NRC Reports Incomplete, Inconclusive, Inconsistent and Unacceptable

The REAL CAUSE of San Onofre's Unit 3 massively expensive failure...

It appears that a complacent SCE and the inexperienced Mitsubishi engineers did not perform proper academic research and industry comparisons about the potential adverse consequences of the reducing the pressures in the original steam generators. Lowering the pressures were the primary cause of shortening the life of the Original Generators due to increased tube wear and plugging caused by random vibrations and also caused the destruction of the new Unit 3 Replacement Steam Generators due to the same thing. 

In addition, Edison engineers prepared a defective NRC report and design specifications, which were not challenged by Mitsubishi, the manufacturer, and/or adequately reviewed by NRC Region IV. Mitsubishi then at the direction of SCE engineers made numerous untested and unanalyzed design changes to the steam generators under the pretense of “like for like”, exchange and even NRC Region IV Director Elmo Collins said, “The guts of the machinery look …. Different.”

So based on a review of the AIT Report and some of the World’s Experts, the three potential causes, which were significant contributors to the “fatigue damage” in San Onofre Unit 3 and the tube-to-tube wear resulting in the tube leak are as follows:

A. Insufficient internal supports and differences in manufacturing or fabrication of the tubes and other components between Units 2 & 3.

B. Due to modeling errors, the SONGS replacement generators were not designed with adequate thermal hydraulic margin to preclude the onset of fluid-elastic instability.

C. Differences between Unit 2 and Unit 3’s Operational Factors


CONCLUSIONS: Until the NRC can determine that San Onofre is 100% safe to operate at its approved rated power, granting any Unit 2 Restart testing is unacceptable, because if a nuclear accident occurred during testing who would be held liable, the Nuclear Utilities, the Insurance Carriers, the Federal Government, the State of California, the CPUC, the NRC Commissioners, NRC Region IV, EIX/SCE Shareholders & Employees or just the millions of affected southern Californians?  The DAB Safety Team believes that once the true amount of existing tube fatigue and all other associated damage is KNOWN, anything short of a total steam generator rebuild and/or replacement will be unacceptable prior to any restart being authorized by the NRC.

2013 is the year to Decommission San Onofre

For much more on this read:

Allegation – NRC AIT Report Incomplete, Inconclusive, Inconsistent and Unacceptable

Unsafe NRC Computer Model Requires Investigation

Snip from:

Press Release 13-01-22 ATHOS Validity Questioned, Qualifying Investigation Required

The validity of the ATHOS T/H computer model for San Onofre Unit 2 at Main Steam Line Break  conditions requires that the NRC Office of Nuclear Reactor Regulations complete a Qualifying Investigation to assure steam generator tube integrity before any restart decision is made.

PROBLEM STATEMENT: The computer thermal-hydraulic models cannot account for all the mechanical factors and extremely narrow tube-to-tube clearance differences, which would very likely contribute to catastrophic tube-to-tube wear (fluid elastic instability) in San Onofre Unit 2.  In light of the 8 tube failures of Unit 3 at Main Stream Line Break testing conditions, fluid elastic instability can cause cascading tube leakages/ruptures in Unit 2 even at 70% power due to Steam Generator pressure and temperature changes caused by, for example, a main steam line break, earthquake, loss of offsite power, stuck main steam safety valve and/or other operational transients.  The cascading tube failures would “pop like popcorn” (as described by nuclear expert Arnie Gundersen) and cause excessive offsite radiation exposures.  Operator Action as claimed by Edison to re-pressurize the steam generators is not feasible to stop a major nuclear accident in Unit 2 in the first 15 minutes of a Main Stream Line Break,  stuck open SG safety valve, earthquake, steam generator tube ruptures and other operational transients during the preposed 5-month trial TEST PERIOD.

INVESTIGATION REQUEST: The DAB Safety Team seeks to assist the NRR by requesting a Qualifying Investigation, as noted above and by providing additional information, as noted below.

For much more read  DAB Safety Team Documents     “Media Alert 13-01-22 Faulty Modeling And Unreasonable Operator Actions Make San Onofre Restart Unsafe”, “Emergency Preparedness at San Onofre”, “Managing Control Room Safety” and Press Release: “TEST: Viability of Operator Actions to Prevent Offsite Radiation Releases 

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Some useful nuclear phrases:

Normal operational conditions

Normal operational conditions mean that the nuclear power plant is operated according to the Technical Specifications and operational procedures. These also include tests, plant start-up and shutdown, maintenance and refueling.

Anticipated operational transient

An anticipated operational transient means a deviation from normal operational conditions, which is milder than an accident and which can be expected to occur once or several times over a period of a hundred operating years.

