Wednesday, March 28, 2012

Pilgrim's failed Target Rock SRV

New April 5, 2:30pm
The OIG gave me a call today.

...He humiliated and disrespected me with this phrase " if your were a decent whistleblower" you would have a complete report.

You know what I say, record and transcript every conversation I have with NRC official. If you were with me on my conversation you would see how disgraceful and uneducated some officials are.

Mostly the front line NRC inspectors and their bosses are really decent people...but the support people like Allegation and the OIG are atrocious and with their knowledge of the nuclear industry. They generally don't have the skills and are not trained to talk in a non threatening manner and have a open discussion.

This guy began exactly like the Allegation...what was the LER nmber?
...So were talking about target rock and why components immediately failed on new installs.

This guys didn't know what a safety relief valve did in a BRW. I had to educate him on its function.

You know what, these are really complicated components and organizational issues. You just can't come into a conversation with me without deeply researching my issues or I have to give you grammar school class in BWR designs. Both Allegation and the OIG did this.

If you don't do your background work before you get to me...i am going to lose you within the first five minutes.

The NRC OIG guy said its not fraud waste, misconduct or abuse within the rules of the it a licensing or NRR thing. I said believe me i got it with your NRC people, you are going to pass me from one department to another because some NRC employees are too lazy to do their jobs. I am going to have to explain myself 100 times to different departments and NRC employees, who don't even know what the function of a SRV is. 
...The NRC is doing one of those teenager la la la la deals while covering their ears to the obvious.

Basically, I asserted LER's are insanely incomplete and inaccurate...

...I would say i was exposed to a militaristic use of language to disrupt communications....the use of rules and regulations in way to disrupt communication and knowledge of the problem to the
public. It is using words, language, rules and regulations, indeed government as weapons against the innocence...the intent is deny public participation with government. They militaristically trying to rule me and everyone out of public participation.

I think what we got here is systemic breakdown with the utilities and NRC to control vender repair, new parts and basic off site engineering services. I think these vendor component and engineering suppliers are not required to tell the truth. I would say since I been hitting them on these issues the NRC has tried to come to grips with their vender service provider problem.

Bottom line, they are having trouble getting replacement parts on these obsolete plants. Companies have gone out of business and ceased production streams, and the new deal is they are hiring companies who specialize in doing "reverse engineering" on replacement parts that are dangling without any new parts stream.

...As example, all the new Mitsubishi kids are making the San Onophe SGs and the old experienced engineers have retired or died.  

New March 28
I backed out of the NRC allegation process. They got hyper legalistic and evidence thingy on me...they knowing that the agency and the utility had all the cards. I said the Peach Bottom 2.206 administrator sent my issue into allegation...I didn't call in allegation on my own. I thought it was going to be a conversation between me and agency...not this one way deal where if i said i sneezed then I had to prove I sneeze. I asked, should I have brought my lawyers and engineers into the deal.

I didn't think the Allegations process was fair and was hyper legalistic and hyper regulatory rules thingy where you couldn't sneeze if it wasn't in the rules. The Alligation team went cold into this not even researching my involvement with VY and Peach Bottom, and the LERs and inspection reports.   

I said I withdrawal my concern and I don't want to be updated about this. They told me you can't withdrawal a concern once one was given to the NRC....but you can be anonymous.

  ...At the bottom of it over VY and the Peach Bottom SRV issue, I spent days researching everything i could about the SRVs. I spent a hour and half each with both inspectors at VY and Peach Bottom for a total of four plant inspectors and three hours talking to me. I knew the territory and what I was talking about...I was frustrated that these four officials went cold into this meeting. Then they played the, mike this thing is evidence driven and we got to know the LER number and we got to know who the VY inspector's names are. It was humiliating and disrespectful for me. There was one official talking to me as I was discussing my issue, then none of the other three officials could even do quick search on the VY docket for the LER document number to get us past the sticking point. What BS!

I got a e-mail trail from Don, lets schedule a meeting beginning last thurs. I say I ready right now, tomorrow and any time at your convenience next week. Just set the time and date and i will be there. I wanted to make it easy for him. Then I get a e-mail tues saying I can't find anyone to have a meeting with you without any explanation. Next day he tells me the following day the meeting is on, what time.

