NRC "having fun" over Vermont Yankee 2.206

I requested a NRC OIG investigation concerning these events...both in writing and in a phone call. Nobody was in the NRC OIG home, so I left my telephone number and name, no courtesy call or note as of yet that the NRC OIG had received my complaint.

Why didn't I hear something like these "petitions are a sacred" responsibilities "instead of have fun"...

As a note, the NRC had no intention for this women NRC official to speak as this meeting, and she said nothing...so why the fun comment?
　
Public Participation

The point I make, is public participation fun for the NRC, they don't take it as a serious business.

NRC "having fun" over Vermont Yankee 2.206

So I am on the phone bridge this morning...Feb 3, 2011...I identify myself to the mechanical voice message system, then I am just kind of waiting around in silence on the phone waiting for them to push the button to join the conference. There are people on the voice bridge, and then there are NRC officials in one or more rooms on a speaker phone device.

All of a sudden I hear a click, I hear the snippet "and have a little fun", then I hear the talking of all the NRC officials, then the "welcome to this 2.206 petition...". All the background chatter of the officials stops...then we are off to the races with the 2.206 processes. From this point on everything is recorded in the NRC ops center and it is transcribed for addition into the public record.

They do the introduction, then they give me the microphone so to speak. I say I got to get this down on the record. I just heard a snippet of "and have a little fun" when I first came into the meeting, when I was connected to the phone bridge...what did you mean by this? It was a male voice talking to a female. I am thinking two NRC officials were talking about outside activities, but you never can tell what is behind it. I said to myself too, they just might be talking about have having a little fun with me in the meeting.

The chairman of the petition board pops up on the phone connections explaining, "I was introducing a new NRC official to the petition board and I was telling her to have a little fun as she participates and listens to your review board" concerning tritium and root cause analyze issues at Vermont Yankee.

Can you imagine a 2.206 petition meeting chairman indoctrinating a new NRC official into the petition process by saying have a little fun with it?  Are they all laughing and making faces behind my back as I am stuttering, stammering and fumbling my way through my speech. Are they laughing and having a little fun over us all?

Shumlin calls for Vermont Yankee oversight committee

In his own words:
Gov. Peter Shumlin calls for Vermont Yankee Reliability Oversight Committee, citing tritium leaks

Governor calls for Vermont Yankee oversight committee
Terri Hallenbeck, Free Press Staff • Tuesday, February 1, 2011
MONTPELIER -- Gov. Peter Shumlin announced Tuesday morning that he will form a five-person Reliability Oversight Committee to offer him expert advice.
Shumlin, a vocal critic of the Vernon nuclear power plant who took office as governor last month, said the panel will help the state with oversight of the recent discovery of radioactive tritium in a different location from what was reported a year ago. The committee will also advise the state on planning for decommissioning of the plant...

New NRC Blog

Welcome to the new NRC Blog. We are excited about using this new communications tool and hope it will increase our collaboration and interaction with the public. The blog is intended to serve as a vehicle for informing, explaining and clarifying the actions, roles and responsibilities of the NRC, raising awareness about our agency and its mission, and – most importantly – giving us an opportunity to hear from you.

2.206 liquid scintillation counter emergency evacuation delay

I withdrew this 2.206!


I could inquire about the hydrogen production and release in a accident, then turning into water, but that be nit picking. I have no bases for a 2.206 and will not sunmit one.
Mike,
The liquid scintillation counter at Vermont Yankee is only used for tritium analysis. It is not used in any accident scenario.
NRC Public Affairs
Waiting as answer:
Mr Sheehan,
"He determined that the liquid scintillation counter is not vital to the plant’s radiological emergency response."
So it played no role in the radiological emergency response?
Was there training and practice with a loss of scintillation detector accident?
Mr Sheehan,
"All he had to say is the liquid scintillation counter plays no role in the radiological response?"
Are you saying the scintillation counter plays no role in radiological emergency response capability, or the lead up to the detection of a radiological emergency condition?

I didn't send in the 2.206...but I asked Neil Sheehan about it.
Jan 31 11:00 What does this mean?
...Mr. Mulligan,
A staffer in the Region I Division of Reactor Safety I has reviewed the issue and its potential impact on Vermont Yankee’s radiological emergency response capability. He determined that the liquid scintillation counter is not vital to the plant’s radiological emergency response. In fact, in-line beta-gamma monitors are used for real-time emergency response indications and dose-significant radionuclides are measured via gamma spectroscopy counters in the chemistry laboratory, based on sample measurements. There is sufficient redundancy in the in-line plant monitors and chemistry laboratory gamma monitors to evaluate radiological conditions affecting emergency response. Therefore, there is no safety concern associated with out-of-service liquid scintillation counting equipment with respect to emergency response capabilities.
I hope this addresses your concerns.
Neil Sheehan


Jan 30, 2011
R. William Borchardt
Executive Director for Operations
US Nuclear Regulatory Commission
Washington, DC 20555-0001

Subject: 10 C.F.R. § 2.206 Request a emergency shutdown of Vermont Yankee because the radiological and evacuation emergency procedures and plans were secretly inoperable or impaired between Dec 29, 2010 and Jan 11, 2011.


Dear Mr. Borchardt,

“Rutland Herald Susan Smallheer Jan 29
Irwin said the failure of the test equipment was disturbing.
They told me about the liquid scintillation counter being down and that was the cause of the delay. Irwin said, I figured like most labs, they would get the instrument repaired relatively quickly but for some reason that did not the case.
Irwin said that he only found out about the equipment failure last Friday (Feb 21?) (disclosed at the end of the week Jan 28, 2011), when he asked why the test results form the first well were so late.”


Timeline with Vermont Yankee events: http://steamshovel2002.blogspot.com/2011/01/vt-gov-shumlin-patsy-to-entergy.html


I request a immediate emergency shutdown of Vermont Yankee because of the unreliability of their radiological and emergency plans for a indeterminate amount time. The liquid scintillation counter was broken between Dec 29, 2010 and Jan 11, 2011. That makes the radiological procedures inoperative or severely degraded in this time frame. Not having a backup liquid scintillation counter would make the emergency evacuation plans unreliable. If a nuclear power plant doesn’t have the capability to make reliable their evacuation plans, then they shouldn’t be licensed to operate a nuclear plant.

1) I request a NRC OIG and congressional investigation with why the NRC didn’t immediately notify the community that the Vermont Yankee radiological procedures and evacuation plans were not functional during these dates.

2) Request a investigation, in making sure that all radiological capabilities at the nuclear plants are reliable and durable with sufficient back ups in order to be able to carry out their emergency plans. Request all USA plants have sufficient back up liquid scintillation counter capabilities.

3) Request a information notice to given to all plants about this.

4) Request a disclosure of all delays with getting any radiological measurements that effected any normal or emergency requirement of a procedure.

Sincerely,

Mike Mulligan
Hinsdale, NH 03451
1-603-336-8320
steamshovel2002@yahoo.com

(I know they get a rough measure of liquid radioactivity from other detectors...the downfall in this is I am not exactly clear what the scintillation detector plays in the radiological plans. It seems preposterous the agency would let them get away with ineffective emergency evacuation plans.

You know, if it ain't defined as safety related and in a requirement of a procedure, they let the world fall off a cliff.)

2.206 on VY plant stack...not safety related.

2.206 on plant stack...not safety related.

Requested immediate shutdown of Vermont Yankee because the plant stack is not safety related. This questions maintaining the safety quality of the stack and it associated equipment and piping...the protection of the public...thus assurance of safety and dose limits can't be maintained at my town of Hinsdale NH.

If the stack toppled over it would take two years or more before it was discovered.

Request all plants in the USA with similar stacks be shut down because there is no assurance of radiological safety and functionality of the plant stack.

Aren't you dying to get the NRC on the record saying the plant stack is not safety related...the stack is visual icon for the whole area...the NRC is saying through the AOG tritium issues you could chop off the stack at the base and the plant could still operate. It is not safety related...

I wonder what the tech spec requirements are if the stack toppled over...how long could they operate without the stack?

They were supposed to have the RCA inspectors talking who wrote the report in the meeting...they withdrew them at the last minute.


Rich, the station chief said really astonished, mike, what you are asking for is a national standard of RCA. I said, you bet we should be doing that..

They basically said we enforce the RCA procedures Entergy writes even if they don't make sense...we don't have our own.

They had absolutely no idea what the engineering characterization of the tunnel was...was it a radioactive barrier?
They both said, what happened greater than three year ago is irrelevant to what the NRC does. We only regulate in a three year window...nothing matters in excess of three years.

I am sorry, I always have had issues with people being intentionally evasive to me, I pressed them a little, I though I behave myself.

You want my opinion, they maintain their profile as small as possible, they are a nothing neutral gray...there object is to make as small a wave as they can.

Mike

Washington Snow Storm

I would be surprised if the NRC could keep their date with me for our teleconference with the DC snow.

....rescheduled for tomorrow at 1pm

4:00pm: Fascinating isn't it...The Space Shuttle Challenger disaster occurred on January 28, 1986...

Space disasters still have lessons to teach

http://www.msnbc.msn.com/id/41279886/ns/technology_and_science-space/


The Apollo fire, on Jan. 27, 1967 , was made possible by a decision to believe that flammability in pressurized pure oxygen couldn’t be that bad, even if no tests had been run to check out that convenient assumption.

