Palisades safety Refueling Water tanks 2.206 (rev 1)

　

June 21, 2012: Request Emergency Palisades Shutdown

My old Feb 22, 2011 2.206, actually dating back to 2010. "God help us all, can you see the problem with the repetitive nature of Entergy having the instincts to not the due proper inspections... to do it over and over again like a madman. They are laughing at us and the
NRC because these employees and managers know we can't control them. The NRC has no ability to control Palisades...that is my god damned political statement to the NRC."
(Note I edited this for easier reading and corrected some errors on June 27, 2012)


June 18, 201


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

　

　

Dear Mr. Borchardt,

The Poppersville Town Hall
Request Emergency Palisades Shutdown (Jan 10, 2012)
 
Request Emergency Palisades shutdown (June 18, 2012)


Feb 22, 2011 and Jan 10, 2012 2.206:   
“Subject 2.206: Request a emergency shutdown of Palisades because the Reactor Oversight Program is ineffective and Entergy has a documented history of a culture of falsification and thumbing their noses at reoccurring violations. It should be noted in this inspection period most of the fleet of Entergy’s plants are on fire and burning in the Gulf of Mexico with numerous NRC inspection findings including Grand Gulf, River Bend, Arkansas One and Cooper. And we sit in the shadow the River Bend’s troublesome plant trip and the restart, then the subsequent shutdown with three leaking safety relief valves and Augment Inspection Team. How can you say there are not systemic problems with Entergy? You had a short in a motor, then the first safety breaker and relay failed to stop the fault. It was a cascade effect and other pieces of equipment were affected. Is it just me with the nuclear industry, there has been a rash of recent electrical equipment and switchgear faults and shorts, and the first safety breakers and relays fails to operate and stop the massive short. If you want my opinion, the wires and electrical (switchgear, breakers and safety devices) will lead to a limiting accident before the pipes do. In truly Palisades nuclear plant biblical proportion, the last River Bend’s NRC inspection uncovered nine violation. Theses guys are riddled with similar violation throughout the year as their brother plant Palisades is. This is a systemic problem with Entergy and the NRC doesn’t have the power to control it before this company damages the nuclear industry.

Now we got repetitive electrical shorts in the VY Recirc MGs and heavy smoke in the reactor building. Chances are the vender that made motor is out of business or this line of component they don’t make anymore. These guys are struggling to get people who really know what they are doing to repair or replace this gear. Chances are the new replacement and repair parts stream is dead and they are paying engineering firms to reverse engineer these components like we were the third world. This is a huge crisis in these aging plants. The whole technological and scientific world has passed by these ancient archeological artifact...

Got a assortment of states desperately trying to shutdown Entergy’s nuclear plants because nobody trust these guys. Unbelievable union troubles at the Pilgrim nuclear plant and rumors the union employees have sabotaged the plant by tripping it in a union action, while the state of Massachusetts is trying to put hold on their relicencing. Massachusetts and Vermont are more persistent than me. It is a double hitter going on over there is New York

The NRC is probably going to call the leaking Safety Injection Refueling Water tank (SIRW) shutdown a planned shutdown. Seeing how for a indeterminate amount of time, certainly before the last outage, they knew the tank was leaking and did nothing. They didn’t care the leaking 300,000 gal tank sits above the control room with all the invaluable instrumentation and all those electrical cables.Palisades: And only god knows where they were collecting the allowable leakage that they didn’t know where it was coming from and what it was running down on. Were they measuring all the leakage? I can imagine this tank failing with the water filling up the control room and suffocating all control room operators.

They had a opportunity to drain it and fix it in the safety of a shutdown outage. This was a totally preventable and unnecessary shutdown. A rash of planned and not planned shutdowns and plant trips prematurely wears out a lot of equipment in a nuclear plant. This leads to the risk of more shutdowns and drives bad accidents. Ask Palisades about this overcome. This is a indication Entergy doesn’t know how to run a plant and maintain it. I request the NRC characterize this as a unplanned shutdown because of how egregiously not conservative it has been.

So this is the record going into the last outage and the red finding:  
“Palisades had five unplanned shutdowns in 2011. Because of that the power plant now has one of the worst safety ratings in the country.”
NRC concerns:

Organizational failures
The need for a recovery plan
Poor quality work instructions
Failure to follow procedures
Poor supervision and oversight of work
Poor maintenance
Failure to respect the role of an operator
Multiple events caused by personnel or equipment failures
Questionable safety structure
Language As a Technology of Exclusivity and Special Rules

I framed it as the NRC engineer’s language picks and chooses what issues they bring to the public table and it is immoral. They create a architecture of engineering half truths and misconceptions in the language structure they make to a community. Vermont, Massachusetts and New York don’t think the NRC has the ability to control chaos at a plant. They always got some agency rule trap door leading to all bad behavior is acceptable and nothing ever matters at a nuclear power plant. As long as the public can’t see the bad behavior mean nothing is ever wrong. A structure of selective self interested truths and thus the whole building becomes one enormous inscrutable lie. It’s the history of this industry to tell half truths in defense of self interest and in their perception of doing good. It is how you think you are doing good, then end up destroying 100,000s of jobs and damaging a great nation in the ends of altruism. These guys invented the corporate and government crazy talk phraseology of the 1970’s and 1980’s.

I have seen this over and over again where the agency uses a special language and a assortment of language rules and engineering rules, supposedly engineer’s speak, as a intentioned tool of understanding disruption and public knowledge sabotage. These guys are a cohesive mafia honor culture of half truths and it always ends up as the nuclear industry repetitively shooting themselves in the foot. The industry is sabotage their employee’s future for ideology and profits to special people.

This is primarily a crisis of truth telling and the US government doesn’t have a vehicle that demands on severe penalty truth telling. This is a age old crisis on just “what is truth”?
A NRC official recently spoke of a engineer’s language.
Me: “ As I spoken, it my feeling that the NRC engineer's language...picks and chooses engineering rationales and issues...indeed picks specific terms of a petitioner to meet a NRC agenda. What is going on is not pure science, it's mocking science and the public process. I am not talking about you, you were a nice guy trying to listen to me...but as the agency talks to me. I have no beef with you.
See I think NRC answers me in a benign and selective way...they answer me with a engineered interpretation of my words that favors the industry or NRC, not in the most unfavorable interpretation of what I am saying against the utility and NRC. I think this is on purpose and it may be the way they are trained to make a response. They could always called me to quiz a point I am really making.

So they expect me to challenge them further down the line with a come back. It is playing games hoping I will lack the initiative to answer them back.

It is just not being straight and direct...it is a form of coercion and corruption.
The official: “You expressed that the material facts of the seal (the temperature duration in radiation for example) had not been established through testing. Therefore, the NRC staff could not prove to you that the Buna-N threaded seal material is adequate for accident conditions as well as normal operating conditions. You also expressed that you felt that the NRC staff’s safety determination was merely “throwing engineering language” at you instead of addressing your concerns.”
Gaming Language: when did the SIRW tank begin leaking?

