Jan 2014 Messages to Senator Shaheen about Seabrook

Jan 2014 Messages to Senator Shaheen about Seabrook

Bottom line, they only replaced a small percentage of the defective service water piping.  

Apr 28 2015

Service Water Piping Replacement for the Diesel Generator and Primary Component 

Cooling Water Heat Exchangers 

a. Inspection Scope The team reviewed EC 274172 which replaced degraded Plastisol-lined service water (SW) piping on the supply and return of the ‘A’ and ‘B’ emergency diesel generator (EDG) heat exchangers and degraded cement-lined SW piping on the supply side of the ‘A’ primary component cooling water (PCCW) heat exchanger. NextEra performed the modification to replace degraded SW piping with a corrosion resistant material to ensure long-term system pressure boundary integrity. NextEra replaced the carbon steel lined piping with AL-6XN, an austenitic stainless steel material, suitable for seawater service without the need for internal lining or protective coating.

I give Senator Shaheen a B+ on this. She got it all on the record. But she never had any active involvement or follow-up. The office never stayed on top of it. The NRC read her like a book..felt she would be happy just getting this on record. 

Writing to Senator Shaheen office and on the NRC docket
Remsburg, KristyFrom: Holmes, Sarah (Shaheen) [mailto:Sarah Holmes@shaheen.senate.gov]
Sent: Tuesday, January 07, 2014 10:09 AM
To: Dacus, Eugene
 Subject: FW: Seabrook issues
 Gene, Happy New Year- I hope you and your family had a nice holiday and are staying warm. Please see the note below from the Senator's constituent Mike Mulligan . He is very concerned about issues with deteriorating plumbing around the plant at Seabrook. could you please provide us with a formal reply to his concerns/allegations Thank you, please let me know if you need any additional information Kind Regards,

Sarah
From: Michael Mulligan [mailto:steamshovel2002@yahoo.com]
Sent: Wednesday, December 18, 2013 1:22PM
To: Holmes, Sarah (Shaheen)
Subject: Re: Seabrook issues
 Sarah, If you don't talk tough to these guys, they will allow Seabrook to deteriorate into a Vermont Yankee. This is very similar to their concrete problem where it took much more NRC action. I never have any confidentiality or anonymity needs what so ever! Mike  

Dear Senator Shaheen, These comments below are from the NH Union Leader newspaper by Seabrook Station's Local 555 Union President Ted Janis on Nov 26, 2013. They were negotiating a union contract.

"Their battle cry is 'natural gas' is killing us. We are not making the money we were making five years ago,'" said Jenis. "But it's hard for us to sit here and see these raises go out to management."

"This is a workplace that has been beaten down over the last few years," he said."

"There seems to be a total attitude change toward the workers from the corporate level."

"This is a workplace that has been beaten down over the last few years," he said."

Seabrook nuclear plant was brought on line in 1990 with cheap and non-corrosion resistant carbon steel service water piping. Within two years, piping integrity problems began showing up with pitting and local corrosion. And this problem has only gotten worst and it's running out of control as I write. It is corrupting the staff of this organization.

In 2011 they replaced a 30 year old 8 foot section of 24 inch {huge) width pipe qn the service water strainer by pass line. I think because of corrosion issues. It seemingly had a secret failure of some sort in 2011, as the NRC didn't disclose it in their most recent inspection report (2013001).

They replaced it with new carbon steel piping that was lined with so called super epoxy material Belzona. It failed within three years during August of this year. This is called progress. How do we know if the Belzona isn't going to clog again the emergency diesel generator cooling water orifices?

As it stands right now, the pipe only has a Band-Aid over the wound till the next outage {late spring 2014). Seabrook and the NRC will tell you they ultrasonically tested the hell out of this section of pipe once they detected it leaking. This device shows you the thickness of the metal piping. This is a nuclear plant and a crucial nuclear safety component...one which just failed mysteriously after 2 years ... why weren't they UTing the hell out the pipe before it leaked, as they knew the carbon steel service water piping was seriously corrosion prone? Why wasn't there an intense program to uncover any corrosion throughout the system and especially on the strainer bypass line that already failed?

Why didn't they catch the defect before it first leaked ... then catch it before the tinfoil thickness pipe wall burst and the leak got even bigger threatening the design of the plant? This is a matter of trusting them and their integrity. This is a matter of the NRC prodding them over and over again about following their procedures and using conservative engineering ethics. 

Seabrook through August this year didn't want to shut down over a pipe leak fearing a summer grid emergency with limited electricity and in a heat wave with expensive replacement electricity. Was this all about money and very little about public safety?

Seabrook obtained regulatory good will and forbearance to not shutdown to fix this dangerous leak even after botching the UT reading. The American Society of Mechanical Engineers sets the engineering standards that the NRC requires Seabrook to abide by. The ASME nuclear piping codes requires Seabrook to repair the pipe ... not a temporary repair like the NRC gave them permission to do. I bet you they want Seabrook to actually see the damage inside by eye to make certain they know what is going on ... not guessing. They could have kept this plant up at power if they first designed this plant prior to construction with sufficient extra service water capacity and flexibility in this area.

