ML13031A509

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LTR-13-0087 - Don Leichtling & Ace Hoffman Email Provides Media Alert 13-01-29 - Allegation - NRC Region IV Violating Presidential Directive and the Public Trust
ML13031A509
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 01/30/2013
From: Hoffman A, Leichtling D
The DAB Safety Team
To: Macfarlane A
NRC/Chairman, NRC/SECY
References
LTR-13-0087
Download: ML13031A509 (1)


Text

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed:Jan 30, 2013 16:09 PAPER NUMBER: GGING DATE: 01/30/2013 ACTION OFFICE:

SNs-V AUTHOR: Don Leichtling AFFILIATION:

CZ6,ae 1 6OW ADDRESSEE: CHRM Allison Macfarlane (Chairman Resource)

SUBJECT:

Provides Media Alert 13-01 Allegation - NRC Region IV Violating Presidential Directive and the Public Trust ACTION: Appropriate DISTRIBUTION: RF, SECY has Ack.

LETTER DATE: 01/29/2013 ACKNOWLEDGED Yes SPECIAL HANDLING: Lead office to publicly release 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after SECY's assignment, via SECY/EDO/DPC.

NOTES:

FILE LOCATION: ADAMS DATE DUE: DATE SIGNED:

Joosten, Sandy From: Capt.D [captddd@gmail.com]

Sent: Tuesday, January 29, 2013 4:17 PM To: Capt D

Subject:

Media Alert 13-01-29: Allegation - NRC Region IV Violating Presidential Directive and the Public Trust Media Alert 13-01-29 Allegation - NRC Region IV Violating Presidential Directive and the Public Trust Media

Contact:

Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261 Before ANY San Onofre Unit 2 Restart Decision by NRC - DAB Safety Team demands Investigation by U.S. Justice Department and NRC Commissioners The DAB Safety Team has transmitted the following Allegation to "The United States Department of Justice", "Office of the Chairman of the NRC" and "The United States Senate Committee on Environment and Public Works."

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 benchmarking 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 pressures (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 a defective 10 CFR 50.59 Evaluation and design specifications, which were not challenged by MHI, and/or 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 even the NRC's Region IV administrator 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 Learned: 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 shareholdersThe real lesson learned is that ALL parties follow NRC Chairman's and NRC Branch Chief's Advice, pay close attention to their work and always ensure that public safety is an 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) That operators can effectively implement emergency plans and procedures with zero Drills/Exercise Performance indicator failures during a Fully Staffed NRC/FEMA evaluated exercise prior to Unit 2 Restart.

The United States Department of Justice website http://www.iustice.qov/open/ states, "The Department of Justice is committed to achieving the President's goal of making this the most transparent Administration in history. In the Memorandum on Transparency and Open Government, issued on January 21, 2009, the President instructed the Director of the Office of Management and Budget to issue an Open Government Directive. The Open Government Directive directs executive departments and agencies to take specific actions to implement the principles of transparency, participation, and collaboration set forth in the President's Memorandum."

1

Albert Einstein described insanity as: Doing the same thing over and over again and expecting different results.

The DAB Safety Team has challenged previously in their published DAB Safety Team Documents, that Southern California Edison's controversial plan to restart San Onofre Unit 2 as a "Bogus and dangerous SCE experiment." According to SONGS Anonymous Insiders, SCE's Engineers were under the false impression that Unit 3 Anti-vibration Structure was built better than Unit 2. Therefore, SCE Engineers were operating Unit 3 at lower steam pressures than Unit 2 in a test mode to generate more thermal megawatts and thereby more electricity. To add to Arnie Gundersen's and John Large's Technical Affidavits, DAB Safety Team's investigation reveals that in the process of this "money-hungry experiment", lower steam pressures in combination with other unapproved and unanalyzed design changes destroyed Unit 3 due to fluid elasticity instability. SCE and NRC AIT Team both blamed Unit 3 FEI on botched up MHI Computer Modeling and insufficient tube-to-AVB gaps. AREVA, Westinghouse, John Large and DAB Safety Team findings dispute these statements. NRC Augmented Inspection Team and NRR Panel have swept DAB Safety Team Findings consistently under the rug, in what must be now labeled as a Gov't cover-up!

The DAB Safety Team reaffirms, that a formal NRC 50.90 licensing review with public input is now required, before any decision to restart Unit 2 by the NRC is considered. The DAB Safety Team's published position is in full agreement with the Friends of Earth's Nuclear Experts' Public statements, "Edison's experimental plan to restart a badly broken reactor and see what happens is unacceptable. Edison simply cannot prove that if they operate San Onofre under the terms of their restart plan, more steam generator tubes will not fail. This reckless plan would risk the lives and livelihoods of millions of Southern Californians. Edison's defective steam generators are simply too damaged to meet the terms of San Onofre's current operating license. Edison played fast and loose by making radical design changes and ducking the rules. The result was the most rapid breakdown of such replacement steam generators in the history of the U.S. nuclear industry. If Edison had followed the rules, an NRC license review would have found these glaring defects, and the lives and livelihoods of millions of people would not have been put at risk nor would hundreds of millions of dollars have been squandered."

