|
|
| Line 14: |
Line 14: |
| | document type = Meeting Briefing Package/Handouts, Slides and Viewgraphs | | | document type = Meeting Briefing Package/Handouts, Slides and Viewgraphs |
| | page count = 39 | | | page count = 39 |
| | project = TAC:MF0061, TAC:MF0060 | | | project = TAC:MF0060, TAC:MF0061 |
| | stage = Meeting | | | stage = Meeting |
| }} | | }} |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:1 2.206 PRESENTATIONSanOnofreUnits2and3San Onofre Units 2 and 3Replacement Steam GeneratorsMEETING WITH PETITIONER FRIENDS OF THE EARTH, REQUESTING ENFORCEMENT ACTION AGAINST SOUTHERN CALIFORNIA EDISONUNDER10CFR2206EDISON 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:ChronologyofEventsSECTION 1:Chronology of EventsSECTION 2:Magnitude of Design Changes SECTION 3:Conclusions3 SECTION 1 CHRONOLOGY OF EVENTS4 Prior To Analysis And Design Of RSGs, EdiAlidTCPUCEdison Applied To 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's PUC on February 27, 2004, which was prior to the contract with MHI on September 30, 2004.5 In 2004 Edison Contract LanguageDirectedMHIThatCFR§5059Directed 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 Replacement Steam GeneratorpDesign & Performance Specifications SO23-617-1Originator -James ChanIRE -Jun GaorFLS -David Calhoun SLS -Craig Herberts6gPE Tom PiernoNO& A Bill Kotekkaskos 7 | | {{#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: |
| San Onofre DiSifitiFRSG#1Design Specification For RSG #13.6.1.1 "Edison intends to replace the steam generators under th10CFR5059l"the 10 CFR 50.59 rule." 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"Edisons approval.8 San Onofre DiSifitiFRSG#2Design Specification For RSG #2362LicensingTopicalReport:3.6.2 Licensing Topical Report: "The Supplier shall prepare and submit for Edison's approval a LicensingTopicalReportdemonstratingcomplianceoftheLicensing 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 TNRCJ2006To NRC June 2006EdiNtifidNRCf5059DiiiJ2006EdisonNotified NRC of 50.59 Decision in June 2006"AmeetingwasheldonWednesdayJune72006A meeting was held on Wednesday, June 7, 2006, between the Nuclear Regulatory Commission (NRC) staff andtheSCE,thelicenseeforSONGS2and3.Themeetingand 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 NRC11 2006 NRC Informed of "Improvements"12 2006 Edison Accepts Responsibility13 Mitsubishi Heavy Industries Was yConstrained By The ContractBetween the contract award in 2004 and NRC kickoffmeetingin2006,MitsubishiHeavykickoff meeting in 2006, Mitsubishi Heavy Industries had to force fit the RSG analysis and designinordertosupportEdison'searlierdesign 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 thatthisisthecorrectto the NRC, Edison said "As discussed in Section 1.3 of that this is the correct approach, and it should have been implemented.*HoweverthisapproachwasHowever, this approach was not applied during the RSG Project. Rather this "multistep process" was thwarted by pyEdison. *No "appropriate engineering and technical evaluation"was performed by Edison when the contractual decision was made that 10CFR§50.59 would not apply.15 StandardTechnicalSpecificationsStandard Technical Specifications License Amendment2009:DuringtheSanOnofreStandardTechnical2009: During the San Onofre Standard Technical Specification License Amendment, Edison identifiedmanareasheretheSanOnofreidentified many areas where the San Onofre Replacement Steam Generator was dramatically different than the Original Steam Generator. 16 San Onofre RSG'sWereNotLike-For-LikeWere Not Like-For-Like17 Edison Identified Numerous San Onofre Design Changes2011 Edison and MHI Report tout all the design changes implemented in the San Onofre RSG:*Remove Stay Cylindergp*Add 377 Tubes*Change Tube Support Structure*Add New Anti-Vibration Bars*DozensMoreChanges*Dozens More Changes-18 SECTION 2 MAGNITUDE OF DESIGN CHANGES19 In and of themselves, Edison's design changes to the Replacement Steam Generators shouldhavetriggeredshould have triggered the 10CFR§50.59 process.20 | | Magnitude of Design Changes SECTION 3: |
