Gmcp Comment

REPUBLIC OF THE PHILIPPINES SUPREME COURT

l\1anila

EN BANC

Bayan Muna Representatives NERI JAVIER COLMENARES and CARLOS ISAGANI ZARATE, Gabriela Women's Party Representatives LUZ ILAGAN and EMMI DE JESUS, Act Teachers Party-List Representative ANTONIO TINIO, and Kabtaan Party-List Representative TERRY RIDON,

Petitioners,

- versus -

ENERGY REGULATORY COMMISSION, MANILA ELECTRIC COMPANY (MERALCO), PHILIPPINE ELECTRICITY MARKET CORPORATION, SEIVl-CALACA POWER CORP., MASINLOC POWER PARTNERS CORP., THERMA LUZON INC., SAN MIGUEL ENERGY CORP., SOUTH PREMIER POWER CORP., and THERMA MOBILE, INC.,

Respondents, :x------------------------------------------------:x

NATIONAL ASSOCIATION OF ELECTRICITY CONSU1\1ERS FOR REFORMS, represented by Petronilo L. Ilagan, FEDERATION OF VILLAGE ASSOCIATIONS, represented by Siegfriedo A. Veloso, FEDERATION OF LAS P][NAS HOMEOWNERS SSOCIATIONS, represented by Bonifacio Dazo, and RODRIGO C. DOMINGO, JR.,

Petitioners,

- versus -

MANILA ELECTRIC COMPANY,

1

G.R. No. 210245

G.R. No. 210255

ENERGY REGULATORY COMMISSION, DEPARTMENT OF ENERGY, PHILIPPINE ELECTRICITY MARKET CORPORATION, SEMCALACA POWER CORPORATION, MASINLOC POWER PARTNERS CORP., SAN MIGUEL ENERGY CORPORATION, SOUTH PREMIERE POWER CORPORATION, THERMA MOBILE, INCORPORATED, FIRST GAS POWER CORPORATION, QUEZON POWER PHILS. LTD. COMPANY, THERMA LUZON, INCORPORATED, FGP CORPORATION, NATXONAL GRID CORPORATION OF THE PHILIPPINES, 1590 ENERGY CORPORATION, BAC-MAN ENERGY DEVELOPMENT CORPORATION/BAC-MAN GEOTHERMAL, INCORPORATED, AP RENEWABLES, INCORPORATED, FIRST GEN HYDRO POWER CORPORATION, GNPOWER MARIVELES COAL PLANT LTD. CO., PANASIA ENERGY HOLDINGS, POWER SECTOR ASSETS & LIABILITIES MANAGE1\1ENT CORP., SN ABOITIZ-BENGUET, INCORPORATED/ SN ABOITIZ-MAGAT, INCORPORATED, STRATEGIC POWER DEVELOPMENT CORPORATION, TRANS ASIA POWER GENERATION CORPORATION, and VIVANT STA. CLARA NORTHERN RENEWABLES GENERATION CORPORATION,

Respondents, x------------------------------------------------x

COMMENT ON (i) THE ANIENDED PETITION FOR CERTIORARI AND PROHIBITION WITH PRAYER FOR A TEMPORARY

RESTRAINING ORDER AND/OR PRELIMINARY INJUNCTION, (ii) THE AMENDED PETITION FOR CERTIORARI AND/OR

PROHIBITION (CLASS SUIT), and (iii) THE CONSOLIDATED COMMEN'f/OPPOSITION WITH COUNTER-PETITION

2

Third-Party Respondent GNPower Mariveles Coal Plant Ltd. Co.

("GMCP"), by undersigned counsels, and in compliance with this

Honorable Court's Order dated January 10, 2014 ("Order"), most

respectfully states that:

1. Third-Party Respondent GMCP received a copy of this

Honorable Court's Order via facsimile on January 10, 2014 at 5:54 p.m. and

by personal service on January 13, 2014, requiring the impleaded parties

respondents to ( 1) file and serve a COMMENT on the Petitions and

Counter-Petition by personal service not later than January 20, 2014

and (2) ATTEND the initial Preliminary Conference on January 13, 2014 or

FILE, on or before January 15, 2014, the NECESSARY MANIFESTATION

in Court should they desire to waive their right to participate in the

scheduled oral arguments on January 21, 2014.

2. Pursuant to the Order, Third-Party Respondent GMCP attended

the initial Preliminary Conference on January 13, 2014 and submits the

instant Comment on (i) the Amended Petition for Certiorari and Prohibition

with Prayer for a Temporary Restraining Order and/or Preliminary

Injunction, (ii) the Amended Petition for Certiorari and/or Prohibition (Class

Suit), and (iii) the Consolidated Comment/Opposition with Counter-Petition

to this Honorable Court.

