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| number = ML13016A092
| number = ML13016A092
| issue date = 01/16/2013
| issue date = 01/16/2013
| title = G20120891, Friends of the Earth Presentation for 1/16/13 Meeting with to Provide an Opportunity to Address the NRC PRB, Pursuant to 10 CFR 2.206.(TAC Nos. MF0060 and MF0061)
| title = G20120891, Friends of the Earth Presentation for 1/16/13 Meeting with to Provide an Opportunity to Address the NRC PRB, Pursuant to 10 CFR 2.206.
| author name =  
| author name =  
| author affiliation = Fairewinds Associates, Inc
| author affiliation = Fairewinds Associates, Inc
Line 19: Line 19:


=Text=
=Text=
{{#Wiki_filter:1 2.206 PRESENTATIONSanOnofreUnits2and3 San Onofre Units 2 and 3Replacement Steam GeneratorsMEETING WITH PETITIONER FRIENDS OF THE EARTH, REQUESTING ENFORCEMENT ACTION AGAINST SOUTHERN CALIFORNIA EDISONUNDER10CFR2206 EDISON UNDER 10 CFR 2.206January 16, 2013Presented For Friends of the Earth By Fairewinds Associates Inc, Burlington VTBased Upon Non-Proprietary Information Sequence of PresentationSECTION1:ChronologyofEvents SECTION 1: Chronology of Events SECTION 2:
{{#Wiki_filter:1 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 2 206 January 16, 2013 Presented For Friends of the Earth By Fairewinds Associates Inc, Burlington VT Based Upon Non-Proprietary Information
Magnitude of Design Changes SECTION 3:
Conclusions 3
SECTION 1  CHRONOLOGY OF EVENTS 4
Prior To Analysis And Design Of RSGs, EdiAlidTCPUC Edi son A pp li e d T o CPUC For RSG PermitsAccording to Southern California Edison
's 2004 Annual Report, its application for its Unit 2 and 3  Replacement Steam Generators was filed with the


State of California
Sequence of Presentation SECTION 1: Chronology of Events SECTION 2: Magnitude of Design Changes SECTION 3: Conclusions 3
's PUC on February 27, 2004, which was prior to the contract with MHI on September 30, 2004.5 In 2004 Edison Contract LanguageDirectedMHIThatCFR
§5059 Directed MHI That CFR§50.59 Would Not ApplyAn Edison Whistleblower released the San Onofre Design Specification for RSG. This specification required that CFR
§50.59 would not apply to the San Onofre RSG
's even though an analysis had not yet been completed. EXCERPTS FROM SONGS Re p lacement Steam Generato r pDesign & Performance Specifications  SO23-617-1Originator -James ChanIRE -Jun GaorFLS -David Calhoun


SLS -Crai g Herberts 6 gPE Tom PiernoNO& A Bill Kotekkaskos 7
SECTION 1 CHRONOLOGY OF EVENTS 4
San Onofre DiSifitiFRSG#1 D es i gn S pec ifi ca ti on F or RSG #1 3.6.1.1 "Edison intends to replace the steam generators under th10CFR5059l" th e 10 CFR 50.59 ru l e."  3.6.1.2 "theSuppliershallguaranteeinwritingthattheRSG
-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 Edison'sapproval"Edison s approval.8 San Onofre DiSifitiFRSG#2 D es i gn S pec ifi ca ti on F or RSG  #2 362LicensingTopicalReport:
3.6.2 Licensing Topical Report:  "The Supplier shall prepare and submit for Edison
's approval a LicensingTopicalReportdemonstratingcomplianceofthe 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."
9 Edison Official Notification TNRCJ2006 T o NRC J une 2006 EdiNtifidNRCf5059DiiiJ2006 Edi son N o tifi e d NRC o f 50.59 D ec i s i on i n J une 2006"AmeetingwasheldonWednesdayJune72006 A meeting was held on Wednesday , June 7 , 2006 , between the Nuclear Regulatory Commission (NRC) staff andtheSCE,thelicenseeforSONGS2and3.Themeeting 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) 10 JUNE 2006 Edison Presentation to NRC 11 2006 NRC Informed of "Improvements "12 2006 Edison Accepts Responsibility 13 Mitsubishi Heav y Industries Was yConstrained By The ContractBetween the contract award in 2004 and NRC kickoffmeetingin2006,MitsubishiHeavy kickoff meeting in 2006, Mitsubishi Heavy Industries had to force fit the RSG analysis and designinordertosupportEdison
'searlier design in order to support Edison's earlier decision determining that 10CFR
§50.59 did not apply.14 The 10CFR§50.59 ProcessIn its January 9, 2013 Response totheNRCEdisonsaid
*Fairewinds agrees with Edison thatthisisthecorrect to the NRC , Edison said "As discussed in Section 1.3 of that this is the correct approach, and it should have


