Brown's Ferry and TVA

Update:
April 4 public meeting...they got me on the phone bridge.

"Review of MOVAT testing data, combined with stellite aging research, strongly indicates that the disc separated prior to November 2008"

If you agree with TVA on this, the valve testing program for critical safety valves is ineffective. It missed a clear indication of a valve disc seperation over this, the NRC and TVA should have done a investigation on is movat a effective safety program....it looks totally dysfunctional to me according to the TVA’s own words. It should be a NRC violation.

Why hasn't anyone talked about fixing movats?

Like I said, there is micro difference in diameter of the disc and the seat, noise of the electrical lines suppling the valve motor, that would give you movat noise seen on the recording. You can only tell by looking at a bunch of movat testing recordings, whether these bumps are the real deal or noise. Did TVA just choose the pretty data?

Was the movat equipment calibrated properly...

Though, I just don’t find much certainty evidence that the disc would have unseated...all I see is the gunslinger pro nuclear industry engineering firms doing TVA’s bidding for money...

So let me get this straight, according to the NRC pilgrim’s inspection report 2011-008 dated from February 14 through March 4,2011, the HPCI diaphragm event happened before July 2010, why still no LER? Basically there is the same kind of issues with the delay of the reliefs valves thread LER with on two Vermont Yankee petitions on Entergy.

The Brown Ferry identical LER 2009-004 says the event date is 07 24 2009, the NRC says they made the document on sept 2009...why is Entergy having so much problems with pushing out LERs? The BF inspection report 2009-005 came out between October 1, 2009 through December 31, 2009

Just to be clear, the NRC drums out their inspection report on TVA in 3 months...while Pilgrim’s inspection takes 7 mouths, and they still don’t have the LER out...

It is just hit and miss and completely erratic with NRC inspection reports and utilities LERs ...

It just fascinating, so on the VY HPCI steam line leak and gasket issues on LER 2011-001...the event occurs on around Feb 17, 2011, Entergy pumps the LER out on April 14 (good as far a timeliness))....basically a petition maker forces the NRC to do a inspection on the gasket problem and the LER. It is object insanity! Now it seems the inspection report is mon
ths away...

...April 10..."By the way, I think Browns Ferry is the most dangerous plant it the nation and they have a culture of falsification of documents to the government. Check out their LER falsification. Matter of fact, you got a wide spread culture of falsification throughout the nuclear industry as outlined narrowly in the NRC OIG investigation on LERs and part 21..."

Mike Mulligan

Hinsdale, NH

From: "Lewis, Shani"

To: "steamshovel2002@yahoo.co m"

Sent: Wednesday, April 27, 2011 8:12 AM

Subject: Your Concerns Regarding Browns Ferry

Mr. Mulligan,

This is to acknowledge our receipt of your e-mail dated April 10, 2011. We will respond specifically to the concerns you raised regarding the Browns Ferry Nuclear Plant but first we need to verify that we can communicate with you via this e-mail address. Please reply to this email or call me at the number listed below to advise us of your preference going forward.

My name is Shani Lewis, Allegation Coordinator. You can contact me by calling 1-800-577-8510, extension 4461 or communicate with me via e-mail, Shani.Lewis@nrc.gov. Please also be advised that we cannot protect the information during transmission on the Internet and there is the possibility that someone else could read your and our responses while it is transmission.

Shani A. Lewis
Allegation Coordinator
U.S. Nuclear Regulatory Commission, Region II
404-997-4461

From: Michael Mulligan
To: "Lewis, Shani"
Sent: Thursday, April 28, 2011 1:14 PM
Subject: Re: Your Concerns Regarding Browns Ferry

Ms. Lewis,
Inspection Report 2009005
I see many more safety processes being in similar straits....identification, RCA and corrective action problems...

.....PG 19 In September, 2008, the inspectors presented a concern to the licensee that approximately 17 Cause Determination Evaluations (CDE) had exceeded the licensee’s Maintenance Rule (MR) program completion guidelines, and the licensee initiated PER 152007 to address this potential adverse trend. But in April 2009, the licensee identified additional late CDEs and initiated PER 169954 which required an effectiveness review in six months. In those six months, the inspectors and the licensee identified approximately 20 more CDEs that were untimely or past due. Inspectors discussed this potential adverse trend with the licensee who entered the issue into their CAP as PER 210091.

What you can say about LER 2009-004, is all the hand holding the NRC had to do to get to them to get them to submit a LER and be it accurate. One wonders all the missed LERs that wasn’t submitted that the NRC didn’t have time to catch.

