10 CFR 50.73(a)(2)(v)(D), Any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident.The NRC has said because of the nitrogen reservoir the valve actuator would still operate the valve in an accident, make the accumulator unessential. As I have asked them, what engineering testing and proof do they have that 200 degree actuator seal would survive 340 degrees temperature for the length of time. In the pedigree of these actuators, it has to state this component is qualified for for the DBA accident.
We don't know how many plants in the USA can't survive a Fukushima event and they would fail extremely early in a design bases accident with defective components that was accepted like this by the agency. And make no case about the NRC, they never addressed the 10 CFR 50.73(a)(2)(v)(D implications of this. And any NRC official should have recognized the CFR implication of the VY and Peach Bottom seal problem and should have directly addressed it. There is a tremendous amount of money involved in this and it directly challenges the credibility of the NRC. As I said, because this constitutes a potential NRC cover-up and wrong doing by the agency...the official I talk to was forced to flip it into a allegation. I did not want him to do that because it might effect a future 2.206. The NRC resident did tell me I had a legitimate issue with this that is beyond his control. This isn't a resident inspector level issue! Remember, he told me the Peach Bottom issue had far ranging ramifications for the agency.
This asks everyone do I have to state or write a perfectly correct technical phrase that is never attainable before the agency is forced to act. I found it suspicious as hell why the inspector repeatedly told me I had wide spread ramifications to the agency over this. I am pissed that the agency never in writing gave me any credit for prompting the agency.
I feel the agency was acting suspicious with me within their communication with me. It was like, you sure you can swallow the results of what we said. It is like nobody in the agency can suggest a different wording on the record to me that will get the agency in trouble...cause there will be an implication to their career if it gets on the record.
"While performing an extent of condition review associate with the adequacy of air operated equipment inside containment to withstand containment main steam line break (MSLB) and loss of coolant accident (LOCA)temperatures, it was discovered that valves HCV-238 ( Reactor Coolant System (RCS) Loop 1a Charging Line Stop Valve), HCV-239 (RCS Loop 2a Charging Line Stop Valve), and HCV-240 (Pressurizer RC-4 Auxiliary Spray Inlet Valve) have nitrile based elastomers for the air filter regulator and actuator and may not be able to withstand Containment MSLB and LOCA temperatures. The design temperature limit for the nitrile elastomers used in the valves is 180°F which is acceptable for the normal operating conditions inside Containment of 120°F. However, during the MSLB and LOCA accident the temperature inside Containment is analyzed to reach 370°F. Since these valves have both open and close functions supported by an air accumulator, failure of the nitrile based elastomers could prevent the valves from fulfilling their intended safety function."Oct 5: Basically Lara and inspector interrogated me with who am I and what group do I represent. They insulted me by accusing me of being from the media. I just told them I am Mike Mulligan in Hinsdale NH...I am a skilled safety advocate with tremendous NRC access.
I just can't find the key where they will give me access to Fort Calhoun resident inspectors.
They spun me up with these mechanical hurdles that would get me nowhere...I was spiting mad with this mindless bureaucratic bullshit just before they hung up on me or threatening they were going to hang up with me.
Mr Drinks,
The Popperville Town Hall
A follow up to my phone call messages I recorded on OCT 5...
You and me have tangled over at Region III or earlier at Region I...
Like I said, I could throw 2.206s at region IV if I wanted to...
So I wanted to talk to the Fort Calhoun inspector about the environmentally unqualified containment valve actuators.Region IV is a mess with Fort Calhoun and San Onofre....the investigation with intimation by the region IV staff with their boss. You know, Brown Ferry, Palisades, VY and Peach Bottom, the agency almost allows me to talk at will with their senior staffs and the resident inspectors.I just call up the resident inspector for a talk and it happens. I spend a lot of time criticizing the agency. I tell everyone it is absolutely amazing the contact time the agency allows me with resident inspector programs. I make a big deal how good these inspectors are to the one.
So I call up the Calhoun inspector...he tells me he is not busy. I explain the LER and the reason why. He says he can't remember the LER...I tell him all the Region I, II and III inspectors almost got a photographic memory to the one...the Peach Bottom resident really on a cold call was very familiar the Fort Calhoun actuator LER. I am always astonished with the professionalism with the northeastern residents...how they keep up with the issues and their ability to cold talk with me. The VY resident knew my name, most of them others too...he blew my socks off with the detailed knowledge he had about the service water system, service water, Diesel Generator and Loss of off-site power accident procedure issues. We had a hour conversation. My task for VY politically that day by my handlers was a test to see just how accessible the VY residents were to the community. They got an A plus from me that day. I talked to the Peach Bottom senior resident about their SRV issue just days ago for 45 minutes with a cold call.
I have big issues with Peach Bottom, Browns Ferry, VY, Palisades and how the agency regulates these guys. What I am astonished with is the access the little guy has with the resident program in region I, II and III. They have spoiled the hell out of me. At some level I respect the hell out of them for this even in my disagreements.
So the Fort Calhoun Resident blew me off with "I am unfamiliar with a LER in my plant"...you have to call Lara Uselding to get me to talk. Lara was bemused why the inspector would make me call her. She questioned me why somebody from NH would call Region IV. She told me to throw me a e-mail with What I wanted...I told her I am sick and tired of the decency of women with not giving me a call back when I call. I felt she again was going to throw me in the trash can.
I massively overloaded her in technical talk in one minute and she admitted this sounded like technical talk way above her head. I left a message on her phone the day before... and she couldn't even call me back in a timely manner. She told me she is headed for another plane ride, I told her I heard that often from you kind of guys...region IV is overloaded and overwhelm with their troubles.
The thing I would do is retire or lay off Dricks...never mind wipe out all the region IV staff through firings, transfers or retirements because they don't know how to communicate with the good public...
Thanks,
Mike Mulligan
Hinsdale, NH
The NRC inspectors said they have had far reaching discussions on a nation level over my issue at Peach Bottom but they kept it secret from me.So generically now I have to ask...what is the magnitude nation wide with allowing extremely inadequate environmental qualification of nuclear safety components in containment. Basically they have been allowed to operate outside licencing bases and safety studies.
So generally the Peach Bottom actuators and Vermont Yankee safety actuators in containment are designed for that 200 degrees temperature...but containment temps are expected to be 370 degrees in accidents...it should be noted VY shifted to new material that is qualified for 400 degrees...so how can Peach Bottom be safe.
340 degrees for BWRs and I verified PB actuators are in the 180 degree range for the seals...
John.Hughey@nrc.gov
Peach Bottom SRV seal notes
Emergency shutdown of Peach Bottom over SRV Seals
Fort Calhoun containment actuator valves
Emergency shutdown of Peach Bottom over SRV Seals
Fort Calhoun containment actuator valves
"The design temperature limit for the nitrile elastomers used in the valves is 180°F which is acceptable for the normal operating conditions inside Containment of 120°F. However, during the MSLB and LOCA accident the temperature inside Containment is analyzed to reach 370°F. Since these valves have both open and close functions supported by an air accumulator, failure of the nitrile based elastomers could prevent the valves from fulfilling their intended safety function."
Michele G. Evans, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
No comments:
Post a Comment