ML13080A008
| ML13080A008 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/18/2013 |
| From: | Hoffman A - No Known Affiliation |
| To: | Macfarlane A NRC/Chairman, NRC/SECY |
| References | |
| LTR-13-0232 | |
| Download: ML13080A008 (9) | |
Text
OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: Mar 19, 2013 14:56 PAPER NUMBER: S 13 0232 LOGGING DATE: 03/19/20 13 ACTION OFFICE:
c0* ~A AUTHOR: Ace Hoffman AFFILIATION: CA ADDRESSEE: Chairman Resource
SUBJECT:
Provides newsletters regarding San Onofre Nuclear Generating Station operation and restart ACTION: Appropriate DISTRIBUTION: RF, SECY to Ack.
LETTER DATE: 03/18/2013 ACKNOWLEDGED No 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: Two newsletters dated 3/18 and 3/19 FILE LOCATION: ADAMS DATE DUE: DATE SIGNED:
Joosten, Sandy From: Ace Hoffman [rhoffman@animatedsoftware.com]
Sent: Monday, March 18, 2013 9:42 PM
Subject:
SCE says San Onofre can be operated safely. Facts say otherwise.
Follow Up Flag: Follow up Flag Status: Flagged 3/18/2013
Dear Readers,
SCE's plan to run San Onofre at 70% power for five months, submitted to the Nuclear Regulatory Commission last October, is based on faulty assumptions which defy logic.
And yet, incredulously, today SCE announced that they believe they could run Unit 2 at 100%
power for 11 months without going over the 35% tube wear limit on ANY of the nearly 20,000 tubes inside the two "new" steam generators in Unit 2!
Some of those tubes inside those steam generators are already worn more than 20% of their thinner-than-a-dime thickness. None have been inspected with the most thorough equipment available, which can detect stress corrosion cracking,-not just tube wall wear.
Yet SCE is sure that they can run Unit 2 without causing "high void fractions" in the steam/water.mixture, and without causing excessive turbulence, which was about as bad as anything the industry had ever seen in Unit 2 as well as in Unit 3, which no one is about to try to claim can be restarted.
And presumably, SCE is claiming they could run at 100% power for 11 months without an unreasonable risk of another tube rupture like what happened 3anuary 31st, 2012, which shut down the two reactors.
However, SCE has yet to prove their case for restart, and these are just additional speculative claims to confuse and inappropriately reassure the public that restart is safe, and to prod the NRC into a favorable and inappropriate decision. San Onofre cannot be safely restarted. Period. It CAN'T be proven safe, because it's already been proven unsafe. Real-world experience and test results top the fanciest mathematical equations and computer software programs.-
Despite this new announcement -- a "trial balloon" in the political sense -- SCE still plans to only run the Unit 2 reactor for 5 months at 70% power... but by doing this, they are obfuscating the dangers, making it sound like additional wear is the only problem, followed by a single tube rupture at some point if things go wrong. This is not the case. In fact, the main worry is that, the wear that has occurred is more than they realize because their inspections are inadequate, coupled with concern that a main steam line break (coupled with the failure of an accompanying isolation valve to close) could lead to "fluid elastic instability" and a multiple-tube rupture, as illustrated in my animation available online here:
http://www.acehoffman.blogspot.com/2013/02/new-animation-shows-what-could-happen.html Click the triangles in the upper left to go to various screens; and click on MSLB when a steam generator is on the screen to see the event I am referring to. It might only take a couple of seconds or minutes, and happens whether the reactor is SCRAMed successfully or not.
The steam line breaks, the water in the steam generator almost instantly turns to steam, it
,rushes out the top of the steam generator, the u-tubes start fluttering, and .... they break away in clusters.
Last year, eight tubes ruptured during "MSLB" testing, three of those did so below the pressure differential that an actual main steam line break would incur. The requirements include a margin of error of about 180%, and the other 5 tubes failed that part of the test.
Only about 1.5% of all the tubes were pressure tested -- the ones that were going to be taken out of service anyway. because they were located in areas of highest wear and thus, it's presumed, the areas of highest heat and highest fluid velocities as well. (And highest void fractions.)
San Onofre has no answer for the problem indicated by those test results. However, lucky for them, the Nuclear Regulatory Commission has deemed a multi-tube rupture scenario "not credible" as stated at the last NRC hearing, February 12, 2013 at the Church of the God Loving Beach People. But under oath, with experts cross-examining the NRC's own experts or San Onofre's, I don't think they would be able to deny this is a real and reasonable possibility. Not only is it a possibility, but a main steam line break is probably about ten times more-likely than a severe earthquake (one cause of a main steam line break might be an earthquake, but it's not the only possible cause. Rust is another.).
