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 Criteria 14, "Reactor Coolant Pressure Boundary—shall have "an extremely low probability of abnormal leakage…and gross rupture."
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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 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.



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 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.

_______________________________________________

Press Release + 12-12-28 Thirty Alarms Demonstrates SONGS Unsafe

Press Release Shortened Version (for Complete Version see below)

The DAB Safety Team: December 27, 2012

Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261


The 30 Un-Resolved Alarms Recorded by SONGS Vibration Monitoring System During 11 Months of Operation, Requires An Immediate NRR Safety Investigation


Three Questions affecting US reactor safety need to be answered ASAP, by the NRR:

1.  WHY, if these 30 separate alarms were indicating that some unusual phenomena (e.g., FEI) was occurring in Unit 3, did SCE not immediately shut down Unit 3, notify the NRC of the unusual phenomena and get their help in order to properly understand what exactly was going on inside the Unit 3 SG in order to properly diagnose the problem(s), instead of just ignoring them while continuing to operate Unit 3 for 11 months in an unsafe manner?

2.  Why has NRC Region IV's AIT Team NOT resolved this issue almost 6 months after issuance of their AIT Report and already informed the public as to the cause(s) of these unusual phenomena, if the causes are now understood.

3.  WHY should a Utility be able to operate a nuclear reactor while something unknown is happening without shutting it down ASAP and informing the NRC?

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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 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 27, 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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Press Release (Complete Version)


The DAB Safety Team: December 27, 2012

Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261


The 30 Un-Resolved Alarms Recorded by SONGS Vibration Monitoring System During 11 Months of Operation, Requires An Immediate NRR Safety Investigation

The DAB Safety Team has transmitted the following Request to the Chairman of the NRC, Offices of Nuclear Regulator Regulations, Atomic Safety Licensing Board and NRC AIT Team Chief. 

Observation: Thirty times over 11 months, vibrations monitors positioned in the Unit 3 reactor's two steam generators near the tube sheet triggered alarms after sensing unusual movements.  30 alarms were recorded in Unit 3, but none were detected at its sister, Unit 2, which is the same Mitsubishi Heavy Industries design. NRC officials sifted through months of data to determine if Edison properly analyzed a series of mysterious vibrations detected inside the now-crippled Unit 3 reactor. At the time, it raised questions about whether Edison completely missed possible clues that something was terribly wrong inside the generators. However, the agency later determined that the vibrations were not connected to tube-to-tube wear, according to NRC officials. Unit 3 RSGs were operating at lower pressures compared with Unit 2 therefore lower operating pressures in Unit 3 caused FEI while higher operating pressures did not cause FEI in Unit 2.  Mitsubishi states, "lower pressures at steady power cause severe vibrations." NRC AIT Report States, "Additional review and follow up will be required of the vibration and loose parts monitoring system alarms, including evaluation and disposition of Unit 3 alarms and then determine whether this issue represents a performance deficiency or constitutes a violation of NRC requirements."  This issue is identified in the NRC AIT Report as URI 05000362/2012007-02, "Evaluation of Unit 3 Vibration and Loose Parts Monitoring System Alarms (Section 3)."


NOTE: According to a Japanese Research Paper, "Large vibrations in a nuclear steam generator may suddenly or periodically appear when the fluid velocity approaches the critical velocity creating the onset of fluid elastic instability."  Fluid elastic instability may temporarily become pronounced due to formation of steam dry-outs in regions of U-tube bundle with low tube clearances, high heat flux and no in-plane protection.  During this time, the entire tube from the bottom of the tube sheet to the top of the U-tube bundle free span* would move with large amplitudes and hit other neighboring tubes with violent impact due to absence of water film (no tube damping) on the tubes.  As the tube clearances adjust due to tube-tube impact and secondary side flow velocity decreases due to changing plant and thermal-hydraulic conditions, the vibrations tend to reduce and fluid elastic instability changes into random vibrations. DAB Safety Team and Westinghouse have established that Unit 3 experienced FEI, but Unit 2 did not. This explains why 30 vibration alarms were recorded in Unit 3 near the tubesheet by vibration loose part monitoring sensors because entire tubes were vibrating with large amplitudes but none were detected at its sister, Unit 2, because its tubes were vibrating below the detection limit of the poor choice of vibration sensors used.

·      NRC AIT report states, "In general, tubes exhibiting the free-span wear indications tended to exhibit tube support plate indications with the highest depth measurements, typically with the deepest values at the seventh tube support plate and trending down at successively lower support levels." There were 3000 tube support plate wear indications in Unit 3, while only 360 tube support plate wear indications were found in Unit 2.



Three Questions affecting US reactor safety need to be answered ASAP, by the NRR:

1.    WHY, if these 30 separate alarms were indicating that some unusual phenomena (e.g., FEI) was occurring in Unit 3, did SCE not immediately shut down Unit 3, notify the NRC of the unusual phenomena and get their help in order to properly understand what exactly was going on inside the Unit 3 SG in order to properly diagnose the problem(s), instead of just ignoring them while continuing to operate Unit 3 for 11 months in an unsafe manner?



2.    Why has NRC Region IV's AIT Team NOT resolved this issue almost 6 months after issuance of their AIT Report and already informed the public as to the cause(s) of these unusual phenomena, if the causes are now understood?



3.    WHY should a Utility be able to operate a nuclear reactor while something unknown is happening without shutting it down ASAP and informing the NRC?





Background



1. OC Register Published: Dec. 19, 2012 Updated: 8:32 a.m.:

 San Onofre: Edison backpedals on claim that retooling will aid safety

The utility that runs the idled San Onofre nuclear power plant backpedaled Tuesday from an earlier claim that a retooled vibration-detection system for the plant's ailing steam generators would be an important safety advance that could help open the way for a possible restart. Southern California Edison said in its October proposal to restart the Unit 2 reactor that the redesigned system, which relies on monitors to detect unusual vibration inside the huge generators, could help detect a break in a tube that carries radioactive water, according to federal documents.

Edison officials came under sharp questioning about the monitors at a U.S. Nuclear Regulatory Commission panel meeting in Maryland, where an NRC official argued that the equipment could not do the job described by the company or provide additional safety if the plant is restarted.

"The instrumentation that you're proposing ... does not appear to be capable of detecting the conditions that would lead to actual tube wear," said Richard Stattel of the agency's instrumentation branch.

The company depicted the equipment in its restart plan as an important safety measure "but it doesn't appear to do that," Stattel said. The NRC staff "doesn't understand where that adds an additional safety margin" as proposed by the company.

Mike Short, an Edison consultant, told regulators that the company "had not intended" to characterize the system as an important safeguard, technically known as "defense-in-depth," or multiple layers of systems designed to prevent accidents or the release of radiation from a nuclear power plant.  Short said the data collected by the system could be used in future research examining vibrations picked up by the monitors. "It's our plan ... to make sure that's clear," he said.

The original monitoring system was at issue in a federal investigation after the plant was shut down in January. NRC officials sifted through months of data to determine if Edison properly analyzed a series of mysterious vibrations detected inside the now-crippled Unit 3 reactor. Thirty times over 11 months, monitors positioned in the reactor's two steam generators triggered alarms after sensing unusual movements, according to documents and Nuclear Regulatory Commission officials involved in the probe. At the time, it raised the questions about whether Edison missed possible clues that something was terribly wrong inside the generators. However, the agency later determined that the vibrations were not connected to tube-to-tube wear, according to NRC officials.

According to an analysis by an outside contractor that reviewed some of the data, the signals picked up by the Unit 3 monitors were similar in nature to what would occur with steep temperature changes when a reactor is starting up or shutting down. But, strangely, the vibrations were detected when the Unit 3 reactor was running at a steady clip. The monitors, technically known as accelerometers and designed to detect loose or broken parts, were positioned near the bottom of the 65-foot high generators. In that location, federal officials say, it would be difficult or even unlikely to pick up vibration and friction among tubes at the other end, where damage was concentrated. And while 30 alarms were recorded in Unit 3, none was detected at its sister, Unit 2, which is the same Mitsubishi Heavy Industries design. The redesigned system is expected to be more sensitive.



