Tuesday, November 20, 2012

Hurricane Sandy Cover-up at Oyster Creek nuclear plant

Reposted again from 11/14/2012

So the Oyster Creek's senior resident inspector just called me about my allegation surrounding Hurricane Sandy.  He called to tell me I was full of shit (fos)...just kidding. He was a nice guy!  But he was right I was fos. He really nicely explained to me the NRC would like to go over some points in your e-mail. You just got to give them credit when they do things right.

Oyster Creek's two diesel generators are air cooled machines...the inspector said "like a locomotive", it don't need service water to cool their DGs. Their service water pumps are open air motors....meaning there is no roof above the motors and they aren't in a cellar below ground level.

The resident inspector said, your e-mail to us covers just about everything in the NRC special inspection.  He wouldn't spill the beans about what is going to be in the inspection report. I tried as hard as I could to pry it out of him. I told him I was mulling a 2.206...but your phone call allayed my "paranoia". He said the service water pumps showed no problems during the  hurricane.

I was shocked the Diesel Generators were air cooled...

So I don'thave any concerns with the Oyster Creek now...I am confident the NRC will handle the shortcomings of Exelon-Oyster Creek during Superstorm Sandy.

My remaining questions are:

1) Did the air cooled DGs show any problems is the hurricane and especially when in operation.

2) what level is the seawater level  of the DGs... what seawater level or tide surge will inop these machines.

3) what surge level will inop the service water pumps...


I still think the prior NRC report on the storm surge capabilities was fundamentally inaccurate for Oyster Creek....well, until I see the special inspection results.



...It is interesting I got a, after I sent my Oyster Creek superstorm e-mail to the NRC :

""MAILER-DAEMON@yahoo.com" Sorry, we were unable to deliver your message to the following ...Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO]",

I assumed my e-mail didn't ever get to the NRC. So this NRC phone call to me today about Oyster Creek hurricane Sandy says my e-mail did get past this yahoo DAEMON notification. I ask the inspector what does this DAEMON thing mean when I send e-mail to the NRC, he seemed to be aware people were getting it, he told me to just send it again.

I am still confused about the meaning of the MAILER-DAEMON notification after I send into the NRC ...but the indication is my stuff is still getting into the agency.



NRC probes Oyster Creek’sHurricane Sandy response

Nov 15: Federal regulators have launched a special probe to determine if officials at the Oyster Creek nuclear power violated rules and waited too long to declare an emergency alert as rising waters threatened critical reactors systems. The three member team, said Screnci, “are looking at the response of the emergency preparedness at the site, and the circumstances surrounding the rising levels in the intake structure. They are looking specifically at the timing of the alert declaration, and the company’s preparedness prior to the storm, the performance of its equipment, and their command and control during the storm. The onsite inspection should be concluded by the middle of next week," Screnci said. The inspection was triggered by observations of the two resident inspectors at the plant, who raised questions about the handling of the emergency alerts. “The resident inspectors have been doing some follow up since the hurricane,” Screnci said, “and we decided we needed to send the inspectors there to take a closer look.”

The NRC:
"The focus of the SIT is to review circumstances surrounding Exelon’s event declaration activities related to water level increases at the intake structure during the storm on October 29, 2012."
Me on the first event report:
"I just can't believe with a lost of off site power and a threat to the emergency diesel generator, that it wasn't higher than a Alert."
Message 5 Oct 30...


50/50 chance it will ever be restarted....

Reposted again originally from Oct 31, 2012... 

...I think Exelon is saying, if you give us any shit about meeting regulations, we will begin to permanently shut down one nuclear plant after another.

They are blaming other people and the agency for the business strategy they themselves chose.

I'll bet they made a determination the plant is dead...they are just beginning the process of notifying everyone...

Nov: 14: Right, Exelon is trying to intimidate the NRC into softening their special inspection of Superstorm Sandy...don’t you even think of exposing how out of regulation Oyster Creek is or we will immediately shut the plant down.

And don’t forget under our severe financial threat over natural gas...we could be talking about a group of nuclear plants.

Here is giant Exelon trying to throw the inspection results of a federal agency in the public realm...

Exelon is terrified they are out of compliance with emergency and flooding compliance...
Bloomberg NewsExelon Open to Closing Oyster Creek Reactor Pre-2019Exelon Corp. (EXC), the largest U.S. nuclear plant operator, would consider closing its Oyster Creek station before the plant’s planned 2019 decommissioning, Chief Executive Officer Christopher Crane said.
 Exelon would accelerate plans to close Oyster Creek in Forked River, New Jersey, if it faced unexpected new capital costs at a time when depressed power prices and cheap renewable energy are squeezing nuclear generation margins, Crane said in an interview yesterday.
 
Exelon already has deferred plans to boost capacity at its LaSalle nuclear station in northern Illinois and Limerick plant in Pennsylvania, saving $1.2 billion in the near-term, the chief executive said.
Nov 13:
 NRC BEGINS SPECIAL INSPECTION AT OYSTER CREEK NUCLEAR PLANT
TO REVIEW ISSUES AT SITE DURING HURRICANE SANDY

The Nuclear Regulatory Commission has initiated a Special Inspection at the Oyster Creek nuclear power plant in response to issues that arose when Hurricane Sandy impacted the facility on Oct. 29 and 30. The inspection began today at the plant, which is located in Lacey Township (Ocean County), N.J., and operated by Exelon.

Oct 31:
So here they are making the declaration, filling out the paperwork and preparing for the NRC phone call...and the level rises .3 feet. And they are telegraphing to the NRC: Remember, the highest ever tide or storm surge at Oyster Creek is 4.6 feet.
"the ocean level "and slowly rising"
Their eyes must have been popping out now next at the six foot point and they provide no historical context to the NRC...did the site have the highest recorded ocean level ever?

There they go again, the declaration, preparing for the NRC phone call, and they just lost off site power...with the ocean level going up to 6.6 feet. There are sending a coded signal that its going up .6 feet in this short period of time.
"At 2044 EDT on 10/29/2012, the licensee escalated its emergency declaration to an Alert per criteria HA4 for high water level in the station intake structure of greater than 6.0 feet. At the time of the notification, water level in the intake structure was approximately 6.6 feet. The site also experienced a loss of offsite power event concurrent with the additional water level increase. Both emergency diesel generators started and are supplying power to the emergency electrical busses. Shutdown cooling and spent fuel pool cooling have been restored. Reactor pressure vessel level is steady at 584.7 inches. Intake levels continues to rise slowly and the licensee is monitoring."
I just can't believe with a lost of off site power and a threat to the emergency diesel generator, that it wasn't higher than a Alert. It seems the lost of off site power played no role in the alert status. Just a plain ocean level 6.0 feet emergency entry classification point would get you into a alert status. The loss of off site power emergency entry point classification "plus" a ocean level 6.0 feet emergency entry classification point still gets you into just a alert status. It just don't make sense an additional serious threat to public safety doesn't kick it into a higher classification.