They don't even have the courtesy on their own to read my 2.206s and transcripts surrounding the VY and Peach Bottom seals. These Allegation idiots have in their documents I make a recent allegation by phone about VY seals again and they are the ones who made the VY inspectors call me without going though the Allegation process.

That is another more specfic information not disclosed in the VY LERs or inspection reports...the 400 degree vitol seals.

We should go through the VY seal LER and update, then contrast what got in the NRC inspector report and then what came out in the NRC inspectors meeting with me. We should then discuss what should have been disclosed in LERs and further inspection reports. As far as i am concerned, the inspectors at both plants should be on the phone bridge. We should go over it point by point and not have any other commitment to rush anyone, until everything is completely hashed out. We should do the same thing with the Peach Bottom LER.

Again, we don't have public participation with the NRC and utilities around our homes, unless all the aspects of the problem is out in the public arena.


Mr. Mulligan:
I have been unable to contact the appropriate NRC technical staff, for a telephone call with you. I will contact you when I know more.
Sorry for the late information.
Ron Schmitt


From: "Schmitt, Ronald"
To: "Michael Mulligan ("
Cc: "James, Lois"
Sent: Thursday, March 22, 2012 8:33 AM
Subject: Time to discuss your concerns (RE: Quality Assurance program at Target Rock)

Dear Mr. Mulligan:
This email is in regards to your email that you sent to Mr. John Hughey, of the U.S. Nuclear Regulatory Commission (NRC) on March 17, 2012. In your email, you expressed concerns regarding the Quality Assurance program at Target Rock, as a result of failed safety relief valves at Vermont Yankee, Pilgrim and Peach Bottom nuclear power plants.
We would like to set up a call with you so that our staff can ask additional questions to better understand your concern.

Please respond to this email with some days and times that are convenient for you so that I can schedule the call.
Thank you for informing us of your concern. If you have any questions, please contact me or Ms. Lois James at .
Ronald V. Schmitt
Office Allegation Coordinator
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission

Pilgrim's failed Target Rock SRV
Licensee Event Report 2011-007-00: Safety Relief Valve leakage

So you get it, with the SRV threaded seals at VY and Peach Bottom they failed within the first cycle from degradation due to poor quality seals. Now at Pilgrim another SRV fails with months due to leakage and they blame poor pilot valve workmanship at Target Rock.

Sounds like systemic QA problems with Target Rock. I request a investigation of Target Rock and all similar safety valves.

I talked to your nice Peach Bottom inspectors over increasing the SRV's set inaccuracy from plus or minus 1% to plus or minus 3%. Does the NRC have any evidence that decreasing the margin of set point accuracy reduces the entry into applicable tech spec LCO. I see all the utilities have different guesses on what cause pilot valve bonding. Some say its oxygen or hydrogen that sets up bonding on the surfaces, others say its just bonding and they don't care. Others again say its outside insulation and temperatures that sets it up.

As far as the statement that increasing the relief valve testing set point inaccuracy will reduce entry into a LCO, I don't think that is true. The limited data I see indicates when you increase testing set point inaccuracy, you increase entry into a LCO in the long run.


October 1, 2011 through December 31 , 2011

 The inspectors selected the issues of safety relief valve (SRV) and automatic depressurization system (ADS) valve leakage and setpoint test failures as an inspection sample for in-depth review to assess the corrective actions taken by Entergy to address these long-standing issues. Entergy's corrective actions included replacing the four ADS valves and the two safety relief valves with a Target Rock three-stage relief valve design, increasing the capacity of the two safety relief valves, and amending the license to allow for a set-point pressure band of +/- 3%. Additionally, the new valves were equipped with multiple leak detection temperature indicators.

The inspectors reviewed procedures, condition reports, engineering evaluations, modification packages, post maintenance testing, and license amendment correspondence, and interviewed plant personnel to assess Entergy's problem identification, evaluation, and corrective action effectiveness with respect to SRV and ADS valve leakage and set-point drift. Additionally, the inspectors reviewed the technical specifications and UFSAR to assess the change to the relief valves with respect to design and licensing bases requirements. Documents reviewed are listed in the attachment. Findinqs and Observations

Findinqs and Observations
No findings were identified.

