US power firms slam ISO NewEngland over market ‘flaws’

So a pack of power firms are circle the defenceless public doe.

US power firms slam ISO NewEngland over market ‘flaws’

Author: Alexander Osipovich

Source: Energy Risk| 18 Dec 2013

Market woes may threaten winter reliability, firms argue

Winter reliability at risk due to problems with real-time pricing, market participants warn

As the northeast US prepares for winter, electricity firms are warning that flaws in the design of the New England power market will threaten the reliability of the region’s power supply in the event of an extended cold snap.

No Accident Cameras in Nuclear Power Plants?

Asiana, MTA Metro North Crash and our nukes

Asiana captain 'very concerned' about making visual landing

By Martha Mendoza and Stephen Braun, The Associated Press

The pilot whose Boeing 777 crashed last summer at the San Francisco airport told investigators he was "very concerned" about attempting a visual approach without the runway's instrument landing aids, which were out of service because of construction, according to an investigative report released Wednesday...

So why aren’t our nuclear plants camera’d up and voice recorded? They might  be able to transfer the crash data over to the simulators so all the switch movements and dials and monitors redo the accident....but that is it.

But what if we had a new TMI…the public wouldn't have the camera images and voice to see.

Why is the nukes any different than out the airline industry?

I think the Nuke industry would behave better off if outsiders could see the control room.

Remember routine plant business and nodding off on shift would be invaluable information if recorded...

Pilgrim Plant: What Was Behind the Disclosure of the "Bridge Failure" and Shutdown?

Basically, they get away with violating the rules until the plant runs away from the staff and NRC!

We really got the national philosophy of ghost regulations and rules...  "translucent or barely visible wispy shapes rules" that come in and our of reality depending on if they are convenient to profits and plant viability.

1EP5 Maintaining Emergency Preparedness (71114.05 – 1 sample)

a. Inspection Scope

The inspectors reviewed a number of activities to evaluate the efficacy of Entergy’s efforts to maintain the PNPS emergency preparedness program. The inspectors reviewed letters of agreement with offsite agencies; the 10 CFR 50.54(q) Emergency Plan change process and practice; Entergy’s maintenance of equipment important to emergency preparedness; records of evacuation time estimate population evaluation; and provisions for, and implementation of, primary, backup, and alternate ERF maintenance. The inspectors also verified Entergy’s compliance at Pilgrim with new NRC emergency preparedness regulations regarding: emergency action levels for hostile action events; protective actions for on-site personnel during events; emergency declaration timeliness; ERO augmentation and alternate facility capability; evacuation time estimate updates; on-shift ERO staffing analysis; and ANS back-up.

And blizzzard Nemo occured in Feb 2013 knocking out the Met Tower
 

During the 2009 NRC emergency preparedness program inspection, the inspectors determined that the 2008 quality assurance (QA) surveillance performed to justify exceeding the 12-month review frequency did not include an assessment against adequate performance indicators.

 The above on Feb 11, 2013

Swinging in the background before my Dec 3, 2013 contact beginning  at 10 am with Branch Chief Ray Mckinley was a important emergency preparedness "conference bridge failure" and leaking big turbine steam valve. They decided to shutdown to fix it later in the day. 

I leaving it to you to figure out if someone prompted me to make this call. I am uncertain the bridge failure would have been reported if it wasn't for my interest in this. I had talked to the Pilgrim NRC senior resident about this four or five days ago and I suspect senior inspector Max Schneider told his boss. They had failed to report on the Met Tower just recently and I am not sure how deep this goes. 

...I spent about an hour talking to this Ray M. Summed up the conditions in Region 1 and complained the agency has gone weak kneed on us with non cited violation at Indian Point, Seabrook and Pilgrim. I told Ray with the meteorological tower inop, the commissioner chairman came to Pilgrim saying they were one step from Fort Calhoun and we got enormous budgets problem-Natural Gas...now you are throwing out non cited violations like candy. We jostled about the tower being so out many times and the meaning of the national weather service. Told him he he’s got at least three senators gunning for the agency and they don’t need 60 votes anymore. I said you are using unjustly the NWS as a tool so you don’t have to site the plant. Your guys are going weak on us at a critical time.

He listened to me attentively and engage me...actually another guy I like. I am not saying he is on my side by a far shot.

Told him the big problem is you don’t have enough horsepower such that these plants don’t fear you enough and fear the day when they don’t tell you everything about their problems.

Power Reactor Event Number: 49605
Facility: PILGRIMRegion: 1 State: MAUnit:[1][][]RX Type:[1] GE-3NRC Notified By: PAUL GALLANTHQ OPS Officer: VINCE KLCO Notification Date: 12/03/2013Notification Time: 20:04 [ET]Event Date: 12/03/2013Event Time: 13:30 [EST]Last Update Date: 12/03/2013
Emergency Class: NON EMERGENCY10 CFR Section:
50.72(b)(3)(xiii)- LOSS COMM/ASMT/RESPONSEPerson (Organization):
WILLIAM COOK (R1DO)
Unit SCRAM Code RX CRIT Initial PWR Initial RX Mode Current PWR Current RX Mode1 N Y 100 Power Operation 82 Power Operation

Event Text

LOSS OF EMERGENCY COMMUNICATIONS CAPABILITY- EP CONFERENCING LINES UNAVAILABLE

"At approximately 1330 [EST] on Tuesday, December 03, 2013, while performing a table top drill, Pilgrim Nuclear Power Station (PNPS) discovered that EP [Emergency Preparedness] bridge conferencing lines were unavailable. The conference lines affected included the mitigation line, plant data phone, radiation data phone, emergency conferencing line, and the back up conference bridge line. Reviews to determine the cause of the event and efforts to restore the system are ongoing.

"The licensee has determined the Emergency Plan to be functional based on other communication methods that are available between onsite and offsite facilities. These include direct telephone lines, portable handheld radios, satellite phones and cell phones. Immediate actions to establish compensatory conferencing lines have been completed. On-going actions are in-progress to ensure procedure instruction is provided at each facility to enable use of the compensatory conference lines.

"At the time of this report, the plant is currently operating at 82% power due to a planned power maneuver unrelated to the reported communication event.

"The licensee has notified the NRC Senior Resident Inspector [and will notify the Commonwealth of Massachusetts.

During a table-top emergency preparedness drill earlier that day, staff discovered that the “bridge-conferencing” system that allows operators to remain in constant communication during an emergency wasn't working.

... So now we are talking about the pathetic widespread condition of the infrastructure necessary to reliable evacuate the public and notify the state in a meltdown or potential meltdown.

I am telling you the truth, I am certain today he is thinking WTF am I dealing with that Mr Mulligan?
Leaky valve causes Pilgrim plant shutdown

Dec 4

Representatives from Entergy Corp., Pilgrim's owner-operator, were offering a scheduled presentation to officials and residents at Plymouth Town Hall on Tuesday night, touting the nuclear plant's safety features and outlining post-Fukushima federal requirements for future improvement. 

During a table-top emergency preparedness drill earlier that day, staff discovered that the “bridge-conferencing” system that allows operators to remain in constant communication during an emergency wasn't working.

... I kept hitting him over and over ...why wasn’t the Met Tower reported to the NRC and the public. Why wasn’t it in an event report or as UE? Why didn’t the agency enforce this?

He never gave me a direct answer...so I would wait a few minutes and ask him the same question in different way. I did this at least three times.

So today we get this daily event report you see and shutdown on a steam leak...

No question about it, this guy was really intelligent. He had a lot of miles under his belt! He got what I was doing.

... This is for Entergy’s benefit.