2. NRC Augmented Inspection Team Report for SONGS

Description:  During the review of operational differences between Unit 2 and 3 steam generators the team identified a significant difference in the number of valid vibration and loose parts monitoring system alarms.  The vibration and loose parts monitoring system was designed to provide continuous monitoring and conditioning of loose parts accelerometer signals.  Two separate accelerometers were installed on each of the steam generators.  The location of these instruments are on the steam generators' lower supporting structures and provide acoustic information about loose parts impacts specifically on the reactor coolant or primary side of the steam generators.  The vibration and loose parts monitoring system real time functions consist mainly of impact alarm validation of suspected loose part events and recording acoustic data.  Long term vibration monitoring and loose part event trending were done by engineering personnel using recorded data.   



Unit 3 returned to service in February 2011, and the resident inspectors noted a number of nuclear notifications associated with Unit 3 steam generators vibration and loose parts monitoring alarms.  On January 20, 2012, prior to the Unit 3 tube leak, engineering personnel also identified this trend and documented in Nuclear Notification NN 201818719 this problem and assigned an action to do further evaluation.  On February 3, 2012, engineering personnel sent two sets of alarm signatures to Westinghouse, which contained impact data on alarms for time periods of steady state operation (i.e., no major temperature changes).  Westinghouse engineering personnel concluded that the acoustic signals picked up by the accelerometers were valid and similar in nature to acoustic signatures caused by thermal movement of a steam generator expected during changes in thermal conditions, such as plant startup or shutdown.  However the data obtained and analyzed had been taken during steady state operations.  The team noted that Unit 2 steam generators did not receive the same number and type of alarms during a similar period of steady state operations.  Engineering personnel also compared hot leg temperature changes linked to Unit 3 operations from February 18, 2011, to January 31, 2012, and confirmed about 30 valid alarms during this period were not associated with thermal transients.   



NRC AIT report states, "In general, tubes exhibiting the free-span wear indications tended to exhibit tube support plate indications with the highest depth measurements, typically with the deepest values at the seventh tube support plate and trending down at successively lower support levels." There were 3000 tube support plate wear indications in Unit 3, while only 360 tube support plate wear indications were found in Unit 2.



3. AREVA Operational Assessment Report for SONGS Unit 2 Restart 



http://www.songscommunity.com/confirmation-action-letter.asp, Attachment 6, Appendix B, SONGS Unit 2 Return Service to Service Report shows Figure 4-4 (Pg. 26) and Figure 4-5 (Pg. 27) are tubesheet maps illustrating the U-bends in Unit 3 SG E-088 and SG E-089 that have TTW.  The more detailed view of the positions of TTW indications in Figure 4-6 (Pg. 28), Figure 4-7 (Pg. 29) and Figure 4-8 (Pg. 30) are instructive.  Note that the positions are contiguous with only one tube not affected.  This argues against a random spatial and temporal occurrence of instability.  There just aren't enough unaffected tubes to indicate that instability independently initiated at different positions at different times.  Three dimensional plots of TTW depth versus column and row in Figure 4-9 (Pg. 31) and Figure 4-10 (Pg. 32) reinforce the concept that the development of instability at different positions is a sequence of dependent events and not a sequence of independent events.



DAB Safety Team Observations



Unit 3 tubes were severely vibrating at the top with large amplitudes, and also moderately vibrating near the tube sheet (3000 TSP wear indications) near the bottom, that is why we believe the alarms were triggering (30 alarms in 11 months) due to FEI.  The Unit 2 tubes were vibrating at the top with smaller amplitudes and were not vibrating with any detectable magnitude near the tube sheet near the bottom (no FEI and only 360 TSP wear indications near the top plate) because of the poor choice of detection equipment used, that is why no alarms were triggered in the 22 months of operation, despite all the damage that was occurring in Unit 2.



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Glossary of Terminology:

AIT: Augmented Inspection Team
DID: Defense-In-Depth
FEI: Fluid Elastic Instability
MSLB: Main Steam Line Break
NN: Nuclear Notification
NRC: Nuclear Regulatory Commission
NRR: Nuclear Reactor Regulation, Office of (NRC)
RCS: Reactor Coolant System
RSG: Replacement SG
SCE: Southern California Edison, an Edison Int'l Company
SG: Steam Generator
SONGS: San Onofre Nuclear [Waste] Generating Station
TSP: Tube Sheet Plate
TTW: Tube-to-Tube Wear
URI: Unresolved Item



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 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 27, 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.
______________________________________________

Press Release + 12-12-26 Nuclear Reactor Regulations (NRR) Meeting Request

Press Release

The DAB Safety Team: December 26, 2012


Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261



The DAB Safety Team Requests A Special Meeting With The NRR To Discuss SONGS Steam Generator Safety



In the interest of the Health & Safety of Southern Californians, the DAB Safety Team's Principal Investigator and Other Experts (Optional) wish to be invited to attend a Closed Door Confidential Meeting, Tuesday February 19, 2013 in Washington D.C., ideally to be held under oath, about SONGS' severely damaged Replacement Steam Generators and other safety related problems, before any SONGS Unit 2 restart is granted by the NRC.


The following optional observers (OO) and/or participants (P) are encouraged to attend:



·      Senator Barbara Boxer (OO),

·      Senator Diane Feinstein (OO),

·      The Full NRC Commission (OO),

·      Office of Nuclear Reactor Regulations, NRR (P),

·      Atomic Safety Licensing Board Panel, ASLBP (P or O),

·      NRC Augmented Inspection Team, AIT Chief (P or O)

·      Nuclear Advisor, Senate Committee on Environment and Public Works (P or O)



The DAB Safety Team has transmitted the above Request to the Chairman of the NRC, Offices of Nuclear Regulator Regulations, Atomic Safety Licensing Board and the NRC AIT Team Chief.  A list of Potential DAB Safety Team Experts/Attorneys and Agenda will follow pending acceptance of this invitation by the NRR.  Note: The DAB Safety Team is requesting this meeting in accordance with "NRC Public Meetings and Involvement", which states, "The NRC considers public involvement in, and information about, our activities to be a cornerstone of strong, fair regulation of the nuclear industry."



This press release will be posted on the web at this link: SanOnofre 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 please visit the link above.

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

Copyright December 26, 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.

The nuclear waste dump formerly known as San Onofre?

12/27/2012

Dear Readers,

Southern California Edison, the operator of the (non-operating) San Onofre Nuclear Waste Generating Station, is running out of options.

Even the federal regulators are coming down hard on them. The public remains deeply skeptical, while local elected officials continue to press for further investigations into the problems at the plant.

It ain't over 'til it's over, but yesterday SCE took a couple of hard blows.

First, the Nuclear Regulatory Commission sent Pete Dietrich, Senior Vice President and Chief Nuclear Officer at Southern California Edison, a letter requesting 32 clarifications regarding SCE's risky -- some would even say CRAZY (I would say that) -- plan to restart San Onofre Unit 2 at 70% power as a five-month test. And if that wasn't enough, the NRC is also saying that SCE must prove that the plant could be operated safely at 100% power before approving a restart plan. SCE's proposal to prove they could operate safely at 70% power simply isn't good enough.

This is exciting.

Edison felt they could show that operating for five months at 70% power was safe using "conservative" benchmarks, retraining the staff, adding additional monitoring equipment, and crossing their fingers for good luck. The NRC's demand will be virtually impossible to fulfill, considering that the plan to operate at 70% power was full of holes to begin with (resulting in the 32 points of clarification in yesterday's letter from the NRC).

The U-tubes in Unit 2's replacement steam generators are highly damaged, and they only ran for 22 months out of a planned 60-YEAR life expectancy (60 years was truly a pipe dream). Unit 3's new U-tubes only ran for 11 months before one of them burst, and the plant has been shut down ever since.

