Tuesday, October 27, 2015

Hope Creek's SRVs, pipe pinning and cold spring?

update 10/28

(new)-Hope creek and Salem 1& 2 is the second largest nuclear facility in the USA. They own Peach Bottom, Salem 1& 2 and Hope Creek. They have a high plant number for such a small company. I'll bet you per stockholder to nuclear plant ratio, PSEG has the highest rate in the nation. They have a very high nuclear plant exposure. Man, abutting the cheap Marcellus shale gas field and Pennsylvania...cheap electricity??? Maybe the cheap natural gas plants can bail out their nukes...  

(New)Forgot- asked why there never was a licence event report (LER) on the H SRV. The failure of the H SRV last Sept 2014 was a "special interest" to the nuclear industry directly after shutdown according to the NRC inspection report...but why no LER? He verified no H SRV LER on the docket. He thought it surprising it wasn't on the docket. He thought NRC regulations don't required federal reporting on this kind of problem. I am telling you, it is a cover-up and the rules for NRC LER reporting is part of the problem. They corrupted public transparency...
   
"So a special or stand in Hope Creek NRC resident called me up.
  • Basically Hope Creek were in negotiation with a European firm on replacement SRVs (identical to Pilgrim’s now in plant)…the Europeans backed out because they couldn’t meet our quality standards. 
  • Then Hope Creek approached Target Rock for a SRV contract for the 2 stage replacement. They pulled out of the discussion without a reason.
I gave him the SRVs setpoint admin scenario. He gave me all the nuclear analysis saying they were safe. I said safe for me is following all the plant licensing and tech specs without question first. If the written rules aren’t right, you do a written evaluation, then change the rules. But you have to follow tech spec. What if in the control room you came upon information one SRV setpoint was at 5%, is the valve inop? On the second one going out, are they required to shut down? What does the actual tech specs required the plant to do? Then I told him the situation with H SRV testing. Said it went to 3.6% at 7 months. When does the valves go out of tech specs, at the one month or six months? HC last testing has a 71% failure rate. At the 8 month time frame will HC with two inop SRVs and have to shutdown. Hope Creek for about a decade has been whining about the need to replace the 2 stage.   
This so called stand in NRC resident is siloing information in his head just to career wise survive.  This information goes into this cubby hole and that information goes into another cubby hole…but never shall all the information in my special cubby holes meet.  
Does the uncertainty of not knowing the actually set point lift point require an immediate plant shutdown?
That is when he explained to me these are complicated matters, he will have to get back to me in a few days.
I am thinking this is a huge cover-up. At least the Pilgrim style model, there is no new replacement to be had on the market. It probably all over the BWRs, I see similar issues with the PWRs with the pressure operated relief valves (PORV).
Everything is always an information gather campaign?  
I’ll bet you the liability for making these kinds valves is too large for any manufacturer to consider supply the nukes. What if one of our valves caused a trillion dollar plant meltdown?"
Another update:
We are in that SRV setpoint lift pressure inaccuracy admin error I talked about the other day. Them idiots. That leaking Hope Creek H SRV last sept 5 2014…they replaced it with a refurbished one. Started up and seven months later they entered the normal outage. Massive SRV setpoint lift inaccuracies in the refueling outage forced them to test all 14 SRVs. They tested the Sept 2014 installed H SRV who was only in the plant for seven months. It failed the lift pressure test accuracy with a 3.6% (while in the plant for only seven months). On two SRVs being declared inop they are required to be shutdown within 24 hours. Hope Creek SRVs had a 71% lift accuracy failure rate this period. Some huge numbers too. How can Hope Creek demonstrate they are within Tech Specs say at the 8 month point …prove they are safe and fully within tech specs? These guys are the same model SRVs as Pilgrim. They have been operating for 5.5 months now…how many inop SRVs are in the plant now?

The admin scenario I was talking about in Pilgrim. The SRV testing facility calls Pilgrim saying the SRVs you sent us have all been tested, inspected...they are good for plant operation and well within tech specs. Pilgrim installs these and restarts. The testing facility calls six months later saying we made a terrible admin mistake. The A SRV was mistakenly set to lift at 5%. Plus or minus 3% pressure is the tech spec limit. It is outside your tech specs and you need to call the valve inop.
What would Pilgrim be required to do per tech specs?
Tech Specs says all SRVs need to be operable at power and be within 3% lift pressure testing limits. Upon one two SRV being inop, the plant is required to be shutdown within 24 hours. They would have need NRC permission to stay up in power after 24 hours.
Tech Spec SRV lift pressure valve actuation point isn't discoverable at power or fixable. 
Works in progress

Update@1pm

You get it with the H SRV valve. In a little over six months of operation, this valve exceeded its tech spec plus or minus 3% limits of 3.6%. It was required to be called inop. The second inop SRV would require the plant to be shutdown per Tech Specs
How many SRVs were lift setpoint inaccurate on Aug 2014? Why didn't they yanking out all the reliefs on the Sept maintenance outage and reset them.  How many right now are inop and Hope Creek should be required to be shutdown.  
  • April 2012: startup from refueling
  • Sept 5, 2014: leaking SRV  ‘H’ shutdown
  • April 11, 2015-May 13: normal refueling. 32 day outage
***Hope Creek from the Sept 2014 end of maintenance outage till beginning of April 2015 normal refueling outage. The amount of time it takes for a SRV setpoint lift pressure accuracy to be within tech specs and then get to 3.6% over tech spec lift limits.
Result: 218 days 
It is 218 days from the start date to the end date, but not including the end date 
Or 7 months, 6 days excluding the end date 
***Hope Creek from end May 2015 normal refueling till today 
Result: 167 days 
It is 167 days from the start date to the end date, but not including the end date 
Or 5 months, 14 days excluding the end date
***Pilgrim from end of normal May 2015 refueling till today
Result: 154 days
It is 154 days from the start date to the end date, but not including the end date
Or 5 months, 1 day excluding the end dat
LER 2015-004-01 
F013H 1148 1108 1074.8-1141.2 3.60%

