Thursday, September 03, 2015

My Pilgrim 2013 Petition Board SRV 2.206 Recording: I Clearly State A Cover-up Was On Going

I apologize for my stuttering and stammering here:
Voice recording of Pilgrim contentious petition board address
Most smart people go into these things with a canned speech...I like just like winging it on my own. I am a little bit better organized today. I going heavy into these things today with written down talking points today.

My talking point were on my old computer...The screen froze up right in the middle of it.

As you see the NRC changed the routine for this presentation...I couldn't figure why they were doing this. Do you think it was a cover-up?

I knew I was in the middle of a cover-up, the NRC was doing it right in the open...I was unnerved by it all.

Maybe you can choke my down 2013 NRC transcript better than my voice. If anything, it is a record of the times, the NRC and me.

My 2013 Pilgrim plant SRV 2.206 Petition Board Presentation Transcripts: 

1)
4/11/2013

2)
6/11/2013

Remember basically in the early Feb 2015 blizzard NRC special inspection the NRC discovered that Pilgrim cover-up in 2013...withheld information from the NRC.... that the A SRV failed to open when called upon during 2013 Juno event. Entergy needs to be severely punished for this cover-up and withholding information from the NRC
.
2013: The final attribute in Appendix M is to consider any additional qualitative circumstances associated with the finding. Accordingly, the NRC considered Pilgrim’s organizational performance during the 2013 and 2015 events, as documented in NRC Inspection Report Number 05000293/2015007. Specifically, during the 2013 event, Pilgrim staff did not identify that the ‘A’ SRV had failed to open in spite of having sufficient information available to do so.
So during and after the my March and June 2013 Petition Board presentation Entergy and NRC were involved in a cover-up with the degradation the SRVs.
 
Excepts in my 4/11/2013 presentation to the NRC:
   
Post the discovery in 2015 special inspection with the cover-up on hiding the failure of the A SRV valve, this statement was a yet discovered fact.
"Mr. Mulligan alleges that NRC allowing the plant to operate with unsafe SRVs until the next refueling outage and is covering up an unsafe condition at Pilgrim." 
This goes to show how worthless the OIG is. Nobody every gets to see any documentation the OIG looked into this and their determination is. This distributive OIG secrecy is a protection tool. Nobody can ever challenge us because we never document concerns and determinations. Probably the OIG office is overwhelmed and they can go over concern superficially. Anyways, the OIG is solely the tool of the pro nuclear Republicans congressmen.   
"Mr. Mulligan requests an investigation by the Office of the Inspector General for this concern."
I believe I made the below statement in a 2009 Petition at Palisades. Then over a host mind boggling plant problems including severely putting their plant a risk and threatening the safety of an employee over working improperly in a Emergency DC distribution panel Palisades got into a NRC Yellow finding. I predicted it all in writing in 2009. I always speak with a eye how my words will look in the future. I was trying to warn the NRC Pilgrim is turning into a Palisades.   
"Don't you wish you had a button on your computer where it would give you a yellow, red, or green light? How are you doing now? How will the whole of Entergy do in a year, two years, or five years? Where will the NRC be stationed in the next decade? Is it going to boggle the mind, what the NRC discovers the next year or two at Palisades just like the last two years? I say they are going to find bigger and more repetitive problems, not that this will present our nation's long-term interest making..."rudely interrupted by Chairman Gitter.
I think Mr Giitter was intentionally and maliciously trying to disrupt my massage. Doesn't my words here in 2013 ring so true today with Pilgrim. Just like my words in 2009 Palisades.  
"CHAIRMAN GIITTER: Mr. Mulligan, I'm sorry to cut you off, but I'd really like to stick to the issues at hand. And since we're talking about Pilgrim, I'm not sure what the relevance of Palisades is at this point."
I was desperately trying to head off the future problems at Pilgrim. I was using everything I got.   
"Well, the relevance of Palisades is that it shows a pattern of problems at Palisades, at Arkansas, at Vermont Yankee, at Pilgrim, and stuff like that. And it lends to a pattern that Entergy is a rogue company and they're out of control. And the NRC can't control them"
Was I talking about events in the middle of 2013 or events around Pilgrim in Sept 2015. 

Have unimaginable dysfunction been recently going on in Pilgrim. Do you think the NRC can control Pilgrim tomorrow?   
"History teaches us unimaginable things are going to go on behind the security fence of Palisades. And the NRC misses the really important stuff, better than the NRC doesn't have the power to make Entergy meet the greater aims of us all. 
And so, you know, I was trying to get the NRC to -- you know, to engage with Entergy and behavior. You know, the problems seems to jump into one plant, then jump into another, then jump into another. They must send a lot of personnel or expertise over the troubled plant and then another plant gets ignored and that type of thing, which I'm worried about. And so here, you know -- you know, I'm trying to lay that out. Give me a second here. 
And so I just want everybody to understand this, the system behind this. It's not just a broken relief valve. It's a broken set of regulators that creates this situation. And, instead  of seeing it in a rules-based type of situation that's primitive at best, it's better to think of this as holistically. You know, how does the political system control doing  the  NEISO, create stable grid? And how does the NRC control? How does the NRC control the reliability of the Pilgrim station?"
Right, they needed a  major SRV and switchyard special inspection in 2013. 
 "And Entergy basically promises that ice was falling off the main transformer and another resister or something like that. You know, the lines weren't qualified for the grid or qualified for the weather and stuff like that. And they promised to look into that thoroughly. And then the same thing (2013) happens during a plant trip with the SRVs and stuff like that.
And then we find out that, you know, they really didn't -- you know, the 2,000 LER promises that they were going to make the grid more -- their transmission system -- their switchyard system more reliable. And they were going to look into all of these ice-falling things and causing shorts and stuff like that. And, of course, then we have the loop over on ice that shouldered the thing."
I knew the switchyard was degrading  and other components right before our eye...things were only going to get worst. 
"So that questions, you know. Is the grid reliable enough to support the plant? Why is the Pilgrim plant having all of these plant trips in severe weather? How come? You know, it shouldn't have happened in 2008 if they did what they said they were going to do and repair and inspect the plant and never trip that plant again.
"How come you can't -- it's easy engineering to keep that plant reliable. How come they can't do that? How come they have a repetitive pattern of not keeping that plant in the condition whether the normal weather or maybe a moderate or a minor blizzard -- how come they can't keep that plant reliable?" 
This guys was out to maliciously disrupt me. I knew I was in the middle of a giant cover-up. Remember in this time-frame the nuclear Nuclear renaissance was evaporating right before their eyes. Where the blaming me. 

