Monday, January 31, 2011

New NRC Blog

Welcome to the new NRC Blog. We are excited about using this new communications tool and hope it will increase our collaboration and interaction with the public. The blog is intended to serve as a vehicle for informing, explaining and clarifying the actions, roles and responsibilities of the NRC, raising awareness about our agency and its mission, and – most importantly – giving us an opportunity to hear from you.

Sunday, January 30, 2011

2.206 liquid scintillation counter emergency evacuation delay

I withdrew this 2.206!


I could inquire about the hydrogen production and release in a accident, then turning into water, but that be nit picking. I have no bases for a 2.206 and will not sunmit one.
Mike,
The liquid scintillation counter at Vermont Yankee is only used for tritium analysis. It is not used in any accident scenario.
NRC Public Affairs
Waiting as answer:
Mr Sheehan,
"He determined that the liquid scintillation counter is not vital to the plant’s radiological emergency response."
So it played no role in the radiological emergency response?
Was there training and practice with a loss of scintillation detector accident?
Mr Sheehan,
"All he had to say is the liquid scintillation counter plays no role in the radiological response?"
Are you saying the scintillation counter plays no role in radiological emergency response capability, or the lead up to the detection of a radiological emergency condition?

I didn't send in the 2.206...but I asked Neil Sheehan about it.
Jan 31 11:00 What does this mean?
...Mr. Mulligan,
A staffer in the Region I Division of Reactor Safety I has reviewed the issue and its potential impact on Vermont Yankee’s radiological emergency response capability. He determined that the liquid scintillation counter is not vital to the plant’s radiological emergency response. In fact, in-line beta-gamma monitors are used for real-time emergency response indications and dose-significant radionuclides are measured via gamma spectroscopy counters in the chemistry laboratory, based on sample measurements. There is sufficient redundancy in the in-line plant monitors and chemistry laboratory gamma monitors to evaluate radiological conditions affecting emergency response. Therefore, there is no safety concern associated with out-of-service liquid scintillation counting equipment with respect to emergency response capabilities.
I hope this addresses your concerns.
Neil Sheehan


Jan 30, 2011
R. William Borchardt
Executive Director for Operations
US Nuclear Regulatory Commission
Washington, DC 20555-0001

Subject: 10 C.F.R. § 2.206 Request a emergency shutdown of Vermont Yankee because the radiological and evacuation emergency procedures and plans were secretly inoperable or impaired between Dec 29, 2010 and Jan 11, 2011.


Dear Mr. Borchardt,

“Rutland Herald Susan Smallheer Jan 29
Irwin said the failure of the test equipment was disturbing.
They told me about the liquid scintillation counter being down and that was the cause of the delay. Irwin said, I figured like most labs, they would get the instrument repaired relatively quickly but for some reason that did not the case.
Irwin said that he only found out about the equipment failure last Friday (Feb 21?) (disclosed at the end of the week Jan 28, 2011), when he asked why the test results form the first well were so late.”


Timeline with Vermont Yankee events: http://steamshovel2002.blogspot.com/2011/01/vt-gov-shumlin-patsy-to-entergy.html


I request a immediate emergency shutdown of Vermont Yankee because of the unreliability of their radiological and emergency plans for a indeterminate amount time. The liquid scintillation counter was broken between Dec 29, 2010 and Jan 11, 2011. That makes the radiological procedures inoperative or severely degraded in this time frame. Not having a backup liquid scintillation counter would make the emergency evacuation plans unreliable. If a nuclear power plant doesn’t have the capability to make reliable their evacuation plans, then they shouldn’t be licensed to operate a nuclear plant.

1) I request a NRC OIG and congressional investigation with why the NRC didn’t immediately notify the community that the Vermont Yankee radiological procedures and evacuation plans were not functional during these dates.

2) Request a investigation, in making sure that all radiological capabilities at the nuclear plants are reliable and durable with sufficient back ups in order to be able to carry out their emergency plans. Request all USA plants have sufficient back up liquid scintillation counter capabilities.

3) Request a information notice to given to all plants about this.

4) Request a disclosure of all delays with getting any radiological measurements that effected any normal or emergency requirement of a procedure.

Sincerely,

Mike Mulligan
Hinsdale, NH 03451
1-603-336-8320
steamshovel2002@yahoo.com

(I know they get a rough measure of liquid radioactivity from other detectors...the downfall in this is I am not exactly clear what the scintillation detector plays in the radiological plans. It seems preposterous the agency would let them get away with ineffective emergency evacuation plans.

You know, if it ain't defined as safety related and in a requirement of a procedure, they let the world fall off a cliff.)

Saturday, January 29, 2011

2.206 on VY plant stack...not safety related.

2.206 on plant stack...not safety related.

Requested immediate shutdown of Vermont Yankee because the plant stack is not safety related. This questions maintaining the safety quality of the stack and it associated equipment and piping...the protection of the public...thus assurance of safety and dose limits can't be maintained at my town of Hinsdale NH.

If the stack toppled over it would take two years or more before it was discovered.

Request all plants in the USA with similar stacks be shut down because there is no assurance of radiological safety and functionality of the plant stack.

Aren't you dying to get the NRC on the record saying the plant stack is not safety related...the stack is visual icon for the whole area...the NRC is saying through the AOG tritium issues you could chop off the stack at the base and the plant could still operate. It is not safety related...

I wonder what the tech spec requirements are if the stack toppled over...how long could they operate without the stack?

Friday, January 28, 2011

They were supposed to have the RCA inspectors talking who wrote the report in the meeting...they withdrew them at the last minute.


Rich, the station chief said really astonished, mike, what you are asking for is a national standard of RCA. I said, you bet we should be doing that..

They basically said we enforce the RCA procedures Entergy writes even if they don't make sense...we don't have our own.

They had absolutely no idea what the engineering characterization of the tunnel was...was it a radioactive barrier?
They both said, what happened greater than three year ago is irrelevant to what the NRC does. We only regulate in a three year window...nothing matters in excess of three years.

