Why fatigue damage will stop the NRC from allowing Unit 2 to restart

FATIGUE DAMAGE TO SONGS STEAM GENERATORS

J. Hopenfeld 

Provided to the “DAB Safety Team” as additional explanation of the fatigue damage to SONGS steam generators which was discussed in a report by the author and was submitted to the California Public Utility Commission on March 29, 2013

Note: Links to these documents are listed below 

SCE/MHI made a mistake in their stress analysis, which directly impacts the safety of restarting Unit 2.  When the error is corrected, the result clearly shows that Unit 2 has already used up its allowed fatigue life and is not fit for service any longer.  This means that if Unit 2 is restarted at any power level an abrupt pressure change such as inadvertent closing or opening of a valve or a steam line break could lead to a sudden tube ruptures.   The ASME code and NRC regulations do not permit safety components to operate when their fatigue life has been exhausted.

The source of MHI’s error resulted from how they calculated the increase in the local stress at geometrical discontinuities  (notches), which are formed when two metal surfaces come in contact during vibration.  Since the worn surfaces of the tubes inside the steam generators cannot be seen, MHI made two key assumptions, which are inconsistent with the observation that both the tube and the supporting bar are worn into each other.  First, MHI assumed that the ASME endurance limit could be applied directly to the notched tube surfaces.  Since it is commonly known that surface roughness significantly reduces fatigue life and since the ASME data is for smooth polished surfaces, this assumption would underestimate the amount of fatigue damage.  Second, when using the Peterson chart, MHI assumed unrealistically large fillet radius and consequently derived a low concentration stress factor.  Large radii would decrease the local stress and cause the tube to fail at a higher stress thereby increasing its fatigue life.  Only by using these two, arbitrary non-conservative, assumptions was MHI able to conclude that Unit 2 did not suffer any fatigue damage.

As depicted in the MHI drawings the support bar and the tube form a sharp discontinuity at the contacting surface, therefore the appropriate geometry for calculating the stress concentration is an abrupt geometry change (very small radii), not a large radius shoulder fillet that was assumed by MHI.  When a correction is made to account for the sharp notch, the corrected stress indicates  (see Figure 1 below) that the tubes have used up their fatigue life during the first cycle of operation.  Structures with sharp notches can fail catastrophically when subjected to high cycle vibrations.  (MHI redacted their assumption so the exact value of the radius they used is unknown.)

 The loss of fatigue life is a major defect in the tube material; NRC regulations 10CFR50, Appendix B, Criterion 16 specify that for a licensee to maintain his operating license, such non-conformance must be promptly identified and corrected.   The licensee must assure that “corrective action (is) taken to preclude repetition.  NRC’s General Design Criteria 4 and 10CFR50 Appendix A also specify that steam generator tubes must be able to “ accommodate the effects of loss of coolant accidents “ The fact that the NRC has not already raised these issues in any of their  “Requests for Additional Information, RAIs” indicates that the NRC would be ignoring its own regulations if it allows SCE to restart Unit 2.

 In Summary: The SCE request for approval to operate Unit 2 at 70 % power for 150 days provided no explanation for the selection of this inspection interval.  The absence of such explanation and the absence of an indication of the actions that would follow demonstrate the unreliability of SCE entire assessment of restarting Unit 2.  Edison did not specify pass/fail criteria for the tubes during the outage inspection.  Given the fact that fatigue damage does not lend itself to detection, SCE request is unacceptable and should be rejected. 

  

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

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

Which includes both Dr. Hopenfeld's CPUC documents as Parts 4 & 5:

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

Proactive Solar Action, Be Part of the Solution

To my friends,

Residents Organized for a Safe Environment (ROSE) is proud and happy to announce our first solar project in conjunction with the Boy Scouts of America, Orange County.  For practical and teaching purposes, ROSE will provide the scouts with a solar project at their boat house at Oso Lake. The object of the project is to provide lights and the recharging of the batteries that are needed for the boats off grid. Each weekend there are as many has 300 young scouts and family members at the lake. They will all get to see and learn about the practical applications of solar energy and have the chance to participate in a renewable energy merit badge.

ROSE is honored to ask you to join us in this project.  Your help will be greatly appreciated. Our project goal is $3,315 with shipping.   Checks may be made out to Gene Stone. The Boy Scouts of America will provide a receipt for a tax deductible donation.

Join with us in this proactive approach to educate our children about the benefits of renewable energy. Help us replace nuclear power one solar panel at a time.

Sincerely,

Gene Stone

ROSE, genston@sbcglobal.net

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

The Pledge

I commit to conserving electrical power and other forms of energy as much as possible each and every Wednesday. I will also continue to conserve electrical usage throughout the week and think conservation and energy efficiency in other areas of my life.

I will continue to conserve electrical energy until all dirty and outdated forms of electrical generating facilities are decommissioned and replaced with clean renewable sources of energy.

Visualise A Land Without SONGS

Will the United States move towards a nuke-free future after the Japanese nuclear power plant meltdown? An 85 years old grandma and a 13 years old little girl from southern California swear to take down the old and damaged nuclear power plant San Onofre Nuclear Generating Station, known as SONGS. Will it end up with a happy tune? or not? 

