Palisades safety Refueling Water tanks 2.206 (rev 1)

　

June 21, 2012: Request Emergency Palisades Shutdown

My old Feb 22, 2011 2.206, actually dating back to 2010. "God help us all, can you see the problem with the repetitive nature of Entergy having the instincts to not the due proper inspections... to do it over and over again like a madman. They are laughing at us and the
NRC because these employees and managers know we can't control them. The NRC has no ability to control Palisades...that is my god damned political statement to the NRC."
(Note I edited this for easier reading and corrected some errors on June 27, 2012)


June 18, 201


R. William Borchardt
Executive Director for Operations
US Nuclear Regulatory Commission
Washington, DC 20555-0001

　

　

Dear Mr. Borchardt,

The Poppersville Town Hall
Request Emergency Palisades Shutdown (Jan 10, 2012)
 
Request Emergency Palisades shutdown (June 18, 2012)


Feb 22, 2011 and Jan 10, 2012 2.206:   
“Subject 2.206: Request a emergency shutdown of Palisades because the Reactor Oversight Program is ineffective and Entergy has a documented history of a culture of falsification and thumbing their noses at reoccurring violations. It should be noted in this inspection period most of the fleet of Entergy’s plants are on fire and burning in the Gulf of Mexico with numerous NRC inspection findings including Grand Gulf, River Bend, Arkansas One and Cooper. And we sit in the shadow the River Bend’s troublesome plant trip and the restart, then the subsequent shutdown with three leaking safety relief valves and Augment Inspection Team. How can you say there are not systemic problems with Entergy? You had a short in a motor, then the first safety breaker and relay failed to stop the fault. It was a cascade effect and other pieces of equipment were affected. Is it just me with the nuclear industry, there has been a rash of recent electrical equipment and switchgear faults and shorts, and the first safety breakers and relays fails to operate and stop the massive short. If you want my opinion, the wires and electrical (switchgear, breakers and safety devices) will lead to a limiting accident before the pipes do. In truly Palisades nuclear plant biblical proportion, the last River Bend’s NRC inspection uncovered nine violation. Theses guys are riddled with similar violation throughout the year as their brother plant Palisades is. This is a systemic problem with Entergy and the NRC doesn’t have the power to control it before this company damages the nuclear industry.

Now we got repetitive electrical shorts in the VY Recirc MGs and heavy smoke in the reactor building. Chances are the vender that made motor is out of business or this line of component they don’t make anymore. These guys are struggling to get people who really know what they are doing to repair or replace this gear. Chances are the new replacement and repair parts stream is dead and they are paying engineering firms to reverse engineer these components like we were the third world. This is a huge crisis in these aging plants. The whole technological and scientific world has passed by these ancient archeological artifact...

Got a assortment of states desperately trying to shutdown Entergy’s nuclear plants because nobody trust these guys. Unbelievable union troubles at the Pilgrim nuclear plant and rumors the union employees have sabotaged the plant by tripping it in a union action, while the state of Massachusetts is trying to put hold on their relicencing. Massachusetts and Vermont are more persistent than me. It is a double hitter going on over there is New York

The NRC is probably going to call the leaking Safety Injection Refueling Water tank (SIRW) shutdown a planned shutdown. Seeing how for a indeterminate amount of time, certainly before the last outage, they knew the tank was leaking and did nothing. They didn’t care the leaking 300,000 gal tank sits above the control room with all the invaluable instrumentation and all those electrical cables.Palisades: And only god knows where they were collecting the allowable leakage that they didn’t know where it was coming from and what it was running down on. Were they measuring all the leakage? I can imagine this tank failing with the water filling up the control room and suffocating all control room operators.

They had a opportunity to drain it and fix it in the safety of a shutdown outage. This was a totally preventable and unnecessary shutdown. A rash of planned and not planned shutdowns and plant trips prematurely wears out a lot of equipment in a nuclear plant. This leads to the risk of more shutdowns and drives bad accidents. Ask Palisades about this overcome. This is a indication Entergy doesn’t know how to run a plant and maintain it. I request the NRC characterize this as a unplanned shutdown because of how egregiously not conservative it has been.

