Monday, January 19, 2015

Endemic Engineering Corruption at McGuire and in NRC?

'Who is on first"? 

Basically Duke-McGuire with full knowledge of the NRC shapes an inspection finding of the NRC. In order to keep a plant up a power and making money, as in this case, they will falsely shape their engineering disclosures to the NRC and the NRC willing accept any incorrect testimony and document falsification from the licensee.

I consider any defects in the valve inserts as immediately inoping the DG and all similar DGs. Especially if the insert can get sucked into the cylinder and get chewed up by the piston-cylinder "Waring blender". A lose diesel insert could damage a DG such it couldn't perform its intended function. It is common knowledge for years McGuire-Nordberg has too small diameter valve inserts and susceptible to inoping and damaging the machines. Basically the inserts should be hard attached to the head or cylinder by a set screw or threaded…a secure attachment of some kind. 

At the end of the day, I expect the NRC to whisper in the ears of the licensees…with the licensees trembling in object fear over the power the agency has over them with the ends of serving the nation's greater interest. I expect the agency to quietly whisper in the licensees’ ears (publicly document it), with then the licensees and vendors “going to the ends of the earth” to comprehensively investigate and fix the problem. One peep or hint from a plant NRC inspector, the incident or component degradation will never happen again. Period! Today the NRC "wets their pants" in terror at the sight of any licencee executive.   
McGuire Nuclear Station, Units 1 and 2

Inspection Report: 50-369, 50-370 NPF-9, NPF-17 50-369/99-07, 50-370199-07

September 12, 1999 -October 23, 1999
McGuire and Brunswick need new nuclear qualified Caterpillar (or USA similar) DGs…
'NRC IRs 50-369,370/98-06, 98-07, and 99-02 documented and assessed previous failures of cylinder head sub-components. In 1997 the cylinder heads were rebuilt by an approved Appendix B vendor at the vendor's facility as part of a 100 percent EDG refurbishment. 
During the inspection period, the inspectors reviewed two recent issues involving degraded conditions of valve seat inserts (VSIs) on EDG 1B. The Nordberg diesel engines used at McGuire have 16 cylinders with one exhaust and one intake valve for each cylinder head.

Each VSI comprises an approximately 5.128 inch diameter ring of steel which is interference fit (friction fit at the walmart auto shop) into its respective cylinder head port.

Partially Dropped VSI (PIP M99-4413)

On October 2, 1999, with Unit 1 defueled, maintenance technicians performed corrective maintenance on EDG 1 B cylinder 4L due to degraded performance that was identified during a 15-minute low load break-in run. Technicians inadvertently over-adjusted an exhaust valve and caused extensive damage to the associated cylinder piston, liner, and head during the next post-maintenance EDG run. A subsequent investigation revealed that the over adjustment was made
See how they turn a design error into an unforeseen technician error. Conservationism also calls for, if you don’t fully and completely understand the failure, you assume the defect is bounded by the worst case assumption. The worst case assumption is the “interference” and the engine design is the problem and now, the repair, replacement parts and the traditional manufacturer engineering servicing is absence. This is only going to get worst in the years to come  

I get that with the NRC now, the unknowables and undetectables…the engineering safety uncertainties…they always go to the towards profit and plant survival interest of Duke instead of the licensee having the available evidence and proof these machines will operated reliably in the plant for their intended duty and all the designed accident.

As a aside, Progress Energy, now Duke, once recently intended to replace their Nordberg emergency diesels over their poor quality and obsolete repair and replacement parts Woodward governors. The magnitude of the recurrent amount of out of specs and out of tolerance repair and replacement parts for their emergency diesels within the no longer manufactured Nordberg line of nuclear diesels at Brunswick nuclear power plants. 

