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