ML12362A032

LTR-12-0828 - E-Mail Don Leichtling Re Press Release on Causes of Destruction of San Onofre Nuclear Generating Station (Song) Replacement Steam Generators, Requires NRR Complete an Investigation Prior to Any SONGS Unit 2 Restart

ML12362A032
Person / Time
Site:	San Onofre
Issue date:	12/21/2012
From:	Leichtling D - No Known Affiliation
To:	Macfarlane A NRC/Chairman
References
LTR-12-0828
Download: ML12362A032 (7)

Text

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed:-Dec 26, 2012 09:59 PAPER NUMBER: LTR-12-0828 LOGGING DATE: 12/26/2012 ACTION OFFICE: EDO V

AUTHOR: Don Leichtling k'efr-wjn=

AFFILIATION:

ADDRESSEE: Chairman Resource

SUBJECT:

Provides press release - the causes of destruction of San Onofire Nuclear Generating Station (SONGS) replacement steam generators, requires the NRR complete an investigation prior to any SONGS Unit 2 restart ACTION: Appropriate DISTRIBUTION: RF LETTER DATE: 12/21/2012 ACKNOWLEDGED No SPECIAL HANDLING:

NOTES:

FILE LOCATION: ADAMS DATE DUE: DATE SIGNED:

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Mike, Linda From: CHAIRMAN Resource Sent: Friday, December 21, 2012 3:34 PM To: Remsburg, Kristy; Lewis, Antoinette; Mike, Linda

Subject:

FW: Press Release: The Causes Of Destruction of SONGS Replacement Steam Generators (RSGs)...

From: Capt.D [1]

Sent: Friday, December 21, 2012 11:34 AM To: Capt D

Subject:

Press Release: The Causes Of Destruction of SONGS Replacement Steam Generators (RSGs)...

Press Release The DAB Safety Team: December 21, 2012 Media

Contact:

Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261 The Causes Of Destruction of SONGS Replacement Steam Generators (RSGs)

Requires The NRR Complete An Investigation Prior To Any SONGS Unit 2 Restart The DAB Safety Team has transmitted the following request to the Chairman of the NRC, Atomic Safety Licensing Board, NRC Offices of Nuclear Reactor Regulations and Nuclear Regulatory Research. NOTE: All information provided below has been obtained from publicly available documents on the web.

SUMMARY

A Chart (Page 2) comparing the SONGS original steam generators designed by Combustion Engineering and the replacement steam generators reverse engineered by SCE's in-house design team shows why these numerous untested and unanalyzed design changes destroyed both units 2 and 3. SCE made all of these changes in a rush to generate more electricity and more profits at the expense of Public Safety without submitting to a NRC 50.90 License Amendment Process and Evidentiary Public Hearings. MHI as a NEI Qualified, "US Nuclear Power Plant Designer" should have properly reviewed and tested the effects of these ,changes before manufacturing the replacement steam generators. The AREVA report indicates that FEI destroyed Unit 3, not Tube-to-AVB contact forces ALONE as SCE has claimed. NRC Region IV did not appropriately review these design changes in accordance with the 10 CFR 50.59 requirements as stated in the NRC AIT Report. Compare the above RSG debacle to the Palo Verde Nuclear 1

Generating Station's CE replacement steam generators that were designed by Westinghouse and Combustion Engineering, which were later approved by the NRC via a NRC 50.90 License Amendment Process* that have had no RSG problems. DAB Safety Team findings are consistent with several reports issued on this subject by Internationally Known Nuclear Consultant Arnie Gundersen and other Steam Generator Experts. These inconsistencies between the NRC and NRC Region IV do not meet the NRC Public Safety Charter and Mission consistent with President Obama's Open Government initiative and the NRC Chairman Dr. Macfarlane's public statements.

• Please see http://www.nrc.qov/reactors/operatinq/licensinq/power-uprates/pwr-stretch/palo-verde2-pu.html, the DAB Safety Team's The Big Number 1 Attachment and San Onofre Papers for more details.