I am sorry, I always have had issues with people being intentionally evasive to me, I pressed them a little, I though I behave myself.

You want my opinion, they maintain their profile as small as possible, they are a nothing neutral gray...there object is to make as small a wave as they can.

Mike

Thursday, January 27, 2011

Washington Snow Storm

I would be surprised if the NRC could keep their date with me for our teleconference with the DC snow.

....rescheduled for tomorrow at 1pm

4:00pm: Fascinating isn't it...The Space Shuttle Challenger disaster occurred on January 28, 1986...

Space disasters still have lessons to teach

http://www.msnbc.msn.com/id/41279886/ns/technology_and_science-space/


The Apollo fire, on Jan. 27, 1967 , was made possible by a decision to believe that flammability in pressurized pure oxygen couldn’t be that bad, even if no tests had been run to check out that convenient assumption.

The loss of Challenger, on Jan. 28, 1986 , was made possible by the decision that even though flexible O-ring seals had never been verified to function properly at sub-freezing temperatures, it was convenient to assume they would still do so in the absence of tests proving otherwise.

The loss of Columbia, on Feb. 1, 2003, was made possible by the decision — set down in writing — that even though observers suspected that tank debris might have hit the panel-covered leading edge of the shuttle's left wing, those panels were "probably" just as tough as other tile-covered areas that were previously hit. As was the case for the earlier tragedies, this was a claim that had never been tested.

Appallingly, in hindsight, when tests were made, they showed hazards that should never have been "assumed away." Pure oxygen fires were horrifically violent. Flexible pressure seals at low temperatures did not seat properly in their slots when hit by rocket thrust. And a leading-edge panel hit by a flying piece of insulation didn’t just get scratched — it shattered.

Wednesday, January 26, 2011

RCA

Jan 28....I sent the 2.206 and within two days VY admitted another leak.

...Buildings in plume being explosive hazard...was the DG threatened.

...Has the gaseous tritium been accounted for...about 3 curies.?

...How about a hydrogen detonation of the drain pit building or any nearby buildings where hydrogen and oxygen can seep into?

..Entergy's causal evaluation identified deficiencies involving not having satisfied early-1970s non-safety-related construction and housekeeping standards, and weaknesses in the station's erosion/corrosion program.



...The Entergy report identified "(t)he ineffective monitoring and inspection of the leakage control system of the AOG pipe tunnel, i.e., the tunnel floor drain and sump

pump" as the second root cause.


Entergy's RCA:

RC1: Latent Standards and Practices That Were Inadequate

Inadequate housekeeping standards and practices were applied during the construction of the AOG Pipe Tunnel in 1972. Inadequate design and installation standards and practices were applied during the installation of the 2”CNPE-172A line in 1978. These latent issues combined to compromise the leak tight design of the AOG Pipe Tunnel and allow for water containing radio nuclides to leak to the environment.

NRC:
Root Cause No.1: Latent Standards and Practices That Were Inadequate

The Entergy report stated: "Inadequate housekeeping standards and practices were applied during the construction of the AOG pipe tunnel in 1972. Inadequate design and installation standards and practices were applied during the installation of the two-inch drain line CNPE-172A in 1978. These latent issues combined to compromise the leak tight design of the AOG pipe tunnel and allowed for water containing radionuclides to leak to the environment."

The inspectors concluded that the licensee's first root cause was well-supported.

Corrective actions planned were appropriate to the circumstances and included:

1) clearing of obstructions and removal of debris to the extent possible in the AOG pipe tunnel, completed prior to AOG system startup; and, 2) redesign and implement the removal from service (by sealing) of the two-inch drain line CNPE-172A. This action was completed in June 2010. The inspector reviewed Engineering Change(EC) 22659 developed to seal drain line CNPE-172A.

It is interesting...Entergy didn't submit a voluntary LER on it...

Tuesday, January 25, 2011

12 noon today...Hmm, called Dr Irwin of the Vermont Department of Health, their Radiological officer.

He says they are waiting for VY water sample results from the rad waste well. He tells me they are going to be sampling on a daily bases...then Irwin is going to get them and post them on their internet site.

I get from Dr Irwin, I seen your latest 2.206, man you name is all over Vermont Yankee documents. I'd also seen you at a bunch of VY and NRC meetings. I wonder if he remembers me making a jerk out of myself in front of chairman Jazcko last summer in Bratt. We talk a litttle about my history...he seems to be really up on nuclear submarine history.

He says the process pipe from the AOG building to the stack goes right through the area of the rad waste well. The is a lot of rad pipes in that area. You got those sampling tanks near by and they can be hot.

My scenario for a new well, it takes a lot of withdrawing of water, so that you pull far off contamination into the well to be sampled. He thinks it is a brand new leak and he fears it is going to get a lot higher.

Dr Irwin thinks the first negative sample...no tritium...was a legitimate sample. Entergy has a company come in to gather and measure the water radiation, then splits the sample with Vermont...they are the ones who disclose the count level. Then Vermont counts their half on their own. He just doesn't see how that first sample could have been doctored.

Dr Irwin implied, they should have begun excavating...

NRC Decision on Immediate Action of Vermont Yankee

From: "Kim, James"
To: Michael Mulligan
Sent: Tue, January 25, 2011 8:58:14 AM

Subject: VY 2.206 Petition on Shut-Down Vermont Yankee - Decision on Immediate Action

Mr. Mulligan,

With regard to your petition dated January 18, 2011, the Petition review Board (PRB) met on Monday, January 24, 2011, to discuss only the request for immediate action of immediately shutdown Vermont Yankee. The PRB determined that there was no immediate safety concern to the plant or to the public health and safety. The system is non-safety-related and the tritium leak amounted to approximately less than 1 mrem exposure to the public. No drinking water sources were impacted. Therefore, the PRB denied the request to immediately shutdown Vermont Yankee.