The resulting Chinese, no longer in established manufacturing production lines non pedigree, untraceability and voodoo contractors, the second rate engineering service providers and black-market refurbished and replacement parts vendors.

https://adamswebsearch2.nrc.gov/webSearch2/view?AccessionNumber=ML15005A044

Basically the “stepping down the load” is a corrupt “facilative assumption” to keep the machine operational at all cost without actually spending money on it even if you have to lie to the NRC and public. Nordberg many years back, told Duke to “step down the load” when shutting down the diesels to limit the risk of a dropped valve insert (DVI) because of the insert defect that was known to inop the diesel and was very dangerous to operability.
If stepping down the loads was the fix for the piston inhaling and then choking on the loose valve insert...how in the hell is the machine going to behave with large loads being dropped with the diesels isolated from the grid in a accident? So a dg carrying its load in a terrible accident, then dropping a few large pumps, say caused by shorts? How about the diesel tripping for some reason, but the operator having the capability fix the problem and they try to restart the DG. So how is the operators going to control "stepping down the load" during a LOOP. In other words, what does the loads of the dgs look like in a accident? Let me tell you something, there is a lot of uncontrollable down power maneuvers and tripping and starting up these dgs in the big accidents. They cycle up and down in power on the governor all through these.

It is utterly immoral and unethical, implies the plant staff and NRC lacks a conscience. The idea you control through "stepping down the load" in the testing and maintenance regime to minimize the total destruction of the dgs through an active component flaw. While in the accident scenarios there is no means to control load reduction and protect from a dangerous loose valve insert. Usually the way it goes with with guys, you don't fix the component flaw, make it easier for the operators, you just jack up massively the complexity to the licensed operators dealing with the operation of the plant in accident to save a few pennies. The way you would do that, is in the normal and emergency procedures to dictate how the operators would control the dg load reductions in all of the accidents.
I am just saying the out of production and unsupported manufacturer Nordberg dg has a too poor "real" reliability (the reliability would be a lot worst, but for the federal falsification of documents and getting away with lying to the NRC)than the recorded and publicly seen reliability...these machine are grossly inappropriate for a nuclear safety function. It going to get much worst with the replacement parts problem and as these DG age during the rest of the life of the plant. 


“On August 18, 2014, at 1718, approximately 14 hours into a 24 hour surveillance test of EDG 1B, cylinder 5L exhaust temperature dropped" indicates the inop wasn't initiated by the poor quality of the components and tolerances. It is obvious the valve inserts dropped and damaged the rest of the components. Duke with the concurrence of the NRC, turned the event from knowingly operating the DGs recklessly with dangerous components or parts and the associated federal falsification of documents into a “combination of the above factors” beyond the control of the licencee as stated in LER 369/2014-01. I am surprised Duke didn't frame it as a act of god, thus beyond their control.  