1. Comparison of Original SG's to SCE's Unsafe Replacement SG's:

• Design and Performance Specifications: Based on a review of SONGS Return to Service Report, Enclosure 2 and SCE Unit 3 Root Cause Evaluation Report, the following table shows the design and performance specifications changes between the SONGS Original Combustion Engineering (OSGs) and Replacement Steam Generators (RSGs) 0 Design Parameter CE OSGs SCE RSGs Is the Change Adverse Thermal Power, MWt 17053 17291 Yes Steam Pressure, psia 1 900 833 Yes Interstitial Velocity ft/sec2 22.9 22.1 N/A Steam Moisture Content' < 0.20% < 0.10% Yes Maximum Void Fraction2 99.6% 96.1% Yes Number of Tubes 1 9350 9727 Yes Top of the Bundle' 381.0 inch 388.2 inch Yes 1 SCE Unit 3 Root Cause Evaluation 2SONGS Return to Service Report, Enclosure 2, Value selected from Westinghouse and Independent ATHOS Thermal-Hydraulic Computer Modeling results 3 SCE Combustion Engineering Model 3410 OSGs Specifications 2

2. NRC AIT Report states, "The combination of unpredicted, adverse thermal hydraulic conditions and insufficient contact forces in the upper tube bundle caused a phenomenon called 'fluid-elastic instability' which was a significant contributor to the tube to tube wear resulting in the tube leak." The team concluded that the differences in severity of the tube-to-tube wear between Unit 2 and Unit 3 may be related to the changes to the manufacturing/fabrication of the tubes and other components which may have resulted in increased clearance between the anti-vibration bars and the tubes; (3)

Due to modeling errors, the SONGS replacement generators were not designed with adequate thermal hydraulic margin to preclude the onset of fluid-elastic instability. Unless changes are made to the operation or configuration of the steam generators, high fluid velocities and high void fractions in localized regions in the u-bend will continue to cause excessive tube wear and accelerated wear that could result in tube leakage and/or tube rupture; (4) The thermal hydraulic phenomena contributing to the fluid-elastic instability is present in both Unit 2 and 3 steam generators; (5) Based on the updated final safety analysis report description of the original steam generators, the steam generators major design changes were appropriately reviewed in accordance with the 10 CFR 50.59 requirements.

Where are (1) and (2) & why were they left out?

3. Summary of MHI, AREVA, Westinghouse, and DAB Safety Team Reports:

• Fluid Elastic Instability (FEI), Flow-induced Random Vibrations (FIRV) and Mitsubishi Flowering Effect (MFE) destroyed Unit 3. FIRV and MFE destroyed Unit 2.

The causes are as follows:

> Steam Pressures, RSGs, 833 psia (OSGs - 900 psia): Effect - Adverse Design/Operational Changes to produce more electricity in RSGs than OSGs - Caused FEI (void fraction >=99.6%) in Unit 3 only, Unit 2 was operating at higher pressures (between 863-942 psia), which resulted in void fractions less than 98.5% (Please see DAB press release dated December 19, 2012, "SCE's Conflicting, Contradicting & Catastrophic Statements" for details)

> Steam moisture Content %, RSGs, < 0.10 (OSGs - < 0.20): Effect - Adverse Design Change -

Required NRC 10 CFR 50.90 License Amendment and Evidentiary Public Hearings - Caused FEI (void fraction, >=99.6%) in Unit 3 only. Unit 2 was operating at higher pressures than Unit 3 (between 863-942 psia), which resulted in void fractions less than 98.5%

> Number of Tubes, RSGs, 9727 Tubes (OSGs - 9350 tubes): Effect - Adverse Design Change to produce more electricity in RSGs than OSGs, Required NRC 10 CFR 50.90 License Amendment and Evidentiary Public Hearings) - Caused FIRV and MFE in Units 2 and 3 due to narrow tube to pitch diameter

> Tube Length, RSGs, 7.2 inches added to ALL 9727 Tubes (OSGs - 381.0 inches): Effect -

Adverse Design Change to produce more electricity in RSGs than OSGs, Required NRC 10 CFR 50.90 License Amendment and Evidentiary Public Hearings - Caused FIRV and MFE in Units 2 and 3 3

