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Nuclear Hotseat #58 – Ray Lutz Shreds the NRC’s Whitewash of SCE/San Onofre Steam Generator Redesign

Nuclear Hotseat (2012-07-24) Libbe Ha Levy

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More Info: Nuclear Energy, Shut San Onofre

Featured Interview: Engineer and activist Ray Lutz “nukes” the NRC’s cover-up of SCE’s responsibility for San Onofre’s steam generator problems.

  • Four nuke plants trigger NRC “Unusual Events” in a single day. With that many, is it still “unusual?” (And still, no blackouts!);
  • Illinois reactor in “hot water” – at 102 degrees, cooling water can’t cool but the nuclear reactor’s still on line;
  • Japanese Prime Minister Noda admits that nuclear energy is dividing the nation;
  • TEPCO gets a rate hike as well as a bailout;
  • Temperature gauge cables on verge of breaking at Fukushima;
  • Subcontractor forces Fukushima clean-up workers to cover their dosimeters w/lead shields;
  • And Russia is doing a better job at protecting its citizens from radiation than the US. <!>

Partial Transcript


Libbe HaLevy: In the United States, San Onofre is again making headline news. In a stunning report, nuclear safety regulators have found that the operator of the San Onofre nuclear power plant did not mislead the government about changes to replacement steam generator that leaked radiation and has sidelined the plant for nearly six months so far.

The NRC on Thursday, July 19th, announced that Southern California Edison provided "all the information required under existing regulations about proposed design changes to its steam generator prior to replacing them in 2010 and 2011." They put the blame on faulty computer modeling and manufacturing issues. They stopped just short of saying the dog ate it.

California energy officials are now preparing for the possibility that San Onofre could be offline through 2013 or 2014, while at the same time Southern California Edison is putting forth the proposition that they restart one of their reactors in September at 70% power and run it for six months just to see what's going to happen. Well we thought it was time to get an expert in to comment on all of these changes, and I have one. I interviewed him from his home in San Diego.

My guest today is Ray Lutz. He has a background as an engineer with a master's in engineering. He served as the national coordinator for Citizens Oversight Project, and he has been actively involved in the San Onofre issue, especially since the problems with the steam generators emerged earlier this year. Ray, welcome to Nuclear Hotseat.

Ray Lutz: Thank you, Libbe. I appreciate being here.

Libbe HaLevy: First of all, give us a sense as to how you become involved in the whole nuclear issue.

Ray Lutz: Well, I had followed this throughout my, you know, being a student as an engineer and throughout my engineering career, all the things that were coming out about the different disasters and how, you know, the big question is whether human beings can handle this type of complex machine. When I was first going into college, the Navy did court me to work as a nuclear reactor operator aboard a submarine. I didn't do that, but I did find it interesting to tour the submarine and, you know, have their luncheon (laughs) and see what was going on there. But as a result I did stay interested in the nuclear energy issue, even though it isn't my focus as an engineer – I'm an electronics and electrical engineer – but those things are very tightly woven because the nuclear power systems are actually electricity generators, so it's very much similar to what I'm in.

Libbe HaLevy: Bring us up to date. Nuclear Hotseat has been following San Onofre. Give us a brief summary of what the problem was that showed up in January. Let's not go into what's happened since the press releases came out last week.

Ray Lutz: Yeah, well if you look at this, it's very interesting. Because surprisingly enough, Edison put out a very lengthy journal article published in January of this year, and it actually was probably written in October because you have to do them in advance of when they're published. The engineers who worked on the steam generators, I believe also the ones at Mitsubishi as well as the ones at Edison, went into great detail as to how proud they were of this work that they had done, and –

Libbe HaLevy: Meaning the re-engineering of the steam pipes to put more pipes in than it was originally designed for.

Ray Lutz: Yeah. And they had a mention in there that there was a premise, the major premise of the project, was to avoid NRC approval of the work. In other words, they didn't want to go through a license amendment process, public review, NRC review and all of that, which probably would have taken 18 months and would have cost them a little bit more but in the end would have avoided, maybe avoided, this problem. You would hope that it would have. And probably, you know, what probably would have happened, had they gone through that, is the public would have said no to everything and they would have said decommission at that time. So they desperately did not want to open up that can of worms.