 Unanticipated operational transient

An unanticipated operational transient means a deviation from normal operational conditions, which is not proceduralized and Plant Operator does not recognize that condition.   A good example are the so called SONGS Unit 3 false alarm from loose parts vibration monitoring system for which there is no explanation from SCE, NRC or Westinghouse.  Another example would be a leakage from a pump pumping radioactive fluid without any area radiation monitors to warn the operators of the leakage.

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Accident

An accident means such a deviation from normal operational conditions as is not an anticipated operational transient. There are two classes of accident: postulated accidents and severe accidents. Based on the initiating event, postulated accidents are further divided into two sub-classes whose acceptance criteria are described in Guide YVL 6.2.

Postulated accident

A postulated accident means such a nuclear power plant safety system design-basis event as the nuclear power plant is required to withstand without any serious damage to the fuel and without discharges of radioactive substances so large that, in the plant’s vicinity, extensive measures should be taken to limit the radiation exposure of the population.

Severe accident

OMG................. Talk about SanO Nuclear Denial* “severe accident” is not even listed in the 130 page NRC Collection of Abbreviations, but if you do a computer search for it on the NRC website you find this:

Severe accident

A type of accident that may challenge safety systems at a level much higher than expected.

* http://is.gd/XPjMd0
The illogical belief that Nature cannot destroy any land based nuclear reactor, any place anytime

NRC Violating Presidential Directive and the Public Trust

SCE’s PR Machine Is Capable Of Overcoming ALL Hurdles,

Except Good Science And Safety

Albert Einstein also described INSANITY as

Doing the same thing over and over again and expecting different results. 

The DAB Safety Team has challenged previously in their published DAB Safety Team Documents, that Southern California Edison’s controversial plan to restart San Onofre Unit 2 as a “Bogus and dangerous SCE experiment.”  

According to SONGS Anonymous Insiders, SCE’s Engineers were under the false impression that Unit 3 Anti-vibration Structure was built better than Unit 2.  Therefore, SCE Engineers were operating Unit 3 at lower steam pressures than Unit 2 in a test mode to generate more thermal megawatts and thereby generate more electricity.

 To add to Arnie Gundersen’s and John Large’s Technical Affidavits, DAB Safety Team’s investigation reveals that in the process of this “money-hungry experiment”, lower steam pressures in combination with other unapproved and unanalyzed design changes destroyed Unit 3 due to Fluid Elasticity Instability (FEI). SCE and NRC AIT Team both blamed Unit 3 FEI on botched up MHI Computer Modeling and insufficient tube-to-AVB gaps. AREVA, Westinghouse, John Large and the DAB Safety Team findings dispute these statements. The NRC Augmented Inspection Team and the NRR Panel have swept the DAB Safety Team Findings consistently under the rug, in what must be now labeled as a Gov’t cover-up!

The NRC keeps issuing both controversial and conflicting press statements that a decision to allow the restart of Unit 2 could come as early as March 2013.  According to SONGS anonymous insiders, Edison officials have announced in internal SONGS Staff Meetings that a restart decision is imminent in March despite the huge public outcry about safety problems by SCE.  Press reports as of January 14, 2013 state, “Small steps are being taken to prepare for possibly restarting the troubled San Onofre nuclear power plant, even as its future remains clouded with uncertainty, officials said Monday. Nuclear Regulatory Commission senior inspector Greg Warnick said Monday that the agency is beginning to prepare a detailed plan of what would need to be done to bring the plant safely back to service.” (SOURCE: CBS Los Angeles, Associated Press)

NRC’s enforcement history, drama and pre-rehearsed tough questions, press reports, casual relationship and/or protection of SCE officials and utility biased public meetings are just old and cheap regulatory tricks that are now being used to protect the NRC’s own public image and to fool the public into believing that the NRC is really concerned about public safety regarding SCE’s Restart Plan.  The Justice Department & NRR Officials need to set up a legal/technical taskforce to publically question Edison’s design and MHI Engineer’s listed below under oath regarding their:

1. Understanding of their legal obligations under the 10 CFR 50.59 Process,
2. Understanding of problems with the original steam generators,
3. Critical questioning and professional/investigative skills,
4. Efforts made in industry and academic benchmarking to identify and resolve problems with the original steam generators
5. What part did they play in the preparation of design specifications, fabrication, computer modeling, mock-up testing, anti-vibration bar structure, and research required to prevent the adverse effects of fluid elasticity and flow-induced random vibrations in these unique San Onofre Combustion Engineering replacement generators.

Any NRC decision to grant a restart of Unit 2 without a formal 50.90 licensing review along with public participation will be seen as an invitation to risk a Fukushima-type disaster happening in Southern California. 

