Vermont's Appeal over VY

Interesting, the chairman posed the same question I did but in a more delicate manner...
Gregory B. Jaczko: "Looking to the Future”

February 9, 2012

"So the question is: what does that tell us about the use of risk? Is it an effective metric? To some extent one could argue that based on the risk models, accidents like Fukushima will happen -- hopefully with a very unlikely or low frequency, but they will happen -- and they are acceptable. They are well within our risk metrics, primarily because we ultimately had a robust system that allowed people to be evacuated and allowed ultimately for people to be relocated from any exposure to radiation.

Now, I think if I were to talk to an average person on the street and say that, people would say no, that was a pretty significant event. And I personally think that's right. I think that this was a significant event, and it was an unacceptable event. But if we look at the risk models that we use today, it is not -- in our risk model -- an unacceptable event."

Feb 18: I also spoke, "imagine if we had a core meltdown without fatality in a severe accident in the USA. You people discount this, only consider a nuclear fatality. A nuclear accident with fatality is just marginally worst than a no fatality.

At Peach Bottom, it would destroy two plants because they are so close to each other even if the other one wasn't damaged. It would destroy the value of the largest utility in the USA. There would be massive investigations. What was once thought of as accepted behavior would be thought as gross negligence and a cover-up for decades. I am certain the investigation would rip the lid off the NRC and the whole industry...what other plants are threatened. Certainly the NRC losing their credibility and trust would be a accident in itself.

Remember, we have only had a meltdown in the pre internet period and pre social media interconnectivity period. TMI would be a drastically different accident in this social media and self publishing world....nobody could control the political fallout from this. It would cascade until the energy was spent. And Fukushima got us all teed up already....

Who knows what this stock and debt panic would do to the utilities in the outcome in the meltdown without fatality. That is 20% of our electricity, its a enormous amount of electricity and irreplaceable out for a decade or two. We'd have massive speculation, price spikes and shortages for a far as you can see. It would be disruptive to the whole nation. It would be disruptive to our political system. I am talking about a catastrophe of epic proportions for our electric system.

On a planetary level, the USA would be a nuclear technology disgrace...who knows how many plants would get kicked off the line. Our national stature and credibility would be threatened. Depending what they find under the sheets, we might even get a new president...it might just throw the election. You know everyone would play political football with this. Can you imagine the world we would live in if the antis had a current meltdown as ammo?  

Feb 17 (Reuters) - Vermont's Attorney General appealed on Saturday a federal judge's ruling that had prevented the state from shutting down its only nuclear power plant, escalating a two-year battle over state's rights and atomic energy.

Was that pretty neat yesterday in the 2.206 proceeding inviting all the NRC and Exelon employees to watch the Sunday CCN special about the NRC and VY...

Wasn't that neat when i said to them, "does anyone think this is a coincidence that I on am on a phone in my house and I got all you people in your offices listening to me today, and you got a CNN special about Vermont Yankee later this weekend. Does anyone not believe this was intentioned this way?

Then I give them my rendition of the Vermont Yankee problem..."it is excuses over and over again of the NRC and utilities with intentionally turning your heads away from immediately addressing and fixing known problems in the industry"...

NRC’s OIG: Confirmatory Action Letters

Feb 15: Yep, you got to wonder if the NRC OIG initiated the CAL investigation after reading my Casablanca-Palisades 2.206 on Feb 22, 2011... The NRC says the investigation started 9 months ago?

You notice I stayed with the themes of the Casablanca 2.206 on my newest 'Nothing Ever Matters-Palisades' 2.206.     

OIG-12-A-09 February 10, 2012

Audit of NRC’s Use of Confirmatory Action Letters

I think they got a lot of neat tools, but the NRC doesn't have the skills and training in order to properly and effectively use these neat tools. You catch the similarities with the OIG event reporting...mass confusion with contradictory NRC policies. Can you imagine all the confirmatory Actions letters awarded to Palisades and Entergy...and why are they so ineffective with getting a change of heart out of Entergy?  

Jan 10, 2012: Request Emergency Palisades Shutdown

"We are broadly worried about in 2009 over the Palisades security falsification, in the outcome of the violations...whether all the reports and employee cultural surveys with the assortment of NRC and Entergy processes over this very serious violation ever had any meaning at all. According to the Palisades Fukushima Emergency Power System DC short and plant trip, the most recent root cause Entergy admits there is deep and widespread safety cultural problems at the Palisades plant. I feel Palisades safety culture was in the pits in 2009 and before...and the cultural safety survey was a grand Entergy and NRC falsification. The NRC Alternate Dispute Resolution secession over this, the Confirmatory Order, the Entergy investigative reports and safety cultural survey, the willing acceptance of this insanity by the NRC and Entergy...the NRC created the inaccurate falsified impression to the outsiders that Entergy had discovered all the cultural safety problems and corrected them. Nothing could be farther from the truth, all these corporate and agency processes covered up and deepened, took the public’s eyes off fixing Entergy...where Entergy now is in much worst condition than they were then. I request independent outside investigation on this dangerous agency corruption before Palisades start-up."

Audit of NRC's Implementation of 10 CFR Part 21, Reporting of Defects and Noncompliance OIG-11-A-08 March 23, 2011 "NRC Regulations and Guidance for Implementing Section 206 Are Contradictory and Unclear

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." Transcripts 2.206 Petition Review Board RE Palisades Nuclear Plant dated January 31, 2012
"And like I said, you know, we can -- all this survey -- cultural survey stuff, you know, words have meaning, and results having meaning and stuff. And that was inaccurate, that survey stuff was inaccurate. And it's a con job because, essentially, Entergy gets to hire their own people. And they probably tell the companies beforehand this is what we want, can you do it for us? And that's what they get.

You know, I don't know. Maybe the NRC ought to hire somebody independent or something like -- I don't know what the question is but, you know, that was -- we could have -- Entergy should have found the problem two years ago and they didn't.

The problem is they go through another ADR process. It began in 2010. It just came out as an enforcement finding with the employee that stormed out of the control room. Basically, the same thing is --another agreement. This thing isn't, you know --Entergy, you do it or stay shut down. This is another-- you know, a gentleman agreement, essentially -- I can't even say the word, confirmaternity [confirmatory action] letter, whatever you call it.
How many (confirmatory action letters) has Entergy had in the last few years --two or three at Palisades, and who knows what they've gotten over the fleet. I mean, how well does that work and stuff? So, you know, so another survey is going to be, done fleet-wide, more fleet training. These poor guys they're getting overwhelmed with all the fleet training on integrity and stuff. You know, it just bothers me that this thing wasn't prevented." US nuclear watchdog questions oversight of safety enforcement

By M. Alex Johnson, msnbc.com

The federal government's nuclear watchdog has faulted the Nuclear Regulatory Commission for failing to follow through on safety agreements with nuclear facilities, saying its system for tracking corrective action raises questions about its oversight of nuclear safety and security.

After an eight-month audit, the NRC's Office of Inspector General concluded last week that the commission has no centralized way to oversee or follow up on documents confirming that a nuclear facility has committed itself to address "significant concerns regarding health and safety, the environment, safeguards or security."

The documents — known as Confirmatory Action Letters, or CALs — are one of the last measures before the NRC cracks down with a stringent binding order like suspension or revocation of a nuclear plant's license.

Because CALs are reserved for a small number of potentially serious cases — 15 to 20 of the hundreds of incident reports the NRC issues each year, according to its records — effective oversight of the confirmation process is of "utmost importance," the inspector general said. But in some cases, the action letters are so poorly drafted that they don't even make it clear who the intended recipients are, the report asserts.

Bureaucracy to blame

The problem is one of red tape, not willful inaction or neglect, the report says. But the weaknesses — which include lack of consistent guidelines for regional NRC offices, regional offices' failure to comply with those guidelines and some offices' lack of any tracking system whatsoever — "degrade" the agency's accountability, it says.

 A spokesman for the NRC said the agency believes "the CAL process has been effective" and that it would have a formal reply "in the near future." In an informal meeting last month, the NRC generally agreed with the inspector general's recommendations to update its main enforcement manual, centralize tracking and submit to occasional audits of the action letter system, the report said.

Peach Bottom SRV Seal notes

Feb 21
Oversight of Nuclear Reactor Suppliers

See, they don't have broadly the proper quality framework to maintain standards...either operating and new.

Like I said, the NRC doesn't have the power or know how to us power and coercion to maintain standards againt the corporate interest of making profits...

Somebody's got to be the bad guy...not a consensus maker?

Feb 17 (Reuters) - Vermont's Attorney General appealed on Saturday a federal judge's ruling that had prevented the state from shutting down its only nuclear power plant, escalating a two-year battle over state's rights and atomic energy.

Was that pretty neat yesterday in the 2.206 proceeding inviting all the NRC and Exelon employees to watch the Sunday CCN special about the NRC and VY...

Wasn't that neat when i said to them, "does anyone think this is a coincidence that I on am on a phone in my house and I got all you people in your offices listening to me today, and you got a CNN special about Vermont Yankee later this weekend. Does anyone not believe this was intentioned this way?

Then I give them my rendition of the Vermont Yankee problem..."it is excuses over and over again of the NRC and utilities with intentionally turning your heads away from immediately addressing and fixing known problems in the industry"...

Main Steam Safety Relief Valves Buna-N thread seals (March17, 2002)

You like that picture, these electrical towers are what the back-up to the back-up Fukushima emergency supply of electricity get supplied to VY through...

First Transcripts

Second TranscriptsSome commonalities with the SRV seals

1) Buna-n.

2) Both facilities when they got new actuators ...during the next cycle their buna-n failed. VY had multiple seal failures after new actuators and Peach Bottom's seal failure came after they were just installed.

3) As a thumb rules, you can't trust the quality of buna-n material after 2002.

Mr Mulligan

I have also spoken with the Peach Bottom Resident Inspectors regarding your request to discuss the Peach Bottom safety relief valve (SRV) seal failure history with them prior to the PRB teleconference. The Senior Resident Inspector, Sam Hansell, and Resident Inspector, Adam Ziedonis, would be happy to speak with you. You can contact them directly at 717-456-7614.

The PRB met internally on February 3, 2012, and denied the request for immediate action to shutdown Peach Bottom Units 2 and 3, and replace the SRV pneumatic actuator threaded seals, because there was no immediate safety concern to the plant, or to the health and safety of the public. Specifically, the PRB determined that threaded seals with Buna-N material have been used in the PBAPS Unit 2 and 3 SRVs for 20 years with no seal failures until the subject failure in September 2011. The 3-ADS-SRV 71B seal had been in service for less than one year before its failure and the seals are replaced every 4 years. In addition, the insulation configuration on the Vermont Yankee SRVs that contributed to their 2 seal failures was confirmed to not be a contributing cause for the PBAPS Unit 3 ADS-SRV 71B failure. These facts support the conclusion that the failure of the 3-ADS-SRV 71B threaded seal was not a common mode failure, or an age related failure, but was isolated to the particular seal installed in the 3-ADS-SRV 71B actuator in November 2010. This information will be included in a future NRC Inspection Report regarding the subject SRV threaded seal failure.

Thank you,

John Hughey

Peach Bottom Project Manager

NRR / Division of Operating Reactor Licensing

Phone: 301-415-3204

e-mail: John.Hughey@nrc.gov