Exelon’s And Pentas Controls’s Fake Nuclear Plant Parts

I doubt he would do this without instructions from Peach Bottom and Brunswick.   

Misrepresentation – Display Serial Numbers - Pentas Controls, LLC (Pentas) - In 2010, the owner/president of Pentas directed one of his employees to switch a broken display on a Peach Bottom Atomic Power Station steam leak detector monitor with a working display unit from the Brunswick Nuclear Plant site. Before its shipment, the owner/ president also instructed an employee to file down the serial number on the substitute display to conceal its identity and to ship the working display to Peach Bottom without informing that site of the switch. On March 15, 2011, the owner/president made false statements to NRC investigators by repeatedly denying that the unrepairable Peach Bottom display had been substituted with a working display from Brunswick site.

Because of the egregiousness of the owner/president’s actions, the U. S. Department of Justice (DOJ) prosecuted the case in Federal district court in Phoenix, AZ. The president pled guilty to making false statements to NRC investigators, a felony, and was sentenced on February 11, 2013. In exchange for his guilty plea, the president will serve a 5-year probation during which time he will complete several conditions that the NRC developed and included in the DOJ’s global settlement agreement. The NRC will monitor these conditions. As part of the agreement, the owner/president was required to notify his employees of his violation and its consequences and Pentas was required to conduct training on safety-related activities and hire an outside contractor to conduct employee protection training. The owner/president was banned from safety-related decision making for 1 year and from quality-assurance oversight activities indefinitely. Additional information is available in Judgment in Department of Justice prosecution of President of Pentas Controls, Inc., including Terms of Probation (ADAMS Accession No. ML13213A376) and in the NRC Enforcement Program Annual Report, Calendar Year 2012, on page 16; (ADAMS Accession No. ML13079A446).

"The company specializes in nuclear reactor and power plant equipment repairs and refurbishments."

 

This is the model of these monstrous nuclear repair parts/refurbishment vendors or contractors. They sand papered the serial numbers of the nuclear plant component and a whistleblower brought it to the attention of the NRC.

I give you an example in the Brunswick nuclear power plants with their Nordberg DG manufacturer. Their emergency Diesel Generators are no longer supported by a large manufacturer. Nordberrg has long gone bankrupt. Duke has purchased the paperwork ruminant of Nordberg. They got them patents. The major repair parts, parts refurbishment partial owner or vendors basically goes to the commercial ship fleet graveyard where many obsolete Norberg diesel generators now reside. These dgs propelled the screws of the ship. We are talking WW II vintage here. It is a really dirty business. These venders collect parts of the obsolete dgs and refurbish them into nuclear grade parts. They had a lot of troubles with these parts. Duke planed to replace all eight emergency diesel generators on the two plants...but the project was cancelled. The DG job at the two plants was more expensive than actually the value of the two sites. I believe these guys are two plant sites...meaning at least eight diesel generator. Duke thought these guys needed to be replace, but the value of the sites and price of electricity got them backed into a corner nobody wants to be in.
      
Basically the utilities are pretty tough on these small companies. Its provide us what we need or perish. It is a dirty business. In the old days their own employees would do this dirty work. Getting a private company to do it, its a barrier that protects the nuclear plant credibility with the NRC.    

  Originally post on 12/7/12

What a disgusting April 30 letter the NRC wrote to the Pentas president...the letter included at the end of this article.

Can you believe this guy ever had the trustworthiness to work on critical nuclear safety equipment... 

And "United Controls International inc" of Tucker Georgia is all wrapped up in the South Korean fraudulent certification of nuclear power plant replacement parts...

 

This guy wasn't a low level guy...he was the owner of the company. ..you can assume he taught all his employees how to lie to high up NRC officials. Sounds like he was use to getting away with NRC lying?

Phoenix business owner pleads guilty to lying about nuclear power plant repairs

Phoenix Business Journal by Mike Sunnucks, Senior Reporter

The owner of a Phoenix company faces prison time and a $250,000 fine after pleading guilty to making false statements to federal investigators regarding repairs to a Pennsylvania nuclear power plant.

Kevin A. Doyle, 47, of Scottsdale, owns Pentas Controls LLC. The company specializes in nuclear reactor and power plant equipment repairs and refurbishments.

Doyle entered his guilty plea Nov. 30 in federal court in Phoenix.

The U.S. Attorney’s Office for Arizona said Pentas was not able to repair measurements display equipment at the Peach Bottom Atomic Power Station in southeastern Pennsylvania.

Federal prosecutors said Doyle then lied to investigators from the Nuclear Regulatory Commission about the repair and the shipment of a substitute display panel from the Brunswick Nuclear Generating Station in North Carolina.

Nuclear power plants have a wide array of rules, regulations and laws governing their owners, operators, contractors and repair firms.

Doyle will be sentenced Feb. 11. He faces as much as five years in federal prison and a $250,000 fine.

Pentas Controls

Constellation Nuclear
Tennessee Valley Authority
Duquesne Light
Progress Energy
Texas Utilities
Niagara Mohawk
Exelon
Entergy
Florida Power & Electric
First Energy
Union Electric
Pennsylvania Power & Light
Carolina Power & Light
South Carolina Electric & Gas

Progress Energy

Calvert Cliffs Nuclear Power Plant

IES-Duane Arnold

Texas Utilities.

 

Kevin Doyle

General Manager

Value added services to the  Nuclear Power Utilities Industry 

Pentas Controls was founded in 1992 with the specific objective of supplying quality printed circuit board replacements to the nuclear, fossil fuel, and hydro-electric utilities as well as other industrial customers. Pentas has since developed the specialized capability to troubleshoot, reverse engineer, perform failure analysis, manufacture, repair/refurbish and thoroughly test instrument modules and power supplies as well as printed circuit board assemblies.

