Junk Plant Hope Creek: Paul Krohn and Safety Related "SW Pump Discharge Isolation Valves"

Updated 2/24

The NRC says now, the three valves are in the normal reverse orientation direction and the offending one is in the non-reverse orientation. All four valves after this 2016 refueling outage will be in the reverse engineering direction. The NRC is convinced all the valves will meet their intended safety function with all the new engineering evaluations. The NRC says they gave Hope Creek much value added with sw discharge valve CDBI inspection results. The NRC was always concerned with the level of engineering detail over these valves.   

The NRC seems to be saying prior to 2013 with all of the valves in the normal reverse orientation…they were always operable. I have questions on that. Looking in the reverse mirror might indicate that, but what proof did they have in 2012?

I asked when these SW discharge valves with reverse orientation were installed. They didn’t know for sure. Where they installed on new construction or did they put them in post construction…could you give me the date? Did the NRC give permission with the reverse orientation? They said it would have to go past their boss.      

Updated 2/24

Talk to NRC today about this.


Update 11:44

Cowan, Grace <Grace.Cowan@nrc.gov> Mr. Mulligan, I received your e-mail, and forwarded it to Paul. He’s working in HQs until June, so I wasn’t sure if he was in the office today or not. Sincerely, Sincerely, Grace Grace Cowan US NRC-Region I Division of Reactor Safety 610-337-5070

To: Michael Mulligan

Today at 11:44 AMMr. Mulligan,  I received your e-mail, and forwarded it to Paul.  He’s working in HQs until June, so I wasn’t sure if he was in the office today or not.  Sincerely,  Sincerely,Grace  Grace Cowan

I had a hard time finding NRC's Chief Mr. Krohn today. He is a region I official. He is temporally assigned to duties in Washington. Ms. Cowan seems to be a secretary of some NRC group in Washington. She gave me her e-mail address and told me to write a note to Paul...she'd pass the message along to him.  

Engineering Branch 2 Chief: Paul Krohn

'Hope Creek and Chief Paul Krohn'

From Michael Mulligan <steamshovel2002@yahoo.com>

To: grace.cowan@nrc.gov

Today at 11:26 AM

 

grace.cowan@nrc.gov

paul krohn

Mr. Krohn,

I am a safety advocate. I had recent issues with Hope Creek’s SRV setpoint lift inaccuracies and my issues were placed on the docket. We are watching Hope Creek very carefully. You signed off on the below IR.

Entry on my blog:

“Junk Plant Hope Creek: PSEG's Frivolous Denial Of NRC Non Sited Violation”

http://steamshovel2002.blogspot.com/2016/02/junk-plant-hope-creek-frivolous-psegs.html

 

My friends and I were debating this issue this morning. We think this issue deserves a much higher violation level. 

So why wasn’t Hope Creek required to ask NRC permission to put all the safety related “sw pump discharge isolation valves (4 of them)” in the “intentionally reverse direction”?  Why didn’t they fulfill the requirements of 50:59? Why wasn’t this in the inspection report? Why wasn't the public immediately informed of this licensing deviation through a safety evaluation?  

We feel if Hope Creek was required to ask NRC permission, they would have taken the easy way out and then put in the proper quality valves for the intended duty. They would have properly fixed these leaking valves when the symptoms first was seen?  It’s pretty pathetic the NRC didn’t immediately flip this 2013 event up into a regular inspection report.  

We think collectively Hope Creek and the NRC has systemic “Normalization of Deviance” on steroids big time???

I believe I have spoken to you in the past and you are one of the good guys. Did we talk about the structure of the CDBIs? The public meeting? Do I remember it right, with all the nuke guys bitching about how useless the CDBIs were, and a diversion from safety?   

Could we have a discussion just about this particular issue?

I never have any confidentiality or anonymity needs what-so-ever.

