Monday, March 17, 2014

Palisades 2.206 PCP Broken Impeller: Emergency Request to Stay Shutdown


The Palisades Saga

March 21:
Today at 11:37 AM

Mr. Chawla, 
I don't agree with the agency's decision on the impeller. I'd like to speak to the PRB by telephone please.
But, good job on the CRDMs! 
Can i speak to agency experts about the Palisades PCP broken impellers...can they be "up" on the history of PCP impeller damage at Palisades and the industry? 
I am waiting to see the NRC PCP impeller report concerning this on Adams...what is your proof that it is safe? I am particularly interested in IN 85-03. 
Thank you,
Mike

March 17: I am sure Palisades and the NRC got twenty pointy headed nuclear safety engineers each locked in a room for weeks poring over the paperwork and pictures. They call that safety. I call actual testing and experiments as safety.

The NRC has validated my scenarios as valid in my 2.206...the head corroding and blocking off flow to the assemblies. I certainly know my way around a PWR core and vessel.
"The NRC conducted an in-depth, independent review of the plant analysis of the impact the piece of metal within the vessel may have on the reactor vessel and fuel safety."
 Here is my criticism of their plan.
The Palisades Cracked and Detached PCP Impeller Saga 
 So the agency is answering me and validating my scenarios in my 2.206.
"The NRC conducted an in-depth, independent review of the plant analysis of the impact the piece of metal within the vessel may have on the reactor vessel and fuel safety."
Originally published on March 5
March 11
Honestly, this is what would make me conformable. Make a mockup of the core...then get a size assortment of impellers pieces. Say measure the  stuck piece as best as can...say the accuracy is plus or minus 10%. You then get something like three pieces of of the impeller pieces, one the estimated size and shape, then a  piece 10% bigger and another 10% ssmall. Then bang the pieces around in all kinds of core flows. In the mock up, you could carefully monitor where the pieces go and how they behave.  I am certainly not a engineer...but you get the idea  
So it is in to  the NRC...I misdated it as of yesterday.
Another area of increased non transparency is the leaking fuel pins and damaged fuel tubes. It would be legal today with half the pins in the core being  pierced and fuel pellets are rattling around in coolant:)  
They have administratively reduced the reportability requirements with damage fuel.
Honestly, I am beginning to wonder if Palisades would intentionally damaged a few fuel pins. It would kick up to radioactive dose rates all over the plant. Palisades could then use the high dose rates as justification for reducing half their maintenance and testing. I bet you they could cut the outage time in half! We know the NRC would buy into this craziness.
Personally, I think we have entered a very dangerous period within nuclear power. The idea that a lot of insiders and outsiders fear that one little "huff and puff of a little wolf’s breath" could knock prominently Palisades off the line. It is plain as daylight that a lot of people and news media around Palisades fear one more article could knock Palisades off the line.   
Everyone is pulling their punches fearing their utterance will kill 1000 or more jobs...  
March 5, 2014
Mr. Mark A. Satorius
Executive Director for Operations
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
DEFINITION OF NUCLEAR SAFETY CULTURE

Nuclear safety culture is the core values and behaviors resulting from a collective commitment by leaders and individuals to emphasize safety over competing goals to ensure protection of people and the environment.

TRAITS OF A POSITIVE NUCLEAR SAFETY CULTURE

Experience has shown that certain personal and organizational traits are present in a positive safety culture. The following are traits of a positive safety
culture:

• Leadership Safety Values and Actions—Leaders demonstrate a commitment to safety in their decisions and behaviors.

• Problem Identification and Resolution—Issues potentially impacting safety are promptly identified, fully evaluated, and promptly addressed and corrected commensurate with their significance.

• Personal Accountability—All individuals take personal responsibility for safety.

• Work Processes—The process of planning and controlling work activities is implemented so that safety is maintained.

• Continuous Learning—Opportunities to learn about ways to ensure safety are sought out and implemented.

• Environment for Raising Concerns—A safety conscious work environment is maintained where personnel feel free to raise safety concerns without fear of retaliation, intimidation, harassment, or discrimination.

• Effective Safety Communication—Communications maintain a focus on safety.

• Respectful Work Environment—Trust and respect permeate the organization.


• Questioning Attitude—Individuals avoid complacency and continuously challenge existing conditions and activities in order to identify discrepancies that might result in error or inappropriate action.

(The problem I have with “commensurate with their significance” is the agency and nuclear industry exaggerates their granularity with seeing safety significance reality boundary...it is a political statement. Nobody here has a god’s eye perfect view of what engineering reality is...the demarcation between safety and safety insignificant. You can’t even anticipate or predict with all the scientific and engineering tools known to mankind when a PCP impeller or CRDM will crack with accuracy. My proof of this is within this outage and the repetitive nature of these events.) 

Dear Mr. Satorius,

The links on the below are all on my blog:


The research concluded that the cause of the failures is fatigue-related effects from the operation of the pumps in conditions beyond the maximum flow rates and below the minimum net positive suction head recommendations as described in the UFSAR and other design documentation.

