ML13003A184
| ML13003A184 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/02/2013 |
| From: | Leichtling D, Hoffman A The Animated Software Co, The DAB Safety Team |
| To: | NRC/Chairman |
| References | |
| LTR-13-0003 | |
| Download: ML13003A184 (10) | |
Text
OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed:Jan 02, 2013 17:12 PAPER NUMBER: LTR-13-0003
.ACTION OFFICE:
'TO Lff-i fkPp Don Leichtling, et al.
AUTHOR:
CA f "f(ZLý CL-00 AFFILIATION:
ADDRESSEE: Chairman Resource
SUBJECT:
Concerns press release - the NRC AIT Team's review of San Onofre Nuclear Generating Station's original steam generators and their replacement steam generators require another immediate investigation ACTION: Appropriate DISTRIBUTION: RF LETTER DATE: 01/02/2013 ACKNOWLEDGED No SPECIAL HANDLING:
NOTES:
FILE LOCATION: ADAMS DATE DUE: DATE SIGNED:
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Joosten, Sandy From: Capt.D [captddd@gmail.com]
Sent: Wednesday, January 02, 2013 2:46 PM To: Capt D
Subject:
Press Release + 13-01-02 Supplemental: NRC Region IVAIT Team's SG Review Requires Another Immediate NRR Investigation Press Release + 13-01-02 Supplemental To Our Press Release + 12-12-31 The DAB Safety Team: January 2, 2013 Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261 The NRC AIT Team's Review Of The SONGS Original Steam Generators (OSGs) And Their Replacement Steam Generators (RSGs) Requires Another Immediate NRR Investigation The DAB Safety Team has transmitted the following to the Chairman of the NRC, Offices of Nuclear Regulator Regulations, Atomic Safety Licensing Board and NRC AIT Team Chief.
NRC Office of Nuclear Reactor Regulation has requested Edison in a December 26, 2012 letter the following additional information (RAI #32): "Please clarify how the information submitted by SCE demonstrates: (1) that the structural integrity performance criterion in TS 5.5.2.11.b.1 is met for operation within current licensed limits up to the licensed Rated Thermal Power (RTP or 100%
Power), or (2) provide an operational assessment that includes an evaluation of steam generator Tube-to-Tube Wear (TT-W) for operation up to the RTP."
OSGs Design: The SONGS OSG design had shown to be susceptible to out-of-plane tube through-wall wear and severe corrosion of the tube supports. The maximum Stability Ratio calculated by SCE Engineers in 2001 Power Uprate Application was 0.675 (< 1 so no Fluid Elastic Instability (FEI)).
According to Enclosure 2 of SONGS Unit 2 Return to Service Report, OSGs were operating at 1709 MWt (Reactor Thermal Power or RTP), vapor fraction (96.1 %), Interstitial or gap velocity of 22.9 feet/second.
DAB SAFETY Team Comments. re: OSGs Design: The OSGs operated for 28 years, did not experience abnormal tube leak or-tube-to tube wear (TTW) for operation up to 1709 RTP. No FEI occurred (stability ratio <1). Furthermore, the OSG FSAR analyses demonstrated that the offsite radiological release doses due to an OSG tube rupture, main steam line break or an inadvertent opening of an OSG Atmospheric Dump valve with single active failure were at the time, well within the federal 10CFR100 guidelines.
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St I SCE Profit-Motivated RSGs Design Changes: According to Enclosure 2 of SONGS Unit 2 Return to Service Report, the SONGS RSGs RTP specifications were changed to 1729 MWt. To accommodate this additional 20 MWt, SCE engineers changed the vapor fraction (99.6%), Interstitial or gap velocity of 28.3 feet/second, added 377 additional tubes and increased the length of each tube by more than 7 inches. NRC AIT Team report states, "SCE Design Specification S023-617-1 did not address specific criteria for stability ratio and does not mention fluid-elastic instability." Note: All these changes were made: (1) In a rushed "hush-hush" manner to generate extra profits for SCE and its Shareholders, (2) SCE Engineers prepared a defective 10CFR 50.59 safety evaluation hiding these numerous untested and unanalyzed changes under the pretense of "like for like" between the OSGs and the RSGs. Then they convinced NRC Region IV to review these without a formal NRC 50.90 License Amendment Process and Evidentiary Public Hearings.
