ML13144A102

Comment (294) of Dab Safety Team on the Application and Amendment to Facility Operating License Involving Proposed No. Significant Hazards Consideration Determination; San Onofre Nuclear Generating Station, Unit 2

ML13144A102
Person / Time
Site:	San Onofre
Issue date:	05/16/2013
From:	The DAB Safety Team
To:	Rules, Announcements, and Directives Branch
References
78FR22576 00294, NRC-2013-0070
Download: ML13144A102 (44)

Text

Page 1 of 1.RULES AND DIRECTIVES BRANCH USNRC PUBLIC SUBMISSION 2013 MAY 17 AN 10: 9 As of: May 17, 2013 Received:

May 16, 2013 Status: Pending Post Tracking No. ljx-85d2-h5 lc Comments Due: May 16, 2013 Submission Type: Web Docket: NRC-2013-0070 t F R ,CF IV/ D Application and Amendment to Facility Operating Licens-1nvolving roposed Consideration Determination Comment On: NRC-2013-0070-0001 Application and Amendment to Facility Operating License Involving Proposed Consideration Determination; San Onofre Nuclear Generating Station, Unit 2 Document:

NRC-2013-0070-DRAFT-0202 Comment on FR Doc # 2013-08888 No Significant Hazards Hazards Submitter Information Organization:

DAB Safety Team General Comment#1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators

-Technical Version (36 Pages) +Attachment Notes (7 Pages)"Based on a review of the above evidence, it appears that the NRC accepted Edison's 10 CFR 50.59 Screening, Evaluations and supporting documents without due diligence, independent analysis and violating its own rules." Attachments The Big Number I Technical Version 10-04 The Big Number 1 Attachment Notes -Updated- 10-29-2012 SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= B. Benney (bjb)https://www.fdms.gov/fdms-web-agency/componentlcontentstreamer?objectId=09000064812e7b79&for...

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1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 NOTE: The DAB Safety Team Expert Panel will update this report after a thorough review of Actions to Address Steam Generator Tube Degradation San Onofre Nuclear Generating Station, Unit 2, which were transmitted to Mr. Elmo E. Collins, Regional Administrator, Region IV on October 3 in response to NRC Confirmatory Action Letter (Ref. Docket No.50-361) by Peter T. Dietrich, Senior Vice President

& Chief Nuclear Officer, Southern California.

Based on the results of Attachment I and other evidence presented in this report, the DAB Safety Team Expert Panel has concluded that numerous major untested and unanalyzed design changes were made by Southern California Edison (SCE) to the original steam generators without prior approval from NRC and without the 10 CFR 50.90 Licensing Amendment Process. Fairewinds Associates states (See Attachment 1, Table 1), "A total of 7 out of 8 of these major design changes to the original steam generators failed to meet all the eight 50.59 criteria and created a total of 39 safety issues requiring amendment to the license." According to Professor Daniel Hirsch, "At Edison's request, Mitsubishi made numerous changes to the design of the steam generators compared to those originally at San Onofre. Yet, by asserting that it was making a "like for like" change, SCE bypassed the normal requirement to apply for a license amendment, which would have entailed a higher degree of scrutiny by the NRC and the opportunity for the public to request an evidentiary hearing." One SCE Engineer wrote in a paper published in an International Magazine,"Continuing to operate with highly degraded steam generators can involve substantial economic risks from forced outages, extended refueling outages, as well as the direct costs of inspections and repairs. As specified, the Original Steam Generators (RSG's) were supposed to be a replacement in-kind for the Original Steam Generators (OSG's) in terms of form, fit and function.

At the same time, however, the RSG specification included many new requirements derived from both industry and SONGS operating experience, and the requirement to use the best and most suitable materials of construction.

These requirements were aimed at improving the RSG longevity, 2

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 reliability, performance and maintainability.

Also, the specification called for very tight fabrication tolerances of the components and sub-assemblies, especially the tube-sheet and the tube U-bend support structure.

In addition, SONGS steam generators are one of the largest in the industry, which called for innovative design solutions and improved fabrication processes when working on the RSGs. Conceivably, the MHI and Edison project teams faced many tough challenges throughout the entire project in the design, manufacturing and QC areas, when striving to meet the specification requirements." SCE made these untested and unanalyzed changes in a rush to maximize profits and violated the Federal Regulations, NRC "Reasonable Assurance" and SCE's"Overriding Obligation" for adequately protecting the health and safety of the public from the potential adverse consequences due to a near miss major nuclear accident.These numerous and unprecedented design changes caused 8 tubes to fail "in-situ" pressure testing and resulted in plugging of almost 1317 tubes in Replacement Steam Generators.

At the June 18, 2012 AIT presentation, the NRC said, "Throughout the US nuclear industry, this is the first time more than one steam generator tube failed pressure testing....

Eight tubes failed. The pressure testing identified that the strength of eight tubes was not adequate and structural integrity might not be maintained during an accident...

this is a serious safety issue." The Replacement Steam Generators were designed to last between 40 (SCE) to 60 years (MHI), but failed with less than 2 years in operation.

These untested and unanalyzed design changes made by the SCE Engineers to prevent the plugging problems and steam generator industry improvements, which the old steam generators experienced (e.g., fluid elastic instability, turbulence-induced vibrations, corrosion, etc.) resulted in the destruction of both brand new replacement steam generators.

The SCE Engineers did not follow the advice of an NRC Section Chief of MIT Intelligence, who said to his staff, "Read and reread in-between the lines', use a 'Critical Questioning

& Investigative Attitude' and 'Solid Teamwork &Alignment" and the World's Foremost Expert on preventing the adverse and expensive effects of Turbulence-induced vibrations and Fluid Elastic Instability in Nuclear Power Plant Components and their Heat Exchangers.

That means that SCE Engineers also 3

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 violated the SONGS Human Performance Tools and Procedures, by not using the above described critical attributes.

Southern Californians were very lucky this time, because a potentially serious nuclear accident in progress was stopped by the swift and intelligent actions of SONGS Shift Manager Mr. Flynn and his Operating Crew, who reduced the power and the plant was eventually safely shut down by others without any measurable dose to the public (Attributed to multiple high radiation alarms, NO operational transients, NO Automatic Reactor Trip and without any inadvertent actuation of Main Steam Line Valves, which luckily happened to be maintained and in good working condition!).

Now let us examine the kind of radiological consequences that could occur with a steam generator tube rupture (without a main steam linebreak) accident with 8 steam generator rupture tubes! The industry tube rupture experience shows a complete tube failure resulting in a leak rate of between 90-630 gallons per minute (gpm), assuming ongoing leakage prior to the break (e.g., I gpm), and 1% defective fuel. Even without a main steam line break, if these 8 (or more) tubes had ruptured, they could have caused the secondary side to over-pressurize and superheat, that in turn, could have then potentially resulted in many more additional SG tube leaks or ruptures due to jet impingement from high pressure, high temperature primary reactor coolant from the already degraded tubes. With 8 simultaneous tube ruptures, approximately 60 tons of very hot high-pressure radioactive reactor coolant would have leaked into the secondary system within 5-20 minutes of the initiating event depending upon the size of the leaks. The amount of steam released from a stuck-open spring loaded main steam pressure relief or stuck atmospheric dump valve to atmosphere would have been much more than the amount of steam released by the Mihama Unit 2 Steam Generators (Approximately 250 tons or Fort Calhoun 260 tons manufactured by MHI) because of the large size of the Steam Generators (623 tons)at SONGS. The concern is that multiple tube failures would have decreased the SONGS NRC approved safety margins so that, in essence, the SG's became "loaded guns," or an accident waiting to happen. Under these conditions, significant amounts of radiation would have escaped to the atmosphere.

With the reactor at 100% power, a major 4

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 nuclear accident could have easily resulted and caused much wider radiological consequences than the SONGS NRC approved safety analysis.

A review of industry documents and memorandum indicates that similar concerns in the past have been raised by concerned citizens, officials of the Nuclear Regulatory Research and Nuclear Reactor Regulations, but have been either ignored or "closed by NRC Staff" without any adequate resolution.

SCE Engineers did not benchmark the Palo Verde Nuclear Generating Station (PVNGS)and other US Combustion Engineering (CE) Replacement Steam Generators (RSGs)design and fabrication details provided in NUREG-1841 and Power Uprate Applications to eliminate the problems experienced by the old steam generators experienced.

This appears to be a sheer case of lack of critical questioning and investigative attitude, self-imposed time and financial pressure, and lack of solid teamwork and alignment between SCE & MHI Engineers.

In addition, SCE selected the lowest cost manufacturer, which did not have the proven and tested technology to fabricate such large SONGS RSGs (623 Tons). These factors contributed to the failure in the design and fabrication of such an important piece of equipment vital to the safety of the public and reliable power generation to meet the needs of the Southern Californian Ratepayers.

In 2005, the plant's operators were granted permission by the California Public Utilities Commission (CPUC) to spend up to $680 million installing new replacements steam generators at the facility.

Additional costs up to a total of $782 million were also approved [Source: May 29, 2012, San Diego Reader]. Southern California Edison has spent additional

$48 million in inspection and repair costs in 2012 and the company is expected to pay another $25 million for the restarting the Unit 2 reactor operations at reduced power[Source July 31, 2012: 89.3 KPCC; Orange County Register; The Press-Enterprise].

NOTE: SCE Unit 3 Root Cause Evaluation, pages 28 and 29 state, "The review did not identify a missed-opportunity for SONGS to use industry or site OE in developing design specifications for the new SGs. There were no events identified at other stations involving tube-to-retainer bar wear, and there were only three events involving tube-to-tube wear.5

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 Two of these events involved Once-Through Steam Generators (OTSGs) and only one recirculating SGs, such as at SONGS. Additional information was identified discussing tube-to-tube wear in original SGs (since replaced) at Palo Verde, however the information was not readily available as industry operating experience within the INPO (IER, SER, etc.). These OEs were not considered to be missed opportunities due to the lack of readily available information.

