Friday, April 28, 2017

Junk NRC and Watts Bar's Safety Culture?

***You get how pathetic the NRC is? It took a employee talking to allegations...to make the residents go looking for safety culture at Watts Bar. It makes you wonder how structurally preventing the residents from seeing the real plant condition at any plan. Now the residents are implicated. SO why couldn't the residents pick this up on their own during normal inspection routines?

You get in these NRC inspection, the NRC never goes to the employees asking them when trust issues and safety discussion, how did this mistrust exceed the safety of the plant? Actual conditions...    

This looks like the typical extremist southern utility ideology of total dominance and absolute submission by their employees. We are the total gods of our sites, we can lie and cheat to meet our ideological-business agenda of the organization. We totally define truth at our sites independent of our nation's culture of truthfulness and transparency.

The fallacy of the worth of third party safety experts in the industry can clearly be seen in Watts Bar. These experts are just PR arm of the executives. You get it, it's better the third party doing the lying and deceiving than the NRC who catches Watts Bar doing the same. Third party investigators always craft their reports to those that pays them. I would rather the NRC pay for these investigations.

Again, the NRC doesn't enforce truth telling and document inaccuracies and falsification. They think lying and deception aren't safety related.   

Watts bar interfered with the ability of the NRC to oversee the site by lying and deception, this in itself should have been a shutdown issue at both sites for a year. It is the only way to keep the system straight, prevent anyone else from pulling a Watts Bar on the NRC. Shut them down for a years and fired anyone who has a association with intimidating the staff. I doubt this is limited to the TVA or Watts Bar. It is all over the place.  

What everyone is afraid of, is doing a survey on Watts Bar employees asking them how effective is the NRC's oversight of Watts Bar?

Big picture: The NRC is down two commissioner. If indicates our political system is failing the nuclear industry. The silence of the commissioners is the largest symptom of the disease, it has nothing to with the condition of the industry being in calm waters with nothing to talk about.  

Both Watts Bar plant are shutdown now. One being in outage and the other shutdown on a collapse of the huge main condenser. I have talked to experts over this. The collapse of the main condenser is unprecedented in the industry. It a shocking indicator with how poorly build Watts Bar 2 is.


Report: TVA meddled in third-party reviews on Watts Bar Nuclear Plant

"Mistrust permeates the organization," says reviewing consulting firm. CEO says that's the old TVA.

A firm that investigated TVA’s Watts Bar Nuclear Plant has alleged TVA edited third-party reports on the plant's work environment.

TVA's Office of the Inspector General enlisted NTD Consulting Group to review TVA's history of nuclear safety culture issues and the company's response to a "
Chilled Work Environment" letter from the Nuclear Regulatory Commission in March 2016.

The letter was written after a series of allegations reported to the NRC and to TVA's Employee Concerns Program indicating employees were afraid that raising safety concerns would result in harassment, intimidation or retaliation by management.

The NTD group released the
final draft of its report April 19, which contains the results of TVA's most recent NRC inspection.

The inspection report said TVA lacked clear, objective criteria for evaluating how nuclear standards are met. The report called into question the independence of previous reviewing teams that sometimes included TVA personnel, and said the company was not "appropriately self-critical" in looking at the work culture.

TVA President and CEO Bill Johnson said he could not answer whether TVA had a hand in third-party reports, because that information came from employee interviews with TVA's Inspector General, and those are not shared with other company staff.

"I can't answer what consultants were told what or what was told to anybody else," Johnson said.

Johnson also disputed NTD's report, which included information from previous interviews with TVA's Office of the Inspector General.

"The report doesn't represent the current state of affairs at Watts Bar or at TVA," Johnson said. "The NRC told us last March we had a chilled work environment at Watts Bar and we have never contested that fact. We don't contest it, and we've been working hard for the past year to fix it."

The Inspector General did gather the interviews after a confidential informant first reported the chilled work environment in 2015, about a year before the NRC's letter. Upon reviewing the interviews, the NTD group alleged TVA leadership was "in denial" of events that were precursors to the NRC's letter.

"They were clear, covering a period of years," the NTD report said. "It appears there were attempts to downplay the precursors and failures to implement appropriate (corrective actions)."

TVA had hands in investigations?

According to NTD, one of the Watts Bar senior leaders told TVA's Office of the Inspector General they "heavily managed the results" of root-cause analysis reports on Watts Bar's work culture.

Members of management told investigators they had directed some findings be left out of reports because they were worried Watts Bar’s second reactor would not get licensed if there were a problem with the nuclear 
 

Members of management told investigators they directed findings be left out of reports for fear Watts Bar’s second reactor would not get licensed if there were a nuclear safety culture problem.

TVA spokesman Jim Hopson leads a media tour of the new Unit 2 turbine floor Wednesday, Oct. 19, 2016, at the Watts Bar Nuclear Plant. Watts Bar Unit 2 already has provided consumers with more than 500 million kilowatt/hours of carbon-free energy during testing. It joins six other operating TVA nuclear units to supply more than one third of the region's generating capacity, meeting the electric needs of more than 4.5 million homes.(Photo: Paul Efird)

Story Highlights

CEO: Inspector General interviews don't represent "current state of affairs."

Employees told reviewers they felt safer bringing up nuclear safety issues than non-nuclear safety issues to supervisors.

Watts Bar senior leaders reportedly told Inspector General they "heavily managed the results" of reports on work culture.

Latest NRC inspection shows some improvement but still more work to do

A firm that investigated TVA’s Watts Bar Nuclear Plant has alleged TVA edited third-party reports on the plant's work environment.