And you get it, in less than two hours the rate of change for processing a declaration with the second ocean level declaration rise has doubled from .3 feet to .6 feet.
"Intake levels continues to rise slowly"
And still Exelon reports at 6.6 feet point...
"Intake levels continues to rise slowly
Hurricane  Sandy Cover-Up at Oyster Creek Nuclear Plant
Dear Sir,
I request a special or higher level inspection at the Oyster Creek nuclear plant over Superstorm Hurricane Sandy.I requested an immediate release of information on the outline of how Oyster Creek prepared for Hurricane Sandy. Also, an outline of what the control room saw and did on the approach and the passing of Superstorm Sandy. Especially an accurate account minute by minute, the full disclosure of the service water bay (ocean level) level recorder rolls or computer readings on the service water bay level readings from 8 am Oct 29 to 8 an Oct 31 2012.
A full and accurate account of what the employees saw with the service water bay level reading and if water got into where the service water pumps were located.A full and accurate report with what the control room told the NRC and state, as the service water bay level was increasing....
Provide an accurate explanation with how the diesel generators are cooled by the service water pumps. What ways do Oyster Creek have to cool the DGs for electric power to the facility and its core cooling systems if the plant lost the intake structure or service water pump building.Please give an account of the fuel loading in the core...what percentage of the core at the time of the Superstorm was new fuel and what percentage used fuel. Was the core fully off loaded?
Please add this email to Oyster Creek's NRC docket...Mike
....
I would frame the event like this...usually they replace a third of the nuclear fuel in the core each shutdown. Very very rarely do they fully off load all of the fuel from the core into fuel pool. The likely scenario is they replaced a third of the core with new fuel and two thirds was old fuel. Meaning two thirds of the core is extremely hot, lots of decay heat...while the other third is new fuel without any decay heat. They say a plant is more risky when shutdown because of all this decay heat than if it was running. There is a slight chance the core had all of its old fuel...they hadn't took out depleted fuel and replaced it with new fuel yet.

My blog
"Oct 29...
Think about it, the service water intake high level 4.5 feet warning came in 7 pm and rising pretty quickly...
Lost of off site incoming electricity occurred at 8:14 pm...
The high high alert of 6 feet came in 8:44 pm...submergence of all service water comes in at 8 feet according to Exelon...meaning they lose both diesel generators at 8 feet.
I will bet you there never has been any testing with supporting the diesel generator on the portable pump.
The ocean level was rising at a greater rate of 18 inches in 1.5 hours. You know for a fact, they were trending this thing in the control room probably in one minute intervals. They were trending the rate of increase on a one minute or five minute interval...
Right, they had no idea what was ahead of them...they had no idea how high it would get...everyone knew the low pressure of this storm was one for the record books many hour before the storm struck. How do you transition from the service water cooling the DGs, to the outside pump supporting the plant though the fire system ad cooling the DGs.

The team of three NRC inspectors is reviewing the circumstances surrounding the company’s event declaration activities related to water level increases at the plant’s water intake structure during the storm. The Special Inspection will expand on reviews conducted during and after the storm by the NRC Resident Inspectors assigned to Oyster Creek.
Nobody should ever forget, Dresden has extensive problems this summer with having to down power to deal with a historic drought, high river temperature and low stream flow...extensive Illinois EPA river and stream temperature variances to discharge hot waster. Do a Google search.  As I explained it early this summer, Exelon's fleet of nuclear plant's aren't adequately designed for the current climate and future global warming. Basically, the cheapskate Exelon-Dresden facility isn't adequately designed for droughts and floods.  

So how far down the road do you want to go with a bankrupt Exelon and their inability to  have enough money to keep up with the safety and maintenance of their plants.
Right, they are in a death spiral for the foreseeable future...
And these are the recent inspection talked about by in the NRC Dresden letter. They are playing the well trodden ping pong game of throwing the issues back and forth to each other ending in doing nothing or very little. It gives everyone the impression that a lot of work is being done....paper whipping and blizzards of paperwork obscuring our vision...but it ends quietly with nothing happening here after the flurry of initial activity. As with the 1982 engineering flooding safety report finally being maybe enforced by the 2012 Nov letter.

The employees and officials basically stating the problem in documents...while high NRC officials and the utilities in a state of watering down the report and demanding the low level employees forget about the threat.

Don't forget about the recent NRC official who sabotaged his career by leaking documents identifying the agency was secretly hiding...under national security pretext of terrorism rationalization...that upstream dam breaches were a bigger threat to nuclear plants than what the NRC was publicly admitting. Maybe the NRC was afraid of this NRC employee...so they disclosed for self protection. This flooding thing even before Sandy was a big thing with secret NRC documents and leaking NRC officials.
1)  INSPECTION OF NEAR-TERM TASK FORCE RECOMMENDATION 2.3 FLOODING WALKDOWNS (TI) 2515/187  
This letter is in response to the results of recent site walkdowns conducted by NRC inspectorsand technical experts to address NRC Temporary Instruction (TI) 2515/187 (ML12129A108) inspection procedure finished August 19, 2011, got around to inspect July 2012

2) Technical Evaluation Report - Dresden Unit 2 - Hydrological Considerations SEP Prep by Franklin Research 
This guy was entered into NRC documents this Sept 2012 and written up in 1982. It is a sin the agency is just getting partially around to enforcing the 1982 engineeing document the agency paid for. .  
3) INTEGRATED INSPECTION REPORT 05000237/2011003; 05000249/2011003  Dated August 4, 2011 
So why do you think the NRC wrote the post Hurricane Sandy Dresden nuclear demand for information letter? I think:
1) A diversion  from what happened with Oyster Creek.
2) The agency was in a industrial corporate style the public relation image shaping game...not in regulating the nuclear plants. 
3)The agency was trying to mitigate the effects of payola for reduce flooding safety at numerous nuclear power plants. If you want to get promoted up the ranks of the agency your better learn how to close your eyes to costing the nuclear industry money over safety.
4) I supposed you might think the NRC wants to give Exelon black eye over dragging their feet with flooding issues at Dresden...but generally these little black eyes of no consequence to a big utility is solely based on supporting the credibility of the agency. If the little people lose confidence of the USA's corporatized nuclear village regulatory machine then it will be big trouble to the nuclear industry...and lesser monies to nuclear k street and congress. The big boys know they have to take black eyes for the common good, for the public to accept the complacent in the  corporate pockets regulator.
$)  Don't forget about the recent NRC official who sabotaged his career by leaking documents identifying the agency was secretly hiding...under national security pretext of terrorism rationalization...that upstream dam breaches were a bigger threat to nuclear plants than what the NRC was publicly admitting. Maybe the NRC was afraid of this NRC employee...so they disclosed for self protection. This flooding thing even before Sandy was a big thing with secret NRC document and leaking NRC officials. 
5) Does NRC Region III have to act tough because of their troubled plants, mostly Exelon plants...and especially Palisades?      