I’ll just say, San Onofre came to the end through many years of horrendous maintenance and operational problems. The last straw came from poor maintenance and bum engineering associated with the new generators. I think if San Onofre had a sterling NRC and public record...they would have survived.


Do you even want one nuclear plant operating in the USA if the agency allows a corporation to operate a nuclear plant in such a sloppy manner...indeed the NRC's ROP accommodates this sloppiness over and over again?
SUBJECT: PALISADES NUCLEAR PLANT INTEGRATED INSPECTION REPORT 05000255/2012003
The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR 50 Appendix B, Criterion III, Design Control, for the failure to operate the Primary Coolant Pumps (PCPs) in accordance with their design operating criteria. In October 2011, a slight rise in vibration levels on the ‘C’ PCP occurred and was sustained for approximately 24 hours. This was followed by a short spike in vibrations and a return to a lower stabilized value than what had been previously observed. Investigation by the licensee revealed it was likely a piece of an impeller vane which had deformed and broken free. Based on a review of operating experience associated with impellers and further licensee investigation, the inspectors concluded that the PCPs had been operated outside of their license/design basis as stated in the Updated Final Safety Analysis Report (UFSAR) with regard to minimum net positive suction head and maximum flow. Further, based on impeller-like pieces found in the reactor vessel in 2007 (which an apparent cause stated likely came from a PCP), and an operating history which indicated past occurrences of vane breakage and degradation, the inspectors concluded the licensee had the ability to foresee and correct the condition affecting the PCPs prior to the release of a piece in October 2011. The licensee entered the issue in their Corrective Action Program (CAP) as CR-PLP-2011-5744 and performed additional research into the phenomena leading to the impeller degradation. The PCP operating sequence was changed, an Operational Decision Making Issue was implemented, and efforts to explore further procedural changes are on-going to mitigate degradation of the impellers.
Criminal and malicious facilitative assumptions never backed up by science and evidence...judgments dictated by self-interest and massive political corruption. The utilities get to write the rules and control the agency.
 
2012-003: Investigation by the licensee with the assistance of outside consultants concluded it was likely that a piece of the ‘C’ PCP impeller deformed and broke free. There was no indication of degradation to the primary coolant system or reactor core components as a result of this postulated failure. NRC inspectors, including experts at the Offices of Research and Nuclear Reactor Regulation (NRR) reviewed the data gathered by the licensee and concluded that the pump was safe to operate until the refueling outage in April 2012 with the monitoring plan that the licensee had put in place.
This is a huge piece of metal.
The metal is 5 inches by 12 inches long..
"Lindsay Rose, spokeswoman for Entergy Corp"...why do we let these officials speak to us so plausibly stupid? Why are they so ill prepared with the history of the issue when they talk to the public? I think this is purposeful. Why aren't they technical people talking to us, instead of highly paid corporate spokesmen paid to talk stupid to us! This was intentional she didn't have the history on the impellers.
 
Rose said she did not have any information about when the metal piece might have broken off the impeller, which has been replaced. An impeller is a rotor that is used to pump water within the reactor.
This exactly like the "safety injection refueling water tank", which took them decades of leaks and half ass fixes before they discovered the tanks weren't constructed as designed (constructed poorly). Don't forget about the massive self-destruction of the  Palisades CRDMs they are dealing with right now. The repetitive nature of flaws, cracks, leaks and shutdowns...the obscene nature of the exact same NRC violations and failed revolutionary alloy designs repeated over and over again derived from poor quality maintenance and plant operations! The impeller weld job from the Walmart Superstore Automart known to be a lessor quality than the Primary Coolant initial design requirements.
   
The NRC accommodates plant and corporate destructive behavior...they aren't in the game of mandating a change of bad behavior! The NRC isn't in the game of picking up the easily detectable early stages of bad behavior...then turning it into good business behavior towards the better interest of the USA and our communities. Believe me we get it, this result is a political congressional and presidential prerogative.
The licensee identified impeller cracking had been observed at Palisades on several occasions since 1984, when the pumps had been removed for inspection and refurbishment/replacement.  
How many total pieces? Obviously they falsified past investigations and searches for broken impeller pieces...knowing the current piece was unrecoverable or not removable. At worst, they were incompetent with past searches.
Additionally, pieces suspected to be from impellers were discovered in the bottom of the reactor vessel in 1984 and 2007.  
The broken impeller and cracked CRDM are terrible and dangerous news...but all the things that has happened in last four years at this plant are much worst?
 