Thermal Power MWt, RSGs 1729 (OSGs - 1705)

Effect - Adverse Design Change to produce more electricity in RSGs than OSGs, NO Required NRC 10 CFR 50.90 License Amendment and Evidentiary Public Hearings) - Caused FIRV and MFE in Units 2 and 3 FEI destroyed Unit 3, not Tube-to-AVB contact forces ALONE as SCE states, because: (1)

Westinghouse states that none of the MHI fabrication issues were extensively analyzed in the SCE root cause evaluation, and (2) AREVA states, "The primary source of tube-to-AVB contact forces is the restraint provided by the retaining bars and bridges, reacting against the component dimensional dispersion of the tubes and AVBs. Contact forces are available for both cold and hot conditions. Contact forces significantly increase at normal operating temperature and pressure due to diametric expansion of the tubes and thermal growth of the AVI3s. After fluid elastic instability develops, the amplitude of in-plane motion continuously increases and the forces needed to prevent in-plane motion at any given AVB location become relatively large. Hence shortly after instability occurs, U-bends begin to swing in Mode 1 and overcome hindrance at any AVB location," and (3) According to MHI Technical Reports, Unit 3's SG manufacturing process used more accurate and tighter tolerances which improved alignment such that tubes had more contact with AVB's.

4. Unless the NRR investigates the above changes, how can the NRC make a correct decision on Unit 2's restart is in the interest of Public Safety commensurate with Dr. Macfarlane's public statements: (1) SCE is responsible for the work of its vendors and contractors, and (2) There are a number of lessons that have come from the Fukushima tragic accident that are important for all countries with nuclear power reactors including: the importance of an independent regulator that operates in an open and transparent manner; the need for measures to prevent and mitigate severe accidents that displace people or contaminate land; and the significance of international cooperation to share experience and expertise to strengthen nuclear safety and security worldwide.

The DAB Safety Team seeks to assist NRR and NRC in making the right decision.

Glossary of Terminology:

AIT: NRC's Augmented Inspection Team ATHOS: A computer modeling program for predicting thermal hydraulic conditions AVB: Anti-Vibration Bar CE: Combustion Engineering (OSG manufacturer)

CFR: Code of Federal Regulations DAB: DAB Safety Team 4

ECT: Eddy Current Testing FEI: Fluid Elastic Instability FIRV: Flow Induced Random Vibration (aka FIV)

FIV: Flow Induced Vibration ft: Feet GDC: General Design Criteria MHI: Mitsubishi Heavy Industries (RSG manufacturer)

MFE: Mitsubishi Flowering Effect MWt: Megawatts Thermal NEI: Nuclear Energy Institute, a coalition of for-profit nuclear corporations NRC: Nuclear Regulatory Commission NRR: [Office of] Nuclear Reactor Regulations OSG: Original SG psia: Pounds per Square Inch Atmospheric (pressure)

RC: Reactor Coolant RCPB: RC Pressure Boundary (includes SG tubes and all other RC boundaries)

RSG: Replacement SG SCE: Southern California Edison sec: Seconds SG: Steam Generator SONGS: San Onofre Nuclear [Waste] Generating Station TTW: Tube-to-Tube Wear This press release will be posted on the web at this link: San Onofre Papers.

The DAB Safety Team: Don, Ace and a BATTERY of safety-conscious San Onofre insiders plus industry experts from around the world who wish to remain anonymous. These volunteers assist the DAB Safety Team by sharing knowledge, opinions and insight but are not responsible for the contents of the DAB Safety Team's reports. We continue to work 5

together as a Safety Team to prepare additional San Onofre Papers, which explain in detail why a SONGS restart is unsafe at any power level without a Full/Thorough/Transparent NRC 50.90 License Amendment and Evidentiary Public Hearings. For more information from The DAB Safety Team, please visit the link above.

Our Mission: To prevent a Trillion Dollar Eco-Disaster, like Fukushima, from happening in the USA.

Copyright December 20, 2012 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team. The contents cannot be altered without the Written Permission of the DAB Safety Team Leader and/or the DAB Safety Team's Attorneys.

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