Thanks,
James Kim
PRB Manager

Mr. Kim,

The is the problem in a nut shell, I have to have triplicate poor that the plant is unsafe against impossible barriers to the truth, but the NRC and Entergy can use subjective and in the complete absence of any real information that a nuclear plant is safe. There are different standards for insiders and out insiders. It seems the more access to real information that you have at your fingertips, the more subjective and specious your assertions can be. The flip side of it is, the more distant to real information is your privilege, the more triplicate proof and evidence your need to make a case.

Mostly, in the RCA, there is nothing but unproven specious assertions in the characterizations within the RCA.

Again, in a culture of falsifications and a intimidation system to enforce illegal behavior at the employee level, how do we know anything we see with Entergy is true?

I can tell you for a fact, if a plant has a off site radiation event or any core damage in the USA today with NRC language like this, the media and political frenzy would take out the NRC as a credible regulator. That would have serious blow back consequences for the whole nuclear industry and the American public.

Anyways, I really do appreciate the official response...

Added Jan 25, 2011 at 6:51pm

This is what the NRC said on my emergency shutdown of VY: "The system is non-safety-related and the tritium leak amounted to approximately less than 1 mrem exposure to the public."

They could cycle this question to their computer models that estimates dose in a few fractions of a second: "how many curries being pumped into the ground would to take without taking any actions to get a member of the public or employees to exceed the licensing dose limit in the ground below the rad waste building well."

Say there is no well down there, how many curries being pumped into the ground would it take to get a regulated dose to be first exceeded?

I'll bet it would take a mind boggling amount of curies pumped into the ground to get that dose exceeded...that is why the limit is ridiculous.

Jan 26, 2011

It would probably take 10 VY spent fuel pools worth of fuel to get all chopped up in a blender and injected into ground before a member of the public would exceed his NRC regulated dose.

Monday, January 24, 2011

Emergence Shutdown of Vermont Yankee 2.206 prehearing

The NRC called today to set up a meeting with me on this Thursday Jan 27. It will be about the VY Root Cause Analysis. The are going to have the NRC inspectors and inspection RCA report writers at the teleconference. The NRC Section Chief and others will be in the conference.

I am concerned about what are the NRC standards with Root Cause Analyses, both for the NRC and a licensee.

Emergence Shutdown of Vermont Yankee 2.206

I got another message talking about setting up the 10 CFR.2.206. It will occur on Feb 3, 2011 between 9 and 10AM.

Sunday, January 23, 2011

Vt Gov Shumlin a Patsy to Entergy

Nov 1, 2010
Some time before the election Entergy knows the area around the radioactive waste building is independently contaminated and schedules to drill a sampling well after the election. They know the election is a squeaker...they know the bad news would give the elected to Shumlin. Entergy is gaming and spinning information...withholding information hoping to drive a outcome to protect profits.

Nov 2, 2010
Gov Shumlin gets elected.

Nov 7, 2010
My “Advice for Gov Shumlin”:
“Remember Charlie Crist: http://en.wikipedia.org/wiki/Charlie_Crist
He crossed the republicans with his decision on their PSC or PUC...the utilities and their buddies then ripped him to shreds. Many think it was over the Florida new nukes. The got a tea bragger to run against him and withdrew campaign monies. They viciously threw him under the bus.
So yes, there is Pilgrim, Indian Point, Oyster Creek plus Vermont Yankee on the line.
I think the utility and nuclear folks would want to make a example of you...to send a message to all politicians around the NE nuclear plants. It is my judgment these gangs of utility boys are going to weaken and sabotage your administration from the first days of your governorship. These guys, as you know, are extraordinarily powerful.
Matter of fact, I’ll bet you they twist the VY issue in anyway they can think of, in order weaken and destabilize your administration, draw you attention away from the duties of the state helping the middle class an the poor.
They will use any arm of the utility sector to get you in trouble. It is common knowledge the utility sector has veto power over the success of a governorship. I bet you they put the VY issue in newspapers every day...constant drama and turmoil...they will want you consumed by the VY issue and utilities issues.
They are going to do you a Obama... slit your throat...intent to destroy and weaken you from day one.
You are going to be a example to everyone else!”

Nov. some date 2010
The well, which was dug in November, had shown only minimal levels of contaminated water, less than 2,500 picocuries per liter, until Jan. 17, Irwin said. It is located in the vicinity of the radioactive waste building, which was one of the areas investigated when the January 2010 leak was discovered.

How much less than 2,500 picocuries per liter? The Comcast emergency alert tone buzzer should have been going on in the top VY and Entergy offices...they should have gotten a full irritating 5 alarm Comcast tv buzzer blast for an hour.

Anything between 500 and a 1000 pCi/L should indicate a leaking pipe and a emergency...

Nov 18, 2010
Pumping from ground stops ...”Groundwater Extraction Terminated On November 18, Entergy Vermont Yankee officials told the Health Department that the 300,000 gallon objective for groundwater remediation had been met, and groundwater extraction has been terminated. Why didn't Shumlin stop it on Nov 18”...

Dec 3, 2010
Tritium in a drinking well near the COB building... “More Tritium Contamination Detected in Deeper Groundwater Monitoring Wells
Vermont Yankee notified the Health Department late afternoon on Dec. 3 about high concentrations of tritium detected in samples taken Nov. 29 from two of its nine newest groundwater monitoring wells. Both are deeper wells, about 60 feet below ground level and just above bedrock:GZ-12D, located near the Containment Access Building (CAB), measured tritium concentration at 65,000 picocuries per liter (pCi/L) GZ-22D, located near the Construction Office Building (COB), measured tritium concentration of 500,000 pCi/L

Dec 6, 2010
...the only sample from well GZ-24S that was provided by Vermont Yankee to the Department of Health Laboratory for analysis tested at less than the lower limit of detection (LLD).

Dec 7, 2010 Gov Elect Shumlin demands Entergy resume pumping tritium from the aquifer.

