What is going on here? The NRC recently tazed Millstone in a 2002 10 CFR 50.59 violation and now Clinton is being zapped by a non sited 1979 50.59 violation. What is the message the NRC is trying to say?
The national problem with screenings, 50.59 and LAR...you never know what the sample size is compared to all screenings, 50.59 and LARs. The complaint with the San Onofre SG 50.59 is the agency is resourced restrained and the agency is a sample agency. The only get to sample a small amount of the documents and report. Basically a plant with more than 800 employees can bury the two or more inspectors on site with paperwork.
Basically a 50.59 is a analysis if a issue needs permission to change the licencing conditions of a plant.
I still don't understand what caused Clinton in 1997 to discover their Div 1,2 and 3 breaker weren't fully seismically qualified in the racked out position. It is interesting, why not always remove the racked out breaker from the compartment? An empty breaker bus cabinet has to seismically safety. Then it will be seismically qualified
On February 27, 1997, the licensee generated Condition Report (CR) 1-97-02-273, “ABB [ASEA Brown Boveri] and General Electric Breakers Not Seismically Qualified in Racked Out Position.”So once they discovered the breakers weren't fully seismically qualified, they were required to enter Tech Specs and enter a LCO. At some near point, if not fixed they were facing a shutdown. Millions of bucks a day were on the line by shutting down unnecessarily.
So the solution was to write up a silly evaluation saying if the racked out breaker was a short time duration, the risk were so slight as to not required NRC permission. What this really is doing by getting NRC permission according to the lessens learn from San Onofre, is to informing the public and bring them along on licencing changes. But this is circa 1997. It also required Clinton to write a public evaluation about the possible change.
It does increase risk if the Inop is a short duration? This risk perspective goes to their heads if they are not careful. Again it is certainty/uncertainty gaming...selectively releasing information to what is favorable.The inspectors reviewed NEI 96-07, Section 4.3.2, “Does the Activity Result in More Than a Minimal Increase in the Likelihood of Occurrence of a Malfunction of an structure, system, or component (SSC) Important to Safety?,” which stated that changes in design requirements for earthquakes, tornadoes, and other natural phenomena should be treated as potentially affecting the likelihood of malfunction.
On March 20, 1997, the licensee completed “Risk Evaluation for Seismically Indeterminate Switchgear Configurations,” which was included as an attachment to the licensee’s letter Y-106400 to address the switchgear’s seismically unanalyzed conditions. The purpose of the evaluation was to address the risk significance of the seismically unanalyzed conditions. The evaluation concluded there were no adverse impacts on the intended safety function of the affected switchgear, and other adjacent cubicles’ in-service devices (i.e., relays, instruments, etc.); provided the duration of the seismically unanalyzed conditions only existed for a limited period of time.This is when it was entered into the USAR. So it was inop from Feb 27 to the illegal, unethical and inappropriate April 22 entry into the USAR. So why didn't the NRC enforce tech specs and a shutdown? You want to make these guys pay a horrendous price for not purchasing and acquiring appropriate grade and tested safety equipment. You want to give them a incentive to fix tier shaky bureaucracy. See, this is what I am talking about with incentivizing a big corporation to do the right thing. Was the 1982 $92 million dollar fine to the Clinton nuclear plant the largest fine by the agency? This was three years after TMI???
So in the below, we see the terrible flaw in the NRC oversight of nuclear plants. We get to see the hyper technical violations and how they proportion violations through risk perspectives in the NRC inspection reports that nobody understands. We never get to see the real story behind the ultra technical story...the real mover with why the problem develops. Illinois Power was right in their 199 evaluation and the 2015 NRC 50.59 inspection report was completely off base according to the perspectives on the condition of the plant in 1997. A grievous wrong has been done to Illinois power and the Clinton nuclear plant by this 50.59 violations.
So maybe a 1997 historic perspective is in order with the Clinton plant.
Most of the nukes is Illinois including all of Comed/ Exelon nuke plants were in big trouble with the NRC towards the end of the 1990s. Illinois Power tried to build a single plant nuclear plant...they made a mess out of it. By 1997, the plant had been shutdown for a year, two more years of shutdown was ahead of them. At the 1997 inspection violation point, the future of the Clinton nuclear plant was very bleak. Maine Yankee was permanently shutdown in 1997 and the two plant Zion plant owned by Commonwealth Ed was heading towards a permanent shutdown in 1998. Region III had to be a absolute basket case in 1997. In 1997 the QA and safety bureaucracy in the Clinton plant was in total disarray and utter breakdown?