Here is a prime example of the engineer’s language. And I will tell you something, there is no engineer’s professional ethical code or legal requirement for these officials to tell the full and complete truth in the media. There is no ethical code requiring the nuclear officials to tell the full truth to the public. These official don’t have a moral code in them, in their heads...that complete truth telling has a benefit to our nation. There is a bogus permissive for “competitive or propriety reasons” nothing ever should be disclosed without a huge fight to the public. They basically filter their story through a series of unseen code and immoral acceptable rules where the final story we see is almost a complete fabrication. As along as the story filters through a set of official rules and unseen group codes and customs , they have faith the outcome is a god given truth. They can’t see how ridicules the product of their rules has become. There is no law to hold these official accountable to the truth said in the media. And there is very little law that holds them accountable in legal documents. Certainly there is no consequences for lying. These are public news announcements.
Published: Thursday, June 14, 2012, 6:15 AM
The NRC was made aware of the leak in April when the plant shut down for refueling. Both Entergy and NRC inspectors monitored the leak. The plant set a limit that if more than 31 gallons leaked in a day, the plant would shut down, Mitlyng said. The plant's license specifies that no more than 34.8 gallons leak a day.

According to a news release from an Entergy spokesman, workers had been monitoring leakage from the plant's safety injection/refueling water tank for several days. but by 1:41 p.m. Tuesday, the leakage had surpassed the limits they set so the tank was declared inoperative.


Palisades nuclear power plant shuts down to fix water leak
10:44am June 14 Mark Savage is a spokesperson for Entergy, the company that owns the Palisades plant. He says this tank has been leaking for several weeks. It’s an old aluminum tank that holds 300,000 gallons of water. He says the tank is the same age as the Palisades plant: 40 years old.How come Entergy’s Mr. Savage isn’t required to give all the factual information...how come in the shadow of the red findings they didn’t disclose when this leak began and the location of the tank? How come as a matter of community honor Mr. Savage didn’t initially disclose we got a leak in these tanks...what do you think if we ignore it and started up? What do you think if we ran it to the tech spec limit? What do you think of us if the unknown crack and leak was getting bigger...we said it would months until we are required to shutdown and find out what is leaking?     
Event Number: 48018
The licensee believes that the tank is leaking from several locations. However, at this time, they cannot determine exact locations.
The Fallacy of Risk Based (regulation) Plant Operations

The best defense for safety for the plant is to have adequate safety margins “as the designers intended the plant to be”. And the first nuclear safety culture precept in any deficiency in safety plant design is you fully understand what is causing the barrier degradation. You can’t tell how bad the crack is until you eyeball it for yourself. Imagine that, there is no law requiring them know where a leak is? Engineering says for critical safety public interest, you fully understand the magnitude of the degradation and what is causing a leak. How can you tell the difference between a insignificant leak and another insignificant leak, but the second insignificant leak is showing the potential for a catastrophic break? A leak of unknown engineering dimensions, a leaking rate of 10, 20 and 30 gals per day....the leak gives an engineer extremely limited information.

Davis Besse once had a safety insignificant safety leak and the information entrained with this increasing insignificant leak brought the nation to within 1/8 of a inch nuclear crisis. They were diligently measuring its increasing leakage rate, as a unimaginable hole ate inches of metal away from a reactor head. They tripped over the leak while shutdown, that is how they caught it?

Right, it is how men make self interested rules based on personal advantage on how to interpret new information. We are lucky there is more a female presence in this industry. It is not requiring a human to use his full astonishing mental capacities to interpret new information. You see the how risk related regulation allows the facility to make a safety determination based on very limited information? It gives the operators of a nuclear plant a permissive to act stupid for mere pennies. This 300,000 gal tank has very small 35 gal a day leak and it gives Entergy the permissive to not care why it is broken. You could have a minor earthquake, and there could be a degradation in the tank wall in which the whole tank spills into the bottom of the building. In nuclear power plant, there is many more safety angles other than just having enough water to cool a core. You might plenty of water, but not a way to get it to the core. You see what I am saying, risk regulations allows them to base safety on just a fragment of information. A 300,000 gal tank:
It would take you 42 days to fill up this tank by a garden hose.
It is 15 average size swimming pools of water in the bottom of the reactor building or within the control room...And then the size of the leak was increasing over months. It means some worsening process was ongoing and nobody thoroughly understood what the process was. Risk regulations is the permissive to make me think stupid and act in my own interest! None of this is nuclear safety! Those concepts of blowing by the initial engineered safety tank design margins and not knowing what caused a tank leakage is a threat to the conservative safety assumption and actions country wide. It not what you know that kills you (leakage rate) in Davis Besse, it is the unknowns the leakage is telegraphing you. This tank feeds all of the emergency make water for this nuclear reactor: high, medium and low pressure feed. It bad enough the utility doesn’t know right from wrong...but this is a grave principle of conservative nuclear safety that the agency doesn’t know right from wrong. As for the acceptance of a assurance on a Safety Injection Refueling tank leak with such a worsening indeterminate leakage and carrying so little factual information by Entergy, are there any real engineer’s with a moral conscience voice left in the NRC? Does the agency know how important missing information and selective data is with knowing and understanding safety? It is not the information and evidence you can see with your eyes...it is the missing information and evidence that is the killer.

Does risk perspectives make curiously, facts and evidence obsolete?
NRC concerns:
Organizational failures
The need for a recovery plan
Poor quality work instructions
Failure to follow procedures
Poor supervision and oversight of work
Poor maintenance
Failure to respect the role of an operator
Multiple events caused by personnel or equipment failures
Questionable safety structure   I always thought the ROP punishment for a utility’s bad behavior was to appease the wider public. It is to shallowly make the public feel better about nuclear power instead of making the industry better. It is to create a smoke screen to make the public think grand changes are underway for a bad utility. But it has no or little effect at changing utility bad behavior. Here is the absolute evidence just months away from a rare red finding. The ROP is just for show. Here is what the NRC thought of Entergy this past Feb in their red finding.   Feb 2012 IR 2012005
For conservative assumptions, the inspectors reviewed the Apparent Cause Evaluation(ACE), corrective action documentation, the recovery plan and NRC inspection findings. The licensee determined that the apparent cause was managers making decisions based on meeting only minimum regulatory requirements. The inspectors concluded that based on the findings reviewed by the licensee, the licensee identified a reasonable apparent cause. However, the inspectors believe that the recovery plan elements related to address leadership engagement, correction of performance gaps and degradation of safety culture principles more accurately characterize the causes of the findings. In addition, the recovery plan includes broader actions that will more likely effect change. The ACE actions included training of supervisors on conservative decision making. While this is a reasonable step in eliminating the cross-cutting theme, management reinforcement of conservative decision making is necessary to achieve sustainable results. While the ACE corrective actions capture this through an observation form, the broader elements of the recovery provide a mechanism more likely to achieve sustainable results.So here we are in a preventable shutdown. From the beginning before the outage Entergy knew they had a unknown defect in the Safety Injection Refueling tank with a increasing leakage rate. They had a conservative opportunity to completely understand the nature of the leakage and repair it before the startup. It is right out of the mouths of the Entergy officials before the red finding and all the plant troubles... now with the SIRW tanks accident. Its right out of the mouth of the NRC talking about Entergy’s problems...they continue “only” meeting the minimum regulatory requirements and making poor conservative decision after all this self flogging back whipping and crying crocodile tears. It is as if pretty words and promises in front of community made to a nation have no meaning at all. It is all for show! We are all in a reality TV show and nothing has meaning at all except customer ratings. They don’t even care if all they are drawing in their reality TV viewership is the losers in our society.

