Saturday, December 05, 2015

El Nino: Severe Snow Drought in Buffalo:

It Still Hasn't Snowed in Buffalo This Season; Where's the Snow?

By Quincy Vagell
Published Dec 4 2015 09:02 PM EST
weather.com

Unusual Pattern Gripping U.S.
Meteorologist Ari Sarsalari talks about a widespread warm-up coming across the country. 
·          
Where's the Snow, Buffalo?
·          
Where is the Cold Air?
·         
Unusual Pattern Gripping U.S.
·          
Ski Resorts Waiting on Snow in New England
·          
Sleet vs. Freezing Rain
·          
Not Something You See Everyday
·         
It's already December and still no snow has been measured this season at Buffalo, New York, breaking a record that had stood for over 100 years.

Buffalo usually expects to see at least some significant snow by this point in the season. Just last year, an intense lake-effect event dumped over 80 inches of snow in mid-November across parts of the Buffalo area.

The last time Buffalo did not measure any measurable snow in the autumn before Dec. 3 was in 1899. But that record has been broken and may be shattered. With warmer than average temperatures forecast for much of December, it could be quite some time before the area finally sees measurable snowfall. Measurable snowfall is defined as at least 0.1 inch of snow falling on a given day.

What's Causing the Lack of Snow?

Warmer-than-average conditions, driven by one of the strongest El NiƱos on record, is one glaring reason why snow has struggled to reach Buffalo.

This past month marked the seventh warmest November on record for Buffalo, and temperature records for the area go back to the early 1870s. For daytime warmth, 21 days in the month of November reached or exceeded 50 degrees, tying 2001 and 2011 for the most on record in November.

Red colors indicate warmer than average temperatures, while blues highlight below average temperatures for November 2015.

The numbers tell a similar story at night, with just seven November days reporting a low temperature at or below freezing. Only six of the past 142 Novembers have had fewer freezing daily lows. It is hard to experience accumulating snowfall when it has been as mild as Buffalo has been.

It's not just the warm weather though. This past November was also the third-driest November on record. Precipitation was 67 percent below average for the month at Buffalo.
So, where is the snow?


Moving into December, the jet stream is displaced unusually far north across Canada. That means the active storm track and cold air are largely displaced north and northwest of Buffalo. While it may be snowing in Canada, not much of that snow has reached the Great Lakes region...

Friday, December 04, 2015

NEI’s Fukushima Voodoo Flex Philosophy For The whole Nation

They would be a lot better if they used all the monies from this to show us the real realities of plant life and the nuclear industry. 

For special NRC projects at each plant...where are your weaknesses and how can you communicate better to outsiders

  

Developed by the NEI FLEX in Risk Informed Decision Making (FRIDM) Task Force  
PURPOSE

The purpose of this guidance document is to establish the considerations that should be assessed when evaluating the qualitative risk and safety benefit of Mitigating Strategies Equipment in Risk Informed Decision Making (RIDM). The licensee should determine that the use of a qualitative risk assessment is acceptable for the specific RIDM process being evaluated (e.g.
Shutdown Risk Assessment, Online Risk Management, Significance Determination Process (SDP), and Notice of Enforcement Discretion (NOED)). This guidance uses FLEX as an example case, however equipment of other mitigating strategies is applicable. This guidance identifies the key elements of a qualitative assessment of the benefits of mitigating strategies and the associated equipment. These strategies and equipment can be used to enhance and/or develop qualitative considerations for use in the risk-informed decision making process. This qualitative risk assessment can supplement or be used in lieu of quantitative risk assessment if applicable.
More flex crap. The object of the whole deal is to make it so complicated nobody can understand a thing they are saying including themselves.

Hey, when things go south nobody can blame anyone...

Good job everyone! 


Developed by the NEI FLEX in Risk Informed Decision Making (FRIDM) Task Force

1. PURPOSE
The purpose of this guidance document is to establish the considerations that should be assessed when evaluating the qualitative risk and safety benefit of Mitigating Strategies Equipment in Risk Informed Decision Making (RIDM). The licensee should determine that the use of a qualitative risk assessment is acceptable for the specific RIDM process being evaluated (e.g.
Shutdown Risk Assessment, Online Risk Management, Significance Determination Process (SDP), and Notice of Enforcement Discretion (NOED)). This guidance uses FLEX as an example case, however equipment of other mitigating strategies is applicable. This guidance identifies the key elements of a qualitative assessment of the benefits of mitigating strategies and the associated equipment. These strategies and equipment can be used to enhance and/or develop
qualitative considerations for use in the risk-informed decision making process. This qualitative risk assessment can supplement or be used in lieu of quantitative risk assessment if applicable.




Thursday, December 03, 2015

My Errant Comments On NRC blog about "Spent Fuel"

Basically the whole deal is here is to advantage the nuclear utilities while consuming our government's credibility.  

