Thursday, March 07, 2013

2.206: Pilgrim Nuclear Plant SRV Request For Emergency Shutdown


So from March 29 to March 30...they reduced power from 94% power to 84% power for safety reasons.

This dog just severely picked up the level of leaking...


March 24, 2013:

But you get it, with these new SRV valves, there is no direct limit that forces them to shutdown. There just is a top secretive internal "engineering evaluation" they have to preform...really no requirement of public notifications. The notification are totally at their convenience  and utter voluntary. 

I get it they log temps continuously or at least every hour. But the requirements are they log it once every 24 hours...and many safety requirements are based continuously and or hourly logging.
The Daily Event Report: Specifically, the SRV is inoperable if the pilot stage thermocouple temperature is 35 degrees F below its baseline temperature (with a lower decrease at the 2nd stage thermocouple) and cannot be explained by a corresponding downpower. 
What the plant is thinking, we got to have tons of wiggle room so we got to make the regulation as loose as possible. We could have an event where we are only logging the temps once a day and we still could be up at power operation for a long as we what.

I am just saying these kinds of insane operational flexibility rules and regulation are all over the place...the utilities get to writing the federal regulation without any second outside voice of criticism. This looseness systemic... 

On the technical side of it, the first safety limit needs a continuous or at least a hourly logging of the temperature to fulfill the requirement, while the minimum NRC standards of plant operation is they only have to log it once ever 24 hour.

I would like to see all the internal evaluations associated with the SRVs since May 2011...

I wonder why they re-released this 2010 document on 2/28/2013...

I know from this, they could have had leaking relief valves for a lot longer that what has been disclosed so far....  

Yep, what is their definition of "logged daily"...

I believe they got the capabilities to measure the RTD voltages or resistance with independent means...it is a manual operation. 

Entergy Response to NRC Request for Additional Information dated July 21, 2010, in support of Proposed License Amendment for Pilgrim Setpoint and Setpoint Tolerance Increases for Safety Relief Valves (SRV) and Spring Safety valves (SSV), and Related Changes (TAC NO. ME3543)

1) Safety / Relief Valves Temperature Monitoring
If the discharge pipe temperature of any safety relief valve (SRV) measured at 4.5 to 6 feet exceeds ambient temperature by 30 degrees F during normal reactor power operation for a period of greater than 24 hours, an engineering evaluation shall be performed justifying continued operation for the corresponding SRV temperature increases.

2) Safety / Relief Valves Temperature Monitoring
Whenever the safety relief valves are required to be operable, the safety relief valve discharge pipe temperature of each safety relief valve shall be logged daily.
This is a market based dysfunction and breakdown derived from our dysfunctional political system...this didn't emerge from natural gas or shortage of natural gas pipeline.
This is a market based dysfunction and breakdown derived from our dysfunctional political system...this didn't emerge from natural gas or shortage of natural gas pipeline.
The limited pipeline capacity allowed us to more see our USA oligarchy...

Down south they call this an oligarchy derived banana republic electric system.

We got groups of professional people that act like a family who control our electric system by corrupting our political system.
You read this from the bottom up it might make more sense for you! 


Mike Mulligan 
5:32 PM (4 hours ago)



to Richard.Guzman
To the PRB board,

The facts are the NRC allowed the Pilgrim Plant to run contrary to federal regulations during our severe NE ISO grid and transmission crisis and the agency rebuffed my attempts repeatedly to talk about these problems to the resident inspector and region I public relation spokesman.
 
Neil Shaheen last said to me "I will report your concerns to management". We had no open discussion about the issues, I e-mailed him a note, left a recording on the residents, just a "I will report your concerns to my management". I would like to see the written evidence he did report my concerns his management and outside his department? 

I keep hearing Commissioner Ostendorff beckoning us to stay aware of the"situation awareness". 
 
Seeing how this kind of severe grid and transmission crisis may affect and challenge other plants and their supportive transmission system...a new nationwide developing problem...we need a deeper inspection on plant safety degradation in tandem with the extremes of weather interacting with a poorly designed transmission system and with a prolonged, degraded and unreliable grid problems generated by organizational and regulatory flaws as seen with the Pilgrim Plant over the winter. It is generally initiated by state and federal rules balkanization and organizational rules mental stove piping. It is organization and agencies not talking to each other and not holistic federal oversight with agencies who are involved in getting to production and distribution of our electricity.
 
I hope all the senior NRC executives are keeping  up to date with the issue with the crisis on our NE Independent System Operator. 
 
Mike Mulligan
 Hinsdale, NH
 
...Senator Markey,

Yea, well, I would call it the Balkanization of the system creates a wondrous opportunity for fraud and corruption much like the California electricity shortage in the early 2000 and 2001...did we have a silent and non shaking tsunami in NE this winter all over our NE electric system?
 
I will tell you what, did they operate the Pilgrim Nuclear Plant knowingly in an unsafe manner throughout the winter with the dangerous safety relief valves in order to support a wobbling transmission and electric system. Was this in order to support our extraordinarily fragile natural gas electric system and grid...two or more huge complex systems crashing into each other. This terrifies me!
 
Is that what is behind this?
 
Within the NE ISO control room this winter they describe it as "those tense moments", "most stressful in recent memory", "because the uncertainty persisted" and "periods of uncertainty, it did not disappear due to the continuation of the same conditions (between Jan 21 and Feb 8)" . Parallel to the most stressful NE ISO control room, you have a seriously degraded condition at the Pilgrim station with leaking safety relief valves and a reduction of power to 80% because of the leak Tech Spec inop requiring a plant shutdown within 24 hours for other SRV leaks, which they ignored all this time and beyond, leading up to the Nemo storm.
 
At the bottom of it all, did the NRC stiff arm a member of the public asking for an explanation about SRV problems and the plant forced Pilgrim Plant shutdown? Did the NRC feel it was in the public good to withhold safety information from me because a nuclear safety issue would threaten the public good leading to widespread blackouts because the grid was severely organizationally degraded (most stressful in recent memory)?
 
In other words, did the public good of maintaining widespread public "apparent" electric reliability and NE ISO megawatt cost ...did it justify not disclosing prolonged safety problems at the Pilgrim Plant to me? Did broad public risk override the disclosure of plant problems and mandatory regulatory nuclear safety cause it might threaten the grid?

Right, all these organizations, these regulatory agencies, the politicians and the private businesses, the large utilities set up this crisis over long term back slapping big bucks behaviors. The first instinctual solution of the system when the crisis is approaching is for the greater altruism and the good us all, is to withhold nuclear safety formation from a little twerp like me and the really hard working and burdened public. Why isn't there instints to get out the information to everyone and fix it.
 
Guys, this is self interest they are hiding in the name of doing the greater good and altruism. This is using altruism to destabilize or destroy you...using "doing good" to unjustly raise your rates. They are going to "do good" to you until you are in the poor house, you don't have electricity and a melted down nuclear plant is located right next to you!

Reliance on natural gas fuels risk to grid

By DAVE SOLOMON
New Hampshire Union Leader
New Englanders braced for the coldest weather of the winter the week of Jan. 21, knowing temperatures were going to dip below zero. What they didn't know was that controllers of the New England power grid came dangerously close to imposing roving blackouts due to constraints on the supply of natural gas that fuels most of the region's power plants.

Then on Feb. 8, as the region braced for Winter Storm Nemo, it happened again.

"If we had lost one more big generator or a transmission line, we would have had to resort to our emergency procedures," said Vamsi Chadalavada, executive vice president and chief operating officer for the Independent System Operator of the New England power grid (ISO-NE), based in Holyoke, Mass. "Those procedures are to call on help from neighboring areas, then to call for voluntary conservation, and if that's not sufficient, to institute controlled power outages ... We came quite close."

Chadalavada described those tense moments in the control room at ISO-NE as the most stressful in recent memory. "And the period between them was equally stressful," he said, "because the uncertainty persisted. Although those were the peak periods of uncertainty, it did not disappear due to the continuation of the same conditions."...
Three questions:

1) Was our NE grid system reliable enough to support a nuclear plant operation...did we have a drastic potential and actual grid reliability collapse?

2) Is it clear we were in a grid crisis in-and-around the Nemo blizzard with the Pilgrim nuclear plant trip and their repeated "Loss Of Off Site Power (LOOP)" accident...disconnected from the grid for a god awful amount of time in an accident. This in itself should have been investigated and why that plant was disconnected from the grid for so long. Why, when the huge transmission lines were tripping as the plant was up at power creating enormous surges of electricity... didn't they immediately trip the plant for self protection? Why didn't they diagnose a severely unstable and dangerous transmission system, then following their procedures requiring them to scram? Why didn't they anticipate that...bring the plant to an orderly shutdown before the storm? Is your transmission system designed for our climate and predicted climate...why all this trouble at Pilgrim? Millstone has more snow and wind during this storm...but they continued up a power without any problems. I don't understand!

Did the unseen developing crisis with an inadequately maintained nuclear plant and the developing natural gas grid crisis leading to perilous reliability issues out of nowhere get us close to a unforeseen emergent phenomena...two or more hugely complex mechanical/electrical and organizational systems blindly crashing into each other.
Emergent phenomena. They are flow systems far from equilibrium which arise spontaneously, often upon crossing a critical threshold. They are not obviously predictable from the underlying conditions. They move and act unpredictably, they are often associated with phase changes, and they exhibit “overshoot” (hysteresis So those are some of the characteristic features of ).
3) We are god dam lucky we are in a near depression economy...there were be horrendous economic and job damage with shortages and the spiking electric prices if our economy was booming right now. You should thank your lucky stars!
 
So you got a nuclear plant with secret serious nuclear safety problems going on next door. Which one would you choose:
1) A wobbling nuclear plant with a strong and stable high voltage electric transmission system around you.
2) A wobbling nuclear plant with the transmission system secretly on the edge of collapse

March 19

SHORT SUMMARY OF TESTIMONY


"AMERICAN ENERGY SECURITY AND INNOVATION: THE ROLE OF REGULATORS AND GRID OPERATORS IN MEETING NATURAL GAS AND ELECTRIC COORDINATION CHALLENGES."
ISO-New England exec to Congress: Electric reliability threatened



Published: Wednesday, March 20, 2013
The head of ISO-New England told a congressional subcommittee Tuesday the prevalence of natural gas used to generate the region’s electricity is creating “tremendous operational challenges and threatens reliability” in terms of running the grid.

ISO-NE President and Chief Executive Officer Gordon van Welie told the U.S. House Energy and Commerce Subcommittee on Energy and Power that although the “natural gas and electric industries operate under different regulatory, contracting and operational structures, (they) are increasingly interdependent.”

“Electricity supply and demand must be balanced on an instantaneous basis and problems on the electric system require immediate action, often through the operation of fast responding gas generators,” van Welie said in a copy of his testimony. “However, if generators have not contracted for gas prior to the electric operating day, the gas system may not be able to respond to the real time, instantaneous demands of the electric system.

“This is particularly acute in New England, where the region has a significant reliance on ‘just in time’ interruptible fuel delivery and it is clear that the gas system is inadequate to meet the demands of electric generators during peak periods.
Van Welie said ISO-NE is seeing this more frequently.

“We believe the status quo is unsustainable,” he said. “For power grid reliability to be maintained, we need to have adequate levels of fuel inventory within the region, either through storage or reliable transportation arrangements so that the electric sector is ready to respond whenever called on by the ISO.”
 ISO New England is the independent system operator for the New England power grid with three major areas of responsibility: operate the bulk electric system on a 24x7 basis, administer the region’s wholesale electricity markets, and conduct long-term planning of the transmission system. 
 In a little more than a decade, New England has seen a transformation in its generation mix, moving from a mix of oil, coal, nuclear, and natural gas generators, to a system with more than half of the electricity production coming from natural gas generation (52%). In addition, the region is seeing the retirement of coal and oil generators, and the introduction of a diverse set of renewable and demand resources. 
 Wholesale prices are driven by natural gas generation, but the wholesale electricity markets do not provide adequate incentives for generators to provide electrical energy when called upon by the ISO during stressed system conditions, and in particular for gas generators that have not made adequate and reliable arrangements for fuel supply. 
 The region’s reliance on generation with “just in time” interruptible fuel-delivery arrangements has created operational challenges that are escalating rapidly. The region experienced significant operational challenges in January and February when a significant number of generators were unavailable due to uncertain fuel supplies or storm-related outages. We are seeing this more frequently and it is unsustainable. 
 The market-based solution to this problem is to strengthen the economic incentives in the wholesale markets to cause generators to make adequate and reliable fuel arrangements, so that they are ready to respond to the ISO when needed. 
 New England is urgently working toward solutions that include market changes that provide the incentives necessary to provide greater fuel certainty. 
Thanks

Mike Mulligan
Hinsdale, NH

The Presidential Commission on the Three Mile Island Accident

I was in the Mediterranean Ocean in a new nuclear powered fast attack submarine and we were watching Iran and other hotspots carefully when TMI popped up...