....A dope would realized the NRC is throwing the below out for political self interest reasons. They are throwing this just two days after a superstorm hurricane and a few days before the presidential election. Do you think it is the prerogative of a federal agency to incorrectly shape public opinion over hurricane events to a power plant or shape a presidential election? So why was this letter dated Nov 2 instead of coming out a month ago, or a month from now...the agency is trying to shape the public story around flood protection and Superstorm Hurricane Sandy. Do you think it is fair and accurate? Was the letter generated...written... especially for hurricane Sandy just before the hurricane struck and within a day of being struck. I think the letter was designed to shape the story around a unprecedented hurricane and a unprepared facility.

I think the agency is trying to minimizing a cascading scandal surrounding hurricane and flooding events. If the agency throws up a request for information like this the media is unlikely to enter a rampage forcing the utility and NRC to fess up for their bad behaviors and save them from heading rolling.

Above everything else, the complacent NRC is signaling Exelon is a not trustworthy partner. The agency senses Exelon is dragging their feet and they won't comply with a "pretty please" after all the agency resources spent on this.

But what do i think is going on? I think many agency employees and especially the senior agency executives have become aligned to payola and a expectation of big pay Exelon executive jobs post NRC career. This is a wide spread conspiracy to save one of largest utilities big bucks when they are near bankrupt in return for breaking regulation or turning a blind eye, giving the impression of action, but doing nothing in order to get big post NRC payola. So in a wide area across at least two plants and two regions, they aren't enforcing the codes, laws and standards with flooding and hurricane safety.

I think that is what Sandy outed this fall...that is why the NRC wrote this unprecedented pubic shaping Dresden letter in a direct response for the extreme close call of Oyster Creek. Don't forget I called the NRC a direct liar in their Oyster Creek 2006 hurricane lessens learned task force.                
November 1, 2012
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer (CNO), Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: REQUEST FOR A WRITTEN RESPONSE TO NRC OBSERVATIONS AND
CONCERNS REGARDING DRESDEN STATION RESPONSE PLAN FOR
EXTERNAL FLOODING EVENTS

This letter is in response to the results of recent site walkdowns conducted by NRC inspectors and technical experts to address NRC Temporary Instruction (TI) 2515/187 (ML12129A108) in response to the “Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident,” and confirms discussions between Mr. David Czufin, Site Vice President of Dresden Station, and myself and other members of the NRC regarding our observations and concerns about Dresden Station’s response plan associated with external flooding events.
To address the disparity between the original and revised design basis for flooding, Dresden Station developed a response procedure and strategy that permitted flooding of plant structures and provided supplemental equipment and actions to quickly shut down the plant in advance of a predicted flood and maintain the reactors in a safe condition. During NRC’s review of that response procedure and strategy, as part of the 1982 SEP reevaluation, the staff identified a number of observations and concerns regarding the viability of elements of the procedure as written.
Those observations and concerns were documented in the Technical Evaluation Report – “Hydrological Considerations Dresden Unit 2,” prepared by the Franklin Research Center, on behalf of the NRC, on May 7, 1982 (ADAMS Accession Number ML12300A305), beginning on page 51, and are included as Enclosure 1. As a result of our recent site walkdown for NRC Temporary Instruction (TI) 2515/187, NRC inspectors and technical experts again questioned the adequacy of elements of Dresden’s current flood response procedures and strategy in the event of a design basis flood to execute a timely shutdown of the reactors and to maintain cooling of the reactors. Those current observations and concerns were verbally communicated to Station personnel at the end of the walkdowns, and are included in Enclosure 2 to this letter. Following those recent walkdowns, NRC staff raised additional questions regarding the viability of the current flood response planat Dresden. Those additional questions are included in Enclosure 3.
Nov 4: The strategy for improperly engineered facilities has been to compensate by driving the plant's to use more complex procedures and organizational complex gymnastics. What we know about Fukushima even way before the earthquake is the complexity of system swallows up the  engineering sanity of the machine and organization. Generally once the earthquake struck the complexity swamped the knowledge base of what is happening to their facility and how to cope with the damage. Did anyone even have the ability to understand the political system surrounding these plants in the set up to the accident..how they really set the standards of a facility.

So at some point you have to say, we can never let a facility go past this crazy complexity point where we have no assurance with the outcome of a plant no matter how many procedures they have. The larger the potential consequence of the accident, the more simple and assured the procedures need to be. That is what engineering is for.

You can already see this crazy complexity with how Exelon, the NRC and how the political system handles flooding protection to a facility. Basically the theme is they understand the flooding threat....but the politics of the NRC and Exelon continually weaken the inspection findings and so call weaken solutions to a flooding threat.  Over and over they re-identify flooding threats, the annunciate publicly the threats and solutions,  stick their chest out like proud men, but the system in the end weakens these solutions and or eventually weakens the regulations in the bushes off the  well trodden path that define the minimum flooding standards to nothing.

Basically an eye raising event shows up,  the NRC triumphantly does the inspections or throws out a do nothing past inspections as proof they care...then nothing ever gets done. I think the public gets the message that the NRC is falsely telegraphing is we are on top of the issues and the problems is going to be solved trust us, there are just throwing words at the pubic and harmlessly paper whipping the influential utilities but doing nothing.

We see the do nothing spasms of this behavior over and over again.

