ML13017A047

LTR-13-0046 - E-Mail Don Leichtling Provides Media Alert 13-01-15 - Allegation - SCE Violated Federal Regulation and the Public Trust. Expert Summation - San Onofre'S Replacement Steam Generators Unsafe

ML13017A047
Person / Time
Site:	San Onofre
Issue date:	01/15/2013
From:	Leichtling D The DAB Safety Team
To:	NRC/Chairman
References
LTR-13-0046
Download: ML13017A047 (4)

Text

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: Jan 16, 2013 10:04 PAPER NUMBER: LTR- 13-0046 LOGGING DATE: 01/15/2013 ACTION OFFICE:

EDeO ýToxd,?T-Oa-b AUTHOR: Don Leichtling AFFILIATION:

ADDRESSEE: Chairman Resource

SUBJECT:

Provides media alert 13-01 Allegation - SCE violated Federal Reg.'s and the public trust.

Expert summation - San Onofre's replacement steam generators unsafe ACTION: Appropriate DISTRIBUTION: Chairman, Commissioners, OIG LETTER DATE: 01/15/2013 ACKNOWLEDGED No SPECIAL HANDLING: Immediate public release via SECY/EDO/DPC. (Note: Sender.has this on web site)

NOTES:

FILE LOCATION: ADAMS DATE DUE: DATE SIGNED:

, a Joosten, Sandy From: Capt.D [captddd@gmail.com]

Sent: Tuesday, January 15, 2013 12:18 PM To: Capt D

Subject:

Media Alert ==> Allegation - SCE Violated Federal Reg.'s And the Public Trust Media Alert 13-01-15 Allegation - SCE Violated Federal Reg.'s And the Public Trust Media

Contact:

Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261 Expert Summation - San Onofre's Replacement Steam Generators Unsafe The DAB Safety Team has transmitted the above Allegation to the Chairman of the NRC and Senator Barbara Boxer's Committee on Environment and Public Works (EPW).

Summation: Based upon our ongoing review of evaluations, engineering analyses, inspections, technical and operational assessment reports prepared by the NRC's Augmented Inspection Team, MHI, SCE, Westinghouse, AREVA, Professor Daniel Hirsch, industry experts and knowledgeable whistle blowers, along with the recent affidavits prepared by Arnie Gundersen and John Large, we reaffirm the following statements which have been previously substantiatedin numerous DAB Safety Team Documents:

1. DAB Safety Team has been saying for months in several San Onofre Papers and Press Releases that SCE and MHI Engineers did a very poor job in review of Academic Research Papers and Industry Benchmarking on how to prevent the adverse effects of fluid elastic instability during the design stages of replacement steam generators. The original Combustion Engineering steam generators did not experience the adverse effects of fluid elastic instability. NRC AIT Report states," The team noted that Design Specification S023-617-1 did not address specific criteria for stability ratio and does not mention fluid-elastic instability." SONGS Insiders told SCE Management in an Anonymous Notification in June 2012, "Inadequate Design Change Process POTENTIALLY produced super-heated steam, which caused potential void fractions in the Unit 3 SG E088 Upper U-Tube region wear areas as high as 99.5%. With the top of the U-tubes almost dry in this region due to the super-heated steam, there was less damping energy available to stop the tubes from vibrating and hitting each other and supports. The combination of adverse thermal-hydraulic conditions and lack of effective tube AVB supports resulted in a severe fluid-elastic instability consequence (FEI > 1).

This condition was not predicted by the MHI computer modeling methods used for the design of the SONGS steam generators.

SONGS SG FEI is a consequence of Inadequate Design process used by MHI and not the ROOT CAUSE of the U3 SG E088 leak." Mitsubishi in Unit 2 Return to Service Report, Attachment 4, states, "The SONGS RSGs were specified, designed and fabricated as replacements on a like-for-like basis for the original steam generators in terms of fit, form and function with limited exceptions, and were replaced under the 10CFR50.59 rule. MHI investigated field experience with U-bend tube degradation using INPO, NRC and NPE data bases, and concluded that tube wear in the operating U-tube SGs was mostly being caused by out-of-plane tube motion. Consistent with this and Reference 7, only out-of-plane vibration of the SG U-tubes was evaluated because tube U-bend natural frequency in the out-of-plane direction is lower than natural frequency in the in-plane direction and out-of-plane vibration is more likely to occur than in-plane vibration. No SG problems stemming from in-plane tube motion were identified by MHI and thus MHI concluded that the design and fabrication processes described above were sufficient for minimizing tube wear in the SONGS RSGs." John Large statesA, "Ihave little confidence in the outcome of AREVA's projection of the time period through which the U2 nuclear plant could be reliably expected to operate without incurring a tube failure or running at a greater risk of a tube failure occurring. Section 5.8.20: This is because: Section 5.8.21, i) the root cause leading to TTW is the omission in the design of the AVB features to cope with in-plane motion of the tubes - since this was not specified at the design stage, the in-plane effectiveness of the AVBs is, essentially, something acquired by chance, being highly variable and inconsistent from one AVB to another; Section 5.8.22, ii)the key assumption that the AVB tube capturing friction force can be reliably deduced indirectly by the 1