During the 22 months that Unit 2 operated successfully with the new steam generators, Fukushima happened, to warn Southern Californians of the consequences of failure at San Onofre. The consequence would be the loss of our communities, our jobs, our families, and our lives. Lost to cancer, deformities, heart disease, inflammation and many other ailments, the effects of radiation poisoning. The lesson of Fukushima has not been forgotten among the populace, even if it's been largely forgotten by the media. But even the head of the NRC admits 100,000 families in Japan cannot return home because of the Fukushima nuclear disaster. We don't want that here.

What happened at Fukushima -- or even far worse -- can happen at San Onofre in a matter of seconds. It can happen the instant they restart the reactor.

Every knowledgeable nuclear energy expert has been forced to admit that such disasters, once claimed to be impossible due to their extensive "defense-in-depth" technology, are not only possible, but cannot be prevented in some circumstances. Foreseeable circumstances, even inevitable: Earthquakes happen. Tsunamis happen. Valves stick open (or closed). Pipes burst. Operators make errors. Oh, do they ever! The combination will bring down a power plant somewhere, and it might be San Onofre. Every expert now has to admit what they used to deny: That accidents are possible. In fact, they've introduced a new term into their vocabulary: Mitigation. But that just means "move, quickly, and never come back." But we live in paradise here! We don't want to be forced to move!

One wonders, after Chernobyl and Fukushima -- and a thousand near-misses here in America -- why does the NRC allow the plants to operate at all? How is that possible? The answer is: They are playing the odds. Large accidents are deemed unlikely, such as a meteor crashing into it (or an airplane). The NRC doesn't require the power plants to protect themselves against earthquakes larger than a certain size, they deem them too unlikely to have to worry about. Similarly for tsunamis higher than a certain size, or terrorist actions involving airplanes, or even numerous innocent operator mistakes. Such events are deemed too unlikely and are considered to be "beyond design basis" and the utility company doesn't have to plan for them at all. The plant is built for a 7.0 earthquake, for example, not because an 8.0 is impossible, but because the possibility of an 8.0 is considered "remote."

All other events, however, the utility must plan for and prove they can handle. Southern California Edison is in a tight spot on that right now, because operation of Unit 2 at 100% power IS surely very risky. They've even so much as admitted it in their request to operate at 70% power -- they said that was what they could "conservatively" estimate was safe. So now what can they say?

A brief history of steam generator problems at San Onofre: Unit 1 was put down in the early 1990s for steam generator problems very similar to what happened in units 2 and 3. New SGs were put in the two operating units, but one of Unit 3's new SGs failed on January 31st, 2012, after only 11 months of operation, and that unit cannot be returned to service without replacing the SGs with an unknown design -- which would presumably include a lengthy and unpredictable license amendment process. Unit 2's new replacement SGs are of identical design to Unit 3's failed SGs and experienced unprecedented wear due to excessive vibrations in the 22 months they operated, but not as much wear as Unit 3 experienced. The amount of wear in Unit 2 was extensive and well outside industry norms, but in many ways similar to the wear in Unit 3.

So it appears that the NRC has demanded the impossible of SCE, for how can SCE possibly prove that Unit 2 can be operated at 100% power safely? (In this writer's opinion, they cannot assert it at 70%, either, but they were trying.) At 100% power it's not only possible but probable that the problems that occurred in Unit 3 could occur in Unit 2. And even if that doesn't happen, they could occur during "design basis events" such as a "main steam line break."

So is the game over? Will SCE announce that they'll decommission the reactor, permanently shutting it down? Maybe, but it hasn't happened. One person suggested to me that the NRC's "top guns" are handling San Onofre's problems now, not just the NRC Region IV guys, who have been coddling the corporations, ignoring the activists, and failing in their duties here for years. (Management retaliation problems against the workers have persisted at the plant, even as it is unable to get back on its feet and start making money for its owners.)

Yesterday's letter from the NRC does not force decommissioning. It does not force SCE to move the used reactor cores to a "safe" storage place. None exists -- the last viable option for SCE, the "Private Fuel Storage" (PFS) facility proposed for the Goshute Indian Reservation in Utah, has been cancelled (as it should be -- it was a terrible idea). Yucca Mountain, the nation's former proposed repository, is unworkable politically and geologically. Transportation of nuclear waste is extremely difficult and there's nowhere to go with it anyway. Dry cask storage is not "hardened" in any way. Spent fuel pools are full and expensive to maintain. There are no good options for the waste.

Mining the raw uranium is a health hazard to the miners who dig it out of the ground, but used reactor cores are millions of times more dangerous, pound for pound, than fresh, unused reactor fuel. It stays that way for hundreds of thousands of years.

It's time to stop making more and more of this deadly waste. It's time to stop risking a Fukushima disaster in Southern California. It's time to demand now, more than ever, that SCE shut San Onofre forever.

Tomorrow SCE might announce that they are going to decommission San Onofre, but a nuclear reactor license is a multi-billion-dollar asset, so don't hold your breath. If SCE can rebuild the steam generators over the coming years -- and better yet, bill the ratepayers for the delay -- that's exactly what they'll do. (They've made that clear in a recent filing with the California Public Utilities Commission, who normally gives SCE all the money they say they need to operate the plant at a profit, including $5 billion dollars in rate increases earlier this month.)

So even with the NRC's letter demanding so many things of SCE, and even with so many other problems, the battle is not over. It's only over when the plant is demolished and the waste removed, the land restored, and the licenses to operate have been revoked forever. Only then is it over for the local residents -- but someone will still have to mind the waste for thousands of generations. The smaller the pile we leave them, the better.

Ace Hoffman
Carlsbad, CA

NRC's letter to Mr. Peter T. Dietrich, SVP & CNO, SCE, SON[W]GS:
http://www.sanclementegreen.org/files/NRC-RAI.pdf


[Note: San Onofre is built to withstand a 7.0, not a 7.5 earthquake.  This has been corrected above, and the more lengthy correction shown below was emailed to subscribers.]

-----------------------------------------
Ace Hoffman, computer programmer,
author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
ubscribe to my free newsletter today!
Email: ace [at] acehoffman.org
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12/28/2012

Dear Readers,

Thanks to everyone who published, distributed, or just read yesterday's essay, "The Nuclear Waste Dump Formerly Known as San Onofre?" Unfortunately, I misspoke about the earthquake capabilities of the plant, mixing up Diablo Canyon's capabilities with SanO's. The correct figure for San Onofre's supposed, assumed, claimed, and probably exaggerated earthquake rating is 7.0, not 7.5. That is a 5X difference so it's not exactly a trivial amount. I apologize for, and regret, the error. I've corrected the online version that appears at my blog:

http://acehoffman.blogspot.com/2012/12/the-nuclear-waste-dump-formerly-known.html

Short url:

http://goo.gl/Bneqq

My thanks to Donna Gilmore, ever the perfectionist (and we love her for it) for pointing this error out, and she adds that a lot of additional information about San Onofre's lack of earthquake preparedness, and the local communities' general lack of preparedness for ANY San Onofre accident, is available at the San Onofre Safety web site:

http://Sanonofresafety.org

Also, there you can find information about peak electricity loads in California, showing San Onofre is unnecessary (there's enough electricity available without it), and charts on worker retaliation complaints, safety complaints, and so on. Also, petitions and letters from various cities to the CPUC and NRC, handouts that can be printed out and distributed, current events and an overall look at the many issues involved. The site contains numerous technical documents, useful links and public forums as well.

Sincerely,

Ace Hoffman
Carlsbad, CA

Press Release: SCE's Statements to the NRR requires an investigation

**** Press Release ****

The DAB Safety Team: December 19, 2012

Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261


SCE's Conflicting, Contradicting & Catastrophic Statements RE: Fluid Elastic Instability In SONGS Unit 2, requires NRR Complete An Investigation Before Any San Onofre Unit 2 Restart is Permitted




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. The information provided below has been obtained from publicly available documents on the web.


SUMMARY: SCE is stating that FEI in Unit 2 "most likely," "may have been," or alternatively close proximity of the two tubes may have led to TTW from normal vibration.  AREVA states that any claims that, "fluid-elastic instability cannot develop in Unit 2 would be inappropriate."  Westinghouse is stating FEI in Unit 2 could not have occurred in these tubes.