been implemented.
Prior To Analysis And Design Of RSGs, Edi Edison    Applied A li d To T 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.
*Howeverthisapproachwas However , this approach was not applied during the RSG
5


Project. Rather this "multistep process" was thwarted b y py Edison. *No "appropriate engineering and technical evaluation "was performed by Edison when the contractual decision was made that 10CFR
In 2004 Edison Contract Language Directed MHI That CFR§50.59            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.
§50.59 would not apply.
EXCERPTS FROM SONGS Replacementp        Steam Generator Design & Performance Specifications SO23-617-1 Originator - James Chan IRE - Jun Gaor FLS - David Calhoun SLS - Craig g Herberts PE Tom Pierno NO& A Bill Kotekkaskos 6
15 StandardTechnicalSpecifications Standard Technical Specifications License Amendment2009:DuringtheSanOnofreStandardTechnical 2009:  During the San Onofre Standard Technical Specification License Amendment, Edison identifiedmanareasheretheSanOnofre identified man y areas w here the San Onofre Replacement Steam Generator was dramatically different than the Original Steam Generator.
16 San Onofre RSG
'sWereNot Like-For-Like Were Not Like-For-Like 17 Edison Identified Numerous San Onofre Design Changes2011 Edison and MHI Report tout all the design chan g es im p lemented in the San Onofre RSG:
*Remove Stay Cylinder gp*Add 377 Tubes
*Change Tube Support Structure
*Add New Anti-Vibration Bars
*DozensMoreChanges
*Dozens More Changes-18 SECTION 2  MAGNITUDE OF DESIGN CHANGES 19 In and of themselves, Edison's design changes to the Replacement Steam Generators shouldhavetriggered should have triggered the 10CFR§50.59 process.
20
*The San Onofre tubes and tube sheets are part of the containment boundary and are safety related.
*San Onofre claimed to the NRC that newimproved anti-vibrationbars new improved anti-vibration bars would reduce wear on these importantcomponentsandwouldnot important components and would not adversely impact their design function.
21 http://www.fairewinds.com/content/san-onofre
's-steam-generator-failures-could-have-been-prevented 22 Mitsubishi Heavy Industries Should Not Be The Scapegoat "If th e R SGs h ad bee n des i g n ed a n d m a n u f ac t u r ed in eSGsadbeedesgedadauacuedaccordance with the procurement specification, the leak and tube wear would never had occurred."Page 12, 1/9/13 EdisonLettertoNRC Edison Letter to NRC*The replacement steam generator design developed by Mitsubishi-inaccordancewiththelicensee
'sdesign Mitsubishi
- in accordance with the licensee s design specification was translated into the same set of design and fabrication drawings. AIT Report, Page 27
*No matter who fabricated the RSG
's for San Onofre, the tube damage would have occurred. The root causeofthisproblemwasthedesignnotthe 23 cause of this problem was the design , not the fabrication.
Edison2003AnnualReport:
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 158%itththdid a 15.8% i n t eres t , h ave th e same d es i gn an d material properties as the San Onofre units. During 2003, the Palo Verde Unit 2 steam g enerators were g replaced."(Edison 2003 Annual Report, Page 21
)http://www.edison.com/images/cms_images/c6452_2003_annual_eix_5543.pdf 24 Stay Cylinder: Retained On Palo Verde And Eliminated On San Onofre 25 EggCrateDesignRetainedOnPaloVerde/
Egg Crate Design Retained On Palo Verde/ Eliminated On San Onofre BROACHED TUBE SUPPORTEGG CRATE TUBE SUPPORT 26 SanOnofreProblemWasForeseeable San Onofre Problem Was Foreseeable
*Stay Cylinder removal and Tube addition ldhhihfS p l ace d too muc h h eat i n t h e center o f S an Onofre's Replacement Steam Generators
*SanOnofreadded4%moretubesatthe
*Palo Verde added 10% to the periphery and
*San Onofre added 4% more tubes at the center of its RSGsadded 2.9% more heat
*Palo Verde has no FEI p roblems p*Edison's Design destroyed San Onofre's RSGs 27 Contour Of Steam QualityCondition 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.
28 What Did The 10CFR
§50.59 Review Say?Edisonisparsingitswords!
Edison is parsing its words!*"At the time the RSGs were designedMHIevaluatedthe
*Removing the stay cylinder allowed377extratubes designed , MHI evaluated the flow patterns and determined that fluid elastic instability (FEI) w ou l d n o t occu r."1/9/1 3 allowed  377 extra tubes into the center void, creating more interior heat
*Therisercolumnwatervoid()oudooccu./9/3Edison brief to NRC, page 14
*"MHIprovidedathermal
-*The riser column water void above the tube sheet was