The review of site OE going back approximately eight years did not identify previous problems with the SONGS original SGs with respect to tube-to-retainer bar wear, tube-to-tube wear, or FEI in general. Thus, there was no missed opportunity for SONGS to identify and address the potential for these types of wear in the new SGs." NRC AIT July 18, 2012 Report, page 44 states, "The team reviewed NRC generic communications not falling into one of the above categories for potential relevance to SONGS Unit 2 and 3. One of these was NRC Information Notice 2004-16 concerning an operational leakage event at another plant due to damage caused by a packing screw during transport to the steam generator manufacturer.

The licensee stated in its steam generator change package that this incident was precluded for SCE by prohibiting the use of screws and nails as fasteners for tubing shipping crates." NRC Information Notice 2004-16, dated August 2004 states," During the review of the manufacturing records of the replacement steam generators for Palo Verde, it was determined that one tube was scrapped during the fabrication of the replacement steam generators since it was damaged (or pierced) by a packing screw. Screws are used in the packing crate in which the tubes are shipped from the tubing manufacturer to the steam generator fabrication facility." SCE is a partner in Palo Verde, and the Palo Verde design and fabrication information provided in the Palo Verde Replacement Steam Generator 50.90 License Amendment and Power Rate Application (ML042010289

-Cover Letter dated September 29, 2003 from B. M. Pham, USNRC to G.R. Overbeck, "Palo Verde Nuclear Generating Station, Unit 2 (PVNGS-2)

-Issuance of Amendment on Replacement of Steam Generators and Uprated Power Operations")

was available to SCE Engineers as to how PVNGS eliminated (design changes and fabrication details) the fluid elastic instability and turbulence-induced vibrations experienced in Original Palo Verde CE Steam Generators, which were similar ill design as SONGS Original CE Steam Generators.

NRC Augmented Inspection Team Report (ML2012007, 7-6

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 18-12) Report and SCE Unit 3 Root Cause evaluation (Unit 3 Steam Generator Tube Leak and Tube-to-Tube Wear Condition Report: 201836127, Revision 0, 5/7/2012) are dubiously silent on Palo Verde benchmarking relating to the design and fabrication details of CE Replacement Steam Generators and the improvements carried out to solve the problems related to the Original Palo Verde CE Steam Generators, which were also applicable to SONGS. Please Note that tube ruptures at Mihama, St. Lucie were caused by deformation of Anti-vibration bars and approximate 4400 tube wears at SONGS Units 2 & 3 have been caused by tubes rubbing against Anti-vibration bars (www.nrc.gov).

All it shows you is that SCE Engineers did not use a "Critical Questioning

& Investigative Attitude" and "Solid Teamwork & Alignment" between NRC Staff, Licensee, Manufacturers and Vendors during design and fabrication of Replacement Steam Generators." According to discussions with several SONGS Managers, part of the Steam Generator Recovery Project and Oversight Teams, "To achieve the maximum heat transfer rate from RSGs and maximize profits, SCE Engineers wrote defective specifications, made numerous untested and unanalyzed design changes and specified the tallest U-tube bundle with the maximum number of tubes, which could fit within the RSGs. The biggest mistake SCE Steam Generator Experts made was, 'Instead of making numerous design changes at one time, they should have made incremental changes after thorough discussions with MHI Team and verified/validated with test data or industry experience to ensure that these changes did not pose any safety risks."* The Original Steam Generators, CE Model 3410 (Each Generator Rated at 1705 MWt) had 9350 Mill Annealed Alloy 600 Tubes. According to the published industry literature, the new thermally treated Alloy 690 has a 10% less thermal conductivity compared with Alloy 600 (Thermal Conductivity Btu-in./ft2-h-0 F @ 600 OF, 122 vs.133). Let us say, to achieve the same Thermal Output of 1729 MWt between the old and new generators, you need 10% more tubes, that is 9350 + 935 = 10285 tubes. But by removing the stay cylinder from the old generator, there was enough space only to cram 377 additional tubes. So the new generator has a total of 9350 + 377 = 9727 Alloy 7

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 690 tubes. But you still need 935-377 = 558 Tubes. Since there was no room to add the additional 558 tubes, SCE Engineers specified to increase the length of each tube in the U-Tube Bundle by 7.2 inches to increase the total heat transfer area to 116,100 square feet. According to discussions with several SONGS Managers, part of the Steam Generator Recovery Project and Oversight Teams, "This change was made to generate Thermal Output of 1729 MWt from each replacement steam generator without officially informing the NRC." These untested and unanalyzed design changes (increasing the length of U-Tubes)resulted in over-pressurization and superheating of steam in the U-tube bundle, while both the Units 2 & 3 were operating at full power. According to Fairewinds Associates, "The original steam generators had a triangular tube pitch pattern, very closely packed U-tubes, and unique egg-crate tube supports that kept the tubes from vibrating and colliding.

The pitch to diameter ratio of tubes in the original CE generators is dramatically different from any of the Westinghouse generators fabricated by Mitsubishi.

Not only is Mitsubishi unfamiliar with the tightly packed CE design, but also Edison's engineers created so many untested variables to the new fabrication that this new design had a significantly increased risk of failure. As a result of the very tight pitch to diameter ratios used in the original CE steam generators, Mitsubishi fabricated a broached plate design that allows almost no water to reach the top of the steam generator." The steam over-pressurization and superheating caused "Flowering (Elastic deformation) of the U-tube Bundle, which was attributed by MLHI due to high void fractions in the localized regions and a relatively small tube pitch to tube diameter ratio (P/D). Flowering was described by MHI as the elastic deformation of the anti-vibration bar structure and the tube bundle in the U-bend region, as a result of thermal expansion and fluid dynamic pressures acting on the secondary side of the tubes. The deformation caused by the "flowering" effect was believed to result in multiple areas of no contact between the anti-vibration bars and the tubes, which minimized resistance to in-plane motion of the U-bend area of the tubes. The NRC inspection team concluded that SONGS Unit 3 steam generators had experienced excessive vibration of tubes in 8

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 the U-bend region to the extent that the tubes rubbed against each other (tube-to-tube interactions) causing excessive wear and loss of structural integrity.

SCE staff has determined that the vibrations were caused by the high flow, high-velocity and localized dry-out steam conditions in the U-bend region of the steam generators by a phenomenon called "fluid elastic instability." The NRC inspection team further concluded that the steam generators design and configuration did not provide the necessary margin to prevent fluid elastic instability in both steam generators.

According to the DAB Safety Team and NRC AIT Experts, these adverse design changes caused: (1) The combination of unpredicted, adverse thermal hydraulic conditions and insufficient contact forces in the upper tube bundle caused a phenomenon called "fluid-elastic instability" which was a significant contributor to the tube to tube wear resulting in the tube leak. The NRC AIT Team concluded that the differences in severity of the tube-to-tube wear between Unit 2 and Unit 3 may be related to the changes to the manufacturing/fabrication of the tubes and other components which may have resulted in increased clearance between the anti-vibration bars and the tubes; (2)Due to modeling errors, the SONGS replacement generators were not designed with adequate thermal hydraulic margin to preclude the onset of fluid-elastic instability.

According to the DAB Safety Team and other Anonymous SONGS Root Cause Team Members, Shift Managers and Emergency Planning Experts, to prevent risks to public health and safety, SONGS Steam Generators need to be re-configured, reverse-engineered and duplicated like the PVNGS Replacement Steam Generators.

Without these modifications, even at reduced power operations, the SONGS Replacement Steam Generators U-Tube section will continue to experience excessive vibrations due to fluid elastic instability conditions.

Certain sections of the U-tube Bundle will experience violent vibrations due to high void fractions in the localized regions (e.g., Superheated Steam regime, mist-flow, almost no water) and low in-plane clearances due a relatively small tube pitch to tube diameter ratio (elastic deformation of the U-Tube bundle and weakened damping capability of the Anti-Vibration System) will continue to cause excessive and accelerated tube wear that could result in multiple tube leakage and/or 9

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 tube ruptures.

These unanticipated operational occurrences coupled with operator error and inadvertent operation of main steam valves could potentially create radioactive releases to the outside environment and result in a loss of cooling to the reactor core.The accident in progress would result in uncontrolled reactor core meltdown like Three Mile island, Fukushima and will become a MAJOR nuclear accident in the backyard of Southern Californians affecting the safety and health of countless human lives and destroying the economies of California and Mexico.NRC AIT Report states, "With regard to the major design changes between the original and replacement steam generators, the updated final safety analysis report did not specify how the original steam generators relied on special design features such as the stay cylinder, tube-sheet, tube support plates, or the shape of the tubes to perform the intended safety functions.

The description of the original steam generators was focused on the overall thermal performance characteristics and the applicable codes and standards used for fabrication.

The licensee's bid specification required that the stay cylinder feature of the original steam generators be eliminated to maximize the number of tubes that could be installed in the replacement steam generators and to mitigate past problems with tube wear at tube supports caused by relatively cool water and high flow velocities in the central part of the tube bundle. Mitsubishi employed a broached trefoil tube support plates instead of the egg crate supports in the original design. In addition to providing for better control of tube to support plate gaps and easier assembly, the broached tube support plates were intended to address past problems with the egg crate supports by providing less line of contact and faster flow between the tubes and support plates, reducing the potential for deposit buildup and corrosion." According to Fairewinds Associates, "As water moves vertically up in a steam generator, the water content reduces as more steam is created. When the volume of steam is much greater than water then the flow resistance of the water/steam mixture passing through the tube supports accounts for one third of the total resistance at the top of the steam generator.

Therefore to avoid vibration at the top of the tubes, Mitsubishi 10

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 needed to specifically analyze the type of tube support to use in this unique application.

The flow resistance of the Mitsubishi broached plate is much higher than that of the original Combustion Engineering egg crate design because the tubes are so tightly packed in the original CE San Onofre steam generators.

By reviewing the documents thus far produced, it appears that due to Mitsubishi's fabrication experience with broached plates, both Edison and Mitsubishi missed this key difference in the design and fabrication of the new San Onofre steam generators.