The McGuire NRC inspection report 99-07 and this event in LER 2014-01 are identical. Duke is shaping the regulatory response to a ghostly “ inadvertent, unforeseen and a act of god by the licensee” from the real "corruption, falsification of federal documents and pure corporate negligence issue".  
because of unforseen movement of the VSI upon engine shutdown prior to the maintenance activity. The slippage
"The slippage of the VSI"...isn't it hilarious this choice of words. Engineering language...language or word understanding disruption...the real possibility of the operability destruction of the dg through touristy and flowery words and language.   
of the VSI from the cylinder head was attributed to a combination of conditions, most prominently involving elevated exhaust temperatures in tandem with a rapid cylinder cooldown. Other factors that may have contributed to the failure included the quality of the interference fit between the VSI and the head during installation. Improper seat installation reduces contact between the seat and the cylinder head which could make the seat vulnerable to drop out under certain conditions. 
(me-the NRC engineering safety philosophy where uncertainty always gets thrown towards the licensee executive's bonuses) side) 
However, the licensee was not able to establish that the seat was improperly installed during the 1997 rebuild because the subject seat was destroyed and the head distorted during the failure of cylinder 4L( me-or if the part gets destroyed, that gives you the option to lie your teeth off).
Basically the inspectors and NRC's bureaucracy unproductively churning the agencies process without getting a result. Meaninglessly churning the NRC's processes to no ends. Is primarily churning the process the ultimate ends to what is in the best interest of the USA according to the NRC...not making a safer and better world for its people.
The slippage of the VSI was similar to the dropped VSI event that was discovered on EDG 2A in June 1998. The inspectors independently reviewed the diagnostic information of EDG 1B and noted that similar conditions to the dropped VSI event of 1998 were present. However, in this post-maintenance configuration, the engine was not operated at the full load condition. Had these conditions been present during  a full-load run (as is performed to "demonstrate operability), a local alarm for elevated cylinder exhaust temperature would have alerted operators to the conditions. In accordance with the annunciator response procedure, an elevated temperature alarm (activated above 3500 kilowatts EDG load) would trigger an engineering assessment and prompt an extended engine cooldown to prevent dropping a VSI. The inspectors concluded that this degraded condition would not have been permitted to exist following an operability test and that the previous corrective actions would have prevented the EDG from being returned to service in a degraded condition. The licensee informed the inspectors that additional monitoring of cylinder performance at lower load conditions was being evaluated to eliminate this type of failure. Subsequently, maintenance procedures for valve adjustments have been improved to prevent over-adjustments in case of unknown VSI movement. The long-term corrective actions include replacement of all exhaust VSis to an improved VSI part (discussed below).
Cracked VSI (PIP M99-4450)

On October 4, 1999, the licensee performed a visual inspection for potential loose parts from the 4L cylinder failure on the remaining EDG 1 B cylinder heads and discovered a crack on cylinder 2R exhaust VSI. The subject VSI contained a 360-degree circumferential crack; however, the seat remained intact (no missing pieces). A previously cracked VSI occurred at McGuire on May 19, 1998, where a circumferential crack resulted in a 120-degree piece of the exhaust VSI (EDG 1A cylinder 6R) breaking away and lodging onto the turbocharger inlet screen. The inspectors reviewed temperature trends of EDG 1B cylinder 2R, which revealed no abnormal performance. Prior to identification of this cracked VSI, the licensee believed that a precursor condition existed that could be detected prior to failure of a cracked VSI. Although this was true in the previous case, the inspectors observed that these precursor symptoms (lower than expected exhaust temperatures at low load conditions) were not present for the current case. In addition, the root cause of the previously cracked VSI concluded that a material defect likely caused the failure. This conclusion was based on a detailed root cause investigation; however, the metallurgical analysis did not provide conclusive evidence of a defect.
Following the recent VSI crack, licensee corrective action included a video inspection of the VSIs on the other three EDGs. The inspectors considered this to be prudent. The inspectors observed portions of the video boroscope. Video quality and resolution were excellent; however, residual fuel oil limited seat details in some areas and only 300 degrees of the VSI surface could be observed because of physical limitations to camera movement inside the cylinder head. The licensee informed the inspectors that 360 degree cracking had been observed previously on cylinders with approximately one million cycles of operation (65 hours of engine run time). The proposed long-term corrective action was to replace the exhaust VSIs with those having a 0.001 inch greater interference fit and perform the rework with improved installation methods using qualified McGuire maintenance personnel. All EDG 1 B exhaust VSIs were subsequently replaced with those of greater interference fit, the EDG was operated for more than 65 hours, and then the VSIs were boroscoped. For all four EDGs, no additional cracked exhaust VSIs were identified and the inspectors confirmed that each cylinder head inspected did have more than 65 hours of run time prior to the video inspection. The licensee now believes that both cracked VSls were fatigue related failures related to improper installation and not a material defect in the VSI. (me- I can’t  catch my breath I laughing so hard. I think I am having a heart attack)
It is amazing, in the written record and part 21, the magnitude of out of specs and out of tolerances problems with Nordberg nuclear diesel repair and replacement parts throughout many decades. It is amazing how reliable these repair and replacement parts systems are with producing so many out of specs and out of tolerance components over the decades. Another commonality in the Nordberg system over the ages is how incomplete and shallow the engineering and its documentation are with their dgs. How incomplete and the missing is engineering information on Nordberg ds. The Nordberg technical specifications, policies and procedures and information are so insufficient on these nuclear grade safety components.
  