eddy current probe reading of the AVB-to-tube gaps, for thousands of AVB-tube locations, is not at all robust; Section 5.8.23, iii) there are similar, indeed, if not greater difficulties in applying such measurements made when the RSG is cold and depressurized, to the RSG when it is in service, that is hot and pressurized, particularly when it is acknowledged that thermal-pressure distortion (flowering) is an acknowledged in-service phenomenon in the higher U-bend region of the tube bundle; and Section 5.8.24, iv) even if these uncertainties can be resolved, which in my opinion is highly unlikely, there must remain strong doubts about the quality assurance at the MHI manufacturing and procurement plants if, that is, the recent NRC Non-conformance Notice relating to the tubing for RSG mock-ups currently being evaluated by MHI, were to have equally applied to the manufacture of the tubes installed in the U2 RSGs. Section 5.7.52, v) as I have previously noted, this type of AVB assembly was not designed to provide effective restraint in the in-plane direction so, it follows, no specific contact and friction force levels were specified at the onset or, put simply, in-plane tube motion was not foreseen at the design stage so nothing was put in place to counter it. A complete understanding of the causation of the in-plane FEI is essential to ensure that the SONGS Unit 2 plant is acceptably safe to restart and, once restarted, predictably safe to continue in operation over the proposed 150 day inspection interval. To the contrary, the understanding presented by SCE is neither comprehensive nor convincing. In my opinion, simply sweeping the FEI issue under the carpet on the basis of (in- or out-of-plane) FEI will not reoccur at 70% power is not only disingenuous but foolhardy. " NRC chairman has publicly stated, "SCE is responsible for the work of its vendor and its contractor." The bottom line is that SCE Root Cause Evaluation is incorrect and SCE alone is held responsible for the "Billion Dollar Debacle" of Replacement Steam Generator.

DAB Safety Team alleges that SCE actions are in violation of the Federal Regulations, its CPUC Charter, the NRC Chairman Standards and even its own advertised charter of "Overriding Obligationsto Shareholdersand Public Safety."

2. Design Basis Accidents involving steam generator (SG) depressurization (main steam line break), station blackout (SBO) and anticipated transients without scram (ATWS) events causing SG over-pressurization can occur at any time over the full range of normal operating conditions up to Reactor Thermal Power (3438 MWs). Any of these adverse conditions can cause 100% vapor fraction (steam voids, dry-outs, tube-to-tube wear or fluid elastic instability (FEI)*) in the defectively designed and already degraded SG U-tube bundles. Therefore BY DESIGN, these SG U-tube bundles and their anti-vibration bar structures/restraints are NOT capable of protecting these SG worn and cracked tubes from radioactive leakages and/or ruptures caused by the adverse effects of fluid elastic instability, flow-induced random vibrations and excessive hydrodynamic pressures.

3. In Unit 2, these already fatigued, cracked, and heavily degraded tubes can snap, leak and/or rupture at the tube sheet, tube support plate or the unsupported anti-vibration bars mid and free spans during these postulated adverse accident conditions. John Large statesA, "For the MSLB event very high, two-phase fluid cross-flow velocities would be expected to instantaneously develop in the U-bend region, triggering vigorous FEI that could, particularly if the AVB restraints are ineffective, promote violent tube to tube clashing and the potential for a multiple tube failure event."

4. It is ABSOLUTELY CLEAR, that San Onofre Unit 2 RSGs will likely experience single to multiple tube-to-tube failures (e.g.,

San Onofre Unit 3, Mihama Unit 2, North Anna, Indian Point 2 and Craus, France, etc.) during these postulated adverse licensed conditions at any power level up to 100% Power (Licensed Reactor Thermal Power of 3438 MWTs).

5. The proposed Defense-in-Depth instrumentation, along with unreliable and unproven operator actions to detect multiple tube leaks/ruptures and/or to re-pressurize the steam generators during these postulated adverse licensed conditions as claimed by Edison are not practical to stop a major nuclear accident from progressing and causing a Unit 2 meltdown.

6. There are conflicting, contradicting, ambiguous and confusing findings between the Unit 2 Operational Assessments: From AREVA that AVB-to-tube and TTW result from in-plane FEI, contrasted to Westinghouse that there is no in-plane FEI but most probably it was out-of-plane FEI, and from MHI that certain AVB-to-tube wear results in the absence of in-plane FEI from just turbulent flow and SCE (FEI Most Likely, May Be, or Alternatively, Not Sure....). Such conflicting disagreements over the cause of TTW reflects poorly on the depth of understanding of this crucially important FEI issue by SCE, each of these SCE consultants and the designerlmanufacturer of the RSGs. The DAB Safety Team's findings contradict the SCE and all the three NEI qualified, "US Nuclear Plant Designers" findings about Unit 2 FEI (See, Overview - Consequences of a Main Steam Line Break).

