Oyster Creek: Old Design Issues in the Assessment Process.

OC's Electromatic Relief Valve yellow finding don't meet a old design issue get out of jail free card? 

Ho K. Nieh, DirectorDivision of Reactor Projects

ERV yellow finding: The violation was also preliminary determined to meet the IMC 0305, Section 11.05, criteria for treatment as an old design issue.

Now I got the right version...

NRC INSPECTION MANUAL IPAB INSPECTION MANUAL CHAPTER 0305 OPERATING REACTOR ASSESSMENT PROGRAM 

11.05. Treatment of Items Associated with Enforcement Discretion.  

A finding that includes a violation that meets the criteria discussed below will be processed as specified in this section. The intent of this section is to establish ROP guidance that supports the objective of enforcement discretion, which is to encourage licensee initiatives to identify and resolve problems, especially those subtle issues that are not likely to be identified by routine efforts. 

The purpose of this approach is to place a premium on licensees initiating efforts to identify and correct safety-significant issues, which are not likely to be identified by routine efforts, before degraded safety systems are called upon to work. The assessment program evaluates present performance issues, and this approach excludes old design issues from consideration of overall licensee performance in the Action Matrix. The DRP or DRS

I am not sure what "excludes old design issues from consideration of overall licensee performance in the Action Matrix" means.

division director will authorize the treatment of findings as old design issues after conferring with the Deputy Director, NRR/DIRS. This is not an Action Matrix deviation. 

A finding that includes a violation subject to enforcement discretion must be dispositioned under one of the following categories:

a. Treatment of Old Design Issues in the Assessment Process. A finding associated with engineering calculations or analysis, associated operating procedure, or installation of plant equipment is considered an Old Design Issue if it meets all of the following criteria: 

1. It was licensee-identified as a result of a voluntary initiative, such as a design basis reconstitution. For the purposes of this IMC, self-revealing findings, which are defined in IMC 0612, are not considered to be licensee-identified.

2. It was or will be corrected, including immediate corrective actions and long-term comprehensive corrective actions to prevent recurrence, within a reasonable time following identification (this action should involve expanding the initiative, as necessary, to identify other failures caused by similar root causes). For the purpose of this criterion, identification is defined as the time when the significance of the finding is first discussed between the NRC and the licensee. Accordingly, issues being cited by the NRC for inadequate or untimely corrective action are not eligible for treatment as old design issues.

3. It was not likely to be previously identified by recent ongoing licensee efforts, such as normal surveillance, quality assurance activities, or evaluation of industry information.

4. It does not reflect a current performance deficiency associated with existing licensee programs, policy, or procedure.

If all the old design issue criteria are met, then the finding would not aggregate in the Action Matrix with other PIs and inspection findings.

If the old design issue criteria are not met, then the finding would be treated similar to any other inspection finding and additional NRC actions would be taken in accordance with the Action Matrix.

Overall Inspection Approach

The finding considered for treatment as an old design issue shall be brought to a SERP and a Regulatory Conference, if applicable. The finding shall be discussed in the appropriate inspection report cover letter and displayed on the NRC’s web site with its actual safety significance after the final safety significance is determined. Issue Date: 11/20/14 38 0305

If enough information is known to determine that the finding meets the old design issue criteria, then the licensee shall be notified in the inspection report cover letter that the finding was determined to be an old design issue. The regional office shall perform an IP 95001 supplemental inspection for a white finding or an IP 95002 supplemental inspection for a yellow or red finding to review the licensee’s root cause evaluation and corrective action plan for that particular issue. Because Old Design Issues often predate current licensee policies and practices, performing a review of the licensee’s safety culture as part of an IP 95002 inspection may not be necessary. If the region determines that a safety culture review is not required as part of an IP 95002 inspection for an Old Design Issue, the region should document that the review was not performed and include justification in the inspection report.

Example 11.05-1: The NRC concluded that a white finding in the Mitigating Systems Cornerstone meets the criteria for an old design issue for a plant. The plant also has a white PI in the Mitigating Systems Cornerstone. This plant would be placed in Column 2 of the Action Matrix because of the white PI, and NRC actions would be taken in accordance with that column, including an IP 95001 supplemental inspection for the white PI. The old design issue does not aggregate with other inputs in determining the Action Matrix column or required NRC response. Therefore, the white old design issue would be considered independently, and an IP 95001 supplemental inspection for that issue would be conducted.

If additional information is needed to determine whether the finding meets the old design issue criteria, the inspection report cover letter should state that the finding is being considered for treatment as an old design issue. The regional offices should then perform an IP 95001 supplemental inspection for a white finding or an IP 95002 supplemental inspection for a yellow or red finding to review the licensee’s root cause evaluation of that particular issue and to gather the additional information required to determine whether the finding meets the old design issue criteria.  

