My Thinking Notes
Title: 10 CFR 2.206 Petition RE
Pilgrim Nuclear Power Station
Docket Number: (n/)
Location: teleconference
Date: Thursday, April 11, 2013
Would you look over this Pilgrim 2.206 prehearing
transcript.
Upon first installation with the so caled new SRVs in 2011,
the first leak occurred within two weeks of first heat-up.
I have had a lot of experience with 2.206s. The routine of
the process changed without notifying me. The chairman was being rude to me and
unprofessional…I interpreted this behavior as intimidation and part of a
coverup. I clearly stated it in the meeting. Hope they saved the recording of
this? The tone of this was horrid.
Why wasn’t there a investigation over this 2.206 process
intimidation?
Why didn’t somebody in the meeting report that mike felt
intimidation in the proceeding? Why no transparent investigation of it?
There were some 15 to 20 officials listening in on the
bridge. Why didn’t somebody report that mike felt intimidation and a cover-up
here? A least a investigation to cover the NRC’s asses. Maybe if the OIG got
involved, ordered a huge special inspection in 2013…maybe the 2015 SRV blizzard
event wouldn’t have happened and Entergy would have made the rest of their bad
actor plants to straighten up.
My Pilgrim 2.206 date: March 7, 2013
ANO’s dropped stator: March 31, 2013
***I requested in the 2013 2.206 the Pilgrim SRV problem be
referred to the OIG. Was it referred to OIG? I considered the OIG a black box.
How was my OIG complaint dispositioned? I frequently get from the NRC
inspectors, “I’ll refer your complaint to the OIG”. I have no idea if the
resident sent the message to OIG, if the OIG dispositioned the complaint and
why was it rejected. Is the OIG living in Russia? Is the NRC residents lying to
me when they say they are sending my issue to the OIG, just to get me off their
backs? The agency and OIG treats us so disrespectfully.
Why didn’t higher officials not in the meeting sense there
was improprieties going with our problem “Mike” after reading the transcripts?
Why wasn’t this reported to the OIG?
If you think the system is straight, you would think, if all
the non public licensee reports about the magnitude of the leaks and poor
testing leading up to this transcript, the NRC would require Pilgrim to
shutdown and replace the SRVs. There was scant public reporting about the
malfunctioning srvs, the down powers and shutdown required to replace the
valves. The bureaucrats by this excessive secrecy are just protecting themselves
from accountability?
We felt as Vermont Yankee was wobbling towards permanent
shutdown, the NRC was giving Pilgrim special compensations outside the rules
and laws of the NRC. We felt the NRC was withholding inspection resources from
the Pilgrim in order to make their record look better than deserved? ANO and
Pilgrim were quickly going down the tubes during this period, why couldn’t this
all be prevented by the activities of the NRC and OIG.
Why didn’t the LER system and inspection report system work
during this? There was precious little reporting on the troubles of these valves
until the next big blizzard in 2015. There was a white finding in this. The
finding should have been much higher than it was. All valves should have been
inop since 2011 based on the quality of the valves was unknown. The backup
power line was unreliable too. It should have been at a much higher violation
level. To date, it has been reported as test stand damage to the valves. I got
from lead inspector with the upcoming inspection report that Entergy still
hasn’t done a root cause on the SRV failures.
Believe me, it is very painful for me to read my comments in
the transcripts. I have very poor verbal communication skills when I am nervous
and under pressure.
Why didn’t the 2013 blizzard 2.206 process work to prevent
the dysfunctions in the 2015 Blizzard? I am anticipatory, the NRC is
reactionary. Believe me on predicting the future, there is no evidence
available about future events. If you are excessively evidenced based, you can
never disrupt the upcoming accident.
In hindsight with all the information, all the licensee
corrective action and other internal reports, why couldn’t I make my case in
real time. Because I didn’t have all of the available evidence. The NRC needs
triplicate proof perfect evidence and never obtainable facts in order to get
enforcement action.
Do I just have a grudge with Entergy? A few years or months
prior to Pilgrim, I put a 2.206 on the Vermont Yankee SRV actuators. They put
in new SRVs just like Pilgrim did. Upon first leak rate testing with the new
SRV pneumatic actuators one failed. The actuator shaft buna seals got brittle
and leaked based on too much heat. Two of us put in 2.206s trying to figure out
what failed. Information was terribly sparse. As VY controversy pick up
steam and the politicians got involved, the NRC got sensitive to their
credibility. Many months later in an inspection report (and LER), the IR
disclosed VY put in inferior environmental grade SRVs in the plant. They needed
Type I SRVs, but there were no replacements available. The vendor talked them
into putting in type II SRVs. The heat damage these guys. I don’t think the NRC
gave permission via a public discloser it is ok to put information inferior
grade SRVs into the plant. Why didn’t the NRc demand a 50:59 to allow VY to put
inferior grade SRVs into the plant?
