San Onofre Legacy (SOL Part 1, 2 and 3)

The DAB Safety Team released three Media Alerts today!

Together they describe (in technical detail) the current situation at San Onofre, along with what SCE, their experts and other public nuclear watchdogs are now saying about all the NRC RESTART QUESTIONS they have been told to answer:

1. SONGS Unit 2 Fluid Elastic Instability, Thermal-Hydraulic Modeling, Enlightening Dr. Pettigrew, Concerned/Frustrated NRC Commissioners and Main Steam Break (28 Pages)

snip:

The following paper shows that the entire NRC Regulatory Process is underfunded, broken and needs additional funding, oversight and extensive overhaul to ensure public safety.

2. SCE’s Dismal and Unconvincing Performance before NRC Commissioners (13 Pages)

snip:

The presentation by SCE, Mitsubishi and other experts to the NRC was very disappointing and disturbing to 8.4 million Southern Californians.  The presentation did not address U.S. Sen. Barbara Boxer and Congressman Edward J. Markey’s concerns expressed on February 6, 2013 in her letter to NRC Chairman McFarlane, “Southern California Edison was aware of problems with replacement steam generators at its San Onofre nuclear power plant but chose not to make fixes.

3. Unit 2 Retainer Bars Integrity Unproven and Unsafe During a MSLB  (12 Pages)

snip:

The structural integrity of SONGS degraded retainer bar system to withstand combined loads that result from postulated accident conditions events has not been demonstrated.

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

San Onofre's TTW Assessment Is NOT ACCEPTABLE

SCE Cannot Develop A New Tube-To-Tube (TTW) Operational Assessment ACCEPTABLE To The NRR, After Wasting Hundreds of Millions of Dollars

NRC Office of Nuclear Reactor Regulation asked in a letter dated December 26, 2012 to Edison the following questions during review of SONGS Unit 2 to Service Report: (1) Under SONGS Unit 2 Technical Specifications structural integrity performance criterion 5.5.2.11.b.1, the plant is required to ensure that generator tubes retain "structural integrity" during "the full range of normal operating conditions," including if the plant is running at full power, and (2) NRC wanted Edison to demonstrate that Unit 2 could meet that threshold, or explain how generator tubes would interact with each other if the plant is operating at maximum capacity?

DAB Safety Team Conclusions: Based on the data presented in Table 1 (below) and analysis of NRC AIT, MHI, SCE, Westinghouse and AREVA Reports shown below and in the attached DAB Safety Team Paper Response to NRR RAI #32 - Technical, it is clear that SONGS Unit 2 RSGs will continue to experience Tube-to-Tube Wear (TTW) just like Unit 3 for operation up to 100% Power, or Licensed Reactor Thermal Power of 3438 MWTs because of ... 

The COMPLETE Press Release + 13-01-04 Supplemental To Our Press Release + 12-12-31

The 3 page Non-Technical Condensed Version or the longer 8 page NRR Technical Version

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. 

Our Mission: To prevent a Trillion Dollar Eco-Disaster like Fukushima, from happening in the USA.

Copyright January 5, 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 Attorneys

14 Reactor Safety Questions That Edison Needs To Answer Regarding San Onofre

The 14 most important questions that the DAB Safety Team feels must be answered before the NRC, Atomic Safety Licensing Board, NRC Offices of Nuclear Reactor Regulations and Nuclear Regulatory Research can complete their investigation regarding the reasonableness of the actions of SCE with respect to San Onofre steam generator replacements and their subsequent safe operation:

1 - According to some Newspaper Comments and Industry Reports in 2004, the going price for each of the four 620 Ton CE Replacement Steam Generator was estimated to be between 175-200 Million Dollars (Per Piece). How did SCE CNO/President in 2004 convince MHI to build such large, complicated, innovative and complex steam generators for 569 million dollars, which is almost 130 million dollars short of the market price and funds approved by CPCU? 

Note: The steam generator project execution began in 2004 after a SCE cost-benefit analysis, which revealed that replacement of major parts and components would save $1bn for Southern California Edison customers during the plant's license period. Instead, the ratepayers have lost $1bn in less than 2 years due to SCE’s in-house design teams mistakes.

2 - Since MHI only had experience building Fort Calhoun’s Generator of less than 320 tons, how did the SCE Engineers Technically Qualify MHI?