TVA's Office of the Inspector General enlisted NTD Consulting Group to review TVA's history of nuclear safety culture issues and the company's response to a "
Chilled Work Environment" letter from the Nuclear Regulatory Commission in March 2016.

The letter was written after a series of allegations reported to the NRC and to TVA's Employee Concerns Program indicating employees were afraid that raising safety concerns would result in harassment, intimidation or retaliation by management.

The NTD group released the
final draft of its report April 19, which contains the results of TVA's most recent NRC inspection.

The inspection report said TVA lacked clear, objective criteria for evaluating how nuclear standards are met. The report called into question the independence of previous reviewing teams that sometimes included TVA personnel, and said the company was not "appropriately self-critical" in looking at the work culture.

TVA President and CEO Bill Johnson said he could not answer whether TVA had a hand in third-party reports, because that information came from employee interviews with TVA's Inspector General, and those are not shared with other company staff.

"I can't answer what consultants were told what or what was told to anybody else," Johnson said.

Johnson also disputed NTD's report, which included information from previous interviews with TVA's Office of the Inspector General.

"The report doesn't represent the current state of affairs at Watts Bar or at TVA," Johnson said. "The NRC told us last March we had a chilled work environment at Watts Bar and we have never contested that fact. We don't contest it, and we've been working hard for the past year to fix it."

The Inspector General did gather the interviews after a confidential informant first reported the chilled work environment in 2015, about a year before the NRC's letter. Upon reviewing the interviews, the NTD group alleged TVA leadership was "in denial" of events that were precursors to the NRC's letter.

"They were clear, covering a period of years," the NTD report said. "It appears there were attempts to downplay the precursors and failures to implement appropriate (corrective actions)."

TVA had hands in investigations?

According to NTD, one of the Watts Bar senior leaders told TVA's Office of the Inspector General they "heavily managed the results" of root-cause analysis reports on Watts Bar's work culture.

Members of management told investigators they had directed some findings be left out of reports because they were worried Watts Bar’s second reactor would not get licensed if there were a problem with the nuclear safety culture.

They also said they were worried the reports would reflect poorly on senior management.

The confidential informant's 2015 tip on the plant's work environment also triggered an internal investigation by TVA's Employee Concerns Program. The ECP hired two consultants - one used to be a manager at TVA - to perform the investigation.

The consultants were told what they could include and must exclude in their reports. One of the consultants who performed the ECP review told the Inspector General he believed he was not invited back for a second debrief because Watts Bar senior management did not like what he wrote.

Once the consultants finished their report, they said TVA's ECP personnel edited it to remove any mention of the term "chilled work environment" and replaced it with the term "degraded work environment," a non-regulatory phrase that was reportedly never used by TVA or the NRC before.

The new phrase appeared in subsequent TVA reports at least 28 times.

The NTD group said the use of the term was an "unfortunate choice" that may have given an inaccurate picture of Watts Bar's work culture. Joey Ledford, an NRC spokesman, said that though the NRC does not recognize the term "degraded work environment," he does not believe its use impacted their investigations.

Johnson said TVA avoided using the term “chilled work environment” until it received the letter in 2016 because TVA views it as a regulatory conclusion that only the NRC could declare.

"We would talk about degradation or a degraded environment, which I think is common in the industry," Johnson said.

"Our focus is on meeting the requirements of the NRC, which is the exclusive regulator of commercial civilian nuclear plants."

TVA spokesman Jim Hopson said the NRC has not turned up any specific instances of retaliation, and contends whether it happened was never the issue.

"Perception equals reality in this case," Hopson said. "If there is even a perception people can't raise concerns or use their voices, then things can go off the rails. It's a culture that over time would have allowed something unsafe to happen, and that's why we take this so seriously."

'Mistrust permeates'

The plant has had a history of these perceptions.

In 2016, Watts Bar led the nation in allegations submitted to the NRC, indicating employees did not feel comfortable raising concerns internally.

Several employees reportedly told NRC reviewers in 2016 that they felt safer bringing up nuclear safety issues than non-nuclear safety issues to their supervisors.

In interviews with TVA's Inspector General, employees said they did not trust Watts Bar's Employee Concerns Program because they believed it was not independent from the nuclear plant. The Office of the Inspector General validated the employees' concerns about the ECP when another survey revealed 50 percent of Watts Bar's ECP personnel did not feel comfortable going forward with the safety concerns employees told them.

"Mistrust permeates the organization, yet in leadership's mind the challenge is contained to operations and represents a miscommunication problem rather than a need for management to regain trust and credibility," NTD's report said.

In 2009, the NRC ordered TVA to make changes after two investigations revealed a maintenance mechanic at Browns Ferry Nuclear Plant in Alabama was demoted for raising a safety concern.

That same year, Synergy Consulting Services completed a survey report indicating instances of mistrust and intimidation existed at Watts Bar Nuclear Plant. A second report in 2011 said the behaviors were continuing. Subsequent reports by Synergy and other groups highlighted
"significant weaknesses" in Watts Bar's safety culture.

NTD's review of TVA's Inspector General interviews pointed to several instances of employee intimidation that occurred in the years leading up to the NRC's chilled work environment letter:

According to NTD's report, a manager told the Inspector General that a senior leader called him into his office after workplace survey results came out one year and instructed him to discipline employees for their answers;

A maintenance employee told reviewers he lived in constant fear he'd lose his job because plant leadership routinely threatened to fire the entire staff and bring in a contractor;

Another employee said that during a refueling outage, one manager would come into the shop, sit down and glare at employees without speaking to them. He later told employees his intention was to get them to "the breaking point" so he could get the most out of them;

A senior reactor operator said he was "relieved from watch" for raising a safety concern to his supervisor. The NTD group believed the operator's concern was valid, but TVA reviewers did not corroborate it.