Pentas' combined nuclear engineering management experience exceeds 80 years. This, coupled with our in-house assembly and troubleshooting, testing and manufacturing capabilities positions Pentas to handle all customers' needs for refurbishing/repairing or replacing like-for-like instrument and control boards, instrument modules, power supplies and other control devices.

One example of this support would be the total refurbishment of 39 Bailey Modules. This project included replacement of all aluminum electrolytic capacitors (including 100% component receipt testing, Substitution, Evaluations, 48 hour burn-ins, Full Functional Testing and all supporting documentation). This project was completed in 6 days from receipt to the ship date. The utility furnished Pentas all the applicable bills of material, test specifications and Model type/quantities. With this data Pentas was able to order the applicable components and perform receipt testing prior to the Module receipts. This particular project required continuous communication with the utility prior to the start of the project and continually throughout the project. A COMPLETE SUCCESS!!!!!

PENTAS CONTROLS QUALITY IS #1.

Pentas demands quality and integrity in all its interactions, internal and external, to maintain the highest possible reputation within the business community and to promote inter-company unity. Each person is individually responsible for and is expected to maintain quality, integrity and ethics in all corporate activities.

"10CFR50" Appendix B Qualified

Pentas Controls has successfully passed 10CFR50, Appendix B audits and quality servers performed by Progress Energy, Calvert Cliffs Nuclear Power Plant, IES-Duane Arnold, and Texas Utilities.

Pentas Controls can assist you in lowering your maintenance cost.

With today's rapid growth and advancements in the electronics technology and manufacturing methods can renders many instrument designs obsolete shortly after production is complete. This situation presents a unique challenge, especially to industries that require strict control of configuration to maintain equipment qualification or who are trying to contain costs. Often, circuit board and instrumentation and control devices are obsolete long before the life expectancy of their host equipment. At best, new replacements are expensive and require long lead times. In some cases, equipment owners are forced to complete expensive modifications, redesign, and document updates to accommodate the new replacement parts and keep the equipment and/or plant operable. As a result, Operations and Maintenance costs increase significantly.
 

Pentas controls can help you meet your repair and refurbishment requirements.

Pentas can assist our customers in becoming more cost competitive. Pentas' utility or industrial customers can no longer afford to continue paying the high costs demanded by the Original Equipment Manufacturers (if they are still in business) for printed circuit board assemblies or electronic modules, controllers, power supplies, etc. or the costs associated with system or component modifications (i.e., equipment costs, technical specification/procedure changes, downtime, re-training, etc.) By maintaining the existing system configurations, Pentas will lower our customers' Operating and Maintenance Budgets significantly.

About Us

Our Engineering Experience

Pentas' combined nuclear engineering management experience exceeds 80 years. Our in-house assembly and troubleshooting, testing, and manufacturing capabilities position Pentas to handle all customer needs for refurbishing, repairing, or replacing like-for-like instrument and control boards, instrument modules, power supplies, and other control devices.

Our expertise encompasses all areas relevant to electronic device manufacturing and repair for nuclear and commercial industries. Our many years of nuclear experience include dedication testing of various commercial grade electronics for use in safety-related applications; performing numerous equivalency evaluations, developing dedication testing plans for circuit boards, power supplies, and instrumentation and control devices; and performing component and system level troubleshooting and start-up evaluations.

Additionally, our personnel have served on various Electric Power Research Institute (EPRI) Plant Support Engineering (PSE) and Nuclear Management Resources (NUMARC) committees. Pentas Controls has successfully passed "10CFR50," Appendix B audits, and Quality Surveys performed by Progress Energy, Calvert Cliffs Nuclear Power Plant, IES - Duane Arnold, and Texas Utilities.

Our customer base includes the following electric utilities:

Constellation Nuclear
Tennessee Valley Authority
Duquesne Light
Progress Energy
Texas Utilities
Niagara Mohawk
Exelon
Entergy
Florida Power & Electric
First Energy
Union Electric
Pennsylvania Power & Light
Carolina Power & Light
South Carolina Electric & Gas

David Hignite
QA Manager

· The Quality Control Program of Pentas Controls LLC. meets Appendix B of 10 CFR Part 50, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" audit has successfully undergone Quality audits."

· The intent of the Program is to also meet the requirements of the International Standard (ISO) 9001 "Quality Systems - Model for quality assurance in design/development, production, installation and servicing."

· Pentas Controls, LLC. intends to strictly comply with the Quality Control Program and all lower tier documents to assure our customers the highest standards of quality and integrity.

Pentas demands quality and integrity in all its interactions, internal and external, to maintain the highest possible reputation within the business community and to promote inter-company unity. Each person is individually responsible for and is expected to maintain quality,integrityand ethics in all corporate activities.

RICHARD HENNE
Director of Engineering Services

Pentas Controls - Mission Statement:

"To Assist our Customers in achieving Maximum production output while Minimizing Operating and Maintenance Expenses." 

Achievable by:

Supporting our customers in maintaining existing systems to facilitate the customers needs to be more cost competitive by reducing maintenance costs. 

Enter into long term strategic alliance or partnership arrangements to maintain existing plant configurations throughout plant life.

Partake or assist in any possible future system needs (i.e., new design, enhancements, modifications, etc.). 

Assist in areas of Inventory Control and Warehousing to minimize excessive costs of maintaining inventory and any associated costs ultimately passed on to O&M budgets.

Director of Engineering Services Pentas Controls - Mission Statement: "To Assist our Customers in achieving Maximum production output while Minimizing Operating and Maintenance Expenses."

Achievable by: Supporting our customers in maintaining existing systems to facilitate the customers needs to be more cost competitive by reducing maintenance costs. Enter into long term strategic alliance or partnership arrangements to maintain existing plant configurations throughout plant life. Partake or assist in any possible future system needs (i.e., new design, enhancements, modifications, etc.). Assist in areas of Inventory Control and Warehousing to minimize excessive costs of maintaining inventory and any associated costs ultimately passed on to O&M budgets.

