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.

###

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

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

SCE's News Years Resolution 2013: Decommission SONGS ASAP

NRR RAI Answers Will Prevent Any SCE Restart At San Onofre

The NRC Office of Nuclear Reactor Regulation has requested from Edison in a letter dated December 26, 2012, the following additional information (RAI #32): “Please clarify how the information submitted by SCE demonstrates: NRRRAI#32(1) that the structural integrity performance criterion in TS 5.5.2.11.b.1 is met for operation within current licensed limits up to the licensed Rated Thermal Power (RTP or 100% Power), or NRRRAI#32(2) provide an operational assessment that includes an evaluation of steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP.”

The DAB Safety Team’s Response: 

Answer to NRRRAI#32(1): As shown in the linked Response to NRR RAI#32  - Technical, by operating the “Defectively Designed and Degraded” Unit 2 Replacement Steam Generators (RSGs), SCE CANNOT DEMONSTRATE [with all the World’s Expert’s Assistance - emphasis added] that ALL in-service RSGs tubes would retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, cool down and all anticipated transients included in the design specification) and design basis accidents in accordance with SONGS Unit 2 Technical Specifications structural integrity performance criterion in TS 5.5.2.11.b.1.

Answer to NRRRAI#32(2): As shown in the linked Response to NRR RAI#32  - Technical, SCE CANNOT PROVIDE AN ACCEPTABLE OPERATIONAL  ASSESSMENT  TO  THE  NRR, which demonstrates that steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP would not cause a tube leak in order to comply with Code of Federal Regulations, 10 CFR Part 50 Appendix A, General Design Criteria 14, “Reactor Coolant Pressure Boundary—shall have “an extremely low probability of abnormal leakage…and gross rupture.” 

Southern California’s future is now in the hands of the NRR: As shown in this section, the SONGS RSG’s U-Tube bundle and Anti-vibration Bar Structures are not designed like Palo Verde RSGs to handle high steam flows, high velocities and to prevent the formation of highly localized steam dry-outs and TTW (FEI) for operation up to the RTP.  The “defectively designed and degraded” Unit 2 RSGs, if operated, will suffer additional radioactive tube leaks like SONGS Unit 3, Mihama Unit 2, North Ana, Indian Point 2 and Craus.  Therefore, SCE  CANNOT  PROVIDE AN  ACCEPTABLE  OPERATIONAL  ASSESSMENT  TO  THE  NRR, which demonstrates that steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP would not cause a tube leak in order to comply with the  Code of Federal Regulations, 10 CFR Part 50 Appendix A, General Design Criteria 14, “Reactor Coolant Pressure Boundary—shall have “an extremely low probability of abnormal leakage…and gross rupture.” 

...

The DAB Safety Team’s CONCLUSIONS

1. Based on an in-depth review of the above listed documentation and direct observation of Plant Operators and SONGS Emergency Response Organization Performance, the DAB Safety Team agrees with Dr. Johan Hopenfeld’s published concerns and concludes that Operator Action is not feasible to stop a major nuclear accident in Unit 2 in the first 15 minutes of a MSLB, stuck open SG safety valve, Earthquake, cascading SG tube ruptures and or any other combination of Un-anticipated operational transients, during the proposed 5-month trial period of the already heavily damaged Unit 2 RSG’s at any power setting.

2. The Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation must now formally address Dr. Johan Hopenfeld’s published concerns, as mentioned in Response to NRR RAI#32  - Technical  in light of the eight RSG tube failures at SONGS at main steam line break testing conditions, and the cascading effect that these failures prove is a very serious safety issue, that reactor operators do not currently have the ability to control. which might result in significant risk impacts such as a nuclear meltdown.

Full Press Release + 12-12-31 NRR RAI #32 Request

Copyright December 31, 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.