ML13153A018
| ML13153A018 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/27/2013 |
| From: | Tom Gurdziel Public Commenter |
| To: | Macfarlane A NRC/Chairman |
| Shared Package | |
| ML13153A019 | List: |
| References | |
| LTR-13-0473 | |
| Download: ML13153A018 (3) | |
Text
Joosten, Sandy From:
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Cc:
Subject:
Attachments:
Good morning, Tom Gurdziel [tgurdziel@twcny.rr.com]
Monday, May 27, 2013 10:59 PM CHAIRMAN Resource jicc; Uldis Vanags; Bridget Frymire; thenry; OPA4 Resource Arrival Eddy Current Testing at SONGS CPUC 5.docx I hope to mail this letter early this week.
Thank you, Tom Gurdziel 1
President Michael R. Peevey Public Utilities Commission 505 Van Ness Avenue San Francisco, CA 94102
Dear President Michael R. Peevey:
9 Twin Orchard Drive Oswego, NY 13126 May 27,2013 Isn't it too bad that they ruined (or at least damaged) those expensive replacement steam generators at SONGS by operating them with those inadequately designed Anti Vibration Bars?
Wait. Let's just pause here a minute. Anybody working in the nuclear industry longer than 6 months would have heard the advice to have a "questioning attitude."
So, let's use our "questioning attitude" now. First off, ifthe anti-vibration bars, (AVBs) caused the damage during plant operation, wouldn't the replacement steam generators have been undamaged before the start of operatic~? How can we prove this? Fortunately, we can see from the very top of page 4 of the NRC Augmented Inspection Team Report 05000361/2012007 and 05000362/2012007 that an eddy current test was done in Japan and was done at SONGS on the Unit 2 steam generators. And, a statement is made that no changes were identified.
Well, this sounds good. However, I cannot see any mention in the attached List of Documents Reviewed that the NRC team actually looked at these eddy current tests. (There is mention of eddy current tests of the U-bend portion during manufacture. They are mentioned on pages 4 and 5 ofthe attachment to NRC Augmented Inspection Team Follow-up Report 05000361/2012010 and 05000362/2012010. I would not conclude these are the same tests, though they may be.)
That was for Unit 2, the one that did not have a tube break. What about Unit 3? Well, go to the bottom 2 paragraphs of page 4 of the AIT Report, (not the AIT Follow-up Report). See if you can find any reference to the fact that they did an eddy current test on the Unit 3 replacement steam generators at SONGS. I don't think you will see it. So, how can you blame the AVBs for causing damage to what have been assumed to be undamaged tubes, when you cannot show that the tubes were undamaged at the start of Unit 3 operation?
Thank you, Tom Gurdziel Member, ASME
(Please note that, in my first sentence, I have "jumped to cause." The common advice when doing problem solving is to NEVER jump to cause.)
Copy:
Commissioner Catherine J.K. Sandoval Commissioner Mark J. Ferron Commissioner Mike Florio Commissioner Carla J. Peterman