Friday, January 18, 2013

Millstone and NRC falsifies documents in order to keep plant at power

Check out all that warmer water in the ocean off the coast of NE. It is 2 degrees warmer than normal.

Jan 22: 12 January 2013 Last updated at 17:07

I don't know, so this sudden stratopheric warming transfers very cool air from the polar vortex into the wider open ocean? I don't know? But it brings warmer air to the artic. 

Sudden stratospheric warming responsible for UK's icy blast

You catch that spin of the blocking high over is pumping intensified moisture from the intensified Gulf Stream into a mega snow making monster. Ask Mosco?

Jan 21: So what would our world look like if our Thermohaline Gulf Stream Intensified...what would we look like if we had a runaway Gulf Stream? 


NYT's article about Braidwood's safety cooling limits on July 17...

 Intentional Inaccurate Documents By The NRC and Millstone

All documents associated with the Millstone nuclear plant Long Island Sound Ocean high temperature shutdown in Aug 2013 are grossly inaccurate.  


 Labrador Current/ Gulf Stream
Drastic changes ahead in our coastal areas.

...The next two videos were made Jan 19..

More on Millstone's Inaccurate Documents...

More on the Labrador Current and The Gulf Stream Diversion...

We a seasonal computer model of the Labrador and Gulf Stream Current.

...I'll put it is simple terms. The Virginian southern carpetbaggers think it is their only prerogative to extract profits at any cost out of Millstone and the NE electric customers. Their only priority is to squeeze every penny out of Millstone just short of melting down the plant or pissing off the state regulator so they get kicked out of New England.

Basically Dominion  is saying the Millstone facility is not profitable if they are fully forced to handle global warming...if both plant have to easily pass the rigger of any conceivable climate for the rest of the plant's life.

It just gets you wondering if grid prices and state financial recovery to Millstone can support nuclear safety and vital New England societal electric reliability responsibilities.  

...What I can say about this, the NRC's nuclear plant license amendment process has become nothing but a corporatize public relation spin operation. Just pick and chose the facts you want to use. It's nothing about painfully explaining truthfully the predicament you got in.

The bottom line here for Millstone is, we have seen global warming coming and we are too cheap to fix it. And we don't want to tell anyone.

The societal implication, what if all the electric utilities could make more money by shutting down for a month in a grid and heat crisis, by not having an adequate cooling systems? It's called spiking electricity cost and an unstable grid.

Millstone looking to adjust operation to warmer water
Temperature data collected by environmental scientists at Millstone shows average temperatures of the waters around the plant have risen by 0.67 degrees per decade since 1976, Holt said. In 1976, the annual mean temperature was 51.6 degrees, compared to 53.4 degrees in 2009.

Temperature data collected by environmental scientists at Millstone shows average temperatures of the waters around the plant have risen by .67 degrees per decade since 1976, Holt said. In 1976, the annual mean temperature was 51.6 degrees, compared to 53.4 degrees in 2009. The mean temperature in August 1976 was 67.3 degrees, compared to 69.8 degrees in August 2009. The next year, the temperature went still higher in August. In a 2010 annual environmental report, Millstone scientists noted that April and May of that year had the warmest temperatures on record, and that the mean August temperature was 70.3 degrees.
Last year, the mean August temperature was slightly lower, 69.9 degrees, while the annual mean for 2011 was 53.8 degrees.
Aug 15: fixed it up a little to read better. I am always a work in progress. 

This is my theory on what is going on at Millstone. Yea, there are some serious climate change events going on in the Long Island Sound. You can clearly see it on my NOAA's 10 hottest Julys. I am saying the Millstone facility weather is pretty mild and incremental compared to the Midwest this year. I will bet you each year's the peak summer heat sink temperatures for a decade or more the (inlet temperatures) have shown a clear increasing indication. Millstone knew it in their late July panic LAR filing after we brought up the Braidwood high cooling water temperature problem that their site was going to be screwed in August. Millstone should have seen this day coming from a million miles and had prepared their site for it. 

The spotty summer peak heat sink temperatures have repetitively challenged regulations at Millstone for decades. Millstone’s and the NRC’s biggest sin was not seeing the big picture 15 years ago and causing the site to fudge numbers to stay up at power. So everyone had to come up with tricks, jacking up the limit of a degree or so, playing around with shifting seawater measurement from the control room indication into temperature averaging at far flung areas of the plant without automatically recording the temp and its time. You began fudging 8ths of a degree to keep the plant up at power. And we know there are lots of seawater temperature noise out there, maybe plus or minus 3 degrees of slugs of different temperatures and tons of swirling eddies directly outside plant. A ridiculously small 2 degree swing from a normal year to the hottest summer since 1895 with heat sink temperature could make you start banging the plant up and down in power. You are smart enough to cherry pick the temperatures you want. It is insanity!

