ML13016A086

Fairwinds Presentation for 1/16/13 Meeting with Friends of the Earth to Provide an Opportunity to Address the NRC PRB, Pursuant to 10 CFR 2.206 (TAC Nos. MF0060 & MF0060)

ML13016A086
Person / Time
Site:	San Onofre
Issue date:	01/16/2013
From:	Fairewinds Associates
To:	Plant Licensing Branch IV, Friends of the Earth
Benney B
Shared Package
ML13016A077	List: ML13016A082 ML13016A086 ML13016A092
References
G20120891, TAC MF0060, TAC MF0061
Download: ML13016A086 (39)

Text

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2.206 PRESENTATION San Onofre Units 2 and 3 Replacement Steam Generators MEETING WITH PETITIONER FRIENDS OF THE EARTH, REQUESTING ENFORCEMENT ACTION AGAINST SOUTHERN CALIFORNIA EDISON UNDER 10 CFR 2.206 January 16, 2013 Presented For Friends of the Earth By Fairewinds Associates Inc, Burlington VT Based Upon Non-Proprietary Information

Sequence of Presentation SECTION 1: Chronology of Events SECTION 2: Magnitude of Design Changes SECTION 3: Conclusions 3

SECTION 1 CHRONOLOGY OF EVENTS 4

Prior To Analysis And Design Of RSGs, Edison Applied To CPUC For RSG Permits According to Southern California Edisons 2004 Annual Report, its application for its Unit 2 and 3 Replacement Steam Generators was filed with the State of Californias PUC on February 27, 2004, which was prior to the contract with MHI on September 30, 2004.

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In 2004 Edison Contract Language Directed MHI That CFR§50.59 Would Not Apply An Edison Whistleblower released the San Onofre Design Specification for RSG. This specification required that CFR§50.59 would not apply to the San Onofre RSGs even though an analysis had not yet been completed.

EXCERPTS FROM SONGS Replacement Steam Generator Design & Performance Specifications SO23-617-1 Originator - James Chan IRE - Jun Gaor FLS - David Calhoun SLS - Craig Herberts PE Tom Pierno NO& A Bill Kotekkaskos 6

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San Onofre Design Specification For RSG #1 3.6.1.1 Edison intends to replace the steam generators under the 10 CFR 50.59 rule.

3.6.1.2 the Supplier shall guarantee in writing that the RSG design is licensable and provide all support necessary to achieve that end.

3.6.1.3 Any deviations from these requirements shall require Edisons approval.

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San Onofre Design Specification For RSG #2 3.6.2 Licensing Topical Report:

The Supplier shall prepare and submit for Edisons approval a Licensing Topical Report demonstrating compliance of the RSG design with all SONGS licensing requirements. The report shall include an engineering evaluation, including all necessary analyses and evaluations, justifying that the RSGs can be replaced under the provisions of 10 CFR 50.59 (without prior NRC approval). The 10 CFR 50.59 evaluation shall be performed by Edison.

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Edison Official Notification To NRC June 2006 Edison Notified NRC of 50.59 Decision in June 2006 A meeting was held on Wednesday, June 7, 2006, between the Nuclear Regulatory Commission (NRC) staff and the SCE, the licensee for SONGS 2 and 3. The meeting was held at the request of the licensee to provide to the NRC staff an overview of the various aspects of its steam generator (SG) replacement project.

(ML061670140)

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JUNE 2006 Edison Presentation to NRC 11

2006 NRC Informed of Improvements 12

2006 Edison Accepts Responsibility 13

Mitsubishi Heavy Industries Was Constrained By The Contract Between the contract award in 2004 and NRC kickoff meeting in 2006, Mitsubishi Heavy Industries had to force fit the RSG analysis and design in order to support Edisons earlier decision determining that 10CFR§50.59 did not apply.

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The 10CFR§50.59 Process In its January 9, 2013 Response

• Fairewinds agrees with Edison to the NRC, Edison said that this is the correct approach, and it should have "As discussed in Section 1.3 of been implemented.

