ML13161A437
| ML13161A437 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/06/2013 |
| From: | Hawkins B Public Commenter |
| To: | Apostolakis G, Macfarlane A, Magwood W, Ostendorff W NRC/Chairman, NRC/OCM/GEA, NRC/OCM/WCO, NRC/OCM/WDM |
| Shared Package | |
| ML13161A438 | List: |
| References | |
| LTR-13-0506 | |
| Download: ML13161A437 (5) | |
Text
Joosten, Sandy From:
Sent:
To:
Subject:
Follow Up Flag:
Flag Status:
Bill Hawkins <billleel23456@gmail.com>
Thursday, June 06, 2013 2:38 PM CHAIRMAN Resource; CMRAPOSTOLAKIS Resource; CMRMAGWOOD Resource; CMROSTENDORFF Resource; Borchardt, Bill; Leeds, Eric; Hall, Randy; Benney, Brian; Lantz, Ryan; R4ALLEGATION Resource; Howell, Art; Dorman, Dan; Woollen, Mary San Onofre Replacement Steam Generators Billion Dollar Sad Saga Continued -
SCE/MHI/NRC/Public Awareness Series Follow up Flagged Former NRC Chairman says, "Edison's proposal to restart the San Onofre nuclear plant at 70 percent power for five months does not instill a lot of confidence in me and the process known as 10 CFR 50.59 was not meant for such a significant change of steam generators as occurred at San Onofre."
On top of that San Onofre is an IN PO 4 plant, with the worst management, maintenance, fire/industrial safety, discrimination, harassment, intimidation and nuclear safety concerns retaliation record. Unit 2 Restart at 70% power level is an unapproved experiment designed solely for SCE profits and sharpening the pencils of SCE Engineers. Public safety is of paramount importance and operation of a nuclear power plant is very serious business. San Onofre Emergency Plan is not proven to shelter and evacuate the transients, disabled residents, affected families and children within the 10 mile zone during rush traffic hours in the event of a Design Basis radiological accident. A nuclear fallout from San Onofre can shutdown completely the business at Los Angeles and Long Beach Harbors and chock the already fragile economy of Southern California. SCE Unit 2 Return Service and NRC AIT Reports are unambiguous, smoking mirrors, incomplete and inconclusive. SCE and other Independent Safety Experts do not agree amongst themselves with the conclusions and safety of these reports, Root Cause for Units 2 & 3 SG tube degradation and the scope of Unit 2, 170,000 incomplete and hastily conducted cheap tube inspections. SCE consultants have not addressed the synergic effects of tube-to-tube wear and internal incubating cracks caused by high cycle metal fatigue. MHI Repair and Replacement plans for Units 2 & 3, explanation of tube-to-A VB contact forces and Unit 2 Tube Plugging Screening Criteria are hideous, incomplete and unconvincing. Accidents caused by natural events, anticipated operational occurrences, inadvertent equipment manipulations and operator errors do not wait for the 5 month experimental period. These conclusions are consistent with DAB Safety Team, Arnie Gundersen, John Large, Dr.
Joram Hopenfeld, Professor Daniel Hirsch and Anonymous San Onofre Insiders assessments. Per the ASLB Ruling, a complete NRC review of SCE Submittals and thorough, satisfactory and convincing public hearings are required and the investigations by the US Justice Department, NRC Inspector General and Office of Investigations should be completed, before even a restart request is forwarded by NRC Staff to the ASLB and NRC Commission.
Preface: Researchers from Ecole Polytechnique de Montreal (Dr. Pettigrew), MIT, UCLA (Dr. Cotton, Dr. Dhir),
Korea, Pakistan and Dwight Nunn (Former SONGS Chief Nuclear Officer, who for unknown reasons was forced to l~ave in 2005) have been warning for the last 40 years about the adverse effects of high void fractions, fluid elastic instability, flow-induced random vibrations and poor circulation ratios in nuclear steam generators. The adverse 1
effects of these phenomena have lead to many steam generator costly shutdowns and tube rupture accidents. In accordance with 10CFR 50.59, 50.90 and US Federal Energy Regulations, the evolutionary steam generator designs such as San Onofre Replacement Steam Generators have to be properly coordinated between the designer, the manufacturers, NRC Staff and may be affected Public during the research, design, fabrication and testing stages to identify and correct the problems before installation, functional testing and operation of these generators. PWR Premium and Leading Manufacturers like Westinghouse have established extensive research, testing, design and development, computer modeling and benchmarking facilities to anticipate, analyze, foresee and correct these problems before they result in unacceptable economic and safety consequences.