"As-Found Values for Safety Relief Valve Lift Set Points Exceed Technical Specification Allowable Limit." 
Technical Specification (TS) 3.4.2.1 requires that the safety function of at least 13 of 14 SRVs be operable with a specified code safety valve function lift setting, within a tolerance of+/- 3%. Action (a) of TS 3.4.2.1 specifies "With the safety valve function of two or more of the above listed fourteen safety/relief valves inoperable, be in at least HOT SHUTDOWN within 12 hours and in COLD SHUTDOWN within the next 24 hours." Therefore, this is a condition reportable under 10 CFR 50.73(a)(2)(i)(B) as an Operation or Condition Prohibited by TS.
CORRECTIVE ACTION
1. All 14 SRV pilot stage assemblies were removed and replaced with pre-tested, certified spare pilot valves(H1R19).
2. Evaluate options for the replacement of the currently installed Target Rock two-stage SRVs with a design that eliminates setpoint drift events exceeding +/-3% and improve SRV reliability. The replacement schedule will be developed after a suitable valve is identified.
I am still working on this...

So how would say five SRVs discharge piping severing effect all the accidents. A stuck open SRV and a severed SRV discharge line?

This is a much worst accident than the NRC portrays and it should have gotten a much bigger inspection...

Remember LaSalles torus temperature stratification incident...

They had to use torus cooling to compensate for the leaking SRV throughout the cycle and they were surprised with hearing steam bubble collapse booms in the torus. 

Bet you those steam bubble vacuum booms sound very similar to the normal operation of HPIC and RCIC. 

I am shocked they had to use safety systems(torus cooling)excessively just because they were too cheap to fix the SRV right and then failed to immediately shutdown on the fist indication the H SRV was leaking.      

Hope Creek
February 5, 2015 

Pg11
 (NCV 05000354/2014005-01, Failure to Identify and Correct a Condition Adverse to Quality Associated with Safety Relief Valve Discharge Piping Misalignment)
***and the August 2014 power reduction due to a safety relief valve indicating open.
***The SRVs are Target Rock Model 7567F two-stage SRVs
 1R15 Operability Determinations and Functionality Assessments (71111.15 – 3 samples)
a. Inspection Scope

Findings 
Introduction. A self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, “Corrective Action,” because PSEG did not promptly identify and correct a condition adverse to quality. Specifically, PSEG did not initiate a NOTF or perform an evaluation of a cold spring condition
The SRV and its discharge piping were not line up on installation of the tested valve in 2012... the relief and it discharge piping was out of alignment by some two inches. Hope Creek used the tremendous force of a "come-along" chain to jack the valve and piping together for attachment. One doesn't know the misalignment before the the "come-along". This damaged the 2 stage SRV.  This is what happens when you have gorilla maintenance employees and a initially poorly designed valve. Then you had incompetent control room people who never could make the right safety call from 2012 to Sept 2014. This is very similar to the bungling of the Pilgrim SRVs since new installation in 2011 with the length of time the licencee and NRC took to come to terms with their SRV problems. 

Check out the SRV set point lift pressure inaccuracy inops in Licensee Event Report 2015-004-01. Ten out fourteen failed their tech spec acquirement. They needed to be declared broken at greater plus or minus three percent inaccuracy. Severity one percent failed tech spec testing. Upon discovering more than one SRV was outside tech spec they were required to shutdown and fix them. A large number of SRVs being outside Tech Specs were substantially outside plus or minus 3%.   

I consider the "identification occurrence" as being corrupt and a document falsification. The "event date" was sometimes during "plant operation".   Because they have no means to know or proof when the tens valve went broken, they would have to make a conservative guess they went broken one day after startup from outage after in 2012.  

IDENTIFICATION OF OCCURRENCE
Event Date: June 2, 2015
Discovery Date: June 2; 2015

So in this operating period (18 month) with Hope Creek's model 7567F (Pilgrim too)they has extremely dangerous leaking H SRV and other 9 failed testing valves. 

***Where the hell is the Licence Event report(LER)on the leaking 'H' SRV valve??? 

Just saying, 'H' SRV valve was inop before they even started up.
found in the ‘H’ SRV discharge piping during the valve’s replacement in 2012. This condition that occurred during installation was determined to be the cause of a leak on the main seat of the newly installed SRV. The leak proceeded to degrade during the operating cycle and ultimately caused Hope Creek to shut down and replace the SRV on September 5, 2014.
Description. The target rock model 7567F two-stage, pilot-operated SRV consists of two assemblies: a pilot stage assembly and a main stage assembly. These two assemblies are directly coupled to provide a unitized, dual function SRV. The pilot stage assembly is a pressure sensing and control element, and the main stage assembly is a system fluid-actuated reverse seated angle globe valve which provides for the pressure relief function or system depressurization at full rated flow. This model SRV has a set pressure range of 1025 to 1190 psig and weighs approximately 1100 pounds. The  main stage disc is tightly seated by the combined forces exerted by the preload spring and the system internal pressure acting over the area of the valve disc.
_________________________________________________________________________________


***2014005 February 5, 2015-The inspectors reviewed PSEG’s ACE, SRV work history, procedures and previous CAP evaluations and determined that PSEG’s conduct of maintenance in WO 60097071 should have generated a NOTF to document and evaluate the discharge piping misalignment found when removing the ‘H’ SRV in RF17. The inspectors also identified a note in Section 5.2.3 of MA-AA-734-458, Pressure Relief Device Removal and Installation, which states that “discharge piping should not cause any bending or apply any cold spring to the relief valve. Any cold spring or pipe distortion should be brought to the attention of supervision.” The inspectors determined that PSEG should have evaluated the misaligned SRV discharge piping as a potential condition adverse to quality.




