NRC: The Good, The Bad and the Ugly

NRC: The Good, The Bad and the Ugly

... and why it is unsafe To restart San Onofre

A GOOD NRC enforcement example:

Davis-Besse Nuclear Power Station is a nuclear power plant in Oak Harbor, Ohio. On March 5, 2002, maintenance workers discovered that corrosion had eaten a football-sized hole into the reactor vessel head of the Davis-Besse plant. Corrosion had been clogging the plant’s filters for months, requiring repeated filter replacement, but the cause was not investigated until after a worker leaned against a control rod drive mechanism, and it toppled over. Although the corrosion did not lead to an accident, this was considered to be a serious nuclear safety incident. Some observers have criticized the NRC’s Commission work as an example of regulatory capture [See Note 1] and the NRC has been accused of doing an inadequate job by the Union of Concerned Scientists.  The Nuclear Regulatory Commission kept Davis-Besse shut down until March 2004, so that FirstEnergy was able to perform all the necessary maintenance for safe operations. The NRC imposed its largest fine ever—more than $5 million—against FirstEnergy for the actions that led to the corrosion. The company paid an additional $28 million in fines under a settlement with the U.S. Department of Justice. The NRC closely monitored FENOC’s response and concluded in September 2009 that FENOC met the conditions of the 2004 order. From 2004 through 2009 the NRC reviewed 20 independent assessments conducted at the plant and verified the independent assessors’ credentials. The agency also conducted its own inspections and reviewed FENOC’s reactor vessel inspections conducted in early 2005. NRC inspectors paid particular attention to the order’s focus on safety culture and safety conscious work environment to ensure there were no new signs of weakness. The NRC task force concluded that the corrosion, occurred for several reasons:

·    NRC, Davis-Besse and the nuclear industry failed to adequately review, assess, and follow up on relevant operating experience at other nuclear power plants;

·    Davis-Besse failed to ensure that plant safety issues received appropriate attention; and

·    NRC failed to integrate available information in assessing Davis-Besse’s safety performance.

A BAD NRC enforcement example:

At San Onofre by Region IV and the NRC: The papers shown below have been obtained from Public Domain written by Dr. Joram Hopenfeld and a former SONGS Employee based on his investigation of the steam generator issues, review of the plant data and discussions with several Key SONGS Insiders. These papers confirm that Southern California Edison wants to restart unsafe Unit 2 nuclear reactor at 70% power under false pretenses, just for profits, and as an unapproved risky experiment by subverting the NRC and Federal regulatory process.  The true Root Cause (See Note 2) of the unprecedented tube-to-tube wear in Unit 3 has NOT been officially established, as required by NRC Confirmatory Letter Action 1 for restarting the defectively designed and degraded Unit 2.  NRC has not even completed their review of Unit 2 Return to Service Reports, nor have they finished Special Unit 2 Tube Inspections, nor have they (publicly?) reviewed SCE’s Response to NRC’s Requests for Additional Information (RAIs).
NOTE: NO FINES ARE MENTIONED - WHY?

An UGLY NRC enforcement example?:

Now, SCE wants the NRC to approve a new shady License Amendment, undermining public safety and they want it done without the involvement of Public Safety Experts, Attorneys and/or Citizens/Ratepayers.  After the review of the Mitsubishi Root Cause Evaluation and the Draft SCE License Amendment, it is crystal clear that the NRC needs to follow the example of their own enforcement at David Besse together with the lessons learned from Fukushima, when it comes to NOT approving this new Shady License Amendment for restarting San Onofre Unit 2’s defectively designed and degraded replacement steam generators.  In light of the unanticipated/unprecedented tube leakage at San Onofre Unit 3, the health and safety, along with the economic concerns/objections of 8.4 million Southern Californians’ MUST OVERRIDE and PREVENT the restarting of Unit 2 at ANY power level.  In a Democratic Society, truth must prevail over profit motivations, misleading propaganda of electricity service disruption and/or projected probabilistic temporary inconveniences to the public based on phony data, because America cannot afford a trillion dollar nuclear eco-disaster!

Our Safety must override SCE's profits and prevent them from restarting Unit 2.

Notes:

1: Regulatory capture occurs when a regulatory agency, created to act in the public interest, instead advances the commercial or special concerns of interest groups that dominate the industry or sector it is charged with regulating.  Regulatory capture is a form of government failure, as it can act as an encouragement for firms to produce negative externalities. The agencies are called "captured agencies".

2. Human performance errors resulting from the negative safety culture of production (profits) goals overriding public safety obligations.


