Thursday, November 15, 2012

Escalation of problems with Peach Bottom’s SRVs


Originally published on Nov 15, 2012

Nov 26: Doing a little work on this for a few days...

Nov 25: How come from a period of 8/01/2001 to 11/25/2003(8) compared to 8/01/2009 to 11/25/2011(23) there are 300% more BWR's safety relief valve license event reports from the same length of time.I did a search on these terms in NRC Adams document system... 

The two year period covers the typical 28 months to two year operating cycle....

Content search on "Safety Relief valve" and "LER". 

Do you think the NRC criteria for writing LER had loosened, tightened or stayed the same. I think it loosened.

Why are there more troubles today?  

Nov 18: LER2012001
"There were no previous similar LERs identified involving an ADS SRV inoperability due to failure of the actuator diaphragm thread seal."
Well, truth be told, in the 2003 dual plant trip with SRV failures, with the SRV pilot valve stem packing failure on the steam side, the steam leak from the main valve damaged the actuator diaphragm thread seal and the heated steam damaged the diaphragm preventing opening the valve by control room switch.

...Hmmm: "The six SRVs and the one SV were replaced with refurbished SRVs / SV for the 20th Unit 2 operating cycle."

"There were a total of seven SRVs and one SV initially removed for testing and replacement during the 1 9 th Refueling Outage."

So 6 out of 7 were failures...so a 86% failure rate...430% more failure than average... 

So this outage had 500% more SRV failures than expected and the alarms bells hadn't gone off? Licensee Event Report (LER) 3-07-01: 
(2007)A historical review of SRV as-found test set points indicates that approximately20% of valves tested over time do not meet the + 1% Technical Specification set point.
Unit 2  LER 2012001 event date 9/26/2012
Based on information received from a laboratory performing Safety Relief Valve (SRV) / Safety Valve (SV) as-found testing, Site Engineering personnel determined on 9/25/12 that SRV / SV setpoint deficiencies existed with six SRVs and one SV that were in place during the Unit 2 19th operating cycle. The SRVs / SV were determined to have their as-found setpoints outside of the Technical Specification allowable ± 1% tolerance. The six SRVs outside of their Technical Specification (TS) allowable setpoint range were within the ASME Code allowable ± 3% tolerance. The one SV outside of its TS allowable setpoint range also exceeded the ASME Code allowable ± 3% tolerance. The cause of the SRVs / SV being outside of their allowable as-found setpoints is due to setpoint 
SRV 71A 24 1143-1167 1121 -2.94%
SRV 71D 16 1124-1146 1118 -1.50%
SRV 71E 81 1124-1146 1103 -2.82%
SRV 71F 19 1124-1146 1116 -1.67%
SRV 71G 82 1134-1156 1127 -1.57%
SRV 71H 17 1134-1156 1111 -2.97%
SV 70B BL-1095 1247 - 1273 1303 +3.41%
10CFR 50.73(a)(2)(i)(B) - Condition Prohibited by Technical Specifications 'Technical Specification Limiting Condition for Operation (LCO) 3.4.3 requires that 11 of the 13 SRVs / SVs be operable during operational Modes 1, 2, and 3. Contrary to this requirement, six SRVs and one SV were found with setpoints outside of the Technical Specification setpoint requirements.
10CFR 50.73(a)(2)(vii) - Common Cause Failure of Multiple Trains being Inoperable - Six SRVs and one SV were considered inoperable as a result of exceeding their allowable setpoint range based on laboratory testing. Therefore, this occurrence is considered as a common cause failure of multiple independent trains being inoperable.
There were a total of seven SRVs and one SV initially removed for testing and replacement during the 19th  Refueling Outage.

 That is a 100% failure rate and they don’t test all the rest of them...???

LER 2-10-03 reported two SRVs and one SV having their as-found setpoints in excess of the TS allowable + 1% tolerance. LER 3-07-01 reported two SRVs and one SV having their as-found setpoints in excess of the TS allowable ± 1% tolerance. LER 2-06-02 reported one SV having its as-found setpoints in excess of the TS allowable ± 1% tolerance. LER 3-05-04 reported a situation involving four SRVs having their as-found setpoints in excess of the TS allowable ± 1% tolerance.

Friday, October 26, 2012

More NRC troubles at Fort Calhoun

Jan 21:
 
The Nuclear Regulatory Commission sent Omaha Public Power District a notice in 1985 to replace Teflon as insulation in the building housing Fort Calhoun's reactor. The utility subsequently replaced it on wires that it considered at critical risk but left some in places it did not consider a safety concern.

