My old Feb 22, 2011 2.206, actually dating back to 2010.
"God help us
all, can you see the problem with the repetitive nature of Entergy having the
instincts to not the due proper inspections... to do it over and over again
like a madman. They are laughing at us and the NRC because these
employees and managers know we can't control them. The NRC has no
ability to control Palisades...that is my god damned political statement to the NRC."
June 18, 2012
R. William
Borchardt
Executive Director for Operations
US Nuclear Regulatory Commission
Washington, DC 20555-0001
Executive Director for Operations
US Nuclear Regulatory Commission
Washington, DC 20555-0001
Dear Mr.
Borchardt,
Feb 22, 2011 and Jan 10, 2012 2.206:
“Subject
2.206: Request a emergency shutdown of Palisades because the Reactor Oversight
Program is ineffective and Entergy has a documented history of a culture of
falsification and thumbing their noses at reoccurring violations. It should be
noted in this inspection period most of the fleet of Entergy’s plants are on
fire and burning in the Gulf of Mexico with numerous NRC inspection findings
including Grand Gulf, River Bend, Arkansas One and Cooper.
Now we got repetitive electrical shorts in the VY Recirc
MGs and heavy smoke in the reactor building. Got a assortment of states
desperately trying to shutdown Entergy’s nuclear plants because nobody trust
these guys. Unbelievable union troubles at the Pilgrim nuclear plant and rumors
the union employees sabotage the plant by tripping it in the union action while
the state of Massachusetts is trying to put hold on their relicencing.
Massachusetts and Vermont are more persistent than me. It is a double hitter
going on over there is New York
The NRC is probably going to call the leaking Safety Injection Refueling Water tank (SIRW) shutdown
a planned shutdown. Seeing how for a indeterminate amount of time, certainly
before the last outage, they knew the tank was leaking and did nothing. They
didn’t care the leaking 300,000 gal tank sits above the control room with all
the invaluable instrumentation and all those electrical cables.
So this is the record going into the last outage and the red finding:
“Palisades
had five unplanned shutdowns in
2011. Because of that the power plant now has one of the worst safety ratings in the country.”
NRC concerns:
·
Organizational failures
·
The need for a recovery plan
·
Poor quality work instructions
·
Failure to follow procedures
· Poor supervision and oversight of work
· Poor supervision and oversight of work
·
Poor maintenance
·
Failure to respect the role of an operator
·
Multiple events caused by personnel or equipment failures
·
Questionable safety structure
Language As a Technology of Exclusivity and Special Rules
I framed it as the NRC engineer’s language picks and chooses what issues they bring to the public table and it is immoral. They create a architecture of have engineering half truths and misconceptions in the language structure they make to a community. Vermont, Massachusetts and New York don’t think the NRC has the ability to control chaos at a plant...always got some agency rule trap door leading to all bad behavior is acceptable and nothing ever matters at a nuclear power plant. As long as the public can’t see the bad behavior mean nothing is ever wrong. A structure of selective self interested truths and thus the whole building becomes one enormous inscrutable lie. It’s the history of this industry to tell half truths in defense of self interest and their perception of doing good. It is how you think you doing good and end up destroying 100,000s of jobs and damaging a great nation in the ends of altruism. These guys invented the corporate and government crazy talk phraseology of the 1970’s and 1980’s.
I have seen this over and over again where the agency uses a special language, and a assortment of language rules and engineering rules, supposedly engineer’s speak, as a intention tool of understanding disruption and public knowledge sabotage. These guys are a cohesive mafia honor culture of half truths and it always ends up as the nuclear industry repetitively shooting themselves in the foot. The industry is sabotage their employee’s future for ideology and profit to special people.
This is primarily a crisis of truth telling and the US government doesn’t have a vehicle that demands on severe penalty insufficient truth telling. This is a age old crisis on “what is truth”?
A NRC official recently
spoke of a engineer’s language.
Me: “ As I spoken, it my feeling that the NRC engineer's language...picks
and chooses engineering rationales and issues...indeed picks specific terms of
a petitioner to meet a NRC agenda. What is going on is not pure science, it's
mocking science and the public process. I am not talking about you, you were a
nice guy trying to listen to me...but as the agency talks to me. I have no beef
with you.