Dec 17, 2010
Gov elect Shumlin visits the Vermont Yankee site and gets a detailed briefing about the tritium issue from VY and Entergy experts.

Dec. middle something 2010
Sheehan said Vermont Yankee has conducted several tests from the well, showing increasing levels of tritium. In December, the well showed 2,400 picocuries per liter, he said. At least two more tests were done this past Monday and Thursday, reaching 9,200 picocuries, he said.”

Dec 17, 2010
Gov Elect Shumlin request and gets Entergy to resume pumping tritium from the aquifer.

Late Dec 2010
Said by the VDOH on Jan 21: “According to information provided to the Department of Health today by Entergy Vermont Yankee, the concentration of tritium in GZ-24S has been trending upward since late December” At that time, a sample taken from well GZ-24S tested at a concentration of approximately 2,500 picocuries per liter (pCi/L).

The VY Root Cause Analysis Page 3 –declares their AOG leak started off at “705 pCi/L; This was slightly higher than Teledyne Brown’s minimum detectable activity of ~230 pCi/L” then ramped up to 17,000. 1000 pCi/L should have been confirmation that a leak is right here.

Dec 28, 2010
Disclosed in the media on Jan 29 2011: "So therefore the samples were unable to be analyzed until January 11 of 2011 when the machine was repaired. So that accounts for the delay in reporting that."
The radiological analyzing device or counter was found to be broken around this date that measures tritium.

Jan 6, 2011
Peter Shumlin was sworn in as Governor of Vermont.

Jan 6, 2011
mike mulligan wrote (Jan 6 message 10):

“I just see it as Entergy throwing a slow pitch at gov Shumlin...giving the gov a opportunity to hit the ball out of the park. Are they already in cahoots? Entergy is signaling to Shumlin...play our ball, and you can expect to hit a lot of home runs.”

(This is about the whole deal of stopping the pumping, then a letter from Shumlin demanding a restart of pump, then Shumlin prancing around the plant on a tour and a full and comprehensive brief on conditions.)

Jan 11, 2011
Disclosed in the media on Jan 29, 2010; "So therefore the samples were unable to be analyzed until January 11 of 2011 when the machine was repaired. So that accounts for the delay in reporting that."
The radiological analyzing or counter was made to be fixed on this date that measures tritium.

Jan 11-14 2011
Lawyers, consultants wrangle over ‘root cause’ of Yankee leaks
In the hearings, lawyers for the New England Coalition, the Conservation Law Foundation, Vermont’s Agency of Natural Resources, and Vermont’s Department of Public Service cross-examined Entergy experts about written testimony they had submitted regarding the leaks, their causes, what was released, and what is being done to prevent future leaks.
The “root cause” of the leaks was the most contentious issue.
Margolis asked Trask if identifying holes in the pipes as a “contributing cause” meant that Entergy’s root cause analysis did not need to evaluate whether similar plant pipes were developing holes. Trask replied that Entergy is “already constantly looking for where that is occurring in the plant.”
CLF:
"Do you know if there's any percentage that remain uninspected or untested?" asked John Burke of the Public Service Board.
"I can't give you the specific percentage," answered Timothy Travis of Entergy Nuclear.
"Can you give me a ballpark as to what percentage may remain uninspected or untested?" Burke asked.
"I guess I'd like to answer that in-- no, I cannot. However-- need to look at what the definition of what 'inspected' is," Travis answered.
"The question was asked a few times-- have you done a root cause evaluation of the actual cause of the leaks in the pipes? And they haven't. And that's really what we're asking about-- shouldn't you be asking about where else this is occurring around the plant? Shouldn't you be inspecting the pipes to make sure other pipes aren't leaking?" said Jared Margolis of the New England Coalition.
"We're looking at buried and underground piping, we're monitoring and using the latest technology, whether it's guide wave technology, whether it's visual inspection of piping, whether it's looking at increased barriers-- we're looking at more ways to identify piping," said Larry Smith of Entergy.

Jan 17, 2011
Said Jan 22, 2010 by Reformer...“The well, which was dug in November, had shown only minimal levels of contaminated water, less than 2,500 picocuries per liter, until Jan. 17”

Jan 18, 2011
Sent my petition to the NRC: “Subject: 10 C.F.R. § 2.206 Emergency shutdown of Vermont Yankee and requesting a NRC OIG investigation of the NRC behavior surrounding inspecting activities associated with the AOG piping tritium leak and its Vermont Yankee Root Cause Analysis. Entergy and the NRC gamed the RCA and inspection activates in order to try to influence the 2010 election of the Governor of Vermont...with their intent to save the life of Vermont Yankee no matter what it took.”

Jan 20, 2011
A sample from that well taken January 20, 2011, had a concentration of about 9,000 pCi/L...

Jan 21, 2011 (Friday12:03:18pm)
From: Michael Mulligan steamshovel2002@yahoo.com
My back door channel to Entergy?
Sent: Fri, January 21, 2011 "12:03:18". “Organizational Control of Investigation Methods”...I don’t see any evidence that AOG tunnel was ever a radioactive designed and engineered barrier. If it wasn’t engineered, designed and maintained to be a rad barrier...how could it be the number one causal factor in the uncontrolled release of radioactive to the environment?
Like where did the activated hydrogen (tritium) gas go too, that is a major function of the AOG system to combine the gas into water. The leak occurred before the recombiners. What if we assume all of it, and the other gaseous and particulate activity, and whatever else went through weep hole, then escaped from the butler building.

Jan 20, 2011
From the VDOH page wrtten on late Jan 21, you see how fast they can get a sample..."A sample from that well taken January 20, 2011, had a concentration of about 9,000 pCi/L. Jan 21 2011."

Jan 21, 2011
Multiple Media outlets came out late Friday afternoon informing us of new leak.

Jan 21, 2011
Disclosed on Jan 29 Rutland Herald by Susan Smallheer...Vermont's rad officer admitted he discovered on Dec 21 he discovered the tritium detector broken from Dec 28, 2010 to Jan 11, 2011.