| *The San Onofre tubes and tube sheets are part of the containment boundary and are safety related.*San Onofre claimed to the NRC that newimprovedanti-vibrationbarsnew improved anti-vibration bars would reduce wear on these importantcomponentsandwouldnotimportant components and would not adversely impact their design function.21 http://www.fairewinds.com/content/san-onofre's-steam-generator-failures-could-have-been-prevented22 Mitsubishi Heavy Industries Should Not Be The Scapegoat"If the RSGs had been designed and manufactured in eSGsadbeedesgedadauacuedaccordance with the procurement specification, the leak and tube wear would never had occurred."Page 12, 1/9/13 EdisonLettertoNRCEdison Letter to NRC*The replacement steam generator design developed by Mitsubishi-inaccordancewiththelicensee'sdesignMitsubishi - in accordance with the licensees design specification was translated into the same set of design and fabrication drawings. AIT Report, Page 27*No matter who fabricated the RSG's for San Onofre, the tube damage would have occurred. The root causeofthisproblemwasthedesignnotthe23cause of this problem was the design, not the fabrication. | | Conclusions 3 |
| 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%itththdida 15.8% interest, have the same design and material properties as the San Onofre units. During 2003, the Palo Verde Unit 2 steam generators were greplaced."(Edison 2003 Annual Report, Page 21)http://www.edison.com/images/cms_images/c6452_2003_annual_eix_5543.pdf24 Stay Cylinder: Retained On Palo Verde And Eliminated On San Onofre25 EggCrateDesignRetainedOnPaloVerde/Egg Crate Design Retained On Palo Verde/ Eliminated On San Onofre BROACHED TUBE SUPPORTEGG CRATE TUBE SUPPORT26 SanOnofreProblemWasForeseeableSan Onofre Problem Was Foreseeable *Stay Cylinder removal and Tube addition ldhhihfSplaced too much heat in the center of San 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 problemsp*Edison's Design destroyed San Onofre's RSGs27 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 allowed377extratubesdesigned, MHI evaluated the flow patterns and determined that fluid elastic instability (FEI) would not occur."1/9/13 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*TherewasnothingontheMHI 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 patterns would be no FEI."page 17pwere never established.*The 10CFR§50.59 analysis should identify high void ygfractions and confused in/out-of-plane FEI. 29 Friends Of The Earth Consultants Reached ADifft10CFR§5059CliA Different 10CFR§50.59 Conclusion"- 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. *ThetotalityofRSGchangesfunctionPage 9, Edison Response, 1/9/13"The adverse condition that later resulted in the tube leak was a *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."Page9,Edisonside of the tubes that then created the FEI. *Fairewinds and John Large both agreethatitshouldhavebeenwas performed.Page 9, Edison Response, 1/9/13agree 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*Former NRC Chairman Gregory Jaczko promised StdthblilttCSenator Boxer and the public a complete Root Cause Analysis. This has not been conducted.iif*Kepner Tregoe Cause Analysis is severely flawed.*"If they can get you asking the wrong questions, they don'thavetoworryaboutanswers"ThomasPynchondon'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)31Replacement SG(page 43, Condition Report) | | SECTION 1 CHRONOLOGY OF EVENTS 4 |
| What Root Cause Question 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. ThhEdihldhldThe changesEdison should have analyzed and compared are those between the OSG andtheRSGorbetweenSanOnofreandPaloand the RSG or between San Onofre and Palo Verde, since Edison has acknowledged that Palo Verde's RSG is identical to San Onofre's OSGOSG.32 Exclusions From Edison'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 5233 SECTION 3 CONCLUSIONS34 THE CHANGES EDISON MADE CREATED FORESEEABLEPROBLEMSFORESEEABLE PROBLEMSDuringthepasteightyearstheNRChadextensiveDuring 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-likeltfthiildiEdiittdreplacements for the original designs, as Edison committed during the 10CFR50.59 processes. And, as demonstrated by the significant damage in the San Onofre Replacement StGtthdihdidhSteam Generators, the design changes did have a significant impact upon key design functions and in fact degraded the containment boundary.Edison should have notified the NRC that the significance of all the changes required a 10CFR50.59 license amendmentamendment.35 SanOnofreWasA'NearMiss'San Onofre Was A 'Near Miss'ThtbfilThe tube failures at San Onofre aretheworstare the worst nuclear equipment qpfailures since the near miss at Davis Bessie in 2002.36 San Onofre Technical SpecificationsSanOnofreTechnicalSpecificationsstatesSan