Fluid elastic instability is both very complex and controversial, but it must be fully understood in order to design, repair and/or operate SONGS Unit 2 replacement steam generators in order to absolutely protect Southern Californian's Health, Safety, Environment and Economy. 



Academic Researchers have warned about the adverse effects of FEI since the 1970's in Nuclear Steam Generators. For example, Westinghouse/Combustion Engineering designed the Palo Verde Replacement Steam Generators vibration support system, (the largest in the world) to prevent the adverse effect of FEI caused by high steam flows, high velocities and localized steam dry-outs (high void fractions).  Both MHI and SCE missed the boat on Industry Benchmarking and Academic Research by not designing the SONGS Replacement Steam Generators vibration support system to prevent these adverse conditions. NRC AIT Report states that SCE Design Specification SO23-617-1 did not address specific criteria for stability ratio and does not mention fluid-elastic instability.



Recent History:



*       On July 15, 1987, a steam generator tube rupture event occurred at North Anna due to fluid elastic instability.

*   On February 9th, 1991, a heat transfer tube (SG tube) in a steam generator of the No. 2 pressurized water reactor at the Mihama nuclear power station of the Kansai Electric Power Company broke off due to fluid elastic instability.

*   On January 31, 2012, in SONGS Unit 3, one tube started leaking radioactive coolant in one of brand new 580 million dollar replacement steam generators (RSG's) E-088 reverse-engineered by SCE and manufactured by Mitsubishi Heavy Industries, Ltd (MHI).  The leak, although small, had increased enough in a 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 RSGs E-088 failed "in-situ" main steam line break pressure testing and therefore were plugged, after only 11 months of operation, something that had never happened before in the history of the US Nuclear fleet.  Additionally, 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 progress in Unit 3 was stopped. The RSGs designed by SCE and manufactured by MHI clearly violate the Code of Federal Regulations, 10 CFR Part 50, GDC 14, RCPB shall have "an extremely low probability of abnormal leakage and gross rupture."



SCE in Unit 2 Return to Service Report, Enclosure 2, Section 12.0 states, "The TTW in Unit 2 SG E-089 may have been caused by FEI, or alternatively, close proximity of the two tubes may have led to TTW from normal vibration."



SCE in its November 30 public Meeting stated that, "In Unit 2, tube-to-tube wear was caused most likely by in-plane vibrations."

 

AREVA in Unit 2 Return to Service Report, Attachment 6, Appendix B, Section 3.0 states, "Based on the extremely comprehensive evaluation of both Units, supplemented by thermal hydraulic and FIV analysis, assuming, a priori, that TTW via in-plane fluid-elastic instability cannot develop in Unit 2 would be inappropriate."

 

Westinghouse in Unit 2 Return to Service Report, Attachment 6, Appendix D, Executive Summary states "An evaluation of the tube-to-tube wear reported in two tubes in SG 2E089 showed that, most likely, the wear did not result from in-plane vibration of the tubes since all available eddy current data clearly support the analytical results that in-plane vibration could not have occurred in these tubes."



The Unit 2 steam generators were operating at higher pressures than Unit 3. The data for Unit 2 pressures reported from various root cause evaluation teams, operations personnel, and documents was within the range of 863-942 psi. The data reported for both Units 2 and 3 steam generators pressures is as follows: NRC AIT Report, Range 833-942 psi; SCE Root Cause Evaluation, 833 psi; Westinghouse Operational Assessment, ~ 838 psi.  Secondary side higher pressure (863-942 psi) at 100% power produced lower void fractions (<98.5) due to higher steam saturation temperatures in the Unit 2 tube bundle region. Because of the lower void fractions, no tube-to-tube wear (fluid elastic instability) in Unit 2 was observed.  Based on personnel and plant documents information, SCE has reported incorrect pressures for Unit 2 in their cause evaluation and provided wrong data to Westinghouse for Unit 2.  SCE has reported correct pressures for both Units to the AIT Team. Despite the confusion, Westinghouse Assessment concluded correctly based on the ECT data that FEI did not occur in Unit 2.  Westinghouse Assessment contradicts both SCE and AREVA's conclusions regarding occurrence of FEI in Unit 2. 



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 AVBs.  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) Unit 3 SG manufacturing process used more accurate and tighter tolerances which improved alignment such that tubes had more contact with AVB's.



Unless NRR determines whether Westinghouse or SCE and AREVA are correct on the Unit 2 FEI conclusions, how can NRC make the correct decisions on Unit 2's restart 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 making the right decision.





###



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 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 19, 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.  **** Press Release ****

The DAB Safety Team: December 19, 2012

Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261


SCE's Conflicting, Contradicting & Catastrophic Statements RE: Fluid Elastic Instability In SONGS Unit 2, requires NRR Complete An Investigation Before Any San Onofre Unit 2 Restart is Permitted




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. The information provided below has been obtained from publicly available documents on the web.


SUMMARY: SCE is stating that FEI in Unit 2 "most likely", "may have been", or alternatively close proximity of the two tubes may have led to TTW from normal vibration.  AREVA states that any claims that, "fluid-elastic instability cannot develop in Unit 2 would be inappropriate."  Westinghouse is stating FEI in Unit 2 "could not have occurred in these tubes."



Fluid elastic instability is both very complex and controversial, but it must be fully understood in order to design, repair and/or operate SONGS Unit 2 replacement steam generators in order to absolutely protect Southern Californian's Health, Safety, Environment and Economy. 



Academic Researchers have warned about the adverse effects of FEI since the 1970's in Nuclear Steam Generators. For example, Westinghouse/Combustion Engineering designed the Palo Verde Replacement Steam Generators vibration support system, (the largest in the world) to prevent the adverse effect of FEI caused by high steam flows, high velocities and localized steam dry-outs (high void fractions).  Both MHI and SCE missed the boat on Industry Benchmarking and Academic Research by not designing the SONGS Replacement Steam Generators vibration support system to prevent these adverse NRC AIT Report states that SCE Design Specification SO23-617-1 did not address specific criteria for stability ratio and does not mention fluid-elastic instability.



Recent History:



·       On July 15, 1987, a steam generator tube rupture event occurred at North Anna due to fluid elastic instability.

·   On February 9th, 1991, a heat transfer tube (SG tube) in a steam generator of the No. 2 pressurized water reactor at the Mihama nuclear power station of the Kansai Electric Power Company broke off due to fluid elastic instability.

·   On January 31, 2012, in SONGS Unit 3, one tube started leaking radioactive coolant in one of brand new 580 million dollar replacement steam generators (RSG's) E-088 reverse-engineered by SCE and manufactured by Mitsubishi Heavy Industries, Ltd (MHI).  The leak, although small, had increased enough in a 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 RSGs E-088 failed "in-situ" main steam line break pressure testing and therefore were plugged, after only 11 months of operation, something that had never happened before in the history of the US Nuclear fleet.  Additionally, 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 progress in Unit 3 was stopped. The RSGs designed by SCE and manufactured by MHI clearly violate the Code of Federal Regulations, 10 CFR Part 50, GDC 14, "RCPB—shall have "an extremely low probability of abnormal leakage…and gross rupture."



SCE in Unit 2 Return to Service Report, Enclosure 2, Section 12.0 states, "The TTW in Unit 2 SG E-089 may have been caused by FEI, or alternatively, close proximity of the two tubes may have led to TTW from normal vibration.



SCE in its November 30 public Meeting stated that, "In Unit 2, tube-to-tube wear was caused most likely by in-plane vibrations."

 

AREVA in Unit 2 Return to Service Report, Attachment 6, Appendix B, Section 3.0 states, "Based on the extremely comprehensive evaluation of both Units, supplemented by thermal hydraulic and FIV analysis, assuming, a priori, that TTW via in-plane fluid-elastic instability cannot develop in Unit 2 would be inappropriate."

 

Westinghouse in Unit 2 Return to Service Report, Attachment 6, Appendix D, Executive Summary states "An evaluation of the tube-to-tube wear reported in two tubes in SG 2E089 showed that, most likely, the wear did not result from in-plane vibration of the tubes since all available eddy current data clearly support the analytical results that in-plane vibration could not have occurred in these tubes."