Mike Mulligan

Hinsdale, NH

16032094206

Hope Creek Generating Station - Component Design Bases Inspection Report 05000354/2015007

Description. 1 EAHV-2198C is the 'C' SW pump discharge isolation valve. The valve is a 28- inch Weir Tricentric butterfly valve with a SMB-1/HBC-4 (60-1) Limitorque motor operator. The valve has an active safety function in the open position to provide normal SW flow to the safetyrelated safety auxiliaries cooling system (SACS) heat exchangers (HXs) and non-1 E reactor auxiliaries cooling system (RAGS) HXs, and emergency SW flow to other systems. PSEG had originally intentionally installed all four 1 EAHV-2198 valves in the reverse flow direction to permit the downstream header pressure to seat the valve tighter to minimize seat leakage during SW pump and strainer on-line maintenance.

Junk Plant FitzPatrick Purchasing Junk New Components.

"The previously installed Temperature Transmitters were Fisher Controls transmitters; model PM511, an original electronic transmitter from the 1970s. Model PM511 is obsolete and replacement parts were running out so an Engineering Equivalent Change evaluated using an alternative model. The new Moore Industries
temperature transmitters, model RBT/3W20-40/4-20mA/117 AC/-EZ84.06-LNP-VTD[EX], were procured from Moore Industries International and Nutherm International performed the Commercial Grade Dedication."

The industry would say this equipment would be needed so infrequently that not shutting down when required by tech Specs is, the risk is insignificant. I am saying if the plant doesn’t pay a steep price for incompetence with purchasing poor quality new safety components( shutdown per tech specs), then the industry will keep calling events like this to their doorstep.

Junk Plant FitzPatrick Purchasing Junk New Component.  

LER: 2015-008 

‘Containment Atmosphere Dilution System Reliability Degraded due to Manufacturer Defect in Temperature Transmitters’

Dec 18, 2015: Part 21notification

July 31, 2015: First Failure

On 11/11/2015, a second failure

On December 18, 2015, James A. FitzPatrick Nuclear Power Plant (JAF) was operating at 100 percent power when a 10 CFR 21.21(d)(3)(ii) Notification was received from Nutherm International. It identified a defect in Moore Industries temperature transmitters. Specifically, insulation was damaged in the T2 transformer during assembly which could result in premature failure.

These components were installed starting in June 2015 at 27TT-113A and 27TT-113B in the Containment Atmosphere Dilution (CAD) system. The defect caused failures in July and November which resulted in either the “A” or “B” CAD subsystem isolating. Corrective actions included replacing both temperature transmitters with ones that were confirmed to not contain this defect.

Even though these defective temperature transmitters function appropriately until they fail, this defect reduced the reliability of the CAD system to perform its function for its entire mission time. Therefore, this deficiency resulted in a loss of safety function to mitigate the consequences of an accident, reportable per 10 CFR 50.73(a)(2)(v)(D). Also, a single cause affected the safety function of independent CAD trains, reportable per 10 CFR 50.73(a)(2)(vii)(D); and, this condition existed longer then allowed by Technical Specifications 3.6.3.2, reportable per 10 CFR 50.73(a)(2)(i)(B).

Background

The Containment Atmosphere Dilution (CAD) system [EIIS designation: BB] functions to maintain combustible gas concentrations within the Drywell and Torus [BT] at or below the flammability limits following a postulated loss of coolant accident (LOCA) by diluting hydrogen and oxygen with nitrogen. Also, the CAD system provides the pneumatic supply to instruments and controls inside the Drywell; including the long term (100 day) pneumatic supply to the Automatic Depressurization System (ADS) valves [SB] and accumulators following a LOCA…

Event Description 

On December 18, 2015, James A. FitzPatrick Nuclear Power Plant (JAF) was operating at 100 percent power when a 10 CFR 21.21(d)(3)(ii) Notification was received from Nutherm International. It identified a defect in Moore Industries Resistance Temperature Detector (RTD) temperature transmitters supplied to JAF. The transmitters were installed at 27TT-113A and 27TT-113B in the CAD System. A failure of 27TT-113A initiates a closure of CAD subsystem “A” isolation valves 27AOV-128A and 27AOV-129A. A failure of 27TT-113B initiates a closure of CAD subsystem “B” isolation valves 27AOV-128B and 27AOV-129B. Isolating either CAD subsystem impacts the containment makeup capability and the Instrument Nitrogen Header. An Operability Evaluation determined that this defect reduced the reliability of the CAD system such that it may not be able to meet its full 100 day mission time.