I was surprised they published it. The reason why I worried is they knew I was expressing a wider truth not spoken. 
See, this is nuclear waste materials is owned and produced by a private entity. It’s not even partially owned and controlled by the federal government. So why does a US government regulator become the public relation spokesperson on nuclear waste issues? Can’t the government wait to open your mouth until you actually own and control the material? Why aren’t the owners of this waste the primary spokesmen…the public know these are the guys are in control of the waste. We hold you businesses and real owners responsible!!! You made it, you bury it? 
When the government speaks for a private entity you are lending the government’s credibility to a private businesses or the nation is consuming our credibility for a private business. These businesses hate your guts and are fighting the government tooth and nail. 
You are doing the same thing on the plant operational side. The US government is increasingly lending our credibility…our nation’s credibility…disproportionately on a specific industrial sector. The NRC is increasingly becoming the nuclear industry’s plant public relation spokesman. You are excessively promoting the industry. We focus on blaming the government when a private business fails cause that is the only people we see and hear in this? The nuclear industry and the plants knows the liabilities of explaining and defending themselves publically. Cause then the public holds them accountable for what they say or neglect to say and do. The safest thing for these nuclear company’s is just to say as little as they can. Then never risk their own credibility unless they are forced too. They never volunteer to be openly accountable, democratic and transparent… 
The government has an infinite reservoir of credibility, so the NRC becomes/defaults into the promoter public relation spokesman for all the nuclear industry and nuclear plants. Why doesn’t the US government become the primary promoter public relation spokesman of all corporations and businesses against the weak and the poor? Is that a upside-down government or what?
Let the giant US government take the hit of their credibility for the nukes, my credibility and your credibility and the US government’s credibility. I just want to know what our government gets for this favor? Remember most these giant corporations and plant employees have very little respect for their great nation in the bowels of their corporate offices and nuclear plants. They spend the majority of their high income lives trying to tear down and speak down the US government in any way they can. Our government. Your neighbor’s government. My government! 
I live in the greatest nation on the planet! My state I am not so sure. 
Mike Mulligan
Hinsdale, NH

Moments in NRC History: Regulating for Safety and Non-Proliferation, Part II” 

Anonymous December 2, 2015 at 8:50 am

Well, what I don’t like about nuclear nonproliferation activities with our government, parts of this has been blighted my mind boggling cover-ups such as the megatons to megawatt program and the forced federal takeover nationwide with the deposition of used nuclear fuel. Greed and political agendas took priority over doing what is in the best interest for the nation. The idea the majority of the electricity from US nuclear power plants was from corrupt Russian uranium supporting a corrupt government.

Mike Mulligan
Hinsdale, NH

Note: Moved by the Moderator

Risk-Informed and Performance-Based Regulation

This sounds like exotic science and engineering...underneath it all is unquestionable self interested assumptions and judgements. There is no facts and evidence here. It's pseudoscience built on a house of cards.

The common useage of the nuclear word "safety" is grossly corrupted by the explanation of the below.     

(Neat NRC explanations and definitions)

Risk-Informed and Performance-Based Regulation

The NRC has established its regulatory requirements, in both reactor and materials applications, to ensure that "no undue risk to public health and safety" results from licensed uses of Atomic Energy Act (AEA) materials and facilities.

The objective of these requirements has always been to assure that the probabilities of accidents with the potential for adversely affecting public health and safety are low. For reactors, these probabilities were not quantified in a systematic way until 1975 when the Reactor Safety Study (WASH-1400) was published. For non-reactor activities, the situation is more complex. In some areas, high-level waste disposal and transportation, risk assessment has been in use since the 1970s; in others, such quantification is still evolving. Consequently, most of NRC's regulations were developed without the benefit of quantitative estimates of risk. The perceived benefits of the deterministic and prescriptive regulatory requirements were based mostly on experience, testing programs and expert judgment, considering factors such as engineering margins and the principle of defense-in-depth.

There have been significant advances in and experience with risk assessment methodology since 1975. Thus, the Commission is advocating certain changes to the development and implementation of its regulations through the use of risk-informed, and ultimately performance-based, approaches. The Probabilistic Risk Assessment (PRA) Policy Statement (60 FR 42622, August 16, 1995) formalized the Commission's commitment to risk-informed regulation through the expanded use of PRA. The PRA Policy Statement states, in part, "The use of PRA technology should be increased in all regulatory matters to the extent supported by the state of the art in PRA methods and data, and in a manner that complements the NRC's deterministic approach and supports the NRC's traditional defense-in-depth philosophy."

The transition to a risk-informed regulatory framework is expected to be incremental. Many of the present regulations are based on deterministic and prescriptive requirements that cannot be quickly replaced. Therefore, the current requirements will have to be maintained while risk-informed and/or performance-based regulations are being developed and implemented.

To understand and apply the commitment expressed in the PRA Policy Statement, it is important that the NRC, the regulated community, and the public at large have a common understanding of the terms and concepts involved; an awareness of how these concepts (in both reactor and materials arenas) are to be applied to NRC rulemaking, licensing, inspection, assessment, enforcement, and other decision-making; and an appreciation of the transitional period in which the agency and industry currently operate

1. Risk and Risk Assessment: This paper defines risk in terms that can be applied to the entire range of activities involving NRC licensed use of AEA materials. The risk definition takes the view that when one asks, "What is the risk?" one is really asking three questions: "What can go wrong?" "How likely is it?" and "What are the consequences?" These three questions can be referred to as the "risk triplet." The traditional definition of risk, that is, probability times consequences, is fully embraced by the "triplet" definition of risk.
 The first question, "What can go wrong?" is usually answered in the form of a "scenario" (a combination of events and/or conditions that could occur) or a set of scenarios. The second question, "How likely is it?" can be answered in terms of the available evidence and the processing of that evidence to quantify the probability and the uncertainties involved. In some situations, data may exist on the frequency of a particular type of occurrence or failure mode (e.g., accidental overexposures). In other situations, there may be little or no data (e.g., core damage in a reactor) and a predictive approach for analyzing probability and uncertainty will be required. The third question, "What are the consequences?" can be answered for each scenario by assessing the probable range of outcomes (e.g., dose to the public) given the uncertainties. The outcomes or consequences are the "end states" of the analyses. The choice of consequence measures can be whatever seems appropriate for reasonable decision-making in a particular regulated activity and could involve combinations of end states. A risk assessment is a systematic method for addressing the risk triplet as it relates to the performance of a particular system (which may include a human component) to understand likely outcomes, sensitivities, areas of importance, system interactions and areas of uncertainty. From this assessment the important scenarios can be identified.