See I
think NRC answers me in a benign and selective way...they answer me with a
engineered interpretation of my words that favors the industry or NRC, not in
the most unfavorable interpretation of what I am saying against the utility and
NRC. I think this is on purpose and it may be the way they are trained to make
a response. They could always called me to quiz a point I am really making.
So they expect me to challenge them further down the line with a come back. It is playing games hoping I will lack the initiative to answer them back.
It is just not being straight and direct...it is a form of coercion and corruption.
So they expect me to challenge them further down the line with a come back. It is playing games hoping I will lack the initiative to answer them back.
It is just not being straight and direct...it is a form of coercion and corruption.
The
official: “You expressed that the material facts of the seal (the temperature
duration in radiation for example) had not been established through testing.
Therefore, the NRC staff could not prove to you that the Buna-N threaded seal
material is adequate for accident conditions as well as normal operating conditions.
You also expressed that you felt that the NRC staff’s safety determination was
merely “throwing engineering language” at you instead of addressing your
concerns.”
Gaming Language: when did the SIRW tank begin leaking?
Here is a prime example the engineer’s language . And I will
tell you something, there is no engineer’s professional ethical code or legal
requirement for these official to tell the full and complete truth in the media.
There is no ethical code requiring the nuclear officials to tell the full truth
to the public. There is a bogus permissive for “competitive or propriety
reasons” nothing ever should be disclosed without a huge fight to the public.
There is no law to hold these official accountable to the truth said
in the media. Certainly there is no consequences for lying. These are public
news announcements.
The NRC was made aware of the leak in April when the plant shut
down for refueling. Both Entergy and NRC inspectors monitored the leak. The
plant set a limit that if more than 31 gallons leaked in a day, the plant would
shut down, Mitlyng said. The plant's license specifies that no more than 34.8
gallons leak a day.
According to a news release from an Entergy
spokesman, workers had been monitoring leakage from the plant's safety
injection/refueling water tank for several days. but by 1:41 p.m. Tuesday, the
leakage had surpassed the limits they set so the tank was declared inoperative.
Mark Savage is a spokesperson for Entergy,
the company that owns the Palisades plant. He says this tank has been leaking
for several weeks. It’s an old aluminum tank that holds 300,000 gallons of
water. He says the tank is the same age as the Palisades plant: 40 years old.
How come Entergy’s Mr.
Savage isn’t required to give all the factual information...how come in the shadow
of the red finding they didn’t disclose when this leak began and the location
of the tank? How come as a matter of community honor Mr. Savage didn’t
initially disclose we got a leak in this tanks is and want do you think if
ignore it and started up...what do you think if we ran it to the tech spec
limit. What do you think if the unknown crack and leak was getting bigger and
they said it won’t be until months until we are required to shutdown and find
out what is leaking?
The
licensee believes that the tank is leaking from several locations. However, at
this time, they cannot determine exact locations.
The best defense of safety for the plant is to have adequate safety margins, “as the designers intended the plant to be”. And the first nuclear safety culture precept in any deficiency in initial plant safety plant design, is you fully understand what is causing the barrier degradation. You can’t tell how bad the crack is until you eyeball it for yourself. Imagine that, there is no law requiring them know where a leak is. Engineering says for critical safety public interest you fully understand the magnitude of the degradation and what is causing a leak. How can you tell the difference between a insignificant leak and another insignificant leak, but the second insignificant leak is showing the potential for a catastrophic break. A leak of unknown engineering dimensions, a leaking rate 10, 20 and 30 gals per day....the leak gives an engineer extremely limited information.
Davis Besse once had a safety insignificant safety leak and the information entrained with this increasing insignificant leak brought the nation to within 1/8 of a inch nuclear crisis. There were diligently measuring its increasing leakage rate as a unimaginable hole ate away inches of metal away from a reactor head. They tripped over the leak while shutdown, that is how they caught it.
Right, it is how men make self interested rules based on personal advantage on how to interpret new information. It is not requiring a human to use his full astonishing mental capacities to interpret new information. You see the how risk related regulation allows the facility to make a safety determination based on very limited information. It gives the operators of a nuclear plant a permissive to act stupid for mere pennies. This 300,000 gal tank has very small 35 gal a day leak and it gives Entergy the permissive to not care why it is broken. You could have a minor earthquake, and their could be a degradation in the tank wall in which the whole tank spills into the bottom of the building. In nuclear power plant, there is many more safety angles other than just having enough water to cool a core. You might plenty of water, but not a way to get it to the care. You see what I am saying, risk regulations allows them too base safety on just a fragment of information. A 300,000 gal tank:
It would take you 42 days to fill up this tank by a
garden hose.