Libbe HaLevy: So this report that came out from the engineers, this was an attempt at forestalling any criticism or any – this is even before the problems with the steam generators showed up?

Ray Lutz: Yeah. That's the funny thing. It was actually before anything happened, and the engineers were very proudly talking about everything that they had done, even

all of the redesign that they had done internal to the steam generators. They changed so much. And it was supposed to be under this 50.59 rule which states that – it's one of the regulations – it states that if they do a changeout like this, then it would have to be form, fit and function identical to what they were replacing.

And normally, as you can imagine, you know, if you replace something small like a light bulb or a light switch or something, as long as it's about the same, you're fine. But this is a massive part of this reactor. You know, there's two steam generators on each reactor and each one is like 70 feet tall, weighs hundreds of tons. It's almost like, oh, half of the reactor, like they changed out half of it, maybe you could argue a third of it. So it's a huge part.

And when you're changing out such a huge part of it, you can't go by just what the outside envelope looks like. It'd be like saying, well, we're going to give you a house that's the same, and the outline of the floor plan was the same but they changed all the rooms and the plumbing and everything. It's not the same.

So this is what they did. And they added tubes, they added 370 tubes to each one. They changed how they were bent at the top; instead of having a sharp 90˚ bend followed by a straight part at the top and then going down, it was a U-bend, and they changed the support. It went on and on.

This is a common problem, Libbe. All of these reactors have steam generator problems. They all decay over time because it's a really violent area. You know, just look in the bottom of a teakettle and see how violent that is down there. If you start putting 10,000 tubes down there and expect them not to wiggle, you're dreaming. They're wiggling all over. You've got bubbles of gas expanding at really high pressures.

Libbe HaLevy: I'm just thinking about the parallel, if a car gets a replacement part that is not the exact part, or it's like an aftermarket part but the fit isn't quite the same as one if it comes from the dealer, that it can create all kinds of problems with the mechanics of the car and has to be tweaked and adjusted and tested. And that's just for a car, let alone one of these pieces of technology that have the potential to melt down and poison all of us and, you know, and destroy life.

Ray Lutz: Yes. That's –

Libbe HaLevy: So they're playing games with our lives. So we have a pretty good picture of the problem that started to come to awareness with the shutdown on January 31st, which is when there was a break in a pipe and there was a radiation release from the reactor. And it was a short time later that the report came out of all this additional damage and the clogging of the tubes in the other reactor. And so San Onofre has been shut down since then. But of course there's been a lot of politicking too by SCE to try and get it back online.

Last week, on July 19th, there was a press release issued by the Nuclear Regulatory Commission. Basically the NRC signed off on all of the changes. What it said in the press release is that, quote: "The commission report states that the steam generator design changes were appropriately reviewed in accordance with the 10 CFR 50.59 requirements, which govern design changes between original and replacement steam generators, noting that the changes at SONGS " – I hate that, it means San Onofre – "are common in replacement steam generators today. The report also stated that, with the exception of the wear found at the tube retainer bar locations, the wear related to support structures is similar to wear found at other replacement steam generators after one cycle of operation.”

How comforted should we be by this announcement by SCE and the NRC?

Ray Lutz: Well, it's completely ridiculous. This is a classic case of cover your ass, where the regulatory agency, being the NRC, should have been reviewing this much more carefully than they were, and they did not. And so now it's come to light that, gee, we have all these problems and indeed they should have caught these earlier, but now they can't go back and say that they were wrong, because then they would have to admit to doing this wrong the whole time. That's unfortunate, because no one is willing to say that anyone is wrong here.

I was given the example of the Sandusky case where Penn State would not admit to it for a long time – even though everybody knew something was going on, they would not blow the whistle because they didn't want to be shown that they knew about this before. This is the same kind of thing where the NRC does not want to say, "Oh, we were asleep at the wheel and we did not enforce these regulations."

There's no way that all of the changes inside these steam generators is compliant with the "form, fit and function" type of rule which is this 50.59 rule. There's no way. Now, they can go on and try to justify it, but it is not the case.