 Commission spokeswoman Lara Uselding said her agency's oversight process relies on nuclear plant operators identifying and fixing problems while commission inspectors scrutinize that work. This system, she said, has not been successful at the Omaha plant.

"Historically at Fort Calhoun, that has not gone well and that is why they are currently under increased oversight," Uselding said.

 

I made a OIG complaint...

So I sent this to the head of Region IV OPA. I am making a official complaint against misbehavior and unprofessionalism with one of his employee. Does he have the right to retroactively block the e-mail with such a complaint, making believe they never got the complaint? Does the agency have the right to define me as a pest, thus retroactively rejecting my complaint without considering it or having a record of it.
"From: Michael Mulligan
To: "OPA4.Resource@nrc.gov"
Sent: Thursday, October 25, 2012 1:31 PM
Subject: Mr Drinks-NRC employee wrongdoing
Mr Drinks,
I 'd like to report to you I think Region IV treated me unprofessionally and disrespectfully over safety issues at the Fort Calhoun plant. In the scheme of things, this is a poor way to treat a member of the public.
I would like you to think about how the NRC treats the Palisades nuclear power plant. The poor plant NRC rating means region III has to go way above how the NRC communicates normally about a good nuclear power plant. So the NRC is disclosing any new leaks even if not required to from regulations and experimenting with novel communication approaches like webinars.
How Lara and region IV treated me is not in the spirit of region III. So there should be even better communication and more open communication from the NRC on the Fort Calhoun plant because they are a worse grade than Palisades.
I will submit, my interest in Fort Calhoun is driven by employees communicating with me over secret NRC tolerated violations at this plant.
I request you submit this to the Region IV allegations...
Mike Mulligan
Hinsdale, NH"
Say, can the agency secretly retroactively reject a complaint, meaning they read the complaint, but they were able to make believed rejecting the e-mail with prompting yahoo mail to give me a  "we were unable to deliver your message to the following address".

Is this an object lie from the NRC: "Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO]"

So, as example, I could make a complaint to Mr Drinks that one of his employees is accepting payola in return for secretly ignoring serious federal breaking of laws for big bucks. Then he has a officially approved way of making believe he didn't receive the e-mail. Or define me a pest so they could reject my payola e-mail without official record.

See, they don't want me to post their e-mail officially defining my region IV safety concerns as rejected by the NRC as a so called pest. This keeps my NRC concern out of their document historical record...uavailable for higher senior NRC executive, public and legal scrutiny.