The Unit 2 steam generators were operating at higher pressures than Unit 3. The data for Unit 2 pressures reported from various root cause evaluation teams, operations personnel, and documents was within the range of 863-942 psi. The data reported for both Units 2 and 3 steam generators pressures is as follows: NRC AIT Report, Range 833-942 psi; SCE Root Cause Evaluation, 833 psi; Westinghouse Operational Assessment, ~ 838 psi.  Secondary side higher pressure (863-942 psi) at 100% power produced lower void fractions (<98.5) due to higher steam saturation temperatures in the Unit 2 tube bundle region. Because of the lower void fractions, no tube-to-tube wear (fluid elastic instability) in Unit 2 was observed.  Based on personnel and plant documents information, SCE has reported incorrect pressures for Unit 2 in their cause evaluation and provided wrong data to Westinghouse for Unit 2.  SCE has reported correct pressures for both Units to the AIT Team. Despite the confusion, Westinghouse Assessment concluded correctly based on the ECT data that FEI did not occur in Unit 2.  Westinghouse Assessment contradicts both SCE and AREVA's conclusions regarding occurrence of FEI in Unit 2. 



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 AVBs.  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) U3 SG manufacturing process used more accurate and tighter tolerances which improved alignment such that tubes had more contact with AVB's.



Unless NRR determines whether Westinghouse or SCE and AREVA are correct on the Unit 2 FEI conclusions, how can NRC make the correct decisions on Unit 2's restart 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 making the right decision.





###



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 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 19, 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.


AIT: Augmented Inspection Team
AVB: Anti-Vibration Bar
CFR: Code of Federal Regulations
DAB: DAB (Don, Ace, and a Battery of Experts) Safety Team
ECT: Eddy Current Testing
FEI: Fluid Elastic Instability
FIV: Flow Induced Vibration
GDC: General Design Criteria
MHI: Mitsubishi Heavy Industries, manufacturer of the RSGs
NRC: Nuclear Regulatory Commission
NRR: [Office of] Nuclear Reactor Regulations
RC: Reactor Coolant
RCPB: RC Pressure Boundary (includes SG tubes and all other RC boundaries)
RSG: Replacement SG
SCE: Southern California Edison
SG: Steam Generator
SONGS: San Onofre Nuclear [Waste] Generating Station
TTW: Tube-to-Tube Wear

Fwd: PR: SCE's Embarrassing Performance + 14 Questions Regulators Need To Ask SCE At Tomorrow's NRR/RES Meeting

Date: Mon, 17 Dec 2012 10:13:26 -0800
Subject: PR: SCE's Embarrassing Performance + 14 Questions Regulators Need To
 Ask SCE At Tomorrow's NRR/RES Meeting
From: "Capt.D" <captddd@gmail.com>

Press Release


The DAB Safety Team: December 17, 2012

Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261

Concerning SCE's NRC Technical Presentation on 12-11-30

The DAB Safety Team has transmitted the following report this morning to the Chairman of the NRC, Atomic Safety Licensing Board, NRC Offices of Nuclear Reactor Regulations and Nuclear Regulatory Research:

SONGS Unit 2 Dangerous Replacement Steam Generators:

 SCE's Embarrassing Technical Performance Trying To Justify A Restart

 Of Unit 2, To The NRC, At Their November 30, 2012 Public Meeting.

The 78 page technical document includes 14 questions that affect US Reactor SAFETY, that the NRC, NRR and RES Regulators need to ask SCE to answer at their Dec 18, 2012 NRR/RES Meeting.





The report will also 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 in no way 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.  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 17, 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.



The 78 page technical document includes 14 questions that affect US Reactor SAFETY, that the NRC, NRR and RES Regulators need to ask SCE to answer at their Dec 18, 2012 NRR/RES Meeting.





The report will also 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 in no way 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.  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 17, 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.

The rape of Fukushima Dai-ichi...

12/13/2012

Dear Readers,

Dressed all in white from head to toe (including a respirator), it was a shotgun wedding. Or worse, a rape. But one way or the other, U. S. Nuclear Regulatory Commission officials were out to force themselves and their radiation on a helpless Japan -- again. Hiroshima and Nagasaki, 1945. More than a hundred thousand dead, perhaps as many born deformed, or stillborn. Then there was Monju in 1995, and Tokaimura in 1997, and again in 1999. And then Fukushima Dai-ichi, 2011.

And now they're back. The NRC delegation wants Japan to restart more of its nuclear reactors. They've been pushing Japan for more than a year, but the citizens of Japan have been opposing restart vehemently.

American nuclear officials toured the stricken Fukushima Dai-ichi nuclear power plant. NRC Chairman Allison Macfarlane, who led the delegation, praised the "courage" of the Japanese nuclear workers at the Fukushima Dai-ichi and nearly-as-damaged Fukushima Dai-ini nuclear power plants. The delegation took an elevator to the top of the spent fuel pool at Fukushima Dai-ichi Unit 4, the most dangerous place on earth. They called the accident a tragedy, and said all countries need independent regulators, who need to operate in an "open and transparent manner."

We, the citizens of California who live near the also-not-operating San Onofre Nuclear Power Plant, can tell the Japanese people exactly what that will mean.

We've been fighting for "open and transparent" nuclear regulation, and independent regulators, for decades. So we can tell the Japanese people that the #1 obstacle we have faced in achieving that -- is the NRC itself!

And although MacFarlane hasn't been in office long, there's no reason to expect a change. No changes appears in the offing here in California, where the next NRC meeting about San Onofre will be held with the pubic in absentia -- 2700 miles away, in Maryland.

The NRC continues to work in collusion with the nuclear industry to keep old, dilapidated nuclear power plants open forever -- 20 year licenses automatically become 40, then 60, then who-knows-what. It doesn't seem to matter to the NRC that everywhere they look, reactors are leaking tritium. It doesn't seem to matter that there is a "waste confidence" issue that federal judges have ruled needs to be resolved. And it doesn't seem to matter that all over America, nuclear power plants are crumbling due to age. Parts are rusting out and failing abruptly (Davis-Besse's "hole in the reactor pressure vessel head" in 2002 is a classic example, and Vermont Yankee's collapsed cooling system in 2007 is another). Major components have failed at numerous nuclear power plants, and it's only a matter of time before there's a U. S. meltdown. Will it be San Onofre?

And what will Macfarlane and the NRC do when there is a U. S. meltdown?

Mitigate! Mitigate?

What does THAT mean? Those who have been following nuclear issues for decades (like myself) know it means NOTHING. After a nuclear accident, the poisons blanket the area, thousands of lethal doses per square mile, maybe tens of thousands, maybe millions.

Accidents displace people and contaminate the land. Hundreds of square miles around Fukushima Dai-ichi are no longer inhabitable. So what does "mitigation" mean? Nothing.

Imagine if we were to lose ALL of Southern California due to ONE industrial accident! That's what happened in Japan. San Onofre could make Los Angeles AND San Diego, and all points in-between, uninhabitable for generations in just a few hours. Fukushima is still spewing poisons into the air and water -- hence the white suits and respirators for the visitors and workers. San Onofre can do the same thing.

Macfarlane said the Fukushima accident "profoundly changed the nuclear safety landscape and brought a new urgency to improving nuclear safety worldwide." But here in Southern California, the NRC won't force San Onofre to stop trying to restart a broken, old, dilapidated, nuclear reactor! And there is NO transparency, no openness, no independence! Citizens cannot speak to regulators in an adjudicatory process, that is: They can be lied to. No official records of the meetings and hearings are kept, no one is under oath. Promises are made and broken. Nothing changes.

Macfarlane said we've "learned a considerable amount" since the 3/11/11 accident. Have we? Here in California is a perfect opportunity to shut down a dangerous old reactor near numerous earthquake faults AND in a tsunami inundation zone. But instead the utility is trying to spend billions of dollars (of ratepayer's money) to keep San Onofre operating. And meanwhile, the utility actively blocks or delays numerous renewable energy projects in order to appear to "need" San Onofre. And the state regulators have no shame: They give San Onofre everything it needs.