These are called ghost symptoms...improper maintenance symptoms intruding negatively on the current problem...

Heuristics...

The miracle of our mind's ability to disseminate unimportant incoming information...what does it look like when discrimination becomes overloaded. Mental exhuastion and mental numbness ...have you ever felt this condition, we all have...

What does it say about a system where stability depends increasing on human heuristics and discrimination...

So I am saying a poorly maintained plant can cause human beings to become unhinged...

You ain't a good baseball player if you weren't gifted with these mental blessings...
drain pipe that led from the PORV to the reactor coolant drain tank. One emergency procedure states that a pipe temperature of 200°F indicates an open PORV. Another states that when the drain pipe temperature reaches 130 °F, the block valve beneath it should be closed. 25/ But the operators testified that the pipe temperature normally registered high because either the PORV or some other valve was leaking slightly. "I have seen, in reviewing logs since the accident, approximately 198 degrees," Zewe told the Commission. "But I can remember instances before . . . just over 200 degrees."26/ So Zewe and his crew dismissed the significance of the temperature readings, which Zewe recalled as being in the 230 °F range. Recorded data show the range reached 285°F. Zewe told the Commission that he regarded the high temperatures on the drain pipe as residual heat:". . .[K]nowing that the relief valve had lifted, the downstream temperature I would expect to be high and that it would take some time for the pipe to cool down below the 200-degree set point."27
This is my explanation of why I think it is an NRC cover-up!
From: Michael Mulligan < steamshovel2002@yahoo.com>
To: "Guzman, Richard" < Richard.Guzman@nrc.gov>
Sent: Friday, March 15, 2013 11:17 AM
Subject: Re: 2.206: Pilgrim Nuclear Plant SRV Request for Emergency Shutdown

Dear Mr Guzman,
It is interesting, just after the Nemo blizzard LOOP, I called up the Pilgrim plant resident inspector's office requesting a discussion with him about their SRV problems and the hard plant trip. I talked to Neil Shaheen too, e-mails also right after the blizzard ....never got a response. Certainly sounds like a cover-up... then the fourth one began to leak a few weeks after the start-up and no public notification of it. I left my telephone number and never got a call back?
Could I get a telephone discussion about said events with the residents and a region I officials as soon as possible...in preparation for the PRB pre hearing?
I still can't get over the first LER on this, Entergy,Target Rock and the 'Southern Company' found nothing wrong with the first leaking SRV...then you had three more. This has got to be interesting. How many engineers does it take to unscrew a light-bulb?
And the new NRC Commissioner chairperson is worried about the "unknowns".
Yes, please may I address the PRB at the earliest opportunity...I will accept any date and time convenient to everyone else.
Mike Mulligan
Hinsdale, NH
16033368320
 
From: "Guzman, Richard"
To: "'steamshovel2002@yahoo.com'" < steamshovel2002@yahoo.com>
Sent: Thursday, March 14, 2013 3:05 PM
Subject: RE: 2.206: Pilgrim Nuclear Plant SRV Request for Emergency Shutdown
Mr. Mulligan,

Your 2.206 petition by email dated March 7, 2013, was assigned to the Office of Nuclear Reactor Regulation (NRR) for review.My name is Richard Guzman, NRR project manager in the Division of Operating Reactor Licensing, and I have been assigned as the petition manager for your petition.As you’re aware, the 2.206 process is a public process, and your petition will be made a publicly available document in the NRC’s Agencywide Documents Access and Management System (ADAMS).

In accordance with the 10 CFR 2.206 process, the Petition Review Board (PRB) is offering you an opportunity to address the PRB to provide any relevant additional explanation or support for your petition before the it makes an initial recommendation.Please let me know whether you would like to address the PRB.

Thanks,

Rich Guzman
Sr.Project Manager
NRR/DORL/LPL1-1
US NRC
301-415-1030
Excerpts of my letter to US House Representative Ed Markey...
From: Michael Mulligan < steamshovel2002@yahoo.com>
To: ****************************************
Sent: Friday, March 15, 2013 10:50 AM
Subject: Pilgrim nuclear plant: Request shut down and NRC special inspection over these events

Dear Senator Markey,
 
Honestly, how sweet would that be, with Senator Sanders and Senator Markey?

I recently discovered from Pilgrim plant insiders that their plant was on the forth safety relief valve leak. These are extraordinarily important components in a nuclear plant and they dictate overpressure control of the reactor vessel and control core cooling in most modes. To this day, the leak hasn't been explained in our media and even in the any NRC documents. They are right now restricted to 94% because of a leaking SRV valve.
 
They had reliability issues with the valves for years...then they purchased and installed new valves in around 2011. The leaks of these new expensive nuclear safety valves have caused two plant shutdowns, another leak occurred just before the Nemo blizzard and required them to be restricted to 84% reactor to stop the leak. They were preparing to shut down the plant when the blizzard forced them into a trip. A week or so after the restart, so called fixing the valves, another leak began and it secretly forced them into 94% a power restriction. I verified it was a leaking SRV valve from the region 1 public relation spokesmen(Neil Shaheen) and I signaled to the NRC I was working on inside information.

Feb 14:

So I got my information from "wicked local" saying the Entergy public spokesmen says the Pilgrim plant is shut down. This is a lesson in you can't believe everything you read on the internet and then read it carefully.

Today's I was looking at theNRC's region 1
power reactor status report where I became shocked that Pilgrim was still up at 94% today.

Sorry for the inaccuracy. I should have seen no other media outlet was carrying the pilgrim shut down... 


You get it, Engineers make sense of the world by pondering about what information is available...I make sense of the world by pondering about what information is missing...

It is the professional difference between the mindset of Engineers and  professional Operators of large machines and organizations...

We deal with  the potential of high consequences complex events just seconds away from us, which may never before have been seen by mankind ...engineers deal with events many hours, days, weeks, months and years away from them.

Nuclear operators are generally contemptuous of everyone else...because most other people don't have to deal with consequential  new information blasting immediately into their consciousness.

Sorry about the problems with my blog today...I copied the bad codes over from news sources that crashed the blog. It was my stupdity and fault!

March 13:

http://www.roadtechs.com/nukeout.htm

Sounds like I caused them to enter a refueling outage a month early?

...I thought it would come next month...

So, say they get a leak on an SRV a month after start up from refueling. Would they shut down quickly to get the repair over. Say, they got a SRV leak a month before refueling, would they delay the repair just because the refueling is around the corner? What method is safer?

So basically the agency is using words or rules trickstersism. What is the same as having no rules? It is having too many rules? They can pull an obscured sentence out in a rule to throw at me and then spin the meaning in the industry's direction.

I am in my best right here...I am at the apex of doing my job. They were answering in this thorough way because I was representing the New England Coalition. I wish I had an entity whom I could represent to elevated my status to the NRC. They know now i only represent myself.

Along with LaSalle, there was Limerick with their popping open relief valves in this time frame. I got the feeling the NRC was rationalizing away all leaks from the reactors thoughout the nation. This was a group thing with rationalizing away the threat of reactor leaks. SRVs being one, then as a general concern of misusing safety systems because of poor maintenance to maintain commercial operation. They could spin a host of rules around so nuclear vessel core leaks didn't matter. Guys, get real, you can spin around any rule to fit any agenda.

These guys were going crazy in the beginning with their pipe dreams of building the new nukes...pushing corporate and plant capacity factor. We were in a nuclear industry tulip mania. I chose the region III because I got wind these guys were in so much trouble. Balls to the walls deregulation fanatic president Bush who hated all government regulations, just got elected. Clinton was much like president Bush. So I knew the NRC all through 2001 was spinning out of control.

People who know me think I can see premonitions. I can spin organizations' behaviors in my head and I am good at predicting results. What gets to four srvs leaks on four new srvs valves is a deep behavior of a group of people. I wouldn't have spent so much time on LaSalle or Region III if I didn't know they were in big trouble in 2001.

Davis Besse leading from 1998 to 2001 was a terrible leaking ship...unbelievably reckless with downplaying a host of reactor vessel leaks to boost capacity factor and support a weakening stock price. Davis Besse leading up to this had very good grades from the NRC. Post hole in the head, the NRC admitted they severely inflated the grade of Davis Besse in the lead up to this near miss.

The very serious Davis Besse hole in the reactor head accident was discovered in March 2002...

 March 12, 2013:

November 29, 2001

(So i added the link to this NR document.)

Mr. Michael Mulligan
New England Coalition on Nuclear Pollution
5 Woodlawn Lane
Hinsdale, NH 03451

Dear Mr. Mulligan:

Your e-mail dated September 27, 2001, and addressed to Mr. Victor L. Dricks for
Dr. William D. Travers, Executive Director for Operations, has been referred to the Office of Nuclear Reactor Regulation (NRR) pursuant to 10 CFR 2.206 of the Commission’s regulations. A copy of your e-mail and all supplements are enclosed for completeness. Noting your request that the Nuclear Regulatory Commission (NRC) take enforcement action against the LaSalle County Station, Units 1 and 2, (LaSalle), the staff has processed your request following the guidance in Management Directive 8.11, "Review Process for 10 CFR 2.206 Petitions." You requested the following NRC enforcement-related actions:
1. Both units be immediately shutdown for a lengthy maintenance period to replace leaking safety/relief valves (S/RVs).
2. The NRC perform an immediate emergency inspection on the S/RV problems atLaSalle and an assessment of other similar large relief valves at other Exelon Generation Company, LLC, (Exelon, licensee) facilities.
3. The NRC perform a detailed inspection on the suppression pool temperature increases, in-leakage problems, and extended use of the residual heat removal (RHR) system in the suppression pool cooling (SPC) mode during this past summer.
As the basis for your request, supplemented by information you provided to Mr. William A. Macon, Jr., on October 3, 2001, you stated the following.
1. NRC Inspection Reports 00-12, 01-02 and 01-03 for LaSalle indicate multiple Unit 1 and Unit 2 S/RVs have excessive internal seat leakage. You further suggest that the NRC displays a "reckless indifference to safety" regarding S/RV leakage and other degraded components which create "unacceptable risks to the surrounding community."
2. NRC Inspection Report 00-11, which references a LaSalle policy directive (LOP-CM-03) that addresses frequent suppression pool cooling and mixing, indicates many years of living with degraded component problems and allowing suppression pool temperature increases up to the 105 F limit. (I am throwing the best of me at them.) You further suggest that degraded plant operations are bumping past conservative safety limits and analysis, and that the NRC is being "deceptive" and "amoral" regarding its technical reviews of the industry’s engineering analyses.
3. Operation of the RHR system in the SPC mode is not meant to facilitate normal commercial plant operations. Safety systems are designed to be maintained in a standby state and only run when absolutely necessary. The industry has declared that running these components excessively creates the condition which leads to excessive wear and increasing failures. You further suggest the NRC has become a "one way check valve for the industry" by permitting longer testing timeframes and reduced testing for the nuclear industry’s benefit.
You addressed the NRC’s petition review board (PRB) by teleconference on October 12, 2001, to clarify your petition. A transcript of the meeting is enclosed as a supplement to your petition. The results of that discussion have been considered in the PRB's determination regarding your request for immediate action and whether or not the petition meets the criteria for consideration under 10 CFR 2.206. The staff has concluded that your submittal does not meet the criteria for consideration under 10 CFR 2.206 because your petition presents no significant new information and only raises issues that have already been the subject of NRC staff review and evaluation on the LaSalle facility and other similar facilities (e.g., Quad Cities, Fitzpatrick).