7. The DAB Safety Team Comments about SCE 10 CFR 50.59 Safety Evaluation for RSGs: The Big Number 1 Attachment Notes shows the comparison between SONGS and Palo Verde Nuclear Generator Station (PVNGS) Replacement Steam Generators (RSGs) design parameters. Please note that changes between SONGS and PVNGS RSGs are similar. PVNGS has the largest CE RSGs in the world (- 800 Tons each) and SONGS RSGs are the second largest CE RSGs in the world (- 620 Tons each).

SCE and Arizona Public Service Company are partners in the PVNGS. PVNGS applied for a 10 CFR 50.90 License Amendment to the NRC for their RSGs. Palo Verde RSGs have operating for almost 10 years and have had very little damage compared to SONGS. Yet SCE Claims, since the early 1980s, steam generator replacements have been implemented under 10 CFR 50.59 without a license amendment, that is a very misleading and erroneous statement. John Large statesA, "In my opinion, the changes, tests and experiments (CTE) inherent in the SCE proposal to restart Unit 2: (a) involve a significant increase in the probability or consequences of an accident previously evaluated; (b) create the possibility of a new or different kind of accident previously evaluated; and (c) involve a significant reduction in a margin of safety. Arnie Gundersen statesB, "It is my professional opinion that Edison should have applied for the 50.59 process so that the FSAR license amendment evaluation and public hearings would have occurred six years ago, prior to creating an accident scenario and facing losses that by the end of this process will easily total more than $1 Billion." Therefore, the DAB Safety Team concludes that SCE claims as stated are not factual. SCE did not meet the 10CFR50, Appendix B, Quality assurance Standards and has violated the NRC 10 CFR 50.90 Regulations.

8. The Public expects that the Offices of Nuclear Reactor Regulation (NRR) comply with President Barack Obama, Senator 2

I .. ., .

Barbara Boxer and NRC Chairman's Open Government Initiative. Under no circumstancesshould the NRR permit SCE to restartunit 2 without replacingthe defective replacementsteam generators,a full NRC 50.90 Licensing Amendment and transparenttrial-like public hearings.

• FEI or high vapor fractions (> 99% vapor by volume in a steam-water two phase mixture, aka steam dry-outs) are generally caused by a combination of low steam generator pressures, high steam flows, fluid velocities and narrow clearances (aka tube pitch to tube diameterratio). FEI causes these tubes, which are filled with highly radioactive reactor coolant (each tube's diameter is the size of a penny and wall thickness is thinner than a credit card), to vibrate excessively, due to high steam flows and fluid velocities. These increased heat and high velocities sweep away the thin water film present on the outside of the tubes creating what is known as dry-out regions. This thin film of water on the outside of the tubes is required to transfer the heat from the inside of the tubes to the steam-water fluid surrounding the tubing. Additionally, by releasing the heat, the violent and turbulent motion of these hot tubes is temporarily arrested, or restrained (aka damping). Without the thin film of water present on the tubes, these hot tubes are unable to dissipate their heat energy and continue to vibrate excessively with large amplitudes. At the beginning of FEI as these tubes start moving with larger and larger amplitudes, they first start hitting adjacent rows of tubes located in the in-plane direction and then as FEI progresses they start also hitting adjacent columns of tubes located in the out-of-plane direction. The moving tubes change the tube-to-tube clearances, pressures and regions of high heat flux in the hot-leg randomly. These changing thermal-hydraulic and system conditions can create more hot and dry regions within the U-tube bundle which are undetectable by the plant operator, as proven by what happened in San Onofre Unit 2 and 3. The higher vapor fractions in turn increases the velocity of the steam mixture exceeding the critical velocity and further causing Hydro-Dynamic Pressure (Mitsubishi Flowering Effect) to increase as a square function of the velocity. This unending adverse conditions cause more damage to the tubes in the form of tube-to-tube/AVBfTSP wear, and tube leakage/ruptures. The FEI changes the random and small tube vibrations to exponential vibrations. Hence, the presence of a thin water film on these tubes is crucial to prevent leakages and/or ruptures, which in turn cause radioactive releases to the environment. Palo Verde Nuclear Generating Station Replacement Steam Generators (which is the largest in the world) were fabricated, and installed in 2003. They are operated, and majority owned by Arizona Power Service, and were designed by Combustion Engineering /Westinghouse. Palo Verde's Replacement Steam Generators were designed to prevent the adverse effects of fluid-induced vibrations, fluid elastic instability, high steam flows/velocities and steam dry-outs. Edison, a part owner of Palo Verde, made two costly mistakes, one by not benchmarking Palo Verde's generators and the second, by trying to avoid the required NRC 50.90 Licensing Amendment, which could have prevented their debacle. (Note: In Finland, radioactive liquid and steam discharges to the environment are prohibited by law).

A http:l/libcloud.s3.amazonaws.com/93/801a/26801R3218-Large-AF2-redacted propdetary.pdf B http:/lllbcloud.s3.amazonaws.com/931b51f/2677/2013 1 11 FOE Gundersen Affidavit reEdlsonSanOnofreRSG.pdf Full Media Alert 13-01-13 Allegation - Dangerous Safety Cover Up At San Onofre is posted on the web at this link: DAB Safety Team Documents.

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.

Copyright January 14, 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 3