NRC AIT Team review of SCE 10CFR 50.59: The NRC AIT Team stated in its report, "Based on the updated final safety analysis report description of the original steam generators, the team determined that the steam generators major design changes were reviewed in accordance with the 10 CFR 50.59 requirements. The team determined that no significant differences existed in the design requirements of Unit 2 and Unit 3 replacement steam generators. Based on the updated final safety analysis report description of the original steam generators, the team determined that the steam generators major design changes were reviewed in accordance with the 10 CFR 50.59 requirements. The NRR technicalspecialists reviewed SCE's 10 CFR 50.59 evaluation against 10 CFR 50.59(c)(2)(viii) which requires that licensees obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change if the change would result in a departure from a method of evaluation described in the final safety analysis report (as Updated) used in establishing the design bases or in the safety analyses. The NRR technical specialistsfound two instances that failed to adequately addresswhether the change involved a departureof the method of evaluation described in the updatedfinal safety analysis report." (emphasis added) The changes were as follows: (a) Reactor Coolant System Structural Integrity - Use of ABAQUS Computer Program instead of ANSYS: The SCE's 50.59 evaluation incorrectly determined that using the ABAQUS instead of ANSYS was a change to an element of the method described in the updated final safety analysis report did not constitute changing from a method described in the updated final safety analysis report to another method, and as such, did not mention whether ABAQUS has been approved by the NRC for this application. (b) Main Steam Line Break Mass-Energy Blowdown Analysis & Tube Wall Thinning Analysis - Use of ANSYS Computer Program instead of STRUDL and ANSYS Computer Programs: SCE's 50.59 evaluation did not mention whether the method has been approved by NRC for this application.
The DAB Safety Team's Comment's re: SCE RSGs Catastrophic Design Changes: About a year ago, on January 31, 2012, in SONGS Unit 3, one tube started leaking radioactive coolant in one of brand new replacement steam generators (RSG's) E-088 that was reverse-engineered by SCE and manufactured by a complacent Mitsubishi Heavy Industries (MHI). The leak started small, but increased enough in a very short period of time to warrant the emergency shutdown of the reactor.
When tested later (in March 2012), eight (8) steam generator tubes (wear range 72-100%, length of wear 23-34 inches) in the newly replaced San Onofre Unit 3 RSG E-088 failed "in-situ" main steam line break pressure testing and therefore were plugged, after only after 11 months of operation, something that had never happened before in the history of the US Nuclear fleet. Additionally, 2
several hundred of the Alloy 690 Thermally Treated tubes were also plugged due to tube-to-tube wear. SONGS RSG's now have more damaged and/or plugged tubes than all the rest of the US reactor fleet combined. Southern Californians were very lucky, because a potentially serious nuclear accident in Unit 3 was narrowly avoided. This accident could have potentially caused a nuclear meltdown and threatened the health and safety, economy and environment of Southern California.
NRC website also states, "The severity of one of the wear indications at a Unit 2 (steam generatortube to*) retainer bar was significant enough (90 percent thru-wall) to warrant in-situ pressure testing. This pressure test confirmed the structural integrity of this tube (there was no leakage)." This means that Southern Californians lucked out again, because Unit 2 just happened to be shutdown for refueling, otherwise, this tube could have also leaked radiation due to any design bases accident or unanticipated transients. Finally, the NRC AIT Team displayed poor judgment in their review of SCE's 10 CFR 50.59 Evaluation and the NRR Specialists wisely questioned the inadequacy SCE's 10 CFR 50.59 Evaluation. The NRR now needs to review the NRC AIT Teams' failure to enforce NRC Regulations and find out what exactly happened to ensure the Public Safety.
- Wording added for clarification DAB SAFETY Team Comments to NRR RAI#32: By operating the "Defectively Designed and Degraded" Unit 2 Replacement Steam Generators (RSGs) at 100% Reactor Thermal Power:
(1) SCE CANNOT DEMONSTRATE [with all the World's Expert's Assistance - emphasis added]
that ALL in-service RSG tubes would retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, cool down and all anticipated transients included in the design specification) and design basis accidents in accordance with SONGS Unit 2 Technical Specifications structural integrity performance criterion in TS 5.5.2.11.b.1.
(2) SCE CANNOT PROVIDE AN ACCEPTABLE OPERATIONAL ASSESSMENT TO THE NRC, which demonstrates that steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP would not cause a tube leak in order to comply with Code of Federal Regulations, 10 CFR Part 50 Appendix A, General Design Criteria 14, "Reactor Coolant Pressure Boundary-shall have "an extremely low probability of abnormal leakage... and gross rupture."