Your petition, supplemented by information you provided to Mr. Macon on October 9, 2001, raises additional concerns about potential NRC misconduct. You state that the agency has ignored known problems with leaking S/RVs and RHR reliability at LaSalle and throughout the industry. The staff is treating these concerns as assertions of impropriety by NRC staff and has referred them to the Office of the Inspector General. Although the staff has concluded that your submittal does not meet the criteria for consideration under 10 CFR 2.206, the staff has reviewed the relevant technical issues and has developed the following response to your concerns:

EVALUATION

LaSalle County Station, Units 1 and 2, currently operates in accordance with a set of improved technical specifications (TSs) based on NUREG 1433, Revision 1, "Standard Technical Specifications, General Electric Plants BWR/4," dated April 1995, NUREG-1434, Revision 1, "Standard Technical Specifications, General Electric Plants BWR/6," dated April 1995, and on guidance provided in the Commission’s "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," published on July 22, 1993 (58 FR 39132). These technical references, prepared by the NRC staff, have been extensively reviewed by the industry, professional organizations, academic institutions, and the public. The staff prepared the Safety Evaluation (SE) for the LaSalle improved TS conversion in accordance with these references and NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," dated July 1981. On March 30, 2001, the Commission issued Amendment 147 to Facility Operating License No. NPF-11 and Amendment No. 133 to Facility Operating License No. NPF-18 for the LaSalle County Station, Units 1 and 2, respectively. The licensee implemented the improved TS at LaSalle on May 1, 2001, which are currently the licensing basis under which NRC inspectors monitor plant activities, evaluate if NRC requirements are violated, and, if a violation is found, determine its effect on plant safety and risk. Excerpts from the LaSalle TS and bases are enclosed for reference to clarify the staff’s evaluation of your safety concerns.

Safety/Relief Valves (S/RVs)

In your 10 CFR 2.206 petition and in previous communications with the staff regarding LaSalle and other facilities (e.g., Limerick, Prairie Island, Susquehanna), you have expressed concerns regarding the degradation of S/RVs, the amount of leakage which is considered to be acceptable for S/RVs and other large relief valves, and the surveillance testing interval which is acceptable to satisfy ASME Code requirements. The staff has responded to you on several occasions, most recently on September 14, 2001, in response to your June 21, 2001, concerns regarding leakage of large remotely controlled relief valves. The NRC staff considers some leakage to be acceptable without affecting plant operation or safety, and, in fact, all S/RVs may leak without necessarily rendering them mechanically inoperable and incapable of performing their safety functions in the event of a reactor overpressurization event. As long as TS Limiting Condition for Operation (LCO) 3.4.4 and Surveillance Requirement (SR) 3.4.4.1 are satisfied (see enclosed excerpts), no NRC enforcement-related action is warranted. The staff further considers that NRC requirements are being met to ensure S/RVs are monitored and maintained in a condition that ensures they will perform their safety functions.

Safety-related components such as S/RVs are within the scope of the Maintenance Rule (10 CFR 50.65). The Maintenance Rule requires that licensees monitor the performance or condition of components, such as S/RVs and other large relief valves, against licensee established goals commensurate with safety, taking into account industry-wide operating experience. Licensees must take corrective action when these goals are not met. The NRC has determined that the Boiling Water Reactor (BWR) Owners Group and individual licensees at LaSalle and other facilities have significantly improved the performance of three-stage S/RVs and two-stage S/RVs as demonstrated by plant-specific operational experience and test data. The NRC staff does not believe there is a generic problem regarding the operability of S/RVs, despite known component degradation and leakage problems. These are maintenance issues which fall within the scope of the licensee’s maintenance programs and corrective action programs, and not within the scope of direct NRC enforcement. The licensee has indicated that it plans to replace the current hard-seat S/RVs with soft-seat S/RVs during upcoming outages to fix the leakage problems, and the staff is satisfied that these planned corrective actions will be sufficient. The staff continues to monitor the S/RV leakage problems, but neither the NRC staff’s evaluation, nor industry operational data, indicates that the currently installed S/RVs pose a risk-significant safety concern.

Suppression Pool Average Temperature

In your 10 CFR 2.206 petition you have expressed concerns regarding the licensee approaching TS limits on suppression pool temperatures. This is an operating issue which falls within the scope of the licensee’s operating procedures, and not within the scope of direct NRC enforcement. As long as LCO 3.6.2.1 and SR 3.6.2.1.1 are satisfied, no NRC enforcement related action is warranted. TS limits are not safety analysis limits, and approaching a TS limit is within the bounds of acceptable plant operation as long as the limit is not exceeded. NRC inspectors continue to monitor plant activities to ensure NRC requirements are met and plant procedures are followed. There has been no indication that these TS limits have been exceeded or plant procedures violated, nor has there been any other indication to suggest that the current safety analyses are non conservative.

Residual Heat Removal (RHR) Suppression Pool Cooling

In your 10 CFR 2.206 petition, you express concerns regarding the degradation of the RHR system, excessive run times of the RHR subsystems, and the operation of safety systems such as RHR during regular plant operation rather than maintaining them in a standby state. Although there is no TS limit or other licensing restriction on run times for the RHR pumps at LaSalle, there are starting limitations on the pumps and they are required to be run quarterly (every 92 days) in accordance with the inservice testing (IST) program. The pumps are, in fact, designed for extended operation for use during the long term core cooling mode of operation.

As long as LCO 3.6.2.3, SR 3.6.2.3.1 and SR 3.6.2.3.2 are satisfied, no NRC enforcementrelated action is warranted. The staff considers that NRC requirements are being met to ensure RHR suppression pool cooling subsystems are monitored and maintained in a condition that ensures they will perform their safety functions. Safety-related components such as RHR pumps and valves are within the scope of the Maintenance Rule (10 CFR 50.65). Licensees must take corrective action when licensee established goals are not met. The NRC staff does not believe there is a generic problem regarding extended use of the RHR system in the SPC mode, as far as normal system reliability and operability are concerned. Concerns about excessive wear and increased risk of failures of RHR system components are maintenance issues which fall within the scope of the licensee’s maintenance programs and corrective action programs, and not within the scope of direct NRC enforcement. The staff continues to monitor the safety system performance of RHR and other systems, but neither the NRC staff’s evaluation, nor industry operational data, indicate that the currently demonstrated level of performance at LaSalle poses a risk-significant safety concern.

However, the NRC staff shares your concerns about extended use of the RHR system in the SPC mode and the potential for water hammer in the RHR system during a design basis loss of coolant accident (LOCA) coincident with a loss of offsite power (LOOP) while the system is aligned in this mode. This issue has been previously identified in NRC Information Notice (IN) 87-10, "Potential for Water Hammer During Restart of Residual Heat Removal Pumps," dated February 11, 1987, and Supplement 1, dated May 15, 1997. This supplement specifically addresses the increased use of RHR pumps in the SPC mode due to leaking S/RVs. The concern is that during a design basis LOCA coincident with a LOOP, the LOOP, subsequent valve realignment, and large elevation differences may allow portions of the RHR system to drain down to the suppression pool, leaving voids in the RHR piping. When the emergency diesel generators reenergize the emergency buses in response to the LOOP, the RHR pumps will start and possibly cause water hammer damage in the voided RHR loop.

In 1993, NRC inspectors expressed concerns that the licensee had not adequately addressed IN 87-10, and the licensee subsequently performed additional analysis and testing and concluded that the potential for severe water hammer was possible. As a result, Sargent and Lundy performed water hammer analysis EMD-067982, "Evaluation of Potential Water Hammer In Residual Heat Removal System," Revision 0, dated February 18, 1994. This report concluded that although a water hammer would occur, the RHR system would maintain its pressure boundary integrity, structural stability, and functional capability during the water hammer event. NRC inspectors noted that plastic deformation and ovalization of system piping as well as snubber failure were also predicted. These results were subsequently documented in the LaSalle updated final safety analysis report (UFSAR).

In December 1995, General Electric Report NEDC-32513, "Suppression Pool Cooling and Water Hammer," was issued to document the conclusion of a General Electric review of the generic water hammer issue. In that report, the following conclusions were documented:
Operation of the RHR system in the SPC mode has been expected to be an infrequent occurrence during normal operation. As a result, the original LOCA design basis and supporting analysis only assumed initiation of the ECCS/LPCI [Emergency Core Cooling Systems/Low Pressure Coolant Injection] mode to be from a standby configuration.
The frequency of occurrence of a LOOP/LOCA coincident with the RHR system being in the SPC mode is less than the probability of events considered in the design of BWRs (< 1.0x10-6 per year, per ANSI/ANS-52.1, "Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants").
Although LOOP/LOCA occurrence during secondary modes of operation (such as SPC mode) may not have been included in the original design basis, the staff has determined that the increased use of SPC mode, possibly beyond the frequency defined as "short operational periods," would require analysis of the event and the corresponding draindown and water hammer. The LaSalle licensing basis contains no specific restrictions regarding the time in which RHR may be operated in the SPC mode and the 1994 water hammer analysis concludes that the RHR safety function will be maintained despite the potential for severe water hammer, which indicates that LaSalle has been operating within currently acceptable limits and analyses.

(The below talking about, I was banging on the NRC before April/May 2001. This got the whole industry to reevaluate running invaluable safety systems to maintain commercial operation)

Due to the number of S/RVs leaking at both LaSalle units during the current operating cycles, and the expected increased use of RHR in the SPC mode during the summer months with elevated ultimate heat sink (UHS) temperatures, NRC inspectors began reviewing the LaSalle water hammer analysis during April/May 2001 and began an iterative series of discussions with the licensee. As late as September 17, 2001, prior to your petition on September 27, 2001, NRC Inspection Report 01-10 notes that the inspectors reviewed selected Operability Evaluations and Condition Reports related to the leaking S/RVs and a licensee management decision to operate one train of the Unit 1 RHR system continuously in the SPC mode, and identified this issue as an Unresolved Item (URI 50-373/2001010-02).

This unresolved item involves regulatory interpretations unrelated to the technical concerns raised in your petition. For example, the staff currently has a concern that the 1994 RHR water hammer analysis does not meet the criteria specified in Appendix F of Section III of the ASME Code. The licensee has commissioned an independent contractor to review the analysis and determine whether the analysis is reasonable to demonstrate system functionality. Additionally, the staff is reviewing the overall adequacy of the LaSalle water hammer analysis and the applicability of the recently revised 10 CFR 50.59 change control process to this issue.

These ongoing discussions primarily involve regulatory interpretations and do not involve any new technical issues which have not already been the subject of NRC staff review and evaluation (e.g., Fitzpatrick in 1996, Quad Cities in 1997). Your petition does not present any significant new information which may be relevant to these discussions. The staff continues to monitor the LaSalle water hammer analysis issue and will employ whatever regulatory actions are appropriate, including enforcement action if warranted.

CONCLUSION

Based on the above, the NRC staff has concluded that your submittal dated September 27, 2001, supplemented by information provided on October 3, 2001, does not meet the criteria for consideration under 10 CFR 2.206 because your petition presents no significant new information and only raises issues that have already been the subject of NRC staff review and evaluation on the LaSalle facility, other similar facilities (e.g., Prairie Island, Susquehanna, Limerick, Fitzpatrick, Quad Cities), and on a generic basis, for which the issues have been resolved and the resolutions are applicable to LaSalle. No NRC enforcement-related action is warranted based upon the information you have presented.

Mr. Mulligan, please understand that if a violation of NRC requirements is found during NRC inspections or brought to the attention of the NRC by either plant personnel or other individuals, there are basically two mechanisms used by the NRC to address the problem based upon its effect on plant safety and risk. If the violation is of very low safety significance, it will be discussed in an inspection report with no formal enforcement action. The utility is expected to deal with the violation through its corrective action program, correcting the violation and taking
steps to prevent a recurrence. If the NRC risk evaluation finds that the violation has a higher risk significance, a Notice of Violation will be issued to the licensee which may or may not involve a civil penalty. A Notice of Violation requires the licensee to respond formally to the NRC with its actions to correct the violation and what steps it will take to prevent the violation from occurring again. Both mechanisms involve a public process and all documentation is available for public review.

In summary, the NRC staff concludes that no violation of NRC requirements exists at the LaSalle County Station, Units 1 and 2, which warrants NRC enforcement-related action.