2. Deterministic and Probabilistic Analyses: All safety regulation ultimately is concerned with risk and addresses the three questions discussed in item 1 above. In practice, NRC addresses these three questions through the body of regulations, guidance, and license conditions that it uses to regulate the many activities under its jurisdiction. The current body of regulations, guidance and license conditions is based largely on deterministic analyses and is implemented by prescriptive requirements. As described in the PRA Policy Statement, the deterministic approach to regulation establishes requirements for engineering margin and for quality assurance in design, manufacture, and construction. In addition, it assumes that adverse conditions can exist and establishes a specific set of design basis events (i.e., what can go wrong?). The deterministic approach involves implied, but unquantified, elements of probability in the selection of the specific accidents to be analyzed as design basis events. It then requires that the design include safety systems capable of preventing and/or mitigating the consequences (i.e., what are the consequences?) of those design basis events in order to protect public health and safety. Thus, a deterministic analysis explicitly addresses only two questions of the risk triplet. In addition, traditional regulatory analyses do not integrate results in a comprehensive manner to assess the overall safety impact of postulated initiating events.
 PRA and other risk assessment methods (also described in the PRA Policy Statement) consider risk (i.e., all three questions) in a more coherent, explicit, and quantitative manner. Risk assessment methodology examines systems and their interactions in an integrated, comprehensive manner. Probabilistic analysis explicitly addressesa broad spectrum of initiating events and their event frequency. It then analyzes the consequences of those event scenarios and weights the consequences by the frequency, thus giving a measure of risk. Since risk assessment methods were first used to gain a better understanding of the risk associated with some of the activities and facilities that the NRC regulates, substantial event data and increased sophistication and experience in the use of certain risk assessment methods (e.g., Probabilistic Risk Assessment (PRA), IntegratedSafety Assessment (ISA), and Performance Assessment (PA)) have been acquired. Accordingly, there is now the opportunity to enhance the traditional approach by more explicitly addressing risk and incorporating the insights thus gained. While the traditional deterministic approach to regulation has been successful in ensuring no undue risk to public health and safety in the use of nuclear materials, opportunities for improvement exist. Given the broad spectrum of equipment and activities covered, the regulations can be strengthened and resources can be allocated to ensure that they are focused on the most risk-significant equipment and activities, and to ensure a consistent and coherent framework for regulatory decision-making. The different "risk-informed" and/or "performance-based" approaches to regulation described below, if properly applied singly or in combination, would provide such a framework. 3. "Risk Insights": The term "risk insights," as used here, refers to the results and findings that come from risk assessments. The end results of such assessments may relate directly to public health effects as in the Commission's Safety Goals for the Operation of Nuclear Power Plants. For specific applications the results and
findings may take other forms. For example, for reactors these include such things as identification of dominant accident sequences, estimates of core damage frequency (CDF)(1) and large early release frequency (LERF)(2), and importance measures of structures, systems, and components. On the other hand, in other areas of NRC
regulation, findings and results include risk curves(3) for disposal facilities for radioactive wastes, frequency of and costs associated with accidental smelting of sealed sources at steel mills, frequency of occupational exposures, predicted dose from decommissioned sites and many others. Risk insights have already been incorporated successfully into numerous regulatory activities, and have proven to be a valuable complement to traditional deterministic approaches. Given the current maturity of some risk
assessment methodologies and the current body of event data, risk insights can be incorporated more explicitly into the regulatory process in a manner that will improve both the efficiency and effectiveness of current regulatory requirements. 4. "Risk-Based Approach": Regulatory decision-making is required in both the development of regulations and guidance and the determination of compliance with those regulations and guidance. A "risk-based" approach to regulatory decision-making is one in which such decision-making is solely based on the numerical results of a risk assessment. This places heavier reliance on risk assessment results than is currently practicable for reactors due to uncertainties in PRA such as completeness. Note that the Commission does not endorse an approach that is "risk-based"; however, this does not invalidate the use of probabilistic calculations to demonstrate compliance with certain criteria, such as dose limits.
 5. "Risk-Informed Approach": A "risk-informed" approach to regulatory decision making represents a philosophy whereby risk insights are considered together with other factors to establish requirements that better focus licensee and regulatory attention on design and operational issues commensurate with their importance to public health and safety. A "risk-informed" approach enhances the deterministic approach by: (a) allowing explicit consideration of a broader set of potential challenges to safety, (b) providing a logical means for prioritizing these challenges based on risk significance, operating experience, and/or engineering judgment, (c) facilitating consideration of a broader set of resources to defend against these challenges, (d) explicitly identifying and quantifying sources of uncertainty in the analysis (although such analyses do not necessarily reflect all important sources of uncertainty), and (e) leading to better decision-making by providing a means to test the sensitivity of the results to key assumptions. Where appropriate, a risk-informed regulatory approach can also be used to reduce unnecessary conservatism in purely deterministic approaches, or can be used to identify areas with insufficient conservatism in deterministic analyses and provide the bases for additional requirements or regulatory actions. "Risk-informed" approaches lie between the "risk-based" and purely deterministic approaches. The details of the regulatory issue under consideration will determine where the risk-informed decision falls within the spectrum.
 6. "Risk-Informed Approach and Defense-in-Depth": The concept of defense-in depth(4) has always been and will continue to be a fundamental tenet of regulatory practice in the nuclear field, particularly regarding nuclear facilities. Risk insights can make the elements of defense-in-depth more clear by quantifying them to the extent practicable. Although the uncertainties associated with the importance of some elements of defense may be substantial, the fact that these elements and uncertainties have been quantified can aid in determining how much defense makes regulatory sense. Decisions on the adequacy of or the necessity for elements of defense should reflect risk insights gained through identification of the individual performance of each defense system in relation to overall performance.
 7. "Performance-Based Approach": A regulation can be either prescriptive or performance-based. A prescriptive requirement specifies particular features, actions, or programmatic elements to be included in the design or process, as the means for achieving a desired objective. A performance-based requirement relies upon measurable (or calculable) outcomes (i.e., performance results) to be met, but provides more flexibility to the licensee as to the means of meeting those outcomes. A performance-based regulatory approach is one that establishes performance and results as the primary basis for regulatory decision-making, and incorporates the following attributes: (1) measurable (or calculable) parameters (i.e., direct measurement of the physical parameter of interest or of related parameters that can be used to calculate the parameter of interest) exist to monitor system, including facility and licensee, performance, (2) objective criteria to assess performance are established based on risk insights, deterministic analyses and/or performance history, (3) licensees have flexibility to determine how to meet the established performance criteria in ways that will encourage and reward improved outcomes; and (4) a framework exists in which the failure to meet a performance criterion, while undesirable, will not in and of itself constitute or result in an immediate safety concern. The measurable (or calculable) parameters may be included in the regulation itself or in formal license conditions, including reference to regulatory guidance adopted by the licensee. This regulatory approach is not new to the NRC. For instance, the Commission previously has approved performance-based approaches in 10 CFR Parts 20, 50 (Option B, Appendix J and the Maintenance Rule,10 CFR50.65), 60, and 61. In particular, the Commission weighed the relative merits of prescriptive and performance-based regulatory approaches in issuing 10 CFR Part 60.
 