Yet, where was the conservative influence of the NRC on making Entergy eat there own words in another component degradation. In their own words, “stop just meeting only the minimum regulatory requirement”? How come NRC behaves like reality tv, where words and errant emotions have no meaning...where everything is a insignificant show. How come they don’t act like billions of dollars and our nation’s engineering reputation are at stake? How do you get them out of la la land...what will it take?

Does the agency put in credence in their own NRC inspection report words that condemned Entergy with only meeting minimum regulatory requirement, engagement of performance gaps and degradation of safety principles? Does the agency’s own words have any meaning at all and do they perform any organization force on maintaining safety principles in the whole of the nuclear industry? If congress or the president told the NRC to rob a bank or destroy the nuclear industry through a set of self serving rules...are the plant NRC inspector obliged on pain of the law to rob a bank or destroy their nuclear plants through indifference? Are promises to keep to a community and inspection report words, just meaningless noises in the breeze? Is this reality tv disconnected from meaning? NRC concerns:
Organizational failures
The need for a recovery plan
Poor quality work instructions
Failure to follow procedures
Poor supervision and oversight of work
Poor maintenance
Failure to respect the role of an operator
Multiple events caused by personnel or equipment failures
Questionable safety structure   All of the nuclear safety principles the NRC has been espousing in the shadow of Palisades bad behavior post red finding should have drove the agency to make Entergy fully engineering wise understand the Safety Injection Refueling tank leak before start-up and bring that tank back to the initial plant safety design at earliest shutdown opportunity. The agency’s correct ‘inspection’ and red findings words to Entergy now condemn the agency itself. The agency’ s nuclear industry philosophy are a disgrace to the world of nuclear power safety principles itself. The first principle to the community should have been to notify the public that the tank was leaking from a unknown location and the leakage rate was increasing, yet still meeting its tech spec limit from the moment it began leaking. In the shadow of one of the worst plants in the nation and a red finding, why does this information only show up in a emergency shutdown. A conservative assumption based on the location of the tank, the leak rate is ramping up in a spike for unknown reasons...they should have scrammed the plant.  They should have admitted the 300,000 leaking tank sat on top of the vital control room. The agency should have asked the public what they thought about this condition when the leak first showed up. That is public participation. The first principle should have been complete truth and full disclosur to the public in the shadow of the 4^th worst operating plant in the nation. I certainly would have requested a immediate shutdown and repair of this tank from the moment the tank began leaking (sorry, I missed in the inspection reports). It is beyond preposterous public credibility-wise in the shadow of Fukushima, that the agency didn’t admit the core cooling and make up tank was leaking and the utility didn’t know where and the extent of the damage till it directly challenge tech specs. Palisades and NRC secrecy facilitated the operation of a not safe nuclear power plant.  In the shadow of Fukushima and the 4^th most dangerous plant in the USA, should the agency be creating more plant operating super secrecy or more transparency?Does the agency know right from wrong? Does the agency’s words of criticism to a poorly performing plant have any order creating meaning at all? Or are they just altruistic pretty words broadcasted to the public without any internal backing what so ever.

So here I am giving two week warning on May 30 predicting based on the past behavior of Entergy that a controversial plant trip or a unplanned shutdown (June 12) was right around the corner. Congratulation Entergy that was a pathetic 34 days of continuous plant operation. Doesn’t that question how many shutdowns and plant trips they will have in the next cycle.Palisades nuclear plant trip?’
“I smell a troublesome plant trip in the air....”
“Come on, admit it? Is this the grand NRC “nothing ever matters” philosophy on leaking nuclear reactor safety system water leakage stated by a agency official? Does all that we know about accident warnings and precursors boil down to all nuclear plants are able to operate when some parts that are leaking? Does the NRC just act like reality TV thinking the viewer aren’t real...the community out there is fake...the world has no meaning and consequences at all?

And we sit in the shadow of another NRC disgrace in San Onofre. The new steam generators didn’t meet their original design specification. Who cares if nuclear components are always leaking and nobody is required to meet original design specification until a terrible accident shows up costing the ratepayers and our nation billions. Who cares, it acceptable in our rules, our rules are the primacy in our safety philosophy. Our rules are our god and our god is unanswerable to all outsiders. Right, it all a reality TV show and nothing matters or has consequences. We are all protected because everything is fake.

Who cares about if all or some reactor safety parts are leaking...who cares if the computer safety engineering codes don’t meet original design specification? And she misrepresented it cause the leak has been getting bigger and nobody understood why and how it was leaking. There is not a higher safety principle in engineering than in fully understanding what is going on in a nuclear plant. I know what is going on with my indications and I can confidently predict the outcome of all my indications...no guess work and rolling the dice in this industry. Is this really the safety philosophy of the NRC?   Nuclear plants are able to operate when some parts are leaking. "There is always some kind of leakage going on," Mitlyng said. "As long as it's very small and doesn't get bigger." Here is an emergent problem Palisades didn’t handle correctly in the recent past. It lead to a very serious plant accident and out of control plant trip. It set up a pattern of operational risk taking leading to risking human life trying to keep the plant operating when maintenance work wasn’t done right and safety equipment wasn’t installed as originally designed. There are many other serious problems and this led to being one of the worst operating plants in the USA. Basically they had a so called minor indication of a failed equipment warning light that they put off at fixing when the plant was in safe shutdown condition. Does it sound familiar? This minor lamp defect led directly to a grossly botched installation of new breakers replacing obsolete breakers to a back up DC emergency electrical system. Honestly, talking about safety budgets and priorities...risk perspective...what proof do you got that insignificant problem won’t lead to a enormously mind boggling problem. There it is, that insignificant problems lead directly to a incompetent nuclear operator and big national problems. Here is the case that a perceived insignificant problem led to a degradation to the life blood of emergency electrical power to many nuclear plant safety devices. And with the Safety Injection Refueling Water tank leak of unknown location and degradation mechanism, the chances they take just get bigger and bigger. What is wrong with you, our rules allows this? Our rules are your god!

Buddy, in a nuclear plant all priorities and budgets are immoral. You never know all the risk until you get down to the bottom of the rat hole...a sterile computer model is never as smart as our brains and computers senses are not hard wired to the real world like ours. They found grave maintenance errors in the installation of this important safety gear while at power and they didn’t have the integrity to immediately shutdown the plant and fix it at a safe shut condition. The DC electricity plant trip and the leaking Safety Injection Refueling Water tank is the exact same issue derived from only meeting the minimum regulatory requirement. Rules carry so little information and our human brains can process so much information...our brains are so smart at discriminating important information from insignificant information. We do it much better than some blind and stupid rule. But what can you do if a rule gives us all the permissive to act stupid...