So you would have a huge crisis keeping the plant up at power one hot summer over 8ths of a degree decades ago. I don't know, maybe you wrote it off as a fluke after the crisis is over. Maybe the next summer was cooler and you never challenged the limit. A few years down the pike, another hot summer of operational challenges and you would use the experience of the last crisis to get thought it. You just got into a repetitive pattern of squeaking through a hotter than normal summer and never constructing new cooling water capacity in defense of the good public you serve.      

I ask, could incremental climate changes lead to subtle heat sink increases, a struggle to not be impacted by the approaching legal cooling water without plant expenses? Then sliding into widespread lying and falsification by the utility and the NRC...into destroying the plant safety culture. I am saying it is a widespread known agency and utility problem over decades....the utilities will fight to death and destroy the NRC if they have to spend one more penny on a plant if a new problem shows up no matter how justified it is. The fact don’t matter and they will rip the agency apart over spending pennies. It is these ideological nuts on K street and the Washington politicians.   

If you are lying and falsifying, everyone knows you have to have plant enforcers.

So one employee "plays the game" and fudges numbers in unrecorded far flung dark corners of the plant and gets promoted. The new guys wonder, do i have to do the same thing to be respected and have a job. It always rips the plant safety culture apart and pits one innocent employee against another innocent employee.

So unattended climate change threatens the nation...lying and falsification can destroy almost immediately the culture of a huge facility and also an invaluable government regulator.

I think it is a big deal when a NRC official says the climate is the hottest since 1895 to cover-up fudging 8ths of a degree temperature of cooling water while NOAA says it only the 9th hottest summer around Millstone. The NRC did not fully express to the public and understand, what they were really dealing with with this emergency amendment request. They are just picking facts for their own agenda and not explaining the whole story.

I think the Millstone facility, with the help of the NRC, should have seen this day coming many years ago and spent the appropriate amount of resources to make the hot summer of 2112 a insignificant blip on the radar. The Millstone staff this summer should have had many excess luxurious degrees of cooling capacity to enjoy another endless summer without any worry in the air...

It drives me really crazy when highly educated employees play stupid and then gets away with it.

That just might big threat of climate change to a nuclear plant. It “frog boils” everyone into complacency and fudging 8ths of degree of water temperature at a time ...then the lying destroys the safety culture of nuclear plant without insiders knowing it.

Drought Washing
Using a drought emergency to improperly get regulatory, corporate and business sympathy to make more pennies and profits. 
Using the drought emergency as an excuse and accepted, which gets a federal and state regulation reduction without a breath of a connection to a drought emergency.
Gaining obscene totally unjustified profits with blackmail over a drought emergency and screwing the vulnerable.

August 14, 2012, 2:51 pm
A Nuclear Regulator’s Wish List

August 13, 2012, 4:58 pm
Heat Shuts Down a Coastal Reactor

July 14: Using a local measuring location, nothing specifies how often the temperatures needs to be recorded. It is a huge hole. In the control room it is not a issue because the points are automatically recorded by regulation and stored on the paper recorder roll or on the computer.

You got crawling under ocean sand dunes at the tip the discharge peninsula...when was the last time Millstone dredge this area. You got an assortment of hurricanes or their ruminates, lots of nor'easters, big waves, big and small tides to churn up the Sound, Hurricane Irene gravel and sedimentation shooting down the Connecticut River and like rivers. Hurricane Irene walked right up the Connecticut River. It raked massive amounts of gravel and debris from Vermont.

How about a list of all the peak summer time heat sink inlet temps and their dates since beginning of operations with Millstone unit 2?    

I still don't buy it. AP:
Robert Wilson, a professor at Stony Brook University's School of Marine and Atmospheric Sciences, said readings show temperatures in central Long Island Sound are nearly 80 degrees, much higher than the more typical 74 degrees.
...Basically, the central LI Sound, whatever that is, is a million miles away from the Eastern Sound's high velocity throat flow directly opposite the open Atlantic...