This is the crazy talk of the NRC I was talking about “was not repetitive or willful”, but in this inspection report there are two issues with failure to submit a LER

“However, because this violation was of very low safety significance, was not repetitive or willful, and was entered into the licensee’s CAP as PERs 177206 and 204364, the NRC has characterized the significance of this reporting violation as a Severity Level IV NCV in accordance with Section IV.A.3 and Supplement I of the NRC Enforcement Policy.”

I read a lot of issues with the Watts Bar....with the TVA habitually not filling timely responses and documentation. I believe it is systemic within TVA...

Don’t forget in the lead up to the RCA valve injection valve failure, you had a disgraceful event with a bowed RHR rotor and its subsequent destruction within days of the RHR injection valves. You had three safety relief valves technically inop that would have caused you shutdown if you could have seen it. I am saying the equipment failures indicate the plant carries a lot more level of risk to the community that what you risk analyses shows. Can you imagine a accident with all these defects showing up instantaneously in one accident.

Inspection Report 2010-005

NPG-SPP-02.8 was adequate to meet the purpose and objectives of the ITR program. The inspectors also reviewed the two most recent Integrated Trend (IT) reports. The licensee had identified certain departments that did not submit their reports on time which contributed to the site report being issued after its required due date. The inspectors noted that SRs were written for each occurrence. The inspectors also noted that the new procedures improved the consistency of trend discussions and the report format across departments.

...PER 213116 was generated to address the licensee’s actions to address an inspector identified trend, concerning the adequacy of post maintenance testing (PMT), which has been previously documented in multiple inspection reports, but is yet to be adequately addressed by the corrective action program.

...The inspectors identified a potential adverse trend regarding inaccuracy and incomplete information contained in LERs. During the review of LERs from 2009 through 2010, inspectors identified seven examples where LERs contained inaccurate statements, incomplete descriptions and details, and other technical and editorial errors. The licensee had previously initiated the following PERs to resolve the issues identified by the inspectors: PERs 215479, 205308, 201410, and 163176. Additionally, as documented in report Section 4OA3.1 below, the inspectors identified two violations associated with inadequate and incomplete information in Unit 3 LER 2009-003. The licensee initiated SR 314177 to address this apparent adverse trend.

Over the past operating cycle, Units 2 and 3 have developed a large number of control rod Rod Position Indication System (RPIS) component problems. Unit 2 had outstanding WO’s on about 25 different control rods with RPIS related problems, and Unit 3 had about 15 control rods with WO’s. These problems involved incorrect back lighting, intermittent drift alarms, and primarily inaccurate rod position indication at one or more positions. The licensee initiated SRs 313460 and 313465 to address this adverse trend.

What can be said clearly from the LER crazy talk in 2009 “was not repetitive or willful” with two LERs, then the proliferation of LER problems in 2010-005...you might have covered it, but the agency’s ROP is not effective with changing a plant’s behavior.

I am just saying the NRC might be somewhat good on describing the pieces of the puzzle...but you suck a putting the puzzle together and seeing the big picture.

It get you to wondering, is the TVA being shown favoritism because they are they brought back on line BF 1 and working on bringing on other new nuclear plant.

I’d like to see a full scale investigation on the recent history TVA’s LERs and the current status.

As I said, a assortment of safety bureaucracy and processes are dysfunctional leading to preventable failures of safety systems...you got to know there are many defects within the plant not seen and one wonders if all these defects will conspire to come together in a big accident and create shame to our nation.

With the HPCI diaphragms, why did you ding them on not writing a LER accurately, when you should have dinged them with illegally putting in the defective quality safety repair parts.

I remember being at the HB Robinson plant public meeting...where there was serous talk about in the future how safety critical LERs are. They were talking about inaccurate information from Robinson. It is interesting, last spring the NRC came to visit Vermont Yankee about their tritium leak. I got up behind Jazcko chanting "Remember the HB Robison plant"....everyone including the anti's thought I was nuts. I was talking about the terrible Robinson plant accident in March...I didn't think it was over with. Then the plant had two more serous plant accidents and many NRC findings.

Mullanism

This testimony came way before the NRC OIG investigation...you notice how starling close my language was the NRC OIG report about LERs and part 21...

http://steamshovel2002.blogspot.com/2011/04/mulliganism-and-nrc-oig-investigation.html

2.206 transcripts on June 29, 2010 on the Vernon Tie.