San Onofre Replacement Steam Generators: The original San Onofre Combustion Engineering steam generators operated at a void fraction of-96% for 28 years and did not suffer fluid elastic instability. Based on internal San Onofre Steam Generator Investigation, started in March 2012 and continuing to date, it is concluded that due to the SCE Management Pressure to maximize the thermal performance and profits, SCE/MHI Engineers made numerous untested and unanalyzed design and operational changes (new design evolution in violation of 10CFR 50.59 and US Energy Standards GDC) in the replacement steam generators without preparing an adequate 10CFR 50.59 and not informing the NRC Commission of the full extent and effects of these changes. SCE controlled SCE/MHI AVB Team ignored Dwight Nunn's warning regarding high void fractions, refused to reduce high void fractions and inadvertently introduced very high fractions (fluid elastic instability) in San Onofre RSGs. SCE/MHI A VB Team appointed by Dwight Nunn acknowledged that the considered changes had unacceptable consequences and agreed not to reduce them by implementing an unproven and untested experimental A VB design. Had the SCE/MHI A VB Team used critical questioning & investigative attitude, performed adequate academic and industrial benchmarking and testing, they should have been able to foresee the disastrous consequences of this new evolutionary design as warned by Dwight Nunn and Dr. Pettigrew. Now SCE and MHI are both transitioning from the ignorance/profits/ ego frying pan into the public safety, credibility and economics fire. The only way to find out what the real truth is by Justice Department interviewing SCE/MHI Engineers under oath and subpoena all the records of A VB Joint Team and other files as recommended by the Honorable Senator Barbara Boxer and former San Onofre Steam Generator Investigator.
Former NRC Chairman: Gregory Jaczko, who chaired the Nuclear Regulatory Commission (NRC) from 2009 to 2012, said he has doubts about Edison's proposal to restart the San Onofre nuclear plant at 70 percent power for five months. "The approach does not instill a lot of confidence in me," he said Tuesday in San Diego. "It's a fairly novel idea to allow a plant to operate at a reduced power level because of a safety issue." He said the proposal raises doubts about the nuclear plant's operations. "When you're operating at a reduced power level, it indicates a lack of confidence," explained Jaczko. "It raises a lot of questions." He also said the process known as 10 CFR 50.59 (or "50.59" for short) which nuclear plants use to change similar equipment without a new license, was not meant for such a significant change of steam generators as occurred at San Onofre. It is believed the change in equipment led to a leack of radioactive steam, which caused the plant to be shuttered last year. He said the Fukushima Daiichi nuclear disaster in 2011 showed that scenarios previously thought to have very low probabilities can indeed happen.
And when they do, they can have a catastrophic impact on the environment, public safety and the economy. He said U.S. regulators no do not pay enough attention to the dire consequences of nuclear accidents. "When I was at NRC, there was resistance to looking significantly at these things," said Jaczko. "I think that's a mistake." Jackzo said most U.S. nuclear plants were designed so to 6o years ago and have antiquated safety measures. "As we look at the current fleet, many plants we have are aging," said Jaczko. "I think it's time we begin to reconsider prolonging the life of many of these reactors." J ackzo said when he was first told about Fukushima, his first concern was a Tsunami damaging the San Onofre or Diablo Canyon nuclear plants in California. Both of them are built near the Pacific 2
Ocean. While those fears did not come to pass under his tenure, what happened in Japan showed him that U.S. facilities should be equipped to deal with what happened at Fukushima. "Not all plants are required to deal with all accidents," he said. "If nuclear is going to be used, I think we have to make rules such that there will never be an evacuation." Jackzo said he tried putting a halt to new nuclear licenses in the U.S. after Fukushima, but he met resistance from fellow members of the NRC.
3
CHAIRMAN Resource From:
Sent:
To:
Subject:
Bill Hawkins <billlee123456@gmail.com>
Thursday, June 06, 2013 8:05 PM CHAIRMAN Resource; CMRAPOSTOLAKIS Resource; CMRMAGWOOD Resource; CMROSTENDORFF Resource; Benney, Brian; Borchardt, Bill; Leeds, Eric; Hall, Randy; Lantz, Ryan; R4ALLEGA TION Resource; Dorman, Dan; Howell, Art; Woollen, Mary San Onofre Sad Saga Continued-SCE/MHI/NRC/Southern Californians Education Series Th~i&tdlf.fortbe Dayou*IJa,neeFs.ofSan 0"no,fre::IJ:.Jt:it *2. Re.start E:tperim1e11t AREVA states, "Out-of-plane fluid-elastic instability has been observed in nuclear steam generators in the past and has led to tube bursts at normal operating conditions.