Products

 

All reverse engineering manufactured for identical fit, form and function to original OEM product specification.

Please request Quote for pricing.

Power Supply
Reverse Engineering
PCI-2-04-A

Reverse engineering of Lamda LCS-2-04 Power Supply.

 

Sub Assembly

Reverse Engineering

PCI-101070506-A

Reverse engineering of Yusa Exide Current model.

PCI's in stock and Quick Turn PCB's

Many in stock replacement PCB's and Quick turned manufactured PCB's.

 

Services
 

Value added services include:

Ability for customers to maintain existing system configurations. Repair and refurbishment of printed circuit board assemblies. Repair and refurbishment of power supplies, instrument modules, controllers, etc.

Repair and Refurbished parts OEM's to include:

ABS/PCI	ACDC Electronics	Acopian	Adtech Power
Aipax	Alison Controls	Altec Lansing	AMG Electronics
Analog Devices	Armistead	ASI	Astec
Bell & Howell	Bentley-Nevada	Berkleonics	BW/IP
C & D	Calex	Canberra	CE
CE ACDC Electronics	Chemetron	Computer Products	Condor Inc.
Controlotron	Cooper	Cooper Electronics	CPI
Deltron	Devar	Diamond Electronics	Dressen-Barnes
Eaton	Ederer	Electro Devices	Electronique
Encore	Encore Elec.	ESFAS	Esterline Angus
F & P	Factron	Federal Signal Corp.	Fiber Options
Fire Systems Inc.	Fluid Components	Foxboro	GA Technologies
Gamma-Metrics	GE	GEMAC	General Atomic
Gulf Electronics	Hathaway Corp.	Hathaway/PCI	HC Power Inc.
Honeywell	HV	Hydro Products	Ingersoll-Rand
ITT Barton	Kaman	Kaman/AIS	KaY-Ray
Kemco	Kepco	L & N	Lambda
LH Research	Louis Allis	Love Controls	National Sonics
Newport	Nine Mile	NLI	NMC
NRC	Optron	Panalarm	Pentas Controls LLC
PCI/ASI	PCI/Hathaway	PCI/National Sonics	PCI/Teledyne
Pentas Controls/Teledyne	Pioneer Magnetics	PMC	Polyphase Instruments
Power Design	Power One	Pyrotonics	RFL
Riley	RIS	Robicon	Ronan
Rosemount	RTP	S & K	Schlumberger
SCI	S-E-Co.	Sentry	Sentry Equi, Inc.
Seimens	Simmonds	Percesion	SIMPLEX
SKF	Sola	Solidstate Controls	Sorrento
Speedomax	SPS	Struthers-Dunn	TEC
Technical Novations	Thermon	TI	Todd
Topaz	Tracor Westronics	Transistor Devices	Transmation
Triumph Controls, Inc.	Trygon	Validyne	Victoreen
Vitro Corp.	Wanless	Weathermeasure	Westinghouse
Westronics	Woodward	Yuasa Exide	Zenith

Failure Analysis Capabilities:

Pentas Controls can provide all levels of module, PCB and component level root cause failure analysis reporting. Pentas Controls possesses the ability to analyze and test almost any electrical component, PCB assembly or Module assembly.

We have a multi-million dollar laboratory at our disposal to analyze performance, root cause of failure, or operating characteristics of circuit board assemblies or electronic modules, controllers, power supplies, etc., as well as their component parts

Sophisticated test equipment allows us to directly observe electrical device semiconductor junctions and additional capabilities range up to and include layer-by- layer die analysis to determine cause of failure in integrated circuits.

Our laboratory is also capable of performing material analysis and testing.

With access to these formidable capabilities, Pentas Controls can determine root cause of failure for frequently replaced "trouble" printed circuit boards or electronic modules, controllers, power supplies, etc., and suggest corrective action which will improve the reliability of these components.

April 30, 2013

Mr. Kevin Doyle, President

Pentas Controls, LLC

20650 N 29

th Place

Suite 106
Phoenix, AZ 85050

Dear Mr. Doyle:

We have reviewed the information you included in your various email submissions. As noted in our April 4, 2013, email response, please be aware that Pentas Controls, LLC (hereinafter

referred to as Pentas Controls) is subject to Nuclear Regulatory Commission (NRC inspections, which will determine whether Pentas Controls is meeting all applicable NRC regulations and requirements as well as the Terms of Probation contained in your sentencing document. NRC requirements that apply to Pentas Controls include, for example, that Pentas Controls shall comply with NRC regulations 10 CFR §§ 50.5, Deliberate Misconduct; 50.7, Employee Protection; 50.9, Completeness and Accuracy of Information; 10 CFR Part 21, Reporting of Defects and Noncompliance; and Appendix B of 10 CFR Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. The Terms of Probation are additional requirements that Pentas Controls must complete as it engages in activities as a vendor of nuclear services and repairs.

In light of your submissions to the NRC in response to the Terms of Probation contained in your sentencing document, the NRC has the following responses:

I. Communication:

A. Requirement:

1(a): Within 30 days of sentencing, defendant shall provide a letter or memo to his employees at Pentas Controls, LLC (hereinafter Pentas Controls) involved in any nuclear safety-related activities including, but not limited to, the repair, refurbishment, or replacement of nuclear safety-related items, advising them that he violated NRC requirements and the consequences of his violation.

B. Submission:

You sent an initial letter to Pentas Controls employees within the appropriate time in response to Requirement 1(a) above; however, the first letter failed to capture the basis for this communication as articulated in the Terms of Probation. You subsequently sent a revised letter to your employees addressing most of the issues the NRC raised but concluded the letter with a statement that Pentas Controls employees could bring safety-related concerns to you in addition to the other points of contact. In a subsequent email, the NRC advised you that including yourself as a point of contact was not appropriate.