With Dresden issues, many years ago the agency should have been draconian saying fix our inspection finding in say 6 months, or shutdown until you got your head on straight.  This thing of decisions being continuously being in flux  means nothing ever gets done

...Rapid collapse of USA coal holds warning for tar sands 

Barry Saxifrage
Posted: Oct 19th, 2012

To give you a flavor of the shifting economics around US coal pollution, here is one of the examples I've been following.
The owners of three coal plants in Maryland spent $1 billion adding new pollution reduction equipment. Then they tried to sell the plants. Investors were watching carefully. In June Bloomberg News wrote an article on this upcoming sale headlined "Coal-Plant Plunge Threatens Billions in Pollution Spending":
"An indication of how much new emissions rules and cheaper natural gas have hammered the value of coal-burning generation will come when Exelon announces the results of the first big sale of U.S. coal-fired power plants in four years.
Exelon, the largest U.S. power company, may have to take a 40 percent discount for three Maryland plants it’s seeking to sell by the end of August. Bidders including NRG Energy Inc. (NRG) have offered $600 million to $700 million for the units, which have a fair value of $1 billion"
Talk about a fire sale. By the time the sale closed in August the price had plunged further. In the end Exelon could only get $400 million -- a whopping 60 percent loss compared to current fair value. In 2008 these three plants would have "fetched $2.5 billion, less any added environmental compliance costs."
Nov 3: So, Exelon's "parts of  your dividend" are going disappear got to be political. It's got to advantage or disadvantage to either Romney or Obama. Why would it pop up before the just before the election. Its been basically the CEO's choice when to cry dividend cuts. 
Is  the energy voters stealing  money from your portfolio...vote for Obama...  
Are they blackmailing Obama, you got to help us after the election or else.    
Are they blackmailing Obama, you got to help us after the election or else.  

Nov 2: So Sandy hit on Oct 29. Exelon disclosed bad quarterly profit on Nov 1 and then the CEO said he may cut dividends in order to support investment credit ratings.

Then we have the results of Hurricane Sandy spinning in the northeast and questions of engineering safety fraud surrounding hurricane defenses. You would think he wait for a few week to spill the beans about the dividend cuts?

Or was the investment community losing confidence in the NRC and Exelon nuclear ...The CEO thought it would better the dividend cut panic washed out the investor lost of confidence with their nuclear plant strategy?    

...OK, these are the possibilities why I am getting  a yahoo "MAILER-DAEMON 452 too many recipients received this hour":

1) The NRC is really overloaded with receiving too many e-mails.

2) There is a malfunction with the NRC mail system or yahoo.

3) Something is wrong with my computer and e-mail program.

Just added: 4) NRC now prefers I only only talk to them on the record, as in a 2.206 process.

Either I could have been unprofessional to their employees or they are be faking I have been unprofessional them as the means to reject my e-mail to protect the agency and big utilities.

I believe the NRC are rejecting  my e-mail on purpose...or they are faking rejecting my e-mails.

If they are purposely rejecting my e-mails, then they are falsifying the reason why my e-mails gets returned to me. How far will they go with this atmosphere of falsification? Where is their proof that I misbehaved as in the American way. I have never treated any of them unprofessionally.

What I have a hard swallowing, the NRC didn't spit out a e-mail to me identifying what their problems are with me, giving me a opportunity to correct my faults...or just plain saying e-mails by me will no longer be accepted because of this.

If I was a scumbag to NRC employees, would they still reject a legitimate safety complaint from me...

Are they ticked at me for releasing their private e-mails to me, I don't buy it, these are all government employees and they can't expect any privacy.

Hmm, are they going to charge me with something?

...The problem is, the NRC advertises catastrophe would occur at Oyster Creek at 22 feet ocean surge, while everyone knows catastrophe is highly likely at 7 to 8 feet. Nobody knows what the flood debris could do at a plant?  

The 2006 HURRICANE LESSONS LEARNED TASK FORCE REPORT states the historic high ocean level or storm surge at Oyster Creek is:
"The highest observed water elevation was 4 ft. 6 in. above MSL."
During megasstorm Sandy, during the first ocean surge notification and just before they actually called the NRC, Oyster Creek entered  historical territory. The site had notification days before Sandy that the storm surge level was going to be historic in nature.
At 6.5 feet, pump operations could be affected, but the problem was minimized because of the shutdown, NRC spokesman Neil Sheehan said. The water reached a peak of 7.4 feet at 12:45 a.m. Tuesday. It had receded to 5.7 feet by 2:15 p.m.
In Exelon's slow words, as they just entered historic territory and heading to 7.4 feet:
"At the time of the notification, water level in the intake structure was approximate 4.8 feet and slowly rising."  
"Intake levels continues to rise slowly" at 6 feet
I guess the NRC has made a decision not to accept anymore "points of view" e-mails from me or 2.206s? This goes across two regions.
Sorry, we were unable to deliver your message to the following address.
<allegation@nrc.gov>:
Message expired for domain nrc.gov. Remote host said: 452 Too many recipients received this hour [RCPT_TO
So the max the DBA probable hurricane surge is 22 feet including the accepted lost of service water bay and pumps at 8 feet mean sea level. It is totally nonsensical. 

The NRC was covering up in 2006 how poorly the Oyster Creek plant was designed for a hurricane. Can you imagine post Sandy Superstorm hurricane meltdown them finding this in their record. It would terribly indite the NRC with producing falsified hurricane engineering documents in support of a giant utility's interest.   
"The highest observed water elevation was 4 ft. 6 in. above MSL." 
 Why is this inaccurate?
May 26, 2006
MEMORANDUM TO: Melvyn N. Leach, Deputy Director for Incident Response
Office of Nuclear Security and Incident Response
SUBJECT: ACTIONS TO BE TAKEN IN RESPONSE TO THE HURRICANE LESSONS LEARNED TASK FORCE REPORT
Oyster Creek Nuclear Generating Station (Oyster Creek) is located on the coastal pine barrens of New Jersey in Lacey and Ocean Townships, Ocean County, approximately 2 miles from the Atlantic Ocean and historically has not been subjected to the full force of hurricane winds. The plant is designed to withstand sustained winds of up to 100 mph, which is based on a 100-year recurrence interval as well as tornadic wind speeds as discussed below. The wind design also considers the velocity distribution and appropriate wind gust factors. The design of Oyster Creek for wind loadings is described in Updated Final Safety Analysis Report (UFSAR) Sections 2.3.2.1.1, 2.3.2.1.2, and 3.3.1.1.
Hurricane Design
Oyster Creek is designed for a probable maximum hurricane (PMH), which is defined by the National Weather Service as a hypothetical hurricane having that combination of characteristics which will make it the most severe that can probably occur in the region involved. The PMH is assumed to approach the plant site along the critical path and at the optimum rate of movement. For Oyster Creek, the PMH results in a probable maximum surge elevation of 22 ft. above mean sea level (MSL). With the exception of the circulating water intake structure, the plant grade level is 23 ft. above MSL. Flooding of this structure would require shutdown of the circulating water and emergency service water pumps. The utility has emergency plant procedures in place that require appropriate actions (including plant shutdown) when water reaches a predetermined level as to ensure for the safe shutdown of the plant. Therefore, the plant is designed to withstand a surge of water of 22 ft above MSL reaching the plant structures.
The hurricane flood design for Oyster Creek is based on the historical data on nine severe hurricanes which threatened the plant site between 1935 and 1967. The highest observed water elevation was 4 ft. 6 in. above MSL. Water level would need to reach the plant grade level 6 ft. MSL before it would seep into any of the Oyster Creek buildings. The hurricane design is described in UFSAR Section 2.3.1.2.1.
External Flood Design
The design of the plant for flooding caused by external sources (e.g., rain, hurricane, dam failure) is described in UFSAR Sections 2.4.2 and 2.4.5. As discussed in UFSAR Section 2.4.5, due to the site proximity to Barneget Bay and the Atlantic Coast, flooding water levels are influenced solely by storm and tidal actions. Therefore, the flooding due to a hurricane is considered to be the limiting case."

