit 2 Return to Service Reports, nor have they finished Special Unit 2 Tube Inspections, nor have they (publicly?) reviewed SCE’s Response to NRC’s Requests for Additional Information (RAIs).
NOTE: NO FINES ARE MENTIONED – WHY?



An UGLY NRC enforcement example?:

Now, SCE wants the NRC to approve a new shady License Amendment, undermining public safety and they want it done without the involvement of Public Safety Experts, Attorneys and/or Citizens/Ratepayers.  After the review of the Mitsubishi Root Cause Evaluation and the Draft SCE License Amendment, it is crystal clear that the NRC needs to follow the example of their own enforcement at David Besse together with the lessons learned from Fukushima, when it comes to NOT approving this new Shady License Amendment for restarting San Onofre Unit 2’s defectively designed and degraded replacement steam generators.  In light of the unanticipated/unprecedented tube leakage at San Onofre Unit 3, the health and safety, along with the economic concerns/objections of 8.4 million Southern Californians’ MUST OVERRIDE and PREVENT the restarting of Unit 2 at ANY power level.  In a Democratic Society, truth must prevail over profit motivations, misleading propaganda of electricity service disruption and/or projected probabilistic temporary inconveniences to the public based on phony data, because America cannot afford a trillion dollar nuclear eco-disaster!


Our Safety must override SCE’s profits and prevent them from restarting Unit 2.
Notes:

1: Regulatory capture occurs when a regulatory agency, created to act in the public interest, instead advances the commercial or special concerns of interest groups that dominate the industry or sector it is charged with regulating.  Regulatory capture is a form of government failure, as it can act as an encouragement for firms to produce negative externalities. The agencies are called “captured agencies”.

2. Human performance errors resulting from the negative safety culture of production (profits) goals overriding public safety obligations.




=======================================================================
Additional Information:


The full DAB Safety Team’s Media Alert 5 Parts:

https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=15V8BD4YK0MjwUV6gPZt6ILS_lP7CpClzgnZentLfx8U

The complete five (5) part presentation, see the eight (8) titles listed below:

Aging Nuke Plants On Fault Lines In Tsunami Hazard Zones = Fukushimas… Any Questions?
PLEASE Turn off a light for Fukushima USA / San Onofre

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San Onofre Unit 2 Retainer Bars Could Cause Massive ? Leakage


In an accident like a main steam line break at San Onofre, the badly designed retainers bars in Unit 2 could actually make things much worse by causing more damage to any of the 9,727 already fatigued tubes in each of its steam generators which could lead to additional leakage of highly radioactive reactor core coolant and/or cause a nuclear incident or worse a nuclear accident like Fukushima!


Radioactive Leaks and ruptures can happen without notice:



Allegation/Violations

The NRC has decided in AIT follow-up report dated 11/09/2012, “Item 3. “(Closed) Unresolved Item 05000362/2012007-03, ‘Evaluation of Retainer Bars Vibration during the Original Design of the Replacement Steam Generators” as a non-cited violation in accordance with Section 2.3.2 of the NRC’s Enforcement Policy.”  However, as shown below, SCE/MHI’s failure to verify the adequacy of the retainer bar design as required by SCE/MHI’s procedures have resulted in plugging of several hundred tubes in the brand new replacement generators. This has resulted in these violations:

1. Failure to meet NRC Chairman Standards on Nuclear Safety by SCE,
2. Failure to meet Senator Boxer’s Committee on Environment and Public Works
(EPW) Standards on Nuclear Safety by SCE,
3. Failure to enforce SCE Edison Contract Document instructions to MHI by SCE,
4. Failure to meet SONGS Technical Specifications by SCE,
5. Failure to meet general design criteria (GDC) in Appendix A, “General Design
Criteria for Nuclear Power Plants,” to 10 CFR Part 50, “Domestic
Licensing of Production and Utilization Facilities GDC 14, “Reactor
Coolant Pressure Boundary” by SCE/MHI,
6. Failure to demonstrate that Unit 2 retainer bars will maintain tube bundle
geometry at 70% power due to fluid elastic instability during a main line
steam break (MSLB) design basis event, and
7. SCE/MHI took shortcuts by avoiding the 10 CFR 50.90 License Amendment
Process under the false pretense of “like for a like” replacement steam
generator.  SCE added 377 more tubes, increased the average length of the
heated tubes and changed the thermal-hydraulic operation of the RSGs without

proper safety analysis and inadequate 10CFR 50.59 Evaluation.