Do you really think I was done or was he trying to push me to be done. I think the NRC was afraid I understood what was going on in the big picture? 
"CHAIRMAN GIITTER: All right. I appreciate your comments, Mr. Mulligan. 
MR. MULLIGAN: You know, this is --you're throwing me off. This is what really is happening here. You throw me off 
CHAIRMAN GIITTER: I thought you were done." 
This is a cover-up
"This is all a coverup to get the plant into an outage to get the plant out of the severe grid crisis with not having a lot of electricity, enough electricity to support the New England and stuff like that."
This was a cover-up. 
"How come this behavior of harassing me when I'm in the 2.206 process and stuff like that? How come we can't get to the root of this? How come people can't discuss things honestly and talk about it and lay out what they think is the problem going on here? And why does the NRC have to be so militaristic with me as far as disrupting me and all  that sort of stuff? You know, this is just a pattern of a coverup"
This is a NRC cover-up. 
"Why does everybody use rules to create secrecy instead of using rules to, you know, communicate and talk? How come you guys can't talk in a manner that brings confidence to the public at large and a lot of the people around the nuclear And, like I have been saying about the nuclear plants? How come you can't -- what is going on with this militaristic type of stuff with the NRC in attacking people and that type of stuff? Is it where you don't want to get the story out that, you know, the natural gas thing and a lot of plants are threatened."

Nearly Identical To Pilgrim’s SRVs: 71% Target Rock Two Stage SRV Tech Spec Failure Rate

Update 9/3, 2015
***Until recently there has been very little srv setpoint testing failures. The last three operating period sit outside the normal. The first two operating period consist of three or four SRV setpoint testing failure, while the last setpoint testing failures has 10 failed SRVs. Why are the failures skyrocketing up? What has changed to cause this.    

You can't do a SRV lift setpoints accuracy test up at Power. You have to shutdown to test these valve. If one of Pilgrims SRV valves was known to be outside their plus or minus 3% tech spec limit, they would be required to shutdown within 24 hours.

This exact problem with repeated two stage Target Rock inaccuracy setpoint testing problems...the ones in the plant now... is the reason why Pilgrim dumped their two stage SRV valve and jumped into their defective three stage SRVs valve.

You get it, Target Rock hasn't made nuclear plant grade two or three stage safety relief valves for many decades. They are out of manufacturing for decades. Currently the whole USA nuclear fleet (BWRs) gets their reliefs from canceled or decommissioning plant junk yards. 
Current one of the Hatch plants  is trying to get out of the unreliable Target Rock two stage SRV valve. They installed three Target Rock three stage relief valves in their plant in anticipating shifting all of their 12 Two stage reliefs into three stage. The issue of unreliable three stage relief have at Pilgrim had delay shifting over to all three stage reliefs 

LER: As-Found Values for Safety Relief Valve Lift Set Points Exceed Technical Specification Allowable Limit
On June 2, 2015, Hope Creek Generating Station (HCGS) received initial results of the 'as-found' setpoint testing for the safety relief valve (SRV) pilot stage assemblies. The initial results indicated that three SRV pilot stage assemblies had exceeded the lift settings prescribed in Technical Specification (TS) 3.4.2.1. The TS requires the SRV lift settings to be within +/- 3% of the nominal setpoint value. During the nineteenth refueling outage (H1R19),

all fourteen SRV pilot stage assemblies were removed for testing at an offsite facility. Between June 2 and June 1 O, 2015, HCGS received the test results for the remainder of the SRV pilot valve assemblies. A total of ten of the fourteen SRV pilot stage assemblies experienced setpoint drift outside of the TS 3.4.2.1 specified values. All of the valves failing to meet the limits were Target Rock Model 7567F two-stage SRVs. This is a condition reportable under 1 O CFR 50. 73{a)(2)(i)(B) as an Operation or Condition Prohibited by Technical Specifications.

The cause of the setpoint drift for the ten SRV pilot stage assemblies is attributed to corrosion bonding between the pilot disc and seating surfaces, which is consistent with industry experience. This conclusion is based on previous cause evaluations and the repetitive nature of this condition at HCGS and within the BWR industry.

Technical evaluations performed to assess the aggregate safety significance of ten SRVs with out of tolerance initial lift setpoints concluded that this condition had no safety significance.

DESCRIPTION OF OCCURRRENCE

During the nineteenth refueling outage (H1R19) at Hope Creek Generating Station (HCGS), all 14 Main Steam Safety Relief Valves (SRV) pilot stage assemblies {SB/RV} were removed and tested at NWS Technologies. The SRVs are Target Rock Model 7567F two-stage SRVs. During the period from June 2, 2015 through June 10. 2015, HCGS received the results of the 'as-found' set pressure testing required by Technical Specification (TS) Surveillance Requirement (SR) 4.4.2.2. A total of ten of the 14 SRV pilot stage assemblies had setpoint drift outside of the required

TS 3.4.2.1 tolerance values of +/-3% of nominal value. The 'as-found' test results for the ten SRVs not meeting the TS requirements are as follows:

Valve ID As Found TS Lift Setting Acceptable Band % Difference

(psig) (psig) (psig) Actual

F013C 1216 1130 1096.1 -1163.9 7.61%

F013F 1240 1108 1074.8 -1141.2 11.90%

F013G 1208 1120 1086.4 - 1153.6 7.86%

F013H 1148 1108 1074.8-1141.2 3.60%

F013J 1161 1120 1086.4 -1153.6 3.66%

F013K 1161 1108 107 4.8 -1141.2 4.80%

F013 L 1165 1120 1086.4 -1153.6 4.00%

F013 M 1207 1108 1074.8 -1141.2 8.90%

F013P 1221 1120 1086.4 -1153.6 9.00%

F013R 1169 1120 1086.4 -1153.6 4.38%

CAUSE OF EVENT

The cause of the setpoint drift for the ten SRV pilot stage assemblies is attributed to corrosion bonding between the pilot disc and seating surfaces, which is consistent with industry experience. This conclusion is based on previous cause evaluations and the repetitive nature of this condition at HCGS and within the BWR industry.

