CPUC OII Prep

• Set ALLOWTOPICVIEW = Main.ProgressiveStrategyGroup

• Parents -- ShutSanOnofre, CoalitionToDecommissionSanOnofre

QUESTIONS

1. On 09 Jan 2012, SCE removed Unit 2 from service for the planned Unit 2 Cycle 17 refueling outage. It was reported in the Orange County Register that a new turbine with increased power output was installed, enough to power 31,000 homes. Is this true?
2. If true, how did SCE estimate the increased power output?
3. Did the increase in power expected from Unit 2 rely on additional steam generated by the new steam generators?
4. According to the Root Cause Analysis Document, "This SONGS RCE is focused on determination of the mechanistic cause for steam generator tube-to-tube wear. No safety culture components (human performance, programmatic, and organizational issues) were identified involving SONGS as defined in SONGS Procedure SO123-XV-50.CAP-3 (Evaluations and Action Plans).

   The newly installed SGs were purchased from MHI and, in accordance with their Appendix B program, MHI will be performing a RCE to understand the human performance, programmatic and organizational issues involved in SG design/fabrication and the mechanistic cause of FEI. MHI’s RCE should provide insights into safety culture issues. SONGS RCE will be revised to include a Safety Culture Review after receipt of MHI’s RCE (See CA6 in the CA Matrix)." -- Does that mean that no safety culture components are being studied by SCE? It seems that the fact that this vast design error crept into the process means RCE should be performed at levels higher than the mechanistic cause.

5. In OOT CAUSE EVALUATION NN 201843216 April 2, 2012 Page 43 of 82, Attachment 4 - History and System Description Steam Generators, it says

   In the PWR plant, there are three boundaries pr eventing radioactive material from being released to the environment – nuclear fuel cladding, reactor coolant pressure boundary and the containment structure housing the Nuclear Steam Supply System (NSSS). The steam generator primary side (channel head) and heat transfer tubing are a part of the reactor coolant pressure boundary. In addition to being a part of the pressure boundary, the steam generators are a part of the safe shutdown system and are required to remain operable for heat removal during certain plant upset and postulated accident conditions.

   In the approval of the 70% mode of operation, this does not appear to be take into account.

6. Our electric utilities should be responsible for the most cost-effective solution for providing power. The most cost-effective is not necessarily the most profitable, unfortunately. According to Arno Harris in the 31 August 2011 Renewable Energy World. "A Silver Lining in Declining Solar Prices",

   The less solar power costs, the more favorably it compares to conventional power, and the more attractive it becomes to utilities and energy users around the globe. Utility-scale solar power can now be delivered in California at prices well below $100/MWh ($0.10/kWh) less than most other peak generators, even those running on low-cost natural gas. Lower solar module costs also stimulate demand from consumer markets where the cost of solar compares very favorably to retail electric rates.

   The RSGP cost at least $700 million. For that price, at $100/MWh, about 7000 GWh would be produced from solar.

R. The SONGS Units 2 & 3 daily energy production from December 1, 2010 through 7 December 31, 2012 are provided in Appendix 1, Tab 23.

Notes

• SONGS Procedure SO123-XV-50.CAP-3 -- I can't find this.

Talk with Martha and Ray on 2013-05-06

• Find out what they mean by exhibits which need to be determined by Tuesday, 5/7
• Our written testimony.
• Where we reference other documents, those should also provide those, at least the executive summary.
• Relate the HPT project to a specific SCE witness.
• Sent HPT info to Ace and Don to let them chew on this.
• Priorities:
• HPT issue -- Q:\z\COPS\Projects[ShutSanOnofre](/Common/ShutSanOnofre)\CPUC\CPUC Extraction\Workpapers%20Supporting%20SCE-4%20Vol%202%20(%20Supporting%20Appendices%20for%20Capital%20Projects%20in%20SCE%202012%20GRC).pdf
• split shutdown issue *

Workpapers_Supporting_SCE-4_Vol_2_(_Supporting_Appendices_for_Capital_Projects_in_SCE_2012_GRC).pdf

HPT Issue:

The HPT issue was disclosed in the document:

TESTIMONY OF SOUTHERN CALIFORNIA EDISON COMPANY IN SUPPORT OF APPLICATION FOR REVIEW OF THE 2012 EXPENSES RECORDED IN THE SAN ONOFRE NUCLEAR GENERATING STATION MEMORANDUM ACCOUNT (SONGSMA)

A.13-01-XXX_SONGSMA_-_SCE_Testimony_In_Support_of_Application_for_Review_of_the_2012_SONGSMA.pdf

pages 99-102. Witnesses: Jose Perez, Russell Worden

Details disclosed in this document: A.13-01-016_SONGSMA_-_SCE_Workpapers_Supporting_SCE-4_Vol_2_(Page_Numbered_Version).pdf Pages 65-97

Apparently, this proceeding was consolidated with the OII I.12-10-013.