So I called region 1 yesterday morning...their phone answering system is terrible. I get the regional administrator’s number and give the secretary a call. She gives me the number to the inspector’s boss. I leave a message on his telephone number. Right, I outline my past interest on this on the message recording, my complaint in their system...the issues I want to talk about with this. Maybe 10 am.

Then he called me back at around 2 pm...

I tell him right off the bat, I initiated your Met tower NRC inspection and the findings. He scoffs at this...no I said, I got it on your document system. You were responding to me complaint. Get a blah, blah, blah, my inspectors were working on that long before that, he said. I said, I doubt it, I waited for the LER and the inspection report, you guys were in la la land. You guys didn’t have a clue the met tower was out in blizzard Nemo and many times before that.

He was feeling me out if I had Pilgrim staff cooperation on it?

Just like his quick phone call back to me....he was wondering if I had cooperation on the phone bridge thingy being out yesterday and the upcoming daily event report. They probable had the drill in the morning table top. I wonder if he was wondering how much I knew about the steam leak.

... "conferencing lines” : is this entergy's property or the NRC's...or is it a private conferencing sevice?

Is this another thing we don't understand how it will perform in an emergency.

.. I talked about the new complexity we have with the national weather services with my boss buddy yesterday. We don’t understand how the communication lines are set up; we don’t have any understanding of the communications and computer junk in the National Weather Service, the organizational rules, their QA...

Right, we got a highly trained staff at the plant and we got a QA system over the whole deal. We got and dependent regulator who oversees everything. We don’t have that with the NWS. This is what supposed to make the met tower highly reliable.

Then he talks about there is very good procedures that allows using the NWS. I remind him, say you own a jet airplane and have the best and most expensive procedures in the world. Those procedures mean nothing unless the pilot is trained over and over again with how to operate the ship...and he says highly proficient at operating that craft.

Good procedures don't mean shit if they aren't tested over and over again in real world situations

.... A real accident might not use a conferencing line? Right, but then they wouldn’t have made it a NRC mandated daily event report.

Was the states involved with this boondoggle?

... His name was Ray Mckinley...he is the branch chief.

... Infrastructure issues continue to plague Plymouth's Pilgrim Nuclear

While officials briefed selectmen why Fukushima can't happen here, reactor had to be shutdown because of steam leak 

Read more: http://www.wickedlocal.com/plymouth/news/x182...

... Talked yesterday about the Palisades debacle. I would have thought Entergy would have learned from that painful episode. They were up and down a lot...very costly shutdowns...lost reputational points.

I thought they would never want to go that way again as a corporation...then we have the Palisades adventure all over again with Pilgrim.

I told Ray, this isn’t just about the Met tower...it was about a pattern of poor behavior at Pilgrim, back to Palisades...within Entergy for a very long time.

And they don’t seem to learn by their mistake...

.Feynman's Appendix to the Rogers Commission Report on the Space Shuttle Challenger Accident 

Conclusions 

If a reasonable launch schedule is to be maintained, engineering often cannot be done fast enough to keep up with the expectations of originally conservative certification criteria designed to guarantee a very safe vehicle. In these situations, subtly, and often with apparently logical arguments, the criteria are altered so that flights may still be certified in time. They therefore fly in a relatively unsafe condition, with a chance of failure of the order of a percent (it is difficult to be more accurate). 

Official management, on the other hand, claims to believe the probability of failure is a thousand times less. One reason for this may be an attempt to assure the government of NASA perfection and success in order to ensure the supply of funds. The other may be that they sincerely believed it to be true, demonstrating an almost incredible lack of communication between themselves and their working engineers. 

In any event this has had very unfortunate consequences, the most serious of which is to encourage ordinary citizens to fly in such a dangerous machine, as if it had attained the safety of an ordinary airliner. The astronauts, like test pilots, should know their risks, and we honor them for their courage. Who can doubt that McAuliffe was equally a person of great courage, who was closer to an awareness of the true risk than NASA management would have us believe?Let us make recommendations to ensure that NASA officials deal in a world of reality in understanding technological weaknesses and imperfections well enough to be actively trying to eliminate them. They must live in reality in comparing the costs and utility of the Shuttle to other methods of entering space. And they must be realistic in making contracts, in estimating costs, and the difficulty of the projects. Only realistic flight schedules should be proposed, schedules that have a reasonable chance of being met. If in this way the government would not support them, then so be it. NASA owes it to the citizens from whom it asks support to be frank, honest, and informative, so that these citizens can make the wisest decisions for the use of their limited resources. 

For a successful technology, reality must take precedence over public relations, for nature cannot be fooled. 

Dr. Feynman discusses his experience on the Rogers Commission as part of his second autobiographical volume.

...For a successful technology, reality must take precedence over public relations, for nature cannot be fooled.

You get it, the implication was the NRC was sitting on the steam leak to dress up the pathetic shutdown history of Pilgrim. But it's occording to the rules.
 

2013 Pilgrim shutdowns and glitches

Jan. 10-17: Both recirculation pumps tripped, followed by a head drain valve leak.

Jan. 20-24: Leaking safety valve.

Feb. 8-16: Winter storm, 169 hours down.

Aug. 22-26: All three main water pumps shut down.

Sept. 8-17: Steam pipe leak.

Oct. 14-21: Off-site power to plant unavailable because of NStar problem, which caused initial shutdown. Plant remained closed for two days after power restored because of faulty mechanical pressure regulator, which caused water levels in the nuclear reactor to become too high.

Dec. 4: Leaky steam valve. Reactor still down.

OTHER INCIDENTS

July 15: Loss of control room alarms. Plant stayed online. Alarms came back on with no explanation. Reason for malfunction never found.

July 16: Heat wave warmed seawater temperatures, forcing the plant to power down to about 85 percent intermittently. Federal regulation requires seawater, used for cooling the reactor, to be no warmer than 75 degrees.

Sources: NRC website and Entergy press releases

 

Hinsdale NH Route 119 Bridges Abandoned By NHDOT and Concord

It is interesting to think if the discovery and the 10 year plan were structured to come out together? I think discovery was withheld until the plan came out and I am grateful.

I got about a 5% confidence factor that the 10 year plan has any meaning at all.

Probably got a 65% confidence factor the bridge will be shut down or weight restricted by 2022...got a 75% confidence factor the bridge construction will be significantly delayed past 2022.

I got this a little while ago. So now it is on to the worthless legislators and governor...

*** SELECT 10YR PLAN PROJECTS: Monadnock Region & Western NH *** 

Hinsdale Bridge Replacement – Added back into the plan, for preliminary engineering work beginning in 2016 and construction in 2021-2022.

I got the feeling they are spending $500 dollars of bureaucrat money to save $30 bucks to shut off one bridge light. Like to know what is the KW cost of electricity between Hinsdale, the NHDOT and the ratepayers cost.

It is the same old thing with the weak kneed NH Democrats. We put them in the governorship and give them the house, once they owned everything...and they didn't use their power to contest the ideology of the republican extremist or neutralize them.  Can't tell them apart...can't even see them.

New Hampshire shuts off Arch Bridge lights to save money

BELLOWS FALLS -- Village residents heading to Walpole, N.H., may notice their trip across the Arch Bridge is much less illuminated than it used to be.

That's because the New Hampshire Department of Transportation is shutting off what it calls non-essential lights on state-maintained roads in response to severe budget limitations. Bill Boynton, the public information officer with NHDOT, told the Reformer this process started about two years ago as a cost-saving measure.

"We had our utility budget at the DOT virtually cut in half. That was a couple of years ago," he said, adding the Arch Bridge's lights were turned off on Friday, Nov. 27. "It was driven mostly by costs. But many lights were put up for want, rather than need."

