This was part of my pitch trying to get the OIG auditors to make a case study on the 2.206 failure over the Pilgrim SRVs.
My Thinking NotesTitle: 10 CFR 2.206 Petition REPilgrim Nuclear Power StationDocket Number: (n/)Location: teleconferenceDate: Thursday, April 11, 2013Would you look over this Pilgrim 2.206 prehearing transcript.Upon first installation with the so caled new SRVs in 2011, the first leak occurred within two weeks of first heat-up.I have had a lot of experience with 2.206s. The routine of the process changed without notifying me. The chairman was being rude to me and unprofessional…I interpreted this behavior as intimidation and part of a coverup. I clearly stated it in the meeting. Hope they saved the recording of this? The tone of this was horrid.Why wasn’t there a investigation over this 2.206 process intimidation?Why didn’t somebody in the meeting report that mike felt intimidation in the proceeding? Why no transparent investigation of it?There were some 15 to 20 officials listening in on the bridge. Why didn’t somebody report that mike felt intimidation and a cover-up here? A least a investigation to cover the NRC’s asses. Maybe if the OIG got involved, ordered a huge special inspection in 2013…maybe the 2015 SRV blizzard event wouldn’t have happened and Entergy would have made the rest of their bad actor plants to straighten up.My Pilgrim 2.206 date: March 7, 2013ANO’s dropped stator: March 31, 2013***I requested in the 2013 2.206 the Pilgrim SRV problem be referred to the OIG. Was it referred to OIG? I considered the OIG a black box. How was my OIG complaint dispositioned? I frequently get from the NRC inspectors, “I’ll refer your complaint to the OIG”. I have no idea if the resident sent the message to OIG, if the OIG dispositioned the complaint and why was it rejected. Is the OIG living in Russia? Is the NRC residents lying to me when they say they are sending my issue to the OIG, just to get me off their backs? The agency and OIG treats us so disrespectfully.Why didn’t higher officials not in the meeting sense there was improprieties going with our problem “Mike” after reading the transcripts?Why wasn’t this reported to the OIG?If you think the system is straight, you would think, if all the non public licensee reports about the magnitude of the leaks and poor testing leading up to this transcript, the NRC would require Pilgrim to shutdown and replace the SRVs. There was scant public reporting about the malfunctioning srvs, the down powers and shutdown required to replace the valves. The bureaucrats by this excessive secrecy are just protecting themselves from accountability?We felt as Vermont Yankee was wobbling towards permanent shutdown, the NRC was giving Pilgrim special compensations outside the rules and laws of the NRC. We felt the NRC was withholding inspection resources from the Pilgrim in order to make their record look better than deserved? ANO and Pilgrim were quickly going down the tubes during this period, why couldn’t this all be prevented by the activities of the NRC and OIG.Why didn’t the LER system and inspection report system work during this? There was precious little reporting on the troubles of these valves until the next big blizzard in 2015. There was a white finding in this. The finding should have been much higher than it was. All valves should have been inop since 2011 based on the quality of the valves was unknown. The backup power line was unreliable too. It should have been at a much higher violation level. To date, it has been reported as test stand damage to the valves. I got from lead inspector with the upcoming inspection report that Entergy still hasn’t done a root cause on the SRV failures.Believe me, it is very painful for me to read my comments in the transcripts. I have very poor verbal communication skills when I am nervous and under pressure.Why didn’t the 2013 blizzard 2.206 process work to prevent the dysfunctions in the 2015 Blizzard? I am anticipatory, the NRC is reactionary. Believe me on predicting the future, there is no evidence available about future events. If you are excessively evidenced based, you can never disrupt the upcoming accident.In hindsight with all the information, all the licensee corrective action and other internal reports, why couldn’t I make my case in real time. Because I didn’t have all of the available evidence. The NRC needs triplicate proof perfect evidence and never obtainable facts in order to get enforcement action.Do I just have a grudge with Entergy? A few years or months prior to Pilgrim, I put a 2.206 on the Vermont Yankee SRV actuators. They put in new SRVs just like Pilgrim did. Upon first leak rate testing with the new SRV pneumatic actuators one failed. The actuator shaft buna seals got brittle and leaked based on too much heat. Two of us put in 2.206s trying to figure out what failed. Information was terribly sparse. As VY controversy pick up steam and the politicians got involved, the NRC got sensitive to their credibility. Many months later in an