3. Third-Party Respondent GMCP is a duly registered limited

partnership organized and existing under and by virtue of the laws of the

Republic of the Philippines, with principal office address at 1905 Orient

Square Building, Don Francisco Ortigas, Jr. Road, Ortigas Center, Pasig

City, and engaged in the business of developing, financing, constructing,

operating and owning a 2x300MW (net) clean pulverized coal-fired power

plant and private port facility in Mariveles, Bataan ("GMCP Facility") and

generation, sale and trade of electric power, importing machines, equipment,

3

motor vehicles, tools, appurtenant spare parts, coal for fuel, lubricants,

cleansing substances and other necessary and related materials or chemicals

and any and all transactions necessary for or consistent with the foregoing

purposes.

4. Respondent Energy Regulatory Commission ("ERC") issued

the Certificate of Compliance with COC No. 12-12GN 282-19811L to

Third-Party Respondent GMCP on December 3, 2012. Further, Third-Party

Respondent Philippine Electricity Market Corporation ("PEMC") has

approved Third-Party Respondent GMCP's application for registration as

Direct WESM Member and Trading Participant (Generation Category) on

August 7, 2012 with respect to the GMCP Facility Unit 1 and December 6,

2012 with respect to the GMCP Facility Unit 2.

5. As pointed out by Respondent Manila Electric Company

("MERALCO") in its Consolidated Comment/Opposition with Counter

Petition, the GMCP Facility is the only major committed base load power

project in Luzon after the enactment of Republic Act No. 9136 otherwise

known as the Electric Power Industry Reform Act of 2001 ("EPIRA Law").

6. In line with the rationale for enacting the EPIRA Law, the

Third-Party Respondent G11CP, with the aim to help alleviate the looming

power shortage in the country and provide a competitively priced power, has

embarked on the construction and operation of the GMCP Facility in

response to the challenge of ave1iing power shortfalls that could hit the

Luzon and Visayas grids and can therefore effectively support the additional

capacity needed by the electricity consumers in Luzon and Visayas regions.

7. At this point, it is important to note that the Third-Party

Respondent GMCP does not have an existing power supply agreement

("PSA") with Respondent MERALCO as the GMCP Facility has fully

contracted its capacity when it entered into various PSAs with distribution

utilities in Luzon and Visayas, a government-owned and controlled

4

corporation administering a freeport area and a number of contestable

customers.

8. Since the GMCP Facility is a newly constructed power plant,

fine tuning of some machines and equipment is vital to make it more reliable

in the long run. Consequently, the performance of adjustments and

corrections necessitates the occurrence of scheduled and unscheduled

outages. A summary of the scheduled and unscheduled outages of GMCP

Unit 2 during the November billing period (from October 26, 2013 to

November 25, 2013) and the December billing period (from November 26,

2013 to December 25, 2013) and the reasons therefor is attached hereto as

Annex A.

9. It bears emphasis that the Third-Party Respondent National

Grid Corporation of the Philippines ("NGCP") approved the Third-Party

Respondent GMCP's requested scheduled outage of GMCP Unit 2. A copy

of the Third-Party Respondent GMCP's request letter to the Third-Party

Respondent NGCP dated September 24, 2013 is attached hereto as Annex B

and a copy of the Third-Party Respondent NGCP's reply letter dated

September 25, 2013 is attached hereto as Anlllex C.

10. As this Honorable Court may note in the attached summary, the

Third-Party Respondent GMCP was constrained to extend the scheduled

outage of GMCP Unit 2 until November 21, 2013 in order to perform the

much needed vibration test, steam turbine dynamic balancing and overspeed

test. In this connection, the Third-Party Respondent GMCP promptly

informed and coordinated with the Third-Party Respondent NGCP as

regards such extended scheduled outage.

11. With respect to the unscheduled outage of GMCP Unit 2, the

Third-Party Respondent G~/_[CP submitted a detailed report to Respondent

Department of Energy last January 9, 2014, a copy of which is attached

hereto as Annex D.

5

12. Further, the Third-Party Respondent GMCP, despite the

temporary shutdown of GMCP Unit 2, exerted its best efforts to generate as

much power as it can within the limits of the GMCP Facility.

13. Pursuant to the PSAs entered into by the Third-Party

Respondent GMCP and its customers, (i) the Third-Party Respondent

GMCP, on behalf of its customers, manages and administers the portion of

the customer's allocated contracted capacity based on the actual available

capacity of the Third-Party Respondent GMCP that was not nominated by

the customer ("Unutilized Contracted Capacity of the Buyer" or

"UCCB") and, accordingly, offers the UCCB for sale at the WESM

("WESM Sale"); and (ii) all nroceeds from tllie WESM Sale (net of the

administrative charge for the (!erformance of the UCCB services and

the applicable incremental cost for generation) shall be directly remitted

by the Third-Party Respondent GMCP back to its customers.