So this is the record going into the last outage and the red finding:  
“Palisades had five unplanned shutdowns in 2011. Because of that the power plant now has one of the worst safety ratings in the country.”
NRC concerns:

Organizational failures
The need for a recovery plan
Poor quality work instructions
Failure to follow procedures
Poor supervision and oversight of work
Poor maintenance
Failure to respect the role of an operator
Multiple events caused by personnel or equipment failures
Questionable safety structure
Language As a Technology of Exclusivity and Special Rules

I framed it as the NRC engineer’s language picks and chooses what issues they bring to the public table and it is immoral. They create a architecture of engineering half truths and misconceptions in the language structure they make to a community. Vermont, Massachusetts and New York don’t think the NRC has the ability to control chaos at a plant. They always got some agency rule trap door leading to all bad behavior is acceptable and nothing ever matters at a nuclear power plant. As long as the public can’t see the bad behavior mean nothing is ever wrong. A structure of selective self interested truths and thus the whole building becomes one enormous inscrutable lie. It’s the history of this industry to tell half truths in defense of self interest and in their perception of doing good. It is how you think you are doing good, then end up destroying 100,000s of jobs and damaging a great nation in the ends of altruism. These guys invented the corporate and government crazy talk phraseology of the 1970’s and 1980’s.

I have seen this over and over again where the agency uses a special language and a assortment of language rules and engineering rules, supposedly engineer’s speak, as a intentioned tool of understanding disruption and public knowledge sabotage. These guys are a cohesive mafia honor culture of half truths and it always ends up as the nuclear industry repetitively shooting themselves in the foot. The industry is sabotage their employee’s future for ideology and profits to special people.

This is primarily a crisis of truth telling and the US government doesn’t have a vehicle that demands on severe penalty truth telling. This is a age old crisis on just “what is truth”?
A NRC official recently spoke of a engineer’s language.
Me: “ As I spoken, it my feeling that the NRC engineer's language...picks and chooses engineering rationales and issues...indeed picks specific terms of a petitioner to meet a NRC agenda. What is going on is not pure science, it's mocking science and the public process. I am not talking about you, you were a nice guy trying to listen to me...but as the agency talks to me. I have no beef with you.
See I think NRC answers me in a benign and selective way...they answer me with a engineered interpretation of my words that favors the industry or NRC, not in the most unfavorable interpretation of what I am saying against the utility and NRC. I think this is on purpose and it may be the way they are trained to make a response. They could always called me to quiz a point I am really making.

So they expect me to challenge them further down the line with a come back. It is playing games hoping I will lack the initiative to answer them back.

It is just not being straight and direct...it is a form of coercion and corruption.
The official: “You expressed that the material facts of the seal (the temperature duration in radiation for example) had not been established through testing. Therefore, the NRC staff could not prove to you that the Buna-N threaded seal material is adequate for accident conditions as well as normal operating conditions. You also expressed that you felt that the NRC staff’s safety determination was merely “throwing engineering language” at you instead of addressing your concerns.”
Gaming Language: when did the SIRW tank begin leaking?

Here is a prime example of the engineer’s language. And I will tell you something, there is no engineer’s professional ethical code or legal requirement for these officials to tell the full and complete truth in the media. There is no ethical code requiring the nuclear officials to tell the full truth to the public. These official don’t have a moral code in them, in their heads...that complete truth telling has a benefit to our nation. There is a bogus permissive for “competitive or propriety reasons” nothing ever should be disclosed without a huge fight to the public. They basically filter their story through a series of unseen code and immoral acceptable rules where the final story we see is almost a complete fabrication. As along as the story filters through a set of official rules and unseen group codes and customs , they have faith the outcome is a god given truth. They can’t see how ridicules the product of their rules has become. There is no law to hold these official accountable to the truth said in the media. And there is very little law that holds them accountable in legal documents. Certainly there is no consequences for lying. These are public news announcements.
Published: Thursday, June 14, 2012, 6:15 AM
The NRC was made aware of the leak in April when the plant shut down for refueling. Both Entergy and NRC inspectors monitored the leak. The plant set a limit that if more than 31 gallons leaked in a day, the plant would shut down, Mitlyng said. The plant's license specifies that no more than 34.8 gallons leak a day.

According to a news release from an Entergy spokesman, workers had been monitoring leakage from the plant's safety injection/refueling water tank for several days. but by 1:41 p.m. Tuesday, the leakage had surpassed the limits they set so the tank was declared inoperative.