The loss of Challenger, on Jan. 28, 1986 , was made possible by the decision that even though flexible O-ring seals had never been verified to function properly at sub-freezing temperatures, it was convenient to assume they would still do so in the absence of tests proving otherwise.

The loss of Columbia, on Feb. 1, 2003, was made possible by the decision — set down in writing — that even though observers suspected that tank debris might have hit the panel-covered leading edge of the shuttle's left wing, those panels were "probably" just as tough as other tile-covered areas that were previously hit. As was the case for the earlier tragedies, this was a claim that had never been tested.

Appallingly, in hindsight, when tests were made, they showed hazards that should never have been "assumed away." Pure oxygen fires were horrifically violent. Flexible pressure seals at low temperatures did not seat properly in their slots when hit by rocket thrust. And a leading-edge panel hit by a flying piece of insulation didn’t just get scratched — it shattered.

RCA

Jan 28....I sent the 2.206 and within two days VY admitted another leak.

...Buildings in plume being explosive hazard...was the DG threatened.

...Has the gaseous tritium been accounted for...about 3 curies.?

...How about a hydrogen detonation of the drain pit building or any nearby buildings where hydrogen and oxygen can seep into?

..Entergy's causal evaluation identified deficiencies involving not having satisfied early-1970s non-safety-related construction and housekeeping standards, and weaknesses in the station's erosion/corrosion program.



...The Entergy report identified "(t)he ineffective monitoring and inspection of the leakage control system of the AOG pipe tunnel, i.e., the tunnel floor drain and sump

pump" as the second root cause.


Entergy's RCA:

RC1: Latent Standards and Practices That Were Inadequate

Inadequate housekeeping standards and practices were applied during the construction of the AOG Pipe Tunnel in 1972. Inadequate design and installation standards and practices were applied during the installation of the 2”CNPE-172A line in 1978. These latent issues combined to compromise the leak tight design of the AOG Pipe Tunnel and allow for water containing radio nuclides to leak to the environment.

NRC:
Root Cause No.1: Latent Standards and Practices That Were Inadequate

The Entergy report stated: "Inadequate housekeeping standards and practices were applied during the construction of the AOG pipe tunnel in 1972. Inadequate design and installation standards and practices were applied during the installation of the two-inch drain line CNPE-172A in 1978. These latent issues combined to compromise the leak tight design of the AOG pipe tunnel and allowed for water containing radionuclides to leak to the environment."

The inspectors concluded that the licensee's first root cause was well-supported.

Corrective actions planned were appropriate to the circumstances and included:

1) clearing of obstructions and removal of debris to the extent possible in the AOG pipe tunnel, completed prior to AOG system startup; and, 2) redesign and implement the removal from service (by sealing) of the two-inch drain line CNPE-172A. This action was completed in June 2010. The inspector reviewed Engineering Change(EC) 22659 developed to seal drain line CNPE-172A.

It is interesting...Entergy didn't submit a voluntary LER on it...

12 noon today...Hmm, called Dr Irwin of the Vermont Department of Health, their Radiological officer.

He says they are waiting for VY water sample results from the rad waste well. He tells me they are going to be sampling on a daily bases...then Irwin is going to get them and post them on their internet site.

I get from Dr Irwin, I seen your latest 2.206, man you name is all over Vermont Yankee documents. I'd also seen you at a bunch of VY and NRC meetings. I wonder if he remembers me making a jerk out of myself in front of chairman Jazcko last summer in Bratt. We talk a litttle about my history...he seems to be really up on nuclear submarine history.

He says the process pipe from the AOG building to the stack goes right through the area of the rad waste well. The is a lot of rad pipes in that area. You got those sampling tanks near by and they can be hot.

My scenario for a new well, it takes a lot of withdrawing of water, so that you pull far off contamination into the well to be sampled. He thinks it is a brand new leak and he fears it is going to get a lot higher.

Dr Irwin thinks the first negative sample...no tritium...was a legitimate sample. Entergy has a company come in to gather and measure the water radiation, then splits the sample with Vermont...they are the ones who disclose the count level. Then Vermont counts their half on their own. He just doesn't see how that first sample could have been doctored.

Dr Irwin implied, they should have begun excavating...

NRC Decision on Immediate Action of Vermont Yankee

From: "Kim, James"
To: Michael Mulligan
Sent: Tue, January 25, 2011 8:58:14 AM

Subject: VY 2.206 Petition on Shut-Down Vermont Yankee - Decision on Immediate Action

Mr. Mulligan,

With regard to your petition dated January 18, 2011, the Petition review Board (PRB) met on Monday, January 24, 2011, to discuss only the request for immediate action of immediately shutdown Vermont Yankee. The PRB determined that there was no immediate safety concern to the plant or to the public health and safety. The system is non-safety-related and the tritium leak amounted to approximately less than 1 mrem exposure to the public. No drinking water sources were impacted. Therefore, the PRB denied the request to immediately shutdown Vermont Yankee.

Thanks,
James Kim
PRB Manager

Mr. Kim,

The is the problem in a nut shell, I have to have triplicate poor that the plant is unsafe against impossible barriers to the truth, but the NRC and Entergy can use subjective and in the complete absence of any real information that a nuclear plant is safe. There are different standards for insiders and out insiders. It seems the more access to real information that you have at your fingertips, the more subjective and specious your assertions can be. The flip side of it is, the more distant to real information is your privilege, the more triplicate proof and evidence your need to make a case.

Mostly, in the RCA, there is nothing but unproven specious assertions in the characterizations within the RCA.

Again, in a culture of falsifications and a intimidation system to enforce illegal behavior at the employee level, how do we know anything we see with Entergy is true?

I can tell you for a fact, if a plant has a off site radiation event or any core damage in the USA today with NRC language like this, the media and political frenzy would take out the NRC as a credible regulator. That would have serious blow back consequences for the whole nuclear industry and the American public.

Anyways, I really do appreciate the official response...

Added Jan 25, 2011 at 6:51pm

This is what the NRC said on my emergency shutdown of VY: "The system is non-safety-related and the tritium leak amounted to approximately less than 1 mrem exposure to the public."

They could cycle this question to their computer models that estimates dose in a few fractions of a second: "how many curries being pumped into the ground would to take without taking any actions to get a member of the public or employees to exceed the licensing dose limit in the ground below the rad waste building well."

Say there is no well down there, how many curries being pumped into the ground would it take to get a regulated dose to be first exceeded?

I'll bet it would take a mind boggling amount of curies pumped into the ground to get that dose exceeded...that is why the limit is ridiculous.

Jan 26, 2011

It would probably take 10 VY spent fuel pools worth of fuel to get all chopped up in a blender and injected into ground before a member of the public would exceed his NRC regulated dose.

Emergence Shutdown of Vermont Yankee 2.206 prehearing

The NRC called today to set up a meeting with me on this Thursday Jan 27. It will be about the VY Root Cause Analysis. The are going to have the NRC inspectors and inspection RCA report writers at the teleconference. The NRC Section Chief and others will be in the conference.

I am concerned about what are the NRC standards with Root Cause Analyses, both for the NRC and a licensee.

Emergence Shutdown of Vermont Yankee 2.206

I got another message talking about setting up the 10 CFR.2.206. It will occur on Feb 3, 2011 between 9 and 10AM.

Vt Gov Shumlin a Patsy to Entergy

Nov 1, 2010
Some time before the election Entergy knows the area around the radioactive waste building is independently contaminated and schedules to drill a sampling well after the election. They know the election is a squeaker...they know the bad news would give the elected to Shumlin. Entergy is gaming and spinning information...withholding information hoping to drive a outcome to protect profits.

Nov 2, 2010
Gov Shumlin gets elected.

Nov 7, 2010
My “Advice for Gov Shumlin”:
“Remember Charlie Crist: http://en.wikipedia.org/wiki/Charlie_Crist
He crossed the republicans with his decision on their PSC or PUC...the utilities and their buddies then ripped him to shreds. Many think it was over the Florida new nukes. The got a tea bragger to run against him and withdrew campaign monies. They viciously threw him under the bus.
So yes, there is Pilgrim, Indian Point, Oyster Creek plus Vermont Yankee on the line.
I think the utility and nuclear folks would want to make a example of you...to send a message to all politicians around the NE nuclear plants. It is my judgment these gangs of utility boys are going to weaken and sabotage your administration from the first days of your governorship. These guys, as you know, are extraordinarily powerful.
Matter of fact, I’ll bet you they twist the VY issue in anyway they can think of, in order weaken and destabilize your administration, draw you attention away from the duties of the state helping the middle class an the poor.
They will use any arm of the utility sector to get you in trouble. It is common knowledge the utility sector has veto power over the success of a governorship. I bet you they put the VY issue in newspapers every day...constant drama and turmoil...they will want you consumed by the VY issue and utilities issues.
They are going to do you a Obama... slit your throat...intent to destroy and weaken you from day one.
You are going to be a example to everyone else!”

Nov. some date 2010
The well, which was dug in November, had shown only minimal levels of contaminated water, less than 2,500 picocuries per liter, until Jan. 17, Irwin said. It is located in the vicinity of the radioactive waste building, which was one of the areas investigated when the January 2010 leak was discovered.

