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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 |
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| {{#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:
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| Conclusions 3
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| SECTION 1 CHRONOLOGY OF EVENTS 4
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| 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
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| 's 2004 Annual Report, its application for its Unit 2 and 3 Replacement Steam Generators was filed with the
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| 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
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| §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
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| §50.59 would not apply to the San Onofre RSG
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| '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
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| 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
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| -the Supplier shall guarantee in writing that the RSG design is licensable and provide all support necessary to achieve that end.
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| "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:
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| 3.6.2 Licensing Topical Report: "The Supplier shall prepare and submit for Edison
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| '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."
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| 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.
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| "(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
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| 'searlier design in order to support Edison's earlier decision determining that 10CFR
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| §50.59 did not apply.14 The 10CFR§50.59 ProcessIn its January 9, 2013 Response totheNRCEdisonsaid
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| *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
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| 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 |
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| 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.
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| 16 San Onofre RSG
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| '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:
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| *Remove Stay Cylinder gp*Add 377 Tubes
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| *Change Tube Support Structure
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| *Add New Anti-Vibration Bars
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| *DozensMoreChanges
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| *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.
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| 20
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| *The San Onofre tubes and tube sheets are part of the containment boundary and are safety related.
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| *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.
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| 21 http://www.fairewinds.com/content/san-onofre
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| '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
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| 'sdesign Mitsubishi
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| - in accordance with the licensee s design specification was translated into the same set of design and fabrication drawings. AIT Report, Page 27
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| *No matter who fabricated the RSG
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| 's for San Onofre, the tube damage would have occurred. The root causeofthisproblemwasthedesignnotthe 23 cause of this problem was the design , not the fabrication.
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| Edison2003AnnualReport:
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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 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
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| )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/
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| Egg Crate Design Retained On Palo Verde/ Eliminated On San Onofre BROACHED TUBE SUPPORTEGG CRATE TUBE SUPPORT 26 SanOnofreProblemWasForeseeable San Onofre Problem Was Foreseeable
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| *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
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| *SanOnofreadded4%moretubesatthe
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| *Palo Verde added 10% to the periphery and
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| *San Onofre added 4% more tubes at the center of its RSGsadded 2.9% more heat
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| *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.
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| 28 What Did The 10CFR
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| §50.59 Review Say?Edisonisparsingitswords! | |
| Edison is parsing its words!*"At the time the RSGs were designedMHIevaluatedthe
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| *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
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| *Therisercolumnwatervoid()oudooccu./9/3Edison brief to NRC, page 14
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| *"MHIprovidedathermal
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| -*The riser column water void above the tube sheet was
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| 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
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| §5059Cli A Diff eren t 10CFR§50.59 C onc l us i on"- design changes may be
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| *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
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| 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
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| 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:
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| *Statement upon which Edison based its Cause Report: "What is different or has changed when comparing SONGS Replacement SGs to Another US plant
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| 's ReplacementSG
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| "(page43,ConditionReport) 31 Replacement SG (page 43, Condition Report)
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| What Root Cause Q uestion QShould Edison Have Asked?
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| There are no changes to compare among Edison's RSG and other RSGs nationwide. It's an apples and oranges comparison.