This intentional action to produce more thermal megawatts out of the

RSGs compromised safety at SONGS Unit 2 due to the failure of 90

percent through wall thickness of a tube by the inadequate design of the

r

etainer bar.

Recommended Actions:

NRC San Onofre Special Panel is requested to resolve the above listed Allegations and/or Violations within 30 days of receipt of this email and prior to granting SCE’s permission to do any restart “testing” of Unit 2. Answer all allegations factually, don’t just void them.
 
See Full Document:
Media Alert: San Onofre Retainer Bar Problems

Aging Nuke Plants On Fault Lines In Tsunami Hazard Zones = Fukushimas… Any Questions?
PLEASE Turn off a light for Fukushima USA / San Onofre

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San Onofre Legacy (SOL Part 1, 2 and 3)

The DAB Safety Team released three Media Alerts today!


Together they describe (in technical detail) the current situation at San Onofre, along with what SCE, their experts and other public nuclear watchdogs are now saying about all the NRC RESTART QUESTIONS they have been told to answer:


snip:
The following paper shows that the entire NRC Regulatory Process is underfunded, broken and needs additional funding, oversight and extensive overhaul to ensure public safety.
snip:
The presentation by SCE, Mitsubishi and other experts to the NRC was very disappointing and disturbing to 8.4 million Southern Californians.  The presentation did not address U.S. Sen. Barbara Boxer and Congressman Edward J. Markey’s concerns expressed on February 6, 2013 in her letter to NRC Chairman McFarlane, “Southern California Edison was aware of problems with replacement steam generators at its San Onofre nuclear power plant but chose not to make fixes.
snip:
The structural integrity of SONGS degraded retainer bar system to withstand combined loads that result from postulated accident conditions events has not been demonstrated.
Aging Nuke Plants On Fault Lines In Tsunami Hazard Zones = Fukushimas… Any Questions?
PLEASE Turn off a light for Fukushima USA / San Onofre

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Unsafe NRC Computer Model Requires Investigation

Snip from:

Press Release 13-01-22 ATHOS Validity Questioned, Qualifying Investigation Required

The validity of the ATHOS T/H computer model for San Onofre Unit 2 at Main Steam Line Break  conditions requires that the NRC Office of Nuclear …

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Unsafe NRC Computer Model Requires Investigation

Snip from:

Press Release 13-01-22 ATHOS Validity Questioned, Qualifying Investigation Required

The validity of the ATHOS T/H computer model for San Onofre Unit 2 at Main Steam Line Break  conditions requires that the NRC Office of Nuclear …

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NRC Violating Presidential Directive and the Public Trust

SCE’s PR Machine Is Capable Of Overcoming ALL Hurdles,

Except Good Science And Safety

Albert Einstein also described INSANITY as

Doing the same thing over and over again and expecting different results. 

The DAB Safe…

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NRC Violating Presidential Directive and the Public Trust

SCE’s PR Machine Is Capable Of Overcoming ALL Hurdles,

Except Good Science And Safety

Albert Einstein also described INSANITY as

Doing the same thing over and over again and expecting different results. 

