The NRC's Happy Juice On Fort Calhoun

(A works in progress!)

The NRC certain knows how to play the media. Happy tunes in the beginning of the inspection report for the new media shallow idiot, while the very troubling violations later in the report. In other words, they know the reporters don't have the skills to properly interpret the report.

You just have to wonder how the NRC are catering  their activities to board candidate andlawyer Jeff Lux?

You just wonder how the Problem Identification and Resolution, the  corrective action program and the recent well known training program are interrelated. Right, the NRC expresses the CAP and training program in a isolated light. They never speak to us how the CAP and training are interrelated.

 Right, the NRC speaks as if Fort Calhoun is meeting 9 out of 10 commitments identified in CAL. We are safe, safe, safe! It is like saying the all these systems in you car are working great; the motor, transmission, headlights, tires, battery and brake lights are working properly, but your actual brakes are wheezing on their deathbed. Fort Calhoun is meeting the magority of their CAL commitments (whatever that means). Running a nuclear power plants with a broken CAP is very dangerous and it just might the greatest show stopper. The NRC is front loading you brain, the media with the happy juice... but the experienced guys knows this is a very troubling report and the plant shouldn't be running.

Fort Calhoun is effectively without their brakes???

Again, why is Cooper and Fort Calhoun having training problems together...why does it take outsiders to kick Fort Calhoun in the ass? This INPO deal is a rather secretive process where the NRC allows a plant to operate in a degraded condition hoping INPO will turn their hearts. The NRC hopes Fort Calhoun will come to their senses before they have to notify the public. They are basically forsaking public notification and operating outside the reactor oversight process process in cahoots with a wholly nuclear industry funded program.

I wonder if the NRC seen any problems with the Fort Calhoun's training programs upon their shutdown inspections? The only thing that has changed since then is Exelon is managing the plant. The problem with these kinds of relationships, is now the board is even more isolated than before. It just might be the reason why they did this, board political protection. Hey, you can't blame us Exelon never told about the problem...

Again, the NRC protects plant management with not expessly stating why the CAP isn't being followed, where the public might comdemn them all the more.

I either hit a tree because a deer jumped out in the road right in front of me or I was severely intoxicated, I just didn't care about paying attention to the road. Which is it?  

"A number of the deficiencies that were identified by the inspectors involved inadequate evaluations of degraded or non-conforming conditions that were entered into the CAP."

September 18, 2014
EA-14-151

SUBJECT: FORT CALHOUN STATION – NRC CONFIRMATORY ACTION LETTER FOLLOW UP INSPECTION AND PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NUMBER 05000285/2014009 AND NOTICE OF VIOLATION

Based on the inspection results, the team concluded that FCS maintained a CAP in which
individuals generally identified issues at an appropriately low threshold. Of concern, the team
identified a number of deficiencies involving OPPD’s ability to effectively and consistently
evaluate and resolve problems as discussed in more detail below, and in the enclosed
inspection report.

A number of the deficiencies that were identified by the inspectors involved inadequate
evaluations of degraded or non-conforming conditions that were entered into the CAP. Several
examples involved the failure to make an immediate determination of operability because your
staff failed to recognize that a degraded or non-conforming condition existed. Additional
examples involved operability evaluations that lacked adequate technical justification as to why
the affected system, structure, or component would perform its specified safety function as
described in licensing and design basis documentation. The team concluded weakness exists
in this area and that OPPD’s corrective actions, to date, have not been effective in ensuring that
problems are consistently evaluated in a thorough and effective manner, with the appropriate
technical rigor that supports the operability conclusion.

These findings and observations are similar to previous NRC inspection results identified during
the last NRC PI&R team inspection completed in June 2013, documented in NRC Inspection
Report 05000285/2013008. Many of the issues, identified both prior to and following restart,
reflect a poor understanding and use of design basis information. We do note that you are
taking action to address this challenge by a long-term licensee commitment to conduct a design
basis reconstitution through 2018. Based on the results of this inspection, the NRC
understands OPPD is conducting evaluations to determine the cause of the performance
problems affecting effective implementation of the corrective action program. The NRC is
interested in understanding the status of these evaluations and corrective actions during an
upcoming public meeting in Omaha, Nebraska on September 25, 2014. Additionally, the NRC
will be conducting future inspections focused on these areas of concern.


The NRC determined that, with the exception of the PI&R key area and the Operability
Determination element of the Program key area, OPPD is adequately implementing the CAL
items. The NRC determined that five key CAL areas were adequately completed and are
considered closed. These five key areas are:

• Organizational Effectiveness, Safety Culture, and Safety Conscious Work Environment
• Site Operational Focus
• Procedures
• Nuclear Oversight
• Transition to the Exelon Nuclear Management Model and Integration into the Exelon
Nuclear Fleet

Finally, there were also a number of deficiencies identified by the inspectors that involved
inadequate resolution of problems. Of particular concern, the inspectors reviewed OPPD’s
actions to resolve 36 previously issued NRC non-cited violations, documented in various
inspection reports in 2013, and identified five examples where OPPD failed to adequately
address the issues. Several examples were noted where no actions were either planned or
implemented to resolve the findings. The inspectors noted that a self-assessment, performed
by both OPPD and Exelon individuals prior to the team inspection, also identified this concern,
however, incomplete CAP implementation resulted in deficiencies that were not entered into the
process, and, subsequently, the particular non-cited violations were not adequately addressed.
As a result, the NRC has determined that one Severity Level IV violation of NRC requirements
occurred and four violations associated with findings of very low safety significance (Green)
occurred. The NRC evaluated these violations in accordance Section 2.3.2.a of the NRC
Enforcement Policy, which appears on the NRC’s Web site at http://www.nrc.gov/aboutnrc/
regulatory/enforcement/enforce-pol.html.