I know for a fact the agency e-mail system wasn't overloaded...
 From: "MAILER-DAEMON@yahoo.com"
To: steamshovel2002@yahoo.com
Sent: Friday, October 26, 2012 4:44 PMSubject: Failure Notice
Sorry, we were unable to deliver your message to the following address.
<opa4.resource@nrc.gov>:
Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO]
--- Below this line is a copy of the message.
Received: from [98.139.91.68] by nm21.bullet.mail.sp2.yahoo.com with NNFMP; 25 Oct 2012 17:31:01 -0000
Received: from [98.139.91.57] by tm8.bullet.mail.sp2.yahoo.com with NNFMP; 25 Oct 2012 17:31:01 -0000
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X-Yahoo-Newman-Property: ymail-3
X-n
Message-ID: <1351186260.6348.YahooMailNeo@web163903.mail.gq1.yahoo.com>
Date: Thu, 25 Oct 2012 10:31:00 -0700 (PDT)
From: Michael Mulligan <steamshovel2002@yahoo.com>
Reply-To: Michael Mulligan <steamshovel2002@yahoo.com>
Subject: Mr Drinks-NRC employee wrong doing
To: "OPA4.Resource@nrc.gov" <OPA4.Resource@nrc.gov>
MIME-Version: 1.0
Content-Type: multipart/alternative; boundary="1797399434-584891482-1351186260=:6348"
--1797399434-584891482-1351186260=:6348
Content-Type: text/plain; charset=utf-8
Content-Transfer-Encoding: quoted-printable
=C2=A0=0AMr Drinks,=0A=C2=A0=0AI 'd like to report to you I think Region IV=
treated me unprofessionally=C2=A0and disrespectfully over safety=C2=A0issu=
es=C2=A0at=C2=A0the Fort Calhoun plant. In the scheme of things, this is a =
poor way to treat a=C2=A0member of the=C2=A0public.=0A=C2=A0=0AI would like=
you to think about how the NRC treats the=C2=A0Palisades=C2=A0nuclear powe=
r plant. The poor plant NRC rating mean
Here is another one. So we got another: "452 Too many recipients received this hour [RCPT_TO]" and "Sorry, we were unable to deliver your message" This was the terribly insulting e-mai
From: Michael Mulligan
To: "Crutchley, Julie"
Cc: "James, Lois" ; "Schmitt, Ronald" ; "Bernal-Taylor, Sara"
Sent: Thursday, September 13, 2012 9:14 AM
Subject: Re: Email Dated March 30, 2012 re Industry Root Cause Analyses
Mrs Crutchley,
I got the big picture perfect and you know it....the reason why there is more agency findings and troubles within the industry recently.
The rules of the NRC and "Allegation" aren't fair, "Just" or ethical....this attitude isn't serving the needs of our great nation.
It is legal and according to Congress...it give you, Allegations and the agency the permission to lie to me and the public! More worrisome than that, it gives you the permission to lie to yourself.
You are bigger than that!
Mike Mulligan
Hinsdale, NH
This is the rejected message...
From: "MAILER-DAEMON@yahoo.com"
To: steamshovel2002@yahoo.com
Sent: Friday, September 14, 2012 1:45 PM
Subject: Failure Notice
Sorry, we were unable to deliver your message to the following address.
:
Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO]
--- Below this line is a copy of the message.
Received: from [98.139.91.64] by nm30.bullet.mail.sp2.yahoo.com with NNFMP; 13 Sep 2012 13:14:58 -0000
Re
Content-Type: multipart/alternative; boundary="1584674120-368148426-1347542097=:15500"
--1584674120-368148426-1347542097=:15500
Content-Type: text/plain; charset=iso-8859-1
Content-Transfer-Encoding: quoted-printable
Mrs Crutchley,=0A=A0=0AI got the big picture perfect and you know it....the=
reason why there is more agency findings and troubles within the industry =
recently.=0A=A0=0AThe rules of the NRC and "Alligation"=A0aren't=A0fair, "J=
ust" or ethical....this attitude isn't serving the needs of our great natio=
n. =0A=A0=0AIt is legal and according to Congress...it give you, Alligation=
s=A0and the agency the permission to lie to me and the public! More worriso=
me than that, it gives you the permission to lie to yourself.=A0=0A=A0=0AYo=
From: "Crutchley, Julie"
To: Michael Mulligan
Cc: "James, Lois" ; "Schmitt, Ronald" ; "Bernal-Taylor, Sara"
Sent: Thursday, September 13, 2012 8:34 AM
Subject: Email Dated March 30, 2012 re Industry Root Cause Analyses
Dear Mr. Mulligan,
The U.S. Nuclear Regulatory Commission has reviewed your email dated March 30, 2012 regarding industry root cause analyses. A copy of our response is attached.
Thank you for bringing these matters to our attention. If you have any further questions or comments, please contact Ms. Lois James (Lois.James@nrc.gov) or Mr. Ron Schmitt (Ronald.Schmitt@nrc.gov), or call either, toll free, at 1-800-368-5642.
Regards,
Julie Crutchley
EMAIL DATED MARCH 30, 2012, REGARDING INDUSTRY ROOT
CAUSE ANALYSES
This is the attachment..
Dear Mr. Mulligan:
This letter is in response to the concern you brought to the attention of the U.S. Nuclear
Regulatory Commission (NRC) via an email dated March 30, 2012, and a subsequent telephone call with Mr. Ronald Schmitt and staff on April 10, 2012 regarding the quality of industry root cause analyses. Specifically, you were concerned that utilities were not performing systematic analyses for problems identified at their plants.
For an issue to be processed as an NRC allegation, the NRC first needs to determine that it meets the definition of an allegation, i.e. “an inadequacy or impropriety associated with NRCregulated activity, the validity of which has not been established.” The NRC staff reviewed your concern and, based upon our evaluation of the information that you provided, determined that your concern did not meet the NRC’s definition of an allegation. Specifically, no new or site specific information was provided which would have allowed further NRC staff review and evaluation. During the telephone call on April 10, 2012, you indicated that improvements to the allegation process could be made. The NRC welcomes public input on all of our process and encourages you to provide specific, constructive recommendations.
Thank you for informing us of your concern. Allegations are an important source of information in support of the NRC's safety mission. We take our safety responsibilities to the public very seriously, and will continue to do so within the bounds of our lawful authority. Unless we receive new or specific information that suggests that our conclusions should be altered, we plan no further action on this matter.
Should you have any additional questions, or if we can be of further assistance to you, please contact me or Ronald Schmitt toll free at (800) 368-5642.
Sincerely,
This what it all revolves around...
From: Michael Mulligan <steamshovel2002@yahoo.com>To: "allegation@nrc.gov"
Sent: Friday, March 30, 2012 8:47 AMSubject: State of RCA in nuclear industry?