On March 26, 2013, you sent the NRC an email with an attachment containing a third letter you provided to Pentas Controls employees that removes the offending language, i.e., this revision excludes your name as a point of contact.

C. NRC Response: Your email states that you provided the revised letter attached to your March 26, 2013 email to Pentas Controls employees involved in any nuclear safety-related activities including, but not limited to, the repair, refurbishment, or replacement of nuclear safety-related items. You removed your name as a point of contact for Pentas Controls employees to bring safety-related concerns and appropriately addressed the other information included in Requirement 1(a). The NRC will review Pentas Controls documentation during inspection to verify this.

II. Safety-Related Training:

A. Requirement:

 

2 (a): Pentas Controls will create a written policy, develop training, and train employees
involved in any nuclear safety-related activities including but not limited to the repair, refurbishment, or replacement of nuclear safety-related items, addressing compliance with NRC regulations within 60 days of sentencing.

B. Submission:

You have hired a Quality Assurance (QA) Manager, Mr. Robert Prigmore.

You submitted a document entitled “Pentas Controls, 10 CFR Part 21 Notifications.”

You also submitted QA Procedures for Qualification of Inspection and Testing Personnel and Qualification of Solder Personnel.

C. NRC Response: Mr. Prigmore’s resume indicates that he is qualified to create the written policy, develop training and train employees in areas addressing compliance with NRC regulations specifically focusing on QA processes and procedures that are contained in 10 CFR Part 21 and Appendix B of 10 CFR Part 50.

The NRC is not aware of any written procedures indicating that Pentas Controls has a written policy addressing the requirements in Appendix B of 10 CFR Part 50.

The QA Manager is responsible for evaluating qualification procedures for adequacy. As part of NRC inspection, we will review these procedures and verify their implementation, including training that the QA Manager provides, per the Terms of Probation and Appendix B requirements. However, the NRC does not intend to review Pentas Controls qualification

procedures to provide guidance on how to meet Appendix B requirements.

III. Employee Protection Training:

A. Requirement: 2(b): Within 90 days of sentencing, Pentas Controls shall hire an outside consultant, approved by the NRC, with expertise in NRC employee protection regulations to develop and conduct training modules, and provide recommendations for improvement. The training will include:

1. Information regarding the important role an open and collaborative work environment

plays in a positive safety culture as described in the NRC’s Safety Culture Policy Statement, which applies to vendors and suppliers of nuclear safety-related items;

2. The importance of providing complete and accurate information to the NRC, including a

focus on the actions that led to the subject terms of probation and the lesson-learned from the precipitating event to include a review of the consequences of and the potential actions that NRC may take against an individual for willful violations;

3. A focus on 10 CFR 50.5, “Deliberate Misconduct,” 50.7, “Employee Protection,” and 50.9. “Completeness and Accuracy of Information” to include potential enforcement outcomes when these requirements are violated either by an organization such as Pentas Controls or an individual.

4. This requirement then lists several items that must be included in this training, including that training records shall be retained consistent with applicable Pentas Controls record retention policies and made available to the NRC upon request.

B. Submission:

To satisfy this requirement, you initially submitted a list of employees that had attended training that was developed and completed by the Pentas Controls QA Manager, Mr. Prigmore. Because Mr. Prigmore is the QA Manager for Pentas Controls, he does not meet the requirement that initial training be developed and provided by an outside consultant. The NRC called this to your attention. In response, in emails dated April 8 and April 9, 2013, you

submitted the resumes of three outside consultants, i.e., Mr. David A. Taggart, Mr. Peter J. Rail, and Mr. Russell Wise, to develop and conduct the training specified in 2(b).

C. NRC Response:

The NRC has reviewed the resumes of the consultants and all three consultants appear qualified to develop and provide this training; however, Mr. Taggart is associated with the NDT Consulting Group, LLC, which is the same consulting company with which Mr. Prigmore has been associated. This association does not provide the independence envisioned by this requirement. While an actual conflict of interest may not exist; the appearance of a conflict of interest does exist. As with the training discussed in item 2(a) above, as part of its inspection, the NRC will review the training records and verify its implementation per the Terms of Probation.

IV. Organizational Changes:

A. Requirements:

3(a): For the first 365 days of probation, defendant is banned from any decision-making authority under the purview of the NRC regulatory authority regarding any nuclear safety-related activities included but not limited to repair, refurbishment or replacement of nuclear safety related tems. 3(b): Defendant shall be removed indefinitely as the individual responsible for QA oversight of activities regarding the repair, refurbishment or replacement of nuclear safety-related items. The NRC, in consultation with the U.S. Probation Office, will have the authority to reduce the restrictive nature of this term as appropriate.

3(d): Pentas Controls will hire a Quality Assurance Manager to provide oversight for the repairs, refurbishment or replacement of all nuclear safety related items. Defendant will not have any authority over the quality assurance activities in order to ensure sufficient independence from cost and schedule when opposed to safety considerations.

B. Submission:

You submitted a “Statement of Authority and Policy” which notes, in pertinent part, that the

Quality Assurance Program is delegated to the Quality Assurance Director; however, this
statement includes language that allows you to act in the place of the QA Manager in his/her
absence.

C. NRC Response:

The Statement of Authority and Policy does not provide the independence specified by the

requirements in paragraph 3. Specifically, the last paragraph of this delegation of authority
indicates that, “In the absence of the Quality Assurance Director, the president may act in his stead. In the absence of the President, the Quality Assurance Director may act in his stead.”