Palisades nuclear power plant shuts down to fix water leak
10:44am June 14 Mark Savage is a spokesperson for Entergy, the company that owns the Palisades plant. He says this tank has been leaking for several weeks. It’s an old aluminum tank that holds 300,000 gallons of water. He says the tank is the same age as the Palisades plant: 40 years old.How come Entergy’s Mr. Savage isn’t required to give all the factual information...how come in the shadow of the red findings they didn’t disclose when this leak began and the location of the tank? How come as a matter of community honor Mr. Savage didn’t initially disclose we got a leak in these tanks...what do you think if we ignore it and started up? What do you think if we ran it to the tech spec limit? What do you think of us if the unknown crack and leak was getting bigger...we said it would months until we are required to shutdown and find out what is leaking?     
Event Number: 48018
The licensee believes that the tank is leaking from several locations. However, at this time, they cannot determine exact locations.
The Fallacy of Risk Based (regulation) Plant Operations

The best defense for safety for the plant is to have adequate safety margins “as the designers intended the plant to be”. And the first nuclear safety culture precept in any deficiency in safety plant design is you fully understand what is causing the barrier degradation. You can’t tell how bad the crack is until you eyeball it for yourself. Imagine that, there is no law requiring them know where a leak is? Engineering says for critical safety public interest, you fully understand the magnitude of the degradation and what is causing a leak. How can you tell the difference between a insignificant leak and another insignificant leak, but the second insignificant leak is showing the potential for a catastrophic break? A leak of unknown engineering dimensions, a leaking rate of 10, 20 and 30 gals per day....the leak gives an engineer extremely limited information.

Davis Besse once had a safety insignificant safety leak and the information entrained with this increasing insignificant leak brought the nation to within 1/8 of a inch nuclear crisis. They were diligently measuring its increasing leakage rate, as a unimaginable hole ate inches of metal away from a reactor head. They tripped over the leak while shutdown, that is how they caught it?

Right, it is how men make self interested rules based on personal advantage on how to interpret new information. We are lucky there is more a female presence in this industry. It is not requiring a human to use his full astonishing mental capacities to interpret new information. You see the how risk related regulation allows the facility to make a safety determination based on very limited information? It gives the operators of a nuclear plant a permissive to act stupid for mere pennies. This 300,000 gal tank has very small 35 gal a day leak and it gives Entergy the permissive to not care why it is broken. You could have a minor earthquake, and there could be a degradation in the tank wall in which the whole tank spills into the bottom of the building. In nuclear power plant, there is many more safety angles other than just having enough water to cool a core. You might plenty of water, but not a way to get it to the core. You see what I am saying, risk regulations allows them to base safety on just a fragment of information. A 300,000 gal tank:
It would take you 42 days to fill up this tank by a garden hose.
It is 15 average size swimming pools of water in the bottom of the reactor building or within the control room...And then the size of the leak was increasing over months. It means some worsening process was ongoing and nobody thoroughly understood what the process was. Risk regulations is the permissive to make me think stupid and act in my own interest! None of this is nuclear safety! Those concepts of blowing by the initial engineered safety tank design margins and not knowing what caused a tank leakage is a threat to the conservative safety assumption and actions country wide. It not what you know that kills you (leakage rate) in Davis Besse, it is the unknowns the leakage is telegraphing you. This tank feeds all of the emergency make water for this nuclear reactor: high, medium and low pressure feed. It bad enough the utility doesn’t know right from wrong...but this is a grave principle of conservative nuclear safety that the agency doesn’t know right from wrong. As for the acceptance of a assurance on a Safety Injection Refueling tank leak with such a worsening indeterminate leakage and carrying so little factual information by Entergy, are there any real engineer’s with a moral conscience voice left in the NRC? Does the agency know how important missing information and selective data is with knowing and understanding safety? It is not the information and evidence you can see with your eyes...it is the missing information and evidence that is the killer.