(I like my language better because it is more colorful and accurate.)

MR Mulligan: "The new way they do it nowadays is, you have a set of conflicting codes and regulations. You have five or six of them all intertwining and intermingling and very few people can understand, and you have an outcome in mind, and you twist these codes and regulations around until you get the outcome you want.

Nowadays, we play games, we twist around regulations, and we make believe that the regulations, you know, are going to tell us the ultimate truth, if we obey the regulations, it's going to tell us the ultimate truth, and the perfect outcome. If we just follow the rules, there's going to be a perfect outcome."

MR. PICKETT: One more, again, Doug Pickett.

Mr. Mulligan, you were making a number of statements about the codes and regulations are twisted by regulators to get the desired results. Are you aware of any particular regulation or code that is not being met?

MR. MULLIGAN: Well, a code. Well, you see, the problem is I've got a big barrier in front of me, everybody knows that, you know? This is what this is about, is to keep me -- keep a barrier in front of me, and not be able to get the hard questions asked and stuff like that.

You know, I -- you know, one day, you know, I envision a different 2.206 process, where, you know, you are my government, I don't own the government, but I do in a way, but you work for me and stuff, and there's an issue of, you know, I have access to NRC people, we get into a group where there's an assertion like this, and people are on my side, you know.

I don't have these techno barriers, and these legalistic barriers, and these kind of evidence, super-duper evidence barriers and all that sort of stuff that people play games, like, you know, to put a barrier in front of me and stuff like that. I have a thing where a group of people, NRC people, would get together with me before 2.206, we talk about all the different issues, and you would bring up the information, we'd share it freely and stuff like that, and would go into a 2.206 process a lot different way than we do now.

You know, that's how I would make my government work for me. As of now, this process works for the utilities and the NRC. It's designed to be a barrier for me, as far as legalistic stuff, you know, Congress and stuff. So, that's my envision of a government that works for me.

Fukushima meltdown: HPCI and RCIC Rupture Disc?

Update:
By around 2:30 a.m., the pressure inside the vessel that forms a protective bulb around the reactor's core reached twice the level it was designed to withstand. Amid delays and technical difficulties, it was another 12 hours before workers finished releasing radioactive steam from this containment vessel, via reinforced pipes, to the air beyond the reactor building.

About an hour later, the reactor building itself exploded—a blast that Japanese and U.S. regulators have since said spread highly radioactive debris beyond the plant. The explosion, along with others amid overheating at reactors 2, 3 and 4, contributed to radiation levels that led to mandatory evacuations around the plant and the government's admission that the Fukushima Daiichi disaster ranks alongside Chernobyl at the top of the nuclear-disaster scale.

Tepco says pressure in the containment vessel likely hit 840 kilopascals (the metric equivalent of 121.8 pounds per square inch) around 2:30 a.m, roughly double the maximum pressure of 427 kilopascals the vessel was designed to handle.

BURSTING OF HIGH PRESSURE COOLANT INJECTION STEAM LINE RUPTURE DISCS INJURES PLANT PERSONNEL

This is how I came to talk about it...topix.
OK, so I am really talking about a rupture disc...I will corrected the title...

Questions for fukushima building explosions...

It is excessive pressure safety device on the piping between HPCI exhaust and the torus....if the HPCI exhaust piping or torus pressure gets too high, the blow out panel is designed to rupture.

It is beyond interesting with the WSJ saying the Japanese torus and primary containment got to be twice the design pressure...why didn't these blow out panels let go.

The HPCI or RCIC exhaust needs to go under water, to be condensed by the torus cool water, I think comes in from the bottom of the tous.

It would be interesting in the Fukushima plants how these blow out panels functioned.

If they are under water, did the panel rupture and did that lead to prematurely draining the torus.

If above the water line in the torus, did the lowering of the torus water uncover the blow out panel and lead to the leak of hydrogen into secondary containment that distroyed the buildings...

NRC says VY HPCI is obsolete

Message 45 and Feb 22, 2010 on topix

Yep, it was a flexitallic gasket thing...they didn't have the proper replacement gasket on site, so they had to special order if from Texas, and you how long the shipping takes from across the country.

As NRC resident Dave Spindler says, "its a obsolesce thing" with not having adequate and the appropriate safety grade spare parts on site at the plant. The HPCI is obsolete? Dave said its going on at every plant in the nation.

Entergy had to do a engineering equivalency thing, cause they had to manufacture it in Texas, meaning it is not a identical replacement.

