Vermont Yankee 2.206: Inaccurate Documents And Reports

So Vermont Yankee, Peach Bottom, Fort Calhoun sample valves and now the electrical cables not being  environmentally qualified...with a asleep NRC. 

Fort Calhoun:

The Nuclear Regulatory Commission sent Omaha Public Power District a notice in 1985 to replace Teflon as insulation in the building housing Fort Calhoun's reactor. The utility subsequently replaced it on wires that it considered at critical risk but left some in places it did not consider a safety concern. 

Commission spokeswoman Lara Uselding said her agency's oversight process relies on nuclear plant operators identifying and fixing problems while commission inspectors scrutinize that work. This system, she said, has not been successful at the Omaha plant."Historically at Fort Calhoun, that has not gone well and that is why they are currently under increased oversight," Uselding said.

So the NRC says accurate nuclear plant and NRC documents aren't nuclear safety related.


From: "Kim, James"
To: Michael Mulligan
Sent: Friday, December 21, 2012 12:08 PM
Subject: Vermont Yankee- 2.206 Petition on SRV LER
Mr. Mulligan,
Your petition dated December 5, 2012, was assigned to the Office of Nuclear Reactor Regulation (NRR) for review. My name is James Kim, the NRR project manager in the Division of Operating Reactor Licensing (DORL) and I have been assigned as a petition manager.
The NRR Petition Review Board (PRB) met on December 20, 2012, to consider your request for emergency shutdown of Vermont Yankee, because the NRC and Entergy can’t keep their nuclear safety paperwork and documents accurate and up to date. The PRB denied the request for immediate action because there was no immediate safety concern to plant, or to the health and safety of the public.
In accordance with the 10 CFR 2.206 process, the Petition Review Board (PRB) is offering you an opportunity to address the PRB to provide any additional explanation or support for the petition before the PRB makes an initial recommendation. Please let me know whether you would like to address the PRB.
Thanks
James Kim
Project Manager, DORL
U.S. Nuclear Regulatory Commission
301-415-4125
E-mail: james.kim@nrc.gov

Originally posted on Dec 4, 2012

Corrections

So why isn't there a NRC explanation with what happened here...why the secrecy?  Why haven't they identified exactly what the nuclear measurment display is?

Come on, you think Peach Bottom and Exelon management wasn't into it. This guy is being scrape goated...he is taking the fall for everyone else.

Nuclear power repair man pleads guilty in repair scam

December 6, 2012

By ADI News Services

Kevin A. Doyle, owner of owns Pentas Controls, LLC, which is a qualified vendor for Nuclear Power Plants, pleaded guilty to material false statements, in federal district court in Phoenix last week. The 47 year old, Scottsdale man’s sentencing is set before U.S. District Judge Susan R. Bolton on Feb. 11, 2013.
When Pentas Controls was unable to repair a nuclear measurements display for the Peach Bottom Atomic Power Station, Doyle caused a substitute display from the Brunswick Nuclear Plant to be shipped from his Scottsdale facility. Prior to its shipment, a Pentas Controls employee filed down the serial number on the substitute display to conceal its identity, in violation of Nuclear Regulatory Commission safety regulations. On March 15, 2011, Doyle made false statements to officials from the Nuclear Regulatory Commission-Office of Investigations (NRC-OI) by repeatedly denying that the un-repairable Peach Bottom Atomic Power Station display had been substituted with a working display from the Brunswick Nuclear Plant.
A conviction for false statements carries a maximum penalty of 5 years in federal prison, a $250,000 fine, or both.
The Peach Bottom Atomic Power Station is located in Peach Bottom Township, York County, Pennsylvania, on the Susquehanna River three miles north of the Maryland border.

So this is it now: 
.

December 5, 2012

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

Request an immediate shutdown of VY because the NRC and Entergy can't keep their nuclear safety paperwork and documents accurate and up to date. I wonder how that fits into risk informed regulations?

So here below is how the VY's SRV degraded thread seal LER 2010-002-01 dated March 1, 2011 expresses the "cause of the event".