The enclosed report documents 14 additional findings of very low safety significance (Green).
All of these findings involved violations of NRC requirements; one of these violations was
determined to be Severity Level IV under the traditional enforcement process. Two additional
Severity Level IV violations with no associated finding are also documented in the enclosed
report. The NRC is treating these violations as non-cited violations consistent with
Section 2.3.2.a of the NRC Enforcement Policy.

Four licensee-identified violations are being documented in the enclosed report that were
determined to be of very low safety significance. The NRC is treating these violations as noncited
violations consistent with Section 2.3.2.a of the NRC Enforcement Policy.

Fort Calhoun Nuclear Station on probation; 'Why didn’t the public know?' OPPD board candidate asks

Fort Calhoun Nuclear Station on probation; 'Why didn’t the public know?' OPPD board candidate asks

Posted: Thursday, September 18, 2014 2:00 am

By Cody Winchester / World-Herald staff writerThe Omaha World-Herald

Training and maintenance programs at Fort Calhoun Nuclear Station have been on accreditation probation since March, a candidate for the Omaha Public Power District board revealed Wednesday.

The National Nuclear Accrediting Board imposed the six-month probation in late March, citing “broad gaps” in training at the nuclear plant, which restarted in December after being shut down for nearly three years.

Thank you for reading and relying on Omaha.com for your news and information. You have now viewed your 30 day allowance of 10 free articles.

The accrediting board is an arm of the Institute of Nuclear Power Operations, a trade group that offers technical assistance and training to member utilities.

Candidate Jeff Lux, who is challenging 18-year incumbent Anne McGuire for the District 2 seat in South Omaha, called a press conference Wednesday outside OPPD’s headquarters to criticize the utility for not disclosing the problems.

“Why didn’t the public know about this?” Lux said.

The plant about 15 miles north of Omaha was taken offline in April 2011 for a scheduled refueling. But then flooding, a fire and the discovery of numerous safety violations led the U.S. Nuclear Regulatory Commission to place the plant under special oversight.

In 2012, the district hired an outside firm, Exelon, to run the plant. Fort Calhoun’s regular accreditation review came shortly after restart.

OPPD spokesman Jeff Hanson said the institute simply needed more time to review new processes as the plant transitions to new management.

The accrediting board will discuss lifting the probation when it convenes today in Atlanta. OPPD is optimistic about the outcome, Hanson said.

“All indications are that we will receive positive news,” he said.

If the board votes against re-accreditation, employees at the plant no longer could get any training, he said.

The probation was a “critical issue” at Fort Calhoun that prompted weekly conference calls with accrediting managers, who later visited the plant on inspection visits, according to internal OPPD newsletters provided by Lux.

“Without an accredited program, (Fort Calhoun) can’t properly train and qualify personnel to operate and maintain the station,” assistant plant manager Tim Uehling wrote in a July memo to employees.

Although employees and OPPD board members were kept in the loop, the probation never was made public, Lux said. He called it another example of the district’s record of keeping ratepayers in the dark.

Many issues identified by an internal review of the training problems, including weak management oversight, also were noted in a longer technical report that delved into why the plant was shut down in the first place, Lux said.

The district “shelved” that report, too, said Lux, a felony prosecutor in the Douglas County Attorney’s Office.

McGuire responded that Lux, whom she describes on her campaign website as a “bully” and a “manipulator,” is overstating his case.

She said the board was fully briefed on the probation, which has been discussed at committee meetings. Lux would know that “if he’d ever come to a meeting,” she said.

McGuire said Lux has declined offers by OPPD management for background briefings on issues facing the district.

“He’s not getting the right information,” she said. “He doesn’t want to get the right information.”

As the utility shifts to a new management model at Fort Calhoun, McGuire said, the recovery process won’t be perfect. But OPPD is making a lot more progress than Lux gives it credit for, she said.

“As problems come up, management deals with them,” McGuire said. “Bottom line.”s.

Millstone's Three Special Inspections On A Safety Pump

September 15, 2014

CONTACT: Diane Screnci 610-337-5330

Neil Sheehan 610-337-5331

NRC Launches Special Inspection at Millstone 3 Nuclear Power Plant

In Response to Continuing Problems with Pump

Problems affecting a pump that is part of a reactor safety system will be the focus of a Nuclear Regulatory Commission Special Inspection at the Millstone Unit 3 nuclear power plant. The Waterford, Conn., plant is operated by Dominion Nuclear.

The Special Inspection team will have three members and will begin its work today (Sept. 15). The component of interest is the plant’s turbine-driven auxiliary, or back-up, feedwater pump. That pump is one of several that can be used to help cool down the reactor after a shutdown by pumping water into the secondary side of the plant’s steam generators. The steam generators are essentially large heat exchangers that convert heat generated by the reactor into steam, which in turn is used to spin the turbine and produce electricity.

The basis for this Special Inspection is the failure of the turbine-driven auxiliary feedwater pump to pass quarterly surveillance tests on July 15 and Sept. 10. During both tests, the pump started and then unexpectedly stopped. It then restarted without operator intervention and reached rated speed approximately 15 minutes later. The pump has since undergone repairs and been restored to service.

"A key objective of this inspection will be to learn more about this latest malfunctioning of this safety-related component," NRC Region I Administrator Bill Dean said. "The repetitive problems affecting the pump continue to give the NRC concern."

Areas to be reviewed during the Special Inspection will include the adequacy and completeness of testing on the pump and causal evaluations of the problems. The results of the Special Inspection will be discussed in a report expected to be issued within 45 days after the completion of the review.

The NRC conducted a Special Inspection earlier this year into what appear to be unrelated issues with the same pump. That inspection report was issued Aug. 28.

The NRC's Management Stiff Arm

Basically, it is the issues most of the outsiders have...it is hard to get the higher ups to explain their justifications down on the paperwork. They just stiff arm us.  