This condition was reported to the NRC per 10 CFR 50.72(b)(3)(v)(D), ENS 51613, as a condition which could have prevented the fulfillment of a safety function to mitigate the consequence of an accident.

Event Analysis

The previously installed Temperature Transmitters were Fisher Controls transmitters; model PM511, an original electronic transmitter from the 1970s. Model PM511 is obsolete and replacement parts were running out so an Engineering Equivalent Change evaluated using an alternative model. The new Moore Industries temperature transmitters, model RBT/3W20-40/4-20mA/117 AC/-EZ84.06-LNP-VTD[EX], were procured from Moore Industries International and Nutherm International performed the Commercial Grade Dedication.

The new Moore temperature transmitter contained a defect which first failed on 7/31/2015 in 27TT-113A.

When 27TT-113A failed the “A” CAD subsystem automatically isolated by closing the supply valve 27AOV 128A and backup valve 27AOV-129A. This failure was initially identified as component infant mortality and the component was replaced with a spare component.

On 11/11/2015, a second failure of a new Moore temperature transmitter occurred at 27TT-113B. In a similar fashion to the 7/31/2015 failure, “B” CAD subsystem automatically isolated by closing the supply valve 27AOV-128B and backup valve 27AOV-129B. Based on this now being the second failure of newly installed components, there was increased scrutiny placed on this failure. The components were returned to Nutherm to perform a failure analysis.

The December 18, 2015, Part 21 notification from Nutherm informed JAF that the wire insulation in T2 transformer on the Moore Industries RTD temperature transmitter was damaged during assembly. This damage reduced the insulation resistance and dielectric breakdown between the windings of the transformer; resulting in premature failure of the temperature transmitter.

It has been determined that no visual inspection of the transformer or testing after the transformer is installed will discover this defect. This defect can only be found by performing testing on the transformer prior to installation.

The investigation into the two failures on 7/31 and 11/11 became the driving force which led to the Part 21 Notification on 12/18. The replacement spares installed after the two failures were the two serial numbered components included in the Part 21 Notification made to JAF. The removed failed components were also determined to contain the same defect as the Part 21 Notification.

With no method available to inspect the potentially degraded subcomponent after installation, there is not a reasonable assurance the two components would have been able to meet their required 100 day mission time. This condition could have prevented the fulfillment of a safety function, reportable per 10 CFR 50.73(a)(2)(v)(D). This condition caused two independent trains to be Inoperable in a single system designed to mitigate the consequence of an accident, reportable per 10 CFR 50.73(a)(2)(vii)(D). Technical Specification (TS) 3.6.3.2 requires the CAD system to have two Operable subsystems. On June 17, 2015, when the first defective temperature transmitter was installed, “A” subsystem was Inoperable. Required Action A.1 of the TS requires that it be restored within 30 days. On July 2, 2015, a second CAD subsystem became Inoperable when a second defective temperature transmitter was installed. Required Action B.2 requires that one CAD subsystem be restored within 7 days. When this was not accomplished, Required Action C.1 requires that the plant be in Mode 3 within 12 hours. Since JAF was not in Mode 3 within the required completion time, this event was a condition prohibited by Technical Specifications, reportable per 10 CFR 50.73(a)(2)(i)(B).

Cause

The cause of this event is a defect introduced during the manufacturing of temperature transmitters 27TT- 113A and 27TT-113B installed in the Containment Atmosphere Dilution system which resulted in decreased system reliability.