By the way, RCIC is not a standby system from HPCI...all of these components are suppose to operational when the fault hits the plant...their design accident.

So as Dave said according to the NRC...it doesn't matter to the NRC if the repair took 13 days or the gasket was replaced immediately within a few hours with a on site spare repair part....the NRC doesn't care if we are fully prepared for a design accident or partially prepared.

Pilgrim: Unsafe repair parts in nuclear industry...

Wednesday, April 13, 2011...Transcipts on 2.206 about VY reliefs concern buna n thread material

“In Browns Ferry at Unit 1, another LER, 2009-004, I can make a comment that there's questions of the, if everything is reported in LERs, but these are just three of a bunch of LERs. Interesting Buna N material defect was without fibers. It was in the HPCI oil control. That was also due to heat.”

Well., I mean to say it was in hydraulic oil....

Wednesday, April 13, 2011...Transcripts on 2.206 about VY reliefs concerning buna n thread material

So for the VY threaded Buna n, I tried to bring in three industry example, o rings, hydraulic diaphragm and air diaphragms as the scram solenoid valves. Browns Ferry was the hydraulic diaphragm issue, and it is identical to the pilgrim...

“In Browns Ferry at Unit 1, another LER, 2009-004, I can make a comment that there's questions of the, if everything is reported in LERs, but these are just three of a bunch of LERs. Interesting Buna N material defect was without fibers. It was in the HPCI oil control. That was also due to heat.”

Well., I mean to say it was in hydraulic oil....

April 15, 2011

PILGRIM NUCLEAR POWER STATION'NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT O5OOO293/201 1OO8

02/14/2011 – 03/04/2011

Findings

(1) Failure to Follow Corrective Action Process for HPCI Diaphragm Degraded Condition Introduction: The NRC identified a finding of very low significance (Green) for Entergy's failure to follow their corrective action process in the identification, documentation, and evaluation of a degraded condition. Specifically, Entergy failed to recognize and capture in their condition report process that a diaphragm in the HPCI system exceeded its service life.

Description: On March 22,2Q10, GE Hitachi issued a Safety Information Communication in conjunction with the 10 Code of Federal Regulations (CFR) Part21

Report titled, "Failure of HPCI Turbine Overspeed Reset Control Valve Diaphragm." The failure of this diaphragm would result in a loss of the HPCI turbine lube and control oil and could ultimately result in a failure of the HPCI system. Entergy identified that a 'like' diaphragm was installed in Pilgrim's HPCI system pressure control valve (PCV-2301-238) and evaluated the 10 CFR Part 21 Report on July 20, 2010 in CR-PNP-2010-2500. Entergy concluded that the manufacturing defect in the diaphragm described in the Part 21 evaluation was not directly applicable to Pilgrim because the report specified a manufacturing year of 1984 or later. Pilgrim's PCV-2301-238 diaphragm was manufactured in 1981, however it was the same design (2-ply fabric-reinforced BUNA-N material) as specified in the Part2l evaluation. Since the diaphragm was installed and could not be completely inspected to verify reinforcing-fiber continuity, Entergy appropriately scheduled the diaphragm to be replaced during the next HPCI maintenance window, as recommended by the manufacture.

Jaczko doesn't honor the dead in the nuclear industry

Added Apr 14: This accident caused a plant trip and was a very serious nuclear accident.

You know, if we had a USA nuclear plant meltdown and our own Fukushima with lots fatalities and abandoned territory...these lying Ayn Rand republic senators and willing democrat accomplices would frame the question so hyper narrowly, and the answer, they would never admit it was a nuclear accident even if the some of the innocent population was forced to be buried in lead caskets.

Even as they were picking up radioactive fuel pellets on plant property, Chairman Jaczko would say the accident began in the non nuclear and non safety related secondary system, and technically it wasn't a nuclear accident and core meltdown.

We are so captured by the power of the media and all our power brokers who control our political system.

I talked about it a little today...what is going on is we are corrupting language and communication. Matter of fact, I lectured the NRC on this point yesterday.

The senate fruit cakes yesterday, and I included the democrats...they repeatedly asked Jaczko how many people were ever killed in the nuclear industry. Some of them, and the democrats to be more honest with their lies, asked how many people were ever killed by radiation in the nuclear industry. Jazcko repeated responded none. He's got degrees in philosophy and physics, he got a doctorate in physics. This guy spent half his life in the best schools.