"Material testing determined that the apparent cause of the thread seal condition was thermal degradation. The change to use Buna-N material in the new style seal resulted in reduced thermal margin when considering the potential local heat transfer affects on the seal material. The use of silicone material in the original application provided more margin."

And you catch the absolutist certainty gaming phrase in the same document with their correction action section in the LER statement? You catch the loud past tense of the verb "performed" prior to March 1, 2011? Does anyone ever in the nuclear industry ever pay a price for being wrong. Certainly they did material testing and causal analysis, but it was purchased in Walmart and grossly inaccurate.

Can you imagine a nuclear industry if a high percentage problem evaluations and analysis are as wrong with this? Can you image a world where the staff of a nuclear plant and its oversight agency can’t immediately differentiate between safe components and unsafe parts going into nuclear plant before plant operation? It takes years of plant operation before a component defect shows under evaluation. But they all knew from the purchase of that actuator it shouldn't go into a power plant containment used for critical safety core cooling purposes.    

"VY performed material testing and causal analysis."

So the below is how the NRC expresses it in our new NRC inspection report 201204 dated Oct 31, 2012. The inspection took place between July 1 and Sept 30, 2012. We have no idea when Entergy became aware of this new information or when the NRC found out about it. You notice the agency never writes a date associated with this new information, because they don't want to hold Entergy and the agency accountable for complete truth telling. The lack of a date shows they were embarrass to document the dates But one thing we know for sure...there is a cover-up.  Entergy carelessly neglected to update their LER with this new pertinent information with putting unsafe material into the actuator. The NRC has failed to enforce required accurate documents.  Like I been saying all along, it’s the whole actuator which failed to meet “environmental qualifications” (type 2) as admitted and it is terrible unsafe. Why isn't the information in IR 2011008, the actuator type, the whole story how VY and the vendor chose the wrong actuator qualification, recklessly started up,  the whole scam with these guy focusing on the Buna n batch being wrong, the buna-N is acceptable...how come LER 2010-002-02/3 doesn't explain this whole sordid tail with what happened to the SRV actuators? How come we are not seeing the complete story of this in Entergy-Vermont Yankee’s words?     

"However, Entergy’s evaluation of the seal incorrectly concluded that the seal material was defective and a new Buna-N seal was installed. Entergy performed a subsequent evaluation of the seal material and determined that the material was Buna-N, not defective, and the failure of the material was due to exceeding the thermal rating (225 degrees F) of Buna-N. Following identification that the seal material did not meet environmental conditions, Entergy performed an operability determination which concluded that the ADS system was operable, but degraded."

So the batch of buna-N elastomers material was not defective...it was just a grossly inappropriate material for this application. There was nothing at all wrong with the buna-n material that failed. It should be noted, this should be easily picked up by material engineers, general mechanical engineers or PhDs...would pick up the dangerousness of this material immediately. There is much prior information out there the Buna-n is dangerous material for high temperature application and especially for containment pneumatic actuators.

So why doesn’t VY-Entergy update their LER 2010-002-01 and why doesn’t the NRC enforce accuracy of federally submitted documents from the licensee? Why can’t we see the whole story in a single document...why is the information all fractured over years. They all got tons of higher highly educated employees overlooking these guys. It questions whether any LER in the industry is truthful, accurate and complete...can the NRC enforce complete disclosures and truthfulness. Can you ever do a LER search years later and expect to see the whole truth? Like to see a extent of cause/condition on this guy.

Everyone understands what I am doing by holding the agency and entergy accountable with accurate documents...I am telling everyone I want to be held to the same standards I am trying to impose on the agency and Vermont Yankee.

Jesus, VY LER 2010-002-00 came out of the 2010 April-May Vermont Yankee refueling outage...does this inspector even read the real LER? I don’t even think VY had a 2009 outage? There was no VY 2009 refueling outage...was there an actuator leak in 2009 and this was the first time it was disclosed? Was there testing and a leak in 2009? They are all sloppy as hell with safety paperwork accuracy. They exited the last outage in Nov 2008 and 18 months carries them through 2009. So the below comes out of the new Oct 3, 2012 VY (2012004) inspection report.