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| 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
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| 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
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| '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
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| the near miss at Davis Bessie in
| | 2006 NRC Informed of Improvements 12 |
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| 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:
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| 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 |
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| | Stay Cylinder: Retained On Palo Verde And Eliminated On San Onofre 25 |
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| | 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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MONTHYEARML12325A7482012-11-16016 November 2012 G20120891 - Richard Ayres Ltr. 2.206 - 10 CFR Part 50.59 Review for the Replacement Steam Generators at San Onofre Units 2 and 3 Project stage: Request ML13002A2362012-12-27027 December 2012 Revised Forthcoming Meeting with Petitioner Requesting Action Against Southern California Edison Company Project stage: Meeting ML12347A2682012-12-27027 December 2012 G20120891 - 1/11/2013 - Forthcoming Meeting with Petitioner 2.206 Petition, Richard Ayres, Friends of the Earth 11/16/12 Letter and 10 CFR 50.59 Review for the Replacement Steam Generators at San Onofre, Units 2 and 3 Project stage: Meeting ML13015A2082013-01-15015 January 2013 Public Feedback Form Regarding 1/16/13 Meeting with Friends of the Earth to Provide an Opportunity to Address the NRC PRB, Pursuant to 10 CFR 2.206 Project stage: Request ML13029A6432013-01-16016 January 2013 Official Transcript - Nuclear Regulatory Commission 10 CFR 2.206 Petition Review Board Pre-Meeting with Friends of the Earth San Onofre, Units 2 and 3 (TAC Nos. MF0060 and MF0061) Project stage: Meeting ML13016A0922013-01-16016 January 2013 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. Project stage: Meeting ML13016A0862013-01-16016 January 2013 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) Project stage: Meeting ML13016A0822013-01-16016 January 2013 G20120891/San Onofre Nuclear Generating Station,Units 2 and 3- Email from Petitioner Regarding 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.MF0 Project stage: Meeting ML13109A0752013-02-0606 February 2013 Submission by Friends of the Earth Supplementing Its 10 CFR 2.206 Petition and Responding to Southern California Edison'S 2.206 Response Project stage: Request ML13029A6162013-02-0707 February 2013 G20120891 - San Onofre, Units 2 and 3, Memo to File Audio Recording of 1/16/2013 Public Meeting with Friends of the Earth Regarding Its 10 CFR 2.206 Petition Requesting Action Against Southern California Edison Project stage: Meeting ML13116A2652013-02-12012 February 2013 Request for Disclosure of Mhl Report in the 2.206 Petition Review Process Regarding the 10 CFR Section 50.59 Review for the Replacement Steam Generators at San Onofre, Units 2 and 3 Project stage: Request ML13017A1122013-02-13013 February 2013 G20120891 - Summary of 1/16/2013 Meeting with Petitioner 2.206 Petition, Richard Ayres, Friends of the Earth 11/16/12 Letter and 10 CFR 50.59 Review for the Replacement Steam Generators at San Onofre Project stage: Meeting ML13116A2672013-03-27027 March 2013 Declaration by John Large in Support of 2.206 Petition by Friends of the Earth SONGS Units 2 & 3 Project stage: Request ML13116A2662013-04-0404 April 2013 Ayres Law Group, Submittal of MHI Root Cause Analysis Report and Related Documents Into the Record for the 2.206 Petition Review Process Project stage: Request ML13106A1932013-04-30030 April 2013 G20120891 - San Onofre Nuclear Generating Station, Units 2 and 3 - Acknowledgement Letter to 2.206 Petitioner Friends of the Earth Regarding Steam Generator Tube Leak Project stage: Other ML13106A1952013-04-30030 April 2013 G20120891 - Federal Register Notice, San Onofre Nuclear Generating Station, Units 2 and 3 - Acknowledgement to 2.206 Petitioner Friends of the Earth Regarding Steam Generator Tube Leak Project stage: Other 2013-02-13
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Category:Meeting Briefing Package/Handouts