Not only is Mitsubishi unfamiliar with the tightly packed CE design, but also Edison's engineers created so many untested variables to the new fabrication that this new design had a significantly increased risk of failure. As a result of the very tight pitch to diameter ratios used in the original CE steam generators, Mitsubishi fabricated a broached plate design that allows almost no water to reach the top of the steam generator.

The maximum quality of the water/steam mixture at the top of the steam generator in the U-Bend region should be approximately 40 to 50 percent, i.e. half water and half steam. With the Mitsubishi design the top of the U-tubes are almost dry in some regions. Without the liquid in the mixture, there is no damping against vibrations, and therefore a severe fluid elastic instability developed." Professor Daniel Hirsch states, "SCE has attempted to compare its steam generator experience to St. Lucie 2, in order to assert that what is happening at San Onofre is typical for new replacement steam generators and is simply a "settling in" process common to them. These assertions are clearly misplaced.

St. Lucie 2's steam generators are having great trouble, and as the data show, not in any fashion the norm. Indeed, St.Lucie I had only 17 damaged tubes at its first ISI. The serious problems at St. Lucie 2 have resulted in its operators having to conduct a root cause analysis, which concluded that "the root cause was that the U-tubes were not effectively supported during SG[steam generator]

manufacture, which caused the tubes to sag into the Anti Vibration Bars (AVBs) and led to slight AVB deformation that closed the tube-to-AVB gap at specific locations.

This exacerbated tube wears in those locations." 11

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 Due to self-imposed Time and Financial Motivations, SCE selected the lowest cost manufacturer, which did not have the proven and tested technology to fabricate such large SONGS RSGs (623 Tons). The largest RSGs. manufactured by Mitsubishi Heavy Industries (MHI) were for EDF, France (316 tons) and for Fort Calhoun- 1 (260 Tons).SCE and MHI both claimed Great Team Work, Challenges, Rewards and Innovations involved in the design and fabrication of these RSGs. Mitsubishi selected a U-bend configuration for the upper part of the tube bundle instead of the square bend design of the original steam generators based on its experience that U-bends were "cheaper and easier to fabricate/

support and inspect." The Anti-Vibration bar and the support structure designed by SCE and fabricated by MHI did not provide the robust structural integrity and the strong damping capability to prevent in-plane tube-tube wear due to fluid elastic instability and turbulent vibrations caused by high steam flows and velocities and localized void fraction in the certain sections of the super-heated U-tube bundle (Two-phase mist-flow).

A review by DAB Safety Team of Palo Verde Nuclear Generating Station (PVNGS) and other US Combustion Engineering (CE)Replacement Steam Generators (RSGs) details provided in NUREG-1841 and Power Uprate Applications and Professor Daniel Hirsch's Report shows that Westinghouse and Babcox & Wilcox International successfully designed and fabricated more than 100 steam generators in the last 20 years to eliminate the types of problems experienced by the SONGS original CE steam generators.

12

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 MHI is a very aggressive manufacturer trying to capture the Future US Nuclear market and claims, "As a result of extensive verification and qualification testing, we have developed an Advanced Pressurized Water Reactor (APWR) design that is more efficient with greater output than any previous power plant." In a similar claim Mitsubishi Heavy Industries in December 2006, the company claimed, "On the basis of the manufacturing technology, quality control and process management cultivated for decades in PWR plants in Japan, MHI has organized a system for shipping and delivering high-quality reactor products to overseas customers within a short period, as requested.

In the export business, not only in terms of equipment quality but also through a quality assurance system for export, quality records conforming to local laws, regulations, and codes can be compiled and shipped together with products.

Quality record documents including design drawings, manufacturing procedures, and inspection records are highly evaluated by customers.

The know-how of exports of PWR plant components obtained so far will be fully fed back to the replacement work of equipment in overseas plants and the construction work of new plants, and MHI is determined to fulfill its duties as a leading PWR plant equipment company to contribute to the stable supply of electric power all around the world." A review of the industry literature and Internal NRC Correspondence shows that the Office of Nuclear Regulatory Research, Office of Nuclear Reactor Regulations (NRR) and Researchers from MIT and Europe disagree with NRC Staff conclusions,"SG tube integrity provide reasonable assurance that all tubes will exhibit acceptable structural margins against burst or rupture under normal operating conditions and DBAs, including MSLB, and that leakage from one or multiple tubes under DBAs will be limited to very small amounts, consistent with the applicable regulations for offsite and control room dose." The DAB Safety Team Expert Panel (Includes several anonymous concerned members from the SONGS Root Cause Team and other Plant Divisions, PhDs in Chemical Engineering) strongly agrees with the other NRR/MIT/European Experts and totally disagrees with NRC Staff conclusions.

NRC analysis and regulations in light of SONGS Unit 3, 8 Alloy 690 TT failed tubes discovered during in-situ 13

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 pressure testing are outdated!>' The DAB Safety Team strongly recommends that NRC Regulations, Analyses and Computer Models be revised and updated for all US operating reactors to address public safety and radiological doses, which can be potentially caused by multiple tube (already degraded tubes such as SONGS) ruptures under normal operating (65-100% power) conditions with or without DBE/DBAs (Including MSLB, LOCA, LOOP, etc.).The DAB Safety Team says, "After the San Onofre debacle, NRC, NEI, INPO, Utilities and other Agencies need to double their efforts to ensure that the MHI Advanced Pressure Water Reactor Nuclear Technology (1700 MWe, 4451 MWt) is safe, reliable and affordable for the US Public. " The DAB Safety Team requests, "SCE, MHI & NRC to release all the emails, correspondence, telephone notes and ALL documents to the Public/Press pertaining to Steam Generator Replacement Project (SGRP) issued between 2001 and to-date. SCE is also encouraged to apply to NRC for a Full 50.90 Licensing Amendment on the SGRP and an Open/Trial-Like

& Transparent Public Hearing." 1. Public/Experts Opinion and San Onofre Future October 1,2012: SCE in a press statement states, "San Onofre plays a critical role in stabilizing the entire electric grid in the state and regionally.

This stabilization is a critical aspect for adding power to the grid from remotely located energy sources, including wind and solar. San Onofre provides "base-load" generation, meaning its power serves customers' needs day and night, regardless of the weather or the availability of the sun. It also provides critical voltage support -which allows the local grid to import more power -including power from far away renewable sources when demand is high. The nuclear industry has been generating safe, reliable electricity for more than five decades. In California-one of the largest users of electricity in the 14

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 country -nuclear energy produces 24/7 power that is essential to our digital economy, as well as our homes and small businesses.

Nuclear energy facilities supply 37 percent of California's emission-free power. Both San Onofre units are currently safely shut down for inspections, analysis and testing after unexpected tube wear was found in the steam generators.

Because the steam generator tube wear is more significant in Unit 3 than in Unit 2, SCE does not foresee Unit 3 coming online in the near future. SCE is focused on finalizing a response to the Nuclear Regulatory Commission's (NRC)Confirmatory Action Letter that will describe the company's plan for returning Unit 2 to safe operation.

October 1,2012: Friends of the Earth commissioned David Binder Research to survey registered voters in the Edison service area Sept. 11-17. Binder used live callers to both cell phones and landlines.

The poll has a margin of error of plus or minus 3.7 percent.In a telephone poll of 700 registered voters in Edison's service area, 58 percent of respondents said they oppose shut down. "Support for the shutdown is widespread, with voters across all counties in the Edison service area showing support for keeping the nuclear plant shut down and favoring replacing its power with renewable energy and conservation," said Shanan Alper, research analyst with David Binder Research.

More bad news for Edison: During the shutdown, Edison's often-repeated public position on restarting the plant has been that "safety is our number one priority. "While customers surveyed almost unanimously said Edison should put safety first, nearly half believe the utility puts profits before safety. Nearly three-quarters of respondents expressed at least some level of concern about an accident at San Onofre. "Edison's customers are not buying the company line," Damon Moglen, energy and climate director for Friends of the Earth, told ENews Park Forest. "After a summer when the lights stayed on without San Onofre, a strong majority of Southern Californians know that these crippled reactors can be replaced with clean and reliable sources of energy. And a significant number believe Edison's proposal to restart San Onofre is gambling with their safety." 15

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 Del Mar supports investigation of San Onofre nuclear plant: After hearing a detailed explanation from a San Onofre Nuclear Generating Station official about the tubing failure and radiation release that took place in January, as well as nearly a dozen heartfelt pleas from citizens to take a stand on the issue, the Del Mar City Council on Sept. 24 passed a resolution calling for a public Nuclear Regulatory Commission hearing to review the station's license. Southern California Edison, which operates the station, needs to go the extra mile to re-establish public confidence, said Councilman Terry Sinnott. "There is a public confidence issue," he said. "The public is worried.The resolution was adopted with some amendments, however, narrowing the scope of the issue in an effort to make it more effective in obtaining its goal -a transparent investigation.

• 9/26/2012 Encinitas City Council Meeting, "It is of the utmost importance that all measures be taken to assure the complete and total safety of the SONGS facility, both mechanically and operationally, before any consideration is given to permitting reactivation, up to and including consideration of deactivation of the facility."* IRVINE City Council is urging the Nuclear Regulatory Commission to more closely examine safety conditions and potential hazards at the San Onofre Nuclear Generating Station before it is considered for relicensing in 2022.* August 25, 2012, Oceanside:

Professor Daniel Hirsch was in Oceanside on Saturday to voice concerns about the potential dangers of Southern California Edison restarting its reactors at the San Onofre Nuclear Generating Station. "These are very sick puppies," he said of the reactors, which have been shut down for months because of cracks found in the recently replaced steam-generator tubes. Hirsch told attendees that the repairs have been minimal and that Edison plans to restart one of the reactors soon "just to see what happens." "It is the kind of experiment where there are 8.5 million guinea pigs," he added. Eunice Tirado of Escondido called the presentation "scary." "I am here because I don't want." Hirsch said Saturday that "Edison was trying to meet a nine-month deadline 16

1. 1 US Nuclear Safety Concern -- San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 to avoid having to repay residents who paid for the costly replacement steam generators.