Given identical designs, Unit 2 must be judged, a priori, as susceptible to the same TTW degradation mechanism as Unit 3 where 8 tubes failed structural integrity requirements after 11 months of operation. Based on the extremely comprehensive evaluation of both Units, supplemented by thermal hydraulic and FIV analysis, assuming, a priori, that TTW via in-plane fluid-elastic instability cannot develop in Unit 2 would be inappropriate. The nominal distance between extrados and intrados locations of neighboring U-bends in the same plane ranges from 0.25 inches to 0.325 inches due to the tube indexing. There are 36 U-bends in Unit 2 SG E-088 and 34 in SG E-089 with a separation less than or equal to 0.050 inches. "
The circulation ratio of the replacement steam generator secondary-side fluid (ratio of riser mass flow-rate to steam outlet mass flow rate) at 70o/o power is-4.9. A higher circulation ratio limits concerns regarding heat transfer performance, generator sludge management, corrosion product transfer, and tube dry-out.
Based on recent Mitsubishi Testing conducted in Japan, tube-to-A VB contact force more than 30N is required to counteract the adverse effects of in-plane fluid-elastic instability. Unit 2 AVBs only have 2N contact force, which cannot stop tube-to-tube wear and tube burst at 70% Unit 2 normal power operations, if in-plane and out-of-plane fluid-elastic instability develops due to abnormal operation occurrences, main steam line breaks, inadvertent equipment errors and other plant transients.
Let us assume, hope and pray for the benefit of 8.4 Million Southern Californians, I PC, State of California, CPUC, MHI, SCE and NRC, the probability of occurrence of these events is very low and nothing happens. But as stated above, there are 36 U-bends in Unit 2 SG E-088 and 34 in SG E-089 with a separation less than or equal to 0.050 inches. The problem lies that in these U-bends, even at 70% power and a circulation ratio of 4.9, localized areas with very poor circulation ratio and no flow zones (Flow areas blocked by SG debris and corrosion products) can develop 1
resulting in very high void fractions. With no tube damping and insufficient contact forces, in-plane fluid-elastic instability and out-of-plane vibrations can develop, as we witnessed in Unit 3. Just like Unit 3, now, the tubes will start moving in the in-plane direction and hit other worn and plugged/stabilized tubes with low clearances and cause tube-to-tube wear. Also, the tubes in other non in-plane FEI areas will also start moving in the out-of-plane direction, hitting already damaged AVBs with sharp corners (Zero Radius) resulting in the existing incubating cracks in the tubes to grow at a undefined rate.
Now the tubes are wearing and cracks are growing without the knowledge of the operator, because there is no instrumentation installed in the SGs as a part of the NRC Confirmatory Letter to warn/alarm the operator, as to what is going on about this kind of event. This event can occur at any time and propagate during the Unit 2, 5-month experiment window. Now, one, two or more than 5 tubes can potentially leak and/or rupture and the operator gets sudden warning/alarms through existing radiation monitors and proposed temporary N-16 detectors located on the main steam lines.
Shift Manager has only 15 minutes to diagnose, trouble shoot, declare the event and notify the Offsite Agencies for activation of the SONGS Emergency Plan. Before, Shift Manager can call for additional help, activate TSC, OSC, EOF, JIC or start taking actions to mitigate the consequences of a nuclear accident in progress, the reactor trips, turbine trips, main steam lines over pressurizes due to sudden turbine load rejection. The main steam lines atmospheric valves and/or main steam line relief valves will instantaneously open to prevent the main steam line from over pressurization and start dumping the un-partitioned radioactive coolant containing iodine with steam into the environment. In less than 15 minutes, 60 tons of radioactive coolant contained in the faulty and un-isolatable steam generator, will leak to the environment, melt the fuel in the reactor and release offsite doses in excess of Control Room limit of 5 Rem TEDE, and the Exclusion Area Boundary and Low Population Zone limit of 2.5 Rem TEDE.
Based on the NRC Studies, Independent Safety Experts Observations and observation of SONGS Emergency Plan Drills, San Onofre Emergency Plan is not proven to notify, shelter (Plus Kl Tablets) and evacuate the transients, disabled residents, affected families and children within the 10 mile zone during rush traffic hours in the event of above described a sudden large early frequency release radiological accident. A nuclear fallout from San Onofre can shutdown completely the business at Los Angeles and Long Beach Harbors and chock the already fragile economy of Southern California.
2