Other workers refused to speak to reviewers or flipped their badges over their shoulders so they could not be identified for retaliation.

"TVA failed to look for, and in turn deal with harassing, intimidating, retaliatory or discriminatory behaviors of the senior leadership that were common knowledge among personnel in operations and other departments," the NTD said, adding that precursors to the NRC's letter were not "subtle," as the ECP has previously stated.

TVA CEO questions validity

Johnson raised concerns about the validity of the NTD group's report in a response letter, arguing the report’s authors reviewed the information secondhand and didn’t observe the demeanor or credibility of the employees interviewed. TVA's Inspector General office is independent of the company itself, so Johnson did not witness the interviews firsthand either.

"We don't know who said what in what interview to whom. We are not privy to that information," Johnson said in an interview after the NTD report was released.

TVA President and CEO Bill Johnson pauses in front of the cooling towers before announcing the new Unit 2 reactor has entered commercial operation Wednesday, Oct. 19, 2016, at the Watts Bar Nuclear Plant. "Watts Bar Unit 2 is a key part of our commitment to produce cleaner energy without sacrificing the reliability and low cost that draws both industry and residents to our area," said Johnson. (Photo: Paul Efird)

In his response to NTD, he wrote that he questioned the credibility of the interviews because the investigators were armed and credentialed and interviewed some employees more than once. He also alleged investigators may have used tactics designed to pressure or intimidate interviewees.

After the report was published, he added that during the time frame in which the interviews were likely given, TVA was trying to complete the
second Watts Bar reactor.

"This was a stressful environment," he said. "People were tired. There was a lot of work going on and to put it in succinct terms, I think we stressed the workforce a little too much."

Corrective actions taken

Johnson said that since the NRC's letter, TVA has replaced the management team at Watts Bar and is working to regain employees' trust.

NTD reported that TVA hired a specialist after it received the NRC's chilled work environment letter to ensure senior leadership at Watts Bar would
"own the situation."

Wednesday, April 19, 2017

Junk Plant Indian Point 3 Baffle Bolts: How Can You Ever Trust a Nuclear Safety Evaluation Again by Anyone

More failed bolts discovered at Indian Point
BUCHANAN – It was a little over a year ago when Indian Point unit 2 reactor core baffle bolts were found missing or impaired, causing opponents of the nuclear power plant to raise their voices against continued operation of the facilities. At that time, 227 of 832 bolts were found either degraded or missing.

Since then, an agreement was reached to permanently shut down units 2 and 3 in 2020 and 2021.

Now, it has been learned that 256 of the 832 bolts that keep the inner plates of the reactor core from coming apart in unit 3 were impaired.

Riverkeeper has been in the lead along with the governor to close down the facilities.

Riverkeeper spokesman Cliff Weathers said Wednesday the cause of those two situations must be determined immediately.

“We need to know why these two reactors are the only ones to suffer such problems. It is incumbent upon the Nuclear Regulatory Commission to conduct a root-cause analysis of the problem. We don’t know if it is a design or structural problem or just a maintenance issue, but until the NRC determines the cause, they should not let unit 3 reopen,” he said.

Unit 3 has been off-line for weeks for a scheduled refueling.
Here is the NRC's Blog evaluation summation.
Entergy, Indian Point’s owner, is in the process of analyzing the condition and replacing the degraded bolts. It will also assess any implications for Indian Point Unit 3, though that reactor is believed to be less susceptible to the condition for several reasons, including fewer operational cycles.

Monday, April 17, 2017

South Korean Hanul (6 plants) Nuclear Facility Under North Korean Attack, 2 & 4 Are Melting Down

Nobody knows if ballistic missiles or infiltrators? Might have come from a submarine launched medium range ballistic missile with a huge weapon's load.

NRC Office Of Inspector Generial(OIG) Wants To Interview Mike Mulligan Over The 2.206 Complaint Process

Update April 20

This was part of my pitch trying to get the OIG auditors to make a case study on the 2.206 failure over the Pilgrim SRVs.