NEI 96-07, changes are

• However, this approach was evaluated under 10 CFR 50.59 not applied during the RSG using a multi-step process. First, Project. Rather this "multistep a licensee must determine that process" was thwarted by a proposed change is safe Edison.

and effective through

• No appropriate engineering appropriate engineering and and technical evaluation technical evaluations. Page 5 was performed by Edison when the contractual decision was made that 10CFR§50.59 would not apply.

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Standard Technical Specifications License Amendment 2009: During the San Onofre Standard Technical Specification License Amendment, Edison identified many areas where the San Onofre Replacement Steam Generator was dramatically different than the Original Steam Generator.

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San Onofre RSGs Were Not Like-For-Like 17

Edison Identified Numerous San Onofre Design Changes 2011 Edison and MHI Report tout all the design changes implemented in the San Onofre RSG:

• Remove Stay Cylinder

• Add 377 Tubes

• Change Tube Support Structure

• Add New Anti-Vibration Bars

• Dozens More Changes 18

SECTION 2 MAGNITUDE OF DESIGN CHANGES 19

In and of themselves, Edisons design changes to the Replacement Steam Generators should have triggered the 10CFR§50.59 process.

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• The San Onofre tubes and tube sheets are part of the containment boundary and are safety related.

• San Onofre claimed to the NRC that new improved anti-vibration bars would reduce wear on these important components and would not adversely impact their design function.

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h1p://www.fairewinds.com/content/san-onofres-steam-generator-failures-could-have-been-prevented 22

Mitsubishi Heavy Industries Should Not Be The Scapegoat If the RSGs had been designed and manufactured in accordance with the procurement specification, the leak and tube wear would never had occurred. Page 12, 1/9/13 Edison Letter to NRC

• The replacement steam generator design developed by Mitsubishi in accordance with the licensees design specification was translated into the same set of design and fabrication drawings. AIT Report, Page 27

• No matter who fabricated the RSGs for San Onofre, the tube damage would have occurred. The root cause of this problem was the design, not the fabrication.

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Edison 2003 Annual Report:

San Onofre Identical To Palo Verde Palo Verde Steam Generators The steam generators at the Palo Verde Nuclear Generating Station (Palo Verde), in which SCE owns a 15.8% interest, have the same design and material properties as the San Onofre units. During 2003, the Palo Verde Unit 2 steam generators were replaced.

(Edison 2003 Annual Report, Page 21) h1p://www.edison.com/images/cms_images/c6452_2003_annual_eix_5543.pdf

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Stay Cylinder: Retained On Palo Verde And Eliminated On San Onofre 25

Egg Crate Design Retained On Palo Verde/

Eliminated On San Onofre BROACHED TUBE SUPPORT EGG CRATE TUBE SUPPORT 26

San Onofre Problem Was Foreseeable

• Stay Cylinder removal and Tube addition placed too much heat in the center of San Onofres Replacement Steam Generators

• San Onofre added 4% more tubes at the center of its RSGs

• Palo Verde added 10% to the periphery and added 2.9% more heat

• Palo Verde has no FEI problems

• Edisons Design destroyed San Onofres RSGs 27

Contour Of Steam Quality Condition Report: 201836127, Revision 0, 5/7/2012, Figure 2: Contour of steam quality at the height of the maximum quality in U-bend region for T-hot = 598"F (Figure 8.1-2 (a) in Reference [2]), Page 74.

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What Did The 10CFR§50.59 Review Say?

Edison is parsing its words!

• At the time the RSGs were

• Removing the stay cylinder designed, MHI evaluated the allowed 377 extra tubes flow patterns and into the center void, determined that fluid elastic creating more interior heat instability (FEI) would not

• The riser column water void occur. 1/9/13 Edison brief to above the tube sheet was NRC, page 14 also eliminated

• There was nothing on the

• MHI provided a thermal- steam side to facilitate and hydraulic analysis as part of bias the flow direction. The the original design of the steam side flow patterns RSGs that showed there were never established.

would be no FEI. page 17

• The 10CFR§50.59 analysis should identify high void fractions and confused in/

out-of-plane FEI.

