14 Reactor Safety Questions That Edison Needs To Answer Regarding San Onofre

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 San Onofre 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 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 CPCU? 

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 teams mistakes.

2 - Since MHI only had experience building Fort Calhoun’s Generator of less than 320 tons, how did the SCE Engineers Technically Qualify MHI?

3 - Which other utilities’ QA Programs, did SCE take the credit for, to approve Mitsubishi’s quality assurance program. Fort Calhoun? French? Belgium? Japan?

4 – Why did SCE did not apply to NRC for increasing the plugging limit for the Old CE Generators, so they would have had more time to think, research and not rush according to Michael Peevey?

5 - Which CE Replacement Generator US Utilities 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 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 field, or they were just training/sight-seeing?

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 provided all these changes, information and documents to which NRC Engineer, 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 get 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 568 tubes? Did the SCE Engineers tell MHI to increase the length of 9727 tubes and by how much to make up for the 533 tubes?

12 – Why did the SCE Engineers did not question the MHI benchmarking, verification and validation of the FIT-III thermal-hydraulic model?

13 – Why did the SCE engineers did not contact their counter parts at PVNGS for information/advice, since PVNGS has the Largest CE Replacement Generators (800 Tons) in the world, were built in early 2001-2005 time frames and are running successfully?

14 - Were the original CE Steam Generators and new replacement generators exact in Thermal Output (MWe) or were their minor differences?

14 Reactor Safety Questions
That Edison Needs To Answer
Regarding San Onofre 

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.

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Snip From The Report:

Unit 2 now has hundreds of times more bad tubes and a thousand times more indications of wear on its tubes than the 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, over a comparable operating period, in the country combined.  Therefore, the restart of Unit 2 with thousands of degraded tubes present a formidable challenge to the safe restart of Unit 2 plan by making it highly vulnerable to localized steam dry-outs, 100% void fractions, fluid elastic instability, flow-induced random vibrations, cascading tube ruptures during unanticipated operational occurrences and or Main Steam Line Breaks.  In short, SCE is trying to Restart Unit 2’s Degraded RSG’s, which are outside the NORM of the NRC Regulations.

The NRC Chairman has stated that SCE is responsible for the work of its vendors and contractors. Westinghouse states that none of the MHI fabrication issues were extensively analyzed in the SCE root cause evaluation.”  It is the DAB Safety Team’s opinion that SCE claims that insufficient contact forces in Unit 3 Tube-to-AVB Gaps ALONE caused tube "to" tube wear are misleading, erroneous and designed to put the blame on MHI for purposes of making SCE look good in the public’s eyes and for collecting insurance money from MHI’s manufacturing so called defects. 

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The full report will also be posted on the web at this link: San Onofre Papers

or here:  SCE NRC Presentation Analysis + 14 Questions 12-12-17

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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.

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

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.