The correct full answer is, maybe none with radiation, but to honor the dead in the nuclear power industry, the correct answers is four bottom of the barrel pipe fitters and insulation people lost their lives around 1986 in the Surrey Nuclear Plant. The cheapsters let the feedwater pipes erode and a high pressure pipe burst. It must have been a horrific death for these low level employees. Right, the NRC is all highly educated people, and anyone without college degree is throw away garbage and they don't count. This brought broad reforms throughout the secondary and primary systems...it was a nuclear plant event no question.

So this big shot with a philosophy degree and a doctorate in high falutin physics should have been able to frame it in a few sentences. A little humility for the dead and the people at the bottom from the head regulator of the NRC. We had no deaths from direct radiation, but we had four fatalities who died from a nuclear plant accident. This accident caused a plant trip and was a very serious nuclear accident.We are sorry for this and our reforms with measuring pipe wall thickness is a attempt to make up for the deaths of these honorable workers at a nuclear plant. Their deaths constantly remind us of the sacrifices of all the employees in the nuclear industry and it is a beacon for us to always be alert at these sites.

It blatant sickening language corruption right in front of our eyes in a senate hearing. The weasely senators set up the question in a way for PR points for a lily white nuclear industry...knowing the chairman would give a partial or incomplete happy-land and triumphal falsified answer.

Yea, it took a lot of wasted intelligence and a decades of education at the best schools to be able to slickly dance around the deaths of honorable men with suffering families, at a nuclear power plant accident.

NRC Chairmen Jazcko, Adam web search timeout queries

The fixed it at about 9:30 AM this morning on April 11.

This is endemic within the NRC, the cult of self protection...they never disclose what was the problem with Adams web and are they having problems with it. They are exactly like the nuclear power plants...but worst. You know,  you never get a long open discussion with the problems of Adams web. Its the cult of secrecy!


...Dear Chairman Jazcko,

Adam Search: http://wba.nrc.gov :8080/ves/

I logged my problems with Adams queries at this site beginning in Feb 2011:

NRC Web Based Adams timeout query

Why was the search feature of Adams broken for the last three days over this weekend? To tell you the truth, the operation of this has been erratic and dysfunctional since day one...it is a poorly designed system and doesn't lend to public credibility of the agency. I'd be firing people for not doing their jobs!

So I would a search on 05000296, either do a "greater than a date" within the last six months or year, or do a range within the last 6 months or year, then you would get a queried time out. I have long terms problems with queried time out. It is rude a heck to be doing a search and twiddling your thumbs for a minute or two, then get a queried time out and get thrown out without any results. You would be bankrupt if you were Google.

Is Adams search overwhelmed by Fukushima?

By the way, I think Browns Ferry is the most dangerous plant it the nation and they have a culture of falsification of documents to the government. Check out their LER falsification. Matter of fact, you got a wide spread culture of falsification throughout the nuclear industry as outlined narrowly in the NRC OIG investigation on LERs and part 21...

Mike Mulligan
Hinsdale, NH

Electrical self generation in RCIC/ HPIC?

UCS: SOARCA and Vermont Yankee.
SOARCA:

“One concern has been that SOARCA credits certain B5b mitigating strategies (such as RCIC operation w/o DC power) that have really not been reviewed to ensure that they will work to mitigate severe accidents.

I mean, how hard would it be, what don't they have a "alternator" like device attacked to the turbine, like in our cars... where the turbine self generates electricity for the whole machine. Then a computor like device could figure if to stay on the batteries or go alternator.

Yep, then the RCIC pump would have to work with the temp of the water up to 212 degrees, then it might be able to suppy through self generated electrcity power to a motor to cool the torus.

Then you are basically talking about time to boil off the torus and need a vent.

Right, its basically a trade off of primary containment capability, with stretching the core cooling capability as long as can as you are consuming you water reservoirs capabilities.

You could have a small diesel generator stationed in a safe area, up high or distant...run the cable through the reactor building...then all you would have to do is keep the fuel tank full till exhaustion of water resouces on site...that could be the deadicated power source to RCIC or such.

What is your highest prioroity...intergrity of the fuel in the core or primary containment?What is your highest prioroity...intergrity of the fuel in the core or primary containment?

