Friday, January 15, 2016

NRC: Indian Point Is Obstinate With Safety Pipe leaks

So I believe outsiders and I have caused this audit. I am particularly irked with the recent fire water leak in Unit 1 wasn't made into LER. The NRC told me in Indian Point's fire water and service water re-licensing responses to them, it felt like Entergy was just babbling to them. They were giving the agency incomplete answers to the NRC questions. So the NRC was irked at Indian Point.

Ultimately what is wrong here, Indian Point put in improper and cheap fire water and service water pipe metal. They are accommodating this safety deficiency by replacing piping sections as leaks develop. They think it is the cheapest fix. They should have took a prolong shutdown decades ago to completely replace all fire water and service water piping with modern corrosion resistance piping. The piping leaks have gotten out of control. The accommodating strategy has taken resources away from other areas. This accommodation eats up employees and resources...it ultimately weakens the organization and the bureacrocy. They got runaway piping leaks at the plant plus bureaucracy problems. The best solution for the health of the bureaucracy, is you cut off the destructive complexity by replacing the piping. Are they systemically accommodating across many other areas? Then you got very few new problems with proper new pipes and little headaches with a regulator trying to jack up your complexity by pushing you into more employees, inspections and complexity caused by a improper accommodation strategy. You get what I talking about, the improper accommodation strategy slowly blinds a bureacrocy with excessive complexity. You just are juggling too many balls in the air. You are effectively stealing money from the future to support the past and the now.                 
"The corrective actions were to weld repair the affected piping followed by replacing piping with very corrosion resistant material(AL6XN)."
They had to shutdown units two's fire water for two hours. They discovered the beginning or the leak in 2008 and it got lost in their terrible work document system until a huge pipe blew out. At one point, they brought a crew into the plant to replace the weaken section of pipe with the small pin hole leak in it. They botched the replacement job, they neglected (screw-up) to replace the leaking section of pipe...it was scheduled to be replace and they replaced the wrong section of expensive pipe. 
NRC INTEGRATED INSPECTION REPORT 05000247/2015001 AND 05000286/2015001
(pg 27)The inspectors reviewed corrective action documents and WOs for identified degradation of the fire protection piping and conducted a walkdown to assess the material condition. In 2010, Entergy generated CR-IP2-2010-5187 due to the discovery of a through-wall leak in the fire protection piping downstream of valve FP-2. This leak was discovered during a UT conducted as extent of condition for a nearby through-wall leak documented in 2008 (CR-IP2-2008-0044). Entergy created WO 135106 to replace the corroded and corroding piping section. In November 2012, the WO was in a ready status and scheduled to be worked. Due to problems obtaining effective isolation for protective tagging due to valve leak-by, the repair was postponed and the work was not done. Entergy had planned a major maintenance outage for the fire protection system for May 2014 to repair leaking valves and sections of corroded piping. Despite being within the isolation boundary and ready to work, the section of piping containing the 2010 leak was not included in the scope of this work. WO 135106 was instead scheduled following Unit 3 3R18 RFO. The inspectors noted that Entergy did not consider the remaining service life of the degraded piping section when delaying the repair from 2012 to 2015. This issue was entered into Entergy’s CAP as CR-IP2-2014-6668.

That is the trouble with organizational bureaucrats...NRC and Entergy...they think the system is safe just if the paperwork is filled out and complete. The get a grade of "A+" for finding the leak, getting it in the document system and getting resources into the plant to replace the pipe...they got a "E -" for improperly executing the plant in excellence. The leak just got completely lost in the bureaucracy and their work document system. Basically the system is riddled with destructive and massive levels of priorities with too little resources. It is a too complex system with not enough funding. If they don't have enough money to properly run the facility, they just jack up the rules and procedure to compensate for what they don't have. Stick it in the beast slowly digesting facts and we won't have to spend money on the piping leaks for many years.        

We only get a terrible skimpy NRC inspection over this. We are overly dependent on the NRC disclosing these problema. What do they got, three or four NRC inspectors on the site. They got somewhat like a 1000 Entergy employees on the site. Who is likely to catch the problem first?  
December 21, 2015

Vice President, Operations
Entergy Nuclear Operations, Inc.
Indian Point Energy Center
450 Broadway, GSB
P.O. Box 249
Buchanan, NY 10511-0249

SUBJECT: PLAN FOR THE REGULATORY AUDIT OF THE SERVICE WATER INTEGRITY AND FIRE WATER SYSTEM AGING MANAGEMENT PROGRAMS PERTAINING TO THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION (CAC NOS. MD5407 AND MD5408)

Dear Sir or Madam:

By letter dated April 23, 2007, as supplemented by letters dated May 3, 2007, and June 21, 2007, Entergy Nuclear Operations, Inc. (Entergy), submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to the U.S. Nuclear Regulatory Commission
(NRC) for renewal of the operating licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3). The NRC staff documented its findings in the Safety Evaluation Report (SER) related to the license renewal of IP2 and IP3, which was issued August 11, 2009 and supplemented August 30, 2011 (SER Supplement 1), and November 6, 2014 (SER Supplement 2). Subsequent the issuance of SER Supplement 1, the NRC staff identified additional operating experience at several nuclear power plants regarding recurring internal corrosion, corrosion occurring under insulation, and managing aging effects for fire water system components. To address this operating experience, on November 22, 2013, the NRC staff issued interim staff guidance document LR-ISG-2012-02, “Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation.” In accordance with the enclosed audit plan, the NRC staff plans to conduct an onsite audit of the service water integrity and fire water system aging management programs during the week of February 22, 2016. If you have any questions, please contact me by telephone at 301-415- 6459, or by e-mail at michael.wentzel@nrc.gov.

Sincerely,
/RA/
Michael J. Wentzel, Project Manager
Projects Branch 2
Division of License Renewal
Office of Nuclear Reactor Regulation

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