Friday Macfarlane will meet with Japanese regulators and then, this weekend, with officials from around the "global nuclear regulatory" community. Let's hope when she gets back to America, she converts lip service into action.

Sincerely,

Ace Hoffman
Carlsbad, CA

---

... online addendum:  Myla Reson (and others) sent this essay, and someone she sent it to added the following awesome pictures from Sandy to it, and Myla sent a copy to me.  Indian Point NPP and many others were affected by Sandy and could have been destroyed, with a little bad luck.  Then NYC would be lost hundreds or even thousands of years, and millions of people would be permanently displaced.  CLOSE THE NUKES!  SAVE BILLIONS OF DOLLARS AND MILLIONS OF LIVES!

--------------------------------------------

Sent: Wednesday, December 19, 2012 2:00 PM

Subject: Fwd: Hurricane Sandy: Striking Photographs

Hurricane Sandy Unusual Photographs

Absolutely incredible, especially the shark going thru the streets of NJ and the scuba diver in the subway system.

Statue of Liberty with the storm approaching!! 

Nuclear power: Always made to look a lot cheaper than it really is.

12/10/2012

Dear Readers,

A few weeks ago Southern California Edison (SCE) was given several billion dollars by the California Public Utilities Commission (CPUC) in a General Rate Case (GRC). The timing was perfect for SCE. The Order Initiating Investigation (OII) regarding San Onofre's twin-reactor wear-and-tear problems is currently in a nebulous 45-day "grace" period, and so the fact that San Onofre wasn't running and might never run again wasn't factored in to the GRC that the CPUC just approved -- it was as if they didn't know.

The OII is small potatoes to SCE. To them, the OII is all about the money, and they're trying to keep as much of it as possible. SCE doesn't really care about who pays -- they don't expect it to cost them AT ALL: They're sure that the steam generator (SG) manufacturer, Mitsubishi Heavy Industries (MHI) will cover some of the costs, insurance will cover even more, and the ratepayers will cover the rest.

What SCE cares about -- all they care about -- is that the work to restart/rebuild San Onofre be allowed to proceed, and that the ratepayer's rates don't go down just because the -- very expensive -- power plant is off-line. San Onofre's monthly expenses are enormous whether it's running or not. SCE wants ratepayers to pay for rebuilding the reactors, but SCE still doesn't know how they'll do that. In the meantime, they simply want the ratepayers to keep paying for San Onofre's upkeep.

The effort to restart San Onofre is a totally bogus scam for a totally terrible reason: To create deadly poisons in enormous quantities and risk releasing those poisons into the environment, destroying Southern California. Poisons with nowhere safe to put them anywhere. SCE wants to produce some electricity along with these poisons, the poisons will remain but the electricity which will be gone in a flash. Furthermore, the electricity could easily be produced by renewable resources, especially if the same money that will be poured into San Onofre were to be put into solar rooftops and wind turbines instead.

SCE plans to have the ratepayer-funded rebuilding completed within 3 or 4 years -- or more. The replacement SGs that failed will be replaced again, with better-positioned anti-vibration supports and proper clearances between the tubes. SCE wants MHI, the SG manufacturer, to pay the full amount of their potential liability. But who is really to blame? Considering the nearly 1 billion dollar cost and the potential consequences of failure, SCE surely had an obligation to properly inspect the SGs, and to understand how they function. SCE should have carefully checked MHI's work before and after installing and using the new SGs. They should have seen that the tolerances weren't right. But instead, three weeks after Unit 2 was shut down for refueling anyway for the first time since the SG replacement, during which time a reasonable inspection would have uncovered thousands of unusual wear points, Unit 3 sprung a leak and we almost lost SoCal.

SCE plans to have new SGs in BOTH reactors by 2022 at the very latest. Why then? Their current license extension expires then, and they'll want to secure another extension to operate the reactors for another 20 years, and 20 more after that -- and 20 more again, after that! Endlessly.

SCE claims the "new" new SGs will be good for 60 years, just like they told us last time, and the time before that. But lots of other parts are rusting out too. Valves along the Main Steam Lines, for instance? What near the sea DOESN'T rust?!? SCE wants such parts excluded from the "reasonableness review" of SanO that will be part of the OII. Piece by piece, the whole reactor needs replacing. but don't tell the citizens it's falling apart! (And not just the old parts, but the new parts are falling apart, too!)

SCE attempts to claim that SanO belongs in the category of facilities "needed to maintain the reliability of the electric supply" even though we've seen that it's NOT needed, since it's been off since January, and there have been no blackouts or brownouts, despite little or no preparation for a long-term outage by the utility company.

SCE is using the claim of SanO being "needed" to demand all the money necessary to repair it from the ratepayers, courtesy of the CPUC. SCE is demanding that SanO be considered necessary even though it isn't. And they want the long-term costs of waste storage to be excluded from considerations about the costs of SanO, too! And the costs of decommissioning, other repairs, etc.. And the costs of accidents!

Nuclear power: Always made to look a lot cheaper than it really is.

Interestingly, SCE continues to admit that they don't know what really went wrong in Unit 3, that they don't know what the important differences are between the two units, and that they don't know what will happen if they try to run at a lower power. SCE just figures that either the Unit 2 SGs won't break in the first five months, OR if they do break, it will be a simple leak, small enough to be "harmless" but large enough to detect, like what happened, luckily enough, last January 31, 2012. SCE does not contemplate, or believe, that a cascade of tube failures might occur, even though they acknowledge not knowing why Fluid Elastic Instability plagued Unit 3 but hardly touched Unit 2 -- if at all.

SCE is specifically ignoring any discussion of the possibility that restart will result in a catastrophic destruction of the entire SoCal region, where eight and a half million people live. Instead, they requested that the OII be strictly limited in scope to the costs and problems of restarting BOTH units, and to ensuring that the ratepayers pay for it ALL in advance (again).

SCE cites several cases that they say prove a history of OIIs taking a long time and being tied to their next upcoming GRC (which is in 2015). They want the OII to be deferred until all the other legal cases are fought out in court or hearings or wherever, so that the total costs will be adjusted by any amounts they win in those proceedings. Some of these litigations are relatively small and all of them could drag on for years.

SCE doesn't want a variety of costs they say are not directly related to the outage to be included in the refundable amounts. These include costs for spent fuel in the spent fuel pools and in dry casks, and security costs. But NONE of these costs would be incurred -- they would not exist -- if SanO were ANY other kind of power plant other than a nuke plant. So as far as I can tell, these costs ARE directly related to the cost of San Onofre being what it is -- a nuke plant that doesn't work. Since it was SCE's decision to build a nuke plant instead of a solar, hydro, wind or other renewable energy resource, these site-specific costs SHOULD be included in the refundable amount, in my opinion.

Southern California Edison owns a lot of things: Nuclear power plants that don't work and yet still risk catastrophic failure, fossil fuel plants that pollute the air, transmission lines that should be buried but that's too expensive, smart meters... and apparently, they think they own the CPUC, as well.

Ace Hoffman
Carlsbad, CA

Acronyms in this essay:

CPUC - California Public Utilities Commission (headed by ex-SCE president Michael Peevey)
GRC - General Rate Case (decided by the CPUC every 3 years or so)
MHI - Misubishi Heavy Industries (made the replacement SGs)
OII - Order Initiating Investigation (called for by the CPUC)
SCE - Southern California Edison (an Edison International Company)
SG - Steam Generator (they were poorly designed)

========================================================

Press Release: SCE’s Claims About SONGS Unit 2 Steam Generator Operating Pressures Are Erroneous ...

Subject: Press Release: SCE�s Claims About SONGS Unit 2 Steam Generator Operating Pressures Are Erroneous ...

Press Release

The DAB Safety Team: December 7, 2012

Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261

SCE's Claims About SONGS Unit 2 Steam Generator Operating Pressures Are Erroneous Because They Conflict With SCE's Submitted NRC Reports And SCE's Plant Procedures (Operational Data).