Your concerns related to excessive leakage of S/RVs, suppression pool temperatures approaching operational limits, and extended use of the RHR system in the SPC mode have been previously addressed and evaluated by the staff. The NRC, therefore, does not intend to review your concerns under the 10 CFR 2.206 petition process for the aforementioned reasons.

Thank you for bringing these issues to the attention of the NRC.

Sincerely,
/RA/
John A. Zwolinski, Director
Division of Licensing Project Management
Office of Nuclear Reactor Regulation
Docket Nos. 50-373 and 50-374
Enclosures: As stated
cc w/Enclosures: See next page

Is this good news...at least they acknowledge my concern unlike the NRC...
----- Original Message -----
From: ago (AGO)

To: Michael Mulligan
Cc:
Sent: Friday, March 8, 2013 2:07 PM
Subject: RE: Safety Relief Valves at the Pilgrim Nuclear Station

Dear Mr. Mulligan:

Thank you for contacting the Office of Attorney General Martha Coakley. I am writing to acknowledge receipt of a recent message you sent to the Office. Your message has been forwarded to the appropriate division for response. Please note that you may also wish to contact our office directly by telephone at 617-727-2200, and a live operator may be able to direct you. As always we appreciate your patience.

Sincerely,

Constituent Services Coordinator
Public Inquiry & Assistance Center
Office of Attorney General Martha Coakley
12.5% of all LERs are SRV related....

Licensee Event Report 2012-001-00

March 9

What I am trying to say, is the Pilgrim plant has had a terrible record with their SRVs before the three stage new valves...the record is worst now than the past...

I mean, this is why Pilgrim got new SRV valves. The pilgrim plant has had a terrible record with SRV set point accuracy more than the Vermont Yankee plant over the years.
On March 28, 2012, Pilgrim Nuclear Power Station (PNPS) was notified that three of four, two-stage Target Rock Safety Relief Valve (SRV) pilot assemblies exceeded the Technical Specification (TS) tolerance limit for routine set point pressure testing performed at the Wyle Laboratories test facility. Certified replacement three-stage SRVs were installed in the plant at the time Pilgrim was notified.
The old limit is 1% plus or minus the set point accuracy...the new limit is plus or minus 3%. Of the three failed valves, one was off by 6.8% and the other 14.1%

Right, if you had the perfect god's eye view with SRV set point inaccuracy, one that went past 1% accuracy, they would be required to be in cold shutdown within 24 hours. But the valves are hidden behind three feet of containment concrete when the plant is operating. They can't ascertain the accuracy of the set point opening of this valve. Get it, once the valve went past the 1% set point opening accuracy, but they can't detect it a power, only during plant shutdown.. They were required to shutdown the plant. If you don't see a safety defect, you don't need to shutdown.

They could be operating the plant for 6 months with INOP valves requiring an immediate shut to fix it when it first went past 1%?

 
How good do you feel about this: 
"On March 28, 2012, Pilgrim Nuclear Power Station (PNPS) was notified that three of four..."

"Report date: May 23, 2012"
Technical Specification (TS) 3.6.D.1, in effect during Cycle 18 (May 2009 to April 2011)..."

 They yanked the valve out of the plant to be tested somewhere during the refueling outage after April 2011. Then Entergy notified the public with the test results on May 23, 2012...that is a year later to get the results of safety testing. These are nuclear professional and highly educated and paid...this is the best they can do to get at notifying the public of a failed test.

What do they take us for, a safety analysis dated in 1984.Was NEDE updated for the power up rating? The consumer internet wasn't even invented in 1984 and cell phones were as big as semi-tractor trailers.


"The Cycle 18 analysis for overpressure protection predicted a peak vessel pressure of 1298 psig (EC22573) which results in a margin of 77 psig to the ASME Code upset limit. For the as-found set pressures, the peak vessel pressure would increase but would not have exceed the acceptance limit of 1375 psig. This conclusion is based on the results of a sensitivity analysis documented in NEDE-30476 ("Setpoint Drift Investigation of Target Rock two-Stage Safety / Relief Valves," February, 1984) that estimates a 40 psig increase in the peak vessel pressure for a 10% increase in the set pressure for each of the four SRVs. This translates to a 4 psig increase for each 1% the set pressure increases."

Oh yea, this sounds safe: 
This exceeds the emergence limit used for ATWS analysis

For ATWS analysis, a 1500 psig peak vessel pressure limit is used. The Cycle 18 analysis resulted in essentially no margin to this limit; 1499.8 psig. Assuming that the same sensitivity of peak pressure to set pressure applies to the ATWS analysis as applies to the overpressure analysis, the high SRV and SSV set pressures would have resulted in a peak vessel pressure of 1520 psig. This exceeds the emergence limit used for ATWS analysis but is less than the hydrostatic pressure of 1560 psiqc and the stress analysis limit of 1875 psig for faulted conditions. Based on the hydrostatic test pressure described in the Updated Final Safety Analysis (UFSAR), system integrity would not have been impaired.
All these failures and inability to shutdown when required lead to them purchasing the new three stage Safety relief valves.

SIMILARITY TO PREVIOUS EVENTS: A review was conducted of Pilgrim Station LERs related to relief valve setpoint test failures. This review identified LER 2001-004-000, LER 2004-001-00, LER 2005-003-00, LER 2007-004-00, and LER 2009-001.
March 9, 2012:

So think about it, they got four control room operated safety relief valves. The call the valve inoperable, they have to be shutdown in 24 hours. They get a tiny little leak, a temperature change in the valve or discharge line, they are required to be in cold shutdown in 24 hours Like, does this signal how important these valves are and how much the system lacks excess flexibility and capacity?
"Due to the valve being declared inoperable the station is required to be shutdown and reactor coolant pressure below 104 psig within 24 hours per TS 3.6.D.2."
Why not six or eight SRV valves with remotely operated inlet isolation valves. They got these in the PWRs. So a SRV valve starts to leak, you just shut the isolation valve. You got seven other valves causing tremendous plant operational flexibility...two valves leak, so what. You would never have to shutdown a plant over defective SRV valves.

Yea, I get it...there is a conflict between the non design of the plant for extreme plant capacity factor and the risk of a loss of coolant accident with a unisolable leak between the steam line...the short SRV piping... and the SRV valve. I'd make the risk trade off with all these shutdowns and the fear of a valve failure in a big accident and this risk of a unisolable leak before the SRV and the main steam line.

You got a plant design flaw where they didn't install enough SRVvalves. These plants weren't designed the for the ultra extreme plant capacity factors in the high 90% of today.


...These guys get away with word, term, phrase or language fraud...they get away with it all the time because the nuclear language is so technically indecipherable. Their language is so technically indecipherable they are basically lawless...the legal system hasn't been able to define what lawlessness is through most legal codes or laws for the nuclear industry.

Right, you would have to have the prosecutors and judges, let alone the politicians who write the laws, who are highly competent in nuclearese language (legalese) to prosecute the nuclear bad guys?

Man, if you don't think proper words and language are important? It is like the politicians, prosecutors, police and judges don't know how to write up with coherent words a law saying society will hold you responsible for holding up a bank.



It is like the bank robbers getting to write the laws on bank robbing...

So what is the meaning of term INOP? Basically the 35 degrees F is an industry standard or agreement...it is only according to what is in their procedure. It is not a government standards. Is there science behind their procedure or massive nuclear industry deregulation. It is INOP when the "observed reduction in first stage pilot valve temperature of greater than 35 degrees F from baseline temperatures.

Honestly, what is the meaning of the term INOP...it is a physical characteristic of the seat leakage caused by a steam cut between the seat and the valve with the reactor at 100% power in this case. It is a physical space or hole between the seat and the valve. The leakage is defined by the size of the hole...the instrument temperature at 100% power defines the hole size. It could come from the first stage or the main valve...or some kind of mechanical defect that blows steam past the actual valve. I woun't go into how often these temperature instrumentation are inaccurate or broken. All they are doing is reducing the leakage rate by holding power at above an “observed reduction in first stage pilot valve temperature of greater than 35 degrees”...it doesn’t fix the steam cut or defect. This is cheating...they got no science that backs up it safe at 94% power.
This required shutdown limit is only good at 100% power...it is meaningless at any other power level. It is only a gross indication of what is going with these valves
And these valves historically are extremely dangerous...they are behind three feet of cement. You don't have direct contact or sight of these valves for months at a time. You never at power have a god's eye view of the attributes of these extremely important components.
Ok, you got a big crack or huge defect in the safety relief valve. Its reading 50 degree above the safety limit of the “observed reduction in first stage pilot valve temperature of greater than 35 degrees F”about the limit. They go down to 50% power where the temperature is below 35 degrees...they are lowing the pressure and temperature the valve feels...the temperature is below the 35 degree F or seemingly not measurable. Do you think you know the size of the leak or its risk of failure?

Do you see what they are doing? It is like you got the buttons on your cell phone where you can dial in the speed limit on the road you are driving on. Everyone else has to obey the speed limit, but you get to set your own speed limit.

It is safety and risk fraud...this poisons the conscience of everyone working at the plant.
I mean, you got a tear or crack in your swimming pool wall. Do you feel safe and confident the defect is fixed if you lower the water level below the crack? If you can't see a leak then it is fixed independent of the water level.
Is the problem gone, or you just can’t see it.
"On February 3, 2013 at 1245 EST, with the reactor at 100% core thermal power (CTP) safety relief valve, RV-203-3B was declared inoperable as required by station procedural direction due to an observed reduction in first stage pilot valve temperature of greater than 35 degrees F from baseline temperatures. At 1300 EST, reactor power was lowered to approximately 80% CTP at which time the relief valve parameters returned or trended to normal steady state values.Consistent with a reactor power reduction, reactor pressure also lowered from 1035 psig to 1000 psig. This action was taken consistent with industry operating experience related to three stage target rock relief first stage pilot valve leakage.
Just to be clear, there is nothing in the NRC, the outside and in the media written record that Pilgrim has another leaking safety relief valve.
But they are at 94% power for some undisclosed reasons...
I request Entergy-Pilgrim writes up a voluntary Daily Event Report about their current leak.
Safety breaches seen at U.S. nuclear reactors
By Brian Wingfield, Bloombergwillitsnews.com
Posted: 03/08/2013 08:44:02 AM PST
WASHINGTON - Nearly one in six U.S. nuclear reactors experienced safety breaches last year due in part to poor oversight by federal regulators, according to the Union of Concerned Scientists.
Incidents including a cooling water leak and unusual wear on steam generator tubes were reported at 16 units owned by companies including Entergy and Edison International, the Cambridge, Mass.-based environmental group said in its third annual report on reactor safety released Thursday.
"The NRC has repeatedly failed to enforce essential safety regulations," wrote David Lochbaum, director of the group's Nuclear Safety Project and author of the study.
The NRC "is tolerating the intolerable," the scientists' report said. "The simplest repair available is for the NRC to enforce existing regulations, using its ability to impose fines on owners and shut down reactors that violate safety regulations."...

The Japan Times

Nuke safety body touts voluntary measures
K
azuaki Nagata Staff Writer
Utilities were unwilling to voluntarily improve safety at their nuclear plants before the Fukushima crisis erupted, but the chairman of the Japan Nuclear Safety Institute, an entity aimed at monitoring efforts by power firms to improve atomic safety, is determined to change that mindset.
"Overseas experts have pointed this out before, but nuclear power station operators and industry regulators in Japan thought they had ensured safety simply by following regulations," said Shojiro Matsuura, who headed the Cabinet Office’s now-defunct Nuclear Safety Commission before taking the institute’s reins
"Because of that mindset, operators did not really make voluntary efforts to improve safety beyond what was required. I think this was the indirect cause of the Fukushima disaster, and it has to change fundamentally," Matsuura said in an interview with The Japan Times...
Ok, so the plant was shutdown for 8 days...the NRC said it took them 4 days until to Tues to recover from the troubling Nor'easter Nemo, then another 4 days to repair the leaking SRV before they started-up. A greater truth is, they got enough people to be working on both these problems simultaneously...

And the NRC asserts they have no immediate concerns with the SRV, then it leaks within weeks of the startup...