Pg 28: “specifically, Entergy identified repeat occurrences of leakage around actuator stems during the 2009 and 2011 refueling outages.”

Pg 29: “During the 2009 refueling outage, Entergy found nitrogen to be leaking from the actuators and determined the actuator stem nut seals were degraded.”

Can’t make heads or tails of the below statement. Seriously, would you trust them to amputate the correct bum leg? The NRC got the refueling years correctly with three out of four outages.

Pg 29: “Specifically, the inspectors reviewed the documents to determine if the seal material used on the ADS actuator stems from 2008 to 2011 should be attributed as the root cause of the 2009 and 2011 stem leakage and to verify that the replacement seal material now installed was qualified for the expected environmental conditions.”

You get it, the NRC and Vermont Yankee just throws worthless safety paperwork at each other and nobody ever reads it. None of these guys got the habit or balls to correct each other with inaccuracies in each other's paperwork. This thoroughly questions the independence of the agency.

So Vermont Yankee declared in their first leaking SRV pneumatic actuator LER it was a SRV “actuator threaded seal“. A few paragraphs down it then became a “shaft to piston thread seal“. The NRC’s first swipe at naming the defective component was in IR 2011002 with a “shaft-to piston thread seal”. In the newest IR 2012004, years later after the event, it mysteriously turns the incorrect leaking material buna-n into the “seal material for the actuator stem nut”. What the hell do you accurately call this leaky seal material? You notice nobody presents a diagram of the actuator.

I request that Vermont Yankee be immediately shutdown because the plant staff doesn't see the value of keeping their required federal “comic book” paperwork and documents accurate and fully up to date with new and current information. They are unaware of the value of telling the truth to the public. Well, the greater peoples are the enemies...so truth telling is optional in any war with enemies. They only fill out accurate federally required documents and reports if they can selectively angle the facts to absolved the licensee of responsibility ...keep the plant running no matter what it takes...they write to just state the facts if it is never condemn their incompetence and attention to nuclear safety detail.

You know I get it, they have private nuclear safety data bases they share within the nuclear industry and NRC, which is totally not scrutinizable by outsiders and totally unregulated...so LERs don't matter. They are shifting most of the information into secret private and propriety internal document systems in which the greater people can never see. Who said, trust but verify? They are hiding as much information from the public that protects both the NRC and nuclear industry as they can legally get away with. Right, this has been a long term shift to get nuclear plant safety information and problems off the federal and public books. If you can't see it, then you will never be bothered by it...it helps making profits devoid of safety. I suspect the hiding problems system from the public was in anticipation and intensified for the nuclear renaissance. 

And it is obvious the NRC doesn't enforce the accuracy of required federal documents and paperwork. How can you trust any of their safety paperwork and document products to be current and up to date with the newest safety information? You know with these off the books private data bases systems, how do you know the players are documenting and distributing all the pertinent information in these voluntary systems? Who enforces the internal disclosures.  You know, now with the VY SRV threaded seal the required reports will be intentionally structured to be many years too late and blatantly false from the startup in the initial conception of the problem. The NRC is a god totally unto themselves and they report to no one.

I bet you this isn't a simple document rule oversight. I bet you the rules are written up this way and they are not required to make updated accurate safety information and documentation such as LERs. This is the game of meeting the minimum intent of federal requirements for pubic disclosures. I'll bet you they are strictly following the rules that facilitates this document inaccuracy...the crazy rules were written up by campaign contributions paid by the nuclear industry so they aren't required to tell the truth to the communities outside the plant  and little lying is never risk related.

So the plant, industry and NRC will conspire to allow the plant to cold bloodily start-up and remain in operation with bad nuclear safety parts, usually under the euphemism of we always get what we want out of risk informed and nothing ever matters regulation...running with knowingly unsafe replacement or new parts in the plant. This is what happened with Vermont Yankee. They just might secretly allowed a unsafe plant to operate for a cycle or two until the unavailable and appropriate quality components and repaired parts are reverse engineered, acquired or purchased.