Now SCE is claiming in their Unit 2 Restart documents, "Limiting power to 70% significantly reduces fluid velocity. The reduction in fluid velocity significantly reduces the potential for FEI."  What they are not saying is that reducing power to 70% significantly increases the steam generator operating pressures, (as the NRC said in its AIT Report) which will:

• Increase the pressure inside all the already damaged SG tubes
• Do nothing to completely eliminate FEI from happening at any time during normal plant operations, and especially during a MSLB or similar accident, which can cause a nuclear incident or worse!

SCE's attempt in using evasive and misleading technical inconsistencies to justifying their dangerous and possibly catastrophic restart plan cannot hide the truth, revealed in their actual plant operational data provided to the NRC and published in the NRC AIT Report.






Background History:

After the radioactive leak occurred in the San Onofre Unit 3 steam generator, Arnie Gundersen along with a team of anonymous steam generator experts were the first ones in the industry to absolutely state, "The pitch to diameter ratio of tubes in the original CE generators is dramatically different from any of the Westinghouse generators fabricated by Mitsubishi.  As water moves vertically up in a steam generator, the water content reduces as more steam is created.  With the Mitsubishi design the top of the U-tubes are almost dry in some regions. Without liquid in the mixture, there is no damping against vibration, and therefore a severe fluid-elastic instability developed.  The real problem in the replacement steam generators at San Onofre is that too much steam and too little water is causing the tubes to vibrate violently in the U-bend region. The tubes are quickly wearing themselves thin enough to completely fail pressure tests. Even if the new tubes are actively not leaking or have not ruptured, the tubes in the Mitsubishi fabrication are at risk of bursting in a main steam line accident scenario and spewing radiation into the air."



SCE's Restart Plan Justification Is Just Scientific Misinformation:



Based on analysis of the NRC AIT Report, Westinghouse's Operational Assessment, SONGS procedures, operational data, plant daily briefing sheets and engineering calculations the DAB Safety Team concludes the following:



*      Secondary side lower pressures (833 psi) along with higher reactor thermal power and design deficiencies (low tube clearances) at 100% power created conditions of "ALMOST NO WATER" in certain regions of both Unit 3 steam generators tube bundles.  This resulted in fluid elastic instability, where unprecedented tube-tube wear was observed.  At the June 18, 2012 AIT presentation, the NRC said, "Throughout the US nuclear industry, this is the first time more than one steam generator tube failed pressure testing... Eight tubes failed. The pressure testing identified that the strength of eight tubes was not adequate and structural integrity might not be maintained during an accident... this is a serious safety issue."  Southern Californians were lucky, that SONGS Unit 3 tube leakage was detected and stopped in time.  Otherwise, this condition could have potentially caused a reactor meltdown like Fukushima in Southern Californian's backyards. 

*      Secondary side higher pressures in Unit 2 (864-942 psi) at 100% power negated the effects of  "low tube clearances" and prevented steam "dry-out" (high void fractions) in the Unit 2 tube bundle region, where no fluid elastic instability (tube-tube wear) was observed. 



The DAB Safety Team's findings are summarized as follows:



*      DAB Safety Team "Strongly Agrees" with Arnie Gundersen and his team of anonymous steam generator experts and with MHI on the causes of fluid elastic instability in Unit 3.  What did SCE do, instead of thanking Arnie Gundersen, who first identified the real cause of the problem, tried to discredit him by implying, "What does he know about steam generators, he is just a high school math teacher." [See Mr. Gundersen's actual credentials, below.]

*      DAB Safety Team "Agrees" with Westinghouse, why fluid elastic instability did not occur in Unit 2.

*      DAB Safety Team "Strongly Disagrees" with both SCE's conclusions "that fluid elastic instability Most Likely Occurred in Unit 2" and "secondary side operating parameters were similar in the U3 and U2 SGs." 

*      DAB Safety Team "Strongly Disagrees" with NRC that the differences in the actual operation between units and/or individual steam generators had an insignificant impact on the results and in fact, the NRC AIT team did not identify any changes in steam velocities or void fractions that could account for the differences in tube wear between the units or steam generators.  Discussions with two of the NRC panel members gives us the perception that the NRC panel members disagree amongst themselves and also with SCE on the effect of operational parameters on fluid elastic instability in Unit 2 Steam Generator E-089.



Adverse operational conditions, such as larger reactor thermal power and lower steam generator pressures (e.g., 833 psia) and design deficiencies (low tube clearances and no-in-plane fluid elastic instability structural protection) cause areas in the U-tube bundle of a nuclear steam generator to have "ALMOST NO WATER" as observed in SONGS Unit 3 steam generators.  When this happens, fluid elastic instability occurs and the thin steam generator tubes carrying radioactive coolant move with large sprinting amplitudes and hit the neighboring tubes with violent and repeated impacts.  Therefore, multiple tube failures can occur, as was observed in SONGS Unit 3 at main steam line break testing conditions.



MHI states, "The higher than typical void fraction is a result of a very large and tightly packed tube bundle, particularly in the U-bend, with high heat flux in the hot leg side. This high void fraction is a potentially major cause of the tube FEI, and consequently unexpected tube-to-tube wear (as it affects both the flow velocity and the damping factors). In general, larger thermal power is more severe for vibration, because the steam flow rate increases. At constant thermal power, lower steam pressure is more severe for vibration than higher pressure." MHI is indirectly saying that steam generator pressures of 833 psia created fluid elastic instability in Unit 3, where unprecedented tube-to-tube wear was observed.  AREVA states, "At 100% power, the thermal-hydraulic conditions in the U-bend region of the SONGS replacement steam generators exceeded the past successful operational envelope for U-bend nuclear steam generators based on presently available data." MHI has officially notified the NRC that all SONGS damaged RSG Tubes subject to tube-to-tube wear (FEI) should be plugged and or stabilized.  SCE cannot certify this as having been done, since they have not inspected the majority of Unit 2's RSG tubes using the most advanced technology, as indicated in HMI's official notice to the NRC.  Again SCE is caught guessing about the amount of tube fatigue damage, which directly affects the RSG tube structural integrity; all RSG tubes are subject to tube-to-tube wear, extreme pressure variations and other stresses during a MSLB or other unanticipated operational transients.



NRC AIT Report states, "The team performed a number of different thermal-hydraulic analysis of Units 2 and 3 steam generators. The output of the various analyses runs were then compared and reviewed to determine if those differences could have contributed to the significant change in steam generator tube wear. It was noted that Unit 3 ran with slightly higher primary temperatures, about 4 degrees F higher than Unit 2. The result of the independent NRC thermal-hydraulic analysis indicated that differences in the actual operation between units and/or individual steam generators had an insignificant impact on the results and in fact, the team did not identify any changes in steam velocities or void fractions that could attribute to the differences in tube wear between the units or steam generators. It should be noted that increases in primary temperature and steam generator pressures has the effect of reducing void fractions and peak steam velocities, which slightly decreases the conditions necessary for fluid elastic instability and fluid-induced vibration. The analysis included the varying of steam generator pressures from 833 to 942 psia."



SCE says in their Root Cause Analysis, "Secondary side operating parameters were similar in the U3 and U2 SGs and well within their design limits (e.g., steam generator pressures, 833 psia)." Note, NO mention varying the pressure to 942 psia at all...





Copyright December 7, 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.

=====================================================

Arnie Gundersen

Arnie Gundersen has 40-years of nuclear power engineering experience. He attended Rensselaer Polytechnic Institute (RPI) where he earned his Bachelor Degree cum laude while also becoming the recipient of a prestigious Atomic Energy Commission Fellowship for his Master Degree in nuclear engineering. Arnie holds a nuclear safety patent, was a licensed reactor operator, and is a former nuclear industry senior vice president. During his nuclear power industry career, Arnie also managed and coordinated projects at 70-nuclear power plants in the US.  (from Fairewinds Associates)

===================================================== Press Release

The DAB Safety Team: December 7, 2012

Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261

SCE's Claims About SONGS Unit 2 Steam Generator Operating Pressures Are Erroneous Because They Conflict With SCE's Submitted NRC Reports And SCE's Plant Procedures (Operational Data).

