| THE HANDSTAND |
WINTER 2012
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Our Mission: To prevent a
Trillion Dollar Eco-Disaster, like Fukushima, from
happening in the USA.
The DAB Safety Team: December 31, 2012
Media Contact: Don Leichtling (619) 296-9928
or Ace Hoffman (760)
720-7261
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?
NRR Requests Additional Information on SCE’s San
Onofre Unit 2 Restart Proposal
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 Team Chief.
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.”
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 NRC, 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.”
###
Press
Release (Complete Version) +
12-12-31 NRR RAI #32 Request
Snip:
NOTE: Here are 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 SONGS 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 (RSG’s) 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 CPUC?
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
team’s mistakes.
2 - Since MHI only had experience building Fort
Calhoun’s tiny RSG’s (less than 320 tons), how
did the SCE Engineers Technically Qualify MHI for the
much larger RSGs?
3 - Which other utilities’ QA Programs did SCE use
to approve Mitsubishi’s quality assurance program?
Fort Calhoun? French? Belgian? Japanese?
4 - Why didn’t SCE apply to NRC for increasing
the plugging limit for the Original CE Generators, so
they would have had more time to think, research and not
rush according to the CPUC?
5 - Which Utilities’ CE Replacement Generators 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 new 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
exact field, or they were just in training and/or
sightseeing?
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(s) provided all these changes,
information and documents to which NRC Engineer(s), 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 make up for the 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 558 tubes? Did the SCE Engineers
tell MHI to increase the length of 9727 tubes and by how
much, to make up for the 558 tubes?
12 – Why didn’t the SCE Engineers question/independently
verify/validate the MHI benchmarking of the FIT-III
thermal-hydraulic model?
13 – Why didn’t the SCE engineers contact their
counterparts at PVNGS for information/advice, since PVNGS
has the largest CE Replacement Generators (800 Tons) in
the world, were built in early 2001-2005 and are
currently still in operation?
14 - Were the original CE Steam Generators and new
replacement generators exact in Thermal Output (MWt) or
were there “minor” differences?
Under no circumstances should the
NRC Region IV, Offices of Nuclear Reactor Regulation and
Nuclear Regulatory Research*, and the NRC Atomic Safety
Licensing Board permit SCE to restart unit 2 without re-tubing
or replacing the defective replacement steam generators,
along with a full NRC 50.90 Licensing Amendment and
transparent trial-like public hearings.
* The DAB Safety Team would like to
extend a Professional Compliment to the NRR for doing a
thorough investigation on their review of the San Onofre
Unit 2 Restart Proposal as indicated by their Request for
Additional Information #32.
###
ABBREVIATIONS AND ACRONYMS:
· AIT: NRC’s
Augmented Inspection Team
· AREVA: Nuclear
engineering firm owned by French Atomic Energy Commission
· AVB: Anti
Vibration Bar
· CE: Combustion
Engineering, builders of SONGS original steam generators
· CNO: Chief Nuclear
Officer
· CPUC: California
Public Utilities Commission
· DABST: DAB Safety
Team
· FEI: Fluid Elastic
Instability
· MHI: Mitsubishi
Heavy Industry
· MSIV: Main Steam (line)
Isolation Valve
· MSLB: Main Steam
Line Break
· MWt: Mega-Watts
Thermal
· NRC: Nuclear
Regulatory Commission
· NRR: NRC’s
Office of Nuclear Reactor Regulations
· PVNGS: Palo Verde
Nuclear Generating Station
· QA: Quality
Assurance
· RAI: Request
Additional Information
· RSG: Replacement
Steam Generator
· RTP: Reactor
Thermal Power
· SCE: Southern
California Edison
· SG: Steam
Generator
· SONGS: San Onofre
Nuclear (Waste) Generating Station (alternate
abbreviation: SONWGS)
· TS: Technical
Specifications (for operation of a NPP)
· TTW: Tube-to-Tube
Wear
This press release along with DAB Safety Team’s Response
to NRR RAI #32 - Technical will be
posted on the web at this link: San
Onofre Papers.
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 San
Onofre Papers, 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.
Copyright December 31, 2012: The DAB Safety Team. All
rights reserved. This material cannot be published,
broadcasted and/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.
_______________________________________________
************************************************
** Ace Hoffman, Owner & Chief
Programmer, The Animated Software Co.
** POB 1936, Carlsbad CA 92018
** U.S. & Canada (800) 551-2726;
elsewhere: (760) 720-7261
** home page: www.animatedsoftware.com
** email: rhoffman@animatedsoftware.com
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