- In 1982 the Nuclear Regulatory Commission issued ten separate stop-work orders at the Clinton site resulting from concerns that inspection and documentation of completed work was not keeping pace with construction. That same year IP agreed to pay a $90 million NRC fine, stemming from charges that NRC quality control inspectors had been intimidated at the construction site and the company failed to appropriately document and implement electrical quality assurance programs.
- In 1997, it was also said to be producing "some of the highest electric rates in the midwest". After less than a decade of operation the plant's original owner, Illinois Power, had to close it in 1996 following some technical problems and safety violations resulting in a $450,000 fine.( Shutdown from 1996 to 1999)
- Having deduced that it was not economical to own and operate only one nuclear generating station in the newly deregulated market, they kept it shut down during around 3 years whilst looking for an interested buyer.[6] Exelon Corporation bought it for a more modest price of $40 million, with the purchase including the fuel in the reactor vessel and responsibility of all the radioactive waste in the spent fuel storage pool. The Operator and Owner is the Exelon Corporation.
- On April 22, 1997, the licensee applied the results of the evaluation and updated the safety analysis report per USAR Change 7-209, “Section 3.10, Qualification of Seismic Category I Instrumentation and Electrical Equipment.”
In 1982 the Nuclear Regulatory Commission issued ten separate stop-work orders at the Clinton site resulting from concerns that inspection and documentation of completed work was not keeping pace with construction. That same year IP agreed to pay a $90 million NRC fine, stemming from charges that NRC quality control inspectors had been intimidated at the construction site and the company failed to appropriately document and implement electrical quality assurance programs.
This issue was a
On February 27, 1997, the licensee generated Condition Report (CR) 1-97-02-273, “ABB [ASEA Brown Boveri] and General Electric Breakers Not Seismically Qualified in Racked Out Position.”What is going on here? The NRC zapped Millstone of a 2002 10 CFR 50.59 violation. And now Clinton is being zapped by a non sited 1979 50.59 violation.
Basically in 1997 Clinton discovered having a switchgear in a racked out position, they had no proof this position was seismically qualified. At this point, they were supposed to enter tech specs, I am not sure of the TS requirement and when they needed to be shutdown.
Instead Clinton changed the UFSAR without NRC permission saying if it was less than 24 hours.
On February 27, 1997, the licensee generated Condition Report (CR) 1-97-02-273, “ABB [ASEA Brown Boveri] and General Electric Breakers Not Seismically Qualified in Racked Out Position.”
The evaluation concluded there were no adverse impacts on the intended safety function of the affected switchgear, and other adjacent cubicles’ in-service devices (i.e., relays, instruments, etc.); provided the duration of the seismically unanalyzed conditions only existed for a limited period of time. On April 22, 1997, the licensee applied the results of the evaluation and updated the safety analysis report per USAR Change 7-209, “Section 3.10, Qualification of Seismic Category I Instrumentation and Electrical Equipment.”
The evaluation concluded there were no adverse impacts on the intended safety function of the affected switchgear, and other adjacent cubicles’ in-service devices (i.e., relays, instruments, etc.); provided the duration of the seismically unanalyzed conditions only existed for a limited period of time.
On April 22, 1997, the licensee applied the results of the evaluation and updated the
safety analysis report per USAR Change 7-209, “Section 3.10, Qualification of Seismic
Category I Instrumentation and Electrical Equipment.”
Severity Level IV-Green.
The inspectors identified a finding of very-low safety significance, and an
associated Non-Cited Violation of Title 10, Code of
Federal Regulations Part
50, Section 59, “Changes, Tests and Experiments,” (effective January 1, 1997)
for a procedure change dated May 2, 1997, where the licensee allowed
safety-related switchgear to operate for a limited period of time during plant operation
in equipment configurations that were seismically unanalyzed. Specifically, for
Safety Evaluation Log 97-060, “CPS [Clinton Power Station] Procedure No.
1014.11,” Revision 0, the licensee failed to include a written safety
evaluation which provided the bases that concluded for all switchgear
configurations that a seismically unanalyzed condition does not involve an
unreviewed safety question, and the possibility for a malfunction of a
different type than any evaluated previously in the Safety Analysis Report may
be created. The licensee entered the issue into their Corrective Action Program
as Action Request 02471583, “NRC Mod 50.59 Inspection Safety Eval 97-060 for
CPS 1014.11,” dated March 20, 2015.
See, this is what I am talking about with incentivizing a big corporation to do the right thing. Was the 1982 $92 million dollar fine to the Clinton nuclear plant the largest fine by the agency? This was three years after TMI???
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