In Palisades words, this was a really insignificant lamp problem with the Fukushima emergency electricity system. I’ll makes the case insignificant lamp problem carried all the information about the up coming DC accident.“Prior to the 2010 refueling outage 1R21, routine preventive maintenance performed per work order WO52025543-01 identified that the green status indication lights for the containment escape air lock MZ-50 were not working. Although CR-PLP-2010-3580 and work request WR210717 were issued at the time, this condition was not addressed until the troubleshooting activities scheduled for Thursday 09/22/11 under WO248834-01 In the NRC’s words, this was all thought of as a insignificant problem until seen from the light of the history made from the DC bus plant trip. Did I once say it, all catastrophes emerge from inaccurately perceived insignificant problems.During Refueling Outage (RFO) 21 in the fall of 2010, the licensee performed extensive maintenance on Panel D11-2, which included the replacement of 10 breakers inside the panel, as well as other maintenance activities. Any performance deficiencies associated with the maintenance conducted during RFO 21, which led to the instrument air transient that occurred on September 23, 2011, will be addressed in the fourth quarter NRC Integrated Inspection Report (IR) (05000255/2011005). On Thursday, September 22, 2011, the licensee commenced a WO to troubleshoot the inoperative green indicating lights for Door MZ-50 (Emergency Airlock Lights). Through this investigation, all interlocks, indication lights, and limit switches for this door were found to be satisfactory. Since this door was due for its technical specification (TS) required surveillance test on Monday, September 26, 2011, the decision was made to conduct more troubleshooting activities to identify the cause of the indicating light issue. The Safety Injection Refueling Water tank leak is much worst than the DC system short. It is the exact same accident with the NRC and Entergy accepting for self interest reason incomplete information around a safety system defect or degradation. The crack rules allows us the permission to not fully investigation a safety system degradation because risk regulation is designed to make us stupid.

The point I am trying to make is Entergy and the NRC has a habit of getting indications that problems are developing and they define it as minor until they hear the zapping of a huge electrical short and this creates a troublesome plant tip with complications. Plants like Palisades have a lot of other secret known problems pop out the woodwork in a huge zapping short accident. You are pushing the capacities of good people with this unnecessary complexity.

It is the smoke and huge zapping spark from a large electrical short that frightens them that gets them thinking that little problem was bigger than I thought. It one thing to read about how powerful these energy sources are that are coiled up in a spring....it another thing all together to see exploded parts and melted metal after a accident. It beyond comprehension to see your buddies carted off in a stretcher to a ambulance.

All huge tragic accidents with body parts spued all over the place begin as insignificant problems that were ignored and approved by risk perspectives. They bury it in their bureaucratic maintenance document priority system for months and years. They wait until the last and worst possible moment in their work priority system, which drives the plant and employees into creating a grossly unprofessional plant transient. Of all the public back flagging over Entergy’s shameful red findings and poor behaviors over the last few years, in the last 6 months with both the agency and Palisades, now in shadowed of the SIRW leak, they act/acted as if they haven’t learned one lessen. The whole lot of them from our political system, to the Nuclear Regulatory Commission, to Entergy-Corp and all the human between them. I can make the case we are in a gigantic financial crisis in our electric utility system, the likes this nation have never seen before. The times demand we act and behave different than we have in the past!

They keep recklessly repeating the bad behavior over and over again no matter how much public back flogging they do to each other and the promises they make to the public and the community about changing their bad behaviors. As with a host of terribly poor utility’s behaviors like Entergy, Fort Calhoun, TVA and SCE; it is like the NRC is oblivious to their choices of not demanding a change in behavior from a bad utility. This is truly regulatory and NRC insanity. There are enormously costly consequences to our nation all around us right now. It is like the agency is running around utterly disconnected from the consequences of their choices and the outcomes of not being involved with controlling bad behaviors. The agency doesn’t understand cause and effect....or the agency doesn’t know how to drive effect.

Fed 22, 2011'It would know the conditions (dysfunction) of the managers and employees, we would know every error of a policy, the absence of a procedure, rule or organization attribute, know perfectly every defect in every component. We would have the perfect god’s eve view of the plant and the organization. Push the magic button, do we have a green, yellow or red light at Palisades, the NRC or Entergy?"  Request Palisades nuclear power plant and all Entergy nuclear power plants

be immediately shutdown.
NRC concerns:
Organizational failures
The need for a recovery plan
Poor quality work instructions
Failure to follow procedures
Poor supervision and oversight of work
Poor maintenance
Failure to respect the role of an operator
Multiple events caused by personnel or equipment failures
Questionable safety structure 1) That the Safety Injection Refueling Water tank shutdown be defined as a unplanned shutdown.

2) Request the NRC bump up the Palisades performance indication from red to the next level of V: Unacceptable Performance.

3) Request an outside authority, nobody trust the NRC’s OIG...why didn’t the agency force Palisades Entergy to thoroughly investigate SIRW leak when the leak first appeared. Why didn’t the NRC make them fix it in the last safe shutdown period according to the agency’s own nuclear safety culture philosophy.

4) Request top Palisades Management staff be fired and replaced before startup.

5) Request Entergy's corporate nuclear senior staff be fired and replaced before the restart of the plants.

6) Immediately request two addition NRC inspectors to be assigned to Palisades plant, and to all the rest of the troubled Entergy nuclear plants. There seems to be a few plants of the bunch that behave themselves.

7) Request the formation of a local public oversight panel around every plant.

8) Request a emergency NRC senior official oversight panel with the aims of reforming the ROP.

9) Request a national NRC oversight panel of outsiders to oversee and report on the agency's activities. There should be a mixture of professional academic people and capable lay people.

10) There continues to be some heavy duty and exceedingly numerous findings of problems with Entergy plants' this inspection reporting cycle...do an analysis of why this is occurring.

11) Request a evaluation if NRC region III has enough personnel and resources.

12) Stay shutdown or remain shutdown until all procedures are fully updated and corrected, all technical and maintenances backlogs are updated and corrected, all training completed, all reports and safety processes fully completed and implemented.

13) Request a independent outside investigation over the insufficient process outcome of the 2008-2009 Palisades security falsification, investigation, safety survey local and fleet wide training and safety surveys. Based on the DC root cause it appears the safety culture for many years has been grossly defective and ineffective, along with the ROP... with then all these processes failing to discover the true depth of Entergy's safety cultural problems and they lied about these processes fixing Entergy. It sounds like this is a generic problem to me. 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 these 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 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.

...And all Entergy’s and the NRC’s promises to the community post red finding and in community meetings has been found to be meaningless promises in the light of the Safety Injection Refueling Water tank leak. All of the ROP and NRC recent meeting about the troubles with the Palisades plant been a intentional a scam to deceive the public. The intent of this activity by both the NRC and Entergy has been to weaken the nuclear industry as a national security energy-electricity resource. 

 14) I request that President Obama fire Chairman Jazcko and the other Four Horsemen of the Apocalypse Commissioners! Oops, this has been completed.

　

Sincerely,


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

Palisades Numerious Roof leaks 2.206

June 28, 2012

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

Dear Mr. Borchardt,

I called up the Palisades NRC inspectors about 2:00 pm yesterday just before the notification of the NRC Office of Investigations. I spoke with inspector that they brought in for this. I asked if there were any rust and degradation anywhere around and underneath the SIRW tanks? Do you know of any rebar showing and crumbling concrete? He said all areas looked surprisingly good. I came back with a diatribe concerning my old days at Vermont Yankee in 1991.

I had a reactor operator license and I was coming in and out of the diesel generator rooms for many years in my rounds as a plant operator. I told this special inspector, you wouldn't believe what my eyes had seen in that place. We had very serious roof leaks in these rooms. All the employees would kid, are you bringing along your scuba gear to do your rounds in these rooms during a heavy rain storm. There would be huge puddles of the floor and rain and snow water would be eaking on the equipment. We had  lots of grounds and shorts on the diesel generators over the years with the leaks We had many times inoped these machine over rain water leaks. All my buddy employees and me had given up bringing it to the attention of our mangers. Rain water was leaking down on the engine and on top of vital electrical generators in both rooms. I had the serious rust and water spots you could see on the components even when dry. It was leaking on top of control panel and leaking into the electronics. It was pudding many inches on the floor and water was lapping up against the control panel with all that delicate instrumentation and control devices. I got fed up with my life and I decided I am going to change this come hell or high water.

I was a bad guy that should have known better...but where was the NRC inspectors over all these years of pudding and roof leaks?

So I started writing up reports on this and raising hell. For months, I come into these rooms during and after a storm, there would polyethylene protective sheets all over the place trying to protect the equipment. We had a huge exhaust fan in that room cooling the engine and the generator that circulated a lot of air...an enormous amount of cooling air. I knew the wind would shred the poly sheets and foul the safety fan if we had to used the DGs. I watched water roll off the poly sheet and then leak on to the invaluable spiritual public safety machines.

For the first time in my life, I went up to the residential NRC inspector office and dragged him kicking and screaming into the DG rooms. These room were security key carded and I figure my management would know I was ratting on them when they checked the badge computer read out in.The NRC inspector came back to me in weeks saying he'd never seen the puddles, and furthermore, do your know your mangers are looking over the roof structure and this has turned out to be a very complex roof structure problem. I told him back in the bravo DG room, F*** ****, I will handle it myself.

I called the state nuclear engineer and explained what my eyes had seen. In a few days, he came down for a state "routine" inspection with the Governor of Vermont and their entourage. They requested to look inside the diesel generator room. Vermont Yankee told them they weren't allowed in that room for no reason at all. The state nuclear engineer, along with the governor, then stated a whistleblower had grave concerns with a roof leak in these rooms and it is damaging the machines. They told VY that is why we are here today. They were still denied access and a inspection. I knew that would happen and we predicted it. All this controversy created today's VY and Vermont's defined relationship through a new MOU made in the outcome of this.

I am always shocked with what information small and insignificant problems have contained in them. Insignificant problems open up our eyes and minds up to the wider world. Insignificant problems might contain very little risk at first blush, but they are chocked full with information about the current organization status and it is very predictive of the future behavior of the staff. It would be months before they confronted the problems with the DG roofs. We discovered the roof had aged out and they had come to the end of their life. A industrial flat roof only has a 20 life span...we were way past this point at VY. Vermont Yankee then went on a campaign to replace all their roof's site wide within the next year. I talked to the roof contractor, he said the plant never spent a lot of money on constructing the first roof.

Additionally, this represented an era of the 1960s and 1970s nuclear construction boom, now where the roofs of many facilities were wearing out. It is absolutely amazing how much information a insignificant problem carries...it is chocked full of data. Many plants were facing site roof end of life and many more would face this crisis in the short upcoming years.

It was my last view of the front side of Vermont Yankee between the turbine office area and the front security gate. As we walked by the start-up transformers, I was being escorted off site for the last time with a security guard and a high Vermont Yankee official. We watched and I pointed out to my friends I knew for many years, "you catch that professional roof crew and their equipment putting tar and sheet paper up on the Diesel Generators roof. The NRC finally gave VY a do or die on immediately replacing this roof. You want to know another problem I fixed, I got them to build that new multimillion dollar security building gate 1 through a tip from another senior security force employee and the begrudged help of the NRC.

I never worked for Entergy, but my direct boss who fired me from Vermont Yankee is now the highest nuclear official in Entergy.

So the conversation with the flustered special NRC investigator began at 2:00 pm on 6/28  and then ended like this. How many roof leaks does Palisades have now?Inspector: Palisades has numerous roof leaks. But none of buildings and their areas are safety related .Then began the inspector, "I have to get off the phone now". He was persistent with quickly ending the conversation. He mentioned nothing about  NRC Office of Investigations. I was disappointed we couldn't talk as long as necessity for me to gain a understanding on what was going on at the site.

So what is a nuclear safety related roof? Is the roof above the emergency diesel generators or control room a critical nuclear safety related barrier.

Please list all the current roof leaks and their locations at the Palisades nuclear power plant? I'd like a discussion if there are safety related components near the leaks. And list all the roof leaks at the Palisades plant in the last five years. Is the trend of roof leaks increasing or decreasing...is Palisades quickly and properly evaluating roof leaks and are they repairing them in a timely manner?

In the light of the new revelations on the disgraceful latest third party safety cultural survey at Palisades, how in the world did the NRC and the 2.206 petition board get away without answering my past concerns about all the Entergy and NRC processes that failed to detect the real obscene safety culture and fix it? Not detecting the real safety culture attributes or making believe Entergy had a good safety culture I consider as fraud and a federal falsification at both the NRC level and Entergy. I consider it as a known and intentioned illegal behavior. How can the NRC get away with not answering these grave "active" safety concerns, which everyone knew I was expressing a truth? How could they allow this plant to run with such a impaired employee safety culture...how did this agency risk damaging the nuclear industry in such a way? " From past 2.206s) 13) Request a independent outside investigation over the insufficient process outcome of the 2008-2009 Palisades security falsification, investigation, safety survey local and fleet wide training and safety surveys. Based on the DC root cause it appears the safety culture for many years has been grossly defective and ineffective, along with the ROP... with then all these processes failing to discover the true depth of Entergy's safety cultural problems and they lied about these processes fixing Entergy. It sounds like this is a generic problem to me. We are broadly are 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 these 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 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.

...And all of Entergy’s and the NRC’s promises to the community post red finding and in community meetings has been found to be meaningless promises in the light of the Safety Injection Refueling Water tank leak. All of the ROP and NRC recent meeting about the troubles with the Palisades plant has been a intentional scam to deceive the public. The intent of this activity by both the NRC and Entergy has been to weaken the nuclear industry as a national security energy-electricity resource. 1) Request Entergy be prevented from starting up until all the safety problems at the site has been publicly identified and the safety culture repaired.

2) Heads need to roll in Region III and at headquarters, for tolerating and covering up these very serious safety problem at Palisades and throughout the Entergy organization. This all has the potential to gravely damage our nation.

3) Request top Palisades Management staff be fired and replaced before startup.

4) Request Entergy's corporate nuclear senior staff be fired and replaced before the restart of the plants.

5) Immediately request two addition NRC inspectors to be assigned to Palisades plant, and to all the rest of the troubled Entergy nuclear plants. There seems to be a few plants of the bunch that behave themselves.

6) Request the formation of a local public oversight panel around every plant.

7) Request a emergency NRC senior official oversight panel with the aims of reforming the ROP.

8) Request a national NRC oversight panel of outsiders to oversee and report on the agency's activities. There should be a mixture of professional academic people and capable lay people.

9) There continues to be some heavy duty and exceedingly numerous findings of problems with Entergy plants' this inspection reporting cycle...do an analysis of why this is occurring.

10) Request a evaluation if NRC region III has enough personnel and resources.

11) Request a report on why the 2.206 petition process failed so utterly for us...for the agency to hold officials accountable to the plant employees and me with not doing their jobs in trying to understand what was going at the site and not repairing the organization at the earliest point. I say again, the whole Entergy organization is involved and they have huge costly hole to dig out of. It is much easier digging the hole, than crawling out of one.

12) May I please have a meeting with the Palisades inspectors and other inspectors to discuss the conditions of Palisades before the petition board pre-hearing.

Sincerely,

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

Jan 10, 1212: Request Emergency Palisades Shutdown

help

New 6/ 27@ 2:245pm: The special NRC  SIRW inspector says Palisades has numerious other roof leakages.


I am trying to get Congressman's Markey's letter up on my blog. The PDF form is throwing me off.

http://media.mlive.com/kzgazette_impact/other/06-22-2012_LettertoNRC_Palisades.pdf


The Honorable Greg Jaczko Chairman

Nuclear Regulatory Commission 11555 Rockville Pike

Rockville, MD 20852

Dear Chairman Jaczko:

I am writing to you regarding the June 12, 2012, shutdown of the nuclear reactor at the Palisades Nuclear Power Plant located on the southeastern shore of Lake Michigan near the city of South Haven, Michigan. I am concerned that the cause of the shutdown, a leak in a water storage tank that was dumping gallons of water into the reactor’s control room, had been known to the plant licensee and to the U.S. Nuclear Regulatory Commission (NRC) for approximately one year, yet the leak was not repaired and, in fact, worsened, leading to the recent shutdown.

On June 12, 2012, Entergy Nuclear Operations, Inc. shut down the reactor due to a leak in the safety injection refueling water storage (SIRW) tank.l The 40 year old aluminum SIRW tank, which contains a minimum of 250,000 gallons of water, is a source of borated water (water that contains boric acid) for activities during refueling outages-the borated water floods the reactor cavity to cool the reactor when the plant's nuclear fuel is replaced. The tank also supplies the Emergency Core Cooling Systems and the Containment Spray System during emergencies.

The plant operators commenced the shutdown when the SIRW tank leakage exceeded the limit of 31 gallons per day established for the operability of the tank; the leak reached 31.4 gallons per day. The Event Notification report stated that “The licensee believes that the tank is leaking from several locations. However, at this time, they carmot determine exact locations. The refueling water has minor tritium contamination. The refueling water is being collected in a reservoir and then pumped into a holding tank. The licensee will be shutting down to cold shutdown.”2

I became aware of this SIRW tank leak and ensuing plant shutdown on June 14, 2012, when I received a letter from Billie Pimer Garde of Clifford & Garde, LLP (Attachment 1). Ms. Garde informed me that the leak had been observed during a June 30, 2011, NRC inspection and subsequently documented in an August 3, 2011 inspection report3 which stated that “The issue was more than minor because it impacted the equipment performance attribute of the Mitigating Systems Cornerstone, whose objective is to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.”

_____________________

Preliminary Notification of Event or Unusual Occurrence - PNO-lll-l2-O04 2 http'./Jwww.nrc.govlreadíng-rm/doc-collectionsfevent-statusfevent/2012/20 l206l3en.html 3 Palisades Nuclear Plant Integrated Inspection Report 05000255f20l

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Despite that assessment by the NRC, Ms. Garde has informed me that in the year following the inspection the leak had been continuous and increasing, leaking into the plant’s Control Room and Auxiliary Building. A number of concerned individuals contacted Ms. Garde in order to alert her to water leaking into the plant’s Control Room and Auxiliary Building. I was extremely alarmed to learn that she was told that the water was radioactive and being captured in “catch basins” with radioactive waste designators attached.

As you know, Palisades, which is one of the ten oldest nuclear plants in the U.S., has suffered a number of safety problems in recent years. In 2011, Palisades underwent five unplanned shutdowns. In the first six months of 2012, four off1cia1NRC enforcement actions have been issued.4 Furthermore, earlier this year, the NRC characterized Palisades as one of the least safe nuclear reactors in the country. The NRC assigns nuclear reactors to one of five categories based on their safety perfonnance. Earlier this year Palisades was downgraded to the third categoryf a status currently shared only by two other reactorsf and only one reactor in the country ranked lower.7

Given the troubled recent safety history at Palisades, I am very concerned to learn of yet another problem. My concern is compounded by the fact that this leak was known for approximately one year during which the licensee’s response consisted of little more than collecting the water in a pail. I therefore ask that you address the following:

1. The June 14, 2012 Preliminary Notification of Event or Unusual Occurrence states that the licensee is investigating the cause of the leak and evaluating what repairs need to be completed prior to restarting the unit.

a. If that investigation is complete, please provide the results. Have the necessary repairs been made? If not, when will they be performed? How and when will the NRC verify that the repairs have been completed? b. If that investigation is not complete, what is the expected completion date? 2. When were the effects of the leak into the Control Room and Auxiliary Building first observed by the licensee? How was it decided that the leak did not warrant further inspection or repair? After the NRC’s June 30, 2011 inspection, what steps did the licensee take to address the leak? What actions did the NRC take to follow up on the status of the leak? When did NRC staff first receive information regarding the source of the leak into the Control Room and Auxiliary Building? Please provide copies of all documentation related to the discovery, monitoring, or remediation of the leak.

3. Was the leaking water ever tested for radioactivity? If so, when and what were the results of the test(s)? If it has not been tested, why not?

4. Please describe the nature of the “catch basin(s)” that is/was being used to collect the leaking water? Was this basin affixed with radioactive Waste designators? Where was it

_________________________________

4 http1//www.nrc.gov/reading~rm/doc~collections/enforcement/actions/reactors/p.htm|#Palisades

5http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/actionmatrix_summary.html#am_summary

6 The Perry Nuclear Power Plant‘s Unit 1 generator near Cleveland, Ohio, and the Susquehanna Nuclear Power Plant's Unit l generator in Berwick, Pennsylvania

7 The Browns Ferry Unit l near Athens, Alabama located?

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Located? How closely is this “catch basis” located to stations where employees of the facility typically sit or are stationed?

5. How was the collected water disposed of each day prior to the June 12, 2012, reactor shut down?

6. Entergy spokesperson Mark Savage has stated that they will "Shut the reactor down - which we’ve done, unload the water from the tank, the leak, repair the leak, flll it up again and start the reactor back up." 8 Has the water been disposed of yet? If so, how? lf not, when will it be disposed of and how? 7. It has been reported that water was observed leaking in the control room. Have inspections been performed to determine if leaks are present in areas not immediately visible, for example, behind walls, into electrical panels, etc.‘? If yes, what was inspected and what were the results of those inspections? If no such additional inspections occurred, why not?

8. Ms. Garde informed me that on April 5, 2012, Palisades executives and NRC officials received a briefing on the results of a Safety Culture assessment that was performed by an outside consultant. Ms. Garde shared several alarming findings of this assessment, including:

• 74% of respondents said they do not believe that they can openly challenge decisions made by management.
• Only 65% of respondents feel that management wanted concerns reported.
• 32% of respondents believe that management tolerates harassment and retaliation for raising concerns.

a. Please provide a copy of the final Safety Culture assessment report entitled

“Palisades Nuclear Power Plant Safety Culture Assessment 2012” and dated

April 1 8, 2012.
b. Please provide a copy of the presentation entitled “Palisades Nuclear Power Plant Safety Culture Assessment Results, dated April 5, 2012, and any other information from and about that assessment.

c. What action is the NRC taking in response to this Safety Culture assessment? How is the NRC ensuring that Palisades is taking appropriate actions in responding to the problems identified in the Safety Culture assessment?

d. What action did Entergy take in response to the safety culture findings?

Thank you very much for your consideration of this important matter. Please provide your response no later than close of business Friday, July 13, 2012. If you have any questions or concerns, please have your staff contact Dr. Makenzie Lystrup or Dr. Michal Freedhoff of my staff at 202-225-2836.