How much less than 2,500 picocuries per liter? The Comcast emergency alert tone buzzer should have been going on in the top VY and Entergy offices...they should have gotten a full irritating 5 alarm Comcast tv buzzer blast for an hour.

Anything between 500 and a 1000 pCi/L should indicate a leaking pipe and a emergency...

Nov 18, 2010
Pumping from ground stops ...”Groundwater Extraction Terminated On November 18, Entergy Vermont Yankee officials told the Health Department that the 300,000 gallon objective for groundwater remediation had been met, and groundwater extraction has been terminated. Why didn't Shumlin stop it on Nov 18”...

Dec 3, 2010
Tritium in a drinking well near the COB building... “More Tritium Contamination Detected in Deeper Groundwater Monitoring Wells
Vermont Yankee notified the Health Department late afternoon on Dec. 3 about high concentrations of tritium detected in samples taken Nov. 29 from two of its nine newest groundwater monitoring wells. Both are deeper wells, about 60 feet below ground level and just above bedrock:GZ-12D, located near the Containment Access Building (CAB), measured tritium concentration at 65,000 picocuries per liter (pCi/L) GZ-22D, located near the Construction Office Building (COB), measured tritium concentration of 500,000 pCi/L

Dec 6, 2010
...the only sample from well GZ-24S that was provided by Vermont Yankee to the Department of Health Laboratory for analysis tested at less than the lower limit of detection (LLD).

Dec 7, 2010 Gov Elect Shumlin demands Entergy resume pumping tritium from the aquifer.

Dec 17, 2010
Gov elect Shumlin visits the Vermont Yankee site and gets a detailed briefing about the tritium issue from VY and Entergy experts.

Dec. middle something 2010
“Sheehan said Vermont Yankee has conducted several tests from the well, showing increasing levels of tritium. In December, the well showed 2,400 picocuries per liter, he said. At least two more tests were done this past Monday and Thursday, reaching 9,200 picocuries, he said.”

Dec 17, 2010
Gov Elect Shumlin request and gets Entergy to resume pumping tritium from the aquifer.

Late Dec 2010
Said by the VDOH on Jan 21: “According to information provided to the Department of Health today by Entergy Vermont Yankee, the concentration of tritium in GZ-24S has been trending upward since late December” At that time, a sample taken from well GZ-24S tested at a concentration of approximately 2,500 picocuries per liter (pCi/L).

The VY Root Cause Analysis Page 3 –declares their AOG leak started off at “705 pCi/L; This was slightly higher than Teledyne Brown’s minimum detectable activity of ~230 pCi/L” then ramped up to 17,000. 1000 pCi/L should have been confirmation that a leak is right here.

Dec 28, 2010
Disclosed in the media on Jan 29 2011: "So therefore the samples were unable to be analyzed until January 11 of 2011 when the machine was repaired. So that accounts for the delay in reporting that."
The radiological analyzing device or counter was found to be broken around this date that measures tritium.

Jan 6, 2011
Peter Shumlin was sworn in as Governor of Vermont.

Jan 6, 2011
mike mulligan wrote (Jan 6 message 10):

“I just see it as Entergy throwing a slow pitch at gov Shumlin...giving the gov a opportunity to hit the ball out of the park. Are they already in cahoots? Entergy is signaling to Shumlin...play our ball, and you can expect to hit a lot of home runs.”

(This is about the whole deal of stopping the pumping, then a letter from Shumlin demanding a restart of pump, then Shumlin prancing around the plant on a tour and a full and comprehensive brief on conditions.)

Jan 11, 2011
Disclosed in the media on Jan 29, 2010; "So therefore the samples were unable to be analyzed until January 11 of 2011 when the machine was repaired. So that accounts for the delay in reporting that."
The radiological analyzing or counter was made to be fixed on this date that measures tritium.

Jan 11-14 2011
Lawyers, consultants wrangle over ‘root cause’ of Yankee leaks
In the hearings, lawyers for the New England Coalition, the Conservation Law Foundation, Vermont’s Agency of Natural Resources, and Vermont’s Department of Public Service cross-examined Entergy experts about written testimony they had submitted regarding the leaks, their causes, what was released, and what is being done to prevent future leaks.
The “root cause” of the leaks was the most contentious issue.
Margolis asked Trask if identifying holes in the pipes as a “contributing cause” meant that Entergy’s root cause analysis did not need to evaluate whether similar plant pipes were developing holes. Trask replied that Entergy is “already constantly looking for where that is occurring in the plant.”
CLF:
"Do you know if there's any percentage that remain uninspected or untested?" asked John Burke of the Public Service Board.
"I can't give you the specific percentage," answered Timothy Travis of Entergy Nuclear.
"Can you give me a ballpark as to what percentage may remain uninspected or untested?" Burke asked.
"I guess I'd like to answer that in-- no, I cannot. However-- need to look at what the definition of what 'inspected' is," Travis answered.
"The question was asked a few times-- have you done a root cause evaluation of the actual cause of the leaks in the pipes? And they haven't. And that's really what we're asking about-- shouldn't you be asking about where else this is occurring around the plant? Shouldn't you be inspecting the pipes to make sure other pipes aren't leaking?" said Jared Margolis of the New England Coalition.
"We're looking at buried and underground piping, we're monitoring and using the latest technology, whether it's guide wave technology, whether it's visual inspection of piping, whether it's looking at increased barriers-- we're looking at more ways to identify piping," said Larry Smith of Entergy.

Jan 17, 2011
Said Jan 22, 2010 by Reformer...“The well, which was dug in November, had shown only minimal levels of contaminated water, less than 2,500 picocuries per liter, until Jan. 17”

Jan 18, 2011
Sent my petition to the NRC: “Subject: 10 C.F.R. § 2.206 Emergency shutdown of Vermont Yankee and requesting a NRC OIG investigation of the NRC behavior surrounding inspecting activities associated with the AOG piping tritium leak and its Vermont Yankee Root Cause Analysis. Entergy and the NRC gamed the RCA and inspection activates in order to try to influence the 2010 election of the Governor of Vermont...with their intent to save the life of Vermont Yankee no matter what it took.”

Jan 20, 2011
A sample from that well taken January 20, 2011, had a concentration of about 9,000 pCi/L...

Jan 21, 2011 (Friday12:03:18pm)
From: Michael Mulligan steamshovel2002@yahoo.com
My back door channel to Entergy?
Sent: Fri, January 21, 2011 "12:03:18". “Organizational Control of Investigation Methods”...I don’t see any evidence that AOG tunnel was ever a radioactive designed and engineered barrier. If it wasn’t engineered, designed and maintained to be a rad barrier...how could it be the number one causal factor in the uncontrolled release of radioactive to the environment?
Like where did the activated hydrogen (tritium) gas go too, that is a major function of the AOG system to combine the gas into water. The leak occurred before the recombiners. What if we assume all of it, and the other gaseous and particulate activity, and whatever else went through weep hole, then escaped from the butler building.

Jan 20, 2011
From the VDOH page wrtten on late Jan 21, you see how fast they can get a sample..."A sample from that well taken January 20, 2011, had a concentration of about 9,000 pCi/L. Jan 21 2011."

Jan 21, 2011
Multiple Media outlets came out late Friday afternoon informing us of new leak.

Jan 21, 2011
Disclosed on Jan 29 Rutland Herald by Susan Smallheer...Vermont's rad officer admitted he discovered on Dec 21 he discovered the tritium detector broken from Dec 28, 2010 to Jan 11, 2011.


January 21, 2011
Investigation Update (Came out late Friday!)
The Department of Health was notified this morning by Entergy Vermont Yankee officials that a sample taken from groundwater monitoring well GZ-24S has been confirmed as being contaminated with tritium.
Groundwater monitoring well GZ-24S is a newer well completed and first sampled last November. GZ-24S is located 150-200 feet north of the bulk of the plume released from the Advanced Off-Gas (AOG) Building. ( Map )
The source of this tritium contamination is not yet known. Entergy Vermont Yankee is investigating possible sources of any new leaks, including four drain lines from the reactor and turbine building ventilation system, and one drain line from the AOG Building. Plant officials are also investigating whether other plant structures might serve as "conduits" of tritium contaminated water away from the estimated AOG plume area.
According to information provided to the Department of Health today by Entergy Vermont Yankee, the concentration of tritium in GZ-24S has been trending upward since late December. At that time, a sample taken from well GZ-24S tested at a concentration of approximately 2,500 picocuries per liter (pCi/L). A sample from that well taken January 20, 2011, had a concentration of about 9,000 pCi/L. On December 6, 2010, the only sample from well GZ-24S that was provided by Vermont Yankee to the Department of Health Laboratory for analysis tested at less than the lower limit of detection (LLD).
Entergy Vermont Yankee officials report that its on-site laboratory has not detected tritium above the LLD at groundwater monitoring wells near GZ-24S. However, a sample from well GZ-6 independently analyzed by the Department of Health Laboratory as well as by Entergy Vermont Yankee’s contract laboratory has tested for tritium slightly above the LLD. ( Health Department Lab Analyses )
Entergy Vermont Yankee is now sampling well GZ-24S daily. The Department of Health has requested split samples of GZ-24S to be provided weekly for analysis.

