Thursday, December 6, 2012

SCE’s Technical Ability To Perform Safe Restart Questioned

SCE’s misleading and embarrassing technical presentation at their NRC public meeting when explaining fluid elastic instability in SONGS Unit 2, creates doubts about Edison’s ability to perform a safe restart of their damaged “Radiation Steaming Crucibles” aka Replacement Steam Generators (RSG's).

After spending almost a year, wasting hundreds of millions of dollars of rate payer’s money and hiring World’s Best Experts, Southern California Edison brought out SONGS Senior Vice President of Engineering, Tom Palmisano, on November 30, 2012 (Friday night) to give an intense technical presentation and a dazzling performance in a bid to convince the regulators they should be able to restart Unit 2 at the plant. However, Palmisano failed miserably to convince the DAB Safety Team, NRC Region IV Panel and the Public/Technical Experts, that Southern Californians will be safe from the effects of a potential nuclear radiological accident by the restart of Unit 2’s “Sick and Unsafe” Steam Generators by operating them at 70% power for a trial period of 5 months.  When questioned by NRC Panel Members, the unprepared and uncomfortable Palmisano tasked with convincing the NRC, the Public and the News Media that Unit 2 is safe for restart “stumbled several times during the presentation”, then in response to the panel members questions for further technical details said sometimes irritatingly, “I will get back to you” and then finally “hesitantly” admitted, “SCE and MHI analysis are still not yet complete and will continue for several months for a detailed analysis and investigation to this problem.” 

Palmisano declared with his face beaming that tube-to-tube wear was caused “Most Likely” by in-plane vibrations (fluid elastic instability) in Unit 2 Steam Generator E-089 (U2SGE089).  Two affected tubes in U2SGE089 with 14% wear depth were plugged and they preventatively plugged 321 tubes to conservatively add to the safety margin.  It is astonishing and alarming to note that SCE’s Vice-President contradicted the World’s Leading and Pioneering Nuclear Plant Designer, Westinghouse Operational Assessment, which concluded, “ In-plane vibrations (fluid elastic) instability did not occur in U2SGE089 in two affected tubes.  The tube-to-tube wear is most likely a result of out-of-plane vibrations (flow-induced random vibrations) of the two tubes in close proximity to the level of contact during operation.”

The DAB Safety Team perception is that Palmisano is either pretending or really does not understand the Westinghouse Operational Assessment’s conclusions regarding the adverse effects of fluid elastic instability and flow-induced random vibrations, which caused the January 31, 2012, radioactive leak in one of the SONGS Unit 3’s brand new 680 million dollar replacement steam generators (RSG’s) reverse-engineered by the inexperienced SCE in-house engineers and manufactured at the direction of complacent Mitsubishi Heavy Industries.  Southern Californians were very lucky, because a potentially serious nuclear accident in progress was stopped by an emergency shut down. 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” pressure testing and therefore were plugged, after only 11 months of operation.  After that, several hundred Alloy 690 Thermally Treated tubes were also plugged due to tube-to-tube wear. SCE did not disclose intentionally to the public that one Unit 2 tube had also experienced a 90% through wall wear due to a MHI Manufacturing retainer bar defect.  Southern Californians were once again very lucky that a serious nuclear accident was prevented by a planned refueling shut down. SONGS RSG’s now have more damaged and/or plugged tubes than all the rest of the US reactor fleet combined. Based on analysis of NRC AIT Report and SONGS Procedures, Operational Data, Plant Daily Briefing Sheets, Engineering Calculations and conversations with Plant Personnel, the DAB Safety Team disagrees with SCE and confirms Westinghouse Operational Assessment conclusions that fluid elastic instability did not occur in Unit 2 Steam Generator E-089.  The DAB Safety Team 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.

