San Onofre's Restart Reports Fail BOTH NRC Safety Definition & Quality Assurance Standards

The DAB Safety Team has serious concerns about SCE’s Unit 2’s Restart Reports, because these reports do not meet the NRC Chairman’s Safety Definition nor do they satisfy the NRC’s 10CFR50, Appendix B Quality Assurance Standards.

Ultimate Responsibility: The top U.S. nuclear safety official, the Chairman of the NRC said earlier this month the operator of the idled San Onofre nuclear plant is ultimately responsible for ensuring the quality of equipment and work provided by vendors or its contractors.  Addressing nuclear industry executives in Atlanta, Nuclear Regulatory Commission Chairman Allison Macfarlane touched upon challenges at the idled San Onofre nuclear station and highlighted the responsibilities of the plant license holder. "This obligation extends to the licensees’ use of vendors and contractors," McFarlane said. "The licensee is ultimately responsible for the work done by their vendors and contractors to ensure they meet our quality assurance requirements." [Source: U-T San Diego November 7-2012]

Question Number 1: Why the massive tube damage at San Onofre aka SONGS?

More than 100 Replacement Steam Generators (RSGs) in the USA with Alloy 690 TT Tubes have been designed, fabricated and tested by Westinghouse, BWI and other vendors, including Fort Calhoun by MHI.  These steam generators have only had very few plugged tubes according to NUREG-1841 and Professor Dan Hirsch’s September 12, 2012 Report.  MHI has built more than 100 Steam Generators since 1970. Only Mihama Unit 2 SG built by MHI had a single tube rupture due to a displaced Anti Vibration Bar.  The question is, why did the SONGS Replacement Steam Generators suffer so much severe degradation in such a short time?  Is this the fault of SCE’s in-house design team, their Performance Specifications coupled with their numerous design changes and or the MHI Fabrication/Testing Technology combined with Faulty Thermal-Hydraulic Computer Codes?   The DAB Safety Team and the Public expected that SCE and their three NEI Qualified, “US Nuclear Power Plant Designers”, Westinghouse, AREVA and MHI would arrive at a concise and clear answer (Meeting the NRC Quality Assurance requirements as stated by NRC Chairman Allison Macfarlane) to this puzzling question in the Unit 2 Return to Service Report.

Observations On Number 1: The SCE Cause Evaluation Report, Operational Assessments reports prepared by SCE, AREVA and Westinghouse, and MHI Technical reports conflict and contradict with each other on the causes and extent of degradation pertaining to the fluid elastic instability in SONGS Unit 2 Steam Generator Replacement Generators (RSGs) and Tube-to-AVB gaps in both Unit 3 and Unit 2 RSG’s.  MHI further states that specific causes that resulted in tubes being susceptible to fluid-elastic excitation are not yet completely known.  Furthermore SCE has not plugged all the 2 tubes in one of the Unit 2 RSG’s nor have they removed the Retaining Bars (RB’s) as recommended by MHI in their latest NRC notification, issued after their preliminary report!

Operational Note On Number 1: Unit 2 was running at higher steam pressures than Unit 3 and lower thermal power than Unit 3.  That is why the void fractions were lower than 98.5% and no fluid elastic instability occurred in Unit 2.  AREVA, Westinghouse, MHI and SCE missed this key observation in the SCE Unit 2 restart Plan. At least one person working at SONGS spoke up about this fact but nobody listened to him and it was ignored because everybody in SCE was focused on blaming MHI to recover the insurance money and or absolving themselves of all blame.  The DAB Safety Team will explain the probable reasons other than the ECT results for Unit 3’s increased clearances between the anti-vibration bars and the tubes in their next Press Release.

Comments And Observations About Number 1: It is the opinion of the DAB Safety Team’s Expert Panel, former NRC Staff and SONGS Concerned Insiders that this Westinghouse Operational Assessment is full of holes based on incomplete inspection data, under-conservative computer modeling and is in effect, just “Smoke & Mirrors,” because:

(1)  SCE Engineers have either not provided, or they are withholding important information from Westinghouse because of  “The consequences of being Wrong, Terminated or Fired,”

(2)  Due to competing and proprietary interests between Westinghouse and MHI, Westinghouse Engineers do not have all the MHI Manufacturing Details and are just guessing in their Deterministic Operational Analysis of Unit 2, the second worst Degraded Replacement Steam Generators in the Operating US Nuclear Fleet,

(3)  Due to Time Pressure exerted by SCE, Westinghouse Staff did not have proper time for independent validation of all facts, documentation and data provided by SCE’s Engineers, in their original report.