Further, Hirsch argued that the NRC is run by those with close ties in nuclear energy.This is an uneven fight," he said. There are lot of powerful people behind this."* Carol Jahnkow of the Peace Resource Center of San Diego: "It's a very sad commentary when regulatory agencies will allow transgressions to occur and will not speak out about them, to avoid scrutiny themselves."* Ray Lutz, Coordinator of Citizens' Oversight: "Either the regulations were insufficient and followed or sufficient but not followed, you can't have both. Our regulatory process must safeguard against radiation leaks, emergency shutdowns, and $670 million steam generators failing within months of installation.

To say that nothing is wrong takes the cake",* Gene Stone of ROSE stated -repeating a scenario described by nuclear industry expert Arnie Gundersen: "California Edison's plan to restart reactor number two is extremely risky. Any restart could result is a cascading blowout, one tube influencing the next, and may even progress to a meltdown"," California Senator Barbara Boxer called on Allison Macfarlane, the new head of the Federal Nuclear Regulatory Commission, to push for safety improvements at the nation's nuclear power plants, and specifically at San Onofre north of San Diego. At a meeting of the Senate Environment and Public Works Committee, Boxer urged the NRC to address safety concerns at San Onofre in an "open and transparent way." She said San Onofre's reactors must not be started until the NRC's investigation is complete and the results made public, and (10) Macfarlane told the Senate Environment and Public Works Committee today, "San Onofre's operator, Southern California Edison, has told the NRC it will send a letter by the end of the first week in October outlining the "root causes " of the problems with the steam generators.

She said it would take the NRC a matter of months rather than weeks to determine whether the root cause of the problems 17

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 are properly understood." Hoover Institution Press released The Nuclear Enterprise:

High-Consequence Accidents:

How to Enhance Safety and Minimize Risks in Nuclear Weapons and Reactors, a book edited by George P. Shultz and Sidney D. Drell in which contributors examine risks associated with the nuclear enterprise of weapons and power plant accidents.

This book emphasizes the importance of adopting essential safety and security measures so as to minimize these risks globally in view of the potentially devastating consequences of accidents in the nuclear enterprise.

The Nuclear Enterprise addresses three key issues: the need to improve the safety and security of nuclear operations; the importance of establishing and maintaining independent nuclear regulatory authorities and preventing their capture by government or industry interests; and how scientists, economists, and journalists can interact more effectively and communicate more clearly to raise public understanding of nuclear risks, consequences, and costs. The book is based on a conference on the risks and rewards of the nuclear enterprise held at Stanford University's Hoover Institution in October 2011. The conference included a panel of expert contributors who presented papers on technical safety, management operations, regulatory measures, and the importance of accurate communication by the media.From missing seismic devices to insufficient emergency back up systems, Europe's nuclear power plants face hundreds of problems requiring billions in new investment to bring them up to safety specifications, a leaked draft European Union report said.With 68 European reactors located in populated areas -reactors with more than 100,000 people living within 30 kilometers of them -"the EU must learn the lessons of Fukushima to further reduce the risk of nuclear incidents in Europe," the report says.The 25-page document was drafted with the participation of the 14 EU nations that operate nuclear power plants, as well as Lithuania, Switzerland, Ukraine and Croatia.The European stress tests simulated safety in case of floods, earthquakes and airplane crashes when "normal safety and cooling functions" are shut down. The report lamented that measures agreed after the accidents at Three Mile Island and Chernobyl are "still 18

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 pending in some member states', 'Following the accidents at Three Mile Island and Chernobyl, urgent measures to protect nuclear plants were agreed," continued the report."The stress tests demonstrated that even today, decades later, their implementation is still pending in some member states." Fairewinds Associate International Nuclear Expert Arnie Gundersen states, "Plugging tubes and operating at lower power (as Southern California Edison suggests) are not viable solutions." Arnie further states: o Vibration is the result not the root cause of the steam generators problems at San Onofre.o Plugging tubes cannot repair design changes that caused the tubes to collide with each other.o Reducing power does not provide a remedy for the underlying structural problems that are creating the vibration that has damaged and will continue to damage the tubes.o Reducing power will not change the pressure inside or outside the tubes -previously damaged tubes will continue to vibrate, damaging surrounding tubes and tube-supports and worsen the existing damage.o Lower power might create a resonate frequency at which vibration might increase without notice.o Historical evidence at other reactors has shown that operating at lower power has not been an effective solution.Professor Daniel Hirsch in his report to The US Senate Committee on Environment and Public Works Committee states, "The conclusion is clear: San Onofre Unit 2 and Unit 3 are both very ill nuclear plants. Unit 3'sfever is slightly higher, but both are in serious trouble. What they are experiencing is not just normal wear due to "settling in" 19

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 purportedly experienced with similar replacement steam generators.

They are far, far outside the norm of national experience.

And Unit 2 cannot be said to be acceptable for restart, any more than Unit 3. Unit 2 has hundreds of times more bad tubes and a thousand times more indications of wear on those tubes than the typical reactor in the country with a new steam generator, and nearly five times as many plugged tubes as the rest of the replacement steam generators, over a comparable operating period, in the country combined.

Restarting either San Onofre reactor with crippled steam generators that have not been repaired or replaced would be a questionable undertaking at best.International Nuclear Expert Dale Bridgenbaugh states, "San Onofre experience after only two or less years of operation with replacement steam generators lies far outside the bounds of normality when compared to the experience of other nuclear units with such replaced components.

Steam generators, and more specifically the tube boundaries, play a critical role in assuring plant safety and the containment of possible radioactive releases.

In spite of Edison's attempt to assert a different level of risk between Units 2 and 3, it seems clear that similar design and failure challenges are present in both units and that future operation of either unit has not been technically justified.

It is my opinion that measures necessary for the future safe operation of either of these unit have not been adequately put forth at this time, and that operation with or without reduced power of Unit 2 should not be authorized." An anonymous SONGS concerned insider Expert states, "San Onofre Nuclear Generating Station Units 2 & 3 should be decontaminated and decommissioned (dismantled) without delay because Southern Californians do not want to take the risk of a Fukushima Nuclear Disaster in their Backyard.

The aging and radiating San Onofre Units 2 & 3 should be replaced by new 4-500 MW Gas Fired/Solar Units and the existing Retaliatory SONGS Senior Leadership Team replaced with a New Team, which respects and not retaliates against workers for earning Performance Bonuses.Southern Californians do not want damaged San Onofre Replacement Steam Generators to be restarted for them to act as a Test "Laboratory for NRC/SCE/MHI to determine 20

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 the real root cause of tube damage. The restart approach to reduced power operations is unacceptable because, 'Many more damaged tubes in the steam generators due to steam voiding, Flowering Effects and other factors can break catastrophically and create a Southern California's Fukushima." Professor Daniel Hirsch stated in a Public Meeting in Oceanside, "SCE wants to run Unit 2 (Unit. 3 is planned to be defueled), so they can make some money and avoid an investigation by the CPUC of what went wrong." Hirsch told attendees that the repairs have been minimal and that Edison plans to restart one of the reactors soon "just to see what happens.'

'It is the kind of experiment where there are 8.5 million guinea pigs," he added.Another anonymous SONGS concerned insider Expert states, "It appears that NRC Region IV was sleeping on the wheel and the NRC AIT Report is just a repetition and rubber stamping of the SCE Units 2 & 3 Root Cause Evaluations." NRC region IV Officials have a history of being very lenient on the SCE Management for the chronic regulatory issues for years. These NRC Inspections have not resulted in any significant improvements in resolving the safety and retaliation concerns." 2. DAB Safety Team, "American Democratic Values and Southern California Edison's Irresponsible Behavior" America is a Model Democracy and a source of inspiration for Human Values, Labor Rights and Democratic Processes throughout the World. 20% Americans rely on Electric Utilities to provide safe, reliable and affordable nuclear power to enjoy the convenience and comforts of21st Century Technology.

Nuclear Safety, People's Life/Voice and Freedom of Press Prevails over the Wrong Decisions of Political Leaders, Misuse of Power of Government Institutions (NRC, CPCU) and Corporations Greed/Profits. Powerful and Rich Quasi-Public Institutions like EIX/SCE cannot compromise Nuclear Safety and silence People's Voice and Freedom of Press in America for making profits by operating Unsafe San Onofre Units 2 & 3. SCE cannot procure a license to operate a nuclear facility by patronizing the Political Leaders and providing 21

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 repeatedly misinformation to NRC and CPCU. EIX/SCE has to learn to act as a Responsible Corporate Leader by respecting People's Voice and Freedom of Press.Therefore, Southern California Edison needs to go the extra mile to re-establish public confidence and learn not to put pressure on News Editors and Reporters to suppress the facts about Edison's Grave Steam Generator Billion Dollar Mistakes and cover them-up (Watergate).

Edison has to remove the Irresponsible, inefficient and retaliatory Management, and improve the Chronic and Poor Safety Record, worst in the US Nuclear Fleet.After all, Nuclear power only makes sense if the plants are well maintained, effectively managed, produce safe and affordable power, and workers are treated with respect, if any of the above criteria is not met by SCE (See Attached Spreadsheet prepared by the DAB Safety team), then SONGS units 2 and 3 should be decontaminated, dismantled and decommissioned and replaced with small solar/gas fired plants installed throughout the Edison Grid.3. 10CFR Part 50, Section 50.59, Changes, Tests and Experiments.

According to Fairewinds Associates, "The requirements for the process by which nuclear power plant operators and licensees may make changes to their facilities and procedures as delineated in the safety analysis report and without prior NRC approval are limited by specific regulations detailed in The Nuclear Regulatory Commission's 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, Section 50.59, Changes, Tests and Experiments.