Sent to NRC Region I Allegations
To who it may concern:
I can't believe I am doing this after having such a painful outcome talking to NRC Region 1 Allegation officials just a few days ago. I told myself I would never talk to Allegations again. If you want to talk to me I suggest it be outside Region I Allegations and preferably somebody from headquarters. I know their are lots more experienced people in the NRC than what I was recently exposed too.
I consider Region 1 Allegations compromised much like the March 2007 Peach Bottom sleeping guard incident where Allegations needed 500% absolute perfect inside evidence that was never obtainable in our existence. The NRC was too lazy to go down to Peach Bottom to investigate it on their own and they took the false assurances of Peach Bottom that there was no sleeping guards until the inside video came out that shook up the nation.
I consider the below a "cry for help" to me from multiple plant high nuclear employees and nuclear safety officials. And I certainly assert my confidentiality rights with this because this is so explosive to many careers. Nuclear Industry safety consultants might become blacklist from the nuclear industry. It exemplifies a pervasive of "I don't care" nuclear safety attitude throughout the nuclear industry. And these utilities are disrespectful to nuclear safety oversight in general.
I bet we are painting the most accurate leading indicator the NRC has seen in decades and we know the industry is in deep troubles as seen with all of your issues in recent years. These guys got a attitude problem and so doesn't the NRC!
I wish you would send a copy of this to the OIG?
We are discussing this with Senator Bernie Sanders office and others..
..."To all,
Is no-one from Nuclear Power able to help me with this?
How does Nuclear Power know when to investigate an incident?
Are thresholds, or trigger levels defined?
Or is it merely up to a supervisor to determine what is investigated?
Thanks,
Mike Mulligan said:
It is totally unregulated when and it is totally up to a plant to define what a RCA is.
That is why nobody wants to respond...
To all,
I am getting some private responses to this question and, to be honest, I am a bit shocked.
I had thought that nuclear power was at the leading edge of much of what we talk about here on this forum (and I still think that), but the gist of what I’m reading is bothersome.
I thought there was a borderline EAGERNESS to learn from SMALL THINGS within nuclear power.
But the impression I’m getting from some of the private responses is that there’s a borderline eagerness to avoid having to investigate anything.
“Let’s wait to see if we’re forced to investigate.”
Am I getting the wrong impression?
 
I’m not sure I understand your question.
Are you asking how I came to this conclusion?
If so, it’s an impression I got from reading the emails people sent.
I asked “how does nuclear power decide whether or not to do an RCA” and the “red tape” around it seems horrendous.

Some of what I was sent seems to require a PhD to decipher.
Others hint of an “act of congress” to trigger an investigation.
So it’s just as impression I get that there’s an attitude of “let’s wait to see if we’re forced to investigate this.”
Am I wrong?
So I received these two this late afternoon Oct 27. I have no idea what is going on.

***From: "MAILER-DAEMON@yahoo.com"
To: steamshovel2002@yahoo.com
Sent: Saturday, October 27, 2012 5:21 PM
Subject: Failure Notice
Sorry, we were unable to deliver your message to the following address.
:
Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO]
--- Below this line is a copy of the message.
Received: from [98.139.91.66] by nm12.bullet.mail.sp2.yahoo.com with NNFMP; 26 Oct 2012 16:28:47 -0000
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X-Yahoo-Newman-Property: ymail-3Sorry, we were unable to deliver your message to the following address.