Boynton said New Hampshire owns nearly all of the Arch Bridge.

There are roughly 3,000 lights on roads maintained by New Hampshire and each one costs about $30 a month to illuminate, he said. While there are no federal requirements for lighting on bridges, Boynton said, the state is abiding by national lighting standards.

"Everything is being reviewed on a case-by-case basis and it's a lengthy process," he said, mentioning a bridge on New Hampshire Route 18 was deemed essential. "For the most part, lighting on bridges is for aesthetics, and not required for highway safety."

Members of the Rockingham Selectboard and the public were told about the discontinuance of the lights when Municipal Manager Willis D. "Chip" Stearns II mentioned it in his manager's report during a Selectboard meeting on Dec. 3. Selectboard Chairman Tom MacPhee facetiously asked Stearns if the state was shutting off the lights to save money to repair the Vilas Bridge, which also connects the village to Walpole and has been closed to vehicular traffic in 2009, much to the dismay of local residents.

MacPhee told the Reformer he was shocked to hear Stearns' news.

"That sounds crazy to me, because it is a safety issue," he said when told about Boynton's explanation. "I'm very surprised they picked the Arch Bridge as non-essential.

There is a three-way stop where the bridge touches down in Vermont.

Though he understands NHDOT's need to save money, the chairman said the Selectboard may draft a letter to send to NHDOT to inquire about its rationale behind the decision.

In defense of the state's discontinuance of the lights, Boynton said there were also plenty of complaints about light pollution -- or excessive artificial light -- from residents on the New Hampshire side of the bridge. He also said many towns and cities affected by the discontinuance have the option of taking on the responsibility of financing and maintaining the lights.

Rockingham Highway Supervisor Mike Hindes said he noticed one of the light bulbs over the Arch Bridge was out about a year ago and reached out to NHDOT to replace it, which he does not believe was done. He said he got an e-mail last week from a NHDOT representative about the lights' discontinuance.

The few lights on the Anna Hunt Marsh Bridge and Charles Dana bridges, which link Brattleboro to Hinsdale, N.H., and the ones illuminating the road in between them will not be affected by the budget cuts because the electricity is funded by the town of Hinsdale.

There are no lights on the United States Navy Seabees Bridge, which connects Brattleboro and Chesterfield, N.H.

Domenic Poli can be reached at dpoli@reformer.com, or 802-254-2311, ext. 277. You can follow him on Twitter @dpoli_reformer.

Hinsdale NH Bridges Abandoned NHDOT and Concord

See, the “Governors Advisory Commission on Intermodal Transportation” ,  the Executive Council and ten year plan are inconsequential  to the damage with the loss of our bridge may bring to us.

The way I see it from a year ago, we got way less chance on the replacements in the next ten years than a year ago. The NH political finacial and idealogical warfare crisis is worsening.

Our obsolete bridges are a symbol of the damage happening all through NH and the nation...

I consider all the “Governors Advisory Commission on Intermodal Transportation” ,  the Executive Council and ten year plan are con jobs with all the politicians are throwing nothing but peanuts at us.

Like washing salt off our bridge late last summer.

December 03. 2013 10:48PM

DOT chief details highway funding worries; Senate president opposes gas tax hike

By GARRY RAYNO
State House Bureau

CONCORD — Facing a yearly $20 million deficit in the state highway fund, Department of Transportation Commissioner Christopher Clement told a House panel Tuesday the DOT faces 700 layoffs in fiscal year 2016.

He said without additional revenue, 20 of the 89 highway sheds will close, along with one of the six district offices in the state.

The state's highway fund receives about $120 million a year from the gas tax and about $105 million to $110 million from vehicle registrations.

He said without additional revenue, 20 of the 89 highway sheds will close, along with one of the six district offices in the state.

The state's highway fund receives about $120 million a year from the gas tax and about $105 million to $110 million from vehicle registrations.

A proposal to increase the gas tax by 12 cents over three years passed the House last session, but was killed in the Senate.

Senate President Chuck Morse, R-Salem, said Tuesday night the DOT cannot keep asking for more money.

"We're going to have to look at reducing spending ... rather than increase taxes or tolls," Morse said. "We produce the budget and (Clement) needs to live within his means."

A bill sponsored by Sen. Jim Rausch, R-Derry, Senate Transportation Committee chairman, will be introduced in the 2014 session to raise the gas tax 4.5 cents, which would raise $32 million a year for highways.

Morse said he would not support Rausch's bill.

"I continue to oppose a gas tax increase," he said. "It hurts the people who can least afford it."

Clement told the House Public Works and Highways Committee in fiscal year 2016, the state's 13 bridge maintenance crews, which repair the majority of the state's red-listed bridges, would have to be reduced to seven.

The current winter maintenance policy of having the roads "black and wet in two-and-a-half hours" won't hold, he said, noting it will take longer.

Patrick McKenna, the department's Director of Finance, said the 300-member engineering staff, which designs and inspects federal projects, will be cut in half.

"We may come up with the $250 million to finish the (Interstate 93 expansion project between Salem and Manchester), but not have the engineers to do it," said Patrick McKenna, the department's Director of Finance.

DOT officials said the problems stem from the loss of one-time money, leaving the department with a projected deficit of $48 million for the 2016 fiscal year, and $105 million deficit for 2017.

Over the past few years, the state's highway fund has been boosted from the "sale" of the I-95 high level bridge between Portsmouth and Kittery, Maine to the Turnpike system, which has about $30 million a year.

The state also bonded operating expenses for the department, but that avenue is maxed out, according to Clement.

He said ideally the state should be paving 500 miles of roads a year so that all the state's roads will be repaved every 10 years, but instead about 300 miles of roads are repaved a year, making it a 15-year cycle.

Although about 10 to 15 red-listed bridges are repaired and moved off the list every year, more bridges than that are added each year, he said. (The only path to a possible new bridge is getting it red-listed...but they won't make the call on it with our bridges. But more bridge jobs are piling up and we are getting less word done.)

"We've been doing less with less," Clement said.

Although he assumes the federal highway department will provide the $150 million a year it currently provides, Clement said, that is uncertain. In the past, the authorization would be for multiple years so the state could depend on the money, but now the federal budget is funded on continuing resolutions on a year-to-year basis.

Clement told the committee the state's turnpike fund paid for by tolls is in better shape due to two toll increases in the last six years, but the I-93 expansion from Salem to Manchester will come to a halt in October 2016, unless $250 million is found to complete the project from exit three to Manchester.

The last construction contract paid through authorized funding will be before the Executive Council today. After that contract, no others will be awarded without additional revenue from a new source, Clement said.

Cover-up And OK'd Falsification of Documents At Seabook

Straight from Seabrook's union President Ted Jenis today about why they are still using that carbon steel crap pipe in the service water system.

November 26. 2013 9:53PM

Seabrook plant close to lockout in union dispute

SEABROOK — A federal mediator arrives at the Seabrook Station nuclear power plant today, hoping to break a contract impasse that could lead to a lockout of plant operators represented by the Utility Workers Union of America, AFL-CIO, as early as Dec. 2.

“Their battle cry is‘natural gas is killing us. We are not making the money we were making five years ago,’ ” said Jenis. “But it’s hard for us to sit here and see these raises go out to management.”

"This is a workplace that has been beaten down over the last few years," he said.

 “There seems to be a total attitude change toward the workers from the corporate level.”

...This comes from a discussion I had with the senior resident NRC inspector in Seabrook.

So basically they put in a new 10 foot section of service water pipe in 2011. It had a plastic coating where they bragged it would last 20 years. It’s carbon steel pipe in a seawater system.
 