Example 11.05-2: The regional office does not have enough information to determine if a red finding meets the criteria for an old design issue. The regional office would perform an IP 95002 inspection to review the root cause evaluation and gather additional information on whether the finding meets the criteria for an old design issue. As a result of the inspection, if the regional office determines that the criteria have not been met, the regional office would perform the additional inspection activities to complete supplemental inspection requirements for an IP 95003 inspection

Brunswick Nuclear Plant: Are They Just "Running to Failure" These Components

Junk Nordberg Diesel Generators: 

HPCI DECLARED INOPERABLE DURING WEEKLY INSPECTION

"EVENT DESCRIPTION: On February 12, 2015, at 1336 Eastern Standard Time (EST) the Unit 1 High Pressure Coolant Injection (HPCI) system was declared inoperable due to a failure of the HPCI Auxiliary Oil Pump. During performance of a routine HPCI weekly inspection, the auxiliary oil pump was started and subsequently experienced a loss of discharge oil pressure. The HPCI Auxiliary Oil Pump provides hydraulic pressure required to open the HPCI Turbine Stop Valve and the HPCI Turbine Control Valve during initial HPCI startup. Failure of the HPCI Auxiliary Oil Pump prevents the HPCI system from performing its design safety function. As such, this event is being reported in accordance with 10 CFR 50.72(b)(3)(v)(D) as a condition that at the time of discovery could have prevented the fulfillment of the safety function of a system that is needed to mitigate the consequences of an accident.

"This event did not result in any adverse impact to the health and safety of the public.

"INITIAL SAFETY SIGNIFICANCE EVALUATION: The safety significance of this condition is minimal. All other Emergency Core Cooling Systems and the Reactor Core Isolation Cooling (RCIC) system remain operable [per the requirements of 14-day LCO (Limiting Condition of Operation) 3.5.1].

"CORRECTIVE ACTIONS: Troubleshooting activities are in progress. The HPCI system will remain inoperable until the cause of the failure has been corrected. 

The NRC's GDC 17 Pilgrim Plant Proviso?

My commentary? 

I don't think the ops went into Juno with an idea to shutdown. I think upper management said we will tell you when to shutdown! 

From then on, ops was ticked off at management, let just say, ops didn't heavily participate in helping management in the beginning to shutdown the plant. 

The NRC was in the control room! 

Like to know the panel alarms walking toward Juno...they must have a cheat sheet with indications based on past LOOPs in winter storms. 

Again, it looks like poles failed outside the plant, as the NRC says, "the licensee has no control outside their property". Hmm, what was all that work with separating the four lines in the Millstone. Something about one line not falling over and knocking down another?

This NRC tack cheats the community with understanding what is going on outside the property leading to many LOOPs. So a giant precursor to a station blackout generated offsite is beyond the preview of the NRC...it sounds too bureaucratic to me. I am disappointed the new inspection report don't carry an explanation of this. Was it part of a NRC cover-up?     

I think Pilgrim has the responsibility to understand the big picture with the lines surrounding their plant. Entergy could have called in big wig transmission system engineers to access the condition of the lines…say out to 5 miles. The NRC could have asked Entergy to preform this and put the information on the docket. As Entergy said yesterday, the grid wasn't reliably capable of transmitting Pilgrim power. 

The two lines go out many miles through one small right of way, by the way, the smaller line follow alongside the 345 lines for many miles. 

It looks like to me maybe from two or three miles from the plant, the two line right of way corridor goes out...it is the wooden poles they are talking about? Once getting to the first substation or switch-yard two miles...from then on its modern new poles and lines. 

This plant has an astounding lack of power line diversity and it isn't in accordance to GDC 17. 

Is Pilgrim having troubles getting a permit for the line upgrade? Can you even imagine the cost of separating the lines. Sounds like they are boxed in. 

Appendix A to Part 50—General Design Criteria for Nuclear Power Plants

Criterion 17—Electric power systems. An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents. 

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure. 

Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on

The Pilgrim Plant proviso and dangerous!!!! This is where the NRC rules are dangerous. 

separate rights of way) designed and located so as to minimize to the extent practical the likelihood of their

What does this mean and specifically how do they control the simultaneous failure risk? These are the words Pilgrim lives or dies by.    

simultaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits  shall be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained. 

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

Blizzard Timeline in 2015 with Pilgrim Nuclear Plant

NRC focused inspection on scrams and prior LOOPs.

Jan 27, 2015 Storm Juno:

Plant trip, equipment problems, LOOP and special inspection. I predicted the plant LOOP. 

Feb 9, 2015 Storm Marcus:

Slow moving storm and rather high snow accumulation. Not much wind. Plant survives without problem.  

Feb 15, 2015 Storm Neptune 

Bombogenesis: intense low pressure and hurricane force winds. Forecasted as not a big accumulation. Pilgrim shutdown voluntarily prior to storm, but under 'concerns' and equipment problems. (questioned if secretly ordered by NRC)

Feb 22, 2015 Storm Octavia?

? Might intensify out in the ocean and run up the coast as a typical Nor’easter.

Boston thinks it might be 18"

Operations Advised Precautionary Pilgrim Plant Shutdown in Juno (1/27): Higher Management said Go to Hell

updated

Big Cover up at Pilgrim Just Before Storm Juno plant trip and LOOP 

"What if the management did not want the operators to shutdown early?"

"Was there any benefit to ops for keeping, to run the plant at full power?'

"Does management have more to gain if they wanted ops to continue full power operation?"

The Operations Department (OPS) is the most influential department at the plant. These employees are the only licensed employees at the plant...have to pass testing at the plant.

I just received a tip from a operation department employee…a very senior individual.

The game may go between the NRC and licence, 'I won't ask you and you don't tell me'. A tip just may disrupt this game of selective disclosures.  

The operation department requested and advised to senior management just hours before Storm Juno struck Pilgrim, that the plant is unsafe at power facing a hard plant trip and LOOP. Operations advised Pilgrim take a precautionary plant shutdown and sit out the storm in a shutdown condition leading up to Jan 27… 

Are Entergy's executive bonuses with staying up at power or capacity factor behind not playing it safe? 