Sincerely,

Edward J. Markey

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Law office

CLIFFORD & GARDE, LLP

June 14, 2012

The Honorable Edward J , Markey, Ranking Member House Natural Resources Committee

2108 Rayburn House Building

Washington, D.C. 205 I 5-2167

RE: Palisades Nuclear Power Plant

Dear Congressmen,

The Palisades Nuclear Power Plant is located in Michigan on the southeastern shore of Lake Michigan. It is one of the nation’s older Pressurized Water Reactors (PWR), licensed originally in 197], with the license renewed in 2007. The license to operate is currently held by Entergy Nuclear Operations, lnc. It is under the regulatory oversight of Region IlI of the Nuclear Regulatory Commission (NRC). On Tuesday, June l2, 2012, Palisades was shutdown when a leak of water exceeded 31 gallons per day. The leak has been constant and grown in size for at least the past year. And, this is not a minor leak. Last summer it was estimated at l5 gallons per day, its origin unknown. In my view, what is most disturbing is not that there is a leak that went uncorrected for over a year, but where the leaking water was going. The water was leaking into the Palisades nuclear power plant control room! 2

This is the latest in a series of unfortunate events at Palisades over the past several years, including an event in September 2011 during which the plant lost partial electrical control due to a decade

_____________________________

I It had been reported to me that the water was radioactive, and being captured in catch basins with radioactive waste designators attached.

2 I bring these issues to your attention because the Office of the inspector General of the NRC has proven itself to be completely useless in addressing any issues that question the competency, judgment, or decisions ofthe technical staff in carrying out its obligations. See, in particular, my letter of June 9, 201l, to NRC Chairman Gregory Jaczko regarding the OIG actions in failing to address, if not deliberately covering up, the Staffs failures in regulating serious issues at the Byron nuclear power plant in Illinois, also located in the NRC’s Region III. To the best of my knowledge, no action was taken as a result of the Byron situation, and no action has been taken with respect to the OIG. Thus, without any reforms there is no point in bringing issues to the OIG.

3 In 2010, the NRC issued Notices of Violations for failing to meet specific requirements For fuel storage in the spent fuel pool, specifically a fuel pool storage rack neutron absorber had deteriorated over the life of the plant to less than required. In January 2012 the NRC issued a Notice of Violation for failing to require inspections on aging equipment on the turbine driven auxiliary feedwater pump, which was inoperable from October 2010 to May 20l l. In December after an operator left his controls during a heated argument, without a proper turnover' to a

Page 5

old, unidentified design Haw. Only the Operators excellent reaction saved the plant, and southeastern Michigan, from a catastrophic accident. New issues are now identified, including a complete collapse of its safety culture, that raise serious questions regarding whether the NRC should have reasonable assurance that the Palisades plant is able to operate in a manner that adequately protects the public health and safety.

This letter is to request your assistance in investigating and addressing the NRC’s lack of adequate attention on serious issues at Palisades that it has found acceptable and tolerated

 UNKNOWN LEAK OF WATER

One of the issues that the NRC has apparently tolerated is a growing leak of water into the Control Room and Auxiliary Building. When I learned of this concern from a number of Concerned Individuals (Cls) I contacted the NRC to inquire what, if any, knowledge that the NRC had about this leak and what action it had taken to address it. I was told that the leak had initially been identified last fall and was slated to be repaired during the recently completed outage. However, the NRC Staff conceded it was leaking again at 20 gallons a day. I was told that the information about this leak was reported in Inspection Report 05000255/20l 1003, and that no further information was publicly available. I Was assured that the NRC was Satisfied with the plant’s actions with respect to the leak. In the meantime the leak continued to grow and be caught in a “catch basin.” (A recent news states that the NRC “was made aware of the leak in April when the plan! was shut down for refueling.” Kalamzaoo Gazette, June 14, 2012. That is not true.)

I then reviewed the August 3, 201 I inspection Report (Palisades Nuclear Plant Integrated Inspection Report 05000255/201 1003) and the regulatory discussion about the leak. According to the Inspection Report, the Licensee represented to the NRC that it had identified “water leakage from the ceiling in the control room during a period of heavy rain.” (Inspection Report, at p. I6) Upon further investigation the Licensee apparently identified that Water coming through a series of concrete walls, or Catacombs, that support the Safety Injection and Water (SIRW) tank sitting on the roof of the Auxiliary Building which contains both trains of emergency core cooling System suction piping from the tank. It also identified boric acid and concrete washout on the floors, ceiling and some of the piping. The areas had not been inspected since at least l995.

In December 2011 an operator left his controls during a heated argument, without a proper turnover to a qualified individual or without obtaining permission from the Control Room Supervisor, the NRC issued a Confirmatory Order to Entergy on January 25, 2012. On February I4, 2012 the NRC issued another Notice of Violation for failing to verify the adequacy of the safety-related service water pump. Additionally, on February I4, 2012 the NRC issued a Notice of Violation for failing to ensure that work done on September 25, ZOE I was done in accordance with proper procedures and instructions, resulting in a deficiency that caused the loss of the left train 1l25-Volt DC safety- related system and loss of both preferred AC sources associated with the left-train system, the DC bus issue.

4 I note that the NRC issued a Confirmatory Order on January 25, 20I2 which required Entergy to, among other things, to conduct a “safety culture assessment” within 180 days of the order, Entergy agreed as part of the Confirmatory Order to make the results of the assessment available for the NRC inspection, Entergy agreed “to address any relevant observations, findings, or recommendation in its Corrective Action program ” Confirmatory Order, at ppg,, pg.6. Thus, it is noteworthy to point out that the decision to conduct a survey was not because Entergy realized it needed one, but because the NRC did.

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The inspection report states that the “(d)etermination of the source of the leak was still underway.” Although the the report briefly mentions water coming down the walls and into the control room and auxiliary room, the report is silent about the source of that water or whether it was radioactive. That report is the only public record of this leak. The report does not indicate any planned follow up by the NRC on this issue. This leak apparently did not alarm the NRC; last week when I advised it of the concern that had been brought to my attention by plant employees, the NRC staff attempted to convince me that the leak was not a problem.

It is beyond comprehension what the NRC has been doing over the past year on this issue. How can a growing leak of potentially radioactive water, from an unidentified source, leaking into the control room and auxiliary building and being captured in “catch basins” possibly be considered appropriate by the NRC staff? it goes without saying that large amounts of water,whether radioactive or not, leaking into and around the control room of a nuclear power plant could result in unanticipated widespread damage to the functionality of the control room infrastructure and circuitry? It should be pointed out that the initial l5 gallons a day, then 20 gallons a day, only reflects the measure of observable water into the areas of the control room that were visible. How much more water was seeping or leaking into areas of the control room that were inaccessible and obstructed, i.e., behind walls, into the electrical panels, impacting control systems?

A review of the publicly available records raises significant questions about the competency of the staff and its judgment at yet another poor performing Region III plant. It seems to me that either the Licensee staff made a misrepresentation to the NRC during the August 201 I inspection about what it knew, and when it knew it, regarding the source of water leaking down the walls of the Auxiliary Building, and into the Control Room, i.e., it was just heavy rain water; or the NRC itself is playing a shell game about the leak and about what information is included in the inspection report. Given the poor regulatory status of Palisades, one more problem could have easily forced a plant shut down. I cannot comprehend under what circumstances a leak of this magnitude, coming from an unidentified and unanalyzed source, running down the ceiling and walls of the Auxiliary Building and/or Control Room would be considered an acceptable risk for continued operations. What are the Palisades requirments and NRC regulations that address control room operations and habitability risks in the face of this leak?