 I dare you to do a Google search on this:
"Water temperatures in Long Island Sound, warmest on record"
Don't you find it suspicious as hell nobody outside the Millstone site reported record breaking hot waters in the Long Island Sound this year? There is nobody else reporting the warmest water temperatures ever on Long Island Sound. Isn't that news...
So what would it take to cool my jets on this. Say the last five hottest summers...a comparative graph of inlet time versus temperature for the whole year with the 5 hottest summers and this year. I'd want the all the data points on one graph...with the granularity to see the results of the tides on temperatures.     
Aug 13 11 AM : The NRC says they wouldn't be surprised if Millstone 3 has to shutdown in the near future as they are also on the edge...same temperature limit.

They have been asking questions about the discharge heat backwash into the suction in recent days and are closely watching temperature parameters to see if there are any changes with Unit 2 as being down associated with backwashing heat.

Ok, so what is the evidence the unit 3 suction takes a deeper suction from the bay, they are less than 50 away from each other...or are these blind assertions by Millstone accepted by the NRC without a shred of proof.  I asked, so why doesn't Millstone blast out a channel similar as unit 3 allowing access to similar cool bay water? Got a "good question mike?

I asked, as there are four or five worst hotter Julys since construction...then Unit 2 must have a large record with heat sink temperature shutdowns? So why hotter summer climates and no shutdowns?
Warm water in Sound causes Millstone unit to shut down
By Judy Benson  
Published 08/13/2012 12:00 AM
Ken Holt, spokesman for Millstone owner Dominion, said this is the first time Unit 2 has had to shut down due to water temperature since it began operating in 1975.
The plant’s license states that it must be shut down when the water temperature is 75 degrees or higher over a 24-hour period. Water temperatures in Long Island Sound this summer are the warmest on record. (So Ken, what is the proof of that...)
The above added at 3 PM
A  news story like the NRC infers, but two week ago. Like, "The Long Island Sound seawater temperature is on pace to beat 1895 records"...the hottest temperature since 1895. "The Long Island Sound seawater temperatures are the hottest its ever been for this time of year since records began. How come there are no news stories like that before last Friday...?    
The NRC is oblivious to the heat sink temperature historical record at the Millstone facility and it is astonishing for an engineering organization!!!


Notification Date: 08/12/2012
Notification Time: 01:48 [ET]
Event Date: 08/12/2012
Event Time: 00:44 [EDT]
Last Update Date: 08/12/2012


Millstone Unit 2 reported that it is in a technical specification shutdown condition based on the ultimate heat sink average water temperature exceeding a temperature limit of 75 degrees Fahrenheit. The ultimate heat sink is supplied by water from Niantic Bay. At the time of this report, the bay water temperature is slightly below the 75 degree temperature limit but the time average calculation for the ultimate heat sink temperature limit still exceeds 75 degrees.

The Ultimate Heat Sink Technical Specification, TS 3.7.11.a, requires the unit to be in hot shutdown within 6 hours when the average temperature limit is exceeded. The licensee is in a slow power ramp-down while monitoring the ultimate heat sink average temperature for water temperature conditions to drop below the limit. The high heat sink temperatures are based on natural environmental conditions and not from plant operation.

Millstone Unit 3 is not impacted at this time.

The licensee has notified State and local authorities and will notify the NRC Resident Inspector.


The licensee reported that it had exited the Technical Specification LCO based on a current average heat sink temperature below 75 F. However, the licensee will hold power at 65% to ensure the temperature is stable and will remain below the limit during the day shift.

The licensee has notified the NRC Resident Inspector. R1DO (Burritt) notified.


At 0943 EDT on 8/12/12, the average ultimate heat sink temperature on Unit 2 exceeded the 75 degree limit again. The licensee re-entered TS LCO 3.7.11.a and commenced to shutdown the unit from a starting power level of 65%. The licensee plans to proceed to Hot Standby in compliance with the TS action statement even if the heat sink temperature drops back below the TS limit.

The licensee has notified State and local authorities and the NRC Resident Inspector. R1DO (Burritt) notified.


At 1645 EDT on 8/12/12, Unit 2 is in Hot Standby and the heat sink temperature is below the 75 degree limit.

The licensee has notified State and local authorities and the NRC Resident Inspector. R1DO (Burritt) notified.

...Why unit 2 and not unit 3...because the warmer plant discharge water gets sucked into unit 2 preventing most of it from getting to unit three plant suction...
Right, the most important thing for a nuclear plant is to know how the plant and components interact with the have a perfect model with how the flow interacts...   