Now SCE is claiming in their Unit 2 Restart documents, "Limiting power to 70% significantly reduces fluid velocity. The reduction in fluid velocity significantly reduces the potential for FEI."  What they are not saying is that reducing power to 70% significantly increases the steam generator operating pressures, (as the NRC said in its AIT Report) which will:

• Increase the pressure inside all the already damaged SG tubes
• Do nothing to completely eliminate FEI from happening at any time during normal plant operations, and especially during a MSLB or similar accident, which can cause a nuclear incident or worse!

SCE's attempt in using evasive and misleading technical inconsistencies to justifying their dangerous and possibly catastrophic restart plan cannot hide the truth, revealed in their actual plant operational data provided to the NRC and published in the NRC AIT Report.






Background History:

After the radioactive leak occurred in the San Onofre Unit 3 steam generator, Arnie Gundersen along with a team of anonymous steam generator experts were the first ones in the industry to absolutely state, "The pitch to diameter ratio of tubes in the original CE generators is dramatically different from any of the Westinghouse generators fabricated by Mitsubishi.  As water moves vertically up in a steam generator, the water content reduces as more steam is created.  With the Mitsubishi design the top of the U-tubes are almost dry in some regions. Without liquid in the mixture, there is no damping against vibration, and therefore a severe fluid-elastic instability developed.  The real problem in the replacement steam generators at San Onofre is that too much steam and too little water is causing the tubes to vibrate violently in the U-bend region. The tubes are quickly wearing themselves thin enough to completely fail pressure tests. Even if the new tubes are actively not leaking or have not ruptured, the tubes in the Mitsubishi fabrication are at risk of bursting in a main steam line accident scenario and spewing radiation into the air."



SCE's Restart Plan Justification Is Just Scientific Misinformation:



Based on analysis of the NRC AIT Report, Westinghouse's Operational Assessment, SONGS procedures, operational data, plant daily briefing sheets and engineering calculations the DAB Safety Team concludes the following:



·      Secondary side lower pressures (833 psi) along with higher reactor thermal power and design deficiencies (low tube clearances) at 100% power created conditions of "ALMOST NO WATER" in certain regions of both Unit 3 steam generators tube bundles.  This resulted in fluid elastic instability, where unprecedented tube-tube wear was observed.  At the June 18, 2012 AIT presentation, the NRC said, "Throughout the US nuclear industry, this is the first time more than one steam generator tube failed pressure testing…. Eight tubes failed. The pressure testing identified that the strength of eight tubes was not adequate and structural integrity might not be maintained during an accident… this is a serious safety issue."  Southern Californians were lucky, that SONGS Unit 3 tube leakage was detected and stopped in time.  Otherwise, this condition could have potentially caused a reactor meltdown like Fukushima in Southern Californian's backyards. 

·      Secondary side higher pressures in Unit 2 (864-942 psi) at 100% power negated the effects of  "low tube clearances" and prevented steam "dry-out" (high void fractions) in the Unit 2 tube bundle region, where no fluid elastic instability (tube-tube wear) was observed. 



The DAB Safety Team's findings are summarized as follows:



·      DAB Safety Team "Strongly Agrees" with Arnie Gundersen and his team of anonymous steam generator experts and with MHI on the causes of fluid elastic instability in Unit 3.  What did SCE do, instead of thanking Arnie Gundersen, who first identified the real cause of the problem, tried to discredit him by implying, "What does he know about steam generators, he is just a high school math teacher." [See Mr. Gundersen's actual credentials, below.]

·      DAB Safety Team "Agrees" with Westinghouse, why fluid elastic instability did not occur in Unit 2.

·      DAB Safety Team "Strongly Disagrees" with both SCE's conclusions "that fluid elastic instability Most Likely Occurred in Unit 2" and "secondary side operating parameters were similar in the U3 and U2 SGs". 

·      DAB Safety Team "Strongly Disagrees" with NRC that the differences in the actual operation between units and/or individual steam generators had an insignificant impact on the results and in fact, the NRC AIT team did not identify any changes in steam velocities or void fractions that could account for the differences in tube wear between the units or steam generators.  Discussions with two of the NRC panel members gives us the perception that the NRC panel members disagree amongst themselves and also with SCE on the effect of operational parameters on fluid elastic instability in Unit 2 Steam Generator E-089.



Adverse operational conditions, such as larger reactor thermal power and lower steam generator pressures (e.g., 833 psia) and design deficiencies (low tube clearances and no-in-plane fluid elastic instability structural protection) cause areas in the U-tube bundle of a nuclear steam generator to have "ALMOST NO WATER" as observed in SONGS Unit 3 steam generators.  When this happens, fluid elastic instability occurs and the thin steam generator tubes carrying radioactive coolant move with large sprinting amplitudes and hit the neighboring tubes with violent and repeated impacts.  Therefore, multiple tube failures can occur, as was observed in SONGS Unit 3 at main steam line break testing conditions.



MHI states, "The higher than typical void fraction is a result of a very large and tightly packed tube bundle, particularly in the U-bend, with high heat flux in the hot leg side. This high void fraction is a potentially major cause of the tube FEI, and consequently unexpected tube-to-tube wear (as it affects both the flow velocity and the damping factors). In general, larger thermal power is more severe for vibration, because the steam flow rate increases. At constant thermal power, lower steam pressure is more severe for vibration than higher pressure." MHI is indirectly saying that steam generator pressures of 833 psia created fluid elastic instability in Unit 3, where unprecedented tube-to-tube wear was observed.  AREVA states, "At 100% power, the thermal-hydraulic conditions in the U-bend region of the SONGS replacement steam generators exceeded the past successful operational envelope for U-bend nuclear steam generators based on presently available data." MHI has officially notified the NRC that all SONGS damaged RSG Tubes subject to tube-to-tube wear (FEI) should be plugged and or stabilized.  SCE cannot certify this as having been done, since they have not inspected the majority of Unit 2's RSG tubes using the most advanced technology, as indicated in HMI's official notice to the NRC.  Again SCE is caught guessing about the amount of tube fatigue damage, which directly affects the RSG tube structural integrity; all RSG tubes are subject to tube-to-tube wear, extreme pressure variations and other stresses during a MSLB or other unanticipated operational transients.



NRC AIT Report states, "The team performed a number of different thermal-hydraulic analysis of Units 2 and 3 steam generators. The output of the various analyses runs were then compared and reviewed to determine if those differences could have contributed to the significant change in steam generator tube wear. It was noted that Unit 3 ran with slightly higher primary temperatures, about 4°F higher than Unit 2. The result of the independent NRC thermal-hydraulic analysis indicated that differences in the actual operation between units and/or individual steam generators had an insignificant impact on the results and in fact, the team did not identify any changes in steam velocities or void fractions that could attribute to the differences in tube wear between the units or steam generators. It should be noted that increases in primary temperature and steam generator pressures has the effect of reducing void fractions and peak steam velocities, which slightly decreases the conditions necessary for fluid elastic instability and fluid-induced vibration. The analysis included the varying of steam generator pressures from 833 to 942 psia."



SCE says in their Root Cause Analysis, "Secondary side operating parameters were similar in the U3 and U2 SGs and well within their design limits (e.g., steam generator pressures, 833 psia)."  Note, NO mention varying the pressure to 942 psia at all…





Copyright December 7, 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.

=====================================================

Arnie Gundersen

Arnie Gundersen has 40-years of nuclear power engineering experience. He attended Rensselaer Polytechnic Institute (RPI) where he earned his Bachelor Degree cum laude while also becoming the recipient of a prestigious Atomic Energy Commission Fellowship for his Master Degree in nuclear engineering. Arnie holds a nuclear safety patent, was a licensed reactor operator, and is a former nuclear industry senior vice president. During his nuclear power industry career, Arnie also managed and coordinated projects at 70-nuclear power plants in the US.  (from Fairewinds Associates)

=====================================================

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Ace Hoffman
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Carlsbad, CA
Email: ace [at] acehoffman.org

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