MONTHYEARML21053A4412021-02-23023 February 2021 NRC Staff Slides: Feb 23, 2021 Pre-submission Meeting for San Onofre Nuclear Generating Station (SONGS) ML21042A0772021-02-11011 February 2021 Public-Watchdogs-Langley-Final-02-11-2021 ML20149K4992020-07-0101 July 2020 California Coastal Commission July 2020 Meeting on San Onofre Nuclear Generating Station Independent Spent Fuel Storage Installation Inspection and Maintenance Program ML20178A2482020-06-24024 June 2020 Public Watchdogs 10 CFR 2.206 Petition - E-mail from Public Watchdogs with Presentations for June 24th Public Meeting with the NRC ML20178A2492020-06-24024 June 2020 Public Watchdogs - 10 CFR 2.206 Meeting with NRC - Petition Review Board, June 23, 2020 ML19234A0082019-08-20020 August 2019 Southern California Edison Company, San Onofre Nuclear Generating Station, August 20 2019 NRC Town Hall Meeting Sjc ML19154A1372019-06-0303 June 2019 June 3, 2019, Webinar Slides ML19084A1342019-03-25025 March 2019 NRC Slides for March 25 2019 Public Webinar ML19029B5092019-01-24024 January 2019 Final NRC Presentation for SCE Enforcement Conference ML18353A7492018-12-12012 December 2018 Presentation Slides: NRC SONGS Presentation December 2018, Victor ML18340A1762018-11-29029 November 2018 Southern California Edison Company; San Onofre Nuclear Generating Station; SONGS Community Engagement Panel, November 29, 2018 ML18318A0642018-11-0808 November 2018 Public Meeting Slides with Extra Content ML18312A1182018-11-0808 November 2018 Presentation for San Onofre Special Inspection Webinar November 8, 2018 ML17088A6572017-03-28028 March 2017 2017 RIC Presentation from Yamir Diaz-Castillo Entitled, Current NRC Vendor Findings and the Results from the 1st SONGS Lessons Learned Inspection. ML14216A4512015-02-0909 February 2015 7/31/14 Summary of Closed Meeting with Southern California Edison to Discuss Scope and Schedule Related to Cyber Security License Amendment Request for San Onofre Nuclear Generating Station, Units 2 and 3 ML14303A6392014-10-27027 October 2014 NRC Slides - SONGS PSDAR Public Meeting October 27, 2014 ML14303A6242014-10-27027 October 2014 Licensee'S Slides - SONGS PSDAR Public Meeting October 27, 2014 ML14272A4152014-09-25025 September 2014 SONGS EP RAI Response Review Slides - Public Meeting September 25, 2014 ML14272A4652014-09-24024 September 2014 SONGS Public Meeting Slides (Non-Public Portion) - Public Meeting September 24, 2014 ML14239A4642014-08-28028 August 2014 August 28, 2014, Public Meeting Slides Concerning San Onofre Nuclear Generating Station (SONGS) Decommisioning Quality Assurance Program ML14199A0982014-07-17017 July 2014 SONGS Cep Meeting Slides- Reactor Decommissioning Process ML13268A0032013-09-25025 September 2013 Reactor Decommissioning Process- Presentation for San Onofre 2&3 PSDAR Public Meeting ML13092A2882013-04-0202 April 2013 Licensee Slides for 4/3/13 Pre-Submittal Meeting to Discuss License Amendment Request ML13059A1572013-02-27027 February 2013 Licensee Slides from 2/27/13 Meeting Regarding a Request for Additional Information ML13059A1522013-02-27027 February 2013 NRC Meeting Slides from 2/27/13 Public RAI Meeting ML13016A0922013-01-16016 January 2013 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. ML13016A0862013-01-16016 January 2013 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) ML12352A4112012-12-18018 December 2012 NRC Slides for 12/18/12 Meeting with Southern California Edison ML12352A3852012-12-18018 December 2012 Licensee Slides for 12/18/12 Public Meeting ML12346A1162012-12-10010 December 2012 Meeting Summary for November 30, 2012, Meeting with Southern California Edison Company ML12311A0492012-09-18018 September 2012 Part 26 Public Meeting NEI Presentation Slides ML12157A2722012-06-11011 June 2012 5/31/2012 Summary of Telephone Conference with Licensees Regarding Near Term Task Force Recommendation 2.1 Seismic Reevaluations - Diablo Canyon, 1 and 2, San Onofre, Units 2 and 3, Columbia Generating Station, and Palo Verde, Units 1, 2, a ML1115304302011-06-0101 June 2011 Meeting Summary for Public Meeting with Southern California Edison to Present & Discuss the Performance Results for San Onofre Nuclear Generating Station Units 2 & 3 for Period of January 1 Through December 31, 2010 ML1101206302011-01-12012 January 2011 License Amendment Request to Support Use of Areva Nuclear Fuel, Slides from 1/12/2011 Meeting ML1027304522010-09-30030 September 2010 Meeting Summary for 09/16/2010 Public Meeting with