But you have to respect the Hell out of the NRC and Mr. Peck for allowing this to become a public disscussion.

These cultural traits are expressed perfectly by Dr Peck.

"As an insider, I’ve found that the industry culture sometimes operates with the assumption that NRC Rules and license requirements impose excessive margins and burdens. In the 1980s, I worked as a reactor engineer (in-core physics) for the Tennessee Valley Authority. The plant culture often viewed NRC design basis requirements as far exceeding those need to preserve safety. “We have systems that back-up systems, that back-up systems, that … ” This industry culture justified encroachment on the facility design basis."

"As I’ve worked thought these issues, I’ve heard agency personnel express over and over again that Diablo Canyon has “plenty of seismic margin.” “Just look at the HE.” These statements imply that no real safety issue exists with the new seismic information. I maintain that Diablo Canyon seismic safety is very complex. It took the DPO Panel almost year just to conclude that the new ground motions were within the bounds of the existing SSE safety analysis. And I’m still not 100 percent convinced that they got it right. While the NRC license review processes may seem cumbersome and stakeholder input can be frustrating at times, use of the established regulatory framework provides us the basis for our presumption of nuclear safety. History has repeatedly taught us that we sometimes get ourselves in trouble when we try working around these processes."

Mr. Peck doesn't address at the bottom of this all is the issue of budget pressures and financial priorities...insufficient resources.

This isn’t about safety…it about money and profits!

Diablo’s Former Inspector Explains

Summary of the Diablo Canyon Differing Professional Opinion

Friday, September 19, 2014

By Michael Peck

The Nuclear Regulatory Commission’s internal processes allow employees to raise issues and make recommendations that differ from the prevailing agency view. Michael Peck, a resident NRC inspector at Diablo Canyon nuclear plant, had a “differing professional opinion” (DPO) after new seismic information was developed. His DPO asserted that PG&E operated the reactors outside the bounds of the facility design basis as defined by its license to operate. Any operation outside of the design basis challenges plant safety due to an erosion of regulatory margins. No immediate or significant safety issues were noted, but Peck points out that operations outside the design basis have contributed to nuclear accidents in the past.

Beginning in 2012, I used the NRC non-concurrence and differing professional opinion (DPO) processes to raise nuclear safety issues affecting the Diablo Canyon Nuclear Facility. These internal processes allow employees to raise issues and make recommendations that differ from the prevailing agency view. These safety issues were related to how the NRC addressed design control, equipment evaluation, and Operating License fidelity after Pacific Gas and Electrical (PG&E) Company developed new seismic information affecting the Diablo Canyon site. The agency carefully considered my recommendations and dispositioned these concerns in September 2014. The NRC subsequently made my views and the agency’s conclusions publicly available in the Agencywide Documents Access and Management System (ADAMS Accession Number ML1425A743).

Diablo Canyon seismology is both highly complex and controversial. However, my DPO was not about seismology. My DPO addressed routine and generally well-understood inspection practices related to agency enforcement of existing design basis requirements at a power reactor facility. These requirements are equally applicable regardless if the issues involved seismic qualification, spent fuel, accident analysis, or any other aspect of the facility design basis. The DPO did not identify any “immediate or significant safety issues.” However, the DPO asserted that PG&E continues to operate the Diablo Canyon reactors outside of the bounds of the facility design basis as defined by the NRC Operating License. Any operation outside of the design basis challenges plant safety due to erosion of regulatory margins.

For example, in 2004 a seismologist identified that the Fukushima sea wall was too low. This was a condition outside of the facility design basis that required protection against the maximum creditable flood and demanded corrective action. But this was not an “immediate or significant safety issue” because the probability of a large tsunami was thought to be small. But as we saw in 2011, the low sea wall height did impact the capability of facility operators to mitigate a flood.

The license application (Final Safety Analysis Report or FSAR) for a nuclear power plant must include safety analyses demonstrating that regulatory design basis are satisfied. The design basis includes requirements that equipment important to safety remain functional following the safe shutdown earthquake (SSE). The NRC defines the SSE as largest credible earthquake that can affect the site.

The Diablo Canyon license application, as amended and approved by the NRC, stated that this design basis SSE was satisfied by the Double Design Earthquake (DDE) safety analysis. NRC Rules required PG&E to maintain the plant capable of meeting this design basis requirement, as specified in the license application (as amended), during reactor operation. The Diablo Canyon license application also discussed a second earthquake analysis, called the Hosgri Evaluation (HE).

Nuclear seismic qualification is not just about how much the ground will shake following an earthquake. Equally important are the methods used to analyze how seismic energy propagates through plant structures; the engineering assumptions and inputs used in the safety analysis; and the application of load combinations and acceptance limits. The larger HE earthquake (0.75 g peak ground acceleration) predicted less mechanical stress on plant equipment, including reactor components, than the smaller SSE/DDE (0.4 g). While this may sound counterintuitive, this result reflected the different analytical methods and assumptions used in the two analyses. The PG&E license application (as approved) explicitly stated that SSE design basis requirement was satisfied by the DDE. The application discussed the HE as a response to NRC questions raised during the original licensing process. The application also specifically stated that the HE did not meet NRC requirements for the SSE. In other words, the facility Operating License established the DDE/SSE as the maximum ground motion for the site, implementing NRC design basis Rules for protection against earthquakes. The HE demonstrated that PG&E could safety shutdown the plant (assuming no accident or fire) if a 7.5 magnitude earthquake occurred on the Hosgri fault. The reasons for excluding the larger HE ground motions from the SSE safety analysis are complex and reflect negotiated agreements made between the NRC and PG&E prior to original plant licensing.