Front Page Boston Globe: Pilgrim Downgraded

This below little paragraph is all that is wrong with our news media. The just don't have the specific expertise to ask the important questions? What does "previously addressed the safety relief valve issue" mean. You trust the NRC to be completely truthful to you? These so called new replacement valves really are of a disgraced design...prone to be broken and not detectable and issues with leaking. The two stage valves are dogs. They don't manufacture these valves anymore, they are probably many decades old. These two stage Target Rock safety relief valves (4 of them) were old defective valve the so called new three stage Target replaced. The three stage reliefs have been out of manufacturing for decades also, they get all the two and three stage relief valves from the nuclear junk yards and refurbish them with unreliable foreign parts.
 
Pilgrim nuclear plant safety rating downgraded NRC cites valve problems and shutdowns
The federal Nuclear Regulatory Commission announced Wednesday that it had downgraded the Pilgrim Nuclear Power Station’s safety rating after repeated unplanned shutdowns at the Plymouth facility and recurring problems with the plant’s safety relief valves. 
The plant is now one of just three nuclear power reactors nationwide ranked in the next-to-lowest performance category, officials said. There are no plants in the lowest category.
“They are one step removed from the column where they would be at risk of being shut down by the NRC,” said NRC spokesman Neil Sheehan. 
Pilgrim will now be subject to more stringent oversight by regulators, who will conduct an inspection to determine what problems — equipment failures, procedural trouble, or human error — led to the shutdowns in 2013 and 2015.
“Pilgrim is going to receive scrutiny at the highest levels,” said Sheehan. Despite the downgrade, he said, regulators do not believe there is a pressing safety risk associated with operating the plant. “If we did, we’d intervene. But we do believe there are enough problems that need addressing that this level of attention was warranted.” 
Attorney General Maura Healey called the downgrade “disturbing” and said her primary concern is for the safety and well-being of the people living near the plant, which is owned and operated by Entergy Corp. 
“Entergy must act swiftly and decisively to correct these issues and restore the public’s trust in its ability to safely operate this plant,” she said in a statement.
The 680-megawatt Pilgrim plant opened in 1972. In 2012, its operating license was extended to 2032. 
Regulators will increase the frequency of inspections at Pilgrim, and Entergy will be required to present its performance improvement plan to regulators at a public meeting. 
“Over the coming days Entergy will review the details of the NRC’s decision to consider what actions we need to take to enable Pilgrim Station to return to normal NRC oversight,” Bill Mohl, president of Entergy Wholesale Commodities, said in a statement.
This below little paragraph is all that is wrong with our news media. The just don't have the specific expertise to ask the important questions? What does "previously addressed the safety relief valve issue" mean. You trust the NRC to be completely truthful to you? These so called new replacement valves really are of a disgraced design...prone to be broken and not detectable and issues with leaking. The two stage valves are dogs. They don't manufacture these valves anymore, they are probably many decades old. These two stage Target Rock safety relief valves (4 of them) were old defective valve the so called new three stage Target replaced. The three stage reliefs have been out of manufacturing for decades also, they get all the two and three stage relief valves from the nuclear junk yards and refurbish them with unreliable foreign parts.          
Mohl said that the plant has previously addressed the safety relief valve issue and the plant is operating safely. 
The plant has four safety relief valves, Sheehan said, which alleviate pressure and facilitate the cooling of the reactor. If the reactor cannot be sufficiently cooled, the fuel can begin to melt, which can lead to a radiation leak, though Pilgrim has many redundant systems that would kick in if a valve stopped working, said a spokeswoman. 
“There are backups to backups,” said Pilgrim spokeswoman Lauren Burmin an e-mail. 
All US nuclear power plants are equipped with containment structures to help prevent the release of radioactive material to the environment in the event of an accident, said Sheehan. 
In February 2013, said Sheehan, one of the valves at Pilgrim failed to open during a cooldown, though the station was not cited at the time. The plant’s safety rating was downgraded in 2014 after a series of unplanned shutdowns in late 2013
The problem with the safety valves should have been fully addressed in 2013, said Sheehan, but on Jan. 27 of this year, during a shutdown amid a major snowstorm, another safety relief valve failed to open. 
“They had an opportunity in 2013 to identify the problem, and they failed to do so,” said Sheehan. The plant has since replaced all four valves, Sheehan said, but the repeated failures “point to some programmatic and cultural issues that we believe deserve a closer look.” 
Burm said in an e-mail that the company recognizes the need to strengthen its corrective action program. 
“We work hard every day to find and fix problems in a timely manner,” said Burm. 
Governor Charlie Baker, who recently toured Pilgrim, said Wednesday that he was confident in the plant.
“I do believe it’s safe, yeah,” said Baker, the State House News Service said. “I certainly view the issues that have been raised by this most recent report [as] something we need to pay attention to and be careful and thoughtful about, but the NRC is the most knowledgeable enterprise involved in this oversight activity. We’re going to let them lead this one.” 
The downgrade drew calls for the NRC to continue its aggressive oversight of the plant until Entergy can prove that it has dedicated the proper resources and training to the safe operation of the plant. 
“For decades, I have raised concerns about Pilgrim’s operations, security preparedness, the safety of the surrounding communities in the event of a nuclear accident, and the willingness of Entergy to dedicate sufficient resources to run the reactor safely,” US Senator Edward J. Markey said in a statement. “Pilgrim has had longstanding and repetitive safety problems and unplanned shutdowns that require this increased level of NRC oversight, especially since it is the same design as the reactors that melted down during the Fukushima nuclear disaster.” 
Markey said that Entergy should be required to pay for the distribution of potassium iodide, an anti-radiation drug that can prevent thyroid cancer caused by radiation released during a reactor meltdown, to any Massachusetts community that requests it. 
Mary Lampert, director of Pilgrim Watch, a group that has long sought to close the plant, said trouble has been brewing at Pilgrim for years. 
“This is an old reactor, and like old people such as myself, it requires a lot of money and maintenance,” said Lampert. “Entergy, because it is not able to effectively compete with natural gas and wind, is not making the money that it panned to, is not spending the money for maintenance.” 
Lampert, who can see Pilgrim from her home in Duxbury, said she feared an accident at the plant. 
“You recognize accidents can and do happen,” she said. “That’s something you don’t like to think about, because you’re here.”

