NRR RAI Answers Will Prevent Any SCE Restart At San Onofre
The 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 220.127.116.11.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.”
The DAB Safety Team’s Response:
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 18.104.22.168.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 NRR, 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.”
Southern California’s future is now in the hands of the NRR: As shown in this section, the SONGS RSG’s U-Tube bundle and Anti-vibration Bar Structures are not designed like Palo Verde RSGs to handle high steam flows, high velocities and to prevent the formation of highly localized steam dry-outs and TTW (FEI) for operation up to the RTP. The “defectively designed and degraded” Unit 2 RSGs, if operated, will suffer additional radioactive tube leaks like SONGS Unit 3, Mihama Unit 2, North Ana, Indian Point 2 and Craus. Therefore, SCE CANNOT PROVIDE AN ACCEPTABLE OPERATIONAL ASSESSMENT TO THE NRR, 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 the 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.”
The DAB Safety Team’s CONCLUSIONS
1. Based on an in-depth review of the above listed documentation and direct observation of Plant Operators and SONGS Emergency Response Organization Performance, the DAB Safety Team agrees with Dr. Johan Hopenfeld’s published concerns and concludes that Operator Action is not feasible to stop a major nuclear accident in Unit 2 in the first 15 minutes of a MSLB, stuck open SG safety valve, Earthquake, cascading SG tube ruptures and or any other combination of Un-anticipated operational transients, during the proposed 5-month trial period of the already heavily damaged Unit 2 RSG’s at any power setting.
2. The Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation must now formally address Dr. Johan Hopenfeld’s published concerns, as mentioned in Response to NRR RAI#32 - Technical in light of the eight RSG tube failures at SONGS at main steam line break testing conditions, and the cascading effect that these failures prove is a very serious safety issue, that reactor operators do not currently have the ability to control. which might result in significant risk impacts such as a nuclear meltdown.
Copyright December 31, 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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