***05000354/2015002-On April 15, 2015, PSEG NDE personnel were attempting to perform an ASME Code required ultrasonic examination of a weld on the ‘A’ SRV inlet piping, just below the bolted flange, when NDE personnel discovered tooling marks in the area of the weld preventing them from performing the weld examination.
 
In addition, the inspectors identified that PSEG procedure, HC.MD-CM.0006, Sections 5.4 Valve Body Removal, 5.5 Valve and Piping Inspections and 5.6 Valve Body Installation contained supervisory hold points for maintenance supervision to verify work task completion. Specifically, the inspectors identified that Sections 5.5 and 5.6 required visual inspection of the SRV inlet and outlet piping as well as notes that any nicks, pits and grooves that are greater than 0.062 inches in depth are to be evaluated by the engineering staff.

The inspectors observed that each use of the torque tool on the RCS piping likely caused unquantified degradation to the affected RCS piping. The inspectors’ review of PSEG’s technical evaluation, SRV work history, and procedures determined that these tooling marks should have been identified and evaluated as a condition adverse to quality by PSEG prior to April 2015, and as early as the first usage of the torque tool for SRV maintenance applications which started per HC.MD-CM.AB-0006 Revision 17 in October 2004. In addition, the inspectors identified that PSEG procedure, HC.MD-CM.0006, Sections 5.4 Valve Body Removal, 5.5 Valve and Piping Inspections and 5.6 Valve Body Installation contained supervisory hold points for maintenance supervision to verify work task completion. Specifically, the inspectors identified that Sections 5.5 and 5.6 required visual inspection of the SRV inlet and outlet piping as well as notes that any nicks, pits and grooves that are greater than 0.062 inches in depth are to be evaluated by the engineering staff.

_____________________________________________________________________________________

On August 12, 2014, an equipment operator on reactor building rounds noted a loud banging noise emanating from the torus room area between the 54’ and 77’ elevations. Further investigation by operations within the torus room revealed the noise to be loudest around azimuth 340 degrees, with a pattern of a loud bang followed by several softer, quieter bangs. The loud bangs occurred at a frequency of every 5 seconds. PSEG conducted a review of plant parameters and correlated the noise with an increased frequency in the need to run suppression pool cooling and torus letdown  due to increases in torus heat input and level since February 2014.

PSEG initiated an investigation to determine the potential causes of the noise. As part of this investigation, PSEG developed a failure mode causal team (FMCT) with input from subject matter experts throughout the industry to identify potential causes of the noise. Industry operating experience (OE) was also reviewed, indicating similar events at Hatch and Millstone. The FMCT determined that the two most likely causes of the noise were either cycling of the ‘H’ SRV tailpipe vacuum breakers (VBs) inside primary containment (elevation 112’) or ‘H’ SRV leak by resulting in a water chugging event within the SRV discharge pipe T-quencher located inside the torus. OE from Hatch and Millstone indicated that if the VBs were cycling, failure of the VBs could occur within 30 days of the appearance of the noise, causing a potential direct pathway of any steam flow through ‘H’ SRV to the drywell instead of being dissipated by the water volume of the torus. Due to this potential failure mode, PSEG made the decision on August 25, 2014, to conduct a planned maintenance outage on September 5, 2014, to further troubleshoot and repair the source of the noise.

After shutting down the plant on September 5, 2014, PSEG refuted the cycling SRV VB potential cause by conducting walk downs at rated pressure inside the drywell and performing inspections of the ‘H’ SRV VBs to verify they had not been cycling. After completing detailed visual inspections inside the drywell and torus, PSEG concluded that the most probable cause of the torus noise was excessive leakage past the ‘H’ SRV main seat inducing a water chugging event within the T-quencher. This water chugging event occurred when significant quantities of steam reached the water in the T-quencher initiating a repeating condensate induced water hammer inside the T-quencher. PSEG removed and replaced the ‘H’ SRV main and pilot valve assemblies, and had both assemblies tested offsite. The results of the testing yielded 0.05 gpm and 2.35 gpm leakage past the pilot and main seats, respectively, totaling approximately 2.4 gpm or 1200 lbm/hr at 1000 psig.

PSEG’s investigation of the ‘H’ SRV main seat leakage identified the main disc as being severely steam cut. The apparent cause evaluation determined the most likely cause of the steam cutting to be the existence of cold spring in the tailpipe of the ‘H’ SRV during the last replacement of the valve in RF17 (April 2012) under WO 60097071. This WO documented that the ‘H’ SRV tailpipe was misaligned and discussion with maintenance found that a “come-along” was used to adjust for piping misalignment following removal of the valve. PSEG determined that a large moment force was applied to the SRV main during installation, causing the initial leak on the SRV main seat, which then degraded during the operating cycle. During the removal of the ‘H’ SRV main assembly in September 2014, the misalignment of the discharge piping was documented in NOTF 20661387 as off by 1.5” horizontally and 1.25” vertically. PSEG found that the ‘H’ SRV discharge piping spring can was not pinned during the removal process in 2012, and if it had been pinned prior to removal, it could have prevented any cold spring or piping misalignment during reinstallation of the new SRV. PSEG’s apparent cause evaluation (ACE) determined that the SRV installation and removal procedure does not include steps to pin the spring can prior to SRV piping disassembly.