Mulliganism and the NRC OIG investigation on LERs and part 21

I believe the contradictory and incomplete, or too complex for human or public understanding with NRC's rules and policies...it is endemic in the NRC. It is a secret deregulation or reduction in federal oversight scheme with their utilities buddies who work in the NRC. It is a mofia like organization that owns the NRC.  I think the agency employees are maliciously sabotaging government oversight. Most of these guys at the top are extraordinarily educated and experienced...and I don't think these things happen as a one off or by mistake. These things are engineered...purposely taken advantaged to protect the agency employees and give secret benefits to the nuclear industry.

Like I said, we need a outside group or somebody with extraordinarily power to come into the NRC...to immediately create order in this troubled agency.

NRC Office of Inspector General investigation

Audit of NRC's Implementation of 10 CFR Part 21, Reporting of Defects and Noncompliance

"Part 21 component defect reporting issues exist because NRC regulations and guidance for implementing Section 206 are contradictory and unclear. Specifically, NRC regulations and guidance for implementing Section 206 contain stipulations that have been interpreted as not requiring a report under Part 21 if an LER was not required. This interpretation seemingly contradicts Section 206, which requires reporting of component defects that could cause substantial safety hazards. Furthermore, applicable NRC reportability guidance is not utilized by some licensees and NRC staff, and NRC’s Baseline Inspection Program does not include requirements to inspect licensee reporting of Part 21 defects." (you get it, there is inadequate NRC training to the local inspectors and the reactor oversight process doesn't carry it. It is interesting looking at the graph from 1998 to 2009. Other LER reporting are in similar straights )

2.206 transcripts on June 29, 2010 on the Vernon Tie.

(I like my language better because it is more colorful and accurate.)

MR Mulligan: "The new way they do it nowadays is, you have a set of conflicting codes and regulations. You have five or six of them all intertwining and intermingling and very few people can understand, and you have an outcome in mind, and you twist these codes and regulations around until you get the outcome you want.

Nowadays, we play games, we twist around regulations, and we make believe that the regulations, you know, are going to tell us the ultimate truth, if we obey the regulations, it's going to tell us the ultimate truth, and the perfect outcome. If we just follow the rules, there's going to be a perfect outcome."

MR. PICKETT: One more, again, Doug Pickett.

Mr. Mulligan, you were making a number of statements about the codes and regulations are twisted by regulators to get the desired results. Are you aware of any particular regulation or code that is not being met?

MR. MULLIGAN: Well, a code. Well, you see, the problem is I've got a big barrier in front of me, everybody knows that, you know? This is what this is about, is to keep me -- keep a barrier in front of me, and not be able to get the hard questions asked and stuff like that.

You know, I -- you know, one day, you know, I envision a different 2.206 process, where, you know, you are my government, I don't own the government, but I do in a way, but you work for me and stuff, and there's an issue of, you know, I have access to NRC people, we get into a group where there's an assertion like this, and people are on my side, you know.

I don't have these techno barriers, and these legalistic barriers, and these kind of evidence, super-duper evidence barriers and all that sort of stuff that people play games, like, you know, to put a barrier in front of me and stuff like that. I have a thing where a group of people, NRC people, would get together with me before 2.206, we talk about all the different issues, and you would bring up the information, we'd share it freely and stuff like that, and would go into a 2.206 process a lot different way than we do now.

You know, that's how I would make my government work for me. As of now, this process works for the utilities and the NRC. It's designed to be a barrier for me, as far as legalistic stuff, you know, Congress and stuff. So, that's my envision of a government that works for me.

Paper Mache Nuclear Power Plant Safety Systems

Paper Mache Nuclear Plant Safety systems:

I have been talking about "Paper Mache" nuclear plant safety systems recently...maybe first brought it up in my Palisades 2.206 last week. Paper Mache are non testable safety systems...systems where the engineers create mind boggling tons of paperwork and procedures, but fundamentally the system is never tested under real operating conditions. The system or component is made out of nothing but Paper Mache...and in the first huff and puff of the wolf in "The Story of the Three Little Pigs" the house blows over.

The clear example is the backup cooling water system of our Emergency Diesel Generator, the RHR/Service Water cross connects. Say we lose the intake structure or have to shutdown while not using the control room, it is a very complicated procedure and there is a lot of walking around the plant and outside by the cooling towers, it eats up huge shift resources...then the cooling of the Emergency DG's comes from the deep basin, a big swimming pool type structure, the emergency cooling towers cell and the RHR service water pumps.

The gold standard of nuclear safety is the system has been tested in real conditions and the employees have used the system over and over again so they know easily how to bring on the system. So then when the shock of a accident occurs...then you can almost automatically put on the system without any kinks because you trained over it so many times.