Senior Management just blew off the advice of the Operation Department...ordered them to stay up at power.

This will turn into a whole different game if Entergy didn't disclose this to the NRC resident inspector or the special inspection team.

Storm Neptune Pilgrim plant shutdown 

Did the NRC politely tell Entergy to voluntarily shutdown the plant or we will order it shutdown. They just got done with a 12 day outage...now they found other other problems?

"Burm said that they cannot reveal how long they will be offline but adds that they are addressing a number of concerns"

Winter Storm Octavia?

???

How Does Pilgrim Behave in Winter Storm Neptune

The Weather Channel is stationed in Plymouth Ma for Neptune. Can you even imagine them covering an incident at the plant in the middle of the blizzard?

Pilgrim Plays It Safe Finally

‘Pilgrim nuclear power plant shut down for storm” (12:30 pm)

Posted Feb. 14, 2015 at 12:01 AM Updated at 12:50 PM
PLYMOUTH – The Pilgrim nuclear power plant will be shut down during the blizzard on Saturday and Sunday to avoid a repeat of problems that occurred during the Jan. 27 storm, which resulted in a 12-day shutdown. 

“We are following plant procedures to prepare for a potential loss of offsite power or the grid’s inability to accept the power Pilgrim generates," Lauren Burm, a spokesman for Entergy, the own of the plant, said in an email on Saturday afternoon. 

The 680-megawatt plant shut down automatically around 4 a.m. Jan. 27 after an electrical connection used to feed electricity to the grid was interrupted amid the worsening storm. 

It was reconnected to the grid last Saturday.

Originally posted on Feb 13...reposted it.  

Feb 14

12:12 pm: I'd be surprised if they didn't shutdown before the blizzard. I am predicting this as a second LOOP in 2015. They won't survive it. 

Pilgrim is in widespread electrical outage area red zone....high winds. 

You get it, A LOOP is usually a very infrequent and is considered a terrible incident as it strips a lot of safety components from the plant and is a serous precursor for a fukushima station blackout.

What has happened in Pigrim, is they have transferred 'a avoid at all cost' high risk incident, into a normal operation or shutdown regime. It's safe...it's all part of a normal and expected operating mode of the plant. 

The plant never designed a LOOP as a normal operational mode...a lot more engineering would have gone into it.   

4 pm: They have just vastly increased the blizzard warning area on the Ma coast...

The difference from storm Marcus (last one)…Neptune is going to have tremendously more wind than Marcus!!!!

Juno wasn't even a Bomb?

Is the Pilgrim site VP (top dog) going to bunk over at the site for storm Neptune as the Millstone VP did in Juno. I am raising my LOOP probability because the strong wind field. It should be noted they have already increased the snowfall totals from this morning... 

2:30 PM update

As the Blizzard Neptune is predicted now…it is developing far out to sea and it not going to bomb out to well past Boston. I think the possibility are slim Pilgrim will get a LOOP.

Bombogenesis: first time this year we heard this term.  

(The weather Channel) So what happens when a "weather bomb" strengthens? 

Wind speeds increase and precipitation can become more intense, often creating heavy snowfall and potential blizzard conditions during winter storms. Heavy snow rates can also occur during bombogenesis, which is sometimes accompanied by lightning. 

This happened in February 2013, when Winter Storm Nemo dropped 29 mbars within a span of 24 hours (specifically, a barometric pressure of 1000 mbars was recorded at 4 a.m. on Feb. 8, and it dropped to to 971 mbars at 4 a.m. on Feb. 9). Winter Storm Nemo ultimately "bottomed out" with a minimum barometric pressure reading of 968 mbars at 4 p.m. on Feb. 9

If they start drastically jacking up the snowfall totals, it means the bomb started sooner than expected and it is tracking closer to the coast.

There is where I think you will see another LOOP. 

I hope for the future of the 2015 everyone is aware of roof snow loading...especially if in few weeks we get a large rain storm event.

I left a message about Pilgrim’s snow loading with the resident inspectors. Made a complaint to the  NRC Allegation line…they told me the project manager will give me a call back.

Neil Shaheen just called, said everyone else is busy preparing for the storm. He assured me the plant is going to act more proactively this storm. He expects hurricane force winds this time around. He said everyone was or will be well aware of snow loading. He said the NRC asked Pilgrim about the snow loading on their roofs...Pilgrim just hasn't come back with a response yet. He implied their was prior hurricane force winds on the site, he thought all the snow was blown off the roofs.

I asked Neil is Pilgrim going to shutdown this time before the blizzard...he said that kind of information is proprietary.  

The Weather Channel has named Winter Storm Neptune, a winter storm forecast to deliver blizzard conditions to parts of New England still struggling to recover from a series of major snowstorms virtually unprecedented in modern times.

Winter Storm Neptune: Watches, Warnings and Advisories

Enlarge

Winter Storm Neptune: Watches, Warnings and Advisories

Watches, warnings, and advisories issued by the National Weather Service. This map only shows advisories in effect at least 24 hours from now, in order to exclude short-term wintry weather not related to Neptune.

The National Weather Service has already issued blizzard watches for the entire east coast of New England, stretching from Cape Cod in southeast Massachusetts through the Boston area, the Seacoast region of New Hampshire, and the entire coast of Maine as well as areas as far inland as Bangor.

Winter Storm Neptune's impact will likely be magnified by a large field of strong winds, even in areas outside the heaviest snow, and a sharp drop in temperatures that will lead to dangerously low wind chills in the wake of the storm.