The NRC keeps issuing both controversial and conflicting press statements that a decision to allow the restart of Unit 2 could come as early as March 2013. According to SONGS anonymous insiders, Edison officials have announced in internal SONGS Staff Meetings that a restart decision is imminent in March despite the huge public outcry about safety problems by SCE. Press reports as of January 14, 2013 state, "Small steps are being taken to prepare for possibly restarting the troubled San Onofre nuclear power plant, even as its future remains clouded with uncertainty, officials said Monday. Nuclear Regulatory Commission senior inspector Greg Warnick said Monday that the agency is beginning to prepare a detailed plan of what would need to be done to bring the plant safely back to service." (SOURCE: CBS Los Angeles, Associated Press)

NRC's enforcement history, drama and pre-rehearsedtough questions, press reports, casual relationship and/or protection of SCE officials and utility biased public meetings are just old and cheap regulatory tricks that are now being used to protect the NRC's own public image and to fool the public into believing that the NRC is really concerned about public safety regarding SCE's Restart Plan. The Justice Department & NRC Commission need to set up a legal/technical taskforce to publically question Edison, MHI Engineer's and NRC AIT members listed below under oath regarding their: (1) Understanding of their legal obligations under the 10 CFR 50.59 Process, (2) Understanding of problems with theoriginal steam generators, (3) Critical questioning and investigative attitude, (4) Efforts made in industry and academic benchmarking to identify and resolve problems with the original steam generators and, (5) What part did they play, if any, in the preparation/review of design specifications, fabrication, computer modeling, mock-up testing, anti-vibration bar structure, and research required to prevent the adverse effects of fluid elasticity and flow-induced random vibrations in these unique San Onofre Combustion Engineering replacement generators.

The following listed names of SCE/MI-HI (NRC AIT personnel has been obtained from public domain websites:

1. John Brabec, SONGS Steam Generator Project Manager
2. Gary Kline - SCE Unit 3 RCE Management Sponsor
3. John Osborne -SCE Unit 3 RCE Team Leader
4. John McGaw- RSG 10 CFR 50.59 Evaluator
5. Steve Seward - RSG 10 CFR 50.59 Approver Design & Performance Specifications S023-617-1
1. Originator - James Chan (SCE)
2. Independent Review Engineer - Jun Gaor (SCE)
3. First Line Supervisor - David Calhoun (SCE)
4. Second Line Supervisor - Craig Herberts (SCE)
5. Procurement Engineering Tom Pierno (SCE)
6. Nuclear Oversight &Assessment Bill Kotekkasko (SCE)

Challenges and Rewards of Innovative Design of Replacement Steam Generators

1. Boguslaw J. Olech, Steam Generator Expert (SCE)
2. Tomoyuki Inoue, Steam Generator Expert (MHI)

Export of High-performance & High-quality Components 2

1. Yasuhiro Kutomi, Nuclear Energy System Headquarters (MHI)
2. Takaya Kusakabe, Kobe Shipyard & Machinery Works (MHI)
3. Yoshinori Takata, Kobe Shipyard & Machinery Works (MHI)
4. Toshiyuki Mizutani, Kobe Shipyard & Machinery Works (MHI)
5. Chikara Kurimura, Kobe Shipyard & Machinery Works (MHI)
6. Seiji Asada, Kobe Shipyard & Machinery Works (MHI)

NRC Augmented Inspection Team Members

1. G. Werner, RIV/Branch Chief/Plant Support Branch 2
2. A. Johnson, NRR/Materials Engineer
3. E. Murphy, NRR/Senior Materials Engineer
4. J. Ortega-Luciano, NRO/Reactor Operations Engineer
5. J. Reynoso, RIV/Resident Inspector
6. J. Rivera-Ortiz, RII/Senior Reactor Inspector
7. Thurston, RES/Reactor Systems Engineer Any NRC decision to grant a restart of Unit 2 without a formal 50.90 licensing review along with public participation will be seen as an invitation to risk a Fukushima-type disaster happening in Southern California.

More:

Allegation - NRC AIT Report Incomplete. Inconclusive. Inconsistent and Unacceptable and Allegation - NRC Violatinq President'sDirective And the Public Trust are both posted on the web at this link: DAB Safety Team Documents.

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/Thoroughrrransparent 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 3