14. It should be noted that the net UCCB proceeds are given to the

customers of the Third-Party Respondent GMCP in addition to the prompt

payment discount. Consequently_,_ the remittance of the net UCCB

proceeds to the distribution utility customers of the Third-Party

Respondent GMCP is an additional i11J1.centive for them to effectively

reduce the generation charge, which is 1mssed on to their respective

electricity consumers.

15. Since the net UCCB proceeds are remitted to the

distribution utility customers and therefore not retained by the Third

Party Respondent GMCP, it was the distribution utility customers of

the Third-Party Respondent GMCP, and ultimately the electricity

consumers, who enjoyed the net revenues from the WESM Sales during

both the November and December billi1t11_g_11eriods and definitely not the

Third-Party Respondent GMCP.

6

16. Moreover, it must be emphasized that during the November

and December billing periods,_ the Thiird-P:arty Respondent GMCP's

bid price at the dispatch level ranges from zeiro (0) to Two and 439/1000

Pesos (PhP2.439) per kWh only. Hence, the Third-Party Respondent

GMCP has been consistently maintaining its bid strategy from the onset.

1 7. In light of the foregoing facts, it cannot be gainsaid that the

Third-Party Respondent GMCP neither colluded with the other key players

in the power industry nor incurred windfall profits from the incident that is

subject of the instant Petitions. Verily, the Third-Party Respondent GMCP

has consistently acted in good faith and dealt fairly with its customers.

18. Finally, the Amended Petition for Certiorari and/or Prohibition

docketed as G.R. No. 210245 is procedurally infirm considering that the

issue of whether there was collusion among the key players in the energy

industry is factual in nature. Time and again, this Honorable Court has ruled

that the Supreme Court is not a trier of facts and consequently, the resolution

of the said factual issue is not a function of this Honorable Court. Therefore,

the preceding Amended Petition should be dismissed.

PRAYER

WHEREFORE, foregoing premises considered, the Third-Party

Respondent GMCP respectfully prays that this Honorable Court renders a

Decision declaring that the inclusion of GMCP as a third-party respondent is

without basis both in fact and in law and therefore dismissing the Amended

Petitions and Counter-Petition for utter lack of merit.

Other reliefs, just and equitable under the circumstances, are likewise

prayed for.

Respectfully submitted.

Pasig City for Manila, January 20, 2014.

7

LOURDY D. TORRES and FRANCHESCA T. OVALLES Counsels for Respondent GNPower Mariveles Coal Plant Ltd. Co.

1905 The Orient Square Building Don Francis · as, Jr. Road,

·gas enter, Pa · g City

LOURDY D. TO ES IBP OR No. 914394/ 16 January 2013/ Quezon City

PTR OR NO. 7701944/ 16 January 2013/ Quezon City ROLL NO. 13525

MCLE Compliance No. IV-0013311/ 11March2013

FRAN ESCA T. ES IBP OR No. l4 27/ 02 January 2014/ Quezon City PTR OR No. 845717/ 10 January 2014/ Pasig City

ROLL NO. 57346 MCLE Compliance No. IV-0015945/ 10 April 2013

Copy Furnished:

ATTY. RENE A.V. SAGUISAG Counsel for Petitioners NASECORE, et al. 4045 Bigasan Street Brgy. Palanan, Makati City

ATTY. MARIA CRISTINA P. YAMBOT Counsel for Petitioners Bayan Muna, et al. No. 45 K-7th Street, Brgy. West Kamias, Quezon City

ATTY. NELSON A. LOYOLA Co-counsel for Petitioners NASECORE, et al. Suite 201 Carreon Building, 2746 Zenaida Street, Brgy. Poblacion, Makati City

ATTY. RONNIE B. RODILLAS Co-counsel for Petitioners NASECORE, et al. No. 137 Libis Gochuico Street, Circumferential Road 3, Caloocan City 1400

THERMAL MOBILE INCORPORATED Ground Floor, Philippine Fisheries Devt. Authority Complex Building Navotas, Metro Manila

THE SOLICITOR GENERAL 134 Amorsolo Street, Legaspi Villlage Makati City 1229

ENERGY REGULATORY COMMISSION Pacific Centre Building San Miguel A venue, Pasig City

DEPARTMENT OF ENERGY c/o Secretary Carlos Jericho L. Petilla Energy Center, Rizal Drive, Bonifacio Global City, Taguig 1632

MANILA ELECTRIC COMPANY Lopez Building, Ortigas A venue Pasig City

PHILIPPINE ELECTRICITY MARKET CORPORATION 9th and 18th Floors, Robinsons Equitable Tower, ADB Avenue, Ortigas Center, Pasig City 1600