The implementing procedures for the 10 CFR 50.59 regulations have eight criteria that are important for nuclear power plant safety. These implementing procedures created for 10 CFR 50.59 require that the license be amended unless none of these eight criteria are triggered by any change made by Edison at San Onofre. If a single criterion is NOT met, then the regulation requires that the licensee pursue a license amendment process. By claiming that the steam generator replacements were a like-for-like design and fabrication, Edison avoided the more rigorous license amendment process. From the evidence reviewed, it appears that the NRC accepted Edison's statement and documents 22

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 without further independent analysis.

Fairewinds identified 39 separate safety issues that failed to meet the eight NRC 50.59 criteria.

Any one of these 39 separate safety issues should have triggered the license amendment review process by which the NRC would have been notified of the proposed significant design and fabrication changes. As the NRC guidelines state: (c)(1) A licensee may make changes in the facility as described in the final safety analysis report (as updated), make changes in the procedures as described in the final safety analysis report (as 1.187-A-1 updated), and conduct tests or experiments not described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to 10CFR 50.90 only if: (i) A change to the technical specifications incorporated in the license is not required, and (ii) The change, test, or experiment does not meet any of the criteria in paragraph (c)(2) of this section. In its previous reports, Fairewinds identified at least eight design modifications to the original steam generators at San Onofre. 7 out of 8 of these major design changes to the original steam generators failed to meet all the eight 50.59 criteria (shown in Attachment I Notes) and created a total of 39 safety issues requiring amendment to the license." 4. Background Information

• SONGS Unit 3 had been operating for approximately 1 year following the replacement of the new steam generators, when the control room operators received alarms on January 31, 2012, indicating that reactor coolant was leaking into one of the steam generators (3E088). The leak was unexpected, although small, had increased to approximately to 75 gallons per day and increased enough in a short period of time to warrant the precautionary shutdown of the Unit 3 reactor. The first indication of the leak was that the main condenser air ejector radiation monitors reached their alarm set-points.

This event caused a direct release of radioactivity to the atmosphere.

The radiological release resulted in an estimated 4.52 E-5 mrem dose to the public.* Southern Californians were very lucky this time, because a potentially serious nuclear accident in progress was stopped because of a high radiation reading on the main condenser air ejector radiation monitors, which happened to be maintained and in 23

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 working condition!

In March 2012, eight steam generator tubes in San Onofre Unit 3 Steam Generator E-088 had failed their pressure testing and therefore were plugged.According to NUREG-1841 and Fairewinds Report, San Onofre's eight plugged tubes are an anomaly for the entire operating history of US nuclear industry." NRC website just makes a casual note of the Unit 3 tube leak by stating, "The leak, although small, had increased enough in a short period of time to warrant the precautionary shutdown." If these non-safety related radiation monitors were Inoperable (e.g., out of service for repairs, needed spare parts, etc.) or the Operators had not performed the precautionary shutdown of the Unit 3 reactor, this unanticipated leak could have developed into one full tube rupture, eight full tube ruptures, or undetermined amount of tube ruptures, and potentially released significant amounts of radiation.

This unanticipated radiological release from the newest, safest, most efficient 21st century Steam Generator in the USA[The New 680 Million Dollar Steam Generator (SG) Replacements costs paid for by the Southern Californian Ratepayers]

could have potentially and adversely affected the health and safety of all Southern Californian residents plus the transient population within the 10-mile Emergency Planning Zone. DAB Safety Team concurs with International Nuclear Consultant Arine Gundersen, when he says, "A steam line break accident would have rendered the San Onofre emergency plan totally inadequate and an evacuation of a large portion of Southern California would have failed because there is no adequate evacuation plan in place." Approximately eight million people live within a 50-mile radius of the San Onofre Nuclear Plant. They will need to be evacuated if there is an emergency at the plant. The Nuclear Regulatory Commission (NRC) only requires a 10-mile evacuation zone and does not require a current safe emergency plan for San Onofre (NRC Reg. 50.47). Freeway on-ramps will be blocked, so only those within the 10-mile zone will be able to enter the freeways.

The NRC assumes the radiation plume will be diluted, so won't impact people beyond 10 miles of San Onofre. However, they assume a 50-mile contamination zone (e.g., ground and food contamination).

After the March 2011 nuclear disaster in Japan, Americans in Japan were told by the U.S.government to evacuate 50 miles from the Fukushima Daiichi nuclear power plant.AB Team does not believe that the San Onofre nuclear plant emergency plan would be 24

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 approved under Post Fukushima NRC safety regulations and standards.

According to information provided by the San Onofre Emergency Response Organization (ERO) concerned members from the SONGS Nuclear Oversight Emergency Preparedness Audit records, San Onofre Drills/Exercise Performance (DEP)for the last six years is consistently amongst the lowest (Nuclear Industry 4 th quartile DEP Performance) out of the 100+ operating reactors in the country. According to these records, out of the 4 emergency plan drills conducted between August 2011 and May 2012, 3 were rated as ADEQUATE and I was UNSATISFACTORY.

One of the Key Shift Managers recently resigned due to differences with the plant management and very senior and the most qualified Station Emergency Director disgusted with the unknown and controversial status of Unit 2 Restart is either planning to retire or has retired.Several Shift Managers have been consistently complaining for years about cumbersome and lengthy emergency plan implementing procedures.

The November 2011 ALERT and April 2012 Fire Notification of Unusual Event Emergency Declaration were considered over-conservative by some senior operations and nuclear regulatory assurance personnel and they attributed these non-conservative decisions to inadequate bench marking, incorrect interpretation of SONGS emergency plan technical decisions, faulty procedures and untimely/poor maintenance.

Data obtained by DAB Safety Team from nuclear industry operating experience and licensee event reports shows a list of nuclear plants (shown below), which have experienced major steam generator tube leakage events even with one tube rupture.The data shows the significance of what could have happened to Southern California, if the eight steam generator tubes in San Onofre Unit 3 Steam Generator E-088 had failed concurrently while Unit 3 was operating.

The data shown below contradicts NRC Website statement about SONGS Tube Leak and Staff correspondence dated May 20, 2009, which states, "By means of plant technical specifications, licensees are required to assure with high confidence that steam generator tubes have sufficient integrity to survive normal operations as well as possible design basis accidents, such as the rupture 25

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 of a main steam line outside of the containment boundary.'

'Current TS requirements relating to SG tube integrity provide reasonable assurance that all tubes will exhibit acceptable structural margins against burst or rupture under normal operating conditions and DBAs, including MSLB, and that leakage from one or multiple tubes under DBAs will be limited to very small amounts, consistent with the applicable regulations for offsite and control room dose (ref. ADAMS Accession Number ML091320055)." 1975 Point Beach 1 1976 Surry 2 1979 Prairie Island 1 Wisconsin 125 gal/min i Virginia 330 gal/min Minnesota 390 gal/min 1982 Ginna New York 630 gal/min 1987 North Anna 1 Virginia 600 gal/min North 1989 McGuire 1 Carolina 500 gal/min 1993 Palo Verde 2 Arizona 240 gal/min 2000 Indian Point 2 New York 90 gal/min At around 13: 50, on February 9th, 1991, leakage of about 55 tons of primary coolant occurred due to the failure of one SG tube in a steam generator built by Mitsubishi in the No. 2 pressurized water reactor at the Mihama nuclear power station in Japan. This Tube rupture caused the first INES level 3 nuclear incident in Japan, which raised social concerns.

This accident ignited social concerns in Japan because it shattered the industry myth of 100% safe nuclear reactors!

The International Nuclear Events Scale (INES)-A level one is a minor event, and the highest level is a level seven, which is a major nuclear accident, so the level number increases with the scale of the nuclear accident.For example, the loss of coolant that occurred in Three Mile Island was ranked a level five, while both Fukushima Daiichi and Chernobyl Nuclear Disasters were ranked level seven or major accidents.

• Based on the latest information provided by current SONGS concerned employees (Long Term Senior Project Managers and dissenting members of the Steam Generators 26

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 Root Cause Team), DAB Safety Team believes that the most likely potential reasons that Unit 2 suffered less damage than Unit 3. were minor operational and design differences, which are as follows: (I) Unit 2 was producing 3 MWe less than Unit 3, thereby steam velocities were lower in Unit 2 U-Tube bundle compared with Unit 3 U-Tube bundle, (2) Unit 2 operating steam pressures were 30 pounds lesser than Unit 3, therefore less localized steam voids in the Unit 2 U-Tube Bundle. Therefore, Unit 2 tubes were hitting each other with lesser force than Unit 3 tubes. Hence, Unit 2 Tubes suffered less tube-to tube wear than Unit 3 Tubes, and (3) In Unit 2 Steam Generator divider plate, no problems were reported during manufacturing, whereas problems were reported in Unit 3 d Steam Generator divider plate during manufacturing.

Additionally, based on a review of the AIT Report and information from SONGS insiders that less damage was found in the Unit 2 AVB structure, DAB Team believes that Unit 2 AVB Support Structure was manufactured slightly better than the Unit 3. Therefore, most likely, Unit 2 Tubes suffered less tube-to tube wear than Unit 3 Tubes. Therefore, compared with the NRC AIT Report conclusions shown below, reports from the SONGS concerned employees and plant data directly contradict the NRC AIT Findings.The result of the independent NRC thermal-hydraulic analysis indicated that differences in the actual operation between units and/or individual steam generators had an insignificant impact on the results and in fact, the team did not identify any changes in steam velocities or void fractions that could attribute to the differences in tube wear between the units or steam generators.

It should be noted that increases in primary temperature and steam generator pressures has the effect of reducing void fractions and peak steam velocities, which slightly decreases the conditions necessary for fluid elastic instability and fluid-induced vibration.