At this point, I felt the NRC lost control of enforcing
environmental and safety regulations on the SRVs. I feel it is happening all
over the industry. I feel 1000 times more sure it is still going on today. Any
third world reactor can run at 100%. It is much more difficult to align the
plant for the worst design event.
Pilgrim has the worst LOOP rate in the industry. The average
is about 2 LOOPS per lifetime. LOOP rates are calculated into all violations
and all sorts of other issues in the plant. The standard-generic rate for
safety analysis and violations is about 3.5 LOOPs per lifetime. Pilgrim’s LOOP
rate is beyond 21 LOOPs and we aren’t counting in the early years. Pilgrim’s is
seventeen times worst than the inputted into safety analysis rate. One wonders
why the real LOOP rate as penalty, isn’t inputted into all violations and
safety analysis?
The OIG by me and others think this branch of the NRC as
highly dysfunctional. We consider the OIG as a paper tiger. I had discussions
with a high OIG official concerning the OIG’s investigation on San Onofre
defective steam generator and the NRC response to this. He talked about the OIG
is severely hemmed in because the they can’t challenge any NRC’s staff
inspections and safety analysis. He talked about using tricky interview and
investigative techniques to write up the San Onofre. The OIG needs to gear up
with plant and oversight expertized to challenge any staff evaluation or
activity at any plant. We think this OIG restriction comes from the utilities
big bucks through the politicians influence over the NRC, limiting the
capabilities of the OIG.
Loops and paper tiger OIG
My Pilgrim 2013 2.206
March 7, 2013
Bill Borchardt
Executive Director for Operations
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
Dear Mr. Bochardt,
Request an emergency and for a exigent bases, that the
Pilgrim Nuclear plant be immediately shut down.
Don't tell me just before the Nor'easter Nimo struck the
Pilgrim plant with a leaking safety relief valve and down at 80%, Entergy was
intending to operate that plant with a defective leaking safety relief valve
till the next refuel outage? Tell it ain't so. It certainly looks like with the
current leak today that is intending to operate till next month.
Is the game plan today to incrementally increase reactor
power from 94% by 1% to see if a new SRV leak is getting worse?
Timeline:
1) New three stage safety relief valves installed in the
plant around May 2011.
2) First leak and shut down on Dec, 26. 2011 (SRV
RV-203-3D).
3) Second leak and shut down on Jan 20, 2013 (SRV
RV-203-3B).
4) Third leak occurred a few weeks later and the plant
was at a restricted to 84% power...the Nemo blizzard Feb 9, 2013
tripped the plant. The NRC promised these valves are fixed before startup. (SRV
RV-203-3B).
5) Basically, they operated for 20 days at 100% power
operation post shutdown, then reported on Feb 27 the plant is operating at 94%
power with no explained reason until today. The reason for the down power was
kept secret from the public.
6) Today March 7, 2013 I called the NRC's public
relation people and the agency told me they had indications of a leak
and that is why the plant is at a restricted power level.
Don't forget the repetitive nature of the recently broken
scram discharge volume vent and drain valves...implies Entergy is incapable of
maintaining safety components of a nuclear plant.
The repeated nature of the failure of the safety relief
valves means Entergy doesn't know the mechanism of the failure...it is a common
mode failure. The design and manufacture of these valves are defective and it
is extremely unsafe to operate a nuclear plant with all safety relief valves
being INOP. A condition adverse to quality...
The NRC should have made a public comment about the new
leaking safety relief when they first became aware of th leak. The implication
is the agency was going to allow the plant to operate with unsafe SRVs until
the refueling outage next month. The NRC is involved in a serious cover-up of
an extremely unsafe operation of a nuclear power.
1) Request an immediate shutdown the Pilgrim Plant.
2) The is the second time I requested a special NRC
inspection concerning the defective SRV valves.
3) Not allow the plant to restart Pilgrim until they fully
understand the past failure mechanisms of the four bad new three stage safety
relief valves.
(April 18 2017-again below, I request the paperwork trail
with how this got to the OIG and its disposition of my request)
4) Request the OIG investigate this NRC cover-up to keep an
unsafe nuclear plant at power.