The DAB Safe…

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SCE Violated Federal Reg.’s And the Public Trust

Nuclear Experts Agree, San Onofre’s Replacement Steam Generators Are Unsafe

Summation: Based upon our ongoing review of evaluations, engineering analyses, inspections, technical and operational assessment reports prepared by the NRC’s Augment…

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SCE Violated Federal Reg.’s And the Public Trust

Nuclear Experts Agree, San Onofre’s Replacement Steam Generators Are Unsafe

Summation: Based upon our ongoing review of evaluations, engineering analyses, inspections, technical and operational assessment reports prepared by the NRC’s Augment…

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TEN Unresolved Items, Requires NRR Investigate The NRC

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

The DAB Safety Team has transmitted the following to
the Chair…

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TEN Unresolved Items, Requires NRR Investigate The NRC

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

The DAB Safety Team has transmitted the following to
the Chair…

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NRC AIT Review Of San Onofre Requires An NRR Investigation

NRC AIT review of SCE 10CFR 50.59: The NRC AIT stated in its report, “Based on the updated final safety analysis report description of the original steam generators, the team determined that the steam generators major design changes were r…

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NRC AIT Review Of San Onofre Requires An NRR Investigation

NRC AIT review of SCE 10CFR 50.59: The NRC AIT stated in its report, “Based on the updated final safety analysis report description of the original steam generators, the team determined that the steam generators major design changes were r…

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San Onofre’s TTW Assessment Is NOT ACCEPTABLE

SCE Cannot Develop A New Tube-To-Tube (TTW) Operational Assessment ACCEPTABLE To The NRR, After Wasting Hundreds of Millions of Dollars

NRC Office of Nuclear Reactor Regulation asked in a letter dated December 26, 2012 to Edison the following questi…

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NRC Region IV AIT Team Report Requires Immediate NRR Investigation

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

Condensed Version

NRC AIT Team review of SCE 10CFR
50.59: The NRC AIT Team stated in its report, “Based on the
updated final safety analysis report description of the origi…

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NRC Region IV AIT Team Report Requires Immediate NRR Investigation

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

Condensed Version

NRC AIT Team review of SCE 10CFR
50.59: The NRC AIT Team stated in its report, “Based on the
updated final safety analysis report description of the origi…

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SCE’s News Years Resolution 2013: Decommission SONGS ASAP

NRR RAI Answers Will Prevent Any SCE Restart At San Onofre

The NRC Office of Nuclear Reactor Regulation has requested from Edison in a
letter dated December 26, 2012, the following additional information (RAI
#32): “Please …

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SCE’s News Years Resolution 2013: Decommission SONGS ASAP

NRR RAI Answers Will Prevent Any SCE Restart At San Onofre

The NRC Office of Nuclear Reactor Regulation has requested from Edison in a
letter dated December 26, 2012, the following additional information (RAI
#32): “Please …

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Thirty Alarms Demonstrates SONGS Is Unsafe

The 30 Un-Resolved Alarms Recorded by SONGS Vibration Monitoring System During 11 Months of Operation, Requires An Immediate NRR Safety Investigation

Three Questions affecting US reactor safety need to be answered ASAP, by the NRR:…

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Thirty Alarms Demonstrates SONGS Is Unsafe

The 30 Un-Resolved Alarms Recorded by SONGS Vibration Monitoring System During 11 Months of Operation, Requires An Immediate NRR Safety Investigation

Three Questions affecting US reactor safety need to be answered ASAP, by the NRR:…

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NRR Meeting Request About SONGS Restart Safety

The DAB Safety Team and Other Experts wish to be invited to a Confidential NRR Meeting about SONGS’ severely damaged Replacement Steam
Generators and other safety related problems, before any SONGS Unit 2 restart
is granted by the NRC.

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NRR Meeting Request About SONGS Restart Safety

The DAB Safety Team and Other Experts wish to be invited to a Confidential NRR Meeting about SONGS’ severely damaged Replacement Steam
Generators and other safety related problems, before any SONGS Unit 2 restart
is granted by the NRC.

