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

NRC AIT Review Of San Onofre Requires An NRR Investigation

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!

Link to full Press Release 13-01-07 NRC AIT Review Requires An NRR Investigation

The DAB Safety Team: January 7, 2013    Supplemental To Our Press Release + 12-12-31

Copyright January 1, 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 Radiation Hurts Children Most

June, a Buddhist nun recently returned from Fukushima, graphically documents how children are the most tragic victims of nuclear contamination.

Decommission San Onofre - Fukushima USA 

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

NRC Region IV AIT Team Report Requires Immediate NRR Investigation

Press Release + 13-01-02 Supplemental To Our Press Release + 12-12-31

Condensed Version

NRC AIT Team review of SCE 10CFR 50.59: The NRC AIT Team 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.

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:

1. 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.
2. 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 the NRC for this application.

The NRR needs to investigate why NRC Region IV AIT Team overlooked the above information, which is vital to the health and safety of Southern California and and then issue a fine.

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Press Release + 13-01-02 Supplemental To Our Press Release + 12-12-31

The Full Version Of The Above Press Release Is Posted Here: