"In regards to your issue with potential falsification of documents, the NRC characterized the subject Licensee Event Reports as inaccurate."
That makes the first NRC inspection report more falsified than inaccurate...
We'd be in a different world if it was illegal to make a incomplete or inaccurate LER or inspection report....
In the comment section are the e-mails to the NRC about my allegation...
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
June 10, 2011
Mr. Mike Mulligan
steamshovel2002@yahoo.com
SUBJECT: ISSUES YOU RAISED TO THE NRC REGARDING THE BROWNS FERRY NUCLEAR PLANT – FILE NO. RII-2011-A-0078
Dear Mr. Mulligan:
The NRC has completed its follow up in response to the issues you brought to our attention on April 10, 2011, regarding the Browns Ferry Nuclear Plant. You identified issues with the safety of the Browns Ferry Nuclear Plant and falsification of documents submitted to the NRC by the Browns Ferry Nuclear Plant.
In regards to the safety of the Browns Ferry Nuclear Plant, the NRC determines its regulatory response in accordance with an Action Matrix that provides for a range of actions commensurate with the significance of performance indicators (PI) and inspection results. Browns Ferry Unit 1 was recently assessed to be in the Multiple/Repetitive Degraded Cornerstone Column of the NRC’s Action Matrix. The Action Matrix is intended to provide consistent, predictable, understandable agency responses to licensee performance. The actions of the matrix are graded such that the NRC becomes more engaged as licensee performance declines. The NRC can make adjustments to the inspection plan based on plant performance trends. For example, for plants that do not have all green PIs and inspection findings, the NRC will perform additional inspections beyond the baseline program. Both Green inspection findings and PIs allow for licensee initiatives to correct performance issues before increased regulatory involvement is warranted. White, Yellow, or Red inspection findings or PIs each, respectively, represent a greater degree of safety significance and therefore trigger increased regulatory attention. It should be noted that an individual Red input may indicate a performance issue that is significantly degraded. However, overall plant performance may not be unacceptable due to the defense-in-depth design of the plant.
In regards to your issue with potential falsification of documents, the NRC characterized the subject Licensee Event Reports as inaccurate. Documentation concerning our finding can be found in NRC Integrated Inspection Reports 2010003 (ML102110467) and 2010005 (ML110400431). Licensee Event Reports are inspected by the staff and, as with all inspection findings, willful aspects, which can include falsification, are considered. None of the LERs reviewed were determined by the staff to be willfully false or written with the intent to mislead the NRC.
Thank you for informing us of this matter. Should you have any questions, please call me at 1-800-577-8510 or you may provide information to me in writing at P.O. Box 56274 Atlanta, GA 30343.
Sincerely,
/RA/
Eugene F. Guthrie, Chief
Projects Branch 6
Division of Reactor P
6 comments:
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
I think the resident NRC inspectors were giving TVA a opportunity to create a coverup...between the first LER and then the updated LER...
From: Michael Mulligan
To: "Lewis, Shani"
Sent: Thursday, April 28, 2011 8:50 PM
Subject: Re: Your Concerns Regarding Browns Ferry
IR 2010-005[ "The valve disc was found to be seated and stuck in the valve seat, essentially blocking all RHR Loop II flow."
More NRC crazy talk: This finding does not have a cross-cutting aspect because it is not reflective of current licensee performance.
LER 2010-003-01: "The disc could not be removed from the body by conventional means (e.g., chain falls) with the operator removed. A combination of hydraulic jacks and heating the valve body to prevent galling the seats freed the disc."
Considering the hammering by the stem and motor...is the galling just a made up story...
I am flabbergasted the NRC on their own didn’t write in their own independent characterization in the initial inspection report, of how stuck the disc was, like I said this was not included in the first LER. We should have gotten a complete explanation of what TVA has to do to get that valve unstuck...
It sounds like the NRC in the first inspection report was telegraphing to TVA we don’t care how you disposition the stuck disc, you can even say it would break free in 7 minutes and we will agree with you.
From: Michael Mulligan
To: "Lewis, Shani"
Sent: Thursday, April 28, 2011 9:30 PM
Subject: Re: Your Concerns Regarding Browns Ferry
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 this valve safety 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....
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 two employees in a office at a nuclear plant could conspire to write a falsified LER in order that they limit their buddy's accountability to management and NRC repercussions...then submit it to the NRC. As long as these employees don't admit the inaccuracy was intentional, think up a phony fall back story it was mistakenly made inaccurate if the NRC catches them...then these employees knows at worst it is a insignificant infraction or most likely they will get away with it...
At the end of the day, did the NRC use just enough horsepower so the agency would seem a creditable regulator or did they use sufficient horsepower to guarantee a change of behavior with TVA and the nuclear industry...?
I think the agency was only looking towards just enough public credibility to feed their public relation image...
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