FIRST GAS POWER CORPORATION 3/F Benpres Building, Exchange Road cor. Meralco A venue, Ortigas Center, Pasig City

SOUTH PREMIERE POWER CORPORATION 808 Building, Meralco Avenue cor. Gen. Lim Street, San Antonio Village, Pasig City

SAN MIGUEL ENERGY CORPORATION 808 Building, Meralco A venue cor. Gen. Lim Street, San Antonio Village, Pasig City

MASINLOC POWER PARTNERS CO. LTD. 18/F Bench Tower, 30th Street comer Rizal Drive Bonifacio Global City, Taguig City

9

QUEZON POWER (PHILS.) LTD. CO. 62 H. dela Costa, Mauban, Quezon Province c/o Quezon Management Service Inc. Philippine Branch Office 14th Floor Zuellig Building Makati A venue corner Paseo de Roxas 1226 Makati City

THERMA LUZON, INC. NAC Tower, 32nd Street, Bonifacio Global City, Taguig

SEM-CALACA POWER CORPORATION 2/F DMCI Plaza Building 2281 Don Chino Roces Extension Brgy. Magallanes, Makati City

FGP CORPORATION 3/F Benpres Building Exchange Road cor. Meralco Avenue, Ortigas Center, Pasig City

NATIONAL GRID CORPORATION OF THE PHILIPPINES Quezon A venue comer BIR Road, Diliman, Quezon City 1100

1590 ENERGY CORPORATION Unit 107 First Midland Office Condominium Building, Gamboa Street, Legaspi Village, Makati

AP RENEW ABLES, INC. 15/F NAC Tower, 32nd Street, Bonifacio Global City, Taguig City

BAC-MAN ENERGY DEVELOPMENT CORPORATION/ BAC-MAN GEOTHERMAL, INC. 3 8/F One Corporate Centre, Julia Vargas comer Meralco Avenue, Ortigas Center, Pasig City 1605

FIRST GEN HYRDO POWER CORPORATION 3/F Benpres Building, Exchange Road cor. Meralco Avenue, Ortigas Center, Pasig City

PANASIA ENERGY HOLDINGS, INC. 2nd floor, 808 Building,

10

Meralco A venue, Pasig City 1600

POWER SECTOR ASSETS & LIABILITIES MANAGEMENT CORPORATION 7th Floor Bankmer Building, 6756 Ayala Avenue, Makati City

SN ABOITIZ POWER - BENGUET, INC. SN ABOITIZ POWER - lVIAGAT, INC. 1 O/F NAC Tower, 32nd Street, Bonifacio Global City, Taguig City

STRATEGIC POWER DEVELOPMENT CORPORATION 2nd Floor, 808 Building, Meralco Avenue cor. General Lim Street San Antonio Village, Pasig City 1600

TRANS-ASIA POWER GENERATION CORPORATION 11th Floor PHINMA Plaza 39 Plaza Drive, Rockwell Center, Makati City 1200

VIV ANT STA. CLARA NORTHERN RENEW ABLES GENERATION CORPORATION Unit 107, 1st Midland Office Condominium Bldg., Gamboa Street, Legaspi Village, Makati City

11

ANNEX A

GMCP UNIT 2 OUTAGE SCHEDULE

------Start of End of Preliminary Reason Outage Outage

SCHEDULED OUTAGE -Cooling down of turbine Bearing Inspection/Modification

September 26, November 11, IP/LP Coupling Alignment LP Generator Coupling Alignment

2013 (2343H) 2013 (1650H) Thrust Bearing Inspection/Repair Post outage testing Dynamic Balancing

EXTENDED SCHEDULED OUTAGE Outage was extended to perform Vibration

November 12, November 21, test, Steam turbine dynamic balancing, 2013 (llllH) 2013 (1005H) and Overspeecl test.

(Includes turbine cool down of 5 days) UNSCHEDULED OUTAGE

November 27, December 8, 2013 (155 lH) 2013 (1345H) Due to boiler tube leak December 11, December 1 7, Turbine lube oil fittings leakage. Auto-trip 2013 (2153H) 2013 (1913H) due to low oil pressure

12

ANNtX IS

GNPower Mariveles Coal Plant Ltd. Co. September 24, 2013

Mr. Raul Joseph G. Seludo Head, Luzon System Operations National Grid Corporation of the Philippines Quezon A venue corner BIR Road Diliman, Quezon City

Subject: Request for Revision of Shutdown Schedule of lMARVEL _ G02

Dear Mr. Seludo:

We refer to GNPower Marivelcs Coal Plant Ltd. Co. ("GMCP") letter dated as of August 28, 2013 in relation to GMCP request for IMARVEL_GOl and Jrv1ARVEL_G02 shutdown as confimwd by the National Gr'.d Corporation of the Philippines ("NGCP"') in its letter dated as of August 30, 2013.