inspection report (and LER), the IR disclosed VY put in inferior environmental grade SRVs in the plant. They needed Type I SRVs, but there were no replacements available. The vendor talked them into putting in type II SRVs. The heat damage these guys. I don’t think the NRC gave permission via a public discloser it is ok to put information inferior grade SRVs into the plant. Why didn’t the NRc demand a 50:59 to allow VY to put inferior grade SRVs into the plant?At this point, I felt the NRC lost control of enforcing environmental and safety regulations on the SRVs. I feel it is happening all over the industry. I feel 1000 times more sure it is still going on today. Any third world reactor can run at 100%. It is much more difficult to align the plant for the worst design event.Pilgrim has the worst LOOP rate in the industry. The average is about 2 LOOPS per lifetime. LOOP rates are calculated into all violations and all sorts of other issues in the plant. The standard-generic rate for safety analysis and violations is about 3.5 LOOPs per lifetime. Pilgrim’s LOOP rate is beyond 21 LOOPs and we aren’t counting in the early years. Pilgrim’s is seventeen times worst than the inputted into safety analysis rate. One wonders why the real LOOP rate as penalty, isn’t inputted into all violations and safety analysis?The OIG by me and others think this branch of the NRC as highly dysfunctional. We consider the OIG as a paper tiger. I had discussions with a high OIG official concerning the OIG’s investigation on San Onofre defective steam generator and the NRC response to this. He talked about the OIG is severely hemmed in because the they can’t challenge any NRC’s staff inspections and safety analysis. He talked about using tricky interview and investigative techniques to write up the San Onofre. The OIG needs to gear up with plant and oversight expertized to challenge any staff evaluation or activity at any plant. We think this OIG restriction comes from the utilities big bucks through the politicians influence over the NRC, limiting the capabilities of the OIG.Loops and paper tiger OIGMy Pilgrim 2013 2.206March 7, 2013Bill BorchardtExecutive Director for OperationsU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001Dear Mr. Bochardt,Request an emergency and for a exigent bases, that the Pilgrim Nuclear plant be immediately shut down.Don't tell me just before the Nor'easter Nimo struck the Pilgrim plant with a leaking safety relief valve and down at 80%, Entergy was intending to operate that plant with a defective leaking safety relief valve till the next refuel outage? Tell it ain't so. It certainly looks like with the current leak today that is intending to operate till next month.Is the game plan today to incrementally increase reactor power from 94% by 1% to see if a new SRV leak is getting worse?Timeline:1) New three stage safety relief valves installed in the plant around May 2011.2) First leak and shut down on Dec, 26. 2011 (SRV RV-203-3D).3) Second leak and shut down on Jan 20, 2013 (SRV RV-203-3B).4) Third leak occurred a few weeks later and the plant was at a restricted to 84% power...the Nemo blizzard Feb 9, 2013 tripped the plant. The NRC promised these valves are fixed before startup. (SRV RV-203-3B).5) Basically, they operated for 20 days at 100% power operation post shutdown, then reported on Feb 27 the plant is operating at 94% power with no explained reason until today. The reason for the down power was kept secret from the public.6) Today March 7, 2013 I called the NRC's public relation people and the agency told me they had indications of a leak and that is why the plant is at a restricted power level.Don't forget the repetitive nature of the recently broken scram discharge volume vent and drain valves...implies Entergy is incapable of maintaining safety components of a nuclear plant.The repeated nature of the failure of the safety relief valves means Entergy doesn't know the mechanism of the failure...it is a common mode failure. The design and manufacture of these valves are defective and it is extremely unsafe to operate a nuclear plant with all safety relief valves being INOP. A condition adverse to quality...The NRC should have made a public comment about the new leaking safety relief when they first became aware of th leak. The implication is the agency was going to allow the plant to operate with unsafe SRVs until the refueling outage next month. The NRC is involved in a serious cover-up of an extremely unsafe operation of a nuclear power.1) Request an immediate shutdown the Pilgrim Plant.2) The is the second time I requested a special NRC inspection concerning the defective SRV valves.3) Not allow the plant to restart Pilgrim until they fully understand the past failure mechanisms of the four bad new three stage safety relief valves.(April 18 2017-again below, I request the paperwork trail with how this got to the OIG and its disposition of my request)4) Request the OIG investigate this NRC cover-up to keep an unsafe nuclear plant at power.