The inspectors reviewed PSEG’s ACE, SRV work history, procedures and previous CAP evaluations and determined that PSEG’s conduct of maintenance in WO 60097071 should have generated a NOTF to document and evaluate the discharge piping misalignment found when removing the ‘H’ SRV in RF17. The inspectors also identified a note in Section 5.2.3 of MA-AA-734-458, Pressure Relief Device Removal and Installation, which states that “discharge piping should not cause any bending or apply any cold spring to the relief valve. Any cold spring or pipe distortion should be brought to the attention of supervision.” The inspectors determined that PSEG should have evaluated the misaligned SRV discharge piping as a potential condition adverse to quality.

Analysis. The inspectors determined that the inadequate identification and evaluation of the conditions adverse to quality associated with ‘H’ SRV discharge piping misalignment found during valve replacement in 2012, was a performance deficiency that was within PSEG’s ability to foresee and correct. The finding was more than minor because it was associated with the procedure quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of an event that upsets plant stability. Also, if left uncorrected, the finding had the potential to lead to a more significant safety concern. The inspectors determined that this finding was of very low safety significance (Green) using Exhibit 1 of IMC 0609, Appendix A, “The Significance Determination Process (SDP) for Findings At-Power,” dated June 19, 2012, because the finding did not cause both a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. Specifically, the ‘H’ SRV safety-related function, relied upon for accident mitigation and pressure relief, remained operable.

This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Identification, because PSEG did not identify this issue completely, accurately and in a timely manner in accordance with the CAP. [P.1]

Enforcement. 10 CFR 50, Appendix B, Criterion XVI, “Corrective Action,” requires in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to the above, PSEG failed to promptly identify and correct a condition adverse to quality. Specifically, PSEG did not initiate a NOTF or perform an evaluation of a cold spring condition found in the ‘H’ SRV discharge piping during the valve’s replacement in 2012. This condition was determined to be the cause of an initial leak on the main seat of the new SRV during installation, which then proceeded to degrade during the operating cycle and ultimately caused PSEG to shut down and replace the SRV on September 5, 2014. PSEG’s corrective actions included replacing the ‘H’ SRV, providing training to all maintenance crews responsible for SRV work, and adding steps to the SRV removal and installation procedure to: 1) generate a notification for the identification of any piping misalignment; and 2) pin the discharge piping spring can prior to SRV removal. Because this finding was of very low safety significance and because it was entered into PSEG’s CAP as NOTF 20661387, this violation is being treated as an NCV, consistent with the NRC Enforcement Policy. (NCV 05000354/2014005-01, Failure to Identify and Correct a Condition Adverse to Quality Associated with Safety Relief Valve Discharge Piping Misalignment)


Friday, October 23, 2015

Pilgrim: Letter to Gov Baker About Defective 2 Stage In Plant Now

Updated 10/24

Gov Baker is pulling a Gov Douglas of Vermont just before Vermont Yankee blew up. I'd say based on the history of the 2 stage, a leak is right around the corner. It could be leaking right now and they wouldn't tell us. He si painting himself in the corner. Maybe Entergy learned their lessen. Their interest always trump a sitting governors political interest. Wait till Baker figures out Entergy without a whim is going to screw him in the corporate interest. Entergy interacts with a lot of governors across the nation...I think this huge corporation hates all governors and politician whatever their political stripe.   

The NE ISO with their extraordinary low market priced electricity for a year now is a indication we are over supplied with electricity. The real scandal is, why is your home electricity price so high. Is he blocking natural gas into Massachusetts. All these sources of electricity make too much profits. They spend enormous resources politically and regulatory sabotaging each others interest. The whole market of electricity and its energy sources is corrupt as hell. The outcome of sabotaging each other is high price electricity. They all make more profits per unit of energy. It is collusion!      
Activists challenge Baker's response on plant closure
"We need to be in constant communication with ISO, which is the enterprise that oversees the New England energy grid, and make sure whatever it is that happens here happens as quickly and as appropriately and as safely as it possibly can," Baker said. "I am completely with people on that, but we also need to make sure that we don’t end up doing something that translates into rolling brownouts or, God forbid, blackouts here in the New England region.”

Now is the time for Massachusetts to plan, he said, to make sure an adequate flow of energy continues. "In the end, the NRC and ISO are going to have as much to say about when we actually shut down Pilgrim as anybody in our administration is," he said.
***October 22, 2015
MA Statehouse      
Second Open Letter and Appeal to Governor Baker to Intervene and
Call for Immediate Closure of the Pilgrim Nuclear Power Plant

Citizens Across the Commonwealth Call for Exercise of Executive Action to Preserve Public Safety.

Dear Governor Baker,
With  their recent comments and the final decision by Entergy to close the Pilgrim Nuclear Plant in 2019, a new set of urgent considerations have become paramount. Your administration reacted quickly to proactively develop proposals to expand production of clean, renewable power.  Put in perspective, Pilgrim "offers 680 megawatts of the 31,000 available in New England" (Patriot Ledger).