These guys are overseeing a nuclear power plants who have very good college degrees and much experience, their bosses have advanced degrees and PhDs.

Does this rosy scenario on Feb 16, 2013 from the NRC with everything is well, makes sence after two forced shutdowns with prior leaks. Then staging for another shutdown with the third leak? Does Entergy give you enough honest information over these events for you to have the opportunity to make up your over mind?

If this plant was forced to shutdown over every leak and it being fixed...then they would figure out how to quickly permanently fix the defective valves.

That is four leaks with these valves in this system they still can't get a handle on. What makes you confident after the outage these leaks won't occur again?
Pilgrim nuclear plant back in service

By Beth Daley Globe Staff

February 16, 2013

The Pilgrim Nuclear Power Station in Plymouth went back in service late Friday night after being offline since last weekend’s powerful winter storm, according to the Nuclear Regulatory Commission.

The plant, owned by Entergy Corp. of Louisiana, originally went out of service Feb. 8 when the storm knocked out the plant’s off-site power lines. Power was restored on Sunday morning but lost again that afternoon when ice fell on a switchyard line and caused a transformer electrical fault.

Power was restored Tuesday, but the plant remained out of commission to repair a leaky safety relief valve, the NRC said.

“Our resident inspectors assigned to Pilgrim kept close tabs on the loss of off-site power throughout the storm and afterwards,’’ Neil Sheehan, an NRC spokesman said in an e-mail Saturday morning. “They also tracked the company’s work to fix the safety relief valve. They did not identify any immediate safety concerns.”

Pilgrim’s shutdown was its third this year. The first two — both in January — were caused by equipment issues at the plant.

The leaky safety valve that was being repaired caused one of the January shutdowns. The other one happened when the plant’s recirculation pumps, used to adjust power levels, stopped working.

Pilgrim, which began operating in 1972, was relicensed by the NRC last year. The license extends until 2032.

An Entergy spokesman confirmed that operators returned the plant to service at 10:49 p.m. Friday when it was reconnected to the New England electric transmission grid.
Dear Attorney General Coakley,

I called your agency's tip line yesterday to explain my issues and they connected me to a place where I could leave a recorded message for some kind of complaint. This is a written follow up to that.

I worked as a licensed nuclear operator at a sister plant Vermont Yankee for many years and I was in the Navy stationed on a nuclear fast attack submarine. Got fired for raising safety issues at Vermont Yankee in 1992.

Ultimately, my aims are to transform the nuclear regulatory commission. I support the good guys in the plant control room...I think telling the truth is good for our nation and it makes the nuclear industry and nuclear plant more safe and strong.
My name is all over the NRC's Adams document system...I am an expert on their document system.

It would be nice if the Massachusetts joined my petition in some way...gained me some leverage and status over the NRC ...help me gain the documents and information not so far disclosed. I would like Massachusetts and the Attorney General to demand an immediate shutdown of Pilgrim to repair/replace these valves...to demand from the NRC a thorough "special inspection" over these safety relief valves. I discovered the forth new leak from a plant insider. I think this is a generic issue at many plants.

This is a cover-up since the nemo blizzard restart. You have to have $100,000s worth of special nuclear education that gets you to look in the right direction and ask the right question...instead of the NRC and the Pilgrim plant to thoroughly self disclose to a community. It is just not right...it is honesty and integrity! Do you know the difference between state oversight between Massachusetts and Vermont?

Personally, I think the NRC is thumbing their nose at Massachusetts and the Attorney General's office over the recent court relicensing case. We are the top dog here in Massachusetts with a nuclear plant...we can allow Pilgrim to operate in any manner we wish. I am certain the NRC is looking over their shoulder to the nuclear industry with recent events...the states will never have any influence over the safety of a nuclear plant. It is similar to the Vermont Yankee and Vermont state court case. The agency and industry are edgy over this with a lot of money on the line...so they are allowing the Pilgrim Plant to operate outside the lines as a showcase to the industry...show that NRC will always dominate over plant operation even if they are unsafe.

The industry with natural gas fracting, low electric demand and cheap electric grid prices has never been as economically threatened as it is now with declining stock prices and budget cutbacks the plants. The NRC is totally controlled by the rabid mad dog congressional extreme right wing republicans. The Nuclear Regulatory commission is in terrible shape.

I grew up in the Pine Point section of Springfield Ma!

Mike Mulligan
Hinsdale, NH
16033368320

Now I get it.

http://signon.org/sign/massachusettss-gov-patrick?source=c.url&r_by=7116619
 
Signon.org

Please sign my petition?

Massachusetts's Gov. Patrick: Demand Immediate shutdown/NRC investigation Of Pilgrim Nuclear Plant because of defective "new" core cooling safety valves.

Note: 

So today I called NRC's Neil Shaheen saying, "rumor has it the Pilgrim plant is restricted to 94% for the last few weeks because another SRV is leaking. The design of the the valves are defective. He knew I had information that wasn't publicly available. That is when he said a SRV is leaking.

So I also spoke to person in the Ma Executive Office of Energy and Environmental Affairs...

Then to the Massachusetts's Attorney General Office...

Ultimately, I am trying to reform the NRC...

Pilgrim's Safety Relief Valve Leaking Boondoggle  ...I started documenting events Feb 10...

From: Michael Mulligan  To: "newstip@globe.com" ; "allegation@nrc.gov"
Sent: Thursday, March 7, 2013 12:32 PM
Subject: 2.206: Pilgrim Nuclear Plant SRV Request for Emergency Shutdown
 
 
Dear sir,

I called this into your hotline by telephone and left a message to a reporter an hour or so ago. This is just a follow-up.

I'd like to get Gov Patrick to demand an immediate Pilgrim shutdown and demand a special investigation of these events.

Mike
So the below is my 2.206 request to the NRC. You'd do me a favor if the BG calls our region I public relation people...Neil Shaheen.
March 7, 2013

Bill Borchardt
Executive Director for Operations
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001

Dear 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.

4) Request the OIG investigate this NRC cover-up to keep an unsafe nuclear plant at power.

References:
  

 


Sincerely, 

Michael Mulligan
PO Box 161
Hinsdale, NH 03541
16033368320
steamshovel2002@yahoo.com

Wednesday, March 06, 2013

Oconee Nuclear plant: “quality issues with vendors”

So you think this stops at Oconee?
Repko and his colleagues blamed “quality issues with vendors” and waiting too long to assess the root causes of the delays.
This is the oldest game of delaying a inspection, investigation or root cause investigation for self interest....engineering the timeframe for a investigation...

The NRC can't enforce standards on Oconee and Oconee can't enforce standards on their venders.

Welcome to the to the world of the mad dog rabid "I hate the government standards anything" teabagger right wing extremist Republicans...

Nuclear station fire improvements delayed until 2016

 
ROCKVILLE, Md. — Duke Energy officials said Tuesday that fire safety upgrades at the Oconee Nuclear Station may not be complete until November 2016.

Duke executives met with Nuclear Regulatory Commission staff Tuesday to explain why the upgrades, which were due for completion at the end of 2012, are still not done. Temporary measures such as portable water pumps for firefighting, enhanced training for employees and mutual-aid agreements with Oconee County’s emergency management office are now in place.

Regis Repko, the Duke vice president in charge of the Oconee station, admitted that the temporary measures are little comfort.

“Incremental risk management cannot excuse the fact we missed the date,” Repko said.

Repko and his colleagues blamed “quality issues with vendors” and waiting too long to assess the root causes of the delays.

“We did not understand the full breadth and scope of the project,” Repko said.

Duke asked in July 2012 for an extension until 2014 to finish the project, only to be rebuffed by the commission. When pressed Tuesday for an estimate of when the work would be complete, Repko and his colleagues said it would probably be November 2016 — four years past the deadline and two years later than they estimated last summer.

They said many of the corrective actions have only come since the beginning of this year, after the extension request was denied.

“It sounds like a lot of this was in response to the (enforcement) letter sent earlier this year,” noted NRC staffer John Monninger

Industry watchdogs listening in on a conference call were incensed.

“I find it troubling that they’ve laid off a timeline three and a half years down the road,” said Tom Clements of Friends of the Earth in Columbia.

David Lochbaum, the Knoxville-based watchdog for the Union of Concerned Scientists, called for the “immediate shutdown” of all three nuclear reactors at the Oconee facility until Duke is in full compliance.

Monninger, who ran the meeting, wrapped up the proceedings by stressing that no action, civil or otherwise, has been determined. No date has been set for the NRC to announce what, if any, sanctions Duke will face.

Tuesday, March 05, 2013

Immediate Safety Shutdowns And Inspections For All USA Nuclear Plants

More Nuclear Safety Counterfeit and Fraudulent Parts In Fort Calhoun.

So these guys had environmentally unqualified nitrile elastomers in containment nuclear safety valve air actuators...then we know Peach Bottom and Vermont Yankee had grossly unqualified buna-n seals in their safety relief valve air actuators.

We have had a massive breakdown in the quality of components in the nuclear industry...this places in question the safety of any nuclear plant in the USA.

We have had a massive breakdown with enforcing environmental qualification of the safety components in all reactors by the utilities and the NRC!




Power Reactor
Event Number: 48806
Facility: FORT CALHOUN
Region: 4 State: NE
Unit: [1] [ ] [ ]
RX Type: (1) CE
NRC Notified By: SCOTT MOECK
HQ OPS Officer: VINCE KLCO

Notification Date: 03/04/2013
Notification Time: 18:32 [ET]
Event Date: 03/04/2013
Event Time: 14:00 [CST]
Last Update Date: 03/04/2013

Emergency Class: NON EMERGENCY
10 CFR Section:
50.72(b)(3)(ii)(B) - UNANALYZED CONDITION

Person (Organization):
RYAN LANTZ (R4DO)


 

Unit

SCRAM Code

RX CRIT

Initial PWR

Initial RX Mode

Current PWR

Current RX Mode

1

N

N

0

Cold Shutdown

0

Cold Shutdown


Event Text

UNANALYZED CONDITION DUE TO MECHANICAL SEAL MATERIAL DESIGN

"It has been determined that the mechanical seals used in two Low Pressure Safety Injection Pumps and three Containment Spray Pumps are made of a material that may not maintain the designed integrity of the systems under certain accident conditions. These seals have been installed since original plant construction. This issue was discovered by plant personnel while researching requirements for the replacement parts during scheduled outage activities."

The licensee notified the NRC Resident Inspector.

Friday, March 01, 2013

Durbin blast Exelon For FutureGen Betrayal

March 4:

Just saying, our political system has severely polluted our energy and electricity system with ghost cost to us little people...
Is that our future, all the electricity players get to burden their expensive pet project on the bottom half as they are draining our income away from us...then these sources get to pay the elections bills of the politicians.

Typically the highest priced electricity source sets the prices on everyone else...the highest price electricity that gets on the grid they pay to everyone else.

I am just saying, I am against all sources of energy that survives by heavy government subsidies, then this expensive electricity comes on as the highest price source of electricity on the grid, this then set the cost we pay of even the lowest cost producers...
 
So Durbin wants to undermine the rate player and Exelon to support 200 workers and his getting elected through the green folks.

For a second here, I pity Exelon...

Effectively Durbin wants to turn Exelon into his piggy bank...

Exelon got a huge dividen cut, natural gas is breathing down their thoats...and wind is sucking the rest out of them...

Durbin blasts Exelon for FutureGen 'betrayal'
U.S. Sen. Dick Durbin today blasted Commonwealth Edison Co. and its parent Exelon Corp. for what he termed a “heavy-handed corporate betrayal” after Crain's report of ComEd's plan to challenge a state decision to impose a surcharge on electricity customers statewide to pay for development of the FutureGen 2.0 “clean coal” power plant downstate.

In a statement, Mr. Durbin, the No. 2 Democrat in the Senate, said Chicago-based Exelon, the state's largest power generator and the country's largest nuclear plant operator, acted as a member of the FutureGen Alliance for more than two years.

Exelon, he said, “was an intimate party to our state's strategy to negotiate this historic energy research project and the 2,000 jobs it will bring to our state. Exelon sent its smiling representatives to press conferences lauding the virtues of FutureGen.”