January 21, 2011
Investigation Update (Came out late Friday!)
The Department of Health was notified this morning by Entergy Vermont Yankee officials that a sample taken from groundwater monitoring well GZ-24S has been confirmed as being contaminated with tritium.
Groundwater monitoring well GZ-24S is a newer well completed and first sampled last November. GZ-24S is located 150-200 feet north of the bulk of the plume released from the Advanced Off-Gas (AOG) Building. ( Map )
The source of this tritium contamination is not yet known. Entergy Vermont Yankee is investigating possible sources of any new leaks, including four drain lines from the reactor and turbine building ventilation system, and one drain line from the AOG Building. Plant officials are also investigating whether other plant structures might serve as "conduits" of tritium contaminated water away from the estimated AOG plume area.
According to information provided to the Department of Health today by Entergy Vermont Yankee, the concentration of tritium in GZ-24S has been trending upward since late December. At that time, a sample taken from well GZ-24S tested at a concentration of approximately 2,500 picocuries per liter (pCi/L). A sample from that well taken January 20, 2011, had a concentration of about 9,000 pCi/L. On December 6, 2010, the only sample from well GZ-24S that was provided by Vermont Yankee to the Department of Health Laboratory for analysis tested at less than the lower limit of detection (LLD).
Entergy Vermont Yankee officials report that its on-site laboratory has not detected tritium above the LLD at groundwater monitoring wells near GZ-24S. However, a sample from well GZ-6 independently analyzed by the Department of Health Laboratory as well as by Entergy Vermont Yankee’s contract laboratory has tested for tritium slightly above the LLD. ( Health Department Lab Analyses )
Entergy Vermont Yankee is now sampling well GZ-24S daily. The Department of Health has requested split samples of GZ-24S to be provided weekly for analysis.

Jan 22, 2011
Most Vermont newspapers carried follow-ups concerning Jan 21 disclosure of new leak
“Officials investigate possible new leak at Vermont Yankee”
You can’t trust Irwin to correctly warn us of the risk and announce a troubling anomaly...Irwin is the chief minimizer.
“The well, which was dug in November, had shown only minimal levels of contaminated water, less than 2,500 picocuries per liter, until Jan. 17, Irwin said.”

Jan 29, 2011: I will just say 2500 picocuries is way sufficient to declare a rad leak and start spending money on trying to detect and stop it. Irwin should know this.

January 24, 2011
Monday, The NRC called today to set up a meeting with me on this Thursday Jan 27. It will be about the VY Root Cause Analysis. The are going to have the NRC inspectors and inspection RCA report writers at the teleconference. The NRC Section Chief and others will be in the conference.
I am concerned about what are the NRC standards with Root Cause Analyses, both for the NRC and a licensee.
Emergence Shutdown of Vermont Yankee 2.206
I got another message talking about setting up the 10 CFR.2.206. It will occur on Feb 3, 2011 between 9 and 10AM.

January 25, 2011
Tuesday, 12 noon today...Hmm, called Dr Irwin of the Vermont Department of Health, their Radiological officer.
He says they are waiting for VY water sample results from the rad waste well. He tells me they are going to be sampling on a daily bases...then Irwin is going to get them and post them on their internet site.
I get from Dr Irwin, I seen your latest 2.206, man you name is all over Vermont Yankee documents. I'd also seen you at a bunch of VY and NRC meetings. I wonder if he remembers me making a jerk out of myself in front of chairman Jazcko last summer in Bratt. We talk a litttle about my history...he seems to be really up on nuclear submarine history.
He says the process pipe from the AOG building to the stack goes right through the area of the rad waste well. The is a lot of rad pipes in that area. You got those sampling tanks near by and they can be hot.
My scenario for a new well, it takes a lot of withdrawing of water, so that you pull far off contamination into the well to be sampled. He thinks it is a brand new leak and he fears it is going to get a lot higher.
Dr Irwin thinks the first negative sample...no tritium...was a legitimate sample. Entergy has a company come in to gather and measure the water radiation, then splits the sample with Vermont...they are the ones who disclose the count level. Then Vermont counts their half on their own. He just doesn't see how that first sample could have been doctored.
Dr Irwin implied, they should have begun excavating...

January 27, 2011
Washington Snow Storm  I would be surprised if the NRC could keep their date with me for our teleconference with the DC snow.
....rescheduled for tomorrow at 1pm
4:00pm: Fascinating isn't it...The Space Shuttle Challenger disaster occurred on January 28, 1986...

Jan 27, 2011
Disclosed Rutland Herald Susan Smallheer Jan 29
Sheehan said, noting Entergy held a conference call Thursday (Jan 27) with NRC officials to go over their investigation into the possible new underground leak.

Jan 28, 2011
Right off the bat I thought it was rude of them not saying anything about the RCA inspector not being available for my questioning. I thought they would make a simple excuse, sorry the RCA inspection writer can't be here because they are stuck in a snow bank. Do these people think I am that stupid?
I pick up right away this was a ceremonial meeting...this meeting was a show meeting for talking about it in the 2.206. I could tell they both were all hyped up and something was going on behind the scenes....they were defensive and evasive as heck.
Well, if they want to play that game, then I am spending a lot of time lecturing them both. I talk big time about the Challenger explosion, I tell them what I think is behind all of these institutional accidents, the accident initiates from a language problem. People start using weaselly words and phrases, they get away with it, then everyone does it. In a wide spread manner people default into a inaccurate language...basically the definition of words and concepts lose their definitions. Everyone goes by their own definition of a word or phrase...the game becomes evasion and not truth telling. I told them, there has been nothing going on here but evasion with you two.
Further I said, as in engineering ethics you own me the whole truth on what is going on here. Do you throw out the code of engineering ethics when you become a government official? That is when they closed the meeting and hung up the phone. They were polite though.
It just irks the heck out of me, I am thinking about Egypt here, they are using the NRC codes and regulations to be evasive and give a small proportion of the truth to me. I just think that is degusting, a federal official can use the tools of government to be dishonest to members of the public. It is so offensive to democracy.
The meeting started at 1PM and ended promptly at 1:30.
The dance with the snow and cancelling the meeting yesterday looks suspicious to me.
Another Well At Yankee Contaminated With Tritium
Friday, 01/28/11 12:04pm
Do you think this was really true?