ASME Standards used in over 100 countries

ASME members provide engineering and technical expertise to policy makers in Congress, the White House Office of Science and Technology policy, and key federal agencies"

You get it, the poor initial plant design of the service water system sets Seabrook up to cry tike a baby to the NRC with the burdens of code and agency compliance. Your brother Pilgrim (Entergy) plant up north and the NRC doesn't have a care in the world with any "shutting the plant down in mid-cycle creates undue and unnecessary stress on plant systems, structures, and components" during the last year over all the multitudes of shutdowns and scrams they had caused by their poor plant upkeep and maintenance. These are nothing but excuses of convenience and it borders on another falsification in federal documents. 

It is impractical to complete a Code-acceptable repair to the identified SW leak at Seabrook Station without shutting the plant down. Shutting the plant down in mid-cycle creates undue and unnecessary stress on plant systems, structures, and components." (Sept 4, 2013)

I don't think these guys deserved any regulatory forbearance. They should have prepared their service water system years before for the rigors of summertime operations. This is how you protect the consumers from the potential of electricity shortages and maintain nuclear safety. Nuclear safety never comes from undeserving regulatory good will. Honestly, they need to spend big bucks to fix their service water. Course, the grid might be more vulnerable in winter time operations and with our limited natural gas piping capacity. They should have spent our good money towards the aims of making this plant reliable without regulatory nuclear safety forbearance during these critical summer months. Do you think the NRC's regulatory good will and forbearance will get us a reliable service water system for the rest of the life of this plant?

The service water cooling system supports all the reactor core cooling and the emergency diesel generator. This is certainly their Fukushima nuclear safety system. I spent considerable time talking to the NRC senior resident inspector and his boss the branch chief. The senior NRC resident frames the quality of the carbon steel service water piping system as "crap". Every professional in the field knows this is grossly inappropriate material for a salt water system.

Because of the poor quality of the carbon steel and its reckless susceptibility to early failure and all sorts of corrosion, they have lined (inside) portions of the piping with concrete, plastisol and Belzona. Seabrook began using plastisol in 1992 two years after first operation of the plant. The station was oblivious to the fact that the plastisol only has a service life of fifteen years. The NRC had to remind them of this. The brittle and pitted plastisol then sheeted off the piping and clogged a cooling orifice into a Fukushima emergency diesel generator. The machine didn't have enough cooling water and the station botched the "operability determination" over this twice. The big event you should be worrying about is any of the cement, plastisol or Belzona detaching from the inside of the piping and clogging up the water flow or damaging any of the valves.


I believe Seabrook knowingly falsified internal paperwork (prompt operability determination (POD)) the NRC depends on it to make a regulatory judgment. Is it safe to stay up at power orshould they shut down? Seabrook has made a string of bad "operability determinations" over the recent years and nothing the NRC does seem to turn these guys around into making accurate operability determinations. Seabrook had a leak in their service water system and they used a ultrasonic detector to measure the nature of hole in the pipe. They had information the hole was a very dangerous type which could leak big amounts of water ... but they put on the POD document it was a safe and stable hole. Within weeks the hole widened and leaked significant amount of water inside the plant threatening other safety equipment.

I questioned the Branch Chief and senior NRC inspector. They tell me Seabrook didn't adequately support their prompt operability determination (POD). This is a basic operation's safety function at a nuclear plant and they are all trained much on it. What are they even up at power for if they can't perform this simple determination? These guys are all extremely educated and there are many employees with advanced engineering degrees who ultimately make these determinations. It doesn't wash with these really smart and educated people making these kinds of simple mistakes. What they are really good at is covert-ups and playing stupid. Like I said, this plant has had lots of bum service water safety operability determinations lately ... why isn't the punishment cumulative? They had at least two stupid and inaccurate operability determinations with erratic cooling water flow indication to an emergency diesel generator. The dangerous brittle and over aged so called protective plastisol that sheeted off the sw pipes. What does it take to turn their hearts? What does it take to make accurate and safe operability determination? How will this faux stupidity end? This revolved around
an accurate UT scan of the pipe hole on day one and the staff blowing it with getting the information into the "Prompted Operability Determination".(wink wink)

I questioned the NRC inspector Mr. Cataldo about if it was a falsification of documents or if the NRC interpretation was Seabrook didn't adequately support the POD. How could these really smart and highly trained employees ever make that kind of simple mistake? He said, "Mike, it was just gross staff incompetence" surrounding the reading of the UT and getting the correct information into the POD." I still believe it was an intentional willful! falsification of documentation and the NRC is sweet talking this event into a poor support of the POD. But the great problem now is; why didn't the NRC accurately characterize this event as "gross Seabrook staff incompetence" surrounding the UT and the characterization of the hole in the NRC's inspection report? Does the NRC have two tiers of reporting, the prettified talk in the inspection reports for the community and the actual events at the plant?

I have real issues with the early failure of the new carbon steel piping and its super epoxy material Belzona. The nuclear industry is riddled with issues of improper heat treatment of metals and using the wrong type of metal. Remember, the old section of pipe failed mysteriously after 30 years. You get it, they never depressurized this section of piping. They never eyeballed the flaw inside the pipe and taken samples for sophisticated metallurgical analysis at an approved engineering laboratory. And these guys are terrible at guesswork. It could be related to microbial corrosion, electrochemical reactions with dissimilar metals and cement is a great worry.