Really, the fire pump becomes a ECCS core cooling systems...and everthing in the fire system and the fire pumps should be Nuclear Safety Grade quality such as the ECCS systems. They never really test this system under real conditions.


NRC examines nuclear plant risks in U.S.

Virgilio addressed the NRC e-mails, obtained by the Union of Concerned Scientists through the Freedom of Information Act and released Wednesday. In the e-mails, NRC risk analysts questioned an exercise that simulated a catastrophic loss of power at a nuclear plant due to an earthquake, and whether operators should rely on equipment that was not certified to survive an earthquake.

The exercise, played out on a computer model, looked at what would happen at two U.S. power plants, Surry in Virginia and Peach Bottom in Pennsylvania, with new equipment and procedures, called B.5.b, ordered since the 9/11 terror attacks to make nuclear power plants more resistant to attack. One of the hypothetical accidents that the NRC analyzed was a "station blackout" at Peach Bottom where the plant fails to recover power before backup batteries run out, as happened at Fukushima.

Under the scenario, the plant loses outside power, its diesel backup generators and battery power too, Virgilio said. The new B.5.b strategy would employ new, portable equipment to operate emergency cooling pumps off steam from the reactor core.

One NRC risk analyst questioned how NRC could rely on strategies "that have really not been reviewed to ensure that they will work to mitigate severe accidents.

Questions raised by this and other analysts "are an open item that will need to be looked at," Virgilio said. But he added that the exercise looked at an unlikely scenario — a major earthquake that knocks out power inside and outside the plant.

Cracks in the NRC concrete facade and the Vernon Tie.

My impression with what went on in my 2.206. There was a new PRB chairman from any of my past 2.206, and its my impression it didn't go well. I spoke about my mental models...the models I make about events around me, Mr. Blunt said basiclly at one point, everything about you is models, models, models today mike. A big dog in the NRC recently said the agency models about backup power supplies are inaccruate and not conservative.

Comments:
...Did you ever go in front of this new guy...Blunt.
He tried to steer my presentation and be disruptive.
I am supposed to be allowed the state my presentation...he can ask me questions...but the intent of the question are not supposed to disrupt my conversation.
I was shocked, I had so many regional representatives in there...maybe 1 through 5....
I wanted to talk about the organizational attributes that was causing this...he wanted me to talk about the reactor building cracks...
I told him it was a process fallacy...him wanting evidence from me...and then the agency making me powerless to create my own transparency and all the barriers the agency puts up in front of me.

....I called them nuclear gods and I never seen a more corrupt and damaging group of people than as engineers in general...
They are all whores to money and promotionalism....

....We spent about 30% of my time talking about how I am supposed to be allowed to give a presentation on my take of the petition...I drove these guys into looking into their management directive. It is my pitetion and not yours...

I got really irritated, he told me the issue was there are cracks in the reactor building and my concern is the reactor building would collapse in on itself.

My take, a design earthquake would occur with maybe a wall delaminating away and damaging safety equipment. I don't have the engineering skills to know if the cracks challenge the whole structure.

I think Mr Blunt was trying to make me look like a fool, this idiot thinks the whole reactor building will collapse in on itself...he was setting me up to look like a crazy. I need no help from him in that department.

All these guys have to do is quote what I wrote in my petition...not make a crazed interpretation of what I was trying say.

...Right, I was right on cue, the media was filled with stories about backup power systems today, I spent all my time until I was interrupted talking about the tie and the crazed petition process...where the agency from days back was trying to steer my conversation into the cracks.

I was trying to say, these guys in the last petition process were crazy to accept the Vernon tie...my intent was to indict the NRC and the petition.

I told them right up front, I really want to make a 2.206 petition on NRC...but you won't let me.

I called Mr. Blunt a god and arrogant for playing with me...but I kept my cool and didn't get spitting mad at him....

...Mr. Blunt said I might be in the wrong process...I should go to rule making. I said Mr Blunt, your just like the rest of the NRC employees I have had to deal with. I gone to the NRC OIG, allegation amount others, I tell them my sad story, and they in turn tell me I am talking to the wrong department. I told him I could spend a decade of time with your employees...going down that rat hole...one right after another pawning me off to the next NRC employee down the line. I said it sounds like all you want me to do is run around in your unproductive rat hole. There always has been a extraordinary hurdle with any of your employees to listen to the public and even the nuclear employees.