Why is Wolf Creek In Trouble II?

As a message to the employees of Wolf Creek nuclear plant, throw me some insider not known executive wrongdoing. Tell me about secret problems they wouldn't fix or if they are not following the rules...I promise you I will get the NRC's attention. I will make their lives so miserable I will make them cry. I will fix Wolf Creek for you. My phone number and email is at the top of my blog...

For everyone else, you can talk to me about training or simulator troubles. You executives would regret they lived?  

I ask the right question worry about if something deeper was going in early Oct 2014. This is a horrible report card for the whole training and licensed operator ranks. There is no question the NRC down played this. But it is only going to get horrible worst.    

Why is Wolf Creek In Trouble? 

***During the facility-administered annual operating tests of licensed operators, the licensee training staff evaluated crew and individual operator performance during dynamic simulator scenarios and individual operator performance during job performance measures. There were two crew failures and 11 individual failures. The licensee remediated and retested the staff prior to returning them to licensed duties. Analysis. In accordance with Inspection Procedure 71111.11, each of the following was a performance deficiency against expected licensed operator knowledge and abilities: 1) Greater than 20 percent of the crews failing their scenarios and 2) greater than 20 percent of the licensed operator staff failing their operating tests. Using the Inspection Manual Chapter 0612, Appendix B, "Issue Screening," the inspection determined that the finding was more than minor because the performance deficiency was associated with the Mitigating Systems Cornerstone attribute of human performance, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspector determined that this finding could be evaluated using Inspection Manual Chapter 0609, Appendix I, "Licensed Operator Requalification Significance Determination Process." This finding was of very low safety significance (Green) because the finding was related to the requalification

I'd like to know how they come up with the 40% failure rate is unsafe?

exam results, did not result in a failure rate of greater than 40 percent, and the licensed operators were remediated prior to returning to shift. This finding has a cross-cutting aspect in the area of human performance associated with Green. The inspector reviewed a self-revealing finding associated with licensed operator performance on the annual requalification operating tests. Specifically, 2 of 8 crewThmance measure portions of the operating tests. The licensee remediated and retested the staff prior to returning them to licensed duties. Wolf Creek entered this finding into their corrective action program as Condition Report 75336.

This kind of plant ownership is very dangerous. A split ownership between two small potatoes utilities. 

You are see the worst of the NRC here. So the simulator was inaccurate and the safety knowledge of the licensed operators was really poor. They bufucated the depth of the problem or diluted the magnitude the the problems by separating these problems between two independent inspection reports. I am certain the NRC seen the inadequacies of the licensed operators training and the inadequacies of accurate simulator modeling at the same time. They strategized to separated the issues to minimize the violations for their buddies. 

If they would have hit these guys with these two problems at the same time, jacked up the violation level...threw it into the special inspection...these guys would have gotten the message to clean up their act really hard. Everyone else would have seen this saying, we can't let this happen to us.

Better yet, failed training and shut them down for a month or so for retraining...this wouldn't be seen in the nuclear industry for a decade or more.        

Enforcement. This finding does not involve enforcement action, because no violation of a regulatory requirement occurred. Because this finding does not involve a violation and is of very low safety significance, it is identified as FIN 05000482/2014005-01, “Failure to Conduct and Evaluate Simulator Testing In Accordance With ANSI/ANS 3.5-2009 and ANSI/ANS 3.5-1998.”

Can you believe from the latest inspection report in the above... that training the licensed operator with a inaccurate simulator is not against the rules. Only campaign contributions buys you that 

WOLF CREEK GENERATING STATION – NRC INSPECTION REPORT - Dated February 10, 201 

by Bob Meyer : How comfortable are you with your simulator performance? Does your simulator provide negative training to the operators? This inspection finding is a shot over the bow for the industry. If you are putting up with poor performance on your simulator, look at this inspection report. 

Licensed Operator Requalification Program and Licensed Operator Performance (71111.11) 

Violation: The inspectors identified a Green finding for the inadequate conduct and evaluation of simulator performance testing in accordance with the standards of ANSI/ANS 3.5-2009 and ANSI/ANS 3.5-1998, “Nuclear Power Plant Simulators for Use in Operator Training and Examination.” Specifically, Wolf Creek Nuclear Operating Corporation (WCNOC) did not adequately identify that the simulator responses during 2008 through 2014 tests of Transient 3, “Simultaneous Closure of All Main Steam Isolation Valves,” did not meet the acceptance criteria described in Section 4.1.4 of ANSI/ANS 3.5-2009 (or the 1998 edition), which if left uncorrected, could have resulted in negative training of licensed operators and call into question Wolf Creek’s ability to conduct valid licensing examinations with the simulator. WCNOC initiated condition reports 90179 and 90417 and simulator discrepancy report. A14-154. WCNOC also plans to conduct benchmarking at other sites to compare simulator responses during applicable testing, and is evaluating the need for additional procedure revisions or other corrective actions. 

The performance deficiency is more than minor because it adversely impacted the human performance attribute of the mitigating systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, if left uncorrected, the performance deficiency could have become more significant in that not correcting noticeable differences between the simulator and the reference plant could cause negative training of licensed operators and call into question WCNOC’s ability to conduct valid licensing examinations with the simulator. Utilizing Inspection Manual Chapter 0609, “Significance Determination Process,” Attachment 4, Tables 1 and 2 worksheets, issued June 19, 2012, and flowchart block 14 of Appendix I, “Licensed Operator Requalification Significance Determination Process (SDP),” issued December 6, 2011, the finding was determined to have very low safety significance (Green), because the deficiencies were associated with simulator testing, modifications, and maintenance, and there was no evidence that the plant-referenced simulator does not demonstrate the expected plant response or have uncorrected modeling and hardware deficiencies.

