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 184.108.40.206.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 220.127.116.11.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 Criteria 14, "Reactor Coolant Pressure Boundaryshall have "an extremely low probability of abnormal leakage and gross rupture."
Press Release (Complete Version) + 12-12-31 NRR RAI #32 Request
NOTE: Here are the 14 most important questions that the DAB Safety Team feels must be answered before the NRC, 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?
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
· 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.