Onofre Technical Specifications states that the limiting design basis accident is a "doubleendedruptureofasingletube".double ended rupture of a single tube. Page 51037 Edison's San Onofre: dsosSaOoe:Operating Outside Design BasisEight Tubes failed their pressure test, not one! TheevidenceshowsthatSanOnofrewasoperatingThe 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 Report38 Arnie Gundersen, Chief EngineerFiidAitIFairewinds Associates, IncNuclear Engineering, Safety, and Reliability Expert 42-years of nuclear industry experience and oversight ME NEMaster of Engineering Nuclear EngineeringRensselaerPolytechnicInstitute,1972Rensselaer Polytechnic Institute, 1972U.S. Atomic Energy Commission FellowshipThesis: Cooling Tower Plume RiseBSNEBhlfSiNlEiiBS NEBachelor of Science Nuclear EngineeringRensselaer Polytechnic Institute, 1971, Cum LaudeJamesJKerriganScholarJames J. Kerrigan ScholarROLicensed Reactor OperatorU.S. Atomic Energy Commission39License # OP-3014 | | 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 |
| | '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 |
| | 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. |
| | *Howeverthisapproachwas However , this approach was not applied during the RSG |
| | |
| | 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 |
| | §50.59 would not apply. |
| | 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 |
| | *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. |
| | "page 17 p were never established. |
| | *The 10CFR§50.59 analysis should identif y hi g h void ygfractions and confused in/out-of-plane FEI. |
| | 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. |
| | *ThetotalityofRSGchanges function Page 9 , Edison Response, 1/9/13"The adverse condition that later resulted in the tube leak was a |
| | *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. |
| | "Page9,Edisonside of the tubes that then |
| | |
| | created the FEI. |
| | *Fairewinds and John Large both agreethatitshouldhavebeen was performed. |
| | 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 |
| | *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 |
| | '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 |
| | |
| | 2002.36 San Onofre Technical SpecificationsSanOnofreTechnicalSpecificationsstates San Onofre Technical Specifications states that the limiting design basis accident is a "doubleendedruptureofasingletube |
| | ".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. |
| | "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 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}} |
Letter Sequence Meeting |
|---|
|
|
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
[Table View] |
|
|---|
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
[Table view] |
Text
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:
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
'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
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.
- Howeverthisapproachwas However , this approach was not applied during the RSG
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
§50.59 would not apply.
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
- 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
-*The riser column water void above the tube sheet was
also eliminated
- 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.
"page 17 p were never established.
- The 10CFR§50.59 analysis should identif y hi g h void ygfractions and confused in/out-of-plane FEI.
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.
- ThetotalityofRSGchanges function Page 9 , Edison Response, 1/9/13"The adverse condition that later resulted in the tube leak was a
- 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.
"Page9,Edisonside of the tubes that then
created the FEI.
- Fairewinds and John Large both agreethatitshouldhavebeen was performed.
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
- 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
'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
2002.36 San Onofre Technical SpecificationsSanOnofreTechnicalSpecificationsstates San Onofre Technical Specifications states that the limiting design basis accident is a "doubleendedruptureofasingletube
".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.
"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 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