Please See DAB Safety Team Paper Response to NRR RAI #32 - Technical for additional details.
This press release will be posted on the web at this link: DAB Safety Team Documents.
ABBREVIATIONS AND ACRONYMS:
- AIT: NRC's Augmented Inspection Team
- AVB: Anti Vibration Bar 3
. CE: Combustion Engineering, builders of SONGS original steam generators
- CNO: Chief Nuclear Officer
- DAB: DAB Safety Team
- FEI: Fluid Elastic Instability
" MHI: Mitsubishi Heavy Industry
- MSIV: Main Steam (line) Isolation Valve
" MSLB: Main Steam Line Break
- MWt: Mega-Watts Thermal
- NRC: Nuclear Regulatory Commission
- NRR: NRC's Office of Nuclear Reactor Regulations
- PVNGS: Palo Verde Nuclear Generating Station
- QA: Quality Assurance
" RAI: Request Additional Information
- RSG: Replacement Steam'Generator
" RTP: Reactor Thermal Power
- SCE: Southern California Edison
- SG: Steam Generator
" SONGS: San Onofre Nuclear (Waste) Generating Station (alternate abbreviation: SONWGS)
- TS: Technical Specifications (for operation of a NPP)
- TTW: Tube-to-Tube Wear 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 together as a Safety Team to prepare additional DAB Safety Team Documents, 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.
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Copyright January 1, 2013 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 Attorney 5
Joosten, Sandy From: Ace Hoffman [rhoffman@animatedsoftware.com]
Sent: Monday, December 31, 20.12 7:14 PM
Subject:
Press Release + 12-12-31 Office of Nuclear Reactor Regulations RAI #32 Request Press Release (Condensed Version)
The DAB Safety Team: December 31, 2012 Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261 NRR Requests Additional Information on SCE's San Onofre Unit 2 Restart Proposal The DAB Safety Team has transmitted the following to the Chairman of the NRC, Offices of Nuclear Regulator Regulations (NRR), Atomic Safety Licensing Board and NRC AIT Team Chief.
NRC Office of Nuclear Reactor Regulation has requested from Edison in a letter dated December 26, 2012, the following additional information (RAI #32): "Please clarify how the information submitted by SCE demonstrates: NRRRAI#32(1) that the structural integrity performance criterion in TS 5.5.2.11.b.1 is met for operation within current licensed limits up to the licensed Rated Thermal Power (RTP or 100% Power), or NRRRAI#32(2) provide an operational assessment that includes an evaluation of steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP."
Answer to NRRRAI#32(1): As shown in the linked Response to NRR RAI #32 - Technical, by operating the "Defectively Designed and Degraded" Unit 2 Replacement Steam Generators (RSGs), SCE CANNOT DEMONSTRATE [with all the World's Expert's Assistance - emphasis added] that ALL in-service RSGs tubes would retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, cool down and all anticipated transients included in the design specification) and design basis accidents in accordance with SONGS Unit 2 Technical Specifications structural integrity performance criterion in TS 5.5.2.11.b.1.
Answer to NRRRAI#32(2): As shown in the linked Response to NRR RAI #32 - Technical, SCE CANNOT PROVIDE AN ACCEPTABLE OPERATIONAL ASSESSMENT TO THE NRC, which demonstrates that steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP would not cause a tube leak in order to comply with Code of Federal Regulations, 10 CFR Part 50 Appendix A, General Design 1
Criteria 14, "Reactor Coolant Pressure Boundary-shall have "an extremely low probability of abnormal leakage... and gross rupture."
Press Release (Complete Version) + 12-12-31 NRR RAI #32 Request Snip:
NOTE: Here are the 14 most important questions that the DAB Safety Team feels must be answered before theNRC, Atomic Safety Licensing Board, NRC Offices of Nuclear Reactor Regulations and Nuclear Regulatory Research can complete their investigation regarding the reasonableness of the actions of SCE with respect to SONGS steam generator replacements and their subsequent safe operation:
1 - According to some Newspaper Comments and Industry Reports in 2004, the going price for each of the four 620 Ton CE Replacement Steam Generator (RSG's) was estimated to be between 175-200 Million Dollars (Per Piece). How did SCE CNO/President in 2004 convince MHI to build such large, complicated, innovative and complex-steam generators for 569 million dollars, which is almost 130 million dollars short of the market price and funds approved by CPUC?