(4)  Since nobody knows what really happened, all the Parties have a shared interest to “Operate Unit 2 at reduced power as a nuclear “RSG Tube Wear Test Lab”.

UCS Observations: The Union of Concerned Scientists (UCS) has serious concerns about Southern California Edison’s (SCE) restart plans for San Onofre Unit 2. In a 10/12/2012 letter submitted to the Nuclear Regulatory Commission (NRC), David Lochbaum, Director, Nuclear Safety Project, identified the following issues:

·      Unit 2 replacement steam generator 2SG89 has significantly more wear indications per number of supports than does [Unit 2] replacement steam generator 2SG88. Until the reason for this marked difference between the wear degradation for the Unit 2 replacement steam generators is understood, the operational assessment performed for future operation is suspect.

·      Since all four replacement steam generators came from the same manufacturer, were of the same design, made of the same materials, assembled using the same procedures, and operated under nearly identical conditions in twin reactors, the reason for this marked difference is unclear… [the] explanation is not well documented and therefore appears to be more convenient than factual.

·      The document states that the owner will “administratively limit Unit 2 to 70% reactor power prior to a mid-cycle” outage to inspect the replacement steam generators. What are the legal and safety consequences if the reactor power were to increase to 75%, 85% or 100% power, advertently or inadvertently?  The NRC has licensed San Onofre Unit 2 to operate at 100% power. What would legally prevent the owner from restarting Unit 2 and increasing its output to the NRC licensed limit? The NRC’s enforcement program includes sanctions when its regulations are violated, but nothing if promises are broken. If the NRC agrees that reactor operation at less than 100 percent power is warranted, it should enforce that reduction with an order or comparable legally enforceable document.  However even that will not necessarily prevent its occurrence.  Has NRC even considered that fact?

·       Table 8-1 of Enclosure 2 and its accompanying text attempt to explain how operating Unit 2 at 70% power will prevent the tube-to-tube wear (TTW) experienced on Unit 3 by comparing it to an anonymous reactor (called Plant A). Reliance on one suspect data point (Plant A) is hardly solid justification for operation at 70% power being acceptable.

·      There is no justification in this 80-plus-page document for an operating duration of 150 days.

·      There are no legal means compelling the plant’s owner to shut down Unit 2 after 150 days of operation at or above 15% power.

·      A temporary nitrogen-16 radiation detection system will be installed prior to the Unit 2 startup. However, there is no commitment to use it after startup, or to keep it in service should it stop functioning. The detection system is proposed as a defense-in-depth measure, but there is no assurance it will be operated.  Furthermore, it will NOT provide the necessary warning that tube rupture is eminent.  It will only indicate that it is already occurring.

·      Attachment 6 to Enclosure 2 has proprietary information redacted. Section 1.4 of Enclosure 2 states that the owner used AREVA, Westinghouse Electric Company LLC, and Intertie/APTECH to review the operational assessment. At least one of these companies manufactures replacement steam generators and would therefore be a competitor to Mitsubishi Heavy Industries (MHI), which made the replacement steam generators for San Onofre. If the owner did not withhold the proprietary information from MHI’s competitors, why withhold it at all? If SCE did withhold the proprietary information from these reviewers, what is the value of their independent, but limited, review?

Conclusions And A Final Question: The DAB Safety Team Agrees with NRC Chairwoman Allison Macfarlane that SCE is ultimately responsible for the work done by their vendors and contractors to ensure they meet our quality assurance requirements.  Based upon the review of all Restart Documents and all the issues identified by David Lochbaum, The DAB Safety Team’s Expert Panel along with their SONGS Concerned Insiders opinion that these reports are full of holes and based on incomplete inspection and or operational data, under-conservative computer modeling and represents Smoke & Mirrors which does not meet the NRC Chairwoman’s Safety Definition nor the standards outlined in the 10 CFR Part 50, Appendix B, “Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.”

The Trillion Dollar Question is now, how can the NRC’s Region IV in good faith, even consider having a November 30 Public Hearing, except to possibly give SCE a Billion Dollar Christmas present, by allowing them to restart their damaged Unit 2 without a 50.90 License Amendment Process by completely ignoring the safety of all those living in Southern California due to the potential of having a Trillion Dollar Eco-Disaster at San Onofre because of their already well documented massively damaged RSG tubes?  

PRESS RELEASE 

The DAB Safety Team: November 26, 2012

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

Copyright November 26, 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.

10-18-12 SCE's RSG Testing Update + New NRC Blog Topic

The NRC has just posted this new topic on their blog site:

In Response to Your Letters: Proposed Restart of SONGS Unit 2

by Allison Macfarlane

NRC Chairman

http://public-blog.nrc-gateway.gov/

You are encouraged to add your own comments, but be advised that moderation/posting is glacial!

