ML13016A092
| ML13016A092 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/16/2013 |
| From: | Fairewinds Associates |
| To: | Plant Licensing Branch IV, Friends of the Earth |
| Benney B J | |
| Shared Package | |
| ML13016A077 | List: |
| References | |
| G20120891, TAC MF0060, TAC MF0061 | |
| Download: ML13016A092 (39) | |
Text
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
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
- 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.
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)
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