Attention has also been focused on worker retraining, minimizing economic impact, and securing what the Boston Globe editorialized recently as "The Nuclear Graveyard", the nuclear waste dump at Plymouth.  You also have spoken of challenges and opportunities to chart a new course. The future is bright if the right choices are made.

But your silence on the continued operation of the Pilgrim Nuclear Plant for almost another four years is deafening and confounding.  All that citizens hear is a Pilgrim "death rattle" at the beleaguered facility. 

The Commonwealth is confronting a very real, public safety crisis, with five million citizens in harm's way.  The primary issue surrounding Pilgrim is neither energy nor economics. It is public safety. Thus, it is a grievous mistake to keep Pilgrim operating in its dangerous, perilous state.  Pilgrim needs to be closed immediately for an orderly shutdown, not in reaction to another emergency or disaster.

Let's be clear. Pilgrim still retains the lowest "degraded rating" of any USA nuclear plant, operating with the same depleted assets and poor management  Entergy has officially written off the Plant on their balance sheet, refusing to fund required NRC safety improvements.  As the storm clouds of danger continue to gather, we are at an impasse.  Why?  Nothing has been fixed and systemic failure is accelerating as closure looms. The recent trend for Pilgrim has been a downward spiral.  Do any of the following events inspire confidence?

* A 22 year old fire code violation was recently discovered and the NRC has ordered a fire watch patrol in the nuclear control room (24/7) to sniff out smoke.  Where was the NRC? 


* The meteorological towers to detect the direction of nuclear releases, wasout repeatedly for three years.  Never maintained.  Still notfixed.  Where was the NRC?
* The failed and broken electric switchyard, never fixed, repeatedly cited, and still on the brink of collapse with the next blizzard.  Where was the NRC?

* After the Juno storm of 2015, failed safety relief valves (SRVs) were replaced with refurbished valves of a type previously removed by Pilgrim in 2010 for being defective and prone to leaking (More)


* With the news of the closure, the talent pool at Pilgrim is evaporating as resumes seek out new destinations.  Those site specific skill sets at Pilgrim are weakening.


* Entergy's mindset to intensely minimize their expenses will be not be altered.  If history is any lesson, only a steep decline in focus and resources can be expected to closure date.

Operating a nuclear reactor in this environment, to eke out any marginal benefit, is folly.  When the next emergency shutdown strikes, assuming no fatalities/injuries, do you "press" the bet again?  It is like the Commonwealth running a high wire act with the NRC as an unreliable and slow to respond "spotter"- who can't prevent the big fall. 
You have publicly stated your trust in the NRC experts.  Your trust has been sadly misplaced with the belated disclosure of long standing and unreported failings, and lack of enforcement at Pilgrim.  

Citizens across the State truly understand the gravity of the situation.  We petition and implore you, once again, as Chief Safety Officer for the Commonwealth and the responsibilities invested in you, to respond to this petition as the evidence demonstrates a very clear and present danger to the people of Massachusetts and beyond.  We need decisive and strong leadership immediately to provide to us the protection the situation demands.  Demand the NRC to CLOSE PILGRIM NOW.
God speed in your deliberation. 
Sincerely,

On Behalf of MA Downwinders

Diane Turco, Cape Downwinders,  Harwich/Cape Cod           tturco@comcast.net
Guntram  Mueller, Boston Downwinders, MA Peace Action, Newton/Boston                                                                                                                                                                                                                                                                           guntrammueller1@gmail.com                                                                                                     Sheila Parks, On Behalf of planet Earth  Watertown/Boston  sheilaparks@comcast.net      John Gaulley, Occupy Hingham  South Shore      quillena@glastonburyabbey.org             Bruce Skud, No More Fukushimas Newburyport/ North Shore  bskud@verizon.net            Yvonne Baracos, Down Cape Downwinders  Wellfleet/Outer Cape  abilyoyo1@aol.com

cc
Senate President Stan Rosenberg

Senator Daniel Wolf Representative Sarah Peake


Senator Vincent DeMacedo

Secretary of Energy and Environment Matt Beaton

MEMA Director Kurt Schwartz

Attorney General Maura Healey

Senator Edward Markey

Senator Elizabeth Warren

Thursday, October 22, 2015

First Governmental Declared Luekemia In Fukushima

This could be just a normal presentation of leukemia...

On the other hand, this guy is young and this disease popped up quickly after his exposure. The Japanese are notorious with not monitoring radiation accurately on there nuclear employees. Usually radiation leukemia takes in excess of twenty years to develop. This is the first time a major nuclear accident happened in  modern democracy. We would openly acknowledge Fukushima leukemias and cancers.

If this Leukemia is caused by Fukushima, then there will be a enormous population of new leukemias following this poor guy. It will have a profound shadow over the nuclear industry world wide.

They got accurate epidemiological radiation model available...one or a few data points could get you to know the magnitude of the estimation cancers caused by Fukushima. Forty thousand radiation worker during this so far.
 

KYODO
The health ministry Tuesday certified a man with leukemia as having suffered an industrial accident and being entitled to benefits after he was exposed to radiation as a construction worker at the Fukushima No. 1 nuclear plant, though it did not confirm there was a link between the radiation and the cancer.
The man, now in his early 40s, is the first person involved with working at stricken facility to receive the certification for developing leukemia.
He installed covers for the damaged reactor buildings at the plant between October 2012 and December 2013 before being diagnosed with leukemia, according to the ministry. He developed the disease while in his 30s…

Tuesday, October 20, 2015

What It Would Cost To Shut Me Up?