Jan 22, 2011
Most Vermont newspapers carried follow-ups concerning Jan 21 disclosure of new leak
“Officials investigate possible new leak at Vermont Yankee”
You can’t trust Irwin to correctly warn us of the risk and announce a troubling anomaly...Irwin is the chief minimizer.
“The well, which was dug in November, had shown only minimal levels of contaminated water, less than 2,500 picocuries per liter, until Jan. 17, Irwin said.”

Jan 29, 2011: I will just say 2500 picocuries is way sufficient to declare a rad leak and start spending money on trying to detect and stop it. Irwin should know this.

January 24, 2011
Monday, The NRC called today to set up a meeting with me on this Thursday Jan 27. It will be about the VY Root Cause Analysis. The are going to have the NRC inspectors and inspection RCA report writers at the teleconference. The NRC Section Chief and others will be in the conference.
I am concerned about what are the NRC standards with Root Cause Analyses, both for the NRC and a licensee.
Emergence Shutdown of Vermont Yankee 2.206
I got another message talking about setting up the 10 CFR.2.206. It will occur on Feb 3, 2011 between 9 and 10AM.

January 25, 2011
Tuesday, 12 noon today...Hmm, called Dr Irwin of the Vermont Department of Health, their Radiological officer.
He says they are waiting for VY water sample results from the rad waste well. He tells me they are going to be sampling on a daily bases...then Irwin is going to get them and post them on their internet site.
I get from Dr Irwin, I seen your latest 2.206, man you name is all over Vermont Yankee documents. I'd also seen you at a bunch of VY and NRC meetings. I wonder if he remembers me making a jerk out of myself in front of chairman Jazcko last summer in Bratt. We talk a litttle about my history...he seems to be really up on nuclear submarine history.
He says the process pipe from the AOG building to the stack goes right through the area of the rad waste well. The is a lot of rad pipes in that area. You got those sampling tanks near by and they can be hot.
My scenario for a new well, it takes a lot of withdrawing of water, so that you pull far off contamination into the well to be sampled. He thinks it is a brand new leak and he fears it is going to get a lot higher.
Dr Irwin thinks the first negative sample...no tritium...was a legitimate sample. Entergy has a company come in to gather and measure the water radiation, then splits the sample with Vermont...they are the ones who disclose the count level. Then Vermont counts their half on their own. He just doesn't see how that first sample could have been doctored.
Dr Irwin implied, they should have begun excavating...

January 27, 2011
Washington Snow Storm  I would be surprised if the NRC could keep their date with me for our teleconference with the DC snow.
....rescheduled for tomorrow at 1pm
4:00pm: Fascinating isn't it...The Space Shuttle Challenger disaster occurred on January 28, 1986...

Jan 27, 2011
Disclosed Rutland Herald Susan Smallheer Jan 29
Sheehan said, noting Entergy held a conference call Thursday (Jan 27) with NRC officials to go over their investigation into the possible new underground leak.

Jan 28, 2011
Right off the bat I thought it was rude of them not saying anything about the RCA inspector not being available for my questioning. I thought they would make a simple excuse, sorry the RCA inspection writer can't be here because they are stuck in a snow bank. Do these people think I am that stupid?
I pick up right away this was a ceremonial meeting...this meeting was a show meeting for talking about it in the 2.206. I could tell they both were all hyped up and something was going on behind the scenes....they were defensive and evasive as heck.
Well, if they want to play that game, then I am spending a lot of time lecturing them both. I talk big time about the Challenger explosion, I tell them what I think is behind all of these institutional accidents, the accident initiates from a language problem. People start using weaselly words and phrases, they get away with it, then everyone does it. In a wide spread manner people default into a inaccurate language...basically the definition of words and concepts lose their definitions. Everyone goes by their own definition of a word or phrase...the game becomes evasion and not truth telling. I told them, there has been nothing going on here but evasion with you two.
Further I said, as in engineering ethics you own me the whole truth on what is going on here. Do you throw out the code of engineering ethics when you become a government official? That is when they closed the meeting and hung up the phone. They were polite though.
It just irks the heck out of me, I am thinking about Egypt here, they are using the NRC codes and regulations to be evasive and give a small proportion of the truth to me. I just think that is degusting, a federal official can use the tools of government to be dishonest to members of the public. It is so offensive to democracy.
The meeting started at 1PM and ended promptly at 1:30.
The dance with the snow and cancelling the meeting yesterday looks suspicious to me.
Another Well At Yankee Contaminated With Tritium
Friday, 01/28/11 12:04pm
Do you think this was really true?

Jan 29, 2011
VY continues to look for source of tritium
By BOB AUDETTE / Reformer Staff
BRATTLEBORO -- Technicians are still looking for the source of tritiated water that was discovered in a well about 150 feet north of a plume of contaminated groundwater that originated in Vermont Yankee's advanced off gas system.
That leak was discovered Jan. 10, 2010, and stopped later in March.
Last week, Yankee revealed a groundwater monitoring well, GZ-24S, had tested positive for tritium at a level of 9,200 picocuries per liter, which is more than 20,000 picocuries lower than the reporting level required by the Nuclear Regulatory Commission. The Environmental Protection Agency's limit for tritium in drinking water is 20,000 picocuries.
No deep wells, the source of drinking water in the area around Yankee, have shown detectable levels of tritium.
In a sample taken on Jan. 26, 1,024 picocuries per liter were discovered in a well, GZ-6, which is near GZ-24S.
On Jan. 26, a sample from GZ-24S showed a drop in tritium levels to 8,139 picocuries per liter...
Vermont Yankee reports tritium in new well near last week's
By Terri Hallenbeck, Free Press Staff Writer • Saturday, January 29, 2011
"Vermont Yankee officials had reported no elevated levels of tritium in GZ-6 last week, but an independently analyzed sample by the state Health Department tested slightly above the lowest limit of detection. Smith said Vermont Yankee's tests found slightly elevated levels for the first time this week."
Rutland Herald Susan Smallheer Jan 29
Irwin said the failure of the test equipment was disturbing.
They told me about the liquid scintillation counter being down and that was the cause of the delay. Irwin said, I figured like most labs, they would get the instrument repaired relatively quickly but for some reason that did not the case.
Irwin said that he only found out about the equipment failure last Friday (Feb 21), when he asked why the test results form the first well were so late.
Sheehan said, noting Entergy held a conference call Thursday (Jan 27) with NRC officials to go over their investigation into the possible new underground leak.

Jan 30, 2011

2.206 liquid scintillation counter evacuation delay
I request a immediate emergency shutdown of Vermont Yankee because of the unreliability of their radiological and emergency plans for a indeterminate amount time. The liquid scintillation counter was broken between Dec 29, 2010 and Jan 11, 2011. That makes the radiological procedures inoperative or severely degraded in this time frame. Not having a backup liquid scintillation counter would make the emergency evacuation plans unreliable. If a nuclear power plant doesn’t have the capability to make reliable their evacuation plans, then they shouldn’t be licensed to operate a nuclear plant.
1) I request a NRC OIG and congressional investigation with why the NRC didn’t immediately notify the community that the Vermont Yankee radiological procedures and evacuation plans were not functional during these dates.
2) Request a investigation, in making sure that all radiological capabilities at the nuclear plants are reliable and durable with sufficient back ups in order to be able to carry out their emergency plans. Request all USA plants have sufficient back up liquid scintillation counter capabilities.
3) Request a information notice to given to all plants about this.
4) Request a disclosure of all delays with getting any radiological measurements that effected any normal or emergency requirement

Feb 2, 2011
Gov. Peter Shumlin calls for Vermont Yankee Reliability Oversight Committee, citing tritium leaks
MONTPELIER – Gov. Peter Shumlin, citing the on-going discovery of tritium leaks at the plant, instructed the Vermont Department of Public Service to appoint a Vermont Yankee Reliability Oversight Committee.
“I've asked the Department of Public Service to organize a Reliability Oversight Committee to provide, in these coming critical months, additional expertise on oversight of Vermont Yankee issues within the state's jurisdiction,” Gov. Shumlin said. “I am deeply concerned with Vermont Yankee’s lack of transparency about serious problems that continue to be discovered around the plant.”
Shumlin continued, “I learned two weeks ago about another well with a tritium hit, and this one is not near the plume we already knew about, but 150 feet away. Then, last Friday, I was told that yet another well had a tritium hit. Vermont Yankee had the samples pulled that showed the new tritium hits, but didn't test those samples for a few weeks because a piece of equipment was broken.”

Feb 3, 2011
"All of a sudden I hear a click, I hear the snippet "and have a little fun", then I hear the talking of all the NRC officials, then the "welcome to this 2.206 petition...". All the background chatter of the officials stops...then we are off to the races with the 2.206 processes. From this point on everything is recorded in the NRC ops center and it is transcribed for addition into the public record...
...The chairman of the petition board pops up on the phone connections explaining, "I was introducing a new NRC official to the petition board and I was telling her to have a little fun as she participates and listens to your review board" concerning tritium and root cause analyze issues at Vermont Yankee."

The quintessential mike mulligan

It is quintessential mike mulligan...everyone and especially me has had to learn to deal with this for twenty years.

Jan 19, 2011 People who crave risk...the risk takers...they tend to be way better at ESP than everyone else.

Officials investigate possible new leak at Vermont Yankee

By JOSH STILTS / Reformer Staff Saturday January 22, 2011

The well, which was dug in November, had shown only minimal levels of contaminated water, less than 2,500 picocuries per liter, until Jan. 17, Irwin said.