@@@

I suspect they throw these broken, wrong or defective and degraded components to contracted investigative or testing vendors...the sole purpose of it just might be a delay mechanism to get past the heat of a brewing scandal. It is more protective if a vendor gets caught in a lie...that won’t challenge continued plant operation. I think these investigative and testing contractors are corrupt as hell... they are lying professional engineering gunslingers. It is a pay-to-lie engineering service business and absolutely no NRC enforcement of integrity and truth telling. The stinking lying abscess of payola with investigative contractor and vendors testing is a critical nuclear safety sore on the whole industry and it is a national energy security threat to the whole nation.

It might throw the broken or wrong material part investigation to a half ass testing contractor or vendor testing process, again, the sole purpose is to come up with a first wrong investigative result. It has nothing to do with finding the whole truth "so help me god" at the earliest opportunity. Then you have to throw it into another troubled testing contractor...it eats up years of wasted time and it gets out past the bad result many years after problem. Most worrisome, is they throw the bad part investigation to vendor or contractor who manufactured the bad part...they would never be expected lie of fudge the facts in support of stock price due diligence. Worst, in order to get business from a nuclear plant or corporation, it becomes a contractual requirement the investigation service lies to the regulator and the public. This corruption allows the plant to operate with defective nuclear safety equipment for more than one cycle and this has the ability to destroy the nuclear industry.

Most of these defective or degraded parts get thrown into vendor or manufacturer investigation who have total control of the results. It is like investigating, prosecuting and judging your own robbery. How can you expect to get a clear and accurate investigation when so much self interest is on the line?  

Believe me, as with delayed justice, delayed purposely engineered untimely safety information (results of reports and investigation) disclosures for self interest is no truth whatsoever. It is worst than a direct lie because many people are involved in cover-up over years of time. It pollutes the conscience so many employees and it sets these employees on a long term false agenda they can’t escape from.

You just have to have much shorter investigative periods...it has to be enforced to the industry by the NRC. People should be punished for coming up with wrong answers! I think the NRC has to take control of many of these investigations and pay the contractors. The results of these investigation should be in the interest of the rate payers, stockholders and in our national interest. An investigative and testing result should never solely support CEO lying bonuses and the destructive short term utility stock prices. A broken part or degraded safety system investigative report should never try to support and mitigate sinking stock prices by telling structured half truths for years on end. These kinds of lying games destroys the conscience of good employees all through the nation

I am telling you, there is arc of a huge cover-up from the opening days of the AOG pipe tritium leak in early 2010. Then a few months later discovering the leaking SRV actuators during the Apr-May 2010 refueling outage when the Vermont governor, their Senate and House, where trying to pull VY’s license and everyone had great mistrust of the NRC. The governor of Vermont got elected over this tritium issue. The delayed totally fictitious disclosures in 2011008, the totally fictional insulation issue on the actuators, new cooling fin problems and insulation problem challenging the Buna-n, their certainty it was normal elevated high temperature problem challenging the correct buna-n nitrile based elastomers. The nrc was completely duped for swallowing the load of falsified crap stated in agency inspection report 2011002/8 by Entergy. I find it suspicious in the opening stages of the seal leak with all the professional NRC engineering resources at their beck and call the agency don’t know the buna n material was the wrong kind material. Why wasn't the NRC nosing around in VY’s purchasing system for nuclear safety parts, why didn't Entergy notify the NRC we are putting substandard new components into VY...why wasn't there a document trail of caring about what quality parts they are put in a nuclear plant?

Why wasn't everyone scrutinizing carefully these off normal events such as the new type 2 actuator of a lower quality...why isn’t there a public document trail of due diligence? That is how trust is developed...you got a dated document trail where people of caring jumped in there in a differential of required component quality at the earliest opportunity of awareness. They create a document great debate if it right or wrong. It just sounds like a great crazy blind monster was banging around this plant uncontrollable putting in unqualified parts and his bad behavior wasn’t observed.   