My Thinking Notes
Title: 10 CFR 2.206 Petition RE
Pilgrim Nuclear Power Station
Docket Number: (n/)
Location: teleconference
Date: Thursday, April 11, 2013
Would you look over this Pilgrim 2.206 prehearing transcript.
Upon first installation with the so caled new SRVs in 2011, the first leak occurred within two weeks of first heat-up.
I have had a lot of experience with 2.206s. The routine of the process changed without notifying me. The chairman was being rude to me and unprofessional…I interpreted this behavior as intimidation and part of a coverup. I clearly stated it in the meeting. Hope they saved the recording of this? The tone of this was horrid.
Why wasn’t there a investigation over this 2.206 process intimidation?
Why didn’t somebody in the meeting report that mike felt intimidation in the proceeding? Why no transparent investigation of it?
There were some 15 to 20 officials listening in on the bridge. Why didn’t somebody report that mike felt intimidation and a cover-up here? A least a investigation to cover the NRC’s asses. Maybe if the OIG got involved, ordered a huge special inspection in 2013…maybe the 2015 SRV blizzard event wouldn’t have happened and Entergy would have made the rest of their bad actor plants to straighten up.
My Pilgrim 2.206 date: March 7, 2013
ANO’s dropped stator: March 31, 2013
***I requested in the 2013 2.206 the Pilgrim SRV problem be referred to the OIG. Was it referred to OIG? I considered the OIG a black box. How was my OIG complaint dispositioned? I frequently get from the NRC inspectors, “I’ll refer your complaint to the OIG”. I have no idea if the resident sent the message to OIG, if the OIG dispositioned the complaint and why was it rejected. Is the OIG living in Russia? Is the NRC residents lying to me when they say they are sending my issue to the OIG, just to get me off their backs? The agency and OIG treats us so disrespectfully.          
Why didn’t higher officials not in the meeting sense there was improprieties going with our problem “Mike” after reading the transcripts?
Why wasn’t this reported to the OIG?
If you think the system is straight, you would think, if all the non public licensee reports about the magnitude of the leaks and poor testing leading up to this transcript, the NRC would require Pilgrim to shutdown and replace the SRVs. There was scant public reporting about the malfunctioning srvs, the down powers and shutdown required to replace the valves. The bureaucrats by this excessive secrecy are just protecting themselves from accountability?
We felt as Vermont Yankee was wobbling towards permanent shutdown, the NRC was giving Pilgrim special compensations outside the rules and laws of the NRC. We felt the NRC was withholding inspection resources from the Pilgrim in order to make their record look better than deserved? ANO and Pilgrim were quickly going down the tubes during this period, why couldn’t this all be prevented by the activities of the NRC and OIG.  
Why didn’t the LER system and inspection report system work during this? There was precious little reporting on the troubles of these valves until the next big blizzard in 2015. There was a white finding in this. The finding should have been much higher than it was. All valves should have been inop since 2011 based on the quality of the valves was unknown. The backup power line was unreliable too. It should have been at a much higher violation level. To date, it has been reported as test stand damage to the valves. I got from lead inspector with the upcoming inspection report that Entergy still hasn’t done a root cause on the SRV failures.
Believe me, it is very painful for me to read my comments in the transcripts. I have very poor verbal communication skills when I am nervous and under pressure.
Why didn’t the 2013 blizzard 2.206 process work to prevent the dysfunctions in the 2015 Blizzard? I am anticipatory, the NRC is reactionary. Believe me on predicting the future, there is no evidence available about future events. If you are excessively evidenced based, you can never disrupt the upcoming accident.
In hindsight with all the information, all the licensee corrective action and other internal reports, why couldn’t I make my case in real time. Because I didn’t have all of the available evidence. The NRC needs triplicate proof perfect evidence and never obtainable facts in order to get enforcement action.  
Do I just have a grudge with Entergy? A few years or months prior to Pilgrim, I put a 2.206 on the Vermont Yankee SRV actuators. They put in new SRVs just like Pilgrim did. Upon first leak rate testing with the new SRV pneumatic actuators one failed. The actuator shaft buna seals got brittle and leaked based on too much heat. Two of us put in 2.206s trying to figure out what failed. Information was terribly sparse.  As VY controversy pick up steam and the politicians got involved, the NRC got sensitive to their credibility. Many months later in an inspection report (and LER), the IR disclosed VY put in inferior environmental grade SRVs in the plant. They needed Type I SRVs, but there were no replacements available. The vendor talked them into putting in type II SRVs. The heat damage these guys. I don’t think the NRC gave permission via a public discloser it is ok to put information inferior grade SRVs into the plant. Why didn’t the NRc demand a 50:59 to allow VY to put inferior grade SRVs into the plant?
At this point, I felt the NRC lost control of enforcing environmental and safety regulations on the SRVs. I feel it is happening all over the industry. I feel 1000 times more sure it is still going on today. Any third world reactor can run at 100%. It is much more difficult to align the plant for the worst design event.
Pilgrim has the worst LOOP rate in the industry. The average is about 2 LOOPS per lifetime. LOOP rates are calculated into all violations and all sorts of other issues in the plant. The standard-generic rate for safety analysis and violations is about 3.5 LOOPs per lifetime. Pilgrim’s LOOP rate is beyond 21 LOOPs and we aren’t counting in the early years. Pilgrim’s is seventeen times worst than the inputted into safety analysis rate. One wonders why the real LOOP rate as penalty, isn’t inputted into all violations and safety analysis?
The OIG by me and others think this branch of the NRC as highly dysfunctional. We consider the OIG as a paper tiger. I had discussions with a high OIG official concerning the OIG’s investigation on San Onofre defective steam generator and the NRC response to this. He talked about the OIG is severely hemmed in because the they can’t challenge any NRC’s staff inspections and safety analysis. He talked about using tricky interview and investigative techniques to write up the San Onofre. The OIG needs to gear up with plant and oversight expertized to challenge any staff evaluation or activity at any plant. We think this OIG restriction comes from the utilities big bucks through the politicians influence over the NRC, limiting the capabilities of the OIG.
Loops and paper tiger OIG
My Pilgrim 2013 2.206
March 7, 2013
Bill Borchardt
Executive Director for Operations
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
Dear Mr. Bochardt,
Request an emergency and for a exigent bases, that the Pilgrim Nuclear plant be immediately shut down.
Don't tell me just before the Nor'easter Nimo struck the Pilgrim plant with a leaking safety relief valve and down at 80%, Entergy was intending to operate that plant with a defective leaking safety relief valve till the next refuel outage? Tell it ain't so. It certainly looks like with the current leak today that is intending to operate till next month.
Is the game plan today to incrementally increase reactor power from 94% by 1% to see if a new SRV leak is getting worse?
Timeline:
1) New three stage safety relief valves installed in the plant around May 2011.
2) First leak and shut down on Dec, 26. 2011 (SRV RV-203-3D).
3) Second leak and shut down on Jan 20, 2013 (SRV RV-203-3B).
4) Third leak occurred a few weeks later and the plant was at a restricted to 84% power...the Nemo blizzard Feb 9, 2013 tripped the plant. The NRC promised these valves are fixed before startup. (SRV RV-203-3B).
5) Basically, they operated for 20 days at 100% power operation post shutdown, then reported on Feb 27 the plant is operating at 94% power with no explained reason until today. The reason for the down power was kept secret from the public.
6) Today March 7, 2013 I called the NRC's public relation people and the agency told me they had indications of a leak and that is why the plant is at a restricted power level. 
Don't forget the repetitive nature of the recently broken scram discharge volume vent and drain valves...implies Entergy is incapable of maintaining safety components of a nuclear plant.
The repeated nature of the failure of the safety relief valves means Entergy doesn't know the mechanism of the failure...it is a common mode failure. The design and manufacture of these valves are defective and it is extremely unsafe to operate a nuclear plant with all safety relief valves being INOP. A condition adverse to quality...
The NRC should have made a public comment about the new leaking safety relief when they first became aware of th leak. The implication is the agency was going to allow the plant to operate with unsafe SRVs until the refueling outage next month. The NRC is involved in a serious cover-up of an extremely unsafe operation of a nuclear power.
1) Request an immediate shutdown the Pilgrim Plant.
2) The is the second time I requested a special NRC inspection concerning the defective SRV valves.
3) Not allow the plant to restart Pilgrim until they fully understand the past failure mechanisms of the four bad new three stage safety relief valves.
(April 18 2017-again below, I request the paperwork trail with how this got to the OIG and its disposition of my request)
4) Request the OIG investigate this NRC cover-up to keep an unsafe nuclear plant at power.
Update  April 6