also eliminated
7 San Onofre D i Design    Specification S      ifi ti      For F RSG #1 3.6.1.1 Edison intends to replace the steam generators under th 10 CFR 50.59 the          50 59 rule.
*Therewasnothingonthe MHI provided a thermalhydraulic analysis as part of the original design of the RSGs that showed there There was nothing on the steam side to facilitate and bias the flow direction. The steam side flow p atterns would be no FEI.
l 3.6.1.2 the the Supplier shall guarantee in writing that the RSG design is licensable and provide all support necessary to achieve that end.
"page 17 p were never established.
3.6.1.3 Any deviations from these requirements shall require Edisonss approval Edison   approval.
*The 10CFR§50.59 analysis should identif y hi g h void ygfractions and confused in/out-of-plane FEI.
8
29 Friends Of The Earth Consultants Reached ADifft10CFR
§5059Cli A Diff eren t 10CFR§50.59 C onc l us i on"- design changes may be
*Fairewinds agrees with this screened out under 10 CFR 50.59 if the changes do not adversely affect a design function"Page9Edisonapproach, but it is not the approach used by Edison at


San Onofre.  
San Onofre D i Design      Specification S        ifi ti      For F RSG #2 3 6 2 Licensing Topical Report:
*ThetotalityofRSGchanges function Page 9 , Edison Response, 1/9/13"The adverse condition that later resulted in the tube leak was a  
3.6.2 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.
*The totality of RSG changes Edison proposed in 2004 created an unacceptable void fraction at the top of the hot deficiency associated with the design and was not known at the time the 50.59 evaluation wasperformed.
9
"Page9,Edisonside of the tubes that then


created the FEI.  
Edison Official Notification T NRC June To          J      2006 Edi Edison  N tifi d NRC off 50.59 Notified        50 59 Decision D ii    iin JJune 2006 A
*Fairewinds and John Large both agreethatitshouldhavebeen was performed.
A meeting was held on Wednesday Wednesday, June 7  7, 2006 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.
Page 9, Edison Response, 1/9/13 agree that it should have been foreseeable to Edison in 2004 that this combination of changes would cause FEI to occur. 30 Edison's Cause Report Was Wrong
(ML061670140) 10
*Former NRC Chairman Gregory Jaczko promised StdthblilttC S ena t or Boxer an d th e pu bli c a comp l e t e Roo t C ause Analysis. This has not been conducted.iif*Kepner Tregoe Cause Analys i s i s severely f lawed.*"If they can get you asking the wrong questions, they don'thavetoworryaboutanswers "ThomasPynchon don't have to worry about answers."Thomas Pynchon , Gravity's Rainbow*StatementuponwhichEdisonbaseditsCauseReport:
*Statement upon which Edison based its Cause Report: "What is different or has changed when comparing SONGS Replacement SGs to Another US plant
's ReplacementSG
"(page43,ConditionReport) 31 Replacement SG (page 43, Condition Report)
What Root Cause Q uestion QShould Edison Have Asked?
There are no changes to compare among Edison's RSG and other RSGs nationwide. It's an apples and oranges comparison.
Th hEdihldhld Th e c h anges Edi son s h ou ld h ave ana l yze d and compared are those between the OSG andtheRSGorbetweenSanOnofreandPalo and the RSG or between San Onofre and Palo Verde, since Edison has acknowledged that