Then, Mr. Durbin went on, “last month Exelon abruptly resigned from the FutureGen Alliance without explanation, and today we learned Exelon has filed an appeal challenging the (Illinois Commerce Commission) ruling which is a critical part of our FutureGen strategy. This heavy-handed corporate betrayal has few parallels in Illinois history.”

Earlier today, before Mr. Durbin's broadside, an Exelon spokesman said the company never joined the alliance despite a January 2010 announcement that it intended to do so.

“Our decision reflects our long-held position that customers should not be forced to pay enormous above-market charges for electricity, as the project is now seeking,” the spokesman wrote in an email.

Asked about that, a Durbin spokeswoman confirmed that Exelon never paid any money or signed formal papers to join the FutureGen board. But, she said, the company participated in strategy and planning for two years and only stopped participating last month.

In a Feb. 18 letter from Exelon CEO Christopher Crane to Mr. Durbin furnished by Exelon, Mr. Crane said his company opted not to join the alliance because its financing plan shifted from one relying more heavily on corporate equity investment to one focused on charging Illinois consumers more for energy. In January 2010, when Exelon announced its intention to join the alliance, the plan was to ask 20 corporate members to contribute up to $30 million each.

“Unfortunately in 2012 this original structure was scrapped in favor of a new structure where corporate contributions are significantly reduced and customers are now required to fund approximately $150 million in annual above-market costs for the entire 30-year life of the project — a total of $4.5 billion,” Mr. Crane wrote.

The $1.6 billion project, which aims to retrofit a shuttered power plant formerly run by Ameren Corp. in downstate Meredosia and construct a pipeline to carry carbon dioxide for burial in nearby Morgan County, needs more than $600 million in private financing. The ICC in December approved a plan to require household and business power customers, whether they buy from utilities or competing retail suppliers, to purchase output from the plant at above-market prices.

Under the plan, the FutureGen Alliance projects household customers will pay a little over $1 per month extra for 20 years to finance the project.

Mr. Durbin finished his statement with this: “We fought Texas to win this project and we fought the odds to move it forward. Now we are prepared to fight Exelon to save 2,000 jobs for our state.”

Saturday, February 23, 2013

The LaSalle Nuclear Plant Cooling Lake and NRC Idiocracy

LASALLE COUNTY STATION UNIT 2 NRC SPECIAL INSPECTION REPORT 50-374/01-017(DRP) 2001017

LASALLE COUNTY STATION NRC INSPECTION REPORT 50-373/01-16(DRP); 50-374/01-16(DRP) 2001016


Feb 26, 7 pm: You get it, a forced two year shutdown by the NRC beginning in 1996. A massive capitol under investment in their nuclear fleet for the first half of the 1990's and enormous problems fleet wide. So they had a huge re-think brought about by a newly serious NRC. ComEd stated massively reinvesting back in their nuclear fleet. This directly lead to the huge 1999 Chicago electric power distribution and transmission crisis. Lots of electric blackouts in this summer of 1999. They plowed monies into their nuclear fleet and started starving their transmission system

It wasn't a nuclear technology crisis...it a management crisis of one of our largest electric utilities. 

What was growing on at the end of the 1990s, in the weakened end of president Clinton's era, the rabid mad dog republicans had taken over congress. They intimidated the NRC by threatening to cut their budget, the 1990 rendition of the republicans shutting down government over deficits and the new obstructionist blackmail politics.  

This was when the NRC moved towards massive historic public opaqueness. The nuclear industry moved in a unparalleled historic manner towards nuclear industry deregulation. Building a hundred new nuclear plants was on the horizon. It was a boomerang from the re-regulation area, trying to gain control of the poor performing and unsafe early 1990s nuclear industry.

Right, 1999 Chicago was in a terrible drought and heat wave, terrible fear was in the air over electric deregulation and ComEd stock prices were pitifully weak. Enron and the California power crisis were just a few years away. The "Exelon" name was just a knockoff of the Enron name.

So happy days were here again on July 24, 1998.                  
NEWS ANNOUNCEMENT: RIII-98-46 July 24, 1998
CONTACT: Jan Strasma 630/829-9663

NRC STAFF FINDS SUFFICIENT IMPROVEMENTS FOR RESTART
OF UNIT 1 OF THE LASALLE NUCLEAR POWER STATION
The Nuclear Regulatory Commission staff has determined that
Commonwealth Edison Company has made sufficient improvements at Unit 1 of the LaSalle Nuclear Power Station for the unit to resume operations. The two-reactor facility is located near Seneca, Illinois.

The utility is planning to begin startup of the unit next week. Both units were shut down in September 1996 for refueling and maintenance and remained shut down for extensive plant modifications, staff retraining, and other performance improvement initiatives.
So the lights go out in Chicogo in 199
Comed Pays For Misspent Decades

Aging Infrastructure Now Haunting Utility

August 15, 1999|By Peter Kendall and Laurie Cohen, Tribune Staff Writers. 
Like most everything at ComEd, following the trail of the problem eventually leads back to the utility's struggles with its nuclear generation program, the most ambitious in the nation.  
Even a decade ago, many were warning that some of the billions of dollars spent to build the nuclear plants should have been spent on wires and transformers. 
Ironically, at the point at which ComEd seems to have turned around its mismanaged nuclear plants--this summer, for the first time in years, all five plants were up and running--it is now suffering the fallout from what many say has been equally shoddy management of its more prosaic electricity delivery system.
By 2001, with all the leaking safety relief valves seen throughout the Exelon fleet of nuclear power plants, particularly the six pack of SRV valves leaking at both LaSalle plants: they raising their suppression pool temp limit to 105 F to accommodate poor maintenance and quality safety parts; beginning to overload their cooling pond with plant heat; then panically trying to raise the cooling pond temperature..I thought these guys had marginally adequate systems and components at the plants, had marginally competent employees running the nuclear fleet just after a prolonged shutdown for safety reasons in the late 1990s. It was startling.     

We knew we were on our way to nirvana with “balls to the wall” George Bush assuming office in Jan 2001, with LaSalle by-passing 10% of power from their turbine through their SRV valves, then demanding their suppression pool safety pumps run on continuously

...the 2002 Davis Besse head leak was frosting on the cake.  

Where do we sit today. Exelon just slashed their dividend by 41% because of the cheap natural gas problem, poor electric demand...they are threatening to shutdown nuclear plants. By the grace of god and fracting, they have cancelled all the nuclear plant Extended Power uprates as too expensive. They are cutting $2.4 billion dollars from Exelon’s nuclear capital expenses.  Exelon’s stock price in 1999 was $24, a massive Exelon stock price speculative bubble led to a historic high price of $91 dollars...the current price is $31 dollars. After the stock price speculative bubble burst in 2008 to about $50 dollar...the stock price has been slowly declining to today price of $31 dollar.         

...Graphical Climatology of Chicago Temperatures, Precipitation, and Snowfall (1871-Present)

Right, they are planning for a extended 12% power up rate per plant by 2015 without building cooling towers. 

So, the below is Aug 15, 2011 NRC request for information posed to Exelon after their May 6, 2011 LAR.
If the agency would have done a proper "due diligence" data search in the lead up to their Exelon's LAR response...they would have known the high historic cooling pond temperature of 101.33 °F occurred on August 12, 2010  and was in their Aug 12/13 daily event report page. Doesn't seem to be in the 2010004 inspection report. Maybe this was the reason for the write-up on the 2012004. It is spotty inspectors reporting on these events.
The NRC in their IR 2010004 says Lasalle was down powering through the summer of 2010 to control the high temperature of the LaSalle cooling water pond. 
This Aug 15, 2011 NRC document is grossly inaccurate with these NRC officials in assuming Exelon-LaSalle was "approaching the TS limit of 101.25 F" (they exceeded it with 101.34 Aug 12, 2010) and the "actual peak accident post-accident UHX temperature of 104" (it is actually 106F).

Who can you trust?

No question the agency should have demanded a voluntary thorough and detailed LER out of Exelon on the Aug 12 2010 event and certainly the NRC failed to do a immediate detailed inspection.
(Aug 15, 2011)Exelon's request for amendment to TSs dated May 6, 2011 states:


"High temperatures and humidity during the daytime, in conjunction with minimal cooling at night and little precipitation during the summer months, results in elevated water temperatures in the LSCS UHS. Weather conditions in the future may result in the temperature of the [Core Standby Cooling System] CSCS pond challenging the current TS limit of 101.25 F.'' 
LSCS updated final safety analysis report (UFSAR) Section 9.2.6.3.2, "Ultimate Heat Sink Temperatures and Evaporation Losses During Shutdown Conditions," states:

"The results of the analysis for the worst-case historical weather effect on the temperature of cooling water supplied to the plant from lake/UHS indicate the peak temperature of cooling water from the lake will be 97.5 F and it occurs late in the afternoon (approximately 6 pm)." 
If the analysis shows that the worst case historical weather effect on the cooling water to the plant from the lake/UHS results in a peak temperature of 97.5 F.
(a) Why is the CSCS pond temperature exceeding 97.5 F and approaching the TS limit of 101.25 F?

(b) With the CSCS pond exceeding the UFSAR peak temperature of 97.5 F and the high temperatures and humidity (as stated above), discuss the validity of the 1.3 F post accident heatup in the CSCS pond and its affect on the actual peak accident post- accident UHX temperature of 104 106F
Can you imagine that, this is the first or maybe the second summer after the 2000 five percent power uprate...they are already begging the NRC for a raise in the LaSalle cooling pond water temperature limits.

As in engineer's plant language,  the "prolonged hot weather" term to totally fictitious and they know it...they are falsifying federal documents. At the least they can say, the prolonged hot weather is a minor factor, the major cause is we are overloading the lake with heat from the power unrate.   

They are already overloading the cooling pond with nuclear plant heat: To a 103 degrees, not yet? This is the amendment :
August 2, 2001 
RS-01-152 
Subject: Application for Amendment to Technical Specifications Surveillance Requirement 
for the Ultimate Heat Sink Temperature 

Prolonged hot weather in the area has resulted in sustained elevated cooling water temperature supplied to the plant from the CSCS pond. High temperatures and humidity during the daytime, in conjunction with very little cooling at night and very little precipitation, have resulted in elevated water temperatures in LaSalle County Station's UHS. 

The average temperature of the UHS reached 98 OF on July 21, 2001.
 The current SR verifies that the temperature of the cooling water supplied to the plant from the Core Standby Cooling System (CSCS) pond is •100 °F every 24 hours. This request will modify SR 3.7.3.1 to allow continued operation of both units with CSCS pond temperature of •103 OF through September 30, 2001. 
The NRC's  Licencing Amendments Request (LAR) requires a sworn and certified signature. It is the accepted culture of lying and half truths for self protection.
AFFIDAVIT 
I affirm that the content of this transmittal is true and correct to the best of my knowledge, information, and belief.

K. A. Ainger (C/ 
Director- Licensing Mid-West Regional Operating Group 
SUMMARY OF JUNE 28,2012, PRE-APPLICATION MEETING WITH EXELON GENERATING COMPANY, LLC, TO DISCUSS LICENSING AMENDMENT REQUEST FOR LASALLE COUNTY STATION UNIT 1 AND UNIT 2 ULTIMATE HEAT SINK AT AT EXTENDED POWER UPRATE POWER LEVELS (TAC NOS. ME8866 AND ME8867)
It's called magical thinking...you let them get away with it for over a decade.


Previously, the staff has reviewed LSCS UHS LARs in 2001,2006,2007, and 2011 (only the 2007 UHS LAR concluded in an NRC approval). (Ouch) The licensee stated that they did not consider the UHS LAR linked to the future EPU application.

only nuclar enginners think this inside the boxthinking is safe and wha the public wants  ...wow...did not consider the UHS LAR linked to the future EPU application.

I feel sympathy for the Exelon's monsters the inspectors are dealing with...feeling sorry for these little inspector whose big bosses aren't backing them agianst the monster corporatim



...At least the 2012 flextime safety cooling pond amendment proposed 30 day worst case aligns with either 1995 drought and heatwave. The current worst case of record is in left field. The 1 day July 2001 aligns with   the IR 2001010 (2001)/
How come the cooling lake peak historic temperature of August 12, 2010 and the second worst on Aug 8, 2005 is totally disconnected for the worst meteorological worst case choices of Exelon's 2012 flextime amendment request. How come the severe droughts and heatwaves of 1995 and 1999 didn't challenge the 100 F limits of the LaSalle... how come in the inspection report 2010004 and the 2012004 they didn't talk about the cooling pond highest historic peak temperature wasn't in the severe droughts and heat wave of 1995 or 1999. 