Experts not tied to the nuclear industry (anymore...) believe a cascading tube rupture scenario, such as that depicted by the main steam line break animation, is plausible.
And although it's not guaranteed to cause a meltdown all by itself -- there are a few backup systems that might still work -- it would bring SoCal frighteningly close to our own Fukushima. A main steam line break can produce sonic-level sound vibrations, inhibiting communication. The loss of numerous sensors and controls is very likely to accompany such an event. The operators in the control room might need some time to figure out what happened:
They might not have that time. But what if they try to isolate the WRONG steam generator, for example? What if the break is inside the containment dome and the burst pressures are exceeded because, unknowingly or covered-up, the dome cut to insert the steam generators didn't go as well as they thought it had, like at Crystal River in Florida? The engineers thought they had closed that one up pretty good too, and then cracks developed...
if a meltdown occurs, the containment area may not be enterable, as in the case of Fukushima, for years or even decades or centuries. And, like at Fukushima, our children will be most affected, our crops, our land will be lost, and no one will compensate us for the loss. It will be no different for hundreds of thousands of people around the plant, maybe millions.
And Fukushima wasn't even as bad as it could be, not by two orders of magnitude at least:
The cores did not fully explode vaporize in a massive steam explosion, for instance .... at least, not yet. But all of multiple core's noble gasses were released, their full loads of cesium and strontium... and some plutonium and uranium, but the majority of the plutonium and uranium is still inside the reactor buildings somewhere, at this time. Things could have been a lot worse there, and could be a lot worse than that here.
And even if there is no main steam line break, there are still a multitude of other problems.
First of all, and perhaps most importantly, SCE's plan for restart has always depended on FRICTION FORCES to prevent "in-plane" vibration of the tubes inside the steam generators.
Vibration in other directions has always been taken care of by having supports that the tubes butt up against, and it was assumed by the nuclear industry that if you solve the out-of-plane vibration problems, you will also have solved any in-plane vibration problems.
However, San Onofre Unit 3 proved that "rule-of-thumb" to be incorrect, and the industry needs to amend its thinking.
Another Achilles' Heal of the industry is the waste problem. Not mentioning it (as SCE never does) doesn't make it go away. In fact nothing makes it go away. The federal government 2
,will continue to. break its promise to remove the waste from near the reactor, because there is no place to put the waste -- no national repository -- and we are many decades away from having such a place, if ever. So the less waste that sits here on our coast, exposed and dangerous as it sits there, its containers rusting in the sea breeze, its contents in constant need of attention and protection (and inert gasses under pressure), the better. It all costs money for tens of thousands of years, and the more radioactive trash there is, the greater the cost, the larger the land that's needed to store it, and the greater the risk.
Let's hope the CPUC will stop wasting the ratepayer's money on the hopes of restarting a fault reactor based on a faulty premise -- on a fault line. Let's hope the NRC will flat-out refuse to allow SCE to restart. Let's hope SCE gives up this foolish plan. And, since hoping won't change anything, let's decommission San Onofre starting right now. It's the only way forward for society.
Sincerely, Ace Hoffman Carlsbad, CA The following was left by an acquaintance of mine at the NRC Blog site today:
Sincere Thanks to Mr. Victor Dricks, Mr. Cale Young, Mr. Ryan Lantz, Mr. Randy Hall and entire NRC Staff. Thanks to NRC posting this blog As a part of San Onofre Public Awareness and SCE/MHI Lessons Learnt Series, Brilliant NRC Staff should summarize for the benefit of General Public an Unbiased Gap Analysis on San Onofre Degradation before Unit 2 restart based on the plant data and a review of following reports:
- 1. NRC AIT and follow up reports
- 2. SCE Root Cause Analysis Evaluations (Safety Short Cuts and Avoidance of 10 CFR 50.90) 3.
Westinghouse Operational Assessment 4. AREVA Operational Assessment 5. MHI Root Cause Analysis & Technical Reports (Safety Short Cuts and Avoidance of 10 CFR 50.90) 6. SCE Enclosure 2 and Remaining Operational Assessments 7. Internationally Known Chartered Engineer and Nuclear Scientist John Large Technical ASLB Paper 8. Internationally Known Nuclear Engineer Arnie Gundersen's Technical Papers 9. Professor Daniel Hirsch's Report 10.