V. Additional Comments:

You asked whether Pentas Controls can use Skype to provide the initial employee protection training. While the method of training is not expressly specified in the Terms of Probation, as noted above, the NRC will review the actions taken to satisfy NRC regulations and the requirements specified in the Terms of Probation to verify that they have been appropriately implemented. The NRC will also review the effectiveness of this training during NRC inspections. While the NRC has provided Ms. Schwartz as a point of contact in the event that you have questions pertaining to the implementation of the Terms of Probation, you are solely responsible for ensuring the implementation of these terms. As noted above in this letter, Pentas Controls is subject to NRC inspections, which will determine whether Pentas Controls is meeting all applicable NRC regulations and requirements as well as the Terms of Probation contained in your sentencing document.

Sincerely,

/RA/

Dave Solorio, Chief

Concerns Resolution Branch

Office of Enforcement

U.S. Nuclear Regulatory Commission

K. Doyle - 5 -

While the NRC has provided Ms. Schwartz as a point of contact in the event that you have questions pertaining to the implementation of the Terms of Probation, you are solely responsible for ensuring the implementation of these terms. As noted above in this letter, Pentas Controls is subject to NRC inspections, which will determine whether Pentas Controls is meeting all applicable NRC regulations and requirements as well as the Terms of Probation contained in your sentencing document.

Sincerely,

/RA/

Dave Solorio, Chief

Concerns Resolution Branch

Office of Enforcement

U.S. Nuclear Regulatory Commission

DISTRIBUTION:

MLemoncelli, OGC DCopeland, NRO RZimmerman

ERoach, NRO ACampbell RArrighi

OE R/F

ADAMS ACCESSION NO.: ML13115A953

 

 

Chinese Black Market 2 Stage Safety Relief Valves In Pilgrim Now?

Everyone knows the NRC Blog is a back door method for me to speak to Entergy. So your paragraph is aimed to Entergy too.

Do you think the 2010 3 stage SRVs were "new" valves. Target Rock no longer makes nuclear SRV valves…they haven’t done this for decades. Who even knows where they get repair and replacement parts? This is the world obsolete aged nuclear plants and our times…the manufacturers no longer support their lines or the manufacturer is no longer in business. They reverse engineer these kind or components…we are better reverse engineering than the Chinese now. Worse, companies like target rock blackmail companies like Entergy to get a cut out of reverse engineering because they own the patents with the component. We have big companies who specialize in reverse engineering. Reverse engineering is very dangerous because they don’t keep track of the history of the component or their failure mechanisms. These nuclear junk yard obsolete component vendors and contractors…it is a very lucrative business. Basically for these large manufacturers, the nuclear sector is not sustainable or profitable because no growth and a too small market.

So Pilgrim borrowing the two stage from another plant…this supports the idea of a secret black market in SRVs. Think about it, a plant has a set of standby SRVs, why would they risk a long shutdown if SRV problems show up at their plant. The don’t have enough good SRVs to place in the plant. We think “got SRVs from another plant” is a cover story for we got the 2 stage from the black market nuclear junk yard vendor.

I got a question, why didn't Pilgrim comprehensively refurbish the 2010 2 stage SRVs and have them in their store room just in case? Where did Pilgrim's old 2010 2 stage SRVs go? What plant?

This might all be at the heart of all the SRVs and similar relief valve(PORV) problems in the Industry…components and repair parts not comprehensively supported by a large and reputable USA manufacturer who keeps track of the component failure history. I am a mental freak with my ability to puzzle out an accurate model of these large system (Donald Trump?).

These nuclear component junk dealers and their new or replacement repair parts venders, contractors and specialized businesses…the USA don’t make these small replacement parts anymore. You can call or e-mail over to China the specs on a repair part…they will have the part at your door in a few weeks. They are really hungry for business in china. One wonders the magnitude of this outside the obsolete component business this is? China is notorious with their middleman. The part will be made in a factory…it will go through 5, 10 or even 20 secretive untraceable middlemen before coming to your door.

So I will add your paragraph to the NRC blog. It will be posted on Monday. The value of it is, Entergy and the NRC will see where we are heading. I doubt you will get a straight answer. I am notorious with writing up petitions to the NRC…10 CFR 2.206...they are all waiting for this. If somebody gains new information on this whole deal, if you pass it on to me, I make up a quickie 2.206 and submit it to the NRC. The value of me is I got a long relationship with the NRC, all the companies are watching me, everyone thinks I am highly influential with the agency. As example this spring, on my call, I got two huge NRC special inspection at River Bend nuclear plant. “The Mike Mulligan River Bend special inspections.

Main Steam Safety Relief Valves Buna-N thread seals

***(update) So the  NRC and Entergy says they fixed the actuator with the 400 degree vitol seal material. It is much better material and with a high likelihood of accident survivability. It is much better material than the Buna at first blush. But if they put grade B material in for the actuator seals, what about all the rest materials in the valve and actuator? Please list all the grade B material in the SRVs? They were built as a grade B valve, not a grade A valve.

I am strictly a show me man in nuclear power. I want you to put that valve and actuator on a test stand, mimic the duty of severe accident with 400 degrees. I need a positive repeatable test many times and without leaks.

As far as the SRV problems at Peach Bottom, they seemed to have put in 3 stage SRVs their plants. There has not been any new SRV pressure lift test reportable inaccuracies problem since. They had tons of problems in the setpoint lift test with the 2 stage. Generally it is not required public reporting when a SRV leaks. They might not be using their SRVs like Pilgrim for the cooldowns...thus really not cycling them allowing them to see and report  a failure to operate.       

Forgot-the trajectory of this began as the SRVs actuators seals were first made from asbestos. Asbestos was dangerous and for legal reasons they shifted to silicone seals. Then when they didn’t have a grade A actuator, they went to a grade B actuator with a lower grade seal buna material in it. Then installed 400 degree vitol material. Can you just imagine the fractions of pennies the saved by using the buna.

You can destroy the culture of many people having to play words game here. 