  

Junk Plant June 2012 Announcement of Special Unit Investigation

NRC special unit launches investigation into potential wrongdoing at Palisades nuclear plant related to leaking tank

By Fritz Klug | fklug@mlive.com

on June 27, 2012 at 6:35 PM, updated June 27, 2012 at 8:58 PM
 COVERT, MI — A special unit of the Nuclear Regulatory Commission is investigating whether there was any wrongdoing related to how Entergy Energy handled a leaking cooling tank at the Palisades nuclear power plant.
 The investigation was launched Tuesday by the NRC's Office of Investigations, according to NRC spokeswoman Viktoria Mitlyng. Entergy shut Palisades down two weeks ago after a leak in a cooling tank surpassed a minimum level of 31 gallons a day. Mitlyng said Wednesday that the NRC cannot disclose details of the investigation because it is ongoing. Entergy spokesman Mark Savage would not comment on the investigation. Instead of looking for performance deficiencies at the

Why is the normal inspectors only relegated to only performance issues?  

plant as is typical of NRC investigations, the Office of Investigations looks at whether there was any "potential wrongdoing" in how the company handled a situation and the its participation in an inspection…

52 shares

Junk Plant Palisades Safety Culture

So basically on top of the control room sat the SIRWT. On top of of the SIRWT was the leaking roof. The roof and the SIRWT were both leaking. It looked to me the confusion with the leaking roof was intentional in covering up the Leaking SIRWT. They were certainly trying to disrupt oversight and delaying the repair of the SIRWT until proper planning and service were brought to the site.

It would be interesting when the NRC was first aware falsification was ongoing.

On June 25, 2012, the U.S. Nuclear Regulatory Commission’s Office of Investigations initiated an investigation to determine whether personnel at the Palisades Nuclear Power Plant(Palisades) deliberately failed to provide complete and accurate information to the NRC regarding a safety injection and refueling water storage tank (SIRWT) leak. The investigation was completed on March 10, 2015.

Would the outcome be different on my 2.206 if the NRC disclose four individuals were being prosecuted for falsifying documents on the SIRWT instead of three year later?

Mike Mulligan's 2.206 on the Palisades SIRW tank. 

November 20, 2012

Mr. Michael Mulligan

P.O. Box 161

Hinsdale, NH 03451

Dear Mr. Mulligan: 

You recently submitted two petitions addressed to Mr. William Borchardt, Executive Director for Operations at the U.S. Nuclear Regulatory Commission (NRC). The petitions were referred to\ the NRC’s Office of Nuclear Reactor Regulation pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 2.206.

In your first petition dated June 18, 2012, as revised on June 27, 2012, you requested that the Palisades Nuclear Plant (Palisades) remain shutdown. In the petition, you were critical of Entergy Nuclear, the NRC, and the programmatic aspects of the regulatory program, including the Reactor Oversight Process (ROP). You focused on a leak of the Safety Injection Refueling Water (SIRW) tank at Palisades, but also discussed past events at both Palisades and other

Entergy-owned facilities. Finally, you also discussed the lack of an adequate safety culture environment at Palisades.

You requested that the following actions be taken:

(1) The shutdown resulting from the SIRW tank leak should be categorized as unplanned. 

(2) The NRC should move the Palisades performance indicator from Red to the next level V:Unacceptable Performance. 

(3) An outside authority (not the NRC’s Office of the Inspector General (OIG)) should determine why the NRC did not force Palisades (Entergy) to thoroughly investigate the SIRW leak when the leak first appeared. 

(4) Top Palisades management staff should be fired and replaced before startup. 

(5) Entergy’s corporate nuclear senior staff should be fired and replaced before restart. 

(6) The NRC should assign two additional NRC inspectors to Palisades and to the rest of the Entergy nuclear plants. 

(7) A local public oversight panel should be formed around every plant. 

(8) An emergency NRC senior official oversight panel should be convened to reform the ROP.

(9) A national NRC oversight panel of outsiders (consisting of a mixture of professional and academic people, as well as lay people) should be convened to oversee and report on agency activities.

(10) The NRC should perform an analysis to determine the cause of the numerous findings of problems with Entergy plants during this inspection reporting cycle.

(11) The NRC should evaluate if Region III has enough personnel and resources.

(12) Palisades should remain shutdown until all procedures are fully updated and corrected, all technical and maintenance backlogs are updated and corrected, all training completed, and all reports and safety processes are fully completed and implemented. 

(13) An independent outside investigation should review the insufficient process outcome of the 2008-2009 Palisades security falsification, investigation, safety survey local and fleet-wide training and safety surveys.

(14) President Obama should fire Chairman Jazcko and the four Commissioners.