A performance-based approach can be implemented without the use of risk insights. Such an approach would require that objective performance criteria be based on deterministic safety analysis and performance history. This approach would still provide flexibility to the licensee in determining how to meet the performance criteria.Establishing objective performance criteria for performance monitoring may not be feasible for some applications and, in such cases, a performance-based approach would not be feasible.
 As applied to inspection, a performance-based approach tends to emphasize results (e.g., can the pump perform its intended function?) over process and method (e.g., was the maintenance technician trained?). Note that a performance-based approach to inspection does not supplant or displace the need for compliance with NRC requirements, nor does it displace the need for enforcement action, as appropriate, when non-compliance occurs. (5)As applied to licensee assessment, a performance-based approach focuses on a licensee's actual performance results (i.e., desired outcomes), rather than on products (i.e., outputs). In the broadest sense, the desired outcome of a performance-based approach to regulatory oversight will be to focus more attention and NRC resources on those licensees whose performance is declining or less than satisfactory. 8. "Risk-Informed, Performance-Based Approach": A risk-informed, performance-based approach to regulatory decision-making combines the "risk-informed" and "performance-based" elements discussed in Items 5 and 7, above, and applies these concepts to NRC rulemaking, licensing, inspection, assessment, enforcement, and other decision-making. Stated succinctly, a risk-informed, performance-based regulation is an approach in which risk insights, engineering analysis and judgment including the principle of defense-in-depth and the incorporation of safety margins, and performance history are used, to (1) focus attention on the most important activities, (2) establish objective criteria for evaluating performance, (3) develop measurable or calculable parameters for monitoring system and licensee performance, (4) provide flexibility to determine how to meet the established performance criteria in a way that will encourage and reward improved outcomes, and (5) focus on the results as the primary basis for regulatory decision-making.
 

The definitions and concepts in this paper have proven suitable for application to nuclear power plants and certain nonreactor activities (e.g., PA of geologic repositories). While different in detail, these activities are similar in terms of system complexity and the application of probabilistic methods to the determination of safety. In simpler situations, the concepts and definitions should prove equally suitable provided that NRC adopts a flexible framework for the implementation of risk-informed, and ultimately performance-based, regulation across the full spectrum of the materials, processes, and facilities regulated by the NRC.


1. CDF is the frequency of the combinations of initiating events, hardware failures, and human errors leading to core uncovery with reflooding of the core not imminent.

2. LERF is the frequency of those accidents leading to significant, unmitigated releases from containment in a timeframe prior to effective evacuation of the close-in population such that there is a potential for early health effects.

3. Risk curves (also known as Complementary Cumulative Distribution Functions (CCDFs) or Farmer curves) are estimates of the probability that a given consequence will be exceeded.

4. Defense-in-depth is an element of the NRC's Safety Philosophy that employs successive compensatory measures to prevent accidents or mitigate damage if a malfunction, accident, or naturally caused event occurs at a nuclear facility. The defense-in-depth philosophy ensures that safety will not be wholly dependent on any single element of the design, construction, maintenance, or operation of a nuclear facility. The net effect of incorporating defense-in-depth into design, construction, maintenance, and operation is that the facility or system in question tends to be more tolerant of failures and external challenges.

5. Not every aspect of licensed activities can or should be inspected using this approach. For example, if a licensee is unsuccessful in meeting the criteria defined by a performance-based regulation, the inspector should then focus on the licensee's process and method, to understand the root cause of the breakdown in performance, and to understand how future poor performance may be avoided.


Wednesday, December 02, 2015

Our Nuclear Village Secretly At Work Again



So let me get this straight, Pilgrim got into trouble with too many scrams in 2013. I am sure Entergy is upset with this. The NRC finally does a inspection on this 2012-2013 set of events and it comes out in the beginning of 2015. The NRC was sitting on the inspection all during 2014. A day after the Nemo blizzar they release the inspection results. This guys (NRC)can totally engineer when a finding and violation appears. Then the 2013 set of violations appears in 2015. 