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14 Reactor Safety Questions That Edison Needs To Answer Regarding San Onofre

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 …

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14 Reactor Safety Questions That Edison Needs To Answer Regarding San Onofre

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 …

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Edison Pushes Restart, Despite UNSAFE Assessment

NRC No Restart at San Onofre

Steam
generator tubes and their support structures need to be extremely carefully
designed and manufactured within the allowed design tolerances.  These tubes preform a very important safety
function b…

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Edison Pushes Restart, Despite UNSAFE Assessment

NRC No Restart at San Onofre

Steam
generator tubes and their support structures need to be extremely carefully
designed and manufactured within the allowed design tolerances.  These tubes preform a very important safety
function b…

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Plug All Of San Onofre’s Unsafe Tubes, Not Just Some

The DAB Safety Team Agrees With Newly Released MHI Data:

Plug All Of SONGS Unsafe Tubes, Not Just Some

The DAB
Safety Team along with the support of an ever-growing number of SONGS
Concerned Insiders and Whistleblowers, prepared t…

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San Onofre’s Unsafe Inspections Put SoCal At Risk

San Onofre Unit 2 Replacement Steam Generators Incomplete and Inadequate Tube Inspections

San Diego, CA (November 9, 2012) – The failure of eight Replacement Steam Generator (RSG) tubes (something which has never
happened before…

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San Onofre ALMOST Caused A Nuclear Disaster

PRESS RELEASE

DAB Safety Team   November 02, 2012

Media Contact: Don Leichtling
(619) 260-0160 or Ace Hoffman (760) 720-7261

FOR  IMMEDIATE  RELEASE 

Fluid Elastic Instability
(FEI) is a phenomenon that can…

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San Onofre ALMOST Caused A Nuclear Disaster

PRESS RELEASE

DAB Safety Team   November 02, 2012

Media Contact: Don Leichtling
(619) 260-0160 or Ace Hoffman (760) 720-7261

FOR  IMMEDIATE  RELEASE 

Fluid Elastic Instability
(FEI) is a phenomenon that can…

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10-18-12 SCE’s RSG Testing Update + New NRC Blog Topic

The NRC has just posted this new topic on their blog site:

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

by Allison Macfarlane

NRC Chairman

http://public-blog.nrc-gateway.gov/

You are encouraged to add you…

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CPUC – DRAFT ORDER INSTITUTING INVESTIGATION REGARDING SONGS UNITS 2 AND 3

The San Francisco-based California Public Utilities Commission on Tuesday published a draft investigation order regarding the idled San Onofre Nuclear Generating Station.

 It will take up the matter at a public meeting Oct. 25 in Irvine.&nb…

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FOE –> San Onofre – Feds Stonewall FOE’s Petition For Legal Hearing On Reactor Restart

Posted Oct. 16, 2012,           Salute to FOE!

WASHINGTON, D.C. —  The Nuclear Regulatory
Commission’s continued refusal to consider a legally binding hearing on the
future of the San Onofre nuclear plant h…

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Update 10-14-12, SCE’s Replacement Steam Generator $680 Million Debacle

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

1.   If SCE’s and MHI’s Engineers had used all the following
guidelines, they would have p…

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SCE’s Restart PR Campaign Backfires in MV!

SCE’s RESTART PR campaign is now in full swing, please tell your friends to find out what SanO insiders are saying about all the technical issues AGAINST RESTARTING SanO, before they attend the NRC Dana Pt. meeting on 10-09-12.

The complet…

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California ISO prepares for another potential summer without San Onofre generation

News Release

News Release

For immediate release | September 13, 2012 Media Hotline ? 888.516.6397

For more information, contact:

Steven Greenlee | sgreenlee@caiso.com Stephanie McCorkle | smccorkle@caiso.com

California ISO prepares for another …

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The Number 1 US Nuclear Safety Concern ==> San Onofre’s Replacement Steam Generators

The DAB Safety Team is thankful to numerous
anonymous concerned SONGS Workers, who have provided factual information in the
interest of the Public Safety to us so that we could arrive at these “Reasonable
Conclusions?…

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San Onofre Nuke Questions That Need To Be Answered By The Nuclear Regulatory Commission (NRC) Prior To The Upcoming Oct. 9, 2012 Meeting

Here are some questions for the Public and MSM Reporters to ask the NRC prior to the Public Meeting scheduled about restarting San Onofre on Oct. 9, 2012:

Has the Mitsubishi Heavy Industry (MHI) Root Cause Evaluation been completed and a…

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