Southern California Edison ML0932402122009-11-20020 November 2009 Summary of Public Meeting with Southern California Edison Company on San Onofre Nuclear Generating Station 2009 Performance ML0926502992009-09-22022 September 2009 Summary of Public Meeting with Southern California Edison Regarding Site Improvement Initiatives ML0914905092009-05-28028 May 2009 Summary of Meeting with Southern California Edison Company Several Initiatives That Were Being Implemented to Improve Licensed Operator Training at San Onofre Nuclear Generating Station ML0832408342008-10-30030 October 2008 Licensee Handout for 10-31-08 Call ML0819303742008-06-11011 June 2008 Attachment 2: Presentation Slides by James Shepherd, NRC from June 11, 2008 Public Meeting with SONGS ML0819305432008-06-11011 June 2008 Attachment 3: Presentation Slides, Emilio Garcia, NRC from June 11, 2008 Public Meeting with SONGS ML0819305802008-06-11011 June 2008 Attachment 4: Presentation Slides, James Reilly, SONGS from June 11, 2008 Public Meeting with SONGS ML0729806642007-10-24024 October 2007 Meeting Presentation on Update on Generic Safety Issue 191 Plant Audits ML0727500132007-09-25025 September 2007 9/25/2007 Licensee Handouts for Meeting Re San Onofre Nuclear Generating Station, Unit 3 - Reclassification of Control Rod Drive Mechanism 56 NDE (Non Destructive Examination) Indication ML0720703362007-07-20020 July 2007 Summary of San Onofre Nuclear Generating Station End-Of-Cycle Public Meeting ML0634600722006-11-17017 November 2006 Licensee Information in Support of 11/17/2006 Discussions Steam Generator Tube Inspections - Refueling Outage 14 ML0613604892006-05-0303 May 2006 Meeting Slides, Southern California Edison for San Onofre Nuclear Generating Station (Enclosure 2) M060502, M060502-Briefing on Status of Emergency Planning Activities (Slides)2006-05-0202 May 2006 M060502-Briefing on Status of Emergency Planning Activities (Slides) ML0609601982006-01-23023 January 2006 SONGS 2, Handouts, Information Supplied by SCE in Support of Discussion ML0712401852005-12-31031 December 2005 Reactor Decommissioning Program Lessons-Learned 2021-02-23
[Table view] Category:Slides and Viewgraphs
MONTHYEARML21053A2382021-02-22022 February 2021 Southern California Edison Slides for Feb 23, 2021, Pre-submission Meeting for SONGS Proposed Exemption- 10 CFR 72.106b ML21042A0772021-02-11011 February 2021 Public-Watchdogs-Langley-Final-02-11-2021 ML20178A2482020-06-24024 June 2020 Public Watchdogs 10 CFR 2.206 Petition - E-mail from Public Watchdogs with Presentations for June 24th Public Meeting with the NRC ML20178A2492020-06-24024 June 2020 Public Watchdogs - 10 CFR 2.206 Meeting with NRC - Petition Review Board, June 23, 2020 ML19255F6182019-09-17017 September 2019 Presentation Slides: SONGS Recent Dry Storage Operating Experience ML19235A1892019-08-29029 August 2019 Final NEIMA Meeting Slides - SONGS Presentation ML19234A0082019-08-20020 August 2019 Southern California Edison Company, San Onofre Nuclear Generating Station, August 20 2019 NRC Town Hall Meeting Sjc ML19154A1372019-06-0303 June 2019 June 3, 2019, Webinar Slides ML19084A1342019-03-25025 March 2019 NRC Slides for March 25 2019 Public Webinar ML19029B5092019-01-24024 January 2019 Final NRC Presentation for SCE Enforcement Conference ML19023A0332019-01-24024 January 2019 Southern California Edison Company; San Onofre Nuclear Generating Station, Pre-Decisional Enforcement Conference Slides ML19023A2492019-01-23023 January 2019 NRC Slides for Southern California Edison Conference January 24, 2019 ML18353A7492018-12-12012 December 2018 Presentation Slides: NRC SONGS Presentation December 2018, Victor ML18340A1762018-11-29029 November 2018 Southern California Edison Company; San Onofre Nuclear Generating Station; SONGS Community Engagement Panel, November 29, 2018 ML18318A0642018-11-0808 November 2018 Public Meeting Slides with Extra Content ML18312A1182018-11-0808 November 2018 Presentation for San Onofre Special Inspection Webinar November 8, 2018 ML17088A6572017-03-28028 March 2017 2017 RIC Presentation from Yamir Diaz-Castillo Entitled, Current NRC Vendor Findings and the Results from the 1st SONGS Lessons Learned Inspection. ML14216A4512015-02-0909 February 2015 7/31/14 Summary of Closed Meeting with Southern California Edison to Discuss Scope and Schedule Related to Cyber Security License Amendment Request for San Onofre Nuclear Generating Station, Units 2 and 3 