As I been saying for years, if the NRC would have hammered Entergy with a blizzard worth of NRC inspection hours in 2013 irrespective of apparent risk according to their nuclear village violations and significance system, they would have cleared out the possibility of future violations and the big one in the Dec/Feb 2015 blizzard Nemo LOOP. Or at least Pilgrim would have voluntarily shutdown for this blizzard and the next...wouldn't have had the LOOP, scram or SRV problems. 

All I am saying is global risk from events before the 2013 "excessive scram violations" to the Nemo LOOP violations would have been drastically reduced if the NRC didn't obey their reactor oversight process. It looks at events in an inappropriate span of time that is favorable to a plant. If they were allowed to hit Pilgrim hard in the easily detectable plant decline in the 2012-2013 in timeframe with a host of inspections...bringing immediately to light and amplifying the seeming significance of each problem like the emerging problems with the 3 stage SRVs, then early on Entergy would be made to see the errors of the ways. All the riskful ways in 2014 and 2015 would have not occurred. So they never see all the past and current risk and significance in real time, and anticipate the easily predictable future risk they could have prevent. How much risk could the NRC have prevented?  

The fatal flaw in the Reactor Oversight Process is the NRC just looks at a licencee's favorable selective subset list of all risk...not looking at all the holistic risk and and safety significance. 

The NRC employees as happy as a clam if they are just following some approved policy or procedures making their bosses happy..they have no care if they don't really understand what they are doing.  

These guys are just gaming the system and favorably engineering outcomes in the name of self interest.            
The NRC determined that the performance at Pilgrim has been in the Repetitive Degraded Cornerstone Column (Column 4) of the Reactor Oversight Process (ROP) Action Matrix since the beginning of the first quarter of 2015 following the final significance determination of a White finding under the Mitigating Systems Cornerstone referenced in a separate letter issued on September 1, 2015 (ADAMS Accession No. ML15230A217). Pilgrim was already in the Degraded Cornerstone Column (Column 3) of the ROP Action Matrix for more than five consecutive quarters as of January 1, 2015, due to two open White inputs under the Initiating Events Cornerstone. In Supplemental Inspection Report 05000293/2014008 (ML15026A069), dated January 26, 2015, the NRC noted that Pilgrim did not adequately evaluate the causes and take or plan timely corrective actions to address the issues associated with a high number of unplanned scrams which occurred in 2013. As a result, the two White inputs under the Initiating Events Cornerstone remained open for greater than five consecutive quarters and were in effect when the new White finding under the Mitigating Systems Cornerstone was identified in an exit meeting on March 20, 2015, as documented in Special Inspection Report 05000293/2015007 (ML15147A412), dated May 27, 2015. The White inputs under the Initiating Events Cornerstone have subsequently been closed as of June 30, 2015, due to the successful completion of a follow-up inspection in accordance with Inspection Procedure (IP) 95002 as documented in Inspection Report 05000293/2015009 (ML15169A946) dated June 18, 2015.

The Nuclear Regulatory Commission approved changes today to the agency’s Reactor Oversight Process, adjusting the criteria for subjecting a nuclear power plant to additional oversight and directing the staff to develop new guidance to help identify weaknesses in a licensee’s performance.  The Commissioners approved a staff recommendation to require three low-to-moderate safety significance (white) inspection findings or performance indicators to push a reactor into the “degraded cornerstone” category of regulatory oversight, often known as Column Three of the Reactor Oversight Process Action Matrix. Column One represents a reactor receiving normal oversight and Column Five is reserved for reactors ordered to shut down due to unacceptable performance. 

The ROP, initiated in 2000, assesses a nuclear power plant’s performance across seven aspects of facility operation, called cornerstones. Inspection findings are color-coded as green, white, yellow or red, in increasing order of safety significance.

Gobbly Goop

Performance indicators are objective data regarding licensee performance in the different cornerstones. These safety-significant numbers are compiled by licensees and reported to the NRC; they are color coded in a similar manner.

The NRC always has a huge population of known unenforced regulation violations. They can pick from this group anytime they want and engineer any violation they want.
  
The current criteria would move a plant to Column Three based on two white inputs in the same cornerstone or a single yellow input.

They are pulling on a thread with equating finding level to safety risk. Do these guys ever show their work?

A staff assessment determined that from a risk-informed perspective, three white findings, not two, are more closely equivalent to a single yellow input.

Moving from Column Two to Column Three involves a significant increase in resources for both the NRC and the plant: Column Two involves about 40 hours of additional inspections, while Column Three requires 200 hours.

So we are going to have more yellow finding. There is a severe disconnect with finding levels and controlling a utility’s aberrant behavior.

More highly technical talk gobbly goop.

The change to three white inputs in the same cornerstone better aligns the safety significance to the additional level of inspection. 

Tuesday, December 01, 2015

Nuclear Power: Closing the civility gap (VY)

I was there at this meeting. I had gone through a FBI Joint Terrorism Task Force bogus investigation over these events. At this public meeting when I was up at the podium, I spent the majority of my time profusely thanking the local police and NRC for being with us in the pitiful times. I'll make the case, the antis or Entergy never thanked the local police force for making all of us safe. What can I say, they both hated government equally.        

It was a hugely contentious era we all went through from the AOG radioactive pipe leak to final licenced meeting we are talking about here.

Remember both a Republican and Democrat Vermont governor's lost trust in Entergy. Entergy senior management was arrogant and thought they were superior to everyone surrounding Vermont Yankee. What set this up, is in a Vermont legislature testimony a VY engineer denied there were radioactive pipes outside any building buried in the ground. Then a large radioactive leak occurred in a pipe Entergy denied was ever in the yard. Entergy was playing their highly technical tricky and deceptive word games. They got caught in a lie and they didn't quickly admit it and say they were sorry. They had a lot of good employees at VY. I felt sorry for how entergy supported them.