***From: "MAILER-DAEMON@yahoo.com"
To: steamshovel2002@yahoo.com
Sent: Saturday, October 27, 2012 3:44 PM
Subject: Failure Notice
Sorry, we were unable to deliver your message to the following address
:
Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO]
Received: from [98.139.91.65] by nm13.bullet.mail.sp2.yahoo.com with NNFMP; 26 Oct 2012 18:06:43 -0000
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Thursday, October 25, 2012

Communication about Fort Calhoun to the NRC

...It is interesting I got a, after I sent my Oyster Creek superstorm e-mail to the NRC :
""MAILER-DAEMON@yahoo.com" Sorry, we were unable to deliver your message to the following ...Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO]"
I assumed my e-mail didn't ever get to the NRC. So this NRC phone call to me today about Oyster Creek hurricane Sandy says my e-mail did get past this yahoo DAEMON notification. I ask the inspector what does this DAEMON thing mean when I send e-mail to the NRC, he seemed to be aware people were getting it, he told me to just send it again.

I am still confused about the meaning of the MAILER-DAEMON notification after I send into the NRC ...but the indication is my stuff is still getting into the agency.
...So a utility get the best gold plate consigliore service from the NRC, while the public get cheap Wal-Mart little trained and overwhelmed opa people...disconnect from the operation of the plants.
Yea, but I got a lot of access from the NRC officials. Still I don't have access to foundational raw information.


...Is this anything?
Fort Calhoun on their red finding: "Design engineers had limited knowledge of GE AKD-5 switch gear which resulted in over-reliance on vendor knowledge and skill. 
VY with their SRV air actuator seals that failed "Entergy Engineering staff overly relied upon the vendor's recommendation and did not conduct an appropriate equivalency review on their own."  
...So I bumped into a ongoing NRC investigation. And the Region didn't have the professionalism and decently to say it is under investigation. We don’t know how seriously they took the environmental qualification problem in the containment until I showed up. With the link to the Popperville Town Hall I am trying to draw their attention to my Peach Bottom problem on the NRC, PB and VY on not calling containment components a 10 CFR 50.73(a)(2)(v)(D): "Any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident. Including wiring insulation and other plastic or rubber like material of the actuator or components."

I think they thought I had inside information and they were trying to play me for it.

I am tired with the NRC saying in a almost infinite and prolong excuse with plant’s like Fort Calhoun, this is under a investigation. 
From: Michael Mulligan
Sent: Friday, October 05, 2012 6:17 PM To:
OPA4 Resource Subject: Lara Uselding and Fort Calhoun Mr Drinks,
The Popperville Town Hall 
A follow up to my phone call messages I recorded on OCT 5... 
You and me have tangled over at Region III or earlier at Region I... 
Like I said, I could throw 2.206s at region IV if I wanted to... 
So I wanted to talk to the Fort Calhoun inspector about the environmentally unqualified containment valve actuators. Region IV is a mess with Fort Calhoun and San Onofre....the investigation with intimation by the region IV staff with their boss. You know, Brown Ferry, Palisades, VY and Peach Bottom, the agency almost allows me to talk at will with their senior staffs and the resident inspectors. I just call up the resident inspector for a talk and it happens. I spend a lot of time criticizing the agency. I tell everyone it is absolutely amazing the contact time the agency allows me with resident inspector programs. I make a big deal how good these inspectors are to the one. 
So I call up the Calhoun inspector...he tells me he is not busy. I explain the LER and the reason why. He says he can't remember the LER...I tell him all the Region I, II and III inspectors almost got a photographic memory to the one. The Peach Bottom resident really on a cold call was very familiar the Fort Calhoun actuator LER. I am always astonished with the professionalism with the northeastern residents...how they keep up with the issues and their ability to cold talk with me. The VY resident knew my name, most of them others too...he blew my socks off with the detailed knowledge he had about the service water system, Diesel Generator and Loss of off-site power accident procedure issues. We had a hour conversation. My task for VY politically that day by my handlers was a test to see just how accessible the VY residents were to the community. They got an A plus from me that day. I talked to the Peach Bottom senior resident about their SRV issue just days ago for 45 minutes with a cold call. 
I have big issues with Peach Bottom, Browns Ferry, VY, Palisades and how the agency regulates these guys. What I am astonished with is the access the little guy has with the resident program in region I, II and III. They have spoiled the hell out of me. At some level I respect the hell out of them for this even in my disagreements. So the Fort Calhoun Resident blew me off with "I am unfamiliar with a LER in my plant"...you have to call Lara Uselding to get me to talk. Lara was bemused why the inspector would make me call her. She questioned me why somebody from NH would call Region IV. She told me to throw her a e-mail with what I wanted...I told her I am sick and tired of the decency of women with not giving me a call back when I call. I felt she again was going to throw me in the trash can. 
I massively overloaded her in technical talk in one minute and she admitted this sounded like technical talk way above her head. I left a message on her phone the day before... and she couldn't even call me back in a timely manner. She told me she is headed for another plane ride, I told her I heard that often from you kind of guys...region IV is overloaded and overwhelm with their troubles. 
The thing I would do is retire or lay off Dricks...never mind wipe out all the region IV staff through firings, transfers or retirements because they don't know how to communicate with the good public... 
Thanks,Mike Mulligan 
Hinsdale, NH 
16033368320
So I sent e-mails and left messages on their phone...I was irked that Lara blew off my first phone message. This is the signal Region IV is going to blow me off.
From: OPA4 Resource
To: 'Michael Mulligan'
Sent: Thursday, October 11, 2012 12:40 PM 
Subject: RE: Lara Uselding and Fort Calhoun
Thank you Mr. Mulligan for your email. Again, feel free to email me your technical questions and we can get you the information you need.