According to the Senior Resident inspector there is a lot of leaks in the service water system, one now in the cooling tower piping...he said carbon steel piping for seawater is “crap”. Him and me are brothers as we both served in nuclear submarines. He was talking about all the leaks and the chlorides in the seawater...I interrupted his happyland with that carbon steel is nothing but junk. I said you know that. Then he said, “yep, its crap”.

So it began leaking this Aug 7^th or so. It is the summer and everyone worries about grid load if you know what I mean. Who pays for the replacement power if Seabrook had to shut down?

So Seabrook filled out per procedure “prompt operability determination” (POD) document. They did ultrasonic testing (UT)...the NRC report says they first filled out a UT report which is a falsification. There was no report in the most important moment of the NRC’s investigation when the inspector was first investigating the leaks. And the NRC’s managers don’t give a shit if Dominion puts up a ton of barriers making it difficult and timely...eat up the precious inspector time... for the inspectors to investigate safety problems at a operating reactor.

As the senior inspector complained to me...we got only a very limited amount of paid time in a day, week or monthly pay period. We are incentivized to spend very little time at the plant. We don’t get paid after 40 hours. I believe the manager don’t want them to put in extra time. Political Campaign contributions stuff these rule down the inspector throats. The nuclear plant executives fears the more hours an inspector spends at a plant the more violation they will get.   

“No” so says the senior resident inspector. The POD referencing the UT basically said the leak was insignificant and there are no long term risks. This resident inspector in a prior life was a welder and he read many UT results. Dominion didn’t think the NRC would go in farther than the POD. But the resident asked to see the UT report. Seabrook himmed and hawed looking for the document...the resident finally decided to hunt it down by foot. He went into a few offices...finally an Dominion employee finding it in the UT machine. He had start up the actual device. Dominion was making it difficult for the inspectors to see the documents.

The UT reading was obscenely worse than the POD. Dominion falsified the POD.

I asked the resident, well then it’s a falsification and you can’t trust the integrity of the staff at the plant. He said he agreed with that...but we called it just gross incompetence. What is the difference I said, if you are so grossly incompetent you can’t accurately assess the leaking hole in a pipe in an unbelievable important plant and reactor cooling pipe. The UT said a rather large area had a zero thickness.   

I mean, how can you trust Seabrook to assess anything in the plant.

I asked, once you learned Seabrook lost the bubble and played games in hiding safety testing results why didn’t the agency declare the side INOP and make them shutdown in 24 hours like the rules demand. He remained silent on this. But I pushed him about Dominion falsifying safety documents the NRC depends on. He thought for a moment, “saying they didn’t see it like that, they were just grossly incompetent.

The leak eventually got much worst...the NRC said the sized of the hole and leak in the plant was larger than any of there safety analysis.

He said the Dominion was basically obstinate throughout this, that the plant was safe through the next month...they didn’t even need to put a Band-Aid on it. 

The resident indicated he couldn’t believe how reckless Dominion was and how disrespectful Seabrook was to the role he played at the plant  He advocated Seabrook should be severely sited with a violation for their behavior...but his bosses above him prevented him from siting the plant. So how is the plant going to respect him now.

Dominion stock price is doing extremely well compare to the other utilities. Their stock price has been on a steep increase for many years. We have seen how utilities get big headed over high stock prices. They basically think their stock price proves they are safe. A high price stock price is very unsafe...it leads to arrogance and overconfidence.

1)    Dominion falsified the POD saying the leak was insignificant when they had indications there was zero pipe wall metal left and the geometry of the hole could lead to a very large increase in leak rate. The NRC allows Dominion to get away with inaccurate and falsified documents to a Federal regulator.

2)    Dominion gave falsified information on the new "piping material and Belzona" on its service water system. So they had evidence this Belzona crap could fail very early and it still did. Seabrook promised in their license renewal they would get service water leaks and degradation and it is only gotten more out of control and worsening with new piping failing in two years.

     April 26, 2012

      Seabrook Station Response to Request for Additional Information 
NextEra Energy Seabrook License Renewal Application Supplemental Response - RAI B.2.1.11-2 and B.2.1.12-6 

      Belzona® products are polymeric materials commonly used for lining and liner repairs at Seabrook Station. An engineering evaluation performed in 1993 indicates that Belzona lined pipe has an expected service life of 15 years. However, review of the NextEra Energy OE database has not indicated failures of the Belzona lining due to exceeding its service life. The condition of all Service Water pipe linings is monitored via periodic internal pipe inspections in accordance with the "Service Water Inspection and Repair Trending Program"' Preventive maintenance activities have been initiated to insure inspections are scheduled and are being tracked. The extent of use of the Belzona and polyurethane coatings in Service Water piping has been identified and is being tracked in the Service Water Inspection and Repair Trending Program.

3)   The NRC managers place improper pressure on a senior resident inspector to downplay the severity of safety piping leak into a non sited violation.

 

I wish the inspectors and their managers had more attention to detail. There is two renditon with how they charactoize the leaking hole. Which one is right?

I been through the rounds, made a safety complaint to region I. Talked to the region I public relation department and got Senator Shaheen office to begin asking questions to the NRC. Called Seabrook plant security and asked them to pass on a message to their PR department or engineering for comment.
 

November 19, 2013

Mr. Kevin Walsh

Site Vice President

Seabrook Nuclear Power Plant

NextEra Energy Seabrook, LLC

c/o Mr. Michael Ossing

P.O. Box 300

Seabrook, NH 03874

SUBJECT: SEABROOK STATION, UNIT NO. 1 - NRC INTEGRATED INSPECTION REPORT 05000443/2013004 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) REPORT NO. 07200063/2013001

Introduction. The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” and an associated violation of TS 3.7.4, because NextEra did not follow the requirements of station procedure EN-AA-203-1001, “Operability Determinations/ Functionality Assessments.” Specifically, NextEra did not properly evaluate and document an adequate basis for operability, when relevant information was available that would have challenged the “reasonable assurance for operability” threshold for a SW through-wall leak that degraded incrementally from weepage on August 7, 2013, to a significantly larger leak on August 28, 2013.

Description. On August 7, 2013, NextEra personnel discovered a through-wall leak on  a section of 24-inch bypass piping associated with the “B” train SW system strainer No. 11. In accordance with EN-AA-203-1001, “Operability Determinations/ Functionality Assessments,” an immediate operability determination was performed that concluded the SW system was operable but degraded, with an estimated leak rate of 10 drops per minute (dpm), and within the CAP under action request (AR) No. 01895334. NextEra subsequently completed a prompt operability determination (POD), on August 8, 2013, which utilized American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code case N-513-3, “Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping,” Section XI, Division 1, consistent with site procedures and NRC regulations. The POD documented the piping section had adequate structural integrity to meet code requirements, following the performance of volumetric examination of the flaw, through the use of ultrasonic testing (UT), performed in accordance with procedure ES1807.012, “Ultrasonic Thickness Measurements.”

Additionally, the UT report was reviewed by Engineering based on the results of the flaw evaluation and concluded the flaw was stable and acceptable for continued service. The UT evaluation documented and characterized the flaw as exhibiting an “abrupt change in thickness from nominal…absent the normal intermittent thickness readings that are seen within flawed areas of SW piping.” Because of this atypical result, the flaw was “conservatively bounded” by the inside piping surface UT signal loss, resulting in a flaw size of “…2.327-inches circumferentially by 1.50-inches axially with a remaining wall thickness of 0.00-inches…” The POD also concluded the observed leak rate was within design and licensing basis flow and leakage requirements, which supported the operable but degraded conclusion.