In early 2011, PG&E placed a reevaluation of the local seismology on the NRC docket. This report concluded that three earthquake faults were capable of producing greater ground motion than SSE/DDE but less than the HE. NRC regulations required PG&E to evaluate this new information against the existing facility design basis and update any deficient FSAR safety analysis. PG&E could have updated the SSE safety analysis with the new ground motions. However, this approach would have required an amendment to the Operating License because the resulting stress would have exceeded established safety limits for equipment important to safety, including the reactor pressure boundary. The NRC typically doesn’t approve safety analysis changes that conclude safety limits have been exceeded.

As an alternative, PG&E chose to change the SSE safety analysis methodology from the DDE to the HE. At the time, this seemed to be a reasonable approach since the new ground motions were bound by the HE spectrum. PG&E was required to obtain NRC approval before incorporating this change. NRC Rules require an amendment to the Operating License if less conservative analytical methods are used to demonstrate that a design basis requirement is satisfied. In October 2011, PG&E submitted License Amendment Request 11-05 requesting NRC approval for this change. NRC Rules allowed continued reactor operation while the agency reviews the amendment request provided that PG&E demonstrates a “reasonable assurance” that equipment important to safety remains “operable.” In other words, PG&E would have to show by evaluation that accident mitigation equipment would still work and reactor piping would hold together (meet acceptance limits of the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code) given the higher seismic inputs.

As a resident inspector, my job was to compare the Diablo Canyon facility and PG&E activities against the facility Operating License, NRC regulations, and industry guidance. When inspections identify gaps in the implementation of these requirements, then I was expected to draft violations consistent with the NRC Enforcement Policy. I was specifically tasked with reviewing between 19 and 25 PG&E operability evaluations each year.

In the summer of 2011, PG&E concluded that all safety equipment was “operable” given the higher ground motions. This evaluation relied on the HE as an alternate methodology. NRC operability policy allows use of “alternate analytical methods” provided certain conditions are met. For example, the alternate method cannot produce a result that “over-predicts” equipment performance when compared to the design bases method.

My inspection concluded that the PG&E evaluation failed to meet NRC operability standards. For a given ground motion, the HE method will always produce a less conservative result when compared to the SSE/DDE method. Gaining margin over the SSE/DDE was the sole reason PG&E used the HE as an alternate method. I also knew that very little margin to the Code limits existed from my experience with the replacement reactor head and steam generator inspections. Almost any increase in seismic loading would result in exceeding the Code acceptance limits, roughly 2/3 of the critical buckling strength for the material.

I included an inadequate operability evaluation violation with my 2011 third and fourth quarter Intergraded Inspection Reports. In both cases, NRC Region IV management removed the violation prior to issuing the report. The proposed violation addressed the decrease in nuclear safety because PG&E had encroached on design basis margins and safety limits.

NRC violations associated with inadequate operability evaluations are common. Typically, these violations address technical deficiencies in the analytical or regulatory approach used by the licensee. Corrective actions usually involve adding technical rigor or additional justification to the evaluation. However, for the seismic operability case, it was unlikely that PG&E would have been successful. The magnitude of the new ground motions combined with the lack of available margin in the existing SSE safety analysis would have made it all but impossible to conclude that plant equipment was operable. If this equipment was determined to be inoperable, then the Operating License required PG&E to immediately shut down both reactors.

A License mandated shutdown is not all that unusual. The NRC has and routinely uses statutory authority to grant regulatory dispensation in these types of cases. PG&E could have used the HE to support a safety argument justifying continued operation pending NRC approval of the license amendment. This path would have required the NRC to formally waive Diablo Canyon seismic design basis requirements and approve relief from the Code. This path would have also reversed the previously well-publicized agency position that PG&E had been operating within the bounds of the facility design basis.

To ensure NRC management fully understood the underlying technical and regulatory aspects of the proposed violation, I non-concurred on my own inspection report. To my surprise, the agency response stated that insufficient information was available to complete an operability evaluation. To the best of my knowledge, this position was completely unprecedented and contrary to written NRC policy. In my 30-plus years’ performing and inspecting operability evaluations, I had never once come across this view. The failure to clearly demonstrate operability has always resulted in a declaration of “inoperability,” requiring immediate application of the Technical Specification remedial actions. The agency’s response went on to state that NRC approval of the PG&E license amendment request was needed before operability could be fully assessed.

Apparently, I had misapplied NRC operability criteria during the inspection. However, the nonconcurrence response did not provide sufficient information for me to understand why or how I had missed the mark. The NRC response also appeared to establish new agency policy and precedent.

In 2012, NRC technical reviewers concluded that HE methodology was not suitable for the Diablo Canyon SSE design basis. In October 2012, PG&E withdrew the license amendment request at the NRC’s request. The NRC Diablo Canyon Project Manager subsequently requested PG&E to directly add the results of the Shoreline fault analysis to the facility FSAR, appearing to work around the failed license amendment process.

This action limited stakeholder input by bypassing statutory requirements for notice and hearing opportunity associated with a facility design basis change. NRC rejection of the license amendment also appeared to have voided the agency’s stated bases for the non-concurrence decision on operability.

I submitted the DPO in July 2013. My goal was to include sufficient technical detail and regulatory analysis to support a third-party review of the issues. I addressed the unresolved operability issue from 2011 and added the lack of appropriate corrective actions to restore the FSAR safety analysis to the facility design basis and regulatory requirements.

During the DPO deliberations, I did my best to reach a consensus on the technical and regulatory issues with the Panel. I offered to withdraw the DPO if the Panel could provide a technical resolution consistent with both agency Rules and the facility License. I also requested that the Panel obtain a legal opinion from the NRC Office of General Council since the DPO involved application of specific legal requirements established by the facility Operating License. My understanding was that the Panel did not accept either recommendation.