Lara Uselding
 
So what the heck, I will throw them some of my questions.
From: Michael Mulligan
To: OPA4 Resource
Sent: Thursday, October 11, 2012 2:05 PM
 
Subject: Re: Lara Uselding and Fort Calhoun 
Was the whole actuator unqualified to be in the containment besides these nitrile parts...370 degrees? What are the licensing temperature requirements of these actuators..err, the containments, both on a PWR and BWR? What did Fort Calhoun and the manufacturer state as the temperature qualification of these actuators? 
How does a PWR depressurized for RHR...does any of the PWR depressurization associated valves and actuators have nitrile problem? 
Could you explain the offending nitrile components more completely...it is a gasket, o-ring or seal? What is the difference between nitrile, buna or buna-n material? 
How long was this nitrile materials installed in containment in LER 2012-017? I hope this isn't a rather new install in the last few years and then it was discovered. Is it like Vermont Yankee's buna-n SRV actuator seal and type 1 or type II air actuators, like in their LERs and inspection reports? 
Who was the manufacturer?  
Any more environmentally unqualified components in the Fort Calhoun's containment...how big of a generic issue is this? 
I wish you would put an NRC name on the response to me who is responsible for writing the e-mail, not like this one.
Why didn't the NRC enforce containment accident maximum temperature requirements on these components?
I am saying to the NRC, I think unqualified components and parts in containments is a national problem. 
From: Michael Mulligan
To: "allegation@nrc.gov"
Sent: Monday, October 15, 2012 12:29 PM
  
Subject: 2.206 on Not Qualified Components In Containment With VY and Peach Bottom Oct 13, 2012
R. William Borchardt
Executive Director for Operations
US Nuclear Regulatory Commission Washington, DC 20555-0001 
Dear Mr. Borchardt, 
(Jan 24, 2012) Request an Emergency Peach Bottom nuclear plants 2 and 3 shutdown to replace all safety relief valves pneumatic actuators buna-n seals with nylon sealsor other high quality and durable materials designed and tested for elevated temperature." So this is a renewed requested based on10 CFR 50.73(a)(2)(v)(D) concern. 
In other words, I am requesting all SRV seal materials be like vitol. They be able to withstand all containment accident conditions and temperatures (340/370 degrees F) . Not only is the buna-n seal material not qualified for worst accident temperature, but the whole actuator won't meet10 CFR 50.73(a)(2)(v)(D) including wiring insulation or any other buna or nitrile based elastomers (rubber or plastic) gaskets or seal material. Any material that won’t stand up to the accident temperatures or conditions.
The "FCS branch" threw me?
 From: OPA4 Resource
To: 'Michael Mulligan'
Sent: Friday, October 19, 2012 11:30 AM
 
Subject: RE: Lara Uselding and Fort Calhoun
Thank you for your email and questions. The FCS branch will take a look and we will get back to you.
The FCS (Fort Calhoun Station) is such a big problem in the NRC, they made it a whole NRC branch out of it.  
From: Michael Mulligan
To: OPA4 Resource  Sent: Friday, October 19, 2012 1:55 PM
 
Subject: Re: Lara Uselding and Fort Calhoun  
What is the FSC branch?
I know its under a serious investigation.
From: Michael Mulligan
To: OPA4 Resource
Sent: Wednesday, October 17, 2012 10:53 AM Subject: Re: Lara Uselding and Fort Calhoun 
 
Is this in any investigation process like Enforcement or the OIG going on with problems inside containment?I will tell you what, it sounds like fraud with the containment accident analysis of record for Main Steam Line Break MSLB). Were they gaming nuclear accident analysis and "modeling" (San Onophre)to fit in environmentally unqualified containment components like the safety actuator or others?
What drove Fort Calhoun into changing the MSLB accident in containment...peak temperature.Did they have a recent power uprate or were they heading towards a power uprate...Mike
It's cooking now i think.