It is 15 average size swimming pools of water in
the bottom of the reactor building or within the control room..
And then the size of the leak was increasing over months. It means some worsening process was ongoing and nobody thoroughly understood what the process was. Risk regulations is the permissive to make me think stupid and act in my own interest! None of this is nuclear safety! These concepts of blowing by the initial engineered safety tank design margins and not knowing what caused a tank leakage is a threat to the conservative safety assumption and actions country wide. It not what you know that kills you (leakage rate) in Davis Besse, it is the unknowns the leakage is telegraphing you. This tank feeds all of the emergency make water for this nuclear reactor: high, medium and low pressure feed. It bad enough the utility doesn’t know right from wrong...but this is a grave principle of conservative nuclear safety that the agency doesn’t know right from wrong. As for the acceptance of a assurance on a Safety Injection Refueling tank leak with such a worsening indeterminate leakage and carrying so little factual information by Entergy, are there any real engineer’s with moral conscience voice left in the NRC? Does the agency know how important missing information and selective data is with knowing and understanding safety? It is not the information and evidence you can see with your eyes...it is the missing information and evidence that is the killer.
Does risk perspectives make curiously, facts and evidence obsolete?
NRC concerns:
·
Organizational failures
· The need for a recovery plan
· The need for a recovery plan
·
Poor quality work instructions
·
Failure to follow procedurese
·
Poor supervision and oversight of work
·
Poor maintenance
·
Failure to respect the role of an operator
·
Multiple events caused by personnel or equipment failures
·
Questionable safety structure
I always thought the ROP punishment for a utility’s bad behavior was to appease the wider public. It is to shallowly make the public feel better about nuclear power instead of making the industry better. It is to create a smoke screen to make the public think grand changes are underway for a bad utility. But it has no or little effect at changing utility bad behavior. Here is the absolute evidence just months away from a rare red finding. The ROP is just for show. Here is what the NRC thought of Entergy this past Feb in their red finding.
For conservative
assumptions, the inspectors reviewed the Apparent Cause Evaluation(ACE),
corrective action documentation, the recovery plan and NRC inspection findings.
The licensee determined that the apparent
cause was managers making decisions based on meeting only minimum regulatory
requirements. The inspectors concluded that based on the findings reviewed
by the licensee, the licensee identified a reasonable apparent cause. However,
the inspectors believe that the recovery plan elements related to address leadership engagement, correction of performance
gaps and degradation of safety culture principles more accurately characterize
the causes of the findings. In addition, the recovery plan includes broader
actions that will more likely effect change. The ACE actions included training
of supervisors on conservative decision making. While this is a reasonable step
in eliminating the cross-cutting theme, management
reinforcement of conservative decision making is necessary to achieve
sustainable results. While the ACE corrective actions capture this through an
observation form, the broader elements of the recovery provide a mechanism more
likely to achieve sustainable results.
So here we are in a
preventable shutdown. From the beginning before the outage Entergy knew they
had a unknown defect in the Safety Injection Refueling tank with a increasing
leakage rate. They had a conservative opportunity to completely understand the
nature of the leakage and repair it before the startup. It is right out of the
mouths of the Entergy officials before the red finding and all the plant
troubles... now with the SIRW tanks accident. Its right out of the mouth of the
NRC talking about Entergy’s problems...they continue “only” meeting the minimum
regulatory requirements and making poor conservative decision after all this
self flogging back whipping and crying crocodile tears. It is as if pretty words
in front of community and the promises they made to a nation have no meaning at
all. It is all for show! We are all in a reality TV show and nothing has
meaning at all except customer ratings. They don’t even care if all they are
drawing is the losers in our society.
Yet, where was the conservative influence of the NRC with making Entergy eat there own words in another component degradation. In their own words, “stop just meeting only the minimum regulatory requirement”? How come NRC behaves like reality tv where words and errant emotions have no meaning...where everything is a insignificant show. How come they don’t act like billions of dollars and our nation’s engineering reputation are at stake? How do you get them out of la la land...what will it take?