We would like to express our appreciation for accommodating GMCP"s request. Due to the required preparation of materials for the additional adjustments and corrections of IMARVEL_G02 and mobilization of manpower, however. we would like hi request for the revision of the shutdown schedule of 1 MARVEL G02 as set forth below:

Original Shutdown ---·r !

Schedule September 22. 2013 -

October 2 J, 2013

Revised Shutdown Schedule

September 26, 2013 -

November 9, 20 ! 3

Unit

lMARVEL G02

The new shutdown schedule shall also include the required testing after the vvorks have been completed.

Rest assured that GMCP will work doubly hard to expedite the maintenance for 1 MARVEL_ G02 in order for the unit to be on line the soonest possible lime. We shall keep you informed of the developments during the requested shutdown schedule.

We look forward to your favorable response regarding our request.

___?~_cere~~ ~ irs, c__ ' ... r;,._ .···~

A .. ur. Bila ~1,., · ,Nie~ President ~!.~·

// Sales and Trading ,.,/

20130924.STRGroup_NGCP_0000018

Unit 1905, The Orient Square, Don Francisco Ortigas Jr. Road. Ortiga.s Centm. Pasig City 1f005, Philippines· Tel: (632) 638-4542 •Fax: (632) 638-4575

NGCP Stronger transmission for a stronger nation

25 September 2013

MR. ARNEL 0. BILAOEN Vice President Sales and Trading GNPower Mariveles Coal Plant ltd. Co. Unit 1905, The Orient Square Don Francisco Ortigas Jr. Road, Ortigas Center, Pasig City

Subject: REQUEST FOR REVISION OF SHUTDOWN OF 1MARVEL_G02

Dear Mr. Bilaoen:

MNEXC

This is to confirm the request of GMCP dated September 24, 2013 regarding the revised scheduled shutdown of 1 MARVEL_G02 as shown below:

Original Shutdown Revised Shutdown Unit Schedule Schedule

September 22, 2013 - September 26, 2013 -1 MARVEL_G02

October 21, 2013 November 9, 2013 '

Kindly ensure 1 MARVEL_G02 to be fully declared available during the Malampaya turnaround activities on November 9 - December 8, 2013.

Please note that the outage shall be classified as unplanned (non-GOMP).

s41y.'r-) ~~~

Head, Luzon System Operations

Cc: ASSISTANT CHIEF TECHNICAL OFFICER- System Operations MR. SANnAGO A. DIMALIWA T IV- Deputy Assistant Chief Technical Officer. SO MS. MA. CYNTHIA Y. MANRJQUE - Head, Revenue and Regulatory Affairs MR. ENRICO A. VIRAY - Head, Networl< Protection Division MR. AMBROCIO R. ROSALES - Head, Network Operations Division FILE

Quezon Avenue corner BIR Road, DUiman, Quezon City 1100 • Tel. No.· +632.981.2100 • Website: www.ngcp.ph

"

ANtJEX D GNPower Mariveles Coal Plant Ltd. Co.

January 9, 2014

Hon. Carlos Jericho L. Petilla Secretary Ll\..!1<U LJH\..1H Vl J.JHl;..J cJ Energy Center, Merritt Road Fort Bonifacio, Taguig

Subject: GMCP's Unit 2 (300MW) Forced Outage

Dear Secretary Petilla,

We refer to your letter dated December 18, 2013 requesting for an incident report regarding GMCP's Unit 2 (300MW) Outage from November 27, 2013 to December 8, 2013. We hereby submit to your office a comprehensive Outage Report prepared by our Operations and Maintenance Department dated December 13, 2013.

Kest assureo mar our uperanons ana Mamtenance group w111 exert theIT best ettort to maintain the plant's reliability and to avoid such incidents as possible.

Sincerely yours, . " GNPower Mariveles Coal Plant Ltd. Co.

By:'-.,,,---..~-"'-"~.L...-0.~~~~ Nam n A. Becker Tit . President and COO

Unit 1905. The Orient Square, Don Francisco Ortigas Jr. Road, Ortigas Centre, Pasig City 1605, Philippines ·Tel: (632) 638-4542 •Fax: (632) 638-4575

Boiler Tube Inspection, Findings, Recommendations & Daily Progress Reporting

Date Prepared: December 13, 2013 Maintenance Department

GNPower Mariveles Coal Plant Ltd. Co. : Barangay Alas-asin : Mariveles, Bataan 2105 Philippines

Unit 2 Forced Outage

Contents

Contents ......................................................................... 1

Executive Summary: ....................................................... 2

Failure Analysis Findings: ................................................ 3

Background: .................................................................... 3

Summary of Major Findings and Observations, Recommendations and Status: 4

Summary of Finishing SH Inspection Findings and Observations, Recommendation and

Illustration with Photo .................................................... 6

Summary of Lower Wall Inspection Findings and Observations, Recommendation and

Illustration with Photo .................................................. 10

Status of Welding and Radiogprahic Testing ................ 13

December 13, 2013


Executive Summary: Unit 2 was shut down on November 28, 2013 to facilitate inspection of damaged tubes on

reheater and superheater section. Gentech (boiler tube repair contractor) conducted initial

inspection and confirmed the location of failed tubes in Finishing SH tubes and Lower Wall

tubes. Assistco (scaffolding contractor) mobilized immediately after Unit 2 boiler cool down

to erect scaffolds for Finishing SH and Lower Wall to allow further inspection and provide

access for repair.