Tuesday, January 18, 2011

Subject: 10 C.F.R. § 2.206 Emergency shutdown of Vermont Yankee
Jan 18, 2011

R. William Borchardt
Executive Director for Operations
US Nuclear Regulatory Commission
Washington, DC 20555-0001

added Jan 22, 2011@5:22 pm

OK....

It just looks like what you said NSD...

It is really about panic and desperation...Entergy lawyers fears another charge of giving false testimony to the state of Vermont. That is why it came out Friday...it is a attempt to limit legal risk.

Chop, chop...you got to charge Entergy with giving false testimony in a Vermont state proceeding...Make Vermont's Attorney General Sorrow investigate this.

I gave you the gun flash and then the smoking gun...

BP's and API's INPO

Institute of Nuclear Power Operation(INPO)
American Petroleum Institute(API)

It is just more anti government hatred....it discloses how dysfunctional our politics is.

You guys are scientist, where is the evidence that INPO works? Like where is the open peer review process where it is opened to a professional and public criticism process. Personally I don't believe outside of this group the nuclear scientific professionals believe in science...the belief of transparency and the art of professional democratic peer reviewed criticism. It is your scientific duty to act in all of our interest. In the eyes of the wide spread view of the public...they don't trust the science and the snake oil scientist of the nuclear industry.

I could make a case inpo makes the possibility of the industry's continued existence...but doesn't create enough public credibility to build any new plants. We know INPO serves the interest of the CEO's of the industry...but does INPO serve my and the public interest.

I mean, the INPO model is a recipe for stagnation of the oil drilling industry for 50 years.

Like, why did INPO fail in the 2010 HB Robinson year, in all of the INPO's soul searching of Davis Besse? Why did INPO fail in the tritium leakage issues national wide, and especially at Vermont Yankee. VY should have had no problems with relicencing, is it a one off? I give you another one, why is INPO failing on safety relatedness and what we think of risk. The nothing ever matters philosophy...it that what we think of science and our scientist?

Does science inform us that there are certain human behaviors of ours that must be placed under control...or does science say we can get away with anything we can get away with?

I could make the case the nuclear industry screw ups became apparent, it gained anti nuclear traction...this created the possibility of operation advancement of the nuclear industry. Basically the fear the public would not support nuclear activities and their rendition of scientific truths.

Theoretically INPO could work...but they don't understand what gets a change in human behavior and what kind of medicine it takes to act in all of our interest.

Subject: 10 C.F.R. § 2.206 Emergency shutdown of Vermont Yankee

Jan 18, 2011

R. William Borchardt
Executive Director for Operations
US Nuclear Regulatory Commission
Washington, DC 20555-0001

Subject: 10 C.F.R. § 2.206 Emergency shutdown of Vermont Yankee and requesting a NRC OIG investigation with the NRC behavior surrounding inspecting activities associated with the AOG piping tritium leak and its Vermont Yankee Root Cause Analysis. Entergy and the NRC gamed the RCA and inspection activities in order to try to influence the 2010 election of the Governor of Vermont...with their intent to save the life of Vermont Yankee no matter what it took.

Dear Mr. Borchardt,

§ 50.9 Completeness and accuracy of information.
(a) Information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects.

(b) Each applicant or licensee shall notify the Commission of information identified by the applicant or licensee as having for the regulated activity a significant implication for public health and safety or common defense and security. An applicant or licensee violates this paragraph only if the applicant or licensee fails to notify the Commission of information that the applicant or licensee has identified as having a significant implication for public health and safety or common defense and security. Notification shall be provided to the Administrator of the appropriate Regional Office within two working days of identifying the information. This requirement is not applicable to information which is already required to be provided to the Commission by other reporting or updating requirements.

[52 FR 49372, Dec. 31, 1987]

I like them words: “An applicant or licensee violates this paragraph only if the applicant or licensee fails to notify the Commission of information that the applicant or licensee has identified as having a significant implication for public health and safety or common defense and security.” So if it is not a significant implication for public health and safety, it is OK to give incomplete information to the agency and the public, that may impact the continued operation of the plant.

ROOT CAUSE EVALUATIN REPORT CR-VTY-2010-00069 dated 06/16/2010

The below Root Cause evaluation is just a falsification. I don’t see any evidence through Entergy documents, NSA and the NRC inspection reports...FSAR and licensing bases...that the AOG tunnel was a initial plant design barrier against the leakage of radioactivity into the environment. It is designed to be a leak off warning and drain water from the saturated outside soils into the piping. If it not a engineered and designated radioactive barrier, then it can’t be a root cause of the leak.

Root Causes:

RC1: Latent Standards and Practices That Were Inadequate
Inadequate housekeeping standards and practices were applied during the construction of the AOG Pipe Tunnel in 1972. Inadequate design and installation standards and practices were applied during the installation of the 2”CNPE-172A line in 1978. These latent issues combined to compromise the leak tight design of the AOG Pipe Tunnel and allow for water containing radio nuclides to leak to the environment.

Although a leak of a tritiated system was required to complete the event, the team concluded that the original design of the tunnel would have been able to adequately contain and process a leak from within the tunnel. It was only after modifications to the tunnel and poor housekeeping during construction, that the water was able to leak from the Pipe Tunnel to ground.

The poor leaking interfaces and the brick replacement of the poured cement encasement indicated in the 1970’s timeframe the tunnel was not a designated radioactive barrier. The poured cement encasement of the piping was just a cheap construction technique for the general environmental protection of the piping. The intent of the encasement and the drain leak off was to protect the carbon piping from standing water. They feared the ground becoming saturated through storms and the water leaking into the tunnel...with the carbon pipe sitting in the water for extended periods of time. One must remember the times of severe fuel failure problems and high AOG piping radioactivity...this was no designed radioactive barrier.

Pg 15-Interface Between The AOG Pipe Tunnel And The Concrete-Encased, 2-Inch Condensate Drain Line, 2”-CNPE-172A, Not Watertight:

A modification was performed to the AOG pipe tunnel in 1978 per Plant Alteration Request (PAR) 78-36., which installed 2”CNPE-172A to AOG, and did not ensure the AOG Pipe Tunnel remained watertight. To implement this modification, workers in 1978 excavated down approximately 18 feet and penetrated the side of the AOG pipe tunnel to gain access to 12”-AOG-100. After the new drain line (2”CNPE-172A) was added, it was surrounded by 4” PVC and encased in concrete. The PVC was cut in half lengthwise to aid in the installation and concrete was poured over the PVC assembly for the encasement. The intent of the PVC was to provide room between pipe and concrete for thermal expansion during heat up and cool down. Furthermore, the 2”CNPE-172A encasement did not form a watertight interface with either the AOG pipe tunnel or with the AOG Drain Pit. These interfaces were not keyed, grouted, or sealed, so the interfaces were not leak tight. Once the water rose as a result of the floor drain obstruction, it was able to communicate to the environment through gaps in the concrete encasement. When the AOG Pipe Tunnel wall was restored in 1978, masonry blocks were used instead of restoring it with poured concrete as the original design had been.

We know with the below there are really two possibilities with how the debris and soil came to obstruct the drain. It could of either came from the 1970’s construction debris like Entergy claimed, or it could have came in from the outside dirt as the water leaked into the tunnel from saturated soil, from storms and snow melt off. It is atrocious these two possibilities was not discussed by the NRC or Entergy. It gives rise to the idea they engineered the RCA to an out come...they picked and chose the facts that fitted into a preconceived political and public objective before the RCA was even began.

Pg-15-Obstruction of the AOG Pipe Tunnel Floor Drain:

Because the AOG Pipe Tunnel was inaccessible, it has not been accessed since original construction in 1972 (with the exception of the field modification to install 2”-CNPE-172A in 1978). Therefore, the debris is considered to be original construction debris left in the tunnel since 1972.

Chief Engineer of Boiling Water Reactors for Entergy Timothy Trask

http://www.reformer.com/localnews/ci_17115617

....high-ranking engineer for Entergy, which owns and operates Vermont Yankee, said that leaks from two pipes were merely a "contributing cause."

Timothy Trask, chief engineer of boiling water reactors for Entergy, said the reason the Root Cause Analysis wasn’t focused on the leaking pipes was because the problem statement was a leak to the environment.

"The concrete barrier in the Advanced Off-Gas pipe tunnel was flawed and had a hole two to three inches in diameter, which allowed the water to leak into the surrounding soil," Trask told the Reformer. "If there was no hole in the concrete tunnel, the tritiated water leaking from the AOG pipes would have flowed into the plant’s drainage system and would have never entered the environment."

He said although the pipes that leaked had not been inspected for at least a decade prior to the leaks being found, an improved inspection program had been put in place.

http://www.bloomberg.com/news/2011-01-12/vermont-regulators-hear-about-nuclear-leaks.html

Trask maintained that the leaking pipes were merely a "contributing cause" of tritium — a radioactive isotope of hydrogen that is a carcinogen when ingested in high amounts — reaching test wells on the Vermont Yankee plant. But he said they were not the most important, or "root cause," of radioactive water reaching the environment. That was a gap in the wall of the concrete underground enclosure where the pipes were located, he said.

Entergy/Vermont Yankee Maintenance Work Manager.

