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

October 20, 2012 (Washington D.C.) -- Citizens' Oversight, an El Cajon-based citizens watchdog group, submitted a formal request[1] to the U.S. Nuclear Regulatory Commission (NRC) regarding a license amendment request[2] by Southern California Edison (SCE) for the San Onofre Nuclear Generating Station (San Onofre).

Raymond Lutz, Electrical Engineer and Founder of Citizens Oversight, prepared the petition to intervene based on a review of the proposed changes to the operating license of San Onofre. These changes to the license do not directly reflect on the recent emergency shutdown on January 31, 2012, and furthermore, is not in response to the proposal by SCE to operate San Onofre Unit 2 at a lower power level despite massive and severe damage to the steam generator tubes due to excessive vibration.

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

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

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

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

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

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

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

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

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

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

[1] - "Review of SONGS License Amendment Request by COPS; Petition to Intervene and Request for a Hearing" --

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


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10-18-12 SCE's RSG Testing Update


====== 10/18/12 RESTART NEWS UPDATE =====
Information Concerning SCE's Ongoing RSG  Restart Testing At SanO:
I saw this info and I've had this email conversation with NRC Region IV about it:
(I saw this on Oct. 17, 2012 and sent it to the NRC)
I saw this posted on Twitter today and wanted to forward it to you, in the hope that it is not factual, because if it is, then the NRC has more problems at San Onofre than just damaged and leaking SG tubes...
This was posted on Facebook:
"ACTION ALERT! San Onofre Nuke Plant could Re-Start Within 10 Days!
From a whistle-blower at San Onofre nuclear plant in Southern California: "We are working on Unit 2, bringing it up from Mode 5 to 4 and are preparing to go from Mode 4 to 3 by the weekend of October 20th. Southern California Edison (SCE) brought in the auxiliary boiler (which runs off of oil), and assigned 12 hour shifts. SCE are making damn sure that no steam leaves the domes for fear the public will catch on. I can’t believe how audacious they are, but for all practical purposes, they are going to restart Unit 2—which still is highly radioactive—without the NRC thoroughly reviewing Edison’s application that was just submitted. Their motivation is to see if they fixed the new reactor head which leaked profusely the first time they tried it. They don’t want anything holding them back from actually restarting when they get the green light from the NRC. The NRC’s Confirmatory Action Letter allows them to take it up to Mode 3 because the reactor is not “critical”, (fission reaction is on hold). They are trying to beat the clock before time runs out on them and the CPUC (California Public Utility Commission) sticks Edison with the cost of the outage instead of the ratepayers.” -M
Question: Has the NRC approved this new TESTING, (as it was my understanding that there would be no restarting until the NRC decided it was safe to do so)?   You should be able to confirm the validity of the above with a simple phone call to the resident inspector at San Onofre...

Hopefully Mr. Elmo Collins will honor his quote, "We don't experiment with safety"...
I look forward to your timely response, as I want to give the NRC a chance to comment before publishing the above.

I got this reply on Oct. 18, 2012:

Southern California Edison is permitted, by their license, and by the Confirmatory Action Letter issued March 27, 2012, to heat up and pressurize Unit 2 to normal operating pressure and temperature.  This heat up is being done using offsite electrical power.  This is NOT starting up the plant.  The safety concern with Unit 2 steam generators is the excessive vibration that occurs during high steam flow conditions in the steam generator, which may result in unexpected and rapid steam generator tube wear.  This cannot occur in the condition the plant is being taken to.  The steam generators will be hot, and pressurized, but there is no heat generation from the reactor, and the heat generation from the auxiliary boiler and reactor coolant (electric) pumps is very small and cannot produce enough energy to cause vibration in the steam generator tubes.  
The NRC has no concern with the structural integrity of the Unit 2 steam generator tubes today, in their current reactor shutdown condition.  The NRC is currently evaluating Southern California Edison’s proposal to restart the reactor.  This proposal states that Unit 2 can be operated, meaning it can start the reactor to produce the large amount of heat and steam flow for 70% of normal full power operation.  This amount of steam flow must be shown to not result in additional unexpected and excessive tube wear, or the NRC will not allow the reactor to be restarted. 
The reactor has not been, and will not be started up until NRC has granted permission.  The “testing” that is being referred to is normal testing that is allowed by the current license at San Onofre.  The “testing” that Mr. Collins was referring to is any test or experiment that is not currently an approved procedure and is outside the safety analysis as described in the facility Updated Final Safety Analysis Report.  As an example, the NRC would not allow the reactor to be restarted, producing the large amount of heat and steam flow, so that the licensee could monitor tube vibration to ‘see’ if excessive vibration is occurring – that would be a “test”.  The licensee must prove, with reasonable assurance, before starting the reactor, that excessive vibration will NOT occur.
Victor Dricks
Public Affairs Officer
U.S. Nuclear Regulatory Commission / Region IV


So I sent this reply yesterday:

Question 1 – Is the pressurized and hot reactor coolant (Any Amount) being circulated through SG 2E-089 under these test conditions?
Question 2 – Does the NRC postulate a MSLB outside containment under these test conditions?
Question 3 – If the answer to Question 1 and 2 is yes, does NRC postulate > 99.6 % steam voiding in the U-Tube Bundle?
 The public is going to ask ,"What is going on between Region IV and the NRC? People need the answers in a hurry.  Is the NRC more concerned about the Safety of The Public or letting Edison get away with whatever they want to do?  If NRC was strict from the very beginning with Edison, things would not have to come to this.  There is still time.  Here is a quote for your benefit, An anonymous participant in an Industry Conference was asking questions and persistently complaining about complex and unclear NRC regulations.  A NRC Branch Chief 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'."

+ Check the COMMENTS for updates...