On August 20, 2013, NextEra personnel identified that the leak had degraded to an approximate leak rate of 90 dpm. The basis of operability, which was documented in AR report No. 01898318, referred back to the August 8 POD, (performed under AR 01895334) and concluded the 90 dpm leakage value continued to be within the bounding design and licensing basis flow and leakage requirements. The operability basis was supported by a follow-up UT of the affected area, performed on August 21, which revealed essentially similar UT results. The evaluation summarized the flaw examination as follows:

“Based on the PAUT examination the flaws axial and circumferential dimensions are unchanged with no reportable thickness. However, the rapid change in the OD surface coupled with the lack of UT thickness data in the flawed area suggests that there is little remaining wall at this location. It is likely that the size of the through wall hole will rapidly increase to the full 1.5-inch by 2.367-inch dimension.”

On August 28, 2013, during a planned performance of surveillance testing of a CT SW pump, NextEra identified that the leak had progressively worsened to an estimated 25 gallons per minute (gpm). Subsequent evaluations postulated that the additional SW header pressure during CT SW pump operation (66 psig versus nominal 48 psig) contributed to the degrading condition of the leak at the identified flaw location. NextEra installed a housekeeping patch to limit the impact of water spray, and instituted several corrective actions under AR No. 01900249, as well as the originating AR No. 01895334 and its associated POD, which had continued to govern the basis and continued reasonable assurance for operability, which included, for example, the formation of an Operational Decision-Making (ODM) team, and planning extent-of-condition piping inspections to meet Code Case N513-3 requirements.

Also, TS 3.7.4.d requires, in part, that with two loops (except two CT loops) inoperable, return at least one of the affected loops to OPERABLE status within 24 hours, or be in at least HOT STANDBY within 6 hours and in COLD SHUTDOWN within the following 30 hours. Contrary to the above, between August 7, 2013, and September 1, 2013, when the weldolet repair was completed on the “B” SW header piping, one CT SW loop and one ocean SW loop were inoperable for greater than TS requirements, and therefore,  is considered a TS-prohibited condition. Corrective actions included apparent cause evaluations to determine the cause of (1) the flaw on the “B” SW strainer bypass header and (2) the missed opportunities to identify the significance of the UT data, as well as the NRC-approved code relief that resulted in the temporary weldolet installed over the flaw area on the “B” SW strainer bypass header. NextEra entered these issues into their CAP as AR 01904703.

The inspectors assessed NextEra performance regarding the evaluation of the degrading and non-conforming condition, and concluded that all available information should have resulted in a determination by NextEra that the leak could propagate to the bounding geometry discussed in the UT reports to 1.5-inches circumferentially and 2.3-inches axially. Moreover, since flow through this 1.5-inch by 2.3-inch defect would result in leakage outside the current licensing and design bases of the plant, reasonable assurance of operability was no longer appropriate for the circumstances, and should have resulted in the “B” SW ocean and CT headers being declared inoperable.

As a result, the inspectors determined that the reasonable expectation of operability was no longer credibly assured based on the following factors:

 1. The subject carbon steel (belzona-lined) piping was newly-installed on or about April 2011, with a nominal thickness of 0.375-inches. The leak in August 2013, directly indicates an average loss over the approximate 28 months of 0.160-inches/year, which far exceeded the corrosion rates of 0.030-inches/year utilized in the POD to justify continued operability;

2. The actual, rapid leak propagation that occurred from 10 dpm on August 7, to 90 dpm on August 20, to 25 gpm (while running CT SW pumps) on August 28, and ultimately, the estimated 15 gpm with normal ocean SW pressures, indicated a flaw degradation that appeared to be consistent with the flaw evaluation conducted following the volumetric examinations;

3. The physical condition of the piping at the flaw location was characterized initially as “weepage,” on August 7, followed by a “concavity” that appeared at the flaw location on August 20, and ultimately as a through-wall hole on August 28 with a resultant estimated leak rate of 25 gpm. This rapid deterioration of ASME Class 3 piping wall was also consistent with the flaw evaluation and volumetric examinations that predicted very little remaining material of a specific geometry;

4. Information regarding the leak-rate from a hole characterized in the flaw evaluation, i.e., bounded by “…2.327-inches circumferentially by 1.50-inches axially with a remaining wall thickness of 0.00-inches…” was not integrated into the evaluation under the POD regarding the reasonable expectation of operability. Moreover, when the bounding flaw size was used to determine potential leak rates using standard engineering equations, an approximate 570 gpm leak rate was calculated. This resultant leak rate was outside the Operability criteria established in the POD of (1) 137.25 gpm (excluding SW boundary valve leak-by) based on leakage criteria associated with UFSAR design basis values of CT inventory for a 7-day mission time without makeup, (2) 130 gpm available margin from calculations that address SW cooling the primary component cooling heat exchanger, and (3) 250 gpm available margin from calculations that address SW cooling the diesel generator heat exchanger; and

5. It was known that the rapid leak propagation occurred from 90 dpm to 25 gpm on August 28, during surveillance testing of CT pumps, which directly indicated that a 20 psig increase in fluid system pressures caused the rapid leak propagation. Coupled with the volumetric flow information that was also known, a direct challenge to the reasonable expectation of operability should have been identified, or, more directly, a recognition that for all specified safety functions and design basis mission times, further operability of the “B” SW header with a rapidly degrading pipe wall and increased leak rates, was not assured.

Subsequently, through discussions between the NRC and NextEra, on August 31, NextEra was granted relief to perform a temporary, non-ASME code repair to the SW piping through the installation of a weldolet assembly over the affected flaw area, in compliance with 10 CFR 50.55a(a)(3)(ii), and completed the repair efforts on September 1, 2013. Current NextEra planning includes replacement of the flaw area in the next refueling outage, and completion of corrective actions associated with a number of apparent cause evaluations and other associated activities.

Analysis. The inspectors identified that NextEra did not follow the requirements of station procedure EN-AA-203-1001, “Operability Determinations/ Functionality Assessments.” Specifically, NextEra did not properly evaluate and document an adequate basis for operability, when relevant information was available in the form of atypical UT data and assessment, and more importantly, the propagation of a SW leak from a flaw that occurred between August 7 and August 28, 2013. The characterization and assessment of the flaw through UT methods was consistent with the leak propagation that was subsequently observed. This information was available for utilization during the prompt operability determination process, and directly challenges the “reasonable expectation for operability” threshold for a SW through-wall leak. Specifically, EN-AA-203-1001 stipulates that determination of operability be based on “the licensee’s reasonable expectation,” from the evidence collected, that SSCs are operable and that the operability determination will support the expectation. This failure to consider all relevant information was reasonably within NextEra’s ability to foresee and correct, and their failure to appropriately assess operability when a degrading or non-conforming condition was identified was a performance deficiency. This performance deficiency is more than minor, and considered a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the prompt operability determination incorrectly concluded the “B” CT SW header and the “B” SW (ocean) pumps were operable, but degraded, because they did not utilize appropriate rigor to determine that given the (1) UT information and assessment, (2) identified flaw size, and (3) actual leak propagation, the resultant information translated into potential leakage values would have yielded leak rates in excess of the operability limits established in NextEra’s current licensing basis, and in some cases, inconsistent with design basis required boundary leakage values.

The inspectors and Region I Senior Reactor Analyst (SRA) used IMC 0609, “Significance Determination Process,” Attachment 04, to perform the initial safety significance characterization of this finding. The inspectors assumed that functionality of the SW system, based upon the as-found wall thinning, would only be challenged when aligned to the cooling tower basin (higher suction pressure) and the SW piping is subjected to a higher overall system pressure. This system configuration is used to mitigate a seismic event following the loss of the normal SW intake structure. Accordingly, the inspectors used IMC 0609, Appendix A, Exhibit 2, “Mitigating Systems Screening Questions,” and Exhibit 4, “External Events Screening Questions,” to assess this issue and conclude a detailed risk evaluation was warranted.