Does the agency put in credence in their own NRC inspection report words that condemned Entergy with only meeting minimum regulatory requirement, engagement of performance gaps and degradation of safety principles? Does the agency’s own words have any meaning at all and do they perform any organization force on maintaining safety principles in the whole of the nuclear industry? If congress told the NRC to rob a bank or destroy the nuclear industry through self serving rules...are the plant NRC inspector obliged on pain of the law to rob a bank or destroy their nuclear plants through indifference? Are promises to keep to a community and inspection report words just meaningless noises in the breezy? Is this reality tv disconnected from meaning?
NRC concerns:
·
Organizational failures
·
The need for a recovery plan
·
Poor quality work instructions
·
Failure to follow procedures
·
Poor supervision and oversight of work
·
Poor maintenance
·
Failure to respect the role of an operator
·
Multiple events caused by personnel or equipment failures
·
Questionable safety structure
All of the nuclear safety principles the NRC has been espousing in the shadow of Palisades bad behavior post red finding should have drove the agency to make Entergy fully engineering wise understand the Safety Injection Refueling tank leak before start-up and bring that tank back to the initial plant safety design at earliest shutdown opportunity. The agency’s correct ‘inspection’ and red findings words to Entergy now condemn the agency itself. The agency’ s nuclear industry philosophy are a disgrace to the world of nuclear power safety principles itself. The first principle to the community should have been to notify the public that the tank was leaking from a unknown location and the leakage rate was increasing, yet still meeting its tech spec limit from the moment it began leaking. In the shadow of one of the worst plants in the nation and a red finding, why does this information only show up in a emergency shutdown.
A conservative assumption based on
the location of the tank, the leak rate is ramping up in a spike for unknown
reasons...they should have scrammed the plant.
They
should have admitted the 300,000 leaking tank sat on top of the vital control
room. The agency should have asked the
public what they thought about this condition when the leak first showed up.
That is public participation. The first principle should have been complete
truth and full discloser to the public in the shadow of the 4th
worst operating plant in the nation. I certainly would have requested a
immediate shutdown and repair of this tank from the moment the tank began
leaking. It is beyond preposterous public credibility-wise in the shadow of
Fukushima, that the agency didn’t admit the core cooling and make up tank was
leaking and the utility didn’t know where and the extent of the damage till it
directly challenge tech specs. Palisades and NRC secrecy facilitated the
operation of a not safe nuclear power plant.
In the shadow of Fukushima and the 4th
most dangerous plant in the USA, should the agency be creating more plant
operating super secrecy or more transparency?
Does
the agency know right from wrong? Does the agency’s words of criticism to a
poorly performing plant have any order creating meaning at all? Or are they
just altruistic words broadcasted to the public without any internal backing
what so ever.
So here I am giving two week warning on May 30 predicting based on the past behavior of Entergy that a controversial plant trip or a unplanned shutdown (June 12) was right around the corner. Congratulation Entergy that was a pathetic 34 days of continuous plant operation. Doesn’t that question how many shutdowns and plant trips they will have in the next cycle.
“I smell a troublesome
plant trip in the air....”
“Come on, admit it?”
Is this the grand NRC “nothing ever matters” philosophy on leaking nuclear reactor safety system water leakage stated by a agency official. Does all that we know about accident warnings and precursors boil down to all nuclear plants are able to operate when some parts that are leaking. Does the NRC just act like reality TV viewer aren’t real...the community out there is fake...the world has no meaning and consequences at all?
And we sit in the shadow of another NRC disgrace in San Onophre. The new steam generators didn’t meet their original design specification. Who cares if nuclear components are always leaking and nobody is required to meet original design specification until a terrible accident shows up costing the ratepayers and our nation billions. Who cares, it acceptable in our rules, our rules are the primacy in our safety philosophy. Our rules are our god and our god is unanswerable to all outsiders. Right, it all a reality TV show and nothing matters or has consequences. We are all protected because everything is fake.