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Additional Information:

The full DAB Safety Team's Media Alert 5 Parts:

https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=15V8BD4YK0MjwUV6gPZt6ILS_lP7CpClzgnZentLfx8U

The complete five (5) part presentation, see the eight (8) titles listed below:

Part 1, First Part  https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=1GcDuO0NvUdBBRVqCinM3Gr9bhmsJDCIbOg65rwdtjBY

Part 1, Second Part https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=1v_UcRLUlwmhtVDbftGcROPkF-cujiGa_-qjUJ7i2WIM

Part 1, Third Part https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=1yCOQ_diw8Qix1qG3j7MC6F2VfcqMoFOidxjJdIBpba0

Part 1, Fourth Part https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1

Part 2 https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?
pli=1&docId=1wkyTGWUy0pIXjBXc91JWr6_ACB3d-AIQbuVVZtDRZvI

Part 3 https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=16VmGtq9oYGS2-bpR4nBt9d-YB21E2xrjFpIJoxFJ4s4

Part 4 https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=0BweZ3c0aFXcFMC1BNlpMeDQyM2M

Part 5 https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=0BweZ3c0aFXcFX2gxRDFCRW9CVzg

Thirty Alarms Demonstrates SONGS Is Unsafe

The 30 Un-Resolved Alarms Recorded by SONGS Vibration Monitoring System During 11 Months of Operation, Requires An Immediate NRR Safety Investigation

Three Questions affecting US reactor safety need to be answered ASAP, by the NRR:

1.  WHY, if these 30 separate alarms were indicating that some unusual phenomena (e.g., FEI) was occurring in Unit 3, did SCE not immediately shut down Unit 3, notify the NRC of the unusual phenomena and get their help in order to properly understand what exactly was going on inside the Unit 3 SG in order to properly diagnose the problem(s), instead of just ignoring them while continuing to operate Unit 3 for 11 months in an unsafe manner?

2.  Why has NRC Region IV’s AIT Team NOT resolved this issue almost 6 months after issuance of their AIT Report and already informed the public as to the cause(s) of these unusual phenomena, if the causes are now understood.

3.  WHY should a Utility be able to operate a nuclear reactor while something unknown is happening without shutting it down ASAP and informing the NRC?

The Complete DAB Safety Team Press Release + 12-12-28 

Edison’s Claims About SONGS Unit 2 Pressures Are Erroneous

Press Release

The DAB Safety Team: December 7, 2012

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

SCE’s Claims About SONGS Unit 2 Steam Generator Operating Pressures Are Erroneous Because They Conflict With SCE’s Submitted NRC Reports And SCE’s Plant Procedures (Operational Data).

Now SCE is claiming in their Unit 2 Restart documents, “Limiting power to 70% significantly reduces fluid velocity. The reduction in fluid velocity significantly reduces the potential for FEI.”  What they are not saying is that reducing power to 70% significantly increases the steam generator operating pressures, (as the NRC said in its AIT Report) which will:

·      Increase the pressure inside all the already damaged SG tubes

·      Do nothing to completely eliminate FEI from happening at any time during normal plant operations, and especially during a MSLB or similar accident, which can cause a nuclear incident or worse!

SCE’s attempt in using evasive and misleading technical inconsistencies to justifying their dangerous and possibly catastrophic restart plan cannot hide the truth, revealed in their actual plant operational data provided to the NRC and published in the NRC AIT Report.

Background History:

After the radioactive leak occurred in the San Onofre Unit 3 steam generator, Arnie Gundersen along with a team of anonymous steam generator experts were the first ones in the industry to absolutely state, “The pitch to diameter ratio of tubes in the original CE generators is dramatically different from any of the Westinghouse generators fabricated by Mitsubishi.  As water moves vertically up in a steam generator, the water content reduces as more steam is created.  With the Mitsubishi design the top of the U-tubes are almost dry in some regions. Without liquid in the mixture, there is no damping against vibration, and therefore a severe fluid-elastic instability developed.  The real problem in the replacement steam generators at San Onofre is that too much steam and too little water is causing the tubes to vibrate violently in the U-bend region. The tubes are quickly wearing themselves thin enough to completely fail pressure tests. Even if the new tubes are actively not leaking or have not ruptured, the tubes in the Mitsubishi fabrication are at risk of bursting in a main steam line accident scenario and spewing radiation into the air.”

SCE’s Restart Plan Justification Is Just Scientific Misinformation:

Based on analysis of the NRC AIT Report, Westinghouse’s Operational Assessment, SONGS procedures, operational data, plant daily briefing sheets and engineering calculations the DAB Safety Team concludes the following:

·      Secondary side lower pressures (833 psi) along with higher reactor thermal power and design deficiencies (low tube clearances) at 100% power created conditions of “ALMOST NO WATER” in certain regions of both Unit 3 steam generators tube bundles.  This resulted in fluid elastic instability, where unprecedented tube-tube wear was observed.  At the June 18, 2012 AIT presentation, the NRC said, “Throughout the US nuclear industry, this is the first time more than one steam generator tube failed pressure testing…. Eight tubes failed. The pressure testing identified that the strength of eight tubes was not adequate and structural integrity might not be maintained during an accident… this is a serious safety issue.”  Southern Californians were lucky, that SONGS Unit 3 tube leakage was detected and stopped in time.  Otherwise, this condition could have potentially caused a reactor meltdown like Fukushima in Southern Californian’s backyards. 