Does risk perspectives make curiously, facts and evidence obsolete?
NRC concerns:
Organizational failures
The need for a recovery plan
Poor quality work instructions
Failure to follow procedures
Poor supervision and oversight of work
Poor maintenance
Failure to respect the role of an operator
Multiple events caused by personnel or equipment failures
Questionable safety structure   I always thought the ROP punishment for a utility’s bad behavior was to appease the wider public. It is to shallowly make the public feel better about nuclear power instead of making the industry better. It is to create a smoke screen to make the public think grand changes are underway for a bad utility. But it has no or little effect at changing utility bad behavior. Here is the absolute evidence just months away from a rare red finding. The ROP is just for show. Here is what the NRC thought of Entergy this past Feb in their red finding.   Feb 2012 IR 2012005
For conservative assumptions, the inspectors reviewed the Apparent Cause Evaluation(ACE), corrective action documentation, the recovery plan and NRC inspection findings. The licensee determined that the apparent cause was managers making decisions based on meeting only minimum regulatory requirements. The inspectors concluded that based on the findings reviewed by the licensee, the licensee identified a reasonable apparent cause. However, the inspectors believe that the recovery plan elements related to address leadership engagement, correction of performance gaps and degradation of safety culture principles more accurately characterize the causes of the findings. In addition, the recovery plan includes broader actions that will more likely effect change. The ACE actions included training of supervisors on conservative decision making. While this is a reasonable step in eliminating the cross-cutting theme, management reinforcement of conservative decision making is necessary to achieve sustainable results. While the ACE corrective actions capture this through an observation form, the broader elements of the recovery provide a mechanism more likely to achieve sustainable results.So here we are in a preventable shutdown. From the beginning before the outage Entergy knew they had a unknown defect in the Safety Injection Refueling tank with a increasing leakage rate. They had a conservative opportunity to completely understand the nature of the leakage and repair it before the startup. It is right out of the mouths of the Entergy officials before the red finding and all the plant troubles... now with the SIRW tanks accident. Its right out of the mouth of the NRC talking about Entergy’s problems...they continue “only” meeting the minimum regulatory requirements and making poor conservative decision after all this self flogging back whipping and crying crocodile tears. It is as if pretty words and promises in front of community made to a nation have no meaning at all. It is all for show! We are all in a reality TV show and nothing has meaning at all except customer ratings. They don’t even care if all they are drawing in their reality TV viewership is the losers in our society.

Yet, where was the conservative influence of the NRC on making Entergy eat there own words in another component degradation. In their own words, “stop just meeting only the minimum regulatory requirement”? How come NRC behaves like reality tv, where words and errant emotions have no meaning...where everything is a insignificant show. How come they don’t act like billions of dollars and our nation’s engineering reputation are at stake? How do you get them out of la la land...what will it take?

Does the agency put in credence in their own NRC inspection report words that condemned Entergy with only meeting minimum regulatory requirement, engagement of performance gaps and degradation of safety principles? Does the agency’s own words have any meaning at all and do they perform any organization force on maintaining safety principles in the whole of the nuclear industry? If congress or the president told the NRC to rob a bank or destroy the nuclear industry through a set of self serving rules...are the plant NRC inspector obliged on pain of the law to rob a bank or destroy their nuclear plants through indifference? Are promises to keep to a community and inspection report words, just meaningless noises in the breeze? Is this reality tv disconnected from meaning? NRC concerns:
Organizational failures
The need for a recovery plan
Poor quality work instructions
Failure to follow procedures
Poor supervision and oversight of work
Poor maintenance
Failure to respect the role of an operator
Multiple events caused by personnel or equipment failures
Questionable safety structure   All of the nuclear safety principles the NRC has been espousing in the shadow of Palisades bad behavior post red finding should have drove the agency to make Entergy fully engineering wise understand the Safety Injection Refueling tank leak before start-up and bring that tank back to the initial plant safety design at earliest shutdown opportunity. The agency’s correct ‘inspection’ and red findings words to Entergy now condemn the agency itself. The agency’ s nuclear industry philosophy are a disgrace to the world of nuclear power safety principles itself. The first principle to the community should have been to notify the public that the tank was leaking from a unknown location and the leakage rate was increasing, yet still meeting its tech spec limit from the moment it began leaking. In the shadow of one of the worst plants in the nation and a red finding, why does this information only show up in a emergency shutdown. A conservative assumption based on the location of the tank, the leak rate is ramping up in a spike for unknown reasons...they should have scrammed the plant.  They should have admitted the 300,000 leaking tank sat on top of the vital control room. The agency should have asked the public what they thought about this condition when the leak first showed up. That is public participation. The first principle should have been complete truth and full disclosur to the public in the shadow of the 4^th worst operating plant in the nation. I certainly would have requested a immediate shutdown and repair of this tank from the moment the tank began leaking (sorry, I missed in the inspection reports). It is beyond preposterous public credibility-wise in the shadow of Fukushima, that the agency didn’t admit the core cooling and make up tank was leaking and the utility didn’t know where and the extent of the damage till it directly challenge tech specs. Palisades and NRC secrecy facilitated the operation of a not safe nuclear power plant.  In the shadow of Fukushima and the 4^th most dangerous plant in the USA, should the agency be creating more plant operating super secrecy or more transparency?Does the agency know right from wrong? Does the agency’s words of criticism to a poorly performing plant have any order creating meaning at all? Or are they just altruistic pretty words broadcasted to the public without any internal backing what so ever.

