So here is the LER on this. With all these bum corrective actions and new ones, in 2014 and 2015 they discovered the floor coating twice cracking and a brand new leak in 2015. They are quailified running a nuclear.
Tell you how much value is a non cited violation, the NCV makes their knees tremble.
How come no new LER on the new 2015 leak???
These guys thinks just throwing in the paperwork in the system mysteriously fixes the problem without using money and organization. If you pray to the gods to fix a problem god always come through. The inspector went to the agency's best go-to excuse...the agency is only a sampling regulator and we see only a limit view of the problems in the plant. So the NRC documents Fort Calhoun's eight or nine failed attempts to fix this safety related roof or ceiling leak in this inspection report. It first was a non sited violation in 2006 when the leak was first documented. Then eight fail attempts or more to fix it over almost over a decade threatening the operation of a emergency Diesel Generator, it is still a non sited violation 2016. The NRC's violation or risk determination system is broken down. The repeated nature as this, the NRC's risk determination system doesn't capture the threat...appropriate feedback to change corporate behavior...with having such a chaotic organization running the plant.
I asked why hasn't the NRC warned Fort Calhoun once say in 2006 or 2009, then if they came upon it again, then violating them and severely jack up the violation level. The new inspector told me they severely punished Fort Calhoun by shutting down the plant. You get it, the agency is siloed by congress to be severely reactionary. Only hammer the plant once it's in the news with a big event. I told him I expect the NRC to prevent a 2011 Fort Calhoun. I pay you to prevent events like this.
Tell you how much value is a non cited violation, the NCV makes their knees tremble.
How come no new LER on the new 2015 leak???
Licensee Event Report 2013-015-01:
Unqualified Coating used as a Water Tight Barrier in Rooms 81 and 82
On September 23, 2013, it was identified that the floor structure in Rooms 81 and 82 may not maintain its integrity during a high energy line break environment allowing water to migrate into the rooms below that houses the diesel generators and safety related switchgear. This was reported on September 23, 2013, under 10 CFR 50.72(b)(3)(ii)(B), Unanalyzed Condition (Event Notification 49378). Fort Calhoun Station was shutdown in MODE 5 when the condition was identified and entered into the station's corrective action program as Condition Report 2013-18103.
Inspection report
***September 23, 2013, CR-FCS-2013-18103: During periodic coating inspections, the licensee identified yet again that the coating in Room 82 had degraded during a routine walkdown. The licensee performed another Apparent Cause Analysis and determined that the 2009 RCA was inadequate.
***October 18, 2014, CR-FCS-2014-12894: A building operator identified several cracks and chips in the Room 82 floor coating. Work Order 552343 was generated to recoat the floor, but was never completed.
***January 21, 2015, CR-FCS-2015-0874 and CR-FCS-2015-0883: During a routine walkdown of Room 82, a design engineer identified additional cracks in the Room 82 floor coating. In addition, the engineer identified a piping penetration seal in the Room 82 floor that was degraded. Work Request (WR) 220667 and WR 220668 were generated to repair the penetration, and WR 220618 was generated to recoat the floor.
***October 14, 2015, CR-FCS-2015-11976: Maintenance personnel identified a water intrusion into Room 63. Water had been dripping around the primary starting air compressor. The leak was identified to be from an auxiliary steam system leak in Room 82.
You know what this reminds me of; the fire water piping leak in Indian Point unit 1 over many years leading to a huge flooding event. They stuck the very small piping leaking problem into their paperwork or computer problem documentation system repeatedly. The small leak kept getting lost in their monsterous bureaucratic system and their godzilla priority system until the huge pipe completely burst. I believe the pinhole leak was spinning in the bureaucracy uncorrected for a decade. Hierarchical bureaucracies are supposed to be highly efficient and effective at identifying and fixing problems. They are not designed to highly efficient at burying and hiding problems.I talked to the new Fort Calhoun inspector yesterday about this problem. Its the "black swan" event proving either the site is severely backsliding or the correction coming out of the NRC 's mandatory plant shutdown in 2011 wasn't deep enough.
I asked why hasn't the NRC warned Fort Calhoun once say in 2006 or 2009, then if they came upon it again, then violating them and severely jack up the violation level. The new inspector told me they severely punished Fort Calhoun by shutting down the plant. You get it, the agency is siloed by congress to be severely reactionary. Only hammer the plant once it's in the news with a big event. I told him I expect the NRC to prevent a 2011 Fort Calhoun. I pay you to prevent events like this.
