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