Response to SCE's Motion To Defer and Strike Testimony

4/22/2013

Dear Readers,

In their response to the California Public Utilities Commission (CPUC) regarding other party's comments, Southern California Edison (SCE) wants to strike and/or defer much of the most crucial testimony, saying that the comments show that the commentator's ultimate goal is to shut San Onofre forever.

SCE says it like that's a bad thing.

It's a good thing, and so feeling that way is NOT proof of an "agenda," as SCE is trying to imply.

SCE plans to restart San Onofre long before the CPUC completes their "OII" Investigation. Thus far the Nuclear Regulatory Commission (NRC) has refused to let SCE restart SanO, but only asked for more information rather than condemn the plant, and the plan, as unsafe. The NRC might let up at any moment and permit restart, starting less than 30 days from today. (A 30-day final public comment period has begun, and after that a decision could come at any time.)

So they say.

In reality, the entire industry knows that technologically, the activists have won on engineering principles and the NRC officials know that THIS time, many people including many of them will surely go to jail of the reactor is restarted, and then fails from a single tube rupture, out of nearly 20,000 tubes, thousands of which -- if not all of which -- are already significantly and measurably damaged.

Such an event would destroy their careers and seriously damage the credibility of the agency.

And their biggest problem isn't the activists, it's that a lot of the possible damage is NOT easily measured or identified. So they're taking a real crapshoot on this one.

A failure during the five-month "test" will destroy Southern California Edison's credibility, and not to mention Mitsubishi Heavy Industries in Japan, AREVA's in France, and Westinghouse, another global shell-game of country-of-ownership, currently a subsidiary of a Japanese company. (Foreign ownership of nuclear power plants is not allowed, but they can buy all the foreign-made, poorly designed, improperly inspected, cheap parts they want.)

Tens, even hundreds of billions of dollars in company worth and reputation will be lost if San Onofre starts up and then fails. But it doesn't even have to fail. Every one of those 170,000 measurements they took beforehand will (presumably...) be rechecked after the five-month test-run (and what if it has to shut down prior to the five months for some other reason? Will they stop the test? By what criteria will they stop the test?). Any greater-than-expected-wear found during inspections after the five month period, even if it doesn't rupture, let alone an actual tube rupture, will cost SCE and all the other corporations, and the NRC, billions of dollars and incalculable amounts of credibility.

It may also destroy San Onofre. The tubes are fatigued. The unprecedented vibrations are potentially catastrophic, because multiple tube ruptures after a main steam line break with a concurrent (and not sufficiently unlikely) failure of a steam line isolation valve is functionally equivalent to a hole in the reactor pressure vessel.

A hole in the reactor pressure vessel? That doesn't sound good! It isn't -- it can lead to "core melt."

A front-page story in my local paper yesterday (San Diego Union-Tribune) declared that the problems that have occurred at San Onofre were well-known in the industry at least at the earliest phases of the steam generator problem, if not sooner. SCE should have known better but used a faulty design.

But the first question to answer is still: What will we do with the waste? Here it is, Earth Day again, and for the first time since the early 1980s (When Unit 1 was down for an extended repair, and before the now-aging Units 2 and 3 were completed) there's been no new nuclear waste produced at San Onofre for more than a year. It has not polluted the earth MORE for one whole year.

That needs to be made permanent.

Decommissioning San Onofre will only get more expensive, so the best time to start is immediately. In fact, we've spent as much on this outage, that if we had put the money into decommissioning, the entire rest of the project has already been funded by ratepayers! How much closer to "free" can you get? Why make the same mistake again this month (nearly $70 million dollars) or next month, or ever again?

Decommission San Onofre NOW. It's the only safe, cost-effective, reasonable thing to do.