It is simple as hell, they overload their cooling pond with heat from the two 5% power uprates in 2000. 

According to the Exelon's  2012 flextime UHX, the proposed worst 30 day weather is from July 21, 1995, 3:00 p.m. to August 20, 1995, 3:00 p.m., the great Chicago heatwave of July 12-16 1995, how come we see no record high temperature LaSalle cooling pond temperatures in the summer of 1995?     

Current UHS TS Analysis 
(through primitive fluid dynamic computer models:) 

Period Analyzed: July 4, 1948, through June 30, 1996

Worst Temperature Weather Periods:

  • 1-day: July 15 to July 16, 1995

  • 30-day: July 10, 1983 to August 9, 1983

  • Worst 30-Day Evaporation Weather Period: June 18, 1954, to July 18, 1954
Proposed UHS TS Analysis 
Weather Period Analyzed: July 4, 1948, through June 30, 1996 (Peoria and Springfield, IL) January 1, 1995 to September 30, 2010 Worst Temperature Weather Periods:


  • 1-day: July 24, 2001, 6:00 a.m. to July 25, 2001, 6:00 a.m.

  • 30-day: July 21, 1995, 3:00 p.m. to August 20, 1995, 3:00 p.m.

  • Worst 30-Day Evaporation Weather Period: June 18, 1954, to July 18, 1954"
Inspection report 05000374/2012004 dated Oct 30, 2012

"from the cooling water temperature from the CSCS pond reaching 101.34 °F on August 12, 2010. This was the highest inlet temperature ever reached to date and had exceeded the TS 3.7.3.1 limit of 101.25 °F. The previous highest temperature for the cooling water from the CSCS pond was 99.8 °F on August 8, 2005." 

The  1999 Illinois drought and heat wave. 
Drought of 1999-2000 Overview
Dry conditions began in Illinois in July 1999 due to a sudden and consistent reduction in the amount of precipitation that was falling over the state (Figure 1). Precipitation in the prior six months (January-June 1999) showed a statewide total of 22.70 inches or 22 percent above average. The other water resources of the state, soil moisture levels, streamflow amounts, and shallow well ground-water depths, reflected the above average precipitation condition, and gave no indication of concern as to the availability or status of the water resources in the state.
The Nature and Impacts of the July 1999 Heat Wave in the Midwestern United States: Learning from the Lessons of 1995
The July 1999 heat wave in the Midwest was an event of relatively long duration punctuated by extreme conditions during its last 2 days. The intensity of the heat wave on 29 and 30 July rivaled that of the 1995 heat wave that killed more than 1000 people in the central United States. In 1999, however, the death toll was about one–fourth of this amount in the same region. The 1999 heat wave 2–day maximum apparent temperature was slightly less than during the 1995 heat wave at most Midwestern first–order stations. In addition, the 2–day peak was preceded by several hot days that allowed some short–term acclimatization to occur prior to the intense final days. In Chicago, conditions during the peak of the 1999 heat wave were very similar to those during the 1995 heat wave peak, especially the extreme nocturnal conditions of temperatures and humidity. Therefore, it seems unlikely that the reduction in the heat wave death toll in Chicago from about 700 in 1995 to 114 in 1999 is due solely to meteorological differences between the two heat waves. In St. Louis, the 1999 heat wave was intense for a much longer duration than the 1995 heat wave, thus partially explaining the increase in heat–related deaths there from the 1995 event to the 1999 event.
Feb 26: Do you really think the high Illinois temperature was the cause of the tech spec change. They would be bypassing 10% of the power from their turbine though the leaks in their SRV valves...10% power was going into their suppression pool. This is what men do with with a mechanical conscience.  

They just got a culture of acceptable lying...engineering lying going on. The NRC allows them to lie for protection from the public. it is still going on...they are lying to protect you. From the revising the Tech Spec from 100 F to 105 F, to the acceptance massively leaking SRV valves, this is all a huge reduction in safety margin for no good reason...

From the NRC in 1989: Specifically, the proposed change would raise the suppression pool temperature limit during normal operation from 10°0F to 105'F.

"The licensee stated that the unusually high temperatures in Illinois, the temperature of the LaSalle lake, which serves as the ultimate heat sink for the plant service water and residual heat removal (RHR) systems, have risen to the point where an insufficient differential temperature is available to maintain the suppression pool temperature below 100'F.
This is the really bad old days (2001010) Sept 2001:

This revised operability evaluation identified that LaSalle Unit 1 and Unit 2 each have six leaking SRVs. The impact of this issue has been an increase in suppression pool level as well as a slow heatup of the suppression pool. To address suppression pool temperature issues, operators run the RHR system in the suppression pool cooling (SPC) mode to cool the suppression pool to maintain the suppression pool temperature below the Technical Specification 3.6.2.1 limit of 105 F.

The operating time of the RHR system in the SPC mode is dependent upon the heat input into the pool and the LaSalle cooling lake temperature. Recently, the Unit 1 SRV leakage rate and lake temperature increased to the point that RHR operation on a daily basis was required. As a result, licensee management made a decision to operate one train of the Unit 1 RHR system in the SPC mode continuously and implemented this action on June 6, 2001. The technical basis for this decision was documented in Analysis L-002766, .GE NEDC & Continuous Operation of RHR in the Suppression Pool Cooling Mode,. Revision 0, dated May 10, 2001, and reviewed and approved by the Plant Onsite Review Committee (PORC) on June 8, 2001.

The inspectors reviewed OE00-009, Revision 2, and verified that the RHR system would automatically re-align from the suppression pool cooling mode to the injection mode within the time required to satisfy design basis assumptions.
In them days, the industry was demanding less testing of the RHR components saying the operation of the system was damaging and wearing out their equipment. But using the RHR component to compensate for poor maintenance and poor quality of safety relief valves leakage does not wear out extremely important RHR components.

 ...I mean, there is a huge disconnect with the meteorological one day worst weather and actual effects on the LaSalle cooling pond temperatures. How come the instrumented meteorological data don't line up with the plant service water inlet temperatures? Meteorological data is supposed drive pond temperatures? 

How come on the amendment the proposed July 24, 2001  historic "one day worst weather" doesn't line up with the historic highest peak cooling pond temperature in IR 2012004. The highest and second to the highest pond summertime temperature peak  is  101.34°F on Aug 12, 2010 and 99.8 °F on August 8, 2005. Exelon says the worst on record is July 24, 2001. You guys worried about spending a $ 1 billions on cooling towers for just three weeks in the summer? Is that what the lying and federal document falsification is all about?  

In the current worst weather analysis and proposed, what it the fixation of the middle of July and the end of July with the worst one day weather, as also an inclination on the 30 day worst weather too? Why the worst weather not heavily weighted in August from your meteorological list...instead of July. Inspection report 2012004 tells us historically the highest temperature of the cooling water occurred Aug 9 and Aug 12 with LaSalle. Millstone shuts down also on Aug 12 last year...is this all a coincidence? Generally across the board on cooling water bodies nationwide, the peak summertime pond, mostly closed cooling bodies, and streams and rivers, occur mostly around mid to late August. It is the so call worst one day or 30 day weather, along with the fuel load for potential fire, that is the as is temperature load of the pond that drives risk?  

I'd like to see a list of peak summertime pond temperatures and the dates for 2 decades.

Is an algae bloom taken into consideration with the Aug solar radiation and cooling pond temps?

The historic 2005 and 2010 peak summertime temperature falsifies your worst weather analysis and it questions the integrity of its predictions.

And service water temperatures are more indicative of risk than the diurnal pond temperature...a three day, week or a monthly rolling average of lake water temperatures.

Why in the world would the NRC accept a 1976 one dimensional computer model in a safety applications in 2013 for flow and thermal dynamics for a UHX? What a disgrace. Does it give you the profit calculations you want?   

The computer program used to model the LaSalle UHS during the design event is LAKET-PC developed by Sargent and Lundy in 1976 as a one-dimensional thermal prediction model for bodies of water.
I called this their flextime nuclear safety amendment...safety limits bent to the convenience of a nuclear utility.

RS-12-084
July 12, 2012
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, DC 20555-0001
LaSalle County Station, Units 1 and 2
Facility Operating License Nos. NPF-1 1 and NPF-1 8
NRC Docket Nos. 50-373 and 50-374

Subject: In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) is requesting a change to the Technical

"The weather data was evaluated to determine the worst 24-hour and 30-day weather periods resulting in maximum plant intake temperature (i.e., minimum heat transfer to the atmosphere) and for the worst 30-day period of net evaporation. The following summarize the results of the limiting weather data periods.
Current UHS TS Analysis
(through primitive fluid dynamic computer models:)

Period Analyzed: July 4, 1948, through June 30, 1996

Worst Temperature Weather Periods:

  • 1-day: July 15 to July 16, 1995

  • 30-day: July 10, 1983 to August 9, 1983

  • Worst 30-Day Evaporation Weather Period: June 18, 1954, to July 18, 1954
Proposed UHS TS Analysis
Weather Period Analyzed: July 4, 1948, through June 30, 1996 (Peoria and Springfield, IL) January 1, 1995 to September 30, 2010 Worst Temperature Weather Periods:

  • 1-day: July 24, 2001, 6:00 a.m. to July 25, 2001, 6:00 a.m.

  • 30-day: July 21, 1995, 3:00 p.m. to August 20, 1995, 3:00 p.m.

  • Worst 30-Day Evaporation Weather Period: June 18, 1954, to July 18, 1954"
Inspection report 05000374/2012004 dated Oct 30, 2012

The inspectors reviewed AR 1101063, “Dual Unit Limiting Condition for Operation (LCO) Entered Due to High Lake Temperature,” that documented a reduction of power to approximately 80 percent for both units due to problems caused by the fish kill resulting from the cooling water temperature from the CSCS pond reaching 101.34 °F on August 12, 2010. This was the highest inlet temperature ever reached to date and had exceeded the TS 3.7.3.1 limit of 101.25 °F. The previous highest temperature for the cooling water from the CSCS pond was 99.8 °F on August 8, 2005.
You guys are confusing the hell out of me. So if you used the post March 13, 2006 UHX service/ circ water temperature accuracy on the Aug 8 2005 peak temperature the indicated temperature would be °F? It is a huge jump from 98.3°F to 101.34 °F. I am drowning here, if we are using the pre March 13, 2006 instrument accuracy on Aug 12, 2010 it would really be 102.84 °Fand still a huge jump from 98.3 °F.

It still don't add up to the limit of >100°F in pre 2006 and less than or equal to 101.5°F post March 13, 2006 amendment?


1) Request a OIG investigation on the massive public lying and other fraud going on here for over a decade.

2) The NRC withdrawal all past LARs on the UHX...limit plant operation to less than 95 degrees F pond temperatures.
4) I consider the worst accident as August plant operations with severe plant heat overload, then breaking historical pond/service water intake temperatures killing many 1000s of lake fish in a historic drought or heat wave, a dike failure and then the DBA nuclear plant accident. The living, dead and dying fish all collecting in the deep water areas, the heat killing them all... it damages all traveling screens and clogs up all cooling water into the plant then leading to LOOP. Just like the pond historical temperature event in 20100004 on Aug 12, 2010 and the Oct IR 2012004.

5) Does the computer model only take into account a uniform temperature in a column of water...while the lake depths has temperature stratifications. Might we have a much higher temperature on the surface, much higher than the limits, while the plant intake sucks on a lower temperature stratification layer. Could the increasing hot surface layer quickly infiltrator the cooler layers...unexpectedly thereby spiking to inlet temperatures as we exceed the historic record temperatures.

6) So the transport time for the lake is 30 hours with two plants up at full power and full circulation water, from the discharge back to the inlet of the plant. Does anyone really know what the lake flow and thermal effects does for two shutdown plants and on emergency service water loads. The full power circulation water flow dwarfs the emergency flows. How do you know the full flow mode...the 30 hour transport time is a worst case more than much less pump drive. Obviously the transport time would be slowed down. You trust your intuitiveness on this? Request the cooling pond be three dimensionally computers modeled with a real transport time and it include all flow and temperature characteristics.


di·ur·nal

I made a lot of mistakes in my first video...