"As previously stated in Section 7.2, the cause of the degradation is from localized corrosion.The typical corrosion rate used in Seabrook Station Service Water piping evaluations is 30 mils per year (mpy). However, the current identified wall defect resides in piping which was recently replaced during Refueling Outage 14 during April 2011, concluding that an accelerated (presently unknown) mechanism exists within the bounding area." (Sept 4, 2013)

The new carbon steel and the super coating failed after two years. The NRC's branch chief says the seawater in the bypass line is stagnant, but is open at the downstream connection. Nowhere in their documentation does it explain why the new section of piping failed so quickly other than to imply it is the same corrosion mechanism that destroyed the 30 year old first pipe. I think it is a new failure mechanism and other areas of the pipe could also fail quickly.

And believe me, there is no way to get an objective and independent interpretation of what went on here. The NRC and Seabrook have dog in this race with protecting their credibility ... you would need a recording (voice, visual) of the initial control room discussion about this hole with the NRC and then a recording of any subsequent discussion on this. Can you even imagine in a nuclear plant's safety cooling water piping, the NRC would allow the metal destruction mechanism to remain unknown?

Senior inspector Paul Cataldo told me he fought like hell with his bosses trying to get a bigger violation over this. He talked to me about the burdens the agency only gives him with a very limited weekly or month time budget with events at the plant. He put in a lot of time with this non violation. No overtime and certainly no paid overtime. I got the impression he thinks his bosses don't fully support him as they should and he is worried Seabrook's management doesn't respect him for his Federal oversight role at the plant.

I have called Seabrook's security gate and left a message asking to speak to an engineer about the sw strainer piping leaks. 

Better, somebody in the know within the operations department. I am still waiting for that call back?

Sincerely,
Mike Mulligan
Hinsdale, NH
(Ce11)16032094206

'The Popperville Town Hall'
http://steamshovel2002.blogspot.com/
On Friday, December 13, 2013 2:35 PM, Michael Mulligan wrote:
Sarah,
There we go!
Mike


On Friday, December 13, 2013 2:27PM, "Holmes, Sarah {Shaheen)" wrote:

Hi Mike,
Let's try this one more time.
Sarah

From: Holmes, Sarah (Shaheen)
Sent: Thursday, December 12, 2013 10:17 AM
To: 'steamshovel2002@yahoo.com'
Subject: Seabrook issues

Mike, 

Nice talking with you today. As we discussed, can you please send me a summary of the issues with leaks at Seabrook, that would be very helpful. I will forward along to the NRC with a cover note from the Senator asking for a response and additional information.

Kind Regards,
Sarah
Sarah Holmes
Special Assistant for Policy and Projects
Office of U.S. Senator Jeanne Shaheen
340 Central Avenue, Suite 205
Dover, NH 03820
P: (603) 750-3004
F: (603) 750-4046
sarah holmes@shaheen.senate.gov
s1gn up '"or
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"Their battle cry is 'natural gas' is killing us. We are not making the money we were making five years ago,'" said Jenis. 

"But it's hard for us to sit here and see these raises go out to management."

"There seems to be a total attitude change toward the workers from the corporate level."

ASME Standards used in over 100 countries

ASME members provide engineering and technical expertise to policy makers in Congress, the White House Office of Science and Technology policy, and key federal agencies"

"6. Burden Caused by Compliance

"As previously stated in Section 7.2, the cause of the degradation is from localized corrosion. The typical corrosion rate used in Seabrook Station Service Water piping evaluations is 30 mils per year (mpy). However, the current identified wall defect resides in piping which was recently replaced during Refueling Outage 14 during April 2011, concluding that an accelerated (presently unknown) mechanism exists within the bounding area." (Sept 4, 2013)

5

More Crap Service Water Piping At Seabrook!

“replace degraded SW piping with a corrosion resistant material: AL-6XN austenitic stainless steel material

SeabrookNuclear Station's "Crap" Service Water Piping System

Senator Shaheen's Help With Seabrook's Deteriorated Service Water Piping

Seabrook's Crap Service Water System

So now the truth comes out. I have gone over a lot of Seabrook’s documents with degraded service water pipes. I knew Seabrook used inappropriate piping materials leading to premature corrosion and pipe leaks. The Seabrook solution was to put a ban aid on the gaping pipe wound...the cement liner and plastisol lined pipe. The foreign material lined piping caused a flow reduction and the material has sloughed off causing blockage in other areas of the plant including the diesel generator.

"...replaced degraded Plastisol-lined service water (SW) piping on the supply and return of the ‘A’ and ‘B’ emergency diesel generator (EDG) heat exchangers and degraded cement-lined SW piping on the supply side of the ‘A’ primary component cooling water (PCCW) heat exchanger..."

Most troubling in all the Seabrook and NRC degraded service water documents...the NRC and Seabrook never admitted the root cause of their trouble was inappropriate pipe metal. Because if they admitted it, all the piping would have needed to be replaced.

Just to be clear, if all of the service water piping was made of AL-6-XN austenitic stainless steel, there never would have been a need of any plastisol or cement service water piping liners. The NRC says this piping was degraded, why wasn't this in a LER and why wasn't Seabrook forced into a tech spec LCO?  

