The old NRC two step with not answering me? I ask for it to be put on the docket...sound like it won't.
I bet you they don't like me pointing fingers on the guy who signed the LER....
This is a habit of the NRC... minimizing the NRC's profile...not giving me a reason for it.
So they interpret "deliberate" and "intent"...it is all a educated word game...they make these regulation unenforceable. They use regulations in a way that doesn't control the bad behavior of the licencee or the NRC itself. The hurdle of the standard is so high you need the culprit to admit his intent and it being deliberate...that is how the industry weakened federal oversight. I bet you they don't like me pointing fingers on the guy who signed the LER....
This is a habit of the NRC... minimizing the NRC's profile...not giving me a reason for it.
From: "Guzman, Richard"nrc .gov>
To: 'Michael Mulligan'
Sent: Thursday, June 13, 2013 6:20 PM Subject: RE: 2.206 Petition re: Pilgrim Nuclear Plant SRVs - PRB Teleconference 6/11/13, 3
Mr. Mulligan,
The PRB has received your messages below and it will be included in the Board’s consideration of your 2.206 petition request.
Sincerely,
Rich GuzmanSr. Project ManagerNRR/DORL/LPL1-1US NRC
The NRC needs unattainable proof of deliberateness and intention...
§ 50.9 Completeness and accuracy
of information.
(a) Information
provided to the Commission by an applicant for a license or by a licensee or
information required by statute or by the Commission's regulations, orders, or
license conditions to be maintained by the applicant or the licensee shall be
complete and accurate in all material respects
§ 50.5 Deliberate misconduct.
(a) Any
licensee, applicant for a license, employee of a licensee or applicant; or any
contractor (including a supplier or consultant), subcontractor, employee of a
contractor or subcontractor of any licensee or applicant for a license, who
knowingly provides to any licensee, applicant, contractor, or subcontractor,
any components, equipment, materials, or other goods or services that relate to
a licensee's or applicant's activities in this part, may not:
(1) Engage in
deliberate misconduct that causes or would have caused, if not detected, a
licensee or applicant to be in violation of any rule, regulation, or order; or
any term, condition, or limitation of any license issued by the Commission; or
(2)
Deliberately submit to the NRC, a licensee, an applicant, or a licensee's or
applicant's contractor or subcontractor, information that the person submitting
the information knows to be incomplete or inaccurate in some respect material
to the NRC.
(b) A person
who violates paragraph (a)(1) or (a)(2) of this section may be subject to
enforcement action in accordance with the procedures in 10 CFR part 2, subpart
B.
(c) For the
purposes of paragraph (a)(1) of this section, deliberate misconduct by a person
means an intentional act or omission that the person knows:
(1) Would cause
a licensee or applicant to be in violation of any rule, regulation, or order;
or any term, condition, or limitation, of any license issued by the Commission;
or
(2) Constitutes
a violation of a requirement, procedure, instruction, contract, purchase order,
or policy of a licensee, applicant, contractor, or subcontractor.
[63 FR 1897,
Jan 13, 1998]
From: Michael Mulligan
Sent: Thursday, June 13, 2013 5:19 PM
Subject: Re: 2.206 Petition re: Pilgrim Nuclear Plant SRVs - PRB Teleconference 6/11/13, 3-4p
Mr Guzman,
In addition:
So I am saying Entergy’s
Ralph A. Dodds, III (Director, Nuclear Safety Assurance) intentionally
materially mis-represented the facts and falsified a federal document with a
signature…in that he stated there were “no” three stage SRV leakage problems
anywhere out in the nuclear industry in LER 2011-007-00.
I request that the NRC
charge him with falsification?
LER 20011-007-00
“There are no previous first stage leakage occurrences with these safety relief valves since all four Safety Relief Valves were newly installed in April/May, 2011, during Refueling Outage 18."
"However, the industry has experienced leakage with otherTarget Rock Model safety relief valves at other plants."
This below sentence in
2013-02-00 indicts Mr. Dodds in LER 2011-007-00. Doesn't this whole deal with
the SRVs remind us of the Palisades SIRWT? In the LER letter dated of Feb 27,
2013, “he knew or should have known” that many plants with Target Rock three
stage SRV where leaking. Including new valves upon first startup.
"The industry has experienced numerous instances where SRV
leakage has occurred at other plants with other Target Rock Model three stage
safety relief valves"
You should consider a model of a SRV valve as
having three stages and near identical design independent of size…
As a note, per 10 CFR 21 bellows failure event
report number # 4896, this implies they are the same model and all leakers.
"The following plants are running with
bellows P/N303480-1 installed: Limerick 1 & 2, Pilgrim, and J.A.
Fitzpatrick."
It is neat how he restructured the below sentence...it
is close, but with a completely different meaning. It is not new information!
2013: "The industry has experienced
numerous instances where SRV leakage has occurred at other plants with other
Target Rock Model three stage safety relief valves"
...2011: "However, the industry has experienced leakage with other Target
Rock Model safety relief valves at other plants."
I never have any
anonymity or confidentially needs!
He lied about no past "leakage" in
VY SRVs and no leaks in three stage relief valves...
Mike
Mike
I get it, the NRC won’t find anyone to indict themselves or their buddies in the group. Not enough evidence Mike, again.
The documents are contaminated much like a brain surgeon using the bathroom and then not washing his hand…then going back to your open brain surgery and sticking his ungloved fingers in your open brain.
It is as dirty as that…with as much consequences and significance…
From: Michael Mulligan
To: "Guzman, Richard"
Sent: Wednesday, June 12, 2013 12:16 PM
Subject: Re: 2.206 Petition re: Pilgrim Nuclear Plant SRVs - PRB Teleconference 6/11/13, 3-4p
The truth was there were three leaks…two from the C second stage and one from the D pilot valve in LER 20011-007-00. In LER 2011-007-00 Entergy only admitted to one leak.
The first LER states only that the 3D pilot valve was repaired/ replace and retested…no talk with fixing the 3C second stage. No correcting it on the update. Trying to make a San Onofre low profile…like to get them to the outage and forgo a public hearing? We know there is no hearing with Pilgrim…but does Entergy has the San Onofre disease of doing whatever they can to limit public exposure up to and including severely sabotaging themselves.
LER 2011-007-00
“There are no previous first stage leakage occurrences with these safety relief valves since all four Safety Relief Valves were newly installed in April/May, 2011, during Refueling Outage 18.”
LER 20011-007-00
“The identified condition is a leaking SRV pilot. Based on a review of plant data, the only pilot to exhibit signs of leakage is RV-203-3D. The leaking pilot has been replaced."
From: Michael Mulligan
To: "Guzman, Richard"
Sent: Wednesday, June 12, 2013 12:16 PM
Subject: Re: 2.206 Petition re: Pilgrim Nuclear Plant SRVs - PRB Teleconference 6/11/13, 3-4p
Mr Guzman,
Could you add this as an addendum to this 2.206? (Allegation). I am trying to better explain the question posed to me in the 2.206 yesterday.
The intentional falsification was…Entergy intentionally gave incomplete information to me and the public to make the leaking problem seem smaller than it really was from 2011-007-02. The quality of the information on the first LER and its update is pathetic.
Could you add this as an addendum to this 2.206? (Allegation). I am trying to better explain the question posed to me in the 2.206 yesterday.
The intentional falsification was…Entergy intentionally gave incomplete information to me and the public to make the leaking problem seem smaller than it really was from 2011-007-02. The quality of the information on the first LER and its update is pathetic.
This is a highly technical and complex endeavor. You could swamp the good citizen with a technical nuance they wouldn’t understand that is technically correct…but on big picture it could be a flagrant falsification with tricky technical wording.
The pattern is, they submit a abysmally inaccurate first LER..they slowly correct it over many years. Or some of the misinformation. The product of the misinformation isn't newly developed information...it is just sloppiness.
The truth was there were three leaks…two from the C second stage and one from the D pilot valve in LER 20011-007-00. In LER 2011-007-00 Entergy only admitted to one leak.
The first LER states only that the 3D pilot valve was repaired/ replace and retested…no talk with fixing the 3C second stage. No correcting it on the update. Trying to make a San Onofre low profile…like to get them to the outage and forgo a public hearing? We know there is no hearing with Pilgrim…but does Entergy has the San Onofre disease of doing whatever they can to limit public exposure up to and including severely sabotaging themselves.
Yea, wink, wink, we believe you four month later you actually fixed it...you just forgot to put it in the federal documents.
What was the motivation to only admit one leak?
So why didn’t Entergy state honestly in 2011 that these are all the leaks we had to date: two with the 3C second stage and one leak with the 3D pilot valve?
I think they were being intentionally word tricky…gaming language in the ends of obscuring the truth… with only admitting the first stage leak. And then not to admit the second stage leak until many months later? Is it going on throughout the industry thanks to The Three Wise Monkeys "see and hear no evil" NRC.
LER 2011-007-00
“There are no previous first stage leakage occurrences with these safety relief valves since all four Safety Relief Valves were newly installed in April/May, 2011, during Refueling Outage 18.”
LER 2013-002-02
"On May 18, 2011 and November 25, 2011, SRV RV 203-3C second stage pilot valve minor leakage was observed."
"On May 18, 2011 and November 25, 2011, SRV RV 203-3C second stage pilot valve minor leakage was observed."
Is this below called being a professional engineer or a highly competent safety engineering organization? How can you trust the honesty Entergy…did they address the 3C or didn’t they?
LER 2007-007-00 says the second stage wasn’t addressed. Why didn’t the NRC make them fix the inaccuracy? If they can't keep their federal safety paperwork straight...should they operate a nuclear plant? You can't yank a license for the NRC to oversee nuclear power plant? We think the first LER is the most important.
Again, it is beyond atrocious since 2011 the NRC allows Pilgrim get away with not understanding what has caused these "new" leaking valves, with all the shutdowns and power reductions.