Read More:  Allegation - NRC Violating President’s Directive And the Public Trust is posted on the web at this link: DAB Safety Team Documents.

Copyright January 17, 2013 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 Attorney

SCE Violated Federal Reg.’s And the Public Trust

Nuclear Experts Agree, San Onofre’s Replacement Steam Generators Are Unsafe

Summation: Based upon our ongoing review of evaluations, engineering analyses, inspections, technical and operational assessment reports prepared by the NRC’s Augmented Inspection Team, MHI, SCE, Westinghouse, AREVA, Professor Daniel Hirsch, industry experts and knowledgeable whistle blowers, along with the recent affidavits prepared by Arnie Gundersen and John Large, we reaffirm the following statements which have been previously substantiated in numerous DAB Safety Team Documents:

1. The DAB Safety Team has been saying for months for a long time that SCE and MHI Engineers did a very poor job in their review of Academic Research Papers and Industry Comparisons about how to prevent the adverse effects of fluid elastic instability in the design of San Onofre's replacement steam generators because the original Combustion Engineering designed steam generators did not experience the adverse effects of fluid elastic instability. Nuclear Expert, John Large statesA, “I have little confidence in the outcome of AREVA’s projection of the time period through which the U2 nuclear plant could be reliably expected to operate without incurring a tube failure or running at a greater risk of a tube failure occurring. ... In my opinion, simply sweeping the fluid elastic instability issue under the carpet on the basis ... it will not reoccur at 70% power is not only disingenuous but foolhardy.” TheNRC chairman has publicly stated, “SCE is responsible for the work of its vendor and its contractor.” DAB Safety Team alleges that SCE actions are in violation of the Federal Regulations, its CPUC Charter, the NRC Chairman Standards and even its own advertised charter of “Overriding Obligations to Shareholders and Public Safety.”


2. Accidents involving steam generator depressurization (main steam line break), station blackout and other anticipated transient events causing steam generators over-pressurization can occur at any time over the full range of normal operating conditions up to Reactor Thermal Power (3438 MWs). Therefore BY DESIGN, these replacement steam generators are NOT capable of protecting their already worn and cracked tubes from radioactive leakages and/or ruptures caused by the above.

3. In Unit 2, these already fatigued, cracked, and heavily degraded tubes can snap, leak and/or rupture at the tube sheet, tube support plate or the unsupported anti-vibration bars mid and free spans during these postulated adverse accident conditions. John Large statesA, “For the MSLB event very high, two-phase fluid cross-flow velocities would be expected to instantaneously develop in the U-bend region, triggering vigorous FEI that could, particularly if the AVB restraints are ineffective, promote violent tube to tube clashing and the potential for a multiple tube failure event.”

4. It is ABSOLUTELY CLEAR, that San Onofre Unit 2 replacement steam generators will likely experience single to multiple tube-to-tube failures (e.g., San Onofre Unit 3, Mihama Unit 2, North Anna, Indian Point 2 and Craus, France, etc.) during these postulated adverse licensed conditions at any power level up to 100% Power (Licensed Reactor Thermal Power of 3438 MWTs).


5. The proposed Defense-in-Depth instrumentation, along with unreliable and unproven operator actions to detect multiple tube leaks/ruptures and/or to re-pressurize the steam generators during these postulated adverse licensed conditions as claimed by Edison are not practical to stop a major nuclear accident from progressing and causing a Unit 2 meltdown.

6. There are conflicting, contradicting, ambiguous and confusing findings between the experts in the Unit 2 Operational Assessments: Such conflicting disagreements over the cause of Tube To Tube Wear reflects poorly on the depth of understanding of this crucially important FEI issue by SCE, each of these SCE consultants and the designer/manufacturer of the Replacement steam generators. The DAB Safety Team’s findings contradict the SCE and all the three NEI qualified, “US Nuclear Plant Designers” findings about Unit 2 FEI (See, Overview – Consequences of a Main Steam Line Break).

7. The DAB Safety Team Comments about SCE 10 CFR 50.59 Safety Evaluation for RSGs: The Big Number 1 Attachment Notes shows the comparison between San Onofre and Palo Verde's Replacement Steam Generator design parameters. Palo Verde has the largest CE RSGs in the world (~ 800 Tons each) and SONGS Replacement Steam Generators are the second largest CE Replacement Steam Generators in the world (~ 620 Tons each). John Large statesA, “In my opinion, the changes, tests and experiments (CTE) inherent in the SCE proposal to restart Unit 2: (a) involve a significant increase in the probability or consequences of an accident previously evaluated; (b) create the possibility of a new or different kind of accident previously evaluated; and (c) involve a significant reduction in a margin of safety. Arnie Gundersen statesB, “It is my professional opinion that Edison should have applied for the 50.59 process so that the FSAR license amendment evaluation and public hearings would have occurred six years ago, prior to creating an accident scenario and facing losses that by the end of this process will easily total more than $1 Billion.” Therefore, the DAB Safety Team concludes that SCE claims as stated are not factual. SCE did not meet the 10CFR50, Appendix B, Quality assurance Standards and has violated the NRC 10 CFR 50.90 Regulations.