Category
Maximum Sustained
Wind Speed
(miles per hour [mph])
Storm Surge
(feet)
1 74-95  3-5 feet
2 96-110  6-8
3 111-13  9-12
4 131-155  13-18
5 156 +  19 +

Figures David Lochbaum would get this out of them. This zipped right over my head as I had other things going on...even through I copied over. Not many people people in the USA are like David who could figure out there is more to the story than what they were reporting on.

I sure wouldn't have wrote as much crap since the Oct 31st if it would have sunk in back then...

It is utterly atrocious the happyland with how Exelon and the NRC reported on Oyster Creek...how can they get away with it being so inaccurate on the first swipe of history?

All I wanted to know is the peak ocean level...

What  the NRC got going for them, once David asked the right question, the NRC responded truthfully.  
No ‘Fukushima revisited’ in nuke-plant operations during SandyOctober 31, 2012|By Jane M. Von Bergen, INQUIRER STAFF WRITER 
At 6.5 feet, pump operations could be affected, but the problem was minimized because of the shutdown, NRC spokesman Neil Sheehan said. The water reached a peak of 7.4 feet at 12:45 a.m. Tuesday. It had receded to 5.7 feet by 2:15 p.m.
Exelon Falls After CEO Says He May Cut Dividend
Exelon Corp. (EXC), the largest U.S. power company by 2011 sales, fell the most in three months after saying it may cut its dividend for the first time to maintain an investment grade credit rating as power prices decline.
Exelon dropped (EXC) 3.1 percent to $34.67 at 1:46 p.m. in New York, the biggest intraday drop since Aug. 1. Exelon, formed in 2000 by the merger of Unicom and Peco Energy, has never cut its regular cash dividend.
Investment grade credit is “fundamental” to about half of Exelon’s business, Chief Executive Officer Chris Crane said on a conference call today. The company’s credit is rated at the second-lowest investment grade, BBB by Standard & Poor’s and Baa2 by Moody’s Investors Service.
“With so much of their business dependent on commodity prices and given where those prices are, one should realize that potential for a dividend cut exists,” Paul Patterson, a New York-based utility analyst for Glenrock Associates LLC, said today in a telephone interview. He doesn’t own or rate the stock. “This is not your grandfather’s utility company.”
Exelon has paid 52.5 cents a share each quarter since November 2008. Benchmark wholesale electricity prices in PJM Interconnection LLC, the nation’s largest power market, have fallen 35 percent since that time to average $41.60 a megawatt-hour in October, according to data compiled by Bloomberg.
“This is a stressed period,” Crane said. “We don’t want to live on the edge.” 
...And what we learned this summer in Exelon's worst drought since 1895, most of the Obama's Exelon fleet of nuclear power plants are wholly unprepared for the current climate...

...Ok, lets hit the Oyster Creek's Superstorm reset button...

As Sandy approached the plant in the real situation, the plant was shutdown and there was very little Oyster Creek's ocean canal loads and flow. It doesn't take much flow to cool the core and fuel pool when shutdown. When the plant is up at full power the circulation pump flow is enormous. This is the cooling water flow that cools the turbine and condenser. It is not safety related. So the ocean canal flow to the plant is much higher when up at power...way higher.

So the plant is now up at 100% power and Exelon's refuses to shutdown the plant until they measure 75 mph hurricane winds as seen by the plant. The front wave tidal and storm surge is leading the  hurricane wind core by many hours. The first warning is a increase of circ water and service water bay trash screen d/p alarms.

These alarms have been coming in a out all day and the operators have placed the trash screens on manual. The screens are like big cylinders with holes in it like that spins around in the ocean canal seawater flow...all the ocean flow has to go through these screen. After the trash screens is the suction of the big service and cire water pumps. At this side of the screens, the water level would go down real fast if there are obstructions in the screens. On the front side the screen they catch all the debris from the ocean, occasionally fish, lobsters and turtles. The screen cylinder spins around with the debris getting attached to the screen or just sits there if the water is clean. When the screen gets to the far side, a strong stream of pressured water sprays the debris off the screen into a trough. The trough directs all the debris outside the service water structure. A d/p pressure device measures the water level between the inlet and outlet of the screams. The debris begins to clog the screen, the water levels between the inlet and outlet of the screen increase. The d/p device calls the screen to begin spinning and opens the spray water. When there is a lot of junk in the ocean they just flip a switch on full time...the screen always then rolls around continuously as the spray water stays on.

So the control room operators knows the screens are on all the time....the d/p alarms still come in and out. The d/p alarms comes in hard, the operator wonder what is going on. If these bays have a too big d/p this also trips the service water and circ water pumps. It is not something to take lightly.

So they made a NRC declaration at the "4 feet" ocean level, the all time record storms surge is 4.6 feet...it is now at the 5.5 feet level.

Outside the barrier reef or sand bar the ocean level has raised quickly. The plant is still at 100% power, and of course, all the outside power lines are unaffected. There are only narrow inlets to inside the sand bar and to the plant. The ocean water level thus only rises slowly seen inside the control room becuase the ocean inlets are a small area. At the 5.5 feet level the ocean level has flooded over the reef or sand bar. The flooding and waves are destroying all the homes and vacation homes on the barrier reef. All the destroyed bits of these home has been washed over the reef by the slow approaching Superstorm and the huge storm waves by the  tons...landfall of the Superstorm wind core is four or five hours away. The wind force of the storm is still relatively low.

So all the flooding debris enters the bay...the strong flow of the plant circulation water flow through these giant pumps begins to suck tons of this debris into the cooling canal unknown to the plant operators. That is when the first giant circulation water pump automatically trips.