Epic non-conservative judgments. It is systemic engineering certainty and uncertainty gaming. Why didn't the agency stop Palisades...make them inspect all the PCP impellers considering all this history upon the first detached impeller vane? Why wasn’t this reportable to the public. What else is not openly disclosed to the public.  The 2011 Red Finding yellow finding spoke of endemic and habituated non conservative judgments (a pattern). They are doing the same engineering and regulatory gaming with the massive and repeated CRDM cracks and the broken off impeller vanes seemingly with the NRC 's permission...the yellow finding medicine through 2012 absolutely did not take hold. It was all a fake phony facade.
I'll put it in the grid and ISO perspective. Exelon is threatening to shut down an assortment of nuclear plants within a short period of time because of low ISO market prices of electricity and unfair competition from corrupt green electricity. Palisades is situated in the same market and undergoing the same pressure. Well, except it is a merchant plant.  The NRC is severely pulling their punches because they know Palisades is so economically vulnerable. Why didn't we ever know what the true motives with the decision the NRC and Entergy makes? Why is everything always hidden from us? Why is our electricity market so Soviet style, when we are supposed to be the most open society is the world?
 
Approx. May 2012: In response to the discovery of two pieces that resembled the PCP impeller composition during reactor vessel inspections in 2007, the licensee conducted an apparent cause analysis. The conclusion was that the pieces were most likely from the ‘D’ PCP. Additionally, the analysis explored the history of Palisades’ PCP impeller conditions which included repeat occurrences of cracking having been identified and an instance of "heavy recirculation damage," which rendered an impeller unfit for continued use. The pump manufacturer, Flowserve, also released a Tech Alert due to the Palisades PCP vane cracking history. The apparent cause analysis implied that the pieces were fatigue generated and that additional vane breakage was possible. Despite this, the PCPs were not declared as non-conforming nor were any compensatory measures taken. When the ‘D’ PCP was later inspected after removal during the 2009 refueling outage, it did not have any pieces of impeller missing. Inspections of the other PCPs, which were recommended in the apparent cause and had been planned to be executed if the ‘D’ PCP was not the source of the 2007 pieces, were cancelled. The cancellations were based, in part, on thoughts that the pieces may have originated elsewhere. However, vessel inspections done in 2007 revealed no deficiencies that would infer the pieces were generated somewhere within the reactor vessel, and the 2007 apparent cause analysis had essentially ruled out other sources.
Come on, the inspection was cancelled because they were trying to save a few pennies by not lengthening an outage. The pressures on making a short refueling outage is going to be very damaging to the USA someday...
Right, the above is engineering certainty/uncertainty language gaming...found impeller pieces in 2007, opened one pump in 2007, found no damaged impeller, assumed they found nothing broken in the primary piping system and core...thus all the other pumps must have no broken impeller. Conservative judgment would consist of finding one piece of impeller...then opening up all the PCP pumps and replacing all the impellers with good quality impellers... matching up the broken pieces with impellers.

Remember, I talked about beautiful science and technology. Why the fixes coming out of the 2012 NRC inspection didn’t put an end of with vane damage. They inspected the impeller this outage and then found this huge piece of metal at the bottom of the vessel. It seems like the opened up pump didn’t have the damaged impeller. How do we know right now there is not another broken impeller in a non-inspected pump? Obviously the pump is a defective design...not good for the duty intended. We still don't know why Palisades operated this pump outside the manufacture recommendations and plant designs.
I try to use science and engineering to anticipate problems and fix them early...Palisades and the NRC uses science and engineering to justify not fixing defects and running equipment irresponsibly. Science is just a tool...you can use any tool to do good or evil. Or just plain “bullshit” the outside with disconnected scientific and engineering talk and rationalizations. Dressed up disconnected corporatese public relations talk.  It is just a choice! 
Rose said the impeller piece was from one of the plant's four main coolant system pumps. That impeller was recently replaced during this outage, she said.
 
Personally in the below, I'd be worried PCP seal damage with a damaged off balanced impeller...that is in the accident studies with the largest risk to the community. I wouldn't trust the accuracy of the installed vibration detectors.
 
Any good corporate citizen would immediately recognize weld repairing a safety related nuclear pump impeller in a high temperature environment is just plain crazy science and engineering talk. Where is the NRC in establishing standards! Maybe the pump is so obsolete they didn’t have new impellers in stock? Why has the NRC allowed Entergy to weld repair PCP impellers? Ah, the codes are god...you can’t question the store bought corporate engineering codes.
The licensee noted, based on metallurgical examination of a previous fragment, previous pump inspection findings, and the mechanism by which the cracks propagate, that weld-refurbished impellers were particularly susceptible to degrading to a point where a piece could be released.
Entergy always knew where to look.
 
Additionally, pieces suspected to be from impellers were discovered in the bottom of the reactor vessel in 1984 and 2007.
I think this all is a broad corporate business philosophy...Entergy is Systematically Destroying Nuclear Plants through a Run-to-Failure Philosophy. Here is a new Pilgrim nuclear plant NRC inspection report. The agency speaks of non-safety component's run-to failure philosophy. It does get you wondering, will the non-safety equipment run-to-failure-philosophy cause the public to lose faith in the safety of a plant? Does Entergy even care?  It might be legal to the corporatized NRC, but it is not be acceptable to the public?
 