In the second petition dated June 28, 2012, you requested that Palisades remain shutdown. 

This petition was focused on roof leaks at Palisades, but also discussed past events at both Palisades and other Entergy-owned facilities. You discussed a lack of adequate safety culture environment at Palisades, and were also critical of the NRC staff for “tolerating and covering up” very serious safety problems at Palisades and throughout the Entergy organization. This petition also included specific questions related to roof leaks.

This petition duplicated many of your requests discussed in the previous petition. However, in your second petition there were new requests which are provided below:

(15) Entergy should be prevented from starting up until all the safety problems at the site have been publicly identified and the safety culture repaired. 

(16) Heads need to roll in Region III and at headquarters for tolerating and covering up these very serious safety problems at Palisades and throughout the Entergy organization. This all has the potential to gravely damage our nation.

(17) The NRC should report on why the 2.206 petition process failed, and for the agency to hold officials accountable to the plant employees and me with not doing their jobs in trying to understand what was going on at the site and not repairing the organization at the earliest point.

(18) A meeting with the Palisades inspector and other…

Junk Grand Gulf Capacity factor

Feb 23 0%
22 0%
21 0%
20 0%
19 95%
18 95%
17 95%
16 95%
15 96%
14 96%
13 96%
12 96%

Usually it is in a paper if a plant goes into refueling. I would not spend so much time on this if Entergy reported the  refueling in the paper.

Sounds like they got failed fuel pin failures????

Grand Gulf has been saying for almost a year they are coasting down to refueling. I guess you can say there is a slow decline in the power level. They problem is this has been going on for about three months. 

Dec 23, 2015:

Grand Gulf 1

98

HOLD FOR SETUP FOR POWER SUPPRESSION TESTING

Dec 11

97

INCREASING POWER

*

Seems Grand Gulf has been having trouble keeping their plant at power.

GRAND GULF NUCLEAR STATION - NRC 95001 SUPPLEMENTAL INSPECTION REPORT 05000416/2014009 (Aug 2014)  

Dear Mr. Mulligan (not me): On June 20, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental inspection at your Grand Gulf Nuclear Station. The enclosed report documents the results of this inspection, which were discussed with you and members of your staff, during an exit meeting on June 20, 2014, as well as during the re-exit meeting on August 6, 2014, with members of your staff. As required by the NRC Reactor Oversight Process Action Matrix, this supplemental inspection was performed in accordance with Inspection Procedure 95001, “Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area.” The purpose of the inspection was to examine the causes for, and actions taken related to, a White Performance Indicator in the Initiating Events Cornerstone at Grand Gulf Nuclear Station. The performance indicator was for Unplanned Reactor Scrams per 7,000 Critical Hours and crossed the Green-to-White threshold during the first quarter of 2013. The performance indicator value was noted as 3.2. This inspection also reviewed the details of all five licensee event reports that were submitted to the NRC for unplanned scram events that occurred between the dates of December 29, 2012 and March 17, 2014. There was an additional unplanned scram event that occurred on March 29, 2014, but due to a vendor review in process, the root cause evaluation was not complete for this inspection period. Thus, the licensee event report for that event will not be addressed in this report.

201501 

Corrective actions associated with the adverse trend are:

• The licensee has taken action already to increase staff allocation in the electrical field so that there are more staff to accomplish the preventative maintenance tasks. Currently, the licensee has identified that there is a shortage of electrical workers and is actively working to increase staff.

November 13, 2015

SUBJECT: GRAND GULF NUCLEAR GENERATING STATION, UNIT 1– NRC

COMPONENT DESIGN BASES INSPECTION REPORT 05000416/2015007


Dear Mr. Mulligan:

On October 1, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station Unit 1. On August 27, 2015, the NRC inspectors discussed the preliminary results of this inspection with you and other members of your staff. On October 1, 2015, the NRC inspectors discussed the final results of this inspection with you and other members of your staff.

Inspectors documented the results of this inspection in the enclosed inspection report. The NRC inspectors documented seven findings of very low safety significance (Green) in this report. All of these findings involved violations of NRC requirements; one of these violations was determined to be Severity Level IV under the traditional enforcement process. Additionally,

the NRC inspectors documented three Severity Level IV violations with no associated finding.