I doubt anything will change. It was a pleasant discussion. They are captured by the monstrous system just like everyone else.
To Michael Mulligan
*I received this email on Good Friday. I thought I was being spammed. I knew this was a holiday for the NRC employees. I looked at the document carefully, figured out it was the real deal. Within a hours, I got a call back from the OIG official.

Gov bureaucrats are usually very sensitive with sending something on a holiday. Sending it on a particular holiday can highlight the agenda of the meeting sometimes.

So I figure, I am going to be crucified or made the savior of the nuclear industry.

This is the only 2.206 that ever got past the prehearing process with me. It was successful in many ways. I got a prime example in Pilgrim where this process completely broke down.   

Dear Mr. Mulligan:
 
The Office of the Inspector General (OIG) for the U.S. Nuclear Regulatory Commission (NRC) is conducting the Audit of NRC’s 10 CFR 2.206 Petition Review Process.  Your petition filed on March 26, 2015, regarding the Vermont Yankee Nuclear Power Station and Kewaunee Nuclear Power Plan, is part of the audit sample selected for analysis.  We would like to meet with you to discuss any insights you have on the 10 CFR 2.206 petition review process from the petitioner’s perspective and any specific concerns you had about the review of this petition.  Your petition and its supplements are in the NRC's Agencywide Documents, Access and Management System (ADAMS) under Accession No. ML15090A487, ML15198A091, ML15286A003, and the Final Director’s Decision under ML16054A731.
 
This OIG audit began on February 13, 2017, and its objective is to determine whether NRC staff follow agency guidance consistently in reviewing 10 CFR 2.206 petitions, and take steps to ensure appropriate information supports NRC decisions on 10 CFR 2.206 petitions.
 
If you agree to this meeting, can you please let us know when you might be available to meet next week? The meeting will take about an hour and will be conducted as a team conference call.  Please provide us the best number to call you.
 
 
Respectfully,
 
 
Deyanara Gonzalez Lainez, MBA, MSM
Auditor
My response
I appreciate your interest in me. I never have any confidentiality or anonymity needs in any of this. Sure, at your convenience next week. Just name the date and time. I will make myself available for the discussion.

A more controversial 2.206 would be the one surrounding the SRVs at Pilgrim in 2013. It shows where the 2.206 process utterly failed its intended purpose. But we can get to my themes going your way. 

Can you follow all the rules, but not meet the intent of the will with all the people of the USA?

Our highest national security priority is our collective faith in government...trusting our government. I love the USA with all of my heart.

( I love our adversarial court system)     

Sincerely,

Mike Mulligan
Hinsdale, NH 





Junk Plant Oyster Creek SRVs: The Collapse Of The Regulator.

Believe me, this plant is more poorly designed than any other plant in the USA. The NRC framed it inappropriately as a individual component issue of the ERVs for both events. It should be framed as a failure to maintain quality of the of the EVRs. It is two failures of the EVRs is a short period of time. The first being a yellow make believe violation, while the second being a rop violation.
(2017)NRC to Increase Oversight at Oyster Creek Nuclear Power Plant The Nuclear Regulatory Commission will increase its oversight of the Oyster Creek nuclear power plant following the finalization of an inspection finding involving deficient maintenance work on a safety-related relief valve. The finding was identified during a 2016 NRC inspection of Oyster Creek. The facility is owned and operated by Exelon, located in Lacey Township (Ocean County), N.J. The white safety finding indicates a low to moderate safety significance. The NRC uses a color-coded system to categorize inspection findings, with colors ranging from green, for very low safety or security significance, to white, yellow or red, for substantial safety or security significance. Findings determined to be greater than green result in additional NRC scrutiny. This finding involves a problem with one of the plant’s electromatic relief valves. EMRVs are used to depressurize the reactor during a pipe break. Oyster Creek has five of these valves. “These valves serve a key safety function and therefore it is important that they be available to help mitigate severe accidents at the plant,” said NRC Region I Administrator Dan Dorman. “We will conduct a supplemental inspection at Oyster Creek to ensure the underlying problems that led to this issue have been appropriately addressed.” Exelon was given an opportunity to request a regulatory conference to provide additional information to the NRC prior to a final agency decision, to submit a written response, or to accept the finding. The company chose to take part in a regulatory conference, which was held on March 9 in the NRC’s Region I Office. In terms of corrective actions, Exelon verified correct assembly of the valves following the most recent refueling and maintenance outage at the plant.
Old design problems means this violation wasn't in the ROP. It was like a warning ticket. If it was a full scale yellow finding with heavy NRC attention,  would the new violation have occurred?  