This finding has a cross-cutting aspect in the area of problem identification and resolution, Identification, because WCNOC personnel did not implement a corrective action program with a low threshold for identifying issues. Specifically, this issue was first identified when the RETRAN-3D code analysis was first used in 2008 transient testing, and additional tests performed in 2008, 2009, 2010, and 2012 were opportunities to identify the performance deficiency; however, the issue was not entered into the corrective action program, a noticeable difference was not evaluated, a training needs assessment was not performed, and the process used to conduct simulator transient testing, as described in Procedure Al 30C-006, was not updated to include all of the minimum acceptance criteria described in the ANSI/ANS 3.5 standard. Hence, simulator issues expected to be identified during the testing process could potentially be missed by implementing the AI 30C-006 procedure, which did not include all of the minimum acceptance criteria described in the ANSI standard [P.1]. 

71111.11 Findings 

Introduction. The inspectors identified a Green finding for WCNOC inadequately conducting and evaluating simulator performance testing in accordance with the standards of ANSI/ANS 3.5-2009 and ANSI/ANS 3.5-1998, “Nuclear Power Plant Simulators for Use in Operator Training and Examination.” Specifically, WCNOC did not adequately identify that the simulator responses during 2008 through 2014 tests of Transient 3, “Simultaneous Closure of All Main Steam Isolation Valves,” did not meet the acceptance criteria described in Section 4.1.4 of ANSI/ANS 3.5-2009 (or the 1998 edition), which if left uncorrected, could have resulted in negative training of licensed operators and call into question Wolf Creek’s ability to conduct valid licensing examinations with the simulator.

Description. In order to maintain an NRC approved simulation facility, licensees are required to conduct performance testing throughout the life of the simulator to ensure that it can be used to model control manipulations consistent with the actual plant. An acceptable method for conducting this testing is by using industry standard ANSI/ANS 3.5. This industry standard has been endorsed by the NRC in Regulatory Guide 1.149, “Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements,” Revision 4 (and Revision 3), as an acceptable method to complete required simulator testing to meet the requirements of 10 CFR 55.46. WCNOC procedure AI 30C-001, “Continued Assurance of Simulator Fidelity,” Revision 15, references ANSI/ANS 3.5-2009 as the standard for its simulator testing.

Part of the required testing detailed in the ANSI/ANS 3.5 standard includes transient performance tests, which include simulator tests on 11 specific transients specified in Section B.3.2 of Appendix B of the ANSI/ANS 3.5 standard. Section B.1.2 of Appendix B of the ANSI/ANS 3.5 standard states that the acceptance criteria for these tests are documented in Section 4.1.4 of the ANSI/ANS 3.5 standard. This section states that simulator response during transient testing will meet the following acceptance criteria:

(1) “The simulator allows the use of applicable reference unit procedures;

(2) Any observable change in simulated parameters corresponds in direction to the change expected from actual or best estimate response of the reference unit to the transient test;

(3) The simulator shall not fail to cause an alarm or automatic action if the reference unit would have caused an alarm or automatic action under identical circumstances; and

(4) The simulator shall not cause an alarm or automatic action if the reference unit would not cause an alarm or automatic action under identical circumstances.”

A failure to meet these acceptance criteria constitutes a difference in the dynamic response between the simulator and the reference unit that is distinguishable by an observer and confirmed by a subject matter expert. This is defined as a noticeable difference by the ANSI/ANS 3.5 standard. Noticeable differences are evaluated by performing a training needs assessment in accordance with Section 4.2.1.4 of the ANSI/ANS 3.5 standard. This assessment helps in determining the appropriate corrective actions, as well as in identifying potential negative effects the noticeable difference can have on licensed operator training.

Procedure AI 30C-001 describes how WCNOC maintains and tests the simulator to meet the ANSI/ANS 3.5 standard. Section 6.4.2 of AI 30C-001, sub-item 4 states, in part, that transient testing acceptance criteria are contained in procedure AI 30C-006, “Simulator Transient Testing.” Section 6.6.1 of AI 30C-006, Revision 11, states, in part, with respect to acceptance criteria, that “The test plots shall be reviewed by the LSI-Simulator or his designee to ensure that the observable change in parameters correspond in direction to those expected from a best estimate for the simulated transient and do not violate the physical laws of nature.” This is the only portion of the procedure that addresses the acceptance criteria, and it only addresses acceptance criteria (2) of the ANSI/ANS 3.5 standard. 

For a comparison of the simulator results during the testing, licensees use baseline data representing the reference unit, consistent with the preference of data sources stated in Section 5.1.1 of the ANSI/ANS 3.5 standard. In this case, WCNOC used the results from a RETRAN-3D engineering software code analysis prepared in 2006 to specifically support ANSI/ANS transient testing.

During the 2014 performance of Transient 3, the simulator initiated a reactor trip based on steam generator lo-lo level signals between 3.4 and 3.85 seconds into the test. The RETRAN-3D code analysis for Transient 3 showed a reactor trip based on high pressurizer pressure between 7 and 7.5 seconds into the test. In this case, the simulator caused an alarm and automatic action (reactor trip based on steam generator lo-lo levels, showing with lit indication on reactor protection system channels A through D) that the reference unit did not initiate. This test was not successful based on acceptance Criterion 4 of the ANSI/ANS 3.5 standard. In accordance with the ANSI/ANS 3.5 standard, this should have resulted in observation of a noticeable difference. However, an observation of a noticeable difference was not documented, and corrective actions were not evaluated using a training needs assessment.