Palo Verde's RSG is identical to San Onofre's OSG OSG.32 Exclusions From Edison
JUNE 2006 Edison Presentation to NRC 11
's Kepner Tregoe (KT) Analysis ProcessExtracted 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 FORESEEABLEPROBLEMS FORESEEABLE PROBLEMSDuringthepasteightyearstheNRChadextensive 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-likeltfthiildiEdiittd rep l acemen t s f or th e or i g i na l d es igns, as Edi son comm itt e d during the 10CFR50.59 processes. And, as demonstrated by the significant damage in the San Onofre Replacement StGtthdihdidh St eam G enera t ors, th e d es ign c h anges did h ave 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 amendment.35 SanOnofreWasA
'NearMiss'San Onofre Was A 'Near Miss'Thtbfil Th e t u b e f a il ures at San Onofre aretheworst are the worst nuclear e q ui p ment qp failures since


the near miss at Davis Bessie in
2006 NRC Informed of Improvements 12


2002.36 San Onofre Technical SpecificationsSanOnofreTechnicalSpecificationsstates San Onofre Technical Specifications states that the limiting design basis accident is a "doubleendedruptureofasingletube
2006 Edison Accepts Responsibility 13
".double ended rupture of a single tube. Page 510 37 E d i so n's Sa n O n o fr e: dsosSaOoe:
 
Operating Outside Design BasisEight Tubes failed their pressure test, not one! TheevidenceshowsthatSanOnofrewasoperating The evidence shows that San Onofre was operating outside of its design basis and the NRC has done nothing to address this major violation.
Mitsubishi Heavy      y 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.
"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.
14
"Page 57, NRC AIT Report 38 Arnie Gundersen, Chief EngineerFiidAitI F a i rew i n d s A ssoc i a t es, I ncNuclear Engineering, Safety, and Reliability Expert 42-years of nuclear industry experience and oversight ME NEMaster of Engineering Nuclear EngineeringRensselaerPolytechnicInstitute,1972 Rensselaer Polytechnic Institute, 1972U.S. Atomic Energy Commission FellowshipThesis: Cooling Tower Plume RiseBSNEBhlfSiNlEii BS NE B ac h e lor o f S c i ence N uc l ear E ng i neer i ngRensselaer Polytechnic Institute, 1971, Cum LaudeJamesJKerriganScholar James J. Kerrigan ScholarROLicensed Reactor OperatorU.S. Atomic Energy Commission 39License # OP-3014}}
 
The 10CFR§50.59 Process In its January 9, 2013 Response
* Fairewinds agrees with Edison to the NRC, NRC Edison said          that this is the correct approach, and it should have "As discussed in Section 1.3 of  been implemented.
* However this approach was However, not applied during the RSG Project. Rather this "multistep process" was thwarted by p                          y Edison.
* No appropriate engineering and technical evaluation was performed by Edison when the contractual decision was made that 10CFR§50.59 would not apply.
15
 
Standard Technical Specifications License Amendment 2009: During the San Onofre Standard Technical Specification License Amendment, Edison identified man many areas where here the San Onofre Replacement Steam Generator was dramatically different than the Original Steam Generator.
16
 
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 g implemented p          in the San Onofre RSG:
* Remove Stay Cylinder
* Add 377 Tubes
* Change Tube Support Structure
* Add New Anti-Vibration Bars
* Dozens More Changes 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.
20
* 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.
21
 
http://www.fairewinds.com/content/san-onofres-steam-generator-failures-could-have-been-prevented 22 Mitsubishi Heavy Industries Should Not Be The Scapegoat If the e RSGs SGs had ad bee been designed des g ed and a d manufactured a u ac u ed 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 licensee licenseess 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, design not the fabrication.
23
 
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%
15 8% iinterest, t      t hhave th  the same d    design i    and d material properties as the San Onofre units. During 2003, the Palo Verde Unit 2 steam g                generators were replaced.
(Edison 2003 Annual Report, Page 21) http://www.edison.com/images/cms_images/c6452_2003_annual_eix_5543.pdf 24
 
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 l  d too much hhheat iin the h center off SSan 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 p
* 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.
28
 