As this played out, there was massive protest surrounding the plant and they were constantly negative in the news. This turned the public against them, the politicians soon followed. Gov Shumlin got elected over going deeply anti nuclear. 

We felt at every step the NRC and their rules were never on the public side. Could never control a bad actor nuclear power plant. We felt there was no enforcement there and it was only going to get worst.   

Believe me, Pilgrim was going in the same direction recently. The NRC felt that and got serious with the plant in the end. Who wants more cow manure thrown at them?        

This disaster could happen at any of the other 99 plants and at any moment. It is not that hard locally to ruin the reputation of a giant corporation no matter how much money they got. Remember we were right in worrying about safety at the VY. History proved us right. Entergy's Pilgrim and Arkansas Nuclear One, according to the NRC, are the worst operating plants in the USA. ANO recklessly dropped a 600 stator in the turbine building through not following procedures and they killed one and seriously injured eight others. River Bend and Waterford are teetering on the cliff.      

Nationwide we were feeling disgraced by our institutions and political systems as the AOG building inlet pipes became leaking. We see the results of it in this presidential election cycle with reckless outsiders leading the polls. Our faith in government is in negative territory. 

It basically was a perfect storm with the massive development of widespread public disgruntlement with our institutions and the loss of credibility with a giant electric utility such as Entergy. 

Everyone is not that far from getting manure flung at them in a public meeting.        

Nuclear Power: Closing the civility gap

By Dan Yurman
Posted:   12/01/2015 11:38:31 AM

On Feb. 19, a Nuclear Regulatory Commission public meeting held in Brattleboro descended into chaos. Protesters who were bent on disrupting the proceedings bullied and threatened people who wanted to speak at the meeting. The disrupters' tactics included shouting at speakers, thereby interrupting their remarks, and making verbal threats against those who sought to speak in support of either the NRC's proposed action or the utility that was the subject of the meeting. 
The objectives of the disrupters were to prevent the NRC from having a credible public process and to attack the diligence and compliance of the nuclear utility, which is regulated by the agency. 
The facts are not open to debate. The disturbing details of this meeting were captured on video and were broadcast the next day on a local cable TV channel. 
Ineffective outreach and failure to control large public meetings aren't a new problem for the NRC. In May 2014, a group of protesters at a meeting regarding Vermont Yankee nuclear power plant in Vernon interrupted the session by shouting that the NRC officials at the meeting were "lying and incompetent." Considering the technical credentials of the staff and their extensive experience as nuclear regulators, these assertions were unfounded and insulting.