Ace Hoffman
Carlsbad, CA

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4/21/2013

Response to Hopenfeld Testimony to the California Public Utilities Commission

By Ace Hoffman & Friends

Dr. Joram Hopenfeld's testimony looks at many aspects of the problems of San Onofre, but concentrates its focus on the concentration of forces in certain areas of the U-tubes of the steam generators, and the effect those forces have over time. He argues that Unit 2's steam generator tubes have already used up their available fatigue life, and if they haven't, it's not possible to know precisely how much time they have left before they do. And it's not possible to fix them. And it's not possible to inspect them.

Dr. Hopenfeld's conclusions are all based on proven engineering principles and incorporate industry and research standard references. Where SCE or MHI redacted specifications and made it impossible to know what the exact values were for a calculation, he was forced to bracket the most reasonable or likely answers. For the size of a wear notch fillet, for instance, the differences in assumed diameters of a thousandth of an inch can have a huge effect over millions of impacts.

Dr. Hopenfeld explains that there are several different kinds of failures possible in a steam generator u-tube, and they can combine to make matters worse. Much of his background testimony consists of standard textbook educational material presumably for the edification of the less-experienced in materials science, about stress corrosion cracking (SCC) (think: rust), fatigue wear (think: bend it back and forth until it breaks), and fretting wear (think: scratch away at the 0.043" wall thickness with a sharp-cornered rectangular piece of hard steel millions of times and see what happens).

Most of the testimony is about fatigue wear, but made worse in combination with fretting and SCC damage.

Fatigue wear, he explains, can be avoided completely if the tubes are not subjected to extreme stress. He then argues that MHI and SCE have not proven that the tubes were not subjected to excessive and life-shortening forces. Using bounding factors where necessary, he calculates that some of Unit 2's u-tubes can be expected to reach 20% to 29% of their allowable fatigue life during the next cycle -- in other words, they have already been overstressed. This is true not just for a small collection of the 9727 tubes in each steam generator but for a great number of them.

He also explains that to be sure you are using "conservative" or safe values, you must account for the variance in the accuracy of your calculations. Edison did not do this.

He explains that Unit 2 is required by NRC regulations to have no worse than one chance in 10,000 per reactor year of a significant radioactive release (known as a LERF), but because the damaged tubes can break off in multiple tube failures due to fatigue, fretting, and SCC acting alone or in combination, and because an MSLB with an isolation valve failure has a greater chance than that of occurring, there is no reason to believe a LERF-sized event also can't occur more frequently than the NRC requirements permit.

Put another way, the eight tube ruptures that occurred during in-situ pressure testing of Unit 3 last year indicated the severity of the problem that COULD have occurred and could also occur at any time if Unit 2 is restarted at 70% or any power level. NRC regulations do not account for more than a small amount of primary-to-secondary radioactive coolant leakage. San Onofre Unit 2 can and possibly will exceed those limits, leading to "core melt" should any number of things go wrong.

These are serious allegations against the claims of Southern California Edison, who has stated that the reduced power level of operating at 70% will protect the public by preventing "Fluid Elastic Instability." Dr. Hopenfeld argues strongly that it doesn't matter if they're right or wrong about that for several reasons: First, the fatigue damage has already been done. Second, the damage cannot be properly detected and even if it could be more properly inspected than it has been, SCE has chosen, for whatever reason, NOT to do more thorough inspections. Third, and perhaps most important, even if Unit 2 can run perfectly at 70% power or 100% power, there is no reason to believe it can survive an operational transient, like opening and closing valves and the extra forces those events put on the system, let alone a main steam line break or other large "design basis accident."

SCE claims their operators can handle a main steam line break event. Dr. Hopenfeld proves they have nothing to go on when making that claim except good luck. Thus the plant would be operating completely outside the bounds of NRC's regulatory safety framework if it is restarted.

San Onofre Unit 2's steam generators are fatigued and broken, and should definitely not be restarted due to the significant risk a restart would pose to the citizens of Southern California and the economy of the entire United States, which cannot afford a Trillion Dollar Eco-Disaster like Fukushima.

Ace Hoffman & Friends
Carlsbad, CA

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Ace Hoffman
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Carlsbad, CA
Email: ace [at] acehoffman.org

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