Update 10/25

I got to get more realistic here. I am seriously considering Cadillac 2016 CT6 SEDAN. It not yet out. It's 4 wheel drive.  
A loner 2016 CTS-V SEDAN sitting in my driveway with the keys in the ignition and a credit card loaded with $50,000 dollars would be a show of good faith? I’d want to choose the car myself later, maybe with a few add-on trinkets.  
We’d sign the documents shortly after I hire a lawyer. We could cycle through this pretty quick and I would never acknowledge this deal.         
Just magical thinking.

Ok, somebody asked what it will take to shut me up.

A new company Cadillac(lease)of my choice(<$100,000) with a new car ever two years for life. Insurance, upkeep and gas included...4 city / 21 highway MPG, 640 turbocharged HP and 6.2L V8.(it's non-negotiable). I got my eyes on a stellar black metallic 2016 CTS-V SEDAN.
Or the pro safety forces would pay me a decent wage to keep on doing what I am doing...or stepping it up to the next level.     
Full medical for life on my wife and me. We won’t need it for about another decade.

I got fired in around 1992 till about 2015…$200,000 per year for 23 years give us about $4.6 million. I really don’t blame this on a particular company, but on collusion with them all overpowering the regulator. I think all the nuclear companies should chip in.

I am not going to charge you with pain and suffering. There was a lot in the beginning and in the last three years of work was horrible. I consider the outcome of pain and suffering as a gigantic positive…it made me a much better person.

A pension for life based on $200,000 and 35 years of service.  

Knowing my addictive life with all this money, it will quickly kill me.

I would just disappear, I would a sign non disclosure contract to not say anything…   
If you have a conscience…set me up in nuclear safety foundation. I’d be the “The Rockford Files” for the nuclear industry. Special projects and investigations. Pay me as a contractor too and expenses. As long as I have access to high corporate and NRC executives, I’d be happy not talking to outsiders. I’d need a date stamp non-erasable electronic log where I could log my investigative issues…where I could later throw it in your faces when I was right.  
I paid my dues and I made an impact…I’d be happy to just disappeared into the sunset never publically saying another word about the nuclear industry.

But my name could carry a credibility none of you got…

So you know what happened if I just disappeared and ended up on Miami Beach dead drunk without a family.  

You are dam right I'd buy a travel trailer with expensive bicycles inside and go all over the county. I put more miles on my bikes than the travel trailer.

You know what, all this money would just yank me away from my beautiful family and my extraordinary beautiful life of bicycling in Hinsdale NH and surroundings.

You know what I'd like most, telling my son I'd pick up the tab on any college of your choice. I'd like my son to finally admire something great I did for him.

Of course, being a available father entrained in healthy multi gender and identity relationships is the best gift you could ever give your son. The normal tussling of relationships in the give and take of life...

Would The Dems Have A Rout if We Had Our Young "Justin Trudeau"?

How could you not vote for this attractive young couple and their clutch of cute children. I tired of seeing old faces and the wreckage of our past lives.

What happened to our 44 year olds? Where did they go?  
 
Justin Trudeau, the leader of the Liberal Party, will become Canada’s second-youngest prime minister and the first to follow a parent into office.
•Born in Ottawa on Dec. 25, 1971, to Pierre Elliott Trudeau, Canada’s prime minister at the time, and the former Margaret Sinclair.
•Raised in Ottawa and Montreal.
•Married Sophie Grégoire, a childhood friend and former television host. The couple have three young children.
Mr. Trudeau grew up in the spotlight of his father’s political career, as well as his parents’ intensely publicized marriage and then its equally public disintegration. His childhood, he said in an interview in 2013, was a mix of privilege and the plebeian. He lived at the prime minister’s official residence and took a school bus to a public elementary school in Ottawa…

 

Farley Pressurizer Safety Valve Troubles


I didn't find any other  problems on their PORVs, but problems with their turbine driven aux feed pumps are a train wreck.  

You see how much higher the pressure is in PWRs.
 
October 9, 2015
Joseph M. Farley Nuclear Plant - Unit 1 LicenseeEvent Report 2015-004-00 Pressurizer Safetv Valve Setpoint Pressure Outside of Technical Specification Tolerance Band
On 8/11/15 Farley Nuclear Plant (FNP) Unit 1 discovered that a pressurizer safety valve (PSV), which had been removed during the May 2015 maintenance outage and shipped offsite for testing, failed its as-found lift test below the Technical Specification (TS) allowable value. The cause of the test failure was attributed to the seat leakage of the valve that occurred during and after startup from the Spring 2015 Refueling Outage (1 R26). This failure constitutes a condition that is reportable pursuant to 10CFR50.73 (a)(2)(i)(B), "Any operation or condition which was prohibited by the plant's Technical Specifications." The 18 pressurizer safety valve was replaced during a May 2015 planned maintenance outage.

Leak began upon startup on 5/4/2015.

Shutdowned plant to fix leak on 5/26/15

They assumed they could manage the leaking for the next two years. You see how far off their engineering instinct are…they should have shutdown on the start-up and fixed the valve. You see how deep this mental disease is in the nuclear disease.  

You see how lenient the NRC is with not requiring Farely to disclose why the valve leaked? This LER doesn't disclose it. This plant is deep into Republican land...they use the rules differently than anyone else.    

The moral of this story is anytime time a nuclear plant safety relief valve leaks they are intentionally aiming at violating tech specs with them demanding an immediate safety shutdown. Basically we are intentionally entering a immediate shutdown requirement and we are going to knowingly ignore it with the knowledge the component is not work as required. 
 