The NRC AIT Report States, "The team noted that Mitsubishi developed a specific plan to conduct the repair of the divider plate weld in both Unit 3 replacement steam generators." The NRC AIT report contradicts itself by stating, "The team did not identify any connection between the repairs of the divider plate and the unexpected tube-to-tube wear. The team concluded that the differences in severity of the tube-to-tube wear between Unit 2 and Unit 3 may be related to the 27

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 changes to the manufacturing/fabrication of the tubes and other components which may have resulted in increased clearance between the anti-vibration bars and the tubes" 5. San Onofre Steam Generators Debacle According to SONGS anonymous and concerned current managers, former employees and Press Reports, SCE did not fully disclose to the NRC of the numerous untested and unanalyzed design changes, which were made in a rush to generate more power in order to make Billions of Dollars in profit by replacing the SONGS Original CE Steam Generators with the SCE designed and MHI fabricated safest, most efficient 21 st century machinery (Source: SONGS Chief Nuclear Officer Pete Dietrich, Jan 10 2012, Marketwatch), "The installation is 'a major milestone in the station's history, said Ross Ridenoure, Southern California Edison senior vice president and chief nuclear officer. We're committed to making sure it's done right." [Source: January 28th, 2009, LA Times]." "Edison President John R. Fielder said new steam generators are cheaper for ratepayers than building new power plants or buying power on the open market. [Source: December 16th, 2005, LA Times]." "The new steam generators are designed to last longer, said Mike Wharton, manager of the steam-generator replacement project. 'They are designed for 40 years,' he said. 'We expect we'll actually be able to get 60 years out of them ... better materials, better design. You learn over the course of years what works well and what doesn't, and you try to build it into the next generation.'

[Source: December 24th, 2009, OC Register]."" Avoiding a thorough required NRC review, combined with the lack of Solid Teamwork& Alignment between SCE & MHI, and the lack of benchmarking on the design and fabrication details of Palo Verde and other CE Replacement Generators is probably either the Root Cause or a significant contributor to the 1.3 Billion Dollar San Onofre Replacement Steam Generator debacles.

A review of NUREG-1 841 and Palo Verde Uprate Application indicates that Westinghouse and Babcox & Wilcox International have designed more than 100 CE and other Replacement Steam Generators Anti-vibration bar and tube support plates to mitigate the adverse effects of high steam 28

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 velocities and flows, localized steam voids on the tube wear from the effects of turbulence-induced vibrations and fluid elastic instability both in the in-plane and out-of plane directions.

6. Flow-induced Vibrations

&Fluid Elastic Instability" The World's Foremost Renowned Professeur Titulaire, Michel J. Pettigre, Ecole Polytechnique de Montreal, on the subject of fluid elastic instability and turbulence-induced vibration states, "It is concluded that, although there are still areas of uncertainty, most flow-induced vibration problems can be avoided provided that nuclear components are properly analysed at the design stage and that the analyses are supported by adequate testing and development work when required.

There has been no case yet where vibration considerations have seriously constrained the designer."" One Masters Research Student R. Viollette states, "Fluid elastic instability is the most important vibration excitation mechanism for heat exchanger, or steam generator type of tube bundles. It is so because of the very high vibrations amplitude that it can induce to the tubes, which can lead to rapid failure by fatigue or wear. Also, unlike vibrations induced by vortex shedding (vortex-induced vibrations), fluid elastic instability is not a self-limiting phenomenon:

amplitude of vibrations does continue to increase with velocity past the critical onset of the instability.

• Based on a review of Industry Benchmarking and Operating Experience, DAB Team concludes, "To minimize the risk of a radiological accident and impact to public health and safety due to a potential radiological accident and radiation

/ contamination exposure requires some of the following attributes between the designer, manufacturer, installer, maintainer and the operator during the design, fabrication and operation of the nuclear steam generators components (not limited to): Solid teamwork and alignment, critical investigative and questioning attitude, flow of information in a timely and accurate manner, self-check, peer check, independent check, industry bench and vendor 29

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 marking, review of industry operating experience, NRC Reports, Information Notices, prudence, diligence and attention to detail, verification/validation mock-up test data, computer modeling accuracy and review of critical parameters.

The industry papers research indicate that the fluid elastic instability is a very complex problem and causes immense problems as witnessed in the SONGS RSGs, when the undesired effects of the flow fields have not been accounted and corrected in the design, manufacturing and testing. In many situations, however, after components are already in operation, modifications/repairs to correct the flow-induced vibrations resulting in fluid elastic instability are very pain staking, time consuming, extremely complex to diagnose/repair and immensely costly to the Utility and Ratepayers." 7. Insights into Potential Root Causes &Contributing Causes Due to self-imposed Time and Financial Greed, SCE selected the lowest cost manufacturer, which did not have the proven and tested technology to fabricate such large SONGS RSGs (623 Tons). The largest RSG manufactured by Mitsubishi Heavy Industries (MHI) was for EDF, France (316 tons) and CE RSG was for Fort Calhoun-1 (260 Tons). SCE and MHI bragged about the SCE/MHI Team Work, Challenges, Rewards and Innovations supporting the design and fabrication of the 21 st Century MHI Magnificent and Safest Machines.

The SCE Steam Generator Experts did not benchmark the steam generator tube accident in the Number 2 pressurized water reactor at the Mihama nuclear power station in Japan, which occurred on February 9th, 1991.The steam generator was built by MHI. As a result of the tube rupture, about 55 tons of primary cooling water leaked out from the SG tube into the secondary cooling loop.The scale of the accident was ranked "level 3" on the international nuclear events scale (INES).* According to the NRC AIT Report, "SCE Engineers did not specify the value of FEI and Stability Ratio in the Replacement steam Generator Design and Performance Specifications." Other Utilities show these values in Replacement Steam Generator 30

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 Power Uprate Applications.

SCE never updated their 2001 Power Uprate Application to show the revised values. Had they done that as late as in 2008, they would have found about the flawed Mitsubishi Thermal-Hydraulic Computer Codes. Based on information from several Insider Sources spanning for a few years, some of the SCE Engineers "On Official Business" were actually going sometimes to Japan with their families "just" to have a good time, for a shopping spree and shake hands with the MHI Engineers.

The result of the independent NRC thermal-hydraulic analysis indicated that differences in the actual operation between units and/or individual steam generators had an insignificant impact on the results and in fact, the team did not identify any changes in steam velocities or void fractions that could attribute to the differences in tube wear between the units or steam generators.

It should be noted that increases in primary temperature and steam generator pressures has the effect of reducing void fractions and peak steam velocities, which slightly decreases the conditions necessary for fluid elastic instability and fluid-induced vibration.

According to discussions with several SONGS Managers, part of the Steam Generator Recovery Project and Oversight Teams and review of the Plant Data Sheets, Unit 3 RSGs were operating at 30 psi lower than Unit 2 RSGs and Unit 3 RSGs were generating slightly more MWt than Unit 2 RSGs. This partially explains the fact why eight Alloy 690 thermally treated tubes in Unit 3 failed In-Situ Pressure Testing. According to NRC NUREG-1841, entitled U.S. Operating Experience with Thermally Treated Alloy 690 Steam Generator Tubes, the nuclear industry has had no instances in which Alloy 690, the thermally treated tube alloy used in the San Onofre replacement steam generators, lacked structural integrity and did not satisfy accident performance requirements.

SCE has plugged 3.7 times (in both units RSGs) as many steam generator tubes than the combined total of the entire number of plugged replacement steam generator tubes at all the other nuclear power plants in the US. 7.The NRC Report pages 33 and 34 states," The team determined that the licensee's evaluation for changes in the updated final safety analysis report's design methodologies for the replacement steam generators was 31

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 consistent with SONGS procedures for the implementation of 10 CFR 50.59 requirements.

The licensee's evaluation contained in Engineering Change Packages 800071702 and 800071703 for the Unit 2 and Unit 3 replacement steam generators, respectively, determined that the replacement of the original steam generators did not affect the current licensing basis to the extent of needing prior approval from the NRC as required by 10 CFR 50.59. The NRC AIT, NRR Specialist and SCE are making contradicting statements.

The NRR technical specialist (NRC Report pages 64 and 65)reviewed SCE's 10 CFR 50.59 evaluation and found two instances that failed to adequately address whether the change involved a departure of the method of valuation described in the updated final safety analysis report. The AlT is saying that SCE's 10 CFR 50.59 evaluation regarding the replacement of the original steam generators did not affect the current licensing basis to the extent of needing prior approval from the NRC as required by 10 CFR 50.59. SCE's is saying that Screening and 10 CFR 50.59 Evaluations for the replacement steam generators were inspected and reviewed by the NRC prior to the recent discovery of the tube wear issues with no findings with respect to 10 CFR 50.59." Any one of these two instances identified by the NRR technical specialist should have triggered the license amendment review process by which the NRC would have been notified of the proposed significant design and fabrication changes. Based on a review of the above evidence, it appears that the NRC accepted Edison's 10 CFR 50.59 Screening, Evaluations and supporting documents without due diligence, independent analysis and violating its own rules.8. DAB Safety Team Recommendations for Uncovering the Truth About San Onofre's Steam Generator Debacle There are more than 100 Replacement Steam Generators (RSGs) built by Westinghouse/

ABB in conjunction with fabricators from Europe and more than 100 Steam Generators built by Mitsubishi including Fort Calhoun, which are currently operating.

According to NUREG-1841 and Professor Daniel Hirsch's Paper published today, none of these generators have the severity of problems reported like the ones with San Onofre Replacement Steam Generators.

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1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 A confidential formal joint enquiry by the US Departments of Justice, Labor and the Committee on Environment and Public Works, Office of Nuclear Regulatory Research and Office of Nuclear Reactor Regulations to determine the REAL TRUTH about the dark inner secrets of the SONGS Steam Generator Degradation and Safety Concerns is recommended.