It just  gets you wonder how much more safety information they withhold from the public because it reflects bad on the agency. 

April 28, 2015: SUBJECT: SEABROOK STATION, UNIT NO. 1 – NRC EVALUATION OF CHANGES,  TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONSTEAM INSPECTION REPORT 05000443/2015007 Service Water Piping Replacement for the Diesel Generator and Primary ComponentCooling Water Heat Exchangersa. Inspection Scope The team reviewed EC 274172 which replaced degraded Plastisol-lined service water (SW) piping on the supply and return of the ‘A’ and ‘B’ emergency diesel generator (EDG) heat exchangers and degraded cement-lined SW piping on the supply side of the ‘A’ primary component cooling water (PCCW) heat exchanger. NextEra performed the modification to replace degraded SW piping with a corrosion resistant material to ensure long-term system pressure boundary integrity. NextEra replaced the carbon steel lined piping with AL-6XN, an austenitic stainless steel material, suitable for seawater service without the need for internal lining or protective coating. 

The team reviewed the modification to determine if the design basis, licensing basis, or performance capability of the EDG, PCCW, and SW systems had been degraded by the modification. The team interviewed design engineers and reviewed design drawings and calculations to determine if the new SW piping met design and licensing requirements.
Additionally, the team reviewed non-destructive examination (NDE) results and associated maintenance work orders to determine if NextEra appropriately implemented the modification. The team performed several walkdowns of the accessible portions of the replaced SW piping, including a walkdown during a prolonged ‘A’ EDG run on March 5, 2015, to verify that NextEra had adequately implemented the modification, maintained pressure boundary integrity and configuration control, and had not impacted the function of other safety-related SSCs located in the vicinity. The team also reviewed corrective action CRs and the EDG, PCCW, and SW system health reports to determine if there were reliability or performance issues that may have resulted from the modification. Additionally, the team reviewed the 10 CFR 50.59 screen and engineering evaluation associated with this modification. The documents reviewed are listed in the Attachment.

Fuel Failures At Garbage Dresden?

Who gives a shit why it happen? 

April 27, 2015: DRESDEN NUCLEAR POWER STATION, UNITS 2AND 3  INSPECTION REPORT05000237/2015001; 05000249/2015001
Unit 3 began the inspection period at full power. On January 9, 2015, reactor chemistry sampling confirmed that a small fuel failure existed in the core. On January 17 operators reduced power to 82 percent to conduct testing as part of fuel failure identification and verification efforts, and returned to full power on January 18. On January 29, 2015, operators lowered power to 50 percent to conduct power suppression testing and identify the core location of the failed fuel. The failed fuel was identified and mitigated, and Unit 3 returned to full power on February 3. On February 28, 2015, the operators reduced power to 58 percent to conduct control rod sequence exchange, and full power was restored on the same day. With the exception of short periods for routine maintenance and surveillances, Unit 3 operated at or near full power for the remainder of the inspection period.

What a disgrace? 

Green. A finding of very-low safety significance, and an associated NCV of 10 CFR 20.1701 was self-revealed during work activities associated with the failure to effectively implement planned radiological engineering controls during reactor head reassembly that resulted in personal contaminations and unintended radiological intakes to workers. On November 14, 2014, during the cleaning of the reactor head studs, several workers on the refuel floor were contaminated, and received unplanned and unintended intakes of radioactive material. Corrective actions included revising applicable procedures to improve the engineering and contamination controls during reactor head reassembly.

Russia: The Global Walmart of Revolutionary Uranium Centrifuging?

Why isn't the USA the Walmart of Revolutionary Uranium Centrifuges?

Man, is Russia more transparent than the USA?  

Russia 1st to test 10Gen uranium enrichment centrifugesPublished time: April 27, 2015 11:37
Edited time: April 27, 2015 12:26

Rosatom, Russia’s nuclear agency, confirms scientists are testing 10th generation centrifuges. No other country even possesses 9th gen tech, putting Rosatom years ahead of the competition. 

“We’re on to 10 Gen,” announced Aleksandr Belousov, general director of Urals Integrated Electrochemical Plant (UIEP), a Rosatom subsidiary in Novouralsk, Sverdlovsk Region, in the Urals. 

“Scientists and engineers are solving technical issues, which is quite difficult. Any kind of new research and technological development is a venture undertaking, you can either succeed or fail... Any new machinery must be economically efficient. [10Gen] is being developed out of economic expediency, not for mere modernization. The more energy-intensive the machinery is, the more technical problems emerge,” Belousov said.

A gas centrifuge uses principles of centrifugal force to perform radioisotope separation of gases, by accelerating molecules to such an extent that particles of different masses are physically separated within a rotating container. 

The centrifugal separation of isotopes is used for various purposes. First of all for production of low-enriched (up to 3-4 percent) uranium to be used as fuel at nuclear power plants. It also is used to produce weapons-grade, highly-enriched uranium (90 percent of U-235). Centrifuges are also needed to produce radioisotopes for medicine and various technical issues.  
Centrifuges are operated in cascades of hundreds and thousands units. Manufacturer supplies centrifuges in assemblies of 20 units in two rows, and at the factory they are placed on the columns in tiers, one above the other. 