From there on all the rest of the circulation pump trips and the flood debris begin to clog the service water trash screens and obstruct cooling to the emergency diesel generator who are about to only supply electricity to the plant.

Within moments the plant is isolated from all outside electricity and the full fury of the storm is two hours away.

What if you then had a LOCA?      
.....
..And this below indicates to me the site was in a undisclosed crisis with flooding debris, the destruction of homes and community was clogging up the service water intake trash screens and obstructing cooling water to the site...

Is that a unrecognized safety concern, the destruction of the commuity upstream to them in a flooding event could end up obstructing the cooling water to nuclear power plant? Is that a generic concern...  

Power Reactor
Event Number: 48460
Facility: OYSTER CREEK
Region: 1 State: NJ
Unit: [1] [ ] [ ]
RX Type: [1] GE-2
NRC Notified By: GILBERT A. DeVRIES
HQ OPS Officer: STEVE SANDIN
Notification Date: 10/31/2012
Notification Time: 00:07 [ET]
Event Date: 10/30/2012
Event Time: 23:40 [EDT]
Last Update Date: 10/31/2012
Emergency Class: NON EMERGENCY
10 CFR Section:
50.72(b)(2)(xi) - OFFSITE NOTIFICATION
Person (Organization):
IRC (R1)

Unit SCRAM Code RX CRIT Initial PWR Initial RX Mode Current PWR Current RX Mode
1 N N 0 Refueling 0 Refueling
Event Text
OFFSITE NOTIFICATION TO THE NATIONAL MARINE FISHERIES SERVICE

"[The licensee] notified National Marine Fisheries Service per OC-08 that Oyster Creek has been unable to use the dilution and intake trash rake for greater than 24 hours due to safety concerns and loss of power. Daily manual raking of intake and dilution is in progress."

The licensee informed the NRC Resident Inspector.
I mean, Exelon should have made voluntary report to the NRC, we are expecting a historic hurricane with a historic projected storm surge...there is a high probability we may top over our service water structure. This would put the NRC on record that Exelon anticipated the scope of the troubles ahead of the site.
"At 1855 EDT on 10/29/2012, the licensee declared a Notice of Unusual Event (NOUE) per criteria HU4 for high water level in the station intake structure of greater than 4.5 feet. At the time of the notification, water level in the intake structure was approximate 4.8 feet and slowly rising."
So here they are making the declaration, filling out the paperwork and preparing for the NRC phone call...and the level rises .3 feet. And they are telegraphing to the NRC: Remember, the highest ever tide or storm surge at Oyster Creek is 4.6 feet.
 "the ocean level "and slowly rising"
Their eyes must have been popping out now next at the six foot point and they provide no historical context to the NRC context...did the site have the highest recorded ocean level ever?

There they go again, the declaration, preparing for the NRC phone call, and they just lost off site power...with the ocean level going up to 6.6 feet. There are sending a coded signal that its going up .6 feet in this short period of time.
"At 2044 EDT on 10/29/2012, the licensee escalated its emergency declaration to an Alert per criteria HA4 for high water level in the station intake structure of greater than 6.0 feet. At the time of the notification, water level in the intake structure was approximately 6.6 feet. The site also experienced a loss of offsite power event concurrent with the additional water level increase. Both emergency diesel generators started and are supplying power to the emergency electrical busses. Shutdown cooling and spent fuel pool cooling have been restored. Reactor pressure vessel level is steady at 584.7 inches. Intake levels continues to rise slowly and the licensee is monitoring." 
I just can't believe with a lost of off site power and a threat to the emergency diesel generator, that it wasn't higher than a Alert. It seems the lost of off site power played no role in the alert status. Just a plain ocean level 6.0 feet emergency entry classification point would get you into a alert status. The loss of off site power emergency entry point classification "plus" a ocean level 6.0 feet emergency entry classification point still gets you into just a alert status. It just don't make sense an additional serious threat to public safety doesn't  kick it into a higher classification.

And you get it, in less than two hours the rate of change for processing a declaration with the second ocean level declaration rise has doubled from .3 feet to .6 feet.
"Intake levels continues to rise slowly"
And still Exelon reports at 6.6 feet point...
"Intake levels continues to rise slowly"
Basically having a Superstorm Hurricane additional NRC inspector on site gives the agency the opportunity for a undocumented back door communication channel. They are talking about events surrounding the Superstorm without it being put in the pubic record.  

The NRC must have had cell phone and satellite coverage through the storm to headquarters  I wonder it this was recorded? Do you this recording is important for for the public to hear.

...Right, the last word we got out of Exelon is shortly after the 8: 44 pm alert declaration, the level was 6.0 feet at the declaration time, they filled out the paperwork, by the beginning of the NRC phone call minutes later Exelon declared it gone to be 6.6 feet. And the last word we get out of Exelon in public documents is:
"Intake levels continues to rise slowly and the licensee is monitoring."
We still don't know what the highest ocean surge level got to be... (7.4 feet)

I hope the "mean seal water level" and the units Oyster Creek uses match?

So the surge at Oyster Creek was about 6.6 feet while NYC got 13 feet?

...So how would I harden the service water pumps cooling the emergency diesel generators. It wouldn't take much. The service water pumps generally have the electric motor sitting only a few feet about the heat sink water level. Then they build sturdy concrete structures around them up many feet. The motor sits on a concrete pad just feet from the ocean. The pump impeller are stuck deep into the river or ocean connected to the motor by a some 20 foot spinning shaft. You double the shaft length and stick the electric motor on concrete stilts another 20 or more feet in the air...then it will survive any hurricane. Then you have to appropriately harden all the electric cables and devices in a similar way.

...Yea, they were in the refueling mode. The head was off, the water in the reactor was flooded above the  head all the way up to the fuel pool level...so you could with a  refueling bridge (underwater crane) pull the assemblies out of the core and move them underwater to the fuel pool racks. So a huge area of water or space of water is directly in contact with each other between the fuel pool and the reactor core. So you could stick a fire hose in the fuel pool and it would fill or cool the core.

But I thought the Fukushima new requirements said the fire hose fuel pool fill had to hard piped into the  pool and not fire hoses.

They would cooling the core and fuel pool by a external pump near the service water pump building, the heat load would be all the fuel in the pool and the reactor core, the rest of the site for many hours would be black. Well, they would have all the emergency batteries to power up the lights and the control room for say around 4 to 6 hours.

It would have been a horrible public spectacle if it happened during Hurricane Sandy...it would have been much worst if the plant was operating normally when the hurricane struck. Would it have been the end of nuclear power in the USA...