Mitsubishi AVB Testing for San Onofre RSG Repairs 11. Dr. Pettigrew's and other research papers published between 2016 and 2011 on FEI & FIRV 12. SONGS Special Tube Inspections &
Insider Reports 13. NUREG 1841- Comparison of CE Replacement Generators with San Onofre 14.
SCE Response to NRR RAI's 15. Fluid Elastic Instability, AVB Contact Forces and risks of Design Bases Accidents at 70% reduced power, Accuracy of Thermal-Hydraulic Computer Modeling and Reliability of SCE Operator Actions 16. Analysis of San Onofre Units 2 & 3 Operational Data and its impact on Units 2 & 3 Cause Root Cause Evaluations and how it relates to Fluid Elastic Instability, Flow-induced Vibrations, Mitsubishi Flowering Effect and AVB Contact Forces 17. SCE's Compliance with NRC CAL and NRC Justification of SCE 1@CFR 50.59 and Assurance to 8.4 Million Southern Californians based on Scientific Facts and Operating Experience Thanks.... HAHN BABA Contact information for the author of this newsletter:
3
Ace Hoffman, computer programmer, author, The Code Killers:
An Expose of the Nuclear Industry Free download: acehoffman.org Blog: acehoffman.blogspot.com YouTube: youtube.com/user/AceHoffman Phone: (760) 720-7261 Address: PO Box 1936, Carlsbad, CA 92018 Subscribe to my free newsletter today!
Email: ace [at] acehoffman.org To unsubscribe:
Send "Unsubscribe" in subject line.
4
Joostbn, Sandy From: Ace Hoffman [rhoffman@animatedsoftware.com]
Sent: Tuesday, March 19, 2013 10:32 AM
Subject:
NO RESTART! NO WAY! Short technical explanation of why San Onofre should not be restarted!!!
3/19/2013
Dear Readers,
I realize the document below, which was left at the NRG BLOG web site this morning by a friend of mine, is fairly technical, so I've added a GLOSSARY at the bottom to help out.
But nevertheless I highly recommend reading it (it's fairly short) and discussing it with as many people as possible in (and especially out of) the movement to shut San Onofre. It is the most succinct technical analysis I've seen to date on why it is unsafe to restart San Onofre Unit 2, even at 70% power.
Ace Hoffman Carlsbad, CA (Note #1: Minor corrections to the version posted at the NRC BLOG have been made to the version below. Please refer to my animation for additional parts placements:
http://goo.gl/CRlQl and to yesterday's newsletter for additional discussion:
(Note #2: Another important point, courtesy Donna Gilmore, http://SanOnofreSafety.org "If the NRC approves restart, Edison will be able to run the plant longer than 5 months. The Confirmatory Action Letter (CAL) gives Edison the discretion to make that decision after the 5 month test period ends. The NRC has refused to modify the CAL to require NRC approval after the 5 month test.")
Subject:
US NRC Blog FROM: HelpAllHurtNeverBaba DATE: March 19, 2013-at 1:12 am NRC STATUS, Your comment is awaiting moderation.
Sincere Thanks to Mr. Victor Dricks, Mr. Cale Young, Mr. Ryan Lantz, Mr. Randy Hall and entire NRC Staff. Thanks to NRC posting this blog San Onofre NRC/SCE/MHI/ Public Education Series by HAHN BABA- Statement of facts unless proven wrong otherwise ......... Southern California Edison Submits Operational Assessment Requested by NRC NRR RAI 32 - Putting Production/Profits over Safety
- 1. BACKGROUND: ROSEMEAD, Calif., March 18, 2013 - A new technical evaluation of San Onofre Nuclear Generating Station Unit 2 demonstrates that the Unit 2 steam generators could be operated safely at 100 percent power and reinforces Southern California Edison's (SCE) more conservative plan to begin operating Unit 2 at 70 percent power for five months. SCE submitted the operational assessment of potential Unit 2 steam generator tube wear to the Nuclear Regulatory Commission in response to NRC questions. The new evaluation determined Unit 2 could operate at full power for 11 months with full tube integrity. The assessment was performed by Intertek APTECH of Sunnyvale, CA, and supplements Intertek's earlier assessment 1
of, Unit 2 operation at 70 percent power. Intertek performs operational assessments relating to steam generators for many nuclear power plants around the U.S. "This evaluation confirms the structural integrity of the Unit 2 steam generators at 100 percent power, as requested by the NRC," said Pete Dietrich, SCE senior vice president and chief nuclear officer. "While we have no intent to restart Unit 2 at full power, this demonstrates the amount of safety margin we have built into our analyses. We welcome this additional safety analysis but remain steadfast in our commitment to restart Unit 2 at only 70 percent power."