In May 2014, the Panel concluded that PG&E had satisfied all regulatory requirements. Apparently, I had misapplied the Diablo Canyon License requirements. The Panel’s conclusion was built on the assumption that the HE was a facility SSE. Because the HE was an SSE, then neither a license amendment nor an operability evaluation was required. To the best of my knowledge, this was the first time the agency had concluded that the HE was the Diablo Canyon SSE. Unfortunately, the Panel Report offered no explanation or the basis for this assumption. I found this partially frustrating since I went to great lengths in the DPO to provide a detailed description of the facility seismic licensing basis. I thought that if I had gotten it wrong, then the Panel should be able to point out were I made my error.

The assumption that the HE was a facility SSE appeared to be in direct conflict with the facility license application (FSAR). I followed up with the Panel Chairman to better understand the basis for their assumption and my error. He directed me to an FASR Section. Interestingly, this section was included in the September 2013 revision following the NRC Project Manager’s direction to add the Shoreline fault to the FSAR. NRC Rules state that FSAR changes that potentially affect how the facility design basis are met, are required to be screened to determine if a license amendment is required. These changes were flagged by PG&E as exempt from this screening requirement based on “correspondence from the NRC.” From my view, the Panel appeared to use circular logic as basis for their underlying assumption and then used this assumption to support their conclusion.

In June 2014, I submitted an appeal to the DPO decision. My appeal stated that the DPO conclusion appeared to be built on a misunderstanding of the Diablo Canyon license requirements and agency Rules. Also, the Panel appeared not to have fully addressed the statutory requirements associated with adding the new seismic information to the FSAR (10 CFR 50.59) and meeting ASME Code for the facility SSE (10 CFR 50.55a). Specifically, the Panel appeared not have compared the new seismic inputs against the FSAR safety analysis as explicitly required by agency Rules.

I included the actual original (license application, as approved) and current FSAR pages describing the seismic design and licensing basis in the Appeal. I included these pages to avoid any misunderstanding of the facility License requirements. I included the specific language of applicable agency Rules and approved guidance to avoid unsupported assumptions. I also added specific examples detailing past NRC enforcement action taken on similar issues at other facilities and formal agency guidance addressing expected actions following discovery of conditions outside of the seismic design basis.

In response to my Appeal, the agency again told me my conclusions were incorrect. Apparently, my regulatory analysis had inappropriately excluded the HE from the facility licensing basis. Again the agency response did not include sufficient detail to help me understand where I had made my error or which part of the license application I misinterpreted.

I have exhausted the NRC processes for raising nuclear safety concerns. At every turn, the agency reinforced that its original conclusions and actions had been correct. From my perspective, I applied the same NRC inspection standards and agency Rules to the Diablo Canyon seismic issues that I’ve used to disposition many other design bases issues during my twenty years as an inspector. Since the DPO was reviewed by the highest levels of agency management, I was left with the impression that the NRC may have applied a different standard to Diablo Canyon.

I’ve also encountered this culture as an inspector. For example, the NRC issued eight violations over five years associated with facility changes PG&E made without first obtaining the required NRC approval in the form of an amendment to the Operating License.

By studying major nuclear accidents, Three Mile Island, Chernobyl, and Fukushima, l found that these events were largely preventable. Encroachment of operating standards and the design basis contributed to each event. In some cases decision makers didn’t fully appreciate the complexity or consequence of the safety barriers they encroached upon. For example, an engineer directed reactor power be maneuvered outside of design basis limits at Chernobyl to support testing. The engineer didn’t realize that his actions had placed the reactor in an unstable region, leading to an uncontrolled power excursion. The results of his actions are now part of the nuclear legacy.

As I’ve worked thought these issues, I’ve heard agency personnel express over and over again that Diablo Canyon has “plenty of seismic margin.” “Just look at the HE.” These statements imply that no real safety issue exists with the new seismic information. I maintain that Diablo Canyon seismic safety is very complex. It took the DPO Panel almost year just to conclude that the new ground motions were within the bounds of the existing SSE safety analysis. And I’m still not 100 percent convinced that they got it right. While the NRC license review processes may seem cumbersome and stakeholder input can be frustrating at times, use of the established regulatory framework provides us the basis for our presumption of nuclear safety. History has repeatedly taught us that we sometimes get ourselves in trouble when we try working around these processes.

Michael Peck, PhD, is the former NRC senior resident inspector at Diablo Canyon Power Plant.

Fort Calhoun and Cooper Identical Twins Training Failures

Just so you get it:

1)      The Cooper plant just recently got a terrible NRC report about their training.

2)      Effectively a politician on a Nebraska state Power board improperly disclosed  that INPO had put Fort Calhoun training on probation as a campaign tactic.

3)      These guys are less than a hundred miles apart.

Nebraska Public Power District (NPPD, Cooper) and Omaha Public Power District,( OPPD, Fort Calhoun)

Are we really watching a plant death spiral?

It questions if these Fort Calhoun should have ever been operating. I seen it back in Jan 2014.

Did I call it right from Jan? 

There are more pre 2011 Fort Calhouns out there right now!

June 2014: Fort Calhoun going nuts on Us.

 Normally a plant gets 3 or 4 LERs per year, maybe less….

2014: 12

2013: 35

Once you get onto the north side of 2005 till today, it is amazing the escalation of the numbers of LERs. I wonder what has changed?

2005:3

2004:3

2003:5

April 2014: The Ongoing 2011 Accident at Fort Calhoun Nuclear Plant

 See, crap quality assurance and crap maintenance. This came out on the same date of the new scram.
Junk! Another plant scram! They fixed the stuff relevant to NRC rules...but neglected components support reliable plant operation
Three years and 200 million dollars...16 days of operation...and they already had two shutdowns.

Were the new sluice gates cheaply purchase at Walmart...

Would that be great, putting on this kind of debt for 10 years...then have to shutdown within a year.

Goes to show you, if the majority of the plant is obsolete and degraded gear...throwing 200 million is a waste of money! They just didn't go in big enough.