So here I am giving two week warning on May 30 predicting based on the past behavior of Entergy that a controversial plant trip or a unplanned shutdown (June 12) was right around the corner. Congratulation Entergy that was a pathetic 34 days of continuous plant operation. Doesn’t that question how many shutdowns and plant trips they will have in the next cycle.Palisades nuclear plant trip?’
“I smell a troublesome plant trip in the air....”
“Come on, admit it? Is this the grand NRC “nothing ever matters” philosophy on leaking nuclear reactor safety system water leakage stated by a agency official? Does all that we know about accident warnings and precursors boil down to all nuclear plants are able to operate when some parts that are leaking? Does the NRC just act like reality TV thinking the viewer aren’t real...the community out there is fake...the world has no meaning and consequences at all?

And we sit in the shadow of another NRC disgrace in San Onofre. The new steam generators didn’t meet their original design specification. Who cares if nuclear components are always leaking and nobody is required to meet original design specification until a terrible accident shows up costing the ratepayers and our nation billions. Who cares, it acceptable in our rules, our rules are the primacy in our safety philosophy. Our rules are our god and our god is unanswerable to all outsiders. Right, it all a reality TV show and nothing matters or has consequences. We are all protected because everything is fake.

Who cares about if all or some reactor safety parts are leaking...who cares if the computer safety engineering codes don’t meet original design specification? And she misrepresented it cause the leak has been getting bigger and nobody understood why and how it was leaking. There is not a higher safety principle in engineering than in fully understanding what is going on in a nuclear plant. I know what is going on with my indications and I can confidently predict the outcome of all my indications...no guess work and rolling the dice in this industry. Is this really the safety philosophy of the NRC?   Nuclear plants are able to operate when some parts are leaking. "There is always some kind of leakage going on," Mitlyng said. "As long as it's very small and doesn't get bigger." Here is an emergent problem Palisades didn’t handle correctly in the recent past. It lead to a very serious plant accident and out of control plant trip. It set up a pattern of operational risk taking leading to risking human life trying to keep the plant operating when maintenance work wasn’t done right and safety equipment wasn’t installed as originally designed. There are many other serious problems and this led to being one of the worst operating plants in the USA. Basically they had a so called minor indication of a failed equipment warning light that they put off at fixing when the plant was in safe shutdown condition. Does it sound familiar? This minor lamp defect led directly to a grossly botched installation of new breakers replacing obsolete breakers to a back up DC emergency electrical system. Honestly, talking about safety budgets and priorities...risk perspective...what proof do you got that insignificant problem won’t lead to a enormously mind boggling problem. There it is, that insignificant problems lead directly to a incompetent nuclear operator and big national problems. Here is the case that a perceived insignificant problem led to a degradation to the life blood of emergency electrical power to many nuclear plant safety devices. And with the Safety Injection Refueling Water tank leak of unknown location and degradation mechanism, the chances they take just get bigger and bigger. What is wrong with you, our rules allows this? Our rules are your god!

Buddy, in a nuclear plant all priorities and budgets are immoral. You never know all the risk until you get down to the bottom of the rat hole...a sterile computer model is never as smart as our brains and computers senses are not hard wired to the real world like ours. They found grave maintenance errors in the installation of this important safety gear while at power and they didn’t have the integrity to immediately shutdown the plant and fix it at a safe shut condition. The DC electricity plant trip and the leaking Safety Injection Refueling Water tank is the exact same issue derived from only meeting the minimum regulatory requirement. Rules carry so little information and our human brains can process so much information...our brains are so smart at discriminating important information from insignificant information. We do it much better than some blind and stupid rule. But what can you do if a rule gives us all the permissive to act stupid...