The SRA used insights from the Seabrook Updated FSAR and Seabrook Individual Plant Examination of External Events (IPEEE), as well as, the Risk Assessment Standardization Project (RASP) Handbook, Volume 2, to perform a qualitative assessment. The operating basis earthquake (OBE) and the safe shutdown earthquake (SSE) peak horizontal ground acceleration values are 0.125g and 0.25g, respectively. From IPEEE Table 3.2, “Seabrook Fragility Analysis: Seismic Capacity of Structures,” and Table 3.3, “Seabrook Fragility Analysis: Equipment Fragilities,” the seismic design capacities of the Service Water (SW) Pumphouse, SW Intake Structure, SW Cooling Tower, and SW piping are all built to withstand seismic events that exceed 2.0g. Based upon IPEEE, Figure 3-1, “Family of Seismic Hazard Curves for the Seabrook Site,” the annual exceedance probability of an earthquake producing ground accelerations greater than 2.0g (of a magnitude sufficient to challenge the seismic capacity of the SW Intake Structure) is approximately 1.0E-07. Assuming an earthquake of this magnitude and the failure of the SW intake structure, it is likely the unit will be manually shutdown, if not automatically tripped, from the event. In conjunction with plant walkdowns to identify and assess SSC damage, operators would be tasked with aligning the service water suction to the cooling tower basin. Assuming worst case operator performance due to high stress and limited time available to restore service water cooling for decay heat removal and RCP seal cooling, the SRA assumed a one in ten probability of failure (to realign the SW system suction to the cooling tower basin). Lastly, the probability of a service water piping failure (rupture) due to the observed wall thinning cannot be accurately quantified, but under a worst case condition can assume to be 1.0. Therefore, the estimated increase in core damage probability associated with this performance deficiency is in the low 1.0E-08 range or very low safety significance (Green).

The finding has a cross-cutting aspect in the area of human performance associated with the decision making component because NextEra failed to use conservative assumptions in decision-making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate it is unsafe in order to disapprove the action. Specifically, NextEra personnel had not considered relevant information in the form of UT data and actual leak propagation to conclude that they no longer had “reasonable assurance of operability” and did not declare the “B” header of ocean and CT SW systems inoperable [H.1(b)].

Enforcement. 10 CFR Part 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” requires, in part, that activities affecting quality shall be prescribed by documented instructions or procedures, and shall be accomplished accordingly. NextEra’s procedure EN-AA-203-1001, “Operability Determinations/ Functionality Assessments,” requires in part, that a SSC remains operable until reasonable expectation of operability cannot be demonstrated, with specific focus on the ability of the SSC to perform its specified safety function. Contrary to the above, NextEra did not properly evaluate and document an adequate basis for operability, when relevant information from volumetric UT data was available that would have challenged the “reasonable assurance for operability” threshold for a SW through-wall leak that degraded incrementally from weepage on August 7, 2013, to a significantly larger leak on August 28, 2013. In addition, between August 7, 2013 and September 1, 2013, when the weldolet repair was completed on the “B” SW header piping, one CT SW loop and one ocean SW loop were inoperable for greater than TS 3.7.4.b. requirements, and therefore, is a TS-prohibited condition. NextEra entered this issue regarding the TS violation in the CAP, to evaluate the cause and to determine actions to prevent recurrence, as AR No. 01916618 and 01904703. Because this finding is of very low safety significance and was entered into NextEra’s CAP, this violation is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy.

(NCV 05000443/2013004-01, Inadequate Operability Determination Regarding Service Water Leakage and Associated TS Violation)

NRC: Nuclear Safety Myth And Risk Perspectives

November 19, 2013

Macfarlane Reaffirms NRC Commitment to Safety; Cautions Industry about Budget Impact on Agency

ATLANTA – Nuclear Regulatory Commission Chairman Allison Macfarlane Tuesday acknowledged to nuclear executives that both the NRC and the industry face economic challenges but cautioned that a diligent commitment to nuclear power plant safe and secure operation of must remain paramount.

“Clearly, these are demanding economic times for all of us. But in the face of uncertainty we must continue to demonstrate together that plant safety and security aren’t, and never will be, in jeopardy,” Macfarlane told the CEO conference of the Institute of Nuclear Power Operations, an industry organization that focuses on improving nuclear safety.
Macfarlane also said the recent government shutdown created a backlog of non-emergency licensing work and delayed important projects such as the Waste Confidence rule work and post-Fukushima actions.

She added that, “while the recent lapse in federal appropriations is the most recent and most problematic external financial challenge we’ve faced, it is not the only one. For the past year we’ve had to readjust our work in response to required sequestration cuts and unabated continuing resolutions. We’re now facing the possibility of another year of sequestration at even more austere funding levels. … The combination of well-grounded immediate priorities and constrained and unpredictable annual budgeting means that important long-term focused work simply isn’t going to get done.”

“In some cases, it could mean additional delays – in others it means certain activities may be temporarily suspended. … The commission recognizes this, and we’re working to ensure that we continue to have the ability to do as much as we can with the resources we have.”

In her remarks Macfarlane also highlighted:

• Appreciation for INPO’s emphasis on the link between strong plant management and consistent plant performance, and for the industry’s work to implement lessons learned from the Fukushima accident.

• Overall nuclear power plants continued to perform well, but there are a few trends of concern attributable to systemic issues, such as maintenance practices for aging equipment.

• The Commission this week decided how the agency will proceed on the Yucca Mountain issue.

• The NRC has received “valuable input” from a variety of perspectives at public meetings on the Waste Confidence issue.

• The agency is monitoring domestic and international concerns about counterfeit and fraudulent parts and challenged both industry and the NRC staff to “maintain a shared commitment to vigilant vendor inspection.”

• The NRC has “worked closely with industry and Federal, state, and local law enforcement agencies on an integrated [emergency] response program for nuclear power plants. In the past year in particular, closer cooperation between industry and the various government entities has yielded good results and the program is advancing.”

• Operators of plants undergoing decommissioning should “engage with the public and be transparent about decision-making.”

• All facility operators “should be more proactive in engaging interested parties in their communities. I think there’s a clear linkage between continued, productive dialogue and the establishment of mutual trust in a particular community.”

Nov 15, 2013

So the Japanese’s nuclear safety myth is their industry’s PR people educating or teaching the general population nuclear power is safer than it really was. This whole deal allowed the collusion between the politicians, regulators and nuclear industry. The whole deal is a system that enables the nuclear industry to hide information from the public and the activist. It is so undemocratic at its core. It also is a system to intimidated the good nuclear employees to not disclose and fix troubling problems...which bolstered the status and profits of the higher ups.

Basically the USA "risk perspectives" is a undecipherable safety analysis and code words to insiders and outsider alike. It is mostly used to get the officials to repeat over and over again the plants are safe, safe, safe.  I called it the "nothing ever matters "rationalization and we know it undermines the good employees in the industry. If you look at risk perspectives carefully, it is a system designed to not discuss ongoing problems in the industry, and get problems fixed. We are spinning safety as much as the Japanese.

You need agency actions that changes plant's bad behaviors...not agency actions that just harmlessly bureaucratizes poor practices and unsafe behavior. Sticking a corporation in the corner for five minutes just doesn't change their behavior. I think we got host of troubling plants out there who have been enabled by the mentality of “nothing ever matters” risk perspectives. And we have entered a historic tough economic environment and the “nothing ever matters” risk perspectives wouldn’t protect the nuclear industry in our new reality.