The NRC is treating these violations as non…

Security related violations and a security related OI investigation are always a symptom a plant is running away from management. 

GRAND GULF NUCLEAR STATION – NRC SECURITY INSPECTION REPORT 05000416/2015404

Dear Mr. Mulligan:

On October 8, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a security inspection at the Grand Gulf Nuclear Station. An NRC inspector discussed the results of this inspection with you and other members of your staff. The inspector documented the results of this inspection in the enclosed inspection report. NRC inspectors documented three findings of very low security significance (Green) in this report. All of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NVCs) consistent with Section 2.3.2.a of the Enforcement

Policy
 

Dear Mr. Mulligan:

This letter refers to the investigation conducted by the U.S. Nuclear Regulatory

Commission's Office of Investigations, Region IV, at Grand Gulf Nuclear Station; Inspection Report 05000416/2015406 enclosed. The purpose of the investigation was to determine if there was a willful security-related violation at the Grand Gulf Nuclear Station. Following notification by Grand Gulf Nuclear Station staff of a potential willful security-related violation the NRC initiated an investigation on February 26, 2014. The investigation was completed on February 25, 2015. Based on the evidence developed during the investigation, the NRC

determined that a willful security-related violation occurred. The enclosed inspection report documents the inspection results, which were discussed on July 16, 2015, with Paul Salgado, Acting Director of Regulatory Assurance and Performance Improvement, and other members of your staff.

Palisades: My Proof The Junk NRC Is Corrupt As Hell.

I see the delay, this way the NRC and outsiders can't make the case there was a pattern of falsification going on in Palisades and Entergy.

You know what injustice is, Justice delayed.  

Just think if the NRC declared Palisades as a corrupt plant in May 2011 over the SIRWT...they told Palisades to shutdown and then said we are going to systematically shutdown your plants one by one for the foreseeable future until you thoroughly reform your organization from the top down.

Why did it take OI till now to come up with these violations? 

There is no doubt these Palisades extremely smart and corrupt officials were playing the NRC like a fiddle. Any plant operator can play the NRC like a fiddle because of a corrupt congress and rules. 

All the below would have never happened if Entergy would have had a near death experiance inflected on them by the NRC in and around the spring of 2011.  

On May 18, 2011 beginning of the SIRWT problem 

September 25, 2011: DC Cabinet short red finding 

March 31, 2013: One dead and eight injured at Arkansas Nuclear One  

2015: Pilgrim LOOP and notice of closing Pilgrim plant by Entergy.

They illegally falsified documents to keep this plant unsafely up a power and to keep the money coming into the coffers.

Think about this, with the OSHA recent finding Palisades had intimidated their security offices, while the NRC with the same information found no employee intimidation. 

February 22, 2015

EA–15–039
Mr. Anthony Vitale
Vice President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Covert, MI 49043–9530

SUBJECT: PALISADES NUCLEAR PLANT, INSPECTION REPORT 05000255/2015013; INVESTIGATION REPORT 3–2012–021; AND APPARENT VIOLATIONS

Dear Mr. Vitale: 

This is in reference to an investigation completed on March 10, 2015, by the U.S. Nuclear Regulatory Commission's (NRC’s) Office of Investigations (OI) at your Palisades Nuclear Plant(Palisades). The purpose of the investigation was to determine whether personnel at Palisades deliberately failed to provide complete and accurate information to the NRC regarding a safety injection and refueling water storage tank (SIRWT) leak. A Factual Summary, included as Enclosure 1 to this letter, provides a summary of the factual basis for the apparent violations.

This is basically industry protection.They are trying to minimize this. Every separate piece of paper falsified should be treated a seperate violation.

It is like me robbing three separate banks at gunpoint and the NRC only charges me with one crime because I used the same gun in all the robberies. They immediately knew who did the three robberies, but inexplicable charged me a decade later. Who gains the advantage with this.      

Based on the results of NRC’s review of this investigation, three apparent violations were identified and are being considered for escalated enforcement action in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC’s website at

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. 