Wednesday, September 02, 2015

Pilgrim: Final White Finding On Safety Relief Valves

July 10, 2015 blog entry: 
The Battle for Safety at Pilgrim Nuclear Plant (secret cell phone recording of NRC officials)
Here is my March 7, 2013 10 CFR 2.206 petition requesting a "Emergency Shutdown of Pilgrim Surrounding Their SRVS" relating to this Sept 1, 2015 white finding.

Excerpt:                 
2.206: Request Emergency shutdown of Pilgrim surrounding their SRVs 
March 7, 2013:
"The repeated nature of the failure of the safety relief valves means Entergy doesn't know the mechanism of the failure.. .it is a common mode failure. The design and manufacture of these valves are defective and it is extremely unsafe to operate a nuclear plant with all safety relief valves being INOP. A condition adverse to quality..."    
Request:  
1) Request an immediate shutdown with the Pilgrim Plant.

2) This is the second time I requested a special NRC inspection concerning the defective SRV valves.

3) Not allow the plant to restart Pilgrim until they fully understand the past failure mechanisms of the four bad new three stage safety relief valves.

4) Request the OIG investigate this cover-up to keep an unsafe nuclear plant at power.

According to recording of the high NRC official in the next paragraph (Mr Mckinley and Mr.Cahill), I read this 2.206 excerpt to them for a comment. They said in this 2013 time-frame it was impossible the anyone (NRC) or you (me) to see any degradation in the valves. I sure if you seen all the records of the prior leaks, valve degradation, down-powers and shutdowns over trying to control these defective leaking valves, you would think these NRC officials in July 2015 were crazy. It was crazy talk! 
During the Aug 8, 2015 meeting and in the next few days, I was paddling my ass off with NRC trying to influence them to be a lot tougher on Entergy.   
***Fundamentally in this 2011 to 2013 time-frame with the new defective three stage relief valves, as Vermont Yankee was in the death rattles, I believe the NRC was pulling their punches on Pilgrim. The NRC was fearful Pilgrim would catch the VY disease. The NRC inaction allowed Pilgrim to spiral down into the deep and profound problems in 2015. 

Aug 8, 2015 recorded conversations between Mr. Mckinley, Chief Division of Reactor Projects, Branch 5, Christopher Cahill Senior Reactor Analysis and Mike Mulligan concerning Pilgrim’s Safety Relief Valve preliminary white finding. This is the NRC meeting with Entergy officials leading to the NRC's final white finding seen below.  
1)  Mr. McKinley and Mike Mulligan recorded discussion concerning white determination
2)  Mr. McKinley, Mr. Cahill and Mike Mulligan recorded discussion concerning LOOP frequency



September 1, 2015

EA-15-081

Mr. John Dent
Site Vice President
Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station
600 Rocky Hill Road
Plymouth, MA 02360-5508

SUBJECT: FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND NOTICE OF VIOLATION - INSPECTION REPORT NO. 05000293/2015011 –PILGRIM NUCLEAR POWER STATION

Dear Mr. Dent:

This letter provides you the final significance determination for the preliminary finding discussed in the U.S. Nuclear Regulatory Commission (NRC) letter dated May 27, 2015, which included NRC Inspection Report Number 05000293/2015007 (ML15147A412).1 The finding involved the failure by Entergy Nuclear Operations, Inc. (Entergy) to identify, evaluate, and correct a significant condition adverse to quality associated with the Pilgrim Nuclear Power Station (Pilgrim) ‘A’ safety/relief valve (SRV). Specifically, Entergy did not identify, evaluate, and correct the ‘A’ SRV’s failure to open upon manual actuation during a plant cool-down on February 9, 2013, following a loss of offsite power (LOOP) event. The failure to take actions to preclude repetition resulted in the ‘C’ SRV failing to open due to a similar cause following a January 27, 2015, LOOP event. The NRC also determined that the ‘A’ SRV had been inoperable for a period greater than the Technical Specifications allowed outage time of 14 days.

The May 27, 2015, NRC letter informed you that the NRC preliminarily determined the finding to be of low to moderate safety significance (i.e., White), and included a choice for Entergy to accept the preliminary finding as characterized in the inspection report, attend a regulatory conference, or reply in writing to provide the licensee’s position on the facts and assumptions the NRC used to arrive at the finding and its safety significance. At Entergy’s request, a regulatory conference was held on July 8, 2015, at the NRC Region I office in King of Prussia, Pennsylvania. The presentation provided by Entergy at the conference is included as Enclosure 1. The conference agenda and attendee list is included as Enclosure 2. As described more fully below, after considering the information presented by Entergy at the conference, the NRC maintains that the finding is appropriately characterized as White.

At the regulatory conference, Entergy staff did not contest the performance deficiency, the related violation, or the NRC description of the event. Entergy staff described the corrective actions that have been taken in response to the issue, which include: performing an ongoing root cause analysis, the results of which the licensee staff would share with the Entergy fleet; and continuing improvements to the site corrective action program (CAP), including establishing performance indicators to monitor CAP performance. These actions were in addition to the actions Entergy has already completed including: replacing the ‘A’ and ‘C’ SRVs in February 2015, prior to restarting from the January 27, 2015 event; and replacing all four SRVs with a different model during the Spring 2015 refueling outage.

Entergy staff also presented the results of their quantitative and qualitative assessments of the issue, which supported Entergy’s view that the finding is of very low safety significance (i.e., Green). Entergy staff presented the results of the vendor’s analysis of the ‘A’ and ‘C’ SRVs, which revealed wearing of internal components, resulting in the valve first stage piston rings creating grooves in the guide cylinder. As a result, the valve pistons required higher pressure in order for the rings to lift out of the grooves to allow the piston to move and open the valve. This degradation (the cause of which was not fully understood, but was likely caused by the method of vendor testing followed by operational vibration and pressure fluctuations) was less significant on the other two Pilgrim SRVs (‘B’ and ‘D’), which had not failed to open at any pressure. Entergy also stated that, although the ‘A’ and ‘C’ SRVs had failed to open at low pressures, both valves had demonstrated functionality at high pressure, thereby reducing the range of plant scenarios for which the finding was of concern. Accordingly, Entergy stated that the NRC’s risk analysis should treat the ‘B’ and ‘D’ valves separately from the ‘A’ and ‘C’ valves and also that the NRC common cause failure methodology and risk assumptions were overly conservative.