If it was a old design issue, this problem would have repeatedly showed up throughout the life of the oldest plant in the USA.
(2015)NRC Slaps Oyster Creek Plant With ‘Yellow’ Finding, Increases Oversight
The federal Nuclear Regulatory Commission this week upheld an enforcement action known as a “yellow” finding against the Oyster Creek nuclear generating station in Lacey Township following the investigation of release valves at the plant in 2014.
The “yellow” finding is the NRC’s second-highest enforcement action, and indicates “substantial safety significance,” NRC officials said in a statement released Monday. The plant was also given a “white” finding for a separate incident involving the plant’s emergency generators and a broken cooling fan.
The “yellow” finding involves design aspects of electromatic relief valves, or EMRVs, for the plant, which is owned by Exelon Corporation and scheduled to shut down in 2019. According to the NRC, during refurbishment work in June 2014 on two EMRVs removed from the plant in 2012, the company found an alignment problem with the valve’s actuator. When the valves were tested, they did not open. Once the issue was identified, Exelon immediately tested five of its then-installed EMRVs, officials said. All five actuated successfully. The company ultimately installed redesigned actuators for the valves during a refueling and maintenance outage at the plant in October 2014.
Even though the violation involving the EMRVs has been classified as “yellow,” the NRC has determined it represents an old design issue.
“That is, the issue stems from an inspection finding involving a past design-related problem and does not reflect a current performance deficiency associated with existing programs, policies or procedures used by the company,” the agency’s statement said.
As a result of the finding, the NRC will carry out a team inspection that will review Exelon’s root- cause evaluation and corrective actions for the issue...
The NRC threw the powerful Exelon a freebee with an old design issue. This is blatant corruption by the NRC and Exelon!!!! The was a "current" negligent maintenance issue in 2015 turned into a old design issue through the greasy NRC hands. Who ever heard of a such a thing in any other regulated industry...


How To Make It Trump's Nuclear Regulartory Commission

I think having half democrat and half republic commissioners dilutes political accountability. I'd get rid of it.

I think this scenario is really cool.

1) Let the clock run out on Svinicki. She is out. I know now Svinicki is really popular with house republicans.  

I don't know how the "going full nuclear" works out in the Senate and House? Would these guys get voted in by 51 votes instead of 60 votes in the senate. I think this is drastically going to change the environment of the commissioners. There is a lot of political horse trading going on outside the nuclear industry with nominating a NRC commissioner. It is never just a nuclear industry focus thing.   

I doubt the democrats would approve any nominee in these times. Could the republicans overwrite the enabling legislation of the NRC? End up with its only up to the president to elect the NRC commissioner with the senate's 51 votes.

2) Drop the even split republican and democrat thing.

3) Now you have only 2 commissioners. Then stack the deck with the new Trump three commissioners.

Big picture, I like the idea if something big happens, it would make the politicians and parties accountable no matter what political party.

You get what has happened here, the NRC initial legislation, it weakened political accountability as a favor to the big utility boys who owned nuclear plants.    

House Energy and Commerce Committee representatives urge Trump to Fill Nuclear Regulatory Commission Vacancies

Published on April 17, 2017 by Daily Energy Insider Reports          

Three U.S. representatives on the House Energy and Commerce Committee recently sent a letter to President Donald Trump, requesting that he fill current and future vacancies on the Nuclear Regulatory Commission (NRC) in order to maintain a quorum.
House Energy and Commerce Committee Chairman Greg Walden (R-OR), Subcommittee on Energy Chairman Fred Upton (R-MI), and Subcommittee on Environment Chairman John Shimkus (R-IL) jointly sent the request.
“We urge you to nominate commissioners to the NRC so the confirmation process may be completed as
soon as possible and provide the NRC a full contingent of commissioners to fulfill its critical mission in overseeing and regulating the civilian use of radioactive material,” the representatives said.

If no new commissioners are nominated and confirmed before July 1 when Chairman Kristine Svinicki’s current term expires, the NRC will lack a quorum, which is necessary to conduct necessary legislative action. The commission requires at least three of the five seats to be filled with no more than three members from the same political party in order to maintain a quorum. There are currently two vacant seats on the commission.
“Absent a nomination and confirmation of additional commissioners, the Commission will lack a quorum on July 1 when Chairman Svinicki’s current term expires,” the representatives said. “This situation could severely inhibit the NRC’s ability to execute its vital responsibility and hamper the nuclear industry.”

Junk Plant Grand Gulf: Extraordinary Collapse of Capacity Factor In last Two Years

May 1

still stuck at 94%

Update April 28

94% for two days. I fear, if the delayed start-up is caused by poorly trained licensed operators and ratty start-up procedures, what is the extend and cause of the procedure site wide.  

Update April 21

Told, secondary side issues and procedures are slowing down the start-up. Tremendous turnover of employees mostly based on retiring. The problems with first generation of retiring employees is not a new phenomena...they should have anticipated it.
  