WCNOC conducted Transient 3 on the simulator on April 10, 2014. The test was considered complete and satisfactory on September 10, 2014. On December 3, 2014, the NRC inspectors communicated to WCNOC that the test results did not meet the acceptance criteria stated in the ANSI/ANS 3.5 standard. On December 9, 2014, further discussion with WCNOC revealed that this issue had been identified when the RETRAN-3D code analysis was first used in 2008 transient testing. With this information, NRC inspectors requested documentation showing that this noticeable difference was evaluated during this time period consistent with Section 4.2.1.4 of the ANSI/ANS 3.5 standard, which would include a training needs assessment. There was no documented evidence provided showing that this evaluation took place. WCNOC initiated Condition Reports 90179 and 90417 and simulator discrepancy report A14-154. WCNOC also plans to conduct benchmarking at other sites to compare simulator responses during applicable testing, and WCNOC is evaluating the need for additional procedure revisions or other corrective actions. 

Analysis. The failure to adequately conduct and evaluate simulator performance testing in accordance with ANSI/ANS 3.5-2009 (and the 1998 edition), as referenced by site procedure AI 30C-001, Revision 15, and as endorsed by Regulatory Guide 1.149, Revisions 3 and 4, was a performance deficiency. The performance deficiency is more than minor because it adversely affected the human performance attribute of the mitigating systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, if left uncorrected, the performance deficiency would have the potential to become more significant in that not correcting noticeable differences between the simulator and the reference plant could cause negative training of licensed operators and call into question WCNOC’s ability to conduct valid licensing examinations with the simulator. Utilizing Inspection Manual Chapter 0609, “Significance Determination Process,” Attachment 4, Tables 1 and 2 worksheets, issued June 19, 2012, and flowchart block 14 of Appendix I, “Licensed Operator Requalification

Significance Determination Process (SDP),” issued December 6, 2011, the finding was determined to have very low safety significance (Green), because the deficiencies were associated with simulator testing, modifications and maintenance, and there was no evidence that the plant-referenced simulator does not demonstrate expected plant response or have uncorrected modeling and hardware deficiencies. 

This finding has a cross-cutting aspect in the area of problem identification and resolution, Identification, because WCNOC personnel did not implement a corrective action program with a low threshold for identifying issues. Specifically, this issue was first identified when the RETRAN-3D code analysis was first used in 2008 transient testing, and additional tests performed in 2008, 2009, 2010, and 2012 were opportunities to identify the performance deficiency; however, the issue was not entered into the corrective action program, a noticeable difference was not evaluated, a training needs assessment was not performed, and the process used to conduct simulator transient testing, as described in Procedure Al 30C-006, was not updated to include all of the minimum acceptance criteria described in the ANSI/ANS 3.5 standard. Hence, simulator issues expected to be identified during the testing process could potentially be missed by implementing the AI 30C-006 procedure, which did not include all of the minimum acceptance criteria described in the ANSI standard [P.1].

Enforcement. This finding does not involve enforcement action, because no violation of a regulatory requirement occurred. Because this finding does not involve a violation and is of very low safety significance, it is identified as FIN 05000482/2014005-01, “Failure to Conduct and Evaluate Simulator Testing In Accordance With ANSI/ANS 3.5-2009 and ANSI/ANS 3.5-1998.

What The Hell is Going On With Region 1: Millstone, Pilgrim and Oyster Creek

What the hell is going on with Region 1. Millstone 2 and 3, Oyster Creek and Pilgrim is going into serious decline.

I think half the reason is the agency is too predictable...

Lets see, out of 25 plants with 4 in steep decline....gives you 16% of regions 1 plants on fire.

The Region 1 northeast quadrant...  Indian Point 1 and 2,  Millstone 2 and 3, Oyster Creek and Pilgrim...

67% of the oil rigs are are on fire and burning in the gulf.

Hmm, two in the same Independent System Operator grid authority,

Dominion, Exelon and Entergy...

Region One 

Valley 1	100
Beaver Valley 2	100
Calvert Cliffs 1	100
Calvert Cliffs 2	100
FitzPatrick	100
Ginna	100
Hope Creek 1	100
Indian Point 2	100
Indian Point 3	100
Limerick 1	100
Limerick 2	100
Millstone 2	100
Millstone 3	100
Nine Mile Point 1	100
Nine Mile Point 2	100
Oyster Creek	100
Peach Bottom 2	89
Peach Bottom 3	100
Pilgrim 1	100
Salem 1	100
Salem 2	100
Seabrook 1	100
Susquehanna 1	100
Susquehanna 2	100
Three Mile Island 1