The NRC considered the information developed during the inspection and the information provided by Entergy at the regulatory conference, and concluded that the finding is appropriately characterized as White. A summary of the information provided by Entergy during this regulatory conference, and the NRC response, are provided in Enclosure 3. Because the finding has been determined to be White, we used the NRC’s Action Matrix to determine the most appropriate NRC response for this finding. You were notified of that determination in the Mid-Cycle Assessment Letter issued today (ML15243A259).

The NRC also determined that the finding involved a violation of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, “Corrective Action,” as cited in the Notice included as Enclosure 4. The circumstances surrounding the violation were described in detail in the subject inspection report. In accordance with the NRC Enforcement Policy, the Notice is considered an escalated enforcement action because it is associated with a White finding.

The NRC has concluded that the information regarding: (1) the reason for the violation; (2) the interim and long term corrective actions already taken and planned to correct the violation and prevent recurrence; and, (3) the date when full compliance was achieved, is already adequately addressed on the docket in NRC Inspection Report 05000293/2015007, in your presentation at the July 8, 2015, regulatory conference, and in this letter. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position.
You have 30 calendar days from the date of this letter to appeal the NRC staff’s determination of significance for the identified White finding. Such appeals will be considered to have merit only if they meet the criteria given in the NRC Inspection Manual Chapter 0609, "Significance Determination Process," Attachment 2. An appeal must be sent in writing to the Regional Administrator, Region I, 2100 Renaissance Boulevard, King of Prussia, PA 19406.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room located at NRC
Headquarters in Rockville, MD, and from the NRC’s Agency-wide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response, if you choose to provide one, should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

Should you have any questions regarding this matter, please contact Mr. Raymond McKinley, Chief, Projects Branch 5, Division of Reactor Projects in Region I, at (610) 337-5150.