The ADS valves and SRVs were originally a two-stage Target Rock-type design, consisting of a pilot-stage assembly and a main-stage assembly. Industry Operating Experience had shown that two-stage Target Rock relief valves exhibited some amount of pilot-stage leakage during plant operation. Additionally, the technical specification allowed valve setpoint pressure band was +/- 1%, which left little margin to maintain the valves operable in the event of valve leakage. As a result, SRV and ADS valve pilot stage leakage were challenges throughout the plant's operating history and caused several forced shutdowns.

The inspectors noted, based on nuclear industry operating experience, that the replacement of all the ADS and SRVs with the three-stage Target Rock design was a significant positive step in reducing the likelihood of relief valve seat leakage.

Additionally, the inspectors noted Entergy's evaluation of an expanded relief valve setpoint pressure band and subsequent license amendment have resulted in significantly more operating margin for the plant in the event that a valve does exhibit signs of leakage. Finally, the inspectors determined the addition of several temperature monitoring points on the valve would allow Entergy to more effectively evaluate the operability of the valve should any leakage occur.

Monday, March 26, 2012

Mike Mulligan's US Government Renaissance

First published as comments in the NYT's in: The Nurture of Nuclear Power

I always thought the problem with nuclear power was ideology not technology. The dominant control ideology of the industry has been increasingly the hard right wing conservatives and this ideology is dominant at every plant. There are very few democrats at any of these plants and certainly even less as you go up the management ranks.

The model has defaulted into a autocratic and a decentralized form...every plant is a one off. We serve profits and self interest, and not the greater good of our nation.

The true benefits of nuclear industry has never been shown. I propose a government take-over of the 25 Fukushima plants in the USA. As a national security issue, we should replace those plants with brand new identical models. Lets begin another grand experiment. They would be large plants and centrally controlled in the initial construction and early operation phase. Imagine the efficiency if these plants were built to one set of codes from both the regulator and the designer/builder stand point. It should be a government controlled and modeled like the TVA project.

What if we woke up one day and we discovered government could be more efficient and 'just' than any corporation...or at least could complete with them.

President Obama could say these plants are a dire threat to the USA and the only way out is to replace them. We just about got negative interest rates with QE2 and why couldn't we come up with a revolutionary borrowing mechanism. It would be a giant jobs and public works project. It would split the Republicans this fall and who knows the size of the political coalition we could create for the nation?

There is more value than the traditional economic benefits than cheap and reliable electricity over a project like this. We should value a project like this for how much advanced education and advance managerial experience it drives into our nation. How much advanced intellectual experienced it drives into all the employees who are associated with this voyage. This is, and always was, the real wealth of our nation!

Wednesday, March 21, 2012

An Unforgettable Night - ATC Operator Event at Palisades

There are a lot of these CRDM seal shutdowns at Palisades. No other plant in the nation has these kinds on troubles. These complex seal repair shutdowns have been involved with unpredictable interactions and incidences.

A initial plant design defect that is not corrected is driving enormous complicity into the control room and their employees are being overwhelmed by it.

I told the NRC this was a very important event for the industry and there should have been reports to the industry about what went on this night a Palisades. What nobody can get away from, the agency doesn't have the capability to capture events in such detail as this employee did.

This event occurred on Oct 23, 2010 and Palisades has had another seal shutdown on Jan of this year. We got to see this letter for the first time this March 8 2012.

I believe the event was entered into the Palisades ROP as a question of why did one of their employees leave the control room. Nobody has yet answered why were they winging this vacuum fill procedure, why did they lose reactor water level for a period of time worrying about vortexing and why did they allow so many distraction going on while they were manipulating core water level during a high risk alignment of the plant.

An Unforgettable Night - ATC Operator Event at Palisades

On the early morning of October 23, 2010, I left the ‘at the controls’ area of Palisades nuclear plant without a proper relief or turnover. Up until that time, I had always considered myself to be a very conscientious and safe operator. I never imagined that I would leave the control room without a proper turnover – but I did. I hope by writing this article, others can learn from my mistakes and avoid making the same or any similar mistake. With that objective, this article describes the events that led to my actions, the effect this event has had on me, the lessons I have learned, and my experiences with the NRC investigative and enforcement processes.

Description of Events
Palisades was nearing the end of a refueling outage, which was on course to be our most successful ever due to the short duration and large number of major projects completed. We were about to enter our third reduced inventory period to perform a vacuum fill operation.