The Barnstable Patriot : Deconstructing Pilgrim

The Barnstable Patriot  Deconstructing Pilgrim  Written by Diane Turco

February 12, 2015

We can’t wait for another storm  The Cape Cod blizzard on Jan. 26 provided yet another scary warning. The real danger during the automatic emergency shutdown, or scram, which occurred at Pilgrim Nuclear Power Station on Jan. 27, had more to do with multiple equipment malfunctions than with the loss of offsite power caused by the storm. What transpired at Pilgrim was a series of failures that highlights the lack of oversight by the Nuclear Regulatory Commission and the hubris of Entergy Corporation while our state government downplayed the unfolding events.  The morning of the scram, Entergy quickly put out a press release stating that “All safety systems worked as designed.” Governor Baker and Secretary of Energy Beaton repeated the upbeat announcement and reported there was “no threat to public health or safety.” But what was described primarily as a loss of offsite power by the downing of transmission wires was not the whole case. Hours after the loss of electricity, a primary emergency cooling system, a safety relief valve and an air compressor failed. Two days later preliminary notification was sent by the NRC to state officials, an early notice of “events of possible safety or public interest significance.” That announcement didn’t make it into the public venue. If the following sequence does not inspire the state government to act on behalf of public safety, we are all in real trouble.  On the day before the storm, Jan. 26, the NRC released their 2014 assessment of Entergy, owner of the reactor. The findings are alarming. Entergy will remain under federal oversight and Pilgrim on the NRC list of the worst operating reactors in the country. Citing the lack of implementation of corrective actions related to inadequate safety performance, Entergy management was effectively told to “try again.” The follow-up plan allows Entergy to contact the NRC when the plant is ready to be inspected again.  The fact that the corporation is in charge of the timeline for following through with NRC recommendations throws a spotlight on the cozy relationship between the industry and the regulator. Essentially, Entergy can fix problems at the nuclear reactor at their convenience, while public health and safety can be ignored. Heightened attention from the NRC should not be the only consequence for a corporation left to complete corrective actions. On Feb. 4, the NRC released a second report on the 2014 investigation at Pilgrim. The cooling system that failed to function as the primary safety system during the blizzard shutdown was evaluated by the NRC staff just two months ago. With “no findings identified,” that same equipment passed inspection with flying colors only to malfunction weeks later. Eight days after the storm, yet another equipment failure was reported. Water level measuring instruments had failed due to the loss of the air compressor during the storm. The resulting assessment revealed there were no clear emergency procedures in place to fix this problem. This situation was serious enough for the NRC to determine it was reportable because it is considered that the event “results in a major loss of emergency assessment capability.” After 12 days of reviewing the problems, the NRC inspectors left town without reporting preliminary findings or holding a public hearing. Why should we, the public, be expected to trust Entergy Corp. with our health and safety? Isn’t it the job of the government to step in to stop this ongoing threat to all of us? Once again, Entergy pushes aside public safety for profit, ignoring activist requests and prior serious plant problems for a precautionary shutdown prior to the blizzard. This was reasonably predicable event. The storm has proven that Pilgrim is a failed design run by a failed corporation regulated by failed oversight. It is time for Governor Baker and the state Legislature to demand on behalf of the citizens of Massachusetts that the NRC withdraw the operating license for Pilgrim and begin its decommissioning. Enough is enough. We can’t wait for another storm.

Controversy At The Pilgrim Nuclear Plant

Feb 12: I added the below to the NRC Blog

Additional Scrutiny at Pilgrim Nuclear Power Plant Set to Continue

‘Controversy at the Pilgrim nuclear plant’ 

Here is another Brian Williams moment. The Pilgrim spokesman and NRC Public Affairs Office Neil Sheehan rope-a-doping the antis. 

Pilgrim Spokesman Lauren Burm “The shutdown occurred safely as plant operators were reducing power in response to the onset of a historic storm. Plant conditions were stable and there was never any threat at all to the safety of plant workers or the public.” 

The NRC’s PNO: “On January 27, 2015, Pilgrim Nuclear Power Station experienced an automatic scram following a turbine trip due to a partial loss of offsite power. The station was experiencing high winds and heavy snowfall during a severe winter storm when the station began experiencing degrading switchyard conditions.”

At 4 am when the plant tripped Boston had 24” of snow on the ground. They were past the middle of the blizzard and these were the exact same grid instability they’d seen in Juno. They were getting control room annunciators of shorts on the line for an hour or more indicating a duel line trip was approaching. It got so bad, they were in an emergency procedure to bring them into a shutdown condition as fast as they could. They showed astounding incompetence in the shutdown as it was started too late…one line had tripped and everyone knew that plant wouldn't get to a safe shutdown condition on one line. Nuclear professionalism dictates you never accept an automatic protection…you manually insert the scram before the automatic action.

Mr. Sheeheen is supposed to be the neutral third party here…why didn't he explain the true conditions of the plant scram. I do understand it is against the NRC policy to never interrupt a licensee’s spokesman no matter how bad the Brian Williams moment is?

Millstone Power Station site Vice President John Daugherty slept on a cot in his office at the plant during storm Juno. The new guy sees the light. Did the equivalent (top dog) at Pilgrim ever show such concern for his employees and his plant? You are putting the individual safety of your employees at risk by forcing them to run around the plant like chickens with their heads cut off by allowing your plant to scram with a high potential of a LOOP in the middle of historic blizzard.     

Personally, in the condition they were in, the evacuation would have needed to occur after 6 to 8 hours. They weren't anywhere close to that. Core cooling was never impaired, but a lot of the safety systems had been stripped away from the plant Pilgrim is in a terrible state.

I am thinking the NRC fears if Pilgrim collapses...then Indian Point will soon follow... 

Does anyone think this is true:(Entergy)"were reducing power in response to the onset of a historic storm."

My interpretation would be they were responding to the shorting lines and  control room annunciators of troubles on the lines. This was hours from the onset of the storm.They were getting instrumentation indications that line trips were moments away.  

