ML13102A248

G20130288/LTR-13-0308 - Ltr. Thomas Gurdziel 2.206 - San Onofre Nuclear Generating Station (SONGS)

ML13102A248
Person / Time
Site:	San Onofre
Issue date:	04/05/2013
From:	Tom Gurdziel American Society of Mechanical Engineers (ASME)
To:	Borchardt W Document Control Desk, NRC/EDO, NRC/SECY
Shared Package
ML13184A011	List: ML13102A248
References
G20130288, LTR-13-0308, 2.206
Download: ML13102A248 (6)

Text

ETS < U.S.NRC Ticket No: G20130288 UiPed Sum Nuclea Regutoy Comisson ProtectinghPepleand lhe Environment 2413

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Assigned Office: NRR OEDO Due Date: 05/10/2013 Other Assignees: SECY Due Date:

Date Response Requested by Originator:

Other Parties:

Subject:

2.206 - San Onofre Nuclear Generating Station (SONGS)

Description:

CC Routing: OGC, RegionlV ADAMS Accession Numbers - Incoming: Response / Package:

• • !i*': .* '.* .

l Cross Reference No: LTR-1 3-0308 SRM\Other: No

'x, Action Type: 2.206 Review OEDO Concurrence: No Signature Level: NRR OCM Concurrence: No Special Instructions: OCA Concurrence: No nt fomo S Originator Name: Tom Gurdziel Date of Incoming: 04/05/2013 Originator Org: Citizens Document Received by OEDO Date: 04/11/2013 Addressee: R. W. Borchardt, EDO Incoming Task: 2.206 OEOO: Da erk

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed:Apr 10., 2013 15:11 PAPER NUMBER: LTR-13-0308 LOGGING DATE: 04/10/2013 ACTION OFFICE:

AUTHOR: Tom Gurdziel AFFILIATION: NY ADDRESSEE: Chairman Resource cc'd

SUBJECT:

Provides a petition under 2.206 concerning San Onofre Nuclear Generating Station situation ACTION: Appropriate DISTRIBUTION: RFR SECY to Ack.

LETTER DATE: 04/10/2013 ACKNOWLEDGED Yes SPECIAL HANDLING: 2.206 petition NOTES:

FILE LOCATION: ADAMS DATE DUE: DATE SIGNED:

EDO -- G20130288

This is a 2.206 request letter.

9 Twin Orchard Drive Oswego, NY 13126 April 5, 2013 Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Bill Borchardt:

The SONGS Situation Let me explain to you my current assessment of the SONGS replacement steam generator situation.

I don't have a problem that Southern California Edison made changes to the design of the replacement steam generators that, they felt, did not require NRC approval. My guess would be that everybody else does this too. And, even though I would question the choice of broached trefoil holes with chamfered lands in Type 405 stainless steel instead of Alloy 690 (for the tube support plates), let me skip this concern. I will assume that the replacement steam generators were presented for shipment from Kobe, Japan in perfect condition.

So, where are the problems I see? First, Southern California Edison directed Mitsubishi to effectively eliminate all environmental requirements. (Ref. Follow-up AIT report, p. 15, 16 lines up). Second, shipping orientation of the plane of the u-tubes was not specified. Third, no method of tube bundle support during shipping was specified, apparently in violation of

Specification S023 017 01. (Ref. AIT report p. 45, 8 lines up). Fourth, unlike for the Unit 2 replacement steam generators, both a baseline pre-service eddy current test (in Japan) and a final pre-service eddy current test (at SONGS) WERE NOT PERFORMED for Unit 3. (Ref. AIT report p. 3, 1 line up and p. 4, top paragraph (for Unit2); and AIT report p. 4, 12 lines up). Any changes resulting from shipping damage are thus hidden. This is particularly significant (and, should I say, suspicious) because at least one very large impact load of 1.23 g was recorded by 3 accelerometers attached to Unit 3 replacement steam generator 3EO-88. (Ref. AIT report p. 46, 19 lines down). This is problem 5. Note that this is the replacement steam generator that had the leak.

These actions/performances lead me to request the following as 2.206 actions:

1. Permanently (and immediately) change the licensed power of SONGS Unit 3 to zero.

2. Prohibit any involvement with all nuclear industry (including SONGS) activities by all Southern California Edison QC, QA, engineers, and other management people that approved removal or dilution of Unit 3 shipping and receipt requirements on December 22, 2009. (Ref. AIT Follow-up report p. 16, 2 lines down).

I consider the Unit 2 replacement steam generators to be in somewhat better condition. Since they DID receive an eddy current test after shipment to SONGS that identified no changes, (Ref.

AIT report p. 4, 4 lines down), and since no impacts to Unit 2 replacement steam generators have been reported in either the AIT report (dated July 18, 2012) or the Follow-up AIT report (dated November 9, 2012), I am requesting an immediate change in the licensed power of SONGS Unit 2 down to 70%, limited to 5 months of operation, and immediate permission to Southern California Edison to start up Unit 2. This also is a 2.206 request.

Finally, let me note that it is my expectation that, at 0% power (and disconnected from the Unit 3 main turbine), the Unit 3 main generator can be set up to run as a synchronous condenser and thereby assist in the maintenance of acceptable voltage on the California electrical grid transmission lines.

Thank you, Thomas Gurdziel Member, ASME Copy:

President Michael R. Peevey Commissioner Catherine J.K. Sandoval Commissioner Mark J. Ferron Commissioner Mike Florio Commissioner Carla J. Peterman U.S. Senator Barbara Boxer U.S. Representative Ed Markey This is a 2.206 request letter.

'Joosten, Sandy From: Tom Gurdziel [tgurdziel@twcny.rr.com]

Sent: Wednesday, April 10, 2013 8:28 AM To: morgan.lee @utsandiego.com Cc: CHAIRMAN Resource; Evans, Michele; Broaddus, Doug; jicc; OPA4 Resource

Subject:

SONGS Decision Attachments: SONGS 2.206.docx Good morning, I have attached a letter requesting certain actions, which I consider warranted, be taken by the Nuclear Regulatory Commission. Whether or not those actions are taken, I believe that it is even more important that a decision on both units be made now, (in other words this month of April, 2013).

I understand that all possible information that can be requested perhaps, has not yet been requested. I don't accept this as an acceptable reason for not making a decision. After all, 14 months have passed already. I feel that there is a need to make a decision based on the information available to this date.

Thank you, Tom Gurdziel 1