I see the degrading economics and poor maintenance as tremendously increasing the complexity of the operators environment. They are juggling too many balls. We are going to have an accident and it is going to look like all the employees are all crazy. It will really be we put these guys in a too complex environment without enough economic support.  

So our USA risk perspectives and the Japanese’s nuclear safety myth and regulatory capture are the same thing. The inability of the NRC to ask the fundamental question of, how is the Japanese’s safety myth the same as our risk perspectives is an indication we are in the Japanese mentality before Fukushima.

The last and most important safety barrier is an active and engaged political system...they are constantly testing if the nuclear industry’s activities are making sense.  If things go south, they know how to go in there and knock heads together in order to get a change of behavior out of the regulator and the industry. Do you think our political system has this competence today?   

"I think that the Fukushima accident provided a clear example of the importance of an independent, well-funded regulator as a critical foundation for any nuclear program, regardless of its size or scope. In the initial months, an independent commission of high-level officials appointed by the Japanese Diet took a hard look at the potential causes of the accident. The Kurokawa Commission, as it was known, released a candid report that concluded that the accident was“manmade,” a result in part of “regulatory capture,” in which the industry had too great an influence over the regulator. The report also coined the phrase“nuclear safety myth” to characterize an unfortunate overconfidence that low-probability, high-risk events would simply not occur."

Prepared Remarks of NRC Chairman Allison M. Macfarlane American Nuclear Society Winter Meeting

Monday, November 11, 2013 – Washington, DC

Good afternoon. It’s a pleasure to be here today to reflect on what lies ahead for nuclear safety in the next quarter century. I’m honored to join this esteemed group of panelists and I’m looking forward to our discussion. Today, I’d like to offer my thoughts on the events and lessons that have shaped our current perspectives on nuclear safety and on how best to keep a bright spotlight on safety in the years ahead.

The annual ANS Winter Meeting always brings together a diverse audience, including students from a number of disciplines. Many of you are engaged in research and in generating knowledge that might advance the use of nuclear technologies for global benefit in the coming years. As a scientist, I know well the excitement and sense of fulfillment that comes from knowing that your contributions are adding to human understanding of the world around us.

This is a significant time for all of us in the nuclear field. Next month marks 60 years since President Eisenhower delivered his iconic “Atoms for Peace” speech at the United Nations. In the decades that have followed, there have been substantial advances in energy, medicine, and industry as a result of nuclear technology.

We’re now at a juncture where further expansion of civilian nuclear power to non-nuclear countries is poised to occur. As the nuclear power landscape changes, the international community must remain vigilant to protect against potential hazards and malicious uses posed by nuclear technology without effective regulation. Use of nuclear power requires a strong regulatory regime to ensure that the power of the atom is put to beneficial use and to protect against misuse and/or complacency that opens the door to unacceptable risk of potentially devastating consequences.

Fukushima’s Ongoing Lessons

The Fukushima-Daiichi accident nearly three years ago challenged us to revisit established assumptions and regulatory priorities. As the accident unfolded, it became clear that we should consider the possibility of multiple units at the same facility experiencing an accident. We also realized that in some cases, we may not have sufficiently addressed the threats that some natural disasters could pose.

As the international community began to come together in the ensuing months, it was affirming to see that we were reaching similar technical conclusions about where safety enhancements were necessary. As a result, despite the diversity of nuclear power programs worldwide in terms of size, scope, design, and other factors, we’ve been able to collaborate closely and benefit from one another’s experiences.

Our work to address lessons learned from the accident continues. We’re reassessing our licensees’ ability to mitigate seismic and flooding events and requiring them to ensure adequate emergency response training and communication to cope with prolonged accident conditions. They’re strategically placing backup equipment on-site to help maintain reactor cooling in the event of a loss of power. We’ve also required enhanced instrumentation to better measure the water level in spent fuel pools. While many of these activities are well on their way to completion, we’ll need to address some items through rulemaking at our agency. This can be time-consuming, but provides the benefit of codifying lessons we’ve learned with opportunities for public participation throughout the rulemaking process.

Worldwide Nuclear Energy Pursuits

The Fukushima accident halted the course of future nuclear energy development in some countries, but others are moving ahead with their plans, including some new players. The community of countries operating or developing nuclear power programs is becoming more diverse. Some of these are developed countries that have an interest in diversifying their energy portfolios. Others are still grappling with developing basic infrastructure. It’s possible that new developments in small modular reactor technology in future years may further broaden the range of countries seeking to pursue nuclear power.

In some respects, the prospect of initiating a new nuclear power program from the ground up could be seen as a positive opportunity. These “newcomer” countries have a chance to reflect on the decades of lessons others have learned – sometimes the hard way. They can establish a competent, well-funded regulator; promote a healthy safety culture; consider the ultimate disposal of nuclear waste before any is generated; and communicate clearly with the public on each new step in the process. I think that the possibilities, at least in a philosophical sense, appear broad and encouraging.

But of course, I note that there are often competing external pressures contributing to the desire to establish a civilian nuclear power program. There are urgent economic and energy needs. There’s political prestige. There’s the consideration of a country’s sovereign right to pursue nuclear technology for peaceful purposes. And, in rare cases, there’s a desire among some to leverage the technology for geopolitical purposes by pursuing a nuclear weapons program. We’ve seen these factors contribute to the establishment of high-level policies that put nuclear power programs on a fast track. From a regulatory standpoint, however, a strong focus on nuclear safety and security should be the ultimate objective. I believe there’s a need to balance the right to possess nuclear technology with the responsibilities that come with it. Nuclear safety is a global obligation – there cannot be a vibrant nuclear power industry without a global commitment to safety. And an essential component of that commitment is the presence of a strong, independent regulatory body.

Why a Strong Regulator?

The role of the nuclear regulator has evolved and expanded over time – the United States is no exception. The creation of the Nuclear Regulatory Commission in 1974 was the result of a pivotal realization that regulation of an industry would never be sufficiently effective if it was linked

organizationally to the promotion of that industry. But I would be remiss if I oversimplified this point. Establishing an effective, independent regulatory structure is not a one-step process, nor does it remain static. The NRC has continued to hone its independent regulatory model in the 35-plus years since our agency was established. On a global level, the NRC and our counterparts in other countries routinely engage in discussions about what regulatory independence means, and there’s not always universal agreement about its definition.

It’s clear that a regulator’s organizational independence will vary depending on the overall political structure of the country – and since there’s no fixed model for the latter, it’s impossible to have a one-size-fits-all approach to nuclear regulation. But while our experiences may differ, one resounding lesson is that safety must transcend all else. To be effective, a regulator must be independent of any political, economic, or other policy interest whose outside influence could coerce the regulatory body to make decisions that aren’t in safety’s best interest. The regulator must have sufficient, sustainable funding to ensure that it can effectively do its job and attract the best and the brightest. I believe that, for a regulator to have the trust and support of the public, it must be committed to openness and transparency – providing information about its work in terms the public can understand, and affording the public opportunities for input into its processes. Finally, the independent status of the regulator must have support from government leaders – nuclear safety must factor into national decision-making.

I think that the Fukushima accident provided a clear example of the importance of an independent, well-funded regulator as a critical foundation for any nuclear program, regardless of its size or scope. In the initial months, an independent commission of high-level officials appointed by the Japanese Diet took a hard look at the potential causes of the accident. The Kurokawa Commission, as it was known, released a candid report that concluded that the accident was “manmade,” a result in part of “regulatory capture,” in which the industry had too great an influence over the regulator. The report also coined the phrase “nuclear safety myth” to characterize an unfortunate overconfidence that low-probability, high-risk events would simply not occur.