Who cares about if all or some reactor safety parts are leaking...who cares if the computer safety engineering codes don’t meet original design specification? And she misrepresented it cause the leak has been getting bigger and nobody understood why and how it was leaking. There is not a higher safety principle in engineering than in fully understanding what is going on in a nuclear plant. I know what is going on with my indications and I can confidently predict the outcome of all my indications...no guess works and rolling the dice in this industry. Is this really the safety philosophy of the NRC?
Nuclear
plants are able to operate when some parts are leaking. "There is always
some kind of leakage going on," Mitlyng said. "As long as it's very
small and doesn't get bigger."
Here is an the
emergent problem Palisades didn’t handle correctly in the recent past. It lead
to a very serious plant accident and out of control plant trip. It set up a
pattern of risk taking that lead to risking human life trying to keep the plant
operating when maintenance work wasn’t done right and safety equipment wasn’t
installed as originally designed. Other serious problems and this led to being one
of the worst operating plant in the USA. Basically they had a so called minor
indication of a fail equipment warning light
that they put off at fixing when the plant was in safe shutdown
condition. Does it sound familiar? This
minor lamp defect led directly to a grossly botched installation of new breakers
replacing obsolete breakers to a back up DC emergency electrical system.
Honestly, talking about safety budgets and priorities...risk perspective...what
proof do you got that insignificant problem won’t lead to a enormously mind
boggling problem. There it is that insignificant problems lead directly to a
incompetent nuclear operator and big national problems. Here is the case that a perceive
insignificant problem led to a degradation in the life blood of emergency
electrical power to many nuclear plant safety devices. And with the Safety Injection Refueling Water tank leak of
unknown location and degradation mechanism the chances they take just get
bigger and bigger. What is wrong with you, our rules allows this. Our rules are
your god!Buddy, in a nuclear plant all priorities and budgets are immoral. You never know all the risk until you get down to the bottom of the rat hole...a sterile computer model is never as smart as our brains and computors senses are not hard wired to the real world like ours. They found grave maintenance errors in the installation of this important safety gear while at power and they didn’t have the integrity to immediately shutdown the plant and fix it at a safe shut condition. The DC electricity plant trip and the leaking Safety Injection Refueling Water tank is the exact same issue derived from only meeting the minimum regulatory requirement. Rules carry so little information and our human brains can process so much information...our brains are so smart at discriminating important information from insignificant information. We do it much better than some blind and stupid rule. But what can you do if a rule gives us all the permissive to act stupid...
“Prior
to the 2010 refueling outage 1R21, routine preventive maintenance performed per
work order WO52025543-01 identified that the green status indication lights for
the containment escape air lock MZ-50 were not working. Although
CR-PLP-2010-3580 and work request WR210717 were issued at the time, this
condition was not addressed until the troubleshooting activities scheduled for
Thursday 09/22/11 under WO248834-01.
In the NRC’s words, this was all thought of as a
insignificant problem until seem from the light of the history made of the DC
bus plant trip. Did I once say it, all catastrophes emerge from inaccurately
perceived insignificant problems.
During
Refueling Outage (RFO) 21 in the fall of 2010, the licensee performed extensive
maintenance on Panel D11-2, which included the replacement of 10 breakers
inside the panel, as well as other maintenance activities. Any performance
deficiencies associated with the maintenance conducted during RFO 21, which led
to the instrument air transient that occurred on September 23, 2011, will be
addressed in the fourth quarter NRC Integrated Inspection Report (IR)
(05000255/2011005). On Thursday,
September 22, 2011, the licensee commenced a WO to troubleshoot the inoperative
green indicating lights for Door MZ-50 (Emergency Airlock Lights). Through this
investigation, all interlocks, indication lights, and limit switches for this
door were found to be satisfactory. Since this door was due for its technical
specification (TS) required surveillance test on Monday, September 26, 2011,
the decision was made to conduct more troubleshooting activities to identify
the cause of the indicating light issue.
The Safety Injection Refueling Water tank leak is much
worst then the DC system short. It is the exact same accident with the NRC and
Entergy accepting for self interest incomplete information around a safety
system defect or degradation. The crack rules allows us the permission to not
fully investigation a safety system degradation because risk regulation is
designed to make us stupid.