Tremendous progress getting too full power(not)...25% power...

Why in the world didn't the NRC catch the broad procedure problems at the plant or it was fixed in the four month shutdown.


Update April 20

Holy shit, traveling at warp speed...16% power.

You get it, they are not properly preparing the plant for start up and sustained plant operations. It was a reckless start-up!!!

Update April 19

What a rat trap, still at 14% speed. Doppler and Temperature Coefficient are weakened at low power. It is not safe for a plant to run at lot power for prolong period of time.   

Update April 18

OMG, they went up 4% in 24 hour. Warp speed now.

***Just within weeks ago, these guys just got done with a voluntary four month safety shutdown based on the incompetence of the license operators. They had a horrid capacity before the shutdown for a year. We are still waiting for the special inspection on this.
The problem I have is Grand Gulf maliciously and repeatedly shoots themselves in the foot, usually based upon perceived self interest....then the industry and NRC treats them as if they were a rape victim. You are all organizationally severely mentally ill. Come on, with the airline who dragged the injured passenger out of the plane, you can't tell me the corporation and organization around them wasn't severely mentally ill. Organizational severe mental illness is very common today.
I worry these guys are getting desensitized or numbed by this behavior in the last few years. Normalization of devience.

This kind of activity is yanking financial resources away from the troubled plant at the worst time.
Power history
April 13: 0%
April 14: 1%
April 15: 1%
April 16: 3%
April 17: 10%

Thursday, April 13, 2017

 How The Unprecedented Heroin Crisis is Destroying Our Constitutional Rights on I 91

Updated April 14

The deputy treasurer and voluntary police officer. The heroin menace have infected all of their gov.
The deputy city treasurer has been placed on leave after it was learned that a man arrested in a major heroin bust on Thursday was taken into custody at her home."The employee was immediately placed on leave and is pending further investigation," Mayor Alex B. Morse said.
Morse confirmed the employee was Deputy City Treasurer Kayla Rodriguez. She owns the home at 14 Laurel St. where Kivanny Sanchez, 22, was arrested and charged with trafficking in heroin over 200 grams and conspiracy to violate the drug law, according to police and city records.

Holyoke police, Hampden DA release names of suspects arrested in major heroin raid
The names of 11 men and women and the charges against them were disclosed. At least five other arrests are still being processed.

Police Chief James M. Neiswanger and Hampden District Attorney Anthony Gulluni described the dozen arrests Thursday morning as a major scoop of 24,000 bags of heroin, $100,000 in cash and three expensive cars: a Porsche, an Audi and a BMW. 
Updated April 13

Come on, with this kind of money being made and lavish spending on cars, you got to know high up they were paying off the police and politicians...


Police raid Holyoke apartment buildings
By George Graham | ggraham@repub.com The Republican
Follow on Twitter
on April 13, 2017 at 11:17 AM, updated April 13, 2017 at 11:48 AM
HOLYOKE -- City and state police seized approximately 24,000 bags of heroin, $100,000 in cash and arrested a dozen suspects early Thursday during multiple raids in the Churchill neighborhood.
Police also seized a trio of high-end cars, each one black: a Porsche Panamera 4, Audi A7 3.OT and BMW 335i
"We really scooped up a significant organization," Hampden District Attorney Anthony Gulluni said during a press conference at the Massachusetts State Police barracks in Springfield.
Around a dozen arrests were made in Holyoke this morning following several drug raids in the Churchill neighborhood.
Hampden District Attorney Anthony Gulluni said Holyoke and state police seized 24,000 bags of heroin, approximately $100,000 in cash, and three luxury cars, in addition to the arrests.
The vehicles seized were an Audi A7 3.0T, a BMW 335i, and a Porsche Panamera 4.
"We really believe that we dismantled a significant drug distribution organization with these arrests." Gulluni said. "We think it's a big win for the city of Holyoke. It's a big win for the region and we are going to continue to fight this war and bring drug traffickers to justice."
Asked if the drug trafficking organization was gang-affiliated, Gulluni said, "We are not aware necessarily with a specific gang structure, but it's a drug distribution organization."
This is a large scale heroin operation. The state police must have been looking at these guys for months now. It is within miles of where the staties pulled me over on I 91. No doubt the staties were trying to snag a car going to and leaving the Holyoke heroin den on I 91.

I think the staties were abusing the "Move Over" law in order gain probable cause to take down these heroin Kingpins. It was a battlefield intelligence operation to gather information on the Kingpins. Right, get a large load of heroin, their CIs must have been telling the staties the frequency of the use of I 91, thus giving the heroin transporter a great court deal in order to bust down the Kingpins.

It this the guy the staties were looking for with the drug bust on April 5...is he how they gained probable cause.
Right, the staties were stationed on both sides of I 91 and north and south of the main exit going into the Heroin kingpin neighborhood.


Police raids in Holyoke yield 24,000 bags of heroin, $100,000 in cash, 12 arrests

By
George Graham | ggraham@repub.com The Republican Follow on Twitter
on April 13, 2017 at 11:17 AM, updated April 13, 2017 at 11:48 AM

HOLYOKE -- City and state police seized approximately 24,000 bags of heroin, $100,000 in cash and arrested a dozen suspects early Thursday during
multiple raids in the Churchill neighborhood.

Police also seized a trio of high-end cars, each one black: a Porsche Panamera 4, Audi A7 3.OT and BMW 335.

