ML13016A092
| ML13016A092 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/16/2013 |
| From: | Fairewinds Associates |
| To: | Plant Licensing Branch IV, Friends of the Earth |
| Benney B | |
| Shared Package | |
| ML13016A077 | List: |
| References | |
| G20120891, TAC MF0060, TAC MF0061 | |
| Download: ML13016A092 (39) | |
Text
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2.206 PRESENTATION San Onofre Units 2 and 3 San Onofre Units 2 and 3 Replacement Steam Generators MEETING WITH PETITIONER FRIENDS OF THE EARTH, REQUESTING ENFORCEMENT ACTION AGAINST SOUTHERN CALIFORNIA EDISON UNDER 10 CFR 2 206 EDISON UNDER 10 CFR 2.206 January 16, 2013 Presented For Friends of the Earth By Fairewinds Associates Inc, Burlington VT Based Upon Non-Proprietary Information
Sequence of Presentation SECTION 1: Chronology of Events SECTION 1: Chronology of Events SECTION 2: Magnitude of Design Changes SECTION 3: Conclusions 3
SECTION 1 CHRONOLOGY OF EVENTS 4
Prior To Analysis And Design Of RSGs, Edi A
li d T CPUC Edison Applied To CPUC For RSG Permits According to Southern California Edisons 2004 Annual Report, its application for its Unit 2 and 3 Replacement Steam Generators was filed with the State of Californias PUC on February 27, 2004, which was prior to the contract with MHI on September 30, 2004.
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In 2004 Edison Contract Language Directed MHI That CFR§50 59 Directed MHI That CFR§50.59 Would Not Apply An Edison Whistleblower released the San Onofre Design Specification for RSG. This specification required that CFR§50.59 would not apply to the San Onofre RSGs even though an analysis had not yet been completed.
EXCERPTS FROM SONGS Replacement Steam Generator p
Design & Performance Specifications SO23-617-1 Originator - James Chan IRE - Jun Gaor FLS - David Calhoun SLS - Craig Herberts 6
g PE Tom Pierno NO& A Bill Kotekkaskos
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San Onofre D
i S
ifi ti F
RSG #1 Design Specification For RSG #1 3.6.1.1 Edison intends to replace the steam generators under th 10 CFR 50 59 l
the 10 CFR 50.59 rule.
3.6.1.2
the Supplier shall guarantee in writing that the RSG the Supplier shall guarantee in writing that the RSG design is licensable and provide all support necessary to achieve that end.
3.6.1.3 Any deviations from these requirements shall require Edisons approval Edison s approval.
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San Onofre D
i S
ifi ti F
RSG #2 Design Specification For RSG #2 3 6 2 Licensing Topical Report:
3.6.2 Licensing Topical Report:
The Supplier shall prepare and submit for Edisons approval a Licensing Topical Report demonstrating compliance of the Licensing Topical Report demonstrating compliance of the RSG design with all SONGS licensing requirements. The report shall include an engineering evaluation, including all necessary analyses and evaluations, justifying that the RSGs can be replaced under the provisions of 10 CFR 50.59 (without prior NRC approval). The 10 CFR 50.59 evaluation shall be performed by Edison.
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Edison Official Notification T
NRC J 2006 To NRC June 2006 Edi N tifi d NRC f 50 59 D i i i
J 2006 Edison Notified NRC of 50.59 Decision in June 2006 A meeting was held on Wednesday June 7 2006 A meeting was held on Wednesday, June 7, 2006, between the Nuclear Regulatory Commission (NRC) staff and the SCE, the licensee for SONGS 2 and 3. The meeting and the SCE, the licensee for SONGS 2 and 3. The meeting was held at the request of the licensee to provide to the NRC staff an overview of the various aspects of its steam generator (SG) replacement project.
(ML061670140) 10
JUNE 2006 Edison Presentation to NRC 11
2006 NRC Informed of Improvements 12
2006 Edison Accepts Responsibility 13
Mitsubishi Heavy Industries Was y
Constrained By The Contract Between the contract award in 2004 and NRC kickoff meeting in 2006, Mitsubishi Heavy kickoff meeting in 2006, Mitsubishi Heavy Industries had to force fit the RSG analysis and design in order to support Edisons earlier design in order to support Edisons earlier decision determining that 10CFR§50.59 did not apply.
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The 10CFR§50.59 Process In its January 9, 2013 Response to the NRC Edison said Fairewinds agrees with Edison that this is the correct to the NRC, Edison said "As discussed in Section 1.3 of that this is the correct approach, and it should have been implemented.
However this approach was However, this approach was not applied during the RSG Project. Rather this "multistep process" was thwarted by p
y Edison.
