April 4 public meeting...they got me on the phone bridge.
"Review of MOVAT testing data, combined with stellite aging research, strongly indicates that the disc separated prior to November 2008"
If you agree with TVA on this, the valve testing program for critical safety valves is ineffective. It missed a clear indication of a valve disc seperation over this, the NRC and TVA should have done a investigation on is movat a effective safety program....it looks totally dysfunctional to me according to the TVA’s own words. It should be a NRC violation.
Why hasn't anyone talked about fixing movats?
Like I said, there is micro difference in diameter of the disc and the seat, noise of the electrical lines suppling the valve motor, that would give you movat noise seen on the recording. You can only tell by looking at a bunch of movat testing recordings, whether these bumps are the real deal or noise. Did TVA just choose the pretty data?
Was the movat equipment calibrated properly...
Though, I just don’t find much certainty evidence that the disc would have unseated...all I see is the gunslinger pro nuclear industry engineering firms doing TVA’s bidding for money...
So let me get this straight, according to the NRC pilgrim’s inspection report 2011-008 dated from February 14 through March 4,2011, the HPCI diaphragm event happened before July 2010, why still no LER? Basically there is the same kind of issues with the delay of the reliefs valves thread LER with on two Vermont Yankee petitions on Entergy.
The Brown Ferry identical LER 2009-004 says the event date is 07 24 2009, the NRC says they made the document on sept 2009...why is Entergy having so much problems with pushing out LERs? The BF inspection report 2009-005 came out between October 1, 2009 through December 31, 2009
Just to be clear, the NRC drums out their inspection report on TVA in 3 months...while Pilgrim’s inspection takes 7 mouths, and they still don’t have the LER out...
It is just hit and miss and completely erratic with NRC inspection reports and utilities LERs ...
It just fascinating, so on the VY HPCI steam line leak and gasket issues on LER 2011-001...the event occurs on around Feb 17, 2011, Entergy pumps the LER out on April 14 (good as far a timeliness))....basically a petition maker forces the NRC to do a inspection on the gasket problem and the LER. It is object insanity! Now it seems the inspection report is mon
...April 10..."By the way, I think Browns Ferry is the most dangerous plant it the nation and they have a culture of falsification of documents to the government. Check out their LER falsification. Matter of fact, you got a wide spread culture of falsification throughout the nuclear industry as outlined narrowly in the NRC OIG investigation on LERs and part 21..."
From: "Lewis, Shani"
To: "email@example.com m"
Sent: Wednesday, April 27, 2011 8:12 AM
Subject: Your Concerns Regarding Browns Ferry
This is to acknowledge our receipt of your e-mail dated April 10, 2011. We will respond specifically to the concerns you raised regarding the Browns Ferry Nuclear Plant but first we need to verify that we can communicate with you via this e-mail address. Please reply to this email or call me at the number listed below to advise us of your preference going forward.
My name is Shani Lewis, Allegation Coordinator. You can contact me by calling 1-800-577-8510, extension 4461 or communicate with me via e-mail, Shani.Lewis@nrc.gov. Please also be advised that we cannot protect the information during transmission on the Internet and there is the possibility that someone else could read your and our responses while it is transmission.
Shani A. Lewis
U.S. Nuclear Regulatory Commission, Region II
From: Michael Mulligan
To: "Lewis, Shani"
Sent: Thursday, April 28, 2011 1:14 PM
Subject: Re: Your Concerns Regarding Browns Ferry
Inspection Report 2009005
I see many more safety processes being in similar straits....identification, RCA and corrective action problems...
.....PG 19 In September, 2008, the inspectors presented a concern to the licensee that approximately 17 Cause Determination Evaluations (CDE) had exceeded the licensee’s Maintenance Rule (MR) program completion guidelines, and the licensee initiated PER 152007 to address this potential adverse trend. But in April 2009, the licensee identified additional late CDEs and initiated PER 169954 which required an effectiveness review in six months. In those six months, the inspectors and the licensee identified approximately 20 more CDEs that were untimely or past due. Inspectors discussed this potential adverse trend with the licensee who entered the issue into their CAP as PER 210091.
What you can say about LER 2009-004, is all the hand holding the NRC had to do to get to them to get them to submit a LER and be it accurate. One wonders all the missed LERs that wasn’t submitted that the NRC didn’t have time to catch.
This is the crazy talk of the NRC I was talking about “was not repetitive or willful”, but in this inspection report there are two issues with failure to submit a LER
“However, because this violation was of very low safety significance, was not repetitive or willful, and was entered into the licensee’s CAP as PERs 177206 and 204364, the NRC has characterized the significance of this reporting violation as a Severity Level IV NCV in accordance with Section IV.A.3 and Supplement I of the NRC Enforcement Policy.”
I read a lot of issues with the Watts Bar....with the TVA habitually not filling timely responses and documentation. I believe it is systemic within TVA...
Don’t forget in the lead up to the RCA valve injection valve failure, you had a disgraceful event with a bowed RHR rotor and its subsequent destruction within days of the RHR injection valves. You had three safety relief valves technically inop that would have caused you shutdown if you could have seen it. I am saying the equipment failures indicate the plant carries a lot more level of risk to the community that what you risk analyses shows. Can you imagine a accident with all these defects showing up instantaneously in one accident.