I asked the inspector, is cracking concrete walls and floors acceptable in plant licensing and USFAR. He laughed saying, I am not a licensing expert. I don't know. Not, I'll get back to you mike.He scoffingly told me, normal buildings are filled with concrete cracks. I've seen concrete building with a lot more cracks. So is telling me his opinion...not a engineering fact. Where is his evidence and codes where it is acceptable with a foundation to have a lot of cracks? These guys advocate for the industry not needing any facts to back him up when they talk off the cuff. I seen a lot of building concrete foundations without a single crack in them. A good quality concrete foundation or building never has a crack in the crack on the concrete.
Generally NRC officials talking to outsiders like me, they get quickly into defending the industry interest. They rarely stay in the government regulatory neutral role.By the way, the inspector was very talkative to me yesterday and he respected me. He knew my name before I said it, he reminded me I had talked to him more than once before.
April 30, 2009
I think it is a huge threat when any water is leaking from the ceiling or through a wall...its alway should be a rather large violation because this piece of equipment is so valuable. Almost a decade to fix this? These guys should be responsible for completely fixing it right on the first leak...taking more than one bite out the apple, it indicates serious organization dysfunction.
FindingsIntroduction. A Green self-revealing noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, “Corrective Action,” was identified for the licensee’s failure to take prompt corrective measures after identifying that water could penetrate cracks in the turbine building concrete floor and adversely impact the operability of an emergency diesel generator and safety related switchgear. Cracks in the floor of turbine building mechanical equipment room were identified in February 2006, when water was observed
***Maybe in the 2009 or the Feb 9, 2011 leaks, the NRC should have severely hammered the hell out of Fort Calhoun over these leaks. This should have cued the NRC into looking more closely into the site organizational problems. They would have found a lot of serious problems. Then rock the organization with a severe violation level into having a change of heart....fundamental reform. Then the summer of 2011 events won't have happened.
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You get it, often looking underneath a perceives insignificant problem leads to discovering huge organization problems under the iceberge.
The IAEA inspection team urged the Nuclear Regulation Authority to enhance inspection competence and the government to amend its nuclear safety law to make on-site safety checks more effective and flexible.
Mission leader Philippe Jamet, a French regulatory commissioner, said Japan's inflexible inspection rules do not allow inspectors to move freely at nuclear facilities or respond quickly when there is a problem.This inspection process is severely flawed in USA nuclear plants. This is similar to the recent IAEA report finding on the Japanese nuclear regulatory authority. NRC regulations severely restricts an inspector from getting into the business of the plant like Fort Calhoun. This is how political campaign contributions influences federal regulations. I proposed an additional area of inspections:1) Inspection report areas defined by NRC regulation.
2) An NRC inspector or official reported observation of events at the plant. These professional observations in inspection reports would be unconstrained from the typical NRC regulations and would be protected areas from intimidation to the inspector and other NRC officials. These are my observation of important or emerging issues at the plant(either in house use or for the industry in general as a mean of drawing attention)needing attention. These inspector or official "observations" would be totally disconnected from any violation or penalty to a licencee. Just a general comment or warning and a inspector's ability to speak totally free without repercussion or restrains.
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leaking
into the Diesel Generator 1 room (Room 63). The licensee took no immediate
corrective actions to evaluate or repair the cracks. In February 2009, water
was again observed leaking into Room 63, resulting in unexpected tripping of
breakers associated with the Diesel Generator 1, secondary compressor motor
starter.
I suspect the cracks are moving as the building and concrete is heated up or cooled off. I'll bet you the concrete foundation at Vogtle or other new construction nuclear plant doesn't have one crack in it.
Description. On February 11, 2009, maintenance workers were removing tags for maintenance on Diesel Generator 1, and determined that three breakers associated with the secondary air compressor had tripped. Investigation revealed that arcing on the power leads had occurred due to the introduction of water into the breakers from the ceiling of the Diesel Generator 1 room (Room 63). The source of the water was standing water on the floor of the turbine building mechanical equipment room (Room 82), which is located directly above Room 63 (as well as the Diesel Generator 2 room, and the east and west Switchgear rooms). After the water was removed from the floor of Room 82, several cracks were evident in the floor, which provided a path of water from Room 82 to Room 63.
***Careless repair of a concrete crack in caulking without understanding the fundamental mechanism causing the crack.Painting it is so unprofessional...