8. The Public expects that the Offices of Nuclear Reactor Regulation (NRR) comply with President Barack Obama, Senator Barbara Boxer and NRC Chairman’s Open Government Initiative. Under no circumstances should the NRR permit SCE to restart unit 2 without replacing the defective replacement steam generators, a full NRC 50.90 Licensing Amendment and transparent trial-like public hearings.
A http://libcloud.s3.amazonaws.com/93/80/a/2680/R3218-Large-AF2-redacted_proprietary.pdf
B http://libcloud.s3.amazonaws.com/93/b5/f/2677/2013_1_11_FOE_Gundersen_Affidavit_reEdisonSanOnofreRSG.pdf

Full Media Alert 13-01-15 Allegation - SCE Violated Federal Reg's And The Public Trust is posted on the web at this link: DAB SafetyTeam Documents.

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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 not responsible for the contents of the DAB Safety Team's reports. We continue to work together as a Safety Team to prepare additional: DAB Safety Team Documents, 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 January 14, 2013 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 Attorney

TEN Unresolved Items, Requires NRR Investigate The NRC

The Unsatisfactory Status Of The NRC Region IV Augmented Inspection Team Report Which Contains TEN Unresolved Items, Requires Additional NRR Investigation And Resolution.

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 Chief.

The NRC AIT Report (ADAMS Accession Number ML2012007) identified ten unresolved items in July 2012 that warranted additional follow-up:

1. Adequacy of the post trip/transient procedure;
2. Evaluation and disposition of the Unit 3 loose parts monitor alarms; 
3. Design of retainer bar;
4. Control of original design dimensions;
5. Evaluation of and controls for divider plate repair;
6. Atmospheric controls of Unit 3 steam generators during shipment;
7. No tube bundle support used during shipping;
8. Evaluation and disposition of accelerometer readings during shipping;
9. Adequacy of Mitsubishi’s thermal-hydraulic model;
10. Change of methodologies associated with 10 CFR 50.59 review.

Consistent with existing NRC inspection processes, these unresolved issues will be inspected and dispositioned during follow-up inspection efforts to determine if there are any violations of regulatory requirements.

DAB SAFETY Team Comments. re: NRC AIT Report : It has been almost six months since the issuance of the original report and since that time the NRC AIT Team has completed several follow-up inspections at SONGS.  However, the NRC AIT Team has not publically updated its report on the results of follow-up inspections to resolve the above items and determination of violations of regulatory requirements by SCE. These concerns were expressed to the NRC Region IV Staff and AIT Team at the November 30, 2012 Public Meeting.  Several Environmental, Public and even Pro-Nuclear Groups have repeatedly and publicly stated to the NRC, Atomic Licensing Board and Office of Nuclear Reactor Regulations (NRR): “When it comes to SCE’s mistakes and public policy, NRC Region IV is asleep at the wheel.”  The NRC Chairman has stressed the need for “Independent Regulators” during her recent Fukushima trip. Therefore, these items should be added to the NRR list for resolution.  Especially, items (2), (3), (9) and (10) should be resolved as soon as possible.  In addition, the NRR should made public SCE’s FSAR analysis showing the effect of a Main Steam Line Break for Unit 2 operation up to Reactor Thermal Power on Steam Generator Tube Ruptures (for one (1), four (4), eight (8) or an ever increasing number (a cascade aka Hopenfeld Effect) of tube rupture/failures) in accordance with President Barack Obama, Senator Barbara Boxer and the NRC Chairman’s Open Government Initiative, as these documents directly affect public safety, they must no longer be considered SCE’s “privileged documents” after their SONGS Replacement Generators $680 Million Debacle.

Please see the DAB Safety Team’s Press Release + 12-12-28 Thirty Alarms Demonstrates SONGS Unsafe for details item (2).

This press release will be posted on the web at this link: DAB Safety Team Documents.

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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 not responsible for the contents of the DAB Safety Team's reports.  We continue to work together as a Safety Team to prepare additional : DAB Safety Team Documents, 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.

Press Release

The DAB Safety Team: January 10, 2013

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

Copyright January 2, 2013 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 Attorney