Last week the second cascade unit of 9 Gen gas centrifuges has become operable at

9GEN makes Russia the world leader?

the UIEP, with the first 9 Gen unit introduced in late December 2013. Having two 9 Gen centrifuge cascades means that UIEP is the leader in the industry, making up to 48

48% of the Russian market and 20% of the global market?

percent of Russian radioisotope market and 20 percent of the global market, RIA Novosti reports. 

The 9 Gen centrifuges are four times more productive than 8 Gen centrifuges, which means a similar productivity pace should be applied to 10 Gen units, Belousov said.

Development of nuclear enrichment centrifuges in the Soviet Union began in 1952. Over the time general dimensions of the machinery changed a little yet the productivity has augmented by 14 times, whereas operating costs have diminished by at least 10 times, aide to the UIEP head, Gennady Solovyov, said. 

The modern Russian centrifuge is a state-of-the-art component made of composite materials and special aluminum alloy. Its rotor spins with unbelievable speed of 1,000 rotations per second and can do it without a single stop for 30 years. Mechanical malfunctions are extremely rare, no more than 0.1 percent (one failure per 1,000 units) per year. 

 

Russia’s TVEL Fuel Company (TENEX for operations abroad) is the largest operator of nuclear enrichment centrifuges and absolute leader of world’s radioisotope market, possessing about 30,000 separative work units (SWU), which is almost half of the world’s total 65,000 SWUs. Russian centrifuges are also the most advanced and have higher output capacity than SWUs from rival companies in France, US or Japan.
Starting from 2009 Russia is supplying 7 and 8 Gen centrifuges to China.The second-largest operator of uranium enrichment centrifuges after Rosatom is URENCO, a joint German, Dutch and UK enterprise operating 14,200 SWUs.
Rosatom is heavily investing in nuclear enrichment at the UIEP. In 2014, the corporation allocated 7.5 billion rubles (nearly $150 million), whereas for 2015-2019 Rosatom plans to spend on the UIEP no less than 34 billion rubles (about $667 million).

Brunswick Junk Norberg Diesel Generator.

05000369,05000324


The problem is:

You are always dependent on small potatoes third party vendors because the original Nordberg DG manufacturer is bankrupt.

It is repetitive with these kinds of failures, such as with Brunswick? 

It's only going to get worst the older the plant gets...

(Closed) LERs 05000369/2014-001-00 and 05000369/2014-001-01, Condition Prohibited by Technical Specifications (TS) due to Emergency Diesel Generator 1B

Failure

a. Inspection Scope 

This URI was initiated for the NRC issuance of Notice of Enforcement Discretion (NOED) 14-2-002, dated August 27, 2014, in order to review the circumstances that led to the NOED request to determine if any performance deficiencies or violations contributed to the need for the NOED. The inspectors reviewed the licensee’s LERs associated with the failure of the cylinder 5L intake valve stem on the 1B EDG, the licensee’s root cause investigation, and their corrective actions to address the failure. Previous evaluation of the accuracy and details of the licensee’s request for the NRC to exercise discretion not to enforce compliance with the required action completion time for TS Limiting Condition for Operability (LCO) 3.8.1 to allow extra time for the engine to be repaired was documented in NRC Integrated Inspection Report 05000369, 370/2014005.

The licensee established a formal root cause team consisting of six team members, including an outside industry diesel expert, to evaluate the failure and to determine applicable corrective actions. An extensive metallurgical laboratory analysis was conducted on the failed parts and further analysis was conducted by the disassembly of other cylinder heads on the 1B EDG during the subsequent fall 2014 refueling outage when the engine was removed from service. The inspectors found the licensee’s root cause evaluation to be detailed and exhaustive. The licensee determined the cause of the 1B

Basically crap parts... 

EDG cylinder 5L intake valve failure was due to the combined effects of three inlet valve sub-parts which were manufactured by a third party supplier outside of the original equipment manufacturer (OEM) (i.e., Norberg) specified tolerances. These manufacturing discrepancies included: 1) the inlet valve stem hardness/tensile strength was below specifications, 2) the hydraulic valve lash adjuster, which dampens the force between the intake valve and its seat, did not function properly due internal clearances being out-of-specification, and 3) the inlet valve spit rings, connecting the valve stem upper end to its rocker arm, was found with a larger radius. The combined effects of these out of tolerances resulted in inlet valve stem stresses beyond the endurance limit and subsequent valve failure due to high cycle fatigue.

The licensee implemented a number of corrective actions to address the causal factors identified. Actions were taken to place a hold on the procurement of the three out of tolerance components until the EDG parts procurement specifications were revised. The revision would add additional vendor verifications that the components meet the original Nordberg specifications. To address the immediate extent of condition to limit the vulnerability of similar cylinder components being out of tolerance, the licensee reviewed cylinder vibration and ultrasonic signature testing of each of the cylinders of all four EDGs to detect any inlet valve closure anomalies. In addition, during the Fall 2014 refueling outage, both the 1B and 1A EDGs were inspected to ensure no similar out of tolerance components were installed. Similar inspections are planned for the remaining 2A and 2B EDGs. In the interim, the licensee plans to continue conducting periodic cylinder performance signature testing to detect any abnormal change in cylinder performance. The inspectors verified that an adequate extent of condition review was performed for all EDGs, and concluded that there were no licensee performance deficiencies associated with the August 18, 2014, 1B EDG failure. This URI and associated LERs are closed.

b. Findings

No findings were identified.