So the hearing in San Juan Capistrano, which happened on June 18th, they went into what they were going to call the root cause. What was the root cause of this? And the Nuclear Regulatory Commission said that the root cause was excessive steam velocity inside these steam generators.

Libbe HaLevy: So in other words, the steam that is used to cool the reactor was moving too fast?

Ray Lutz: No, it's the water on the outside of the tubes. So if you can imagine, there's really high pressure water flowing through these almost 10,000 fairly small ¾"-diameter tubes, and then there's water flowing on the outside of those tubes getting heated up and turning into the steam. And then the steam flows across these tubes in steam bubbles that are expanding and very violently pushing on the tubes, and that causes the tubes to wiggle around and rub against each other, and that's what caused these holes.

Well, they had changed the dynamics of this – and I found an article in a publication, I think it was in the Orange County Register, in January prior to the leak that was talking about how they were changing out the turbines, because they put in turbines that would handle more steam, and in that article it said that these steam generators were going to be developing and producing more steam so that they could produce 31,000 homes' worth of energy from these same, this same reactor.

Libbe HaLevy: In other words, 31,000 additional homes. In other words, they were revving up the engine.

Ray Lutz: They were revving it up and they were doing it without approval. In other words, they were saying everything is the same as it was before, but – (laughs)

Libbe HaLevy: But we'll make more money by putting you more at risk.

Ray Lutz: They look the same from the outside. They have all the same dimensions. But in reality they have basically supercharged these steam generators to produce more steam.

Libbe HaLevy: So let's get back to this hearing that took place in San Juan Capistrano. This is between the NRC and the public and SCE, or who was there?

Ray Lutz: It was mainly the Nuclear Regulatory Commission giving sort of an informal report to the public about what was going on. They had not published their written report yet, and they also had Southern California Edison sitting there to answer questions. And they did actually try to answer the questions, but they only answered them so far.

One of the questions that was a key question to this whole meeting is, what was the cause of this radioactive leak and this tube degradation that occurred? And they said the reason, the root cause, was because of excessive steam velocity. But that's stopping before you're actually getting to the answer, because that's like saying who killed JFK and saying it was a bullet. You want to know who pulled the trigger. And so you have to work your way back to where did the bullet come from, where was the gun, and so forth. In this case, the steam velocity, where did the steam come from? It was the steam generator that had been modified. When did that happen? It happened when Southern California Edison and the Mitsubishi engineers redesigned it so substantially that it had no relation to the other design. And this is why it happened. But they did not want to say that.

Libbe HaLevy: And also it skirts around the culpability of the NRC in not protecting people and the environment but giving a rubberstamp to Southern California Edison.

Ray Lutz: Exactly. And this is why just prior to that meeting we had Friends of the Earth do a press conference about their request to become an intervenor, because they're claiming that the NRC and Edison, you know, that this was a violation basically of the 50.59 rule is what it comes down to. You're allowing the operator of these power plants to replace things as long as they're the same as they were before, but with maybe some minor changes.

Like for example in this case, they should have been able to change just the type of steel alloy that they used for the tubes, because then the design would be the same and they were just saying, "Well, this type of seal is going to last longer." That would be something that would be appropriate. But when you start changing all of the design of the inside of the steam generator, adding tubes, changing the support structure, changing the actual design of how the tubes bend – all of these things would allow more hot water from the nuclear core to come through faster and go around that nice U-bend faster. And so you're getting the whole thing to run hotter, and it's running hotter and developing more steam bubbles and then shaking the whole thing even more, and this is why it is rattling itself to bits.

So they're really – and this is the danger of this thing – you've got profit, you know, pushing everybody to the limit on one side, and there's almost nothing on the other side pushing back and saying, "You got to make it safe."

Libbe HaLevy: So, in other words, it's like the inmates are in charge of the asylum. It's just that the nutballs down at Southern California Electric in dealing with San Onofre are saying, "We'll do whatever we want to in order to increase profits," not thinking about safety, and the NRC is going [as Goofy] "I guess that's okay," and letting them get away with it.