This vacuum fill procedure was relatively new for Palisades, having successfully

performed it for the first time during the previous refueling outage. It is a procedure to lower the water level in the reactor to the middle of the hot leg, and then draw a vacuum on the Primary Coolant System (PCS) to evacuate air and other non-condensable gasses. We devised this procedure in an effort to improve plant reliability—specifically to extend the life of our control rod drive mechanism pressure boundary seals.


During the brief, I mentioned that during my turnover briefing, I heard that the reactor head did not have a vent path.

We lined up the drain path and commenced, but the PCS level indications did not respond as expected and we stopped the drain.

During this period, we had Auxiliary (non-licensed) Operators (AO's) troubleshoot the problem by verifying level glass and vent path lineups.

Concurrent with the PCS drain, most of the control room staff was at the Infrequently Performed Test and Evolutions (IPTE) brief for the vacuum fill work.

While this occurred, we had more issues with the EHC system; a reactor operator called the control room and stated he was not sure we had a good EHC flow path.

I felt this was a problem that required reviewing the prints and was too distracting with the PCS drain taking place while in reduced inventory, so I handed off the call to a different operator.

I told a Senior Reactor Operator that we were having issues with the EHC system, but he was busy overseeing the PCS drain.

A few moments later, however, the EHC low level alarm came in.

Several minutes later, the low level alarm was still not clear and I was concerned about a possible leak, so I secured the pump. I quickly heard back that there was a spill...

Consequently, they requested that the pump be placed in service for their vendor work, stating the cooling and flow path issues were solved.

This was all happening while the PCS level indication troubleshooting was in progress.

Eventually, Maintenance workers removed some temporary flange covers on the reactor head for a better vent path.

The drain that we initially briefed to be about 17 minutes ended up taking over three hours.

After we got to mid-loop, I lowered shutdown cooling flow to about 3100 gpm, which was the high end of the vacuum fill requirements.

...commented that he did not like the pace I was making my adjustments.

The previous time we performed the vacuum fill procedure, it worked flawlessly, but this time was different.

There was indication of a leak somewhere that was intermittently venting and allowing pressures to equalize throughout the system.

While Operator 1 and other members of the control room staff were troubleshooting the problems with vacuum fill, we received the low critical service water alarms and entered a procedure for "Loss of Service Water."

...the Control Room Supervisor (CRS) had to come down off the CRS’ “island” and speak with me directly to ensure effective communications during this very active period in the control room.

We soon learned that the work control center sent out a lube and stroke PM for the main lube oil service water isolations, and that was probably the cause of the low header pressure.

During the hold, I noticed the shutdown cooling flow rate had slowly started to trend down to 2900 gpm on its own and I voiced my concerns to the Control Room Supervisor. I showed him the one minute shutdown cooling flow rate trend on the Palisades Plant Computer (PPC), and said there may be some vortexing or other flow phenomenon that I did not understand.

He stated we could also enter the LCO, if necessary.

Suddenly, however, PCS level indication sharply fell to an elevation below the bottom of the hot leg.

As PCS pressure rose, the primary coolant level slowly recovered to an expected value and I received the order to raise the PCS level to exit reduced inventory.

By this time, it was early morning and we exited reduced inventory during SRO turnover.

Thursday, March 01, 2012

Byron Switchyard Insulator 2.206

So what would prevent all the defective switchyard insulators from breaking and shorting in a heavy storm, tornado or earthquake and then causing another LOOP...

The last LOOP at the plant was extraordenary, in that the plant was disconnected from grid for 31 hours. LOOPs are generially 1,2 to less than 4 hours duration.

March 20:

Exelon upgrades equipment at Byron nuclear plant

The Associated Press

BYRON, Ill. -- Exelon Energy says it has finished upgrading equipment at a northern Illinois nuclear plant where a power failure caused a reactor to shut down two months ago.
The company says it has replaced electrical insulators in the switchyards that help move power to and from the reactors at the Byron Generating Station, which is located about 95 miles northwest of Chicago.
In January, an insulator in Unit 2 switchyard failed and interrupted power, causing the reactor to automatically shut down as a precaution.
Insulators are protective equipment that helps regulate the flow of electricity. Exelon says Unit 1 was taken offline last week while upgrades were finished, and Unit 2 upgrades were finished over the weekend. Both units are back online at full power and generating electricity.

Read more here: