Sunday, February 15, 2015

The NRC's GDC 17 Pilgrim Plant Proviso?

My commentary? 

I don't think the ops went into Juno with an idea to shutdown. I think upper management said we will tell you when to shutdown! 
From then on, ops was ticked off at management, let just say, ops didn't heavily participate in helping management in the beginning to shutdown the plant. 
The NRC was in the control room! 
Like to know the panel alarms walking toward Juno...they must have a cheat sheet with indications based on past LOOPs in winter storms. 
Again, it looks like poles failed outside the plant, as the NRC says, "the licensee has no control outside their property". Hmm, what was all that work with separating the four lines in the Millstone. Something about one line not falling over and knocking down another?
This NRC tack cheats the community with understanding what is going on outside the property leading to many LOOPs. So a giant precursor to a station blackout generated offsite is beyond the preview of the NRC...it sounds too bureaucratic to me. I am disappointed the new inspection report don't carry an explanation of this. Was it part of a NRC cover-up?     
I think Pilgrim has the responsibility to understand the big picture with the lines surrounding their plant. Entergy could have called in big wig transmission system engineers to access the condition of the lines…say out to 5 miles. The NRC could have asked Entergy to preform this and put the information on the docket. As Entergy said yesterday, the grid wasn't reliably capable of transmitting Pilgrim power. 
The two lines go out many miles through one small right of way, by the way, the smaller line follow alongside the 345 lines for many miles. 
It looks like to me maybe from two or three miles from the plant, the two line right of way corridor goes out...it is the wooden poles they are talking about? Once getting to the first substation or switch-yard two miles...from then on its modern new poles and lines. 
This plant has an astounding lack of power line diversity and it isn't in accordance to GDC 17. 
Is Pilgrim having troubles getting a permit for the line upgrade? Can you even imagine the cost of separating the lines. Sounds like they are boxed in. 

Appendix A to Part 50—General Design Criteria for Nuclear Power Plants

Criterion 17—Electric power systems. An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents. 
The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure. 
Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on
The Pilgrim Plant proviso and dangerous!!!! This is where the NRC rules are dangerous. 
separate rights of way) designed and located so as to minimize to the extent practical the likelihood of their
What does this mean and specifically how do they control the simultaneous failure risk? These are the words Pilgrim lives or dies by.    
simultaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits  shall be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained. 
Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

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