Ray Lutz: Yeah, the NRC, you know, these are mostly people from the industry that have been revolving-doored into positions into the NRC and they tend to want to go along. And, you know, it's been a big problem, because they've had all these regulations but they never enforce them, they never – I think it was 1999 was the last time they actually fined somebody.

And what they do is they say, "Well, the rule is that you can't keep that thing for longer than, say, 20 years," whatever the thing is, and the operator will say, "Well, it's not rusted too much. It's still holding pretty well. Why don't you change your regulation to 15 instead of saying that we have to replace it?" And they keep doing this, and so the regulations really mean nothing after awhile.

In this case, the 50.59 rule has been abused so much that it means nothing! Like, when is it that you will say that it is not form, fit and function the same? What the NRC just said in their press release was they followed all the regulations and that all of these changes inside of this steam generator were okay and form, fit and function all right. And the reality is that can't be true. Because if it was form, fit and function identical, it would have lasted 40 years, which is what the old ones were, you know, intended to last. They lasted 25 years. It would have lasted 25 years. Instead –

Libbe HaLevy: As opposed to less than two years they're showing the signs of wear.

Ray Lutz: Only 11 months in one case, and this was only halfway through the first fueling period, and the other ones lasted like 15 or 16 fueling cycles. This one is only halfway through the first fueling cycle and is already breaking. It is completely inconceivable that this steam generator is form, fit and function the same.

Libbe HaLevy: What I'd like to do is move this on, because there's a whole other piece, and this came out in a press release that interestingly seems to have been released on the 22nd of July, which is a Sunday, which is not a usual day for a major press release to go out, but in this release it is said that Edison plans to apply to the NRC in September to restart one of the two generators at 70% capacity for a six-month trial period. How good an idea is this?

Ray Lutz: None of this is a good idea. You know, let's face it. My point of view is that none of these nuclear reactors can be run safely, period. They're way too complex. There are so many things that can go wrong. And the concept that we can plan and basically run these things safely, I have no confidence in that at all. And I'm an engineer who knows how to look at these things.

They say, "Yeah, statistically this is okay," and so forth, but really this is what they found in Japan, they constantly fudge the statistics, they constantly work things for profit, and that's why, mainly, I don't have any confidence, because there isn't enough oversight by the NRC.

But in this case, let's get more detailed about what's going on. You have the Number 2 and Number 3 reactors and they're a little bit different in how they've worn out. The Number 3 reactor is the one that's furthest to the south and it's the one that had this actual pinhole leak. They say it didn't leak very much. Yeah, well it leaked about 75 gallons a day, about as much as a bathtub of radioactive water which was emitted into the air, into the environment. And they say that isn't very much, but it sounds like a lot to me. Okay?

Libbe HaLevy: You know, no radiation is safe. There's no limit below which it is safe to be exposed to radiation. And their assurances that it is insignificant? It's one of the nuclear industry's favorite words. They just say, you know, "Pay no attention to the man behind the curtain," where the man behind the curtain is glowing from the radiation.

What can people, especially those of us who live in proximity with San Onofre and are outraged by this, what can we do to help support the work that you and the other fine activists down in Orange County are currently engaged in?

Ray Lutz: There's a couple of different dimensions that we can work in here. One of them has really been productive, and that is to go to the various city councils and talk to your representatives and get them more interested in this, and this is still ongoing. If you have time and the inclination to go city council meetings and start talking to them about this – go up, put in your speaker slip and take your three minutes and talk about your concerns about this reactor.

And I must say that I didn't quite finish on that Number 3 – if they restart it, it could shake itself to bits, even though they think it won't, and then we could have a meltdown. So it's very, very dangerous. I don't want to see them do that.

So that's the one dimension is going to these various city councils and representatives, calling all the different levels, state, federal, everybody that's your representative, and make sure they know your feelings about this, because power companies have a lot of influence and we need to have a lot more people coming forward.

The other thing is, the experience of the power companies has to do with these various hearings and so forth where they can keep the public pretty much under control and on their own terms, whereas the rallies that we've had at the plant, which we're not planning to have them that close to the plant any more, but we are going to be having actions such as rallies and the like. And let me give you an example. We went to the Sempra headquarters here in San Diego –

Libbe HaLevy: Sempra being the energy company that's involved with San Onofre?