Jan 2014: The Ongoing 2011 Accident at Fort Calhoun Nuclear Plant

 Has INPO also put Cooper training program on probation?

SUBJECT: COOPER NUCLEAR STATION - NRC EXAMINATION REPORT 5000298/2014301 

"The examination included the evaluation of five applicants for reactor operator licenses, one applicant for instant senior reactor operator license, and three applicants for upgrade senior reactor operator licenses. The license examiners determined that two of the applicants satisfied the requirements of 10 CFR Part 55 and the appropriate licenses have been issued."

No findings were identified during this examination.

Can you imagine they would tolerate this post Fukushima?

"The licensee already has areas for improvement that include improved critical task development and scenario performance weaknesses on critical tasks, with Condition Report CR-CNS-2014-04683 written to address these issues."

Can you imagine how horrified the operators would be with their plant in this condition? I always thought the procedures and the component used should be at a much higher quality than if a plant was running in a normal state. A plant at normal operation is fault tolerant and has multiple back up systems…while a plant like this is mostly naked and has most of the safety systems stripped away from them. One operator error can screw the whole region. The industry thinks these procedure and component can be of a lesser quality because the chance of being here is slim to none...I think the quality needs to be at a much higher quality because the consequences of a error is so much higher.

You know, they could have caught Cooper on this five years ago? Why did they catch them on this at this inspection?

I am giving you an example where in the USA training might not be up to the quality advertised to prevent a serious accident or mitigate a bad accident.

Or because credibility issues, we do not the know the true condition of all the plants.

COOPER NUCLEAR STATION – NRC INTEGRATED INSPECTION REPORT05000298/2014003

You gotta know it is ten times more worse than the NRC reports it and employees admit it. Think about it, seven out of nine employees failed initial licensing testing.

Did they shorten initial licensing training…almost an instant license...in order to mitigate the crisis with not enough qualitied licenses at Cooper? Is this why the NRC made an example out of Cooper because initial licensing “lite” training?

How could they get this far behind the license eight ball?

Aug 12:

“Interviewees indicated that a lack of Senior Reactor Operators (SROs) has placed the station in a staffing crunch that could ultimately affect shift staffing options. Operators are concerned that if the number of operating crews is reduced, quality of life effects could add stress to the operators. Management is aware of these concerns. There are currently two initial license classes in progress to address this issue.

The inspection team concludes that staffing at Cooper Nuclear Station is adequate. Station management is taking steps to address potential future short comings, i.e. training more senior reactor operators, and planning a four crew rotation contingency. However, the inspection team recommends that increased monitoring of operation.”

Isn’t it interesting, two completely different corporate nuclear managers, (Entergy, Exelon) Cooper and Fort Calhoun having profound troubles with training…

90 miles from each other and lost deep in the Midwest.

Unbelievable current access to how INPO works…

“Fort Calhoun Nuclear Station on probation; 'Why didn’t the public know?' OPPD boardcandidate asks”

By Cody Winchester / World-Herald staff writer The Omaha World-Herald

Training and maintenance programs at Fort Calhoun Nuclear Station have been on accreditation probation since March, a candidate for the Omaha Public Power District board revealed Wednesday.

The National Nuclear Accrediting Board imposed the six-month probation in late March, citing “broad gaps” in training at the nuclear plant, which restarted in December after being shut down for nearly three years.

The accrediting board is an arm of the Institute of Nuclear Power Operations, a trade group that offers technical assistance and training to member utilities.

Candidate Jeff Lux, who is challenging 16-year incumbent Anne McGuire for the District 2 seat in South Omaha, called a press conference Wednesday outside OPPD’s headquarters to criticize the utility for not disclosing the problems.

“Why didn’t the public know about this?” Lux said.

Fort Calhoun Station sits on the banks of the Missouri River about 15 miles north of Omaha. The plant was taken offline in April 2011 for a scheduled refueling, but then flooding, a fire and the discovery of numerous safety violations led the U.S. Nuclear Regulatory Commission to place the plant under special oversight.

The trade group certifies training programs at nuclear plants every four years; Fort Calhoun’s accreditation review came shortly after restart.

OPPD spokesman Jeff Hanson said the nuclear power institute needed more time to review new processes as the plant transitions to new management. In 2012, the district hired an outside firm, Exelon, to run the plant.

The accrediting board will discuss lifting the probation when it convenes Thursday in Atlanta. OPPD is optimistic, Hanson said.

“All indications are that we will receive positive news,” he said.

If the board votes against reaccreditation, employees at the plant no longer would be allowed to get training.

The probation was a “critical issue” at Fort Calhoun that prompted weekly conference calls with accrediting managers, who later visited the plant on several inspection visits, according to internal OPPD newsletters.

“Without an accredited program, (Fort Calhoun) can’t properly train and qualify personnel to operate and maintain the station,” assistant plant manager Tim Uehling wrote in a July memo to employees.

Although the OPPD board was kept in the loop, the probation never was made public — another example of the district keeping ratepayers in the dark, Lux said.

The news comes after OPPD went to court, unsuccessfully, to fight the disclosure of seven employee severance agreements worth nearly $950,000.

Many of the issues identified in an analysis of training problems, including weak oversight by management, also were identified in a longer technical report that delved into why the plant was shut down in the first place, Lux said. The district “shelved” that report, too, said Lux, a felony prosecutor in the Douglas County Attorney’s Office.

“Two years later — this came out in 2012 — we’re still seeing the same problems,” he said.

Jan 28: The Terribly Uncertainty In The TDAFW Pump NOED At Millstone

(What they really knew but didn't tell and what they assumed they knew in the NOED)

The NRC and Millstone sets this document in utter certainty that they have a god's eye view...they perfectly have all the information associated with risk and the conditions (information) with the TDAFW pumps.