I wonder if the SRVs problems at Peach Bottom continued.  

Originally published on 11/6/12

Now to double check and see if the links work? They are fixed and the last fix of this article happened on Nov 7 at 10:15 am

Right, this grossly rusted picture is from the Vernon Dam emergency power switchyard to Vermont Yankee...we know today the NE Independent System Operator and NRC required them to install a on-site replacement for the dam's capacity with a  4 MW diesel generator before the turn of the year. And VY proposes installing same.

From a nuclear professional, what does this mean?

You notice I submitted my Peach Bottom Petition on Oct 15th and the new Vermont inspection report 2012004 was signed on Oct 31... 

2011008: "During RFO27, Entergy discovered that the SRV Vendor no longer supported the Type-1 SRV actuators which VY had. The vendor recommended replacing the Type 1 actuators with a Type 2 actuator. The Type 1 actuator has silicone thread sealants which are rated up to -390 degrees F while a Type 2 actuator uses BUNA-N polymer which is rated up to 210-250degrees F."

Does this mean only the seal is a type 2, absolutely no. It means the whole actuator is a 225 degree F component. Based on a simpleton nuclear professional assumption, the poor quality at normal temperature and not 400 degree F temperature buna-n critical nuclear safety relief valve should have kicked them into the extent of cause/condition investigation much like the Fort Calhoun recent containment sample valves with 120 degree nitrile elastomers LER (The design temperature limit for the nitrile elastomers used in the valves is 180°F which is acceptable for the normal operating conditions inside Containment of 120°F). Remember the actuator vendor to VY left them out in the blue with no type 1 actuator...I suspect this vendor told all the nuclear plants they supported only type 2 actuator. I am sure the vendor said, tough, or purchase it from somebody else or shutdown. So the VY vendor is: "Parker Hannifin Corporation and dedicated for use in safety class applications by Curtiss-Wright Flow Control Corporation, Target Rock Division."

On the Vermont Yankee SRV actuator LER and within any NRC inspection report on same there is no mention of a "extent of cause/condition investigation" with the SRV seals. This is a fundamental engineering investigatory technique and the missing query indicates fraud and collusion between the NRC and Entergy.    

You see the low standards with how corporation's write License Even Reports... notice Exelon-Peach Bottom  doesn't mention the vendors name on their Safety Relief Valve air actuators seal failure LER. Did Peach Bottom do a "extent of cause/condition" investigation on their dangerous type two 225 degree F SRV valves that should have been qualified for 400 degrees F. Of course not!  This must be collusion and fraud between them all.  

They should have commenced, and the NRC show have demanded....an immediate investigation if other components in the actuator were type 2 components...if these other components couldn't withstand 360 degree heat. That would kicked VY into a Fort Calhoun sample valve air actuator extent of cause/ condition investigation per their Licence Event Report and they would had to declare a 10 CFR 50.73(a)(2)(v)(D). Here is the generic version with Fort Calhoun's air actuator quality problems in containment.   

"This condition is being submitted pursuant to: , Any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident."

I am certain if the NRC knew there was a certain condition where all SRV's would fail in a design accident, that would force VY to immediately shutdown and then get appropriate quality air actuators. And they would have went hunting throughout the industry for dangerous environmentally unqualified less than 225 degrees F actuators and other similar inviromentally unqualified component.

Just to be clear, this is how the NRC speaks to the Vermont Yankee dangerous 225 degree F qualified buna-n SRV that failed at 180 degrees F normal operating temperatures in June 2, 2011 Inspection Report 2011008 for the last time until today's new inspection report.           

"NRC Inspection Report 05000271/2011002 documents an LER closeout review and two Licensee identified Violations related to inoperability of Main Steam Safety Relief Valves (SRVs) due to degraded thread seals. During the 2010 RFO: the pneumatic actuators for the four SRVs were tested and leakage was identified through the shaft-to piston thread seal that was in excess of the design requirement on two of the four SRVs. Material testing determined that the apparent cause of the degraded thread seal condition was thermal degradation. During RFO27, Entergy discovered that the SRV Vendor no longer supported the Type-1 SRV actuators which VY had."

So this is how the NRC explains it today in Vermont Yankee's Inspection Report 2012004　

"During the 2009 refueling outage, Entergy found nitrogen to be leaking from the actuators and determined the actuator stem nut seals were degraded. However, Entergy’s evaluation of the seal incorrectly concluded that the seal material was defective and a new Buna-N seal was installed."

This is Entergy-Vermont Yankee explains it is their revised LER 05000271/2010-002-01.

"During the 2010 refueling outage, the actuators for the four main steam (EIIS=SB) safety relief valves (EIIS=RV)RV-2-71 A, B, C & D, were tested and leakage was identified through the shaft to piston thread seal on three of the four RV actuators."

Is there a difference between "shaft to piston thread seal" and "actuator stem nut seal"...why can't the NRC stay with the same wording they used from the first VY LER and NRC inspection reports.

 

Bottom line after doing a little research, I think the NRC is talking about the same component with the "shaft to piston thread seal" and "actuator stem nuts". I thought it was a completely different new component from yesterday.

But I still think VY should have called a 10 CFR 50.73(a)(2)(v)(D) in the beginning of the SRV seal problem. Those valves are a type 2, remember the vendor cheapskated for pennies savings, installing the buna-n seal into containment. I believe there was, and still are, basically fraud and a cover-up, by knowingly installing environmentally unqualified 225 degree F rubber and  plastic parts in the SRV actuators and possible other components. These guys will fail surprisingly fast in any accident that heats up the containment.  

....     

