NRC AIT review of SCE 10CFR 50.59: The NRC AIT stated in its report, “Based on the updated final safety analysis report description of the original steam generators, the team determined that the steam generators major design changes were reviewed in accordance with the 10 CFR 50.59 requirements. The team determined that no significant differences existed in the design requirements of Unit 2 and Unit 3 replacement steam generators. Based on the updated final safety analysis report description of the original steam generators, the team determined that the steam generators major design changes were reviewed in accordance with the 10 CFR 50.59 requirements.
Later the NRR technical specialists reviewed SCE’s 10 CFR 50.59 evaluation against 10 CFR 50.59(c)(2)(viii) which requires that licensees obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change if the change would result in a departure from a method of evaluation described in the final safety analysis report (as updated) used in establishing the design bases or in the safety analyses.
The NRR technical specialists found two instances that failed to adequately address whether the change involved a departure of the method of evaluation described in the updated final safety analysis report.” (emphasis added) The changes were as follows:
- Reactor Coolant System Structural Integrity - Use of ABAQUS Computer Program instead of ANSYS: The SCE’s 50.59 evaluation incorrectly determined that using the ABAQUS instead of ANSYS was a change to an element of the method described in the updated final safety analysis report did not constitute changing from a method described in the updated final safety analysis report to another method, and as such, did not mention whether ABAQUS has been approved by the NRC for this application.
- Main Steam Line Break Mass-Energy Blowdown Analysis & Tube Wall Thinning Analysis – Use of ANSYS Computer Program instead of STRUDL and ANSYS Computer Programs: SCE’s 50.59 evaluation did not mention whether the method has been approved by NRC for this application.
The NRR now needs to investigate why the NRC AIT Team displayed poor judgment in their review of SCE’s 10 CFR 50.59 Evaluation, which in effect, let SEC off the hook without even a fine, for making design changes that put all of Southern California at risk, since we came so very close to having a Fukushima-type radioactive nuclear accident in San Onofre less than a year ago!
Copyright January 1, 2013 by The DAB Safety
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