Obviously, the Fukushima accident has prompted all of us, even the most developed countries with the most well-established programs, to reassess how we do things and see where enhancements may be necessary. It’s clear that any type of nuclear accident anywhere in the world has global consequences. The response to this accident plainly demonstrates the need for a continued global commitment to preventing future incidents.

You may have seen media coverage over the past year about counterfeit and fraudulent parts making their way into nuclear construction sites, or of greater concern, being discovered at operating reactors. This concern is not unique to the nuclear industry, and general advances in technology have prompted new worries about hard-to-spot fake computer chips and circuit boards. Today’s nuclear industry relies on a global supply chain, and new reactors being designed and constructed around the world have all digital operating systems. Taken together, these factors clearly point to the need for a global regulatory commitment to rigorous quality control, irrespective of a problem’s country of origin. It is unwise, and potentially dangerous, for a country to embark on nuclear construction without a vigilant vendor inspection program.

There’s also been discussion about a “build-own-operate” model for new nuclear power plants in countries without established nuclear programs. The objective would be to rely on vendors and contractors from an experienced nuclear power country to handle all aspects of the new country’s

program, from the construction to the day-to-day operation, and even the regulation. In some cases, this model presupposes virtually no indigenous nuclear engineering capability or regulatory structure. I believe this would be problematic for several reasons.

First, it would make the host country fully reliant on foreign inspectors to maintain the plant, identify safety concerns, and quickly address them. In a worst-case scenario, I find it worrisome to consider a sovereign country counting on a foreign entity, potentially thousands of miles away, to oversee the response to a nuclear accident. Second, as an open, transparent regulator, the NRC regularly communicates with other federal, state, and local government agencies, interest groups, the media, and members of the public. This communication happens on a routine basis – not just in the event of an incident. If a country chooses to place its nuclear program in the hands of a foreign regulator, that country would relinquish its ability to ensure that it is adequately informing its own citizens about that program.

Regulators also have an important role to play in upholding non-proliferation commitments. Regulatory controls on nuclear materials help ensure that these materials are kept out of the hands of malicious actors and ensure safeguards measures are enforced. The Nuclear Non-proliferation Treaty was carefully crafted to create a balance between the right to develop nuclear technology and the responsibility to safeguard this technology to ensure its exclusively peaceful use. The regulator is integral to the efforts to uphold this balance by establishing clear requirements for the safe and secure use of the technology. Effective regulatory requirements demonstrate a country’s commitment to peaceful use, which, in my view, should facilitate access to the technology, rather than being perceived as a bureaucratic obstacle.

A regulator’s non-proliferation role extends to any country that uses nuclear materials for any reason, even if the country never intends to establish a civilian nuclear power program. A robust regulatory infrastructure is necessary to ensure safety and security in authorizing these materials to move from place to place and overseeing their storage and use once at their destinations. There’s also an economic benefit – these types of controls actually enhance efficiency of movement of these materials across the marketplace by ensuring a clear destination, thereby minimizing delays.

Putting it into Practice

The NRC is working continuously to put these regulatory ideals into practice. At home, we have a rigorous safety and security oversight program. Our resident inspectors are a daily presence at our licensed facilities, helping to ensure that identified issues are promptly addressed. I should note that, during our recent government shutdown, all of these inspectors remained on the job. We take more than 1,000 licensing actions each year, all publicly available, following well-established, well-documented procedures. We work closely with the 37 Agreement States, which regulate tens of thousands of nuclear materials licensees throughout the country to ensure that our collective approach is effective. We license all imports and exports of civilian nuclear materials. We’re committed to openness and transparency, and our processes provide documented opportunities for public involvement. While I believe there’s always room for improvement, we’re certainly practicing the kind of competent, independent regulation that we advocate.

The NRC is also engaged internationally, both bilaterally and with multilateral organizations like the International Atomic Energy Agency. We work closely with our regulatory counterparts to

address safety and security issues of mutual interest. We also provide assistance to countries with new or small nuclear programs. We share insights about establishing a sound regulatory infrastructure, offer workshops on the development of laws and regulations, and participate in international peer review missions assessing the health of regulatory bodies. With effective use of these principles in our domestic program, we’re proud to demonstrate credible leadership in this area.

We also played a critical role in strengthening implementation of the Convention on Nuclear Safety, or CNS, following the Fukushima accident. The U.S. Government, with the NRC in a leadership role, joined other countries in successfully advocating for stronger language about the importance of regulatory independence in the Convention’s guidance documents. These documents provide a roadmap for countries to report how they’re meeting their obligations under the Convention. Thanks to these enhanced guidance documents, countries will be asked to offer specific information about their regulatory structure at the upcoming Review Meeting next spring. All countries’ reports, including ours, will be peer reviewed with the intent of identifying areas for improvement. These upcoming exchanges will give us valuable input to consider.

I just mentioned the NRC’s collaboration with other U.S. Government agencies in the CNS context. We also work with our interagency colleagues to provide support and offer regulatory assistance for countries considering U.S. technology. It’s important for me to emphasize that the NRC doesn’t promote nuclear energy. However, it’s become clear that the expertise we can offer in the way of design review and certification, construction oversight and quality assurance checks, and other related areas is of interest to countries considering nuclear power. From a purely regulatory standpoint, we believe this type of focused collaboration contributes positively toward advancing our collective goal of strengthening nuclear safety and security worldwide.

Keeping the Momentum Going

Reflecting once again on the theme of today’s discussions, it’s safe to say that all aspects of nuclear energy – from how it’s generated to how it’s regulated – have changed considerably since the technology’s initial introduction. Today’s approach to nuclear regulation is naturally defined by our experiences. We’ve sought to identify, share, and advance good practices, and we’ve used the less positive moments as opportunities to learn and do better. This is an ongoing process. Growing and changing over time is healthy for any organization.

But as we move forward, ready to embrace the lessons of the decades to come, it is imperative that we continue to shine that bright spotlight on safety. Nuclear regulation, like the nuclear industry and most everything in our time, is a global effort – and safety and security are shared responsibilities. The Fukushima accident reinforced this reality in a tragic way, but it didn’t introduce it. A global commitment to effective, independent nuclear regulation is an absolute must if we are to prevent future accidents and guard against malicious use of nuclear materials.

The NRC is leading by example. Our regulatory oversight of our licensees is rigorous, independent and open. Our export controls facilitate the safe and secure movement of nuclear materials in and out of the United States, and give us assurance that materials will be properly protected upon reaching their destinations. Our international assistance work enables us to share lessons from our domestic regulatory program to benefit others – whether they are countries pursuing nuclear power for the first time or seeking to strengthen their oversight of facilities already in operation. I’m proud to lead our agency at this critical time.

It’s not possible or appropriate for me to predict where the industry will be in the year 2038 or beyond. We may be looking at how new technological advances, like small modular reactors, have brought nuclear power to regions that could not previously have considered it. We may be reflecting on how the medical isotope production market has changed. We’ll have new construction lessons to consider from all over the world, and decommissioning approaches to contrast as other plants shut down. For those of you who will be the stewards of nuclear regulation and the nuclear industry in the coming decades, I cannot emphasize enough the importance of maintaining the momentum on safety. Whatever the future brings, I believe that one thing is certain. If the nuclear industry is going to be operating effectively at any size – if it’s going to inspire confidence and public trust – then we must keep our focus on safety.

It’s an honor for me to have the opportunity to participate in this important conference, and look forward to hearing from the other panelists and to our discussion. Thank you.