As I been saying for years, if the NRC would have hammered Entergy with a blizzard worth of NRC inspection hours in 2013 irrespective of apparent risk according to their nuclear village violations and significance system, they would have cleared out the possibility of future violations and the big one in the Dec/Feb 2015 blizzard Nemo LOOP. Or at least Pilgrim would have voluntarily shutdown for this blizzard and the next...wouldn't have had the LOOP, scram or SRV problems.
All I am saying is global risk from events before the 2013 "excessive scram violations" to the Nemo LOOP violations would have been drastically reduced if the NRC didn't obey their reactor oversight process. It looks at events in an inappropriate span of time that is favorable to a plant. If they were allowed to hit Pilgrim hard in the easily detectable plant decline in the 2012-2013 in timeframe with a host of inspections...bringing immediately to light and amplifying the seeming significance of each problem like the emerging problems with the 3 stage SRVs, then early on Entergy would be made to see the errors of the ways. All the riskful ways in 2014 and 2015 would have not occurred. So they never see all the past and current risk and significance in real time, and anticipate the easily predictable future risk they could have prevent. How much risk could the NRC have prevented?
The fatal flaw in the Reactor Oversight Process is the NRC just looks at a licencee's favorable selective subset list of all risk...not looking at all the holistic risk and and safety significance.
The NRC employees as happy as a clam if they are just following some approved policy or procedures making their bosses happy..they have no care if they don't really understand what they are doing.
These guys are just gaming the system and favorably engineering outcomes in the name of self interest.
The NRC determined that the performance at Pilgrim has been in the Repetitive Degraded Cornerstone Column (Column 4) of the Reactor Oversight Process (ROP) Action Matrix since the beginning of the first quarter of 2015 following the final significance determination of a White finding under the Mitigating Systems Cornerstone referenced in a separate letter issued on September 1, 2015 (ADAMS Accession No. ML15230A217). Pilgrim was already in the Degraded Cornerstone Column (Column 3) of the ROP Action Matrix for more than five consecutive quarters as of January 1, 2015, due to two open White inputs under the Initiating Events Cornerstone. In Supplemental Inspection Report 05000293/2014008 (ML15026A069), dated January 26, 2015, the NRC noted that Pilgrim did not adequately evaluate the causes and take or plan timely corrective actions to address the issues associated with a high number of unplanned scrams which occurred in 2013. As a result, the two White inputs under the Initiating Events Cornerstone remained open for greater than five consecutive quarters and were in effect when the new White finding under the Mitigating Systems Cornerstone was identified in an exit meeting on March 20, 2015, as documented in Special Inspection Report 05000293/2015007 (ML15147A412), dated May 27, 2015. The White inputs under the Initiating Events Cornerstone have subsequently been closed as of June 30, 2015, due to the successful completion of a follow-up inspection in accordance with Inspection Procedure (IP) 95002 as documented in Inspection Report 05000293/2015009 (ML15169A946) dated June 18, 2015.
The Nuclear Regulatory Commission
approved changes today to the agency’s Reactor Oversight Process, adjusting the
criteria for subjecting a nuclear power plant to additional oversight and directing
the staff to develop new guidance to help identify weaknesses in a licensee’s
performance. The Commissioners approved
a staff recommendation to require three low-to-moderate safety significance
(white) inspection findings or performance indicators to push a reactor into
the “degraded cornerstone” category of regulatory oversight, often known as
Column Three of the Reactor Oversight Process Action Matrix. Column One
represents a reactor receiving normal oversight and Column Five is reserved for
reactors ordered to shut down due to unacceptable performance.
The ROP, initiated in 2000,
assesses a nuclear power plant’s performance across seven aspects of facility
operation, called cornerstones. Inspection findings are color-coded as green,
white, yellow or red, in increasing order of safety significance.
Gobbly Goop
Performance indicators are
objective data regarding licensee performance in the different cornerstones. These
safety-significant numbers are compiled by licensees and reported to the NRC;
they are color coded in a similar manner.
The NRC always has a huge population of known unenforced
regulation violations. They can pick from this group anytime they want and
engineer any violation they want.
The current criteria would move a plant
to Column Three based on two white inputs in the same cornerstone or a single
yellow input.
They are pulling on a thread with equating finding level to
safety risk. Do these guys ever show their work?
A staff assessment determined that
from a risk-informed perspective, three white findings, not two, are more
closely equivalent to a single yellow input.
Moving from Column Two to Column
Three involves a significant increase in resources for both the NRC and the
plant: Column Two involves about 40 hours of additional inspections, while
Column Three requires 200 hours.
So we are going to have more yellow finding. There is a
severe disconnect with finding levels and controlling a utility’s aberrant
behavior.
More highly technical talk gobbly goop.
The change to three white inputs in
the same cornerstone better aligns the safety significance to the additional
level of inspection.
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