Heat Sink Temperature NOED and License Amendment Request Were Unforeseeable

From: "Stuchell, Sheldon"
To: "steamshovel2002@yahoo.com"  
Cc: "Bahadur, Sher" ; "Burnell, Scott" ; "Wertz, Trent"  
Sent: Tuesday, August 28, 2012 5:10 PM

Subject: EMAIL DATED JULY 14, 2012, REGARDING U.S. NUCLEAR REGULATORY COMMISSION (NRC) ISSUANCE OF WEATHER RELATED NOTICES OF ENFORCEMENT DISCRETION (NOEDS)

Dear Mr. Mulligan:

This e-mail is in response to the concerns you brought to the attention of the NRC on July 14, 2012, regarding an increasing trend in the issuance of weather-related NOEDs. Specifically, you were concerned about the larger implications of the NOED request concerning a potential industry trend in plant operational challenges due to environmental issues, whether the NRC was reviewing this trend, and what actions were being considered around the country with regard to licensee’s increasing their UHS capacity to address hot weather conditions. Because your concern contained possible safety issues with NRC-regulated activity, your emails were forwarded to my office for review.

The NRC expects all nuclear power plant licensees to operate their facilities safely and in compliance with NRC regulations, the plant license, including technical specifications (TS), and other requirements. Nevertheless, circumstances may occur in which explicit compliance with an NRC requirement could result in an unnecessary plant transient or unnecessary delays in plant startup, or the performance of a test, inspection, or system realignment that is inappropriate for the prevailing plant conditions. 

There are two types of NOEDs: (1) “regular” NOEDs and (2) “severe weather or other natural phenomena-related” NOEDs (severe-weather NOEDs). Requests for “regular” NOEDs involve consideration of the radiological health and safety of the public. Requests for “severe-weather” NOEDs involve not only the consideration of the radiological health and safety of the public, but may also consider the potential impact on public health and safety because of power delivery challenges.

On July 7, 2012, the NRC considered and approved a request for a weather related NOED. The evaluation of this request was performed by NRC staff from various technical specialties to ensure the radiological safety of continued operation. This request for a NOED was approved. 

This was the first weather related NOED request in 2012, and the first in the past 10-years based on a search of NRC records. The NRC takes public health and safety very seriously and will only approve a NOED request if the NRC staff finds continued operation of a nuclear power plant safe.

The NRC reviews all granted NOEDs to ensure that the NOED process is completed in accordance with the NRC Enforcement Policy and to determine if adverse trends are noted. At this time, we do not find it necessary to initiate any further actions.

Concerning other licensee-specific issues you raised in your e-mails, specific questions concerning licensees are the responsibilities of the regions and, if appropriate, the regions will provide a response.

Thank you for informing us of your concerns. Should you have any additional questions concerning NOEDs, or if we can be of further assistance to you, please contact me at (800) 368-5642.

Sincerely,
Sheldon Stuchell
Sheldon D. Stuchell, Acting Chief
Licensing Processes Branch
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation

Mr. Stuchell,

And you call yourselves a scientific based organization and scientist?

The NOEDs don't require a nuclear plant to submit heat sink temperatures trends over a long period of time. The NRC doesn't make them admit our heat sink temperatures have been increasing for years and we aren't required to admit we seen the train coming while we were on the tracks and we were too stupid to move out of the way so it hit us. 

The NRC is using stupid selective information to reject my allegation...

You are defending the agency actions with inaccurate and incomplete information...

Millstone and NRC falsify's documents in order to keep plant at power

Millstone looking to adjust operation to warmer wate 

By Judy Benson
Temperature data collected by environmental scientists at Millstone shows average temperatures of the waters around the plant have risen by 0.67 degrees per decade since 1976, Holt said. In 1976, the annual mean temperature was 51.6 degrees, compared to 53.4 degrees in 2009. 

...WATER TEMPERATURE, THEN AND NOW
Temperature data collected by environmental scientists at Millstone shows average temperatures of the waters around the plant have risen by .67 degrees per decade since 1976, Holt said. In 1976, the annual mean temperature was 51.6 degrees, compared to 53.4 degrees in 2009. The mean temperature in August 1976 was 67.3 degrees, compared to 69.8 degrees in August 2009. The next year, the temperature went still higher in August. In a 2010 annual environmental report, Millstone scientists noted that April and May of that year had the warmest temperatures on record, and that the mean August temperature was 70.3 degrees.
Last year, the mean August temperature was slightly lower, 69.9 degrees, while the annual mean for 2011 was 53.8 degrees.

Impacts of Climate Change on Chicago Expected to Increase in Coming Decades( Sept 18, 2008)

Already, emissions of heat-trapping gasses have changed Chicago’s climate. The city’s temperatures have risen by 2.6 degrees Fahrenheit since 1980, 4 degrees in winter. In 15 of the last 20 years, meteorologists have seen above-average annual temperatures. Many of the defining characteristics of the city are being altered, including more frequent heat waves, warmer winters and a doubling in the amount of heavy rainfall events

Great Lakes water temperatures at record levels
July 24th, 2012

Data shows a long-term warming trend throughout the Great Lakes, which may be related to manmade climate change. According to George Leskevich, a physical research scientist with the Great Lakes Environmental Research Laboratory in Ann Arbor, Mich., there is also a long-term downward trend in Great Lakes wintertime ice cover, although there is considerable year-to-year variability. 

The all-time daily average high temperature record for Lake Superior is 71°F, which was recorded in mid-August 2010. With a few more weeks of warming left, that record is in jeopardy. 

“The season hasn’t played itself out yet and we’re already within 3 degrees of the all-time daily record surface temperature,” Austin said

Of course, the climate around Millstone wasn't the hottest since 1895...it was just the 9th hottest summer this July. 

I just want everyone to stick to the facts and be truthful, not play pretend to keep you out of trouble and no one has accountability...

If everyone plays pretend, then one day a lot of Exelon's nuclear power plant's end up sitting on the edge of shutting down during a heat emergency and the fossil plant's discharge damaging amounts of heat to the waterways as we climb up the results of climate change. Just like we did this year. 

And I will make the case if you start fudging 8ths of a degree temperature of heat sink water to keep a plant up at power in heat wave...the end result of the lying and cheating will damage the safety culture of a plant (and NRC) and that will be the reason why the plant gets into a lot of trouble not related to the heat sink temperatures ("frog boiling"). 

You are giving these utilities under false pretenses unjustified NOEDs and licensing amendments request...it is illegal to submit the falsified documents. You haven't done your jobs through the years with alerting the American public that heat sink temperatures, low flows and levels are becoming a direct threat to our nation...we better act before we all get into trouble! Here are our emerging problems and we better fix them as a nation.

Braidwood and Millstone should have been prepared for this summer and they should have had lots of excess cooling capacity. That would be a great government agency preparing us for this day and you failed miserably! 

And don't get me talking about lying green energy and their electricity... 

You are lying and giving false testimony to the American people through playing word games and rules gaming! You are not helping the American people to deal the with creeping temperatures and thus setting up a future crisis.

You should have told Braidwood and Millstone to drop dead...you guys should have seen this coming. You should have given this signal to the rest of the plants...we won't bail out your stupidity and negligence...we wouldn't tolerate you not protecting and covering your communities... 

Thanks, 
Mike Mulligan 
Hinsdale, NH

...Of course, the climate around Millstone wasn't the hottest since 1895...it was just the 9th hottest summer this July.

I just want everyone to stick to the facts and be truthful, not play pretend to keep you out of trouble and no one has accountability...

You are lying and giving false testimony to the American people through playing word games and rules gaming!

...So this what is going on around the Braidwood plant and I am sure if you cared to look the same thing would be seen on the plant's environmental and heat sink summertime temperatures.

I think all LARs and NOEDs should be completely truthful and complete in all aspects...Braidwood and Millstone should have admitted in their government documents the day of reckoning was knowingly being approached. Exceeding the limits was completely foreseen and knowable....and they failed to act placing them in this completely preventable operational emergency. The NRC should have rejected the LAR and the NOED as being incomplete.

So it is the agency's ethical policy that NOEDs and emergency LARs need only contain incomplete information, which only bolsters the utilities and NRC's actions.

I think the NOED and emergency LAR rules and procedures were intentionally misused on the NRC's and nuclear plant documents!

How you play altruism in the NOEDs and the Emergency LAR is a moral hazard of extreme potency...

"but may also consider the potential impact on public health and safety because of power delivery challenges."

You don't create societal safety by violating important engineering principles and telling half lies in order to prevent power delivery challenges.

Societal safety and security is much broader issue....credibility and nuclear safety is only obtainable if the NRC and utility tells the whole truth of why you want to diverge from tech specs and plant licencing. If  you are covering up why you really need a NOED or emergency LAR...then how can we trust you when you say a plant is safe and this problem is no big deal. Lying and telling only the half truths over a plant event even if technically safe, lends you into destroying the culture of trust and valuable in relationships between humans. I think the culture of trust and relationships...communications...is much more important than all the nuclear emergency diesel generators and emergency core cooling systems. That is the engineer's centric ideation that gadgets are more important  than humans...cheapshakism...I say human relationships, communications, integrity, intelligence and trust are far more important than any gadget.  

 The NRC takes public health and safety very seriously and will only approve a NOED request if the NRC staff finds continued operation of a nuclear power plant safe.

I don't think it is safe for us to have a enormous amouns of electric capacity sitting on the edge of a shutdown in climate change because of inadequate plant investments and insufficient cooling capacity...even if nuclear wise, we are safe. I think it is the NRC's job to help us see this problem.   

...And the highest existential order...I will have faith in government in a national crisis. That I will have a reservoir of a relationship with my government...that I will trust what the government says in a national crisis. If I can't trust my government over talking about nuclear plant issues...how could I trust them in a bigger crisis...