The inspectors’ review of corrective action documents determined that a condition report was created (CR 200600399) which documented an event that occurred on February 1, 2006. That event also involved water flowing through the ceiling of Room 63 near the area of the starting air compressors. The condition report was classified as a Condition Level 6, which was the lowest condition report classification. The condition report was closed to a work request since “equipment is not an SSC [structures systems and components].” The resulting work order applied caulking to certain areas of the floor in
Need a extent of condition or cause on all concrete cracks at Fort Calhoun plant...Room 82, but did not address all of the floor cracks or the
Did any building settle as result of the flooding at Fort Calhoun?
potential impact on safety-related equipment. The licensee’s failure to recognize that cracks in the floor of Room 82 could impact the operability of the diesel generators resulted in an improper classification of the condition report, limiting the review and depth of subsequent corrective actions. The corrective actions that followed were inadequate to ensure a watertight surface between Room 82 and all the rooms located below it.
Analysis. The inspectors determined that the failure to take prompt corrective actions to address a condition adverse to quality was a performance deficiency. This finding was more than minor because the failure to perform adequate corrective actions on the turbine building floor, if left uncorrected, could become a more serious safety concern. Specifically, water could seep through the floor and render the emergency diesel generator and/or safety related switchgear inoperable. Using the Manual Chapter 0609, “Significance Determination Process,” Attachment 4 “Phase 1 - Initial Screening and Characterization of Findings,” this finding was of very low safety significance because it: 1) was confirmed to result in a loss of functionality of the secondary compressor motor starter; 2) did not represent a loss of safety function; 3) did not result in a loss of a technical specification required train for more than its allowed outage time; 4) did not result in a loss of risk significant equipment for more than 24 hours; and 5) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding did not have a crosscutting aspect because the performance deficiency was aged and not indicative of current licensee performance.Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, “Corrective Action,” states, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, in February, 2006, the licensee failed to promptly correct a condition adverse to quality (cracks in the turbine building mechanical equipment room floor). The cracks were a condition adverse to quality because they permitted water to leak on to safety related equipment, which could challenge safety related equipment operability. The licensee entered this issue into their corrective action program as Condition Report 2009-0687.Because this finding was of very low safety significance and has been entered into the corrective action program as Condition Report 2009-0687, this violation is being treated as a noncited violation, consistent with section VI.A of the NRC Enforcement Policy: NCV 05000285/2009002-01, Failure to Implement Adequate Corrective Action for Floor Cracks.
January 21, 2016
Why wasn't this a LER?Findings.a Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with Emergency Diesel Generator Room WaterIntrusionsIntroduction. The team identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, “Corrective Actions,” for the licensee’s failure to take adequate corrective action to prevent repetition of a significant condition adverse to quality. Specifically, since February 2009, the licensee failed to prevent repetitive water intrusions from the Auxiliary Building HVAC room (Room 82) into the number one Emergency Diesel Generator room (Room 63).Description. On February 11, 2009, the licensee had documented a significant condition adverse to quality due to water intrusion from the Auxiliary Building HVAC room (Room 82) into the number one emergency diesel generator room (Room 63), located below. The water intrusion had caused water to leak onto the secondary air compressor motor starter in Room 63 and tripped the associated breakers. This electrical transient then caused the number one emergency diesel generator, which was running for surveillance purposes, to trip. The licensee initiated Condition Report CR-FCS-2009-0687 and subsequently determined that an unanalyzed condition had existed by which an auxiliary steam leak in Room 82 could potentially result in water entering both diesel generator rooms through the floor of Room 82. This condition had existed at least since February 1, 2006, when CR-FCS-2006-0399 was written to document water dripping from the same crack in the ceiling of Room 63 above the secondary air compressor. This event was documented as a Green NCV in NRCInspection Report 0500285/2009002 (ML091200069).
The licensee performed a root cause analysis (RCA) following the event in 2009. The analysis determined that the root cause was a failure to document, in the licensee’s USAR, the implicit assumption that the floor in Room 82 shall not leak. As a result, a program was not established to assure the integrity of the flooring. Licensee corrective actions included the following:
- •Coating the Room 82 floor.
- •Revising the USAR to document the implicit assumption that floors of rooms analyzed for medium and high energy line breaks are leak tight.
- •Revising the periodic structural inspection of the Auxiliary Building to ensure all ceiling cracks, for rooms that are susceptible to internal flooding, are documented and evaluated.