Sincerely,
/RA/
Daniel H. Dorman
Regional Administrator
NRC RESPONSE TO INFORMATION PROVIDED BY ENTERGY NUCLEAR OPERATIONS, INC (ENTERGY) AT THE JULY 8, 2015, REGULATORY CONFERENCE SUMMARY OF INFORMATION PROVIDED BY ENTERGY
At the regulatory conference, Entergy staff presented the results of its quantitative and qualitative assessments of the issue, which supported Entergy’s view that the finding is of very low safety significance (i.e., Green).
Entergy staff presented the results of the vendor’s analysis of the Pilgrim Nuclear Power Station (Pilgrim) ‘A’ and ‘C’ safety/relief valves (SRVs), which revealed wearing of internal components, resulting in the valve first stage piston rings creating grooves in the guide cylinder. As a result, the valve pistons required higher pressure in order for the rings to lift out of the grooves to allow the piston to move and open the valve. This degradation (the cause of which was not fully understood, but was likely caused by the method of vendor testing followed by operational vibration and pressure fluctuations) was not as significant on the other two Pilgrim SRVs (‘B’ and ‘D’).
Based on the results of this analysis, Entergy staff stated that the NRC should factor the following considerations in its qualitative and quantitative evaluations of the finding:
  • The ‘B’ and ‘D’ valves exhibited only minor degradation and remained operable at all times, and opened and closed reliably on multiple demands when called upon across the entire pressure range. Therefore, pressure control for Pilgrim was always available.
  • Although the ‘A’ and ‘C’ SRVs had failed to open at low pressures, both valves demonstrated functionality at high pressure, thereby reducing the range of plant scenarios for which the finding was of concern.
  • Other mitigating strategies remained available, including alternate depressurization systems (High Pressure Coolant Injection (HPCI), Reactor Core Isolation Cooling (RCIC), Main Steam Line drains, and Reactor Water Clean-Up in let-down mode) and for high pressure injection (HPCI, RCIC, Feedwater, Control Rod Drive, and Standby Liquid Control). Pilgrim Emergency Operating Procedures (EOPs) provided direction to operators to use these alternate means, if necessary.
  • The value used by the NRC for an increased probability that the SRVs would fail to close was not credible. This was because, due to the design of the valves, sufficient pressure was always available to achieve closure.
  • The value used by the NRC for the probability that the SRVs would fail to open was overly conservative. Independent engineering analysis obtained by Entergy indicated that the ‘A’ SRV would have opened at pressures above approximately 200 psig and that the ‘C’ SRV would have opened at pressures above approximately 300-400 psig. The ‘B’ and ‘D’ SRVs should have been credited for opening at any pressure based on actual in-plant observation and the minimal degradation of the valves.
  • The common cause failure methodology applied by the NRC in its Standardized Plant Analysis Risk (SPAR) modeling was overly conservative and failed to consider plant specific information.
NRC RESPONSE
The NRC’s preliminary risk determination was performed utilizing NRC Inspection Manual Chapter (IMC) 0609, Appendix M, “Significance Determination Process Using Qualitative Criteria.” This method was utilized because an existing, quantitative significance determination process is not available that can adequately assess the significance of the finding given the uncertainty in the actual pressure at which the SRVs would fail to function, as well as other uncertainties as described below. The resulting NRC preliminary analysis utilized a quantitative assessment to bound the risk and qualitative insights based on the circumstances of the finding and the licensee’s actions.
The NRC evaluated the considerations raised by Entergy. Specifically:
  • Regarding Entergy’s position that pressure control for Pilgrim was always available due to the continued operability of the ‘B’ and ‘D’ SRVs, the NRC determined that, due to the as-found condition and historical observed degradation of the valves of the same design, there was an increased likelihood that the valves would fail if called upon. The as-found and historical degradation of the valves was determined to have an impact on the overall reliability of all the valves to function. Testing performed by the vendor and validated by the licensee’s engineering finite element analysis indicated that new or refurbished valves were experiencing damage during pre-installation testing at pressures as low as 60 psig. This is significantly less pressure and driving force than the valves would be exposed to during at-power transients. This degradation was expected to worsen with additional cycling of the valves during plant transients.
  • The NRC determined that it was reasonable to conclude that given the performance history of the valves (including but not limited to the fretting wear, stem deformation, spring shortening, piston de-torqueing, piston wobble, thread damage, and locking device failures), there was an increased likelihood that the valves would fail if called upon during an event. This, in conjunction with the risk importance of the valves, could challenge the ability to depressurize the reactor under postulated accident conditions. Taken collectively, the NRC determined that additional information provided by Entergy regarding performance of the degraded SRVs did not establish that their failure rate should be considered equivalent to the failure rate of non-degraded SRVs. Entergy accounted for the uncertainty in the valves’ degraded condition by assuming a 2X increase in the probability of failure (above the baseline probability of failure), while the NRC’s analysis assumed a 10X increase in the SRVs’ probability of failure for events other than medium break loss of coolant accidents (MLOCAs). This difference highlighted an uncertainty associated with conducting a quantitative risk assessment for this condition. Based on Entergy’s assumption that the degraded SRVs would fail at twice the rate of non-degraded valves, they determined that the core damage frequency (CDF) for internal events not associated with MLOCAs would increase by 3.6E-7. Both the NRC’s and Entergy’s methods conclude that the degraded SRVs would increase the CDF by some amount.
  • The NRC reviewed the independent engineering analysis obtained by Entergy that provided a postulated lower pressure range at which the valves would function. The independent analysis provided an approximation of the pressures at which the ‘A’ and ‘C’ SRVs would function, but did not include any in-situ measurements or consider other relevant factors that would have correlated to or impacted the calculated lift pressure. Specifically, the calculated lift pressure was highly sensitive to the assumed value assigned to the coefficient of friction (i.e. a small increase in the coefficient of friction would result in a large increase in the expected lift pressure). The coefficient of friction assumed in the analysis was reported as conservative and derived from industry reference data. However, a review of the available NRC-published data (e.g., NUREG/CR 6807, “Results of NRC-Sponsored Stellite 6 Aging and Friction Testing) indicated that the credible range of coefficients could be higher than assumed in the analysis. In addition, the coefficient used in the evaluation apparently did not consider other factors such as the buildup of corrosion or wear products that could further increase the coefficient of friction above that assumed in the calculation. Inspectors observing the valve disassembly and pictures taken by Entergy indicated that some amount of corrosion and/or wear products were present in the main body of the valves. Further, the analysis did not consider the potential impact of multiple cycles on the degradation rate of the SRVs. Taken collectively, the NRC determined that the engineering analysis did not fully resolve the uncertainty associated with the operation of the SRVs at low pressures or make an adequate case for significantly revising downward the NRC’s CDF determination.
  • Regarding Entergy’s position that the common cause failure methodologies and values used in the NRC’s risk analysis for failure to open and close were not credible, the NRC determined that the licensee did not provide an adequate basis to demonstrate that the valves should not be coupled within the same common cause failure grouping or provide any other accepted method to quantify the risk from common cause failure. Specifically, the licensee stated that one of the degradation mechanisms (the amount of wear in the guide cylinder from interaction with the piston rings) was less significant for two of the valves, but did not provide any plant data or specific reason for the difference. In addition, the licensee did not address why the valves should be treated differently considering that they exhibited multiple degradation attributes that were common to all of the valves. The NRC determined that the valves should be treated as a common group since they had multiple, comparable degradation mechanisms and no information was presented to differentiate the design, manufacturing, testing, maintenance, or operation of any of the valves. The NRC’s methodology used to determine the risk associated with common cause failure potential for these valves was peer-reviewed, published, and is considered to be state-of-the-art and the appropriate method to estimate the risk impact associated with the failure of common components.
  • Entergy estimated an increase in CDF of 1.3 E-7 for internal events associated with a MLOCA. The NRC agreed with the Entergy’s determination that the degraded SRVs would increase plant risk during MLOCA events but calculated a higher core damage frequency based on the difference in how the common cause failure potential was determined.
  • Entergy did not present any specific risk insights with regard to external event risk; however, Entergy’s risk analyst indicated that the increase in risk from external events was approximately equal to the increase in internal events. The NRC determined that the dominant external risk contributors would be from seismic and fire events, resulting in loss of offsite power and/or a complete station blackout. Core damage would result in the event of further failure of high pressure injection systems coupled with the failure to depressurize the reactor. The NRC did not conduct a more detailed analysis but agreed with the licensee’s estimation that the risk from external events would be approximately equal to the internal event risk contribution. The NRC did not consider the external event contribution to be as significant for the MLOCA scenarios and did not include this risk in the summary below.
Combining the above quantitative aspects, Entergy estimated an increase in CDF of 4.9E-7 for internal events that, when considering the risk of external events (for non-MLOCA scenarios) would result in an overall estimated CDF increase of 8.5E-7. This was comparable to the NRC’s computed increase in CDF of 4E-6. The differences are due to the analytical uncertainties and differences in some of the assumptions used in the quantitative analysis. Based on the above, the NRC determined that the risk estimates for this performance deficiency overlapped the green to white threshold. The NRC staff concluded that there are significant limitations in the use of existing tools to fully and accurately quantify this risk because of the uncertainties associated with: the degradation mechanism and its rate and the range of reactor pressure at which the degraded valves could be assumed to fully function; any potential benefit from an SRV lifting at rated pressure, such that the degradation would be less likely to occur and, therefore prevent a subsequent failure at low pressure in the near-term; the time-based nature of plant transient response relative to when high pressure injection sources fail and the associated impact of reduced decay heat on the SRV depressurization success criteria; and the ability to credit other high pressure sources of water. Therefore, the above numerical values were considered as an input into the final significance determination, along with the qualitative factors described in IMC 0609, Appendix M.
Entergy provided information regarding operational risk mitigating factors as discussed earlier in this section, and Enclosure 1 contains their assessment of the Appendix M qualitative factors. The NRC reviewed the factors in Appendix M starting with a conservative bounding analysis. As described in NRC Inspection Report Number 05000293/2015007, the NRC calculated a bounding increase in CDF of mid E-4. The NRC determined this value was overly-conservative since both the ‘A’ and ‘C’ SRVs passed as-found high pressure American Society of Mechanical Engineers code required testing and a subsequent lower pressure special test at 100 psig at the testing vendor. This, and the fact that the ‘A’ SRV successfully functioned at high pressure in the plant after the failed low pressure attempt, partially supported the theory that the valves would function at high pressure. However, as previously discussed, there is a high degree of uncertainty associated with SRV performance, which can strongly influence the specific initiating events, success criteria, and common cause factors. The first attribute described in Appendix M is to consider whether the finding impacted defense-in-depth. As noted above, Entergy stated that other mitigating strategies remained available, such as alternative pressure control and high pressure injection. Even so, the NRC considered that the SRVs and low pressure injection provide redundancy and backup to the high pressure injection sources. Specifically, the SRVs are required to perform both an overpressure protection function and to provide a means to rapidly reduce pressure to allow for low pressure sources to inject into the reactor vessel. Emergency depressurizations are directed in the emergency operating procedures when the suppression pool reaches it heat capacity temperature limit, when there is a reactor coolant leak into secondary containment, and when level reaches the minimum steam cooling water level. The NRC determined that SRVs were associated with and required to perform a defense-in depth mitigation function and, therefore, this attribute was impacted by the performance deficiency.
The second attribute is to determine the effect of the finding on a plant’s safety margin, and the fourth attribute is to consider the degree of degradation of the failed components. These two attributes were considered jointly, as they could be assessed by their impact on plant risk.While there is no existing tool to precisely model the impact of the degraded SRVs on plant risk, the NRC and Entergy performed independent risk assessments, achieved comparable results, and bounded the risk in the overlap range between the green to white significance threshold. The third attribute in Appendix M is to consider the effect of the finding on other equipment. The NRC determined that Entergy’s failure to identify and correct the condition of the ‘A’ SRV following the 2013 winter storm event resulted in the failure to identify a significant condition adverse to quality that led to the failure of the ‘C’ SRV during plant cool-down following an actual plant event in January 2015. Thus, the NRC determined that this performance deficiency affected redundant safety equipment.
The fifth attribute is to consider the period of time of the effect of the finding. While Entergy stated that the time period should be limited to twelve months, the NRC determined that it was likely that the valves were nonconforming upon installation, and that the period would then exceed one year. The NRC determined that the performance deficiency led to operation with degraded SRVs for a significant period of time.
The sixth attribute is to evaluate the likelihood that the licensee’s recovery actions would successfully mitigate the finding. As described above, Entergy stated that other mitigating strategies remained available, including alternative pressure control and high pressure injection, which the operators would have utilized in accordance with EOPs. However, the NRC concluded that these strategies are highly dependent on initial plant conditions and operator response to the event. The NRC considered that the redundant mitigation strategies would have been included in the risk estimates provided above, which quantified the risk of this event in the green to white significance level.
The final attribute in Appendix M is to consider any additional qualitative circumstances associated with the finding. Accordingly, the NRC considered Pilgrim’s organizational performance during the 2013 and 2015 events, as documented in NRC Inspection Report Number 05000293/2015007. Specifically, during the 2013 event, Pilgrim staff did not identify that the ‘A’ SRV had failed to open in spite of having sufficient information available to do so.
During the 2015 event, Pilgrim operators and staff did identify that the ‘C’ SRV failed to open. However, engineering, operations, and plant management erroneously concluded that the SRV was operable. Pilgrim did not declare the SRV inoperable until NRC inspectors on the Special