Laurence is a 26 year employee of Vermont Yankee and he was a long time licensed operator.

“Mike, I got 26 years in Vermont Yankee and it doesn’t matter what happens to the plant.” (He is getting a pension)

“We all knew that damn AOG tunnel was leaking for years.”

Real Root Cause(s)

1) The Vermont Yankee knew there was a leaking water anomaly in the AOG tunnel...the AOG piping had a hole in it and higher management prevented them from confronting the problem and fixing it.

2) The AOG tunnel and piping system wasn’t engineered, designed and constructed to contain radioactivity.

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

Questions

Was the water leak from the AOG piping larger than the drain hole...?

Request:

1) 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.

2) Request an extent of conditions with Entergy providing the NRC with inaccurate information, false and incomplete documents and any falsifications to the NRC. I can give you three other inaccurate and false Entergy documents from three different plants other than VY....LERs.

3) Request the NRC look into if Entergy gave new false testimony to any proceeding with the state of Vermont.

4) Request an OIG investigation concerning recent falsified and incomplete NRC inspections...specifically how come the NRC didn’t nail down in inspection reports the design bases, licensing bases, the UFSAR basis and the engineering characterization of the so called radioactive containment system of the AOG piping.

5) Request a extent of conditions with any falsified and incomplete licensing bases, UFSAR or any plant engineering and plant designs that protect the pubic and environment of the people surrounding Vermont Yankee. Request a extent of conditions with this on any other Entergy nuclear plant and at any other plant in the USA. Does Vermont Yankee need a licensing bases reconstruction program?

6) Request a national formal NRC code and regulations on Root Cause Analyses and the quality of RCA...

7) Request to have a discussion with the top NRC official in charge, or the most knowledgeable, with of Root Cause Analysis before the 2.206 pre hearing.

8) You know their corrective action program are keyed off the RCA or RCE...so their corrective actions program is corrupted and they don’t address why the tritium leak occurred.

9) I request the NRC be prohibited from ever using the term...it is before the ROP overhaul and it is of no concern of the NRC....there is no bases at all for that NRC statement other than it is political and they are just plain lazy.

10) If it come down to a OIG involvement, it should be noted that time is a precious commodity. A shutdown is but a year away at the most, there is now significant state issues with this and it should be a unusually open NRC OIG process...mostly the investigation should be accurate, swift and open.



Sincerely,



Mike Mulligan
Hinsdale, NH 03451
1-603-336-8320
steamshovel2002@yahoo.com

2.206: Illegal start-up of VY in 2007

10 CFR 2.206 PETITION for Vermont Yankee

Allegations,
I am requesting a 2.206 on Vermont Yankee. Would you please pass it on?
Mike


Notepad:
NRC reports 1 low-safety issue at VY
HPCI: VY and NRC cult of falsification
The nuclear peanut commission?


June 8, 2008

Executive Director for Operations
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001

10 CFR 2.206 PETITION


I request a 2.206 on Vermont Yankee. Vermont Yankee operated their reactor illegally and unsafely coming out of their start-up after a outage from June 6, 2007 until June 12, 2007. With the cost of a shutdown being $750,000 a day times 7 days, I request Vermont Yankee pay a fine of $5,250,000 for operating the reactor illegally and falsifying paperwork submitted to the NRC.

1) SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 05000271/2007004
(Closed) LER 05000271/2007002-00, High Pressure Coolant Injection System Valve Failed to Open (1 sample)

“On June 8, 2007, with the reactor at 81 percent power, Entergy identified that the HPCI pump injection valve (V23-19) did not open on a manual signal from the control room during a surveillance test. Entergy entered the condition into their corrective action program and a root cause evaluation was performed. Entergy determined that one of the motor operated valve (MOV) contacts (72/C) was in the intermediate position, causing electrical and mechanical interlocks that prevented the open contactor (82/O) from energizing. Entergy identified that the 72/C contacts were pitted and worn, causing the contact surfaces to overheat and weld together. Entergy determined that the PM performed on the valve control circuitry was inadequate, in that it did not contain sufficient guidance on how to determine contact wear and when the contacts should be replaced. The inadequate PM activity constituted a performance deficiency.

This finding is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of assuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

The inspector conducted a Phase 2 SDP analysis, using the following assumptions, and the Risk-Informed Inspection Notebook for Vermont Yankee Nuclear Power Station, Revision 2: the exposure time was approximately six days and no operator recovery credit provided.”

2) So the NRC says it is a 6 day exposure from 06/06/07 to 06/12/07...but the violation began on 06/05 when the mode switch was place to start-up.

“05/31/07: Electrical Maintenance inspected the HPCI V23-19 valve starter LOCAL-23-19 cubicle. The contactors were noted to be carbonized and pitted. This was an expected condition due to the load on these contacts during MOV operation. The contacts were cleaned and no unusual indications were observed.” ( Vermont Yankee LER 2007-002-01)

1) Vermont Yankee operated with OP-5210, "MCC Inspections" procedure that didn’t meet 10 CFR 50, Appendix B, Criterion V. Having procedures that didn’t meet the intent of 10 CFR 50, Appendix B, Criterion V illegally gave Vermont Yankee non conservative operational flexibility and this involved a lot of money.
2) “This was an expected condition due to the load on these contacts during MOV operation.” This is evidence that Vermont falsified their paperwork and reporting to the NRC.
3) According to “10 CFR 50, Appendix B, Criterion V” on 5/31/07 (shutdown) HPCI wasn’t capable of performing its intended function with such a damaged relay.

On June 5, 2007 at around 2 am Vermont Yankee illegally and contrary to technical specification began starting up the nuclear reactor knowing they had a inoperable HPCI. Correction, on some unknown time on June 5, 2007 Vermont Yankee contrary to technical specification positioned their mode switch to start-up and began commencing a improper reactor start-up.

In and around June 6, 2007, after they made the reactor system’s pressure exceed 150 psig, Vermont Yankee was required within 24 hours to make the HPCI fully operational or be below shutdown. They were required to do HPCI line-ups, a full flow test and valve operation timing. That is how you make HPCI operational. There was indications that V23-19 was not functional on 60/06...dimming lights and other indications. In the last operation of V23-19 on June 6, 2007 a relay was welded shut, thus making HPCI inoperable. It is at this point that Vermont Yankee didn’t meet their 24 hour tech spec requirement of having HPCI operational upon start-up. They should have begun a immediate shutdown according to tech specs.

“06/08/07: Operations attempted to open V23-19 as part of normally scheduled surveillance activities for the HPCI System. V23-19 failed to open on a manually initiated signal from the Control Room.” ( Vermont Yankee LER 2007-002-01)

1) Vermont Yankee and the NRC intentionally misinterpreted V23-19 failure to open event. They illegally thought making HPCI “failure to become operational” on June 6, 2007 and the valve V23-19 failure to open on June 8 were separate events. By making it a separate event they wrongly assumed HPCI met the tech spec requirement of being operational within 24 hours of exceeding 150 psig.


"The contactors were noted to be carbonized and pitted. This was an expected condition due to the load on these contacts during MOV operation. The contacts were cleaned and no unusual indications were observed.” ( Vermont Yankee LER 2007-002-01)

"Prior to implementing the corrective actions developed by the Root Cause Analysis Team, the contactors were inspected at 6 year intervals and replaced when signs of degradation such as pitting were present." ( Vermont Yankee LER 2007-002-01)

1) I don’t get it, the NRC says VY didn’t have appropriate quantitative or qualitative acceptance criteria, but the root cause says they had a criteria of replacing the relays if “degradations such as pitting were present”. Everyone knows in critical safety systems if carbonization and pitting shows up in any relays you don’t repair it or sand paper over it. These guys are all profession trades and higher educated nuclear professional. This isn’t a back yard mechanical oil monkey operation going on. It is a nuclear power plant. You are talking about pennies here compared to the risk of the safety system is not working in a accident and the risk of $750,000 a day risk of a shutdown. You never repair a nuclear grade safety relay. You reinstall it with band new high quality safety grade relay. You call immediately that god dam machine or circuit INOP when you get any pitting. You make the component a “critical path” for reactor start-up...to energize all your staff to come up with a new relay before it starts costing us big bucks. Yet again, how times do we have to hear of the opportunities that Vermont should not have started up that reactor, or once it was operational the broken relay should have caused them to immediately shutdown?
2) The above italicized sentences are prima facie evidence coming from the horse’s mouth that Vermont Yankee had reason to know that they started up that reactor illegally and unsafely. And it is evidence that the NRC accepted VY secretly violating tech specs because they haven’t called VY on the big sin in this event.

Discussion
“Revise procedure OP-5210, "MCC Inspections", to provide criteria for determining contact wear and replacement.

See, everything is about this is perspectives. There is fabricated or designed perspective or point of view...then there is the real story. These guys are so deep into lying they can’t keep tract where they lied in the past. Everything written in these procedures is there for a purpose, or what is legally required to be there and is missing is absolutely intentional. These things are so unbelievably scrutinized. The primary function of these procedures is to provide operational flexibility and to conserve corporate cash. There never is a mistake or incompetence in these procedures because a comma misplacement could cost them many millions of dollars. Incompetently written up procedures or invaluable federal regulatory criteria’s missing from them are a sure sign those procedures are designed to improperly enhance operational flexibility, and god knows how risky that is. So the procedure “MCC Inspections” is a generic procedure defining how all breaker inspections are to occur throughout the plant. They got many 100’s of motor operated valves and they got a breaker for each one...they probably got 1000’s of relays.

