Comments by CaptD

California or Corrupt Public Utilities Commission?

From a NRC Blog: Even the Best Guidance Can Be Updated snip One area that needs major improvement is the Like-For-Like replacement criteria, since SCE made a mockery of the NRC by claiming that they were doing a Like-For-Like RSG replacement at San Onofre Nuclear Power Plant when in fact they were making major design changes that resulting in their 4 new RSG failing soon after installation, a situation that placed all of southern California at risk of a nuclear incident and/or nuclear accident! Here is an industry document that describes most of the changes that they made while bragging that it was done as "Improving Like-For-Like” which was published just weeks before one of the four RSG’s started leaking radioactive core coolant from one of the soon to be discovered unprecedented amount of wear damaged RSG tubes. [][1] BTW: Nobody can claim the article is bias since it was published by Nuclear Engineering International, just weeks before Unit 3 started leaking radioactive core coolant. [1]:
— June 10, 2014 3:04 p.m.

Peeved Commissioner Peevey hints at CPUC's disarray

***SCE’s Erroneous Assumption*:***

 **SUMMARY**: In non-engineering terms, the cause of San Onofre Replacement Steam Generator (RSG) debacle was SCE’s in-house design teams erroneous assumption that their four new RSG’s would be identical "enough" to the original San Onofre Steam Generators (SG’s) as manufactured by Combustion Engineering twenty five years prior, in both design and operational function to qualify SCE to make these replacements safely under the NRC’s like for like replacement criteria, instead of having to seek an amendment to the San Onofre Nuclear Power Plant Operating License via the lengthy NRC 10 CFR §50.59 review process which includes public input. SCE then expanded their basic assumption to justify allowing their own in-house engineering staff to:

 1.Develop the RSG design specifications that later proved to be unsafe, causing them to fail soon after being installed.

 2.To manage the entire Replacement Steam Generator Project (RSGP), which included selecting Mitsubishi Heavy Industry (MHI) as the most qualified contractor, from a list of SG manufactures. to manufacture their four new RSG’s, even though neither SCE or MHI had any prior experience in building RSG’s anywhere near this size and/or capacity.

 NRC Region IV, which is based in Texas, is responsible for overseeing the safe operation of San Onofre. Those NRC staff responsible for reviewing SCE’s design assumptions knew full well that there were significant differences between the OSG and the RSG yet they did not have the technical training to understand how these changes would result in the failure of the RSG’s, so instead of seeking additional input from others within the NRC that did have the required technical expertise, they chose to accept SCE assumptions. This decision by NRC Region IV resulted in compounding the problems at San Onofre because now those tasked with making sure that the SCE RSGP was safe were in fact making their decisions based on SCE’s own assumptions instead of industry proven engineering principles, said another way, the blind were leading the blind…

 The result of these assumptions by SCE and NRC Region IV was that, as the NRC Inspection Report (NRC AIT) states, “replacement steam generators were installed at San Onofre with a significant design deficiency, resulting in rapid tube wear of a type never before seen in recirculating steam generators”. ***** This is the first part of a much longer article for SoCal ratepayers to help them better understand exactly what went wrong at San Onofre and why they should all demand a full refunds from their Utilities which caused this *Multiple Billion Dollar Debacle*!
— May 27, 2014 1:45 p.m.

Peeved Commissioner Peevey hints at CPUC's disarray

Many have asked me, "Why SCE went forward with having MHI build and then install the 4 new Replacement Steam Generators (RSG's) knowing that they had design "issues as noted in not one but several SCE documents? My best guess is that they had to since they had already committed themselves as the Operators that were in charge of the RSGP to the CPUC, the NRC and their shareholders, so if they suddenly had to say, "Ah, guys we think we may nave a small problem or two" they would have set themselves up for even bigger legal accountability issues that could have ended up with SCE being not allowed to replace the OSG, which were getting near their plugging limitation and therefore were not generating as much Energy and/or profits as SCE wanted.  Another issue is the use of high burn-up fuel and its effect on the original steam generators and other hardware, which was one of the reasons that SCE wanted to install new RSG since they would have better corrosion resistance since they used a newer alloy for the tubing.

I also think that most of the decision makers at SCE did not understand FEI and figured that they could get away with operating the RSG's in such a way as to minimize any potential problems until they could explain them away as being unrelated to their specific design.  Remember that Unit 2 was replaced first and was operated with different parameters than Unit 3 for about a year and I bet these same decision makers at SCE were feeling pretty confident that both Unit 2 and Unit 3 would work out OK, that is until Unit 3 started leaking, which then lead to the discovery of all the internal SG tube damage which even the NRC said was unprecedented in the history of the US Nuclear Fleet.

This NRC damage assessment was the wake up call for SCE who then shifted into CYA mode, which included coming down hard on any employees that hinted at or even worse provided documentation that these problems were predicted by SCE team members but ignored by those in charge.  As SCE tried to regroup as they "studied the problem" they brought in outside experts but only gave them "some" of the data, which I believe was the reason that all their results conflicted with each other, creating a bigger smoke screen for SCE to better hide behind. [1]:
— May 27, 2014 1:39 p.m.

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