NOTICE OF ENFORCEMENT DISCRETION FOR DOMINION NUCLEAR CONNECTICUT,INC. REGARDING MILLSTONE POWER STATION UNIT 3

[TAC NO. MF3393, NOED NO. 14-1-01]

Dear Mr. Heacock:

By letter dated January 28, 2014, Dominion Nuclear Connecticut (DNC), Inc. requested that the U.S. Nuclear Regulatory Commission (NRC) exercise discretion to not enforce compliance with the actions required in Millstone Power Station (MPS) Unit 3 Technical Specification (TS) 3.7.1.2,“Auxiliary Feedwater (AFW) System,” Action C, to restore the Turbine Driven Auxiliary Feedwater (TDAFW) pump to operable status within 72 hours. This letter documented information

On January 23, 2014, at 1:50 p.m., during a planned surveillance test, the MPS Unit 3 TDAFW pump tripped on an over speed condition and was declared inoperable by plant operators. After review of the troubleshooting data, the most probable cause was identified by station personnel that insufficient force was being transferred via the linkage to the turbine steam supply control valve.

You stated that at 1:50 p.m. on January 23, 2014, MPS Unit 3 operators entered TS 3.7.1.2, Action C. Further, TS 3.7.1.2 requires that if 3.7.1.2, Action C, cannot be met within 72 hours, operators at Unit 3 are required to shutdown the reactor and place the unit in at least hot standby within 6 hours and in hot shutdown within the following 12 hours. You sought enforcement discretion to allow for continued operation in violation of TS 3.7.1.2 in order to permit additional time for station personnel to make repairs, perform testing activities, and restore the TDAFW pump to operable status. An additional 72 hours (NOED completion time) was requested beyond the TS completion time allowance to restore the TDAFW pump to an operable condition, such that the need for enforcement discretion would no longer be required at 1:50 p.m. on January 29, 2014. This letter documents the telephone conversation between DNC and NRC staff on January 26, 2014, which concluded at approximately 1:00 p.m., when the NRC staff verbally granted a NOED for 36 hours. Your written request reflected this 36 hour authorization. Subsequent to that call, station personnel restored the TDAFW pump to operable status, allowing operators at Unit 3 to exit TS 3.7.1.2, Action C, and terminate the NOED at 5:05a.m on January 27, 2014.

During the teleconference on January 26, 2014, and further elaborated in your January 28, 2014 letter, your staff indicated that from a risk perspective, it was unnecessary to place MPS Unit 3 into a plant shutdown in that MPS Unit 3 was operating in a stable configuration with offsite power and both MPS Unit 3 Emergency Diesel Generators available, along with the Station Blackout (SBO) Diesel Generator. Based on actual plant conditions on January 26, 2014, quantitatively your staff estimated the Incremental Conditional Core Damage Probability (ICCDP) to be approximately 2.97E-08, and the Incremental Conditional Large Early Release Probability (ICLERP) to be approximately 1.88E-09. Additionally, it was noted that the estimated ICCDP and ICLERP values did not take into account various additional conservatisms associated with compensatory actions which had been put in place. The results of your staff’s quantification were independently corroborated by NRC analysts and were determined to meet the guidance thresholds as articulated in Inspection Manual Chapter (IMC) 0410, “Notices of Enforcement Discretion,” (ADAMS Reference Number ML13071A487).

Your staff implemented compensatory risk management measures prior to entering the period of the enforcement discretion, which were to remain in effect throughout the proposed period of discretion and were independently verified by NRC inspectors. The compensatory measures included staging an operator continuously at the station blackout diesel generator, performing no planned switchyard maintenance, protecting the motor-driven auxiliary feedwater trains and condensate and main feedwater systems, and implementing fire risk management actions. The compensatory actions were intended to increase operator awareness of plant conditions, to reduce the likelihood of losing redundant trains, and to reduce the likelihood and consequences of initiating events. Your staff also stated that no severe weather was forecast, which could challenge offsite power availability during the proposed period of enforcement discretion, grid conditions were normal, and no maintenance would be performed on safety-related equipment.

Your staff stated that the proposed change did not involve a significant hazard based on the three standards set forth in 10 CFR 50.92(c), and did not involve adverse consequences to the environment such that the proposed change meets the categorical exclusion set forth in 10 CFR 51.22(c)(9). The MPS Facility Safety Review Committee reviewed and concurred with the NOED request. Because the request was a one-time extension of the required completion times for repairs, your staff stated that a follow-up license amendment request was not required.

Based on the NRC staff’s evaluation of your request, the NRC has concluded that granting this NOED is consistent with the NRC’s Enforcement Policy and staff guidance. In addition, it meets Section 3.0.3 (b) of IMC 410 in that compliance with the TS would result in an unnecessary down-power or a shutdown of the reactor without a corresponding health and safety benefit.

Therefore, as communicated to your staff at 12:44 p.m. on January 26, 2014, the NRC exercised discretion to not enforce compliance with TS 3.7.1.2, Action C, for an additional period of 36 hours, which expired at 1:50 a.m. January 28, 2014. In addition, as discussed on January 26, 2014, the NRC staff agreed with your determination that a follow-up TS amendment is not needed. The staff concluded that an amendment (either a temporary or permanent amendment) is not necessary because this NOED involves a nonrecurring noncompliance and only involves a single request to not enforce compliance for36 hours with TS 3.7.1.2, Action C, to restore the TDAFW pump to an operable status within 72 hours.

As stated in the Enforcement Policy, action will be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.

There are more pre 2011 Fort Calhouns out there right now!

Originally published this on July 15, 2014

July 15: Where did I hear intrusiveness…that was in the Palisades red yellow finding?

Reoccurring themes:  lack of Executive intrusiveness and just meeting the minimum regulatory requirements.

Bill,

Fort Calhoun Corrective Action Program Root Cause Analysis Report.  

Organizational Ineffectiveness at Fort Calhoun.