Originally posted on 1/13/2015

Can you imagine having no manufacturer support, replacement parts stream or large DG engineering or maintenance service.

It is like owning a car and you have to contract through a private vendor service to get them to manufacture spark plugs according to your special specification. You just can't call the manufacturer with a parts number and get the item by FedEx delivery.  

Tim

Talked to the McGuire senior resident for about an hour today over this LER. He was a inspector for twenty five years. Couldn't get him to end the conversation. This is the LER:

LER 2014-01

Components inside the DG failed leading to a shutdown (Aug 2014). McGuire and Brunswick are the only plants in the USA who sports Nordberg DGs. Nordberg went out of business. Basically Duke bought the remaining shell of a company, mostly for the paperwork to support their DGs. They don’t have a typical repair parts stream…they contract to get replacement parts on their own. 

• Counterfeit, Suspect, Fraudulent Items

I believe these replacement parts came from an ocean transportation company who owns big ships according to the resident. Seems old and obsolete Nordberg DG engines are popular in ocean shipping. The NRC is going to violate them in the future. The machine failed in Aug 2014 and the NRC still can't make their mind up to charge them or not.

"The cause of the EDG 1 B cylinder 5L failure is high cycle fatigue of the inlet valve due to the combined effects of three inlet valve train parts which were manufactured outside of original equipment manufacturer (OEM) specified tolerances.

The following factors caused the 5L inlet valve failure:
* Inlet valve stem hardness/strength below specification
* Hydraulic lash adjuster internal inadequate clearance
- Inlet valve keeper inadequate upper ID radius and thickness

You can imagine Duke going to the large DG manufacture for independent advice...do you think these out of tolerance parts will be safe and not cause us problem? If they were a valid manufacturer, you know they would say replace it.  

Interaction of the above factors subjected the cylinder 5L inlet valve to forces beyond the design and endurance limit. Evidence of inadequate manufacturing was confirmed by inspection, measurement, and testing of the EDG 1 B cylinder 5L inlet valve train components. No single factor on its own can cause an inlet valve failure. A combination of the above factors created the conditions necessary for a failure of the inlet valve from high cycle fatigue over a relatively long time period. EDG 1 B operated for approximately 13 years with the out of tolerance parts. All of the above parts issues were created during manufacturing by inadequate adherence to original Nordberg specifications for materials and tolerances by a third party supplier that is no longer in operation."

You get it with the above, how far down the pike you willing to go with a no longer in operation machine manufacturer ( Nordberg) and then the third party parts supplier who no longer is in operation also. Now the parts are made fraudulently in China. What are we going to think if these parts came from a chain of 5 or 6 no longer operating third party suppliers. That is two corporations. You notice the NRC doesn't specify the third party. This should go to the justice department.   

I consider not having a traditional manufacturing company backing up these machines as an un-reviewed safety issue. I told the inspector you got two separate parts found to not meet manufacture specs…how can you trust all the other parts. It got by Duke's QA and their black market parts company is supposed to have nuclear grade QA. Duke has proven themselves as not being a good owner of a DG manufacturing company. You got to test a representative sample of replacement parts to see it them meet specs( they are). I told the inspector making a plant engineer basically playing manufacturer and ordering the manufacturing of parts, plant or corporate engineering isn’t designed for that. It eats up engineering resources and it might cause them not to watch other problems.

I posed the question, well, why can’t you order them to replace all the dgs with new machines. Get a giant manufacture with large engineering services on their machines and the replacement parts traditional stream. He says it is impossible, the specific DGs are integral to the licensing of the plant. Even putting in new machines, it wouldn’t be the original quality. What bs! He said it would be cheaper building a new plant than ripping out an obsolete dg and installing an identical or better dg. If a dg fails in a way it can't be used again...it means the plant would have to permanently shutdown.

He says that is why the industry has never changed out not even one dg in all of the history. 

They could do as a LAR…it certainly is a lot smaller job that replacing SGs. 

The resident brought in NRR and other staff…because the parts had an inadequate pedigree.They really have no idea where the parts came from and they are worried they come from a Chinese fraudulent parts sweat shop?

He was vaguely talking about Duke installing non-nuclear grade DGs outside the building to compensate for the reduced quality with their Nordberg DGs. The Nordbergs would still be used and operational…but some amount of outside non nuclear grade capacity would be in standby in case of failure. I told him don’t worry about in the end, risk perspectives will say it is risk insignificant. He doesn't get my humor.

I found it suspicious as hell I couldn't get him to hang up? 

Mike

 Duke owns Brunswick today. 

November 24, 2009:NRC SPECIAL INSPECTION 05000325/2009011 AND 05000324/2009011

"Brunswick and McGuire are the only two operators in the United States that utilize Nordberg EDGs in nuclear safety-related applications. Progress Energy and Duke Power Corporation are partnered with ESI as owners of the Nordberg nuclear EDG design and share information regarding the Nordberg EDGs. This provides Progress Energy with the availability of shared resources and access to a spare Nordberg diesel at the McGuire nuclear plant for training and troubleshooting. Also, operating experience gained from McGuire provides immediate feedback on key diesel issues or previous maintenance activities."

https://adamswebsearch2.nrc.gov/webSearch2/view?AccessionNumber=ML15005A044

LER 2014-01-01: Condition Prohibited by Technical Specifications (TS) due to Emer ency Diesel Generator 1 B Failure.