- 2. Facts to Dispute/Refute SCE Claim A. San Onofre Unit 3 operation @100 Power - 11 Months- SONGS Unit 3 Failed In-situ Wear Data
- Unit 3 SG 3E088 (www.nrc.gov). The following tube wear data is based on a result of actual tube degradation in SONGS Unit 3 SG 3E088 caused by fluid elastic instability.
Row 106 Column 78, 100 percent through wall wear, length of wear - 29 inches Row 102 Column 78, 99 percent through wall wear, length of wear - 23 inches Row 104 Column 78, 99 percent through wall wear, length of wear - 27 inches Row 100 Column 80, 81 percent through wall wear, length of wear - 28 inches Row 107, Column 77, 80 percent through wall wear, length of wear - 34 inches Row 101, Column 81, 78 percent through wall wear, length of wear - 26 inches Row 98, Column 80, 72 percent through wall wear, length of wear - 29 inches Row 99, Column 81, 72 percent through wall wear, length of wear - 27 inches B. Mitsubishi Root Cause Document UES-20120254, Rev 0, page 13_of 64, Item 1, "Tube to Tube Wear due to in-plane FEI" states," Tube to tube wear was found in the U-bend region, located between AVBs, in the free span. Many of the tubes exhibiting tube to tube wear also exhibited wear at the AVBs and TSPs, in particular at the top tube support plate. For tubes with wear at the top tube support plate, it is considered that the entire tube, including its straight region, is vibrating. Tube to tube wear occurs when there is tube in-plane motion (vibration) with a displacement (amplitude) greater than the distance between the tubes in the adjacent rows, resulting in tube-to-tube contact. Some of the tubes with tube-tube wear did not experience large amplitude vibration but were impacted by tubes that did experience large amplitude vibration. Also the two tubes in Unit 2 with tube-to-tube wear had different wear characteristics than the Unit 3 tube-to-tube wear."
C. Based on Dr. Pettigrew's Research and other papers published between 2006 -2011 on fluid elastic instability experimental data, "The high dry steam velocities differ in the in-plane and out-of-plane directions. For the SONGS RSG tube geometry, based on experimental data, it is conservatively estimated that the high dry steam velocities for in-plane FEI are at least 200 % of the high dry steam velocities for out-of-plane FEI."
D. The SONGS Unit 2 SG tube wear rates calculated by AREVA, Westinghouse and Intertek Operational Assessments and Work Rates are based on the results of out-of-plane velocities, which are under conservative based on FEI Observations in SONGS 3 and Dr. Pettigrew's Research acknowledged by MHI and NRC Chairman and Commissioners.
E. Deterministic Analysis - Uniform Linear Tube-to Tube Wear Rate in Unit 2 based on Unit 3 Benchmarking = 100%/11 months = 9%/month, consistent with item D and Actual Observations in SONGS 3 F. Westinghouse in SONGS Unit 2 Return to Service Report, Attachment 6, Appendix D, (www.songs.community.com), page 91 states, "Table 3-2. Wear Projection Results for Active Tubes with Limiting AVB Wear Indications" shows the following active tubes in Unit 2 SG 3EO89 with the following data:
Row 119 Column 89, 28 percent ECT reported through wall wear, Row 121 Column 91, 28 percent ECT reported through wall wear Row 131 Column 91, 21 percent ECT reported through wall wear 2
Rqw 129 Column 93, 22 percent ECT reported through wall wear Row 126 Column 90, 21 percent ECT reported through wall wear G. Calculate SG 3E089 tube rupture time @ 9% wear/month for 100% Tube wear @ full power operation Row 119 Column 89, 28 percent wall wear + 72 % in 8 months = 100 % wear = Tube Rupture Row 121 Column 91, 28 percent wall wear + 72 % in 8 months = 100 % wear =. Tube Rupture Row 131 Column 91, 21 percent wall wear + 81 % in 9 months = 101 % wear = Tube Rupture Row 129 Column 93, 22 percent wall wear + 81 % in 9 months = 102 % wear = Tube Rupture Row 126 Column 90, 21 percent wall wear + 81 % in 9 months = 102 % wear = Tube Rupture H. Intertek APTECH Operational Assessment referenced in item 1 above, page I-iv states, "Two OA analysis cases were evaluated based on the sizing techniques used to define the Unit 3 TTW depths. Case 1 evaluated the situation where voltage based sizing for Eddy Current Testing Examination Sheet (ETSS) 27902.2 was used to establish the TTW depth distributions and the correlated wear rate with wear index. The results for Case 1 indicate that the Structural Integrity Performance Criteria,.(SIPC) margin requirements are satisfied for an inspection interval length of 0.94 years (11.5 Months) at 100% power level. For Case 2, where the TTW depths were resized by AREVA using a more realistic calibration standard, the SIPC margins will be met for an inspection interval length of 1.04 years at 100% power level. The plan for Unit 2 is to operate for an inspection interval of 5 months at a 70% power to provide additional margin to the industry requirements for tube integrity. Tube burst at 3xNOPD (Normal Operating Pressure Differential) is the limiting requirement for inspection interval length. Therefore, the accident-induced leakage requirements will be satisfied provided that burst margins at 3xNOPD are maintained during the inspection interval.