While waiting access for inspection, Reliability Section conducted Positive Material

Identification (PMI) of spare Finishing SH tubes and Lower Wall tubes. Two (2) lengths of

straight oioe SA-213 T23 llow allov material\ for Finishin2 SH and three 131 lenl!ths of SA-210 Al (carbon steel) was found at warehouse and confirmed with correct material specification

through PMI testing. Thirty eight (38) out of forty (40) u-bends of SA-213 T23 were rejected

due to wrong material specification confirmed through PMI testing. This lead to sourcing out

of local company capable of bending tubes which caused approximately 2 to 3 days

extension in the schedule due to availability of contractor during the weekend and holiday

and bending activities.

Upon completion of scaffold erection, extensive Ultrasonic Testing Thickness Gauging {UTTO) Wd!> 1..Ufll.JUC..lt:LI IJy f\t:lldlJlllly ::Jt:C..llUI I Ull LUIJt: H::J LU H10 ur Luwt:t Wdll lulJt:::> 0111..1 lUUt:

#40 to #44 of Finishing SH tubes to determine the extent of damage. Six (6) lower wall tubes

and nine (9) finishing SH tubes were recommended for sectional replacement (inclusive of 3

holed thru lower tubes and 3 holed thru finishing SH tubes) based on visual inspection and

tube thickness results. Random UTTG and visual inspection was also conducted on other

accessible areas of superheater tubes and reheater tubes to check for damage.

Mechanical Section worked together with Maintenance Engineering Center (tube bending

contractor) and Gentech for tube bending of Finishing SH. While waiting for the arrival of

bent tubes, Gentech personnel underwent welder qualification to ensure that they are

qualified to conduct the repair on carbon steel and low alloy tubes. 6 out of 10 welders

passed on SA-213 T22 (low alloy material) while 7 out of 10 welders passed on SA-210Al 1caroon stee1 matena11.

The 6 damaged tubes were cut and were sent to Singapore for laboratory examination and

failure analysis. Gentech performed the repair and welding of a total of 30 joints was

completed on November 6. WTL (NOT contractor) conducted 100% Radiographic Testing

(RT) of all joints and all have successfully passed based on evaluation using ASME Section I.

To further ensure the quality of butt joint welds and membrane fillet welds, Reliability

Section conducted Penetrant Testing (PT) of all welds as final acceptance prior to removal of

o:r::iffnlci.

All mechanical works were completed on December 7 where Unit 2 Boiler start-up

commenced. The unit was successfully synchronized to grid at 134SH of December 8.

December 13, 2013

Unit 2 forced Outage

Failure Analysis Findings: The 6 damaged tubes (3 Finishing SH and 3 Lower Wall) was sent to Matcor Technology and

Services Pte. Ltd., located at Singapore for them to carry out the failure analysis which

covers laboratory examination such as macroscopic, fractography, metallographic, hardness,

energy dispersive x-ray in order to determine the cause of failure. They conducted initial

visual inspection of 6 tubes and identified 3 tubes for laboratory examination. Refer to

MATCOR's initial report for the root cause of boiler tube failure.

Background: f"\n Nnuomhor ')R f\nor::atinnc: to::am r.onnrtp.rf th::.t thoro \Al:aC c.ionifir~nt Ince: in rl,;:.min,::.r::ali7Prf

water turning into higher make up water being supplied to the system. Operations staff

heard hissing sound near Finishing RH tubes section of boiler which was suspected as the

source of leak. It was decided to shutdown Unit 2 and on November 29, personnel from

Gentech conducted initial assessment upon opening of manway near finishing RH tubes.

There were three ruptured tubes observed on Finishing SH tubes, three holed thru tube on

Lower Wall. Several adjacent tubes were also affected by the leak and appeared slightly

deformed with localized thinning observed due to exposure on leaking water/steam. The

areas affected are shown below in elevation view of Reheater and Superheater section of the boiler.

'-'1"" ~;----~

i , __ _s:!!"