The inexperienced and complacent SCE Engineers in a rush to make profits for SCE Officers and Shareholders ignored: (a) CPUC advice on applying to NRC for increased plugging limit to extend the life of Original Steam Generators, and (b) SDG&E opposition to the wisdom and viability of the RSG Project.  Although SCE was a shareholder in PVNGSs, the SCE Engineers due to time pressure and complacency did a very poor job of Benchmarking, (a) Especially of PVNGS on the new fabrication techniques and design to prevent the adverse effects of fluid elastic instability (FEI) and flow-induced turbulent and random vibrations (FIRV), and (b) Did not keep up with the research of World’s Foremost Expert and other academic scholars to prevent the adverse effects of FEI and FIRV, prepared a defective 10 CFR 50.59 Evaluation and made numerous untested and unanalyzed design changes under the pretense of like-for-like to avoid lengthy and evidentiary public hearings and thorough NRC 50.90 Amendment. If Edison had informed the NRC that the new steam generators were not like-for-like, the more thorough NRC licensing review process would have hopefully identified the design problems before the steam generators were manufactured. The unauthorized and untested design changes made by SCE Engineers to extract more heat and make more money for SCE shareholders from the RSG’s (1729 MWt) compared with the OSG’s (1705 MWt) destroyed the brand new 680 million RSG’s. [Please see DAB Safety Team Papers, “The Big Number 1 Attachment Notes  & “SONGS Insider Secret)
Based on a review of MHI, AREVA and Westinghouse documents, the DAB Safety Team concludes that FEI and MHI Flowering effect redistributed the tube-to-AVB gaps in Unit 3 RSGs.  It is the DAB Safety team’s strong perception that SCE claims that insufficient contact forces in Unit 3 Tube-to-AVB Gaps “ALONE” caused tube to tube wear are misleading, erroneous, egregious, and designed to put the blame on MHI for purposes of making SCE look good in the public eye so they can collect insurance money for their own design defects.
The NRC Chairman stated that SCE is responsible for the work of its vendors and contractors.  The real crux of the problem with the San Onofre Generators, Palmisano said, was the outdated mathematical model Mitsubishi used. There were mistakes in the parameters concerning the arrangement of the heat transfer tubes, Palmisano said. MHI States, “Minimizing tube wear was given the first priority in the SONGS RSG specification, design and fabrication, and the tube support design and fabrication was discussed by MHI and SCE in numerous design review meetings.A SCE Engineer along with a MHI Technical Specialist claims in a joint paper published in an International Magazine, “SONGS steam generators are one of the largest in the industry, which called for innovative design solutions and improved fabrication processes when working on the RSG’s. Conceivably, the MHI and Edison project teams faced many tough challenges throughout the entire project in the design, manufacturing and QC areas, when striving to meet the specification requirements.  Both teams jointly tackled all these challenges in an effective and timely manner. At the end, MHI delivered the RSG’s, which incorporated all the latest improvements found throughout the industry, as well as innovative solutions specific to the SONGS RSG’s. In Unit 2, the RSG’s were installed and tested in 2009/10 and in Unit 3 in 2010/11. The RSG post-installation test results met or exceeded the test acceptance criteria for all specified test parameters, thus properly rewarding the effort put into their fabrication.”  Therefore, the DAB Safety Team concludes that SCE engineers did not check the work of MHI with a critical and questioning attitude and did not meet the 10CFR50, Appendix B, Quality Assurance Standards, the NRC Chairman’s Expectations and or NRC Regulations.   The SCE claims about MHI Thermal-Hydraulic Computer Modeling errors are misleading, erroneous and designed to absolve SCE of all the mistakes and put the blame on MHI for purposes of collecting insurance money for using outdated computer codes and to appear blameless themselves before the public.
A NRC Branch Chief gifted with MIT Intelligence, Intuition and a Sixth Sense said, "Sir, to resolve any complex technical problem and understand unclear regulations, you have to, 'Read and reread in between the lines', use, 'Critical questioning and an investigative attitude' and 'Solid Teamwork & Alignment." That NRC Chief, if you asked him about the restart of SONGS Unit 2 “As-Designed and Defective RSGs (aka Radiation Steaming Crucibles)” will say, “In Emergency Planning Space, decisions have to be Accurate and Timely. Under-conservative, rushed and profit-motivated analyses based on limited facts, biased and ambiguous operational data, untested deterministic and probabilistic risk analysis, conflicting theories and differing operational assessments of degraded equipment at even reduced power operations for 150 days with conditional monitoring along with unproven and unreliable compensatory and operator actions represent enormous risks to public health and safety, the environment and Southern California’s economy.”
Unit 2 has hundreds of times more bad tubes and a thousand times more indications of wear on those tubes than any typical reactor in the country with a new steam generator, and nearly five times as many plugged tubes as the rest of the replacement steam generators in the country combined, over a comparable operating period. Therefore, thousands of degraded tubes present a formidable challenge to the Safe Restart of Unit 2 by making it highly vulnerable to localized steam dry-outs, 100% void fractions, fluid elastic instability, flow-induced random vibrations and cascading tube ruptures during unanticipated operational occurrences and/or Main Steam Line Breaks. 