====== 10/18/12 RESTART NEWS UPDATE =====

Information Concerning SCE's Ongoing RSG  Restart Testing At SanO:

I saw this info and I've had this email conversation with NRC Region IV about it:

(I saw this on Oct. 17, 2012 and sent it to the NRC)

Sir

I saw this posted on Twitter today and wanted to forward it to you, in the hope that it is not factual, because if it is, then the NRC has more problems at San Onofre than just damaged and leaking SG tubes...

This was posted on Facebook:

"ACTION ALERT! San Onofre Nuke Plant could Re-Start Within 10 Days!
From a whistle-blower at San Onofre nuclear plant in Southern California: "We are working on Unit 2, bringing it up from Mode 5 to 4 and are preparing to go from Mode 4 to 3 by the weekend of October 20th. Southern California Edison (SCE) brought in the auxiliary boiler (which runs off of oil), and assigned 12 hour shifts. SCE are making damn sure that no steam leaves the domes for fear the public will catch on. I can’t believe how audacious they are, but for all practical purposes, they are going to restart Unit 2—which still is highly radioactive—without the NRC thoroughly reviewing Edison’s application that was just submitted. Their motivation is to see if they fixed the new reactor head which leaked profusely the first time they tried it. They don’t want anything holding them back from actually restarting when they get the green light from the NRC. The NRC’s Confirmatory Action Letter allows them to take it up to Mode 3 because the reactor is not “critical”, (fission reaction is on hold). They are trying to beat the clock before time runs out on them and the CPUC (California Public Utility Commission) sticks Edison with the cost of the outage instead of the ratepayers.” -M

Question: Has the NRC approved this new TESTING, (as it was my understanding that there would be no restarting until the NRC decided it was safe to do so)?   You should be able to confirm the validity of the above with a simple phone call to the resident inspector at San Onofre...

Hopefully Mr. Elmo Collins will honor his quote, "We don't experiment with safety"...

I look forward to your timely response, as I want to give the NRC a chance to comment before publishing the above.

=====

I got this reply on Oct. 18, 2012:

Southern California Edison is permitted, by their license, and by the Confirmatory Action Letter issued March 27, 2012, to heat up and pressurize Unit 2 to normal operating pressure and temperature.  This heat up is being done using offsite electrical power.  This is NOT starting up the plant.  The safety concern with Unit 2 steam generators is the excessive vibration that occurs during high steam flow conditions in the steam generator, which may result in unexpected and rapid steam generator tube wear.  This cannot occur in the condition the plant is being taken to.  The steam generators will be hot, and pressurized, but there is no heat generation from the reactor, and the heat generation from the auxiliary boiler and reactor coolant (electric) pumps is very small and cannot produce enough energy to cause vibration in the steam generator tubes.  

The NRC has no concern with the structural integrity of the Unit 2 steam generator tubes today, in their current reactor shutdown condition.  The NRC is currently evaluating Southern California Edison’s proposal to restart the reactor.  This proposal states that Unit 2 can be operated, meaning it can start the reactor to produce the large amount of heat and steam flow for 70% of normal full power operation.  This amount of steam flow must be shown to not result in additional unexpected and excessive tube wear, or the NRC will not allow the reactor to be restarted. 

The reactor has not been, and will not be started up until NRC has granted permission.  The “testing” that is being referred to is normal testing that is allowed by the current license at San Onofre.  The “testing” that Mr. Collins was referring to is any test or experiment that is not currently an approved procedure and is outside the safety analysis as described in the facility Updated Final Safety Analysis Report.  As an example, the NRC would not allow the reactor to be restarted, producing the large amount of heat and steam flow, so that the licensee could monitor tube vibration to ‘see’ if excessive vibration is occurring – that would be a “test”.  The licensee must prove, with reasonable assurance, before starting the reactor, that excessive vibration will NOT occur.

Victor Dricks

Public Affairs Officer

U.S. Nuclear Regulatory Commission / Region IV

=====

So I sent this reply yesterday:

Question 1 – Is the pressurized and hot reactor coolant (Any Amount) being circulated through SG 2E-089 under these test conditions?

Question 2 – Does the NRC postulate a MSLB outside containment under these test conditions?

Question 3 – If the answer to Question 1 and 2 is yes, does NRC postulate > 99.6 % steam voiding in the U-Tube Bundle?