There is a Root Cause Analysis for you?

Do you trust the NRC to tell us really what going on in a nuclear plant and make a plant correct themselves before they cause great economic harm to the parent company and ruin the reputation of the nuclear industry? What role does the NRC play in protecting the ratepayers and businesses? Can you imagine this was going on and they did not or could not report on it pre 2011? Would we be a better nation if we got these employees to talk about their problem before the Great Missouri River flood and their large electric breaker problems leading to a prolonged shutdown and the NRC red finding? Would we be a better nation if the NRC gave the red finding way before the July 11, 2011 breaker fire leading to the red finding and prolonged shutdown?

What if the Great Flood happened and there was no NRC flood findings or poorly operating new large breaker issues...what if the plant came out of the 2011 event with widespread NRC and community respect??? Could they have been our heroes?

Can you even imagine not one employee in the know didn't step out of the shaddows informing the public things are really bad at my plant and we have to change pre 2011. All nuclear plant employees are cowards and they are only out for the money!!!

Should have done a scathing RCA outside report on the regulatory ineffectiveness here?  

What if god didn’t throw the great Missouri River flood at us and the breaker fire…what would have been the end point of the Fort Calhoun decline? What is larger than a red finding?

What if the NRC oversight of our nuclear plants now tolerates twenty Fort Calhoun pre July 11, 2011 plant culture failures, remember the ROP had no inclination to put a floor on the dysfunction (it could have gotten much worst). What would have been the worst accident coming out of these twenty plants if the NRC kept uninvolved ? What would the size be of our national embarrassment be? 

Sept 16, 2014

Here is my example...I wrote this on July 15, 2014

ARKANSAS NUCLEAR ONE- NRCINSPECTION REPORT - PRELIMINARY YELLOW FINDING - September 09, 2014

By Bob Meyer

This report is a shot over the bow of the nuclear industry for each plant to review flood walkdowns and review plant specific flood analysis. Based on my experience, some of the conditions that resulted in NRC violations exist at other plants. The NRC concuded that all long-term core makeup and cooling could have failed during an external flood.

Read this very important, detailed NRC inspection report and compare it to the conditions at your plant. Here is the redacted report.

Apparent Violation. The inspectors identified a finding of preliminary substantial safety significance (Yellow) for the failure to design, construct, and maintain the Units 1 and 2 auxiliary and emergency diesel fuel storage buildings in accordance with the safety analysis reports' description of internal and external flood barriers so that they could protect safety-related equipment from flooding. Two apparent violations were associated with this finding:

In other words, it would have to be worst than a red finding…at what level will the NRC finally put a floor on bad behavior and dysfunctions.

How many mad man and unseen pre July 11, 2011 Fort Calhouns do we have out there right now! 

Organizational ineffectiveness at Fort Calhoun Station

Condition Report: 2012-03986
A. EXECUTIVE SUMMARY:
Event Date: May 11, 2012
Executive Sponsor: W. Gary Gates
Summary of Events:

Fort Calhoun Station has a history of organizational effectiveness weaknesses as indicated by The Nuclear Regulatory Commission has identified organizational effectiveness issues in Problem identification and Resolution (PI&R) inspections conducted in 2007, 2009 and 2011. A PI&R Root Cause Analysis (CR2011~10135) identified that flawed mental models, misguided beliefs, and misplaced values have driven, influenced and permitted the misalignment of organizational behaviors. The station has shown an adverse regulatory trend of violations beginning in 2007, entering action matrix column 3 (95003) in October 2010, then action matrix column 4 in July 2011, to eventually Inspection Manual Chapter 0350 in December 2011.

 A root cause analysis team was formed to evaluate the causes of this organizational ineffectiveness. The team conducted a root cause analysis on organizational effectiveness related events that occurred from 2007 through May 2012. The team also reviewed the! I Sand Strategic Talent Solutions (STS) Executive Leadership Assessment summary to validate their findings.

Condition Report 2012-03986 was initiated when a team of station management personnel and external consultants determined that the Fort Calhoun Station‘s organizational effectiveness is inadequate. The team characterized the issue as follows: "Senior leaders and managers are not providing the necessary leadership to improve organizational performance. Additionally, leadership has failed to be intrusive, set the right priorities, and holds personnel accountable and has not understood major processes or issues affecting morale. As a result, timeliness and thoroughness of resolution of important issues has been lacking and station performance has declined significantly.”

The RCA team subsequently developed a problem statement that, “The Fort Calhoun Station (FCS) organization has been ineffective in meeting regulatory and industry standards, resulting in untimely and ineffective resolution of issues contributing to a significant decline in station performance."

This organizational effectiveness weakness has had a direct negative impact on nuclear, radiological, and industrial safety and other business aspects. Examples include organizational effectiveness issues identified in the Yellow external finding, the FAQ contactor failure White NRC identified finding, and the 184A Bus fire NRC Red finding. industries! safety has been identified by ######### as lacking sufficient organizational oversight and ####### that station oversight did not perform adequate organizational challenging of radiological planning for outages.

The analysis identified that there has been inadequate direction, prioritization and oversight from the "board of directors” down to the station leaders. The team identified three root causes and three contributing causes. Less than adequate corporate and station governance and oversight; leaders functioning more in a tactical rather than strategic manner and not valuing accountability; and lack of thorough policy implementation as root causes. Three policies were determined to be contributing causes base on the fact that both the policy was weak and needed improving, as well as proper implementation. Those three policies included the stations Nuclear Safety policy, Change Management policy, and Communications policy. All three of these policies were identified in the #####.

The extent of condition was based on the problem statement, interviews conducted, documents reviewed and the analytical tools used to assess FCS performance in the area of Organizational Effectiveness. An extent of condition exists: The team concluded the organizational effectiveness deficiencies reviewed by this causal analysis extend to those programs, processes, and departments throughout the organization.