Why hasn't the NRC taken a more proactive approach to preventing its meetings from running off a cliff? The issue is that like ill-informed parents deciding not to vaccinate their children against the measles virus, this kind of antisocial behavior could spread to public meetings and licensing hearings across the country. In fact, a pro-nuclear group in California raised exactly that issue in a recent letter to the NRC about public meetings on seismic safety at the Diablo Canyon nuclear plant. 
The legitimacy of the agency and the diligence and compliance of the nuclear utilities it regulates are being challenged by people who disrupt its meetings. So how much of a problem does the NRC have and what does it intend to do about it? It turns out that the NRC appointed a task force to look into the problem. The task force produced a report on the issue in late January 2015, just weeks before the public meltdown that occurred at the Brattleboro meeting. 
The task force report acknowledges that the NRC is "inconsistent" in its efforts to conduct public outreach. Further, the report notes that there are problems with the "attitude" of the NRC civil servants who conduct the public meetings about how useful the meetings are to the agency. 
The report states that leaving the management of public meetings to technical staff not skilled in the subject of managing public meetings is a problem, and adds that the NRC's engineers and their managers have given public meetings a low priority relative to their other safety-related regulatory duties. 
The report provides a number of recommendations — some useful, and some just wishful thinking — to remedy the situation. Nowhere in the document does it commit to providing funding to carry them out. Without hard dollars behind the recommendations, this report could wind up keeping company with prior versions just like it that hark back more than a decade. We've seen this movie before. 
What's astonishing is that the task force decided not to ask the public what it thinks of the NRC's performance in regard to the conduct of its public meetings. This seems to be clear evidence of the "attitude" problem cited in the report summary. 
According to the report, NRC management does not believe that the meetings do any good, which means that those running the meetings have no incentive to do much beyond the bare minimum. The result is that where there are large crowds and a controversial issue is at stake, NRC technical staff are frozen in place on their chairs and are unlikely to say anything beyond the most basic statements about the meeting process. 
People who are determined to disrupt these meetings say and do outrageous things, taking advantage of the staff's obvious reluctance to assert control over the process. Examples include throwing what they claim are organic waste products onto the podium, and brazenly and repeatedly interrupting speakers. 
The report cites several models of successful public engagement. Clearly, the task force understands what constitutes effective outreach and management of these meetings. What the NRC needs more than practical advice on techniques is a cultural shift, and it needs to hire people who are expert at dealing with large public meetings on controversial subjects. 
The agency gets a plus for its candor in the report, but the space it must travel — the delta — to close these self-reported gap sremains as wide as the Missouri River in "flood stage." 
One of the issues that seems to fall by the wayside is that the nuclear utilities regulated by the NRC have sometimes taken a hands-off approach when it comes to maintaining control of public meetings about their licenses or operations. Part of the problem is a desire to hold the regulator at arm's length, and part of it is a view that the control of a public meeting is the NRC's problem. 
Here is why change is needed. 
To respond to disruptions, bullying, and threats at public meetings, both the NRC and the nuclear utilities it regulates must change the way they communicate and collaborate. Neither can limit their engagement with the public to the single channel of a public meeting. 
A public meeting is one of the few places where the public can interact with a utility's managers and the NRC's engineers and hear what they have to say. A disrupted meeting casts a negative shadow over the utility's message, however positive that message may be, about plant safety. The reason is that people will remembert he disruption and not the safety message. The news media will certainly report the disruption, and the substantive issues that are at stake second, if at all. 
A utility's brand value depends on a positive view of the utility by the public. An NRC meeting that becomes contentious will color public perceptions of both the utility and the NRC, even though both are blameless regarding the cause of the disruption. When the NRC and the utility do nothing to stop disruptive tactics, they become passive enablers of the disrupters' objectives. 
While publicly traded nuclear utilities have signicant fiduciary responsibilities to stockholders that limit what they can say and do in public, informing the public is never a poor choice, and that action goes along with its branding and marketing strategies to boost the value of its stock. 
The NRC and the nuclear industry need to collaborate to and find new ways to ensure that when people show up at a public meeting, they can feel safe and secure, knowing that a civil process will take place. The utility needs to conduct outreach to the community no less so than the NRC when it comes to these kinds of public events.
This advice is counter to the current practice of some nuclear utilities that counsel their employees not to attend a meeting unless they are assigned to support it. Or, if they do attend, they are instructed not to speak on the utility's behalf. 
Utilities say that they don't want the appearance of "packing" a meeting. They may also feel that one or more employees,speaking on their own responsibility, may reveal information that will be misunderstood, will be deliberately misconstrued by antinuclear activists, or that may confuse the NRC staff. What the utility misses is that its employees and their families and friends are already communicating about the plant on social media. Anyone who has watched a Twitter message or YouTube video "go viral" readily understands that an enormous audience can develop over a short period of time and can be drawn into a report about a specific event, even if the report doesn't have the facts right. 
For example, in June 2011, despite the NRC's successful efforts to get the Fort Calhoun nuclear station to develop flood abatement measures, Business Insider, a major social media site, published a report saying that the plant had blown up. This produced a brief but intense frenzy in the mainstream news media, resulting in the dispatch of helicopters to take photographs of what they expected to be a nuclear disaster. Instead, the pilots had their knuckles rapped for violating the Federal Aviation Administration's Notice to Airmen not to fly over commercial nuclear power plants. 
And yet, the answer to problems with communication at public meetings is more communication. A utility that views social media as a liability, or as just a new set of outlets for its press releases, will fail to satisfy its outreach objectives. Using social media prior to public meetings, along with mass media channels, can do a lot to set public expectations and perceptions and to "inoculate" the public against individuals' efforts to disrupt these meetings. 
Social media, with its instantaneous feedback loops, is about dialogue. Mastery of social media means engaging in dialogue in social media channels. This is a daunting challenge for some utilities, which already have executives, legal counsel, and the chief financial officer all scrutinizing even the most routine of press releases. Asking some utility executives to consider dialogue on Twitter or Facebook is simply an invitation to seeing them, metaphorically speaking, blow their gaskets. 
The urgency of the problem of disrupted meetings requires that the NRC and nuclear utilities spend less time trying to control the message — for example, via one-to-many PR methods with the mass media. They need to spend more time engaging in dialogue with various "publics" in many-to-many social media channels. The payoff is that entities with the best ability to mediate dialogue and participate in it effectively will make far more progress in getting their message across than those who don't do these things. 
While it is true that some people seem to think that political theater is a substitute for establishing a meeting record in a regulatory decision-making process, the fact is that the NRC knows that it is likely to be challenged in court. That's why its rigor in establishing a meeting record matters. People in the nuclear industry know that, but the public isn't always cognizant of the boundary between protest and process. 
Meeting records and hearing records are equally important elements of the public'sinput to the NRC's decision-making processes. While NRC public meetings are less formal than its quasi-judicial hearings, both types of forums have suffered from problems caused by a lack of civility and engagement, especially when they have been conducted away from the agency's White Flint headquarters building in Rockville, Md. 
People who opt for protest may feel powerless, and that fuels disruptive behaviors. People who feel that they are being heard are not as likely to create distractions at a public meeting. 
Civility and safety in public meetings, or on social media,still depend on appealing to reason, engaging respectfully with people who hold divergent views, and recognizing that the public brings all kinds of perceptions about power and persuasion to social media forums. 
The more dialogue there is that is civil and safe, the less influence people with an agenda to disrupt public meetings will have over the outcome of the meetings. 
This article can also be found at ansnuclearcafe.org/2015/11/18/27778. Reprinted with permission from the November 2015 issue of Nuclear NewsCopyright ©2015 by the American Nuclear Society. 
Dan Yurman is the Publisher of NeutronBytes.com, a blog about nuclear energy.To contact Yurman, email dan.yurman@usa.net.

Indian Point Safety to Remain Top Priority for Entergy (not)

Unless they can get away with putting the shade over your eyes.

It all depends what the word safety means?  Their definition and common usage is worlds apart.

They corrupted the word safety to the ends of self interest and status.   