 The public is going to ask ,"What is going on between Region IV and the NRC? People need the answers in a hurry.  Is the NRC more concerned about the Safety of The Public or letting Edison get away with whatever they want to do?  If NRC was strict from the very beginning with Edison, things would not have to come to this.  There is still time.  Here is a quote for your benefit, An anonymous participant in an Industry Conference was asking questions and persistently complaining about complex and unclear NRC regulations.  A NRC Branch Chief 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'."

=====

I'll update this post, if I get any additional replies

Best

CaptD

CPUC - DRAFT ORDER INSTITUTING INVESTIGATION REGARDING SONGS UNITS 2 AND 3

The San Francisco-based California Public Utilities Commission on Tuesday published a draft investigation order regarding the idled San Onofre Nuclear Generating Station.

 It will take up the matter at a public meeting Oct. 25 in Irvine. 

                                                   --> Salute to UT's Morgan Lee

COM/MF1/sbf                                     DRAFT                              Agenda ID #11659 

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Order Instituting Investigation on the Commission’s Own Motion into the Rates, Operations, Practices, Services and Facilities of Southern California Edison Company and San Diego Gas and Electric Company Associated with the San Onofre Nuclear Generating Station Units 2 and 3.

Investigation_________

ORDER INSTITUTING INVESTIGATION REGARDING SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3

Complete CPUC Draft Order

snip:

1. Introduction

We open this investigation to consolidate and consider issues raised by the extended outages of Units 2 and 3 at the San Onofre Nuclear Generating Station (SONGS). This includes determining whether to order the immediate removal effective today of all costs related to SONGS from the rates of Southern California Edison Company (SCE) and San Diego Gas & Electric Company (SDG&E), with placement of those costs in a deferred debit account pending the return of one or both facilities to useful service or other possible action. It also includes considering appropriate rate treatment for all SONGS-related costs in other proceedings.

This investigation will consider the causes of the outages, the utilities’ responses, the future of the SONGS units, and the resulting effects on the provision of safe and reliable electric service at just and reasonable rates. Due to the size, location, ownership structure, and unique nuclear licensing requirements of SONGS, the unexpected outages raise particularly complex issues. These issues come before us in many proceedings. This investigation will consider these issues in a consolidated manner that is efficient for the utilities, parties and the Commission. To facilitate that objective, all costs incurred on and after January 1, 2012 that are associated with SONGS shall be tracked in a memorandum account. SCE and SDG&E shall each, within 30 days of today, file with the Energy Division Director and serve on the service list a Tier 1 advice letter to establish that account, including specified subaccounts.

FOE --> San Onofre - Feds Stonewall FOE's Petition For Legal Hearing On Reactor Restart

Posted Oct. 16, 2012,           Salute to FOE!

WASHINGTON, D.C. --  The Nuclear Regulatory Commission’s continued refusal to consider a legally binding hearing on the future of the San Onofre nuclear plant has prompted Friends of the Earth to accuse the agency of failing to protect the public and of failing to follow its own rules and procedures. 


More than three months have passed since Friends of the Earth petitioned the NRC for a legally binding hearing on the future of the crippled plant. In that time, the NRC has failed to even schedule a discussion of the petition. Now that Southern California Edison has submitted a plan to restart one of San Onofre’s reactors, Friends of the Earth is reiterating its request that the NRC begin a license amendment process to determine if San Onofre is safe to operate and is asking for an emergency stay to keep the plant closed in the meantime.

In a letter to the NRC , Friends of the Earth said: “Time is being wasted.” The organization argued that that the Commission is not only ignoring the law but precedent in a strikingly similar case.



In 2002, the Palo Verde nuclear plant in Arizona – partly owned by Edison – replaced two steam generators of similar design to those used at San Onofre. Under NRC rules, when utilities replace major equipment with a revised design that affects the unit’s safe operation, the licensee must obtain a license amendment. Palo Verde’s operators did so.

In contrast, when Edison replaced the steam generators at San Onofre, the utility claimed it was “like for like” – so similar to the units it was replacing that no license amendment was required.  But Edison in fact made major design changes to the new steam generators that caused the equipment to degrade and fail after less than two years of operation.  These errors in design and the steam generators’ failure are now critical to the question as to whether it’s safe to operate either of the San Onofre reactors.