She made a commitment to call me in this sentence, to call me to negotiate a time for the call with the branch: "Please let me know the best number to contact you at so that I can call to set this up" And she didn't keep this commitment without a explanation. 

I hate me not being able to keep a prior stated commitment and I hate people doing the same to me. I can't trust any of her communications and commitments now...Region IV is a black hole as far as communications integrity. If I failed to meet a comment I try to hit people with a messages on explanations before I break my promise...and i profusely apologize after I screw up. She is just making promises she can't keep and she has a habit of forgetting what she wrote in past e-mails.

And if Lara and me would have had that conversation, I would have kissed her ass trying to show her I am a decent person, to show her so I would be professional to the branch chief.

From: OPA4 Resource
To: 'Michael Mulligan'
Sent: Monday, October 22, 2012 1:18 PM
 
Subject: RE: Lara Uselding and Fort Calhoun Fort Calhoun Station
The branch chief can make some time to address your questions. Please let me know the best number to contact you at so that I can call to set this up.
Lara Uselding
I am beginning to kiss her ass...to make up for being a little rude to her in the beginning as she was trying to stiff arm me over talking to the FCS resident inspector.
From: Michael Mulligan
To: OPA4 Resource
Sent: Monday, October 22, 2012 1:28 PM
 
Subject: Re: Lara Uselding and Fort Calhoun 
 Good job. I will be out this afternoon...tomorrow morning is a good time or whenever convenient.
Mike Mulligan
 
1-603-336-8320
 So i interpret this below e-mail as she must have talked to the branch chief...I got three choices, Wednesday, Thursday or Friday. I figure Wednesday is what the branch chief is mostly likely looking for.
I got a 2.206 on Wednesday and i suspect she knows it...I suspect the NRC could be trying to throw me off my stride for Wednesday for Palisades.

I am thinking she is overloaded and overwhelmed ..she and the branch chief are passing like ships in the night with no or miss-communication. I am getting that from her fractured and disconnected communication commitments style.
From: OPA4 Resource
To: 'Michael Mulligan'
Cc: "Uselding, Lara"
Sent: Monday, October 22, 2012 6:32 PM
 
Subject: RE: Lara Uselding and Fort Calhoun
I will need to know your availability Wednesday or later this week. I will then coordinate with the Branch Chief and get back to you.Lara
So i am honest and up front with my needs...I make my commitment at being on the phone anytime on Thursday or Friday bar no excuses with this official. 

If she would told me at any time the only available time of the branch chief is on Wednesday I would have taken it. Right this is Monday and she has inferred she has talked to the branch chief many times about talking possibilities. I don't think Lara can make any committments to anyone.

From: Michael Mulligan
To: OPA4 Resource
Sent: Monday, October 22, 2012 8:15 PM
 
Subject: Re: Lara Uselding and Fort Calhoun 
 Hmm, so I got a 2.206 from 3 to 4 pm on this Wednesday for Palisades....I'll be studying for that all day. Could be available shortly after 4 pm ESDT?Just name the time on this Thursday or Friday and I will be on the phone to you.Mike
Here in the below its two days later. It is Wednesday and she is inferring she hasn't even got in touch with the branch chief yet. Maybe the branch chief is disrespecting Lara, as he doesn't really want to talk with me so he is not getting back to Lara. Maybe they all know this disconnected, benzene and fractured...missed commitments and promised schedules just drives me crazy. It is 10:30 am and she knows my 2.206 is at 3 pm this day...and she knows I don't like to be disrupted before the 2.206. So were they trying to disrupt my Palisade presentation.
From: OPA4 Resource
To: 'Michael Mulligan' ; "Uselding, Lara"
Sent: Wednesday, October 24, 2012 10:25 AM
 