The agency is contemporaneously engineering-wise grossly incompetent. Maybe the agency got a deal with the licensee, if you are doing anything questionable don’t tell us. You will do everyone a favor if you preserve our future claim of plausible deniability. The baseball umpire don't have the guts and confidence to call the strike as the ball passed the batter. At its best, the four year arc of the SRV buna-n problem, six years (2008) if you go back to the acquisition and purchase of environmentally unqualified high temperature new type 2 pneumatic actuator, it is just gross nuclear power plant engineering incompetent and negligent. At worst, it is the professional class of engineer's doing the payola, robbing banks and lying about it to feed their families. This was all was the happy land selective release of information game highly educated employees play to rob banks and to corruptly acquire profession stature.

This is what happens when we allow...all the greater outsiders... when we allow a really small group of threaten and insecure wealthy people to become extremely isolated in a really complicated obsolete technology that is starving for funds. I am talking about all the people in the nuclear industry and within the NRC. What it comes to, these isolated employees coming to the conclusion it is "us" against the "world". It is pushed by all the officials to serve their ends. Hey, Romney, the extremely wealthy right wingers and the tea baggers, it is the etch-a-sketch lying directly in front of the public. Why not the nuclear industry? We are at war with each other and extremely insecure, the first causality in any war is truth. We use a technical language as intentioned understanding disruptor weapons so nobody else can understand us...how can they catch us in a lie if they can't understand what are we talking about? We in the nuclear industry are at war with the country and this is how we gain our group cohesion. When the nuclear industry pushes this dope to their employees, it become an excuse of weapons of mass lying against the great people of the USA. The first causality in any war is the truth, right? Oh, the federal regulation expect us to lie for our common good....congress demands we tell half truths in a so called national security energy emergency.

So just to be clear, Vermont Yankee first stated they got a bad batch of buna-n seal material in the spring of 2010. These crooked guys are really smart. You notice this bad batch rationalization allows a plant startup with supposedly new good buna n seal material. Then they much later said that normal high temperature and insulating the actuator over heated the seal material. I bet you they really never thought about the meaning of the seal failure until well after the startup. Then it was a structure disclosure to not force a shutdown once operating ever since.

Image if they admitted it was the wrong quality actuator in spring of 2010. What if they admitted they put a unsafe actuator in 2008, then it failed within a year due to poor quality materials. Thinks about it, what if Vermont Yankee said we will not start-up in the spring of 2010 until we have the proper quality nuclear safety actuators...admitted the whole ball of wax. It would have probably forced VY into a prolonged wait getting the type 1 actuator that wasn’t being made anymore during heart of the tritium crisis. They would have been permanently shutdown in 2010.

Do you remember all the Entergy officials caught with not telling the truth to the Vermont House and Senate...they were punished for this? Do you remember that outage, it was mass media hysteria over the AOG tritium leak, an assortment of governors and a “governor to be” saying in the media they don’t trust the word of Entergy...do you remember the Senate and House Vote?

Just play it in your head, at the end of that 2010 outage, what if Entergy would have admitted they couldn’t start-up with those bum nuclear safety cooling system actuators. They installed bad actuators two years before that...they knew it was an unproved actuator and the NRC allowed this ...but they installed in anyways. They really had no other choice but a prolong shutdown, so they purposely installed bad SRV actuators to get the plant back on the line in 2008. The seal prematurely failed early in the next refueling outage due to bad quality actuators in the mother of all integrity crisis in the 2010 outage. Does anyone see any document with Entergy asking the NRC for permission to install type 2 actuator prior to 2008? How can your trust any of these guys if they don’t document what is important?    

I am certain VY thought they were dead if this actuator story came out, delay the start-up...so if they were caught lying about the actuators, they were already a walking dead man anyways. Right, you can’t die twice in a row. Would you lie for another 20 years of plant operation and income.

These are the ingredients of mind boggling conspiracy and the greatest lie of all time. This is a really small group of people...the nuclear industry as a whole....compared to the size of our general population. These professional people are isolated from the rest of us unlike any other professionals.

And they are getting more isolated from the rest of us as the seconds tick away...tick, tick, tick...with the ascendancy of the fracting, nature gas and oil era.