Most likely the plant would have been operating, waiting for the high winds to require them to shutdown. Say     the wind or the lost of the off site electrical power lines didn't take them out, one wonders what service water bay level would have required them to shutdown. How much time would they have had with the service water level required shutdown and the calculated loss of the service water motors. Would they have kept the service water motors running as they were getting submerged until destruction? It would have been a big deal destroying all the service water pumps or recovering the service water pumps. One wonders how long it would have took recovering the submerged service water room and motors, so they could run them again. It would have been a long time cooling the fuel pool and core by external pump and the fire system... all nuclear cooling being provided by fire hose....it would have been a national embarrassing spectacle.

Can you even imagine the plant dealing with all the state chaos in the condition of the state of New Jersey in the morning of Oct 30.  

...The difference between the core/vessel and the fuel pool is the fuel pool has 30 or more feet of water above the old fuel...the fuel pool has many 100s of thousands of gallons in it. It is just an enormous heat sink and all that water that can boil off gives the operator a lot of time to deal with the situation.

Now the vessel and the core is chucked full of fuel assemblies in a very small space and it has relatively little water in it....so it can heat up and boil off very fast. The core and the fuel pool are apples and oranges in the eyes of an operator.

The vessel is your first worry unless the fuel pool has a big hole at the bottom of it....

Right, just grab a fire hose on the refuel floor  and spray to your heart's content....while it can be really complicated and time consuming to get water into the core if you lose all electricity...

....Dear sir,


I request a special or higher level inspection at the Oyster Creek nuclear plant over Superstorm Hurricane Sandy.
I requested an immediate release of information on the outline of how Oyster Creek prepared for Hurricane Sandy. Also, an outline of what the control room saw and did on the approach and the passing of Superstorm Sandy. Especially an accurate account minute by minute, the full disclosure of the service water bay (ocean level) level recorder rolls or computer readings on the service water bay level readings from 8 am Oct 29 to 8 an Oct 31 2012.
A full and accurate account of what the employees saw with the service water bay level reading and if water got into where the service water pumps were located.
A full and accurate report with what the control room told the NRC and state, as the service water bay level was increasing....
Provide an accurate explanation with how the diesel generators are cooled by the service water pumps. What ways does Oyster Creek have to cool the DGs for electric power to the facility and it core cooling systems if the plant lost the intake structure or service water pump building.
Please give an account of the fuel loading in the core...what percentage of the core at the time of the Superstorm was new fuel and what percentage used fuel. Was the core fully off loaded?


Please add this email to Oyster Creek's NRC docket...


Mike
....

I would frame the event like this...usually they replace a third of the nuclear fuel in the core each shutdown. Very very rarely do they fully off load all of the fuel from the core into fuel pool. The likely scenario is they replaced a third of the core with new fuel...meaning two thirds of the core is extremely hot, lots of decay heat...while the other third is new fuel without any decay heat. They say a plant is more risky when shutdown because of all this decay heat than if it was running. There is a slight chance the core had all of its old fuel...they hadn't took off depleted fuel and replaced it with new fuel yet.

That is my story and I am sticking to it.

Oct 29...

Think about it, the service water intake high level 4.5 feet warning came in 7 pm and rising pretty quickly...

Lost of off site incoming electricity occurred at 8:14 pm...

The high high alert of 6 feet came in 8:44 pm...submergence of all service water comes in at 8 feet according to Exelon...meaning they lose both diesel generators at 8 feet.

I will bet you there never has been any testing with supporting the diesel generator on the potable pump.

It was rising at a greater rate of 18 inches in 1.5 hours. You know for a fact, they were trending this thing in the control room probably in one minute intervals. They were trending the rate increase on a one minute interval...

Right, they had no idea what was ahead of them...they had no idea how high it would get. How do you transition from the service water cooling the DGs, to the out side pump supporting the plant though the fire system, cooling the DGs.

If I was in charge of the site at 8:44 pm, I would have told the state and the NRC we are imminently going to lose all inside electricity, remember off site electricity has already been lost...all service water and the diesel generators to the site is about to be lost. We are preparing to eminently be in a site wide blackout. This is the only way you notify outside resources we are going to need big help in a very short period of time....give them as much time as possible to bring in the off site resources.

Id be telling the state and NRC, if the rate of heat sink level increase continues at this pace, we will be in a station blackout before 11 pm. You got to know I would be telling the control room staff and technical staff...I want to be continuously updated on the calculated loss of our service water system.

I would have said to the state and NRC, remember the fire outside pump through the fire system has never been tested and its operation cannot be assured....

They should have been in a higher alert status...

I'd like to know the high Sandy surge level around the Oyster Creek plant...

I believe overflowing the barrier sand bar threw a monkey wrench into the calculation.

Looking at it in real time, I bet you they thought you were an hour away from losing the service water pumps at 8:44 pm.



Facility: OYSTER CREEK
Region: 1 State: NJ
Unit: [1] [ ] [ ]
RX Type: [1] GE-2
NRC Notified By: STEVE SERPE
HQ OPS Officer: RYAN ALEXANDER
Notification Date: 10/29/2012
Notification Time: 19:18 [ET]
Event Date: 10/29/2012
Event Time: 18:55 [EDT]
Last Update Date: 10/31/2012
Emergency Class: ALERT
10 CFR Section:
50.72(a) (1) (i) - EMERGENCY DECLARED
50.72(b)(3)(iv)(A) - VALID SPECIF SYS ACTUATION
50.72(b)(3)(v)(B) - POT RHR INOP
Person (Organization):
JOHN CARUSO (R1DO)
WILLIAM DEAN (R1 R)
ERIC LEEDS (NRR)
MICHELE EVANS (NRR)
JANE MARSHALL (IRD)
VICTOR MCCREE (R2 R)

Unit SCRAM Code RX CRIT Initial PWR Initial RX Mode Current PWR Current RX Mode
1 N N 0 Refueling 0 Refueling
Event Text
NOTICE OF UNUSUAL EVENT DECLARED DUE TO HIGH INTAKE STRUCTURE WATER LEVEL

At 1855 EDT on 10/29/2012, the licensee declared a Notice of Unusual Event (NOUE) per criteria HU4 for high water level in the station intake structure of greater than 4.5 feet. At the time of the notification, water level in the intake structure was approximate 4.8 feet and slowly rising. The cause of the increased water level was due to storm surge associated with Hurricane Sandy. No other station impacts were reported at the time. The licensee continues to monitor the intake levels and ocean tides.

The licensee has notified the NRC Resident Inspector and the State of New Jersey.

