Supplement to Palisades Defective PCP Pumps 2.206

 

The problem here is the licensee and NRC didn’t think a USFAR, licensing and other requirement violations were a substantial safety hazard either on the pump or repetitively spewing blade fragments all over in the coolant. They weren’t forced to justify it publicly...

 SUBJECT: STATUS OFRECOMMENDATIONS: AUDIT OF NRC’S IMPLEMENTATION OF 10 CFR PART 21, REPORTING OFDEFECTS AND NONCOMPLIANCE (OIG-11-A-08)

Attached is the Office of the Inspector General’s analysis and status of recommendations 1, 2, 3, 4, and 5 as discussed in the agency’s response dated

April 27, 2011. Based on OIG’s analysis of this response, recommendations 1, 3, and 5 are unresolved and recommendations 2 and 4 are resolved.

OIG notes that NRC management has accepted, but uses conditional language to articulate, the actions planned. This obfuscates the agency’s intentions with regard to the recommendations. It is paramount for OIG to have a clear understanding of the NRC management position with regard to reportability under Part 21. Recent manufacturing defects at two separate nuclear power plants illustrate why this is important.

One nuclear power plant recently received a Red finding under NRC’s Reactor Oversight Program because a safety-related coolant injection valve was discovered to have been broken and unable to perform its safety function for an extended period of time. Had this same valve been out of service for less than 7 days, the failure of the valve would not have been reportable under Part 21 according to some interpretations because it would not have met Part 50 event reporting requirements, and the nuclear industry would not have been informed of a manufacturing defect in a safety-related component.

At another nuclear power plant, the licensee discovered that a safety-related part necessary to operate a circuit breaker had a manufacturing defect that would prevent the breaker from performing its safety function. Some of the breakers were installed in the plant and some were on the shelf in the plant’s warehouse. Under the interpretation of some in industry and at NRC, the failure of the part installed in the operating nuclear plant would not be reportable under Part 21 because the failure did not meet Part 50 event reporting requirements, but the same defective part, if in the warehouse, would be reportable under Part 21.

Until NRC makes a final determination as to whether Part 21 defect reporting should be required separate from Part 50 event reporting requirements, some licensees and NRC staff will continue to assume that Part 21 evaluation and reporting is not necessary at operating nuclear power plants unless the defect causes an event. Accordingly, please provide the proposed corrective action for the unresolved recommendations and an updated status of the resolved recommendations by August 20, 2011. If you have any questions or concerns, please call me at 415-5915 or R.K. Wild, at 415-5948.

...The response states that it agrees that Part 21 and associated staff guidance are open to interpretation. The fact that NRC staff and licensees have varying interpretations of Part 21 reporting requirements is the problem OIG identified in the subject report.

...Does not clearly indicate that the staff will propose clarification so that Part 21 is in full conformity with Energy Reorganization Act of 1974, As Amended, Section 206, Noncompliance, with regard to industry’s obligation to report to NRC defects in basic components that could cause a substantial safety hazard.

... Substantial safety hazard means a loss of safety function to the extent that there is a major reduction in the degree of protection provided to public health and safety for any facility or activity licensed or otherwise approved or regulated by the NRC, other than for export, under parts 30, 40, 50, 52, 60, 61, 63, 70, 71, or 72 of this chapter.

So the above picture are examples of cavitations. Remember a 5 by 12 inch loose blade in Palisades. They only talk about pieces broken...they never talk about how worn the rest of the blades are.

April 10:

Basically controlling the sequencing of the PCP means they start the impellers who are weld free before the impeller who have been welded!

On the Oct, 1211 Palisades had a incident where one of their PCP pump broke off a impeller blade. They continued operating the plant for about 10 months...then went into outage. They did a simple search for the blade...couldn’t find it. IR 2012003 detailed the event. The outage occurred between April 9 and May 12, 2012. IR 2012003 was written up post this outage. During the Palisades 2014 outage, this is when they found the Oct, 2011 broken blade when they did a ten year inspection of core components...they removed components from the core gaining the ability to see this stuck blade.

I consider the NRC not mentioning Palisades couldn’t find the broken blade constitutes a cover-up in IR 2012003. The NRC should have given outsiders opportunity to make comment or inter into a process like a 2.206. The NRC secrecy impeded my ability to interact in an agency process with a dangerous and untrustworthy nuclear poor staff.

In the direct vicinity of the Oct 11 broken blade event Palisades was starting up from the yellow finding  DC bus breaker short and this placed employees in serious risk of death. There weren’t following their procedures...the procedure if followed won’t have worked. During that time they were dealing with multiple shutdowns with the leaking safety injection/refueling water tank and six shutdowns for a host of other reasons. Palisades with their operations and shutdown was considered one the most economically vulnerable plant is the USA. I think the NRC secrecy with not disclosing the unrecoverable blade and forcing the staff to do a ten year style inspection of the reactor internals to find broken blade was intended by the NRC to protect Entergy and Palisades from millions of dollars of expenses and extending the outage for days.

As I spoke about yesterday, I believe the agency sets these events up to be not scutinizable. Outsiders weren’t notified of the Oct 11 broken bladed until about 10 months after the event and on south side of the outage. In the post outage inspection report, the agency never admitted the licensee couldn’t find the broken. The NRC gave “secret” permission to start up the plant without finding the Oct 11 5 inch by 12 inch broken blade and yanking it out of the core. This plant has a long history of finding broken in their system and not repairing the degraded pump.

Further, I can name a 2007 incident where pieces of blades were found in the core. It sounds like finding PCP blade pieces in the core is a frequent experience. Then the Palisades staff played Abbot and Costello’s ‘Who’s one First’ on what PCP pump did the discovered in the core broken blade come from. They stated up the plant with a pump and pumps missing blades and degraded PCP pumps.        

I consider the free floating 5 by 12 inch broken blade post Oct 11 a direct threat to a very serious partial core meltdown. This is the event that remained unscrutinizable to outsiders for 11 mouths...where the agency hid that the blade could not be found and gave secret permission to restate the plant in a dangerous condition.  I contend that plant should have been shut down shortly after Oct 11 to replace the defective impeller with a missing 5 inch by 12 inch blade and inspect all the other impellers for cracks. The NRC should have forced the staff to find and remove the missing blade up and including a ten year style core internal inspection. I know it would have been very expensive...that is why a staff should preclude the possibility of broken PCP blades and degraded pumps. I am convinced if they would have found the blade in the current stuck position between the vessel and the flow shirt shorty after Oct 11it could have been easily removed. I am convinced 11 month later in the April 2012 outage if the NRC would have forced the Palisades staff to find the Oct 2011 blade it would have been removable. I’d like to see the Palisades internal report and analysis near the May 12, 2012 startup, where Palisades thought the broken 5 inch by 12 inch laid in the plant. It doesn’t take a PhD to figure it was somewhere near its current location....they knew it was there.

Right, again the agency sets this up to be unscrutinizable...all the information hidden...until after the bulk of the operation threat is long gone past a possibility. The outage is long gone by and the agency now analyses what they feel what will make them gone. You get what I am talking about...the NRC makes Palisades unscutinizable to outsiders. The big picture here is the agency is making themselves and congressional oversight unscutinable to outsiders. The NRC gets to pick the selective happy news to the outsiders making government unaccountable to the voters!