2nd Petition
Oct 13
Petition On Peach Bottom, VY And Other Unnamed Nuclear Plants

Oct 4
Peach Bottom/Fort Calhoun SRV Seal Questions

*****

1st Petition
Jan 24 then reposted June 11
Emergency Shutdown Of Peach Bottom Over SRV Seals

Feb 01
Peach Bottom SRV Seal Notes

Vermont Yankee Inspection Reports:

2012004 October 31, 2012

2011008 June 2, 2011
2011002 dated April 29, 2010

***Nov 6 2012: I am reposting this...originally posted on April 23, 2011

How this bleeds into the new Pilgrim plant inspection report, it almost looks the NRC and I am working behind the scene...

New Nov 8 
October 31, 2012
Mr. Christopher Wamser
Site Vice President
Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station
Vernon, VT 05354
SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION – NRC INTEGRATED
INSPECTION REPORT 05000271/2012004

2 Annual Sample: Automatic Depressurization System Actuator Leakage

a. Inspection Scope
The inspectors performed an in-depth review of Entergy’s apparent cause analyses and corrective actions associated with the issue of actuator stem leakage on valves in the automatic depressurization system (ADS). Specifically, Entergy identified repeat occurrences of leakage around actuator stems during the 2009 and 2011 refueling outages. The inspectors determined whether Entergy had taken appropriate corrective actions to prevent recurrence of the leakage. Additionally, the inspectors reviewed an operability determination performed during the previous operating cycle following the discovery by Entergy that the seal installed on the ADS actuator stems did not meet environmental qualification requirements.

The inspectors interviewed plant personnel and reviewed test procedure results, condition reports, engineering evaluations, root cause analyses, and manufacturer data to assess Entergy’s problem identification, evaluation, and corrective action effectiveness with respect to the ADS actuator leakage. Specifically, the inspectors reviewed the documents to determine if the seal material used on the ADS actuator stems from 2008 to 2011 should be attributed as the root cause of the 2009 and 2011 stem leakage and to verify that the replacement seal material now installed was qualified for the expected environmental conditions. Additionally, the inspectors reviewed the TS, the UFSAR, and Vermont Yankee licensing documents to assess adverse impact due to the leakage with respect to design basis requirements. Finally, the inspectors evaluated whether the compensatory actions taken by Entergy following identification of the degraded condition provided reasonable assurance of operation of the ADS system during a design basis event and that Entergy’s conclusion that the system remained operable with the degraded condition was correct.


Findings and Observations
No findings were identified.
Entergy modified the actuator system in 2008. However, in consultation with the manufacturer, Entergy incorrectly concluded that the changes to the actuators were “like for like” replacement of components. Entergy failed to determine that the seal material for the actuator stem nut had been changed from Silicon to Buna-N. This change resulted in the temperature rating of the seal dropping from 400 degrees Fahrenheit (F) to 225 degrees F. During the 2009 refueling outage, Entergy found nitrogen to be leaking from the actuators and determined the actuator stem nut seals were degraded. However, Entergy’s evaluation of the seal incorrectly concluded that the seal material was defective and a new Buna-N seal was installed. Entergy performed a subsequent evaluation of the seal material and determined that the material was Buna-N, not defective, and the failure of the material was due to exceeding the thermal rating (225 degrees F) of Buna-N. Following identification that the seal material did not meet environmental conditions, Entergy performed an operability determination which concluded that the ADS system was operable, but degraded. These performance deficiencies were previously evaluated by the NRC in inspection reports 05000271/2011002 and 05000271/2011008.

The ADS system consists of four 3-stage safety relief valves with an actuator attached to the valves so that they can be opened using a nitrogen gas supply. The UFSAR states that nitrogen for the actuation of the valves is stored in accumulators installed in the drywell that are sized to ensure sufficient gas is available for the required number of ADS valve actuations following a design basis accident. This system was credited to respond to design basis accidents and was required to be operable by TS. Additionally, nitrogen bottles were installed outside the drywell to actuate the ADS system following a design basis seismic event. The bottles were sized to allow operators to control reactor pressure using the ADS system for several days following the event. The inspectors determined that this portion of the system had not been evaluated or licensed for design basis accidents other than seismic events.

The inspectors reviewed the evaluations performed by Entergy that assessed past operability of the system prior to the 2011 refueling outage and the operability determination performed during the operating cycle. By crediting the use of the nitrogen bottles, Entergy determined that an adequate nitrogen supply would be available to respond to design basis accidents and events even with the additional loss of inventory from the accumulator stem leakage. Entergy concluded that the ADS system had remained operable because there was adequate nitrogen inventory available. The inspectors questioned whether the bottles and piping would be available for all design basis accidents. In response, Entergy performed an evaluation and concluded the bottle system had been designed to survive the required design basis accidents and would be available. The inspectors reviewed and concurred with the assessment, but noted that the evaluation was not done prior to crediting the system in the 2011 operability determination.

Finally, the inspectors evaluated the corrective action that replaced the Buna-N seal material with Viton®, a flouroelastomer, during the 2011 refueling outage. The inspectors found that this material had the same properties as the previously installed silicon seal,with a temperature rating of 400 degrees F, and met the environmental requirements for the system.

***March 17, 2011

William Borchardt

Executive Director for Operations

US Nuclear Regulatory Commission

Washington, DC 20555-0001

Subject 2.206: Request a emergency shutdown of Vermont Yankee because the Reactor Oversight Program is ineffective and Entergy has a documented history of a culture of falsification and thumbing their noses at reoccurring violations. It should be noted in this inspection period most of the fleet of Entergy’s plants are on fire and burning in the Gulf of Mexico with numerous NRC inspection findings including Palisades, Grand Gulf, River Bend, Arkansas One and Cooper.

Dear Mr. Borchardt,

In the 1942 movie Casablanca:

Rick Blaine: How can you close me up? On what grounds?

Captain Louis Renault: I'm shocked, shocked to find that gambling is going on in here.

Jan 18, 2011: My 2.206 Emergency Shutdown of Vermont Yankee

“The safety culture of the plant is impaired because of information inaccuracies and wide spread acceptance of falsifications.”