If there was a competent internal inspector Generals office that could review the actions of the Region III staff with respect to this matter, I would bring it to their attention. Unfortunately for the public, the NRC’s Office of Inspector General has stopped doing any meaningful work on issues of public heath and safety significance, so it is again up to Congress to provide the oversight and accountability to ensure safety is the overriding priority.

PALISADES SAFETY CULTURE

The situation at Palisades is particularly serious because it has recently been confirmed that the site’s safety culture is at an industry low. On April 5, 2012 the site executives received a briefing on the results of a Safety Culture assessment performed by a credible third-party consultant. The NRC Resident Inspectors were in attendance at this briefing. Even though the NRC was advised of the results, they did not take or ask for a copy of the presentation or the report from the meeting. The Region took no action.

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In fact, as far as I can tell, the NRC did nothing at all except continue on the path it was on - to expect this poor performing plant to cure itself.

Data from the survey reveals that 74% of the almost 600 respondents do not believe that they can openly challenge decisions made by management. In some departments no one believed that was a possibility. Only 65% of the respondents, that is an average with some departments at over 90% negative -- agreed with the statement that management wanted concerns reported. 32% of the respondents believe that management tolerates harassment and retaliation for raising concerns. Even the numbers for the management team are abysmal. As stated in the report:
“All organizational work groups had consistently low scores with respect to, most of the survey statement related to Safety Conscious Work Environment. The pervasiveness and consistency of the results is clearly on area in need of attention.”
This is more than alarming. The NRC shut down the Millstone nuclear plant in 1996 when survey results revealed about 10% of the employees were fearful of retaliation for raising concerns. In this ease, the results of the survey reveal a work force that is “chilled” to the point of immobilization. Yet the NRC resident staff sat through a briefing ofthe results of this survey and did nothing. The plant continued to operate, water continued to pour from the ceiling as employees walked by it every day, and the NRC simply continued to plan for inspections at their convenience, and allow the Licensee to figure out what to do. The NRC did not even obtain a copy of the final Safety Culture report. it seems to be not only the height of regulatory irresponsibility for any plant, but regulatory negligence at a troubled reactor where such serious problems are obvious.

Long before the NRC had regulations, policy statements or guidance about Safety Culture a group of Quality Control inspectors dumped a bucket of urine on the head of a whistleblower at the Zimmer nuclear power plant then under construction in Ohio. The next day the Region III Administrator at the time shutdown the plant, and locked the gate until he had confidence that the workforce understood the expectations of the NRC. Although Zimmer was never completed, the issues that plagued that plant resulted from a decade of bad management and a broken safety culture. in 1996 the NRC took similar action at the Millstone plant in Connecticut. The Palisades survey results, coupled with the operational issues it has faced, and the impact of poor management on its workforce has placed the plant in a dangerous situation. A high percentage oft the work force had said that it doesn’t understand its own responsibilities towards nuclear safety, and those that do are afraid to raise concerns. The plant should not be allowed to operate until the issues are fully aired publicly and the plant is required to undergo a significant recovery plan - at least as strenuous as the Millstone recovery was, since the results of the recent Palisades survey are much worse.
____________

5 I note that Palisades is the subject of an upcoming NRC special inspection; but, results from this survey are so had that it should have generated immediate and significant regulatory action. The foundation of the NRC’s regulatory structure is the belief that all nuclear power plant personnel acknowledge their personal responsibility to ensure nuclear safety, as well as the willingness to raise concerns without fear of reprisal. Neither of these factors exists at Palisades right now. The NRC’s decision to wait six months to perform a special inspection leaves everyone at risk of the consequences of a failed culture.

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NRC NEGLIGENCE

This is a sad reflection on the NRC, which has been working hard on the issue of Safety Culîure. It is not enough to have a handful of good policy people at headquarters, which it does have. The NRC must be required to demonstrate that all the resident inspectors are competent and qualified to perform theirjobs and to identify and respond to precursors and indications of failed safety culture and serious degradations in work environments. This has been a concern to me for some time. Nuclear engineers are not experts on safety culture and often have no clue about what to look for or be eoneerned about in this area. On February 9, 2012, E testified at a Commission meeting on the “Views on industry Activities Related to the NRC Safety Culture Policy Statement.” ln that presentation identified that more work was needed by the Staff in some areas, specifically :
“More staff training needed in recognizing and identifying safely culture precursors. Resident inspectors are the first line of defense, but are often the most overworked and least trained in recognizing safety culture issues.
Prepared testimony of Billie Pirner Garde, February 9, 2012.

The NRC staff was quick to take exception to my statement, Bill Borchardt, the NRC’s Executive Director of Operations (EDO) stated in response to questions by the Commissioners that;
“... There is no position within the NRC the is more well positioned to identify safety culture issues that the resident inspector and they have been ....very sensitive to those issues, and the ROP has provided a vehicle to get that more clearly defined in regulatory space. Having said that, there is also the balance that this is a policy statement and nor a regulation, so we are mindful that we are not regulating safely culture as much as using it as a way to inform our other regulatory activities, to make sure that safety is enhanced and at the highest level possible. with the licensees... ”
Testimony of Bill Borchardt, p. 69-70. Other staff members chimed in to defend their position that resident inspectors were competent and qualified in this area, and no regulation was needed.

Unfortunately, the Resident Inspectors at Palisades apparently “did not get the memo” that the safety culture survey showed a complete collapse of the plant’s culture and deserved more than just casual consideration, and inclusion in the next inspection In this ease, I am reminded of the infamous “red photo” of leaking rust colored boric acid that was given to the resident inspector at Davis Besse by a concerned systems engineer and sat on his desk for years as that plant avoided a near miss from a football size hole that had rusted in the reactor pressure vessel head. Had an accident occurred at Davis-Besse, or if there was an accident as a result of a catastrophic incident at Palisades, it would be the end of the nuclear industry in this country. The OlG’s investigation of the Davis-Besse matter confirmed that the resident inspector completely dropped the ball by failing to understand or follow up on the significance of the event. (See, generally, NRC OIG Event Inquiry, case No. 03-02s, October 17, 2003.) In this case, as in Davis-Besse, there was no comprehension and no sense of urgency exhibited by the Resident Inspector to the information he learned on April 5, 2012. I attribute that to a lack of appreciation for the significance of the results he was privy to, and a degree of ignorance of the types of appropriate actions that should have happened immediately, ie., stand downs, public expression of unacceptability of the

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results, immediate messages to the workforce about retaliation, stop works, accountability for raising concerns, and formal and complete notice to the NRC. This is an unacceptable situation and needs to be addressed.

CONCLUSION

This is but one more example of the problems at the NRC lately. The entire situation at the Agency has reached levels that require congressional intervention and oversight, not just to address internal political squabbles, but focus on the work of the Agency - starting with replacing the inspector General and his Deputy so that office can once again function to be the internal watchdog that should be responding effectively to these types of regulatory mishaps. I strongly urge you to consider these matters and take appropriate Congressional action.

Please feel free to contact me for additional information.

Billie Pirner Garde

cc: Gregory Jaczko, Chairman

Kristine L. Svinicki, Commissioner George Apostoìakis, Commissioner Wilìiam D. Magwood, IV, Commissioner Wiäliam C. Ostendorf, Commissioner U.S. Nuclear Regulat