Planned Tcold change

From Root Cause Evaluation, Page 28

CA5: Conduct a primary system change analysis including the planned TCold change to verify changes in operating parameters will not have an adverse effect on Unit 2 SG operation.

Split Shutdown Issue

Skipped Third Party Review

RCE_U2_SG_R0_Final_Redacted -- ROOT CAUSE EVALUATION NN 201843216 (Page 22 of 82)

The SONGS replacement steam generators were larger in size for MHI from its Westinghouse licensed standard design. Edison Project Management determined that the normal design and fabrication oversight process be proactively augmented. To accomplish this, Edison added special program elements to provide additional oversight and control for the RSG design and fabrication process. One of the additional elements attempted was the use of third party review. The typical third party review was not performed on this project for two primary reasons 1) the number of personnel with SG design experience is very limited and typically associated with SG design/manufacturing companies and 2) the companies with these personnel are in competition with each other and not willing to share proprietary design information. Since SCE was not in a position to make the third party review happen, they recommended and MHI complied with bringing in outside SG design expertise. This consisted of two retired SG design engineers.

RCE page 31:

OA6: Develop guidance on how to perform oversight of vendors when "proprietary" information prevents the use of third party reviews.

Edison disregarded retainer bars as insignificant and MHI had proprietary secrets

From RCE:

The AVB structure (which includes the retainer bars) was prioritized for an augmented level of attention, specifically the potential for tubing wear from the interaction with the AVBs. The retainer bar is a small element of the AVB structure which does not normally interact with the tubing during operation. The primary purpose of the retaining bar is to prevent the AVB assembly from displacement during a main steam line break event. As such the design of the retainer bar itself was not identified for this augmented level of attention. In addition, the retainer bar is part of the proprietary standard design originally developed by Westinghouse and adapted by MHI, to which Edison did not have access. Edison was not aware that the MHI selected size and length represented a departure or change from the standard design. The reviews by Edison were focused on reducing tube wear that might have been caused by tube movement and retainer bar contact. This led to the diameter increase of the selected retainer bars and additional chromium plating thickness. MHI also added a stress analysis for the retainer bars to the AVB calculation as requested by Edison. However, MHI did not include the retainer bars in the flow induced vibration analysis.

RCE Page 32

OA8: Include within the Unit 3 SG tube failure RCE an analysis of SONGS's retainer bar being an unanalyzed change from a proven design as a cause for the extent of cause review. The intent of this review is to determine if there are other latent scaling issues.

More on Tcold

From: Docket No. 50-361 Response to Request for Additional Information (RAI 14) Regarding Confirmatory Action Letter Response (TAC No. ME 9727) San Onofre Nuclear Generating Station, Unit 2

http://pbadupws.nrc.gov/docs/ML1303/ML13032A009.pdf

At 70% power, plugging 8% of the steam generator tubes has the effect of increasing TAVE from 568.1 OF to 568.7 0 F and will consequently change the pressurizer level setpoint program output from 48.86% of the pressurizer level instrument span to 49.18% of span, an increase of 0.32% of span. With the current 2% and 3% tube plugging ratios in the Unit 2 steam generators, the actual pressurizer level setpoint shift going into the U2C17 operating cycle will be even smaller than the insignificant 0.32% value for 8% tube plugging. No changes are needed in the pressurizer level setpoint controller configurations to support reduced-power operations with tube plugging ratios up to 8%. Nuclear Steam Supply System Control Systems Westinghouse previously analyzed the nuclear steam supply system (NSSS) control system configurations for the TCOLD restoration project, which changed full-power TCOLD to 550 0 F. The analysis provided new values for the NSSS control system calibrations (including values for the DFWCS and the SBCS). The new calibration values were installed during the R2C17 outage. As part of the Unit 2 return-to-service effort, the NSSS control system configurations were reviewed again to identify potential impacts from operating at reduced power for an extended period with steam generator tube plugging ratios up to 8%. The review found the installed NSSS control system configurations for 550'F full-power TCOLD to be acceptable from hot zero power to 100% power with up to 8% tube plugging.

Debriefing

Overall Schedule

• June 16 -- NRC deadline to intervene and request a hearing.
• June 21 -- Opening Briefs due -- This will probably get bumped at least a week.
• Be focused in our opening brief.
• Main Issue is No Consideration to cost of options.
  • Continued to restart Unit 2 thinking it was fine.
  • Decided to formulate a restart of Unit 2 after realizing problems were severe
  • Push was to make sure other costs, such as the high pressure turbine retrofit for Unit 2 would be justified.
  • Decided to put Unit 3 in layup instead decommissioning.
  • Didn't talk to MHI seriously (with a deadline) until November.
• Data Requests --
  • Ask for first Rev of layup plan for Unit 3.
  • Ask for any financial model used to make cost sensitive decision on restart.
• July 1 -- Reply Briefs
• ALJ Darling said that ruling on Phase 1A would be complete prior to starting Phase 2.