This investigation is of vital importance to ALL Americans and should also lead to improvements of the safety records at all the other US Nuclear Power Plants. Only an Expert Independent Steam Generator Panel aided by investigators from the Joint Commission can determine the Real Root Cause and find the Truth by examining the SONGS RSGs MHI Procurement/Technical Bid Evaluation, SONGS Performance and Design Specifications and all the QA, Design, Root Cause, Test Reports and interviewing under oath all the Responsible parties both from MHI and SCE. This investigation will help CPCU, NRC, NEI, [NPO and other US Agencies responsible for the protection of health and safety of Americans from potential radiological accidents, which can be caused by natural forces, human errors, equipment failures poor training, poor operating procedures and production/profit oriented management, etc. Here are some questions for the News Reporters, US Departments of Justice, Labor and the Committee on Environment and Public Works to determine the REAL TRUTH about the dark inner secrets of the SONGS Steam Generator Degradation:

1. According to some News Paper Comments and Industry Reports in 2004, the going price for each 620 Ton CE Replacement Steam Generator was estimated between 200-250 Million Dollars (Per Piece). How did SCE CNO/President in 2004 convince MHI to build such large complicated and premium generators for 569 million dollars, which is almost 230 million dollars short of the market price and funds approved by CPCU?2. Since MHI had experience building only CE Fort Calhoun Generator

(< 300 tons), how did the SCE Engineers Technically Qualify MHI?3. Which other utilities' QA Program, SCE took credit to approve Mitsubishi's quality assurance program, Fort Calhoun? French? Belgium? Japan?33

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 4. How come SCE did not apply to NRC for increasing the plugging limit for Old CE Generators, so this they would have had more time to think, research and not rush according to Michael Peevey?5. Which CE Replacement Generator US Utilities SCE benchmark to develop such detailed design and performance specifications or they just modified the Old Generator Specifications with New Industry Information?

Were the engineers, who wrote, checked and approved the specifications were steam generator experts or was it another steam generator expert in the background, who directed all the work?6. Where did all the claims of challenges, reward, innovations and teamwork between SCE and MHI go wrong?7. Were the SCE Engineers sent to Japan to check MHI work and approve documents/test results were qualified in that field, or they were just in the training/sight-seeing process?8. Who made the decision to make all these numerous design changes and determined the changes were "Like for Like" and did not need a Licensing Amendment Process?9. Which SCE Engineer furnished all these changes, information/documents to which NRC Engineer, who decided that it was OK to proceed without a Licensing Amendment Process?10. Which SCE engineer approved/validated the MHI Thermal-Hydraulic FIT-Ill FlVATS code Inputs and Calculations?

II. To get 10% heat transfer equivalent by switching from Alloy 600 To alloy 690, SCE needed to add 935 tubes, but they only added 377 tubes. What happened to the balance of 568 tubes? Were the length of 9727 tubes increased and by how much to make up for the 568 tubes?12. How come the SCE Engineers did not question the MHI benchmarking, verification and validation of the FIT-Ill thermal-hydraulic model?13. How come the SCE engineers did not contact their counter parts at PVNGS for information/advice, since PVNGS has the Largest CE Replacement Generators (800 Tons) in the world, were built in early 2001-2005 time frames and are running successfully?

34

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 14. Were the OLD CE Steam Generators and new replacement generators exact in Thermal Output (MWe) or were there minor differences?

• Mitsubishi has been qualified as a "US Nuclear Manufacturer/Designer" by NEI in 2009 and is trying to dominate the future US Nuclear Energy Market by very aggressively marketing their Advanced Pressurized Water Reactor (APWR) 1700 MWe design by claiming, " US APWR is more efficient with greater output than any previous power plant. This design has been slightly modified to satisfy U.S. and international utility requirements as the US-APWR, and it will become the design that we sell around the globe. The US-APWR satisfies our customers' requirements with the best performance for safety, economy, operation and maintenance." In a Mitsubishi Heavy Industries, Ltd. Technical Review Vol. 43 No. 4 (Dec. 2006), The company claimed, "On the basis of the manufacturing technology, quality control and process management cultivated for decades in PWR plants in Japan, MHI has organized a system for shipping and delivering high-quality reactor products to overseas customers within a short period, as requested.

In the export business, not only in terms of equipment quality but also through a quality assurance system for export, quality records conforming to local laws, regulations, and codes can be compiled and shipped together with products.

Quality record documents including design drawings, manufacturing procedures, and inspection records are highly evaluated by customers.

The know-how of exports of PWR plant components obtained so far will be fully fed back to the replacement work of equipment in overseas plants and the construction work of new plants, and MHI is determined to fulfill its duties as a leading PWR plant equipment company to contribute to the stable supply of electric power all around the world." Note: A joint-venture company has been established by the US Utility Luminant and Mitsubishi Heavy Industries (MHI). This purpose of this joint-venture is to support the construction of US-APWR at Comanche Peak in Texas. The companies' move 35

1. 1 US Nuclear Safety Concern -San Onofre's Dangerous Steam Generators (Technical Version)DAB Safety Team 4-2012 are in line with statements made in December 2008 when they submitted a combined construction and operating license application for the two new reactors they want to build at Comanche Peak. The 1700 MWe APWRs should begin operation before 2020. MHI has submitted application for Standard Design Certification for the U.S.Advanced Pressurized-Water Reactor (US-APWR), a 4,451 -MWt pressurized-water reactor (PWR) on December 31, 2007. The staff of the U.S. Nuclear Regulatory Commission (NRC) is currently performing a detailed review of that application.

The Final NRC Safety Evaluation Report (SER) is projected to be complete in 2015.As NRC Section Chief, of MIT Intelligence, said to his dedicated staff, "Before approving any Licensing Documents/Inspection Reports, Please, "Read and reread in-between the lines', use a 'Critical Questioning

& Investigative Attitude' and 'Solid Teamwork & Alignment' between NRC Staff, Licensee, Manufacturers and Vendors." This critical advice is consistent with the teaching of the World's Foremost Expert on preventing the adverse and expensive effects of Turbulence-induced vibrations and Fluid Elastic Instability in Nuclear Power Plant Components and their Heat Exchangers.

DISCILAIMER

& ACKNOWLEDGEMENTS This report represents the opinions of the DAB Safety Team Expert Panel. Anonymous SONGS Insiders and Industry Experts, who have chosen to remain anonymous, have assisted DAB Safety Team with research and information presented for this report, but are not responsible for its contents.

The DAB Safety Team has "Quoted Information" from the "Fairewinds Associates" and "Far Outside the Norm" Reports to emphasize the enormity and the severity of the safety problems associated with the SONGS Replacement Generators Degradation in the interest of the public. The DAB Safety Team is extremely thankful for the "Quoted Information" to Fairewinds Energy Education, Friends of the Earth, The Committee to Bridge the Gap (Professor Daniel Hirsch & Dorah Shuey) and MHB Associates (Retired Nuclear Engineer Dale Bridenbaugh).

Copyright October 04, 2012 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 Attorneys.

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1. 1 US NUCLEAR SAFETY CONCERN -SAN ONOFRE'S DANGEROUS STEAM GENERATORS DAB Safety Team -Attachment Updated 29-2012 Attachment 1 -Comparison ofSONGS Replacement Steam Generators Desien Parameters (RSrq) with Palo Verde Niclear Generating Station RSGs ls the Ohange Requires a Ad-en L.-neAwenderna Dewgn Parat-e SONGS CE OSG SONGS MHI RSG % Change Yes/No (Si Note 5) Yes/No Rated core Heat Output, MWt 1695 1719 ___Heat Output from Reactor Coolant Pumps, MWt 10 10 Thermal rating, MWt 1729 Yes (See Note 3 below)NomberofTube.

9350 9727 : (.4%) Yesn See Note 3 belw)Heat Transfer Aea, ft2 105,000 116,110 + 410.6%) Yes (SeeNote3below)

Thermal Conductivity 8to.in./ft2-.-'F

@ 600 *F Alloy 600 MA -133 Alloy 690 TF .1-22 J. 9.0%) Yes (See Note 3 below)UAA, Rtu/hr. o F 1.50E+00 1,49E+08 Yes lSee Note 3 bew_Tubes Outside Oiameten.

in. 0.75 0+71 Tube Wall Thicnes,.

n. 0+048 00429 _Tube Pith, in. 1.0

1.0 Triangular

Tube Pugging Mangin, % 8 8 PrimarylSide Operating Pressure, psia 2250 2250 -Operating Temperature (Thor), F 611.2 598 Operating Temrperature (Tcold), 'F 553 541 Reactor Coolant Flow (at cold leg tewperature), gpm 198,000 209,890 Yes lSee Note 3 below) N So Reacto Coolant Voluoe, ft3 1895 2003 Yes (See Note 3 below) YES NO Seorndary Side DIln Prsure, psia 1100 1100 Design Temperature, "F 560 560 __Operoting Pfressre (@100% power),psia 900 833 Operating Temperatr

(@@100% power) 532 523 .__.........

..Steam FRo, lb./hr 7.41E16 7.59E+06 Yes (See Note 3 below" YES NO 0.20 (See Note (See Note Steam Moisture Content 13) 0.10 (See Note 13) 13) YES TopensiTulon Top of the Tube Bundle, in. 381.0 389.2 381 389.2 Yes (See Notes 3 & 4 below) ____________

UpperShelOD, in.264.125 264.125 Lower Shell OD, in.Dry Weight, lb.Fluid Elastic Instability Stability Ratio Computer Codes 172.375 174.65 1+ 3+ %) I_________________________

+YES YES NO10 YES NO 1

1. 1 US NUCLEAR SAFETY CONCERN -SAN ONOFRE'S DANGEROUS STEAM GENERATORS DAB Safety Team -Attachment Updated 29-2012 Attachment 1 -Comparison of SONGS Replacement Steam Generators Dtesien Parameters (RSGq) with Palo Verde Nuclear Generating Station RSGo Adnea Licene Atmendmnent Did PVNGS Apply for lYes/No {See Note S) Yes/No License Amendment Design Parameters PVNGS 016 PONDS RSG I Change _ Yen/No Rated cone Heat Output, MWt _Heat Output ftrom Reactor Coolant Pumps, MWt Thermal rating. MWt 1900 195 (4.,8 -See Note 6) i Number of Tubes NA_ __10%"- See Note 6) _ _ _ YeS Yeo Heat Transfer Area, ft2 Thermal Conducaktty Btu-in./ft2-h-*F