All the big accidents as TMI and Davis Besse, Fort Calhoun, TVA, Entergy, HB Robinson...these are institutional accident with large groups of people going insane in a concentrated rules based organization. In these massive size rules based organization, usually isolated under a serious long term threat, we start shifting around the written rules and unspoken rules as relationships in our heads. A healthy organization used rules to make our greater world more visible and understandable to everyone...it is a communication enhancer. A terrified and insecure organization begins to use rules to blind everyone in the organization, we use rules to fragment the image of the world coming to us...we use rules to fragment human relationships...we use rules to shut everyone up so we can’t see the insecure and trouble world at our feet and ahead of us.

A rule can either be good or evil...it only depends on the motives of the person making, enforcing or accepting these rules. Rules are never good on their own account...rules are a communications tool. And generally the definition of words are contextual... we use the definition of words for a particular purpose.  And it only get worst when we hide and communicate in relationship to ourselves in darken corners. 

Request:

1) That Vermont Yankee-Entergy be fined another $10 million dollar for not keeping required federal “comic book” documents fully accurate, current and up to date. LER 2010-002-00/01 as the example...

2) Request a Department of Justice/ FBI investigation of these events. The agency NRC Enforcement cronies and OIG just blew by this. Why doesn't the NRC enforce accurate document and LERs.

3) An investigation nationwide with equipment and components not being environmentally accident qualified in any nuclear plant containment especially max temperatures and radiation...they should be shutdown immediately to acquire and install the appropriates grade of nuclear accident safety equipment. Is the wiring insulation or any of the rubber like material (Buna nitrile) qualified for 360 degree F or the extreme radiation.

We need strict timeliness and accuracy new NRC regulations with nuclear component and system failures and breakdowns contractor and vendor investigatory and testing reports...similar to Vermont Yankee SRV threaded seal boondoggle. Maybe monthly public reporting. We have to make it a shutdown requirement to get a report on the table within a month from the incident and on the public table for inspection.

It can no longer be the professional engineer gunslinger vendor, investigative or testing wild west with payola for delays and engineering lies in reports to the public, utilities and NRC.

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

5) A emergency NRC senior official oversight panel with the aims of reforming the ROP.

6) 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.

7) Request massive reforms within the 2.206 system and their directives. This system doesn't serve the public and their communities...it serves the agency and protecting the nuclear village industry. This doesn't make our nation greater, it demeans a great nation like ours. It is at the root with why there is no growth in the industry and most of their plants have grown obsolete. There should be strict enforcement of truth telling and integrity within the 2.206 process.

8) Do a comprehensive extent of cause/condition outsider professional investigation at Peach Bottom and Vermont Yankee over the environmental temperature qualification of the SRV leaking actuator pneumatic. Fort Calhoun is doing this over their faulty containment safety actuator pneumatic buna-n nitrile based elastomers material that can't withstand the highest accident temperatures...why didn't these types of investigation happen at Peach Bottom or VY from the opening stages of seal testing failure. The absence of this kind of open fundamental problem investigation by all the professional parties at the get-go is suspicious as hell and indicates a wide spread cover-up to violate federal regulations. I am telling you at the bottom of it all it is about ideals.

A constitutionally and democratically transparent nation is a safe nation...a unsafe nation is when we are insecure and out for self interest, we begin hiding all of the information about ourselves from each other.

9) I am telling you, the outcome of this half truth environment and inspection report truth gaming, in the name of their families and national security interest, these employees will turn off all their nuclear safety equipment and fill up all these plants' with cheap defective components in the name of doing good and altruism within the dank and dark cement vault of any nuclear power plant. Doing good and altruism for the wrong reason is our greatest bane....it the greatest evil the planet has ever witnessed. The rationalism of altruism and doing good turns off all our intelligence and intellectual safety circuit off in our heads...it is the most destructive drug or neurotransmitters chemical the world has ever known.

10) Request a detained report on the new 400 degree viton material installed as seals. Are they fully qualified for normal containment temperatures and accident conditions...are they tested for durability and reliability under their safety use.


Sincerely,



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