Even at 70% power operations, if a steam line break outside containment were to occur in Unit 2, the depressurization of the steam generators with the failure of a main steam isolation valve to close would result in 100% void fraction in the degraded U-Tube bundle and the straight leg portion between the Tube Support Plates.  This condition of ZERO Water in the steam generators due to low tube clearances would cause fluid elastic instability (FEI) and flow-induced random vibrations, which in all likelihood would then result in massive cascading SG tube failures, involving hundreds of degraded active SG tubes, along with all the damaged inactive (all the plugged /stabilized) SG tubes. With an undetermined amount of simultaneous tube leaks/ruptures, approximately 60 tons of very hot high-pressure radioactive reactor coolant would leak into the secondary system. The release of this amount of radioactive primary coolant, along with an additional approximately 200 tons of steam in the first five minutes from a broken steam line would EXCEED the SONGS NRC approved safety margins. So, in essence, the RSG’s are loaded guns, or a nuclear accident waiting to happen. Any failure under these conditions would allow significant amounts of radiation to escape to the atmosphere and a major Loss Of Coolant Accident (LOCA) could easily result causing much wider radiological consequences and even a potential nuclear meltdown of the reactor!  Since these events would happen at an extremely fast pace, no credit is assumed in the first 5 minutes of the main steam line break accident for: (1) Enhanced Unit 2 Defense-In-Depth Actions - SCE Restart Plan Enclosure 2, Item 9.0, and (2) The differential pressure across the SG tubes necessary to cause a rupture will not occur if operators prevent RCS re-pressurization in accordance with their Emergency Operating - Enhanced Unit 2 Defense-In-Depth Actions - SCE Restart Plan Enclosure 2, Item 5.2,2, Probabilistic Risk analysis.

The Final Question – Is Unit 2 Safe At 70% Power For 5 Months Of Operation?
The Answer Is NO.  

SCE is trying to restart their Unit 2’s degraded RSG’s, which are outside the NORM of the NRC Regulations.  The DAB Safety Team has already answered this question previously in their San Onofre Papers posted on the web.

The DAB Safety Team Expert Panel will issue an unbiased detailed technical response in the near future to Edison’s “November 30, 2012  - Public Meeting Presentation with the Nuclear Regulatory Commission Unit 2 Confirmatory Action Letter November 30, 2012” for the benefit of President Barack Obama, Southern Californians, the NRC Chairman, the NRC Atomic Licensing Board, the NRC Staff, the Senate Committee on Environment & Public Works, EIX/SCE Management, its vendors, contractors, employees and Union workers. The DAB Safety team will issue the following papers in the near future:
·      Evaluation of SCE Unit 2 Restart November 30 Public Meeting NRC Presentation
·      NRC Poor Public Perception and Future Expectations to meet President Obama’s and Senator Barbara Boxers Open Government Initiative and 100% Transparency to avoid Collusion with SCE to ensure the Safety of 8.4 Southern Californians and a Trillion Dollar ECODISASTER
·      SONGS Profit-Motivated, Production over Safety and Retaliating Senior Leadership Team
·      SONGS Fire Safety, Emergency Preparedness and Cyber Security Concerns
·      SONGS Worker Rights and Anonymous NNs

The Final FixDecommission both SONGS Units 2 and 3, or replace them using a 50.90 thorough License Amendment Process and Evidentiary Public Hearings.  According to the DAB Safety Team’s conversation with one of the NRC Panel members, Senators Barbara Boxer and Diane Feinstein have told the NRC that both of them are in favor of Replacement or adequate inspections and repairs of SONGS RSG’s along with a 50.90 thorough NRC License Amendment Process and Evidentiary Public Hearings. 
According to public sources, Pete Dietrich has already announced in internal SONGS staff meetings that Unit 2 will tentatively restart on February 2, 2013.  If confirmed, this is stunning news for the public and gives the clear perception of collusion between the NRC and SCE.  TEPCO’s reported collusion with Japanese Regulators resulted in Fukushima’s catastrophic nuclear accident (a Trillion Dollar Japanese economic, public health & safety radiation nightmare and Eco-Disaster).
The public expects that the NRC complies with President Barack Obama, Senator Barbara Boxer and the NRC Chairman’s Open Government Initiative by using the NRC Branch Chief’s advice and Reactor Oversight Process, when it audits SCE’s Licensing Basis Documents, facility procedures/records, 10 CFR 50.59 Safety Evaluations, Unit 2 Restart Documents and issues/approves Safety Evaluation, License Amendment Applications and Inspection Reports, Responses to Confirmatory Action Letters and other enforcement violations, as appropriate.  The NRC should complete its mission of ensuring public safety with complete public respect, transparency and involvement by issuing all documents, emails, telephone records and holding open and trial-like thorough hearings without any time pressure from SCE, its vendors and contractors.
The position that San Onofre’s “As designed and defective” replacement steam generators (aka radiation steaming crucibles) without replacement or adequate repairs (replacement of tube bundle and anti-vibration supports) are unsafe and fail to meet the Steam Generator Fundamental Tube Integrity Criteria for a Main Steam Line Break Accident is consistent with the recommendations earlier made on this subject by:
·      Arnie Gundersen and his team of anonymous steam generator experts
·      Professor Dan Hirsch
·      Dale Bridgenbaugh (Retired professional nuclear engineer),
·      Union of Concerned Scientist (David Lochbaum, Director of Safety)
·      The DAB Safety Team Panel’s of several SONGS insiders root cause and operation experts
·      Other anonymous steam generator and thermal-hydraulic experts, and
·      Retired NRC Experts 

Copyright December 5, 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 DAB Safety Team: December 6, 2012
Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261