Fantastic new scientific invention by our nuclear folks...flextime nuclear plant safety limits.. Safety limits that are convenient to utility profits...

So if the cooling lake exceeds the 100.25 degree limit at 6 am, say 102 degrees. The requirements are they have to be shut down in 12 hours. They can drag their feet and they do drag their feet. So all they do is put their hand in their pockets until the graph rises at about 8:30 am past the limits. They can do that all summer long if they wish.





















They keep uprating power to the nuclear power plant with a too small cooling lake leading to a reduction is safety margins and to unpredictable results.

Can dead fish lead Fukushima?




October 11, 2002 Ultimate Heat Sink

Mr. Michael Mulligan
P.O. Box 161
5 Wood Lawn Lane
Hinsdale, NH 03451

Dear Mr. Mulligan:

I have reviewed your e-mails dated June 18, July 22 and August 7, 2002, all of which were addressed to the U.S. Nuclear Regulatory Commission’s (NRC’s) Office of Public Affairs via Mr. Victor Dricks. Most of your comments were addressed in previous letters to you [specifically our letter dated February 13, 2002, which addressed your Yankee Nuclear Power Station (Vermont Yankee) November 30, 2001, petition, as supplemented on December 3, 2001; your January 4, 2002, petition on Vermont Yankee; and your LaSalle petition dated December 28, 2001, as superseded on January 4, 2002]. As discussed in our letter to you dated August 23, 2002, I am only addressing issues in the e-mails that are within NRC's jurisdiction and that warrant additional actions on our part. As stated in our letter to you on August 22, 2002, the allegations of wrongdoing by the NRC staff have been forwarded to the NRC’s Office of the Inspector General.

You requested an explanation of the sentence on page 2 in the Cooper Nuclear Station (CNS) ultimate heat sink (UHS) amendment (ADAMS Accession No. ML022060152), "Assuming 102 percent reactor power is typical and consistent with what the NRC considers to be acceptable for design-bases applications, we consider this assumption to be acceptable." The NRC staff agrees that this sentence could have been better stated. For the UHS amendment, CNS was not as conservative as their original calculations which assumed 104 percent. However, to account for instrumentation error 10 CFR Part 50 Appendix K requires that the licensee assume at least 102 percent reactor power. Therefore, the NRC staff found CNS’s assumption of 102 percent, for the UHS amendment, to be acceptable.

You asked why the UHS amendment was issued on an exigent and not an emergency basis. The NRC staff evaluated the licensee's rationale against Section 50.91(a)(5) of Title 10 of the Code of Federal Regulations (10 CFR) which requires licensees to "explain why the emergency situation occurred and why it could not avoid the situation." The licensee's letter of July 3, 2002, did not address why the emergency could not be avoided. Therefore, the NRC staff had determined not to act on the licensee's request pursuant to 10 CFR 50.91(a)(5). The NRC staff, however, recognized that for continued operation of CNS, the licensee and the Commission needed to act quickly, and time did not permit the Commission to wait for the 30 day prior public comment period. In accordance with 10 CFR 50.91(a)(6), the staff processed the two amendments concerned on an exigent basis to prevent an unnecessary plant transient.

You expressed concern that there has been an increasing trend with license amendment requests asking for higher UHS limits in the last few years. Generally, trends in license amendments have been attributed to various reasons. For instance, licensees have utilized topical reports as templates for submitting amendment requests. Therefore, related amendments are typically requested following the approval of a topical report. Other times, important inspection findings at one plant have prompted other plants to request license changes. UHS amendments have been issued to remove unnecessary restrictions in the technical specifications (TSs) on plant operators in severe weather conditions. TSs limits on UHS parameters such as temperatures and water levels are based on assumptions made in design and licensing analyses. Changes in weather patterns have resulted in many plants approaching the values assumed during original licensing reviews performed 20 to 30 years ago. In this case, the utility was able to prove that operation at higher UHS temperatures was safe. The NRC determined the licensee’s request was justified and approved the change to the TSs
 
You asked why additional changes were needed (beyond the heat sink limit) in related limits, if there is so much safety margin built in. Many systems are related. Therefore, in considering a change to one system’s parameters, the effect on other systems must be considered. The reactor equipment cooling (REC) system is cooled by water from the UHS, consequently the temperature of the REC system will increase as the UHS temperature increases. Therefore, an increase in the REC system temperature limit was also required.

You stated that CNS has an alcohol abuse problem. After reviewing several of the plants’ fitness-for-duty (FFD) reports over the past two years, the facts do not agree with your assertion that CNS staff has a significant problem. FFD reports are submitted by the licensee biannually per 10 CFR 26.71 to ensure a rigorous drug and alcohol screening policy is in effect. FFD reports are available in the Agencywide Documents Access and Management System (ADAMS) Public Electric Reading Room.
Finally, you stated that you believe the NRC purposely did not include your initial comments regarding the amendment request. The NRC does not purposely leave out public comments received in reference to a Federal Register notice. In this case, your comments contained in the June 18, July 22, and August 7, 2002 e-mails were not forwarded to the staff working on the amendment until after the amendment was issued. The only way to ensure your comment on an amendment is addressed is to follow the instructions outlined in the Federal Register which states:

Written comments may be submitted by mail to the Chief, Rules and Directives Branch, Division of Administrative Services, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, and should cite the publication date and page number of this Federal Register notice. Written comments may also be delivered to Room 6D22, Two White Flint North, 11545 Rockville Pike, Rockville, Maryland, from 7:30 a.m. to 4:15 p.m. Federal workdays.

If you have questions on this matter, please contact Mr. Brian Benney of my staff at 301-415-3764.

Sincerely,
/RA/
Stephen Dembek, Chief, Section 2
Project Directorate IV
Division of Licensing Project Management
Office of Nuclear Reactor Regulation
Docket No. 50-298

If you have questions on this matter, please contact Mr. Brian Benney of my staff at
301-415-3764.

Sincerely,
/RA/
Stephen Dembek, Chief, Section 2
Project Directorate IV
Division of Licensing Project Management
Office of Nuclear Reactor Regulation
Docket No. 50-298

DISTRIBUTION:
PUBLIC
PDIV-2 Reading
RidsNrrOD (SCollins/JJohnson)
RidsNrrAdpt (BSheron/JIsom)
WBorchardt
RidsNrrWpc (TJCarter-Gorham [YT-20020211])
LCox
RidsNrrDlpmPdiv (WRuland)
RidsNrrPMBBenney
RidsNrrLAMMcAllister
KBrockman, Region IV
GMulley
ACCESSION NO.: ML022730516 PKG: ML022270713 NRR-106
Incoming: ML022250558 d/d 08/04/02 (Attached-6/18/02)
ML022250570 d/d 7/22/02
ML022250551 d/d 8/07/02
OFFICE PDIV-2/PM PDIV-1/LA PDIV-2/SC PDIV-2/PD
NAME BBenney: MMcAllister SDembek WRuland
DATE 10/3/02 10/3/02 10/7/02 10/11/02
DOCUMENT NAME: C:\ORPCheckout\FileNET\ML022730516.wpd OFFICIAL RECORD COPY


Friday, February 22, 2013

NRC/Exelon with falsified...incomplete documents and investigations?

We are trying to signal to the nuclear industry they have a higher calling for truth telling other than the limited rules and mandates of the NRC.

 
10 CFR 2.206 Petition Review Board RE Peach Bottom Units 2 and 3 Transcripts
Feb 13 2013

"Anyway, anybody listen to the State of the Union speech last night? The White House basically frames it like it's time to apply the same rules from the top to the bottom. President Obama laid out a blueprint for an economy built on American manufacturing, American energy, skills for the American worker, and a renewal of American values, and American built to last. We can either settle for a country with a shrinking number of people who do well while a growing number of Americans barely get by, or we can restore an economy where everybody gets a fair shot, everybody does his fair share, and everybody plays by the same rules.

So, one of the components he outlined was a fair shot, a fair share, and a fair set of rules. Millions of American -- millions of Americans who work hard and play by the rules every day deserve a government, financial systems that do the same. So, you know, as far as being complete and honest and stuff like that, you know, it's a privilege that I'm -- for you people that I'm here and asking questions. And that's the way you should look at me. I'm a very rare individual that comes here and asks some difficult questions and stuff like that. And I'm an American citizen. I live in the best country on the planet, and that should afford me some special rules. And you people should answer me honestly because really, you're answering the public out there and stuff.

 
I needn't remind you that LERs and the special reports are not necessarily about following the rules. A lot of times it's being honest and ethical and disclose everything. That's the way our system is supposed to run, our free market is supposed to run. We're supposed to all have access to adequate information, and as far as our financial system is concerned and our rate payers, and the stockholders, they ought to get a fair shot of understanding what's going on with these companies. And if these politicians make all these rules that limit what the NRC can do, and say, and stuff like that then you're screwing the rate payer and the financial people, and the stockholders.

Ultimately, these things end in a crash when people aren't honest and truthful, and I don't care if they're following the rules. The ultimate income is to do good for us all, and not just follow the rules. They need to have a higher calling than following the rules."

 
 
Markey: Did San Onofre Operator Violate Federal Securities Law?
 

Feb 21 2013 SEC letter

Company May Have Failed to Fully Inform Investors about Design Issues, Rejected Safety Fixes, Attempted to Avoid New License Requirements

WASHINGTON (February 21, 2013) – Rep. Ed Markey (D-Mass.) today raised the possibility that the utility in charge of the San Onofre nuclear power plant in southern California may have violated federal securities laws by failing to publicly report safety information to investors.

According to a letter sent by Rep. Markey to Securities and Exchange Commission head Elisse Walter, the lawmaker says investors do not appear to have been fully and accurately informed of design flaws found by Southern California Edison and Mitsubishi in advance of the replacement of parts of the plant, and that SoCal Edison decided to reject recommended safety modifications for fear that they would be required to undertake a new license process before the parts could be installed. SoCal Edison is the operator of the plant and hired Mitsubishi as a contractor.

The plant’s two nuclear reactors have been shuttered since January 2012 because of unusual amounts of wear found in tubes in the replaced steam generators. In his letter to the SEC, Rep. Markey raises the question of whether by hiding potential design flaws in the replacement generators, and omitting that the company reportedly did so to avoid having to apply for an amended license to operate the reactors, SoCal Edison may have violated the Securities Act of 1933. That law says that all “material facts” -- information that an investor would consider important -- must be fully disclosed.

“Investors presumably would want to know whether a company is choosing not to implement additional safety protocols because such actions might require a nuclear reactor to go through a more strenuous licensing process,” writes Rep. Markey, who is the Ranking Member of the Natural Resources Committee. “Such choices could be evidence of poor management or even possible future civil liability.”

The full letter to SEC Acting Chairman Walter is available HERE.

Rep. Markey also asked the SEC what the penalties would be for violations of this law, and whether other enforcement actions have been taken against energy companies for failing to disclose under similar facts and circumstances. Last week, the Nuclear Regulatory Commission confirmed that they are investigating the completeness of information SoCal Edison provided on the replacement of steam generators.

Wednesday, February 20, 2013

Palisades Component Cooling Water System Leak

See, this system is nothing but junk...keeps causing troubles.

 IR2011001/005

Inspection Scope

The inspectors reviewed the following issues:

cooling tower degradation;

service water pinhole leaks;

pressurizer pressure indicator degradation;

C Primary coolant pump due to increased vibrations; and

component cooling water heat exchanger flow degradation.

...containment spray during ‘B’ pump maintenance;

component cooling water during ‘B’ pump maintenance;

1-1 diesel generator during 1-2 diesel generator inoperability for emergent

ventilation work; and

low pressure injection with ‘A’ pump out-of-service

The inspectors selected these systems based on their risk significance

2011003

Additionally, the licensee determined that the “white spots” on the head were the result of boron staining, white mastic residue used to attach insulation to the head, or chromate water deposits from a previous component cooling water leak.

2010002

The inspectors evaluated degraded performance issues involving the following

risk-significant systems:

component cooling water system; and

 
....risk during planned component cooling water pump outage;