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Friends Of The Earth Consultants Reached A Different 10CFR§50.59 Conclusion

" design changes may be

• Fairewinds agrees with this screened out under 10 CFR approach, but it is not the 50.59 if the changes do not approach used by Edison at adversely affect a design San Onofre.

function Page 9, Edison

• The totality of RSG changes Response, 1/9/13 Edison proposed in 2004 created an unacceptable void "The adverse condition that fraction at the top of the hot later resulted in the tube leak side of the tubes that then was a deficiency associated created the FEI.

with the design and was not

• Fairewinds and John Large both known at the time the 50.59 agree that it should have been evaluation was performed. foreseeable to Edison in 2004 Page 9, Edison Response, that this combination of 1/9/13 changes would cause FEI to occur.

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Edisons Cause Report Was Wrong

• Former NRC Chairman Gregory Jaczko promised Senator Boxer and the public a complete Root Cause Analysis. This has not been conducted.

• Kepner Tregoe Cause Analysis is severely flawed.

• If they can get you asking the wrong questions, they don't have to worry about answers. Thomas Pynchon, Gravitys Rainbow

• Statement upon which Edison based its Cause Report:

What is different or has changed when comparing SONGS Replacement SGs to Another US plants Replacement SG (page 43, Condition Report) 31

What Root Cause Question Should Edison Have Asked?

There are no changes to compare among Edisons RSG and other RSGs nationwide. Its an apples and oranges comparison.

The changes Edison should have analyzed and compared are those between the OSG and the RSG or between San Onofre and Palo Verde, since Edison has acknowledged that Palo Verdes RSG is identical to San Onofres OSG.

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Exclusions From Edisons Kepner Tregoe (KT) Analysis Process Extracted from the Edison Kepner Tregoe Exclusion Table: Condition Report: 201836127, Revision 0, 5/7/2012, Root Cause Evaluation: Unit 3 Steam Generator Tube Leak and Tube-to-Tube Wear, San Onofre Nuclear Generating Station, Page 52 33

SECTION 3 CONCLUSIONS 34

THE CHANGES EDISON MADE CREATED FORESEEABLE PROBLEMS During the past eight years, the NRC had extensive evidence from multiple sources that the replacement steam generators at San Onofre were not the like-for-like replacements for the original designs, as Edison committed during the 10CFR50.59 processes. And, as demonstrated by the significant damage in the San Onofre Replacement Steam Generators, the design changes did have a significant impact upon key design functions and in fact degraded the containment boundary.

Edison should have notified the NRC that the significance of all the changes required a 10CFR50.59 license amendment.

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San Onofre Was A Near Miss The tube failures at San Onofre are the worst nuclear equipment failures since the near miss at Davis Bessie in 2002.

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San Onofre Technical Specifications San Onofre Technical Specifications states that the limiting design basis accident is a "double ended rupture of a single tube.

Page 510 37

Edisons San Onofre:

Operating Outside Design Basis Eight Tubes failed their pressure test, not one!

The evidence shows that San Onofre was operating outside of its design basis and the NRC has done nothing to address this major violation.

Although in this case the degraded condition of the tubes was manifested as a small primary to secondary leak, it is possible that a full-blown rupture could have been the first indication. Page 57, NRC AIT Report 38

Arnie Gundersen, Chief Engineer Fairewinds Associates, Inc Nuclear Engineering, Safety, and Reliability Expert 42-years of nuclear industry experience and oversight ME NE Master of Engineering Nuclear Engineering Rensselaer Polytechnic Institute, 1972 U.S. Atomic Energy Commission Fellowship Thesis: Cooling Tower Plume Rise BS NE Bachelor of Science Nuclear Engineering Rensselaer Polytechnic Institute, 1971, Cum Laude James J. Kerrigan Scholar RO Licensed Reactor Operator U.S. Atomic Energy Commission License # OP-3014 39