Note: The steam generator project execution began in 2004 after a SCE cost-benefit analysis, which revealed that replacement of major parts and components would save $1bn for Southern California Edison customers during the plant's license period. Instead, the ratepayers have lost $1bn in less than 2 years due to SCE's in-house design team's mistakes.
2 - Since MHI only had experience building Fort Calhoun's tiny RSG's (less than 320 tons), how did the SCE Engineers Technically Qualify MHI for the much larger RSGs?
3 - Which other utilities' QA Programs did SCE use to approve Mitsubishi's quality assurance program?
Fort Calhoun? French? Belgian? Japanese?
4 - Why didn't SCE apply to NRC for increasing the plugging limit for the Original CE Generators, so they would have had more time to think, research and not rush according to the CPUC?
5 - Which Utilities' CE Replacement Generators did SCE benchmark to develop such detailed design and performance specifications or did they just modify the CE Old Generator Specifications with New Industry Information? Were the SCE engineers, who wrote, checked and approved the new specifications steam generator experts or was another steam generator expert in the background, who directed all the SCE work?
6 - Where did all the claims of challenges, reward, innovations and teamwork between SCE and MHI go wrong?
7 - Were the SCE Engineers sent to Japan to check MHI work and approve documents/test results qualified in that exact field, or they were just in training and/or sightseeing?
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8 - Who at SCE made the decision to make all these numerous design changes and determined the changes were "Like for Like" and did not need a Licensing Amendment Process?
9 - Which SCE Engineer(s) provided all these changes, information and documents to which NRC Engineer(s), who then made the decision that it was OK to proceed without a full Licensing Amendment Process?
10 - Which SCE engineer(s) approved/validated the MHI Thermal-Hydraulic FIT-III FIVATS code Inputs and Calculations?
11 - To make up for the 10% heat transfer equivalent by switching from Alloy 600 to Alloy 690, SCE needed to add 935 tubes, but they only added 377 tubes. What happened to the balance of 558 tubes? Did the SCE Engineers tell MHI to increase the length of 9727 tubes and by how much, to make up for the 558 tubes?
12 - Why didn't the SCE Engineers question/independently verify/validate the MHI benchmarking of the FIT-III thermal-hydraulic model?
13 - Why didn't the SCE engineers contact their counterparts at PVNGS for information/advice, since PVNGS has the largest CE Replacement Generators (800 Tons) in the world, were built in early 2001-2005 and are currently still in operation?
14 - Were the original CE Steam Generators and new replacement generators exact in Thermal Output (MWt) or were there "minor" differences?
Under no circumstances should the NRC Region IV, Offices of Nuclear Reactor Regulation and Nuclear Regulatory Research*, and the NRC Atomic Safety Licensing Board permit SCE to restart unit 2 without re-tubing or replacing the defective replacement steam generators, along with a full NRC 50.90 Licensing Amendment and transparent trial-like public hearings.
- The DAB Safety Team would like to extend a Professional Compliment to the NRR for doing a thorough investigation on their review of the San Onofre Unit 2 Restart Proposal as indicated by their Request for Additional Information #32.
ABBREVIATIONS AND ACRONYMS:
AIT: NRC's Augmented Inspection Team AREVA: Nuclear engineering firm owned by French Atomic Energy Commission AVB: Anti Vibration Bar CE: Combustion Engineering, builders of SONGS original steam generators CNO: Chief Nuclear Officer CPUC: California Public Utilities Commission DABST: DAB Safety Team 3
FEI: Fluid Elastic Instability MHI: Mitsubishi Heavy Industry MSIV: Main Steam (line) Isolation Valve MSLB: Main Steam Line Break MWt: Mega-Watts Thermal NRC: Nuclear Regulatory Commission NRR: NRC's Office of Nuclear Reactor Regulations PVNGS: Palo Verde Nuclear Generating Station QA: Quality Assurance RAI: Request Additional Information RSG: Replacement Steam Generator RTP: Reactor Thermal Power SCE: Southern California Edison SG: Steam Generator SONGS: San Onofre Nuclear (Waste) Generating Station (alternate abbreviation: SONWGS)
TS: Technical Specifications (for operation of a NPP)
TTW: Tube-to-Tube Wear This press release along with DAB Safety Team's Response to NRR RAI #32 - Technical 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 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 31, 2012: The DAB Safety Team. All rights reserved. This material cannot be published, broadcasted and/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.
- Ace Hoffman, Owner & Chief Programmer, The Animated Software Co.
- POB 1936, Carlsbad CA 92018
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