It appears to the NRC that parts of these violations were willful as described in the enclosed factual summary. The first apparent violation involves the willful failure, on the part of four individuals, to enter information concerning a leak in the SIRWT into the corrective action program as required by Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V and procedure EN–LI–102, Revision 16. The second apparent violation involves the failure to perform adequate operability determinations of conditions associated with the SIRWT leak as required by 10 CFR Part 50, Appendix B, Criterion V and procedure EN–OP–104, Revision 5. The third apparent violation involves the apparent failure to comply with Technical Specification (TS), surveillance requirement Section SR 3.0.3, when you failed to perform the...

NRC Thinks Non Compliance to Rules (Moral Hazard) Is No Big Deal

They are improperly using The Risk-Informed Approach.

They have no proof the “Risk-Informed Approach is accurate or is qualified for safety relativeness.

All big accidents and institutional failures emerge from insignificant operability issues. Can the NRC distinguish between accident creating compliance issues from insignificant compliance issues.  

You notice how the agency never asked the question if the non-compliance was intentional or malicious.  

Basically the industry and the NRC  are saying something like a bank robbery under $500 isn't a enforceable crime. It creates insignificant harm to the bank and society at large. So they don't enforce bank robberies under $500? 

In economics, moral hazard occurs when one person takes more risks because someone else bears the cost of those risks. A moral hazard may occur where the actions of one party may change to the detriment of another after a financial transaction has taken place. 

Moral hazard occurs under a type of information asymmetry where the risk-taking party to a transaction knows more about its intentions than the party paying the consequences of the risk. More broadly, moral hazard occurs when the party with more information about its actions or intentions has a tendency or incentive to behave inappropriately from the perspective of the party with less information.

Remember the NRC and industry were fighting like hell to keep the leaking Davis Besse up at power. There is a lot of black swans out there that disproves the insignificance  not compliance issue. The NRC had that a small LOCA and increasing pressurizer level was a problem before TMI. They defined it as insignificant safety issue.  The operator's not have a real time indication of PWR vessel level and a malfunctioning pressurizer relief valve (PORV) would never lead to a meltdown.

The agency would have to prove that insignificant compliance issues never leads to significant safety problems.       

WIKI: Moral hazard also arises in a principal–agent problem, where one party, called an agent, acts on behalf of another party, called the principal. The agent usually has more information about his or her actions or intentions than the principal does, because the principal usually cannot completely monitor the agent. The agent may have an incentive to act inappropriately (from the viewpoint of the principal) if the interests of the agent and the principal are not aligned.

But what about the moral hazards   

‘Operability Meeting’ A Risk-Informed Approach for Addressing Low Risk Compliance Issues Robert Elliott, Branch ChiefTechnical Specifications BranchU.S. Nuclear Regulatory CommissionFebruary 3, 2016  Section 1.5 of the NRC Enforcement PolicyStates: – “The NRC also has the authority to exercise discretion to permit continued operations—despite the existence of a noncompliance—where the noncompliance is not significant from a risk perspective and does not, in the particular circumstances, pose an undue risk to public health and safety. When noncompliance with NRC requirements occurs, the NRC must evaluate the degree of risk posed by that noncompliance to determine whether immediate action is required.“ – “Since some requirements are more important to safety than others, the NRC endeavors to use a risk-informed approach when applying NRC resources to the oversight of licensed activities, including enforcement activities.” • The NRC is considering development of a new process to facilitate resolution of low risk/low safety significance compliance issues that could affect operability.
 – When engaging a licensee on a degraded or nonconforming condition operability issue, the licensee/staff would assess the risk associated with the licensee’s condition. – If the condition is demonstrated to be low safety/risk significance, the staff would engage the licensee on a timetable for corrective action and appropriate interim compensatory measures.

Dr. Bill Corcoran's "Non Answer" Explanation.

Dr. Bill Corcoran

 February 10, 2016 at 5:42 am

The non-answer is a nonresponsive reply to a question. A non-answer can take the form of “I already told you the answer”, the form of an answer to a different question, or the form of an evasion.

A non-answer is slick and sleazy. It turns the stomach. A non-answer is like the tarpaulin over the pick-up truck cargo bed on the way to the landfill; it covers everything required by law and conceals the trash and filth.