3 - Which other utilities’ QA Programs, did SCE take the credit for, to approve Mitsubishi’s quality assurance program. Fort Calhoun? French? Belgium? Japan?

4 – Why did SCE did not apply to NRC for increasing the plugging limit for the Old CE Generators, so they would have had more time to think, research and not rush according to Michael Peevey?

5 - Which CE Replacement Generator US Utilities did SCE benchmark to develop such detailed design and performance specifications or did they just modify the CE Old Generator Specifications with New Industry Information?  Were the SCE engineers, who wrote, checked and approved the specifications steam generator experts or was another steam generator expert in the background, who directed all the SCE work?

6 - Where did all the claims of challenges, reward, innovations and teamwork between SCE and MHI go wrong?

7 - Were the SCE Engineers sent to Japan to check MHI work and approve documents /test results qualified in that field, or they were just training/sight-seeing?

8 - Who at SCE made the decision to make all these numerous design changes and determined the changes were "Like for Like" and did not need a Licensing Amendment Process?

9 - Which SCE Engineer provided all these changes, information and documents to which NRC Engineer, who then made the decision that it was OK to proceed without a full Licensing Amendment Process?

10 - Which SCE engineer(s) approved/validated the MHI Thermal-Hydraulic FIT-III FIVATS code Inputs and Calculations?

11 - To get 10% heat transfer equivalent by switching from Alloy 600 To alloy 690, SCE needed to add 935 tubes, but they only added 377 tubes. What happened to the balance of 568 tubes? Did the SCE Engineers tell MHI to increase the length of 9727 tubes and by how much to make up for the 533 tubes?

12 – Why did the SCE Engineers did not question the MHI benchmarking, verification and validation of the FIT-III thermal-hydraulic model?

13 – Why did the SCE engineers did not contact their counter parts at PVNGS for information/advice, since PVNGS has the Largest CE Replacement Generators (800 Tons) in the world, were built in early 2001-2005 time frames and are running successfully?

14 - Were the original CE Steam Generators and new replacement generators exact in Thermal Output (MWe) or were their minor differences?

14 Reactor Safety Questions
That Edison Needs To Answer
Regarding San Onofre 

The DAB Safety Team has transmitted the following report this morning to the Chairman of the NRC, Atomic Safety Licensing Board, NRC Offices of Nuclear Reactor Regulations and Nuclear Regulatory Research:

“SONGS Unit 2 Dangerous Replacement Steam Generators:

 SCE’s Embarrassing Technical Performance Trying To Justify A Restart

 Of Unit 2, To The NRC, At Their November 30, 2012 Public Meeting.”

The 78 page technical document includes 14 questions that affect US Reactor SAFETY, that the NRC, NRR and RES Regulators need to ask SCE to answer at their Dec 18, 2012 NRR/RES Meeting.

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Snip From The Report:

Unit 2 now has hundreds of times more bad tubes and a thousand times more indications of wear on its tubes than the 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, over a comparable operating period, in the country combined.  Therefore, the restart of Unit 2 with thousands of degraded tubes present a formidable challenge to the safe restart of Unit 2 plan by making it highly vulnerable to localized steam dry-outs, 100% void fractions, fluid elastic instability, flow-induced random vibrations, cascading tube ruptures during unanticipated operational occurrences and or Main Steam Line Breaks.  In short, SCE is trying to Restart Unit 2’s Degraded RSG’s, which are outside the NORM of the NRC Regulations.

The NRC Chairman has stated that SCE is responsible for the work of its vendors and contractors. Westinghouse states that none of the MHI fabrication issues were extensively analyzed in the SCE root cause evaluation.”  It is the DAB Safety Team’s opinion that SCE claims that insufficient contact forces in Unit 3 Tube-to-AVB Gaps ALONE caused tube "to" tube wear are misleading, erroneous and designed to put the blame on MHI for purposes of making SCE look good in the public’s eyes and for collecting insurance money from MHI’s manufacturing so called defects. 

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The full report will also be posted on the web at this link: San Onofre Papers

or here:  SCE NRC Presentation Analysis + 14 Questions 12-12-17

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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 in no way responsible for the contents of the DAB Safety Team's reports.  We continue to work together as a Safety Team to prepare additional San Onofre Papers, which explain in detail why a SONGS restart is unsafe at any power level.  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: December 17, 2012

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

Concerning SCE’s NRC Technical Presentation on 12-11-30

Copyright December 17, 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.