It is the widespread go-to excuse for all of the players. 
Just so you get it, the Nordberg nuclear diesel generator line went out of business many years ago. As the reality of the manufacturing line shutdown was approaching Nordberg, they reduced servicing these machines and updating the documentation of problems. Duke now is basically the QEM (qualified equipment manufacturer) and they basically own the documentation remnants of the Nordberg nuclear grade dg line. Duke sometimes is very dishonest with declaring the problem. Duke basically is a purchaser and owner of Nordberg DGs and they own the business entity named Nordberg. There is no similar QEM designation of a licensee such as Duke in the nuclear industry.  
The licensee speculated that vendor problems with improper dimensional checks and installation technique.
It is dangerous beyond understanding...if a licensee is being allowed to speculate on the failures of safety components. If the players are basically playing Abbott and Costello's "Who's On First" in secret and nontransparent maintenance and components failure in the 

 The NRC,licencees and manufacturers' baseball team.


documentation system between the licencee, manufacturers, vendors and engineering service providers. If the maintenance documentation systems of the players can't be seen amongst themselves and outsiders...then they can play "Who's on First" to their hearts delight with the NRC on why a components failed on a nuclear plant emergency diesel generator...may have contributed to the failures.
may have contributed to the failures. In addition, the vendor rebuilt the heads with a smaller VSI than preferred. ( Oh shit, now my wife has called 911 fearing I am going to bust a vein in my head) The inspectors
 Are just the facts a lie in the big story? What evidence does the NRC have these defective inserts could remained stable in the worst case mission time? What evidence does the NRC infer that the insert cracks are stable and the failure is predictable? See how the NRC always throws the engineering and assumption uncertainties to whatever advantages a licensee. They only caught these cracked inserts by chance…they caught the cracks when another cylinder choked on a lose insert. The NRC can only punish the licensees on what the agency can see and measure...can't incentivize a licensee for having cracks on inserts risking a future failure of the machine when much needed in a accident. 

Who was the vendor that did this inadequate job…why does the NRC protect the name of these bad actor servicing vendors? At the heart of this problem, there is absolutely no NRC oversight of the licensee or their vendors overhauling a diesel generator. The NRC doesn’t have the diesel generator expertise to know the proper maintenance of this machine during an overhaul period.

The agency can only catch the problems and failure with the DG through the rear view mirror of component failure…never catch emergent problems in an on going overhaul. I doubt the inspectors get much training with overseeing DG maintenance overhauls. The NRC is overly dependent with the licencee telling the inspector what went wrong with diesel failures and what went wrong or discovered in a DG overhaul.   
cracked VSIs, just like the other degraded EDG sub-components identified in Violation (VIO) 50-369,370/98-07-07, were attributable to inadequate vendor oversight during the 1997 rebuild of the EDGs. As the corrective actions taken in response to VIO 50-369.370/98-0707 already address vendor oversight improvements, the cracked VSls are considered to be an additional example of VIO 50-369,370198-07-07: Inadequate Vendor Oversight of EDG Refurbishment.
c. Conclusions
A negative trend on emergency diesel generator subcomponent reliability continued with two recent issues involving VSIs. The time spent to address the VSI condition resulted in additional EDG unavailability time, which the licensee has acknowledged as a continuing adverse trend. These
These degraded sub-components were considered an additional example of a previous violation for inadequate vendor oversight of rebuilding activities performed in 1997.
degraded sub-components were considered an additional example of a previous violation for inadequate vendor oversight of rebuilding activities performed in 1997. Corrective action to video boroscope all exhaust VSIs was prudent; the technical basis for continued operability was adequate; and proposed long-term corrective action to replace the exhaust VSIs to a more robust part was acceptable. 

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