"We really scooped up a significant organization," Hampden District Attorney Anthony Gulluni said during a press conference at the Massachusetts State Police barracks in Springfield.
Reposted from 4/5/17

updated April 6 

Now if after, say, staties ticket a car on I 91, they observe a car violation of the move over law, I am ok with that pull over. The more appropriate method is flooding the airways with advertisements with move over law. It is the ruse that bother me. They are trying to save officers lives by violating the constitutional rights of everyone else. The essence of truth telling. All these guys testify in the court...this behavior impinges their activity in the courts. With these little things, sometimes a mountain of troubles is hidden behind these little integrity issues.  

Say they get a big heroin bust on I 91, I honestly think the state should disclose to the violator's attorney a ruse was used to create the opportunity of a search. Then the ruse issue cycles through the court system. It is the secrecy of the government that bothers me so much. It doing things behind close doors that bothers me This isn't the America I want to live in.

Again I really don't think the move over law actually works. It just turns the good citizens into state sponsored robots at the behest of the state. You need a evaluation of the drivers who killed state police on the highways. How do you stop them. I just think the campaign to create the move over law, zip it through political system system...was a money making deal to special people. It creates benefits and stature to special people, has nothing to do protecting out police.

Ya, good cops are needlessly dead, but don't take out your anger on the rest of us. 

This is a rendition of altruism or doing good corruption, saying you are trying to protect the police, but the object of the game is to just advance yourself.
           

***Parking the state cruisers on the side of the road with their emergency lights on for no reason to I pull over citizens on I91 as a ruse to preform a illegal search for heroin is unethical. Then the state policed lied to me concerning why they were there.  

How many cars do they pull over for breaking this law per heroin catch? Maybe one in 100?

State police stop vehicle on I-91 in Deerfield, seize over 1,000 packs of heroin

By
George Graham | ggraham@repub.com The Republican

on April 05, 2017 at 8:52 AM, updated April 05, 2017 at 9:02 AM
DEERFIELD -- A passenger in a car that failed to yield for an emergency vehicle on Interstate 91 early Monday was found to be in possession of over 1,000 packs of heroin, state police said.

The incident began shortly after midnight when Trooper Daniel Paras saw the northbound Dodge fail to move over, according to a release issued by state police.

The trooper finished up with the vehicle stop he had been dealing with and ultimately stopped the Dodge north of Exit 26 in Deerfield.

Paras identified the driver and three passengers. Further investigation led to the discover of 1,150 packs of heroin in the car.

One of the passengers, 44-year-old Kevin Rose of Brattleboro, was charged with trafficking in heroin and possession of an open container of alcohol.

The driver was issued a summons for unlicensed operation and failure to move over for an emergency vehicle. A licensed passenger took control of the vehicle.

    Junk Plant Columbia: UCS on Special Inspection

Columbia Generating Station: NRC’s Special Inspection of Self-Inflicted Safety Woes

Dave Lochbaum, director, Nuclear Safety Project | April 13, 2017, 6:00 am EDT

Energy Northwest’s Columbia Generating Station near Richland, Washington has one General Electric boiling water reactor (BWR/5) with a Mark II containment design that began operating in 1984. In the late morning hours of Sunday, December 18, 2016, the station stopped generating electricity and began generating problems.

The Nuclear Regulatory Commission (NRC) dispatched
a special inspection team to investigate the event after determining it could have increased the risk of reactor core damage by a factor of ten. The NRC team sought to understand the problems occurring during this near-miss as well as assess the breadth and effectiveness of the solutions proposed by the company for them…

I put the below on the UCS's blog. They seemed to taken it down.
Special Inspection #1
Yet another special inspection on transporting radioactive material in Nov 2016.

http://www.tri-cityherald.com/news/local/hanford/article144310564.html

Two special inspections in about a month. One wonders if the NRC can call up a special inspection on their whim. In other words, a lot of secret non-documented violations occur at the plant as the price of doing business. Then the NRC can pull up from a huge bank of non-disclosed but known violations as a tool to perform a particular purpose.  
Special Inspection #2 
Why do we always do this? This accident is contextual. Why don't whistleblowers ever get the credit they deserve. Here is where whistleblowers went to the press saying the plant is in more trouble than Columbia or the NRC understands. The NRC in response said the plant is safe. They had a big internal investigation basically saying there are communication problems, but no big problems. I am just saying, out of the whole highly paid lot of them officialdom, the closest one to the anticipating and knowing the future truth was the Columbia Whistleblowers. I will guarantee you, if there were no Columbia whistleblowers, there would be no special inspection. The NRC is terrorized by these whistleblowers. I guarantee to you, the NRC never even for one second, forgot they had unknown knowledgeable whistleblowers simmering at the plant. That special inspection was set up to protect the NRC if things got worst at the plant. I find it despicable you didn’t put the Columbia whistleblower context into explaining the setup of this accident.

I was in a similar situation at Vermont Yankee in 1991. I was leaking documents (stealing) and talking with media. Talking to the governor…she came out on a podium and made big my issues at the plant. Like I said, big internal investigations and NRC investigations. I thought nothing really big is changing as the process played out, they were doing their same lying and falsifying documents as the NRC was breathing down their necks. I thought maybe there is a delay in the atmosphere change we all expected. About a year after getting the governor on the podium, VY had the worst accident in the life of the plant. We had a LOOP on taking shortcuts and not following procedures in switchyard, with insufficient cooling water flow to the diesel generators. The control was in a mess during the event.  A lot of equipment showed as degraded or broken in this accident.

This was when my great disillusionment with how the world works began. All the internal and NRC investigations was just showboating for the public appeasement. There was no intention of ever changing a thing at plant.