Indian Point Safety to Remain Top Priority for Entergy

The owners of the Indian Point nuclear power plants in Buchanan have vowed to ensure the safety of the facility if an additional 20-year license is approved. 
During an appearance before a three-judge panel of the federal Nuclear Regulatory Commission’s Atomic Safety and Licensing Board in Tarrytown two weeks ago, Entergy officials maintained their legally enforceable commitments to safely operating the 40-year-old plants were based on state-of-the-art science. 
“Indian Point has operated safely for more than 40 years, delivering enormous benefits such as reliable price-stable and non-greenhouse gas emitting power generation, day in and day out,” said Fred Dacimo, vice president of operations license renewal for Entergy. “The fact that Nuclear Regulatory Commission staff has spent 37,000 hours over eight years reviewing and inspecting Indian Point’s application should be reassuring to everyone that all aspects of the license renewal process have been thoroughly examined, and that the facility will continue to operate at the highest levels of safety and reliability.” 
In September 2013, Indian Point Unit 2 began operating under Timely Renewal, which extends the initial 40-year license while the license process continues for at least several more years until the NRC makes a final determination. Indian Point Unit 3 will begin its Timely Renewal period on December 13 when its current license expires. 
Indian Point supplies about 25 percent of Westchester County and New York City’s electricity, and 11 percent of New York State’s power. Approximately 1,000 people are employed at the plants, which, according to Entergy, directly and indirectly generate $1.6 billion annually.
The NRC has already issued a report concluding there is nothing to preclude Indian Point from safely functioning for the next 20 years. A Final Environmental Impact Statement issued by the NRC also determined there were no environmental issues preventing license renewal. 
However, Entergy does face some hurdles with the New York Department of State, which earlier this month filed an objection to Entergy’s request for a Coastal Consistency Determination, an objection that could potentially hold up a new license. 
In the objection, Governor Andrew Cuomo, who has long called for the closure of Indian Point, highlighted many concerns about the facility, including the intake of 2.5 billion gallons of water per day for cooling, which kills aquatic life in the Hudson River; a history of operational accidents; the proximity of the plants to a heavily populated area; and the risk of catastrophic events due to flooding. 
While the NRC holds regulatory control over nuclear power plants, the State of New York permits the plant’s use of the river and can withhold or limit the permission to operate based on water quality concerns. 
The state’s position has been backed up by Riverkeeper. “We’re satisfied with the Department of State’s thorough evaluation of the impacts, and risks regarding Indian Point, and ultimate finding that a coastal consistency determination for the plant is simply inappropriate,” said Riverkeeper Staff Attorney Deborah Brancato. 
U.S. Congressman Sean Patrick Maloney (NY-18) also supported the New York Department of State’s assessment of the Indian Point Energy Center.
“This latest Indian Point assessment has shown yet again that this facility just doesn’t make sense for the community and the surrounding environment,” Maloney stated. “I appreciate the steps that the New York Department of State has taken to ensure the safety of folks living near Indian Point. It’s time we focus our efforts winding down Indian Point and get serious about replacing it with a source of energy production that will create and preserve jobs while reducing the risks to our neighbors and our wildlife.”

Monday, November 30, 2015

Junk Point Beach Unit One Plant (266,301)


Point Beach has had a lot of partial loops, transformer problems and switchyard troubles. 


Why did the "auxiliary feed water system actuated based on low steam generator level"? 
Power ReactorEvent Number: 51570
Facility: POINT BEACH
Region: 3 State: WI
Unit: [1] [ ] [ ]
RX Type: [1] W-2-LP,[2] W-2-LP
NRC Notified By: ALEX RIVAS
HQ OPS Officer: HOWIE CROUCH
Notification Date: 11/28/2015
Notification Time: 23:54 [ET]
Event Date: 11/28/2015
Event Time: 19:12 [CST]
Last Update Date: 11/29/2015
Emergency Class: NON EMERGENCY
10 CFR Section:
50.72(b)(2)(iv)(B) - RPS ACTUATION - CRITICAL
50.72(b)(3)(iv)(A) - VALID SPECIF SYS ACTUATION
Person (Organization):
MICHAEL KUNOWSKI (R3DO)

UnitSCRAM CodeRX CRITInitial PWRInitial RX ModeCurrent PWRCurrent RX Mode
1A/RY100Power Operation0Hot Standby
Event Text
AUTOMATIC REACTOR TRIP DUE TO GENERATOR LOCKOUT AFTER VOLTAGE REGULATOR MALFUNCTION

"Unit 1 automatic reactor trip actuated due to an automatic voltage regulator (AVR) malfunction which caused a generator lockout and turbine trip. The cause of the AVR malfunction is unknown at this time.

"All control rods fully inserted. The RCS is being cooled by forced flow (reactor coolant pumps). Secondary heat sink is being provided by the condenser steam dumps utilizing the main feed water system. The auxiliary feed water system actuated based on low steam generator level, but since has been secured. Off-site power remains available. No release is occurring and emergency core cooling systems did not actuate. Emergency plan entry was not required."

The plant is in its normal shutdown electrical lineup at normal operating temperature and pressure. Unit 2 was not affected by the Unit 1 transient.

The licensee has notified the NRC Resident Inspector

So already we are seeing Point Beach isn’t keeping components feeding the vessel in a reliable state and now really the operation's department is implicated in they didn’t get power down to below 50% (two half capacity condensate pumps). Actually sounds like a poorly designed condensate system without three half capacity condensate pumps?
  
Licensee Event Report 266/2015-002-00 Unit1 Manual Reactor Trip
On December 2, 2014, operators commenced a rapid power reduction of Unit 1 due to noted degradation of Unit 1 B Condensate Pump. At 2050 on December 2, 2014, with Unit 1 in Mode 1 at 62% power, operators initiated a manual reactor trip of Unit 1 following securing of the Unit 1 B Condensate Pump due to imminent failure. The Auxiliary Feedwater Pumps started as expected on low steam generator level experienced due to the reduced steam demand from the turbine trip in response to the reactor trip. All other plant systems functioned as required.

The degrading Condensate B pump and motor assembly required the immediate removal from service. A reduction in reactor power was necessary to support the continued operation, considering limitations of a single train of condensate and feedwater. At the time when the condensate pump assembly failure was imminent, the reactor power was not low enough to support removal of one of the two operating condensate pumps, which necessitated a manual reactor trip
.