X. Reasonableness Review-
Management of the Original Steam Generators

TURN states that the Commission did not adequately address the issue of whether SCE reasonably managed its original steam generators. TURN represents that it attempted to ascertain whether SCE had taken all reasonable steps to arrest or slow steam generator corrosion. However, it says that SCE refused to supply the necessary documents.

TURN represents that CE recommended removal of copper-bearing components from the NSSS. TURN states that a 1988 report prepared for SCE revealed that a relatively high copper content in the tube sheet sludge can accelerate corrosion of carbon steel components in the steam generators. TURN says that SCE has replaced only 2 of 13 feedwater heaters that were cited in the study as a source of the sludge, and the condenser tube sheets contain a copper alloy. TURN states that SCE was not reasonably aggressive in removing copper bearing components, and that some copper-bearing components remain in the steam generators to the present day.

For the above reasons, TURN recommends that a separate reasonableness review of SCE's management of its original steam generators be required. If the review found that SCE acted unreasonably, TURN recommends that SCE should be subject to a penalty that would be credited against the SGRP costs if the SGRP is approved.

TURN's request for a separate reasonableness review is based primarily on its representation that SCE unreasonably denied its requests for information. This application was filed in February 2004, and hearings were held beginning in late January 2005. Therefore, TURN had plenty of time to pursue this issue. If TURN felt that SCE had unreasonably denied its requests for information, it should have filed a motion to compel production of the documents it requested. Had it done so, the assigned Administrative Law judge (ALJ) could have determined whether SCE acted reasonably in denying TURN's request, and taken appropriate action. However, TURN chose not to file such a motion. Therefore, we do not find TURN's argument that it was denied the information persuasive. We note that, in this proceeding, SCE addressed the steps it has taken to prevent, detect, mitigate, and repair the degradation of the steam generators. We also note that most of the parties believe that the steam generators will operate past 2010 without the SGRP, and that the failure of the steam generators is due primarily to CE. For these reasons, we do not currently see a need for a separate reasonableness review of SCE's management of the original steam generators.