At Vermont Yankee we'd seen plant discharge heat climb 500 feet upstream and uphill on a fast moving river. In the winter, we'd seen the heat signatures of discharge climbing upstream to our suctions of the plant. There would be a free area of ice from the discharge to the intake?  

July 18 to NRC:
"Pathetic, you people think a drought just uncovers the low rocky shoals and sand bars of our baking steams, river and waterways. I know a drought mostly uncovers a staggering build up and amount of fraud and corruption in our society. A 50 and 100 year drought of staggering dimensions is really an amazing transparency device or tool..."
"I suspect the NRC is going to be confronted with a pan on the stove of popping popcorn amount of NOEDs at many plants before the summer is over.

"All I can think of is in the drought of 1998 thru 2000, the massive amounts of paper whipping NOEDs and tech spec changes that occurred back then. Braidwood did it." 
This below quote is a sickening intentional falsification...the NRC is gaming the national drought crisis in order to gain pennies of profits for an undeserving facility who is not in the bulls eye of a historic drought. A national emergency is not a reason to reduce safety margins to every undeserving nuclear facility...

It is strictly illegal for anyone to falsify NRC documents...this is surprising for highly educated NRC engineers.
"Ambient air temperature in July were the hottest on record in the contiguous United States since record keeping began in 1895 according to the National Oceanic and Atmospheric Administration, and temperature continue to remain high in August." 
"The Braidwood nuclear facility safety cooling water temperature limit is 100 degrees, while Millstone's is 75 degrees. It is well within the state of the art of engineering to design and updated a plant to make the limit 100 degrees. The Millstone facility has been banging around this facility's defect of not being designed for the 1970s climate, as with today's and tomorrow's climate.

As example, the Millstone facility could tunnel out in into the Long Island Sound and take a suction into deeper water like Seabrook or cooling towers or increase plant cooling capacity....

Is should be noted, the NE ISO has been surprising clear of grid alerts and warning so far this summer with the Connecticut climate hotter than anything since 1895?  


July 2012: 9th warmest July on record

Top 10 July temperature anomalies
1st July 1913 +5.4°F
2nd July 1912 +5.1°F
3rd July 1955 +4.1°F
4th July 1994 +3.9°F 
5th July 1949 +3.7°F
July 1999 +3.7°F
7th July 2010 +3.6°F
8th July 2006 +3.4°F 
9th July 2012 +3.2°F 
10th July 1952 +3.1

Is it a much hotter than normal summer in Conn. this summer?

The New London Day today:
Holt said the difference between the highest temperature and the average of three temperatures taken at different locations is just a few tenths of a degree, but it can make the difference when it comes to the water being within the limits. 
Intake water used to cool Unit 3 is drawn from a deeper part of Long Island Sound, so it is a few degrees colder than the intake water used for Unit 2, he said.
I'll bet you plant discharge heat is backwashing into plant two's suction and it only shows up in hot weather? It is like shitting in your own nest?

Last serious drought in 1999: 

" NNECO indicated that tidal effects in the Long Island Sound can cause the UHS to experience temperature swings of 2 to 3 degrees during hot weather conditions. In its application, NNECO reported that a review of plant data for the past 18 years revealed that the 75 F UHS temperature limit has been exceeded approximately five times, each with a duration of less than 2 hours. During hot weather conditions, in anticipation of exceeding the UHS temperature limit, NNECO has previously sought, and the NRC has granted, temporary relief from the shutdown action required by TS 3/4.7.11. Most recently, on July 10, 2000, the NRC approved a TS\ change of this nature that was valid through October 15, 2000 (License Amendment No. 247).
The TS change allowed continued plant operation for up to 12 hours if the UHS temperature limit was exceeded, provided that NNECO confirmed on an hourly basis that the UHS did not exceed 77 F while the temperature was above the TS limit. DNC expects the UHS temperature to continue to approach the TS limit during hot weather conditions and, on rare occasions, expects the UHS temperature to exceed 75 F for short periods of time. The proposed change is expected to enhance safe operation of MP2 by avoiding (a) the risk associated with unnecessary unit shutdown transients, and (b) the administrative burden of processing temporary relief requests during periods when weather conditions are expected to be hot and dry for prolonged periods of time.
Licensees have historically experienced elevated UHS temperature conditions during prolonged periods of hot, dry weather and, on occasion, TS temperature limits have been exceeded. Typically, these situations are infrequent, of short duration, and do not pose a challenge to accident mitigating systems and components. Unfortunately, when these conditions arise, prompt action is required by licensees to address TS requirements, which typically include a request for the NRC to exercise enforcement discretion. The Nuclear Energy Institute’s TS Task Force (TSTF) proposed a change to the Standard Technical Specification (STS) requirements in order to deal more efficiently with short-lived elevated UHS temperatures that...
****August 10, 2012