- ""' H-·~

December 13, 2013


Mechanical section together with Assistco and Gentech is working on scaffolding access, cp:>ro tuboc for bonding ::and coction:>I r<>f'l:>ir nf tho t11h1>c

Reliability section is conducting inspection on all accessible areas of Reheater and

Superheater and ensuring that the material to be installed are of sufficient thickness and

with correct material specification.

Summary of Major Findings and Observations, Recommendations and

Status: Finishing SH; 51 mm diameter x 7 .2 mm thickness; SA-213 T23

• Tubes were numbered from West to East for Finishing SH. The U-bends in parallel with

Date of Inspection 11-29-30

12-1-13

. .\,~'·~~dif!IS and.Ob.se~on~> •·. ,,:,··. --··, '. ' . '

3 Finishing SH tubes were identified with Replace affected Finishing rupture and were marked in field as 41A, SH tubes by sectioning. 42A and 43A. 5 Finishing SH tubes with external wall loss (by visual) and thinning confirmed through ultrasonic testing thickness gauging. Its highly likely this is caused by steam impingement from water leaking out of ruptured water wall tubes. 1 set of tube spacer (SA-167 TP304) for 42A, 426, 42C and 420 was damaged 1 tube erosion shield (SA-167 TP304) for tube# 42A was damaged.

1 Finishing SH tube with external wall loss (by visual) and thinning confirmed through

Replace affected Finishing SH tubes by sectioning.

Reweld tube spacer and install at Finishing SH tubes Reweld erosion shield and install at Finishing SH tubes

Replace affected Finishing SH tubes by sectioning.

Completed

Completed

Completed

Completed

Completed

December 13, 2013


ultrasonic testing thickness gauging. Its n1gn1y llKely tnlS IS causea oy steam impingement from water leaking out of ruptured water wall tubes. Marked in field as 408.

Note: Refer to Appendix Table I for the illustration, location and photo of damaged tube

Lower Wall; 51 mm diameter x 7.2 mm thickness; SA-213 T23

• Tubes were numbered from North to South for Lower Wall tubes.

Dated Inspection 11-29-30

11-30-30

·· ····:findJng~ ~nd Observations.

3 Lower Wall tubes (west side of header) were identified with rupture/holed thru and were marked in field as 6, 7 and 8. 2 Lower Wall tubes (west side of header) were heavily thinned down marked in field as 9and10. 1 Lower Wall tubes (east side of header) was found with old weld repair due to damaged tube. The weld repair is not acceptable because it was only done by weld build up. Morl<ed in field oi: ::!7.

. :.':.'".,' ,. .:·',·~·P'.-~"'··: . .-t·

,~~~ii~;: .. Replace affected Lower Wall tubes by sectioning

Replace affected Lower Wall tubes by sectioning

Replace affected Lower Wall tubes by sectioning

Completed

Completed

Completed

Note: Refer to Appendix Table II for the illustration, location and photo of damaged tube

Miscellaneous Parts

Date()( I ection

12-2-30

· · 'Ftnd~~ a~ ob5ervations The insulation installed on external of sloping wall (beneath Reheater section) was found slightly dislodged. Approximately 3 to 5 tubes of low Restore to correct position. Completed

temperature superheater (vertical) have erosion shields deformed or dislocated.

December 13, 2013

Unit 2 Forced Outage --. Summary of Finishing SH Inspection Findings and Observations, Recommendation and Illustration with Photo

Tube DeScriptkm: Flrilshlri& Sli Nlater~I Specffk:atiOn: SA-213 T2i

Dla~r trrith) t11'11ckness tmm): su 1~2 Ultrasonic Ultrasonic

Tube I Testing Testing

I Findings and

I I Illustration (Green line

Number location I Thickness Thickness

Observation Recommendation

for Tube Replacement) I Photo Showing Damaged Area Gauging Result, Gauging Result, mm (Minimum) mm (Maximum)

40A I Outermost 6.52 7.80 No damage Thickness gauging in I Not Applicable I Not Applicable U-bend observed next shutdown

408 I 2nd U- 5.2 7.94 Localized thinning Replace bottom of U-bend bend approximately 20

cm long

40C I 3rd U-bend I 6.57 I 7.85 I Nodamage Thickness gauging in observed next shutdown

41A I Outermost I HoledThru I 7.86 1-0ne location with Replace half U-bend U-bend tube rupture approximately 82 cm

observed near the long bend

December13,2013

418

41C

410

42A

428

I 2nd U-bend

I 3rd U-bend I

I Innermost U-bend

I Outermost U-bend

2nd Ubend

S.48

6.35 I

6.09

Holed Thru

4.78


7.80 -With signs of exposure to steam. Area exposed with with external wall loss (by visual) and thinning confirmed through ultrasonic

testing thickness gauging.