“I request Vermont Yankee to be immediately be shut down and that Entergy be prohibited from owning nuclear power plants... because Entergy doesn’t have the integrity to tell the truth about safety and nuclear power plant issues. Money and profits comes before truth telling and full disclosures.”

Inoperability of Main Steam Safety Relief Valves due to Degraded Thread Seals (Licensee Event Report 05000271/2010-002-01)

"During the 2010 refueling outage, the actuators for the four main steam safety relief valves , were tested and leakage was identified through the shaft to piston thread seal on three of the four RV actuators. This leakage, when combined with the RV accumulator leakage, caused two of the four RVs to not meet design actuation requirements. The nitrogen gas is introduced from an accumulator assembly which contains enough gas for two operations at 70% of containment design pressure or approximately five operations at atmospheric pressure...and it is critical for the low pressure core cooling system to work."

These relief valves are the devices used to control pressure in the Fukushima plant meltdowns and they had a terrible time maintaining pressure protection during their accident. They had to operate these valves multiple times and all these valves had is the accumulators and no electricity after the safety batteries wore down. You know that outside nitrogen supply was severed be quickly after the accident.

"The thread seals were manufactured in 2002, supplied to Vermont Yankee (VY) in new style actuators in 2008 and were in service for one operating cycle prior to the test."

They were in there less that 2 years and they don't know if they became dysfunctional within month of heated operation.

"The thread seals in the new style actuators are made of Buna-N material, were manufactured by Parker Hannifin Corporation and dedicated for use in safety class applications by Curtiss-Wright Flow Control Corporation, Target Rock Division. Prior to the upgrade to the new style actuators, the thread seals were made from a silicon material. Material testing determined that the apparent cause of the thread seal condition was thermal degradation. The change to use Buna-N material in the new style seal resulted in reduced thermal margin when considering the potential local heat transfer affects on the seal material. The use of silicone material in the original application provided more margin."

This is atrocious behavior for nuclear safety engineers... they substituted Buna-N material for silicone and they weren’t aware of the properties of the Buna-N material or considered for the heated environment? There must be a testing regime to assure the Buna-N material would survive the heated environment before it was used in the plant....how did that fail? This is a object organizational safety related failure of Quality Assurance and Quality Control. Entergy has construction related QA/QC problem and now it is showing up in the nuclear safety end? It is interesting, the NRC suspects QA/QC problems at the plants and they still allow VY to operate without a all clear signal that it isn't known and corrected. It questions their safety related spare or replacement parts purchase programs...in that they can’t maintain the quality of nuclear grade safety components. It questions, in a widespread manner, if they are substituting inferior replacement parts in all their safety components. How many inferior safety related replacement parts are there in the Vermont Yankee?

This event did potentially affect the ability of the RVs to perform their manual and automatic ADS function since the combined thread seal leakage and accumulator leakage impacted the ability of the RVs to satisfy design actuation requirements. However, due to the redundancy in the ADS design, the availability of the HPCI system and availability of backup nitrogen supplies, the ability to depressurize the reactor was maintained.

VY will replace the Buna-N thread seal material in all four RVs during the 2011 refueling outage with a material that provides more temperature margin. This event did potentially affect the ability of the RVs to perform their manual and automatic ADS function since the combined thread seal leakage and accumulator leakage impacted the ability of the RVs to satisfy design actuation requirements. However, due to the redundancy in the ADS design, the availability of the HPCI system and availability of backup nitrogen supplies, the ability to depressurize the reactor was maintained.

Unbelievable, they knowingly started up with inferior critical nuclear safety parts and they had evidence Buna-N would degrade and fail. I bet you they were gaming uncertainty, we got no proof of the Buna-N has failed yet...so we can start up. I‘ll bet they knew the Buna-N was inappropriate, didn’t have on site the appropriate silicone, so they intentionally started up knowing the part would fail between outages.I bet you they could tell by feel the buna-n was degraded. I’ll bet you the manufacture no longer made this obsolete replacement part. How much sense does it take when the material was in for the first time, it failed, it is common sense it was the new material that bad. Thus is absolutely contemptuous of the design function...that their other systems make this a nothing incidence. They should be thinking this system that can’t stand any unknowns...they should be considering this a last ditch system and assume everything else is broken.

1) This should make you absolutely sickened, they know it’s the wrong material, they knows it fails within the first cycle...and they stuck the same defective material in there knowing the plant won’t meets its Fukushima requirements.

2) Request Vermont Yankee immediately shutdown and they replace there relief valve o ring Buna-N material with silicone. The is the shuttle Challenger accident all over again. Request Vermont Yankee nuclear power plant and all Entergy nuclear power plants be immediately shutdown.

3) Request before startup a investigation on “one for one” safety related replacement parts program...and throughout Entergy...one should consider the Entergy QA/QC investigation ongoing. Is the national oversight of safety related replacement parts quality in nuclear power plants adequate?

4) Request a outside the NRC investigation of this NRC behavior for tolerating this atrocious regulatory behavior.

5) Request top Vermont Yankee Management staff be fired and replaced before startup.

6) Request Entergy’s corporate nuclear senior staff be fired and replaced before the restart of the plants.

...7) Request the formation of a local public oversight panel around every nuclear plant.

...8) Request a emergency NRC senior official oversight panel with the aims of

reforming the ROP.

...9) Request a national NRC oversight panel of outsiders to overseer and report on the agency’s activities. There should be a mixture of professional academic people and capable lay people.

10) There is some heavy duty and exceedingly numerous findings of problems with Entergy plants’ this inspection reporting cycle...do an analysis of why this is occurring.


Sincerely,

Mike Mulligan
Hinsdale, NH
1-603-336-8320
steamshovel2002@yahoo.com