Again, it is beyond atrocious since 2011 the NRC allows Pilgrim get away with not understanding what has caused these "new" leaking valves, with all the shutdowns and power reductions.
LER 20011-007-00
“The identified condition is a leaking SRV pilot. Based on a review of plant data, the only pilot to exhibit signs of leakage is RV-203-3D. The leaking pilot has been replaced."
"The pilot stage of RV-203-3D was removed. Following the shutdown, RV-203-3D was repaired with a new pilot valve and the plant was returned to full power operation."
LER 2013-002-02
“On December 26, 2011, SRV, RV-203-3D first stage pilot valve experienced leakage that exceeded the operability criteria while operating at full power. Plant was shutdown as required by TS 3.6.D.2, RV 203-3C and 3D were repaired and the plant returned to full power operation.”
Entergy is implying the three stage SRV shows no indication of ever having leakage. This is how college educated do falsifying federal document? Hyper technically correct, but holistically on the big picture lying through their teeth?
It depends on what the meaning of is, is? Or “model” or when to insert “three stage relief”?
The first implies there is no concern of industry wide issue with the three stage SRV valves, the second implies there are widespread issues with leaking three stage relief valves.
Adding three stages to the sentence on 2013-02 flagrantly changes the meaning of the sentence. These guys are college educated and their bosses….I don’t buy it this is unintentional. The intent was to use sparse technical working that maybe a technical insider would understand…but outsiders would interpret it in a different fashion. Its intent was to be deceptive to outsiders and prevent them from participating in licensing and operating safety issues.
I could give the NRC other examples, exactly like this on inaccurate LERS …the VY SRV treaded seal?
It depends on what the meaning of is, is? Or “model” or when to insert “three stage relief”?
The first implies there is no concern of industry wide issue with the three stage SRV valves, the second implies there are widespread issues with leaking three stage relief valves.
Adding three stages to the sentence on 2013-02 flagrantly changes the meaning of the sentence. These guys are college educated and their bosses….I don’t buy it this is unintentional. The intent was to use sparse technical working that maybe a technical insider would understand…but outsiders would interpret it in a different fashion. Its intent was to be deceptive to outsiders and prevent them from participating in licensing and operating safety issues.
I could give the NRC other examples, exactly like this on inaccurate LERS …the VY SRV treaded seal?
LER 20011-007-00
"However, the industry has experienced leakage with other Target Rock Model safety relief valves at other plants."
LER 2013-002-02
‘The industry has experienced numerous instances where SRV leakage has occurred at other plants with other Target Rock Model three stage safety relief valves”
"However, the industry has experienced leakage with other Target Rock Model safety relief valves at other plants."
LER 2013-002-02
‘The industry has experienced numerous instances where SRV leakage has occurred at other plants with other Target Rock Model three stage safety relief valves”
The only way you can make this below statement true is see and calculate the whole cohort of risk with leaking SRV valves. Like testing and measuring in all leaking SRV valves the opening set point inaccuracy throughout the industry…does leaking SRVs cause set point inaccuracy and figure out the prevalence of it to put into the risk analysis calculation?
Again they are using isolated single event risk when everyone knows it is a common mode failure for all four SRVs…admitted in this LER. They have no idea yet what was the casual factor with the leaking valves or bellows failure.
Any safety risk analyses engineer worth is salt would know the 1.OE-7 number is a complete falsification and is totally inaccurate within this issues with leaking SRV global safety. The idea you could “bound safety” without understanding the issues that caused this. These guys are “superstitious witch doctors” not based on science!
A well trodden tool to knowingly overstate safety at a nuclear plant.
Again they are using isolated single event risk when everyone knows it is a common mode failure for all four SRVs…admitted in this LER. They have no idea yet what was the casual factor with the leaking valves or bellows failure.
Any safety risk analyses engineer worth is salt would know the 1.OE-7 number is a complete falsification and is totally inaccurate within this issues with leaking SRV global safety. The idea you could “bound safety” without understanding the issues that caused this. These guys are “superstitious witch doctors” not based on science!
A well trodden tool to knowingly overstate safety at a nuclear plant.
LER 2013-002-02
"The impact of setpoint drift (0.8% below the 3% tolerance) is considered to be bounded by delta change in core damage frequency of less than 1.OE-7."
"Pilot S/N 23 RV-203-3B
SRV Position 23 RV-203-3B
As-Found Deviation 23 RV-203-3B"
"The impact of setpoint drift (0.8% below the 3% tolerance) is considered to be bounded by delta change in core damage frequency of less than 1.OE-7."
"Pilot S/N 23 RV-203-3B
SRV Position 23 RV-203-3B
As-Found Deviation 23 RV-203-3B"
Again, this below admission in this late stage was to prettify 2011-007-00. It takes them basically two inaccurate LER federal documents and four months to come clean.
LER 2013-002-02
“During the outage for RV-203-3D, the entire RV 203-3C was replaced with a new valve.”
“During the outage for RV-203-3D, the entire RV 203-3C was replaced with a new valve.”
Sincerely,
Mike Mulligan
Hinsdale, NH
No comments:
Post a Comment