Excepts from the LER: 

Brunswick NRC Inspectors Finding DG Day Tank Vent Pipe Violation Like Waterford?

So we are now heading towards a 2.206 on Waterford...(The 2.206 was going to be about missing missile protection on the DG day tank. I just found the NRC identified it on their CDBI inspection. So now the 2.206 is unnecessary.)

Does Waterford have tornado protection on day tank vent lines?

Roof- both A and B
dg fan-B

Dam CDBI- Specifically, between October 8 and 16, 2014, the licensee failed to initiate a condition report to evaluate the lack of missile protection on the emergency diesel generator A and B storage tank vents, a nonconformance that is a condition adverse to quality. In response to this issue, the licensee performed an operability determination to address the team’s concerns and initiated a separate condition report to document the failure to initiate a report for a condition adverse to quality.

So I am not going to have the issue Brunswick got a violation over not missile shields and the NRC ignored it in Waterford.

Bottom line, with the absent missile shield on the day tank vent lines, the DG vent fan being inop since the bugled maintenance on the B in 1999 and the corrosion on the dg day tank vent lines...the operability of the the diesel generators was impaired on multiple causes for decades. The NRC paper whips these guys on the isolated issues, they don't look at these things holistically, with  poor maintenance over multiple issue has cast a terrible possible reliability problem over both diesel generators. Basically thy don't hit Entergy with a big enough hammer to get they to globally change their tune.

You notice post CDBI missile protection finding they have picked it up at another plant-Brunswick. After all these years, why hasn't the NRC caught the divergent from licencing condition across multiple plants. Why is the industry so lackadaisical  with maintaining their original licencing conditions.

Waterford on the broken DG  fan picked up by luck, they weren't positively monitoring the DG ventilation flow...they by procedure didn't have a positive way to immediately detect a DG fan was broken.  

Bottom line, I doubt the NRC knows the totality of all the broken or degraded safety components and the deficiencies in the plant's organization at WaterFord...it is very worrisome. 

Just saying, the probability of tornado winds capable of damaging the DG day tank vent piping is not transparent.

No extent of condition with is the site within the plant design on severe weather.

I still say heavy winds could drive up debris onto the roof above the DG day tank and clog up the roof drain?  

I still say the adequate punishment would have been, you need to assume that the NRC didn't catch this, Waterford was incapable of catching it. The assumption should have been in some future both vent pipes would have rotted through, or tornado or hurricane winds would have picked up missile debris knocking off the badly corroded vent pipe...in a hurricane with a LOOP WaterFord would have lost both DGs on water intrusion into the day tank and been in a blackout. It should have been a red finding.

The worst this to do in plant accident is to tie the hands of the operators around their back...have degraded or broken equipment show up way down the EOPs. 

What you see on the big picture, the NRC has to bail them out with violations or exemptions, equipment fails over poor maintenance...Waterford can't catch problems on their own before accidents and failed equipment shows up.

As an interim action, a stainless steel pipe clamp with a rubber liner was installed around EDG Feed Tank

vent pipe to prevent water intrusion

http://www.tornadohistoryproject.com/tornado/Louisiana/map

Tornadoes in Louisiana

Date(s) (yyyy-mm-dd)	Tornadoes	Fatalities	Highest Fatalities	Injuries	Highest Injuries	Longest Path	Widest Path
1950-02-12 - 2013-12-21	1827	206 people	47 people	3339 people	510 people	234.7 miles	3080 yards

Mike, so is there a difference between a day tank ventilation piping (Brunswick) and a day tank vent pipe (Waterford). They both fill of the Diesel Generator day tank and could take out the DG.

They really never mention specifically the DG  fuel oil. Bastards.

With ventilation you are usually talking moving air, bigger pipes and a motorized fan???

I am calling vent piping and ventilation piping the same...

Waterford's DG day tank vent pipe fiasco:

Licensee Event Report (LER) 2014-004-01

January 22, 2015 WATERFORD – NRC COMPONENT DESIGN BASES INSPECTION REPORT 05000382/2014007 AND PRELIMINARY GREATER THAN GREEN FINDING

 April 09, 2015: WATERFORD UNIT 3 – NRC SUPPLEMENTAL INSPECTION REPORT 05000382/2015010

See how incredibly erratic the NRC is with violating a plant. Two plants with NRC inspectors finding issues of the possible unreliability of the diesel generators that the plant staff's didn't find.

So Waterford repaired the corroded DG vent piping with rubber and hose clamp...how can that stand up to a tornado. Why didn't the NRC inspectors violate Waterford on tornado protection like Brunswick?

January 30, 2015: BRUNSWICK STEAM ELECTRIC PLANT - NRC INSPECTION REPORT NOS. 05000325/2014005 AND 05000324/2014005

Introduction. The NRC identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion III,

Design Control, for failure to ensure adequate tornado missile protection for the EDG 4-day

Actually this is the first mention of fuel oil tank...I am certain its the vent line. Well, 99.5% certain.

fuel oil tank ventilation piping.