They keep
recklessly repeating the bad behavior over and over again, no matter how much
public back flogging they do to each other and the promises they make to the
public and the community about changing their bad behaviors. As with a host of
terribly poor utility’s behaviors like Entergy, Fort Calhoun, TVA and SCE, it
is like the NRC is oblivious to their choices of not demanding a change in
behavior from a bad utility. This is truly regulatory and NRC insanity. There
are enormously costly consequences to our nation all around us right now. It is
like the agency is running around utterly disconnected from the consequences of
their choices and the outcomes of not being involved with controlling bad
behaviors. The agency doesn’t understand cause and effect....or the agency
doesn’t know how to drive effect.
Fed 22, 2011
'It would know the conditions (dysfunction) of the
managers and employees, we would know every error of a policy, the absence of a
procedure, rule or organization attribute, know perfectly every defect in every
component. We would have the perfect gods eve view of the plant and the
organization. Push the magic button, do we have a green, yellow or red light at
Palisades, the NRC or Entergy?"
Request Palisades nuclear power plant and all Entergy nuclear power plants be immediately shutdown.
NRC concerns:
·
Organizational failures
·
The need for a recovery plan
· Poor quality work instructions
· Poor quality work instructions
·
Failure to follow procedures
·
Poor supervision and oversight of work
·
Poor maintenance
·
Failure to respect the role of an operator
·
Multiple events caused by personnel or equipment failures
·
Questionable safety structure
1) That the Safety Injection Refueling Water tank
shutdown be defined as a unplanned shutdown.
2) Request
the NRC bump up the Palisades performance indication from red to the next level
of V: Unacceptable Performance.
3) Request an outside authority, nobody trust the
NRC’s OIG...why didn’t the agency force Palisades Entergy to thoroughly
investigate SIRW leak when the leak first appeared. Why didn’t the NRC make
them fix it in the last safe shutdown period according to the agency’s own
nuclear safety culture philosophy.
4) Request top Palisades Management staff be fired
and replaced before startup.
5) Request Entergy's corporate nuclear senior staff
be fired and replaced before the restart of the plants.
6) Immediately request two addition NRC inspectors
to be assigned to Palisades plant, and to all the rest of the
troubled Entergy nuclear plants. There seems to be a few plants of the bunch
that behave themselves.
7) Request the formation of a local public
oversight panel around every plant.
8) Request a emergency NRC senior official
oversight panel with the aims of reforming the ROP.
10) There continues to be some heavy duty and exceedingly numerous findings of problems with Entergy plants' this inspection reporting cycle...do an analysis of why this is occurring.
11) Request a evaluation if NRC region III has enough personnel and resources.
12) Stay shutdown or remain shutdown until all
procedures are fully updated and corrected, all technical and maintenances
backlogs are updated and corrected, all training completed, all reports and
safety processes fully completed and implemented.
13) Request a independent outside investigation
over the insufficient process outcome of the 2008-2009 Palisades security
falsification, investigation, safety survey local and fleet wide training and
safety surveys. Based on the DC root cause it appears the safety culture for many
years has been grossly defective and ineffective, along with the ROP... with
then all these processes failing to discover the true depth of Entergy's safety
cultural problems and they lied about these processes fixing Entergy. It sounds
like this is a generic problem to me. We are broadly are worried about in 2009
over the Palisades security falsification, in the outcome of the violations,
whether all the reports and employee cultural surveys with the assortment of
NRC and Entergy processes over these very serious violation ever
had any meaning at all. According to the Palisades Fukushima Emergency
Power System DC short and plant trip, the most recent root cause Entergy
admits there is deep and widespread safety cultural problems at the
Palisades plant. I feel Palisades safety culture was in the pits in 2009 and
before... and the cultural safety survey was a grand Entergy and NRC falsification.
The NRC Alternate Dispute Resolution secession over this, the
Confirmatory Order, the Entergyinvestigative reports and safety cultural survey,
the willing acceptance of this insanity by the NRC and Entergy created the
inaccurate falsified impression to the outsiders that Entergy had discovered
all the cultural safety problems and corrected them. Nothing could be farther
from the truth, all these corporate and agency processes covered up and
deepened, took the public's eyes off fixing Entergy... where Entergy
now is in much worst condition than they were then. I request
independent outside investigation on this dangerous agency corruption before Palisades
start-up.
14) I request that President Obama fire Chairman
Jazcko and the other Four Horsemen of the Apocalypse Commissioners!
Oops, this has been completed.