ML14303A6392014-10-27027 October 2014 NRC Slides - SONGS PSDAR Public Meeting October 27, 2014 ML14303A6242014-10-27027 October 2014 Licensee'S Slides - SONGS PSDAR Public Meeting October 27, 2014 ML14272A4152014-09-25025 September 2014 SONGS EP RAI Response Review Slides - Public Meeting September 25, 2014 ML14272A4652014-09-24024 September 2014 SONGS Public Meeting Slides (Non-Public Portion) - Public Meeting September 24, 2014 ML14239A4642014-08-28028 August 2014 August 28, 2014, Public Meeting Slides Concerning San Onofre Nuclear Generating Station (SONGS) Decommisioning Quality Assurance Program ML14199A0982014-07-17017 July 2014 SONGS Cep Meeting Slides- Reactor Decommissioning Process ML13268A0032013-09-25025 September 2013 Reactor Decommissioning Process- Presentation for San Onofre 2&3 PSDAR Public Meeting ML13227A1102013-08-13013 August 2013 8/13/13 Michael F. Weber, Deputy Executive Director for Materials, Waste, Research, State, Tribal, and Compliance Programs Testimony on: the U.S. Nrc'S Power Reactor Decommissioning Process ML13092A2882013-04-0202 April 2013 Licensee Slides for 4/3/13 Pre-Submittal Meeting to Discuss License Amendment Request ML13059A1522013-02-27027 February 2013 NRC Meeting Slides from 2/27/13 Public RAI Meeting ML13016A0922013-01-16016 January 2013 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. ML13016A0862013-01-16016 January 2013 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) ML12352A4112012-12-18018 December 2012 NRC Slides for 12/18/12 Meeting with Southern California Edison ML12352A3852012-12-18018 December 2012 Licensee Slides for 12/18/12 Public Meeting ML12346A1162012-12-10010 December 2012 Meeting Summary for November 30, 2012, Meeting with Southern California Edison Company ML12311A0492012-09-18018 September 2012 Part 26 Public Meeting NEI Presentation Slides ML12179A4472012-06-26026 June 2012 6/18/2012 Meeting Summary for Augmented Inspection Team Exit Meeting with Southern California Edison Co ML12157A2722012-06-11011 June 2012 5/31/2012 Summary of Telephone Conference with Licensees Regarding Near Term Task Force Recommendation 2.1 Seismic Reevaluations - Diablo Canyon, 1 and 2, San Onofre, Units 2 and 3, Columbia Generating Station, and Palo Verde, Units 1, 2, a ML1101206302011-01-12012 January 2011 License Amendment Request to Support Use of Areva Nuclear Fuel, Slides from 1/12/2011 Meeting ML0932402122009-11-20020 November 2009 Summary of Public Meeting with Southern California Edison Company on San Onofre Nuclear Generating Station 2009 Performance ML0926502992009-09-22022 September 2009 Summary of Public Meeting with Southern California Edison Regarding Site Improvement Initiatives ML0914905092009-05-28028 May 2009 Summary of Meeting with Southern California Edison Company Several Initiatives That Were Being Implemented to Improve Licensed Operator Training at San Onofre Nuclear Generating Station ML11216A2442008-12-12012 December 2008 0523 - R504P - Westinghouse Advanced Technology - 07.3 - Water Hammer at San Onofre ML0832408342008-10-30030 October 2008 Licensee Handout for 10-31-08 Call ML0828804352008-10-14014 October 2008 Summary of Meeting with Southern California Edison to Discuss Performance at San Onofre Nuclear Generating Station ML0822602532008-08-12012 August 2008 Summary of Meeting on with Southern California Edison Co Regarding the End-of-Cycle Assessment of San Onofre Nuclear Generating Station ML0819303742008-06-11011 June 2008 Attachment 2: Presentation Slides by James Shepherd, NRC from June 11, 2008 Public Meeting with SONGS ML0819305802008-06-11011 June 2008 Attachment 4: Presentation Slides, James Reilly, SONGS from June 11, 2008 Public Meeting with SONGS ML0819305432008-06-11011 June 2008 Attachment 3: Presentation Slides, Emilio Garcia, NRC from June 11, 2008 Public Meeting with SONGS ML0729806642007-10-24024 October 2007 Meeting Presentation on Update on Generic Safety Issue 191 Plant Audits ML0727500132007-09-25025 September 2007 9/25/2007 Licensee Handouts for Meeting Re San Onofre Nuclear Generating Station, Unit 3 - Reclassification of Control Rod Drive Mechanism 56 NDE (Non Destructive Examination) Indication ML0720703362007-07-20020 July 2007 Summary of San Onofre Nuclear Generating Station End-Of-Cycle Public Meeting 2021-02-22
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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:
- 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