In Palisades words, this was a really insignificant lamp problem with the Fukushima emergency electricity system. I’ll makes the case insignificant lamp problem carried all the information about the up coming DC accident.“Prior to the 2010 refueling outage 1R21, routine preventive maintenance performed per work order WO52025543-01 identified that the green status indication lights for the containment escape air lock MZ-50 were not working. Although CR-PLP-2010-3580 and work request WR210717 were issued at the time, this condition was not addressed until the troubleshooting activities scheduled for Thursday 09/22/11 under WO248834-01 In the NRC’s words, this was all thought of as a insignificant problem until seen from the light of the history made from the DC bus plant trip. Did I once say it, all catastrophes emerge from inaccurately perceived insignificant problems.During Refueling Outage (RFO) 21 in the fall of 2010, the licensee performed extensive maintenance on Panel D11-2, which included the replacement of 10 breakers inside the panel, as well as other maintenance activities. Any performance deficiencies associated with the maintenance conducted during RFO 21, which led to the instrument air transient that occurred on September 23, 2011, will be addressed in the fourth quarter NRC Integrated Inspection Report (IR) (05000255/2011005). On Thursday, September 22, 2011, the licensee commenced a WO to troubleshoot the inoperative green indicating lights for Door MZ-50 (Emergency Airlock Lights). Through this investigation, all interlocks, indication lights, and limit switches for this door were found to be satisfactory. Since this door was due for its technical specification (TS) required surveillance test on Monday, September 26, 2011, the decision was made to conduct more troubleshooting activities to identify the cause of the indicating light issue. The Safety Injection Refueling Water tank leak is much worst than the DC system short. It is the exact same accident with the NRC and Entergy accepting for self interest reason incomplete information around a safety system defect or degradation. The crack rules allows us the permission to not fully investigation a safety system degradation because risk regulation is designed to make us stupid.

The point I am trying to make is Entergy and the NRC has a habit of getting indications that problems are developing and they define it as minor until they hear the zapping of a huge electrical short and this creates a troublesome plant tip with complications. Plants like Palisades have a lot of other secret known problems pop out the woodwork in a huge zapping short accident. You are pushing the capacities of good people with this unnecessary complexity.

It is the smoke and huge zapping spark from a large electrical short that frightens them that gets them thinking that little problem was bigger than I thought. It one thing to read about how powerful these energy sources are that are coiled up in a spring....it another thing all together to see exploded parts and melted metal after a accident. It beyond comprehension to see your buddies carted off in a stretcher to a ambulance.

All huge tragic accidents with body parts spued all over the place begin as insignificant problems that were ignored and approved by risk perspectives. They bury it in their bureaucratic maintenance document priority system for months and years. They wait until the last and worst possible moment in their work priority system, which drives the plant and employees into creating a grossly unprofessional plant transient. Of all the public back flagging over Entergy’s shameful red findings and poor behaviors over the last few years, in the last 6 months with both the agency and Palisades, now in shadowed of the SIRW leak, they act/acted as if they haven’t learned one lessen. The whole lot of them from our political system, to the Nuclear Regulatory Commission, to Entergy-Corp and all the human between them. I can make the case we are in a gigantic financial crisis in our electric utility system, the likes this nation have never seen before. The times demand we act and behave different than we have in the past!

They keep recklessly repeating the bad behavior over and over again no matter how much public back flogging they do to each other and the promises they make to the public and the community about changing their bad behaviors. As with a host of terribly poor utility’s behaviors like Entergy, Fort Calhoun, TVA and SCE; it is like the NRC is oblivious to their choices of not demanding a change in behavior from a bad utility. This is truly regulatory and NRC insanity. There are enormously costly consequences to our nation all around us right now. It is like the agency is running around utterly disconnected from the consequences of their choices and the outcomes of not being involved with controlling bad behaviors. The agency doesn’t understand cause and effect....or the agency doesn’t know how to drive effect.