“It cannot be lawful for utilities to pick and choose the process they undergo,” Friends of the Earth wrote to the NRC. Friends of the Earth “seeks only that this Commission enforce its own rules in an even-handed manner. . . .  We submit that, consistent with its decision on the Palo Verde plant, its own regulations, and the Atomic Energy Act, the Commission, not the staff, must decide the point and must grant the petition filed by Friends of the Earth and convene a licensing proceeding to amend formally the license for San Onofre

”

To read the letter to the NRC: http://libcloud.s3.amazonaws.com/93/23/6/2497/12-10-16_Letter_to_the_NRC.pdf

CONTACT: 
Damon Moglen, (202) 222-0708 
Dave Freeman, (310) 902-2147

Categories: Climate And Energy, News Releases, San Onofre News

Update 10-14-12, SCE’s Replacement Steam Generator $680 Million Debacle

The DAB Safety Team’s - Update 10-14-12,  SCE’s Replacement Steam Generator $680 Million Debacle

1.   If SCE’s and MHI’s Engineers had used all the following guidelines, they would have prevented the

Replacement Steam Generators (RSG’s) catastrophic failures and they would not be in financial trouble with the SONGS Union Workers, the NRC, the Public, the News Media and their Ratepayers:

• ·       Human Performance Tools, along with the NRC Branch Chief and the World’s Foremost Expert’s sage advice of “read between the lines', ‘use critical questioning & an investigative attitude', 'solid teamwork & alignment, and ‘read the academic papers on eliminating fluid elastic instability and flow-induced vibrations in nuclear power plant components.”
•  ·       Benchmarked the design details of Palo Verde and other CE RSGs design details in order to eliminate any potential fluid elastic instability and or flow-induced vibrations experienced in the SONGS CE Original Steam Generators (OSGs), so that they would not occur in their new RSG’s.

  2.  SCE should have embraced rather than bypassed the FULL NRC Licensing Amendment Process.

• ·       SCE “Sweet Talked” the NRC into accepting the results of Inadequate Industry Benchmarking and the Defective 10 CFR 50.59 Evaluation and thus avoided the thorough and lengthy scrutiny of FULL NRC 10 CFR 50.90 Licensing Amendment Process.
•  ·       Note, the lack of strict oversight by Region IV NRC Staff as required by NRC Reactor Oversight Process, was a critical flaw that enabled the debacle.

WHAT IS NEEDED to prevent the adverse consequence of a Main Steam Line Break outside Containment and the resulting nuclear radiological disaster in Southern California, if SCE’s Degraded Unit 2 is allowed to restart at 70% power for an operations trial period of 5 months as an, “Unapproved Experiment”, as SCE and 3 out of 4 Nuclear Energy Institute Qualified “US Nuclear Plant Designers” are recommending?

1.   Submittal of a NRC 10 CFR 50.90 Licensing Amendment Application for SONGS Unit 2 Restart Plan by SCE.

2.   A thorough review of SONGS Unit 2 Restart Plan Return to Service Report by Region IV NRC Staff, NRC Chairman and Commissioners, U.S. Senate Committee on Environment & Public Works, and independent verification/ by the NRC Offices of Nuclear Reactor Regulations, Nuclear Regulatory Research¹ and the Union of Concerned Scientists.

3.   Sworn testimony by all parties responsible for the preparation of SONGS Unit 2 Restart Plan Return to Service Report to insure that public safety and health will not be compromised in case of a nuclear Accident caused by a Design Bases Earthquake/Main Steam Line Break due to multiple tube leaks or ruptures or combination thereof.

4.   Investigation of SONGS Safety Violations and Worker Discrimination, Retaliation, Intimidation and Harassment by an Independent Federal Commission appointed by the President or the Supreme Court of the United States.  This is required to guarantee public acceptance of the results these investigations by the people of Southern California.

5.    Return of the 1.2 Billion Dollars that the ratepayers have “fronted” SCE to date, with interest.

6.    A Financial Bond Guarantee by Southern California Edison to cover the Financial Ruin of Southern California’s economy in case of any nuclear Incident/Accident.

_____________________________________________________

¹Dr. Joram Hopenfeld, a retired engineer from the Office of Nuclear Regulatory Research, sharply criticized NRC officials for downplaying the dangers of degraded steam tubes in  December 1999, three months before the Indian Point accident, and said, “To be credible, risk-informed regulation mandates statistically valid and scrutable data, competent insights of accident scenarios and their consequences, and of accident prevention strategies, as well as meaningful public involvement. In reality, the staff examines accident scenarios and their consequences in a superficial manner; accident prevention is apparently dictated primarily by financial considerations, and the public is being excluded from meaningful participation in the NRC deliberation process’, ‘The nuclear industry and the NRC have a poor track record of controlling steam generator tube degradation.” The NRC's Advisory Committee on Reactor Safeguards (ACRS) issued a report in February 2001 and substantiated many of Dr. Hopenfeld's concerns.

Copyright October 14, 2012 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team.