Jan 29, 2011
VY continues to look for source of tritium
By BOB AUDETTE / Reformer Staff
BRATTLEBORO -- Technicians are still looking for the source of tritiated water that was discovered in a well about 150 feet north of a plume of contaminated groundwater that originated in Vermont Yankee's advanced off gas system.
That leak was discovered Jan. 10, 2010, and stopped later in March.
Last week, Yankee revealed a groundwater monitoring well, GZ-24S, had tested positive for tritium at a level of 9,200 picocuries per liter, which is more than 20,000 picocuries lower than the reporting level required by the Nuclear Regulatory Commission. The Environmental Protection Agency's limit for tritium in drinking water is 20,000 picocuries.
No deep wells, the source of drinking water in the area around Yankee, have shown detectable levels of tritium.
In a sample taken on Jan. 26, 1,024 picocuries per liter were discovered in a well, GZ-6, which is near GZ-24S.
On Jan. 26, a sample from GZ-24S showed a drop in tritium levels to 8,139 picocuries per liter...
Vermont Yankee reports tritium in new well near last week's
By Terri Hallenbeck, Free Press Staff Writer • Saturday, January 29, 2011
"Vermont Yankee officials had reported no elevated levels of tritium in GZ-6 last week, but an independently analyzed sample by the state Health Department tested slightly above the lowest limit of detection. Smith said Vermont Yankee's tests found slightly elevated levels for the first time this week."
Rutland Herald Susan Smallheer Jan 29
Irwin said the failure of the test equipment was disturbing.
They told me about the liquid scintillation counter being down and that was the cause of the delay. Irwin said, I figured like most labs, they would get the instrument repaired relatively quickly but for some reason that did not the case.
Irwin said that he only found out about the equipment failure last Friday (Feb 21), when he asked why the test results form the first well were so late.
Sheehan said, noting Entergy held a conference call Thursday (Jan 27) with NRC officials to go over their investigation into the possible new underground leak.

Jan 30, 2011

2.206 liquid scintillation counter evacuation delay
I request a immediate emergency shutdown of Vermont Yankee because of the unreliability of their radiological and emergency plans for a indeterminate amount time. The liquid scintillation counter was broken between Dec 29, 2010 and Jan 11, 2011. That makes the radiological procedures inoperative or severely degraded in this time frame. Not having a backup liquid scintillation counter would make the emergency evacuation plans unreliable. If a nuclear power plant doesn’t have the capability to make reliable their evacuation plans, then they shouldn’t be licensed to operate a nuclear plant.
1) I request a NRC OIG and congressional investigation with why the NRC didn’t immediately notify the community that the Vermont Yankee radiological procedures and evacuation plans were not functional during these dates.
2) Request a investigation, in making sure that all radiological capabilities at the nuclear plants are reliable and durable with sufficient back ups in order to be able to carry out their emergency plans. Request all USA plants have sufficient back up liquid scintillation counter capabilities.
3) Request a information notice to given to all plants about this.
4) Request a disclosure of all delays with getting any radiological measurements that effected any normal or emergency requirement

Feb 2, 2011
Gov. Peter Shumlin calls for Vermont Yankee Reliability Oversight Committee, citing tritium leaks
MONTPELIER – Gov. Peter Shumlin, citing the on-going discovery of tritium leaks at the plant, instructed the Vermont Department of Public Service to appoint a Vermont Yankee Reliability Oversight Committee.
“I've asked the Department of Public Service to organize a Reliability Oversight Committee to provide, in these coming critical months, additional expertise on oversight of Vermont Yankee issues within the state's jurisdiction,” Gov. Shumlin said. “I am deeply concerned with Vermont Yankee’s lack of transparency about serious problems that continue to be discovered around the plant.”
Shumlin continued, “I learned two weeks ago about another well with a tritium hit, and this one is not near the plume we already knew about, but 150 feet away. Then, last Friday, I was told that yet another well had a tritium hit. Vermont Yankee had the samples pulled that showed the new tritium hits, but didn't test those samples for a few weeks because a piece of equipment was broken.”

Feb 3, 2011
"All of a sudden I hear a click, I hear the snippet "and have a little fun", then I hear the talking of all the NRC officials, then the "welcome to this 2.206 petition...". All the background chatter of the officials stops...then we are off to the races with the 2.206 processes. From this point on everything is recorded in the NRC ops center and it is transcribed for addition into the public record...
...The chairman of the petition board pops up on the phone connections explaining, "I was introducing a new NRC official to the petition board and I was telling her to have a little fun as she participates and listens to your review board" concerning tritium and root cause analyze issues at Vermont Yankee."

Saturday, January 22, 2011

The quintessential mike mulligan

It is quintessential mike mulligan...everyone and especially me has had to learn to deal with this for twenty years.

Jan 19, 2011 People who crave risk...the risk takers...they tend to be way better at ESP than everyone else.

Officials investigate possible new leak at Vermont Yankee

By JOSH STILTS / Reformer Staff Saturday January 22, 2011

The well, which was dug in November, had shown only minimal levels of contaminated water, less than 2,500 picocuries per liter, until Jan. 17, Irwin said.

Tuesday, January 18, 2011

Subject: 10 C.F.R. § 2.206 Emergency shutdown of Vermont Yankee
Jan 18, 2011

R. William Borchardt
Executive Director for Operations
US Nuclear Regulatory Commission
Washington, DC 20555-0001

added Jan 22, 2011@5:22 pm

OK....

