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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 Fix – Decommission
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.
PRESS RELEASE
PRESS RELEASE
The DAB Safety Team: December 6, 2012
Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261
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