Ray Lutz: Well, it is one of the three, yeah.

Libbe HaLevy: Okay.

Ray Lutz: It is owned by Southern California Edison to about 80%, and Sempra Energy, which is the parent of San Diego Gas and Electric, and they own 20%, and Riverside owns a very small fraction, like 1%. And so these, this Sempra Energy, they should be concerned, we think, because they're not really in control of this thing. They have to take the decisions that Southern California Edison has taken on this, and they should be concerned about, and their ratepayers, especially, which are going to be on the hook for this thing.

And so we sent a letter, put a letter, you know delivered it to the door and tried to – and of course they had all of their reinforcements out there. What this does is it puts sort of a shock to their whole organization, because they're not used to these people rallying outside their door about what they're doing wrong, and they hate that. You know, these organizations spend millions of dollars to try to boost their public image. They have whole departments to do this. And so when there's something like this that happens, even a small thing, it can damage so much work that they've done to try to boost their – so they hate these things. And it puts a chill to their own whole organization because they have to say, "Don't talk to the people out there, exit through the back door," (laughs), you know, all of these different changes.

And it's strange, because it's hard to really identify what does it, but I think it's a combination of all of these different tactics together, both speaking at public meetings, like city council meetings, for example, or the public rallies, which I think have been very effective. It's just that we need actually more people to show up –

Libbe HaLevy: So if people want to become involved with some of these demonstrations, be it to Sempra Energy or SCE or others that are being evolved, other tactics that are being evolved, how can they join with you?

Ray Lutz: Well, we have a website, that's You can go there and there's some contact information. Make sure you get on an e-mail list. There's also Facebook and other resources that are fairly easy to get involved in. And once you get hooked into the social media or these e-mail lists, you'll be getting information about when we're going to be doing something.

And it's very important to be ready, kind of at a moment's notice, because some of these things, we have to do them pretty quickly, and we just need people to show up. They had 15,000 people at the rallies in 1980 against San Onofre. And we haven't seen 15,000 people in our rallies recently. And if we had 15,000, trust me, we would have a lot of media coverage and a lot more traction on our position than we would with only maybe a few hundred. You know, if we have 500 people at a rally, that's pretty good, but it's not 15,000.

Libbe HaLevy: Right. And it's not what's happening in Japan, which is 175,000 people at a rally.

Ray Lutz: Right.

Libbe HaLevy: So, again, if people want to get on your social media, where would they go for that?

Ray Lutz: On Facebook, it's Shut San Onofre, and then you will be getting updates. But also if you go to is my website. You can send an e-mail to me, I will make sure that anybody who contacts me will be on the list and you will be getting the information about what we're going to be doing next, and you can join in and say this is a good idea or have some other ideas about what would work. We're always interested in that. And that's the way to do it. And any person – I don't care how little that you want to be involved, even just show up at one of the rallies, that's all you got to do is just be there, and your body is a vote.

Libbe HaLevy: Ray, I want to thank you for being such a font of information on this, and also for all the good work that you and Gene Stone and Donna Gilmore and Gary and his wife are doing down there to focus attention on San Onofre and not leave up on the pressure. It's so important for all of us.

Ray Lutz: My pleasure. Thanks a lot, Libbe. Really, your show is great. Good job.

Libbe HaLevy: Thanks. Ray Lutz has a master's in engineering, he's been national coordinator for Citizens Oversight Project, and as you can hear, he has been actively involved in the San Onofre issue, especially since the problems with the steam generators emerged earlier this year. And we will keep in touch with you to find out what's going on next. Thanks, Ray.


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Title Nuclear Hotseat #58 – Ray Lutz Shreds the NRC’s Whitewash of SCE/San Onofre Steam Generator Redesign
Publisher Nuclear Hotseat
Author Libbe Ha Levy
Pub Date 2012-07-24
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Note Features Ray Lutz
Keywords Nuclear Energy, Shut San Onofre
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Topic revision: r3 - 21 May 2015, RaymondLutz
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