It just looks like what you said NSD...

It is really about panic and desperation...Entergy lawyers fears another charge of giving false testimony to the state of Vermont. That is why it came out Friday...it is a attempt to limit legal risk.

Chop, chop...you got to charge Entergy with giving false testimony in a Vermont state proceeding...Make Vermont's Attorney General Sorrow investigate this.

I gave you the gun flash and then the smoking gun...

Thursday, January 20, 2011

BP's and API's INPO

Institute of Nuclear Power Operation(INPO)
American Petroleum Institute(API)

It is just more anti government hatred....it discloses how dysfunctional our politics is.

You guys are scientist, where is the evidence that INPO works? Like where is the open peer review process where it is opened to a professional and public criticism process. Personally I don't believe outside of this group the nuclear scientific professionals believe in science...the belief of transparency and the art of professional democratic peer reviewed criticism. It is your scientific duty to act in all of our interest. In the eyes of the wide spread view of the public...they don't trust the science and the snake oil scientist of the nuclear industry.

I could make a case inpo makes the possibility of the industry's continued existence...but doesn't create enough public credibility to build any new plants. We know INPO serves the interest of the CEO's of the industry...but does INPO serve my and the public interest.

I mean, the INPO model is a recipe for stagnation of the oil drilling industry for 50 years.

Like, why did INPO fail in the 2010 HB Robinson year, in all of the INPO's soul searching of Davis Besse? Why did INPO fail in the tritium leakage issues national wide, and especially at Vermont Yankee. VY should have had no problems with relicencing, is it a one off? I give you another one, why is INPO failing on safety relatedness and what we think of risk. The nothing ever matters philosophy...it that what we think of science and our scientist?

Does science inform us that there are certain human behaviors of ours that must be placed under control...or does science say we can get away with anything we can get away with?

I could make the case the nuclear industry screw ups became apparent, it gained anti nuclear traction...this created the possibility of operation advancement of the nuclear industry. Basically the fear the public would not support nuclear activities and their rendition of scientific truths.

Theoretically INPO could work...but they don't understand what gets a change in human behavior and what kind of medicine it takes to act in all of our interest.

Tuesday, January 18, 2011

Subject: 10 C.F.R. § 2.206 Emergency shutdown of Vermont Yankee

Jan 18, 2011

R. William Borchardt
Executive Director for Operations
US Nuclear Regulatory Commission
Washington, DC 20555-0001

Subject: 10 C.F.R. § 2.206 Emergency shutdown of Vermont Yankee and requesting a NRC OIG investigation with the NRC behavior surrounding inspecting activities associated with the AOG piping tritium leak and its Vermont Yankee Root Cause Analysis. Entergy and the NRC gamed the RCA and inspection activities in order to try to influence the 2010 election of the Governor of Vermont...with their intent to save the life of Vermont Yankee no matter what it took.

Dear Mr. Borchardt,

§ 50.9 Completeness and accuracy of information.
(a) Information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects.

(b) Each applicant or licensee shall notify the Commission of information identified by the applicant or licensee as having for the regulated activity a significant implication for public health and safety or common defense and security. An applicant or licensee violates this paragraph only if the applicant or licensee fails to notify the Commission of information that the applicant or licensee has identified as having a significant implication for public health and safety or common defense and security. Notification shall be provided to the Administrator of the appropriate Regional Office within two working days of identifying the information. This requirement is not applicable to information which is already required to be provided to the Commission by other reporting or updating requirements.

[52 FR 49372, Dec. 31, 1987]

I like them words: “An applicant or licensee violates this paragraph only if the applicant or licensee fails to notify the Commission of information that the applicant or licensee has identified as having a significant implication for public health and safety or common defense and security.” So if it is not a significant implication for public health and safety, it is OK to give incomplete information to the agency and the public, that may impact the continued operation of the plant.

ROOT CAUSE EVALUATIN REPORT CR-VTY-2010-00069 dated 06/16/2010

The below Root Cause evaluation is just a falsification. I don’t see any evidence through Entergy documents, NSA and the NRC inspection reports...FSAR and licensing bases...that the AOG tunnel was a initial plant design barrier against the leakage of radioactivity into the environment. It is designed to be a leak off warning and drain water from the saturated outside soils into the piping. If it not a engineered and designated radioactive barrier, then it can’t be a root cause of the leak.

Root Causes:

RC1: Latent Standards and Practices That Were Inadequate
Inadequate housekeeping standards and practices were applied during the construction of the AOG Pipe Tunnel in 1972. Inadequate design and installation standards and practices were applied during the installation of the 2”CNPE-172A line in 1978. These latent issues combined to compromise the leak tight design of the AOG Pipe Tunnel and allow for water containing radio nuclides to leak to the environment.

Although a leak of a tritiated system was required to complete the event, the team concluded that the original design of the tunnel would have been able to adequately contain and process a leak from within the tunnel. It was only after modifications to the tunnel and poor housekeeping during construction, that the water was able to leak from the Pipe Tunnel to ground.

The poor leaking interfaces and the brick replacement of the poured cement encasement indicated in the 1970’s timeframe the tunnel was not a designated radioactive barrier. The poured cement encasement of the piping was just a cheap construction technique for the general environmental protection of the piping. The intent of the encasement and the drain leak off was to protect the carbon piping from standing water. They feared the ground becoming saturated through storms and the water leaking into the tunnel...with the carbon pipe sitting in the water for extended periods of time. One must remember the times of severe fuel failure problems and high AOG piping radioactivity...this was no designed radioactive barrier.