Non-answers are a form of bullying. They make use of a position of power to stiff-arm the concerned questioner. They exploit asymmetric relationships.

Non-answers are a form of intellectual corruption. They impede honest dialogue. They are dismissively disrespectful of due process. Historically, non-answers have been used by intellectually corrupt regimes to create a chilling effect on honest dissent.

Once an organization perceives that it has used the non-answer to avoid admitting prior incompetence, lack of integrity, noncompliance, and/or lack of transparency, a precedent has been set. The non-answer becomes an accepted way of life, a part of the intellectually corrupt culture that pervades the agency. When management accepts non-answers to stakeholders it provides a convenient way to evade accountability.

Once the agency accepts non-answers to its critics it begins to accept non-answers from those it oversees. What were the roles of non-answers in agency embarrassing shortfalls such as the Callaway Xenon Shutdown, the Peach Bottom Sleeping Guards and the Davis-Besse 2002 Imprudent Extension?

Non-answers erode public confidence in the fundamental technologies. By not expressing outrage at non-answers to stakeholders the industries are driving nails into their own coffins.

Junk Plant ANO: Plant Spinning Wildly Out Of Control, Raising Power Level Will Fix It?

Licensee Event Report 50-313/2015-001-00

Manual Reactor Trip Due to Oscillations in the Feedwater System

On December 15, 2015, at approximately 0544, Arkansas Nuclear One, Unit 1 (ANO-1), manually scrammed during a scheduled automatic down power to 35% power for planned maintenance. The Integrated Control System (ICS) (JB) was being utilized for the down power. During the down power, oscillations occurred in the Main Feedwater (MFW) (SJ) system. The ICS was placed in manual and efforts were made to dampen the MFW oscillations. The Operators manually tripped the reactor from approximately 43% power when it became evident that an automatic reactor trip was imminent, based on the observed Reactor Coolant System (RCS) (AB) pressure rise caused by the significant reduction in MFW flow. The direct cause of the manual plant trip is currently considered a result of placing the “B” startup valve in HAND (manual) when the valve was ~36% open, which resulted in a significant underfeed condition of the “B” Once-Through Steam Generator (OTSG). There are currently two root causes considered for this condition: (1) inadequate maintenance practices applied to the ICS modules, and (2) inadequate procedural guidance to address ICS malfunctions.

Event Cause 

The direct cause of the manual plant trip is currently considered a result of placing the “B” startup valve in HAND when the valve was ~36% open, which resulted in a significant underfeed condition of the “B” OTSG. There are currently two root causes considered for this condition: (1) inadequate maintenance practices applied to the ICS modules, and (2) inadequate procedural guidance to address ICS malfunctions.

Just because a licensee says it is the most conservative means to the NRC it is the most conservative. 

So basically nuclear safety relay maintenance problems with poor operator training and poor procedures. They assumed though raising plant power level they understood what was going on in the plant…but it was spinning wildly out of control. It is the certainty/ uncertainty gaming…they assume they knew what was going on, but in actuality the plant was spinning wildly out of control. So it’s the operator’s management in the control room duty to perceive things are out of control…then to conservatively scram. It would have headed off the dangerous feed water flow oscillations.   

Remember the NRC thinks this is the worst plant in the USA. They killed an employee and injured eight others through not following procedures by dropping a 600 ton stater. A pipe broke through this, they (NRC and ANO) then accidentally discovered serous flooding vulnerabilities. These guys had many years since this to get their stuff in one sock…the results of this down power should have never happened. They are still not fixed and dangerous operators of nuclear plants.   

The difference in the RCS cold-leg temperatures continued to build as the plant stabilized. With the “B” MFW low-load control valve considered non-functional, it was determined that the most conservative action would be to raise power slightly so the MFW block valves would re-open and the MFW pumps would shift back to the “Flow Control” mode. A slight power increase using the ICS station in manual was initiated at ~ 0455. Power began to rise as expected and the RCS Tcold condition improved as MFW flows became more evenly matched due to increased feedwater flow to the “A” OTSG.