ML13144A023
| ML13144A023 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/15/2013 |
| From: | Gilmore D SanOnofreSafety.org |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 78FR22576 00275, NRC-2013-0070 | |
| Download: ML13144A023 (4) | |
Text
Page 1 of 2 RULES AND DIRECTIVES BRANCH UONRO As of: May 17, 2013 Received: May 15, 2013 Status: PendingPost PIBIMAY 17 M 9: 33 Tracking No. ljx-85cq-b9lb Comments Due: May 16, 2013 Submission Type: Web Docket: NRC-2013-0070 RECEIVED Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination Comment On: NRC-2013-0070-0001 Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination; San Onofre Nuclear Generating Station, Unit 2 Document: NRC-2013-0070-DRAFT-0180 o13 Comment on FR Doc # 2013-08888
-7 7
3 Submitter Information Name: Donna Gilmore Address:
San Clemente, CA, 92672 Organization: SanOnofreSafety.org General Comment The attached chart compares San Onofre plugged tubes with other replacement steam generators in the nation. It makes it clear this is one of the most dangerous and defective reactor in the nation. The summary fact sheet attached explains the reasons this reactor should not be restarted. Expert independent nuclear engineers agree on these facts.
How in good conscience can you consider lowering safety standards that will make it easier for Edison to restart one of the most defective nuclear reactors in the nation?
I support Friends of the Earth's petition to require a thorough license amendment process and hearing on this and other San Onofre safety issues.
This reactor is a few miles from my house. We have plenty of power available in Southern California and our electric grid operator has plans to get us through another hot summer.
There must be good reasons the current NRC license requires the plant to operate as it was designed -- 100%
thermal power for a full cycle. There is no good reason to lower this standard. The FSLB says restarting the plant under these conditions would be an experiment. You are risking California and the nation's food supply with this action. The wind blows East, so you will also be affected.
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05/17/2013
Page 2 of 2 Please do not approve Edison's request.
Attachments SteamGeneratorTubesPluggedByAgeAndSanOnofreSteamGeneratorProblems2012-11-03 https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=09000064812e704c&for...
05/17/2013
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.0 E
z 900 800 700 600 500 400 300 200 100 0
U.S. Nuclear Reactors: Replacement Steam Generators Tubes Plugged to Avoid Radiation Leaks San Onofre Unit 3: 807 tubes plugged - WORST record in history!
Installed less than one year before leaking radiation!
510
- =San Onofre Unit 2: 510 tubes plugged - 2nd WORST record in history!
Installed less than two years -- unprecedented premature tube wear!
108 35 31 24 1 0 2616 4
8 6
5 5
4 3
2 1
0 0
0 0
0 14 13 11 4
1 0
161482 2
2 1
1-4 Years 5-8 Years I*
4 9-16 Years Nuclear Reactors (years replacement steam generators in operation before tubes plugged)
NUCLEAR REGULATORY COMMISSION: www.nrc.gov/info-finder/reactor/songs/tube-degradationJitml#data, http://pbadupws.nrc.gov/docs/MLO723/MLO72330588.pdf, http;//pbadupws.nrc.gov/docs/MLI 127/ML] 1 270A01 5.pdf FAIREWINDS: http://fairewinds.org/sites/fairewinds.org/files/reports/EdisonRSGs@SO-US-Worst_201 2-7-11 _FairewindsRptFOE.pdf July 2012 SanOnofreSafety.org
STEAM OJTLFT San Onofre Steam
$TEAM 26 STEAM Generator Problems SECO"IAMy Why is San Onofre shut down?
MAMVXY 12)
San Onofre has been shut down since January 31, 2012 due WAsER LEVEL to a radiation leak in defective replacement steam FEEDW/ATER-_
generators and unprecedented wear in all four generators.
NZL Generator failure can cause uncontrolled radiation leaks. Generators are critical for cooling the reactors.
A generator tube in reactor Unit 3 leaked radiation into the air after being installed less than a year.
',E NILMOLE All four generators (2/reactor) show unprecedented premature tube wear less than 2 years after installation. (9727 tubes/generator = 38,908 tubes).
SCONDARY HANOEOLE [2)
These cost ratepayers almost $700 million. Before they failed, Edison said the design changes would result in TLI.SSEET the generators lasting 40+ years.
I.OT LEG INLET Can the steam generators be safely repaired?
Typical Combustion Independent Nuclear Engineer Arnie Gundersen1 said the safest option is to replace the steam generators.
What is the impact o NRC Investigation Chief, Greg Werner', said The tubes are now The only way to determine generators are failing is if accident and spewinj they leak radiation3 or when inspected off-line.
0 The top of the new st water, therefore mal4 Technology doesn't exist to test steam generators.
They rely on computer design simulations. The simulations were off by 300-400%. Engineers under Will plugging tubes a predicted the velocities of steam and water inside the 0
No. Reducing power generators.
inside or outside the What are the significant design changes?
will continue to vibr*
and tube supports ai
" Edison's design changes resulted in tube vibrations and extensive premature tube wear.
Vibrator problemsul generator problems The original generators had a unique tube support to cannot repair design prevent vibration - these supports were changed in the collide with each oth new design and 377 tubes added to each generator. This was done to increase profits.
Reducing power doem structural problems t The main structural stay cylinder was removed (see has damaged and wil diagram). This support cylinder was designed to secure the generator and prevent vibration - exactly the kind wiLower power might c of vibration that seems to be causing tube degradation.
Historical evidence al All of these changes necessitated pressure and flow changes in the generator's operation, operating at lower pc solution.
I http://fairewinds.com/content/san-onofre-bad-vibrations 2http://sciencedude.ocregister.com/2012/06/18/nrc-steam-flow-too-high-in-san-onofre-units/173005/
3http://pbadupws.nrc.gov/docs/ML0037/ML003740256.pdf (page 2, second column)
DEULECTOG 32 STEAM DRYER ORAIIS NSTRLAES.T NOZZLE RECIRCULAT ON 3UW REC*pCULArIO#
SMIP DR.INKS
-MA IN EEDWATER NOZZLE VAIN FEED RING NOZZLE WING W0 CRATE WPORTS IOCLE WTBES BOTTOM SLOWOOWN
& DRAIN NOZZLE Engineering Steam Generator f the design changes?
at risk of bursting in a main steam g radioactivity into the air".
eam generator is now "starved of ing tube vibration inevitable".
nd reducing power help?
will not change the pressure tubes. Previously damaged tubes ate, damaging surrounding tubes nd worsen the existing damage.
not the root cause of the steam at San Onofre. Plugging tubes changes that cause the tubes to er.
not remedy the underlying hat are creating the vibration that I continue to damage the tubes.
reate a resonate frequency at t increase without notice.
other reactors has shown that wer has not been an effective Gary@SanClementeGreen.orgSanoraftog SanOnofreSafety.org