Inspection Team raised concerns about the valve’s response. Additionally, during the 2015 event, operators used a high-volume injection system (Core Spray) when other, more desirable, injection systems were available to provide finer level control. As a consequence, reactor level remained high in the control band, allowing reactor pressure to rise, requiring operators to cycle the SRVs. Given that all of the SRVs were exposed to some level of degradation, it is plausible to conclude that stressors, such as excessive cycling, had the potential to increase the probability of SRV failure.
Based on the above factors, taken in conjunction with the uncertainties of the quantitative analysis, the NRC concluded that the finding is appropriately characterized as White (low to moderate safety significance).



Tuesday, September 01, 2015

Natural Gas: Way Beyond A Miracle

There are so many efficiency efficiencies coming on line with the natural gas industry, like new fracting techniques and managing the whole natural gas enterprise...the price of natural gas can go to mind boggling low levels and these guys still are going to make massive profits.

This massive thing is going to restructure our nation...

***That be fracting expanding the petroleum and natural gas fields way beyond what we could imagine just a few years ago. 
Applying newer fracking methods to existing field offers potential for more and cheaper fuel
 
Drillers Unleash ‘Super-Size’ Natural Gas Output
Applying newer fracking methods to existing field offers potential for more and cheaper fuel
 
Newer production techniques being applied to a natural-gas rich area that stretches from northeast Texas into Louisiana are affecting U.S. pricing because of its potential to ‘super-size’ output in an area close to many fuel pipelines. 
 
Updated Sept. 1, 2015 7:12 p.m. ET
 
The U.S. may have far more natural gas than anyone imagined, all reachable at a profit even with today’s bargain-basement prices. 
Experimental wells in Lou isiana by explorers including Comstock Resources Inc. CRK -10.49 % and Chesapeake Energy Inc. CHK -3.07 % are proving highly lucrative thanks to modern drilling techniques and the sheer volume of fossil fuels that can be coaxed out of the ground.
The trick is applying supersize versions of the horizontal-drilling and fracking techniques that worked successfully elsewhere to an area that hasn’t seen this approach yet. The gains come from extending the lateral portions of wells by thousands of feet and pumping them full of enormous volumes of sand, chemicals and water to flush out more hydrocarbons.
So far, the impressive results have been confined to a small area in a single Louisiana parish near the Texas border. But if the approach works across the giant Haynesville Shale, which spans 120 miles across both states, the era of low American gas prices could extend for decades into the future, experts say.
 
“There’s a large likelihood that the United States will be enjoying very low gas prices for a very long time, maybe 20 years,” said Mark Papa, who has monitored Haynesville developments as a partner at Riverstone Holdings LLC, one of the biggest energy-focused private-equity firms in the U.S.