In it's July 17, 2012, and August 9,2012 (2 supplements) letters, the licensee requested that this amendment be treated as an emergency amendment. In accordance with 10 CFR 50.91 (a)(5), the licensee provided the information regarding why this emergency situation occurred and how it could not be avoided.
This emergency situation results from prolonged adverse environmental conditions in the area.  Under these conditions, ONC could not have reasonably applied for this emergency license amendment in advance of the event or in a more timely manner following the event.
The current situation at MPS2 satisfies the criteria for an emergency situation in that MPS2 TSs require shutdown of the unit in the event that the temperature of the UHS exceeds the 7S of temperature limit in TSs. This emergency situation is caused by environmental factors beyond the control of DNC. Approval of the subject license amendment request would allow continued operation of the unit by providing additional operational margin for measurement of UHS temperature.
In this instance, an emergency situation exists in that failure to act in a timely way would result in derating or shutdown or a nuclear power plant. Based on the above, the requirements for an emergency situation as stipulated in 10 CFR 50.91 (a)(5)has been satisfied. 
10 CFR 50.91 (a)(5)
The Commission expects its licensees to apply for license amendments in timely fashion. It will decline to dispense with notice and comment on the determination of no significant hazards consideration if it determines that the licensee has abused the emergency provision by failing to make timely application for the amendment and thus itself creating the emergency. Whenever an emergency situation exists, a licensee requesting an amendment must explain why this emergency situation occurred and why it could not avoid this situation, and the Commission will assess the licensee's reasons for failing to file an application sufficiently in advance of that event.
Taking about Braidwood to NRC on July 15  13...

Monday, January 14, 2013

1) Cover-Up Training 101 For A Nuclear Power Plant: VY

I wish I'd better explained earlier it was SRV pneumatic actuators that leaked nitrogen or air into the wasn't the SRV valve leaking coolant.
 1 Safety Relief Valve Actuator Cover-Up At Vermont Yankee Nuclear Plant-Time Line

Vermont Yankee operated with unsafe components ...lied in documents to the preserve the future operation of the plant. There are incomplete documents to this the state of Vermont and the legal system won't have their sins said in their own words to be used as ammo in the state and legal proceedings.

2 Vermont Yankee Cover-up...why nuclear plant containments are so unsafe

Why SRVand PORV valves are the most dangerous components in a nuclear plant. Why components in the containment are so dangerous. The containment is a locked room that nobody can enter when a nuclear plant is in operation. The containment is almost a total barrier to information where humans aren't allowed to go into for more than a year and the instrumentation is primitive giving very little information to the control room operators

3 Vermont Yankee Cover-up....Cover-up 101

The is the means and methods of all cover-ups and public deception in the nuclear industry.

4 Vermont Yankee Cover-up...everyone knew this material was bad

NRC Information Notice 1994006: Buna-n material is inappropriate in high temperature environments.
5 Vermont Yankee Cover-up...stresses on the industry

Low grid load growth and natural gas fracting.

2) Cover-Up Training 101 for A Nuclear Power Plant:VY

6 Vermont Yankee Cover-up...comparing PB and VY Buna-n

Peach bottom project manager in the 2.206 was dishonest to me

7 Vermont Yankee Cover-up...the documents 1

Explaining the documents

8 Vermont Yankee Cover-up...the documents 2 

 Explaining the documents
9 Vermont Yankee Cover-up...the documents 3 

 Explaining the documents

10Vermont Yankee Cover-up...the documents 3

Explaining the documents

11 Vermont Yankee Cover-up...the documents 3

Explaining the documents

12Vermont Yankee Cover-up...the wrap up 


Saturday, January 12, 2013

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.
James Kim
Project Manager, DORL
U.S. Nuclear Regulatory Commission

Originally posted on Dec 4, 2012


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
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 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 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 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 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 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 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 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 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 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 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 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 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 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. 


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 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 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 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.


Mike Mulligan
Hinsdale, NH