Posted to the NRC page: 

This is what I got a problem with…everyone only showing the most prettified version of self. Not the most completely accurate version of events. The selective release of information that only creates the most handsome profile of self. The Brain Williams in the nuclear industry? 

"During winter storm Juno, operators observed that water level indicators at the plant water intake were non-functional.” 

Why didn’t the NRC admit this was missed by Entergy in storm Nemo? Why didn’t the NRC catch it in 2013? If you had a special inspection in 2013, you would have caught it then and preventing its reoccurrence in 2015? 

 What are you guys going to do if another blizzard knocks Pilgrim into another LOOP in 2015? I am predicting one diesel generator failure this time due to the accumulation to all the fast start-ups creating excessive stress on these machines. How many fast start-ups are these machines designed for considering all the LOOPs at this site and the integrated eccs testing ? 

Don’t even get me talking about the broken meteorological tower I caught in Nemo…it being unreliable for a long period of time before this. This impaired a possible evacuation.  I got it on the Pilgrim docket. 

I do admit the water level is kind of insignificant in the big picture…but not knowing the limitation of your indications in a big event is bad.   

The Enterprise New: 

Controversy at the Pilgrim nuclear plant 

By Frank Mand Posted Feb. 11, 2015 at 5:00 AM

PLYMOUTH – Did Pilgrim come within minutes of sounding its sirens during the recent blizzard, dubbed Juno, or was it just a matter of tempers nearing the boiling point in the week after the nuclear power plant shut down at the peak of the historic storm? 

Neither Entergy nor the NRC is mincing words.

When plant critic and EcoLaw founder Meg Sheehan tweeted, “Insider says #Entergy Pilgrim #nuclear scram during #Juno2015 on 1/27 closest ever to meltdown, within minutes of sounding evacuation sirens,” Pilgrim Spokesman Lauren Burm used social media to call Sheehan's comments “irresponsible.” 

“These claims are completely unfounded and irresponsible,” Burm later wrote in a statement. “They have absolutely no basis in fact. The shutdown occurred safely as plant operators were reducing power in response to the onset of a historic storm. Plant conditions were stable and there was never any threat at all to the safety of plant workers or the public.”

Burm’s response led to a short but passionate exchange of tweets, with Sheehan posting that “a spokesperson for Entergy lacks any credibility.” 

But the NRC weighed in shortly thereafter backing Burm, commenting both on the reports of anonymous insiders and the condition of the plant during Juno. 

“We received similar comments on our blog,” NRC Public Affairs Office Neil Sheehan said. “We have seen nothing that would have qualified as a crisis during the shutdown.” 

Its confidence in the safety of the plant was backed up by its approval for the reactor to be restarted last Saturday, Feb. 7. 

But potentially complicating the matter is a new report saying that along with the loss of power and the failure of other noncritical systems during Juno, the plant also experienced a loss of “instrument air.” 

Instrument air, according to the NRC, is a non-safety-related system used to provide control air to a number of valves and instruments in the plant. If those controls are not working, the plant has to rely on a person with their eyes on the actual conditions. 

Burm acknowledges that the plant did not report this occurrence on a timely basis. The report Pilgrim should have filed, called a 5072 Report, was issued Feb. 5, nine days after the scram, or shutdown. But Burm said the loss of instrument air did not impact safety. 

"During winter storm Juno, operators observed that water level indicators at the plant water intake were non-functional. Actual sea water levels at the intake bay did not rise above typical levels at any time during the storm,” Burm said. “Although the facility did not immediately report the issue with the water level indicators, equipment reliability was never challenged and the plant remained safe and in stable condition."
Page 2 of 2 - The NRC’s Neil Sheehan backed up Burm's statement. 

“In general, a loss of instrument air can complicate plant operators’ response to an event,” Neil Sheehan said, “but the plant can be - and was - safely shut down without it.” 

At Pilgrim, Neil Sheehan explained, “instrument air feeds level instrument bubblers used to measure the sea water intake bay level. These instruments are used by operators to assess Emergency Action Levels." 

It was the NRC that identified the issue, during the inspection that followed the Juno scram."During our Special Inspection, the NRC identified that the level instruments were not functional once instrument air was lost.” Entergy then submitted an Event Notification on the issue. 

“During the storm, the company had an operator outside in the sea water intake structure, and water levels never rose to a level that would have challenged any plant equipment,” Neil Sheehan added. “In addition, our review of tidal conditions, including worst-case forecast storm surge, determined that intake bay levels never actually exceeded an Emergency Action Level, nor were the water levels close to exceeding an Emergency Action Level.”
Was this instrument failure the basis for the allegations that the plant had come close to a catastrophic failure during the storm, and that it was within minutes of sounding its sirens? 

The Old Colony was unable to identify the “insider” who supposedly made the claim that Pilgrim had come close to meltdown and was within minutes of calling for evacuations. 

When EcoLaw’s Meg Sheehan, who tweeted the allegation after, she says, having communicated with this “insider,” was asked why the NRC would have allowed the plant to restart if there were systemic issues and what the insider knows that the NRC does not, she said she didn't want to “debate” the issue. 

She did, however, offer a personal comment. 

“Since the 1970s, I have been told by many friends and acquaintances many things about what goes on inside Pilgrim,” Meg Sheehan said. “This is just one more thing I’ve heard, and happen to believe. 

“During Juno I stayed with my elderly parents who live 8 miles from Pilgrim to make sure they were OK,” Sheehan added. “After what happened at Pilgrim, I realize acutely the danger we are all in.”