The field produces 8% of the nation’s natural gas, making it the second largest after the giant Marcellus Shale in the Northeast. Because it is located in Louisiana, near several interstate pipelines, potential export facilities and industrial consumers, an increase in gas production in the Haynesville has an outsize impact on gas prices across the entire country.

The cost of natural gas matters because the fuel increasingly powers the U.S. economy and is critical to the Obama administration’s push to reduce carbon emissions in electricity generation. American gas consumption has risen at a 2.4% annual growth rate for the past decade, while demand for coal has fallen by 2.7% and oil by less than 1%, according to the federal Energy Information Administration. Gas now is used to generate about 30% of U.S. electricity and heat nearly half of all American homes…

Waterford Diesel Generators Are Junk

They are just not doing the proper proactive maintenance on this machines. Within hours, they had a generator protective trip and then during testing a damper failed on startup. It implies you could have both DGs fail in a bad accident.  
***But  the inverse, if EDG A is already running and loaded, then do they really need to worry about a EDG start?

But in the inverse,  usually one division is in maintenance test, and the other is protected, do not touch.

So with EDG A in test/ maint, there could have other systems / equip in maint / test and not ready for a safety function (SF).

Now with Div B protected, and now have an inop EDG B when it is protected and being counted on to perform its SF,  I think you may have a major gap in reliability and high likelihood of protected Div B ECCS failure.

Time for some deep probing questions that only a skilled experienced deep prober can perform.
This is a severe indicator of maintenance in the whole plant.

Power ReactorEvent Number: 51348
Facility: WATERFORD
Region: 4 State: LA
Unit: [3] [ ] [ ]
RX Type: [3] CE
NRC Notified By: MARIA ZAMBER
HQ OPS Officer: JEFF HERRERA
Notification Date: 08/26/2015
Notification Time: 15:47 [ET]
Event Date: 08/26/2015
Event Time: 07:40 [CDT]
Last Update Date: 08/31/2015
Emergency Class: NON EMERGENCY
10 CFR Section:
50.72(b)(3)(v)(A) - POT UNABLE TO SAFE SD
50.72(b)(3)(v)(D) - ACCIDENT MITIGATION
Person (Organization):
VIVIAN CAMPBELL (R4DO)

UnitSCRAM CodeRX CRITInitial PWRInitial RX ModeCurrent PWRCurrent RX Mode
3NY100Power Operation100Power Operation
Event Text
BOTH EMERGENCY DIESEL GENERATORS DECLARED INOPERABLE

"This is a non-emergency notification from Waterford 3. On August 26, 2015, at 0111 CDT, Emergency Diesel Generator (EDG) 'A' was declared inoperable following a trip of EDG 'A' on Generator Differential. Technical Specification (TS) 3.8.1.1 actions b. and d. were entered. EDG 'A' was being routinely run in accordance with OP-903-115, 'Train A Integrated Emergency Diesel Generator/Engineering Safety Features Test', Section 7.4, '24 hr EDG A Run with Subsequent Diesel Start' to satisfy Technical Specification Surveillance Requirement 4.8.1.1.2 6. EDG 'B' was subsequently started per TS 3.8.1.1 action b. (1). At 0740 CDT, EDG 'B' was declared inoperable and TS 3.8.1.1 f. was entered due to the exhaust fan not starting when the diesel engine was started.

"Troubleshooting determined that the EDG B exhaust fan did not start due to HVR-501B (EG B ROOM OUTSIDE AIR INTAKE DAMPER) not opening. Action was taken to isolate air and fail HVR-501B to its open safety position. At 1001 CDT, EDG 'B' was declared operable and TS 3.8.1.1.f. was exited following verification of proper operation of the EDG 'B' exhaust fan.

"Waterford 3 is currently in TS 3.8.1.1 actions b. and d. Actions to verify a temporary EDG is available and restore EDG 'A' to operable status are in progress.

"This event is reportable pursuant to 10 CFR 50.72(b)(3)(v) (A) and 10 CFR 50.72 (b)(3)(v) (D), 'event or condition that could have prevented fulfillment of a safety function of structures or systems that are needed to (A) shut down the reactor and maintain it in a safe shutdown condition' and (D) 'mitigate the consequences of an accident due to both emergency diesel generators being inoperable.'"

"The NRC Resident Inspector has been notified."


* * * UPDATE FROM SCOTT MEIKLEJOHN TO DONALD NORWOOD AT 1328 EDT ON 8/31/2015 * * *

"The following is a correction to a non-emergency event notification from Waterford 3 originally made on 8/26/2015:

"On August 26, 2015, at 0111 CDT, Emergency Diesel Generator (EDG) 'A' was declared inoperable following a trip of EDG 'A' on Generator Differential. Technical Specification (TS) 3.8.1.1 actions b and d were entered. EDG 'A' was being routinely run in accordance with OP-903-115, 'Train A Integrated Emergency Diesel Generator/Engineering Safety Features Test,' Section 7.4, '24 hr EDG A Run with Subsequent Diesel Start'
to satisfy Technical Specification Surveillance Requirement 4.8.1.1.2(e)6. EDG 'B' was subsequently started per TS 3.8.1.1 action b.(1). At 0740 CDT, EDG 'B' was declared inoperable and TS 3.8.1.1 f was entered due to the room exhaust fan not starting when the diesel engine was started.

"Troubleshooting determined that the EDG B room exhaust fan did not start due to HVR-501B (EDG B ROOM OUTSIDE AIR INTAKE DAMPER) not opening. Action was taken to isolate air and fail HVR-501B to its open safety position. At 1001 CDT, EDG 'B' was declared operable and TS 3.8.1.1.f was exited following verification of proper operation of the EDG 'B' room exhaust fan.

"Waterford 3 is currently in TS 3.8.1.1 actions b and d. Actions to verify a temporary EDG is available and restore EDG 'A' to operable status are in progress.

"This event is reportable pursuant to 10 CFR 50.72(b)(3)(v)(A) and 10 CFR 50.72(b)(3)(v)(D), Event or Condition that Could Have Prevented Fulfillment of a Safety Function of structures or systems that are needed to (A) shut down the reactor and maintain it in a safe shutdown condition and (D) mitigate the consequences of an accident due to both emergency diesel generators being inoperable.

"The NRC Resident Inspector has been notified."