Inspection Report 2010-005
NPG-SPP-02.8 was adequate to meet the purpose and objectives of the ITR program. The inspectors also reviewed the two most recent Integrated Trend (IT) reports. The licensee had identified certain departments that did not submit their reports on time which contributed to the site report being issued after its required due date. The inspectors noted that SRs were written for each occurrence. The inspectors also noted that the new procedures improved the consistency of trend discussions and the report format across departments.
...PER 213116 was generated to address the licensee’s actions to address an inspector identified trend, concerning the adequacy of post maintenance testing (PMT), which has been previously documented in multiple inspection reports, but is yet to be adequately addressed by the corrective action program.
...The inspectors identified a potential adverse trend regarding inaccuracy and incomplete information contained in LERs. During the review of LERs from 2009 through 2010, inspectors identified seven examples where LERs contained inaccurate statements, incomplete descriptions and details, and other technical and editorial errors. The licensee had previously initiated the following PERs to resolve the issues identified by the inspectors: PERs 215479, 205308, 201410, and 163176. Additionally, as documented in report Section 4OA3.1 below, the inspectors identified two violations associated with inadequate and incomplete information in Unit 3 LER 2009-003. The licensee initiated SR 314177 to address this apparent adverse trend.
Over the past operating cycle, Units 2 and 3 have developed a large number of control rod Rod Position Indication System (RPIS) component problems. Unit 2 had outstanding WO’s on about 25 different control rods with RPIS related problems, and Unit 3 had about 15 control rods with WO’s. These problems involved incorrect back lighting, intermittent drift alarms, and primarily inaccurate rod position indication at one or more positions. The licensee initiated SRs 313460 and 313465 to address this adverse trend.
What can be said clearly from the LER crazy talk in 2009 “was not repetitive or willful” with two LERs, then the proliferation of LER problems in 2010-005...you might have covered it, but the agency’s ROP is not effective with changing a plant’s behavior.
I am just saying the NRC might be somewhat good on describing the pieces of the puzzle...but you suck a putting the puzzle together and seeing the big picture.
It get you to wondering, is the TVA being shown favoritism because they are they brought back on line BF 1 and working on bringing on other new nuclear plant.
I’d like to see a full scale investigation on the recent history TVA’s LERs and the current status.
As I said, a assortment of safety bureaucracy and processes are dysfunctional leading to preventable failures of safety systems...you got to know there are many defects within the plant not seen and one wonders if all these defects will conspire to come together in a big accident and create shame to our nation.
With the HPCI diaphragms, why did you ding them on not writing a LER accurately, when you should have dinged them with illegally putting in the defective quality safety repair parts.
I remember being at the HB Robinson plant public meeting...where there was serous talk about in the future how safety critical LERs are. They were talking about inaccurate information from Robinson. It is interesting, last spring the NRC came to visit Vermont Yankee about their tritium leak. I got up behind Jazcko chanting "Remember the HB Robison plant"....everyone including the anti's thought I was nuts. I was talking about the terrible Robinson plant accident in March...I didn't think it was over with. Then the plant had two more serous plant accidents and many NRC findings.
This testimony came way before the NRC OIG investigation...you notice how starling close my language was the NRC OIG report about LERs and part 21...
2.206 transcripts on June 29, 2010 on the Vernon Tie.
(I like my language better because it is more colorful and accurate.)
MR Mulligan: "The new way they do it nowadays is, you have a set of conflicting codes and regulations. You have five or six of them all intertwining and intermingling and very few people can understand, and you have an outcome in mind, and you twist these codes and regulations around until you get the outcome you want.
Nowadays, we play games, we twist around regulations, and we make believe that the regulations, you know, are going to tell us the ultimate truth, if we obey the regulations, it's going to tell us the ultimate truth, and the perfect outcome. If we just follow the rules, there's going to be a perfect outcome."
MR. PICKETT: One more, again, Doug Pickett.
Mr. Mulligan, you were making a number of statements about the codes and regulations are twisted by regulators to get the desired results. Are you aware of any particular regulation or code that is not being met?
MR. MULLIGAN: Well, a code. Well, you see, the problem is I've got a big barrier in front of me, everybody knows that, you know? This is what this is about, is to keep me -- keep a barrier in front of me, and not be able to get the hard questions asked and stuff like that.
You know, I -- you know, one day, you know, I envision a different 2.206 process, where, you know, you are my government, I don't own the government, but I do in a way, but you work for me and stuff, and there's an issue of, you know, I have access to NRC people, we get into a group where there's an assertion like this, and people are on my side, you know.
I don't have these techno barriers, and these legalistic barriers, and these kind of evidence, super-duper evidence barriers and all that sort of stuff that people play games, like, you know, to put a barrier in front of me and stuff like that. I have a thing where a group of people, NRC people, would get together with me before 2.206, we talk about all the different issues, and you would bring up the information, we'd share it freely and stuff like that, and would go into a 2.206 process a lot different way than we do now.
You know, that's how I would make my government work for me. As of now, this process works for the utilities and the NRC. It's designed to be a barrier for me, as far as legalistic stuff, you know, Congress and stuff. So, that's my envision of a government that works for me.