日本福島核災過後 美國這個核能先驅國 是否也將邁向非核? 一位85歲的老奶奶 和只有13歲的小女孩 承先啓後 誓言將南加州老舊毀損核電廠"歌"關閉 結局會是一場悲歌 還是快樂頌?

Visualise A Land Without SONGS

San Onofre Unit 2 Retainer Bars Could Cause Massive ☢ Leakage

In an accident like a main steam line break at San Onofre, the badly designed retainers bars in Unit 2 could actually make things much worse by causing more damage to any of the 9,727 already fatigued tubes in each of its steam generators which could lead to additional leakage of highly radioactive reactor core coolant and/or cause a nuclear incident or worse a nuclear accident like Fukushima!

Radioactive Leaks and ruptures can happen without notice:

Allegation/Violations

The NRC has decided in AIT follow-up report dated 11/09/2012, “Item 3. “(Closed) Unresolved Item 05000362/2012007-03, ‘Evaluation of Retainer Bars Vibration during the Original Design of the Replacement Steam Generators” as a non-cited violation in accordance with Section 2.3.2 of the NRC’s Enforcement Policy.”  However, as shown below, SCE/MHI’s failure to verify the adequacy of the retainer bar design as required by SCE/MHI’s procedures have resulted in plugging of several hundred tubes in the brand new replacement generators. This has resulted in these violations:

1. Failure to meet NRC Chairman Standards on Nuclear Safety by SCE,
2. Failure to meet Senator Boxer’s Committee on Environment and Public Works
(EPW) Standards on Nuclear Safety by SCE,
3. Failure to enforce SCE Edison Contract Document instructions to MHI by SCE,
4. Failure to meet SONGS Technical Specifications by SCE,
5. Failure to meet general design criteria (GDC) in Appendix A, “General Design
Criteria for Nuclear Power Plants,” to 10 CFR Part 50, “Domestic
Licensing of Production and Utilization Facilities GDC 14, “Reactor
Coolant Pressure Boundary” by SCE/MHI,
6. Failure to demonstrate that Unit 2 retainer bars will maintain tube bundle
geometry at 70% power due to fluid elastic instability during a main line
steam break (MSLB) design basis event, and
7. SCE/MHI took shortcuts by avoiding the 10 CFR 50.90 License Amendment
Process under the false pretense of “like for a like” replacement steam
generator.  SCE added 377 more tubes, increased the average length of the
heated tubes and changed the thermal-hydraulic operation of the RSGs without

proper safety analysis and inadequate 10CFR 50.59 Evaluation.

This intentional action to produce more thermal megawatts out of the

RSGs compromised safety at SONGS Unit 2 due to the failure of 90

percent through wall thickness of a tube by the inadequate design of the

r

etainer bar.

Recommended Actions:

NRC San Onofre Special Panel is requested to resolve the above listed Allegations and/or Violations within 30 days of receipt of this email and prior to granting SCE’s permission to do any restart "testing" of Unit 2. Answer all allegations factually, don't just void them.
 
See Full Document: Media Alert: San Onofre Retainer Bar Problems

San Diego screening of MOVIE: "311: Surviving Japan"

WE HAVE THIS weekend to pre-sell just 6 seats to make this screening happen in San Diego! No excuses on the weekend, just DO it: You will NOT be charged until the event is confirmed. ($12 per ticket)http://www.tugg.com/titles/311-surviving-japan?location=global&state=upcoming

Please join us for the 2nd Anniversary of the Fukushima nuclear disaaster!

San Diego screening of "311: Surviving Japan" on Monday, March 11, 2013, the 2nd Anniversary of the Fukushima nuclear disaster (7:30p). PLEASE RESERVE YOUR TICKET(S) ONLINE ASAP TO ENSURE THE FILM IS SCREENED HERE: http://www.tugg.com/titles/311-surviving-japan?location=global&state=upcoming You will NOT be charged until the event is confirmed. ($12 per ticket).  We must sell 50 tickets in advance ASAP for this film to be a go at the theater!

Where:

AMC Fashion Valley 18

7037 Friars Rd, San Diego, California 92108

YOU MUST RESERVE YOUR SEAT ONLINE NOW!  There will be no "walk up" tickets sold.

We will do a "Light Brigade" action along the busy Friars Road entrance to the Fashion Valley Mall from 6-7p, holding lighted letter signs spelling out "No More Fukushimas". Please emailmarthasullivan@mac.com to volunteer as a "Holder of the Light."

We will also do Flyering inside the Mall during the same period before the screening: 6-7p, with a special guest for the occasion. Please email marthasullivan@mac.com to volunteer for the Info Crew.

Here is a brief description of the film: "Inside story of 2011 Japanese Tsunami relief & Fukushima nuclear disaster. A critical look at how the authorities handled the nuclear crisis and Tsunami relief by an American who volunteered in the clean-up. It is in short, a documentary of the devastating events in Japan and 6 months of the after-math that followed. It features true stories from those affected by the disaster, the government and even TEPCO. It highlights the struggle in dealing with: The Tsunami clean-up, Government response to the disaster, radiation plus the future of nuclear power after the accident." (90 minutes long, plus speaker.)