I. Deterministic Analysis results shown in item G shows that all the five tubes can rupture in 9 months or less than shown by Intertek in Probabilistic Analysis of 11 months. This Probabilistic Analysis does not meet the intent of NRR RAI 32, in which SCE promised to provide an OA that includes an evaluation of steam generator TTW for operation up to the RTP.
CONCLUSIONS: SCE is once again trying to circumvent and gaming the NRC RAI #32, just like avoiding 10 CFR 50.90 for the Brand New $570 Million RSGs . MHI Anti-vibration bar structure, designed for out-of plane vibrations, is incapable of preventing the adverse effects of tube-to-tube wear or fluid elastic instability (high dry steam) at 100% power operation or main steam line break. We saw the destruction of SONGS Unit 3 RSGs due to tube-to-tube wear or fluid elastic instability (high dry steam) at 100% power operation or Main Steam Line Break Testing. According to the analysis of Unit 2 Plant Operational Data/Procedures and Westinghouse Operational Assessment, fluid elastic instability (high dry steam, high fluid velocities, in-plane vibrations) conditions did not occur in Unit 2. Therefore, this insufficient contact tube-to-AVB forces in Unit 3 causing the FEI is based on hideous data and unreliable MHI Computer Modeling once again. Taking credit for double contact tube-to-AVB forces (Better supports), which prevented in-plane vibrations or Tube-to-tube wear in Unit 2 by NRC Region IV AIT Team/SCE/MHI directly contradicts and conflicts with statements made by Dr. Pettigrew, Westinghouse, AREVA, John Large and inconsistent with Unit 2 Operational data.
This analysis by SCE does not meet the intent of Federal Regulations, NRC Steam Generator Tube Structural Integrity Criteria, SONGS NRC Approved Technical Specifications, NRC Reasonable Assurance Criteria, NRC Chairman's Standards and SCE's Overriding Obligation for Public Safety. A Lot More to Come... Thanks NRC Staff... HAHN BABA Glossary for above:
AIT: Augmented Inspection Team (of the NRC)
AVB: Anti-Vibration Bar 3
AREVA: French nuclear state-owned corporation CAL': Confirmatory Action Letter (sent from the NRC to SCE)
CFR: Code of Federal Regulations ECT: Eddy Current Testing ETSS: Eddy Current Testing Examination Sheet (27902.2)
FEI: Fluid Elastic Instability MHI: Mitsubishi Heavy Industries NOPD: Normal Operating Pressure Differential NRC: Nuclear Regulatory Commission NRR: Nuclear Reactor Research division of NRC 04: Operational.Assessment RAI: Request for Additional Information RSG: Replacement Steam Generator RTP: Reactor Thermal Pressure (standard thermal pressure)
SCE: Southern California Edison SG: Steam Generator (for example, SG 3E089 and SG 3E@88 are Unit 3)
SIPC: Structural Integrity Performance Criteria SONGS: San Onofre Nuclear [Waste] Generating Station TSP: Tube Support Plate TTW: Tube-to-Tube Wear Contact information for the author of this newsletter:
The original author of the above statement which was left at the NRC web site wishes to remain anonymous, but he can be contacted through Ace Hoffman.
- Ace Hoffman, Owner & Chief Programmer, The Animated Software Co.
- POB 1936, Carlsbad CA 92018
- U.S. & Canada (800) 551-2726; elsewhere: (760) 720-7261
- home page: www.animatedsoftware.com
- email: rhoffman@animatedsoftware.com
- To cease contact, please put "Unsubscribe-me-please" in the subject.
4