These guys got safety culture problems... 
On 8/11/15 during testing at an offsite facility the as-found lift setting for the Unit 1 1 B pressurizer safety valve (PSV) (EllS Code RV) was discovered to be 2425 psig which is outside of the Technical Specification (TS) allowable lift settings of ;:: 2460 psig and s 2510 psi g. On 5/4/15 during startup from 1 R26 with the plant in Mode 3, it was determined that the 1 B PSV was leaking into the pressurizer relief tank (PRT) based on elevated tailpipe temperatures. On 5/8/15 the tailpipe temperature leakage indication stabilized with average PRT in-leakage at 0.12 gpm. Compensatory actions were established which included increased monitoring of leak rate, PRT parameters, radiation levels, PRT venting, and decision points for re-evaluating the need to replace the valve. Based upon the continued leakage Unit 1 entered a planned maintenance outage on 5/26/15 to replace the 1 B PSV. The valve was then shipped to an offsite facility for lift testing and valve disassembly and inspection.

Monday, October 19, 2015

FitzPatrick: Entergy Blackmailing New York


Yea, a Republicans Ideologue company in Republican land cleaving to skirts of regulated market governmentalism.

The haters of the merchant fleet...

I guess if the if you control government, then it is not too bad?

Well, until the fanatical teabaggers take you out...  
Entergy fires back after Cuomo remarks; Fitzpatrick nuke talks shaky
While we have been unsuccessful to date, our discussions are continuing as we approach a final decision. Quite frankly, our desire has been to engage in meaningful discussions regarding continued operations of Fitzpatrick without first having to provide formal notification of a Fitzpatrick shutdown decision to the State of New York, as some have indicated is necessary. Most recently, we have heard inaccurate claims that we are "holding employees hostage" or "only seeking to improve our bottom line." That is simply not the truth. We are facing substantial financial challenges at Fitzpatrick and have been negotiating in good faith with New York State over the last several months to obtain certainty for this facility. We have a very short window of time remaining to come to a successful resolution with New York State and will be doing everything we can to achieve this. Waiting until the last minute does not serve anybody's interests.

10/19

Cuomo first issued his statement to Capital Tonight. Here is his statement in full:

‎"I have heard Entergy's public statements regarding the future of the Fitzpatrick nuclear plant and we are reviewing the economic issues company officials have raised.

This is a serious matter and a cause of anxiety not only for the more than 600 Central New Yorkers who depend on the facility for their livelihood , but also for the communities served by this plant. 


I strongly caution Entergy not to use the threat of job losses as a means of prodding economic relief to help their bottom line. This tactic has been attempted by others i‎n the past and has been unsuccessful. In this state, an entity called the Public Service Commission has oversight over services deemed to be in the statewide public's best interests.


Entergy should keep that in mind. Any decisions will be made on the merits."


Entergy has not provided the PSC with any formal notification that it intends to close FitzPatrick. Power plant owners must give the PSC six months' notice to give state officials time to evaluate the impact of a shutdown.

Sunday, October 18, 2015

River Bend: Unreliable Nuclear Plant instrumentation Power Supplies

One is safety related instrumentation power supplies and the other one is a so called non safety instrumentation power supplies. Either way, it effects plant reliability. I believe any plant scram prematurely wears out safety equipment.
 
Basically these two LERs are the ones on the last two plant scram.
Licensee Event Report 50-458 /2014-006-00 
The Christmas plant trip: Power was lost when the output breaker on the RPS motor-generator (MG) in the Division 2 subsystem tripped. The mostly likely cause of the output breaker trip was an intermittent failure of the MG field flash card due to a degraded capacitor. The capacitor was replaced, and the MG was tested and returned to a standby condition as a backup power supply. The alternate power supply will remain in service carrying the bus until completion of a modification to eliminate the field flash card as a potential source of recurrence of this problem

Licensee Event Report 50-458 /2015-005-00

On June 1, 2015, at 9:09 p.m. CDT, with the plant operating at 90 percent power, an unplanned automatic reactor scram occurred due to low reactor water level. This event resulted from the loss of a non-safety related instrument power panel, apparently caused by an internal electrical transient in a 125-volt AC / DC inverter. This event is being reported in accordance with 10 CFR 50.73(a)(2)(iv)(A)as the automatic actuation of the reactor protection system.

Look What my Complaint DId/ Discovered at River Bend: Simulator Fidelity

Update 10/19

This is very troubling. Why did it take a plant spinning wildly out of control to find grossly inappropriate training? Why didn't inspection activities pick this years ago? What else could the agency miss? You notice, nobody gets to ask the agency why this missed this and the NRC be compelled to be honest and fully truthful?   
OFFICE OF ENFORCEMENT
NOTIFICATION OF SIGNIFICANT ENFORCEMENT ACTION
 
Subject: ISSUANCE OF FINAL SIGNIFICANCE DETERMINATION AND NOTICE OF VIOLATION
This is to inform the Commission that a Notice of Violation will be issued on or about September10, 2015, to Entergy Operations, Inc. (Entergy) for a violation associated with a White Significance Determination Process finding identified during an inspection of River Bend Station.
This White finding, an issue of low to moderate safety significance, involves the failure to maintain the simulator so it would accurately reproduce the operating characteristics of the facility. Specifically, the River Bend Station simulator failed to accurately model feedwater flow and reactor vessel level response following a scram, failed to provide the correct alarm response for loss of a reactor protection system motor generator set, and failed to correctly model the operation of the startup feedwater regulating valve.
A Notice of Violation is included based on Entergy’s failure to meet 10 CFR Part 55.46(c)(1), “Plant-Referenced Simulators,” which requires, in part, that a simulator, “…must demonstrate expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been designed to respond.” In accordance with the NRC Enforcement Policy, the NOV is considered an escalated enforcement action because it is associated with a White finding.
 