“Think about all the issues over degraded contracts over the years at VY....the enormous experience the nuclear industry has with electrical contact problems. Does it seem plausible that they wouldn’t have a written criteria for the relay contact wear and replacement...even as it was required in10 CFR 50, Appendix B, Criterion V? Who would a non disclosed or documented criteria benefit? Can Entergy possibly be this incompetent?

If they had a relay wear inspection criteria on 05/31/07 then the electrician’s would have had to follow the directions of the procedures. They would be held accountable for falsification of documents and not following procedures. If the criteria was in the MCC inspection procedure they would had to call HPCI INOP on 05/31. Once it is written down and a known criteria...the paper trail begins...then they known a cover-up is a impossibility. Can’t start up the plant with HPCI inoperable. So the absence of the relay wear criteria was the intentional tool that allowed VY to look incompetent with not having a relay degradation criteria in their procedure. The “we are so unbelievably stupid defense” was their ticket to start up that reactor unsafely and illegally.

The absence of the criteria was an intentional strategy to give them exactly the operational wiggle room that allowed them to start up the reactor. I’ll bet you the operational testing on V23-19 on 6/01 was because they were nervous with the reliability of the relay. It was designed to give the NRC the assurance of due diligence if it failed immediately upon start-up like it did. The managers could say the “pitting and wear” was normal, we, the so called tested that hand grenade with a pulled pin over and over again, knowing the reactor startup was right around the corner, then illegally start the reactor up on 06/06/07. If Vermont Yankee ran into trouble upon start-up, they knew that relay would be cycled over and over again, the chance of failure was high. They want a phony rationale we certainly tested in enough between 5/31 and start-up. They want to drawl the NRC away from the cover-up of 5/31...give the NRC the flimsiest excuse to overlook the broader cover-up. You see what I an getting at, I think it is a industry wide problem, if you give the NRC the flimsiest excuse or rational they will ignore blatant rule breaking. What kind of parent is that if the NRC accepts any stupid excuse from their children?

The smoking gun would be if on 5/31/07 they went through the paper work process of looking for a repair parts relay for HPCI. Hmm, they might see the limitation of that, gin up a reason to inspect the relay at operation weeks later, then put in the paper work starting the search for a repair part replacement. These guys are all into the knowledge of the meaning of the paperwork trail. They are all aware of the paperwork trail game. You can’t accuse us anything if you can’t prove it.”

I broadly question if the NRC are meeting the community’s needs of maintaining a safe Vermont Yankee organization. The NRC inspector’s on the very next inspection associated the June 6, 2007 start-up with should have fully captured in writing the events in detail of the HPCI in their next inspection report. Both violations should have been uncovered because all the information was there. The first mention of a violation was in Dec 07, then the next one occurred in a upcoming inspection report. This is completely unsatisfactory. It is like a cop giving you a speeding ticket and failure to inspect you vehicle a year after the date when it occurred. I get it, if you got the safety inspection after the violation, entered into you known defective corrective action problem, then the year old car safety inspection never happened, and this new information make it inconsequential. You can’t charge or accuse anyone with anything if it is not written down. Why was the first mention of this in a few paragraphs in December 07 inspection report? How could we be talking about a new violation for a 2007 event, and it be the middle of 2009? Why wasn’t the public immediately notified that there was two violations surrounding this event in the first inspection report opportunity. The not meeting10 CFR 50, Appendix B, Criterion and then not have a appropriate safety evaluation saying that the “carbonized and pitting” relay could meet the full intended function of HPCI in any designed accident. I bet you it would have turned into a sited violation or higher if it was fully disclosed in the first inspection opportunity after early June 07?

There is a whole idea here that the NRC doesn’t capture Vermont Yankee operation events that interest the community in their inspection reports. I have in mind the steam tunnel clean up leak and the cleanup problems where they injected air or resin into the primary system causing the evacuation of the reactor building. The NRC is just not meeting the needs of the community through the ROP and the depth of the inspection reports. I believe if the NRC met the communities needs, this would make the nuclear plants a lot more stronger and safer.

“Imagine you are a licensed operator in Vermont Yankee. Some people know that there are degraded relays in HPCI...but nobody in the control room is allowed to know. If you tell a licensed individual that unreliable relays are in the HPCI he is likely to call that machine INOP on his own. He’d be looking up the wiring diagrams on his own and he would make a independent judgment. You see the incentives from keeping degradation information away from the licensed people?

So an accident occurs with the need of HPIC...the relay slowly fails. The crews gets stuck in diagnosing the completely unknown problem that is really known by everyone. They make a easy human error with over focusing on fixing and operating HPCI when they should be trying to cool the core. They get behind the eight ball and they then overreact. Remember the operation’s department doesn’t know about the degradation...but engineers and executives know about this? Can you see the magnitude of the cover-up when the operator's makes a screw-up?

All bets are off if two known safety degradations show up in a emergency on separate equipment in the same accident. You can’t predict the human interaction and it is highly risky. If they get caught taking a short cuts once (such as carbonized and pitted relays” ...you can depend on this was occurring for 5 years or more and everyone was doing it. You got to know there are a lot of secret component degradation, lots of safety equipment that will break down in the stress of a accident, information is being kept from the license operator. Many off control room engineers and executives know about a lot of secretly degraded safety equipment. This is all below documentations...so nobody is able to keep tract of the magnitude of it.

The more right way of dealing with this( not correct) is notifying all the control room employees of the degradation. Everyone does training on the degradation symptoms...everyone is fully trained on the unreliability of HPCI. So the plant has a accident with the necessity of HPCI, the whole control room is thinking many steps ahead that it is a expected condition when HPCI fails. During the startup of the machine they are fully trained on what symptoms that will show up with a failing relay. That machine blinks or burps they will drop that machine like a ugly women. They already have thought ahead in that it will fail ahead of time. They are prepared to immediately continue on with their emergency procedures. It would just be a inconvenient blip...they would use the rest of the equipment to protect the public.

Right, you don’t have that confusion with a unknown safety system failing and the delay time. Fiddling around with dead, but not known dead machine eats up licensing resources and severely eats up control room intellectual resources.

The problem is once you get the control room licenses involved with accommodating the failing relay...then the cover-up of degraded equipment can’t be maintained. There are all sorts of documents and peoples testimony proving that HPCI wasn’t functional and the plant was knowingly gaming the allowable outage time. That is intentional falsification of the condition of nuclear safety equipment and it is provable in a court.

If you play the very profitable roulette betting game of intentionally not having the expensive repair parts on site...then you should be punished with a very expensive reactor shutdown. If you are not competent with maintaining a nuclear power plant’s repair parts warehouse and inventory ...then you need to be severely punished for the good of everyone. That is the only way you are going enforce the integrity of the warehouse repair parts requirements...that is how you limit the number of lying employees and cover-ups.

If you called one plant on this it, it would never happen again. If you let VY get away with it then everyone else will do the exact same thing....and they will keeping taking chances until there is a huge accident. They will compete to the death.”

You see what I am saying, these control room people are so smart. They all have been trained so much, they all have gone over and over tech spec training so often. They had so many quizes and test questions thrown at them in license school and requal training about the tech spec requirements upon startup ....they know these things in and out. They are seeing these things through a professional eyes and we are seeing it through outsiders eyes.

Imagine you are a young fresh licensed operator up in the control room. Nobody admit these things straight out. You’d seen the NRC inspectors come in and out and they have thoroughly questioned everyone including the shift supervisor. You know everyone is aware of what occur. They started that plant up, and the management with the NRC’s knowledge fiddled with the tech specs and the rules. The pulled their punching in publicly reporting this. Management and the NRC colluded to falsify the whole thing. The young licensed operator would say, really what kind of a risk was this to the public. Especially thinking about it after it was all fixed on 06/13. He would say it was absolutely no risk to the public.

But in the astonishing chilling thought in the back of his mind he’s know management and the NRC were colluding together potentially saving the company millions of dollars. If I catch a safety defect that is going to cost Entergy millions of dollars what chance does my career have to prevail if the NRC and management are in cahoots for the big bucks. They could both lie saying I am a incompetent operator with a mental illness...and I would lose my job over reporting safety defects that crosses the NRC and my company. .

So is this isn’t about the isolated risk of core damage associated with the offending relay...could you get to core damage through our risk studies with a welded relay and HPCI not operational.

Or is it about a completely different accident than the simple assumption. What if the site and the licensed operator’s lived with the idea that the nuclear industry was brutally “unjust” and they thought they faced the fear of being fired for raising legitimate safety concerns. There was only “one” way to talk about conditions in the industry and everyone only talks with the nuclear industry’s single voice. The industry and the NRC held absolute and infinite brutal power over these employees with absolutely no human rights.

How much money is human rights worth? How much salary would you need if they told you your US Constitution would “not” apply while working on corporate property? Would you sell your constitutional rights for $100,000 a year and benefits.

Right, the utility and the NRC are saying our story is the absolute facts....our story can’t be contradicted...truth is disconnected from real reality....your story or evidence will never have any standing in our system.

If that isn’t brutal dehumanization nothing is.