Fed 22, 2011'It would know the conditions (dysfunction) of the managers and employees, we would know every error of a policy, the absence of a procedure, rule or organization attribute, know perfectly every defect in every component. We would have the perfect god’s eve view of the plant and the organization. Push the magic button, do we have a green, yellow or red light at Palisades, the NRC or Entergy?"  Request Palisades nuclear power plant and all Entergy nuclear power plants

be immediately shutdown.
NRC concerns:
Organizational failures
The need for a recovery plan
Poor quality work instructions
Failure to follow procedures
Poor supervision and oversight of work
Poor maintenance
Failure to respect the role of an operator
Multiple events caused by personnel or equipment failures
Questionable safety structure 1) That the Safety Injection Refueling Water tank shutdown be defined as a unplanned shutdown.

2) Request the NRC bump up the Palisades performance indication from red to the next level of V: Unacceptable Performance.

3) Request an outside authority, nobody trust the NRC’s OIG...why didn’t the agency force Palisades Entergy to thoroughly investigate SIRW leak when the leak first appeared. Why didn’t the NRC make them fix it in the last safe shutdown period according to the agency’s own nuclear safety culture philosophy.

4) Request top Palisades Management staff be fired and replaced before startup.

5) Request Entergy's corporate nuclear senior staff be fired and replaced before the restart of the plants.

6) Immediately request two addition NRC inspectors to be assigned to Palisades plant, and to all the rest of the troubled Entergy nuclear plants. There seems to be a few plants of the bunch that behave themselves.

7) Request the formation of a local public oversight panel around every plant.

8) Request a emergency NRC senior official oversight panel with the aims of reforming the ROP.

9) Request a national NRC oversight panel of outsiders to oversee and report on the agency's activities. There should be a mixture of professional academic people and capable lay people.

10) There continues to be some heavy duty and exceedingly numerous findings of problems with Entergy plants' this inspection reporting cycle...do an analysis of why this is occurring.

11) Request a evaluation if NRC region III has enough personnel and resources.

12) Stay shutdown or remain shutdown until all procedures are fully updated and corrected, all technical and maintenances backlogs are updated and corrected, all training completed, all reports and safety processes fully completed and implemented.

13) Request a independent outside investigation over the insufficient process outcome of the 2008-2009 Palisades security falsification, investigation, safety survey local and fleet wide training and safety surveys. Based on the DC root cause it appears the safety culture for many years has been grossly defective and ineffective, along with the ROP... with then all these processes failing to discover the true depth of Entergy's safety cultural problems and they lied about these processes fixing Entergy. It sounds like this is a generic problem to me. We are broadly worried about in 2009 over the Palisades security falsification, in the outcome of the violations, whether all the reports and employee cultural surveys with the assortment of NRC and Entergy processes over these very serious violation ever had any meaning at all. According to the Palisades Fukushima Emergency Power System DC short and plant trip, the most recent root cause Entergy admits there is deep and
widespread safety cultural problems at the Palisades plant. I feel Palisades safety culture was in the pits in 2009 and before... and the cultural safety survey was a grand Entergy and NRC falsification. The NRC Alternate Dispute Resolution secession over this, the Confirmatory Order, the Entergy investigative reports and safety cultural survey, the willing acceptance of this insanity by the NRC and Entergy created the inaccurate falsified impression to the outsiders that Entergy had discovered all the cultural safety problems and corrected them. Nothing could be farther from the truth, all these corporate and agency processes covered up and deepened, took the public's eyes off fixing Entergy... where Entergy now is in much worst condition than they were then. I request independent outside investigation on this dangerous agency corruption before Palisades start-up.

...And all Entergy’s and the NRC’s promises to the community post red finding and in community meetings has been found to be meaningless promises in the light of the Safety Injection Refueling Water tank leak. All of the ROP and NRC recent meeting about the troubles with the Palisades plant been a intentional a scam to deceive the public. The intent of this activity by both the NRC and Entergy has been to weaken the nuclear industry as a national security energy-electricity resource. 

 14) I request that President Obama fire Chairman Jazcko and the other Four Horsemen of the Apocalypse Commissioners! Oops, this has been completed.

　

Sincerely,


Mike Mulligan
Hinsdale, NH 03451
steamshovel2002@yahoo.com
1-603-336-8320