***I was shocked it took a nit-wit like me to make Entergy and NRC come to terms with vessel control in this response to a notice of violation. They were grossly mis-training their operators and it severely lead to the River Bend staff's repetitive inability to control reactor water level. My complaint led to the discovery of the simulator fidelity issue and forced them to fix their site. I even postulated to the inspector making my complaint, they got simulator fidelity issues. They weren't using their simulator properly or professionally.

Post this special inspection(actually two), they had one additional plant trip. As far as I am concerned, they bungled it again. We will be closely watching them in the future with how they control vessel level on plant trips.

They problem I see is, they need a program like tuning the system up in a new plant start up program. They'd have to start-up and scram a few times...tuning all the system as they go. Then getting a perfect vessel control scram.  
Statement of Violation

10 CFR Part 55.46(c)(1), "Plant-Referenced Simulators," requires, in part, that a simulator "...must demonstrate expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been designed to respond."

Contrary to the above, as of January 30, 2015, the simulator failed to demonstrate expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been designed to respond. Specifically, the River Bend Station's simulator failed to correctly model leakage flow rates across the feedwater regulating valves; failed to provide the correct alarm response for a loss of a reactor protection system motor generator set; and failed to correctly model the behavior of the startup feedwater regulating valve controller. These simulator modeling issues led to negative training of operators. This subsequently complicated the operators' response to a reactor scram in the actual plant on December 25, 2014.

This violation is associated with a White Significance Determination Process finding.

Reasons for the violation

Entergy agrees that a performance deficiency exists and has performed a Root Cause Evaluation. The Root Cause shows that there are programmatic gaps in the plant processes to identify and communicate differences between the simulator and the operating characteristics of the reference plant. The root cause resulted from plant equipment issues not being elevated for incorporation into the simulator model. In addition, there was no process for capturing post transient alarms and submitting them to training for evaluation.


This is supported by:

* Failing to recognize, through the Corrective Action Process (CAP), the impact on operator's ability to regulate water level

• No process exists for capturing alarms received during a plant transient and submitting to training for evaluation

* Conditions were not identified as an Operator workaround or burden

* The checklist in Training Policy 97-02, "Training Simulator Configuration Control," does not contain a review of the Operator workaround or burden list for impact on Training.

• Removal of ten demineralizers from service resulted in the inability to obtain post SCRAM feedwater level trends which are used during Post Event Simulator Testing (PEST) to validate simulator configuration


Corrective steps that have been taken and the results achieved

1. Simulator Deficiency Requests were completed to correct the following simulator fidelity issues:

* Feedwater Regulating Valves modeled with no leakage * Startup Feedwater Regulating valve does not operate the same as it does in the plant (plant has up to an 8-minute delay in opening)

* High drywell pressure and Reactor Pressure Vessel (RPV) High pressure alarms do not actuate on a loss of RPS bus

2. Training was developed and administered to the oPerating crews on the changes implemented in the Simulator.

3. GOP-0005, "Power Maneuvering" was revised to include actions to freeze Emergency Response Information System (ERIS) / Safety Parameter Display System (SPDS) Transient Recording and Analysis (TRA) data and collect alarm typer data for Simulator evaluation following a transient.

4. Defined "transient" to set boundaries for evaluation to support revision to GOP-0005, "Power Maneuvering".

5. Revised OSP-0022, "Operations General Administrative Guidelines" to include guidelines for:

a. Capturing post transient alarms

b. Submitting post transient alarms to training for evaluation

c. Submitting all EN-OP-i117, "Operations Assessment Resources" transient snapshot assessments to Training for evaluation

6. Revised Training Policy 97-02, "Training Simulator Configuration Control", to include a review of the Operations Aggregate Index.

7. Reviewed Surveillance Test Procedures (STPs) performed during Simulator Annual Operating test for completeness. Based on the review, the following STPs were added:

a. STP-601 -6301, "RWCU Valve Operability"

b. STP-000-6304, "Auxiliary Building and Annulus Pressure Control Quarterly Operability"

Results were evaluated and approved by the Simulator Review Board.

8. Performed a snapshot assessment of equipment issues that could lead to Simulator differences and result in potential negative training. Assessment included licensed operator interviews and a review of the Operation's Aggregate Index.

9. Reinforced the requirements for Operation's Senior Reactor Operators to initiate a Training Evaluation Action Request (TEAR) for simulator support to run the transient on the Simulator to evaluate accuracy against real plant response per EN-OP-i117, "Operations Assessment Resources."

The results of these actions are:

* Simulator correctly models plant for identified issues,

* Operators are adequately trained on the changes made to the Simulator, and

* Process is in place for operators to capture transient information for training evaluation.

Corrective steps that will be taken

1. Develop case study on the lessons learned for not identifying the Feedwater Regulating valve seat leakage as an operator workaround. Case study will be presented to the

Condition Review Group (CRG) members, all Operations Instructors, and at Supervisor training. Corrective action is due 9/28/1 5.

Date when full compliance will be achieved River Bend is currently in full compliance with the regulations based on the completed corrective actions discussed above. Additional actions are being taken to address the Extent of Condition. These actions will be completed by September 28, 2015.