New Pilgrim Plant inspection-The following observations have been noted by the inspectors: SRV performance was a driver for several down powers and forced outages in 2012 and into 2013; a number of unplanned down powers and shutdowns were the result of non-safety-related equipment failures; it appears that non-safety-related equipment that was characterized as a run-to-failure is starting to reach the end of their service life and can likely become contributors to such events.
Do you want anything nuclear to ever run-to-failure? Are these guys so smart with completely understanding the complexity of the reality inside these plants? If they did, these guys would operate these plants without blemish. We wouldn't be here today. They think we can see a god’s eye granularity...or at least they pretend to speak to us outsiders that way.
 
This is a prime example with the NRC inspection, licensee notification system to the public and the ROP. What is the agency covering up? Why hasn’t every flaw or crack in PCP impeller thoroughly covered in a Licensee Event Report? Why wasn’t all the broken off vanes thoroughly covered in a LER. Why wasn’t every flaw or worst in an impeller thoroughly covered in an inspection report? What you hide, you repeat; what you openly disclose, you fix and begin repairing the organization.
 
Further, this is questions if the NRC are selectively releasing troubling information at all the plants. That is, what information disclosures are required and what info actually gets released? It invalidates the ROP and the trustworthiness of the NRC. In an open democracy like the great USA, so they say...there should have been a public document trail from the moment the first impeller flaw showed up in the NRC and Entergy. I get the NRC has the power of kings...they get to decide what rules are valid for the agency and utility irrespective of the rules on the brooks. The rules are secretly situational for the agency.  This is all razzmatazz corruption up with phony scientific and engineering language.
 
The worst agency sin of all, why wasn’t there a follow up report on “NRC Enforcement Policy (NCV 05000255/2012003-02, Operation of Primary Coolant Pumps Outside the Design Basis”?
 
Basically the NRC and Entergy are saying it is safe to operate these components outside their manufacturer and plant designs...even after repetitive damage. Even after the manufacturer told them to knock it off. It is self-destruction on a massive scale! The NRC allows a utility to run- to-failure safety components? This is a run-to-failure philosophy just like Pilgrim except it is actually safety related.  Are components ever designed, tested and licensed to run-to-failure...where we know by engineering how it happens? You notice the NRC never gets to the bottom of it...public democratic disclosure...the ultimate rationale or justification with why Entergy was operating these components to damage outside the manufacturer’s recommendation. Oh brother, we know why they are doing it. This looks terrible on the nuclear industry to the outsiders...they are protecting themselves through the high powered Soviet style secrecy and deceptions. They are the ones with the keys to the actual information with what is really going on.
 
The research concluded that the cause of the failures is fatigue-related effects from the operation of the pumps in conditions beyond the maximum flow rates and below the minimum net positive suction head recommendations as described in the UFSAR and other design documentation. These conditions are present when operating only one or two PCPs during reduced temperatures and pressures (typically during startup and shutdown activities). Cyclic pressure pulses and stresses are created under these reduced pressure conditions that act on the leading edges of the impellers, which can ultimately lead to vane cracking and the release of impeller fragments. The licensee noted, based on metallurgical examination of a previous fragment, previous pump inspection findings, 18 Enclosure and the mechanism by which the cracks propagate, that weld-refurbished impellers were particularly susceptible to degrading to a point where a piece could be released. Currently, none of the PCPs contain any remaining weld-repaired impeller areas (ones that did are postulated to have released pieces already). Also, at normal operating temperature and pressure, there is adequate net positive suction head on all PCPs, so these additional stresses are not present.
In response to the discovery of two pieces that resembled the PCP impeller composition during reactor vessel inspections in 2007, the licensee conducted an apparent cause analysis. The conclusion was that the pieces were most likely from the ‘D’ PCP. Additionally, the analysis explored the history of Palisades’ PCP impeller conditions which included repeat occurrences of cracking having been identified and an instance of “heavy recirculation damage,” which rendered an impeller unfit for continued use. The pump manufacturer, Flowserve, also released a Tech Alert due to the Palisades PCP vane cracking history. The apparent cause analysis implied that the pieces were fatigue generated and that additional vane breakage was possible. Despite this, the PCPs were not declared as non-conforming nor were any compensatory measures taken. When the ‘D’ PCP was later inspected after removal during the 2009 refueling outage, it did not have any pieces of impeller missing. Inspections of the other PCPs, which were recommended in the apparent cause and had been planned to be executed if the ‘D’ PCP was not the source of the 2007 pieces, were cancelled. The cancellations were based, in part, on thoughts that the pieces may have originated elsewhere.
Engineering and scientific certainty/uncertainty gaming is pernicious engineering language corruption. It is stealing community security and lying to the CEO and stockholders.  
However, vessel inspections done in 2007 revealed no deficiencies that would infer the pieces were generated somewhere within the reactor vessel, and the 2007 apparent cause analysis had essentially ruled out other sources.
In response to the October 2011 event and subsequent research conducted to better understand the phenomena affecting the PCPs, the licensee has instituted a monitoring plan, changed the preferred sequence for starting/stopping PCPs during startups and shutdowns, and has corrective actions to explore further procedure changes regarding operation of the PCPs and the resultant impact on other aspects of plant operation.
Yet here we sit in 2014 with a broken impeller and a blade stuck in the vessel. They don’t know where the broken blade came from...there is no engineering proof it didn’t come from a non inspected pump impeller. Are you absolutely sure your at power plant vibration detectors would detect every detachment?