7:77 ____ 1 No damage

7.86

7.77

7.79

observed

No damage observed

-One location with tube rupture observed near the bend

-With signs of exposure to steam. Area exposed with external wall loss {by visual) and thinning confirmed through ultrasonic testing thickness gauging.

Replace half U-bend approximately 70 cm

long

Thickness gauging in next shutdown

Thickness gauging in next shutdown


long


long

-

Not Applicable I Not Applicable

Not Applicable

December 13, 2013


42C I 3rd u-bend 3.90 7.37 -With signs of Replace whole U-bend exposure to steam. approximately 160 cm Area exposed with long external wall loss (by visual} and thinning confirmed through ultrasonic testing thickness gauging.

420 ) innermost I 2.33 I 7.50 I -With signs of Replace whole U-bend U-bend exposure to steam. approximately 145 cm

Area exposed with long external wall loss (by visual} and thinning confirmed through ultrasonic testing thickness gauging.

43A I Outermost I HoledThru I 7.84 1-0ne location with Replace half U-bend U-bend tube rupture approximately 68 cm

observed near the long bend

438 I 2nd U- I 4.23 I 7.84 I -With signs of Replace bottom of U-bend exposure to steam. bend approximately 20

Area exposed with cm long external wall loss (by visual) and thinning confirmed through ultrasonic testing thickness gauging.

43C I 3rd U-bend I 6.51 I 7.72 I No damage I Thickness gauging in

I Not Applicable

I Not Applicable

observed next shutdown

December 13, 2013


430 Innermost 6.86 8.02 No damage Thickness gauging in Not Applicable Not Applicable U-bend observed next shutdown

--- --- -------~~- ------------ -------------- ------------------- -----------------------44A Outermost 7.18 7.83 No damage Thickness gauging in Not Applicable Not Applicable

U-bend observed next shutdown

448 2nd U- 7.17 7.80 No damage Thickness gauging in Not Applicable Not Applicable bend observed next shutdown

Table I: Summary of Finishing SH Inspection Finding~ and Observations, Recommendation and Illustration with Photo

December 13, 2013


Summary of lower Wall Inspection Findings and Observations, Recommendation and Illustration with Photo

Tube Demfptlotl: LOVler Wall

Material spedflcatlon: SA-210 A1 · Diameter (mm) Jttlllcltn~ (mm): sh s.9 ·.

Tube Number

s

6

Location

West of Header

(Counting from Nto S)

West of Header

(Counting from N to S)

Ultrasonic Testing

Thickness Gauging

Result, mm (Minimum)

6.44

HoledThru

Ultrasonic Testing

Thickness Gauging

Result, mm

(M~~m~'!IL 6.71

6.73

Findings and Observation

No damage observed

Holed Thru and thinned

down

Recommendation

---Thickness

gauging in next shutdown

Replace straight pipe

approximately SO cm

Illustration (Green Line for Tube Replacement)

Not Applicable

North~ South \...) Elevation -.._

View South

North Top View

Photo Showing Damaged Area

Not Applicable

December 13, 2013

7

8

9

West of Header


West of Header


West of Header

(Counting from N toS)

HoledThru

Holed Thru

3.08

6.90

6.67

7.80

With tube rupture

Holed Thru and thinned down

Localized thinning



approximately SO cm


approximately SO cm

Replace straight pipe with one

bend approximately

SO cm

North~...____ V Elevation South

View South

North Top View

North~ South V Elevation --..... View

South

North Top View

North~ South V Elevation ~ View

South

North Top View

11 ' •

''~'~#;~~,:,• ... ' -

December 13, 2013

10

27

West of Header


East of Header


2.56

6.22

6.87

6.46

localized thinning

Tube with weld build up (old repair which is not acceptable)


Replace straight pipe with one

bend approximately

SO cm


approximately 20cm

North~ South U Elevation ---.......

View

South

North Top View

~North South ~ Elevation U

View South

#27 -----+---1

Tap Vi-ew North

Table 11: Summary of lower Wall Inspection Findings and Observations, Recommendation and Illustration with Photo

--.

December 13, 2013

Unit 2 Forced Outage -· Status of Welding and Radiogprahic Testing

Tube Location Boller Settlon · · Status of Wetdlnt Status of Radiographk

Number T@Stlng 40B 2nd U-bend Finishing SH COMP COMP

41A Outermost U-bend Finishing SH COMP COMP

418 2nd U-bend Finishing SH COMP COMP


42B 2nd U-bend Finishing SH COMP COMP

42C 3rd U-bend Finishing SH COMP COMP

420 Innermost U-bend Finishing SH COMP COMP


43B 2nd U-bend Finishing SH COMP COMP

6 West of Header lower Wall COMP COMP





27 East of Header Lower Wall COMP COMP

COMP - Completed; NS - Not Started; IP - In Progress

Table Ill: Status of Welding and Radiographic Testing

December 13, 2013

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