No appropriate engineering and technical evaluation was performed by Edison when the contractual decision was made that 10CFR§50.59 would not apply.
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Standard Technical Specifications Standard Technical Specifications License Amendment 2009: During the San Onofre Standard Technical 2009: During the San Onofre Standard Technical Specification License Amendment, Edison identified man areas here the San Onofre identified many areas where the San Onofre Replacement Steam Generator was dramatically different than the Original Steam Generator.
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San Onofre RSGs Were Not Like-For-Like Were Not Like-For-Like 17
Edison Identified Numerous San Onofre Design Changes 2011 Edison and MHI Report tout all the design changes implemented in the San Onofre RSG:
Remove Stay Cylinder g
p Add 377 Tubes Change Tube Support Structure Add New Anti-Vibration Bars Dozens More Changes Dozens More Changes 18
SECTION 2 MAGNITUDE OF DESIGN CHANGES 19
In and of themselves, Edisons design changes to the Replacement Steam Generators should have triggered should have triggered the 10CFR§50.59 process.
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- The San Onofre tubes and tube sheets are part of the containment boundary and are safety related.
- San Onofre claimed to the NRC that new improved anti-vibration bars new improved anti-vibration bars would reduce wear on these important components and would not important components and would not adversely impact their design function.
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http://www.fairewinds.com/content/san-onofres-steam-generator-failures-could-have-been-prevented 22
Mitsubishi Heavy Industries Should Not Be The Scapegoat If the RSGs had been designed and manufactured in e
SGs ad bee des g ed a d a u ac u ed accordance with the procurement specification, the leak and tube wear would never had occurred. Page 12, 1/9/13 Edison Letter to NRC Edison Letter to NRC
- The replacement steam generator design developed by Mitsubishi in accordance with the licensees design Mitsubishi in accordance with the licensee s design specification was translated into the same set of design and fabrication drawings. AIT Report, Page 27
- No matter who fabricated the RSGs for San Onofre, the tube damage would have occurred. The root cause of this problem was the design not the 23 cause of this problem was the design, not the fabrication.
Edison 2003 Annual Report:
Edison 2003 Annual Report:
San Onofre Identical To Palo Verde Palo Verde Steam Generators The steam generators at the Palo Verde Nuclear Generating Station (Palo Verde), in which SCE owns 15 8% i t t h th d
i d
a 15.8% interest, have the same design and material properties as the San Onofre units. During 2003, the Palo Verde Unit 2 steam generators were g
replaced.
(Edison 2003 Annual Report, Page 21) http://www.edison.com/images/cms_images/c6452_2003_annual_eix_5543.pdf 24
Stay Cylinder: Retained On Palo Verde And Eliminated On San Onofre 25
Egg Crate Design Retained On Palo Verde/
Egg Crate Design Retained On Palo Verde/
Eliminated On San Onofre BROACHED TUBE SUPPORT EGG CRATE TUBE SUPPORT 26
San Onofre Problem Was Foreseeable San Onofre Problem Was Foreseeable
- Stay Cylinder removal and Tube addition l
d h h i
h f S placed too much heat in the center of San Onofres Replacement Steam Generators
- San Onofre added 4% more tubes at the
- Palo Verde added 10% to the periphery and
- San Onofre added 4% more tubes at the center of its RSGs added 2.9% more heat
- Palo Verde has no FEI problems p
- Edisons Design destroyed San Onofres RSGs 27
Contour Of Steam Quality Condition Report: 201836127, Revision 0, 5/7/2012, Figure 2: Contour of steam quality at the height of the maximum quality in U-bend region for T-hot = 598"F (Figure 8.1-2 (a) in Reference [2]), Page 74.
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What Did The 10CFR§50.59 Review Say?
Edison is parsing its words!
Edison is parsing its words!
At the time the RSGs were designed MHI evaluated the Removing the stay cylinder allowed 377 extra tubes designed, MHI evaluated the flow patterns and determined that fluid elastic instability (FEI) would not occur. 1/9/13 allowed 377 extra tubes into the center void, creating more interior heat The riser column water void
(
)
ou d o occu.
/9/ 3 Edison brief to NRC, page 14 MHI provided a thermal-The riser column water void above the tube sheet was also eliminated There was nothing on the MHI provided a thermal hydraulic analysis as part of the original design of the RSGs that showed there There was nothing on the steam side to facilitate and bias the flow direction. The steam side flow patterns would be no FEI. page 17 p
were never established.
The 10CFR§50.59 analysis should identify high void y
g fractions and confused in/out-of-plane FEI.