@ 60 F Alloy 6 MA -133 Alloy 690TT-i- 122 _(-9,0%) es Y, UA, Btu/hr. o F Tubes Outside Diameter, in.Tube Wall Thickness, in N/A Tube Pitch, in. T Tube Plugging Margin, %1 primary Side Operating Pressure, Psia 2250 2250 Reactor outlet temp.. (Thot), -F 621,2 618.9 Reactor inlet temp., (Tcold), F 564.5 560.9 Total flowrate (nominal), Ibmt/hr 164,000.000

-19,820,0 _Rea-tr Coolant Volume, 53 Secondary Side Design pressure, psia 1270 1270 Design Temperature, "F 575 575 Steam pressure at full power, psia 1070 1039 Steam temp. at full power, *F 552.9 549.2 Steam flow at full power, Ibm/hr N/A 1.79E607 -Max. moisture at outlet, full load, % 0.25 10 -Dimtensions Top of the Tube gundle, in. 381.0 388.2 (See Note 6) r'_ y Upper Shell OD, in.Lower Shell 00, in.Dry Weight, Ibm Fluid Elastic Instability I Stabilit Rtio 038 ___Computer C;ode.i_ _ _ _ _ _ _ _ _ _ _ _ _ j._ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _2

1. 1 US NUCLEAR SAFETY CONCERN -SAN ONOFRE'S DANGEROUS STEAM GENERATORS DAB Safety Team -Attachment Updated 29-2012 Attachment I -Comparison of SONGS Replacement Steam Generators Design Parameters (RSGs) with Palo Verde Nuclear Generating Station RSGS The Information provided below was received by the DAB Safety Team from several anonymous concerned members from the SONGS Root Cause Team and other Plant Divisions 1. Replacement of the OSGs with the RSGs is a replacement in-kind in terms of form, fit, and function, and is designed to involve no, or only minimal changes.The RSGs are designed to perform the same design functions as those currently performed by the OSGs, and the differences do not affect their ability to perform these design functions.

3. The Old Generator, CE Model 3410 (Each Generator Rated at 1705 MWt) had 9350 Alloy 600MA Tubes.The new Alloy 690 TT has a 10% less transfer rate. Let us say, to achieve the same Thermal Output of 1729 MWt between the old and new generator, you need 10% more tubes, that is 9350 + 935 = 10285 tubes.But by removing the stay cylinder from the old generator, there was space only to add 377 tubes.So the new generator has a total of 9350 + 377 = 9727 Alloy 690 TT tubes. But you still need 935-377 = 558 Tubes.Since there is no room to add the additional 558 tubes, SCE told MHI to increase the length of each tube by 7.2 inches in the U-Tube Bundle to accommodate 10% more in the RSG (1729MWt).

These unanalyzed design changes (increasing the length of U-Tubes, Crowded Room for Steam to exit into Steam Drum resulted in over-pressurization, Flowering, Causing localized voids, in-plane tube-tube wear) potentially caused over-pressurization of the steam in the already compact U-Tube Bundle (Flowering).

Flowering was described by MHI as the elastic deformation of the anti-vibration bar structure and the tube bundle in the U-bend region, as a result of thermal expansion and fluid dynamic pressures acting on the secondary side of the tubes. The deformation caused by the 'flowering" effect was believed to result in multiple areas of no contact between the anti-vibration bars and the tubes, which minimized resistance to in-plane motion of the u-bend area of the tubes. The NRC inspection team concluded that SONGS Unit 3 steam generators had experienced excessive vibration of the tubes in the U-bend region of the steam generators to the extent that the tubes rubbed against each other (tube-to-tube interactions) causing excessive wear and loss of structural integrity.

SCE staff determined that the vibration was caused by the steam conditions in the U-bend region of the steam generators by a phenomenon called 'fluid elastic instability." The NRC inspection team further concluded that the steam generators' design and configuration did not provide the necessary margin to prevent this phenomenon.

4. The RSG heat transfer area is larger than the OSG area (116,100 ff2 vs. -105,000 ft2) and the RSG tube bundle is taller than the OSG bundle. The larger and taller RSG tube bundle offers an increased driving head for natural circulation flow, so that the RSGs will perform the same as, or better than, the OSGs during the events that credit natural circulation.

V.

-ruowtpit ~ro su~r lDJ I r[IC ralp verue PEU~lIea VUtler~irnB 3LdUUFlI1 Unllt t. ID/U UdHtISi. +/-a.IjjIt.L The number of tubes is increased by 10%. Primary and secondary water volumes are increased.

The RSG dry weight is increased.

The RSGs are taller, resulting in an increase to the main steam nozzle elevation.

3

1. 1 US NUCLEAR SAFETY CONCERN -SAN ONOFRE'S DANGEROUS STEAM GENERATORS DAB Safety Team -Attachment Updated 29-2012 Attachment 1 -Cnmnari.snn nfSONGS Replacement Steam Generators Design Parameters (RSG.) with Palo Verde Nuclear Generating Station R;Gs.q 4

1. 1 US NUCLEAR SAFETY CONCERN -SAN ONOFRE'S DANGEROUS STEAM GENERATORS DAB Safety Team -Attachment Updated 29-2012 ,f cnpjrD., m naion r (RP.t.fi -ith P.In Vordl N I.o.. 4-r.n H.tino qtnlinn R(qC..hm t j -rnm Acn& -.-M. ... ..4; V.U 0 (c)13. Changing the steam moisture content from <0.20 to < 0.10 increased the vapor fraction from 96% in the Original CE Steam Generator (OSGs) to > 99.6% in the Unit 3 Replacement Steam Generators (RSGs). This is the Root Cause for Fluid Elastic Instability and in-plane vibrations, which destroyed the Unit 3 RSGs. Based on the design of OSGs, RSGs were not designed for in-plane vibrations.

$580 Million Design Mistake Attributed to SCE, MHI, Inadequate Benchmarking, intentionally avoiding the Licensing Amendment Process by Edison and lax NRC Oversight.

5

1. 1 US NUCLEAR SAFETY CONCERN -SAN ONOFRE'S DANGEROUS STEAM GENERATORS DAB Safety Team -Attachment Updated 29-2012 Attachment I -Comnarisnn of SONGS Renlacement Steam Generators Desien Parameters fRSGs) with Palo Verde Nuclear Generatine Station RSQ;Table 1 -Steam Generator Design Changes Identified By Fairewinds Compared With The NRC's Like-For-Like Criteria SOURCE: SAN ONOFRE'S STEAM GENERATOR FAILURES COULD HAVE BEEN PREVENTED%Fairewinds Associates Tue, May 15, 2012 Client: Friends of the Earth 50:59 Criteria (A) (B) Remove stay Change tube Tube alloy Add Change tube Add flow Additional water Feed water cylinder sheet change tubes support restrictor volume distribution ring Yes i -Accident Frequency Increase Yes (1) Yes (1) No Yes (3,4,8) No No No____________________________

_________

_________(3,4)

_______ii -Increase in SSC Malfunction Yes Yes (1) Yes (1) No Yes (3,4,8) No No No occurrence

_____ ______(3,4)

_______Yes iii -Accident consequent increase Yes (1) Yes (1) No Yes (3,4,8) Yes (2) Yes (2,5,6) No iv -Increase in SSC consequence Yes Yes (1) Yes (1) No Yes (3,4,8) Yes (2) Yes (2,5,6) No of malfunction (3,4)v -Create unanalyzed accident Yes (1) Yes (1) No No No Yes (2) Yes (2,5,6) Yes (3,7,8)vi -Create new malfunction Yes (1) Yes (1) No No Yes (3.8) Yes (2) No Yes (3,7,8)vii -Alter fission product barrier Yes (1) Yes (1) No Yes (3) No No No No viii -Change design basis Yes (2) Yes (2) NO Yes (2) Yes (2,8) Yes (2) Yes (2,5,6) No evaluation method I Footnote Fairewinds Table 1 Footnotes A (2)0)(ii)(iii)(iv)The criteria listed in the left column in the table above refers to the criteria as laid out in the NRC Guidelines[5]

which states as follows: A licensee shall obtain a license amendment pursuant to § 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would: Result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the final safety analysis report (as updated);Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the final safety analysis report (as updated);Result in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated);Result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated);6

1. 1 US NUCLEAR SAFETY CONCERN -SAN ONOFRE'S DANGEROUS STEAM GENERATORS DAB Safety Team -Attachment Updated 29-2012 Attachment 1 -Comparison of SONGS Replacement Steam Generators Design Parameters (RSG') with Palo Verde Nuclear Generatine Station RSGs (v) Create a possibility for an accident of a different type than any previously evaluated in the final safety analysis report (as updated);(vi) Create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated);(vii) Result in a design basis limit for a fission product barrier as described in the FSAR (as updated) being exceeded or altered;or (viii) Result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses." B -The horizontal axis contains a list of design changes made by Edison and whether they meet or have not met the criteria as set out in 10 CFR 50.59.1 -The Steam Generator Replacement Project modified the tube sheets and stay cylinder that are a containment barrier-The NRC was not informed nor did it specifically approve these changes to the containment barrier as they were apparently not addressed under Edison's analysis for the 10 CFR 50.59 process;2 -The Mitsubishi thermo hydraulic code is inadequate to assess flow inside the Steam Generators that dramatically affect the ability to cool the nuclear reactor core in the event of an accident;3 -The Steam Generator Replacement Project increases the consequences of a steam line break accident;4 -The Steam Generator Replacement Project has already proven to increase the frequency of tube failure;5 -The Steam Generator Replacement Project changed the volume of primary coolant because more tubes were added, which changes the Final Safety Analysis Report;6 -The Steam Generator Replacement Project changed the flow rate of primary coolant, which changes the Final Safety Analysis Report;7 -The Steam Generator Replacement Project changed the potential for water hammer. Given that the Mitsubishi thermo hydraulic code is inadequate, the potential for water hammer is increased; 8 -The Steam Generator Replacement Project created steam binding at top of steam generator.

The steam generator is designed to remove heat in the event of an accident and its role has been compromised.

Copyright October 29, 2012 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 tie Written Permission of the DAB Safety Team Leader and/ or the DAB Safety Team's Attorneys.

7