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 designed,                            allowed 377 extra tubes flow patterns and determined        into the center void, that fluid elastic instability      creating more interior heat
((FEI)) would ou d not o occu occur.
                          . 1/9/13
                                /9/ 3
* The riser column water void Edison brief to NRC, page 14        above the tube sheet was also eliminated
* MHI MHI provided a thermal-thermal
* There was nothing on the hydraulic analysis as part of        steam side to facilitate and the original design of the          bias the flow direction. The RSGs that showed there              steam side flow p patterns would be no FEI. page 17            were never established.
* The 10CFR§50.59 analysis should identifyy high g void fractions and confused in/out-of-plane FEI.        29
 
Friends Of The Earth Consultants Reached A Different Diff          t 10CFR§50.59 10CFR§50 59 C    Conclusionl i
" 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 function          9, Edison
* The totality of RSG changes Response, 1/9/13 "The            Edison proposed in 2004 adverse condition that later      created an unacceptable void resulted in the tube leak was a  fraction at the top of the hot deficiency associated with the    side of the tubes that then design and was not known at      created the FEI.
the time the 50.59 evaluation
* Fairewinds and John Large both was performed.
performed. Page 9, Edison    agree that it should have been Response, 1/9/13                  foreseeable to Edison in 2004 that this combination of changes would cause FEI to occur.
30
 
Edisons Cause Report Was Wrong
* Former NRC Chairman Gregory Jaczko promised S
Senatort Boxer andd the th public bli a complete l t Roott CCause Analysis. This has not been conducted.
* Kepner Tregoe Cause Analysis  i iis severely fflawed.
* If they can get you asking the wrong questions, they don't have to worry about answers.
answers  Thomas Pynchon, 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 SG (page 43, Condition Report) 31
 
What Root Cause Question Q
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 Th  h      Edi Edison  should h ld hhave analyzed l  d 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.
OSG 32
 
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, years the NRC had extensive evidence from multiple sources that the replacement steam generators at San Onofre were not the like-for-like replacements l        t ffor the th original i i lddesigns, i    as Edi Edison committed itt d during the 10CFR50.59 processes. And, as demonstrated by the significant damage in the San Onofre Replacement St Steam    G Generators, t    th the d design i  changes h        did h 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.
amendment 35
 
San Onofre Was A Near Miss The tube Th  t b failures f il at San Onofre are the worst nuclear equipment q p failures since the near miss at Davis Bessie in 2002.
36
 
San Onofre Technical Specifications San Onofre Technical Specifications states that the limiting design basis accident is a "double double ended rupture of a single tube tube..
Page 510 37
 
Edisons d so s Sa San O Onofre:
o e:
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 F i Fairewinds i d Associates, A     i t     Inc I
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 B Bachelor h l off SScience i     N Nuclear l   E Engineering i   i Rensselaer Polytechnic Institute, 1971, Cum Laude James J.J Kerrigan Scholar RO      Licensed Reactor Operator U.S. Atomic Energy Commission License # OP-3014 39}}

Latest revision as of 09:52, 20 March 2020

G20120891, Friends of the Earth Presentation for 1/16/13 Meeting with to Provide an Opportunity to Address the NRC PRB, Pursuant to 10 CFR 2.206.
ML13016A092
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 01/16/2013
From:
Fairewinds Associates
To:
Plant Licensing Branch IV, Friends of the Earth
Benney B
Shared Package
ML13016A077 List:
References
G20120891, TAC MF0060, TAC MF0061
Download: ML13016A092 (39)
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Text

1 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 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, Edi Edison Applied A li d To T 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.

5

In 2004 Edison Contract Language Directed MHI That CFR§50.59 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 Replacementp Steam Generator Design & Performance Specifications SO23-617-1 Originator - James Chan IRE - Jun Gaor FLS - David Calhoun SLS - Craig g Herberts PE Tom Pierno NO& A Bill Kotekkaskos 6

7 San Onofre D i Design Specification S ifi ti For F RSG #1 3.6.1.1 Edison intends to replace the steam generators under th 10 CFR 50.59 the 50 59 rule.

l 3.6.1.2 the 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 Edisonss approval Edison approval.

8

San Onofre D i Design Specification S ifi ti For F RSG #2 3 6 2 Licensing Topical Report:

3.6.2 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.

9

Edison Official Notification T NRC June To J 2006 Edi Edison N tifi d NRC off 50.59 Notified 50 59 Decision D ii iin JJune 2006 A

A meeting was held on Wednesday Wednesday, June 7 7, 2006 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) 10

JUNE 2006 Edison Presentation to NRC 11

2006 NRC Informed of Improvements 12

2006 Edison Accepts Responsibility 13

Mitsubishi Heavy y 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.