·      Secondary side higher pressures in Unit 2 (864-942 psi) at 100% power negated the effects of  “low tube clearances” and prevented steam “dry-out” (high void fractions) in the Unit 2 tube bundle region, where no fluid elastic instability (tube-tube wear) was observed. 

The DAB Safety Team’s findings are summarized as follows:

·      DAB Safety Team “Strongly Agrees” with Arnie Gundersen and his team of anonymous steam generator experts and with MHI on the causes of fluid elastic instability in Unit 3.  What did SCE do, instead of thanking Arnie Gundersen, who first identified the real cause of the problem, tried to discredit him by implying, “What does he know about steam generators, he is just a high school math teacher.”

·      DAB Safety Team “Agrees” with Westinghouse, why fluid elastic instability did not occur in Unit 2.

·      DAB Safety Team “Strongly Disagrees” with both SCE’s conclusions “that fluid elastic instability Most Likely Occurred in Unit 2” and “secondary side operating parameters were similar in the U3 and U2 SGs”. 

·      DAB Safety Team “Strongly Disagrees” with NRC that the differences in the actual operation between units and/or individual steam generators had an insignificant impact on the results and in fact, the NRC AIT team did not identify any changes in steam velocities or void fractions that could account for the differences in tube wear between the units or steam generators.  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.

Adverse operational conditions, such as larger reactor thermal power and lower steam generator pressures (e.g., 833 psia) and design deficiencies (low tube clearances and no-in-plane fluid elastic instability structural protection) cause areas in the U-tube bundle of a nuclear steam generator to have “ALMOST NO WATER” as observed in SONGS Unit 3 steam generators.  When this happens, fluid elastic instability occurs and the thin steam generator tubes carrying radioactive coolant move with large sprinting amplitudes and hit the neighboring tubes with violent and repeated impacts.  Therefore, multiple tube failures can occur, as was observed in SONGS Unit 3 at main steam line break testing conditions.

MHI states, “The higher than typical void fraction is a result of a very large and tightly packed tube bundle, particularly in the U-bend, with high heat flux in the hot leg side. This high void fraction is a potentially major cause of the tube FEI, and consequently unexpected tube-to-tube wear (as it affects both the flow velocity and the damping factors). In general, larger thermal power is more severe for vibration, because the steam flow rate increases. At constant thermal power, lower steam pressure is more severe for vibration than higher pressure.” MHI is indirectly saying that steam generator pressures of 833 psia created fluid elastic instability in Unit 3, where unprecedented tube-to-tube wear was observed.  AREVA states, “At 100% power, the thermal-hydraulic conditions in the U-bend region of the SONGS replacement steam generators exceeded the past successful operational envelope for U-bend nuclear steam generators based on presently available data.” MHI has officially notified the NRC that all SONGS damaged RSG Tubes subject to tube-to-tube wear (FEI) should be plugged and or stabilized.  SCE cannot certify this as having been done, since they have not inspected the majority of Unit 2’s RSG tubes using the most advanced technology, as indicated in HMI’s official notice to the NRC.  Again SCE is caught guessing about the amount of tube fatigue damage, which directly affects the RSG tube structural integrity; all RSG tubes are subject to tube-to-tube wear, extreme pressure variations and other stresses during a MSLB or other unanticipated operational transients.

NRC AIT Report states, “The team performed a number of different thermal-hydraulic analysis of Units 2 and 3 steam generators. The output of the various analyses runs were then compared and reviewed to determine if those differences could have contributed to the significant change in steam generator tube wear. It was noted that Unit 3 ran with slightly higher primary temperatures, about 4°F higher than Unit 2. The result of the independent NRC thermal-hydraulic analysis indicated that differences in the actual operation between units and/or individual steam generators had an insignificant impact on the results and in fact, the team did not identify any changes in steam velocities or void fractions that could attribute to the differences in tube wear between the units or steam generators. It should be noted that increases in primary temperature and steam generator pressures has the effect of reducing void fractions and peak steam velocities, which slightly decreases the conditions necessary for fluid elastic instability and fluid-induced vibration. The analysis included the varying of steam generator pressures from 833 to 942 psia.”

SCE says in their Root Cause Analysis, “Secondary side operating parameters were similar in the U3 and U2 SGs and well within their design limits (e.g., steam generator pressures, 833 psia).”  Note, NO mention varying the pressure to 942 psia at all…

Copyright December 7, 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.