Subject: RE: Lara Uselding and Fort Calhoun
I will need to first check timing with the Branch Chief. I ask that you be respectful. You were not so to me or our Resident Inspector and I will not tolerate rudeness to our staff. So if you will be considerate and respectful then I will move forward on setting up a brief call to get you answers to your questions. If during the call you can’t play fair then I will end the call.Lara Uselding
I am still kissing her ass in the below. I telling her if she and the chief begin to irk me, I will professionally end the conversation without being disrespectful. I am signaling to them I won't let anyone intimidate me over any nuclear safety problem. I think on the whole, the NRC is trying to intimidate me with this benzene style of public communication and it is a attempt to hold the NRC unaccountable to not regulating Fort Calhoun according to the regulations for decades.The NRC gave Fort Calhoun permission to lie to them and the NRC intentionally over decades didn't hold Fort Calhoun to federal oversight and regulations.
From: Michael Mulligan
To: OPA4 Resource
Sent: Wednesday, October 24, 2012 11:59 AM
 
Subject: Re: Lara Uselding and Fort Calhoun  
I got tons of these e-mails... this is over the contentious Palisades plant. I was in a phone call with John and the two resident inspectors for an hour. I get along very well with all the Vermont Yankee and Peach Bottom resident inspectors and higher NRC officials. Call them to see if I am a good guy. I generally can call these guys off the cuff not like your up tight region. What are you hiding.
 I believe Giessner is a branch chief in Region III:  
From: "Giessner, John" <John.Giessner@nrc.gov>
To: "steamshovel2002@yahoo.com"
Sent: Tuesday, August 21, 2012 3:30 PM
Subject: 12 Sep call in Palisades safety culture
Mike, thanks for your insights. I thought the call went well!
Jack
The phone line for call-in (12 September 6PM, EDT)
Phone: 800-621-9524
Passcode: 5591733
I am just saying I will end the call professionally if you guys are playing games with me. From my vantage point in the northeast, the resident inspectors and the NRC officials above them are a cut above the rest of us. 
So why is your region different than these guys? 
Another good question is, does the FCS LOCA DBA bound the MSL break accident or does the MSLB accident bound the LOCA?
It sounds like 3:50 pm she finally got in touch with the branch chief. I had no scheduling conflicts...I was just communicating my wishes and needs. It sounds like she just is disconnected for her past communication and commitments to me throughout this email string. To infer I have a scheduling conflict is beyond unprofessional and disrespectful. I made a commitment to be at the Palisades 2.206 between 3 and 4 pm Wednesday
From: "Uselding, Lara"
To: "steamshovel2002@yahoo.com"
Sent: Wednesday, October 24, 2012 3:50 PM
 
Subject: Fort Calhoun Mr. Mulligan: 
It is not going to work to have a call this week or next due to schedule conflicts you mentioned on your end and here. Inspections continue at the plant and staff are busy overseeing Fort Calhoun. There are several ongoing inspection activities associated with environmental qualifications, equipment qualifications, and corrective actions which are some of the areas you asked about. As you know, they can’t provide preliminary information. You are welcome to view the next Commission meeting on Oct. 30 or attend the upcoming meetings in Nebraska. See Fort Calhoun special oversight page for updates: http://www.nrc.gov/info-finder/reactor/fcs/special-oversight.htmlBottom line, the NRC will not permit FCS to restart until inspectors and staff verify it is safe to do so.
The above rejection e-mail was a out of sequence reply to this e-mail below. Was this a NRC signal.


From: Michael Mulligan [mailto:steamshovel2002@yahoo.com]
Sent: Wednesday, October 17, 2012 9:54 AM
To: OPA4 Resource
Subject: Re: Lara Uselding and Fort Calhoun
Sent: Wednesday, October 17, 2012 9:54 AMTo: OPA4 ResourceSubject: Re: Lara Uselding and Fort Calhoun 
http://steamshovel2002.blogspot.com/ 
Is this in any investigation process like Enforcement or the OIG going on with problems inside containment? 
I will tell you what, it sounds like fraud with the containment accident analysis of record for Main Steam Line Break MSLB). Were they gaming nuclear accident analysis and "modeling" (San Onophre)to fit in environmentally unqualified containment components like the safety actuator or others?

What drove Fort Calhoun into changing the MSLB accident in containment...peak temperature. 
Did they have a recent power uprate or were they heading towards a power uprate...
No doubt, I am irked!
From: Michael Mulligan
To: "Uselding, Lara" >
Sent: Wednesday, October 24, 2012 5:17 PM
 
Subject: Re: Fort Calhoun  
Yea, I get it, I will never trust you and region IV on anything that is said.Good public relation's job. 
Mike