 There is no absolutely no proof that the corrective actions coming from IR 2012003 actually fixed the problems. If the problems was so easy to fix as to the “properly sequence the RCP pumps” during heat up and cool down operation, why didn’t they do this easy and cheap fix three decades ago?  
 
Since the licensee was intending to have this non-conformance on the C pump (missing impeller pieces) the entire cycle, the inspectors (including experts at the Offices of Research and NRR) reviewed the impact of this non conformance on the PCP safety functions. Key safety functions of the pump are to provide a coolant pressure boundary and ensure an adequate coast down of flow. The review indicated there were no current safety issues with this non-conformance. The inspectors are evaluating the monitoring plan to determine its long-term effectiveness.
You get it, no intent in 2012 to inform the public and its being repeated in March start-up?
How do we know what are the forces holding the broken vane to between the reactor vessel and vessel shirt? Everyone in New Hampshire this winter knows the power of water and ice expanding and contracting. We are inundated with frost heaves and frozen broken pipes. So what about the difference of contraction between the vessel and flow skirt from 550 degrees/2250 psi to room temperature? In other words, there could be tremendous forces squeezing the broken vane between the vessel and the flow shirt solely due to the cool down. How do we know if a bolt isn’t snapped or it there is weld failure attaching the shirt to the vessel or other components? How do we even know if the cladding has been penetrated into the vessel alloy by the broken vane. How do we know if some corrosion mechanism on steroids would secretly take place at power and normal temperate? What if  this leads to a vessel penetration and then onto  a LOCA? Would it get past a vessel design max flaw leading to a vessel LOCA?   
So you tried yanking out the broken vane. What if all you did is just loosened it? The vessel and skirt re-expands upon heat-up and normal flow vibration releases the errant broken impeller vane. It then travels into a centerish high powered fuel assembly inlet and blocks off coolant flow? What if it blocks off flow to two fuel assemblies? What if we wake up one morning and two fuel assemblies have been destroyed?  Palisades and the NRC have melted down two fuel assemblies. It would be a tremendous internal release of radioactive. Most likely it will be an insignificant release of radioactivity to the outside. It would destroy the core and the operability of the plant.  Hope your steam generators are tight. It would probably take out many other plants in the USA. It would be a media circus much worse than TMI. There would be massive re-regulation.
I would characterize this off normal event as extremely complex and there is an assortment of barriers preventing everyone from seeing what is going. Palisade has once again over stated their granularity with understanding of what is going ...predicting future interactions.  These guys think they have turned water into wine again. If these palisades engineers are so good at predicting the future...why did n't they allow the impeller even crack and break off? Why didn’t Palisades and the NRC prevent the impeller damage based solely on their perfect science and engineering? These guys can’t even control and predict human behavior...why did they tolerate operating outside the plant designs? There is just so much complexity and missing science and engineering information here...the future of this is not understandable or predictable!  
Engineers make sense out of the apparent available evidence...I worry about the unknown unknowns. (http://en.wikipedia.org/wiki/There_are_known_knowns).
DonaldRumsfeld: ‘Reports that say that something hasn't happened are always interesting to me, because as we know, there are known knowns; there are things we know that we know. There are known unknowns; that is to say, there are things that we now know we don't know. But there are also unknown unknowns – there are things we do not know we don't know”.
You guys are running is the greatest “confidence game” the world has ever known (professionalism and educational). A confidence game are words and utterances by the NRC or a licensee not backed by true science, engineering or the facts. More, situational quasi science, engineering or the facts...ghost truth and evidence!
confidence game, any elaborate swindling operation in which advantage is taken of the confidence the victim reposes in the swindler.
I respectfully request the following.
1)     The NRC and Entergy hold a mandatory public meeting before start-up and disclose at the facts surrounding this. The NRC has a well-known path with only disclosing the dirty laundry months after start-up, if ever.
2)     Palisades and the NRC explain why the plant was allowed operate outside its design bases for so long. Why did the NRC allow this violation until damage show up?
 
3)     Palisades pop open every pump for an inspection...all flaws cleared up with new impeller.
 
4)     Palisades explain why they went to dangerous weld repair instead of new impellers. Please detail how all the other plants repaired their impellers...weld or new impellers?
 
5)     Request a ten million dollar fine over these events.
 
6)     Palisades is mandated to remove the broken vane before start-up.
 
7)     Please detail all activities to prevent going beyond the design basis? Has it been proven this “explored different sequencing of PCP operation during subsequent startups” has prevented further violations of the design basis?
 
8)     Please disclose all plant information and investigatory information associated the damaged impellers. Have there been any flaws post new “sequencing of the PCP” discovered?  
 
9)     Were there any Entergy internal reports or concerns made before the 2012003 NRC inspection that Entergy was operating outside it design bases? Please disclose all documents associated with this.
 
10)  Please disclose all information associated with the CRDMs flaws and crack replacement activities this outage. Request that Palisades not startup until all the CRDMs are replaced.  God help you if the eight or so CRDMs not replaced develops a leak during this next operation period. Please disclose the reasons and resource limitations preventing the replacement of said CRDMs.
 
11)  Please disclose the date and time when the broken vane was reported to the NRC.
 
12)  Is this going to be an LER or event notification...please explain why it is not reportable?
13)  I Request Palisades be returned to the yellow or red status...intensification of NRC monitoring!  This plant continues to be a very dangerous plant to the community of US nuclear plants. This plant has a recent history of excessive shutdowns, taking dangerous shortcut risking human life and plant safety (DC) and the uncontrollable intensification of component flaws, cracks and leaks. Entergy has a known run-to-failure philosophy with the NRC and it clearly has been defusing into safety systems at Palisades.
14)  Please list all the plant debris...especially metal shards and pieces discovered in the inlet to the primary side of the steam generators. Please list and explain any debris discovered anywhere in the primary system for the last ten years.
 
15)  Please replace the Primary Coolant Pumps with a design for its intended duty!
This rises to the level where the public are not being adequately apprised of the conditions of the nuclear plants. Members of the public are being systemically denied an adequate democratic process within the nuclear industry. If big and important events are being withheld from public view...then any minimal NRC process is a impossibility. I hereby declare, we are pre TMI with mandated public disclosures!   
Palisades spokeswoman Lindsay Rose tells WSJM they have "determined there will be no impact on safe operations." She went on to say the piece is separated from the fuel and the material "does not rise to the level of being reportable to the Nuclear Regulatory Commission."
 
Sincerely,
 
Mike Mulligan
Hinsdale NH
16033368320
steamshovel2002@yahoo.com






NRC's Risk Related Transmution Industrial Mill

Glossary of Risk-Related Terms

See, the majority of this is assumptions and them choosing a favorable limitation or a boundary solely based on an ideology. This is a special ideology specific to nuclear power based solely on self-interest.
 
None of this is based on the certainty and evidence of science...it is all crafted on insider assumptions and judgments. Deep in the bowels of these mathematical calculations that nobody can understand is special insider assumptions and judgements...risk is predicated on insider assumptions.  This is an industrial transmutation mill that turns uncertainty into certainty!

It all translates into a nothing-ever-matters attitude because we got multitudes of back-up safety systems to back-up safety system.  Everything is always safe, safe and safe.  Nothing Matters.
If nothing ever matters, do you see how a organization can so spin out of control?





Friday, March 14, 2014

What, Now A CDRM Housing Fragment is Stuck in the Other side of the Vessel-Skirt?

March 16: Bet you the NRC said replace all the CDRMs, and we will forget about the impeller. Very little discussions or disclosure about these things until way after re-start.

Well, I got half of what I wanted. They'll make me a rock star if they melt down a fuel assembly. It would have been a big job to off load all the fuel and start taking apart the core support struture ti get at that stuck impellar. Can you even inagine the dose of these compents?

It is just un-American that you say we got a large foreign object struck in the bottom of nuclear core and you refuse to get it.
You knew the startup was right around the corner...
Palisades Nuclear Power Plant returned to service after 55-day scheduled refueling outage

COVERT TOWNSHIP, MI — The Palisades Nuclear Power Plant was put back into service Sunday morning following a 55-day, 19-hour scheduled refueling and maintenance outage that began Jan. 19.

During the maintenance period, which was the plant's 23rd refueling outage, 64 used fuel assemblies were removed from the reactor vessel and replaced, according to a press release issued Sunday morning. Other major projects completed include inspections of the reactor vessel and the plant's two low pressure turbines.

Early in the inspection, 17 of the plant's 45 control rod drive housings, which protect the drives that allow rods to be inserted and withdrawn from the core reactor, were found to not meet inspection criteria. While there was no leaking associated with any of the housings, all 45 were replaced with new materials.

More than 1,000 outside workers assisted Palisades employees with outage work.

It was also announced during the outage on March 3 that Palisades' workers had found a broken piece of metal from an impeller blade that had lodged itself inside the plant's reactor.

Palisades workers were unable to remove the metal after it became stuck between a vessel wall and the flow skirt. Entergy Corp., which owns Palisades, said at the time it plans to leave the metal in the reactor since it's not a safety issue.
Palisades 2.206 PCP Broken Impeller: Emergency Request to Stay Shutdown

March 15 We are not out of the woods yet. I would still wory about poor workmanship and engineering. But I have no start up issues over the CRDMs.

(Insider Joke)

So there is Palisades first swipe.
Jan 30: "The power plant plans to replace the 17 housings and return to service once work is complete. "One intent of a refueling outage is to conduct inspections or work that cannot be completed when we're online," said Rose. "We will be replacing those 17 housings that did not meet our criteria, and as a proactive measure to ensure continued safety, we will replace several other housings that did meet our criteria. The housings will be replaced with housings of a different design and material.""
Here is the second swipe…I guess Palisades found some extra ability somewhere.

These remaining 8 CRDMs are hard to replace and they cost a tremendous dose of radiation to the employees.
Feb 6: "When asked why the plant wouldn’t replace all 45 control rod drives with the new design, Rose said the plant said the replacement of 38 was “all we have the ability to do with this outage.”
When asked why the plant wouldn’t replace all 45 control rod drives with the new design, Rose said the plant said the replacement of 38 was “all we have the ability to do with this outage.”"
Seems I was persuasive enough in the below…no doubt I influenced them. They are terrified with the fallout of those 8 not replaced leaking in the near future.

"Come on, in the 2012/2013 assumption in this outage is you would test 25% of the CRDM and find no cracks. Then test 25% thereafter. It is the normal condition that a plant finds no cracks on their CRDM throughout the life of the plant.

So far you found 17 CRDM having cracks …that is 37% of the rods. You usually find lots more cracks after the all the is results come in. If you can’t trust the agency to anticipate this blossoming level of degradation…how can we trust the agency to anticipate a leak? How come the agency didn’t see this coming? You know, there is a astonishing number of violations going back years with the CRDMs and quality. The 2012 leak violations was just a repeat of the 2001…and 2001 was violations repeat of other prior incidences.

Just saying, why wasn’t the state of the art with metallurgy able to predict in 2012 that Palisades would find “at least” 37% of their CRDMs had cracks in them. Believe me, based on all the past reports I read on this, you won’t disclose the full numbers of cracks in the CRDMs (more than one per CRDM) till after restart. Why can’t these licensee PhD metallurgist predict future flaws and cracks instead of justifying past flaws? 
It is illegal to start-up and operate if they had evidence CRDM unidentified leakage was increasing…they assumed they didn’t have leaking CRDM because they didn’t have full vision of the CRDM. They didn't have perfect evidence that the unidentified leakage wasn't a CRDM leak.
Lets remember the incomplete information accident in the Davis Besse head event. The licensee and the NRC assumed the CDRM flanges were leaking when it was a crack through the CRDM nozzle and eating the head. Who in a new different accident is talking about they were “refusing to communicate uncertainty“.

For decades there is a widespread mindset in these organization that piping cracks and flaws don’t lead to leaks. That is what is behind this.

You get it, these CRDM leaks at Palisades tend to show up within a month or so of a start-up and the leak worsens quickly. I’ll bet you both leaks (2001 and 2012) actually started before start-up. Palisades has a pattern of calling a prohibited CRDM leaks not a leak….cold bodily waiting to the CRDM leak gets to .3 GPM unidentified leakage or more according to their procedures. They have a requirement not to operated with pressure boundary leak and they chose to ignore the rules!

I am just saying next operating cycle, how can you trust these guys to follow the rules? How can you trust these guys with a pattern of behavior like this…when these guys have abnormal or increasing unidentified leaking, when they don’t have absolute proof a pressure boundary “is not leaking“…how can you trust them to do the right thing with incomplete information. Honestly, how can you trust these guys to meet the commitment they won’t operate with pressure boundary leakage again.
How can we trust the agency to make sure a plant like Palisades is keying on accurate, up to date and real time information about pressure boundary leaks. When Palisades and the agency are knowingly keying off incomplete information…that they act “super” conservatively.

Next operating cycle will they immediately shutdown the plant when a CRDM begins to leak like regulation requires. Will it take weeks and months to shutdown the plant over leaking CRDMs like in the two times in the past? In the leaks in 2001 and 2012 Palisades did that. That is a pattern.


So Palisades destroyed their CRDMs through or a result of all the recent startups and shutdown?

Is the Pressurizer weld flaw today connected the all the CRDM cracks?

Does the NRC really think those pristine inspected rods without flaw in 2012 really didn’t have flaws…when two of them were discovered with cracks this outage?

And the industry says the incubation period for developing a crack is over ten years?

These vulnerable eight CRDMs not replaced this outage…is anyone thinking about the loss of NRC and industry credibility if any of them come up with cracks or leaks within the next operating period…maybe something worst."
A different design and alloy has repeatedly failed in the past. The scientific way to handle this is put the “another new design” in a exact environmental mockup before attaching it on the vessel. Maybe even a hyper environment. Prove there will be no more cracks and flaws in the CRDMs for a decade through a simulated environment.

PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE – PNO-III-14-002A

This preliminary notification constitutes EARLY notice of events of POSSIBLE safety or public interest significance. Some of the information may not yet be fully verified or evaluated by the

Region III staff.

SUBJECT: UPDATE - PALISADES CONTROL ROD DRIVE MECHANISM HOUSING FLAWS

This Preliminary Notification updates information provided in PNO-III-14-002, associated with the licensee’s examination of the Control Rod Drive Mechanism (CRDM) housings, consistent with commitments made by the licensee to the Nuclear Regulatory Commission (NRC) following its previous outage. The CRDM housings are part of the reactor coolant system pressure boundary and are designed to prevent reactor coolant from leaking into the containment. The CRDMs aret the mechanisms that withdraw and insert the control rods into the reactor and extend from the reactor head to about 14 feet upward.

As a result of these examinations, the licensee identified flaws in 17 of the 45 CRDM housings and replaced all of the CRDM housings with new housings of a different design that is more resistant to developing this type of flaw. One of the 45 CRDM housings was replaced during the previous outage and the remaining 44 housings were replaced during the current refueling outage.

Two NRC resident inspectors, assigned full time on-site to inspect and assess licensee activities, and an NRC regional inspector and subject matter expert, who was pre-staged on-site at the start of the refueling outage, observed the licensee’s examination of the CRDM housings and continue to evaluate the licensee’s corrective actions for the identified flaws. Additionally, NRC headquarters and regional experts conducted an independent and detailed review of the licensee’s technical evaluations and destructive testing of four of the housings with identified flaws. Based upon its independent review and assessment, the NRC concluded that the CRDM housings’ structural integrity was not compromised while the plant was operating.

The NRC will document its conclusions in a publicly available inspection report.

The State of Michigan has been notified.

The information in this preliminary notification is current as of 11:00 a.m. (EDT) on

March 14, 2014.

The Extreme Disappointment With Ex Chairman Jaczko


The disappointment with Ex Chairman Jaczko

Former US nuclear regulatory chief wants phase-out as lesson from Japan's Fukushima disaster
Submitted by NUCBIZ on March 14, 2014 - 17:57

TOKYO – As radiation spewed from Japan's nuclear disaster three years ago, the top U.S. atomic energy regulator issued a 50-mile evacuation warning for any Americans in the area, a response some found extreme.

Gregory Jaczko, who stepped down as chairman of the Nuclear Regulatory Commission in 2012, still believes he was right, and says the events at the Fukushima Dai-Ichi plant show that nuclear power should be phased out in Japan and worldwide.

"The lesson has to be: This kind of accident is unacceptable to society. And that's not me saying it. That's society saying that," he said in an interview this week in Tokyo, where he is giving lectures and speaking on panels marking the third anniversary of the March 11, 2011 earthquake and tsunami that overwhelmed the Fukushima plant.

Now a lecturer at Princeton University, Jaczko, 43, has become a hit on the speaking circuit in Japan, where all 48 nuclear plants remain offline as the country debates what role nuclear power should play in its future.

The government is pushing forward with a plan to restart several reactors after safety checks, despite continuing public opposition. Nuclear regulators announced Thursday they are beginning the final approval process for the restart of two reactors at a plant on the southernmost main island of Kyushu.

Jaczko said he had been always concerned about nuclear safety. But so much unfolded at Fukushima that experts were unprepared for, that it changed his view, and that of the Japanese public, on nuclear power.

Chernobyl and Three Mile Island were major accidents, but for Jackso, Fukushima definitively undermined industry assumptions such as multiple accidents were unlikely or hydrogen leaks would be controlled.

Three of the reactors at the Fukushima Dai-ichi plant had meltdowns, and two had hydrogen explosions. The idea that a plant wouldn't be under control three or four days after an accident was unthinkable before Fukushima, he said.

"We have defined safety measures against the things that we kind of know. An accident is going to be something that we didn't predict," he said.

During the Fukushima crisis, the Nuclear Regulatory Commission staff discussed possible evacuation zones of between 20 miles and 50 miles, and given the uncertainty, opted for 50 miles, he said. A 50-mile evacuation has never been adopted as a standard for disaster scenarios in the U.S.

Jaczko said it luck the wind blew in a direction that sent much of the radiation out to sea.

His resignation from the NRC, three years into his five-year term as chairman, followed complaints about his management style. He says he could no longer support the licensing of reactors in the U.S. after Fukushima.

Yotaro Hatamura, an honorary professor at the University of Tokyo who took part in a government investigation of Fukushima, said the right decision on nuclear power can't be made without addressing the what-if scenarios of accidents.

"A true debate is needed, but all we're getting is: Are you for or against nuclear power?" he said, sitting with Jaczko on a recent panel at the Japan Press Center.