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email from Linda Lewison, Jan 19, 2012

Enclosed is a memo from Dr. Dave Lochbaum, Union of Concerned Scientists, analysing the problems associated with the Palisades nuclear facility breakdowns from a more comprehensive framework.

Using the bathtub effect model puts the many breakdowns over the years in a much broader perspective than anything I heard at the Wednesday hearings on Palisades. This evaluation is of criticaal importance to the full discussion and to your thinking as you go forward. I am enclosing it here so that you and your staff will have it in hand as you make your decision to "go red" or "see red" and go all the way to close the facility down.

Your ending comments really nailed it. The record of such repeated incidents is inexcusable. This pattern has been going on too long and is clearly a result of problems with leadership and mission at the highest levels...

- - - Lochbaum: Memo regarding a problem at Palisades nuclear facility in Michigan

Attached is a licensee event report regarding a problem at Palisades nuclear facility in Michigan.

Seems they replaced pumps parts 4-5 years ago. The original carbon steel parts were replaced with stainless steel parts. Not long after the replacement, one of the pumps failed. They replaced the replacement parts with new versions. The same pump failed again.

Turns out the replacement parts were not suitable for the operating conditions. It took them two failures to figure that out. The failures confirmed ample evidence readily available before the initial replacement that it would not work. Palisades' experiment thus confirmed what everyone else already knew,

It's the classic bath-tub curve in action. The bath-tub curve plots the chance of failure versus time. The right-hand portion of the curve is the wear-out phase where embrittlement, rusting and other aging mechanisms increase the chance of failure. The left-hand portion of the curve is the break-in phase where aterial defects, learning curve, installation errors and other factors increase the chance of failure.

Palisades had pumps heading towards if not already in the wear-out portion of the bath-tub curve. So they replaced the pump parts seeking to avoid the increased risk. But they merely swapped to the other high risk portion of the bath-tub curve and experienced the failures they sought to avoid.

Palisades forgot an important lesson and paid a price for it.

When you swap out an old part for a new part of a different type (e.g., stainless steel instead of the original carbon steel), it's smart to look at the experiences of others who have already made this swap. Had Palisades done so here (or done so BEFORE the two failures instead of AFTER them), they would have easily determined that the swap was a bad idea. Instead, they could have swapped to the material that worked better in that operating condition, thus saving themselves two failures.

- - - end of Lochbaum excerpt

Linda Lewison,
Energy Policy Consultant
Board Member: NUCLEAR ENERGY INFORMATION SERVICE
www.neis.org
773-342-7650

Source: ML120240447