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Friends Of The Earth Consultants Reached A Diff t 10CFR§50 59 C l
i A Different 10CFR§50.59 Conclusion
" design changes may be Fairewinds agrees with this screened out under 10 CFR 50.59 if the changes do not adversely affect a design function Page 9 Edison approach, but it is not the approach used by Edison at San Onofre.
The totality of RSG changes function Page 9, Edison Response, 1/9/13 "The adverse condition that later resulted in the tube leak was a The totality of RSG changes Edison proposed in 2004 created an unacceptable void fraction at the top of the hot deficiency associated with the design and was not known at the time the 50.59 evaluation was performed. Page 9, Edison side of the tubes that then created the FEI.
Fairewinds and John Large both agree that it should have been was performed. Page 9, Edison Response, 1/9/13 agree that it should have been foreseeable to Edison in 2004 that this combination of changes would cause FEI to occur.
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Edisons Cause Report Was Wrong
- Former NRC Chairman Gregory Jaczko promised S
t d th bli l t t C Senator Boxer and the public a complete Root Cause Analysis. This has not been conducted.
i i f
- Kepner Tregoe Cause Analysis is severely flawed.
- If they can get you asking the wrong questions, they don't have to worry about answers Thomas Pynchon don't have to worry about answers. Thomas Pynchon, Gravitys Rainbow
- Statement upon which Edison based its Cause Report:
- Statement upon which Edison based its Cause Report:
What is different or has changed when comparing SONGS Replacement SGs to Another US plants Replacement SG (page 43, Condition Report) 31 Replacement SG (page 43, Condition Report)
What Root Cause Question Q
Should Edison Have Asked?
There are no changes to compare among Edisons RSG and other RSGs nationwide. Its an apples and oranges comparison.
Th h
Edi h
ld h l
d The changes Edison should have analyzed and compared are those between the OSG and the RSG or between San Onofre and Palo and the RSG or between San Onofre and Palo Verde, since Edison has acknowledged that Palo Verdes RSG is identical to San Onofres OSG OSG.
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Exclusions From Edisons Kepner Tregoe (KT) Analysis Process Extracted from the Edison Kepner Tregoe Exclusion Table: Condition Report: 201836127, Revision 0, 5/7/2012, Root Cause Evaluation: Unit 3 Steam Generator Tube Leak and Tube-to-Tube Wear, San Onofre Nuclear Generating Station, Page 52 33
SECTION 3 CONCLUSIONS 34
THE CHANGES EDISON MADE CREATED FORESEEABLE PROBLEMS FORESEEABLE PROBLEMS During the past eight years the NRC had extensive During the past eight years, the NRC had extensive evidence from multiple sources that the replacement steam generators at San Onofre were not the like-for-like l
t f th i i l d i
Edi itt d replacements for the original designs, as Edison committed during the 10CFR50.59 processes. And, as demonstrated by the significant damage in the San Onofre Replacement St G
t th d
i h
did h Steam Generators, the design changes did have a significant impact upon key design functions and in fact degraded the containment boundary.
Edison should have notified the NRC that the significance of all the changes required a 10CFR50.59 license amendment amendment.
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San Onofre Was A Near Miss San Onofre Was A Near Miss Th t b f il The tube failures at San Onofre are the worst are the worst nuclear equipment q
p failures since the near miss at Davis Bessie in 2002.
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San Onofre Technical Specifications San Onofre Technical Specifications states San Onofre Technical Specifications states that the limiting design basis accident is a "double ended rupture of a single tube.
double ended rupture of a single tube.
Page 510 37
Edisons San Onofre:
d so s Sa O o e:
Operating Outside Design Basis Eight Tubes failed their pressure test, not one!
The evidence shows that San Onofre was operating The evidence shows that San Onofre was operating outside of its design basis and the NRC has done nothing to address this major violation.
Although in this case the degraded condition of the tubes was manifested as a small primary to secondary leak, it is possible that a full-blown rupture could have been the first indication. Page 57, NRC AIT Report 38
Arnie Gundersen, Chief Engineer F i i d A i t I
Fairewinds Associates, Inc Nuclear Engineering, Safety, and Reliability Expert 42-years of nuclear industry experience and oversight ME NE Master of Engineering Nuclear Engineering Rensselaer Polytechnic Institute, 1972 Rensselaer Polytechnic Institute, 1972 U.S. Atomic Energy Commission Fellowship Thesis: Cooling Tower Plume Rise BS NE B
h l f S i N
l E
i i
BS NE Bachelor of Science Nuclear Engineering Rensselaer Polytechnic Institute, 1971, Cum Laude James J Kerrigan Scholar James J. Kerrigan Scholar RO Licensed Reactor Operator U.S. Atomic Energy Commission 39 License # OP-3014