Flooding and switchgear breaker two year shutdown. You would think by Fort Calhoun getting punished with the two year shutdown and all their mandatory corrective actions...the new conscience of the plant....they could fix it right the first time. Why didn't the intense NRC inspection during the recovery catch the water leaking into a diesel generator room.Following implementation of the above corrective actions, recurrent leaks into Room 63and identified examples of inadequate Room 82 floor coating were identified by the licensee and documented in the licensee’s corrective action program, these included:
- •January 9, 2011, CR-FCS-2011-0156: The licensee identified water leaking into Room 63 at approximately 3 drops per minute. The licensee performed an evaluation and determined that this leak was from a previously identified ceiling crack, and that the drip would not impact the operability of any equipment in this location.
But why in the above?
- •October 6, 2012, CR-FCS-2012-14958: The licensee identified water dripping into Room 63 while placing Room 82 auxiliary steam in service. On October 12, 2012, the licensee generated Work Order 461213 and made repairs to the Room 82 floor coating where chips and cracks were identified. The licensee then performed an
- Apparent Cause Analysis, and determined that the floor coating previously installed was not adequate for Room 82. The licensee generated Engineering Change (EC) 62082 to modify the floor coating to a more suitable material. This EC was implemented on October 22, 2013.
- •September 23, 2013, CR-FCS-2013-18103: During periodic coating inspections, the licensee identified yet again that the coating in Room 82 had degraded during a routine walkdown. The licensee performed another Apparent Cause Analysis and determined that the 2009 RCA was inadequate.
- •October 18, 2014, CR-FCS-2014-12894: A building operator identified several cracks and chips in the Room 82 floor coating. Work Order 552343 was generated to recoat the floor, but was never completed.
- •January 21, 2015, CR-FCS-2015-0874 and CR-FCS-2015-0883: During a routine walkdown of Room 82, a design engineer identified additional cracks in the Room 82 floor coating. In addition, the engineer identified a piping penetration seal in the Room 82 floor that was degraded. Work Request (WR) 220667 and WR 220668 were generated to repair the penetration, and WR 220618 was generated to recoat the floor.
- October 14, 2015, CR-FCS-2015-11976: Maintenance personnel identified a water intrusion into Room 63. Water had been dripping around the primary starting air compressor. The leak was identified to be from an auxiliary steam system leak in Room 82.
Really an act of a employee falsifying internal documents and impairing the NRC oversight?Following the water intrusion event on October 14, 2015, the licensee recoated the floor per an existing WO 552343 and cancelled the work requests associated with the degraded floor penetration (WR 220667 and WR 220668), since work planners had assumed that all repairs had been made.
A broken Significance Determination Process...The inspectors performed a walkdown of Room 82 following repairs to the flooring on November 18, 2015, and noted that the degraded pipe seal had not been fixed, and that water intrusion via this piping penetration was still a vulnerability to the rooms below. The inspectors informed the licensee, and at this time, CR-FCS-2015-13151 was generated to repair the degraded fire seal.Analysis. The team determined that the licensee’s failure to implement adequate corrective actions to prevent repetitive water intrusions into Room 63 was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the protection against external factors attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, water intrusion events from Room 82 into Room 63 could challenge the reliability of the emergency diesel generator when relied upon during a loss of offsite power. Using Inspection Manual Chapter
0609, Appendix A, “The Significance Determination Process (SDP) for Findings At-Power,” Exhibit 2, “Mitigating Systems Screening Question,” dated June 19, 2012, inspectors determined that the finding was of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee’s maintenance rule program. The finding has a problem identification and resolution cross-cutting aspect within the resolution area because the licensee did not take effective corrective actions to address issues in a timely manner commensurate with their safety significance [P.3].Enforcement. Title 10 of the Code of Federal Regulations Part 50, Criterion XVI, “Corrective Actions,” requires, in part, for significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. Contrary to the above, between February 2009 and November 2015, measures established by the licensee to correct a significant condition adverse to quality did not assure that corrective actions were taken to preclude repetition. Specifically, corrective actions taken to address water intrusion from Room 82 into safety related emergency diesel generator Room 63, a significant condition adverse to quality first identified on February 11, 2009, were not effective to prevent recurrent water leaks. Immediate corrective actions to correct this condition included evaluating the Room 82 flooring for operability and recoating it. This violation is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensee’s corrective action program as CR-FCS-2015-11976 and CR-FCS-2015-13151. NCV 05000248/2015009-01, “Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with Emergency Diesel Generator Room Water Intrusions.”
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