The only remaining questions is, what would have happened if Vermont Yankee asked the NRC’s permission to start up with HPCI inop. What would have happened if they couldn’t make the HPCI operational within 24 hours upon start-up, could they asked the NRC permission to keep running until its fixed?

Sincerely,

Mike Mulligan
PO Box 161
Hinsdale, NH 03451
steamshovel2002@yahoo.com
1-603-336-8320

My Christmas story...David

My Christmas story...David


I worked at a children’s mental institution....maybe around 2001. David had Down’s syndrome. If you ever knew what got him up into that facility...it was horrific and unthinkable? Even with the movies and tv...you can imagine it. I was an untrained group home councilor. I had spent some time being unemployed. My last job I was being a long haul truck driver...what did I know about taking care of the most severely disabled children in New England. I couldn’t get up there unless I had a poor work history. I was sent up there to save David. My friends put me in the worst group home in the facility...they targeted me for this house.

I utterly failed.

I remembered seeing David for the first time. I wasn’t ever exposed to many disabled children like this. He frightened me. His nose and mouth was always leaking. He had a huge tongue......he could hardly keep it in his mouth. I remember that flash of disgust and fight, when I was with David, and new people had seen him for this first time. We took him out to the community often. I worked with him for a little over a year. I fell in love with him...well, a much as you could for a counselor at a mental institution. He didn’t know how to talk and sign. He could laugh really well.

I arrive at the group home, early one Saturday morning at 7am...I am getting ready to put in 12 hours of work. About an hour later, I go into David’s room to wake him up.

I walk through a drab, bleak and colorless living room....all the furniture and rugs are extremely old on the way to his room You can tell when you are in a institution with the rooms being ail gray and drab...they are all of the same. After the living room, there is a long hall in front of me...there are three doors on each side. David’s door is the last door on the left. We put him there because he can be rambunctious at times.

I enter his room. His room has grey or light blues colorless walls...there are stains on his walls. It’s got one bed on the far end, one dresser...and absolutely nothing else in the room....well, a closet. He got no pictures on the wall. It is not like my colorful son’s room. David is still sleeping. I open up his window curtains...it’s a beautiful NH winter day and the sky is so blue outside. I call his name nicely.....”David, David”. He stirs awake. He sits up in his bed...he grunts a kind of “hi how are you”. I say “good morning David...how are you”? “It’s a beautiful day outside.”

David and I generally have a blast getting dressed. I would hand him his pants after I get them from the dresser...he was suppose to put them on by himself. He then would fling the pants over my head. He’d do the same with his shirt and socks. He got such a kick out of defying me. He’s run around me laughing...I would say “David”...and he would get me laughing. I might have to chase him and his pants a few times depending on how he felt. He would eventually dress himself. I really enjoyed playing with David.

You never could laugh quietly with David...it was impossible...it was always full and hearty laughing with both of us. Laughing in a bleak mental institution is such a unique and powerful experience. You are laughing at the suffering and death all around you....parentless children mostly. You are laughing at the private, state and federal bureaucracy who set this up. Indeed you are laughing at the indifferent good people of the USA.

So David gave a series of grunts as he was waking up. He recognized who I was and smiled at me. He didn’t jump out of the bed with me gleefully chasing him around the room. I quickly recognized that something was up with him. I sat down on floor trying to signal to him that we could be still for awhile...trying to figure out what was wrong with him. Is he sick...how do you figure out if a child is sick, who can’t talk to you? He is so quiet and pensive. I am not worried about him being sick I feel yet.

I catch his eyes looking at my face, he broadly smiles at me. His head quickly turns away as we make eye contact. It’s a strange smile...it’s a focused smile. This is not like him. He looks at my face again; he has a big wide smile, a quiet smile....not a rambunctious laugh. We have eye contact for a moment, then he turns his head down. I watch his head return to my eyes. He’s got a big wide grin on, holds it for a few seconds...then his face gets serious. His head turns down to his chest. He looks me in my eyes again. He got a painted-on smile on; it is still big and wide then his lips flash into being serious. His head returns to his chest. He does the whole thing again, with a little less of a smile, and his lips are beginning to turn down.

I am confused ...I don’t know what is going on. Then I see his watering eyes and a tear is running down his cheek. The smile completely disappears...but he keeps turning his head to me, then away. He is quietly crying in front of me, returns into his chest, then looks me in the eyes with many tears. Many tears, quietly sobbing... over and over again. I have no idea what is going on...I’ve never seen this.

You have to steel yourself working in a children’s’ institution as this. There are a few laughs, many temper tantrums and outburst...lots of angry children at times....and you call the nurses often. I save my crying for my car when I am driving home. It was such an extraordinary difficult experience...nothing can prepare for it. There was all kinds of children with many different disabilities...and some children were sent there to die. It was a facility for the severely sick and disabled children.

But David is crying in front of me this morning. It’s dawning on me that he is tenderly crying to me...I don’t know what’s wrong with him. How can I fix this I think...Is he sick enough to call the nurse? Then I start tearing and burst out crying, right out of nowhere. It’s way beyond me control...”what is wrong with him”? “How can I fix it?” I have no way with knowing what’s wrong with him. I tearing and crying a lot now...I continue thinking, “what’s wrong with him”. How am I going find out what wrong with him. It dawns on me, that I am not going to find out what’s wrong with him. I cry and sob with him a lot more. I am at a lost with what to do. I am thinking about this horrendous system in front of us and we all are so powerless. It’s a moments like this that time stands still.

I collect myself together a little. I call the nurse into the house, I tell her with unhinged red eyes, David is crying and I don’t know what is wrong with him. Oh, she says, are you OK? She finds nothing wrong with him.

About two weeks later, in the morning, we find David dead in his bed. He died from a blood clot in his heart.

I still don’t know why David was crying...nobody knows why he was crying. It’s not like him.

Please help me figure this out...Do you know why David was crying?

This occurred in and around 2001. Everyone wants to forget about this kid. He is long forgotten....nobody remembers him.

Investigation into pipe welds from Newport News yard widened

Updated 12/19@5pm

I guest the question is...why couldn’t it be sabotage of some type?

Are there any difference between using the fillers...like could there be an advantage of some type with copper-nickel filler...is it easier to weld or quicker.

Was there a shortage of the stainless steal filler or was it more expensive...thus you gain some type of advantage...was there a production problem with the stainless steel filler?

http://www.dailypress.com/news/dp-now-northgrum.1219,0,7482497.story

Navy probe of weld problems expands
By PETER FROST
757-247-4744
3:28 PM EST, December 19, 2007
NEWPORT NEWS

All vessels constructed or serviced by Northrop Grumman Newport News since 2000 will be included as part of an ongoing probe of welding errors on submarines and aircraft carriers, the U.S. Navy said Wednesday.The Navy will complete an initial assessment of critical welds on all interior, non-nuclear pipes in at least 17 vessels affected later this month. The investigation also will be expanded to include other surface ships that have been serviced by the yard in the past seven-plus years. Included in the investigation are at least seven aircraft carriers, six Virginia-class submarines, three Los Angeles-class subs and a Navy cruiser.


Notice, they don’t tell what systems are involved...like any of the seawater systems?

Investigation into pipe welds from Newport News yard widened
NEWPORT NEWS

An investigation of faulty pipe welds on Virginia-class submarines assembled at Northrop Grumman Newport News has been broadened to include aircraft carriers and another class of submarines.

The assessment will cover non-nuclear piping systems on carriers and subs repaired and built by shipyard workers in recent years, shipyard and Navy officials said Monday.

The first indication of a problem came in August, when a piping weld failed during routine testing of the New Hampshire, now under construction in Groton, Conn., at General Dynamics Electric Boat, which is teamed with Northrop Grumman to assemble the subs. When a second weld failed in October, Navy officials launched an investigation.

Since then, the Navy has found at least one faulty or suspect weld on three additional Virginia-class submarines - the Virginia, the Texas and the New Mexico. No welds have failed on the three subs now in service, including the first-in-class Virginia.

It’s the tip of the iceberg...it’s in the navy itself!

It’s the tip of the iceberg...it’s in the navy itself!

One must remember with the Thresher and Scorpion...the theory is nuclear piping took them out>


http://www.navytimes.com/news/2007/12/navy_faulty_shipwelds_071214w/


Faulty sub welds spur inspection of 4 carriers, 3 more subs

By Andrew Scutro - Staff writerPosted : Friday Dec 14, 2007 13:51:18 EST
NORFOLK, Va. — Shipyard workers are inspecting the welds of seven more Navy ships — including four aircraft carriers — after faulty welds were discovered on new Virginia-class submarines built at Northrop Grumman Newport News, according to a company spokeswoman.
The carriers George H.W. Bush, Carl Vinson, Enterprise and George Washington, along with Los Angeles-class attack submarines Oklahoma City, Newport News and Toledo, are being assessed for faulty welds similar to those discovered on the Virginia-class submarines built in part at Newport News, spokeswoman Jennifer Dellapenta wrote in an e-mail response to questions from Navy Times.
But how many total ships will be evaluated “has not yet been determined,” she wrote.
The carrier Bush is under construction at Newport News, Vinson is undergoing a refueling and overhaul at the shipyard, George Washington is in port, and the Enterprise is scheduled to return to Hampton Roads later this month from its deployment to the Middle East.......