* * * ALERT UPDATE ON 10/29/2012 AT 2141 EDT FROM STEVE SERPE TO RYAN ALEXANDER * * *

At 2044 EDT on 10/29/2012, the licensee escalated its emergency declaration to an Alert per criteria HA4 for high water level in the station intake structure of greater than 6.0 feet. At the time of the notification, water level in the intake structure was approximately 6.6 feet. The site also experienced a loss of offsite power event concurrent with the additional water level increase. Both emergency diesel generators started and are supplying power to the emergency electrical busses. Shutdown cooling and spent fuel pool cooling have been restored. Reactor pressure vessel level is steady at 584.7 inches. Intake levels continues to rise slowly and the licensee is monitoring.

The licensee has notified the NRC Resident Inspector and the State of New Jersey.

Notified DHS SWO, FEMA Ops Center, USDA Ops Center, HHS Ops Center, DOE Ops Center, DHS NICC Watch Officer, EPA EOC, and NuclearSSA via e-mail.

* * * UPDATE on 10/30/12 at 0414 EDT FROM GILBERT DEVRIES TO RYAN ALEXANDER * * *

The licensee updated this report with an 8-hour non-emergency notification of emergency diesel generator auto-actuation due to the actual loss of off-site power event [which occurred at 2018 EDT on 10/29/2012]. This event caused a valid RPS actuation with automatic containment isolations that resulted in a temporary loss of shut-down cooling to the reactor. Shutdown cooling was subsequently restored with power provided by the emergency diesel generators.

The licensee has notified the NRC Resident Inspector. Notified R1DO (Caruso).

* * * UPDATE AT 0357 EDT ON 10/31/12 FROM GILBERT A. DeVRIES TO S. SANDIN * * *

"Termination of Alert.

"The Oyster Creek Station has terminated the Alert that was declared at 2044 [EDT] on 10/29/12 due to Intake Structure high water level greater than 6.0 ft. MSL (EAL HA4).

"Intake water level has returned to normal and is now below the Unusual Event EAL threshold (4.5 ft. MSL) and continues to lower."

The licensee informed state and local agencies and the NRC Resident Inspector. Notified Region I IRC (Clifford), NRR (Evans), and IRD (Marshall).

Notified DHS SWO, FEMA Ops Center, USDA Ops Center, HHS Ops Center, DOE Ops Center, DHS NICC Watch Officer, EPA EOC, and NuclearSSA via e-mail.

Thursday, November 15, 2012

Escalation of problems with Peach Bottom’s SRVs


Originally published on Nov 15, 2012

Nov 26: Doing a little work on this for a few days...

Nov 25: How come from a period of 8/01/2001 to 11/25/2003(8) compared to 8/01/2009 to 11/25/2011(23) there are 300% more BWR's safety relief valve license event reports from the same length of time.I did a search on these terms in NRC Adams document system... 

The two year period covers the typical 28 months to two year operating cycle....

Content search on "Safety Relief valve" and "LER". 

Do you think the NRC criteria for writing LER had loosened, tightened or stayed the same. I think it loosened.

Why are there more troubles today?  

Nov 18: LER2012001
"There were no previous similar LERs identified involving an ADS SRV inoperability due to failure of the actuator diaphragm thread seal."
Well, truth be told, in the 2003 dual plant trip with SRV failures, with the SRV pilot valve stem packing failure on the steam side, the steam leak from the main valve damaged the actuator diaphragm thread seal and the heated steam damaged the diaphragm preventing opening the valve by control room switch.

...Hmmm: "The six SRVs and the one SV were replaced with refurbished SRVs / SV for the 20th Unit 2 operating cycle."

"There were a total of seven SRVs and one SV initially removed for testing and replacement during the 1 9 th Refueling Outage."

So 6 out of 7 were failures...so a 86% failure rate...430% more failure than average... 

So this outage had 500% more SRV failures than expected and the alarms bells hadn't gone off? Licensee Event Report (LER) 3-07-01: 
(2007)A historical review of SRV as-found test set points indicates that approximately20% of valves tested over time do not meet the + 1% Technical Specification set point.
Unit 2  LER 2012001 event date 9/26/2012
Based on information received from a laboratory performing Safety Relief Valve (SRV) / Safety Valve (SV) as-found testing, Site Engineering personnel determined on 9/25/12 that SRV / SV setpoint deficiencies existed with six SRVs and one SV that were in place during the Unit 2 19th operating cycle. The SRVs / SV were determined to have their as-found setpoints outside of the Technical Specification allowable ± 1% tolerance. The six SRVs outside of their Technical Specification (TS) allowable setpoint range were within the ASME Code allowable ± 3% tolerance. The one SV outside of its TS allowable setpoint range also exceeded the ASME Code allowable ± 3% tolerance. The cause of the SRVs / SV being outside of their allowable as-found setpoints is due to setpoint 
SRV 71A 24 1143-1167 1121 -2.94%
SRV 71D 16 1124-1146 1118 -1.50%
SRV 71E 81 1124-1146 1103 -2.82%
SRV 71F 19 1124-1146 1116 -1.67%
SRV 71G 82 1134-1156 1127 -1.57%
SRV 71H 17 1134-1156 1111 -2.97%
SV 70B BL-1095 1247 - 1273 1303 +3.41%
10CFR 50.73(a)(2)(i)(B) - Condition Prohibited by Technical Specifications 'Technical Specification Limiting Condition for Operation (LCO) 3.4.3 requires that 11 of the 13 SRVs / SVs be operable during operational Modes 1, 2, and 3. Contrary to this requirement, six SRVs and one SV were found with setpoints outside of the Technical Specification setpoint requirements.
10CFR 50.73(a)(2)(vii) - Common Cause Failure of Multiple Trains being Inoperable - Six SRVs and one SV were considered inoperable as a result of exceeding their allowable setpoint range based on laboratory testing. Therefore, this occurrence is considered as a common cause failure of multiple independent trains being inoperable.
There were a total of seven SRVs and one SV initially removed for testing and replacement during the 19th  Refueling Outage.

 That is a 100% failure rate and they don’t test all the rest of them...???

LER 2-10-03 reported two SRVs and one SV having their as-found setpoints in excess of the TS allowable + 1% tolerance. LER 3-07-01 reported two SRVs and one SV having their as-found setpoints in excess of the TS allowable ± 1% tolerance. LER 2-06-02 reported one SV having its as-found setpoints in excess of the TS allowable ± 1% tolerance. LER 3-05-04 reported a situation involving four SRVs having their as-found setpoints in excess of the TS allowable ± 1% tolerance.