Pg 15-Interface Between The AOG Pipe Tunnel And The Concrete-Encased, 2-Inch Condensate Drain Line, 2”-CNPE-172A, Not Watertight:

A modification was performed to the AOG pipe tunnel in 1978 per Plant Alteration Request (PAR) 78-36., which installed 2”CNPE-172A to AOG, and did not ensure the AOG Pipe Tunnel remained watertight. To implement this modification, workers in 1978 excavated down approximately 18 feet and penetrated the side of the AOG pipe tunnel to gain access to 12”-AOG-100. After the new drain line (2”CNPE-172A) was added, it was surrounded by 4” PVC and encased in concrete. The PVC was cut in half lengthwise to aid in the installation and concrete was poured over the PVC assembly for the encasement. The intent of the PVC was to provide room between pipe and concrete for thermal expansion during heat up and cool down. Furthermore, the 2”CNPE-172A encasement did not form a watertight interface with either the AOG pipe tunnel or with the AOG Drain Pit. These interfaces were not keyed, grouted, or sealed, so the interfaces were not leak tight. Once the water rose as a result of the floor drain obstruction, it was able to communicate to the environment through gaps in the concrete encasement. When the AOG Pipe Tunnel wall was restored in 1978, masonry blocks were used instead of restoring it with poured concrete as the original design had been.

We know with the below there are really two possibilities with how the debris and soil came to obstruct the drain. It could of either came from the 1970’s construction debris like Entergy claimed, or it could have came in from the outside dirt as the water leaked into the tunnel from saturated soil, from storms and snow melt off. It is atrocious these two possibilities was not discussed by the NRC or Entergy. It gives rise to the idea they engineered the RCA to an out come...they picked and chose the facts that fitted into a preconceived political and public objective before the RCA was even began.

Pg-15-Obstruction of the AOG Pipe Tunnel Floor Drain:

Because the AOG Pipe Tunnel was inaccessible, it has not been accessed since original construction in 1972 (with the exception of the field modification to install 2”-CNPE-172A in 1978). Therefore, the debris is considered to be original construction debris left in the tunnel since 1972.

Chief Engineer of Boiling Water Reactors for Entergy Timothy Trask

http://www.reformer.com/localnews/ci_17115617

....high-ranking engineer for Entergy, which owns and operates Vermont Yankee, said that leaks from two pipes were merely a "contributing cause."

Timothy Trask, chief engineer of boiling water reactors for Entergy, said the reason the Root Cause Analysis wasn’t focused on the leaking pipes was because the problem statement was a leak to the environment.

"The concrete barrier in the Advanced Off-Gas pipe tunnel was flawed and had a hole two to three inches in diameter, which allowed the water to leak into the surrounding soil," Trask told the Reformer. "If there was no hole in the concrete tunnel, the tritiated water leaking from the AOG pipes would have flowed into the plant’s drainage system and would have never entered the environment."

He said although the pipes that leaked had not been inspected for at least a decade prior to the leaks being found, an improved inspection program had been put in place.

http://www.bloomberg.com/news/2011-01-12/vermont-regulators-hear-about-nuclear-leaks.html

Trask maintained that the leaking pipes were merely a "contributing cause" of tritium — a radioactive isotope of hydrogen that is a carcinogen when ingested in high amounts — reaching test wells on the Vermont Yankee plant. But he said they were not the most important, or "root cause," of radioactive water reaching the environment. That was a gap in the wall of the concrete underground enclosure where the pipes were located, he said.

Entergy/Vermont Yankee Maintenance Work Manager.

Laurence is a 26 year employee of Vermont Yankee and he was a long time licensed operator.

“Mike, I got 26 years in Vermont Yankee and it doesn’t matter what happens to the plant.” (He is getting a pension)

“We all knew that damn AOG tunnel was leaking for years.”

Real Root Cause(s)

1) The Vermont Yankee knew there was a leaking water anomaly in the AOG tunnel...the AOG piping had a hole in it and higher management prevented them from confronting the problem and fixing it.

2) The AOG tunnel and piping system wasn’t engineered, designed and constructed to contain radioactivity.

3) The safety culture of the plant is impaired because of information inaccuracies and wide spread acceptance of falsifications.

Questions

Was the water leak from the AOG piping larger than the drain hole...?

Request:

1) I request Vermont Yankee to be immediately be shut down and that Entergy be prohibited from owning nuclear power plants... because Entergy doesn’t have the integrity to tell the truth about safety and nuclear power plant issues. Money and profits comes before truth telling and full disclosures.

2) Request an extent of conditions with Entergy providing the NRC with inaccurate information, false and incomplete documents and any falsifications to the NRC. I can give you three other inaccurate and false Entergy documents from three different plants other than VY....LERs.

3) Request the NRC look into if Entergy gave new false testimony to any proceeding with the state of Vermont.

4) Request an OIG investigation concerning recent falsified and incomplete NRC inspections...specifically how come the NRC didn’t nail down in inspection reports the design bases, licensing bases, the UFSAR basis and the engineering characterization of the so called radioactive containment system of the AOG piping.

5) Request a extent of conditions with any falsified and incomplete licensing bases, UFSAR or any plant engineering and plant designs that protect the pubic and environment of the people surrounding Vermont Yankee. Request a extent of conditions with this on any other Entergy nuclear plant and at any other plant in the USA. Does Vermont Yankee need a licensing bases reconstruction program?

6) Request a national formal NRC code and regulations on Root Cause Analyses and the quality of RCA...

7) Request to have a discussion with the top NRC official in charge, or the most knowledgeable, with of Root Cause Analysis before the 2.206 pre hearing.

8) You know their corrective action program are keyed off the RCA or RCE...so their corrective actions program is corrupted and they don’t address why the tritium leak occurred.

9) I request the NRC be prohibited from ever using the term...it is before the ROP overhaul and it is of no concern of the NRC....there is no bases at all for that NRC statement other than it is political and they are just plain lazy.

10) If it come down to a OIG involvement, it should be noted that time is a precious commodity. A shutdown is but a year away at the most, there is now significant state issues with this and it should be a unusually open NRC OIG process...mostly the investigation should be accurate, swift and open.



Sincerely,



Mike Mulligan
Hinsdale, NH 03451
1-603-336-8320
steamshovel2002@yahoo.com