Update July 1: setting the record straight.
I got as call back. Seems Mr. Kim is busy and traded me off to the new guy in the department. It would have been proper to email me a notice that Mr. Kim is no longer my petition manager, your new manager is so and so. The new guy don't get how important it is to get this information down in the system. His intention was to send the transcripts along with the acceptance letter. How does everyone else do it, does he think he gets to decide on his own. Seems I am training him. I wonder what kind of systematic training this guy has had over administering the 2.206 process???
Is the agency "throwing the new guy" sand in the gears as a way to gum up the system.
Does the NRC have enough money and manpower to properly administrate the 2.206 process?
I don't like the way this guy answers me, we talked a little about why the Belgium reactors have delayed startup till Nov 2015. He says it unrelated to the vessel cracking issue. Basically the expert committee decided the agenda the licensee needs to meet to be safe and a restart...the licensee needs to write a report according to the committee's agenda explaining how they will be safe with the flaws. We have no idea what the additional inspections or requirements they will need in order to be accepted by the regulator and then the restart.
The theme is with the NRC in 120 days; they are going to send me a directors decision on whether the industry is safe or not with hydrogen flaking. They are going to tell everyone we are safe with what we got. The theme is, there has been a lot of secret government to government non publically disclosed discussions going on with the hydrogen flakes, the director decision is going to explain what was discussed...update the nation on the hydrogen flakes.
What the agency seems to be doing is answering their own questions posed as my questions...
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So I called my petition manager Mr. Kim, left a message on his phone(about 2:15 pm...asking him to explain my option up in front of me.
Submitted Petition March 26
The Petition pre-hearing accepted April 28
Got to speak to their material expert May 14
scheduled and occurred May 18
NRC notified me by phone the petition was accepted on 6/24. I'll have to get out my 8.1 directive out.
I had to ask to talk to the vessel metallurgist twice. The first time they just conveniently dropped it. I stated to the NRC official I was irked when he didn't acknowledge my first request to converse with a metallurgist (good agency communication), then it was conveniently forgotten. So I had to ask twice. I wrote it up to agency confusion.
Look at this 2.206: "Jet Pump Riser Weld Crack At Columbia Nuclear Plant"
The date the preceding took place is is June 12 (mine occurred May 18)
The transcript came out today on adams.
Why did this guy come out way before mine? How come mine is out yet?
It is obvious I got the agency on some technical issue...they are trying to get their story straight. They are gaming the disclosures on this. I wish I could remember what I said that was so important.
If the would send me a acceptance letter I would remind them again.
Questions for NRC:
- Has anyone received any update regarding the inspection findings and corrective actions taken regarding the Belgium Reactor Pressure Vessel quasi flaw indications?
- Have been any other indications found in any other NPP RPV?
- Please describe how the vessels are ultrasonically inspected(for cracks)?
- Explain the testing of capsules.
- Explain the sensitivity of ultrasonic detector used in vessel inspections…the difference between the Doel 3 and Tihange 2 Nuclear plants and USA plants. What is the best technology?
- I have issues with the codes and regulations under which some of the vessels were accepted for nuclear plant operation.
- Please explain the difference between the vessel codes, regulations and an inspection technology of a 1975 vintage reactor to a current new reactor vessel?
6/25
Doel 3 and Tihange 2 Nuclear
plants
It seems Doel 3 and Tihange 2 are
having issues with getting permission to restart…not safe enough. Might just start for the winters only.
Update 6/24: The NRC Accepted my petition.
Seems the NRC forgot to release my 2.206 transcripts...going to release it soon. Lucky I am not paranoid.
The NRC has accepted my petition. It is the first one they accepted ever.
Seems they were unclear in IN 2013-19 and they want to fix it...what they want the licensees to do.
Basically more clearly explain why it is safe to continue to do what they always been doing.Basically the NRC covering their ass operation...
I wonder if new information has become available from Europe? I believe in the phone call today with the NRC, they would have tipped me off new information has become available. The new information doesn't seem plausible to me. But you never know.
By the way, I give great credit to the NRC with them basically doing an agency research on this problem and them finding they need to be clearer on their take over the Belgium reactor cracks problem. They want to get it right on the documents…
I told the NRC, I operate mostly in a environment which is way out of my league...but this is way way way out of my league.
Originally posted on 5/13...reposted
Update May 19:
So, the NRC
entered my Belgium cracks 2.206 into their system. I spoke to the Petition Review Board yesterday. The five takeaways:
Date: Thursday, March 26, 2015 10:56:12
AM
1) The Belgium’s were originally looking for flaws underneath their
cladding. They had to use more sensitive ultrasonic detectors to accomplish
that. This discovered the hydrogen flakes by accident. Then they had to jack up
the sensitivity of the ultrasonic detectors even more to inspect the flakes. The level of the detector's sensitivity
is crucial in detecting these kinds of flaws. I think they use not sensitive ultrasonic
detectors in the USA dictated by the USA nuclear industry.
Imagine that, they found these flaws shutting down two reactors for
years by accident. I reminded the PRB with the new Areva vessel weakness...it occurred due too little league forging shortcomings and at least one new bad vessel was buttoned up in a reactor building before they discovered it. It can happen in reactor heads also.