14

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

  • Fairewinds agrees with Edison to the NRC, NRC Edison said that this is the correct approach, and it should have "As discussed in Section 1.3 of been implemented.
  • However this approach was However, not applied during the RSG Project. Rather this "multistep process" was thwarted by p y Edison.
  • No appropriate engineering and technical evaluation was performed by Edison when the contractual decision was made that 10CFR§50.59 would not apply.

15

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

16

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 g implemented p in the San Onofre RSG:

  • Remove Stay Cylinder
  • Add 377 Tubes
  • Change Tube Support Structure
  • Add New Anti-Vibration Bars
  • Dozens More Changes 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.

20

  • 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.

21

http://www.fairewinds.com/content/san-onofres-steam-generator-failures-could-have-been-prevented 22 Mitsubishi Heavy Industries Should Not Be The Scapegoat If the e RSGs SGs had ad bee been designed des g ed and a d manufactured a u ac u ed 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 licensee licenseess 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, design not the fabrication.

23

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%

15 8% iinterest, t t hhave th the same d design i and d material properties as the San Onofre units. During 2003, the Palo Verde Unit 2 steam g generators were replaced.

(Edison 2003 Annual Report, Page 21) http://www.edison.com/images/cms_images/c6452_2003_annual_eix_5543.pdf 24

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 l d too much hhheat iin the h center off SSan 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 p
  • 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.

28

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 designed, allowed 377 extra tubes flow patterns and determined into the center void, that fluid elastic instability creating more interior heat

((FEI)) would ou d not o occu occur.

. 1/9/13

/9/ 3

  • The riser column water void Edison brief to NRC, page 14 above the tube sheet was also eliminated
  • MHI MHI provided a thermal-thermal
  • There was nothing on the hydraulic analysis as part of steam side to facilitate and the original design of the bias the flow direction. The RSGs that showed there steam side flow p patterns would be no FEI. page 17 were never established.
  • The 10CFR§50.59 analysis should identifyy high g void fractions and confused in/out-of-plane FEI. 29

Friends Of The Earth Consultants Reached A Different Diff t 10CFR§50.59 10CFR§50 59 C Conclusionl i

" 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 function 9, Edison

  • The totality of RSG changes Response, 1/9/13 "The Edison proposed in 2004 adverse condition that later created an unacceptable void resulted in the tube leak was a fraction at the top of the hot deficiency associated with the side of the tubes that then design and was not known at created the FEI.

the time the 50.59 evaluation

  • Fairewinds and John Large both was performed.

performed. Page 9, Edison agree that it should have been Response, 1/9/13 foreseeable to Edison in 2004 that this combination of changes would cause FEI to occur.

30

Edisons Cause Report Was Wrong

  • Former NRC Chairman Gregory Jaczko promised S

Senatort Boxer andd the th public bli a complete l t Roott CCause Analysis. This has not been conducted.

  • Kepner Tregoe Cause Analysis i iis severely fflawed.
  • If they can get you asking the wrong questions, they don't have to worry about answers.

answers Thomas Pynchon, 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 SG (page 43, Condition Report) 31

What Root Cause Question Q

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 Th h Edi Edison should h ld hhave analyzed l d 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.

OSG 32

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, years the NRC had extensive evidence from multiple sources that the replacement steam generators at San Onofre were not the like-for-like replacements l t ffor the th original i i lddesigns, i as Edi Edison committed itt d during the 10CFR50.59 processes. And, as demonstrated by the significant damage in the San Onofre Replacement St Steam G Generators, t th the d design i changes h did h 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.

amendment 35

San Onofre Was A Near Miss The tube Th t b failures f il at San Onofre are the worst nuclear equipment q p failures since the near miss at Davis Bessie in 2002.

36

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

Page 510 37

Edisons d so s Sa San O Onofre:

o e:

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 F i Fairewinds i d Associates, A i t Inc I

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 B Bachelor h l off SScience i N Nuclear l E Engineering i i Rensselaer Polytechnic Institute, 1971, Cum Laude James J.J Kerrigan Scholar RO Licensed Reactor Operator U.S. Atomic Energy Commission License # OP-3014 39

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