I doubt anything will change. It was a pleasant discussion. They are captured by the monstrous system just like everyone else.
*I received this email on Good Friday. I thought I was being spammed. I knew this was a holiday for the NRC employees. I looked at the document carefully, figured out it was the real deal. Within a hours, I got a call back from the OIG official.Today at 12:19 PM
Mr. Mulligan,Thank you for taking the time to meet with us this morning. The meeting was very informative and forthright. You provided us valuable material about the application of 10 CFR 2.206 from the petitioner’s perspective. Please reach out to any of us if you think of anything that can help us in our audit.Many thanks,Deyanara Gonzalez Lainez, MBA, MSMAuditorNuclear Reactors Safety Audit TeamOffice of the Inspector GeneralU.S. Nuclear Regulatory Commission
Gov bureaucrats are usually very sensitive with sending something on a holiday. Sending it on a particular holiday can highlight the agenda of the meeting sometimes.
So I figure, I am going to be crucified or made the savior of the nuclear industry.
This is the only 2.206 that ever got past the prehearing process with me. It was successful in many ways. I got a prime example in Pilgrim where this process completely broke down.
Dear Mr. Mulligan:The Office of the Inspector General (OIG) for the U.S. Nuclear Regulatory Commission (NRC) is conducting the Audit of NRC’s 10 CFR 2.206 Petition Review Process. Your petition filed on March 26, 2015, regarding the Vermont Yankee Nuclear Power Station and Kewaunee Nuclear Power Plan, is part of the audit sample selected for analysis. We would like to meet with you to discuss any insights you have on the 10 CFR 2.206 petition review process from the petitioner’s perspective and any specific concerns you had about the review of this petition. Your petition and its supplements are in the NRC's Agencywide Documents, Access and Management System (ADAMS) under Accession No. ML15090A487, ML15198A091, ML15286A003, and the Final Director’s Decision under ML16054A731.This OIG audit began on February 13, 2017, and its objective is to determine whether NRC staff follow agency guidance consistently in reviewing 10 CFR 2.206 petitions, and take steps to ensure appropriate information supports NRC decisions on 10 CFR 2.206 petitions.If you agree to this meeting, can you please let us know when you might be available to meet next week? The meeting will take about an hour and will be conducted as a team conference call. Please provide us the best number to call you.Respectfully,Deyanara Gonzalez Lainez, MBA, MSMAuditor
I appreciate your interest in me. I never have any confidentiality or anonymity needs in any of this. Sure, at your convenience next week. Just name the date and time. I will make myself available for the discussion.A more controversial 2.206 would be the one surrounding the SRVs at Pilgrim in 2013. It shows where the 2.206 process utterly failed its intended purpose. But we can get to my themes going your way.Can you follow all the rules, but not meet the intent of the will with all the people of the USA?Our highest national security priority is our collective faith in government...trusting our government. I love the USA with all of my heart.( I love our adversarial court system)Sincerely,Mike MulliganHinsdale, NH