How FANC Discovered Hydrogen Cracks
01.1 The findings in Doel-3 and Tihange-2 "In 2012 a new type of in‐service inspection (ISI) of the reactor pressure vessel (RPV) by ultrasonic testing (UT) was introduced in Belgian nuclear power plants. These inspections were introduced earlier in France to search for underclad cracks that may be present in the base metal directly below the interface to the cladding. These underclad cracks, if present, have perpendicular orientation to the surface and were created by the welding process of the austenitic strip cladding onto the ferritic base metal." Underclad: Looking for Cracks under the vessel cladding.
2) The US only does vessel seam weld UT inspection according to the NRC’s
top vessel metallurgist once a decade from the inside. He reports in the USA,
there never has been discovered in the vessel seam one flaw. I think it
is an inch or two on each side. This seems to be nonsensical...the detectors
are set too low with over a hundred vessels.
3) Much greater than 95% of the vessel are never inspected by any means. That is the main takeaway: we don't inspect these vessels because the agency defines them as mystically invulnerable.
4) The Belgium’s threw a hydrogen flake into a high flux test reactor.
It came out more susceptible to cracking than the operating theoretical models. It worries me the metallurgic theoretical models might not match reality.
5) The NRC’s vessel metallurgist thought it invaluable to grab dead vessel
samples for inspection that backs up theoretic models and add to the world knowledge
concerning metal responses in a high temperature and radioactive environment.
He thought my idea of grabbing sample was great and he would back me up to the hilt with this. There is always an issue of
getting dose versus the value of scientific knowledge that stymies getting these specimens.
I told him the nuclear utilities generally feel there is no benefits with studying
the vessel metal, it will just lead to spending more money and increase regulatory
burdens (Yankee Rowe)...
I first assumed the hydrogen causing the flakes came from the hydrogen in the
coolant. This is wrong. It comes from the forging process with water in the
metal...oxygen and hydrogen separate. The hydrogen comes from that.
Update May 14:
Robert Hardies
Mr. Hardies started his U.S. Nuclear Regulatory Commission (NRC) career in 2005 as a Senior Materials Engineer in the Vessel and Internals Integrity Branch of NRR in DCI. In 2006, Mr. Hardies became Chief of the Component Integrity Branch in the Division of Engineering in the Office of Nuclear Regulatory Research where he was responsible for research related to structural integrity of reactor coolant primary pressure boundary piping and vessels. Prior to joining the NRC, Mr. Hardies worked for the David Taylor Naval Ship Research and Development Center and for 16 years in the commercial nuclear power industry for Constellation Energy. Mr. Hardies received a Bachelor of Science degree in Metallurgy from the Pennsylvania State University and a Master of Science degree in Materials Science and Engineering from the George Washington University.
Belgium Crack in US Vessels?
I requested for my 2.206 to be able to talk to a reactor vessel expert. He’s got to be a PhD. I going to let him do most of the talking and keep my mouth shut as much as I can. I don't want him to really see how stuppid I am? The NRC scheduled a telecom with him with me this afternoon on 24 hour notice. He certainly fits the bill as expert.
Anyone got any good question you want posed to Dr. Hardies this afternoon.
.They say it’s a casting problem, but in the process of this investigation they discovered the metal was much weaker than expected.
Update:May 13
So I'll get to try and pump this NRC reactor vessel expert. I certainly will get the NRC's take concerning the Belgium Reactor cracks problem.
It was gracious of the NRC to let me talk to the expert.
Today at 9:27 AM
Dear Mr. Mulligan,Regarding your 2.206 petition: Belgium Nuclear Plant Vessel Cracks in USA Plants
I was able to schedule a half hour telecon with our subject matter expert for tomorrow, May 14, 2015 from 1430 to 1500. Please confirm this time works for you.We have scheduled an opportunity for you to discuss your petition with the petition review board on May 19, 2015, from 1400 to 1500. Please confirm this time, also.
RegardsSteveStephen S. KoenickSenior Project ManagerPlant Licensing Branch IV-2 (LPL4-2)Division of Operating Reactor Licensing (DORL)Office of Nuclear Reactor Regulation (NRR)US Nuclear Regulatory Commission(301) 415-6631Stephen.Koenick
It is interesting how the NRC framed my 2.206 in this?
"requesting emergency ultrasonic inspection testing for U.S. reactor plants similar to the cracks discovered in Belgium nuclear power"
To'Michael Mulligan' (steamshovel2002@yahoo.com) Apr 28 at 9:29 AM
Mr. Mulligan,
Your petition dated March 26, 2015, requesting emergency ultrasonic inspection testing for U.S. reactor plants similar to the cracks discovered in Belgium nuclear power plants, was assigned to the Office of Nuclear Reactor Regulation (NRR) for review. My name is James Kim, the NRR project manager in the Division of Operating Reactor Licensing (DORL) and I have been assigned as a petition manager.In accordance with the 10 CFR 2.206 process, the Petition Review Board (PRB) is offering you an opportunity to address the PRB to provide any additional explanation or support for the petition before the PRB makes an initial recommendation. Please let me know whether you would like to address the PRB.
Thanks,
James Kim Project Manager, DORL
U.S. Nuclear Regulatory Commission
1-301-415-4125E-mail: james.kim@nrc.gov
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