 ...U.S. Nuclear Regulators Privately Doubted Power Plants Despite Expressing Public Confidence, Documents Show
http://www.huffingtonpost.com/2011/04/06/us-n...

...My contention is not a component or utility centric problem...it is a NRC centric problem in that they would enforce quality electrical supply safety components needed in a design accident.

Mulliganism

These are my best quotes from my earlier Petition concerning the Vernon Tie...the emergency back up power supply.

 ..."(spoken August 02, 2010) Everyone is just waiting around for the big boom and fire, before we recognize we got a industry wide culture problem."

....Mr Mulligan: (spoken June 29, 2010) The new way they do it nowadays is, you have a set of conflicting codes and regulations. You have five or six of them all intertwining and intermingling and very few people can understand, and you have an outcome in mind, and you twist these codes and regulations around until you get the outcome you want.


Nowadays, we play games, we twist around regulations, and we make believe that the regulations, you know, are going to tell us the ultimate truth, if we obey the regulations, it's going to tell us the ultimate truth, and the perfect outcome. If we just follow the rules, there's going to be a perfect outcome.

....MR. PICKETT: "One more, again, Doug Pickett."

"Mr. Mulligan, you were making a number of statements about the codes and regulations are twisted by regulators to get the desired results. Can you give us some examples?"

Right, the NRC OIG investigation report on LERs' and part 21 exactly parroted these concerns. I said it perfectly and LER issue is a symptom ...the agency is riddled with this crazy talk and regulations.

Nowadays, we play games, we twist around regulations, and we make believe that the regulations, you know, are going to tell us the ultimate truth, if we obey the regulations, it's going to tell us the ultimate truth, and the perfect outcome. If we just follow the rules, there's going to be a perfect outcome.

TUESDAY, JUNE 29, 2010....10 CFR 2.206 PETITION REVIEW BOARD (PRB) CONFERENCE CALL RE VERMONT YANKEE - VERNON HYDROELECTRIC STATION...transcripts.

Quotes:

"Believe me, the next event that shatters the nuclear industry, it will all be related back to the "nothing ever matters" mentality of the Ayn Rand republican philosophy of risk informed regulation. This is the genesis of the VY tritium issue and it political problems in Montpelier and Concord NH."

..."As the general theme, I think priorities, and budget restraints, resource limitations for human needs, or safety, I think they are immoral. I think most are institutional problems from Columbia, and Challenger, PMI, most of our institutional accidents, Deep Water Horizon, you know, you can just go on and on, and all of them revolve around budget priorities, resource limitations, and priorities."

..."So, I just -- you know, we don't know what the future holds for us, as far as budgets, and stock prices, and stuff..."

..."My opinion is, the NRC is not a safety regulator, it's a financial regulator. Everything to do with the NRC, risk perspectives, and a whole bunch of other stuff, you are trying to save pennies for the utilities, is what it comes down to. That's what the end game of this whole thing is. So, that's what I think a lot of the problems of this dam business is."

..."It was a stupid thing anyways, and everybody just, you know, wanting to create these super, super safety illusion type of thing, and you end up, you end up having to, you know, close one eye and deceive in the other eye."

Monday, August 02, 2010 9:48 AM...letter to the PRB.

I got to inform you of the truth. These nuclear industry's gaming of language, words, communications, the engineering codes or rule gaming are a severe intimidation threat to any employee in the industry. Hell, most of this stuff is voluntary anyway. Similarly, risk informed regulation, with how it is played in the industry today, is a dire intimidation threat to any employee. It translates into a "nothing ever matters" mentality, we don't have to confront our problems and fix it, because nothing is ever safety related or has any consequence relations.

Everyone is just waiting around for the big boom and fire, before we recognize we got a industry wide culture problem.

"Believe me, the next event that shatters the nuclear industry, it will all be related back to the "nothing ever matters" mentality of the Ayn Rand republican philosophy of risk informed regulation. This is the genesis of the VY tritium issue and it political problems in Montpelier and Concord NH."

Cracks in the NRC and the VY reactor building...

New Apr 6:

This is how I record history...


"Vernon Vt dam high voltage electrical substation."


So tomorrow is another 2.206 concerning...April 6...the reactor building concrete cracks and the Vernon tie again.
It is from 2-3 PM

On April 12th (tues) another 2.206 on non testible safety systems from 9-10 am...

On  April 13th (wens) I be talking in another 2.206 from 2-3pm about the Relief Valve buna n o threads...

This is how to listen in:
1-800-772-3842
PIN:2206