Description. On May 8, 2014, during a walkdown, the inspectors noted that the EDG 4-day fuel oil tank ventilation piping was not protected from tornado-borne missiles. The inspectors questioned the licensee on the whether this piping needed to be tornado protected, and if so, could it withstand the design basis tornado and rain event. On August 14, 2014, under WO 13421302, the licensee took corrective actions to place concrete blocks around the ventilation piping. An engineering evaluation was then performed that identified the worst case design basis tornado and rainfall scenario conditions and what effect those would have on EDG operation. It was determined that with the maximum 24-hour rainfall rate and a tornado missile shearing the ventilation piping at the roof level, the worst case scenario was the EDG1 4-day tank filling with Water  which would be transferred over to the EDG1 saddle tank. The saddle tank would fill to a level high enough to impact EDG operation in less than two hours. Following this evaluation, the licensee completed engineering change (EC) 96860 to install concrete barrier pads around the ventilation piping at the 4-day tank roof level to preclude a tornado missile impact at the most vulnerable part of the piping, and also preclude water accumulation on the roof from entering the EDG 4-day tanks. The inspectors reviewed the engineering evaluation, EC, and interviewed engineering personnel to understand the scenario and the impact to plant operation.

The Brunswick Original Final Safety Analysis Report (Appendix F) and Updated Final Safety Analysis Report (UFSAR), Chapter 3, contain the language of the regulatory requirements for the general design criteria listed in 10 CFR Part 50, Appendix A, and how the licensee complies with those criteria. Criterion 2 for protection against natural phenomena states, in part, that structures, systems, and components (SSCs) important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions. The licensee’s statement of compliance states, “SSCs important to safety have been designed with appropriate margin for uncertainties, to permit safe plant operation or shutdown even under conditions of the most severe natural phenomena which have been conservatively postulated to occur at the site.” Criterion 4 for missile design bases states, in part, that SSCs important to safety shall be appropriately protected against dynamic effects, including the effects of missiles, which may result from events and conditions outside the nuclear power unit. The licensee’s statement of compliance states, “SSCs important to safety have been designed with full consideration of the combined effects of the normal and postulated accident environment, including the effects of pipe whipping or other dynamic effects resulting from the accidents.” Section 3.5.1.4 of the UFSAR contains the specific analysis of four potential tornado-borne missiles and the effects on the plant. The impact of one of these missiles, shearing the EDG 4-day fuel oil tank ventilation line, along with water intrusion into the system from the design basis rainfall event, would prevent the EDG (an SSC important to safety) from performing its required safety function of providing a reliable source of AC power to the engineered safety features for safe shutdown of the plant or during design basis accidents.

Analysis. The inspectors determined the failure to ensure adequate tornado missile protection

There is the first mention of a fuel tank

for the EDG 4-day fuel oil tank ventilation piping was a performance deficiency that warranted a significance determination. The inspectors determined that the finding was more than minor in accordance with IMC 0612, “Power Reactor Inspection Reports,” Appendix B, “Issue Screening,” dated September 7, 2012, because it is associated with the Mitigating Systems Cornerstone attributes of Protection Against External Factors and Equipment Performance, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, it was determined that the ventilation piping could be sheared with a design basis tornado missile at the 4-day fuel oil tank building roof level and water intrusion into the EDG fuel oil system would occur during a design basis rain event that would prevent the EDG from performing its required safety function. Using IMC 0609, Appendix A, issued June 19, 2012, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined the finding screened to a detailed risk evaluation since the EDG1 fuel oil system was assumed to be completely failed due to a tornado, and it would degrade one or more trains of a system that supports a risk significant system or function. The regional Senior Reactor Analyst performed a detailed risk evaluation by using a qualitative screening analysis to determine the significance of the finding. Tornado initiating event frequency was derived from Nation Weather Service data. Because of the low likelihood of a tornado powerful enough to throw an object of sufficient size to damage the piping, the remote chance the thrown object would strike the vent

Sounds like Fukushima reasoning...

pipe, and because the remaining EDGs would not be impacted in the same way by the tornado, the finding was determined to be Green. The inspectors did not identify a cross-cutting aspect associated with this finding because the finding is an old design issue that has been in place since original plant construction.

Enforcement: Title 10 CFR Part 50, Appendix B, Criterion III, “Design Control,” requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis, as defined in Part 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, since the initial construction of both units, until August 14, 2014, the licensee failed to translate the appropriate tornado missile protection requirements into the design of the EDG 4-day fuel oil tank ventilation piping. The licensee performed corrective actions to install concrete blocks around the tank ventilation piping. This violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement

Policy. The violation was entered into the licensee’s CAP as CR 686589. (NCV 05000324; 325/2014005-01, Failure to Protect Emergency Diesel Generator 4-Day Fuel Oil Tank Ventilation Piping from Tornado Missiles) 1R18 Plant Modifications (71111.18 – 1

Waterford

January 22, 2015 WATERFORD – NRC COMPONENT DESIGN BASES INSPECTION REPORT 05000382/2014007 AND PRELIMINARY GREATER THAN GREEN FINDING